ML16286A052

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EP-PP-01, Revision 46 Procedure and Associated 50.54(q) Review
ML16286A052
Person / Time
Site: Pilgrim
Issue date: 08/26/2016
From:
Entergy Nuclear Operations
To:
Office of Nuclear Reactor Regulation
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ML16286A055 List:
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Download: ML16286A052 (151)
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PNPSEMERGENCYPLAN RType H8.22 FOREWORD As required in the conditions set forth by the Nuclear Regulatory Commission for the operating license for the Pilgrim Nuclear Power Station, the management of Entergy Nuclear Operations, Inc., ("Entergy) recognizes its responsibility and authority to operate and maintain the Pilgrim Nuclear Power Station in such a manner as to provide for the safety of the general public.

This Emergency Plan has been prepared to establish the procedures and practices for management control over unplanned or emergency events that may occur at the Pilgrim Nuclear Power Station.

The issuance and control of this Emergency Plan and the Activities associated with emergency preparedness at the Pilgrim Nuclear Power Station shall be the responsibility of the Senior Nuclear Executive. The Emergency Plan and its implementing procedures meet the requirements for quality assurance as set forth in the Entergy Quality Assurance Program Manual.

The Regulatory and Performance Improvement Director is assigned the responsibility for the maintenance of the Emergency Preparedness Programs associated with the operation of Pilgrim Nuclear Power Station as outlined in this document.

Date:___.P'--!t.._J-_S.,__/t__;.:_G? __

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u or nd Performance Improvement Director Date:_~-+-/_2.&-+-/_l(f~-

Date: _

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Ge~ra!Manager, Plant Operatlo s

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IEAr aent (Senior Nuclear Executive)

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Conformance to the practices described in this Emergency Plan and the procedures, which implement it, are required as of the effective date.

Effective Date: 1fi3 /fl,,

Revision 46

PNPS EMERGENCY PLAN LIST OF EFFECTIVE PAGES Revision i to ii......................................................................................................................................... 46 iii to viii..................................................................................................................................... 46 Section A.................................................................................................................................. 46 Section B.................................................................................................................................. 46 Section C................................................................................................................................. 46 Section D................................................................................................................................. 46 Section E.................................................................................................................................. 46 Section F *********************************~************************************************************************************************ 46 Section G................................................................................................................................. 46 Section H................................................................................................................................. 46 Section I..................................................................... :............................................................. 46 Section J.................................................................................................................................. 46 Section K.................................................................................................................................. 46 Section L............................................................................................ :..................................... 46 Section M................................................................................................................................. 46 Section N................................. ~............................................................................................... 46 Section o................................................................................................................................. 46 Section P.................................................................................................................................. 46 Appendix 1............................................................................................................................... 46 Appendix 2............................................................................................................................... 46 Appendix 3............................................................................................................................... 46 Appendix 4............................................................................................................................... 46 (Appendix 5 contained in separate volume) ii Revision 46

~----------

PNPS EMERGENCY PLAN Table of Contents Part 1:

INTRODUCTION Section A:

Purpose........................................................................................................ vii Section B:

Background.................................................................................................. vii Section C:

Scope.......................................................................................................... viii Section D:

Planning Basis............................................................................................ viii Section E:

Form and Content of Plan........................................................................... viii Part 2:

PLANNING STANDARDS AND CRITERIA Section A:

Assignment of Responsibility

1. Concept of Operations........................................................................................... A-1
2. Commonwealth and Local Functions and Responsibilities..................................... A-9
3. Agreements in Planning Effort............................................................................... A-9
4. Continuous Coverage......................................................................................-...... A-9 Section B:

Station Emergency Organization

1. PNPS Emergency Response Organization Assignments....................................... B-1
2. Authority Over PNPS Emergency Response Organization.................................... B-2
3. Succession to Emergency Director.................................... ;................................... B-2
4. Emergency Director Responsibilities...................................................................... B-2
5. PNPS Emergency Response Organization............................................................ B-3
6. Emergency Response Organization Block Diagram............................................... B-6
7. Corporate Emergency Response........................................................................... B-6
8. Private Industry Support........................................................................................ B-6
9. Offsite Emergency Assistance to PNPS................................................................. B-6 Section C:

Emergency Response Support and Resources

1. Federal Response Support and Resources........................................................... C-1.
2. Liaisons................................................................................................................. C-1
3. Radiological Laboratories....................................................................................... C-2
4. Other Assistance................................................................................................... C-2 Section D:

Emergency Classification System

1. Emergency Classification....................................................................................... D-1
2. Emergency Action Levels....................................................................................... D-4
3. Offsite Classification Systems................................................................................ D-4
4. Offsite Emergency Procedures.............................................................................. D-4 Section E:

Notification Methods and Procedures

1. Response Organization Notification....................................................................... E-1
2. Notification and Mobilization of Emergency Response Personnel.......................... E-1
3. Initial Notification.................................................................................................... E-2
4. Follow-up Messages.............................................................................................. E-2
5. Commonwealth and Local Information Dissemination............................................ E-3
6. Notification of the Public........................................................................................ E-3
7. Messages to the Public.......................................................................................... E-4 iii Revision 46

PNPS EMERGENCY PLAN Table of Contents (Cont.)

Section F:

Emergency Communications

1. Communications/Notifications................................................................................ F-1
2. Medical Communications....................................................................................... F-4
3. Communications Drills.................................................................................... :...... F-4 Section G:

Public Education and Information

1. Public Information Publication............................................................................... G-1
2. Public Education Materials.................................................................................... G-1
3. Joint Information Center........................................................................................ G-1
4. Coordination of Public Information........................................................................ G-1
5. Media Orientation...... :........................................................................................... G-2 Section H:

Emergency Facilities and Equipment

1. Technical Support Center (TSC), Operations Support Center (OSC), and the Control Room......................................................................................................... H-1
2. Emergency Operations Facility (EOF).................................................................... H-2
3.,Alternative Facility...... ;................................................................................ '........... H-2
4. Emergency Operations Centers (EOCs) and Incident Command Post (ICP)......... H-3
5. Activation............................................................................................................... H-4
6. Monitoring Equipment for Classification................................................................. H-4
7. Offsite Monitoring Equipment................................................................................. H-5
8. Offsite Monitoring Equipment Storage................................................................... H-6
9. Meteorological Monitoring...................................................................................... H-6
10. Protective and Damage Control Equipment........................................................... H-6
11. Facility and Equipment Readiness......................................................................... H-7
12. General Use Emergency Equipment...................................................................... H-7
13. Collection Point for Field Samples......................................................................... H-7 Section I:

Accident Assessment

1. Plant Parameters and Corresponding Emergency Classification............................ 1-1
2. Onsite Accident Assessment Capabilities............................................................... 1-1
3. Release Source Term Determination...................................................................... 1-2
4. Effluent Monitor Data and URI................................................................................ 1-2
5. Meteorological Information................................................................................... ~.. 1-2
6. Unmonitored Release............................................................................................. 1-3
7. Field Monitoring...................................................................................................... 1-3
8. Offsite Monitoring Teams (OMTs)........................................................................... 1-3
9. Iodine Monitoring.................................................................................................... 1-3
10. Dose Estimates.........................................................,.............................................. 1-3
11. Commonwealth Monitoring Capabilities.................................................................. 1-3 iv Revision 46

PNPS EMERGENCY PLAN Table of Contents (Cont.)

Section J:

Protective Response

1. Notification of Onsite Personnel............................................................................. J-1
2. Evacuation Locations............................................................................................. J-1
3. Radiological Monitoring........................................................................................ :. J-1
4. Evacuation............................................................................................................. J-1
5. Accountability......................................................................................................... J-2
6. Provisions for Onsite Personnel............................................................................. J-2
7. Protective Action Recommendations for the General Public.................................. J-3
8. Evacuation Time Estimates.................................................................................... J-4
9. Protective Measure Implementation....................................................................... J-4
10. Factors Affecting Protective Measure Implementation........................................... J-4
11. Ingestion Pathway Protective Measures................................................................ J-5
12. Monitoring of Evacuees......................................................................................... J-5 Section K:

Radiological Exposure Control

1. Emergency Exposure Guidelines........................................................................... K-1
2. Emergency Radiation Protection Program............................................................. K-1
3. Personnel Monitoring............................................................................................. K-2
4. Non-PNPS Personnel Exposure Authorization....................................................... K-2
5. Decontamination and First Aid............................................................................... K-2
6. Contamination Control........................................................................................... K-3
7. Decontamination of Relocated Personnel.............................................................. K-3 Section L:

Medical and Public Health Support

1. Hospital Services.................................................................................................... L-1
2. Onsite First Aid Capability...................................................................................... L-1
3. Medical Service Facilities....................................................................................... L-1
4. Medical Transportation.......................................................................................... L-1 Section M:

Reentry and Recovery Planning

1. Reentry................................................................................................................. M-1
2. Recovery............................................................................................................... M-2
3. Recovery Phase Notifications............................................................................... M-5
4. Total Population Exposure.................................................................................... M-5 Section N:

Drill and Exercise Program

1. Exercises/Drills...................................................................................................... N-1
2. Specialized Drills.................................................................................................... N-2
3. Conduct of Drills and Exercises............................................................................. N-3
4. Criteria and Evaluation........................................................................................... N-3
5. Resolution of Drill and Exercise Findings............................................................... N-3 Section 0:

Emergency Response Training

1. Assurance of Training................................................................................... :....... 0-1
2. Classroom and Hands-On Training....................................................................... 0-1
3. First Aid Response................................................................................................ 0-2
4. PNPS Emergency Response Organization Training Program............................... 0-2
5. General, Initial and Annual Training Program Maintenance.................................. 0-5 v

Revision 46

PNPSEMERGENCYPLAN Table of Contents (Cont.)

