ML15012A143

Transmittal of Radiation Emergency Plan Revision 64

ML15012A143
Person / Time
Site:	Summer
Issue date:	01/07/2015
From:	Thompson B South Carolina Electric & Gas Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
FOIA/PA-2015-0025
Download: ML15012A143 (208)

Text

Bruce L. Thompson Manager,NuclearLicensing 803.931.5042 A SCANA COMPANY January 7, 2015 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001

Subject:

VIRGIL C. SUMMER NUCLEAR STATION UNIT 1 DOCKET NO. 50-395 OPERATING LICENSE NO. NPF-12 TRANSMITTAL OF RADIATION EMERGENCY PLAN REVISION 64 In compliance with 10 CFR 50.54(q), South Carolina Electric & Gas Company, acting for itself and as agent for South Carolina Public Service Authority, submits one controlled copy of Revision 64 to the Radiation Emergency Plan.

The changes in Revision 64 were reviewed in accordance with 10 CFR 50.54(q) and were found not to decrease the effectiveness of the Radiation Emergency Plan. The 50.54(q) evaluation is attached.

Should you have any questions, please contact Ms. Tammy Price at (803) 345-4176.

Very truly yours, Bruce L.

TJP/BLT/rp Attachments c: Victor M. McCree (With Attachments 2021 and 202J) c: (Without Attachments) W. M. Cherry K. B. Marsh S. A. Williams S. A. Byrne NRC Resident Inspector J. B. Archie K. M. Sutton N. S. Cams RTS (LTD 245)

J. H. Hamilton File (810.10-1, RR 6100)

J. W. Williams PRSF (RC-14-0208)

VirgilC. Summer Station

• Post Office Box 88. Jenkinsville, SC. 29065 F (803) 941-9776

SOUTH CAROLINA ELECTRIC & GAS COMPANY VIRGIL C. SUMMER NUCLEAR STATION NUCLEAR OPERATIONS NUCLEAR OPERATIONS CONTROLLED COPY COPY NO. ;z+/-L RADIATION EMERGENCY PLAN EP-100 REVISION 64 SAFETY RELATED

Table of Contents V. C. Summer Nuclear Station Part 1: Introduction .................................................................................................................. 1 Section A: Purpose ...................................................................................................... I Section B: Background ............................................................................................... 2 Facility D escription ................................................................................................... .. 2 Em ergency Planning Zone .......................................................................................... 2 Section C : Scope ........................................................................................................ 3 Section D: Planning Basis .......................................................................................... 4 Section E: Contiguous-Jurisdiction Emergency Planning ...................................... 4 Section F: Integrated Guidance and Criteria ............................................................. 4 Section G: Funding and Technical Assistance ........................................................ 4 Section H: Emergency Response Organization ........................................................ 4 Section I: Federal Response ................................................................................... 5 Section J: Form and Content of Plan ........................................................................ 5 Figure 1-1: General Location of the Site and Surrounding Area .......................... 6 Figure 1-2: V. C. Summer Site Layout ........................................................................ 7 Figure 1-3: 10-Mile Emergency Planning Zone (Exposure Pathway) ......................... 8 Figure 1-4: 50-Mile Emergency Planning Zone (Ingestion Pathway) ........................... 9 Part 2: Planning Standards and Criteria ........................................................................... 10 Section A: Assignment of Responsibility ............................................................... 10

1. C oncept of O perations ................................................................................... 10

2. State and County Functions and Responsibilities .......................................... 16

3. Agreements in Planning Effort ...................................................................... 16

4. C ontinuous C overage ................................................................................... 16 Figure A-i: Agency Response Organization Interrelationships ............................... 17 Figure A-2: VCSNS Augmented Emergency Response Organization Interrelationships18 Section B: Emergency Response Organization ..................................................... 19

1. On-Shift Emergency Response Organization Assignments ........................... 19

2. Authority over the Emergency Response Organization ................................. 21

3. Criteria for Assuming Command and Control (Succession) ........................... 22

4. Non-D elegable D uties .................................................................................... 22

5. Emergency Response Organization Position Responsibilities ....................... 23

6. Emergency Response Organization Block Diagram ...................................... 29

7. Industry/Private Support Organizations ........................................................ 29 Figure B-la: Overall ERO Command Structure ........................................................ 32 Figure B-lb: Onsite Emergency Response Organization ........................................ 33 Figure B-Ic: Offsite Emergency Response Organization .......................................... 34 Figure B-id: Emergency Public Information Organization ........................................ 35 Table B-ia: Staffing Requirements for the VCSNS ERO .......................................... 36 ii Rev 64

Table of Contents V. C. Summer Nuclear Station Section C: Emergency Response Support and Resources ................................... 39

1. Federal Response Support and Resources .................................................... 39

2. Lia iso ns ...................................................................................................... . . 40

3. Radiological Laboratories ............................................................................. 40

4. Other Assistance ........................................................................................... 40 Section D: Emergency Classification System ........................................................ 41

1. Emergency Classification System ................................................................. 41

2. Emergency Action Level Technical Basis ...................................................... 46

3. Offsite Classification Systems ...................................................................... 46

4. Offsite Emergency Procedures ..................................................................... 46 Section E: Notification Methods and Procedures ................................................. 47

1. Bases for Emergency Response Organization Notification ........................... 47

2. Notification and Mobilization of Emergency Response Personnel ................. 47

3. Initial Notification Messages ........................................................................... 49

4. Follow-Up Messages ..................................................................................... 50

5. State and County Information Dissemination ................................................. 50

6. Notification of the Public ............................................................................... 50

7. Messages to the Public ................................................................................. 51 Section F: Emergency Com m unications ................................................................. 52

1. Communications/Notifications ........................................................................ 52

2. Medical Communications ............................................................................... 55

3. Communications Testing ............................................................................... 55

4. Plant Alarms ................................................................................................. 55 Figure F-i: Notification Scheme (After Full Augmentation) ...................................... 56 Figure F-2: ERF Communications Matrix .................................................................. 57 Figure F-3: NRC Communications for Nuclear Response ......................................... 58 Section G: Public Education and Information ......................................................... 59

1. Public Information Publication ........................................................................ 59

2. Public Education Materials ............................................................................. 59

3. Media Accommodations ............................................................................... 60

4. Coordination of Public Information ................................................................. 61

5. Media Orientation ........................................................................................ 61 Section H: Emergency Facilities and Equipment .................................................... 62

1. Control Room, Technical Support Center, and Operational Support Center ....... 62

2. Emergency Operations Facility ...................................................................... 65

3. Joint Information Center ............................................................................... 66

4. Emergency Operations Centers .................................................................... 66

5. Activation ..................................................................................................... 66

6. Monitoring Equipment Onsite ........................................................................ 68

7. Monitoring Equipment Offsite ........................................................................ 70 iii Rev 64

Table of Contents V. C. Summer Nuclear Station

8. Offsite Monitoring Equipment Storage ........................................................... 71

9. Meteorological Monitoring ............................................................................. 72

10. OSC Capabilities ........................................................................................... 72

11. Facility and Equipment Readiness ................................................................. 72

12. Emergency Equipment and Supplies ............................................................ 73

13. General Use Emergency Equipment ............................................................. 74

14. Collection Point for Field Samples ................................................................. 74 Section 1: Accident Assessment ............................................................................. 75

1. Plant Parameters and Corresponding Emergency Classification ................... 75

2. Onsite Accident Assessment Capabilities ...................................................... 75

3. Source Term Determination .......................................................................... 75

4. Effluent Monitor Data and Dose Projection ................................................... 77

5. Meteorological Information ............................................................................. 78

6. Unmonitored Release ................................................................................... 78

7. Field Monitoring ............................................................................................ 78

8. Field Teams ................................................................................................... 79

9. Iodine Monitoring .......................................................................................... 79

10. Dose Estimates ............................................................................................. 79

11. State Monitoring Capabilities ........................................................................ 79 Section J: Protective Response ............................................................................... 80

1. Notification of Onsite Personnel ................................................................... 80

2. Evacuation Locations .................................................................................... 80

3. Radiological Monitoring of Evacuees ............................................................ 80

4. Protective Actions for Onsite Personnel ........................................................ 81

5. Accountability ............................................................................................... 82

6. Provisions for Onsite Personnel ................................................................... 82

7. Mechanism for Implementing Protective Action Recommendations .............. 83

8. Evacuation Time Estimate ............................................................................ 83

9. Capability of Implementing Protective Action Recommendations .................. 83

10. Implementation of Protective Action Recommendations ................................ 84

11. Ingestion Pathway Protective Measures ........................................................ 85

12. Monitoring of Evacuees .................................................................................. 85 Figure J-1: Sector Population Distribution ............................................................... 86 Figure J-2: PAR Flowchart ...................................................................................... 87 Section K: Radiological Exposure Control ............................................................ 89

1. Emergency Exposure Guidelines ................................................................. 89

2. Emergency Radiation Protection Program ................................................... 89

3. Personnel Monitoring ................................................................................... 90

4. Non-V. C. Summer Personnel Exposure Authorization ................................. 90

5. Contamination and Decontamination ............................................................ 91

6. Contamination Control Measures .................................................................. 91 iv Rev 64

Table of Contents V. C. Summer Nuclear Station

7. Decontamination of Relocated Personnel ..................................................... 92 Section L: Medical and Public Health Support ...................................................... 93

1. Offsite Hospital and Medical Service Facilities ............................................... 93

2. Onsite First Aid Capability ............................................................................. 93

3. Medical Transportation .................................................................................. 95 Section M: Reentry and Recovery Planning ............................................................. 96

1. Reentry and Recovery ................................................................................... 96

2. Recovery Organization .................................................................................. 99

3. Recovery Phase Notifications .......................................................................... 102

4. Total Population Exposure ............................................................................... 102 Section N: Drill and Exercise Program ....................................................................... 103

1. E xe rc ise s ......................................................................................................... 10 3

2. D rills ................................................................................................................. 10 5

3. Conduct of Drills and Exercises ....................................................................... 106

4. Critique and Evaluation .................................................................................... 107

5. Resolution of Drill and Exercise Findings ......................................................... 107 Section 0: Emergency Response Training ................................................................ 108

1. Assurance of Training ...................................................................................... 108

2. Functional Training of the ERO ........................................................................ 109

3. First Aid Response ........................................................................................... 109

4. Emergency Response Organization Training Program .................................... 109

5. General, Initial, and Annual Training Program Maintenance ............................ 114 Section P: Responsibility for the Maintenance of the Planning Effort ..................... 116

1. Emergency Preparedness Staff Training .......................................................... 116

2. Authority for the Emergency Preparedness Effort ............................................ 116

3. Responsibility for Development and Maintenance of the Plan .......................... 116

4. Emergency Plan and Agreement Revisions ..................................................... 120

5. Emergency Plan Distribution ............................................................................ 120

6. Supporting Emergency Response Plans .......................................................... 121

7. Implementing and Supporting Procedures ....................................................... 121

8. Cross-Reference to Planning Criteria ........................................................... 121

9. Audit/Assessment of the Emergency Preparedness Program .......................... 122

10. Maintenance of Emergency Telephone Numbers ............................................. 122 Annex 1: Unit 1 ..................................................................................................................... 123 Section 1: Introduction ............................................................................................... 123 1.1 Unit 1 D e scriptio n ............................................................................................. 12 3 Figure A1-1: Unit 1 Facility Layout (specimen) ....................................................... 124 Section 2: Organizational Control of Emergencies .................................................. 125 2.1 Emergency Response Organization On-Shift Positional Responsibilities ......... 126 V Rev 64

Table of Contents V. C. Summer Nuclear Station Table 2-1: V. C. Summer On-Shift Staffing and ERO Positions .................................. 126 2.2 Normal Shift Staffing ........................................................................................ 127 2.3 Shift Emergency Response Positional Responsibilities .................................... 127 Section 3: Classification of Emergencies .................................................................. 128 Section 4: Emergency Facilities and Equipment ...................................................... 129 4.1 Unit-Specific Emergency Facilities ................................................................... 129 4.2 Assessment Resources ................................................................................... 131 Table 4-1: Radiation Monitoring System Description .................................................. 132 Section 5: Emergency Measures ............................................................................... 137 5.1 Unit Protective Actions ..................................................................................... 137 5.2 Unit Assembly Areas ........................................................................................ 137 5.3 Unit Evacuation Routes .................................................................................... 138 Appendix I - References ...................................................................................................... 139 Appendix 2 - Letters of Agreement ...................................................................................... 140 Appendix 3 - List of Emergency Plan Procedures ............................................................. 141 Appendix 4 - Abbreviations, Acronyms and Definitions .................................................... 143 Appendix 5 - Evacuation Time Estimate Study ................................................................... 151 Appendix 6 - Regulatory Requirements Cross Reference Document ............................... 152 Table 1 - 10 CFR 50 Appendix E - Emergency Planning and Preparedness for Production and Utilization Facilities .................................................................. 153 Table 2 - 10 CFR 50.47 Emergency Plans ................................................................ 161 Table 3 - NUREG-0654 Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power P la nts ............................................................................................................... 16 4 Appendix 7 - On-shift Staffing Analysis ............................................................................. 192 Appendix 8 - Alert And Notification System Design Report .............................................. 193 vi Rev 64

Part 1: Introduction V. C. Summer Nuclear Station Part 1: Introduction Section A: Purpose As required in the conditions set forth by the Nuclear Regulatory Commission (NRC) for the operating licenses for the Virgil C. Summer Nuclear Station (VCSNS) Unit 1, the management of South Carolina Electric & Gas Company (SCE&G) recognizes its responsibility and authority to operate and maintain the nuclear power station in such a manner as to provide for the safety of the general public. This document describes the VCSNS Radiation Emergency Plan Program. The philosophy that guides the development and maintenance of this program is the protection of the health and safety of the general public in the communities around the nuclear power station and the personnel who work at the plant.

This Radiation Emergency Plan (Emergency Plan) establishes the concepts, evaluation and assessment criteria, and protective actions that are necessary in order to limit and mitigate the consequences of potential or actual radiological emergencies. It has been prepared to establish the procedures and practices for management control over unplanned or emergency events that may occur at VCSNS. It also provides the necessary prearrangements, directions, and organization so that all nuclear emergencies can be effectively and efficiently resolved.

The VCSNS Emergency Preparedness Program consists of the Emergency Plan, Unit 1 Annex, Emergency Plan Implementing Procedures (EPIPs), and associated program administrative documents. The VCSNS Emergency Plan outlines the basis for response actions that would be implemented in an emergency. This document is not intended to be used as a procedure.

The Unit 1 Annex is a part of the Emergency Plan and is subject to the same review and audit requirements as the Emergency Plan. In the areas where the Unit 1 Annex deviates from the general requirements of the Emergency Plan, the Unit 1 Annex shall serve as the controlling document.

The information that is in the Plan need not be restated in the Unit 1 Annex.

Annex Format and Specific Content: As a minimum, the Unit 1 Annex shall address the areas described as follows:

Section 1: Introduction The unit description is provided along with the inclusion of maps, drawings, and/or diagrams. It describes the specifics of each unit and its location. A summary statement describes the Annex's interface with the Emergency Plan.

Section 2: Organizational Control of Emergencies Unit-specific on-shift staffing is outlined in the Unit 1 Annex to the Emergency Plan. The on-call Emergency Response Organization (ERO) positions are outlined in Section B of the Emergency Plan.

Section 3: Classification of Emergencies Emergency Action Levels (EALs) are included for all emergency classes for the purpose of event classification in EPP-001, Activation and Implementation of Emergency Plan.

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Part 1: Introduction V. C. Summer Nuclear Station Section 4: Emergency Facilities and Equipment A description of unit-specific facilities and equipment available for use during an emergency response or to support the remainder of the site is included in the Unit 1 Annex.

Section 5: Emergency Measures A description of unit-specific personnel protective actions, assembly areas, and evacuation routes are discussed.

Detailed EPIPs are maintained separately and are used to guide those responsible for implementing emergency response actions.

Section B: Background Facility Description The VCSNS site is on the east side of the Broad River in western Fairfield County. The Unit 1 power block area (generating facilities and switchyard) is on the south shore of the Monticello Reservoir. An exclusion area, defined as the area within approximately 1 mile of Unit 1, is posted and access to land portions of this area is controlled. The Exclusion Area Boundary (EAB) encompasses approximately 2,200 acres. It includes the southern portion of the Monticello Reservoir and parts of the Fairfield Pumped Storage Facility.

The largest industrial center nearest to the site is Columbia, which is approximately 26 miles southeast of the site. The nearest community is Jenkinsville, approximately three miles southeast of the site. The closest primary public road is SC 215 which lies approximately 6,800 feet east of the Unit 1 reactor building centerline and is outside the exclusion area. Highway access to the station is via SC 215 from Columbia or by Interstate 26 to US 176, and then to SC 213 and SC 215.

Figure 1-1 shows the general location of VCSNS.

Figure 1-2 shows the Exclusion Area Boundary for Unit 1.

Within the EAB, ownership is divided between SCE&G and Santee Cooper. Pursuant to the VCSNS owner's agreement authorizing the development, construction, licensing, and operation of generating units, SCE&G, for itself and as agent for the co-owner, retains complete authority to regulate any and all access and activity within the entire exclusion area.

Emergency Planning Zone The plume exposure Emergency Planning Zone (EPZ) for the VCSNS is an area surrounding the VCSNS site with Unit 1 at the center and having a radius of about ten (10) miles. Principal exposure sources from the plume exposure pathway are (a) external exposure to gamma and beta radiation from the plume and from deposition materials and (b) exposure of the internal organs to gamma and beta radiation from inhaled radioactive gases and/or radioactive particles.

The time of potential exposure can range from hours to days. (Exact boundaries are determined in concurrence with state and county authorities). Figure 1-3 shows the plume exposure EPZ.

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Part 1: Introduction V. C. Summer Nuclear Station The Ingestion Pathway Zone (IPZ) is an area surrounding the station with Unit 1 as the center and having a radius of about fifty (50) miles. The primary exposure source from the ingestion exposure pathway is the ingestion of contaminated fresh vegetables and milk. The time of potential exposure can range from hours to months. Figure 1-4 shows the Ingestion Pathway EPZ.

In the context of this Emergency Plan, including the Unit 1 Annex and Emergency Plan Procedures (EPP), SCE&G manages the operations of the VCSNS.

The primary hazard consideration at the nuclear power station is the potential unplanned release of radioactive material resulting from an accident. The probability of such a release is considered very low due to the design of the unit and strict operational guidelines enforced by the NRC. Notwithstanding, federal regulations require that a solid Emergency Preparedness Program exist for each commercial nuclear power station. A detailed description of the station is provided in the unit's Final Safety Analysis Report (FSAR).

To minimize the number of ad hoc decisions made during an emergency and to ensure that necessary equipment, supplies, and essential services are available to meet the needs of an emergency, SCE&G has developed this Emergency Plan. This Emergency Plan is applicable to VCSNS and considers the consequences of radiological emergencies, as required by 10 CFR 50.47 and 10 CFR 50 Appendix E.

In addition, this plan addresses guidance and adheres to the intent of the criteria established and provided within NUREG-0654/FEMA-REP-1 Rev. 1 (NUREG-0654), which is a joint NRC and Federal Emergency Management Agency (FEMA) document. Regulatory Guide 1.101, "Emergency Planning and Preparedness for Nuclear Power Reactors," endorses the criteria and recommendations in NUREG-0654, as methods acceptable to the NRC staff for complying with the standards in 10 CFR 50.47.

The Emergency Plan also considers the consequences of nonradiological emergencies.

Section C: Scope This document describes actions to be taken in the event of a radiological accident at the VCSNS that may impact the health and safety of the general public or station employees. It also serves to limit the damage to facilities and property, and provides for the restoration of such facilities in the event of an emergency. If such an accident were to occur, the ERO would be put in place and maintained until such time when the plant is returned to a stable condition and the threat to the general public or station personnel no longer exists. This plan describes the functions and operation of the ERO, including assignments of authority and responsibility. It does not, nor is it intended to, provide guidance for actual plant equipment manipulations. These instructions are contained in site-specific normal and Emergency Operating Procedures (EOP) as required by Technical Specifications and other regulatory guidance. The Emergency Plan provides for: identification and evaluation of emergency situations, protective measures, communications, coordination and notification of governmental authorities, document review and control, emergency preparedness assessment, and training of all emergency response personnel.

A method for recovering from a declared emergency is also described in this plan.

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Part 1: Introduction V. C. Summer Nuclear Station Section D: Planning Basis The Emergency Plan, in conjunction with the Unit 1 Annex and the emergency plan procedures and administrative procedures, documents the methods by which the VCSNS Emergency Preparedness Program meets the planning standards set forth in 10 CFR 50.47(b) and the requirements of 10 CFR 50 Appendix E. Development of the Emergency Plan was based on NUREG-0654.

Acceptable alternate methods, which deviate from NUREG-0654, are allowed under Regulatory Guide 1.101, "Emergency Planning and Preparedness for Nuclear Power Reactors." However, any and all deviations will be documented in the Unit 1 Annex and evaluated as continuing to meet the Planning Standards of 10 CFR 50.47(b) and 10 CFR 50 Appendix E under the 10 CFR 50.54(q) process. This evaluation process is employed to ensure the continued effectiveness of the Emergency Plan and Unit 1 Annex.

Other applicable regulations, publications, and guidance were used (see Appendix 1, "References") along with site-specific documents to ensure consistency in the planning effort.

Section E: Contiguous-Jurisdiction Emergency Planning The Emergency Plan recognizes the state of South Carolina, in cooperation with the EPZ counties, as the overall authority responsible for Protective Action Directives (PADs) in order to protect the health and safety of the general public.

Section F: Integrated Guidance and Criteria This plan was developed in conjunction with federal, state, and county emergency response plans to ensure a consistent and integrated response to a classified event.

Section G: Funding and Technical Assistance SCE&G is dedicated to providing the level of support necessary, as dictated by federal regulation, to ensure appropriate integration of the state, county, and VCSNS radiological emergency preparedness programs.

Section H: Emergency Response Organization SCE&G acknowledges its primary responsibility for planning and implementing emergency measures within the EAB and for overall plant accident assessment. These emergency measures include corrective actions, protective measures, and aid for personnel onsite. To accomplish these responsibilities, SCE&G has established an augmented ERO that will be mobilized to provide the initial response to an event classified as an Alert, Site Area Emergency, or General Emergency. The ERO may be partially or fully activated during an Unusual Event, if the Interim Emergency Director (lED) determines their assistance is needed to mitigate the event. In addition, advance arrangements have been made with offsite organizations for special emergency assistance such as ambulance, medical, hospital, fire, and police services.

In the longer time frame, a framework for a Recovery Organization is set forth in this plan. It is recognized that the normal station organization will be used for much of the recovery effort, with additional resources identified at the time of the event.

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Part 1: Introduction V. C. Summer Nuclear Station Section I: Federal Response Provisions are made within the Emergency Plan for the integration of appropriate elements of federal assistance activities. Arrangements have been made to accommodate a federal response organization presence in the VCSNS emergency response facilities as well as support communications between VCSNS and federal emergency facilities.

Section J: Form and Content of Plan In accordance with regulatory guidance provided in NUREG-0800, the Emergency Plan is referenced in Chapter 13 of the VCS FSAR. The Emergency Plan is administratively maintained as a separate document.

Appendix 3, List of Emergency Plan Procedures, provides a subject matter cross-reference between the NUREG-0654 evaluation criteria and the EPIPs and applicable administrative documents. Appendix 6 is a specific requirements cross-reference between the Emergency Plan and 10CFR50 Appendix E, 10CFR50.47, NUREG-0654.

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Part 1: Introduction V. C. Summer Nuclear Station Figure 1-1: General Location of the Site and Surrounding Area Page 6 of 193 EP-100 Rev 64

Part 1: Introduction V. C. Summer Nuclear Station

~1 Figure 1-2: V. C. Summer Site Layout Page 7 of 193 EP-100 Rev 64

Part 1: Introduction V. C. Summer Nuclear Station Figure 1-3: 10-Mile Emergency Planning Zone (Exposure Pathway)

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Part 1: Introduction V. C. Summer Nuclear Station Figure 1-4: 50-Mile Emergency Planning Zone (Ingestion Pathway)

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Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station Part 2: Planning Standards and Criteria Section A: Assignment of Responsibility This section describes the primary responsibilities and organizational control of SCE&G, federal, state, county, and other EROs within the plume exposure pathway and the ingestion pathway EPZs. Various supporting organizations are also described as well as staffing for initial and continuous response.

1. Concept of Operations The relationships and the concept of operations for the organizations and agencies that are a part of the overall ERO are as follows:

a. Identified below are federal, state, and county organizations (and other local governmental agencies) that are involved in a response to an emergency at VCSNS (Figure A-i).

1) Federal Agencies: The National Response Framework (NRF) outlines federal statutory and regulatory responsibilities during incidents requiring a coordinated federal response. The primary federal response for supporting an emergency at VCSNS includes:

a) Nuclear Regulatory Commission (NRC): The NRC Regional Office has the responsibility for the auditing of nuclear power stations. It is responsible for ensuring that such activities are conducted in accordance with the terms and conditions of such NRC licenses and that as a result of such operations, there is no undue risk to the health and safety of the public.

The NRC Office of Nuclear Reactor Regulation, established by the Energy Reorganization Act of 1974, as amended, performs licensing functions associated with the construction and operation of nuclear reactors and with the receipt, possession, ownership, and use of special nuclear and byproduct materials used at reactor facilities.

With regard to emergency preparedness, the NRC shall:

• Assess licensee emergency plans for adequacy.

" Review the FEMA findings and determinations on the adequacy and capability of implementation of state and local plans.

• Make decisions with regard to the overall state of emergency preparedness and issuance of operating licenses.

The NRC shall respond to incidents at licensed facilities or vehicular accidents involving licensed materials, in transit. Within the sphere of the NRF, the NRC shall act as a Coordinating Agency. Inthis role the NRC:

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Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station

• Performs an independent assessment of the incident and potential offsite consequences and, as appropriate, provides recommendations concerning any protective measures.

" Performs oversight of the licensee, to include monitoring, evaluation of protective action recommendations (PARs), advice, assistance, and, as appropriate, direction.

" Dispatches, when appropriate, an NRC site team of technical experts to the licensee's facility.

Under certain situations involving the protection of public health/safety or national security, the NRC may take possession of special nuclear materials and/or operate certain facilities regulated by the NRC. FEMA shall act as the lead federal agency for offsite, nontechnical concerns.

During an incident, the Chairman of the Commission is the senior NRC authority for all aspects of a response. The Chairman shall transfer control of emergency response activities to the Director of Site Operations when deemed appropriate by the Chairman.

All NRC Regions as well as Headquarters are prepared to respond to potential emergencies. All Regions and Headquarters have developed plans and procedures for responding to radiological incidents involving NRC licensees.

Headquarters has developed the NRC Incident Response Plans and Implementing Procedures. Each NRC Region has developed Regional Supplements that detail how the Region will fulfill all of the responsibilities assigned in the NRC Incident Response Plan. All NRC organizations are responsible for maintaining an effective state of preparedness through periodic training, drills, and exercises.

Each Region and Headquarters has established and maintains an Incident Response Center designed to centralize and coordinate the emergency response function. Adequate communications are established to link the licensee, Headquarters, and the Region. The NRC has established lines of communications with local government, state government, other federal agencies, Congress and the White House. Public information will be disseminated in a timely manner and periodically.

Each Region is prepared to send a team of qualified specialists to the scene expeditiously. All of the necessary supplies and equipment needed for emergency response will be provided and maintained by the NRC.

The NRC Incident Response Plan objectives are to provide for protection of the public health and safety, property, and the environment, from the effects of radiological incidents that may occur at licensed facilities or which involve licensed materials, including radionuclides in transit.

The objectives of the agency plan set forth the organizational and management concepts and responsibilities needed to ensure that NRC has an effective emergency response program.

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Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station The NRC Incident Response Plan is intended to ensure NRC preparedness:

• To receive and evaluate notification information of incidents, accidents, and unusual events and determine the extent of NRC response necessary to meet NRC responsibilities for mitigating the consequences of these events.

" To determine the cause of incidents, accidents, and unusual events in order to ensure that appropriate corrective actions are taken by the licensee to minimize the consequences of these events.

" To provide onsite expertise in a timely manner, to evaluate the nature and extent of the incident, ascertain plant status (for reactors and fuel facilities),

monitor licensee activities, determine compliance, make recommendations, and, if necessary, issue orders relative to the event.

• To inform the public and others of plant status and technical details concerning the incident.

" To recommend adequate protective actions to the responsible local and/or state agencies.

" To provide technical assistance.

" To ensure the plant is returned to a safe condition.

• To return the NRC Headquarters and Regional office to normal operations.

b) Federal Emerqency Managqement Agency (FEMA): Per the NRF, FEMA, a division of the Department of Homeland Security (DHS) is responsible for the overall coordination of a multiagency federal response to a significant radiological incident. The primary role of FEMA is to support the state by coordinating the delivery of federal nontechnical assistance. FEMA coordinates state requests for federal assistance, identifying which federal agency can best address specific needs. If deemed necessary by FEMA, it will establish a Homeland Security Operations Center (HSOC) from which it will manage its assistance activities.

c) U.S. Department of Energy (DOE): The DOE has extensive radiological monitoring equipment and personnel resources that it can assemble and dispatch to the scene of a radiological incident. The DOE local operations office at Savannah River Site can assist VCSNS following a radiological incident as outlined in the Federal Radiological Monitoring and Assessment Plan (FRMAP). If VCSNS or the affected states deem that assistance from DOE is necessary or desirable, they will request that assistance using the proper channels. VCSNS will contact the U.S. NRC Headquarters and the affected state(s) will make contact through DHS.

d) Environmental Protection Agency (EPA): Assists with field radiological monitoring/sampling and non-plant related recovery and reentry guidance.

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Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station e) 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 provisions of the VCSNS Security Plan, or by the NRC.

f) National Weather Service (NWS): Provides meteorological information during emergency situations, if required. Data available will include existing and forecasted wind directions, wind speed, and ambient air temperature.

2) State Agencies a) The State of South Carolina: The state of South Carolina has the statutory responsibility and authority for protecting the health and safety of the public in South Carolina. The state has developed a "South Carolina Operational Radiological Emergency Response Plan." This plan was developed in accordance with NUREG 0654. The Plan has received 44 CFR 350 unconditional approvals from DHS for all nuclear generating station(s) within the state boundaries. Basic descriptions for the South Carolina state agencies responsible for actions in the event of a nuclear power station are as follows:

• Governor of South Carolina: The governor of the state has overall command authority for both the radiological and nonradiological aspects of a nuclear incident. The governor shall make the final recommendation for protective actions and shall serve as the state's primary spokesperson.

• South Carolina Emergency Management Division (SCEMD): Coordinates the operational response and recovery functions of all state agencies. The SCEMD proposes PARs to the governor. It also coordinates the implementation of the governor's Protective Action Directives (PAD).

The SCEMD response action to a nuclear incident will fall into one of the following functional areas:

- Command for all (state-related) radiological aspects of a nuclear incident.

- Field radiological functions (state-related) of confirmatory accident assessments during a nuclear emergency. This may include a Mobile Command Center, a Mobile Nuclear Laboratory, and monitoring and sampling teams.

The SCEMD has the responsibility to inform and coordinate technical information with the North Carolina Emergency Management Agencies with respect to an emergency that impacts the 50-mile ingestion pathway zone.

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Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station The SCEMD has both the command authority for radiological aspects of a nuclear incident and the responsibility for performing various radiological functions. These functions include milk, water and food control, radiation exposure control for state emergency workers, and confirmatory accident assessment. During an emergency situation, the emergency management agencies shall make PARs to the governor. It also coordinates the implementation of the governor's Protective Action Directives (PADs).

" Department of Health and Environmental Control (DHEC): DHEC maintains a radiological hazard assessment capability and provides radiological technical support, coordination and guidance for the state and local governments; conducts and/or coordinates offsite radiological surveillance and monitoring in coordination with the VCSNS offsite environmental monitoring group; and makes recommendations to SCEMD for protective actions as well as recovery and reentry guidelines.

• South Carolina Law Enforcement Division (SLED): SLED provides support during security related events at the station.

• The South Carolina Department of Natural Resources (SCDNR): The SCDNR patrols and ensures the safety of waterways in South Carolina. The SCDNR is promptly notified of any oil or hazardous substance discharges into rivers or lakes or radioactive contamination of rivers or lakes under its jurisdiction at levels requiring assistance to effect protective actions. The SCDNR is contacted by the appropriate state agencies in the event of an incident at an applicable nuclear power plant. The United States Coast Guard (USCG) is responsible for officially closing the waterways to all boating traffic.

b) The State of North Carolina: A portion of the 50-mile ingestion pathway EPZ for VCSNS lies within the state of North Carolina. The state of North Carolina has developed a Radiological Emergency Response Plan to respond to commercial nuclear power stations within the state of North Carolina and for those nuclear stations outside of the state that are within 50 miles of North Carolina.

3) County Government Agencies VCSNS and the surrounding counties of Fairfield, Newberry, Lexington, and Richland that comprise the plume exposure pathway EPZ have developed integrated emergency response programs that call upon the resources of their county. The county organizations are responsible for implementing and coordinating the county response to an emergency.

Each of the county Emergency Operations Centers (EOCs) serve as the primary coordinating center for local government response within the county's jurisdiction and for coordination between counties.

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Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station

4) Private Agencies There are various private agencies that VCSNS has acquired Letters of Agreement regarding support during an emergency. These agencies have agreed to provide firefighting, medical, resource, and lodging support as needed during an emergency.

These Letters of Agreement are listed in Appendix 2 and are reviewed and updated as necessary.

b. During an emergency condition classified as an Alert, Site Area Emergency, or General Emergency, the station's augmented ERO is notified and responds to augment the normal plant organization under the direction of the lED.

The augmented ERO consists of three major response suborganizations with inter-relationships as illustrated in Figure A-2:

1) The Onsite ERO, directed by the Emergency Director (ED), provides for:

• Control and operation of the plant.

" Mitigation of the emergency condition.

• Protection of station personnel inside the Protected Area.

• Emergency support for Operations, Engineering, Maintenance, Firefighting, Security, and first aid.

The onsite ERO is made up primarily of personnel from the station's day-to-day management team, Operations, Health Physics, Chemistry, Engineering, Maintenance, Security, and other site support personnel.

2) The Offsite ERO, directed by the Offsite Emergency Coordinator (OEC), provides for:

" Offsite radiological accident assessment.

" Protection of station personnel outside the Protected Area.

• Emergency support for acquisition of material and support personnel.

" The primary interface between VCSNS and outside organizations responsible for the protection of the public.

The Offsite ERO is made up primarily of personnel from the station's high level management team, Security, Health Physics, and Training with support from other stations departments as necessary.

3) The Emergency Public Information Organization (EPIO), directed by the Emergency Control Officer/Company Spokesperson, coordinates with Public Information Officers (PIO) from other organizations to provide information to the public through the news media.

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c. The Emergency Control Officer (ECO) is a senior VCSNS employee with overall responsibility for coordinating emergency response actions of the station, and the EPIO with the affected state(s) and county agencies.

d. Procedures for training and maintenance of the emergency organization are in place to ensure 24-hour-per-day staffing for emergency response, including established communication links.

2. State and County Functions and Responsibilities The state and counties have emergency response plans that specify the responsibilities and functions for the major agencies, departments, and key individuals of their organizations.

This information is located in their respective plans.

3. Agreements in Planning Effort Written agreements establishing the concept of operations developed between VCSNS and other support organizations having an emergency response role have been developed.

These agreements identify the emergency measures to be provided, the mutually accepted criteria for implementation, and the arrangements for exchange of information. Agreement letters are not necessary with federal agencies that are legally required to respond based on federal law. However, agreements are necessary if the agency was expected to provide assistance not required by law. Letters of Agreement shall be obtained with private contractors and others who provide services in support of the station during a declared emergency. A list of Letters of Agreement is provided in Appendix 2 of this Plan, the actual letters are maintained on file at the station. Letters of Agreement, as a minimum, state that the cooperating organization will provide their normal services in support of an emergency at the VCSNS site. A contract/purchase order with a private contractor is considered acceptable in lieu of a Letter of Agreement for the specified duration of the contract.

4. Continuous Coverage VCSNS maintains 24-hour emergency response capability. The normal on-shift complement provides the initial response to an emergency. This group is trained to handle emergency situations (e.g., initiate implementation of the Emergency Plan, make initial accident assessment, emergency classification, notifications, communications, and PARs) until the augmented ERO arrives. The ERO is composed of a broad spectrum of personnel with specialties in Operations, Maintenance, Engineering, Radiochemistry, Health Physics, fire protection, Security, communications, and Emergency Preparedness who are available and trained to augment on-shift personnel in an emergency. Procedures for training and maintenance of the emergency organization are in place to provide the capability of continuous (24-hour) operations.

The ED, located in the Technical Support Center (TSC), has the authority and responsibility for assuring continuity of resources (technical, administrative, and material) in the event of the activation of the ERO.

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Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station Figure A-I: Agency Response Organization Interrelationships Page 17 of 193 EP-1 00 Rev 64

Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station Onsite Emergency Response Organization Emergency Response Organization Emergency Public Information Organization Joint Information Center (JIC)

Figure A-2: VCSNS Augmented Emergency Response Organization Interrelationships Page 18 of 193 EP-1 00 Rev 64

Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station Section B: Emergency Response Organization This section describes the ERO, its key positions, and associated responsibilities. It outlines the staffing requirements that provide initial emergency response actions and provisions for timely augmentation of on-shift personnel when required.

1. On-Shift Emergency Response Organization Assignments The normal plant personnel complement is established with the Vice President, Nuclear Operations having overall authority for station operations. The Vice President, Nuclear Operations directs the unit organization in the management of the various departments while the Shift Supervisor retains the responsibility for actual operation of plant systems.

Emergency Preparedness must consider the capabilities of the normal plant organization and the ERO. The initial phases of an emergency situation at VCSNS will most likely involve a relatively small number of individuals. These individuals must be capable of (1) determining that an emergency exists, (2) providing initial classification and assessment, (3) promptly notifying offsite authorities and individuals in the emergency organization, and (4) making PARs as needed. The subsequent phases of the emergency situation may require an increasing augmentation of the emergency organization.

The station has personnel on-shift at all times that can provide an initial response to an Emergency Event. Annex 1 Table 2-1 and Part 2 Section B-1 and Table B-la outlines the unit on-shift emergency organization and its relation to the normal staff complement.

Members of the on-shift organization are trained on their responsibilities and duties in the event of an emergency and are capable of performing all response actions in an Unusual Event and the initial actions of higher classifications. The onsite ERO will be activated at an Alert and the entire ERO will be activated at a Site Area Emergency or General Emergency.

Shift personnel have the capability at all times to perform detection, mitigation, classification, and notification functions required in the early phases of an emergency. Shift augmentation and further ERO involvement will be determined by the extent and magnitude of the event.

When a transition to Severe Accident Management Guidelines (SAMGs) is initiated, the on-shift crew assumes the duties and responsibilities of the SAMG implementers.

Shift Supervisor: Has the responsibility and the authority to declare an emergency and becomes the Interim Emergency Director. In that role, the lED will initiate the appropriate immediate action in accordance with written procedures, mitigate the consequences of the emergency, activate the onsite ERO at an Alert and the entire ERO at a Site Area Emergency or General Emergency and notify offsite support and government agencies, as appropriate. In the Shift Supervisor's absence or incapacitation, the line of succession is defined by unit's Operations and Emergency Plan Procedures.

Shift En-qineer: A qualified individual assumes an overview role as the technical advisor with the specific responsibility of monitoring the maintenance of core cooling and containment integrity. An individual assigned the duty as the Shift Engineer shall be available to the unit Control Room at all times.

Control Room Operators: At least two qualified Reactor Operators are assigned to each shift during normal operations. They are responsible for operating plant equipment from the Control Room.

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Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station Auxiliary Operators: At least five non-licensed operators are assigned to each shift. They are responsible for operating plant equipment throughout the plant.

Radiation Protection: The station Health Physics personnel are responsible for the handling and monitoring of radioactive materials. Included in this organization are Health Physics Supervisors, Staff, and Specialists.

Chemistry: The station Chemistry personnel are responsible for sampling of system effluents, and the chemical and radio-analytical analysis of those samples. Included in this organization are Chemistry Supervisors, Staff, and Specialists.