Section P:

Responsibility for the Maintenance of the Planning Effort

1. Emergency Planning Staff..................................................................................... P-1
2. Authority for Emergency Preparedness Effort........................................................ P-1
3. Regulatory and Performance Improvement Director.............................................. P-1
4. PNPS Emergency Plan Revisions.......................................................................... P-5
5. Emergency Plan Distribution............................................................. :.................... P-5
6. Supporting Emergency Response Plans................................................................ P-6
7. Implementing and Supporting Procedures............................................................. P-6
8. Cross Reference to Planning Criteria..................................................................... P-6
9. PNPS Emergency Preparedness Program Review................................................ P-6
10. Maintenance of the PNPS Emergency Telephone Directory.................................. P-6 Part 3:

APPENDICES Appendix 1:

Appendix 2:

  • Appendix 3:

Appendix 4:

References................................................................................. Appendices-1 Procedure Cross-Reference to Sections of the Plan.................. Appendices-3 Sample Copies of Letters of Agreements................................... Appendices-5 Glossary of Terms.................................................................... Appendices-12 Appendix 5:

Evacuation Time Estimates...................................................... Appendices-14 vi Revision 46

PNPS EMERGENCY PLAN Part 1:

INTRODUCTION Section A:

Purpose This document describes the emergency preparedness program for Entergy's Pilgrim Nuclear Power Station (PNPS). The terms "PNPS" and "plant" as used in this document include the Independent Spent Fuel Storage Installation (ISFSI), except where it is obvious by usage or context that the term only applies to the power plant. The term "facility," when used to describe the nuclear power plant also includes the ISFSI. 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 PNPS and the personnel who work at the plant.

The PNPS 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. Detailed PNPS Emergency Plan Implementing Procedures are maintained separately and used to guide those responsible for implementing emergency actions.

This Plan documents the methods by which the PNPS Emergency Preparedness Program meets the criteria set forth in Title 10 of the Code of Federal Regulation (CFR), Part 50, Section 47(b) and Appendix E.

Section B:

Background

PNPS is located in the town of Plymouth, Plymouth County, in the Commonwealth of Massachusetts at 41° 56.69 min. North, 70° 34.74 min. West. It is situated on the western coast of Cape Cod Bay, on approximately 1600 acres of land, owned by Entergy. The plant is a General Electric Boiling Water Reactor (BWR) design and produces a net electrical output of 689 megawatts. A detailed description of the plant is given in the PNPS Final Safety Analysis Report (FSAR). The ISFSI consists of HI-STORM vertical dry spent fuel storage casks on a concrete slab located within the protected area. A detailed description of the HI-STORM storage casks is given in the HI-STORM 100 Cask System FSAR.

The primary hazard consideration at PNPS is the potential unplanned release of radioactive material resulting from an accident at the plant. The probability of such a "release is considered very low due to plant design and strict operational guidelines enforced by the Nuclear Regulatory Commission (NRC). However, Federal regulations and common sense require that a solid emergency preparedness program exist for each commercial nuclear power station.

10 CFR 72.32 specifies the regulatory requirements for an ISFSI emergency plan. In accordance with 10 CFR 72.32(c), the emergency plan for a nuclear power reactor satisfies the requirements for an emergency plan for an ISFSI which is located within the exclusion area of the nuclear power reactor, and therefore a separate ISFSI emergency plan is not required.

vii Revision 46

PNPS EMERGENCY PLAN Section C:

Scope This document describes actions to be taken in the event of an accident at PNPS which might lead to impact on the health and safety of the general public.

If such an accident were to occur, the PNPS Emergency Response Organization (as defined in this plan) would be put in place and maintained until such time the plant was returned to a stable condition and the threat to the general public no longer existed. This plan describes the operation of the PNPS Emergency Response Organization. It does not, nor is it intended to provide guidance for actual plant equipment manipulations. These instructions are contained in PNPS normal and emergency operating procedures as required by Technical Specifications and other regulatory guidance. An emergency recovery phase is also described in this plan.

Section D:

Planning Basis Development of this plan was based on NRC Regulatory Guide 1.101, "Emergency Response Planning and Preparedness for Nuclear Power Reactors," and NUREG-0654, FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants", Revision 1. Other applicable regulations, publications and guidance were used (see Appendix 1, "References") along with PNPS documents to ensure consistency in the planning effort.

This plan was developed in coordination with the Commonwealth of Massachusetts' Comprehensive Emergency Response Plan, Hazard Annex: "Radiological Emergency Response" and local community emergency response plans.

Section E:

Form and Content of Plan This plan is Appendix N of ~he PNPS Unit 1 FSAR but is maintained as a separate document.

This Plan has been formatted in a manner similar to NUREG-0654, FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants", Revision 1.

The use of this format lends itself to verification of meeting the criteria set forth in NUREG-0654, FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants". Appendix 2, "Procedure Cross-Reference to Sections of the Plan", provides a cross-reference between this plan and the PNPS Emergency Plan Implementing and Administrative Procedures.

This plan is updated as necessary, in accordance with guidance provided by Emergency Preparedness Administrative Procedures viii Revision 46

PNPS EMERGENCY PLAN Part 2:

PLANNING STANDARDS AND CRITERIA Section A:

Assignment of Responsibility This section describes the primary responsibilities for emergency response by Pilgrim Nuclear Power Station (PNPS), Federal, State, Commonwealth, and local organizations within the PNPS Plume Exposure Pathway and the Ingestion Pathway Emergency Planning Zones (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 supporting a response in the PNPS Emergency Planning Zones are as follows:
a. Identified below are Federal, Commonwealth, State, local, and private organizations that are involved in a response to an emergency at PNPS.

Federal Agencies: The National Response Framework (NRF) is a guide to how the Nation conducts all-hazards response. It is built upon scalable, flexible, and adaptable coordinating structures to align key roles and responsibilities across the Nation. It also describes specific authorities and best practices for managing incidents that range from the serious but purely local, to large-scale terrorist attacks or catastrophic natural disasters. The NRF does not alter the NRC's independent authority or impede its ability to respond to events involving NRC-licensed facilities or materials. As outlined in the Nuclear/Radiological Incident Annex, the NRC is responsible to: (a) independently assess facility conditions and monitor licensee response activities; (b) ensure that appropriate protective action recommendations are communicated to the Commonwealth and local officials; (c) keep the public informed of the NRC's understanding of the event; and, (d) if necessary, the Chairman may invoke his authority to intervene and issue orders that may direct tre licensee's response activities on-site.

The NRF is supported by annexes, including the Emergency Support Functions Annex, Support Annexes, and Incident Annexes for specific types of incidents. The annexes provide concepts of operations, procedures, and str\\.]ctures to assist partners with their respective response directives in fulfilling their roles under the NRF.

The Nuclear/Radiological Incident Annex to the NRF states that the NRC is the Coordinating Agency for events occurring at NRG-licensed facilities and for radioactive materials licensed either by the NRC or under the NRC's Agreement States Program. As Coordinating Agency, NRC has technical leadership for the Federal government's response to the event.

The primary Federal response at PNPS supporting an emergency includes:

Nuclear Regulatory Commission (NRC), who acts as technical/regulatory advisors to PNPS during an emergency. They provide Federal communications capabilities, coordination of Federal assistance, and assessment of onsite radiological incidents and potential offsite consequences.

A-1 Revision 46

/

PNPS EMERGENCY PLAN U.S. Department of Energy (DOE), who maintains the lnteragency Radiological Assistance Program (IRAP) which provides radiological assistance to utilities, state, and local governments upon request. This assistance is provided through Brookhaven National Laboratory located in Long Island, New York.

Department of Homeland Security(DHS)/Federal Emergency Management Agency (FEMA), who coordinates the overall offsite Federal response and provides Federal resources and assistance to state and local governments.

Environmental Protection Agency (EPA), who assists with field radiological monitoring/sampling and non-plant related recovery and reentry guidance.

U.S. Coast Guard, who assists the Commonwealth and local authorities in the event of a radiological incident which involves a hazard over water.

National Weather Service, who provides meteorological information to PNPS in the event that the onsite meteorological tower or monitoring instrumentation becomes inoperative. The National Weather Service is located in Taunton, MA.

Commonwealth Agencies: The Commonwealth of Massachusetts Radiological Emergency Response Plan (RERP) provides for assistance from the Commonwealth agencies described below. The plan calls for supplemental support from Federal, Commonwealth, and local agencies.

The Massachusetts Emergency Management Agency (MEMA), Framingham, provides resources to support community response and perform technical response functions for the communities. Their supporting organizations are:

MEMA State Emergency Operations Center (SEOC)

Activates and manages the MEMA Headquarters EOC and activates Public Alert Notification System and the Emergency Alert System (EAS).

Provides resources to support community response.

Coordinates public notification.

Performs offsite support response functions on behalf of the communities.

Massachusetts Department of Public Health (MDPH)

Recommends protective actions to the Governor.

Performs accident assessment functions, environmental monitoring and sampling.

Provides for laboratory analysis of environmental samples.

Massachusetts State Police Provides support for traffic, access control, and security for MEMA Headquarters EOC.

Assists in coordination and implementation of protective actions in conjunction with MEMA.

A-2 Revision 46

PNPS EMERGENCY PLAN Massachusetts Department of Transportation (MOOT)

Provides traffic and access control equipment.

Provides resources to keep roads passable.

Massachusetts National Guard Supports law enforcement agencies for traffic and access control, and security for evacuated areas.

Transports emergency supplies.

Massachusetts Department of Environmental Protection Collects samples from public drinking water supplies within the Ingestion Exposure Pathway EPZ upon request of MDPH.

Restricts the use of public drinking water supplies found to be contaminated.

Massachusetts Department of Conservation and Recreation (OCR)

Provides emergency notification in state parks.

Massachusetts Department of Agricultural Resources Controls contaminated foodstuffs.

Maintains list of agricultural facilities within the Ingestion Exposure Pathway EPZ.

Massachusetts Department of Fish and Game Collects shellfish samples within the Ingestion Exposure Pathway EPZ.

Controls contaminated aquatic foods.

MEMA Region II, Bridgewater, supports community response and coordinates integrated community functions. It coordinates information and resources between the Commonwealth and communities. The MEMA Region II supporting operations are:

Directly supports EPZ and host community response and coordinates functions that require an integrated community effort.

Coordinates information and resources between the Commonwealth and local government.

Massachusetts State Police Troop D Activates and coordinates the State Police Traffic Control Plan.

Massachusetts Department of Transportation Districts 4 and 5 Coordinates Commonwealth traffic and access control equipment support.

Assists local public works departments to assure that roads remain passable.

A-3 Revision 46

PNPS EMERGENCY PLAN Massachusetts National Guard Coordinates National Guard transportation resources.

Coordinates National Guard support for traffic and access control, and security for evacuated areas.

Supports MEMA Region II EOC operations.

American Red Cross Coordinates Red Cross activities at mass care shelters.

State of Rhode Island Agencies Rhode Island Emergency Management Agency (RIEMA)

Assumes overall coordination of State activities in an emergency situation.

Provides technical guidance to state agencies.

Rhode Island State Police Coordinates communications between Rhode Island and other groups.

Rhode Island Department of Health (RIDOH)

Coordinates all state sampling, analysis and protective action guides.

Establishes a system of keeping medical records on events related to incident.

Typical Local Government Agencies: PNPS and the surrounding communities which comprise the PNPS Plume Exposure Pathway EPZ and Reception Centers have developed integrated emergency response programs which call upon the resources of their community. The community organizations are responsible for implementing and coordinating the community response to an emergency at PNPS. Typical key departments/individuals are identified below:

Board of Selectmen Provides overall control of emergency response.

Ensures 24-hour staffing of emergency organization.

Approves public information news statements.

Declares a local State of Emergency.

Ensures activation of Prompt Alert Notification System (PANS).

Ensures implementation of the protective action directives.

Directs town recovery, re-entry, and relocation activities.

A-4 Revision 46

PNPS EMERGENCY PLAN Emergency Management Agency Activates and manages the EOC.

Coordinates response operations.

Provides information to the Commonwealth on local conditions.

Obtains additional resources needed for response.

Maintains the emergency response program.

Coordinates training, drills and systems tests.

Police Department Receives and performs emergency notification.

Provides security at the EOC.

Provides police communications support from the EOC.

Assists in notification to beach and pond population.

Activates the siren system when directed.

Assists in route alerting.

Coordinates traffic flow for evacuation.

Recommends alternate evacuation routes.

Controls access to affected areas.

Provides security for evacuated areas.

Fire DepartmenUEmergency Medical Services Receives and performs emergency notification.

Provides firefighting support to PNPS.

Coordinates town ambulance service activities.

Coordinates mutual aid emergency medical services as needed.

Activates the siren system when directed.

Conducts route alerting, as necessary.

Council on Aging Coordinates notification and assistance to the special needs population.

Coordinates transportation for special needs population.

A-5 Revision 46

PNPS EMERGENCY PLAN Public Works Department Maintains evacuation routes in passable condition.

Provides traffic and access control ~quipment.

Restricts surface water supply to public, if necessary.

Maintains operation and integrity of sewer system.

Assists in establishing alternate evacuation routes, as necessary.

Provides transportation for emergency workers and equipment.

Assists in route alerting and notification to beach and pond population.

Harbor Master Provides emergency notification to boaters.

Assists in controlling access to marine areas.

Coordinates response actions with U.S. Coast Guard.

School Department Notifies and implements protective actions for the school population.

Coordinates transportation of school population.

Provides facilities to support transportation assistance and/or sheltering of the public.

Health Department Notifies camps, campgrounds, and industries and coordinates transportation needs.

Notifies key employers.

Notifies the hospital and nursing homes and coordinates transportation needs.

Operations Officer Coordinates EOC operations.

Assists EOC staff in resolving operational problems.

Ensures EOC staff is updated on events.

A-6 Revision 46

PNPS EMERGENCY PLAN Radiological Officer Distributes dosimetry, potassium iodide (Kl), and record forms to emergency workers.

Monitors radiation levels at EOC.

Ensures emergency worker exposure limit procedures are followed.

Advises EOC staff on emergency worker exposure.

Maintains emergency worker radiological records.

Ensures maintenance and availability of radiological equipment.

Coordinates radiological monitoring and decontamination at REWMDS and the reception centers.

Transportation Officer Coordinates staging area operations.

Ensures adequate transportation resources are mobilized to assist the general public schools, special facilities, and special needs persons.

Public Information Officer Provides information on town response to MEMA Public Information Officer (PIO) at the Joint Information Center.

Provides for rumor control on town-specific response actions.

Shelter Officer Coordinates operations of public shelters.

lndustrv/Private Organizations Beth Israel Deaconess Hospital - Plymouth, located in Plymouth, is the primary care facility for treatment of contaminated injured persons, and for evaluation of radiation exposure and radionuclide uptake (Radiological and the Medical Department determine who needs evaluation). Morton Hospital, located in Taunton, is designated as a back-up hospital and is equipped and trained to handle contaminated injured individuals. Individuals with severe radiation injury may be taken to a hospital as designated by MDPH.

Entergy Corporate has available all company resources for acquiring help from non-affected Entergy nuclear sites and other industry and private organizations. This will include providing all available assistance to maximize corporate management, administrative and technical support for mitigating accident conditions and restoring PNPS to a safe condition. This support also may involve providing technical.

expertise in areas of engineering, design or construction to assist with unique or complex problems, and requesting specialized services or equipment such as environmental monitoring, whole body counting, and personnel monitoring in support of PNPS emergency response and recovery operations.

A-7 Revision 46

PNPS EMERGENCY PLAN The Institute of Nuclear Power Operations (INPO) is able to provide:

Assistance in locating sources of emergency manpower and equipment.

An organization of industry experts who could advise on technical matters.

Analysis of operational aspects to the incident.

American Nuclear Insurers (ANI) provides insurance to cover PNPS 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 PNPS.

b. During an emergency condition at an Alert, Site Area Emergency, or General Emergency level, the PNPS Emergency Response Organization replaces the normal plant organization. The PNPS Emergency Response Organization consists of three major response sub-organizations:

The Onsite Organization, directed by the Emergency Plant Manager, provides for:

Control and operation of the plant.

Mitigation of the emergency condition.

Protection of station personnel.

Initial assessment of the emergency.

Notification of the appropriate individuals and agencies prior to EOF activation.

Emergency support for operations, engineering, maintenance, fire fighting, material acquisition, security, and first aid.

The Offsite Organization, directed by the Emergency Director, provides for:

Emergency notifications Offsite radiological accident assessment and protective action recommendations ~

to offsite authorities It serves as the primary interface between PNPS and outside organizations responsible for the protection of the public.

The Public Information Organization, directed by the Company Spokesperson, coordinates with public information officers from other organizations to provide emergency information to the public through the news media.

c.

Interrelationships between major PNPS organizations and sub-organizations in the total response effort are illustrated in a block diagram in Figure A-1. For a more detailed diagram of the PNPS Emergency Response Organization, see Figures 8-1 a through h.

d. The Emergency Director is the senior PNPS manager in charge of emergency response and has overall authority and responsibility for coordinating all emergency response actions at PNPS.

A-8 Revision 46

PNPS EMERGENCY PLAN

e. The PNPS Emergency Response Organization is composed of pre-designated Station personnel available and trained to augment the on-shift complement in an emergency.

Procedures for training and maintenance of the emergency organization are in place to assure 24-hour per day staffing for emergency response. The normal on-shift complement provides the initial response to an emergency. This group is trained to handle emergency situations, e.g. initiate the implementation of the PNPS Emergency Plan, and make initial accident assessment, emergency classification, notifications, and protective action recommendations until Emergency Response Organization activation occurs.

2. Commonwealth and Local Functions and Responsibilities: The Commonwealth, the local towns and reception center communities have Radiological Emergency Response Plans (RERPs) that specify the responsibilities and functions for the major agencies, departments, and key individuals of their emergency response organizations. This information is located in their respective plans.
3. Agreements in Planning Effort: Written agreements with support organizations having an emergency response role within the PNPS EPZs (including hospitals and medical transportation) are provided in Appendix 3, "Copies of Letters of Agreement". These agreements identify the emergency measures to be provided, the mutually accepted criteria.

for implementation, and the arrangements for exchange of information. Federal, Commonwealth, State, and local agencies that have response functions covered by laws, regulations, or executive orders have developed plans to meet these functions. These approved Plans serve as written agreements for agencies response to an incident at PNPS.

4. Continuous Coverage: The PNPS Emergency Response Organization has sufficient numbers of qualified, trained personnel to provide the capability of continuous (24-hour) operations. The PNPS Emergency Telephone Directory is reviewed and updated on a quarterly basis and identifies these individuals. The Regulatory and Performance Improvement Director administers the program to ensure availability of resources in the event of an emergency. The Emergency Director has the authority and is responsible for assuring continuity of resources (technical, administrative, and material) in the event of the activation of the PNPS Emergency Response Organization.

A-9 Revision 46

PNPSEMERGENCYPLAN Figure A-1:

Emergency Response Organization Interrelationships Operations Support Organization Entergy Corporate Control Room Organization Corrective Support Emergency Public Information Organization Security Assessment Technical Support Organization Protective Emergency Operations Facility Organization Other Industrial Organizations News Media Information Federal Commonwealth and local Agencies Information Notes:

General Public Protective

1. The Control Room initially interfaces with offsite agencies PNPS On site Organization PNPS Off site Organization PNPS Information Organization
2. All PNPS Facilities interface directly with the Nuclear Regulatory Commission's Emergency Response Team when they arrive.
3. The interface is depicted in italics, e.g. assessment actions, corrective actions, protective actions, and information transfer.

A-10 Revision 46

PNPS EMERGENCY PLAN Section B:

Station Emergency Organization This section describes the Pilgrim Nuclear Power Station (PNPS) Emergency Response Organization, its key positions and associated responsibilities. It outlines the staffing requirements which provide initial emergency response actions and provisions for timely augmentation of on-shift personnel when required. It also describes interfaces among PNPS response personnel and specifies offsite support available to respond to the PNPS.

1. PNPS Emergency Response Organization Assignments: Table B-1 outlines the PNPS on-shift complement and their emergency duties.
  • 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. Table B-1 further lists key PNPS Emergency Response Organization positions required to meet minimum augmentation capabilities for the on-shift complement at an Alert or higher classification. Each Emergency Response Facility lead has the authority to, if necessary to make the facility operational, designate personnel to fill Emergency Response Organization positions. These designations should be limited to one shift or until assigned personnel arrive.