Security: The station Security personnel are responsible for the physical security of the site.

Included in this organization are Security management, staff, and Security Officers.

A Fire Brigade for the Protected Area has been established by designating trained individuals as brigade members. The Fire Brigade Leader will be designated as per the FSAR and FPER.

A Medical Emergency Response Team (MERT) for the Protected Area has been established by designating trained individuals from the above listed groups as team members.

An individual (or group of individuals) on each shift is trained and made available to act as the State/County Communicator for the Protected Area. This individual can notify station personnel, state agencies, county agencies, and the NRC. The State/County Communicator will maintain communications as necessary until relieved by a qualified member from the augmented ERO.

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Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station

2. Authority over the Emergency Response Organization The lED, ED, Offsite Emergency Coordinator (OEC), and Emergency Control Officer (ECO) are the designated VCSNS individuals who have overall authority and responsibility, management ability, and technical knowledge for coordinating all emergency response activities at the VCSNS. The lED is the Shift Supervisor. The ED, OEC, and ECO are members of site management.

Control Room: lED (Shift Supervisor), initially in command and control until relieved by the Emergency Director (ED) in the TSC.

TSC: ED, when the TSC has attained minimum staffing levels, assumes the responsibilities for classification, declaration, and notification of emergencies, evaluations of operational events, and mitigation development. These duties may only be turned over to another qualified ED, with exception of the notification, which may be turned over to the OEC in the EOF.

EOF: ECO, when the EOF has attained minimum staffing levels, assumes overall command and control of VCSNS emergency response and approval of press releases. These duties may only be turned over to another qualified ECO.

OEC, when the EOF has attained minimum staffing levels, assumes command and control of the EOF, notification of local, state, and federal agencies, and development and notification of Protective Action Recommendations. These duties may only be turned over to another qualified OEC.

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Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station

3. Criteria for Assuming Command and Control (Succession)

Emergency personnel assume responsibility for their positions upon receiving notification to activate. The responsibility for initial assessment of, and response to, an emergency rests with the Shift Supervisor. The Shift Supervisor is the lED and has the ED's responsibilities and authority until relieved by a qualified ED. The ED will relieve the Shift Supervisor of the responsibility for continued assessment of the severity of the emergency and functions as part of the ERO as appropriate in accordance with the guidance provided in the Emergency Plan, the Unit 1 Annex, and the emergency plan procedures. Final succession is achieved when the ED, OEC, and ECO assume overall command and control, and directs VCSNS's emergency response activities.

The Control Room is to be relieved of command and control as soon as possible after the declaration of an Alert or higher classification. The overall command and control of the emergency is transferred directly to the ECO, as soon as possible. Command and control does not transfer to the TSC and EOF until the following criteria have been met:

• Adequate staff levels are present in support of the non-delegable responsibilities

• The status of the plant is well understood by the relieving individual

• The staff has been fully briefed as to the status of the event and the current proposed plan of action

• A formal turnover between the lED relinquishing command and control and the ED, OEC, and ECO assuming command and control has been made Although the ERO fulfills all regulatory requirements for emergency response, it may be altered at the discretion of the ECO. This type of alteration will be based on identified needs within the ERO, event dependent criteria, and identified needs of the company as a whole.

4. Non-Delegable Duties Non-delegable duties include the following functions:

• Event classification

• Development of PARs for the general public

• Notification of offsite authorities (approval of state, county, and NRC notifications)

• Approving company press releases pertaining to the emergency The Shift Supervisor is responsible for the initial classification of an event and assumes the position as lED. In this capacity, the Shift Supervisor has responsibility for performing the non-delegable responsibilities until relieved.

The ED (in the TSC) will relieve the lED of the command and control, event classification, notification, and Protective Action Recommendation duties. Once the EOF is activated, the OEC will relieve the ED of emergency notifications and PAR development and the ECO will relieve the ED of overall command and control.

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Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station

5. Emergency Response Organization Position Responsibilities Annex 1 Table 2-1 and Part 2 Section B-1 and Table B-la outline ERO positions required to meet minimum staffing and augmentation of the on-shift complement upon activation of the Emergency Response Organization (ERO), and the major tasks assigned to each position.

The augmentation staffing levels are used as a planning basis to cover a wide range of possible events. For extended events (one that is expected to continue for more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />), actual staffing will be established by the ED, OEC, and ECO based on the event and personnel availability. However, reduced staffing will only occur after discussion concerning the impact on plant operations and emergency response with the ED, OEC, and ECO.

As shown on Figure B-la, the overall ERO is made up of three suborganizations:

• The first is called the Onsite ERO. It is responsible for onsite emergency response activities. These activities include protecting plant personnel, mitigating the results of the event classifications, and keeping the Offsite ERO informed of onsite events and actions being taken.

• The second is called the Offsite ERO, which is responsible for offsite emergency response activities. These activities include providing information to and interface with offsite authorities, monitoring offsite results of the event, protecting plant personnel outside the Protected Area, supporting the onsite organization, notifications, Protective Action Recommendations (PARs), and coordinating public information.

" The third is called the Emergency Public Information Organization and is responsible for providing accurate information to the public about the event through the news media.

Specific responsibilities for each sub organization and related positions are as follows:

a. Onsite ERO (Fi-gure B-lb): The Onsite ERO is activated during an emergency classified as an Alert or higher. It can also be activated by the lED at his discretion during an Unusual Event. It functions under the direction of the ED, who is responsible for organizing and coordinating the emergency efforts at and within the Protected Area.

The Onsite ERO consists of station personnel who are involved with emergency response efforts necessary to control the plant during an incident. This organization operates out of the Control Room, the Technical Support Center (TSC), and the Operational Support Center (OSC). Collectively, members of the Onsite ERO provide for the following activities during an emergency:

• Plant systems operations and monitoring

• Radiological survey and monitoring (including Environmental Monitoring)

• Firefighting

• Rescue operations and first aid

• Decontamination

• Security of plant and access control

• Repair and damage control Page 23 of 193 EP-100 Rev 64

Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station

• Personnel protection including assembly, accountability, and evacuation

• Communications When plant conditions warrant entry into the SAMGs, the ED assumes the role of decision-maker. The Technical Support Supervisor or another qualified individual(s) assume the role of evaluator and assistant evaluator, and the Control Room staff assumes the role of implementers. Control Room personnel will perform mitigating actions for severe accidents per SAMGs before TSC activation.

Those personnel identified to augment the on-shift personnel within about 60 minutes of the declaration of an Alert or higher classification are part of the on-call ERO. These personnel are immediately available during normal working hours and are contacted by a call out system during nonworking hours.

For security-related events that would prevent the emergency responders from reaching the site, the augmented TSC, OSC, and Control Room responders would be directed to respond to the EOF or another designated offsite location. TSC/OSC/Control Room staffs will provide any possible assistance from this offsite staging area until such time as site access is restored.

All Onsite ERO personnel shall have the authority to perform assigned duties in a manner consistent with the objectives of this plan. In addition to maintaining adequate documentation of the event, position responsibilities include:

1) Shift Supervisor (Interim Emergency Director) CR A Shift Supervisor is on duty 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 lED in a declared emergency until relieved of this function. While serving in this capacity, the Shift Supervisor is responsible for:

• Activating the ERO (as deemed appropriate or as procedurally required).

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

• Performing those duties outlined for the ED, OEC, and ECO.

The on-duty Shift Supervisor directs the activities of the operating crew and is responsible for the safe operation of the plant in compliance with the unit NRC operating license and the unit operating procedures. The Shift Supervisor, after relinquishing command and control, functionally reports to the ED in the TSC.

The Shift Supervisor's responsibilities, when not in command and control, are described below:

• The authority and responsibility to shutdown the reactor when determined that the safety of the reactor is in jeopardy or when operating parameters exceed any of the reactor protection circuit setpoints and automatic shutdown does not occur.

• To ensure a review has been completed to determine the circumstance, cause, and limits under which operations can safely proceed before the reactor is Page 24 of 193 EP-100 Rev 64

Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station returned to power following a trip or an unscheduled or unexplained power reduction.

• The responsibility to be present at the plant and to provide direction for returning the reactor to power following a trip or an unscheduled or unexplained power reduction.

" The responsibility to adhere to the unit Technical Specifications and to review routine operating data to assure safe operation

• The responsibility to identify applicable EALs and emergency classifications

• The responsibility to adhere to unit operating procedures and the requirements for their use. During an emergency, authorize operations personnel to depart from approved procedures where necessary to prevent injury to personnel, including the public, or damage to the facility consistent with the requirements of 10 CFR 50.54(x) and (y).

" Initiate immediate corrective actions to limit or contain the emergency invoking the provisions of 10 CFR 50.54(x) if appropriate, and specifically when addressing SAMGs

" Approve emergency special procedures, and implement as required under the provisions of 10 CFR 50.54(x)

" Supervise the activities of the Control Room crew and the Communicators

• Initiate onsite protective actions, including authorization of exposure limits for emergency workers in excess of normal station limits

2) Emergqency Director (ED) TSC The ED supervises and directs the Onsite ERO. The ED's responsibilities include organizing and coordinating the onsite emergency efforts. Additionally, the ED has the requisite authority, plant operating experience, and qualifications to implement in-plant recovery operations. The ED is responsible for relieving the lED of classifying emergencies.

3) Technical Support Supervisor TSC The Technical Support Supervisor reports to the ED and directs a staff of engineers in performing technical assessments of station emergencies and assists in recovery planning.

4) Operations Supervisor TSC The Operations Supervisor reports to the ED. Major functions include determining the extent of station emergencies and recommending corrective actions.

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Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station

5) Radiological Assessment Supervisor TSC The Radiological Assessment Supervisor reports to the ED and supervises the activities of the onsite radiological assessments. The supervisor directs the staff in determining the extent and nature of radiological or hazardous material problems onsite.

6) Emergency Notification System (ENS) Communicator TSC The Emergency Notification System Communicators report to the Emergency Director in the TSC and the Emergency Offsite Manager in the EOF. All communicators provide updates and respond to inquiries from the NRC for plant status, emergency classifications, and mitigation assessments and actions.

7) Technical Support Staff TSC Core Thermal, Electrical, and Mechanical Engineers make up the technical support staff. These Engineers evaluate damage assessment reports and support the development of mitigation recommendations, strategies, and procedures to recover the plant and return it to an operational state.

8) State/County Communicator TSC The State/County Communicator reports to the ED and ensures that initial notifications are communicated to the offsite officials within 15 minutes after the change in classification or a change in PARs and that follow-up notifications are made within about 60 minutes of the previous notification.. This position will exchange information with appropriate state and county agencies regarding emergency notification forms or other questions that may arise. Upon activation of the EOF, communications will be transferred to the EOF.

9) Operational Support Center Supervisor OSC The OSC Supervisor reports to the ED and supervises the activities of OSC personnel while implementing the mitigation strategies and procedures.

10) Operational Support Center Damage Control Team OSC Specialists and Operators make-up the OSC Damage Control Teams. These teams perform emergency mitigation tasks throughout the station. Individuals from Health Physics, Mechanical, Electrical, and I&C Maintenance, Chemistry, and Operations are always available as part of the OSC Damage Control Teams. Individuals from other plant organizations may also be called to assist in emergency mitigation efforts.

11) Security Supervisor OSC The Security Supervisor will support the emergency by providing escort or access as requested to areas secured by the Security Force and not normally accessed.

The Supervisor is responsible for the physical security of the plant, access control to the plant Protected Area and access control to plant vital areas. In the event of a security related event, the Supervisor will report to the TSC.

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Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station

b. Offsite ERO (Figure B-ic): The Offsite ERO is activated during an emergency classified as a Site Area Emergency or higher. It functions under the direction of the Offsite Emergency Coordinator, and is responsible for offsite emergency response activities.

These activities include providing information to and interface with offsite authorities; monitoring offsite results of the event; protecting plant personnel outside the Protected Area who are sheltered or evacuated, supporting the onsite organization, and coordinating the flow of information to the EPIO.

1) Emergency Control Officer (ECO) EOF a) When the ECO has command and control, the ongoing responsibilities include:

• Assumes overall command and control of emergency response activities

• Ensure that federal, state, and county authorities and industry support agencies remain cognizant of the status of the emergency situation. If requested, dispatch informed individuals to offsite governmental EOCs

• Serve as the Company Spokesperson for press conferences

• Approve the technical content of VCSNS press releases before they are released to the media (non-delegable duty)

• Coordinate all VCSNS activities involved with the emergency response

" Ensure offsite agency updates are periodically communicated as required/requested

" Request assistance from non-VCSNS emergency response organizations, as necessary

• Provide status, assessment information, and recommended protective actions to offsite emergency response agencies

2) Offsite Emergency Coordinator (OEC) EOF The OEC reports to the ECO. The OEC has the authority, management ability, and technical knowledge to assist the ECO in the management of VCSNS's offsite ERO by directing and coordinating the activation and response efforts of the EOF staff, determining PARs (non-delegable duty) when necessary, and preparing state and county notification forms (non-delegable duty) with the assistance of the Offsite Radiological Monitoring Coordinator.

3) Technical Support Coordinator EOF The Technical Support Coordinator reports to the OEC. The Coordinator supports the OEC and ECO with technical information and engineering support regarding the affected unit.

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4) Offsite Radiological Monitoring Coordinator (ORMC) EOF The ORMC reports to the OEC and directs the activities of the EOF radiological assessment staff. These duties include specific responsibilities: recommending changes in the event classification and PARs based on effluent releases or dose projections, assisting the OEC in the evaluation of the significance of an emergency with respect to the public, and advising the OEC on the need for emergency exposures or for issuance of Potassium Iodide (KI) to the Field Teams.

5) Dose Assessor EOF The Dose Assessor reports to the Offsite Radiological Monitoring Coordinator and operates the dose assessment program, interprets radiological data from the field monitoring teams, and provides PARs based on dose projections to the Offsite Radiological Monitoring Coordinator.

6) State/County Communicator EOF The State/County Communicator reports to the OEC and ensures that initial notifications are communicated to the offsite officials within 15 minutes after the change in classification or a change in PARs and that follow-up notifications are made within about 60 minutes of the previous notification.. This position will exchange information with appropriate state and county agencies regarding emergency notification forms (green sheets) or other questions that may arise.

7) Security Coordinator EOF The Coordinator reports to the OEC and will be responsible for maintaining EOF security, coordinating EOF security with site security, and interfacing with local law enforcement, as needed.

8) General Services Coordinator EOF The Coordinator reports to the OEC and will be responsible for maintaining and coordinating document services, transportation, personnel accommodations, temporary offsite facilities and communications, meals, and procurement and delivery of items requested by the ERO.

c. Emergency Public Information Organization (EPIO) (Figure B-id): The EPIO is part of the overall ERO that is activated during an emergency. It functions under the ECO (Company Spokesperson) and gets support from the OEC.

The EPIO consists of corporate and station personnel who are involved with emergency response efforts necessary to coordinate VCSNS public notices with offsite agency public information updates. This organization operates out of the Joint Information Center (JIC). Collectively, members of the EPIO provide for the following activities during an emergency:

• Development and issuance of news releases

• Coordination and conduct of media briefings

• Rumor control

• Media monitoring and correction of misinformation Page 28 of 193 EP-100 Rev 64

Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station All EPIO personnel shall have the authority to perform assigned duties in a manner consistent with the objectives of this plan. In addition to maintaining adequate documentation of the event, position responsibilities include:

1) Company Spokesperson (Emergency Control Officer) JIC The Company Spokesperson reports is responsible for directing the VCSNS EPIO, coordinating with the other responders, and providing news information to the media.

2) Joint Information Center Coordinator JIC The JIC Coordinator reports to the Company Spokesperson and is responsible for ensuring the operability of the JIC and supervision of monitoring activities in the JIC.

3) Lead Technical Briefer JIC The Lead Technical Briefer reports to the Company Spokesperson and assists in obtaining technical and plant status information for use in news releases and media briefings.

4) Media Coordinator JIC The Media Monitoring Coordinator reports to the JIC Coordinator and ensures that the media is being monitored and that VCSNS personnel review the information detailed or contained in media releases.

The above-listed ERO positions form the basis of VCSNS emergency response. If needed, any company personnel and resources can and will be used to ensure the safety of offsite populations, station personnel, and protection of station equipment needed to maintain nuclear safety.

6. Emergency Response Organization Block Diagram Annex 1 Table 2-1 and Part 2 Section B-1 and Table B-la, list the basis for the ERO and the supporting positions assigned to interface with federal, state, and county authorities. Section B.5 discusses specific responsibilities and the interrelationships for these positions.

7. IndustrylPrivate Support Organizations VCSNS retains contractors to provide supporting services. A contract/purchase order with a private contractor is acceptable in lieu of an agreement letter for the specified duration of the contract. Institute of Nuclear Power Organization (INPO), Electric Power Research Institute (EPRI), and Nuclear Energy Institute (NEI) maintain a coordination agreement on emergency information with their member utilities.

Among services currently provided are the following:

a. Institute of Nuclear Power Operations (INPO): Experience has shown that a utility may need resources beyond in-house capabilities for the recovery from a nuclear plant emergency. One of the roles of INPO is to assist affected utilities by quickly applying the resources of the nuclear industry to meet the needs of an emergency. INPO has an emergency response plan that enables it to provide the following emergency support functions:

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• Assistance to the affected utility in locating sources of emergency personnel, equipment, and operational analysis.

• INPO provides the "Nuclear Network," or its replacement, electronic communications system to its members, participants, NEI, and EPRI to coordinate the flow of media and technical information about the emergency.

" VCSNS may obtain utility industry information and assistance from any party to this agreement through the coordination of INPO.

To support these functions, INPO maintains the following emergency support capabilities:

" A dedicated emergency call number

• Designated INPO representative(s) who can be quickly dispatched to the VCSNS ERO to coordinate INPO support activities and information flow

• The 24-hour-per-day operation of an Emergency Response Center at INPO headquarters INPO will be notified (via the designated emergency call number) for all situations involving an Alert, Site Area Emergency, or General Emergency declaration. INPO has coordinated the preparation of a Voluntary Assistance Agreement for Transportation Accidents. SCE&G has signed this agreement which establishes the rights and responsibilities of electric utilities in requesting or providing assistance for response to a transportation accident involving nuclear materials.

b. American Nuclear Insurers (ANI): In early 1982, ANI issued Bulletin #5B (1981)

"Accident Notification Procedures for Liability Insured" which provides revised criteria for the notification of the pools in the event of a nuclear emergency at one of the liability insured nuclear power reactor sites. This revision brings the ANI/MAELU (Mutual Atomic Energy Liability Underwriters) notification criteria into alignment with the standard emergency classification system adopted by the nuclear industry. This document also identifies a suitable channel for follow-up communication by ANI after initial notification.

c. DOE Radiation Emergency Assistance Center/Training Site (REAC/TS): DOE REAC/TS provides services of medical and health physics support. REAC/TS advises on the health physics aspects of situations requiring medical assistance.

d. Manufacturer Design and Enqineering Support: Under established contracts, the unit(s) design engineering company provides design engineering expertise, specialized equipment, and other services identified as needed and deemed appropriate to assist in an emergency situation.

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8. Supplemental Emergency Assistance to the ERO Agreements are maintained with outside support agencies who do not take part in the organizational control of the emergency. They 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 (named in Appendix 2) provide services of:

a. Law enforcement

b. Fire protection

c. Ambulance services

d. Medical and hospital support Support groups providing transportation and treatment of injured station personnel are described in Section L of this Plan.

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0 of Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station Emergency Control Officer (Company Spokesperson)

/

Emergency Offsite Emergency Director Coordinator

/ / /

Onsite Emergency Response Offsite Emergency Response Emergency Public Information Organization Organization Organization Figure B-la: Overall ERO Command Structure Page 32 of 193 EP-100 Rev 64

Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station I

Electrical Maint Chemistry Operations Staff Electricians Supervisor I

Chemistry Mechanical Maint Operations Specialists Mechanics Supervisor Figure B-lb: Onsite Emergency Response Organization Page 33 of 193 EP-100 Rev 64

0 Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station

-mergency uontro Officer (Company Spokesperson)

State/County Communicators EPIO I I General Services Technical Support Coordinator Coordinator Figure B-Ic: Offsite Emergency Response Organization Page 34 of 193 EP-1 00 Rev 64

0 0 Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station Emergency Control Officer (Company Spokesperson)

I JIC Coordinator I

Lead Technical Media Coordinator Briefer Figure B-Id: Emergency Public Information Organization Page 35 of 193 EP-100 Rev 64

Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station Table B-la: Staffing Requirements for the VCSNS ERO Staffing - Shift/ERO Shift 30 Minute -60 Minute Functional Area Major Tasks Emergency Positions (Facility) Staffing ERO Staffing ERO Staffing**

1. Plant Operations and Control Room Shift Supervisor/Interim ED (CR) 1 Assessment of Staff Control Room Supervisor (CR) 1 Operational Aspects Reactor Operator (CR) 2 Auxiliary Operator (CR) 5

2. Emergency Direction Command and Interim Emergency Director (CR) (a) and Control Control Emergency Director (TSC) - 1(a)

Offsite Emergency Coordinator (EOF) 1(a)

3. Notification & Emergency Interim Emergency Director (CR) (a)

Communication Communications State/County Communicator (CRiTSC) 1(g) 1 Emergency Director (TSC) (a)

State/County Communicator (TSC or EOF) - 1(g)

Offsite Emergency Coordinator (EOF) (a)

Plant Status ENS Communicator (TSC) 1 Page 36 of 193 EP-100 Rev 64

Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station Staffing - Shift/ERO Shift 30 Minute -60 Minute Functional Area Major Tasks Emergency Positions (Facility) Staffing ERO Staffing ERO Staffing**

4. Radiological Offsite Dose Health Physics Specialist (OSC) 1 Assessment and Support of Assessment Offsite Rad Monitoring Coordinator (EOF)

Operational Accident Dose Assessor/Health Physics (EOF) 1 1(h)---

Assessment Offsite Field Monitoring Teams (EOF)

Radiological Health Physics Specialist (or qualified personnel) 1(h)

Monitoring Drivers 1l(h)

Onsite Field Monitoring Teams (OSC)

Radiological Health Physics Specialist (or qualified personnel) 1 Monitoring In-plant Surveys Health Physics Specialist (OSC) 1 1 Chemistry Specialist (OSC) 1 Chemistry Plant Radiological Monitoring Director (OSC)

IHP Supervisory C01 11 5. Plant System Technical Support Shift Engineer (CR) 1 Engineering, Repair, and Operations Supervisor (CR/TSC) - 1 Corrective Actions Technical Support Supervisor (TSC) 1 Core Thermal Engineer (TSC) 1(e)

Mechanical Engineer (TSC) 1 Electrical Engineer (TSC) 1 Repair and Mechanical Maintenance Mechanic (OSC) 2 1 Corrective Actions Electrical Maintenance Electrician (OSC) 1 1 1 I&C Maintenance Mechanic (OSC) 1 1(h) 1 Health Physics Specialist (Rad Waste) (OSC) 1 OSC Supervisor (OSC) 1

6. In-Plant Protective Radiation Health Physics Specialists (OSC) (e) 2 2 Actions Protection

7. Fire Fighting -- Fire Brigade (c) (f)

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Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station Staffing - Shift/ERO Shift 30 Minute -60 Minute Functional Area Major Tasks Emergency Positions (Facility) Staffing ERO Staffing ERO Staffing**

8. Rescue Operations and Medical Emergency Response Team (b)(e) (f)

First Aid

9. Site Access Control and Security & Security Team Personnel (d)

Personnel Accountability Accountability

10. Public Information Media Interface, Company Spokesperson (JIC) 1 Information JIC Coordinator (JIC) 1 Development, Lead Technical Briefer (JIC) 1 Media and Rumor Control Monitoring, and Facility Operations and Control Numbers noted outside the parenthesis are actual personnel on shift. Numbers inside parenthesis may be provided by shift personnel assigned other functions.

(a) The Shift Supervisor shall function as the lED until relieved by the Emergency Director (b) Personnel numbers depend on the type and extent of the emergency (c) Fire Brigade per FSAR/FPER/Technical Specifications, as applicable (d) Per Security Plan (e) May be provided by shift personnel assigned other functions (f) Supported by Offsite Response Organizations (ORO)

(g) Telephone Communicator Only (h) Actual response time is 40 minutes

• • - 60 minute staffing: TSC/OSC - from the declaration of an Alert or higher; EOF - from the declaration of a Site Area Emergency or higher, JIC at the discretion of the ECO Page 38 of 193 EP-100 Rev 64

Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station Section C: Emergency Response Support and Resources This section describes the provisions for requesting and effectively using support resources and for accommodating offsite officials at the VCSNS emergency response facilities.

1. Federal Response Support and Resources Assistance is available from federal agencies through the NRF. The lead federal agency who provides direct assistance to VCSNS during an emergency is the NRC. Other federal agencies, such as the DHS and the DOE provide assistance to the state through implementation of the NRF.

a. Sections A and B of this plan identify the specific individuals by title who are authorized to request federal assistance.

b. Federal agencies that may provide assistance in direct support of VCSNS in the event of an accident are identified in Section A of this plan. If needed, federal resources are made available to VCSNS in an expeditious and timely manner.

c. Each emergency response facility has the equipment and communications capability necessary for a continuous high level of response, interaction, and communication among key personnel during emergency conditions. The emergency facilities are able to accommodate federal representatives with working areas provided for their use. Based on the NRC Response Coordination Manual 1996 (RCM-96) or NUREG-0728, accommodations for the initial site response team assume the following approximate numbers for each facility:

Facility Accommodations EOF 12 TSC 6 CR 1 JIC 2

d. Communication pathways provided in each of these facilities include access to dedicated landline telephones, wireless telephones and FTS telephones as provided by the NRC and include the Reactor Safety Counterpart Link (RSCL), Management Counterpart Link (MCL), the Protective Measures Counterpart Link ( PMCL), and the Local Area Network (LAN). These FTS lines are in place in the appropriate VCSNS emergency response facilities and are for use by the NRC Response Team upon their arrival. The VCSNS ERO does not normally utilize these communication links.

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Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station

2. Liaisons

a. The NRC, FEMA, and the state(s) may dispatch representatives to the EOF where accommodations have been provided.

b. At the Site Area Emergency level and above, VCSNS personnel are assigned as liaisons to the state of South Carolina, Lexington County, Richland County, Newberry County, and Fairfield County EOCs, when they are activated. These representatives act as technical liaisons to interpret emergency action levels, explain accident conditions, and provide technical information regarding actions by the station's ERO.

3. Radiological Laboratories Support of the radiation monitoring and analysis effort is provided by an onsite laboratory.

The onsite laboratory is the central point for receipt and analysis of all onsite samples and includes equipment for chemical analyses and for the analysis of radioactivity.

An additional laboratory facility is available at the DHEC, other nuclear facilities, or private labs. DHEC also has a mobile laboratory for analyzing environmental samples. The response time for efficient activation of the mobile laboratory is approximately 2 to 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.

4. Other Assistance Through INPO, other companies' operating nuclear facilities are available to provide certain types of assistance and support, including engineering, design, consultation, whole body counting, and dosimetry evaluation and equipment. Additional facilities, organizations, and individuals, as listed in the Emergency Planning Telephone Directory, are available and may be used in support of emergency response. In addition, ANI provides insurance to cover VCSNS 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 incident at the plant. Written agreements that describe the level of assistance and resources provided to VCSNS by external sources are included in Appendix 2 as applicable.

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Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station Section D: Emergency Classification System This section describes the classification and emergency action level scheme used to determine the minimum response to an abnormal event at the station. This scheme is based on plant systems, effluent parameters, and operating procedures for each unit. The initial response of federal, state, and county agencies depends on information provided by the ERO. The station's Emergency Preparedness Staff works closely with the state of South Carolina and county agencies to ensure consistency in classification schemes and procedural interfaces.

1. Emergency Classification System The Emergency Plan provides for classification of emergencies into four (4) categories or conditions, covering the postulated spectrum of emergency situations. They are:

" Unusual Event

• Alert

" Site Area Emergency

• General Emergency Each classification is characterized by EALs or event Initiating Conditions (IC) and addresses emergencies of increasing severity.

a. Unusual Event: Events are in progress or have occurred that 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.

This is the least severe of the four levels. The purpose of this classification is to bring response personnel and offsite agencies to a state of readiness in the event the situation degrades and to provide systematic handling of information and decision making. The Unit 1 Shift Supervisor will classify an Unusual Event and become the lED.

Required actions at this classification include:

• Notifications to station and company management

" Notification, within 15 minutes, of the state and counties

• At the discretion of the lED, or the station management, full or selective staffing of any one or more of the emergency response facilities may be initiated

• Notification of the NRC as soon as possible but within 60 minutes of classification

" Assessment of the situation and response as necessary, which may include escalating to a higher classification when and if conditions warrant Page 41 of 193 EP-100 Rev 64

Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station

• When the event is terminated, close-out is performed over communication links to offsite authorities (i.e., NRC, state, county), participating in the response by providing a summary of the event

" Provide a formal written summary transmitted to the state and counties within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

b. Alert: Events are in progress or have occurred that 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 (PAG) exposure levels.

The purpose of this classification is to ensure that emergency response personnel are readily available and to provide offsite authorities with current status information. An Alert will be classified as the initiating event or as escalation from an Unusual Event. In either case, the classification will most likely be made by the Shift Supervisor (lED) before the transfer of command and control.

Required actions at this classification include:

• Notifications to station management

" Notification, within 15 minutes, of the state and counties

" Activation of the Onsite ERO

" Transfer of command and control

• Notification of the NRC as soon as possible but within 60 minutes of classification

• Notification of INPO and ANI

• Assessment of the situation and response as necessary, which may include escalating to a higher classification if and when conditions warrant

• Onsite and offsite field teams are sent to staging areas or dispatched to monitor for releases of radiation to the environment

• Keeping offsite authorities informed of plant status by providing periodic updates to include meteorological and radiological data

• When the event is terminated, close-out is performed over communication links to offsite authorities participating in the response by providing a verbal summary of the event (i.e., NRC, state, county), followed by formal written summary transmitted to the state and counties within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Page 42 of 193 EP-100 Rev 64

Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station

c. Site Area Emergency: Events are in progress or have occurred that involve actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTIONS that result in intentional damage or malicious acts 1) toward site personnel or equipment that could lead to the likely failure of, or 2) that prevent effective access to, equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA PAG exposure levels beyond the site boundary.

This classification will most likely be made by the ED following activation of the TSC with notifications being developed in the EOF.

Required actions at this classification, in addition to those listed under the Alert level, include:

" Activation of the Offsite ERO and Emergency Public Information Organization

" If not previously performed, assembly/accountability shall be performed and site evacuation of nonessential personnel shall be initiated

" Dispatch of plant technical liaisons to the county and state EOCs when they are activated to provide a plant-knowledgeable individual to explain plant communications regarding the emergency and support the interaction with the offsite authorities during the emergency

• Keeping offsite authorities informed of plant status by providing periodic updates to include meteorological data and projected or actual doses for any releases that have occurred

• When the event is terminated, close-out is performed over communication links to offsite authorities participating in the response by providing a verbal summary of the event (i.e., NRC, state, county), followed by formal written summary transmitted to the state and counties within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Page 43 of 193 EP-100 Rev 64

Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station

d. General Emergency: Events are in progress or have occurred that involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility. Releases can be reasonably expected to exceed EPA PAG exposure levels offsite for more than the immediate site area.

The purpose of this classification, in addition to those of the Site Area Emergency level, is to initiate predetermined protective actions for the public and provide continuous assessment of information from monitoring groups. The classification will most likely be made by the ED following activation of the TSC with notifications and PARs being developed in the EOF, following activation.

Required actions at this classification, in addition to those listed under the Alert and Site Area Emergency, include:

• A PAR will be determined and issued

• Assessment of the situation and response as necessary

• When the event is terminated, close-out is performed over communication links to offsite authorities participating in the response by providing a verbal summary of the event (i.e., NRC, state, county), followed by formal written summary transmitted to the state and counties within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />

e. Classification Downgrading: VCSNS's policy is that emergency classifications shall not be downgraded to a lower classification. Once declared, the event shall remain in effect until no classification is warranted, a higher classification is required, or until such time as conditions warrant entry into the Recovery Phase.

f. Guidance for Termination of an Emergency: The purpose of terminating an emergency is to provide an orderly turnover of plant control from the EROs to the normal VCSNS plant organization. Termination of the emergency is authorized by the ECO in command and control. If the emergency is classified as an Alert or higher, the lED must await the activation of the emergency response facilities and turn over command and control to the ECO before initiating the Recovery/Termination Checklist. The considerations provided in the Recovery/Termination Checklist in the emergency plan procedures must be performed before exiting the emergency event. Consultation with governmental agencies and other parties should be conducted before termination of an event classified as Site Area Emergency or General Emergency. Notifications shall be transmitted to appropriate agencies to terminate an event. When a classified event is terminated a Recovery Phase will be entered.

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g. Recovery Phase: That period when the emergency phase is over and activities are being taken to return the situation to a normal state (acceptable condition). The plant is under control and no potential for further degradation to the plant or the environment is believed to exist.

Entry into the Recovery Phase will be authorized by the ECO after consultation with the ED and OEC at an Alert or higher classification and the. offsite authorities if a Site Area Emergency or General Emergency was declared. The lED may enter the Recovery/Termination Phase after the Unusual Event when conditions warrant.

Required actions at this classification include:

• The state and the NRC shall be consulted prior to entry into recovery from a Site Area Emergency or a General Emergency.

• Notifications will be made to station management, state, counties, and NRC.

• A Recovery organization will be established to manage repairs to return the unit to an acceptable condition, and support environmental monitoring activities as requested in coordination with federal and state efforts.

• INPO and ANI are notified of Recovery classification.

h. VCSNS Security Plan: VCSNS has a Security Plan that complies with the requirements of 10 CFR 73. The interface between the Radiological Emergency Plan and the Security Plan is one of parallel operation. The plans are compatible. The Radiation Emergency Plan response measures, once initiated, are executed in parallel with measures taken in accordance with the Security Plan. During a classified event, the individual in overall command and control has responsibility for implementing both plans.

Threats made to VCSNS facilities are evaluated in accordance with established threat assessment procedures and the Security Plan. The Security Plan, Appendix C, Safeguards Contingency Plan, identifies situations that could be ICs for EAL classifications. Contingency events include bomb threats, attack threats, civil disturbances, Protected Area intrusions, loss of guard/post contact, vital area intrusions, bomb devices discovered, loss of guard force, hostages, extortion, fire/explosions, internal disturbances, security communications failure, and obvious attempts of tampering. The Safeguards Contingency Plan provides guidance for decisions and actions to be taken for each security contingency event. As guidance, the Safeguards Contingency Plan allows for differing responses depending upon the assessment of the actual situation within each contingency event classification.

The assessment of any security contingency event and the decision to initiate, or not to implement the Radiation Emergency Plan, will be the responsibility of the Shift Supervisor or ECO. All identified security contingency events have the potential of being assessed as ICs for a radiological emergency declaration.

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2. Emergency Action Level Technical Basis EPP-001, Activation and Implementation of Emergency Plan, includes Unit-Specific EALs consistent with the general class descriptions and provided in NEI guidance documentation in accordance with Regulatory Guide 1.101, "Emergency Planning and Preparedness for Nuclear Power Reactors." Where possible, these EALs will be related to plant instrumentation readings.

Emergency classifications are characterized by EALs. The Threshold Values are referenced whenever an Initiating Condition is reached. An Initiating Condition is one of a predetermined subset of unit conditions, where either the potential exists for a radiological emergency, or such an emergency has occurred. Defined in this manner, an Initiating Condition is an emergency condition, which sets it apart from the broad class of conditions that may or may not have the potential to escalate into a radiological emergency. ICs are arranged in one of the Recognition Categories.

EALs are for unplanned events. A planned evolution involves preplanning to address the limitations imposed by the condition, the performance of required surveillance testing, and the implementation of specific controls before knowingly entering the condition. Planned evolutions to test, manipulate, repair, perform maintenance or modifications to systems and equipment that result in an EAL Threshold Value being met or exceeded are not subject to classification and activation requirements as long as the evolution proceeds as planned.

However, these conditions may be subject to the reporting requirements of 10 CFR 50.72.

An emergency is classified after assessing abnormal plant conditions and comparing them to EAL Threshold Values for the appropriate ICs. Classifications are based on the evaluation of VCSNS. EAL matrix tables organized by recognition categories are used to facilitate the comparison. The EAL matrix for Unit 1 is used when the unit is in the Technical Specification defined modes of Power Operations as: Power Operations, Startup, Hot Standby, Hot Shutdown, Cold Shutdown, Refueling, or the Defueled mode.

All recognition categories should be reviewed for applicability prior to classification. The EALs are coded with a letter and number designator. All ICs, which describe the severity of a common condition (series), are located above the EALs.

3. Offsite Classification Systems VCSNS works with the state and counties to ensure consistency between classification schemes. The content of the EALs is reviewed with the state and county authorities on an annual basis. The state and counties are informed regarding any EAL changes that significantly impact the ICs or Technical Basis.

4. Offsite Emergency Procedures VCSNS works with the state and county authorities to ensure that procedures are in place that provide for emergency actions to be taken which are consistent with the protective actions recommended by the station, accounting for local offsite conditions that exist at the time of the emergency.

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Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station Section E: Notification Methods and Procedures This section describes the notification of state and county response organizations, federal agencies, and VCSNS emergency response personnel. It outlines the content of initial and follow-up messages to response organizations within the plume exposure pathway EPZ.

1. Bases for Emergency Response Organization Notification VCSNS, in cooperation with state and county authorities, has established mutually agreeable methods and procedures for notification of offsite response organizations consistent with the emergency classification and action level scheme. Notifications to offsite agencies include a means of verification or authentication such as the use of dedicated communications networks, verification code words, or providing call-back verification phone numbers.

Notification for Transportation Accidents: A Transportation Accident is defined in 49 CFR 171.15 and 49 CFR 171.16. If a Transportation Accident involving material in the custody of a VCSNS facility occurs, the appropriate internal and offsite agencies will be notified in accordance with VCSNS procedures.

2. Notification and Mobilization of Emergency Response Personnel Emergency implementing procedures are established for notification and mobilization of emergency response personnel as follows:

a. Onsite: When an emergency is declared, reclassified, or terminated, an announcement is made (over the plant public address system or by other means) that includes the emergency classification declared and response actions to be taken by site personnel.

At the Unusual Event classification, select ERO augmentation personnel may be notified and requested to remain available to respond. At an Alert classification or higher, ERO augmentation personnel are notified for activation of the TSC and OSC and at a Site Area Emergency or higher augmentation personnel are notified for activation of the EOF and JIC using the ERO Notification System and/or manual call-outs via commercial telephone as backup.

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Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station

b. Offsite: Notifications are promptly made to offsite EROs as follows:

1) State/County Aqencies: A notification shall be made within 15 minutes of:

• The initial emergency classification

• Classification escalation

• The issuance of, or change to a PAR for the general public

" Changes in radiological release status, occurring outside of an event classification or PAR notification, based on an agreement with the state/county authorities The emergency warning points are simultaneously notified using a dedicated notification system. Commercial telephone lines and/or radios are available as backup notification methods.

A notification will also be initiated to cognizant state/county government agencies as soon as possible but within one hour of the termination of an event classification, or entry into Recovery Phase.

2) NRC: An event will be reported to the NRC Operations Center immediately after notification of the appropriate state and county agencies but not later than one hour after the time of initial classification, escalation, termination, or entry into the Recovery Phase. The NRC is notified by a dedicated telephone system called the Emergency Notification System (ENS). If the ENS is inoperative, the required notifications are made via commercial telephone service, other dedicated telephone service, or any other method that shall ensure that a report is made as soon as practical. The Emergency Notification Form (ENF) may be used as a guide to provide initial information to the NRC. If continuous communication is requested and established, a log is used in lieu of the ENF.

Specific requirements for the notifications to the NRC for classified emergency events are detailed in 10 CFR 50.72 with guidance provided in the station's notification procedures.

The computerized data link to the NRC, referred to as the ERDS, will be initiated within one hour of the declaration of an Alert classification or higher.

Mobilization of federal, state, and county response organizations is performed in accordance with their applicable emergency plan and procedures. At a minimum, mobilization of federal response organizations and activation of state and county EOCs is expected to occur at the declaration of a Site Area Emergency. The state and county authorities are responsible for the process of notification of the general public.