The normal PNPS personnel complement is established with the Senior Nuclear Executive having overall authority for Station operations (the Shift Manager always retains the responsibility for actual operation of plant systems). The Senior Nuclear Executive directs senior Nuclear Organization staff in the management of the various department/organizations. When an emergency is declared, the normal organization structure is replaced by the PNPS Emergency Response Organization. PNPS Emergency Response Organization personnel are selected based on comparison of the emergency functions they are to perform with their normal daily tasks and prior training. EN-EP-801, Emergency Response Organization, outlines position responsibilities for the PNPS Emergency Response Organization. Key positions are normally filled from the Nuclear Organization as listed below. However, due to the large amount of cross training and diversification across all areas within the Nuclear Organization, positions can be staffed from any part of the Nuclear Organization where personnel may be found with the capacity and expertise to perform the assigned emergency function as described in EN-EP-801.

a. The Emergency Director is a member of the PNPS senior management staff.
  • The Radiological Assessment Coordinator is normally from the Radiation Protection Group or Plant Management Staff.
b. The Emergency Plant Manager is a member of the PNPS senior management staff.

The Emergency Plant Operations Supervisor is a member of Plant Operations who holds an operator's license on PNPS.

The Technical Support Center Manager is assigned from Plant Management Staff.

The Operations Support Center Manager is assigned from Plant Management Staff.

The TSC Security Coordinator is assigned from Security Management Staff.

The Radiological Coordinator is the Radiation Protection Manager or a designated senior member of Radiation Protection.

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PNPS EMERGENCY PLAN

c. The EOF Manager is a member of the PNPS senior management staff or designated alternate from PNPS staff.

The Offsite Communicator is normally selected from Plant Management Staff (any management level supervisor who has communication skills and can coordinate emergency communication efforts may be used to fill this position).

The Admin and Logistics Coordinator is normally a member of Plant Management Staff.

The Offsite and MEMA Technical Liaisons are members of Plant Management Staff and/or support organizations.

The Lead Offsite Liaison is a Senior Engineer or a designated alternate from Plant Management Staff.

d. The Company Spokesperson is a senior member of the Plant Management Staff.

The JIG Manager is a member of Plant Management Staff familiar with Joint Information Center operations.

2. Authority Over PNPS Emergency Response Organization: The Emergency Director has overall authority and responsibility for coordinating all emergency response activities at PNPS. Detailed responsibilities are described in Part 4 of this section. The Shift Manager, or in his absence from the Control Room, the available on-shift Senior Reactor Operator (SRO) assumes the position of Emergency Director until the Senior Nuclear Executive or a designated alternate arrives at the Emergency Operations Facility and assumes the position.
3. Succession to Emergency Director: Initially, the Shift Manager or the available on-shift Senior Reactor Operator (SRO) assumes the duties and responsibilities as the Emergency Dfrector. When augmentation of the on-shift complement occurs, the Senior Nuclear Executive or designated alternate reports to the EOF and, once briefed, relieves the Shift Manager of all Emergency Director responsibilities. Once the on-call Emergency Director assumes the Emergency Director responsibilities, overall command and control of the emergency transfers from the Control Room to the EOF. The Emergency Plant Operations Supervisor may relieve the on-shift Emergency Director until such time as the on-call Emergency Director arrives, however he/she must report and remain in the Control Room until relieved.
4. Emergency Director Responsibilities: The Primary responsibilities assigned to the* Emergency Director are to:

Classify the emergency situation using established Emergency Action Levels and periodically review the classification to ensure that it reflects current plant conditions. This responsibility is NON-DELEGABLE.

Apprpve notifications/communications to local, Commonwealth, and Federal government agencies and ensure that correct notifications and information updates are made in a timely manner. This responsibility is NON-DELEGABLE. (Note: approval is not required for NRC notifications once ENS is established or NRC is present.)

Provide Protective Action Recommendations (PARs) to authorities responsible for protection of the general public. This responsibility is NON-DELEGABLE.

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PNPS EMERGENCY PLAN Terminate the event and initiate the recovery phase. This responsibility is NON-DELEGABLE.

At an Alert or higher classification (or when the EOF is operational), authorize PNPS press releases. This responsibility is NON-DELEGABLE.

Ensure other organization's management/decision makers (NRC, Entergy Corp, etc.,) are kept informed of the emergency situation.

Monitor plant status following a security or other event affecting plant and personnel safety to ensure ERO response and mobilization remains appropriate.

Ensure appropriate emergency procedures are implemented.

Ensure all PNPS emergency response facilities are operational and properly staffed.

Authorize required assistance from corporate and/or offsite organizations and agencies.

Interface with NRC and FEMA response teams located at the EOF and other PNPS facilities.

Authorize radiation exposures for offsite PNPS emergency workers in excess of 1 OCFR20 limits and use of potassium iodide as a thyroid blocking agent. This responsibility rests with the Emergency Plant Manager for onsite personnel.

The Emergency Director oversees the PNPS Emergency Response Organization's interfaces with local, Commonwealth, State, and Federal authorities. The Emergency Plant Manager, the EOF Manager, and the Company Spokesperson report directly to the Emergency Director, as do the Radiological Assessment Coordinator, the EOF Technical Advisor and the ICP Security Coordinator.

5. PNPS Emergency Response Organization The Emergency Plant Manager is the senior individual located at the site and is responsible for:

Activities associated with PNPS operations (the Shift Manager retains authority for actual operation of plant systems).

Plant accident assessment.

Emergency classification recommendations to the Emergency Director based on plant parameters.

Onsite actions taken to mitigate the emergency situation.

Waive initial requirements for access authorization to PNPS. This responsibility is NON-DELEGABLE Protective actions for onsite PNPS personnel, including directing site evacuation activities, authorizing emergency exposures in excess of lower 10 CFR20 limits and use of potassium iodide. (non-delegable)

Determination of emergency responder's ability to perform their assigned duties under Fitness For Duty criteria at PNPS.

The Emergency Plant Manager interfaces with the Emergency Director. The Emergency Plant Manager is normally located in the Technical Support Center.

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PNPS EMERGENCY PLAN The Emergency Plant Operations Supervisor is the senior management position in the Control Room and is responsible for coordination of the Control Room activities with all outside emergency facilities. The Emergency Plant Operations Supervisor does not relieve the Shift Manager of responsibilities for operation of the plant. This position advises the Emergency Plant Manager on plant status and trends and their potential impact.

The Emergency Plant Operations Supervisor interfaces with the Technical Support Center Manager, Operations Support Center Manager, Radiological Coordinator and the TSC Security Coordinator.

The Technical Support Center Manager supervises engineering activities associated with mitigation of the emergency situation. This position advises the Emergency Plant Manager on proposed corrective actions and emergency classification from a technical standpoint (i.e. plant system damage, core damage, etc.). The TSC Manager is responsible for the activation and proper staffing of the TSC. This includes augmentation of engineering staff, as needed.

The Technical Support Center Manager interfaces with the Emergency Plant Operations Supervisor, Operations Support Center Manager, Radiological Coordinator and the TSC Security Coordinator.

The Operations Support Center Manager supervises emergency repair teams, search and rescue teams, first aid teams, fire fighting and chemistry teams associated with accident mitigation. This position works with the Operations Support Center Work Control Coordinator to provide for maintenance of accountability for operations personnel dispatched into the plant during the emergency and Emergency Plant Manager in the TSC to provide for appropriate prioritization and dispatch. The Operations Support Center Manager assesses the manpower requirements and technical skill levels required to mitigate the emergency situation and requests augmentation of the Operations Support Center (0SC) staff as appropriate.

The Operations Support Center Manager interfaces with the Technical Support Center Manager, Emergency Plant Manager, Emergency Plant Operations Supervisor, Rad/Chem Coordinator, TSC Security Coordinator and the Admin and Logistics Coordinator.

The Radiological Coordinator supervises the analysis of radiological data and radiation protection measures for personnel inside the Protected Area. This position is responsible for all radiological aspects of the emergency for the plant and making recommendations to the Emergency Plant Manager on classification, onsite protective actions and corrective actions based on this data.

Initially, unless directed to do otherwise by the Shift Manager, the on-shift Radiation Protection Supervisor/Technician performs the duties of Radiological Coordinator until relieved.

The Radiologipal Coordinator interfaces with the Technical Support Center Manager, the Operations Support Center Manager and the Rad/Chem Coordinator.

The TSC Security Coordinator supervises the Station security forces. This position is responsible for the coordination of Protected Area accountability and evacuation, emergency access to vital areas and physical security of the Station. The TSC Security Coordinator keeps the Emergency Plant Manager informed of all security concerns as they pertain to mitigation of the emergency. In addition, the TSC Security Coordinator coordinates the security activities of all Pilgrim Station emergency response facilities, and coordinates with the Admin and Logistics Coordinator regarding security in the JIC. Initially, the Lead Security Shift Supervisor performs the duties of the TSC Security Coordinator until relieved.

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PNPS EMERGENCY PLAN The TSC Security Coordinator interfaces with the Emergency Plant Operations Supervisor, the Operations Support Center Manager, the Technical Support Center Manager, the Admin and Logistics Coordinator, the Emergency Director and the ICP Security Coordinator in response to events involving security threats to the site or site personnel.

The EOF Manager is responsible for the overall operation of the Emergency Operations Facility (EOF) including:

Determination of emergency responders' ability to perform their assigned duties under Fitness for Duty criteria at the EOF following emergency response activation.

Interface with Entergy Corporate to ensure that Company resources are available to the Emerdency Director, and to ensure that senior management has sufficient information to develop Company policy decisions in a timely manner.

Assurance of timely communications with local, Commonwealth, and federal agencies after activation of the EOF following emergency response activation.

Coordination of additional support and resources from corporate through the Admin and Logistics Coordinator and from offsite through the Emergency Director.

The Radiological Assessment Coordinator has the responsibility for computation and evaluation of projected dose rates,. exposures, environmental impacts and PARs for areas outside of the Protected Area. This position utilizes Dose Assessors, the Offsite Monitoring Team Coordinator and Offsite Monitoring Teams and is the Emergency Director's radiological advisor. The Radiological Assessment Coordinator is responsible for radiological exposure controls for all PNPS response personnel outside the Protected Area.

The Radiological Assessment Coordinator interfaces with the EOF Technical Advisor and the Radiological Coordinator.

The Offsite Communicator is responsible for performing offsite communications and notifications with Federal, Commonwealth, State and local emergency organizations and distributing information and forms.

The Admin and Logistics Coordinator is responsible for initial and relief staffing during an extended emergency and logistical support (food, transportation, equipment maintenance, etc.) and for securing the Emergency Operations Facility. The Admin and Logistics Coordinator coordinates with the EOF Manager as necessary to obtain resources from Entergy Corporate.

The Admin and Logistics Coordinator interfaces with the Technical Support Center Manager, the Operations Support Center Manager, the EOF Manager, and the TSC Security Coordinator.

The Lead Offsite Liaison is responsible for assisting the Commonwealth and local authorities in interfacing with the PNPS ERO through the Offsite Liaisons and MEMA Technical Liaison.

The Company Spokesperson is authorized to deliver public statements on behalf of Pilgrim Station pertaining to information approved by the Emergency Director during emergency conditions at PNPS. The Company Spokesperson oversees the flow of information from the Joint Information Center (JIC) and assures that information is provided to the news media in an accurate and timely manner and is coordinated with responding government agencies.

B-5 Revision 46

PNPSEMERGENCYPLAN The Company Spokesperson interfaces with the JIC Manager, Emergency Director and Public Information Officers from Commonwealth and Federal government agencies.

The JIC Manager is responsible for the efficient operation of the PNPS public information effort at the Joint Information Center during an emergency at PNPS. This position assures coordination with Commonwealth and Federal agencies in providing information to the public through the news media.

Table B-1 outlines key emergency response positions, their expected response times and the major tasks assigned to each position.

6. PNPS Emergency Response Organization Block Diagram: Figure B-1 illustrates the positions of the PNPS Emergency Response Organization and supporting positions. Positions are assigned to interface with Federal, Commonwealth, State, and local authorities. Section 8.5 discusses specific responsibilities and the interrelationships for key positions.
7. Corporate Emergency Response: Entergy Corporate provides support to the PNPS Emergency Response Organization. Provisions exist in the PNPS Emergency Plan Implementing Procedures to integrate support available at the corporate level.
8. Private Industry Support: PNPS maintains a list of approved contractor and private organizations that provide technical assistance and can augment the PNPS staff during normal operations in the Emergency Telephone Directory. In addition, industry resource (Institute of Nuclear Power Operations, American Nuclear Insurers, etc.) lists are maintained that identify specialized resources.

These organizations may be called on to assist during an emergency or during the recovery phase.

9. Offsite Emergency Assistance to PNPS: PNPS is located in the Town of Plymouth and served by Town departments and local medical services. The following organizations have entered into agreements to support PNPS in the event of an emergency, including those resulting from hostile actions at the station:
a. The Plymouth Fire Department has agreed, as requested by the PNPS Control Room to Plymouth Fire, to provide:

Fire protection assistance for the site.

Coordination of emergency ambulance services including ambulances and emergency medical technicians as,well as the transport of contaminated and injured personnel or radiation injury victims.

Rescue assistance to the public for the open areas of the site.

Storage of emergency equipment supplied by PNPS (back up breathing air compressor).*

b. The Plymouth Police Department has agreed, as requested by the PNPS Control Room or Security to Plymouth Police, to provide local law enforcement as described in a separate agreement maintained by PNPS Security and Plymouth Police, and to:*

Control access on town roads in the vicinity of the site, including the erection of barricades on Rocky Hill Road if needed.

Initiate evacuation of the public from the site.

Provide offsite storage of emergency equipment.

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PNPSEMERGENCYPLAN

c. Beth Israel Deaconess Hospital - Plymouth and Morton Memorial Hospitals have agreed to provide medical treatment to contaminated and injured personnel or radiation injury victims from PNPS and participate in at least one Emergency Medical Drill per calendar year rotating between hospitals. Additional hospitals have agreed to provide similar services for the treatment of offsite personnel contaminated and injured during an accident at PNPS.
d. The Town of Carver has agreed to provide facilities for the PNPS Alternate Emergency Operations Facility.
e. Bridgewater State University provides facilities for the PNPS Alternate Joint Information Center.

Sample copies of these letters of agreement are displayed in Appendix 3 of this Plan. The original letters are maintained in the Emergency Planning files. Letters of Agreement are renewed annually or at a frequency prescribed in the document.

B-7 Revision 46

PNPS EMERGENCY PLAN Table B-1:

Minimum Staffinq Requirements for the PNPS ERO n Functional Area Major Task Onshift Position Title Res-Pos.No.

ponse Plant Operations Plant Stabilization 1

Shift Manaqer On Shift#

Assessment of Operational Accident Mitigation 2

Control Room Supervisor On Shift#

Aspects 3,4 Lie. Nuc. Plant Operator (2)

On Shift#

5,6 Unlic. Nuc. Plant Operator (2)***FB On Shift#

Emerqency Direction Emerqencv Classification (1)

Shift Manaqer On Shift#

Emergency Control PARs (1)

Shift Manager On Shift#

Emergency Director 60 min.

Emergency Plant Ops Supv 60 min.

Notification and Notification of PNPS, Local, (1)

Shift Manager On Shift#

Communications Commonwealth, and Federal personnel 7

Unlic. Nuc. Plant Operator On Shift#

and Maintain Communications Offsite Communicator 30 min.

EOF Communicator 60 min.

ENS Communicator 60 min.

Rad Accident Assessment EOF Direction EOF Manager 60 min.

Ops Accident Assessment Offsite Dose Assessment (8)

RP Technician***

On Shift#

Support (9)

Radio Chem. Technician***

On Shift#

Radioloaical Assessment Coard 30 min.

Offsite Surveys OMT Member (2) 30 min.

OMT Member (2) 60 min.

Onsite and In-plant Surveys 8

RP Technician On Shift#

RP Technician (2) 30 min.

RP Technician (2) 60 min.

Chemistry I Radiochemistry 9

Radio Chem. Technician On Shift#

Radio Chem. Technician 60 min.

Plant System Engineering TSC I OSC Direction Emergency Plant Manager 60 min.

Repair and Corrective Actions Technical Support 10 Engineer (Shift Control Rm)*

On Shift#

Engineer (Reactor) 30 min.

Engineer (Mechanical) 60 min.

Enaineer (Electrical) 60 min.

Equipment Repairs Nuclear Maint. Technician 30 min.

Corrective Actions Nuclear Maint. Technician 60 min.

11 Unlic. Nuc. Plant Operator On Shift#

12 Nuc. Plant Reactor Operator***FB On Shift#

Nuc. Plant Reactor Operator 60 min.

Nuclear Maint. (Electrical)(2) 30 min.

Nuclear Maint. (Electrical) 60 min.

Nuclear Control Technician(2) 30 min.

Protective Actions (In Plant)

Radiation Protection, Access Control, (8), (9)

RP Technician (2)***

On Shift#

RP Coverage, Personnel Monitoring, RP Technician (2) 30 min.

and Dosimetry RP Technician (2) 60 min.

Fire Fighting 13, 14 Fire Brigade*, (3 ***, 2 [NLO or Sec])

On Shift#

Plymouth Fire Dept.

On Call Rescue Ops and First Aid EMP****

On Shift#

Ambulance Service On Call Site Access Control and Security Security Force**

On Shift#

Personnel Accountability On Shift - A person 1s said to be on shift when, during normal or authorized overtime hours, that person 1s within the PNPS owner controlled areas or on the connecting roads between them with Station Management approval.

Position staffed in accordance with technical specifications.

Position staffed in accordance with technical specifications and station procedures.

May be provided by shift personnel assigned other functions.

(EMP) Emergency Medical Personnel: individuals qualified as EMPs, RNs, First Responders, and Paramedics.

NOTES: Response times are based on optimum travel conditions.

On Shift Position #7 is Assistant to Offsite Communicator and can be replaced by an SRO that is qualified for the task.

On Shift Position #11 can be filled by an RO or SRO that is qualified for the task On Shift Positions #13 and #14 are available to support Shift Manager, where qualified, in non-fire events.

(A) This table B-1 is incorporated into the Emergency Plan in accordance with USNRC Generic Letter 82-33 dated 12/17/82 and incorporates within 30 days of pproval the conclusions of the PNPS On Shift Staffing Analysis Report which is a part of the Emergency Plan in accordance with 1 OCFR50 Appendix E, Section

. A. 9 and maintained as a separate document.

B-8 Revision 46

  • ICP Security Coordinator Emergency Plant Ops Supvervisor See Fig B-1 b TSC Manager See Fig B-1c PNPS EMERGENCY PLAN Emergency Plant Manager osc Manager See Fig B-1d TSC Security Emergency Director I

Rad Assess Coordinator See Fig B-1f Coordinator See Fig B-1e I

EOF Manager See r-*

  • i -

'::l Hostile Action Based Events Position B-9 I

Company Spokesperson See Revision 46

PNPS EMERGENCY PLAN Figure B-1 b:

Operations Emergency Organization Emergency Plant Operations Supv I

I

~

ENS/NRC Communicator I

Control Room Supervisor (SCRE)

Shift Manager I

Licensed Nuclear Plant Operators

    • Located in the OSC
  • Plant Data Communicator I

I Control Room Supervisor I

B-10

/

Rad Data Communicator

    • OSC Operations Support
    • OSC Operators Revision 46

PNPS EMERGENCY PLAN Figure B-1c:

Technical Support Organization I

I I

TSC Manager Engineering 1--

Coordinator Rad Coordinator I Electrical Enqineer Ops Coordinator I I

H l&C Engineer I

Mechanical

~ Ops Engineer I Called in SCRE*

I Enqineer Reactor TSC Communicator I

Enqineer I

TSCIT Specialist Additional Engineering personnel may be called in based on the nature of the event.

  • SCRE: Control Room Supervisor (SCRE)

B-11 I

Revision 46

PNPS EMERGENCY PLAN Figure B-1d:

Operations Support Organization osc Manager I

OPs ~

Work Control Support Coordinator l&C/Elect I Logkeeper ~

Coordinator

--1 Elect Techs

--i Dosimetry l&C Techs Clerk Mechanical Coordinator

~ Mech Techs I

Rad/Chem Coordinator H RP Techs r

Chem Tech I

  • Rad Data i.........