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c. Support Organizations: When an emergency is initially classified, escalated, or terminated, notifications are promptly made to the following support organizations:

• Medical, rescue, and firefighting support services are notified for assistance as the situation dictates

• INPO is notified at an Alert or higher classification with requests for assistance as necessary

" ANI is notified at an Alert or higher classification with requests for assistance as necessary

" Vendor and contractor support services are notified for assistance as the situation dictates

3. Initial Notification Messages VCSNS, in conjunction with state and county authorities, has established the contents of the initial notification message form, the ENF, transmitted during a classified emergency. The contents of the form include, as a minimum:

" Designation ("Drill" or "Actual Event")

" Identity of site and unit

• Event classification

• EAL number (as agreed upon with state authorities)

• Nontechnical event description (as agreed upon with state authorities)

• Date and time of declaration (or entry into Recovery Phase or Termination)

• Whether a release is taking or has taken place (Note: "Release" means a radiological release attributable to the emergency event.)

• Wind direction and speed

• Whether offsite protective measures may be necessary

" Potentially affected subareas when a General Emergency is declared Notification approval, transmittal date and time, and offsite agencies contacted are recorded either on the notification form or in an event logbook.

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4. Follow-Up Messages For all emergency classifications, update messages to state and county authorities will be provided on a prearranged frequency. The facility in command and control is responsible for ensuring that the updates are completed. State and county updates contain the prearranged information plus any additional information requested at the time of the notification.

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

a. The results of evaluations or assessments of plant conditions

b. The effectiveness of response or protective measures taken

c. Information related to plant behavior that is not understood If requested by the NRC, an open, continuous communications channel will be maintained with the NRC Operations Center over the ENS and/or HPN circuits.

5. State and County Information Dissemination The state and county emergency response plans describe procedures for state and county officials to make a public notification decision promptly on being informed by the plant of an emergency. The system for disseminating information to the public includes notification by pre-scripted messages through appropriate broadcast media such as the Emergency Alert System (EAS).

6. Notification of the Public The capability for the prompt notification of the general public within the 10-mile plume exposure pathway EPZ around the VCSNS is covered under this plan.

This notification capability consists of two principal elements: (1) the Alert and Notification Systems (ANS) and (2) the EAS radio or television stations.

" The ANS consists of fixed sirens. Activation of the ANS sirens when directed by the civil authorities will alert the public to turn on their radios or television to a local EAS station for detailed information on the emergency situation.

• The EAS is a network of local radio and television stations prepared to transmit or relay emergency information and instructions from the civil authorities to the general public.

Activation of the ANS will be initiated by VCSNS personnel upon direction by state or local authorities as specified in existing agreements concerning activation of the system. The siren system is designed in such a fashion that it can be operationally segregated by county boundary within the 10-mile emergency zone radius. The ANS signal will be a three-minute steady signal. Upon determination of the need for public notification, the ANS can be activated within 15 minutes.

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Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station The locations of the sirens were determined by a comprehensive engineering study that addressed population density, geographical features, siren output, and mounting heights of sirens, to ensure coverage of the EPZ.

To ensure the ANS is maintained in an operational readiness posture, the local agencies have agreed to a testing frequency for the system (by sounding the sirens) periodically that meets or exceeds FEMA guidance. Reports of inoperable equipment are provided to EP-designated maintenance personnel. The goal of the testing and maintenance program is to identify inoperable equipment in a timely manner and to restore equipment to a functional status commensurate with FEMA operability requirements as referenced in FEMA-REP-10, "Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants" Section E.6.2.1. In addition to this routine test and repair program, preventive maintenance of the ANS will be performed on an annual basis.

The ANS Design Report (Appendix 8 of this plan) provides the details of this controlled document.

7. Messages to the Public The state has developed EAS messages for the public consistent with the classification scheme. These draft messages are included as part of the South Carolina Operational Radiological Emergency Response Plan and contain instructions with regard to specific protective actions to be taken by occupants and visitors of affected areas. Messages may include instructions such as: take shelter and go indoors, close windows and doors, turn off ventilation systems; directions given for evacuation; directions to stay tuned to specific stations for further information, ad hoc respiratory protection, (e.g., handkerchief over mouth, etc.). VCSNS will provide support for the content of these messages when requested. The state and/or the counties control the distribution of radio protective drugs to the general public.

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Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station Section F: Emergency Communications This section describes the provisions used for prompt communications among principal EROs, communications with the ERO, and communications with the general public.

1. Communications/Notifications SCE&G has extensive and reliable communication systems installed at VCSNS. Examples of the communications network include systems such as normal and dedicated telephone lines on landlines, fiber-optic voice channels, cell phones, satellite phones, mobile radio units, portable radios, and computer peripherals. This network provides:

" Voice communication through normal telephone, dedicated line, and automatic ring-down between selected facilities, conference call capability, speaker phones, and operator assistance, where required. In addition, there are satellite phone and cell phone capabilities to maintain communication links to the emergency response facilities and offsite authorities.

• Communications between emergency vehicles and appropriate fixed locations, as well as with state mobile units and fixed locations

• Facsimile, computer network, and modem transmission Figure F-1 depicts the initial notification paths and the organizational titles from the VCSNS Emergency Response Facilities (ERFs) to federal, state, and county EROs, and industry support agencies. The primary and alternate methods of communication, and the NRC communications network, are illustrated on Figures F-2 and F-3.

a. VCSNS maintains the capability to make initial notifications to the designated offsite agencies on a 24-hour-per-day basis. The offsite notification system, referred to as the Emergency Management Network (EMNet), provides communications to state and county warning points and EOCs from the Control Room, TSC, and the EOF. Backup methods include facsimile, commercial telephone lines, radios, and internet. State and county warning points are continuously staffed.

b-d. VCSNS has established several communication systems that ensure reliable and timely exchange of information necessary to provide effective command and control over any emergency response (1) between the station and state and county agencies within the EPZs, (2) with federal EROs, (3) between the station, the EOF, and the state and county EOCs, and (4) between ERFs and Field Monitoring Teams. A general description of the systems is as follows:

1) Private Branch Exchanqe (PBX) Telephone System: The PBX telephone system provides communication capability between telephones located within the VCSNS facilities through direct dialing. The PBX is used to connect the Control Room, TSC, OSC, and the EOF. The PBX telephone system also provides for outside communications through interconnections with the corporate fiber optic telephone communications system and commercial telephone systems.

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2) EMNet: The EMNet is a dedicated commercial communications system that has been installed for the purpose of notifying state and county authorities of declared emergencies at VCSNS. This system links together the VCSNS Control Room, EOF, TSC, and state and county authorities as appropriate.

3) Local Commercial Telephone System: This system provides standard commercial telephone service through the public infrastructure, consisting of central offices and the wire line carrier. The commercial telephone system includes connections to PBX, emergency telephone system, dedicated lines to emergency facilities, and lines to the JIC. The commercial vendor provides primary and secondary power for their lines at their central office.

4) ERDS: As prescribed by 10 CFR 50 Appendix E.VI, ERDS will supply the NRC with selected plant data points on a near real time basis. ERDS is activated by the ERO as soon as possible but not later than one hour after declaration of an Alert, Site Area Emergency, or General Emergency. The selected data points are transmitted via modem or a Virtual Private Network (VPN) to the NRC at approximately 1-minute intervals. The ERO has backup methods available to provide required information to the NRC in the event that ERDS is inoperable during the declared emergency.

5) Field Monitoring Team Communications: A separate radio communications channel has been installed to allow coordinated environmental monitoring and assessment during an emergency. This system consists of the necessary hardware to allow radio communication between the Control Room, EOF, and mobile units in VCSNS vehicles. Commercial cell phones, satellite phones, or other means are available as backup to the primary field team communications system.

6) Satellite Telephones: Satellite telephones are provided to the Control Room, the TSC, and the EOF providing a backup communication link in the event that the landlines are rendered inoperative. These units are equipped with outside antennae to permit the use of the communications device inside the facilities.

7) 800 MHz Radio: This radio system is an 800 MHz SCANA Corporation system that is divided into trunks which are used by corporation subsidiaries. The trunk system at VCSNS is comprised of channels for Maintenance, Operations, Health Physics, Field Monitoring Teams, etc to allow a means of communications between facility personnel and field personnel for routine work and emergency conditions. The system utilizes both base stations and remote units in conjunction with associated cabling, repeaters, and antennas to provide optimum coverage for two-way continuous transmission.

8) SCE&G Fiber Optic System: The fiber optic system connects South Carolina Electric and Gas Company's main office in Cayce, South Carolina with the Summer Complex which includes V.C. Summer Nuclear Station, Fairfield Pump Storage Unit, Parr Steam and Hydro Unit and the New Nuclear Deployment Building.

Summer Station is the hub for this system. The system contains 72 fiber optic channels.

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9) Main & Fuel Handling Page System (Gaitronics): This system of networked phone stations and speakers strategically located throughout the station. Each phone station contains a telephone type receiver-transmitter handset, and channel selector switches. The system is equipped with an alarm encoder for alerting personnel through a series of designated tones. The Fuel Handling Page System is Line 5 on the Main Page System is only available in areas with fuel handling capabilities.

10) Redundant Paging System: This independent system of networked phone stations and speakers strategically located in areas of the station involved in the process of Engineered Safety Features shutdown. The system contains its own phone stations, power supplies, line balance equipment, and cable system. The system is distinguished by its red color.

11) Maintenance Jack System: The Maintenance Communication system consists of a network of strategically located jack stations. Each jack station has four separately wired receptacles mounted on it, providing four independent communications channels. Several headsets, each consisting of a padded earphone type receiver and a boom-mounted noise-canceling microphone are provided for hands-free operation of the system. Each headset is equipped with a belt clip amplifier and 30 feet of cable.

12) In addition, station communication links exist to ensure appropriate information transfer capabilities during an emergency. The station may also use its video conferencing systems, computer network connections, wireless telephones, or station radios to augment its emergency communications.

e. ERO Notification System: VCSNS uses an automated ERO Notification System that employs an automatic telephone system to rapidly notify members of the ERO.

Procedures specify the course of action to be taken if the ERO Notification System fails.

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f. NRC Communications (ENS and HPN): Communications with the NRC Operations Center will be performed via the NRC ENS and the HPN circuits or commercial and satellite telephone lines. Information is normally communicated to the NRC in accordance with NL-122, Regulatory Notification and Reporting, before establishing an open ENS and/or HPN line.

Installation and use of these NRC telephones is under the direction of the NRC (see Figure F-3).

Emergency Notification System: Dedicated telephone equipment is in place between the Control Room and the NRC, with an extension of that line in the TSC. A separate line is available in the EOF with the capability of being patched with the station through the NRC. This line is used for NRC event notifications and status updates. Backup power is provided for these lines.

HPN: There also exists a separate dedicated telephone between the NRC, the TSC, and the EOF for conveying health physics information to the NRC as requested or as an open communication line. Backup power is provided for these lines.

2. Medical Communications Communications are established with the primary medical hospitals and transportation services via commercial telephone that is accessed by VCSNS personnel.

3. Communications Testing Communications equipment is checked in accordance with Section N.2, Drills, between VCSNS and state and county government facilities are conducted in accordance with Section N.2.a. In addition, minimum siren testing is performed as follows:

Silent Test At least biweekly Growl (or Equipment) Test Quarterly and following preventive maintenance Full Volume Test Annually

4. Plant Alarms In conjunction with the Main Plant Page System, the site has audible (pulse, wale, warble, steady, etc.) alarms used to alert site personnel to and unsafe or emergency conditions.

The alarms include a Reactor Building Evacuation Alarm, Radiation Emergency/Site Evacuation Alarm, and Fire Alarm. Activation of these alarms is done from the Control Room.

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Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station Control Room State Warning (Shift Supervisor) Points/EOC and County Warning Initial Points/EOCs IN (Dispatcher/Comm)

NRC Headquarters NRC Region (Duty Officer) (Duty Officer)

(State/County Comm) Commercial (As appropriate) ANIZI LILPOI State Warning Updates Points/EOC and County Warning Points/EOCs (Dispatcher/Comm)

Figure F-I: Notification Scheme (After Full Augmentation)

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Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station Control Room " -- *-

A OSC B C F TSC -----------

D EOF E

JIC

• --Dedicated Phone Link (Independent or Limited PBX) 4--- Station Telephone Line (PBX or Commercial)

A = Dedicated phone link to dispatch OSC teams between the OSC, TSC, and Control Room.

B = Dedicated phone link for use by the ECO or OEC, ED, and Shift Supervisor between the Control Room, the TSC, and the EOF.

C = Dedicated phone link for transmission of technical data between the TSC, Control Room, and the EOF.

D = Dedicated phone link to discuss mitigating activities and priorities between the TSC and EOF.

E = Dedicated phone link to discuss changes in station or affected plant conditions and EPIO needs between the EOF and the JIC.

F = Station telephone line that is a communication link between activated facilities.

Figure F-2: ERF Communications Matrix Page 57 of 193 EP-100 Rev 64

Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station NRC ENS I HPN Headquarters Patch Figure F-3: NRC Communications for Nuclear Response Page 58 of 193 EP-100 Rev 64

Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station Section G: Public Education and Information This section describes the VCSNS public education and information program. It outlines the methods for distributing public information materials on an annual basis and describes how the public is informed in the event of an emergency.

1. Public Information Publication The state of South Carolina has overall responsibility for maintaining a continuing disaster preparedness public education program. The EPIO publication for the VCSNS is updated annually, in coordination with state and county agencies, to address how the general public is notified and what their actions should be in an emergency. SCE&G distributes the publication annually to all residents within the 10-mile plume exposure EPZ and to appropriate locations where a transient population may obtain a copy. The public information publication includes the following information:

a. Educational information on radiation

b. Information regarding who to contact for additional information

c. A description of possible protective measures for the public (take shelter, evacuate, and/or ingest a radioprotective drug)

d. A map of major evacuation routes

e. A list of reception centers to coordinate sheltering of evacuees and instructions on how to obtain additional information, especially for the disabled or their caretakers and those without transportation

2. Public Education Materials Public information publications instruct the public to go indoors and turn on their radios or televisions when they hear the ANS sirens operating. These publications also identify the local radio and television stations to which the public should tune in for information related to the emergency. Information is also provided to the transient population by means of signs at local business establishments and at the entrances to recreational areas around the VCSNS with instructions to be followed in the event of an emergency at VCSNS. A list of radio and television stations that will transmit emergency information is provided on the signs.

Telephone numbers where additional information can be obtained are also provided.

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3. Media Accommodations

a. The SCANA Public Affairs Group is notified when an Unusual Event or higher emergency condition exists. They will handle public and media inquires in the early stages of the event (until the JIC is activated) by distributing background information, news releases, and providing information to SCANA management.

1) The EPI Organization: The EPIO is part of the ERO. It may be activated at any time at the discretion of VCSNS management. However, when there is a procedural requirement to activate the EOF, the EPIO shall also be activated.

The primary purpose of the EPIO is to disseminate information from VCSNS's ERO about the emergency events to the public, via the news media. However, the authority for issuance of news releases for the classification of an Unusual Event or before to ERO activation will always reside with the SCANA Public Affairs Group.

Upon activation, the EPIO has the responsibility and authority for issuance of news releases to the public after the information gains the approval of the ECO/Company Spokesperson.

The EPIO is comprised of senior managers from SCANA who will function as spokespersons, and other individuals including personnel from VCSNS, the SCANA Governmental Affairs and Human Resources areas. SCANA's spokespersons disseminate information to the news media/public concerning the emergency events out of the JIC.

2) The Joint Information Center: The JIC is the facility in which media personnel gather to receive information related to the emergency event. The JIC is the location where approved news releases will be provided to the media for dissemination to the public. News releases are coordinated between the EOF and JIC personnel and state and/or federal representatives in the JIC. Public information personnel operate from the EOF and the JIC, which is under the direction of the ECO/Company Spokesperson and functions as the single point of contact to interface with federal, state, and local authorities who are responsible for disseminating information to the public.

VCSNS has a designated JIC co-located with the EOF. The JIC is equipped with appropriate seating, lighting, and visual aids to allow for public announcements and briefings to be given to the news media. Additionally, the JIC is equipped with commercial telephone lines for making outgoing calls. The EPIO functions from the JIC and EOF in preparing and releasing VCNS information regarding the emergency event. The JIC is activated at the discretion of the Emergency Control Officer in the EOF. Functions of the JIC include:

• Serving as the primary location for accumulating accurate and current information regarding the emergency conditions and writing news releases

" Providing work space and phones for public information personnel from the state, counties, NRC, FEMA, and industry-related organizations

• Providing responses to media inquiries through Media Monitoring Staff telephones that the media can call for information about an emergency Page 60 of 193 EP-100 Rev 64

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b. The news media is not permitted into the EOF during an emergency

4. Coordination of Public Information

a. The JIC is staffed by SCANA, VCSNS, and federal, state, and county government public information representatives who will be the source of public information during an emergency at the station. The ECO/Company Spokesperson is the primary spokesperson for SCANA. The ECO/Company Spokesperson has direct access to all necessary information (see Section B.5). All information will be coordinated before conducting news briefings.

b. Rumors or misinformation are identified during an emergency by the Media Monitors and Rumor Control Monitors. They respond to telephone calls from the public and the media, and monitor media reports.

5. Media Orientation Emergency Preparedness, in conjunction with SCANA Public Affairs Group, offers programs (at least annually) to acquaint news media with the Emergency Plan, information concerning radiation, and points of contact for release of public information in an emergency.

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Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station Section H: Emergency Facilities and Equipment Onsite and offsite facilities are available for emergency assessment, communications, first aid and medical care, and damage control. Of particular importance are the ERFs: the Control Room, TSC, OSC, EOF, and JIC.

This section describes the emergency facilities and equipment used by the ERO and outlines the requirements that aid in timely and accurate response actions. It also describes the surveillance programs used to monitor and ensure that these facilities and equipment are maintained in a high degree of constant readiness.

1. Control Room, Technical Support Center, and Operational Support Center VCSNS has established a TSC that is activated upon declaration of an Alert or higher classification. VCSNS has also established an OSC. Until they become operational, required functions of these facilities are performed by shift personnel and directed from the Control Room. These facilities may be activated at the discretion of the lED at an Unusual Event classification.

a. Control Room: The VCSNS reactor and major plant systems are operated from the Control Room. The Control Room is equipped with instrumentation to supply detailed information on the reactor and its major systems. The Control Room is continuously staffed with qualified licensed operators. The Control Room is the first onsite facility to become involved with the response to emergency events. The Control Room will be the designated location for the lED. Control Room personnel must evaluate and effect control over the emergency and initiate activities necessary for coping with the emergency until such time that augmented emergency response facilities can be activated. These activities shall include:

• Reactor and plant control

" Initial direction of all plant related operations

" Accident recognition, classification, mitigation, and initial corrective actions

• Alerting of onsite personnel

• Activation of the ERO notification system

• Activation of the ERFs

" Notification of offsite agencies

• Activation of ERDS

• Continuous evaluation of the magnitude and potential consequences of an incident

• Initial dose projections

• Recommendations for immediate protective actions for the public Page 62 of 193 EP-100 Rev 64

Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station As other ERFs become activated, they will provide support to the Control Room. Overall command and control of the emergency will transfer to the EOF when it is properly staffed and ready to take over these responsibilities. Throughout all emergencies, the Control Room maintains its emergency activation status until its normal operational status may be resumed or its recovery activities are initiated.

b. Technical Support Center: VCSNS has established a TSC for use during emergency situations by station management, technical, and engineering support personnel. The TSC is provided with communications links that can transmit and receive direct voice and data communications from the Control Room. These communications have alternate pathways that can also be used as needed. The TSC is activated for all emergencies classified as Alert or higher. Activation of this facility for other events is optional. When activated, the TSC functions include:

• Support for the Control Room's emergency response efforts

" Continued evaluation of event and classification of emergencies

• Assessment of the plant status and potential offsite impact

• Coordination of emergency response actions within the Protected Area

• Communication with the NRC via ENS

" Activation of the ERDS or ensuring that it is activated The TSC is the onsite location used to support the Control Room for assessment of plant status and potential offsite impact, and for implementation of emergency actions. The TSC provides technical data and information to the EOF.

Figure B-i b illustrates the staffing and organization of the TSC.

The TSC provides reliable voice communications to the Control Room, OSC, EOF, and NRC. In addition, it provides facsimile transmissions capability and electronic transfer capabilities (see Section F).

The TSC is sized to accommodate a minimum of 25 personnel and their supporting equipment. This includes provisions for NRC representatives.

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Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station Personnel in the TSC shall be protected from radiological hazards, including direct radiation and airborne contaminants under accident conditions with similar radiological habitability as Control Room personnel. To ensure adequate radiological protection, periodic radiation surveys of the TSC are conducted. These systems indicate radiation dose rates and airborne radioactivity inside the TSC while in use. In addition, KI is available for use as required. In the event that the TSC becomes uninhabitable, implementing procedures will provide guidance on the transfer of duties and relocation of the staff until such time that the TSC staff is able to fulfill their duties as assigned.

The TSC has access to a complete set of as-built drawings and other records, including general arrangement diagrams, piping and instrument diagrams (P&IDs), and the 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 support of reactor operations, and for implementation of emergency procedures.

c. Operational Support Center: The OSC is the location to where the unit's support personnel report during an emergency and from which they will be dispatched for assignments or duties in support of emergency operations. The unit's OSC shall be activated whenever the TSC is activated, but need not remain activated at the Alert level if its use is judged unnecessary by the ED. At the Site Area Emergency and General Emergency levels, the unit's OSC or an alternate OSC shall be activated at all times.

Activation for other events is optional. VCSNS disciplines reporting to the OSC include, but are not limited to:

• Operating personnel not assigned to the Control Room

• Health Physics personnel

• Chemistry personnel

• Maintenance personnel (Mechanical, Electrical, and I&C)

Figure B-1 b illustrates the staffing and organization for the OSC The OSC is equipped with communication links to the Control Room and the TSC (see Section F). A limited inventory of supplies will be kept in the OSC or accessible to the OSC. This inventory will include respirators, protective clothing, flashlights, and portable survey instruments.

Refer to the Unit 1 Annex for additional information regarding the OSC.

A Back-up (Remote) OSC is included in the configuration and sizing of the Joint Information Center Building which also houses the EOF. The Back-up OSC includes a designated command area, work areas for OSC groups, and staging areas (break room/kitchen) for OSC Damage Control personnel.

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2. Emergency Operations Facility The EOF is the location where the ECO will direct a staff in evaluating and coordinating the overall company activities involved with an emergency. Activation of the EOF is mandatory upon declaration of a Site Area Emergency or higher classification. The EOF is located in Richland County near the intersection of Bickley Road and SC Hwy 176 and is outside the 10 Mile Emergency Planning Zone and greater than 10 miles from the Technical Support Center (TSC). The EOF provides for:

• Management of overall emergency response

• Performance of the non-delegable emergency notification and PAR development and notification functions when in command and control

• Notification of appropriate corporate and station management

• Coordination of offsite radiological and environmental assessments

• Determination of recommended public protective actions

• Management of recovery operations from an Alert or higher classification

" Coordination of emergency response activities with federal, state, and county agencies The EOF was designed with the following considerations:

• The EOF is provided with access limiting devices when not in use and assigned security personnel during activation to ensure that only authorized personnel are permitted to enter the facility.

• The location provides optimum functional and availability characteristics for carrying out overall strategic direction of VCSNS emergency and support operations, determination of public protective actions to be recommended to offsite officials, and coordination with federal, state, and county agencies.

• It is of sufficient size to accommodate about 50 people including NRC representatives.

• It meets the criteria of NUREG-0696, "Functional Criteria for Emergency Response Facilities" regarding location, structure, habitability, size, communications, instrumentation, data system equipment, power supplies, technical data, records availability, and management. The EOF power is backed with an emergency diesel generator and has an uninterruptable power source to maintain loads during the transfer between power sources.

• It is equipped with reliable voice communications capabilities to the TSC, the Control Room, the NRC, and the state and county EOCs. In addition, the EOF has facsimile, computer transmission, and electronic transfer capabilities.

• Equipment is provided to gather, store, and display data needed in the EOF to analyze and exchange information on plant conditions with the station. 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 condition.

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• The EOF has ready access (either through hard copies or electronic media) to plant records, procedures, and emergency plans needed for effective overall management of VCSNS emergency response resources.

" It is designed to support a remote TSC and remote OSC in the event of an emergency which limits access to the site.

3. Joint Information Center The JIC is the location where the Company Spokesperson will direct a staff in providing and coordinating the release of information during an emergency. The JIC is co-located with the EOF outside the 10-mile EPZ. The JIC provides facilities and equipment for VCSNS, federal, state, and county agencies to interface with each other and to provide a location where information regarding the event is released to the media and general public.

4. Emergency Operations Centers EOCs operated by the state and county communities have been established to perform direction and control of emergency response functions, as outlined in their respective plans.

The respective state EOC is capable of continuous (24-hour) operations for a protracted period. These centers contain sufficient communications (radio, telephone, and facsimile) equipment, maps, emergency plans, and status boards to provide the necessary interfaces with other federal, state, county, and station emergency facilities.

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 EOC. These EOCs have the equipment necessary, (such as facsimile machines, telecommunications equipment, radios, photocopiers, wall maps, etc.) to carry out their emergency responsibilities.

5. Activation NOTE: NUREG-0654 Criterion ll.B.5 states that the "licensee must be able to augment on-shift capabilities within a short period after declaration of an emergency." It further defines that short period as 30 and about 60 minutes. VCSNS will adequately staff its on-shift personnel to support the Control Room personnel upon declaration of an Alert or higher classification. This staffing will fulfill the NUREG-0654 Criterion ll.B.5 for 30-minute responders and provides additional support to the On-shift ERO to permit a 60 minute response for on-call ERO personnel. The time frames for rapid augmentation of a nuclear power plant staff in the event of an emergency are not rigid inviolate requirements but rather goals. It is VCSNS's intent to expend its best efforts to meet the augmentation criteria goals regarding staffing Emergency Response Facilities with sufficiently skilled individuals capable of handling an emergency. Both the NRC and VCSNS realize that due to diversity of normal residential patterns for the stations' staff, possible adverse weather conditions and road congestion, these time frames might be exceeded.

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Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station VCSNS has put into place plans and procedures to ensure timely activation of its ERFs. The Shift Supervisor (as lED) will initiate a call-out in accordance with the emergency planning procedures. The ERO augmentation process identifies individuals who are capable of fulfilling the specific response functions that are listed in Table B-la. This table was developed based on the functions listed in NUREG-0654, Table B-I.

Although the response time will vary due to factors such as weather and traffic conditions, a goal of about 60 minutes for minimum staffing, has been established for the ERO personnel responding to the station onsite emergency facilities, following the declaration of an Alert or higher emergency classification, and to the EOF following the declaration of a Site Area Emergency or higher emergency classification. Additionally, plans have been developed to ensure timely functional activation and staffing of the JIC when the classification of Site Area Emergency is declared.

It is the goal of the organization to be capable of activating the applicable ERF within 15 minutes of achieving minimum staffing. The facility can be declared activated when the following conditions are met:

a. Minimum staffing has been achieved

b. The facility is functionally capable of performing the appropriate activity Although the minimum staffing criteria applies to the JIC, the 60-minute response time and 15-minute activation times are not applicable. Public Information personnel must first coordinate the decision to activate the JIC with the appropriate offsite authorities responding to the facility.

The senior manager in charge may elect to activate their facility without meeting minimum staffing if it has been determined that sufficient personnel are available to fully respond to the specific event (this would not constitute a successful minimum staff response).

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6. Monitoring Equipment Onsite The station is equipped with instrumentation for seismic monitoring, radiation monitoring, fire protection, and meteorological monitoring. Instrumentation for the detection or analysis of emergency conditions is maintained in accordance with station Technical Specifications, if applicable or commitments made to the NRC. The actual instrumentation will not be described in detail in this plan. Additional details, if required, of the equipment will appear in the Unit 1 Annex. This equipment includes, but is not limited to, the following:

a. Geophysical Monitors

1) Meteorological Instrumentation: There are two permanent meteorological monitoring stations located near the station for display and recording of wind speed, wind direction, and ambient and differential temperature for use in making offsite dose projections. Meteorological information is presented in the Control Room, TSC, and EOF by means of the plant computer system. This information is remotely interrogated using a computer or other data access terminal.

With regard to VCSNS's meteorological monitoring program, since the meteorological facilities are not composed of structures, systems, and components that prevent or mitigate the consequences of postulated accidents and are not "safety-related," those aspects of quality assurance germane to providing good meteorological information for a nuclear power station were adopted into the Quality Assurance Program Description (QAPD).

The NWS, or regional weather forecast providers, may be contacted during severe weather periods. These providers analyze national and local weather in order to provide localized weather forecasts for the VCSNS area, as appropriate.

2) Seismic Monitoring: The seismic monitoring system measures and records the acceleration (earthquake ground motion) of the structure. Earthquakes produce low frequency accelerations which, when detected by the remote sensing devices, are permanently recorded as information which defines the response spectrum. The system remains in a standby condition until an earthquake causes the remote unit(s) to activate the recording circuits and tape transports. It also provides signals for immediate remote indication that specific preset response accelerations have been exceeded.

3) Hydrological Monitors: The design basis flood, probable maximum precipitation, and other improbable, conceivable extremes in hydrologic natural phenomena are well below any design limits for the unit as detailed in their FSAR. Hence, there are no specific, dedicated hydrological monitors.

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b. Radiological Monitors and Sampling

1) The RMS: In-plant radiological measurements provide information that may help determine the nature, extent, and source of emergency conditions. The RMS is available to give early warning of a possible emergency and provides for a continuing evaluation of the situation in the Control Room. Radiation monitoring instruments are located at selected areas within the facility 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. Certain radiation monitoring instruments also alarm locally in selected areas of the facility. The RMS is divided into 3 subsystems:

a) Area Radiation Monitors are used for the direct measurement of in-plant exposure rates. The area radiation monitor readings allow in-plant exposure rate determinations to be made remotely without requiring local hand-held meter surveys. This information may be used, initially, to aid in the determination of plant area accessibility. In addition to permanent monitors, portable continuous air monitors measure airborne particulate and airborne iodine activities at various locations within the operating areas.

b) Process radiation monitors are used for the measurement of radioactive noble gas, iodine, and particulate concentrations in plant effluent and other gaseous and fluid streams.

c) The accident, or high range, RMS monitors radiation levels at various locations within the operating area. These are high range instruments used to track radiation levels under accident or post-accident conditions. These instruments include the containment monitors.

The RMS provides the necessary activity or radiation levels required for determining source terms in dose projection procedures. Key RMS data is linked to the plant computer, which allows information to be passed to the TSC and EOF. The isotopic mix, including isotopes such as those in Table 3 of NUREG-0654, is based upon a default accident mix. Refer to the unit-specific FSAR for further detail on the RMS capabilities and design.

2) Liquid and Gaseous Samplinq 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.

The sampling systems use a number of manual sampling techniques to enable reactor coolant and containment sampling operations over a wide range of plant conditions. They are 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 FSAR for further detail on sampling capabilities.

3) Portable Radiation Monitoringq Equipment: Portable radiation survey instruments are available for a wide variety uses such as area, sample, and personnel surveys and continued accident assessment. Instruments are stored throughout the plant and in the emergency facilities.

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c. Process Monitors: The Control Room and applicable redundant backup locations are equipped with extensive plant process monitors for use in both normal and emergency conditions. These indications include but are not limited to reactor coolant system pressure and temperature, containment pressure and temperature, liquid levels, flow rates, status or lineup of equipment components. This instrumentation provides the basis for initiation of corrective actions.

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, conduct reasonability 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. Scanned variables are quality tagged. The system provides for short and midterm storage of data for online retrieval and fast recall, and long-term storage to appropriate media.

2) Safety Parameter Display System (SPDS): SPDS provides a reliable display of plant parameters from which the safety status of operation may be assessed in the Control Room, TSC, and EOF for the station. The primary function of the SPDS is to help operating personnel in the Control Room make quick assessments of plant safety status. SPDS and/or other display systems in the TSC and EOF promote the exchange of information between these facilities and the Control Room and assists the emergency organization in the decision making process. It also provides data trending information regarding current and past status of the unit.

d. Fire Detection System: The fire detection system is designed to quickly detect visible or invisible smoke (or other products of combustion) and/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 nuclear incident or other emergency conditions. Existing plant alarm systems are sufficiently audible to alert personnel in the event of a fire or need for assembly. These alarm communication systems consist of warning sirens and lights (in high noise areas) and the PA system. Refer to the FSAR for further description of the unit's fire protection system.

7. Monitoring Equipment Offsite VCSNS has made provisions to acquire data from and have access to the following offsite sources of monitoring and analysis equipment:

a. Geophysical Monitors: In the event that both onsite meteorological towers or monitoring instrumentation becomes inoperative, meteorological data may be obtained directly from the NWS or the internet.

A South Carolina State Network (SCSN) seismometer is located about 3.2 miles east-southeast of the VCSNS Unit 1. This seismometer near Jenkinsville has been operational since November 1973, and is monitored by the University of South Carolina.

The SCSN seismometer provides background information relative to seismic activity in the area, including confirmation of earthquake occurrences and magnitudes.

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Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station In addition, a central point of contact is the National Earthquake Information Service in Golden, Colorado to obtain information about a seismic event.

The EOF will coordinate hydrology and seismology expertise in the event onsite information becomes unavailable.

b. Radiological Environmental Monitors and Sampling: The state of South Carolina DHEC will conduct an extensive offsite environmental monitoring program to provide data on measurable levels of radiation and radioactive materials in the environs.

VCSNS also maintains an offsite environmental monitoring program as well. The program is described fully in the Offsite Dose Calculation Manual and includes:

• Fixed continuous air samplers

• Routine sampling of river water, milk, and fish

• A fixed thermo luminescent dosimeter (TLD) monitoring network The TLD program consists of the following elements:

• A near-site ring of dosimeters covering the 16 meteorological sectors

• A 16-sector ring of dosimeters placed in a zone within about 5 miles from the plant

• TLDs placed at each of the normal fixed air sampler locations (typically about 8-15 air samplers)

c. Laboratory Facilities: External facilities for counting and analyzing samples can be provided by the other nuclear stations in the area. These laboratories can act as backup facilities in the event that the station's counting room and laboratory become unusable or the offsite radiological monitoring and environmental sampling operation exceeds the capacity of the station capabilities during an emergency. It is estimated that these laboratories will be able to respond within several hours from initial notification.

Outside analytical assistance may be requested from state and federal agencies, or through contracted vendors. The state maintains a radiological laboratory that provides independent analysis. The DOE, through the Interagency Radiological Assistance Program has access to any national laboratory with DOE contract (i.e., Savannah River Site, Brookhaven, Oak Ridge, Lawrence Livermore, etc.).

A general description of the laboratory capabilities is provided in Section C.3.

8. Offsite Monitoring Equipment Storage VCSNS maintains a sufficient supply of emergency equipment (such as portable survey, counting, and air sampling instrumentation and other radiological monitoring equipment and supplies) that may be used for environmental monitoring. These supplies meet the initial requirements of two environmental Field Monitoring Teams. During subsequent phases of an emergency, additional equipment is available from other utility or state Field Monitoring Teams, INPO mutual aid, and offsite response organizations.

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9. Meteorological Monitoring The station has installed and maintains two meteorological towers equipped with instrumentation for continuous reading of the wind speed, wind direction, air temperature, and vertical temperature difference (AT). Additional capabilities are available to obtain representative current meteorological information from other sources, such as the NWS. A full description of the onsite meteorological capabilities is given in Section 4 of the Unit 1 Annex.

10. OSC Capabilities The OSC provides an area for coordinating and planning of OSC activities and the staging of personnel. Additional space is available in adjacent offices and locker rooms to accommodate additional personnel as may be required. Alternate locations are available.

The onsite storerooms maintain a supply of parts and equipment for normal plant maintenance. These parts, supplies, and equipment are available for damage control use as necessary.

Sufficient radiation protection equipment (i.e., protective clothing, respiratory protection gear, KI, and other health physics equipment and supplies) is stored and maintained near the OSC (as well as the other ERFs). Damage control team equipment is available in the maintenance shops which are near the OSC. This equipment may include items such as a camera, portable lighting, and additional portable communications equipment. The areas near the OSC are stocked with an assortment of first aid and medical treatment equipment and supplies. The OSC maintains reliable voice communications with the Control Room, TSC, and EOF. For a description of communications equipment, refer to Section F.

11. Facility and Equipment Readiness Emergency facilities and equipment are inspected and inventoried in accordance with emergency preparedness procedures. 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 actual emergency or drill. During this inventory, radiation monitoring equipment is checked to verify that required calibration period and location are in accordance with the inventory lists.

Surveillances include an operational check of instruments and equipment. Equipment, supplies, and parts which have a shelf-life are identified, checked, and replaced as necessary. Sufficient reserves of instruments and equipment are maintained to replace those which are removed from emergency kits or lockers for calibration or repair.

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12. Emergency Equipment and Supplies Below is a list of typical equipment and supplies dedicated for emergency use in the VCSNS ERFs. Refer to Emergency Equipment Checklist Procedure for specific equipment and supplies found in the various locations:

Control Room

" Emergency Plan Implementing Procedures

• Drawings of Facility and Plant Site

• Self-Contained Breathing Apparatus

• Portable radios

• Telephone (landlines, cellular, and satellite)

• Dose Assessment Computer

• Potassium Iodide (KI) (provided by the TSC)

Operational Support Center

• Emergency Plan Implementing Procedures

• Telephones and Portable Radios

• Flashlights w/batteries

• Portable Survey Meters

• Dosimetry (TLDs and Self-Reading Dosimeters) 0 Portable Air Sampler 0 Air Sampler Filter paper 0 Silver Zeolite cartridges 0 Potassium Iodide (KI)

• 800 MHz Radio Technical Support Center

• Telephones

" Flashlights w/batteries

" Emergency Plan Implementing Procedures

• Graphs, Overlays, and Maps

" Drawings of Facility and Plant Site

" Potassium Iodide (KI)

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" Dose Assessment Computer

" Telephones

• Flashlights w/batteries

" Emergency Plan Implementing Procedures

• Graphs, Overlays, and Maps

• Drawings of Facility and Plant Site Joint Information Center

• Telephones

• Flashlights w/batteries

" Emergency Plan Implementing Procedures

• Graphics, Overlays, and Maps

" Graphics of Facility and Plant Site

" Media Monitoring devices

13. General Use Emergency Equipment Inventory procedures identify the equipment that comprise the kits used in an emergency situation that are available within each emergency facility.

14. Collection Point for Field Samples The environmental lab in the New Nuclear Deployment (NND) Building has been designated as the central point for the receipt and analysis of radiological field monitoring samples.

Sampling and analysis equipment is available for activity determination of these samples.

Sufficient field monitoring equipment is maintained at the station for initial sampling.

Instrumentation and equipment used for sample activity determination are routinely calibrated to ensure timely availability.

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Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station Section 1: Accident Assessment To effectively coordinate and direct all facets of the response to an emergency situation, diligent accident assessment efforts are required throughout the emergency. All four emergency classifications have similar assessment methods; however, each classification requires a greater magnitude of assessment effort dependent upon the plant symptoms and/or initiating event(s).

1. Plant Parameters and Corresponding Emergency Classification Plant system and effluent parameter values are used 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 the emergency implementing procedures. Specific plant system and effluent parameters that characterize a classifiable event (EALs) are presented in the Unit 1 Annex.

In order to adequately assess the emergency condition, each emergency facility has the necessary equipment and instrumentation installed to make available essential plant information on a continuous basis. Evaluation of plant conditions is accomplished through the monitoring of plant parameters both from indication in the Control Room and within the plant. Some of the more important plant parameters to be monitored in the Control Room are assembled into a single display location, which is entitled the SPDS. The SPDS monitors such parameters relative to the plant design such as: reactor coolant system pressure, reactor or pressurizer water level, containment pressure, reactor power, safety system status, containment radiation level and effluent monitor readings. The instrumentation and equipment capabilities available for each emergency facility are described in Section H.

2. Onsite Accident Assessment Capabilities 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 RMSs, and Accident RMSs (which includes the high range containment radiation monitors). Descriptions of these systems are given in Section H.6.b.

3. Source Term Determination Source term (or core damage) estimations serve several roles within the VCSNS Emergency Preparedness Program. For planning purposes, core damage considerations are used as the bases for several of the EAL ICs and as the threshold for the declaration of a General Emergency (the definition of a General Emergency specifies conditions which involve 'substantial' core degradation or melting as one of the bases for classification).

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Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station From an implementation perspective, core damage estimations provide a means of realistically differentiating between the four core states (no damage, clad failure, fuel melt, and vessel melt-through) to:

• Evaluate the status of the fuel barriers and how their status relates to the risks and possible consequences of the accident

• Provide input on core configuration for prioritization of mitigating activities

• Determine the potential quality (type) and/or quantity (%) of source term available for release in support of projected offsite doses and PARs

" Provide information that quantifies the severity of an accident in terms that can be readily understood and visualized

" Support the determination of radiological protective actions that should be considered for long term recovery activities The assessment methodologies used by VCSNS are intended to provide a rapid best estimate of core damage which, when evaluated together, help to develop an overall picture of the extent of core damage. The methods used to estimate the amount or type of core damage occurring under accident conditions includes the following:

" Containment Radiation Monitors: An indirect method used to determine the amount of core damage. Applicable to loss of coolant accident (LOCA) scenarios. Based on an end-of-life source term and static nuclide ratio assumptions yielding a limited accuracy. Valid any time following an accident.

• Core Temperatures: Methods such as core exit thermocouple, peak core temperatures, and hot leg temperatures provide indirect methods used to indicate the type and/or amount of core damage. Applicable for all types of accidents. Valid any time following an accident.

• Core Uncovery: Methods such as core uncovery time, reactor vessel level, and source range monitor count rate provide indirect methods used to indicate the type of core damage (clad failure or fuel melt). Applicable for all types of accidents. Provides a relatively accurate estimate of the state of the core early in the event. Valid any time following an accident.

" Containment Hydrocqen Concentration: An indirect method used to establish the type of core damage. Applicable to LOCA-type accidents where all the Hydrogen generated by the metal-water reaction is released into containment. Valid any time following an accident.

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• Sample Analysis - Isotopic Ratio Comparison: A direct method used to establish the type of core damage. Compares expected isotopic ratios with a sample to determine a general core state. Applicable under all types of accidents. Valid any time following an accident.

" Sample Analysis - Presence of Abnormal Isotopes: A direct method used to provide a go/no-go indication of fuel melt by the presence of unusually high concentrations of the less volatile fission products. Applicable under all types of accidents. Valid any time following an accident.

• Sample Analysis - Concentration Evaluation: A direct method that yields the most accurate numerical estimations of the amount of core damage. Applicable for all types of accidents. Requires the sampled system(s) be in a steady state that usually prevents its use until the plant is in a stable condition.

4. Effluent Monitor Data and Dose Projection Dose assessment or projection represents the calculation of an accumulated dose at some time in the future if current or projected conditions continue. During an accident, the plant parameter display system and personal computers will provide the ERO with the timely information required to make decisions. Radiological and meteorological instrumentation readings are used to project dose rates at predetermined distances from the Station, and to determine the integrated dose received. Dose assessment methods used by the ERO to project offsite doses include:

a. Monitored Release Points: This method uses the plant's effluent radiation monitors and system flow rates. Effluent release points are used to directly calculate a release rate.

The point of the release determines the way the source term is affected and is adjusted by the dose assessment process.

b. Containment Leakage/Failure: This method uses a variety of containment failures or leak rates in conjunction with available source term estimations to develop a release rate to the environment. A direct vent of containment can be modeled as a failure to isolate.

c. Release Point Samples: This method uses a sample at the release point and an estimated flow rate to develop a release rate at the point of release.

d. Field Monitoring Team Data: This method uses a field survey or sample and the atmospheric model to back calculate a release rate and ratio concentrations of radioactive material at various points up and downwind of plume centerline.

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Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station The computer applications used to provide dose calculations are evaluated against the EPA-400 plume exposure PAGs applicable for the early phase of an accident. These evaluations place an emphasis on determining the necessity for offsite PARs. Dose assessment actions will be performed in the following sequence:

First: Onset of a release to one hour post-accident: Shift personnel will rely on a simplified computerized dose model to assist them in developing offsite dose projections using real time data from effluent monitors and site meteorology.

Second: One hour post-accident to event termination: Estimates of offsite doses based on more sophisticated techniques are provided. Dedicated ERO personnel will analyze the offsite consequences of a release using more complex computerized dose modeling. These additional methods are able to analyze more offsite conditions than the simplified quick method, as well account for more specific source term considerations.

5. Meteorological Information Local meteorological data is available from the onsite meteorological towers. The data available includes wind speed, wind direction, temperature, and vertical temperature difference (AT). This data is used by VCSNS, the state, and NRC to provide near real-time predictions of the atmospheric effluent transport and diffusion. Meteorological data from the tower are available in the Control Room, TSC, and EOF. A full description of the onsite meteorological capabilities is given in Section 4 of the Unit 1 Annex.

6. Unmonitored Release Dose projections can be made during a release through use of actual sample data in situations where effluent monitors are either off-scale or inoperative or the release occurs by an unmonitored flow path. In the absence of effluent sample data, a dose projection can be performed simply 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.

7. Field Monitoring In addition to the capabilities and resources described in Section H.7.b and H.8, VCSNS maintains the ability to take offsite air samples and to directly measure gamma dose rates in the event of an airborne or liquid release. The capability to take offsite soil, water, and vegetation samples is also provided by either the Field Teams or South Carolina Department of Health and Environmental Control (SCDHEC) Teams.

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 Field Teams. Samples are taken at predetermined locations as well as those specified both during and after a release.

Environmental measurements are used as an aid in the determination and assessment of protective and recovery actions for the general public.

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

In addition to contamination and dose rate measurements, the change out of environmental TLDs can be performed. 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 program to enable prompt assessments of any subsequent releases from the plant.

The expertise necessary to conduct limited offsite environmental survey and sampling exist onsite 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day. A minimum of two offsite Field Teams are notified and activated at a Site Area Emergency or higher classification. Teams are composed of two individuals who are assembled at the New Nuclear Deployment Building to use dedicated survey and sampling equipment. Teams are then dispatched in company vehicles into the surrounding area when a release is ongoing or is expected to occur. Radiological survey and sample data is transmitted to the emergency facilities. SCDHEC support can be used to perform collection, shipment, and analysis of environmental sample media.

9. Iodine Monitoring Field monitoring equipment has the capability to detect and measure airborne radioiodine concentrations as low as 1x10-7 pCi/cc in the field. Interference from the presence of noble gas and background radiation will be minimized by ensuring that monitoring teams move to areas of low background before analyzing the sample cartridge. The collected air sample is measured by hand-held survey meter as an initial check of the projection derived from plant data to determine if significant quantities of elemental iodine have actually been released (the chemical form that would pose a health hazard).

10. Dose Estimates Specific procedures exist for the correlation of air activity levels to dose rate for key isotopes. These procedures also provide a method to estimate the integrated dose from the projected and actual dose rates and for the comparison of these estimates with the PAGs.

11. State Monitoring Capabilities The state (SCDHEC) has the ability to dispatch their own field monitoring teams to track the airborne radioactive plume. The state also has the ability and resources to coordinate with federal and VCSNS monitoring teams to compare sample results.

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Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station 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/or station personnel. A range of protective actions has been developed for emergency workers and the general public in the plume exposure pathway EPZ. Additionally, guidelines have been established to aid in choosing protective actions during an emergency that are consistent with federal guidance. VCSNS is responsible for onsite actions, while the responsibility for offsite actions rests with the state, county, and other offsite response agencies.

1. Notification of Onsite Personnel For all emergency classifications, all personnel within the Owner Controlled Area (OCA) are notified of the initial classification or escalation of an emergency by recognizable alarms, and/or verbal announcements over the plant public address system. Announcements include the emergency classification and response actions to be taken by personnel onsite (such as ERO, non-ERO, contractor personnel, and visitors). Contractors and visitors will be provided information on how to respond in the event of an emergency. Provisions are made to alert personnel in high noise areas and outbuildings within the Protected Area as applicable.

The station has identified locations where people might be expected to be present outside the Protected Area but within the OCA. Accountability of persons within the OCA but outside the Protected Area is not required. However, provisions including public address system announcements, sirens, and security patrols are established for notification of personnel within the OCA any time a site evacuation has been initiated, or as otherwise deemed appropriate.

2. Evacuation Locations If a site evacuation is required, nonessential 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 offsite locations (Offsite Holding Areas). Visitors to the station will assemble with and follow the instructions of their escorts. Nonessential personnel within the Protected Area will normally exit through the normal access point. Personal transportation (if available) will normally be used and established evacuation routes will be followed. Personnel without transportation will be identified and provided transportation as necessary. Personnel needing transportation are instructed to request assistance from personnel evacuating the site. In the event that personal vehicles cannot be utilized for evacuation, the lED or ED will request offsite assistance to support personnel evacuation.

3. Radiological Monitoring of Evacuees Personnel evacuating the site will be monitored for contamination by the portal monitors as they exit the Protected Area, with portable friskers in assembly areas, or sent to offsite monitoring locations on an as needed basis. If there is no release of radioactive materials within the unit, limited monitoring may be used to speed the evacuation process.

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4. Protective Actions for Onsite Personnel Evacuation is the primary protective action anticipated for onsite personnel not having immediate emergency response assignments. The station has identified locations that serve as assembly areas and offsite locations (Offsite Holding Areas) for nonessential personnel when they are not instructed to proceed home. The specific locations of these areas are provided in the Unit 1 Annex. Implementing procedures describe equipment, supplies, and general operation of these facilities. The ED will designate personnel within the OCA as essential or nonessential. Evacuation of nonessential personnel is usually conducted immediately after accountability if a Site Area Emergency or General Emergency has been declared and conditions permit. Evacuation shall commence in accordance with VCSNS procedures as directed by the lED, ED, ECO or his/her designee, unless one of the following conditions exist:

a. Severe weather conditions threaten safe transport

b. A significant radiological hazard would be encountered

c. There is a security threat occurring that would have an adverse impact on the personnel while leaving the site

d. A condition similar to the above in magnitude, which in the opinion of the OEC would adversely affect the site personnel Security forces will be dispatched, when available, to access road(s) to control entry to site facilities. Unauthorized and non-ERO personnel will be denied entry.

The initiation of a site evacuation will be reported to the appropriate state and county agencies.

In the event that evacuation is not the best protective action, the onsite personnel will be directed to take other protective actions including: sheltering for extremely inclement weather or during an ongoing radiological release and take immediate cover for security events when evacuation will place personnel in jeopardy.

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5. Accountability The purpose of accountability is to determine the locations of all personnel inside the Protected Area and to muster emergency personnel at prearranged locations. When accountability of onsite personnel is determined to be necessary by the lED or the ED, all personnel within the Protected Area shall be accounted for and the names of missing individuals (if any) are determined within 30 minutes of the announcement. Should missing personnel be identified, search and rescue operations are initiated.

Accountability is usually performed in conjunction with assembly, and is required to be initiated whenever a Site Area Emergency or higher classification 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 severe weather or for security concerns.

If it is determined that the prearranged assembly area is unfit for personnel, the lED or the ED may designate an alternative assembly area and direct personnel using appropriate communication systems that are available.

Once established, accountability within the Protected Area is maintained throughout the course of the event, unless specifically terminated by the ED.

6. Provisions for Onsite Personnel VCSNS maintains an inventory of respiratory protection equipment, anti-contamination clothing, and KI that is made available to emergency workers remaining onsite should conditions warrant. During the course of an emergency, protective actions are considered to minimize radiological exposures or contamination problems associated with all onsite personnel. For those who must work within the restricted area of the affected unit, measures that are considered are:

a. Use of Respirators: On-shift and emergency response personnel use respiratory protection in any environment involving exposure to high level gaseous activity or oxygen deficient atmosphere, or where air quality is in doubt. In the presence of airborne particulates, emergency response personnel may be directed by Health Physics personnel to use full-face filter-type respirators. The criteria for issuance of respiratory protection are described in Radiation Protection procedures.

b. Use of Protective Clothing: Anti-contamination clothing, located in or near the OSC and station dress out areas is available for use by onsite personnel. The criteria for issuance of protective clothing are described in Radiation Protection procedures.

c. Use of Potassium Iodide (KI): The use of KI may be recommended when a projected dose of 25 Rem committed dose equivalent (CDE) is exceeded for an emergency worker's thyroid. This is the value specified in EPA 400-R-92-001, "Manual of Protective Action Guides and Protective Actions for Nuclear Incidents." The OSC and the TSC maintain a supply of KI. The Radiological Assessment Supervisor has the responsibility for approval of issuing KI to VCSNS onsite emergency workers.

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7. Mechanism for Implementing Protective Action Recommendations Plant conditions, projected dose and dose rates, and/or field monitoring data are evaluated to develop PARs for the purpose of preventing or minimizing exposure to the general public.

PARs are provided to the offsite agencies responsible for implementing protective actions for the general public within the 10-mile EPZ. PARs are approved by the ECO.

In an emergency that requires immediate protective actions be taken before activation of the offsite emergency facilities, PARs are provided directly to the state and county 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> warning points by the lED.

8. Evacuation Time Estimate An independent Evacuation Time Estimate Study has been performed to provide estimates of the time required to evacuate resident and transient populations surrounding the VCSNS site for various times of the year under favorable and adverse conditions. Evacuation Time Estimate for evacuation of the plume exposure EPZ is referenced in Appendix 5 and detailed in the referenced Evacuation Time Estimate Study.

9. Capability of Implementing Protective Action Recommendations The responsibility for implementing protective measures based on PAGs for the offsite population at risk is the responsibility of the state and county governments. Detailed procedures for public protective actions are contained in the state and county radiological emergency response plans as appropriate.

The state agencies are responsible for evaluation of VCSNS PARs and preparing a recommendation to the governor, or his/her appointed agent. The decision made and the order given based on the state agencies' recommendation becomes the Protective Action Directive (PAD) which is implemented by the offsite agencies. The counties within the 10-mile EPZ may make PADs prior to those of the governor when they determine the need to protect the health and safety of the public in their county.

If the plant conditions are stable and offsite radiological conditions are such that the public health and safety are not endangered, then return to evacuated areas may be discussed with the state. State authorities are responsible for actually recommending return and transmitting this recommendation.

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10. Implementation of Protective Action Recommendations The VCSNS, state, and county emergency plans used to implement the protective measures for the plume exposure pathway take numerous factors into consideration.

Among these considerations are:

a. Most of the public evacuees are expected to travel in their own vehicles, leaving the EPZ via designated evacuation routes. The state and county plans contain official maps and information on the locations of reception centers and shelters.

b. The population distribution around the station for the 10-mile radius is illustrated in Figure J-1. More details of populations can be found in the Evacuation Time Estimate, see Appendix 5 for revision details.

c. As indicated in Section E, offsite agencies are notified in the event the Emergency Plan is activated. State and county agencies have the capability to notify members of the transient and resident population within the plume exposure pathway EPZ.

d-l. Items addressed separately in state and county emergency plans.

m. At a General Emergency classification, VCSNS will provide the state and counties with PARs for the public. For incidents involving actual, potential, or imminent releases of radioactive material to the atmosphere, EPA 400-R-92-001, the NRC Response Technical Manual (RTM-96) and NUREG-0654, Supp. 3 are used as the basis for the general public PARs.

1) Plant-Based PARs Figure J-2 has been developed to aid VCSNS personnel providing PARs based on the above. Possible plant-based PARs issued at a General Emergency include:

• Shelter of the general public within a two mile radius and five miles downwind and institute KI policy (Impediment PAR)

• Evacuation of the general public within a two mile radius and five miles downwind, shelter from 5-10 miles downwind, and institute KI policy (Basic PAR)

" Evacuation of the general public within a two mile radius and ten miles downwind and institute KI policy (Rapidly Progressing Severe Accident PAR)

In addition to the above actions to minimize or prevent potential exposure to radiation, the state will issue a precautionary action for the remainder of the EPZ to monitor the Emergency Alerting Station(s) and prepare for a possible evacuation in accordance with the state emergency plans.

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2) Dose-Based PARs Evacuation is recommended if projected doses reach the minimum EPA PAGs (1 Rem TEDE or 5 Rem CDE thyroid).

Shelter is recommended if projected doses reach the minimum EPA PAGs (1 Rem TEDE or 5 Rem CDE Thyroid) AND there are impediments to evacuation.

Many assumptions exist in dose assessment calculations, involving both source term and meteorological factors, which make computer predictions over long distances suspect. However, in the event dose assessment results indicate the need to recommend actions beyond the outer EPZ boundaries, Field Teams are dispatched to downwind areas to verify the calculated exposure rates before issuing ad hoc PARs outside the EPZ.

Station personnel normally do not have the necessary information to determine whether off site conditions would require sheltering instead of evacuation. An effort to base PARs on external factors (such as road conditions, traffic/traffic control, weather, or offsite emergency response capabilities) is usually performed by the state.

11. Ingestion Pathway Protective Measures The responsibility for specifying protective measures to be used for the ingestion pathway rests with the states of South Carolina and North Carolina. These measures include the methods for protecting the public from consumption of contaminated water and foodstuffs.

12. Monitoring of Evacuees The state and county organizations have the capability to register and monitor evacuees at designated reception centers. This capability includes personnel and equipment capable of monitoring residents and transients evacuating from the plume exposure EPZ and arriving at the reception centers, in accordance with FEMA guidelines.

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E ESE 1745 Ring Total Population 0-2 mile 246 0-5 mile 1728 0-10 mile 12988 Figure J-1: Sector Population Distribution Page 86 of 193 EP-100 Rev 64

Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station Figure J-2: PAR Flowchart Page 87 of 193 EP-100 Rev 64

Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station Protective Action Recommendation Notes:

1. Rapidly Progressing Severe Accident (RPSA) is defined as:

I. This is the first Protective Action Recommendation (PAR) after a General Emergency has been declared, AND II. There is a loss of the containment barrier per the Emergency Action Levels (EAL),

AND Ill. Either of the following:

a. Greater than or equal to Containment High Range Area Radiation Monitor Potential Loss EAL Threshold (20% Clad Damage),

OR

b. A significant radiological release in an hour or less (as indicated by meeting the EAL Initiating Conditions for RG1.1, RG1.2, or RG1.3).

2. When the PAR is being made from the Control Room or the TSC, the only impediment considered should be a Hostile Action Based (HAB) event. When the PAR is being made from the Emergency Operations Facility (EOF), the impediments that will be considered are based on known information that is provided by the State and County liaisons and/or a HAB event.

3. PARs should only be expanded by identified changes in Dose Assessment. PARs are to be expanded to any Protective Action Zone (PAZ) that will exceed Protective Action Guidelines (PAGs - release of gaseous radioactivity resulting in offsite dose greater than 1,000 mrem TEDE or 5,000 mrem thyroid CDE). Expansion of PARs must include previously issued PARs. If an EPA PAG is exceeded or expected to be exceeded beyond 10 miles, then consider the need for PARs beyond 10 miles and discuss possible actions with the counties and/or state.

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Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station Section K: Radiological Exposure Control This section of the plan describes the means for controlling emergency worker radiological exposures during an emergency, as well as the measures that are used by VCSNS to provide necessary assistance to persons injured or exposed to radiation and/or radioactive materials.

Exposure guidelines in this section are consistent with EPA Emergency Worker and Lifesaving Activity PAGs described in EPA 400-R-92-001 (EPA-400).

1. Emergency Exposure Guidelines Being licensed by the NRC, VCSNS maintains personnel exposure control programs in accordance with 10 CFR 20 under normal operating conditions. The ED is assigned the non-delegable responsibility for authorizing personnel exposure levels under emergency conditions in compliance with EPA-400. In emergency situations, workers may receive exposure under a variety of circumstances in order to ensure the safety and protection of others and of valuable property. These exposures will be justified if the maximum risks or costs to others that are avoided by their actions outweigh the risks to which the workers are subjected. The Emergency Worker Dose Limits are as follows:

Dose Limit (Rem TEDE) Activity Condition Personnel should be kept within normal 10 0-5 All CFR 20 limits during bona fide emergencies, except as authorized for activities as indicated below 5-10 Protecting valuable property Lower dose not practicable 10-25 Lifesaving or protection of large Lower dose not practicable populations

> 25 Lifesaving or protection of large Only on a voluntary basis to persons fully populations aware of the risks involved Limit dose to the lens of the eye to 3 times the above values and doses to any other organ (including skin and body extremities) to 10 times the above values.

Whenever possible, the concurrence of the Radiological Assessment Supervisor should be secured before exposing individuals to dose equivalents beyond the EPA-400 lower limit.

2. Emergency Radiation Protection Program The Radiological Assessment Supervisor is the individual responsible for implementing the radiation protection actions during an emergency. Radiation protection guidelines include the following:

Volunteers over 45 years of age are considered first for any emergency response action requiring exposure greater than normal limits. Routine dose limits shall not be extended to emergency dose limits for declared pregnant individuals. As in the, case of normal occupational exposure, doses received under emergency conditions should be maintained as low as reasonably achievable.

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• Persons undertaking any emergency operation in which the dose will exceed 25 Rem TEDE should do so only on a voluntary basis and with full awareness of the risks involved including the numerical levels of dose at which acute effects of radiation will be incurred and numerical estimates of the risk of delayed effects.

" In the context of the emergency limits, exposure of workers that is incurred for the protection of large populations may be considered justified for situations in which the collective dose avoided by the emergency operation is significantly larger than that incurred by the workers involved.

• Exposure accountability is maintained and proper personnel radiological monitoring equipment is provided for all personnel during emergency conditions.

• Access to high radiation areas is only permitted with prior approval of the applicable Radiological Assessment Supervisor. Personnel are not allowed to enter known or potential high radiation areas unless their exposure has been properly evaluated.

• Periodic habitability surveys of emergency facilities are performed during an emergency. If the facility is determined to be uninhabitable, the facility is evacuated in order to prevent or minimize exposure to radiation and radioactive materials. Alternate assembly areas are established, as necessary, to relocate and monitor evacuated personnel.

3. Personnel Monitoring

a. Emergency workers will receive TLD badges and personal self-reading dosimeters capable of measuring expected exposures on a real time basis. The capability exists for the emergency processing of TLDs on a 24-hour per day basis, if necessary.

b. Emergency worker dose records are maintained by Health Physics (as appropriate) in accordance with the emergency and radiological protection procedures. Emergency workers are instructed to read their dosimeters frequently. TLDs may be processed with increased periodicity.

4. Non-V. C. Summer Personnel Exposure Authorization The responsibility for authorizing non-VCSNS emergency workers (i.e., state and local agency emergency workers) to receive exposures in excess of the EPA-400 General Public PAGs rests with the state and county organizations, except when such emergency workers are onsite. Authorization of exposures in excess of EPA General Public PAGs, in this latter instance, rests with the ED.

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5. Contamination and Decontamination During an emergency, the ED is responsible for preventing or minimizing personnel exposure to radioactive materials deposited on the ground or other surfaces inside the Protected Area. Special consideration should be given to setting up contamination control arrangements for personnel entering the OSC after completion of assigned activities. The OEC is responsible for preventing or minimizing personnel exposure to radioactive materials deposited on the ground or other surfaces beyond the Protected Area to the Owner Controlled Area. The OEC is also responsible for the VCSNS Field Team members that are assigned to track and sample the release plume.

a. During emergency conditions, normal plant contamination control criteria will be adhered to as much as possible. However, these limits may be modified by the ORMC in accordance with existing radiation protection procedures, should conditions warrant.

b. Contamination Control Means: Personnel found to be contaminated will normally be attended to at decontamination areas located onsite. The decontamination facility at VC Summer Unit 1 is located at the Radiation Control Area Control Point, elevation 412' of the Control Building. The decontamination facility consists of a men's and women's shower, toilet, locker room, and change areas. Temporary decontamination areas can also be set up inside at various locations. Decontamination showers and supplies are provided onsite with additional personnel decontamination equipment and capabilities.

Decontamination supplies will include soaps, shampoo, mild detergents, 3% Hydrogen Peroxide solutions, plastic bags, plastic suits, cotton swabs, oral hygiene products, and Saline solutions. Shower and sink drains in the Radiation Controlled Area are routed to the miscellaneous waste processing system where the liquid is processed and monitored prior to discharge. Potentially contaminated emergency vehicles will be surveyed before they are allowed to leave the plant or offsite assembly area. If the survey area is not suitable for monitoring and decontamination due to radiological or other concerns, vehicles will be surveyed at an alternate location.

6. Contamination Control Measures Controls are established and maintained 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day to contain the spread of loose surface radioactive contamination.

a. Contaminated Areas are isolated as restricted areas with appropriate radiological protection and access control. Personnel leaving Contaminated Areas are monitored to ensure that they and their clothing are not contaminated. If contamination above acceptable levels is found, they will be decontaminated in accordance with plant procedures. If normal decontamination procedures do not reduce personnel contamination to acceptable levels, the case will be referred to a competent medical authority. Supplies, instruments, and equipment that are in Contaminated Areas or have been brought into Contaminated Areas will be monitored before removal. If personnel are found to be contaminated, they will be decontaminated using normal plant decontamination techniques and facilities. Contaminated materials will be disposed of as radwaste. Contaminated vehicles will be decontaminated before being released. An ambulance responding and transporting injured contaminated personnel will be monitored and decontaminated before departing the medical facility by VCSNS personnel or sent to the county emergency worker decon facility, during a declared emergency.

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b. Measures will be taken to control onsite access to potentially contaminated potable water and food supplies. Under emergency conditions, when uncontrolled releases of activity have occurred, eating, drinking, and chewing are prohibited in all onsite VCSNS ERFs until such time as habitability surveys indicate that such activities are permissible.

c. Restricted areas and contaminated items will be returned to normal use when contamination levels have been returned to acceptable levels. Contamination control criteria for returning areas and items to normal use are contained in the plant procedures.

7. Decontamination of Relocated Personnel Efforts will be made to prevent contaminated vehicles operated by nonessential personnel to depart the VCSNS site. Alternate forms of transportation will be made available to reduce the possibilities of transporting contamination offsite with suspected contaminated vehicles.

Nonessential onsite personnel may be evacuated to an offsite holding area or assembly area, as discussed in Section J. Radiological controls personnel at that location monitor evacuees and determine the need for decontamination. Existing and temporary facilities to limit contamination and exposure will be used and established at the site as necessary during an emergency situation. In the event that decontamination of site 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 types of contaminations, particularly with regards to skin contaminations.

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Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station Section L: Medical and Public Health Support This section describes the arrangements for medical services for contaminated injured individuals at the station.

1. Offsite Hospital and Medical Service Facilities Arrangements, by letter of agreement, are maintained by SCE&G with Palmetto Health Richland Hospital for receiving and treating contaminated or exposed persons with injuries requiring immediate medical care. Hospital personnel have been trained and the hospital is equipped to handle contaminated or radiation injured individuals. Specifically, training of medical support personnel at Palmetto Richland Hospital includes basic training on the nature of radiological emergencies, diagnosis and treatment, and follow-up medical care.

Station personnel are available to assist medical personnel with decontamination, radiation exposure, and contamination control. Materials that are identified as contaminated are collected by Health Physics personnel and returned to VCSNS for decontamination or disposal.

Because of the specialized nature of the diagnosis and treatment of radiation injuries, VCSNS maintains an agreement with the REAC/TS in Oak Ridge, Tennessee. REAC/TS will provide a backup response capability for patients with serious contamination/ingestion or who have been excessively exposed to radiation. REAC/TS has a radiological emergency response team of physicians, nurses, Health Physicists, and necessary support personnel on 24-hour call to provide consultative or direct medical or radiological assistance.

Specifically, the REAC/TS team has expertise and is equipped to conduct: medical and radiological triage; decontamination procedures and therapies for external contamination and internally deposited radionuclides, including chelation therapy; diagnostic and prognostic assessments or radiation-induced injuries; and radiation dose estimates by methods that include cytogenetic analysis, bioassay, and in vivo counting.

Victims of accidents or medical emergencies who are determined as not being contaminated or excessively exposed to radiation may be treated at the closest appropriate medical facility as determined by the responding Emergency Medical Services Crew Chief.

2. Onsite First Aid Capability The station maintains onsite first aid supplies and equipment necessary for the treatment of contaminated or injured persons. In general, physicians or nurses are not staffed at VCSNS, and as such, medical treatment given to injured persons is of a "first response" nature. The Medical Emergency Response Team (MERT) is comprised of on-shift personnel trained as First Responders. The MERT is dispatched by the Control Room or the OSC when it is activated. At least two of these individuals are available on shift at all times to support immediate response in the Protected Area. VCSNS also maintains an agreement with a local physician. That physician serves as the VCSNS's company physician and is available to respond to the site to augment medical treatment as required.

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Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station Additionally, the Health Physics Specialists at VCSNS are experienced and trained in the control of radioactive contamination and decontamination work for injured or ill personnel.

Health Physics Specialists are dispatched to support the MERT if there is a possibility of contamination associated with the injury/illness. The functions of station personnel in handling onsite injured people are:

a. Afford rescue

b. Administer first responder aid including such resuscitative measures as are deemed necessary

c. Request and escort offsite medical assistance to the injured/ill individual in a timely manner when needed

d. Begin decontamination procedures as appropriate

e. Arrange for suitable transportation to a hospital when required Primary attention shall be directed to the actual factors involved in the treatment of injuries or illness, such as: control of bleeding, resuscitation including heart and lung, control of bleeding after resuscitation, protection of wounds from bacterial or radioactive contamination and the immobilization of fractures.

VCSNS personnel provide an initial estimate of the magnitude of surface contamination of the injured and preliminary estimates of total body dose to the injured. Primary rapid and simple decontamination of the surface of the body (when possible and advisable) before transportation to a designated hospital may be carried out. This activity would be as directed or performed by Health Physics personnel. If decontamination is not considered due to the immediacy of medical treatment, efforts will be made to isolate and reduce the spread of the contamination before transportation. When additional professional medical care is needed and contamination is not a factor, injured or ill persons are transported to a local clinic or hospital. Contaminated and injured or ill persons are transported to Palmetto Health Richland Hospital from the VCSNS site.

First aid facilities at VCSNS are designed to provide basic first responder aid to injured or ill personnel before arrival of offsite medical support. First aid facilities are located in the unit and are described in the Unit 1 Annex to this Plan. Medical equipment and supplies are available at these locations.

In the event of a mass casualty incident, medical triage is implemented. MERT members are trained for medical triage using START (Simple Triage and Rapid Treatment) or other similar principals. Each victim is screened and categorized in order to prioritize victim treatment. In the event that station and local response resources are exceeded by the number of casualties, the South Carolina Emergency Operations Plan is implemented to acquire additional resources by the offsite response agencies.

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3. Medical Transportation In situations when transportation of a victim(s) to a hospital is required, arrangements are made by the station for prompt ambulance transport of persons with injuries and/or illness involving radioactivity to Palmetto Richland Hospital. Such service is available on a 24-hour per day basis and is confirmed by letter of agreement with the Fairfield County Emergency Medical Services (FCEMS). The FCEMS is located approximately two miles from VCSNS and is staffed with Emergency Medical Technicians, Paramedics, and additional qualified personnel capable of handling medical emergency situations. VCSNS maintains a communications link with the FCEMS by means of an EMNet telephone, radio and normal telephone lines. VCSNS security personnel will expedite and escort the responding ambulance(s) to the victim's location.

In the event that a helicopter is requested by the response personnel to transport victim(s) to appropriate medical care, a primary helicopter landing area is available onsite for use.

Alternate landing areas are determined by response personnel and marked to assist the landing of the helicopter.

If additional assistance is required for the transportation of accident victims, the Lexington County Emergency Medical Services (LCEMS) will respond. This support would most likely be used in a case where multiple casualty victims would require transportation to offsite medical facilities. LCEMS is located approximately 15 miles from VCSNS and is staffed with Emergency Medical Technicians and Paramedics. Should the need arise, assistance from the LCEMS and other response organizations would be requested by FCEMS or the Incident Commander.

Radiation monitoring services shall be provided by VCSNS Health Physics personnel whenever it becomes necessary to use the ambulance service for the transportation of contaminated persons.

A qualified Health Physics person shall accompany the ambulance to the hospital upon the determination that the injured or ill person is contaminated or if the determination cannot be made that the individual is free of surface contamination. Additional Health Physics personnel may be contacted and dispatched to Palmetto Richland Hospital to assist in the monitoring and decontamination of the injured victim(s), the hospital facilities, and the ambulance and response personnel as needed.

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Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station Section M: Reentry and Recovery Planning This section describes the measures to be taken for reentry into the areas of the Station which have been evacuated as a result of an accident. It also outlines the VCSNS Recovery Organization and its concepts of operation.

1. Reentry and Recovery

a. Evaluating Reentry Conditions During an emergency, immediate actions are directed toward limiting the consequences of the accident to afford maximum protection to station personnel and the general public.

Once corrective measures have been taken and effective control of the plant has been reestablished, a more methodical approach to reentry is taken. This Emergency Plan divides reentry into two separate categories:

• Reentry during the emergency phase of an accident is performed to save a life, control a release of radioactive material, prevent further damage to plant equipment or restore plant equipment. If necessary, this category of reentry may be performed using emergency exposure limits. Briefings, rather than written radiation protection procedures, may be used when making these entries.

All reentry activities conducted during the emergency are authorized by the ED and coordinated by the OSC Supervisor and the Radiological Assessment Supervisor.

• Reentry during the recovery phase of an accident is performed using normal exposure limits. Either normal procedures or procedures that consider existing as well as potential conditions inside affected areas are developed specifically for each reentry.

Reentry activities during the recovery phase are authorized by the Recovery Director and coordinated by the recovery organization managers in charge of personnel making the reentry.

The following items are considered when planning for any reentry:

" Review of available radiation surveillance data to determine plant areas potentially affected by radiation and/or contamination

• Review of radiation exposure history of personnel required to participate in the accident mitigation or recovery operations

" Determination of the need for additional personnel and the sources of these additional personnel

" Review of adequacy of radiation survey instrumentation and equipment (types, ranges number, calibration, etc.)

" Review of nonradiological hazards and required protective measures (e.g., fire, electrical, atmosphere, Hazmat)

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• Preplanning of activities and briefings for the reentry team that include the following:

- Personnel knowledge requirements

- Methods and procedures that will be employed during the entry

- Specific tasks to be performed

- Anticipated radiation and contamination levels as well as "turn back" limits

- Radiation survey equipment and types and ranges of dosimetry required

- Shielding requirements and availability

- Appropriate communications

- Personal protective equipment (PPE) requirements

- Access control procedures

- Decontamination requirements

- Debriefing requirements

- Respiratory protection

• A review of security controls to prevent unauthorized or unintentional entry into hazardous or secured areas.

b. Evaluatinq Entry into Recovery The Recovery Phase is that period when major repairs are being performed to return the plant to an acceptable condition and the possibility of the emergency condition degrading no longer exists. Once the plant has been stabilized, contained, and controlled, the Recovery Phase may be entered. It is the responsibility of the ED to declare emergency phase terminated and entry into Recovery after obtaining concurrence from the ED and consulting with offsite authorities if a Site Area Emergency or General Emergency has been declared.

Establishment of Recovery can be conducted from any emergency classification level.

However, it is possible that the lower classifications of Unusual Event and Alert will conclude with the overall event being terminated. There may be cases where certain EAL ICs remain exceeded, but the station is under control and no further danger of degradation exists. In such a case, it may be appropriate to enter Recovery. Site Area Emergency and General Emergency classifications will require a Recovery Phase to be established before event termination. VCSNS may consult with/notify the cognizant governmental agencies before declaring Recovery or event termination during an Unusual Event or Alert. When in a Site Area Emergency or a General Emergency, VCSNS will consult and notify the cognizant governmental agencies before declaring Recovery or event termination.

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Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station Termination/Recovery considerations are contained in the implementing procedures to provide guidance for evaluating the risk of entering Recovery without alleviating the intent of the Initiating Condition. The purpose of Recovery is to provide the necessary personnel to affect the long-term activities and to return the plant to an acceptable condition.

The following conditions are guidelines for the determination of establishing Recovery (this is not intended to be a complete list and additional criteria may apply, depending on the specifics of the event):

• The risk to the health and safety of the public has been mitigated

• Plant parameters and equipment status have been established and controlled

• In-plant radiation levels are stable or decreasing, and acceptable, given the plant conditions

• The potential for uncontrolled releases of radioactive material to the environment has been eliminated

• Environmental monitoring has been established

• The radioactive plume has dissipated and plume tracking is no longer required (the only environmental assessment activities in progress are those necessary to assess the extent of deposition resulting from passage of the plume)

• VCSNS workers have been protected

• Any security threat has been neutralized, and/or plant Security is under the direction of VCSNS personnel as part of a Unified Command Incident Command System.

• Adequate plant safety systems are operable

• The reactor is in a stable shutdown condition and long-term core cooling is available

• The fuel pool damage has been mitigated, or spent fuel damage has been contained and controlled

• Primary and/or secondary containment integrity has been established

" Plant systems and equipment are restored and/or replaced such that plant conditions are stable and highly unlikely to degrade further

" Conditions that initiated the emergency have been contained, controlled, eliminated, or stabilized such that the emergency classification is no longer applicable

• The operability and integrity of unit or externally supplied radioactive waste systems, decontamination facilities, power supplies, electrical equipment and of plant instrumentation including radiation monitoring equipment Page 98 of 193 EP-100 Rev 64

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• Any fire, flood, earthquake, high winds, or similar emergency condition or security threat no longer exists

• All required notifications have been made

• Discussions have been held with federal, state, and county agencies and agreement has been reached to terminate the emergency for a Site Area Emergency or a General Emergency

• At an Alert or higher classification, the ERO is in place and emergency facilities are activated

• All contaminated injured personnel have been treated and/or transported to a medical care facility

• Offsite conditions do not unreasonably limit access of outside support to the station and qualified personnel and support services are available It is not necessary that all conditions listed above be met; however, all items must be considered before entering the recovery phase. For example, it is possible after a severe accident that some conditions remain that exceed an Emergency Action Level, but entry into the Recovery Phase is appropriate.

2. Recovery Organization Once plant conditions have been stabilized and the Recovery Phase has been initiated, the ECO with assistance from senior management may form a Recovery Organization for long-term operations. These types of alterations should be discussed with the NRC before they are implemented.

• For events of a minor nature, (i.e., for Unusual Event classifications), the normal on shift organization is normally adequate to perform necessary recovery actions.

" For events where damage to the plant has been significant, but no offsite releases have occurred and/or protective actions were not performed, (i.e., for Alert classifications) the station ERO, or portions thereof, should be adequate to perform the recovery tasks before returning to the normal station organization.

" For events involving major damage to systems required to maintain safe shutdown of the plant and/or offsite radioactive releases have occurred, (i.e., for Site Area Emergency or General Emergency classifications) the station recovery organization is put in place.

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Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station The specific members of the station recovery organization are selected based on the sequence of events that preceded the recovery activities as well as the requirements of the recovery phase. The basic framework of the station recovery organization is as follows:

a. The Recovery Director: The ECO is initially designated as the Recovery Director. The Recovery Director is charged with the responsibility for directing the activities of the station recovery organization. These responsibilities include:

" Ensuring sufficient personnel, equipment, or other resources from SCE&G and other organizations are available to support recovery

• Directing the development of a recovery plan and procedures

• Deactivating any of the plant ERO that was retained to aid in recovery, in the appropriate manner. Depending on the type of accident and the onsite and offsite affects of the accident, portions of the ERO may remain in place after initiation of the recovery phase

" Coordinating the integration of available federal and state assistance into onsite recovery activities

" Coordinating the integration of SCE&G support with federal, state, and county authorities into required offsite recovery activities

• Approving information released by the public information organization that pertains to the emergency or the recovery phase of the accident

• Determining when the recovery phase is terminated

b. The Recovery Plant Manager: The General Manager, Nuclear Plant Operations or a designated alternate, will become the Recovery Plant Manager. The Recovery Plant Manager reports to the Recovery Director and is responsible for:

• Coordinating the development and implementation of the recovery plan and procedures

• Ensuring that adequate engineering activities to restore the plant are properly reviewed and approved

• Directing all onsite activities in support of the station recovery effort

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c. The Recovery Offsite Managqer: A senior member of Nuclear Support Services or a designated alternate is the Recovery Offsite Manager. The Recovery Offsite Manager reports to the Recovery Director and is responsible for:

• Providing liaison with offsite agencies and coordinating VCSNS assistance for offsite recovery activities

• Coordinating VCSNS ingestion exposure pathway EPZ sampling activities and the development of an offsite accident analysis report

" Developing a radiological release report

" Designating other VCSNS recovery positions required in support of offsite recovery activities

d. The Company Spokesperson: A senior SCANA Public Relations Group individual is designated as the Company Spokesperson. The Company Spokesperson reports to the Recovery Director and is responsible for:

• Functioning as the official spokesperson to the press for SCE&G on all matters relating to the accident or recovery

" Coordinating with all public information groups (federal, state, county, etc.)