Comm

  • Revision 46

PNPS EMERGENCY PLAN Figure B-1e:

Emergency Security Organization Off site Security Force TSC Security Coordinator

  • PNPS Non-ERO support positio,n B-13 Lead Security Shift Supervisor
  • On site Security Force Revision 46

PNPS EMERGENCY PLAN Figure B-1f: Offsite Radiological Assessment Organization I

Dose Assessor Radiological Assessment Coordinator Off site Monitoring Team #1 (OMT Driver and Monitor)

Offsite Monitoring Team Coordinator Off site Monitoring Team #2 (OMT Driver and Monitor)

  • Rad Data Communicator

\\

I Revision 46

PNPS EMERGENCY PLAN Figure B-1g:

Emergency Operations Facility Organization Emergency Director I

EOF Rad Assessment EOF Technical Manager Coordinator Advisor q

EOF Communicator 1 Admin and Logistics Offsite Team Coordinator Coordinator Log Keeper l IT Off site Specialist Monitoring Teams Lead Offsite

'--1 Dose Assessors I Liaison

_I -I

  • Offsite Liaison(s) I

~

Offsite Communicator Public Information Liaison Located at Commonwealth and Local EOCs B-15 Revision 46

PNPS EMERGENCY PLAN Figure B-1h:

Emergency Public Information Organization I.

Inquiry Resp Coord Phone Team Technical Assistant Press Release Writer Media Monitor Company Spokesperson JIC Manager Information Coordinator B-16 JIC Tech Advisor Media Liaison Media Assistant

~_, AN Assist.

Logistics Coord Log Keeper Agency Coord Admin Team Revision 46

PNPS EMERGENCY PLAN Section C:

Emergency Response Support and Resources This section describes the provisions for requesting and effectively utilizing support resources and for accommodating Commonwealth and local staff at the PNPS Emergency Operations Facility (EOF).

1. Federal Response Support and Resources: Assistance is available from Federal agencies through the National Response Framework (NRF). The primary Federal agencies who provide assistance to the Commonwealth and PNPS, respectively, are the Federal Emergency Management Agency (FEMA) and the Nuclear Regulatory Commission (NRC).

Other Federal agencies, through the NRF, provide assistance to the Commonwealth in an emergency.

a. Sections A and B of this Plan identify the specific persons by title who are authorized to request Federal assistance.
b. Federal agencies that may provide assistance in direct support of Pilgrim Nuclear Power Station (PNPS) in the event of an accident are identified in Section A of this plan. If needed, Federal resources are made available to PNPS in an expeditious and timely manner.
c. Each PNPS 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 Technical Support Center (TSC) is able to accommodate seven NRC representatives. Working areas are available and a desk has been provided for their use. The EOF has space to accommodate twelve NRC representatives as well as representatives from FEMA, the Massachusetts Department of Public Health (MDPH) and the Massachusetts Emergency Management Agency (MEMA).

In addition to PNPS facilities and equipment, Commonwealth and local facilities and equipment are available to support the Federal response. Among these are the Commonwealth Emergency Operations Centers (EOCs) in Framingham and Bridgewater and local EOCs in Plymouth, Duxbury, Carver, Kingston and Marshfield, and Reception Centers in Taunton, Bridgewater and Braintree.

2. Liaisons:
a. The NRC, FEMA, MEMA, and MDPH may dispatch representatives to the EOF where accommodations have been provided.
b. At the Alert level and above, PNPS liaisons are dispatched to the Commonwealth and local government EOCs to act as communications liaisons and to provide clarification of emergency response information.

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PNPS EMERGENCY PLAN

3. Radiological Laboratories: If the offsite radiological monitoring and environmental sampling operation exceeds the capacity of the PNPS capabilities, the radiological analytical capability of other non-affected Entergy nuclear sites, Commonwealth and Federal agencies and other utilities can be used to analyze radiological samples. As discussed in Section A.1, this additional capability is integrated into existing support efforts and concept of operations in responding to a declared emergency at PNPS. Section H.6 also provides more details on the offsite radiological monitoring support that can be used at PNPS.
4. Other Assistance: Contracted services, as listed in the Emergency Telephone Directory (ETD), are available and may be used in support of an emergency response at PNPS.

Though not a typical contracted service, the Institute of Nuclear Power Operations (lNPO) is able to provide:

Assistance in locating sources of emergency manpower and equipment, An organization of industry experts who could advise the utility on technical matters, and Analysis of operational aspects of the incident.

Through lNPO, nuclear sites have identified technical experts and specialized equipment that could be provided upon request in an emergency. The lNPO Emergency Resources Manual includes the information necessary to locate and request specialized equipment and technical assistance in the event of a nuclear emergency at PNPS. lNPO member utilities and suppliers agree to provide assistance as outlined in the lNPO Emergency Resources Manual.

C-2 Revision 46

/

PNPS EMERGENCY PLAN 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 Pilgrim Nuclear Power Station (PNPS) systems, effluent parameters and operating procedures. The initial response of Federal, Commonwealth and local agencies is dependent upon information provided by PNPS. PNPS works closely with the Commonwealth and local agencies to ensure consistency in classification schemes and procedural interfaces.

1. Emergency Classification: This Plan provides for four classifications of emergency conditions. These mutually exclusive classifications cover the postulated spectrum of potential and actual emergencies. Each classification is associated with a particular set of immediate actions. However, during a safeguards contingency event, actions may be taken that depart from the immediate requirements specified for each of the four classification levels when those actions are immediately needed to protect the health &nd safety of members of the public or the plant staff. Those actions may include suspension, delay or modification of activities that could endanger the safety of members of the public, plant staff or security force or which' could interfere with an effective response to the safeguards contingency event. Each classification is characterized by certain initiating symptoms or events called Emergency Action Levels (EALs). These action levels include specific sets of plant parameters (i.e., instrument indications, system status, etc.) that are used to determine the appropriate emergency classification. Table D-1 outlines the example conditions of abnormal symptoms and events, which would require declaration of an emergency at PNPS. The Emergency Plan Implementing Procedure used for classification of an event includes specific instrument readings and equipment status for establishing the symptoms and events appropriate for each classification. A conservative philosophy for classification is used to declare the highest emergency classification for which an EAL has been exceeded. PNPS maintains the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded and promptly declares the emergency condition as soon as possible following identification of the appropriate emergency classification level. The four classification levels are:
a. Unusual Event - Event(s) are in process or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection. 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 (4) levels. The purpose of this classification is to bring the PNPS staff and offsite agencies to a state of readiness in the event the situation degrades.

Required actions at this classification include:

Notification, within 15 minutes, of the Commonwealth of Massachusetts and local communities.

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

Notification of certain members of the PNPS Emergency Response Organization to standby (portions of the organization may be activated at this classification).

D-1 Revision 46

PNPS EMERGENCY PLAN Notification of the Nuclear Regulatory Commission (NRC) immediately after notification of the appropriate Commonwealth and Local Agencies and not later than an hour after classification.

Keeping offsite authorities informed of plant status by providing one hour updates to include meteorological data and projected or actual doses for any releases which have occurred.

When the event is terminated, close-out is performed over communication links followed by transmission of an Initial Notification Form indicating that the event has been terminated.

b. Alert - Event(s) are in process or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or probable damage to site equipment because of Hostile Action. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels. The purpose of this classification is to ensure emergency personnel are readily available to respond, if the situation becomes more serious, and relieve the Control Room of some required actions so that the operations shift can concentrate on restoring the level of safety to the plant.

Required actions at this classification include:

Notification, within 15 minutes, of the Commonwealth of Massachusetts and local communities.

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

Activation of the PNPS Emergency Response Organization which includes activation of the Technical Support Center (TSC), Operations Support Center (OSC),

Emergency Operations Facility (EOF), Joint Information Center (JIC), and notification of Entergy Corporate.

Notification of the NRC immediately after notification of the appropriate Commonwealth and Local Agencies and not later than an hour after classification.

Keeping offsite authorities informed of plant status by providing one hour updates to include meteorological data and projected or actual doses for any releases which have occurred.

When the event is terminated, close-out is performed over communication links followed by an Initial Incident Report to offsite authorities participating in the response (i.e., NRC, Commonwealth, State, and Local) within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

D-2 Revision 46

PNPS EMERGENCY PLAN

c. Site Area Emergency - Event(s) are in process or have occurred which involve an actual or likely major failures of plant functions needed for protection of the public or Hostile Action that results 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 Protective Action Guideline exposure levels beyond the site boundary. The Site Area Emergency class also includes events where a significant release of radioactive material is likely or is occurring but significant core degradation is not indicated based on current information.

The purpose of this classification is to ensure that all emergency response centers are manned, offsite monitoring teams are sent to staging areas or dispatched, personnel required to evacuate near-site areas are in position and provisions are made for information updates to the public through offsite authorities and the news media.

Required actions at this classification include:

Notification, within 15 minutes, of the Commonwealth of Massachusetts and local communities.

Assessment of the situation and response as necessary, this includes escalating to a higher classification if conditions warrant.

Activation of the PNPS Emergency Response Organization which includes activation of the TSC, OSC, EOF, Joint Information Center and Corporate Emergency Response Group. Offsite Monitoring Teams are sent to staging areas or dispatched to monitor for releases of radiation to the environment.

Notification of the NRC immediately after notification of the appropriate Commonwealth and Local Agencies and not later than an hour after classification.

Keeping offsite authorities informed of plant status by providing one hour updates to include meteorological data and projected or actual doses for any releases which have occurred.

When the event is terminated, close-out is performed over communication links followed by an Initial Incident Report to offsite authorities participating in response (i.e., NRC, Commonwealth, State and Local) within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

d. General Emergency - Event(s) are in process or have occurred which 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 Protective Action Guideline exposure levels offsite for more than the immediate site area. This is the most severe classification of an emergency. The purpose of this classification is to initiate predetermined protective actions for the public, provide continuous assessment of information from monitoring groups and provide information updates to the public through offsite authorities and the news media.

D-3 Revision 46

PNPS EMERGENCY PLAN Required actions at this classification include:

Notification, within 15 minutes, of the Commonwealth of Massachusetts and local communities.