• Coordinating media monitoring and rumor control

• Determining what public information portions of the ERO will remain activated The remainder of the recovery organization is established on an initial recovery plan developed at the end of the emergency phase or just after entry into the Recovery Phase.

Consideration is given to recovery activity needs and use of the normal station organizations. Individual recovery supervisors may be designated in any or all of the following areas:

• Training

" Health Physics

• Chemistry

• Technical/Engineering Support

" Nuclear Oversight

• Operations

• Security

• Maintenance

• Corporate Support

" Special Offsite Areas (Community Representatives, Environmental Samples, Investigations, etc.)

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3. Recovery Phase Notifications When the decision is made to enter the Recovery Phase, all members of the ERO are informed of the change. All VCSNS personnel are instructed on the Recovery Organization and their responsibilities during the recovery effort. The offsite authorities are notified of the shift to and the basic structure and management of the Recovery Organization.

4. Total Population Exposure Total population exposure calculations are performed and periodically updated during the Recovery Phase of an accident. A procedure has been developed for estimating the total population exposure resulting from the accident from data collected in cooperation with the state and other federal agencies. Total population exposure is determined through a variety of processes including:

• Examination of prepositioned environment monitoring TLDs

" Bioassay

" Estimates based on release rates and meteorology

• Estimates based on environmental monitoring of food, water, and ambient dose rates The state will be the lead agency in the collection and analysis of environmental air, soil, foliage, food, and water samples and for the generation of radiation monitoring reports.

VCSNS environmental sampling activities will be coordinated with state efforts, as requested, and results shared with the cognizant agencies.

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Part 2: Planning Standards and Criteria V.C. Summer Nuclear Station Section N: Drill and Exercise Program This section describes the Drill and Exercise Program that VCSNS has implemented to:

• Verify the adequacy of the Emergency Preparedness Program

• Develop, maintain, and evaluate the capabilities of the ERO to respond to emergency conditions and safeguard the health and safety of station personnel and the general public

• Identify deficiencies in the Emergency Plan and its associated procedures, or in the training of response personnel, and ensure that they are promptly corrected

• Identify deficiencies in the relationship between the Emergency Plan and the VCSNS Security Plan and ensure that they are promptly corrected

• Ensure the continued adequacy of emergency facilities, supplies, and equipment, including communications networks

1. Exercises Exercises provide an opportunity to evaluate the ability of participating organizations to implement a coordinated response to postulated emergency conditions. Provisions will be made for qualified personnel from VCSNS, other commercial nuclear facilities, or federal, state, or local governments to observe and critique each exercise as appropriate. Exercises are conducted to ensure that all major elements of the emergency plan and preparedness program are demonstrated at least once in cycle. Each scenario variation shall be demonstrated at least once during the cycle and shall include, but not limited to, the following:

• An off-hours exercise between 6:00 p.m. and 4:00 a.m. Weekends and holidays are also considered off-hour periods.

• Hostile action directed at the plant site involving the integration of offsite resources with onsite response; VCSNS participates on a rotating basis with the other fixed nuclear facilities in the state of South Carolina

• An initial classification of, or rapid escalation to Site Area Emergency or General Emergency

• No radiological release or an unplanned minimal radiological release that requires the site to declare a Site Area Emergency, but does not require declaration of General Emergency

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a. Biennial Exercises Federally prescribed exercises are conducted at the station in order 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. Exercises involving offsite agency participation, required under Sections F.2.b., F.2.c., & F.2.d. to 10 CFR 50 Appendix E, are conducted at the station based on FEMA guidance and the respective state and county emergency response plans.

Full participation exercises will include appropriate offsite local and state authorities and VCSNS personnel physically and actively taking part in testing the integrated capability to adequately assess and respond to a declared emergency at the station. Additionally, full participation exercises will include testing the major observable portions of the onsite and offsite emergency plans and mobilization of state, local, and VCSNS personnel and other resources in sufficient numbers to verify the capability to respond to the accident scenario. Some of the offsite response actions may be provided for evaluation in an out-of-sequence manner. These exercises are to be scheduled in an attempt to provide or simulate various weather conditions.

These exercises are usually conducted in conjunction with a full participation exercise as the state chooses.

Where full participation by offsite agencies occurs, the sequence of events simulates an emergency that may result in the release of radioactivity to the offsite environs or the threat of such a release, sufficient in magnitude to warrant a response by offsite authorities. The sequence of events will be submitted to the NRC and FEMA in a timely fashion to ensure that the scenario is judged to provide adequate opportunity for demonstration of the agreed upon objectives and extent of play.

In the event of an inadequate demonstration of the offsite response, VCSNS will participate and support the conduct of activities that are designed to address the deficient or weak demonstrations.

b. Off-Year Exercises An Off-Year Exercise is conducted at the station during the calendar year when an NRC Evaluated Exercise is not scheduled. An Off-Year Exercise shall involve the station and its facilities in order to demonstrate at' least the functions of management and coordination of emergency response, accident assessment, protective action decision-making, or plant system repair and corrective actions. Off-Year Exercises involve no or limited participation by offsite agencies, although a routine offer is made to determine the extent of participation by the offsite authorities. Emphasis is placed on development and conduct of an exercise that is more mechanically and operationally realistic. Players may be able, by implementing appropriate procedures and corrective actions, to determine the outcome of the scenario to a greater extent than when core damage and the release of radioactivity that are prerequisites for demonstration of all objectives which may include security response activities.

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2. Drills In addition to the exercises described above, VCSNS conducts drills for the purpose of testing, developing, and maintaining the proficiency of emergency responders. Drills are scheduled on the Emergency Preparedness annual events plan, which contains provisions for the following drills:

a. Training Drills Training Drills may be conducted before a Biennial Exercise where FEMA evaluation of state and local performance is expected. Training Drills may be conducted before Off-Year Exercises that only involve VCSNS. The Training Drill is a training and experience tool for the participants to sharpen awareness and practice skills necessary to accomplish specific Emergency Plan duties and responsibilities. It also provides a "dry run" for experience dealing with multiple Controllers, Observers and Evaluators that may be in excess of those provided in training drills.

b. Communication Drills

" Monthly: The primary and alternate methods to notify the state and local government warning points and EOCs within the plume exposure pathway EPZ are demonstrated.

Also, the capability to notify the NRC is demonstrated using the ENS.

• Quarterly: The capability to notify the NRC Region and federal EROs as listed in the Emergency Telephone Directory are demonstrated from the EOF. Also, computer and critical communications equipment shall be functionally tested.

• Annually: The emergency communications systems outlined in Section F are fully tested. This includes (1) communications between the plant and the state and local EOCs and Field Teams, (2) communications between the Control Room, the TSC, and the EOF (3) communications between the TSC and the OSCs, and (4) communications between the EOF and the JIC.

Each of these drills includes provisions to ensure that all participants in the test are able to understand the content of the messages.

c. Fire Drills: Fire drills shall be conducted in accordance with the station Technical Specifications, Fire Protection Plan, and/or station procedures.

d. Medical Emergency Drills: A medical emergency drill, involving a simulated contaminated individual and containing provisions for participation by local support services organizations (i.e., ambulance and support hospital) is conducted annually. The offsite portions of the medical drill may be performed as part of the required biennial exercise.

e. Radiological Monitorinq Drills: Plant environs and radiological monitoring drills (onsite and offsite) are conducted annually. These drills include collection and analysis of all sample media (such as, water, vegetation, soil, and air), and provisions for communications and record keeping. Collection of milk is demonstrated in accordance with the ingestion pathway exercises.

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f. Health Physics Drills: Health Physics drills involving a response to, and analysis of, simulated elevated airborne and liquid samples and direct radiation measurements within the plant are conducted semiannually in the Protected Area.

g. Augmentation Drills: Augmentation drills serve to demonstrate the capability of the process to augment the on-shift staff with a TSC, OSC, EOF, and JIC after declaration of an emergency. These drills are conducted using the following methods:

• Semiannually, an unannounced off-hours ERO augmentation drill where no actual travel is required.

• At least once per exercise cycle, an off-hours unannounced activation of the ERO Notification System with actual response to the emergency facilities is conducted to support the response to the unit.

h. Accountability Drills: Accountability drills are conducted annually for the Protected Area.

The drill includes ascertaining the names of all missing individuals within the Protected Area and accounting for all individuals within the Protected Area continuously throughout the event.

3. Conduct of Drills and Exercises Advance knowledge of the scenario will be kept to a minimum to allow "free-play" decision making and to ensure realistic participation by those involved. Before the drill or exercise, a package will be distributed to the Controllers and Evaluators that will include the scenario, a list of performance objectives, and a description of the expected responses.

Drills will be provided to ensure that each member of the ERO will have an opportunity to participate in a drill in their assigned facility at least once in a two-year period.

For each emergency preparedness exercise or drill conducted, a scenario package is developed that includes at least the following:

a. The basic objective(s) of the drill or exercise and the appropriate evaluation criteria

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

c. The simulated events

d. A list of anticipated Drill/Exercise Performance (DEP) opportunities including classification, notifications and PARs

e. A time schedule of real and simulated initiating events

f. A narrative summary describing the conduct of the scenario to include such things as simulated casualties, offsite fire department assistance, rescue of personnel, use of protective clothing, deployment of radiological monitoring teams, and public information activities.

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h. Instructions for the conduct of the drill/exercise for the controller organization Prior approval by the appropriate Station Management is obtained for all drills and exercises conducted in support of the Emergency Preparedness Program.

4. Critique and Evaluation Drill and exercise performance objectives are 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 ERO to implement the Emergency Plan and its implementing procedures.

A formal written critique report is prepared by the Manager, Emergency Planning following a drill or exercise involving the evaluation of designated objectives or following the final simulator session with ERO participation. The report will evaluate the ability of the ERO to respond to a simulated emergency situation or sequence of events. The report will also contain corrective actions and recommendations for improvement.

Biennially, representatives from the NRC observe and evaluate the licensee's ability to conduct an adequate self-critical critique. For full offsite participation exercises, both the NRC and FEMA will observe, evaluate, and critique.

Critique comments identified by participants during a training drill where objectives are not formally being evaluated will be reviewed and dispositioned by the Emergency Preparedness Unit, but are not required to be included in a formal report.

5. Resolution of Drill and Exercise Findings The critique and evaluation process is used to identify areas of the Emergency Preparedness Program that require improvement. The Manager, Emergency Planning 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 the resolution to the items.

Whenever exercises and/or drills indicate deficiencies in the Emergency Plan or corresponding implementing procedures, such documents will be revised as necessary.

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Part 2: Planning Standards and Criteria V.C. Summer Nuclear Station Section 0: Emergency Response Training This section describes the emergency response training that is provided to those who may be called upon in an emergency. It outlines the training provided by VCSNS to both its employees and offsite support personnel requiring site access.

1. Assurance of Training The Emergency Plan 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 Emergency Plan 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. A description of the content of the training courses is given in the VC Summer Training and Qualification Procedures (TQP).

Offsite training is provided to support organizations that may be called upon to provide assistance in the event of an emergency. The following outlines the training received by these organizations:

a. Emergency Preparedness shall annually train, or document an annual written offer to train, those non-VCSNS organizations that may provide specialized services during a nuclear plant emergency (e.g., local law enforcement, firefighting, medical services, transport of injured, etc.). The training made available is designed to 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 (by position and title) of those persons in the onsite organization who will control their support activities.

b. Training of offsite EROs is described in their respective radiological emergency plans, with support provided by VCSNS as requested.

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Part 2: Planning Standards and Criteria V.C. Summer Nuclear Station

2. Functional Training of the ERO In addition to general and specialized classroom training, members of the ERO receive periodic performance-based emergency response training. Performance-based training is provided using one or more of the following methods:

" Familiarization Sessions: A familiarization session is an informal, organized tabletop discussion of predetermined objectives.

• Walk-throucqhs: Consists of a facility walk-through to familiarize plant ERO personnel with procedures, communications equipment, and facility layout. Walk-throughs also provide the opportunity to discuss facility activities, responsibilities, and procedures with an instructor.

" Drills: 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.

3. First Aid Response Selected station personnel are trained in accordance with the VCSNS approved First Aid Program and medical triage. MERTs will likely be augmented with additional personnel such as fire brigade members and other personnel qualified to assist in the rescue.

4. Emergency Response Organization Training Program 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 as defined in this document.

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. Additional Emergency Preparedness information is provided as part of the Station Orientation Training (SOT).

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Part 2: Planning Standards and Criteria V.C. Summer Nuclear Station New ERO personnel receive an initial overview course that familiarizes them with the Emergency Plan by providing basic information in the following areas as well as specific information as delineated in the sections below:

• Planning Basis

• Emergency Classifications

" ERO and Responsibilities

" Call-out of ERO

" ERFs

• Communications Protocol/EPIO

" Offsite Organizations Emergency response personnel in the following categories receive knowledge and/or performance based training initially and retraining thereafter on an annual basis:

a. Directors, Managqers, and selected Coordinators within the Station ERO: Personnel identified by the Emergency Planning Telephone Directory as Directors, Managers, and selected Coordinators for the Station ERO receive training appropriate to their position in accordance with the approved ERO training program. These personnel receive specialized training in the areas of:

• Notifications

• Emergency Classifications

• Protective Action Recommendations

" Emergency Action Levels

• Emergency Exposure Control The ECOs and EDs along with selected managers, coordinators, and IEDs receive training in accordance with the approved ERO training program. Training in accident assessment sufficient to classify an event and to mitigate the consequences of an event is also covered.

b. Personnel Responsible for Accident Assessment: The skills and knowledge required to perform plant stabilization and mitigation are a normal function of operations-specific positions, as identified in Section B of this Plan. Power changes and planned and unplanned reactor shutdowns are handled on a normal operation basis. Subsequent plant stabilization and restoration is pursued using normal operating procedures.

Licensed operators receive routine classroom and simulator training to ensure proficiency in this area.

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Part 2: Planning Standards and Criteria V.C. Summer Nuclear Station

1) Active Senior Licensed Control Room Personnel shall have training conducted in accordance with the approved ERO training program 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

• Notification form completion and use of EMNet

• Federal, state, and county notification procedures as appropriate

• Site-specific procedures for activating the onsite and offsite ERO

2) Core Damage Assessment Personnel: During an emergency when core/cladding damage is suspected, a specialized group of trained individuals perform core damage assessment. At a minimum, personnel responsible for core damage assessment receive classroom and hands-on training in the following areas:

• Available instrumentation and equipment

• Isotopic assessment and interpretation

• Core damage assessment methodology and/or proceduralized assessment methods

c. Field Teams and Radiological Analysis Personnel

1) Field Radiological Monitoring: Field radiological monitoring is performed by trained individuals who provide samples and direct readings for dose assessment calculations and dose projection comparisons.

Personnel identified as members of Field Teams receive training in accordance with the approved training program. Field Team members receive classroom and hands-on training in the following areas:

" Equipment and equipment checks

" Communications

• Plume tracking techniques

2) Personnel Monitoring: Personnel monitoring is performed by trained individuals who monitor station personnel and their vehicles for contamination during an emergency. Health Physics personnel receive classroom and hands-on training in the following areas:

• Personnel Monitoring Equipment and Techniques

• Decontamination Techniques for Personnel

" Decontamination Techniques for Vehicles Page 111 of 193 EP-100 Rev 64

Part 2: Planning Standards and Criteria V.C. Summer Nuclear Station

3) Dose Assessment: Dose assessment training includes the skills and knowledge necessary for calculation and interpretation of an offsite release and its impact on the environment under varying meteorological conditions. Individuals responsible for performing dose assessment are trained in the following areas:

• Computerized Dose Assessment

• Protective Action Recommendations

• Field Monitoring Team Interface

• PAGs associated with offsite plume exposure doses

• Basic Meteorology

d. Police, Security, and Firefighting Personnel

1) Local Police and Firefighting Personnel: The local police and fire departments are invited to receive training as outlined in Part 1.a of this section.

2) Security Personnel: Station security personnel are trained in accordance with training defined by the SOT and VCSNS Security Program.

3) Fire Brigade Teams: Station fire brigade members are trained in accordance with training defined by the VCSNS Fire Protection Program.

e. Repair and Damage Control Teams: Operations, Maintenance, Chemistry, and Health Physics personnel are trained as part of their normal job-specific duties to respond to both normal and abnormal plant operations.

Operations personnel are trained to: (1) recognize and to mitigate degrading conditions in the plant, (2) mechanically and electrically isolate damaged or malfunctioning equipment, (3) isolate fluid leaks, and (4) minimize transients.

Maintenance personnel are trained to troubleshoot and repair damaged or malfunctioning electrical, mechanical, or instrumentation systems as appropriate to their job classification.

Chemistry personnel are trained to take system samples and perform appropriate laboratory chemical analysis of the samples.

Health Physics 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, stay times, and other protective actions specific to the conditions present.

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Part 2: Planning Standards and Criteria V.C. Summer Nuclear Station At least 50% of personnel from the organizations below, who are potential responders to the OSC as Damage Control Team members, are required to be qualified in the use of respiratory protection equipment. This includes in-plant supervision and craft/technical personnel for the following organizations:

• Operations

• Health Physics

• Chemistry

• Maintenance (Mechanical, Electrical, and I&C)

f. Medical Emergency Response Team and Rescue Personnel: MERT and rescue team members receive training as outlined in Part 3 of this section, First Aid Response.

g. Local Support Service Personnel: Local support service personnel providing assistance during an emergency are invited to receive training as outlined in Parts l.a and l.b of this section.

h. Medical Support Personnel: Onsite medical personnel receive specialized training in the handling of contaminated victims and hospital interface. Offsite ambulance and hospital personnel are offered annual training in accordance with a program provided by Emergency Preparedness.

EPIO Personnel: Corporate and station personnel responsible for disseminating public information and responding to media and public information requests receive specialized public information training.

j. Communications Personnel: ERO personnel receive training on communications protocol as a part of the initial Emergency Response Overview Course. Personnel using specialized communications equipment that is not part of their normal daily function receive initial and requalification training on the equipment. Personnel involved in notifications to offsite agencies receive specialized training in the notification process.

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Part 2: Planning Standards and Criteria V.C. Summer Nuclear Station

5. General, Initial, and Annual Training Program Maintenance

a. Station departments and Emergency Preparedness share the responsibility for ensuring that the ERO receives all necessary training and retraining. In order to carry this out, responsibilities are assigned as follows:

Station responsibilities for Station ERO personnel:

" Station management shall ensure the attendance of onsite personnel for training, including required Emergency Planning courses.

• The station shall conduct onsite emergency personnel initial and retraining for station ERO personnel using approved lesson plans.

• The Station Training Department shall provide those shift personnel included in a continuing training program an annual review of the following items as a minimum:

- Assembly Areas

- ERF assignment

- Potential Hazards (radiological and nonradiological)

- Anticipated actions including assembly requirements, protective equipment requirements (clothing, masks, SCBA, etc.), the use of KI, emergency exposure limits, and accountability requirements.

b. Initial and Requalification ERO Training: The proficiency of emergency response personnel (as defined in 10 CFR 50 Appendix E) is ensured by the following means:

" Assigning individuals to emergency duties that are similar to those performed as a part of their regular work assignment or experience

• Initial training and annual retraining on applicable generic and site-specific portions of the emergency plan and the corresponding implementing procedures. Individuals not demonstrating the required level of knowledge in initial or retraining classes receive additional training on the areas requiring improvement. Annual retraining is conducted on a calendar year basis

• Training on Emergency Plan changes shall be completed within 120 days of implementation of the change

• Participation in exercises and/or drills as developed or authorized by the Emergency Preparedness Department and designed to sharpen those skills that they are expected to use in the event of an actual emergency All personnel assigned position specific responsibilities in the ERO are documented by inclusion in the Emergency Planning Telephone Directory listing of positions and personnel.

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Part 2: Planning Standards and Criteria V.C. Summer Nuclear Station

c. Station Orientation Training (SOT): All personnel with unescorted station access are provided with initial orientation training on the notification and instruction methods used in the event of an emergency. Additionally, all badged individuals also receive initial orientation on the basic principles of radiological safety including the effects of radiation and the theory and use of radiation detection devices. Appropriate actions for escorted individuals shall be the responsibility of the escort. SOT provides initial and annual requalification training on the basic elements of the Emergency Plan for all personnel working at the plant. Specifically, these elements include:

• Station emergency alarms and their meaning

• Assembly areas

• Site and exclusion area evacuation procedures

• Special precautions and limitations during an emergency

• Purpose of the Emergency Plan Page 115 of 193 EP-100 Rev 64

Part 2: Planning Standards and Criteria V.C. Summer Nuclear Station Section P: Responsibility for the Maintenance of the Planning Effort This section describes the responsibilities for development, review, and distribution of the Emergency Plan and actions that must be performed to maintain the Emergency Preparedness Program. It also outlines the criteria for ensuring that personnel who perform the planning are properly trained.

1. Emergency Preparedness Staff Training 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. At least once each calendar year, each member of the Emergency Preparedness staff is involved in one of the following activities:

• Training courses specific or related to emergency preparedness

• Observation of or participation in drills and/or exercises at other stations

• Participation in industry review and evaluation programs aimed towards emergency preparedness programs/issues

• 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 and resolution

2. Authority for the Emergency Preparedness Effort The Vice President, Nuclear Operations, is responsible for the safe and reliable operation of the VCSNS. The issuance and control of this Plan and the activities associated with emergency preparedness shall be the overall responsibility of the Vice President, Nuclear Operations. This individual is assigned the responsibility for overall implementation of the VCSNS Emergency Plan and Unit 1 Annex.

3. Responsibility for Development and Maintenance of the Plan The Manager, Emergency Planning and Supervisor, Emergency Services are responsible for the overall Emergency Preparedness Program associated with the operation of VCSNS and to administer the program to ensure availability of resources in the event of an emergency.

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Part 2: Planning Standards and Criteria V.C. Summer Nuclear Station The Manager, Emergency Planning is assisted by the station Emergency Preparedness Unit staff. Specific responsibilities include the following:

Program Administration

" Develop and maintain the Emergency Plan, Unit 1 Annex, implementing procedures and administrative documents

• Develop and maintain 10 CFR 50.54(q) evaluations for changes to Emergency Plan documents

• Coordinate and maintain the Emergency Plan activities schedule

" Develop and maintain working relationships and coordinate meetings with federal, state, and local agencies

• Ensure integration of plans between the station and offsite agencies

• Provide an opportunity to discuss EALs and the availability of SCE&G Quality Systems Group audit results relating to interface with governmental agencies

• Coordinate, negotiate, and maintain agreements and contracts with offsite agencies and support organizations

• Obtain Letters of Agreement with major medical facilities, and medical consultants specifically skilled in the medical aspects of radiation accidents resulting in excessive exposure, contamination, and/or ingestion of radioactive materials

" Coordinate the development and annual distribution of the station's public information publication

" Coordinate and administer the self-assessment program to monitor and evaluate the adequacy of the Emergency Preparedness Program

• Coordinate and support Emergency Plan audits and inspections.

• Ensure the documentation and resolution of adverse conditions in the Emergency Preparedness Program discovered through drills, audits, etc. in accordance with the Corrective Action Program

• Coordinate and develop Operational Experience responses as assigned

• Coordinate, document, and review Emergency Preparedness Performance Indicator data and reports

• Provide oversight of NRC Drill and Exercise Performance (DEP) evaluations during License Operator Qualification and Requalification Training

" Coordinate and conduct Emergency Plan Event reviews and reports

• Maintain adequate documentation/files to support Emergency Plan activities Page 117 of 193 EP-100 Rev 64

Part 2: Planning Standards and Criteria V.C. Summer Nuclear Station

• Develop and manage the Emergency Plan budget

• Maintain the Emergency Planning Telephone Directory Drills and Exercises

• Coordinate and maintain the Emergency Plan drill and exercise schedule

• Coordinate and conduct exercises and drills

" Coordinate NRC, FEMA, state, and local exercise scheduling and development activities

• Coordinate drill and exercise scenario development activities

• Develop and publish drill and exercise scenario manuals

• Coordinate and perform Controller and Evaluator functions for drills and exercises

• Coordinate the selection and ensure the training of Controllers for onsite drills and exercises

• Coordinate response cells for drills and exercises

" Maintain documentation of drill and exercise objectives demonstration and their results

• Develop and issue drill and exercise reports Facilities and Equipment

" Provide maintenance and administration of the ANS

" Provide maintenance of the ERO Emergency Notification System

" Ensure the ERFs are maintained in a constant state of readiness

" Coordinate and review the Emergency Plan equipment inventories

" Coordinate and conduct maintenance and testing of the communications systems

• Maintain the Emergency Plan computer applications Page 118 of 193 EP-100 Rev 64

Part 2: Planning Standards and Criteria V.C. Summer Nuclear Station ERO Qualification and Administration

" Develop and maintain ERO lesson plans, examinations, and qualification records

" Ensure through letters, meetings, seminars, or other means available, that all affected personnel in the ERO are informed of changes to the Emergency Plan and procedures

• Maintain Emergency Plan SOT content

" Coordinate, schedule, and conduct ERO qualification and requalification training

• Oversee the maintenance of ERO training records

" Maintain and coordinate publishing of the ERO duty rosters

• Provide adequate oversight and support for the training of offsite response personnel

• Coordinate conduct of Emergency Medical Assistance Program training

" Coordinate annual training for the media The Vice President, Nuclear Operations is responsible for implementation of the Emergency Plan, with the General Manager, Nuclear Support Services overseeing the process. The General Manager, Nuclear Support Services has the following responsibilities for maintenance of the Emergency Preparedness Program:

" Ensure the adequate staffing and training of station ERO members

" Schedule and conduct drills and exercises to maintain the state of readiness of the Emergency Preparedness Program

" Ensure the operational readiness of station facilities and communication systems for use during an emergency

• Ensure the operational readiness of station emergency equipment and supplies is maintained

• Ensure the Emergency Plan implementing procedures are maintained Page 119 of 193 EP-100 Rev 64

Part 2: Planning Standards and Criteria V.C. Summer Nuclear Station

4. Emergency Plan and Agreement Revisions The Emergency Plan, the Unit 1 Annex, and supporting Agreements are reviewed on an annual basis. The annual Emergency Plan review/update includes required changes, as directed by management, and those changes identified during audits, assessments, training, drills, and exercises. The Manager, Emergency Planning is responsible for determining which recommended changes are incorporated into an Emergency Plan or emergency procedure revision. In those years when the review does not warrant a revision, a letter or memorandum to that affect will be issued.

The Emergency Plan and the Unit 1 Annex shall be revised as needed and the most current approved revisions shall remain in effect so long as they are verified as current. Revisions to the Emergency Plan are reviewed by the Plant Safety Review Committee before approval.

Changes to the Plan are made without NRC approval only if such changes do not reduce the effectiveness of the Plan in accordance with 10 CFR 50.54(q), and the Plan as changed continues to meet the standards of 10 CFR 50.47(b) and the requirements of 10 CFR 50, Appendix E. Proposed changes that reduce or have a potential to reduce the effectiveness of the approved Plan are not implemented without prior approval by the NRC.

" Proposed revisions to the Emergency Plan and Unit 1 Annex shall be completed in accordance with the VCSNS review and approval processes.

" Emergency Plan and Unit 1 Annex changes shall be categorized as (1) minor/administrative or (2) significant programmatic changes. Minor/administrative changes shall be implemented within 30 days of approval. Significant programmatic changes shall be implemented as soon as practical and within 90 days of final station approval.

• After review and approval, the Emergency Plan and Unit 1 Annex shall be:

a) Reviewed by the Manager, Emergency Planning or designee b) Approved for use by the General Manager, Nuclear Plant Operations, or designee.

• The Implementing Procedures shall be developed and revised concurrent with the Emergency Plan and the Unit 1 Annex, and reviewed every two years.

Annually, each Letter of Agreement is reviewed and certified current in order to ensure the availability of assistance from each supporting organization not already a party to the South Carolina Operational Radiological Emergency Response Plan.

5. Emergency Plan Distribution Emergency Plans, Unit Annex, and implementing procedures are distributed as necessary on a controlled basis to the ERFs. Electronic copies of documents are also available on the company's computer network. All controlled document holders are issued revision changes upon approval. Selected federal, state, and local agencies, and other appropriate locations requiring them are also issued copies. Procedures are in place that control the revision of the Emergency Plan.

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Part 2: Planning Standards and Criteria V.C. Summer Nuclear Station

6. Supporting Emergency Response Plans Other plans that support this Emergency Plan are:

• NUREG-0728, U.S. NRC, "Concept of Operations: NRC Incident Response"

" National Response Framework

• South Carolina Operational Radiological Emergency Response Plan

• Fairfield County Emergency Operations Plan

• Newberry County Emergency Operations Plan

" Richland County Emergency Operations Plan

" Lexington County Emergency Operations Plan

" State of North Carolina Emergency Response Plan for Nuclear Power Facilities

" DOE, Region 3, "Radiological Assistance Plan"

" INPO Emergency Resources Manual

" VCSNS Security Plan - Note: The Plan contains safeguards information that must be withheld from public disclosure under provisions of 10 CFR 73.21.

7. Implementing and Supporting Procedures Appendix 3 of this Plan contains a listing, by title, of those procedures that implement this Plan during an emergency. Additionally, administrative procedures that outline the steps taken to maintain the VCSNS Emergency Preparedness Program have been developed and are also listed in Appendix 3.

8. Cross-Reference to Planning Criteria The Plan is formatted in the same manner as NUREG-0654, "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 of the criteria set forth in NUREG-0654. Appendix 6 provides the cross reference for this Plan to the criteria in NUREG-0654.

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Part 2: Planning Standards and Criteria V.C. Summer Nuclear Station

9. Audit/Assessment of the Emergency Preparedness Program To meet the requirements of 10 CFR 50.54(t), the Manager, Emergency Planning shall coordinate an independent review of the Emergency Preparedness Program to examine conformance with 10 CFR 50.47, 10 CFR 50.54, and 10 CFR 50, Appendix E. Included in the audit/assessment are the following:

• The Emergency Plan and associated implementing procedures

• The Emergency Preparedness Training Program, including drills and exercises

• The readiness of the Station ERO to perform its function

• The documents and programs used to direct and document the administrative portion of the Emergency Preparedness Program

• The readiness of facilities and equipment to perform as outlined in the plan and procedures

• The interfaces between VCSNS, the state, and county governmental agencies pertaining to the overall Emergency Preparedness Program The Nuclear Safety Review Committee will ensure that an audit of the VCSNS Emergency Planning Program is performed at least once every 12 months.

Results of this audit are submitted for review to the Vice President, Nuclear Operations. The Manager, Emergency Planning ensures that any findings that deal with offsite interfaces are reviewed with the appropriate agencies. Written notification will be provided to the state and counties regarding the results of the audit on the adequacy of interface with the state and local governments and the availability of the audit records for review at VCSNS.

10. Maintenance of Emergency Telephone Numbers Names and phone numbers of the ERO, support personnel/agencies, and ERFs in the emergency plan implementing procedures and the Emergency Planning Telephone Directory shall be reviewed and updated at least quarterly.

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Annex 1: Unit I V. C. Summer Nuclear Station Annex 1: Unit 1 Section 1: Introduction This VCSNS Emergency Plan Annex provides unit specific details for Unit 1.

This includes a unit description (type of reactor, relationship to other units, special emergency equipment), shift staffing, EALs, and any emergency facility locations which differ from those described in the Plan for a full understanding and representation of the Station's emergency response capabilities. This Unit 1 Annex is subject to the same review and audit requirements as the Radiation Emergency Plan.

1.1 Unit 1 Description The VCSNS is owned jointly by SCE&G and Santee Cooper but is operated by SCE&G. An area map showing geographical location of the facility is provided on Figure 1-1 in Part 1 of the VCSNS Emergency Plan.

Unit 1 uses a pressurized water reactor nuclear steam supply system, designed and furnished by Westinghouse Electric Corporation and a turbine generator, designed and furnished by General Electric Company. The system uses chemical shim and control rods for reactivity control and U-tubed steam generators. A diagram identifying Unit 1 facilities is provided in the Unit 1 Annex Figure Al-1.

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Annex 1: Unit 1 V. C. Summer Nuclear Station Annex 1: Unit I V. C. Summer Nuclear Station Figure Al-1: Unit I Facility Layout (specimen)

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Annex 1: Unit I V. C. Summer Nuclear Station Section 2: Organizational Control of Emergencies Section B of the Plan describes the station's ERO. When the ERO is fully activated, it will be staffed as described in Section B of the Plan. This section of the Unit 1 Annex describes the on-shift ERO staffing and their responsibilities to implement the Plan.

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Annex 1: Unit 1 V. C. Summer Nuclear Station 2.1 Emergency Response Organization On-Shift Positional Responsibilities Table 2-1: V. C. Summer On-Shift Staffing and ERO Positions Minimum Shift Functional Area Major Tasks Shift Position Compliment ERO Position

1. Plant Operations Control Room Shift Supervisor 1 Interim Emer. Dir.

and Assessment Staff Control Room 1 Control Room of Operational Supervisor Supervisor Aspects Reactor Operator 2 Reactor Operator Auxiliary Operator 5 Auxiliary Operator

2. Emergency Command and Shift Supervisor (a) Interim Emergency Direction and Control Director Control

3. Notification & Emergency Shift Supervisor (a) Interim Emergency Communication Communications Director Communicator 1(e) State/County Communicator (e)

4. Radiological Dose Health Physics 1 Health Physics Accident Assess./Health Specialist Specialist Assessment and Physics Support of In-plant Surveys Health Physics 1 Health Physics Operational Specialist Specialist Accident Assessment Chemistry Chemistry Specialist 1 Chemistry Specialist

5. Plant System Technical Shift Engineer 1 Shift Engineer Engineering, Support Repair and Corrective Actions Repair and Mechanical Maint. 2 Mechanical Maint.

Corrective Mechanic Mechanic Actions Electrical Maint. 1 Electrical Maint.

Electrician Electrician I&C Maint. 1 I&C Maint. Mechanic Mechanic

6. In-Plant Protective Radiation Health Physics (b) Health Physics Actions Protection Specialist Specialist

7. Fire Fighting - Fire Brigade (c) Fire Brigade

8. First Aid and - Medical Emergency (b) Plant Personnel Rescue Response Team Operations

9. Site Access Security and Security Force (d) Security Force Control and Accountability Personnel Accountability (a) The Shift Supervisor shall function as the lED until relieved by the Emergency Director and Offsite Emergency Coordinator (b)May be provided by shift personnel assigned other functions (c) Per station Fire Protection Plan (d)Per VCSNS Security Plan (e) Telephone Communicator only PAGE 126 OF 193 EP-100 Rev 64

Annex 1: Unit 1 V. C. Summer Nuclear Station 2.2 Normal Shift Staffing The VCSNS operating organization includes the personnel encompassing both the management and operation of the unit. The maintenance and technical support personnel staffing the station organization are normally onsite daily Monday through Friday, holidays excluded. Plant personnel who are on duty on a 24-hour basis are listed in Table 2-1.

The Shift Supervisors, one of whom is on duty at all times, are responsible for the safe and efficient operation of the plant in accordance with the Technical Specifications and operating procedures during their assigned shift. The duty Shift Supervisor maintains control over plant operations as the senior licensed operator unless properly relieved by another member of the station staff who holds a valid SRO License. The Control Room Supervisor maintains control over the conduct of operations and personnel in the Control Room.

Shift Engineers perform accident assessment and evaluate operating conditions.

Organizationally, they report to the Manager- Operations. While on duty they diagnose off-normal events and report to the Shift Supervisor. The duties of the Shift Engineer do not include the manipulation of controls or the supervision of operators. When on duty, he will be available to the Shift Supervisor in the Control Room within 10 minutes of being summoned. During emergency conditions, the Shift Engineer will report to the Control Room and perform the duties similar to a Shift Technical Advisor (STA).

During off-hour shifts, the plant is staffed to support continuous operation. The normal operational staff includes (as a minimum) two licensed SROs (the Shift Supervisor and Control Room Supervisor), two licensed reactor operators, and five non-licensed operators. In addition, a Shift Engineer is assigned to each shift. The initial emergency organization during off-hours shifts consists of the operating staff, with the Shift Supervisor serving as the lED. The lED may be relieved in the Control Room by another SRO qualified as an lED. Initial actions in regard to first aid, firefighting, rescue, damage control, radiation monitoring, emergency classification, notifications, and dose assessment are performed by the normal operational staff.

2.3 Shift Emergency Response Positional Responsibilities The Unit 1 Annex, Table 2-1 outlines shift ERO positions required to meet minimum staffing and the major tasks assigned to each position.

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Annex 1: Unit I V. C. Summer Nuclear Station Section 3: Classification of Emergencies Section D in Part 2 of the Plan describes the classification of emergencies into four classification levels. They are: UNUSUAL EVENT, ALERT, SITE AREA EMERGENCY, and GENERAL EMERGENCY. These classification levels are entered by meeting the criteria of EALs provided in EPP-001, Activation and Implementation of Emergency Plan.

The EALs and the Technical Bases for the EALs are based on NEI 99-01, "Methodology for the Development of Emergency Action Levels." The details of EAL development are documented in an Emergency Action Level Technical Basis Document. Revision of the Technical Basis Document is controlled the same way as the VCSNS Emergency Plan, requiring the same reviews including a review in accordance with §50.54(q).

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Annex 1: Unit 1 V. C. Summer Nuclear Station Section 4: Emergency Facilities and Equipment 4.1 Unit-Specific Emergency Facilities A. Control Room The Control Room, located in the Control Building is designed to be habitable under accident conditions and shall serve as the onsite Emergency Control Center. Emergency lighting, power, air filtration, ventilation system and shielded walls enables the operators to remain in the Control Room to ensure that the reactor will remain in a safe condition. In addition, the operators shall be able to evaluate situational conditions and relay pertinent information and data to the appropriate onsite and offsite agencies and organizations during all emergencies. To ensure that shift personnel and other personnel assembled at the location can remain self-sufficient, emergency equipment and supplies shall be stored in, or near, the Control Room. The exact location and the type and quantity of emergency equipment and supplies available are specified in EPP-103, Emergency Equipment Checklist.

B. Technical Support Center (TSC)

The TSC, located in the Control Building is designed to be habitable under accident conditions and shall serve as the onsite Emergency Control Center after relieving the Control Room of command and control. Emergency lighting, power, air filtration, ventilation system and shielded walls enable the responders to remain in the TSC. In addition, the responders shall be able to evaluate situational conditions and relay pertinent information and data to the appropriate onsite and offsite agencies and organizations during all emergencies. This facility is located inside the Unit 1 Protected Area and provides the ability to respond and activate the facility in a timely fashion.

C. Operational Support Center (OSC)

The OSC is located on the first floor in the Auxiliary Service Building within the Protected Area and is separate from the Control Room. The OSC is the location from which survey, operations, and repair teams are dispatched into areas of the plant. It is the staging area for individuals who may be assigned to first aid, search, survey, rescue, repair, and corrective action teams.

The OSC Supervisor is responsible for managing the activities in the OSC including:

" Ongoing accountability of anyone dispatched from the OSC. The Control Room Supervisor or the Security Shift Supervisor track individuals who are assigned to the Control Room or the Security Force respectively.

• Radiological exposure control for the individuals within the OSC

" Mobilizing individuals on the emergency roster needed to fill the positions in the OSC and other support personnel such as materials and warehouse personnel The OSC is activated with a minimum staff within about 60 minutes after the declaration of an Alert, SAE, or GE.

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Annex 1: Unit 1 V. C. Summer Nuclear Station Equipment and supplies for the OSC include protective clothing, dosimetry, and sampling and survey equipment to be used by the OSC teams.

Radiological exposure controls for the OSC include monitoring conditions and relocation if necessary.

Tools and parts available for normal plant maintenance are also available for damage control operations during emergencies.

In the event the OSC becomes uninhabitable, Emergency Plan Implementing Procedures provide details on how to relocate OSC personnel.

D. Onsite Laboratories Chemistry laboratories located on the 412' elevation in the Control Building are available for emergency response during an accident. The laboratories can receive power from the plant's emergency diesel generators. General capabilities include:

" Radionuclide identification in various sample media

• Analysis and measurement of radionuclides in samples taken within the plant and samples taken in the plant site and offsite environment E. First Aid Treatment Area First aid treatment areas are located onsite for the treatment of those individuals requiring first aid. These areas are located at the Radiation Control Area Control Point at the 412' elevation of the Control Building and at the 436' elevation of the Service Building.

Medical equipment and supplies are available at these locations.

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Annex 1: Unit 1 V. C. Summer Nuclear Station 4.2 Assessment Resources A. Onsite Meteorological Monitoring Instrumentation

1. Redundant wind and temperature sensors are installed on a 61-meter self-supporting tower for Unit 1. Instrument elevators and 8-foot instrument booms are installed to raise and lower the sensors for easier maintenance. Measurements from these instruments provide indications to various points on the site, including recorders within the Control Room. A dew point sensor is installed near the base of the tower. A total precipitation sensor is installed on an individual pedestal near the tower. Data processing and recording equipment are located at the base of the tower. The tower is located about 1563 feet west of the Reactor Building at elevation 436 feet above MSL.

The Reactor Building is at elevation 436 feet above MSL, and Monticello Reservoir is filled to elevation 425 feet above MSL. Elevations in the site vicinity range from below 230 feet on the Broad River to over 600 feet near Little Mountain. The tower-mounted sensors are as follows:

a. At 61 meters above ground level, the upper wind speed and wind direction sensors, as well as the upper temperature sensors for the 10-61 meter differential temperature measurements are mounted on the 8-foot instrument boom.

b. At 40 meters above ground level, the upper temperature sensors for the 10-40 meter delta temperature measurement is mounted on the 8-foot instrument boom.

c. At 10 meters above ground level, the lower wind speed and wind direction sensors, as well as the lower temperature sensors for the 10-61 and 10-40 meter differential temperature measurements and ambient temperature readings are mounted on the 8-foot boom. Data from the meteorological measurements system are provided to an onsite data capture computer (which is capable of various data manipulations). Meteorological data necessary for the estimation of offsite dose projections is available via terminals to personnel in the Control Room, TSC, and EOF. When the onsite meteorological tower is not available for the estimation of offsite dose projections, meteorological data from the NWS in Columbia, South Carolina, will be used.

B. Onsite Radiation Monitoring Equipment The onsite radiation monitoring capability includes an installed process, effluent, and area RMS; portable survey instrumentation; counting equipment for radiochemical analysis; and a personnel dosimetry program to record integrated exposure. Some onsite equipment is particularly valuable for accident situations and are listed .in Table 4-1, Radiation Monitoring System Description.

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Annex 1: Unit 1 V. C. Summer Nuclear Station Table 4-1: Radiation Monitoring System Description Instrument Channel Location Range Alpha Gamma Monitor RM G1 Control Room 0.1 mr/hr -10 r/hr RM G2 Radio Chemical Laboratory 0.1 mr/hr -10 r/hr RM G3 Sampling Room 0.1 mr/hr -10 r/hr RM G4 Hot Machine Shop 0.1 mr/hr -10 r/hr RM-G5 Reactor Building Personnel Access 0.1 mr/hr -10 r/hr RM G6 Reactor Building Refueling Bridge 0.1 mr/hr -10 r/hr RM G7 Reactor Building 1 r/hr - 107 r/hr RM G8 Fuel Handling Building Refueling Bridge 0.1 mr/hr -10 r/hr RM G9 Auxiliary Building Demineralizer Area 0.1 mr/hr -10 r/hr RM G10 Waste Gas Decay Tank Area 0.1 mr/hr -10 r/hr RM G11 Auxiliary Building Drumming Area 0.1 mr/hr -10 r/hr RM G12 Auxiliary Building Waste Holdup Tank Area 0.1 mr/hr -10 r/hr RM G13 Auxiliary Building Charging Pump Area 0.1 mr/hr -10 r/hr RM G14 Reactor Building In Core Instrumentation Area 0.1 mr/hr -10 r/hr RM G15 Movable Monitor 0.1 mr/hr -10 r/hr RM G16 Turbine Building 0.1 mr/hr -10 r/hr RM G17A Reactor Building Manipulator Crane 1 mr/hr -100 r/hr RM G17B Reactor Building Manipulator Crane 1 mr/hr -100 r/hr RM G18 Reactor Building 1 r/hr -10 7 r/hr RM G19A Main Steam Line 0.1 mr/hr -10 7 mr/hr RM G19B Main Steam Line 0.1 mr/hr -107 mr/hr RM G19C Main Steam Line 0.1 mr/hr -107 mr/hr Atmospheric Radiation Monitors RM-1A Control Room Supply Air Particulate 4.7 x 1011 to 1 x 10-7 pCi/cc Gas: 2 x 106 to 2 x 102 pCi/cc Iodine 2 x 10-11 to 1 x 10.7 pCi/cc RM-A2 Reactor Building Air Samples Particulate 5.5 x 10' 1 to 1 x 10-7 pCi/cc Gas: 2.6 x 10-6 to 2 x 10-2 pCi/cc Iodine 2 x 1011 to 2 x 107 pCi/cc RM A3 Main Plant Vent Particulate 4.7 x 10"1 to 1 x 10-' pCi/cc Gas: 2.6 x 10-6 to 2 x 10-2 pCi/cc Iodine: 2 x 101 1 to 2 x 10-7 pCi/cc PAGE 132 OF 193 EP-1 00 Rev 64

Annex 1: Unit 1 V. C. Summer Nuclear Station Table 4-1: Radiation Monitoring System Description (continued)

Instrument Channel Location Range Atmospheric Radiation Monitors (continued)

RM A4 Reactor Building Purge Exhaust Particulate 4.7 x 10"11 to 1 x 10-7 pCi/cc Gas: 2.6 x 106 to 2 x 10-2 pCi/cc Iodine: 2 x 1011 to 2 x 10-7 pCi/cc RM A6 Fuel Handling Building Exhaust Particulate 4.7 x 10-11 to 1 x 10-7 pCi/cc Gas: 2.6 x 10-6 to 2 x 10-2 pCi/cc Iodine: 2 x 1011 to 2 x 10-7 pCi/cc RM A7 Sampling Rm Monitor (Movable) Particulate 4.7 x 10-11 to 1 x 10-' pCi/cc Gas: 2.6 x 10-6 to 2 x 10-2 pCi/cc Iodine: 2 x 1011 to 2 x 10-7 pCi/cc RM A8 Spent Fuel Area Monitor (Movable) Particulate 4.7 x 10-11 to 1 x 10- pCi/cc Gas: 2.6x 10-6to2x 10-2 pCi/cc Iodine: 2 x 1011 to 2 x 10-7 pCi/cc RM A9 Condenser Exhaust Monitor 4 xl06 to 4 x 10-2 pCi/cc RM A10 Waste Gas Discharge 2 x 10-4 to 2 x 100 pCi/cc RM A11 Auxiliary Building Ventilation Monitor 2 x 10-6 to 2 x 10-2 pCi/cc RM A12 Movable Atmospheric Monitor 4.7 x 1011 to 1 x 10-7 pCi/cc 3 5 RM A13 Main Plant Vent 8.6 x 10- to 8.6 x 10 pCi/cc RM A14 Reactor Building Purge Exhaust 8.6 x 10- 3 to 8.6 x 105 pCi/cc Liquid Radiation Monitors RM Li Primary Coolant Letdown Monitor 1 x 10-3 to 1 x 103 pCi/cc RM L2A Component Cooling Monitors 1 x 10-6 to 2 x 10-2 pCi/cc RM L2B Component Cooling Monitors 1 x 10.6 to 2 x 10-2 pCi/cc RM L3 Steam Generator Blowdown 1 x 10-6 to 2 x 10-2 pCi/cc RM L4 Spent Fuel Cooling Water Monitor 1 x 106 to 2 x 10-2 pCi/cc RM L5 Liquid Waste Effluent 1 x 10-6to 2 x 10-2 pCi/cc RM L6 Boron Recycle 1 x 10-6 to 2 x 10 2 pCi/cc RM L7 Nuclear Blowdown Waste Effluent 1 x 10s to 2 x 10-2 PCi/cc RM L8 Turbine Building Sump 2 x 10-7 to 2 x 10-3 pCi/cc RM L9 Liquid Waste Effluent 1 x 10-6 to 2 x 10-2 pCi/cc RM L10 Steam Generator Blowdown Effluent RM 1 x 10-6 to 2 x 10-2 pCi/cc RML11 Condensate Polisher Backwash Effluent 1x 10-6 to 1 x 10-3 pCi/cc PAGE 133 OF 193 EP-100 Rev 64

Annex 1: Unit 1 V. C. Summer Nuclear Station

1. Area Radiation Monitoring The area monitoring system provides information on existing radiation levels in various areas of the plant to ensure safe occupancy. It is equipped with Control Room and local readout and audible alarms to warn personnel of a elevated radiation level.

2. Radiological Noble Gas Effluent Monitoring The wide range gas monitors are installed on normal station effluent release points.

Each monitor system has a microprocessor which uses digital processing techniques to analyze data and control monitor functions. These monitors provide readout and alarm functions to the Control Room.

3. Radioiodine and Particulate Effluent Monitoring The wide range gas monitor includes a sampling rack for collection of the auxiliary building vent stack particulate and radioiodine samples. Filter holders and valves are provided to allow grab sample collection for isotopic analyses in the station's counting rooms. The sampling rack is shielded to minimize personnel exposure. The sampling media will be analyzed by a gamma ray spectrometer which uses a gamma spectrometer system. In addition, Silver Zeolite cartridges are available to further reduce the interference of noble gases.

4. High-Range Containment Radiation Monitors Two high-range containment radiation monitors are installed. The monitors will detect and measure the radiation level within the reactor containment during and following an accident. The range of the monitors is provided in Table 4-1.

5. In-plant Iodine Instrumentation Effective monitoring of increasing iodine levels in buildings under accident conditions will include the use of portable instruments using Silver Zeolite as a sample media. It is expected that a sample can be obtained, purged, and analyzed for iodine content within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

C. Onsite Process Monitors An adequate monitoring capability exists to properly assess the plant status for all modes of operation and is described in the Unit 1 FSAR. The operability of the post-accident instrumentation ensures information is available on selected plant parameters to monitor and assess important variables following an accident. Instrumentation is available to monitor the parameters in Technical Specifications.

The unit's Emergency Operating Procedures assist personnel in recognizing inadequate core cooling using applicable instrumentation.

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Annex 1: Unit 1 V. C. Summer Nuclear Station D. Seismic Monitors VCSNS has provided seismic instrumentation for onsite monitoring of the nuclear station.

Triaxial time history accelerometers are operable onsite with recorders located in the relay room below the Control Room. An indication and/or an audible alarm in the Control Room is actuated (1) when the triaxial seismic switch at the Reactor Building foundation mat signals that the OBE acceleration has been exceeded in either of the horizontal directions or in the vertical direction, (2) when any of the 12 elements of each component of the triaxial response spectrum recorder at the Reactor Building foundation mat exceeds the frequency acceleration setpoint, or (3) when the seismic accelerometer at the Reactor Building foundation mat detects acceleration greater than 0.01g in either horizontal direction or greater than 0.0067g in the vertical direction. Also a South Carolina Seismic Network seismometer is located about 3.2 miles ESE of the VCSNS Unit 1. This seismometer near Jenkinsville has been operational since November 1973, and is monitored by the University of South Carolina. The South Carolina Seismic Network seismometer provides background information relative to seismic activity in the area, including confirmation of earthquake occurrences and magnitudes.

E. Onsite Fire Detection Instrumentation The fire detection system is designed in accordance with applicable National Fire Protection Association (NFPA) standards. The system is equipped with electrically supervised ionization smoke and heat detectors to quickly detect any fires and the instrumentation to provide local indication and Control Room annunciation. In addition to the smoke and heat detection systems, each fire protection Carbon Dioxide, Halon, or water system is instrumented to inform the Control Room of its actuation or of system trouble.

In the event that a portion of the fire detection instrumentation is inoperable, fire watches in affected areas may be required.

Further details on the unit's fire detection system can be found in the FSAR and Fire Protection Plan.

F. Dose Projection Model The dose projection software system is comprised of a series of software components that function in a multi-tasked Windows environment. The computer receives data from external devices including meteorological and plant effluent monitors. Data can be received via serial port devices or over a LAN/WAN connection. Reports are displayed on a color monitor and copies of screens can be made on a color printer. Also, reports can be sent via LANIWAN connection to central control units.

Input data is available periodically from measuring devices on a meteorological tower and from effluent monitors that measure concentrations or dose. Calculations are made in the computer that can be used to determine the health impact of the release. The user schedules all run from a GUI interface.

The software and the data it uses are stored in pre-allocated files on the hard disk. The keyboard and mouse are used to make entries in response to prompts on the color monitor to initiate all calculations.

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Annex 1: Unit 1 V. C. Summer Nuclear Station Dose calculations for flat terrain are made using a Gaussian plume model while a particle tracking model is used for more complex terrain environments.

The released material is tracked in the environment as it is carried by the wind and dispersed. The three most important parameters are wind speed, wind direction, and atmospheric turbulence. The wind speed determines the initial dilution and plume travel speed. The wind direction determines the effluent plume trajectory. The turbulence determines the rate of spread or growth of the plume. These factors, along with assumptions related to the rate of deposit of particulate matter, are used to determine plume concentration and deposition as a function of location and time.

The accumulated doses to a stationary person are computed, based on the estimated variation of the effluent concentration and deposition. The plume tracks are plotted on site and local maps.

The time-integrated doses resulting from a longer exposure or release can be calculated and results plotted or printed in tabular form. For proper display of time-integrated long-term releases, doses from each release are added on the grid and an isopleths (filled contour showing potentially dangerous areas) is plotted.

All calculations are run from a master function menu with selections made using the system mouse.

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Annex 1: Unit I V. C. Summer Nuclear Station Section 5: Emergency Measures 5.1 Unit Protective Actions During emergencies, personnel in Unit 1 will be provided instruction by the Control Room or TSC regarding actions they are to take for their protection. Protective actions for site personnel are take immediate cover, assembly, or evacuation of an area or the site.

Protective actions will be issued individually or in combination, based on the health and safety of site personnel. There are four distinct zones of the site that personnel may encounter when protective actions are issued. These zones include: Vital Area, Protected Area, the Owner Controlled Area (OCA), and the Nuclear Exclusion Area. Each of these zones has well-established entrance and exit points. These areas are well defined and presented in the SOT that is provided to each employee annually. Take Immediate Cover may be used in a security threat situation where there is little or no time to relocate personnel, or in conjunction with a protective action to evacuate the Protected Area.

Assembly may be used to move personnel into an area where they can be controlled and communicated with in an organized manner. Personnel may be held in the Assembly Area until personnel accountability has been established for the Protected Area. Personnel may be directed to evacuate the Protected Area or the site. If there is a need for personnel or vehicle monitoring after evacuation, personnel will be directed to an offsite assembly area for that activity. If necessary, decontamination will be conducted at the offsite holding area.

5.2 Unit Assembly Areas There are two designated Offsite Holding Areas available if it is determined that onsite personnel should be relocated offsite for further direction and/or monitoring of their vehicles. The primary offsite assembly area is the South Carolina Fire Academy (SCFA) located south of the Station on SC 215. Dependent on wind direction, the SCFA may not be feasible as an offsite assembly area. The lake recreation area located at the north end of the Monticello Reservoir will be used as the alternate offsite assembly area. Signs are posted outside of VCSNS to direct personnel to the designated locations.

The scope of the emergency will dictate the assembly area location, how personnel will be released from the area, and whether or not they will be able to return to their work spaces outside the Protected Area.

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Annex 1: Unit I V. C. Summer Nuclear Station 5.3 Unit Evacuation Routes There are two exits from the Unit 1 OCA. Both of these exits will be used provided that there is evacuation prior to any release of radioactive material. This permits the nonessential personnel at the site an opportunity to depart the site using their personal vehicles. In the event that there is, or has been a radiological release, personnel will be directed as to which exit to use and the egress route to minimize personnel exposure and vehicle contamination.

There are also two distinct exits from the Nuclear Exclusion Area. The North access road and the South access road (off Fairfield Pump Storage road and through the construction site for Units 2 & 3) provide entry and exit from the Exclusion Area in the event of an emergency. The use of these entry and exit points is determined based on radiological conditions and wind direction. Access to the Nuclear Exclusion Area is controlled at these locations during a declared emergency of Alert or higher classification.

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Appendix I V. C. Summer Nuclear Station Appendix 1 - References American Nuclear Insurers (ANI) Bulletin #5B Accident Notification Procedures for Liability Insured, 1981 EPA-400-R-92-001 Manual of Protective Action Guides and Protective Actions for Nuclear Incidents FEMA-REP-10, Section E.6.2.1 Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants, November 1985 NEI 99-01, Revision 5 Methodology for Development of Emergency Action Levels NRC Bulletin 2005-02 Emergency Preparedness and Response Actions for Security-Based Events, July 18, 2005 NRC Bulletin 80-15 Possible Loss of Emergency Notification System (ENS) with Loss of Offsite Power, June 18, 1980 NRC Generic Letter 91-14 Emergency Telecommunications, September 23, 1991 NRC Information Notice 85-44 Emergency Communication System Monthly Test, May 30, 1985 NRC Regulatory Guide 1.101 Emergency Planning and Preparedness for Nuclear Power Reactors, Revision 3, August 1992 NRC RTM-96 Response Technical Manual, March 1996 NUREG-0696 Functional Criteria for Emergency Response Facilities NUREG/BR-0230, RCM-96 Response Coordination Manual, 1996 NUREG-0654/FEMA-REP-1 Rev. 1 Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants NUREG-0728 Incident Response Plan, June 1987 NUREG-0737 Clarification of TMI Action Plan Requirements Regulatory Issue Summary 2004-13 Consideration of Sheltering in Licensee's Range of Protective Action Recommendations, August 2, 2004 VCSNS Unit 1 Final Safety Analysis Report VCSNS Security Plan VCSNS Offsite Dose Calculation Manual PAGE 139 OF 193 EP-100 Rev 64

Appendix 2 V. C. Summer Nuclear Station Appendix 2 - Letters of Agreement VCSNS maintains Letters of Agreement and/or Memorandums of Understanding with the following:

The state of South Carolina, Emergency Management Division (This letter includes the South Carolina Department of Health and Environmental Control.)

The County of Newberry The County of Lexington The County of Richland The County of Fairfield Fairfield County Emergency Medical Services Lexington County Emergency Medical Services The Department of Energy, Savannah River Office Palmetto Health Richland Hospital Radiation Emergency Assistance Center/Training Site, DOE, Oak Ridge, TN Pinner Clinic The Institute of Nuclear Power Operations Jenkinsville - Monticello - Horeb Volunteer Fire Department Greenbrier- Bethel Volunteer Fire Department Blair Volunteer Fire Department Feasterville Volunteer Fire Department Lebanon Volunteer Fire Department Community Volunteer Fire Department Columbia Metropolitan Airport Fire and Rescue South Carolina Fire Marshal's Office/South Carolina Fire Academy NC Department of Crime Control and Public Safety - Div of Emergency Management Letters of Agreement and/or Memorandums of Understanding are reviewed annually, updated as required, and certified. Current copies are retained in the Contract License and Permit Tracking System (CLP).

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Appendix 3 V.C. Summer Nuclear Station Appendix 3 - List of Emergency Plan Procedures Implementing Procedures Plan Section Implemented Activation and Implementation of Emergency Plan (EPP- Part II Sections B & D 001)

Unusual Event (EPP-001.1) Part II Sections H, D.1, E.2 & G.3; Annex 1 Section 3 Alert (EPP-001.2) Part II Sections H, D.1, E.2 & G.3; Annex 1 Section 3 Site Area Emergency (EPP-001.3) Part II Sections H, D.1, E.2 & G.3; Annex 1 Section 3 General Emergency (EPP-001.4) Part II Sections H, D.1, E.2 G.3 & J; Annex 1 Section 3 Communication and Notification (EPP-002) Part II Sections E & F Plant Radiological Surveying (EPP-003) Part II Section H.6, 7, & 8 Offsite Dose Calculation (EPP-005) Part II Section I; Annex 1 F Core Damage Assessment Methodology (CP-308) Part II Section 1.3 Technical Support Center (EPP-023) Part II Sections A, B, C, & H; Annex 1 Section 4.B Operational Support Center (EPP-028) Part II Sections A, B, K, H, & M; Annex 1 Section 4.C Emergency Operations Facility (EPP-051) Part II Sections A, B, C, H, & K Emergency Information Plan (EPP-052) Part II Sections A, B, & H Onsite Personnel Accountability and Evacuation (EPP- Part II Sections D, J:

012) Annex 1 Sections 4.C & 5.1 Environmental Monitoring (EPP-007) Part II Sections C.2, H, & I Onsite Medical (EPP-009) Part II Section L Post Recovery and Reentry (EPP-017) Part II Section M Part II Sections H.5 & K.1; PersonnelNehicle Decontamination (EPP-010) Annex 1 Personnel Search and Rescue (EPP-01 1) Part II Section J.5 Fire Emergency (EPP-013) Part I Section H; Part II Section I; Annex 1 Section D Toxic Release (EPP-014) Part I Section H Natural Emergency (EPP-015) Part I Section H Emergency Personnel Exposure Control (EPP-020) Part II Section K Activation of the Early Warning Siren System (EPP-021) Part II Section E.6 Hostile Action (EPP-027) Part I Section H; Part II Section D; Appendix 4 PAGE 141 OF 193 EP-100 Rev 64

Appendix 3 V. C. Summer Nuclear Station Administrative Procedures Plan Section Reference Emergency Preparedness (SAP-0127) Part Ii Section P Emergency Equipment Checklists (EPP-103) Part II Section H; Annex 1 Verification of Communications Operability (EPP- Part II Section F 104)

Conduct of Drills and Exercises (EPP-1 05) Part II Section N Emergency Preparedness Performance Indicator Part I Procedure (EPP-106)

Conduct of Fire Brigade Drills (EPP-1 07) Part II Section N.2 Emergency Action Level Technical Basis Part 11Section D; Annex 1 Document (EPP-108) Part____SectionD;_Annex_1 Equipment Related to Emergency Preparedness Annex 1 (EPP-1 09)

Emergency Action Level Reference Manual (EPP- Part II Section D; Annex 1 110)

Emergency Preparedness Oversight Committee Part I (EPP-111)

Maintenance of the Early Warning Siren System Part II Section E.6 (EWSS) (EPMP-100)

General Employee Training Emergency Plan Part 11Section 0 Training and Drills (TQP-0605)

Emergency Planning Telephone Directory Part II Section P.10 Offsite Dose Calculation Manual (ODCM) Part II H & I; Annex 1 Evacuation Time Estimate (ETE) Part II Section J.8; Appendix 5 On-shift Staffing Analysis Part 2 Section B and Table B-la; Annex 1 Table 2-1 and Section 2.2 PAGE 142 OF 193 EP-1 00 Rev 64

Appendix 4 V. C. Summer Nuclear Station Appendix 4 - Abbreviations, Acronyms, and Definitions Accident (Incident or Event) An unintentional or unexpected event resulting in radiological exposure, physical injury, or physical damage to property.

ALARA (As Low As Reasonably Achievable) A radiation protection philosophy requiring that personnel exposure to radiation and radioactive material be kept not only within regulatory limits but be maintained As Low As Reasonably Achievable in the light of current technology with appropriate consideration for economic and social factors and for the benefits to be expected. ALARA applies not only to minimizing occupational exposure to radiation workers, but also to limiting the radioactivity of plant effluent and minimizing the potential for exposure to the public.

Annual (Annually) At least once per 365 days + 90 days, unless specifically identified as "based on a calendar year".

ANI American Nuclear Insurers ANS Alert and Notification System CDE (Committed Dose Equivalent) Total Dose from internally deposited radionuclide over subsequent 50 year period to a specific organ.

CEDE (Committed Effective Dose Equivalent) Sum of risk-weighted Committed Dose Equivalents to organs.

Certified Official approval by written letter from the EP Manager verifying the item(s) to be accurate and up to date.

CET Core Exit Thermocouple CFR (Code of Federal Regulations) The Code of Federal Regulations is a codification of the general and permanent rules published in the Federal Register by the Executive departments and agencies of the federal government. The Code is divided into 50 titles that represent broad areas subject to federal regulation. Each title is divided into chapters that usually bear the name of the issuing agency.

Each chapter further subdivided into parts covering specific regulatory areas.

Cold Shutdown A reactor condition in which the coolant temperature has been reduced to 200°F or below and the pressure has essentially been reduced to atmospheric pressure. This is also known as Mode 5.

CA (Contaminated Area) An area where radioactive material is deposited where it is not desired.

CR Control Room DAC (Derived Air Concentration) The concentration of a given radionuclide in air.

DDE (Deep Dose Equivalent) Dose equivalent from external radiation at a tissue depth of 1 centimeter.

DEP Drill/Exercise Performance DHEC (SCDHEC) Department of Health and Environmental Control (SC)

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Appendix 4 V. C. Summer Nuclear Station DHS Department of Homeland Security (US)

DOE Department of Energy (US)

Dose (Radiation) The quantity of radiation absorbed per unit of mass by the body or by any portion of the body. The unit of radiation dose is the RAD.

Dose Equivalent Quantity that expresses all radiations on a common scale for calculating the absorbed dose. It is defined as the product of the absorbed dose in rads and certain Dose Rate modifying factors. The unit is rem.

Dose delivered per unit time.

Dosimeter An instrument used for measuring the absorbed dose, exposure, or similar radiation quantity.

Dosimetry A system of dosimeters for evaluating the absorbed dose, exposure, or similar radiation quantity.

DNR (SCDNR) Department of Natural Resources (SC)

EAB Exclusion Area Boundary (Nuclear Exclusion Area)

EALs Emergency Action Levels EAS (Emergency Alert System) A network of broadcast stations and interconnecting facilities authorized by the Federal Communications Commission to operate in a controlled manner during a war, state of public peril, disaster or other national, state and local emergencies.

ECO Emergency Control Officer ED Emergency Director EMD (SCEMD) Emergency Management Division (SC)

ENF (Emergency Notification Form) A template form provided by the State of SC for the purpose of disseminating information to offsite agencies regarding an emergency.

ENS Emergency Notification System EOC Emergency Operations Center EOF Emergency Operations Facility EPA Environmental Protection Agency EPIO Emergency Public Information Organization EPIP (Emergency Plan Implementing Procedure) Detailed procedures which provide guidance to individuals and groups for implementation of the provisions of the emergency plan.

EPRI Electric Power Research Institute EPZ (Emergency Planning Zone) A generic area defined about a nuclear facility to facilitate offsite emergency planning and develop a significant response base. It is defined for the plume and ingestion exposure pathways.

ERDS Emergency Response Data System ERF Emergency Response Facilities ERO Emergency Response Organization EMNet Emergency Management Network ETE Evacuation Time Estimate Evacuation The removal of people from an area on an emergency basis to avoid or reduce possible short term radiation exposure.

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Appendix 4 V. C. Summer Nuclear Station Exposure Being exposed to ionizing radiation, radioactive materials, or other hazardous substances.

External Dose Dose from a source of radioactive material outside the body.

FBI Federal Bureau of Investigation FCEMS Fairfield County Emergency Medical Services FEMA Federal Emergency Management Agency HEPA High-efficiency particulate air filter Frisker Radiation monitoring equipment. This is a hand-held probe that is slowly passed near the area of interest to determine the presence or absence of radioactive material.

FRMAP Federal Radiation Monitoring and Assessment Plan FSAR Final Safety Analysis Report Gamma Rays High-energy, short-wavelength electromagnetic radiation.

Gamma rays are essentially similar to x-rays, but are usually more energetic and are nuclear in origin.

HP (Health Physics) A general term used as a modifying phrase that may refer to facilities, equipment, programs, etc. used in the discipline of Health Physics. A profession devoted to the protection of man and his environment from unwarranted radiation exposure.

HRA (High Radiation Area) Any area, accessible to personnel, in which there exists radiation originating in whole or in part within licensed material at such levels that a dose equivalent could be received in any one hour in excess of 100 millirem but less than 1000 millirem at 30 centimeters.

HOSTILE ACTION An act toward a nuclear power plant or its personnel that includes the use of violent force to destroy equipment, takes hostages, and/or intimidates the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, projectiles, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the nuclear power plant. Non-terrorism-based EALs should be used to address such activities, (e.g., violent acts between individuals in the Owner Controlled Area.)

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.

HPN Health Physics Network HSOC Homeland Security Operations Center I&C Instrument and Controls lED Interim Emergency Director Ingestion Exposure Pathway The means of ingesting radioactive fallout from the plume through the consumption of food or water within a 10 - 50 mile radius of the site.

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Appendix 4 V. C. Summer Nuclear Station Appendix 4 V. C. Summer Nuclear Station INPO (Institute of Nuclear Power Operations) An organization established by the utilities to set up standardized operations. By Letter of Agreement, INPO agrees to provide the service provided by their organization, coordinate the activities of the organization and provide telephone contacts of the organization during an emergency at the Station.

Internal Dose Dose from a source of radioactive material within the body (as a result of deposition of radionuclides in body tissue).

Ionization Chamber An instrument that detects and measures ionizing radiation by measuring the electrical current that flows when radiation ionizes gas in a chamber, making the gas a conductor of the electricity.

JIC (Joint Information Center) A center set up in a central location where public information officers from the involved agencies come together to ensure coordination of information to be released to the media and the public.

This center becomes the central point for media access to latest developments and emergency information. All information released is coordinated among the agencies involved to ensure its consistency and accuracy. This may also be referred to as the News Media Area.

KI Potassium Iodide LCEMS Lexington County Emergency Medical Services Liquid Effluent Stream Processed liquid wastes containing radioactive materials resulting from the operation of a nuclear power reactor.

LOCA (Loss of Coolant Accident) A loss of coolant accident can result from an opening in the primary cooling system, such as a pipe break or a stuck open relief valve.

Low Population Zone The area which surrounds the exclusion zone and includes populations from the site out to three miles from the Unit 1 Reactor Building.

MAELU Mutual Atomic Energy Liability Underwriters MSL Mean Sea Level MERT Medical Emergency Response Team Monitor, Radiation A radiation detector whose purpose is to measure the level of ionizing radiation (or quantity of radioactive material).

Monitoring The continuous or periodic collection and assessment of pertinent information.

Monthly At least once per 31 days + 7 days NEI Nuclear Energy Institute NFPA National Fire Protection Association NRC (USNRC) Nuclear Regulatory Commission (US)

NRF National Response Framework NSSS Nuclear Steam Supply System PAGE 146 OF 193 EP-1 00 Rev 64

Appendix 4 V. C. Summer Nuclear Station NUREG-0654/FEMA REP1, Rev 1 Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants: The purpose of this guidance and upgraded acceptance criteria is to provide a basis for NRC licensees, and State and local governments to develop radiological emergency plans and improve emergency preparedness.

NWS National Weather Service Occupational Dose A dose received by a permanent or temporary employee while engaged in activities relating to the use, possession, or surveillance of licensed radidactive material or sources of ionizing radiation. Occupational dose shall not include any exposure of an individual to radiation for the purpose of medical diagnosis or therapy. Determination of occupational dose is the responsibility of the licensee.

OCA (Owner Controlled Area) The area bounded by the Protected Area on the inside and by the Primary Vehicle Barrier System (VBS) on the outside.

OEC Offsite Emergency Coordinator ORMC Offsite Radiological Monitoring Coordinator OSC Operational Support Center PA (Protected Area) the area immediately surrounding the nuclear station encompassed by physical barriers (double fence) and access to which is controlled for nuclear security purposes.

PAD Protective Action Directives PAG (Protective Action Guidelines) Projected total effective dose equivalent or committed dose equivalent values to individuals in the general population that warrant protective action following a release of radioactive materials. Protective actions would be warranted provided the reduction in individual dose expected to be achieved by carrying out the protective action is not offset by excessive risks to individual safety in taking the protective actions.

PAR Protective Action Recommendations PBX Private Branch Exchange Personnel Monitoring Equipment Devices designed to be worn or carried by an individual for the purpose of measuring occupational radiation doses, e.g. thermo luminescent dosimeters, pocket dosimeters, and finger badges.

PI&R Problem Identification & Resolution Plume Exposure Pathway The principal exposure sources from this pathway are:

External exposure to gamma radiation from the plume and from deposited materials Inhalation exposure from the passing radioactive plume.

Pocket Dosimeter An ionization chamber carried or worn by an individual for personnel dose monitoring.

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Appendix 4 V. C. Summer Nuclear Station Portal Monitor A walk-through radiation detector whose purpose is to detect beta and gamma emitting contamination on personnel exiting selected areas.

Posted Area An area in which radiation and/or contamination exists or might exist at levels such that the use of warning signs or devices is required.

PPE Personal Protective Equipment Projected Dose An estimate of the radiation dose that affected individuals could potentially receive if protective actions are not taken.

PF (Protection Factor) A measure of the protection afforded by a respirator; the ratio of the concentration of the radionuclide in the ambient atmosphere to the concentration inside the respiratory equipment (usually inside the facepiece) under conditions of use.

Protective Action Those emergency measures taken before or after an uncontrolled release of radioactive material has occurred for the purpose of minimizing radiological exposure to individuals. Also, measures that can be taken for the physical protection of plant personnel from a security or other hazards event.

Protective Clothing Used interchangeably with the term anti-contamination clothing and has the same general meaning in radiation protection procedures.

QAPD Quality Assurance Program Description Quarterly At least once per 92 days + 23 days Rad A measure of the dose produced by directly or indirectly ionizing radiation in terms of the energy absorbed per unit mass of any irradiated material. One rad is the dose corresponding to 100 ergs of absorbed energy per gram of irradiated material.

Radiation, Ionizing Any or all of the following: alpha, beta, gamma, X-rays, neutrons, high speed protons or electrons, and other atomic particles (sound, radio waves, visible, and infrared or ultraviolet light are non-ionizing forms of radiation).

RA (Radiation Area) Any area, accessible to personnel, in which radiation levels could result in an individual receiving a dose equivalent in excess of 5 millirem, but less than 100 millirem in 1 Hour at 30 centimeters.

Radiation Exposure Refers very broadly to the act or state of being exposed to ionizing radiation.

Radiation Protection Used interchangeably with the term health physics.

RWP (Radiation Work Permit) A document providing radiological evaluation and authorization to perform specific activities involving personnel exposure to ionizing radiation or radioactive material. It describes the radiological conditions and specifies radiation protection controls to be used when performing the activities.

Radioactive Contamination The presence of radioactive material in an undesired location. Contamination may be loose, fixed, or present in air.

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Appendix 4 V. C. Summer Nuclear Station Radionuclide A radioactive nuclide is one that has the capability of spontaneously emitting radiation.

RCS (Reactor Coolant System or Primary Coolant) The fluid circulated through the reactor to remove heat.

REAC/TS Radiation Emergency Assistance Center/Training Site Reactor Trip (SCRAM) An automatic procedure by which control rods are rapidly inserted into the core of a reactor to stop the chain reaction.

Recovery The process of reducing radiation exposure rates and concentrations in the environment to acceptable levels for unconditional occupancy.

Relocation The removal or continued exclusion of people from contaminated areas to avoid chronic radiation exposure.

Rem Special unit of any of the quantities expressed as dose equivalent. The dose equivalent in rem is equal to the absorbed dose in rads multiplied by the quality factor.

RMS Radiation Monitoring System RVLIS Reactor Vessel Level Indication System SAMGs Severe Accident Management Guidelines SCBA Self contained breathing apparatus SCE&G South Carolina Electric & Gas SCSN South Carolina Seismic Network Secondary Coolant A separate stream of coolant that is converted to steam by the primary coolant in a heat exchanger (steam generator) to power the turbine.

SRPD (Self-Reading Pocket Dosimeter) A self-reading dosimeter is a direct-reading pocket dosimeter shaped like a pen with a pocket clip. It is generally used to measure X and gamma radiation.

Semi-annually At least once per 184 days + 46 days Severe Accident: PWR A nuclear accident involving a loss of core cooling and damage so severe that there are core geometry changes and possible relocation of core materials, e.g. a core melt.

In accordance with the Severe Accident Management Guidelines, a severe accident has occurred when core exit thermocouple temperatures are greater than 1200 degrees F and actions to cool the core have been, and continue to be, unsuccessful. The plant is outside of the Design Bases for the station.

SHELTER The use of the closest available structure that will provide protection from exposure to an airborne plume.

SLED South Carolina Law Enforcement Division SOT Station Orientation Training SPDS Safety Parameter Display Systems SRO Senior Reactor Operator STA Shift Technical Advisor START Simple Triage and Rapid Treatment TEDE (Total Effective Dose Equivalent) Sum of the deep dose equivalent and the committed effective dose equivalent.

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Appendix 4 V. C. Summer Nuclear Station TLD (Thermo Luminescent Dosimeter) A dosimeter based on the effect of ionizing radiation on certain thermo luminescent crystals, in which radiation excites orbital electrons of some atoms to a higher energy state orbit than normal. Stimulating the crystal by controlled heating allows the electrons to return to normal orbit, thereby emitting discrete quanta of light proportional to the amount of ionizing radiation absorbed by the crystal. Emitted light can be measured and related to personnel dose from ionizing radiation.

TSC Technical Support Center USCG U.S. Coast Guard VBS (Vehicle Barrier System) security barrier delineated by the large rocks and vehicle search areas VCSNS (VCS) V.C. Summer Nuclear Station Weekly At least once per 7 days + 2 days X-Ray Highly penetrating radiation similar to gamma rays.

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Appendix 5 V.C. Summer Nuclear Station Appendix 5 - Evacuation Time Estimate Study The Evacuation Time Estimate Study was prepared by KLD Associates, Inc. This controlled document in its entirety is filed under separate cover and has been distributed to designated locations.

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Appendix 6 V.C. Summer Nuclear Station Appendix 6 - Regulatory Requirements Cross Reference Document Table No. Regulatory Requirement 1 10 CFR 50 App. E 2 10 CFR 50.47 3 NUREG-0654 PAGE 152 OF 193 EP-1 00 Rev 64

0 Appendix 6 V. C. Summer Nuclear Station Table I - 10 CFR 50 Appendix E - Emergency Planning and Preparedness for Production and Utilization Facilities REGULATION STATEMENT EPLAN OTHER COMMENTS The organization for coping with radiological emergencies IV A. shall be described, including definition of authorities, B.1 B.5 responsibilities, and duties of individuals assigned to the B licensee's emergency organization IV A. and the means for notification of such individuals in the E.2 event of an emergency.

IV A. 1 A description of the normal plant operating organization. B.1 A description of the onsite emergency response organization with a detailed discussion of:

IV A.2.a B.2, B.3, B.5 Authorities, responsibilities, and duties of the individual(s) who will take charge during an emergency; IV A2.b Plant staff emergency assignments; B.5 Authorities, responsibilities, and duties on an onsite emergency coordinator who shall be in charge of the IV A2.c exchange of information with offsite authorities B.2, B.4 responsible for coordinating and implementing offsite emergency measures.

A description, by position and function to be performed, of IV A.3 the licensee's headquarters personnel who will be sent to B.5.c, 8.7 the plant site to augment the onsite emergency organization.

Identification, by position and function to be performed, of persons within the licensee organization who will be responsible for making offsite dose projections, and a B5.b.2, 3, 4, 5,& 6 IV A.4 description of how these projections will be made and the results transmitted to State and local authorities, NRC, and other appropriate governmental entities.

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Appendix 6 V. C. Summer Nuclear Station REGULATION STATEMENT EPLAN OTHER COMMENTS IV A.5 Identification, by position and function to be performed, of A.3 other employees of the licensee with special qualifications for coping with emergency conditions that may arise.

Other persons with special qualifications, such as consultants, who are not employees of the licensee and who may be called upon for assistance for emergencies shall also be identified. The special qualifications of these persons shall be described.

IV A.6 A description of the local offsite services to be provided in L.1, 2, 3, 4 support of the licensee's emergency organization.