Assessment of the situation and response as necessary.

Activation of the PNPS Emergency Response Organization which includes activation of the TSC, OSC, EOF, Joint Information Center and Corporate Emergency Response Group. Offsite Monitoring Teams are sent to staging areas or dispatched to monitor for releases of radiation to the environment.

Notification of the NRC immediately after notification of the appropriate Commonwealth and local agencies and not later than an hour after classification.

The emergency organization has personnel available to consult with the NRG on planned actions at the Station.

Keeping offsite authorities informed of plant status by providing one hour updates to include meteorological data and projected or actual doses for any releases which have occurred.

Issuance, as a minimum, based upon plant conditions, initial protective action recommendations to affected EPZ sub-areas. Section J.7 provides a detail description of the possible recommendations that may be issued at the General Emergency classification including the consideration of administering potassium iodide (Kl) to the general public.

  • Consideration of relocating the Joir;it Information Center to its alternate site, based upon radiological or other conditions, such as a Commonwealth-directed evacuation of subarea 7.

Reassessment of PARs as necessary.

When the event is terminated, close-out is performed over communication links followed by an Initial Incident Report to offsite authorities participating in response (i.e., NRG, Commonwealth, State and local) within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

2. Emergency Action Levels: The symptoms and events outlined in Table D-1 encompass the example conditions based on Nuclear Energy Institute (NEI) 99-01, "Methodology for Development of Emergency Action Levels", Revision 5, February 2008. The specific Emergency Action Levels detailed in the Implementing Procedures are utilized to classify emergency conditions and provide the control room operator with the indications characteristic of one or more of the symptoms or events specified.
3. Offsite Classification Systems: PNPS works with the Commonwealth of Massachusetts and local authorities to ensure consistency between classification schemes. The content of the Emergency Action Levels is reviewed with the Commonwealth and local authorities on an annual basis.
4. Offsite Emergency Procedures: PNPS works with the Commonwealth of Massachusetts and local 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 PNPS accounting for local offsite conditions that exist at the time of the emergency.

r D-4 Revision 46

L EXAMPLE PNPS EME.

NCY PLAN Table 0-1 Symptoms and Events Requiring Emergency Classification 3 *--

~

r--

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1

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1

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l. 'l' l I ~

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~-,.._-,._._....,

=.-::....-:::!..~~::

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.rJ.-~!i!:-*

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.J+..
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HOT CONDITIONS

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Revision 46

EXAMPLE PNPS EME.

ENCY PLAN Table 0-1 Symptoms and Events Requiring Emergency Classification I

i i

2 H *-

I 3 I_-:-

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COLD CONDITIONS D-6 EAL ldeotlOer x.xx.x Revision 46

I PNPS EMERGENCY PLAN Section E:

Notification Methods and Procedures This section describes the notification of Commonwealth and local response organizations and PNPS emergency response personnel. It outlines the content of initial and follow-up messages to response organizations within the Pilgrim Nuclear Power Station (PNPS) Plume Exposure Pathway Emergency Planning Zone (EPZ).

1. Response Organization Notification: PNPS, in cooperation with Commonwealth and local authorities, has established mutually agreeable methods for notification of response organizations consistent with the emergency classification and action level scheme.

When an emergency is declared, reclassified, or terminated, the Emergency Director ensures notifications are promptly made to first-line offsite support agencies. These first-line notification contacts are:

The Massachusetts Emergency Management Agency (MEMA), notified by a dedicated notification network, or alternatively with BECONS or commercial telephone as backups. The Massachusetts Emergency Management Agency (MEMA) notifies the Massachusetts Department of Public Health (MDPH), MEMA Region II and Braintree using commercial telep,hone lines.

The local communities within the Plume Exposure EPZ and reception communities are notified by a dedicated notification network, with BECONS or commercial telephone as backups. These communities are Plymouth, Carver, Duxbury, Kingston, Marshfield, Bridgewater and Taunton.

The Nuclear Regulatory Commission (NRG) is notified by a dedicated telephone system called the Emergency Notification System (ENS), or for backup, by commercial telephone. Initial notification occurs from the Control Room.

2. Notification and Mobilization of Emergency Response Personnel: At the Unusual Event classification, the PNPS Emergency Response Organization is notified and may be activated at the discretion of the Emergency Director. At the Alert, Site Area Emergency, or General Emergency classification level, activation of the Emergency Response Organization and related facilities is required. If the nature of the event threatens the safety of the ERO, onsite personnel may be directed to the Alternative Facility at the Chiltonville Training Center or requested to remain in place until the security of the site is restored.

Announcements are made from the Control Room over the plant public address system to notify on-site personnel of plant-related emergency response information. In addition to the public address system, emergency organization personnel are notified by pagers or telephone calls using the EverBridge notification system. Backup systems to EverBridge include the use of the EverBridge alternate activation process or initiating telephone call-outs of emergency response p~rsonnel.

Non-emergency station response is discussed under Station Procedure 1.3.12.1, "Non-Emergency Notification of Management".

E-1 Revision 46

PNPS EMERGENCY PLAN

3. Initial Notification: The initial emergency message form includes information about:

Notification Type, i.e. "This is a Drill" or "This is an Actual Event."

Identity of caller and receiver of call Emergency classification Emergency action level identification and whether a release is in progress Wind direction and speed Whether protective measures may be necessary The date and time of classification and notification Initial notifications are delivered to the Commonwealth and local communities within fifteen (15) minutes of classification of an event. In a General Emergency the initial notification will also include protective action recommendations to the affected EPZ sub-areas. Section J.7 provides a detail description of the possible recommendations that may be issued at the General Emergency classification.

4. Follow-up Messages: The Emergency Director ensures communications are maintained with the offsite authorities through periodic follow-up messages. The follow-up messages include the following, as appropriate:
a. Location of incident and name of caller and receiver of call, whether a drill or not a drill.
b. Time and date of the incident.
c.

Class of emergency.

d. Type of actual or potential radiological release (airborne, waterborne, surface spill).
e. Whether or not [estimate of quantity of] radioactive material has been released or is being released and the points and heights of ~eleases.
f.

Radiological release information, including estimates of the relative quantities and concentrations of noble gases, halogens, and particulates.

\\

g. Meteorological conditions at appropriate levels (wind speed, direction to and from, stability, precipitation).
h. Actual or projected dose rates at the site boundary, projected integrated dose at site boundary.
i.

Projected dose rates and integrated dose at the projected peak and at 2, 5, and 10 miles, including subarea(s) affected.

j.

Estimate of any surface contamination in-plant, onsite, or offsite.

k.

Plant emergency response actions underway.

I.

Recommended emergency actions, including protective measures.

E-2 Revision 46

PNPS EMERGENCY PLAN

m. Request for any needed onsite support by offsite organizations.
n. Prognosis for worsening or termination of event based on plant information.
5. Commonwealth and Local Information Dissemination: Commonwealth and local government organizations, in cooperation with PNPS, have established a system for disseminating appropriate information to the public. The system includes notification through appropriate broadcast media, e.g. the Emergency Alert System (EAS).
6. Notification of the Public: The Massachusetts Emergency Management Agency and the Towns of Plymouth, Carver, Kingston, Duxbury and Marshfield have the capability for providing an alert signal to their population within fifteen (15) minutes following the decision to notify the public.

PNPS, in cooperation with the Commonwealth of Massachusetts and local agencies, has developed the Prompt Alert and Notification System (PANS). PANS is tt,te primary method of notifying the public. This system consists of one hundred and thirteen (113) large scale electronic sirens and five (5) primary radio stations covering the Plume Exposure Pathway EPZ. The sirens alert the public to tune their radios to pre-designated EAS stations to

  • receive instructional messages.

Pre-scripted messages are broadcast by the EAS network along with any protective actions directed by the Governor of Ma~sachusetts from recommendations made by the Massachusetts Department of Public Health and the Massachusetts Emergency Management Agency. The Massachusetts Emergency Management Agency will select and initiate broadcast of appropriate EAS messages for the EPZ Towns. EAS messages are supplemented by news advisories prepared by the Massachusetts Emergency Management Agency.

The siren system is equipped with public address capability. This capability is utilized for early notification to the beach and resident population of the Saquish/Gurnet area. It may also be utilized by any of the towns at any time.

As a backup means of public notification, route alert teams, using public address systems, drive through areas where a siren failure has been indicated and broadcast an alert message which instructs the public to tune to an EAS station. Maps and instructions have been developed for each siren coverage area.

Severely hearing-impaired residents are called by the Town Emergency Response Organization using Teletypewriter (TTY) equipment.

Schools, major employers with 50 employees or more, transient shelters, health care facilities, and recreation areas are notified by tone alert radios activated by the EAS tone.

The public and commercial boating population receives notification from the Harbor Master and U.S. Coast Guard boats equipped with public address systems. Additional notification is also completed by marine and Citizens Band (CB) radios to those boats that are radio equipped.

Beach and pond visitors are notified by personnel from the Police Department or Public Works Department driving public address system equipped vehicles.

E-3 Revision 46

PNPSEMERGENCYPLAN

7. Messages to the Public: The Commonwealth has developed draft EAS and News Advisory messages that are intended for the public. These draft messages are included as part of the Commonwealth's plan and procedures and contain instructions with regard to specific protective actions to be taken by occupants and visitors of affected areas 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 and instructions, ad hoc respiratory protection (e.g. handkerchief over mouth), etc. The Commonwealth of Massachusetts maintains a stockpile of Kl to be made available to emergency workers, institutionalized persons who cannot be evacuated, and the general public. The MDPH and MEMA provide information about the use of Kl and how and where to obtain it. PNPS also provides supporting information for messages through the MEMA.

E-4 Revision 46

PNPS EMERGENCY PLAN Section F:

Emergency Communications This section describes the emergency communications equipment available to support the Pilgrim Nuclear Power Station (PNPS) Emergency Response Organization. It outlines the available communications equipment to:

Notify the PNPS Emergency Response Organization.

Provide Initial Notification to Offsite governmental agencies.

Communicate among the PNPS Emergency Response Facilities.

Communicate with the Nuclear Regulatory Commission (NRC) and other Federal, Commonwealth, and local response agencies.