IV A.7 Identification of, and assistance expected from, C.1, 2, 3, 4 appropriate State, local, and Federal agencies with responsibilities for coping with emergencies.

IV A.8 Identification of the State and/or local officials responsible J.9 for planning for, ordering, and controlling appropriate protective actions, including evacuations when necessary.

IV B The means to be used for determining the magnitude of, 1.2,1.3,1.4,1.5,1.6, 1.7,1.8,1.9, and for continually assessing the impact of, the release of 1.10 radioactive materials shall be described, IV B (continued) including emergency action levels that are to be used as Annex 1, E.2, E.3, E.4 criteria for determining the need for notification and participation of local and State agencies, the Commission, and other Federal agencies, IV B (continued) and the emergency action levels that are to be used for Annex 1, J.7, J.9, J.10 determining when and what type of protective measures should be considered within and outside the site boundary to protect health and safety.

IV B (continued) The emergency action levels shall be based on in-plant Annex 1, 3.2, conditions and instrumentation in addition to onsite and offsite monitoring.

IV B (continued) These emergency action levels shall be discussed and D.2 agreed on by the applicant and State and local governmental authorities and approved by NRC.

IV B (continued) They shall also be reviewed with the State and local D.3 I___ _ Igovernmental authorities on an annual basis.

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Appendix 6 V. C. Summer Nuclear Station REGULATION STATEMENT EPLAN OTHER COMMENTS IVC The entire spectrum of emergency conditions that involve D.1 the alerting or activating of progressively larger segments of the total emergency organization shall be described.

IV C (continued) The communication steps to be taken to alert or activate E.2 emergency personnel under each class of emergency shall be described.

IV C (continued) Emergency action levels (based not only on onsite and Annex 1 offsite radiation monitoring information but also on readings from a number of sensors that indicate a potential emergency, such as the pressure in containment and the response of the Emergency Core Cooling System) for notification of offsite agencies shall be described.

IV C (continued) The existence, but not the details, of a message E.1 authentication scheme shall be noted for such agencies.

IV C (continued) The emergency classes defined shall include: (1) D.1 notification of unusual events, (2) alert, (3) site area emergency, and (4) general emergency. These classes are further discussed in NUREG - 0654; FEMA - REP - 1.

IV D.1 Administrative and physical means for notifying local, E.3, E.4 State, and Federal officials and agencies and agreements reached with these officials and agencies for the prompt notification of the public and for public evacuation or other protective measures, should they become necessary, shall be described. This description shall include identification of the appropriate officials, by title and agency, of the State and local government agencies within the EPZs.

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Appendix 6 V. C. Summer Nuclear Station REGULATION STATEMENT EPLAN OTHER COMMENTS IV D.2 Provisions shall be described for yearly dissemination to G.1, G.2 the public within the plume exposure pathway EPZ of basic emergency planning information, such as the methods and times required for public notification and the protective actions planned if an accident occurs, general information as to the nature and effects of radiation, and a listing of local broadcast stations that will be used for dissemination of information during an emergency. Signs or other measures shall also be used to disseminate to any transient population within the plume exposure pathway EPZ appropriate information that would be helpful if an accident occurs.

IV D.3 A licensee shall have the capability to notify responsible E.2.b.1 State and local governmental agencies within 15 minutes after declaring an emergency.

IV D.3 (continued) The design objective of the prompt public notification E.6 system shall be to have the capability to essentially complete the initial notification of the public within the plume exposure pathway EPZ within about 15 minutes.

The use of this notification capability will range from immediate notification of the public (within 15 minutes of the time that State and local officials are notified that a situation exists requiring urgent action) to the more likely events where there is substantial time available for the State and local governmental officials to make a judgment whether or not to activate the public notification system.

Where there is a decision to activate the notification system, the State and local officials will determine whether to activate the entire notification system simultaneously or in a graduated or staged manner. The responsibility for activating such a public notification system shall remain with the appropriate governmental authorities.

IV 4.E.1 Adequate provisions shall be made and described for H.1, H.2, H.5 emergency facilities and equipment, including:

Equipment at the site for personnel monitoring; IV 4.E.2 Equipment for determining the magnitude of and for H.5.b, H.5.d continuously assessing the impact of the release of radioactive materials to the environment; PAGE 156 OF 193 EP-100 Rev 64

Appendix 6 V. C. Summer Nuclear Station REGULATION STATEMENT EPLAN OTHER COMMENTS IV 4.E.3 Facilities and supplies at the site for decontamination of H.5.b, H.5.c onsite individuals; IV 4.E.4 Facilities and medical supplies at the site for appropriate L.2 emergency first aid treatment; IV 4.E.5 Arrangements for the services of physicians and other L.3 medical personnel qualified to handle radiation emergencies on-site; IV 4.E.6 Arrangements for transportation of contaminated injured L.3 individuals from the site to specifically identified treatment facilities outside the site boundary; IV 4.E.7 Arrangements for treatment of individuals injured in L.1 support of licensed activities on the site at treatment facilities outside the site boundary; IV 4.E.8 A licensee onsite technical support center and a licensee H.1, H.2 near-site emergency operations facility from which effective direction can be given and effective control can be exercised during an emergency; IV 4.E.9 At least one onsite and one offsite communications F.1 system; each system shall have a backup power source.

All communication plans shall have arrangements for emergencies, including titles and alternates for those in charge at both ends of the communication links and the primary and backup means of communication.

IV 4.E.9.a Where consistent with the function of the governmental N.2 agency, these arrangements will include:

Provision for communications with contiguous State/local governments within the plume exposure pathway EPZ.

Such communications shall be tested monthly.

IV 4.E.9.b Provision for communications with Federal emergency N.2 response organizations. Such communications systems shall be tested annually.

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Appendix 6 V. C. Summer Nuclear Station REGULATION STATEMENT EPLAN OTHER COMMENTS IV 4.E.9.c Provision for communications among the nuclear power N.2 reactor control room, the onsite technical support center, and the near-site emergency operations facility; and among the nuclear facility, the principal State and local emergency operations centers, and the field assessment teams. Such communications systems shall be tested annually.

IV 4.E.9.d Provisions for communications by the licensee with NRC N.2 Headquarters and the appropriate NRC Regional Office Operations Center from the nuclear power reactor control room, the onsite technical support center, and the near-site emergency operations facility. Such communications shall be tested monthly.

IV F.1.i The program to provide for: (a) The training of employees 0.2 and exercising, by periodic drills, of radiation emergency plans to ensure that employees of the licensee are familiar with their specific emergency response duties, and (b) The participation in the training and drills by other persons whose assistance may be needed in the event of a radiation emergency shall be described. This shall include a description of specialized initial training and periodic retraining programs to be provided to each of the following categories of emergency personnel:

Directors and/or coordinators of the plant emergency O.4.a organization; IV F.1 .ii Personnel responsible for accident assessment, including O.4.b control room shift personnel; IV F.l.iii Radiological monitoring teams; O.4.c IV F.1.iv Fire control teams (fire brigades); O.4.d IV F.1.v Repair and damage control teams; O.4.e IV F.i.vi First aid and rescue teams; O.4.f IV F.1.vii Medical support personnel; 0.4.h IV F.1.viii Licensee's headquarters support personnel; O.4.i IV F.1 .ix Security personnel. O.4.d.2 PAGE 158 OF 193 EP-100 Rev 64

Appendix 6 V. C. Summer Nuclear Station REGULATION STATEMENT EPLAN OTHER COMMENTS IV F.1 In addition, a radiological orientation training program shall O.4.g be made available to local services personnel; e.g., local emergency services/Civil Defense, local law enforcement personnel, local news media persons. G.5, P.3 IV F.2 The plan shall describe provisions for the conduct of N.1 emergency preparedness exercises as follows:

Exercises shall test the adequacy of timing and content of implementing procedures and methods, test emergency equipment and communications networks, test the public notification system, and ensure that emergency organization personnel are familiar with their duties.

IV F.2.a A full participation exercise which tests as much of the N.1 licensee, State and local emergency plans as is reasonably achievable without mandatory public participation shall be conducted for each site at which a power reactor is located.

IV F.2.b Each licensee at each site shall conduct an exercise of its N.1 onsite emergency plan every 2 years. The exercise may be included in the full participation biennial exercise required by paragraph 2.c. of this section. In addition, the licensee shall take actions necessary to ensure that adequate emergency response capabilities are maintained during the interval between biennial exercises by conducting drills, including at least one drill involving a combination of some of the principal functional areas of the licensee's onsite emergency response capabilities.

IV F.2.c Offsite plans for each site shall be exercised biennially N.1 with full participation by each offsite authority having a role under the plan. Where the offsite authority has a role under a radiological response plan for more than one site, it shall fully participate in one exercise every two years and shall, at least, partially participate in other offsite plan exercises in this period.

IV F.2.d A State should fully participate in the ingestion pathway N.1 a portion of exercises at least once every exercise cycle. In States with more than one site, the State should rotate this participation from site to site.

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Appendix 6 V. C. Summer Nuclear Station REGULATION STATEMENT EPLAN OTHER COMMENTS IV F.2.e Licensees shall enable any State or local Government N.1.b located within the plume exposure pathway EPZ to participate in the licensee's drills when requested by such State or local Government.

IV F.2.f Remedial exercises will be required if the emergency plan N.1.a is not satisfactorily tested during the biennial exercise, such that NRC, in consultation with FEMA, cannot find reasonable assurance that adequate protective measures can be taken in the event of a radiological emergency.

The extent of State and local participation in remedial exercises must be sufficient to show that appropriate corrective measures have been taken regarding the elements of the plan not properly tested in the previous exercises.

IV F.2.g All training, including exercises, shall provide for formal N.4, N.5 critiques in order to identify weak or deficient areas that need correction. Any weaknesses or deficiencies that are identified shall be corrected.

IV F.2.h The participation of State and local governments in an N/A emergency exercise is not required to the extent that the applicant has identified those governments as refusing to participate further in emergency planning activities, pursuant to 10 CFR 50.47(c)(1). In such cases, an exercise shall be held with the applicant or licensee and such governmental entities as elect to participate in the emergency planning process.

IV G Provisions to be employed to ensure that the emergency P.3 plan, its implementing procedures, and emergency equipment and supplies are maintained up to date shall be described.

IV H Criteria to be used to determine when, following an M.1.a accident, reentry of the facility would be appropriate or when operation could be resumed shall be described.

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Appendix 6 V. C. Summer Nuclear Station Appendix 6 V. C. Summer Nuclear Station Table 2 - 10 CFR 50.47 Emergency Plans REGULATION STATEMENT EPLAN OTHER COMMENTS (b) 1 The onsite and, except as provided in paragraph (d) of this A.1 section, offsite emergency response plans for nuclear power reactors must meet the following standards:

Primary responsibilities for emergency response by the nuclear facility licensee and by State and local organizations within the Emergency Planning Zones have been assigned, (b) 1 (continued) the emergency responsibilities of the various supporting A.1 organizations have been specifically established, (b) 1 (continued) and each principal response organization has staff to A.4 respond and to augment its initial response on a continuous basis.

(b) 2 On-shift facility licensee responsibilities for emergency B.1 response are unambiguously defined, (b) 2 (continued) timely augmentation of response capabilities is available B.5.a (b) 2 (continued) and the interfaces among various onsite response Figure A-2 activities and offsite support and response activities are specified.

(b) 3 Arrangements for requesting and effectively using A.3 assistance resources have been made, (b) 3 (continued) arrangements to accommodate State and local staff at the C.2 licensee's near-site Emergency Operations Facility have been made, (b) 3 (continued) and other organizations capable of augmenting the C.4 planned response have been identified.

(b) 4 A standard emergency classification and action level D.1 scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, PAGE 161 OF 193 EP-1 00 Rev 64

Appendix 6 V. C. Summer Nuclear Station REGULATION STATEMENT EPLAN OTHER COMMENTS (b) 4 (continued) and State and local response plans call for reliance on E.2.b information provided by facility licensees for determinations of minimum initial offsite response measures.

(b) 5 Procedures have been established for notification, by the E.2.b licensee, of State and local response organizations (b) 5 (continued) and for notification of emergency personnel by all E.2 organizations; (b) 5 (continued) the content of initial and follow up messages to response E.3, E.4 organizations and the public has been established; (b) 5 (continued) and means to provide early notification and clear E.6 instruction to the populace within the plume exposure pathway Emergency Planning Zone have been established.

(b) 6 Provisions exist for prompt communications among F.1 principal response organizations to emergency personnel (b) 6 (continued) and to the public. G.4 (b) 7 Information is made available to the public on a periodic G.1 basis on how they will be notified and what their initial actions should be in an emergency (e.g., listening to a local broadcast station and remaining indoors),

(b) 7 (continued) the principal points of contact with the news media for G.2 dissemination of information during an emergency (including the physical location or locations) are established in advance, (b) 7 (continued) and procedures for coordinated dissemination of G.3, G.4 information to the public are established.

(b) 8 Adequate emergency facilities and equipment to support H.1, H.2, H.3 the emergency response are provided and maintained.

(b) 9 Adequate methods, systems, and equipment for I assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use.

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0 Appendix 6 V. C. Summer Nuclear Station REGULATION STATEMENT EPLAN OTHER COMMENTS (b) 10 A range of protective actions have been developed for the J plume exposure pathway EPZ for emergency workers and the public.

(b) 10 (continued) Guidelines for the choice of protective actions during an J. 1 O.m. 1, Figure J-2 emergency, consistent with Federal guidance, are developed and in place, (b) 10 (continued) and protective actions for the ingestion exposure pathway J.1 1 EPZ appropriate to the locale have been developed.

(b) 11 Means for controlling radiological exposures, in an K.1 emergency, are established for emergency workers.

(b) 11 (continued) The means for controlling radiological exposures shall K.1 include exposure guidelines consistent with EPA Emergency Worker and Lifesaving Activity Protective Action Guides.

(b) 12 Arrangements are made for medical services for L.1 contaminated injured individuals.

(b) 13 General plans for recovery and reentry are developed. M.1 (b) 14 Periodic exercises are (will be) conducted to evaluate N.1, N.2 major portions of emergency response capabilities, (b) 14 (continued) periodic drills are (will be) conducted to develop and N.2 maintain key skills, (b) 14 (continued) and deficiencies identified as a result of exercises or drills N.5 are (will be) corrected.

(b) 15 Radiological emergency response training is provided to 0.1,0.2, 0.3, 0.4, 0.5 those who may be called on to assist in an emergency.

(b) 16 Responsibilities for plan development and review and for P distribution of emergency plans are established, (b) 16 (continued) and planners are properly trained. P.1 PAGE 163 OF 193 EP-100 Rev 64

Appendix 6 V. C. Summer Nuclear Station Table 3 - NUREG-0654 Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants PLANNING STATEMENT EPLAN OTHER COMMENTS ELEMENT A.1.a Each plan shall identify the State, local, Federal and private sector organizations (including utilities), that are intended to be part of the overall response organization A.1 for Emergency Planning Zones. (See Appendix 5).

A.l.b Each organization and sub organization having an operational role shall specify its concept of operations, A.1 and its relationship to the total effort.

A.1.c Each plan shall illustrate these interrelationships in a A., Figure A-2 block diagram. A.1,_FigureA-2 A.l.d Each organization shall identify a specific individual by A.1 title who shall be in charge of the emergency response.

A.i.e Each organization shall provide for 24-hour per day emergency response, including 24-hour per day manning A.1 of communications links.

A.2.a Each organization shall specify the functions and responsibilities for major elements and key individuals by Offsite Responsibility title, of emergency response, including the following:

Command and Control A.2.a (continued) Alerting and Notification Offsite Responsibility A.2.a (continued) Communications Offsite Responsibility A.2.a (continued) Public Information Offsite Responsibility A.2.a (continued) Accident Assessment Offsite Responsibility A.2.a (continued) Public Health and Sanitation Offsite Responsibility A.2.a (continued) Social Services A.2 Offsite Responsibility A.2.a (continued) Fire and Rescue Offsite Responsibility A.2.a (continued) Traffic Control Offsite Responsibility A.2.a (continued) Emergency Medical Services Offsite Responsibility A.2.a (continued) Law Enforcement Offsite Responsibility A.2.a (continued) Transportation Offsite Responsibility A.2.a (continued) Protective Response (including authority to request Federal assistance and to initiate other protective Offsite Responsibility actions), and A.2.a (continued) Radiological Exposure Control. Offsite Responsibility PAGE 164 OF 193 EP-1 00 Rev 64

Appendix 6 V. C. Summer Nuclear Station PLANNING STATEMENT EPLAN OTHER COMMENTS ELEMENT A.2.a (continued) The description of these functions shall include a clear and concise summary such as a table of primary and Offsite Responsibility support responsibilities using the agency as one axis, and the function as the other. (See Section B for licensee).

A.2.b Each plan shall contain (by reference to specific acts, Offsite Responsibility codes or statutes) the legal basis for such authorities.

A.3 Each plan shall include written agreements referring to the concept of operations developed between Federal, State, and local agencies and other support organizations having an emergency response role within the Emergency Planning Zones. The agreements shall identify the emergency measures to be provided and the mutually acceptable criteria for their implementation, and specify the arrangements for exchange of information. A.3 These agreements may be provided in an appendix to the plan or the plan itself may contain descriptions of these matters and a signature page in the plan may serve to verify the agreements. The signature page format is appropriate for organizations where response functions are covered by laws, regulations or executive orders where separate written agreements are not necessary.

A.4 Each principal organization shall be capable of continuous (24-hour) operations for a protracted period.

A.4 (continued) The individual in the principal organization who will be responsible for assuring continuity of resources AA (technical, administrative, and material) shall be specified by title.

B.1 Each licensee shall specify the onsite emergency organization of plant staff personnel for all shifts and its B.

relation to the responsibilities and duties of the normal staff complement.

B.2 Each licensee shall designate an individual as emergency coordinator who shall be on shift at all times and who shall have the authority and responsibility to immediately and unilaterally initiate any emergency actions, including B.2 providing protective action recommendations to authorities responsible for implementing offsite emergency measures.

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Appendix 6 V. C. Summer Nuclear Station PLANNING STATEMENT EPLAN OTHER COMMENTS ELEMENT B.3 Each licensee shall identify a line of succession for the emergency coordinator position and identify the specific B.3 conditions for higher level utility officials assuming this function.

B.4 Each licensee shall establish the functional responsibilities assigned to the emergency coordinator and shall clearly specify which responsibilities may not be B.4 delegated to other elements of the emergency organization.

B.4 (continued) Among the responsibilities which may not be delegated shall be the decision to notify and to recommend protective actions to authorities responsible for offsite 8.4 emergency measures.

B.5 Each licensee shall specify the positions or title and major tasks to be performed by the persons to be assigned to the functional areas of emergency activity. For emergency situations, specific assignments shall be made for all shifts and for plant staff members, both onsite and away from the site. These assignments shall cover the emergency functions in Table B-1 entitled, "Minimum Staffing Requirements for Nuclear Power Plant Emergencies." The minimum on-shift staffing levels shall be as indicated in Table B-I. The licensee must be able to augment on-shift capabilities within a short period after declaration of an emergency. This capability shall be as indicated in Table B-I. The implementation schedule for licensed operators, auxiliary operators and the shift technical advisor on shift shall be as specified in the July 31, 1980 letter to all power reactor licensees. Any deficiencies in the other staffing requirements of Table B-1 must be capable of augmentation within 30 minutes by September 1, 1981, and such deficiencies must be fully removed by July 1, 1982.

B.6 Each licensee shall specify the interfaces between and among the onsite functional areas of emergency activity, B.6 licensee headquarters support, local services support, and State and local government response organization.

B.6 (continued) This shall be illustrated in a block diagram and shall include the onsite technical support center and the operational support (assembly) center and the licensee's B.6, Figure B-l.a, Tables 2-1 near-site Emergency Operations Facility (EOF)

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Appendix 6 V. C. Summer Nuclear Station PLANNING STATEMENT EPLAN OTHER COMMENTS ELEMENT B.7 Each licensee shall specify the corporate management, administrative, and technical support personnel who will augment the plant staff as specified in the table entitled B.5, Figure B-i.a, Tables 2-1 "Minimum Staffing Requirements for Nuclear Power Plant Emergencies," (Table B-i) and in the following areas:

B.7.a a. logistics support for emergency personnel, e.g., B.5 transportation, communications, temporary quarters, food and water, sanitary facilities in the field, and special equipment and supplies procurement; B.7.b b. technical support for planning and reentry/recovery M.2 operations; B.7.c c. management level interface with governmental B.5 authorities; and B.7.d d. release of information to news media during an G.4 emergency (coordinated with governmental authorities).

B.8 Each licensee shall specify the contractor and private organizations who may be requested to provide technical 8.8 assistance to and augmentation of the emergency organization.

B.9 Each licensee shall identify the services to be provided by local agencies for handling emergencies, e.g., police, B.8 ambulance, medical, hospital, and fire-fighting organizations shall be specified.

B.9 (continued) The licensee shall provide for transportation and treatment of injured personnel who may also be L.3 contaminated.

B.9 (continued) Copies of the arrangements and agreements reached with contractor, private, and local support agencies shall be appended to the plan. The agreements shall delineate 8.8, Appendix 2 the authorities, responsibilities, and limits on the actions of the contractor, private organization, and local services support groups.

PAGE 167 OF 193 EP-1 00 Rev 64

Appendix 6 V. C. Summer Nuclear Station PLANNING STATEMENT EPLAN OTHER COMMENTS ELEMENT C.i.a The Federal government maintains in-depth capability to assist licensees, States and local governments through the Federal Radiological Monitoring and Assessment Plan (formerly Radiological Assistance Plan (RAP) and Interagency Radiological Assistance Plan (IRAP).* Each State and licensee shall make provisions for incorporating the Federal response capability into its operation plan, including the following: C.1

• FEMA issued the Federal RadiologicalEmergency Response Plan (FRERP)on May 8, 1996 (61 FR 20944),

which supersedes these documents.(Source NUREG-0654 Addenda Mar 2002)

a. specific persons by title authorized to request Federal assistance; see A.l.d., A.2.a.

C.1.b b. specific Federal resources expected, including expected times of arrival at specific nuclear facility sites; C.1 .b and C.1.c c. specific licensee, State and local resources available to support the Federal response, e.g., airfields, command C.l.c posts, telephone lines, radio frequencies and telecommunications centers.

C.2.a Each principal offsite organization may dispatch representatives to the licensee's near-site Emergency C.2 Offsite Responsibility Operations Facility. (State technical analysis representatives at the near site EOF are preferred.)

C.2.b b. The licensee shall prepare for the dispatch of a representative to principal offsite governmental C.2 emergency operations centers.

C.3 Each organization shall identify radiological laboratories and their general capabilities and expected availability to 0.3 provide radiological monitoring and analyses services which can be used in an emergency.

C.4 Each organization shall identify nuclear and other facilities, organizations or individuals which can be relied upon in an emergency to provide assistance. Such C.4 assistance shall be identified and supported by appropriate letters of agreement.

D.1 An emergency classification and emergency action level scheme as set forth in Appendix 1 must be established by D. 1 the licensee.

PAGE 168 OF 193 EP-1 00 Rev 64

Appendix 6 V. C. Summer Nuclear Station PLANNING STATEMENT EPLAN OTHER COMMENTS ELEMENT D.1 (continued) The specific instruments, parameters or equipment status Annex 1 Section 4, shall be shown for establishing each emergency class, in the in-plant emergency procedures.

D.1 (continued) The plan shall identify the parameter values and Annex 1 Section 4, equipment status for each emergency class.

D.2 The initiating conditions shall include the example Annex 1 Section 4, conditions found in Appendix I and all postulated accidents in the Final Safety Analysis Report (FSAR) for the nuclear facility.

D.3 Each State and local organization shall establish an emergency classification and emergency action level 0.3 Offsite Responsibility scheme consistent with that established by the facility licensee.

D.4 Each State and local organization should have procedures in place that provide for emergency actions to be taken which are consistent with the emergency actions recommended by the nuclear facility licensee, taking into account local offsite conditions that exist at the time of the emergency.

E.1 Each organization shall establish procedures which describe mutually agreeable bases for notification of response organizations consistent with the emergency classification and action level scheme set forth in E.1 Appendix 1. These procedures shall include means for verification of messages. The specific details of verification need not be included in the plan.

E.2 Each organization shall establish procedures for alerting, E.2 notifying, and mobilizing emergency response personnel.

E.3 The licensee in conjunction with State and local organizations shall establish the contents of the initial emergency messages to be sent from the plant. These measures shall contain information about the class of E.3 emergency, whether a release is taking place, potentially affected population and areas, and whether protective measures may be necessary.

PAGE 169 OF 193 EP-1 00 Rev 64

Appendix 6 V. C. Summer Nuclear Station PLANNING STATEMENT EPLAN OTHER COMMENTS ELEMENT E.4.a Each licensee shall make provisions for follow up messages from the facility to offsite authorities which shall contain the following information if it is known and appropriate: E.4

a. location of incident and name and telephone number (or communications channel identification) of caller; E.4.b b. date/time of incident; E.4 E.4.c c. class of emergency; E.4 E.4.d d. type of actual or projected release (airborne, waterborne, surface spill), and estimated duration/impact E.4 times; E.4.e e. estimate of quantity of radioactive material released or E4 being released and the points and height of releases; E.4.f f. chemical and physical form of released material, including estimates of the relative quantities and E.4 concentration of noble gases, iodines and particulates; E.4.g g. meteorological conditions at appropriate levels (wind speed, direction (to and from), indicator of stability, E.4 precipitation, if any);

E.4.h h. actual or projected dose rates at site boundary; E.4 projected integrated dose at site boundary; E.4.i i. projected dose rates and integrated dose at the projected peak and at 2, 5 and 10 miles, including E.4 sector(s) affected; E.4.j j. estimate of any surface radioactive contamination in EA plant, onsite or offsite; E.4.k k. licensee emergency response actions underway; E.4 E.4.1 I. recommended emergency actions, including protective E.4 measures; E.4.m m. request for any needed onsite support by offsite E.4 organizations; and E.4.n n. prognosis for worsening or termination of event based EA on plant information.

PAGE 170 OF 193 EP-1 00 Rev 64

Appendix 6 V. C. Summer Nuclear Station PLANNING STATEMENT EPLAN OTHER COMMENTS ELEMENT E.5 State and local government organizations shall establish a system for disseminating to the public appropriate information contained in initial and follow up messages received from the licensee including the appropriate notification to appropriate broadcast media, e.g., the Emergency Broadcast System (EBS).* E.5 Offsite Responsibility

• The Emergency Broadcast System (EBS) was replaced by the Emergency Alert System (EAS) by a Report and Order that the Federal CommunicationsCommission issued on December 28, 1994 (59 FR 67090).(Source NUREG-0654 Addenda Mar 2002)

E.6 Each organization shall establish administrative and physical means, and the time required for notifying and providing prompt instructions to the public within the plume exposure pathway Emergency Planning Zone.

(See Appendix 3.) It shall be the licensee's responsibility E.6 to demonstrate that such means exist, regardless of who implements this requirement. It shall be the responsibility of the State and local governments to activate such a system.

E.7 Each organization shall provide written messages intended for the public, consistent with the licensee's classification scheme. In particular, draft messages to the public giving instruction with regard to specific protective actions to be taken by occupants of affected areas shall be prepared and included as part of the State and local plans. Such messages should include the appropriate aspects of sheltering, ad hoc, respiratory protection, e.g.,

handkerchief over mouth, thyroid blocking or evacuation.

The role of the licensee is to provide supporting information for the messages. For ad hoc respiratory E.7 protection see "Respiratory Protective Devices Manual" American Industrial Hygiene Association, 1963 pp.

123-126.*

• The currentRespiratoryProtective Devices Manual (2nd edition) and the forthcoming 3rd edition do not contain a similar table for ad hoc respiratoryprotection, however, according to the American IndustrialHygiene Association, it is still correct to refer to the 1963 manual as the most recent version of the Respiratory ProtectionManual that contains the ad hoc respiratoryprotection table.(Source NUREG-0654 Addenda Mar 2002)

PAGE 171 OF 193 EP-1 00 Rev 64

Appendix 6 V. C. Summer Nuclear Station PLANNING STATEMENT EPLAN OTHER COMMENTS ELEMENT F. 1 The communication Plans for emergencies shall include organizational titles and alternates for both ends of the F.1 communication links.

F.1 (continued) Each organization shall establish reliable primary and backup means of communication for licensees, local, and FA State response organizations. Such systems should be selected to be compatible with one another.

F.1.a Each plan shall include:

a. provision for 24-hour per day notification to and activation of the State/local emergency response network; F.1 and at a minimum, a telephone link and alternate, including 24-hour per day manning of communications links that initiate emergency response actions.

F.l.b b. provision for communications with contiguous State/local governments within the Emergency Planning F.1 Zones; F.1.c c. provision for communications as needed with Federal emergency response organizations; F.1 .d d. provision for communications between the nuclear facility and the licensee's near-site Emergency Operations F.1 Facility, State and local emergency operations center, and radiological monitoring teams; F.1.e e. provision for alerting or activating emergency personnel F.1 in each response organization; and F.1.f f. provision for communication by the licensee with NRC headquarters and NRC Regional Office Emergency Operations Centers and the licensee's near-site F.1 Emergency Operations Facility and radiological monitoring team assembly area.

F.2 Each organization shall ensure that a coordinated communication link for fixed and mobile medical support F.2 facilities exists.

F.3 Each organization shall conduct periodic testing of the entire emergency communications system (see F.3, N.2 evaluation criteria H.10, N.2.a and Appendix 3).

G.1 Each organization shall provide a coordinated periodic (at least annually) dissemination of information to the public G.1 regarding how they will be notified and what their actions should be in an emergency.

PAGE 172 OF 193 EP-100 Rev 64

Appendix 6 0

V. C. Summer Nuclear Station PLANNING STATEMENT EPLAN OTHER COMMENTS ELEMENT G.1 .a This information shall include, but not necessarily be limited to: G.1.a

a. educational information on radiation; G.1.b b. contact for additional information; G.1.b G.l.c c. protective measures, e.g., evacuation routes and relocation centers, sheltering, respiratory protection, G.1.c radioprotective drugs; and G.1.d d. special needs of the handicapped. G.1.e G.1 (continued) Means for accomplishing this dissemination may include, but are not necessarily limited to: information in the telephone book; periodic information in utility bills; posting G.1 in public areas; and publications distributed on an annual basis.

G.2 The public information program shall provide the permanent and transient adult population within the plume exposure EPZ an adequate opportunity to become aware G.2 of the information annually. The programs should include provision for written material that is likely to be available in a residence during an emergency.

G.2 (continued) Updated information shall be disseminated at least G.1 annually.

G.2 (continued) Signs or other measures (e.g., decals, posted notices or other means, placed in hotels, motels, gasoline stations and phone booths) shall also be used to disseminate to G.2 any transient population within the plume exposure pathway EPZ appropriate information that would be helpful if an emergency or accident occurs.

G.2 (continued) Such notices should refer the transient to the telephone directory or other source of local emergency information G.2 and guide the visitor to appropriate radio and television frequencies.

G.3.a a. Each principal organization shall designate the points G.3 of contact and physical locations for use by news media during an emergency.

G.3.b b. Each licensee shall provide space which may be used for a limited number of the news media at the near site G.3.b Emergency Operations Facility.

PAGE 173 OF 193 EP-1 00 Rev 64

Appendix 6 V. C. Summer Nuclear Station PLANNING STATEMENT EPLAN OTHER COMMENTS ELEMENT G.4.a a. Each principal organization shall designate a spokesperson who should have access to all necessary G.4.a information.

G.4.b b. Each organization shall establish arrangements for timely exchange of information among designated G.4.b spokespersons.

G.4.c c. Each organization shall establish coordinated G.4.b arrangements for dealing with rumors.

G.5 Each organization shall conduct coordinated programs at least annually to acquaint news media with the emergency plans, information concerning radiation, and G.5 points of contact for release of public information in an emergency.

H.1 Each licensee shall establish a Technical Support Center and an onsite Operational Support Center (assembly area) in accordance with NUREG-0696, Revision 1.* H.1.b

-"Revision 1" should be deleted; NUREG-0696 has not been revised.(Source NUREG-0654 Addenda Mar 2002)

H.2 Each licensee shall establish an Emergency Operations Facility from which evaluation and coordination of all licensee activities related to an emergency is to be carried out and from which the licensee shall provide information to Federal, State and local authorities responding to H.2 radiological emergencies in accordance with NUREG-0696, Revision 1.*

• -Revision1" should be deleted; NUREG-0696 has not been revised.(Source NUREG-0654 Addenda Mar 2002)

H.3 Each organization shall establish an emergency operations center for use in directing and controlling H.4 Offsite Responsibility response functions.

H.4 Each organization shall provide for timely activation and staffing of the facilities and centers described in the plan.

H.5.a Each licensee shall identify and establish onsite monitoring systems that are to be used to initiate emergency measures in accordance with Appendix 1, as well as those to be used for conducting assessment.

H.6.a The equipment shall include:

a. geophysical phenomena monitors, (e.g.,

meteorological, hydrologic, seismic);

PAGE 174 OF 193 EP-100 Rev 64

Appendix 6 V. C. Summer Nuclear Station PLANNING STATEMENT EPLAN OTHER COMMENTS ELEMENT H.5.b b. radiological monitors, (e.g., process, area, emergency, effluent, wound and portable monitors and sampling H.6.b equipment);

H.5.c c. process monitors, (e.g., reactor coolant system pressure and temperature, containment pressure and temperature, liquid levels, flow rates, status or lineup of equipment components); and H.5.d d. fire and combustion products detectors. H.6.d H.6.a Each licensee shall make provision to acquire data from or for emergency access to offsite monitoring and analysis equipment including: H.6.a

a. geophysical phenomena monitors, (e.g.,

meteorological, hydrologic, seismic);

H.6.b b. radiological monitors including radiometers and H.6.bsampling devices.

H.6.b(continued) Dosimetry shall be provided and shall meet, as a minimum, the NRC Radiological Assessment Branch Technical position for the Environmental Radiological Monitoring Program; and H.6.c c. laboratory facilities, fixed or mobile. H.7.c H.7 Each organization, where appropriate, shall provide for offsite radiological monitoring equipment in the vicinity of H.7 the nuclear facility.

H.8 Each licensee shall provide meteorological instrumentation and procedures which satisfy the criteria H.9 in Appendix 2, H.8 (continued) And provisions to obtain representative current meteorological information from other sources. H.9 H.9 Each licensee shall provide for an onsite Operational Support Center (assembly area) which shall have adequate capacity, and supplies, including, for example, respiratory protection, H.9 (continued) protective clothing, H.10 H.9 (continued) portable lighting, H.10 H.9 (continued) portable radiation monitoring equipment, H.10 H.9 (continued) cameras and H.10 PAGE 175 OF 193 EP-100 Rev 64

Appendix 6 V. C. Summer Nuclear Station PLANNING STATEMENT EPLAN OTHER COMMENTS ELEMENT H.9 (continued) communications equipment for personnel present in the H.11 assembly area.

H.10 Each organization shall make provisions to inspect, inventory and operationally check emergency H.11 equipment/instruments at least once each calendar quarter and after each use.

H.10 (continued) There shall be sufficient reserves of instruments/equipment to replace those which are H.1 1 removed from emergency kits for calibration or repair.

H.10 (continued) Calibration of equipment shall be at intervals recommended by the supplier of the equipment.

H.1 1 Each plan shall, in an appendix, include identification of emergency kits by general category (protective H.12 equipment, communications equipment, radiological monitoring equipment and emergency supplies).

H.12 Each organization shall establish a central point (preferably associated with the licensee's near-site Emergency Operations Facility), for the receipt and H.14 analysis of all field monitoring data and coordination of sample media.

1.1 Each licensee shall identify plant system and effluent parameter values characteristic of a spectrum of off-normal conditions and accidents, and shall identify the 1.1 plant parameter values or other information, which correspond to the example initiating conditions of Appendix 1.

1.1 (continued) Such parameter values and the corresponding emergency class shall be included in the appropriate 1.1 facility emergency procedures.

1.1 (continued) Facility emergency procedures shall specify the kinds of 1.1 instruments being used and their capabilities.

1.2 Onsite capability and resources to provide initial values and continuing assessment throughout the course of an 1.2 accident shall include:

post-accident sampling capability, 1.2 (continued) radiation and effluent monitors, 1.2 1.2 (continued) in-plant iodine instrumentation, and 1.2 PAGE 176 OF 193 EP-1 00 Rev 64

Appendix 6 6

a V. C. Summer Nuclear Station PLANNING STATEMENT EPLAN OTHER COMMENTS ELEMENT 1.2 (continued) Containment radiation monitoring in accordance with NUREG-0578, as elaborated in the NRC letter to all power reactor licensees dated October 30, 1979.*

• NUREG-0737, "Clarificationof TMI Action Plan 1.2 Requirements," November 1980, and Supplement 1 to NUREG-0737, January 1983, supersede these citations.

(Source NUREG-0654 Addenda Mar 2002) 1.3.a Each licensee shall establish methods and techniques to be used for determining:

a. the source term of releases of radioactive material 1.3 within plant systems. An example is the relationship between the containment radiation monitor(s) reading(s) and radioactive material available for release from containment.

1.3.b b. the magnitude of the release of radioactive materials based on plant system parameters and effluent monitors. 1.3 1.4 Each licensee shall establish the relationship between effluent monitor readings and onsite and offsite exposures 1.4 and contamination for various meteorological conditions.

1.5 Each licensee shall have the capability of acquiring and 1.5 evaluating meteorological information sufficient to meet the criteria of Appendix 2.

1.5 (continued) There shall be provisions for access to meteorological information by at least the near site Emergency 1.5 Operations Facility, the Technical Support Center, the Control Room and an offsite NRC center.

1.5 (continued) The licensee shall make available to the State suitable meteorological data processing interconnections which will permit independent analysis by the State, of facility 1.5 generated data in those States with the resources to effectively use this information.

1.6 Each licensee shall establish the methodology for determining the release rate/projected doses if the 1.6 instrumentation used for assessment are off scale or inoperable.

1.7 Each organization shall describe the capability and resources for field monitoring within the plume exposure 1.7 Emergency Planning Zone which are an intrinsic part of the concept of operations for the facility.

PAGE 177 OF 193 EP-1 00 Rev 64

Appendix 6 V. C. Summer Nuclear Station PLANNING STATEMENT EPLAN OTHER COMMENTS ELEMENT 1.8 Each organization, where appropriate, shall provide methods, equipment and expertise to make rapid assessments of the actual or potential magnitude and 1.8 locations of any radiological hazards through liquid or gaseous release pathways. This shall include activation, 1.8 (continued) notification means, 1.8 1.8 (continued) field team composition, 1.8 1.8 (continued) transportation, 1.8 1.8 (continued) communication, 1.8 1.8 (continued) monitoring equipment and 1.8 1.8 (continued) estimated deployment times. 1.8 1.9 Each organization shall have a capability to detect and measure radioiodine concentrations in air in the plume exposure EPZ as low as 10 7 uCi/cc (microcuries per 1.9 cubic centimeter) under field conditions. Interference from the presence of noble gas and background radiation shall not decrease the stated minimum detectable activity.

1.10 Each organization shall establish means for relating the various measured parameters (e.g., contamination levels, water and air activity levels) to dose rates for key isotopes 1.10 (i.e., those given in Table 3, page 18) and gross radioactivity measurements.

1.10 (continued) Provisions shall be made for estimating integrated dose from the projected and actual dose rates and for comparing these estimates with the protective action 1.10 guides. The detailed provisions shall be described in separate procedures.

1.11 Arrangements to locate and track the airborne radioactive plume shall be made, using either or both Federal and 1.11 Offsite Responsibility State resources.

J.l.a Each licensee shall establish the means and time J.1 required to warn or advise onsite individuals and individuals who may be in areas controlled by the operator, including:

J.1

a. Employees not having emergency assignments; J.1.b b. Visitors; J.1 J.1.c c. Contractor and construction personnel; and J.1 PAGE 178 OF 193 EP-1 00 Rev 64

Appendix 6 V. C. Summer Nuclear Station PLANNING STATEMENT EPLAN OTHER COMMENTS ELEMENT J.1.d d. Other persons who may be in the public access areas on or passing through the site or within the owner J.1 controlled area.

J.2 Each licensee shall make provisions for evacuation routes and transportation for onsite individuals to some suitable offsite location, including alternatives for inclement J.2 weather, high traffic density and specific radiological conditions.

J.3 Each licensee shall provide for radiological monitoring of people evacuated from the site.

J.4 Each licensee shall provide for the evacuation of onsite non-essential personnel in the event of a Site or General J.4 Emergency and J.4 (continued) shall provide a decontamination capability at or near the monitoring point specified in J.3.

J.5 Each licensee shall provide for a capability to account for all individuals onsite at the time of the emergency and ascertain the names of missing individuals within 30 J.5 minutes of the start of an emergency and account for all onsite individuals continuously thereafter.

J.6.a Each licensee shall, for individuals remaining or arriving onsite during the emergency, make provisions for: J.6.a

a. Individual respiratory protection; J.6.b b. Use of protective clothing; and J.6.b J.6.c c. Use of radioprotective drugs, (e.g., individual thyroid J.6.c protection).

J.7 Each licensee shall establish a mechanism for recommending protective actions to the appropriate State J.7 and local authorities.

J.7 (continued) These shall include Emergency Action Levels corresponding to projected dose to the population-at-risk, J.7 in accordance with Appendix 1 and J.7 (continued) with the recommendations set forth in Tables 2.1 and 2.2 of the Manual of Protective Action Guides and Protective Actions for Nuclear Incidents (EPA-520/1-75-001).* J.7

• EPA issued EPA-400-R-92-O01, May 1992, which supersedes this document.(Source NUREG-0654 Addenda Mar 2002)

PAGE 179 OF 193 EP-100 Rev 64

Appendix 6 V. C. Summer Nuclear Station PLANNING STATEMENT EPLAN OTHER COMMENTS ELEMENT J.7 (continued) As specified in Appendix 1, prompt notification shall be made directly to the offsite authorities responsible for implementing protective measures within the plume exposure pathway Emergency Planning Zone.

J.8 Each licensee's plan shall contain time estimates for evacuation within the plume exposure EPZ. These shall J.8 be in accordance with Appendix 4.

J.9 Each State and local organization shall establish a capability for implementing protective measures based J.9 Offsite Responsibility upon protective action guides and other criteria.

J.9 (continued) This shall be consistent with the recommendations of EPA regarding exposure resulting from passage of radioactive airborne plumes, (EPA-520/1-75-001) and with those of DHEW (DHHS)/FDA regarding radioactive contamination of human food and animal feeds as published in the Federal Register of December 15, 1978 (43 FR 58790).*

• EPA issued EPA-400-R-92-001, May 1992, which J.9 Offsite Responsibility supersedes EPA-5201 1-75-001. The Food and Drug Administration (FDA), Department of Health and Human Services (DHHS), issued "Guidance on Accidental Radioactive Contamination of Human Food and Animal Feeds, Recommendations for State and Local Agencies, Availability," on August 13, 1998 (63 FR 43402).(Source NUREG-0654 Addenda Mar 2002)

J.10.a The organization's plans to implement protective measures for the plume exposure pathway shall include: J.10.a

a. Maps showing evacuation routes, J.10.a (continued) evacuation areas, J.10.a J.10.a (continued) preselected radiological sampling and monitoring points, (identification of radiological sampling and monitoring points shall include the designators in Table J-1 or an equivalent uniform system described in the plan);

J. 10.a (continued) relocation centers in host areas, J.10.a J.10.a (continued) and shelter areas. J.10.a J.10.b b. Maps showing population distribution around the nuclear facility. This shall be by evacuation areas J.10,b (licensees shall also present the information in a sector format);

PAGE 180 OF 193 EP-1 00 Rev 64

Appendix 6 V. C. Summer Nuclear Station PLANNING STATEMENT EPLAN OTHER COMMENTS ELEMENT J.1O.c c. Means for notifying all segments of the transient and Ji0c resident population; J.10.d d. Means for protecting those persons whose mobility may be impaired due to such factors as institutional or J.10.d Offsite Responsibility other confinement; J.1O.e e. Provisions for the use of radioprotective drugs, particularly for emergency workers and institutionalized J.1O.e Offsite Responsibility persons within the plume exposure EPZ whose immediate evacuation may be infeasible or very difficult, J. 1O.e (continued) including quantities, storage, and means of distribution. J.10.e Offsite Responsibility J.10.f f. State and local organizations' plans should include the method by which decisions by the State Health Offsite Responsibility Department for administering radioprotective drugs to the general population are made during an emergency J.1 0.f (continued) and the predetermined conditions under which such drugs may be used by offsite emergency workers;*

• The Food and Drug Administration (FDA) issued "PotassiumIodide as a Thyroid Blocking Agent in a J. 10.f Offsite Responsibility Radiation Emergency," on December 11, 2001 (66 FR 238:64046), which supersedes this citation.(Source NUREG-0654 Addenda Mar 2002)

J.10.g g. Means of relocation; J.10.g Offsite Responsibility J.10.h h. Relocation centers in host areas which are at least 5 miles, and preferably 10 miles, beyond the boundaries of J.10.h Offsite Responsibility the plume exposure emergency planning zone; (See K.8)

J.10.i i. Projected traffic capacities of evacuation routes under JAW Offsite Responsibility emergency conditions; J.10.j j. Control of access to evacuated areas and organization J. 10.j Offsite Responsibility responsibilities for such control; J.10.k k. Identification of and means for dealing with potential impediments (e.g., seasonal impassability of roads) to J.10.k Offsite Responsibility use of evacuation routes, and contingency measures; J.10.1 I. Time estimates for evacuation of various sectors and distances based on a dynamic analysis (time-motion study under various conditions) for the plume exposure J.10.1 Offsite Responsibility pathway emergency planning zone (See Appendix 4); and J.10.m m. The bases for the choice of recommended protective actions from the plume exposure pathway during J.10.m emergency conditions.

PAGE 181 OF 193 EP-1 00 Rev 64

Appendix 6 V. C. Summer Nuclear Station PLANNING STATEMENT EPLAN OTHER COMMENTS ELEMENT J.10.m This shall include expected local protection afforded

• in (continued) residential units or other shelter for direct and inhalation exposure, as well as evacuation time estimates.

• EPA issued EPA 400-R-92-001 in May 1992, which supersedes this citation.(Source NUREG-0654 Addenda Mar 2002)

J.1 1 Each State shall specify the protective measures to be used for the ingestion pathway, including the methods for J.1 1 Offsite Responsibility protecting the public from consumption of contaminated foodstuffs.

J.1 1 (continued) This shall include criteria for deciding whether dairy J.1 1 Offsite Responsibility animals should be put on stored feed.

J.11 (continued) The plan shall identify procedures for detecting J.1 Offsite Responsibility contamination, J.1 1 (continued) for estimating the dose commitment consequences of J.1 1 Offsite Responsibility uncontrolled ingestion, J.1 1 (continued) and for imposing protection procedures such as impoundment, decontamination, processing, decay, J.1 1 Offsite Responsibility product diversion, and preservation.

J.1 I (continued) Maps for recording survey and monitoring data, key land use data (e.g., farming), dairies, food processing plants, J.1 1 Offsite Responsibility water sheds, water supply intake and treatment plants and reservoirs shall be maintained.

J.1 1 (continued) Provisions for maps showing detailed crop information may be by including reference to their availability and J.1 1 Offsite Responsibility location and a plan for their use.

J.1 1 (continued) The maps shall start at the facility and include all of the JA 1 Offsite Responsibility 50-mile ingestion pathway EPZ.

J.1 1 (continued) Up-to-date lists of the name and location of all facilities which regularly process milk products and other large amounts of food or agricultural products originating in the J.1 1 Offsite Responsibility ingestion pathway Emergency Planning Zone, but located elsewhere, shall be maintained.

J.12 Each organization shall describe the means for registering and monitoring of evacuees at relocation J.12 Offsite Responsibility centers in host areas.

J.12 (continued) The personnel and equipment available should be capable of monitoring within about a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> period all J.12 Offsite Responsibility residents and transients in the plume exposure EPZ arriving at relocation centers.

PAGE 182 OF 193 EP-1 00 Rev 64

Appendix 6 0

V. C. Summer Nuclear Station PLANNING STATEMENT EPLAN OTHER COMMENTS ELEMENT K.1 .a Each licensee shall establish onsite exposure guidelines K.1 consistent with EPA Emergency Worker and Lifesaving Activity Protective Actions Guides (EPA-520/1-75/001) for:*

• EPA issued EPA 400-R-92-001 in May 1992, which supersedesthis citation.(Source NUREG-0654 Addenda Mar 2002)

a. removal of injured persons; K.1 K.1 .b b. undertaking corrective actions; K.1 K.1 .c c. performing assessment actions; K.1 K.1.d d. providing first aid; K.1 K.1.e e. performing personnel decontamination; K.1 K.1.f f. providing ambulance service; and K.1 K.1.g g. providing medical treatment services. K.1 K.2 Each licensee shall provide an onsite radiation protection program to be implemented during emergencies, including methods to implement exposure guidelines. The K.2 plan shall identify individual(s), by position or title, who can authorize emergency workers to receive doses in excess of 10 CFR Part 20 limits.

K.2 (continued) Procedures shall be worked out in advance for permitting onsite volunteers to receive radiation exposures in the course of carrying out lifesaving and other emergency K.2 activities. These procedures shall include expeditious decision making and a reasonable consideration of relative risks.

K.3.a a. Each organization shall make provision for 24-hour-per-day capability to determine the doses received by emergency personnel involved in any nuclear accident, including volunteers.

K.3.a (continued) Each organization shall make provisions for distribution of dosimeters, both self-reading and permanent record K.3 devices.

K.3.b Each organization shall ensure that dosimeters are read K.3 at appropriate frequencies and K.3.b (continued) provide for maintaining dose records for emergency K.3 workers involved in any nuclear accident.

PAGE 183 OF 193 EP-1 00 Rev 64

0 V. C. Summer Nuclear Station Appendix 6 PLANNING STATEMENT EPLAN OTHER COMMENTS ELEMENT K.4 Each State and local organization shall establish the decision chain for authorizing emergency workers to incur exposures in excess of the EPA General Public Protective K.4 Offsite Responsibility Action Guides (i.e., EPA PAGs for emergency workers and lifesaving activities).

K.5.a a. Each organization as appropriate, shall specify action K.5 levels for determining the need for decontamination.

K.5.b b. Each organization, as appropriate, shall establish the means for radiological decontamination of emergency K.5 personnel wounds, supplies, instruments and equipment, and for waste disposal.

K.6.a Each licensee shall provide onsite contamination control measures including: K.6.a

a. area access control; K.6.b b. drinking water and food supplies; K.6.b K.6.c c. criteria for permitting return of areas and items to normal use, see Draft ANSI 13.12.*

• EPA PAG Manual, EPA 400-R-92-001 (see items 16 and 17), and the Food and Drug Administration, DHHS, "Guidanceon Accidental Radioactive Contaminationof K.6.c Human Food and Animal Feeds: Recommendations for State and Local Agencies," dated August 13, 1998 (63 FR 43402) supersede this citation.(Source NUREG-0654 Addenda Mar 2002)

K.7 Each licensee shall provide the capability for K.7 decontaminating relocated onsite personnel, K.7 (continued) including provisions for extra clothing and decontaminants suitable for the type of contamination expected, with particular attention given to radioiodine contamination of the skin.

L.1 Each organization shall arrange for local and backup hospital and medical services having the capability for L.1 evaluation of radiation exposure and uptake, L.1 (continued) Including assurance that persons providing these services are adequately prepared to handle contaminated L.1 individuals.

L.2 Each licensee shall provide for onsite first aid capability. L.2 PAGE 184 OF 193 EP-100 Rev 64

0 V. C. Summer Nuclear Station Appendix 6 PLANNING STATEMENT EPLAN OTHER COMMENTS ELEMENT L.3 Each State shall develop lists indicating the location of public, private and military hospitals and other emergency Not addressed in the VCSNS medical services facilities within the State or contiguous Emergency Plan. Offsite Responsibility States considered capable of providing medical support for any contaminated injured individual.

L.3 (continued) The listing shall include the name, location, type of facility Not addressed in the VCSNS Offsite Responsibility and capacity and any special radiological capabilities. Emergency Plan.

L.3 (continued) These emergency medical services should be able to Not addressed in the VCSNS Offsite Responsibility radiologically monitor personnel contamination, and Emergency Plan.

L.3 (continued have facilities and trained personnel able to care for Not addressed in the VCSNS Offsite Responsibility contaminated injured persons. Emergency Plan.

L.4 Each organization shall arrange for transporting victims of L.3 radiological accidents to medical support facilities.

M.1 Each organization, as appropriate, shall develop general plans and procedures for reentry and recovery and describe the means by which decisions to relax protective M.1 measures (e.g., allow reentry into an evacuated area) are reached.

M.1 (continued) This process should consider both existing and potential M.1 conditions.

M.2 Each licensee plan shall contain the position/title, authority and responsibilities of individuals who will fill key M.2.a positions in the facility recovery organization.

M.2 (continued) This organization shall include technical personnel with responsibilities to develop, evaluate and direct recovery and reentry operations. The recovery organization recommended by the Atomic Industrial Forum's "Nuclear Power Plant Emergency Response Plan" dated October 11, 1979, is an acceptable framework.*

• "FunctionalCriteriafor Emergency Response M.2 Facilities," NUREG-0696, issued on February 1981, and "Clarificationof TMI Action Plan Requirements, Requirements for Emergency Response Capability,"

NUREG-0737, Supplement No. 1, issued January1983, supersede this citation.(Source NUREG-0654 Addenda Mar 2002)

M.3 Each licensee and State plan shall specify means for informing members of the response organizations that a M.3 recovery operation is to be initiated, and of any changes in the organizational structure that may occur.

PAGE 185 OF 193 EP-100 Rev 64

0 Appendix 6 V. C. Summer Nuclear Station PLANNING STATEMENT EPLAN OTHER COMMENTS ELEMENT M.4 Each plan shall establish a method for periodically M.4 estimating total population exposure.

N.1.a a. An exercise is an event that tests the integrated capability and a major portion of the basic elements existing within emergency preparedness plans and organizations. The emergency preparedness exercise N.1.a shall simulate an emergency that results in offsite radiological releases which would require response by offsite authorities. Exercises shall be conducted as set forth in NRC and FEMA rules.

N.1.b b. An exercise shall include mobilization of State and local personnel and resources adequate to verify the capability N.1.a to respond to an accident scenario requiring response.

N.1 .b (continued) The organization shall provide for a critique of the annual N4 exercise by Federal and State observers/evaluators.

N.1 .b (continued) The scenario should be varied from year to year such that all major elements of the plans and preparedness N.1 organizations are tested within a five-year period.

N.1.b (continued) Each organization should make provisions to start an N.1 exercise between 6:00 p.m. and midnight, and N.1.b (continued) another between midnight and 6:00 a.m. once every N.1 exercise cycle.

N.1.b (continued) Exercises should be conducted under various weather NA conditions.

N.1.b (continued) Some exercises should be unannounced. N.A N.2.a A drill is a supervised instruction period aimed at testing, developing and maintaining skills in a particular operation.

A drill is often a component of an exercise. A drill shall be supervised and evaluated by a qualified drill instructor.

Each organization shall conduct drills, in addition to the annual exercise at the frequencies indicated below: N.2.b

a. Communication Drills Communications with State and local governments within the plume exposure pathway Emergency Planning Zone shall be tested monthly.

N.2.a (continued) Communications with Federal emergency response organizations and States within the ingestion pathway N.2.b shall be tested quarterly.

PAGE 186 OF 193 EP-1 00 Rev 64

Appendix 6 V. C. Summer Nuclear Station PLANNING STATEMENT EPLAN OTHER COMMENTS ELEMENT N.2.a (continued) Communications between the nuclear facility, State and local emergency operations centers, and field N.2.b assessment teams shall be tested annually.

N.2.a (continued) Communication drills shall also include the aspect of N.2.b understanding the content of messages.

N.2.b b. Fire Drills Fire drills shall be conducted in accordance with the plant N.2.b (nuclear facility) technical specifications.

N.2.c c. Medical Emergency Drills A medical emergency drill involving a simulated contaminated individual which contains provisions for participation by the local support services agencies (i.e., N.2.d ambulance and offsite medical treatment facility) shall be conducted annually. The offsite portions of the medical drill may be performed as part of the required annual exercise.

N.2.d d. Radiological Monitoring Drills Plant environs and radiological monitoring drills (onsite N.2.e and offsite) shall be conducted annually.

N.2.d (continued) These drills shall include collection and analysis of all sample media (e.g., water, vegetation, soil and air), and provisions for communications and record keeping. The N.2.e State drills need not be at each site. Where appropriate, local organizations shall participate.

N.2.e.1 e. Health Physics Drills (I) Health Physics drills shall be conducted semi-annually which involve response to, and analysis of, simulated N.2.f elevated airborne and liquid samples and direct radiation measurements in the environment. The State drills need not be at each site.

N.2.e.2 (2) Analysis of in plant liquid samples with actual elevated radiation levels including use of the post-accident N.2.e sampling system shall be included in Health Physics drills by licensees annually.

PAGE 187 OF 193 EP-1 00 Rev 64

Appendix 6 V. C. Summer Nuclear Station PLANNING STATEMENT EPLAN OTHER COMMENTS ELEMENT N.3.a Each organization shall describe how exercises and drills are to be carried out to allow free play for decision making and to meet the following objectives. Pending the development of exercise scenarios and exercise evaluation guidance by NRC and FEMA the scenarios for N.3.a use in exercises and drills shall include but not be limited to, the following:

a. The basic objective(s) of each drill and exercise and appropriate evaluation criteria; N.3.b b. The date(s), time period, place(s) and participating N.3.b organizations; N.3.c c. The simulated events; N.3.c N.3.d d. A time schedule of real and simulated initiating events; N.3.e N.3.e e. A narrative summary describing the conduct of the exercises or drills to include such things as simulated casualties, offsite fire department assistance, rescue of N.3.f personnel, use of protective clothing, deployment of radiological monitoring teams, and public information activities; and N.3.f f. A description of the arrangements for and advance N.3.h materials to be provided to official observers.

N.4 Official observers from Federal, State or local governments will observe, evaluate, and critique the required exercises. A critique shall be scheduled at the conclusion of the exercise to evaluate the ability of N.4 organizations to respond as called for in the plan. The critique shall be conducted as soon as practicable after the exercise, and N.4 (continued) a formal evaluation should result from the critique. N.4 N.5 Each organization shall establish means for evaluating observer and participant comments on areas needing N.5 improvement, including emergency plan procedural changes, and N.5 (continued) for assigning responsibility for implementing corrective N.5 actions.

N.5 (continued) Each organization shall establish management control used to ensure that corrective actions are implemented.

PAGE 188 OF 193 EP-100 Rev 64

Appendix 6 V. C. Summer Nuclear Station PLANNING STATEMENT EPLAN OTHER COMMENTS ELEMENT O.1.a Each organization shall assure the training of appropriate individuals.

a. Each facility to which the plant applies shall provide site O.1.a specific emergency response training for those offsite emergency organizations who may be called upon to provide assistance in the event of an emergency, O.1.b b. Each offsite response organization shall participate in and receive training. Where mutual aid agreements exist between local agencies such as fire, police and 0 1b Offsite Responsibility ambulance/rescue, the training shall also be offered to the other departments who are members of the mutual aid district.

0.2 The training program for members of the onsite emergency organization shall, besides classroom training, include practical drills in which each individual 0.2 demonstrates ability to perform his assigned emergency function.

0.2 (continued) During the practical drills, on-the-spot correction of erroneous performance shall be made and a demonstration of the proper performance offered by the instructor.

0.3 Training for individuals assigned to licensee first aid teams shall include courses equivalent to Red Cross 0.3 Multi-Media.

0.4.a Each organization shall establish a training program for instructing and qualifying personnel who will implement radiological emergency response plans.2/ The specialized initial training and periodic retraining programs (including the scope, nature and frequency) shall be provided in the 0.4.a following categories:

a. Directors or coordinators of the response organizations; 0.4.b b. Personnel responsible for accident assessment; 0.4.b 0.4.c c. Radiological monitoring teams and radiological analysis personnel; 0.4.c O.4.d d. Police, security and fire fighting personnel; O.4.d 0.4.e e. Repair and damage control/correctional action teams 0.4.e (onsite);

PAGE 189 OF 193 EP-1 00 Rev 64

Appendix 6 V. C. Summer Nuclear Station PLANNING STATEMENT EPLAN OTHER COMMENTS ELEMENT O.4.f f. First aid and rescue personnel; O.4.f O.4.g g. Local support services personnel including Civil 04g Defense/Emergency Service personnel; O.4.g O.4.h h. Medical support personnel; O.4.h O.4.i i. Licensee's headquarters support personnel; O.4.i O.4J j. Personnel responsible for transmission of emergency O4j information and instructions.

0.5 Each organization shall provide for the initial and annual retraining of personnel with emergency response 0.5 responsibilities.

P.1 Each organization shall provide for the training of individuals responsible for the planning effort.

P.2 Each organization shall identify by title the individual with the overall authority and responsibility for radiological P.2 emergency response planning.

P.3 Each organization shall designate an Emergency Planning Coordinator with responsibility for the development and updating of emergency plans and P.3 coordination of these plans with other response organizations.

P.4 Each organization shall update its plan and agreements as needed, review and certify it to be current on an P.4 annual basis.

P.4 (continued) The update shall take into account changes identified by PA drills and exercises.

P.5 The emergency response plans and approved changes to the plans shall be forwarded to all organizations and appropriate individuals with responsibility for implementation of the plans.

P.5 (continued) Revised pages shall be dated and marked to show where changes have been made.

P.6 Each plan shall contain a detailed listing of supporting P.6 plans and their source.

P.7 Each plan shall contain as an appendix listing, by title, P.7 procedures required to implement the plan.

P.7 (continued) The listing shall include the section(s) of the plan to be implemented by each procedure.

P.8 Each plan shall contain a specific table of contents. Table of Contents PAGE 190 OF 193 EP-1 00 Rev 64

Appendix 6 V. C. Summer Nuclear Station PLANNING STATEMENT EPLAN OTHER COMMENTS ELEMENT P.8 (continued) Plans submitted for review should be cross-referenced to P.8 these criteria.

P.9 Each licensee shall arrange for and conduct independent reviews of the emergency preparedness program at least every 12 months. (An independent review is one conducted by any competent organization either internal P.9 or external to the licensees' organization, but who are not immediately responsible for the emergency preparedness program).

P.9 (continued) The review shall include the emergency plan, its implementing procedures and practices, training, PA readiness testing, equipment, and interfaces with State and local governments.

P.9 (continued) Management controls shall be implemented for evaluation and correction of review findings.

P.9 (continued) The result of the review, along with recommendations for improvements, shall be documented, reported to PA appropriate licensee corporate and plant management, and involved Federal, State and local organizations, P.9 (continued) and retained for a period of five years. P.9 P.10 Each organization shall provide for updating telephone P.10 numbers in emergency procedures at least quarterly.

PAGE 191 OF 193 EP-100 Rev 64

Appendix 7 V. C. Summer Nuclear Station Appendix 7 - On-shift Staffing Analysis The On-shift Staffing Analysis was prepared by Operations Support Services, Inc. This controlled document, in its entirety, is filed under separate cover and has been distributed to designated locations.

PAGE 192 OF 193 EP-100 Rev 64

Appendix 8 V. C. Summer Nuclear Station Appendix 8 - Alert And Notification System Design Report The Alert And Notification System Design Report was prepared by SCE&G in cooperation with West Shore Services, who performed the Acoustical Study for the Alert and Notification System within the EPZ. This document, in its entirety, is filed under separate cover and has been distributed to designated locations.

PAGE 193 OF 193 EP-100 Rev 64

VCS-SAP-0139 Attachment'. II Page 1 of 2 REVISION 1 Document Review Form LDRF)

Douet Id~itifiat P0061 of" f Preparer Name: Lindsay Vance Ext: 55568 Mail Code 815 Date: 11/19/14 Document#: EP-100 Revision: 64 Change NA

Title:

Radiation Emergency Plan [T SR []QR [INNS Development Process: FlNew N] Revision/Change E] Editorial Correction Fi Temporary Approval

==

Description:==

1) Updated the PARs based on EP Rule Making 2) Replaced ESSX with EMNET.

Has scope changed? El Yes M No [If YES, attached 50.59 documentation]

Reason/Basis for Revision/Change: 1)Regulatory Requirement 2) Old technology needed to be updated with new system.

Temporary Approval - if final approval is not completed within 30 days; initiate CR #_"

Qualified Reviewer DCRM person notified Shift Supervisor Date Sect~bn W'i, I s equired RevieWers ircl~Uig;, cimpacter Ad"tjI .'. Ti ist GrouFý

' eweL,

f. idehtifwihnj, Position Type/Print Name Comments Position Type/Print Name Comments El Yes tANo El] Yes M-No-QR Ty Tharp MHPSS Moses Coleman 7Y N MOPS Robert Justice Yes No MC MOHS Melissa Harmon El Yes %) No MMS Don Shue Pl Yes l No MOM Todd Johnson El Yes KNo KLi*eir ,, [ Yes %No MNL Bruce Thompson El Yes 9 No P"E Is-a pervisor oncurrI D Comment Duen ,- t WsignatedSprio ocrec 'Date GM concurrenck, for pxpedited review Section 16.h Il,. .P.. irýmplementat66on Actors ion. ,

All Comments Resolved? 17 NA [fYES 2.)aUC_0 Preparer S-i. D 50.59 Review Requirements Addressed? ,NA Li YES Attached? YES [] No E]

50.59/Part 52 Review Requirements Addressed? ' .NA El YES Attached? YES Ej No 0i Commitments (PCAP and MLSA) Addressed? INA El YES PCAP #__

QR Qualification Verified? i' YES NL Initial/Date Security Compliance Review Completed? [WNA [: YES Pre-Implementation Training Completed? E]rNA Ei YES Training required after implementation? I 4 NA [/ES CR#

PSRC Review Completed? E 1A YES Mtg.# ao -1I" NSRC Review Completed? [NA]YES Mtg. #

CMMS Update Required? [Unit 1] WINA YES Planner Notified YES 171 DWegnated Supervisor Approval Approval Authori .pproyal Date Effective Date: 7jL4,

VCS-SAP-0139 Attachment II Page 2 of 2 REVISION 1 DRF Form (Continued)

Page 2of 2 DOCUMENT # EP-100 Radiation Emerqency Plan Rev,64 Chg. NA DESCRIPTION CONTINUED: 1) New PAR descriptions are on pages 84-85. The new PAR flow chart and notes are pages 87-88.

2) EMNet change from ESSX is on page 52 and the EMNet definition is on page 53.

Other references to EMNet are on paqes 95, 111 and 114.

REASON/BASIS CONTINUED: 1)Regulatory Requirement 2) Old technology needed to be updated with new system.

REQUIRED REVIEWERS CONTINUED:

Position Type/Print Name Comments Position Type/Print Name Comments El Yes No Yes[No GMNPO George Lippard Rob Ray K Yes [] No 17 Yes E] No MPS QA Les Harris El Yes J No El Yes [3 No EL Yes , No FL Yes L] No GMES Wayne Stuart Shaun Zarandi J9 Yes El No LI Yes LI No GMNPS GMOR Robin Haselden F1 Yes K No El Yes El No

SAP-0127 Attachment II Page 1 of 4 Revision 3 10 CFR 50.54 (q) Screen TITLE: Radiation Emergency Plan SCREEN ID: S2014-38 Procedure #: EP-1 00, Radiation Emergency Plan, Rev. 64 (Include Revision and Change) A ORIGINATOR: Lindsay Vance DATE SUBMITTED: 11119/2014 PART I - DESCRIPTION OF PROPOSED CHANGE: (Event or action, or series of actions that may result in a change to the emergency plan or affect the implementation of the emergency plan)

EP-100 is being updated to change the PARs based on Rule Making and NUREG 0654 Supplement 3. ESSX is being replaced with EMNET. Appendix 8 was added to reference the Alert and Notification System (ANS) Design Report.

PART II - ACTIVITY PREVIOUSLY REVIEWED: Is this activity fully bounded by El YES- M NO-an NRC approved 10 CFR 50.90 submittal or Alert and Notification System Design 50.54(q)(3) Continue to next Report? If YES, identify bounding source document number/approval reference and Evaluation is part NOT required.

ensure the basis for concluding the source document fully bounds the proposed Enter change is documented below.

justification below and complete Part vI.

Justification:

E] Bounding document attached (optional)

SAP-0127 Attachment II Page 2 of 4 Revision 3 10 CFR 50.54 (a) Screen Screen ID: S2014-38 PART III -APPLICABILITY OF OTHER REGULATORY CHANGE CONTROL PROCESSES: Does any of the following change process control the proposed change? (These may be accomplished by a separate Applicability Determination procedure.) (Check all that apply.)

NOTE: For example, when a design change is the proposed activity, consequential actions may include changes to other documents which have a different change control process and are NOT to be included in this 50.54(q)(3) Screening.

Change Process Description Applicable

1. A previous 50.59 Screen has been performed lAW SAP-107, 10CFR50.59 Review Process, and additional evaluation or review is not required. (If yes, go to # 3.)

2. A 50.59 Screen lAW SAP-107 has been performed and an evaluation under one or more of the following processes is required.

a. Quality assurance programs - 10 CFR 50.54(a) [Operational Quality Assurance Plan])I

b. In Service Inspection / In Service Testing (ISI /IST) programs - 10 CFR 50.55a [SAP- E]

1294]

c. Physical Security Plan, the Safeguards Contingency Plan, the Guard Training and El Qualification Plan, or the Cyber Security Plan - 10 CFR 50.54(p)

d. Changes, tests, or experiments (operating license) - 10 CFR 50.59 [SAP-01 07] El

e. Maintenance Rule - 10 CFR 50.65 [SAP-01 57] El

f. Technical specification amendment (provided the change to the EP is specifically LI addressed in the amendment) - 10 CFR 50.90 [Technical Specifications]

g. Fire Protection Program - Operating license condition [Fire Protection Evaluation El Report]

3. Appendix J, Primary Reactor Containment Leakage Testing requirements - 10 CFR 50.54(o) LI

[SAP-0145]

4. Interface between security and the emergency plan - 10 CFR 73.58 [SAP-0163] El

5. Changes, tests, or experiments (Independent Spent Fuel Storage Installation) - 10 CFR 72.48 LI

6. Alert and Notification System (ANS) - 44 CFR 350.14 [ANS Design Report] El APPLICABILITY CONCLUSION El There are no controlling change processes selected, continue the 50.54(q)(3) Screening.

M One or more of the controlling change processes are selected, however, some portion of the activity involves the emergency plan or affects the implementation of the emergency plan; continue the 50.54(q)(3) Screening for that portion of the activity.

Ej One or more of the controlling change processes are selected and fully bounds all aspects of the activity. 50.54(q)(3)

Evaluation is NOT required.

SAP-O0127 Attachment 11 Page 3 of 4 Revision 3 10 CFR 50.54 (a) Screen

- S-c-reen ID: S2014-38 PART IV - EDITORIAL CHANGE: Is this activity an editorial or typographical El YES - 0 NO-50.54(q)(3) Continue to next change such as formatting, paragraph numbering, spelling, or punctuation that does Evaluation is part not change intent? NOT required.

Enter justification and complete Part VI.

Justification:

PART V - EMERGENCY PLANNING ELEMENT/FUNCTION SCREEN: Does this activity involve any of the following, including program elements from NUREG-0654/FEMA REP-1 Section II?

Emergency Planning Element/Function Description [reference: 10 CFR 50.47 (b)(#)] Applicable

1. Responsibility for emergency response is assigned (1) El

2. The response organization has the staff to respond and to augment staff on a continuing basis E]

(24/7 staffing) in accordance with the emergency plan (1)

3. The process ensures that on-shift emergency response responsibilities are staffed and El assigned (2)

4. The process for timely augmentation of on-shift staff is established and maintained (2) LI

5. Arrangements for requesting and using off site assistance have been made (3) LI

6. State and local staff can be accommodated at the EOF in accordance with the emergency plan.

(3)

7. A standard scheme of emergency classification and action levels is in use (4) LI

8. Procedures for notification of state and local governmental agencies are capable of alerting them of the declared emergency within 15 minutes after declaration of an emergency and 0 providing follow-up notifications (5)

9. Administrative and physical means have been established for alerting and providing prompt 0 instructions to the public within the plume exposure pathway (5)

10. The public ANS meets the design requirements of FEMA-REP-1 0, Guide for Evaluation Of Alert and Notification Systems for Nuclear Power Plants, or complies with the licensee's FEMA- 0 approved ANS design report and supporting FEMA approval letter (5)

11. Systems are established for prompt communication among principal emergency response 0 organizations (6)

12. Systems are established for prompt communication to emergency response personnel (6) EL

13. Emergency Preparedness information is made available to the public on a periodic basis within LI the plume exposure pathway Emergency Planning Zone (EPZ) (7)

14. Coordinated dissemination of public information during emergencies is established (7) LI

15. Adequate facilities are maintained to support emergency response (8) El

16. Adequate equipment is maintained to support emergency response (8) LI

SAP-0127 Attachment II Page 4 of 4 Revision 3 10 CFR 50.54 (W)Screen Screen ID: S2014-38 Emergency Planning Element/Function Description [reference: 10 CFR 50.47 (b) (#)] Applicable

17. Methods, systems, and equipment for assessment of radioactive releases are in use (9) El

18. A range of public PARs is available for implementation during emergencies (10)

19. Evacuation time estimates for the population located in the plume exposure pathway EPZ are available to support the formulation of PARs and have been provided to State and local governmental authorities (10)

20. A range of protective actions is available for plant emergency workers during emergencies, El including those for hostile action events (10)

21. The resources for controlling radiological exposures for emergency workers are established (11) E]

22. Arrangements are made for medical services for contaminated, injured individuals (12) EL

23. Plans for recovery and reentry are developed (13) EL

24. A drill and exercise program (including radiological, medical, health physics and other program El areas) is established (14)

25. Drills, exercises, and training evolutions that provide performance opportunities to develop, maintain, and demonstrate key skills are assessed via a formal critique process in order to LI identify weaknesses (14)

26. Deficiencies identified as a result of exercises or drills are corrected (14) LI

27. Training is provided to emergency responders (15) EL

28. Responsibility for emergency plan development and review is established (16) El

29. Personnel responsible for emergency plan development and maintenance are properly trained (16)

30. VCSNS formal commitments El

31. Operation, maintenance, or testing of ERDS El APPLICABILITY CONCLUSION El If no Part V criteria are checked, a 50.64(q)(3) Evaluation is NOT required; complete Part VI.

E Ifany Part V criteria are checked, complete Part VI and perform a 50.54(q)(3) Evaluation.

Record the EVALUATION ID: E2014-024 PART VI - SIGNATURES:

Preparer Name (Print) Signature Date Reviewer Nam" Print) Signat re Date Arover Name (Prit" Si) Date

SAP-0127 Attachment V Page 1 of 2 Revision 3 CO3-- 10 CFR 50.54 (W) Evaluation TITLE: Radiation Emergency Plan DATE: 1111912014 Procedure #: EP-100, Radiation Emergency Plan, Rev.64 A (include Revision and Change)

SCREEN ID: S2014-38 EVALUATION ID: E2014-024 EVAL REVISION: 0 PART I - DESCRIPTION OF PROPOSED CHANGE:

EP-100 is being updated to change the PARs based on Rule Making and NUREG-0654 Supplement 3. ESSX is being replaced with EMNET. Appendix 8 was added to reference the Alert and Notification System (ANS) Design Report.

PART II - DESCRIPTION AND REVIEW OF LICENSING BASIS AFFECTED BY THE PROPOSED CHANGE:

NUREG-0717, SER related to V. C. Summer Nuclear Station Unit 1, Supplements 2 and 3 require and state VCSNS has a radiological emergency response plan that includes elements of NUREG-0654, Revision 1 (1979 criteria), NUREG-0696, 10 CFR 50.47, and 10 CFR 50 Appendix E and will provide adequate planning basis for an acceptable state of emergency preparedness and meets these requirements. EP-100 Revision 5 is the revision in which the latest Safety Evaluation Repoit (SER) was issued. Since this revision numerous other revisions have been made under the 10 CFR 50.54(q) process. This revision maintains the intent, purpose, and function of the emergency plan as evaluated up to the current Revision 63.

PART III - DESCRIBE HOW THE PROPOSED CHANGE COMPLIES WITH RELEVANT EMERGENCY PREPAREDNESS REGULATION(S) AND PREVIOUS COMMITMENT(S) MADE TO THE NRC:

The proposed PAR changes are being done to comply with Regulations that were made during EP Rule making with guidance from NUREG-0654 Supplement 3.

The change from ESSX to EMNET will enhance the ability of the Plant to notify the ORO's. EMNET is a dedicated Voice Over Internet Phone (VOIP) that has a Satellite as a backup if the network were to become unavailable.

The ANS Design Report is developed by/for the licensee and reviewed and approved by the Federal Emergency Management Administration (FEMA). The design report is maintained under a separate controlled document, but required the same evaluations and reviews as an emergency plan change. It is being incorporated into the plan by reference.

PART IV - DESCRIPTION OF EMERGENCY PLAN PLANNING STANDARDS, FUNCTIONS AND PROGRAM ELEMENTS AFFECTED BY THE PROPOSED CHANGE:

Procedures have been established for notification, by the licensee, of State and local response organizations and for notification of emergency personnel by all organizations; the Content of initial and follow-up messages to response organizations and the public has been established; and means to provide early notification and clear instruction to the populace within the plume exposure pathway Emergency Planning Zone have been established. (10 CFR 50.47 (b) (5))

The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert and Notification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANS design report and supporting FEMA approval letter (10 CFR 50.47 (b) (5))

Provisions exist for prompt communications among principal response organizations to emergency personnel and to the public.(10 CFR 50.47 (b) (6))

A range of protective actions has been developed for the plume exposure pathway EPZ for emergency workers and the public. In developing this range of actions, consideration has been given to evacuation, sheltering, and, as a supplement to these, the prophylactic use of potassium iodide (KI), as appropriate. Evacuation time estimates have been developed by applicants and licensees. Licensees shall update the evacuation time estimates on a periodic basis.

Guidelines for the choice of protective actions during an emergency, consistent with Federal guidance, are developed and in place, and protective actions for the ingestion exposure pathway EPZ appropriate to the locale have been developed. (10 CFR 50.47 (b) (10))

SAP-0127 Attachment V Page 2 of 2 Revision 3 PART V - DESCRIPTION OF IMPACT OF THE PROPOSED CHANGE ON THE EFFECTIVENESS OF EMERGENCY PLAN FUNCTIONS:

The changes to Part 2 Section J.10.m and Figure Jý2 do not have an impact of the effectiveness of the Emergency Plan Functions. This change will align the PARs with the guidance in NUREG-0654 Supplement 3 and meets the regulatory requirements.

The changes to Part 2 Section F, Part 2 Section L.3, Section 0 and Appendix 4 maintain the intent of the Emergency Plan Functions. EMNET is a dedicated Voice Over Internet Phone (VOIP) that has a Satellite as a backup if the network were to become unavailable. This change not only maintains the effectiveness of the Emergency Plan function it also enhances the ability of the Plant to notify the ORO's in an Emergency.

The design report is maintained under a separate controlled document, however, the addition of the reference to the ANS Design Report ensures regulatory requirements are met and thus do not reduce the effectiveness of the plan.

EVALUATION ID: E2014-024 PART VI - EVALUATION CONCLUSION:

Answer the following questions about the proposed change.

1. Does the proposed change comply with the requirements of 10 CFR 50.47(b) and 10 0 YES El NO CFR 50 Appendix E?

2. Does the proposed change maintain the effectiveness of the emergency plan (i.e., no N YES Ej NO reduction in effectiveness)?

3. Does the proposed change constitute an emergency action level scheme change? D YES ED NO If questions 1 or 2 are answered NO, or question 3 answered YES, obtain prior NRC approval under provisions of 10 CFR 50.90. If questions 1 and 2 are answered YES, and question 3 answered NO, implement applicable change process(es).

PART VII - SIGNATURES:

Preparer Name (Print) Signature Date:

Revi m e nigure "a Dbate: " "

Approver Name (Print) i aueDate, P/