Communicate with hospitals, ambulances, and other agencies providing offsite assistance to PNPS.

This section further outlines the program for insuring that the communications equipment is tested on a regular schedule, and that methods are in place to ensure rapid and reliable repair of any equipment found not operational.

1. Communications/Notifications: Pilgrim Nuclear Power Station maintains the capability to make initial notifications to both the PNPS Emergency Response Organization and designated offsite agencies on a 24-hour per day basis. Figure F-1 depicts the Initial Notification paths and the organizational titles from PNPS to local and Commonwealth emergency response organizations. Those links that are manned 24-hours per day are indicated on Figure F-1. Table F-1 depicts the primary and alternate method of communicating between various PNPS facilities, with offsite facilities, and with the Commonwealth of Massachusetts. Table F-1 also depicts the provisions for communications with Commonwealth and site radiological monitoring teams. Table F-2 shows available communications equipment within each of the PNPS emergency response facilities.

PNPS utilizes the EverBridge notification system to rapidly notify members of the PNPS Emergency Response Organization. EverBridge is a computer system (both hardware and software) that notifies the ERO of an eme.rgency via a number of modalities (i.e., telephone, pager, text, email). This system provides a primary notification through the computerized system with alternate activation capability. The decision process used to activate EverBridge is specified in appropriate Emergency Plan Implementing Procedures.

If the EverBridge computerized system should fail, Emergency Preparedness Implementing Procedures specify the course of action to be taken. These procedures require using the alternate EverBridge activation, if available, or initiating individual telephone call-outs of emergency response personnel.

F-1 Revision 46

PNPS EMERGENCY PLAN Dedicated telephone equipment, such as the Emergency Notification System (ENS), is in place in the Control Room (CR), Technical Support Center (TSC), and the Emergency Operations Facility (EOF). This allows direct communications to the NRC and other Federal emergency response organizations. The ENS is the primary notification system used for NRC notification. In addition to the ENS, administratively dedicated telephones serving as the Health Physics Network (HPN) are used in the TSC and EOF for the transmittal of radiological information to the NRC. It is under the National Response Framework (NRF) that PNPS requests assistance from Federal agencies.

Additional arrangements have been made to allow for the establishment of NRC communications equipment at the EOF.

a. PNPS Radio Communications System: A comprehensive communications network with backup capabilities has been provided to assure reliable onsite and offsite communications between various emergency facilities and agencies as follows:

Pilgrim Alert Radio: This radio system, used on a daily basis, provides backup for communications among PNPS facilities. It is a backup notific?tion method from the Station to Massachusetts State Police Middleboro barracks.

PNPS Security Radio: This radio system is used at PNPS exclusively for security purposes; it also serves as a backup communications link between PNPS Emergency Response Facilities.

Nuclear Incident Advisory Team (NIAT) Radio: This radio system is used by the Commonwealth to direct radiological teams from the EOF.

I PNPS Offsite Monitoring Team Radio: This repeater radio frequency is used during emergencies for the exclusive use of the monitoring teams to communicate with the EOF.

BECONS: BECONS is a dedicated VHF high band radio repeater system.

BECONS is used by PNPS as the backup notification method to the DNN. BECONS is also used for the transmittal of administrative information among offsite authorities and as the primary method of notification for back up siren activation.

b. PNPS Telecommunications Systems: In addition to the above radio systems, the following phone systems are in place to support the emergency efforts:

PNPS Telephone System: A private telephone system connecting all PNPS offices.

At PNPS and the EOF, portions of the telephone system are powered by uninterruptible power supply (UPS) and generator backup power.

Local Commercial Telephone System: This system provides standard commercial telephone service through the Verizon infrastructure, consisting of central offices and the wire line and microwave carrier.

Cellular Telephones: A cellular telephone is provided in the Shift Manager's office in the Control Room, TSC, OSC, CAS and SAS as a backup to the local commercial telephone system.

Satellite Telephones: A satellite telephone is provided in the Shift Manager's office in the Control Room and EOF as a backup to the local commercial telephone system.

F-2 Revision 46

PNPS EMERGENCY PLAN

c. Special Communication Links: Separate communications methods exist among the various emergency response facilities in order to insure reliable and timely exchange of information. These methods consist of the following:

Dedicated Notification Network (DNN): The DNN is a dedicated notification network that provides a notification link from PNPS (Control Room, TSC and EOF) to each offsite agency. (CR-PNP-2014-323, CA-02) The DNN is the primary notification method from PNPS to offsite authorities. Figure F-4 depicts the initial notification scheme. BECONS and commercial telephones are the backup for the DNN.

Ring-down - Plymouth Police Department: A dedicated, automatic Ring-down telephone circuit between PNPS and the Plymouth Police Department intended primarily to rapidly secure law enforcement assistance.

Ring-down - Plymouth Fire Department: A dedicated, automatic Ring-down telephone circuit between the Control Room and the Plymouth Fire Department intended to provide rapid fire fighting support.

EOF - Joint Information Center: Designated telephone circuits between the EOF and the Joint Information Center have been provided to ensure a rapid dissemination of information to Media representatives. Telecommunications equipment has been provided for each of the EPZ communities to contact the Joint Information Center.

Mitigation Line: An administratively dedicated telephone that provides conferencing capability among the Control Room, TSC, EOF and alternate EOF for use by Operations and Engineering personnel.

Plant Data Phone (PDP): An administratively dedicated telephone that provides conferencing capability among the Control Room, TSC, EOF and the Alternate EOF.

The PDP is used to transmit Station data for status boards located in each of the emergency facilities.

Rad Data Phone: An administratively dedicated telephone that provides conferencing capability among the Control Room, TSC, EOF and alternate EOF.

The Rad Data Phone is used to transmit radiological information between the facilities.

Emergency Conference Line (ECL): An administratively dedicated telephone that provides conferencing capability among the Control Room, TSC, EOF, AEOF, and the primary conference room at PNPS for use by management and technical personnel located in each of the facilities.

EverBridge: The primary PNPS ERO notification system utilizing various modalities including telephone, pager, email, SMS text messaging as well as an alternate activation capability using commercial telephone.

Health Physics Network (HPN): Federally provided telephone circuits used to provide communications to and from the NRC radiological section.

Emergency Notification System (ENS): Federally provided dedicated telephone circuits between the Control Room, the TSC, and the EOF to NRC facilities. ENS utilizes the Federal Telephone System (FTS) to provide reliable communication capabilities. The ENS is the primary notification method to the NRC. Additional FTS service is available in the TSC and EOF for use by Federal agency responders.

F-3 Revision 46

PNPS EMERGENCY PLAN Facsimile Equipment: Facsimile equipment located in each of the onsite and offsite Station and governmental emergency response facilities for the transmission and receipt via wire line of information, texts, pictures or diagrams in hard copy form.

Onsite Gaitronics Page System: A public address system, separate from any telephone system, which consists of handset stations, loud speakers, and desk set units. The Gaitronics Page System provides five Station channels, one of which is dedicated to operations/emergency use only.

2. Medical Communications: PNPS establishes communications with the primary medical hospital, Beth Israel Deaconess Hospital - Plymouth, and the backup hospital via commercial telephone which is accessed by Station personnel either via commercial onsite telephone or by a PNPS telephone. A direct, dedicated ring-down telephone into the Plymouth Fire Department (the ambulance Dispatcher) provides for a coordinated communications link to the ambulances responding to PNPS or transporting personnel from the Station. Figure F-3 depicts this coordinated communications link.
3. Communications Drills: Communications drills between PNPS and Commonwealth, State and local governments are conducted in accordance with criteria contained in Section N.2.

Also, at least monthly, PNPS personnel conduct a surveillance to determine the working condition and availability of each piece of communications equipment. This surveillance includes a check of the units' operability and general condition. Deficiencies are identified and corrected. PNPS F&E Staff maintain spare units to rapidly replace non-operational equipment.

F-4 Revision 46

PNPS EMERGENCY PLAN Figure F-1:

Initial Notification PNPS EOF PNPS Control Room

  • Shift Manager!

Communicator Communicator State MEMA Communications

/

Officer/

  • Dispatcher MEMA Region II Communicator Town of Marshfield
  • Marshfield PD Dispatcher On Duty
  • Indicates 24-hour operation OR Town of Kingston
  • Kingston PD Dispatcher On Duty City of Taunton
  • Tauton PD Dispatcher On Duty Town of Bridgewater
  • Bridgewater F Dispatcher On Duty Town of Carver
  • Carver PD Dispatcher On Duty Town of Braintree Operations Staff Town of Duxbury
  • Duxbury ECG Dispatcher On Duty PNPS To Each Offsite Agency

/

1. DNN (Dedicated Notification Network)
2. BECONS
3. Commercial Telephone F-5 Revision 46

PNPS EMERGENCY PLAN Table F-1:

Communications Matrix Control Room TSC osc EOF AEOF JIC Corporate Primary Access Pt.

Control Room

~ <;

'i;/'....
  • ** c,
  • 1

.... ***.*:< *. ", '.?.... *

. k**1

1***

~*.

1 1

TSC 2,6,7,9, 10, 15, 16, 19,24,25,28

'"~. **.**

'..... :./; **~

>***r".. n... :....

1 1'>1/

1

  • 1
  • ./

osc 1,2,4,6,7,9,25,28 9,28

.>.. ****<)*.* **>

.~,,,.

1 1

  • ., '1
  • '"'* *i, 1

EOF 1,2,4,5,6, 7,9,10, 15, 16, 19,24,27 1,2,4,5,7,9, 10, 15, 16, 19,24,27 7,9,10

<~'.X.*

. '?""'::**.. <X:

':,*>. :.11111*:.A>. * '..

AEOF 1,5,7, 10, 15, 16, 19,24 4,7,10,15,16,24 7,9,10 1,4,5, 10, 15, 16,20,24..

<* *. iY11\\

>>1>t:/

.'. ":.'\\"'-'.* '"""'*....,

JIC 10,19 10,19 10 10,14,19 -

10 1

11

  • .:.* Ii;-':..

Coro orate 10,19 10,19 10 10,19 10 10

!;/'..' *.:c 1 Primarv Access Point 1,2,6,9, 10 1,2,6,9 2,9,10 1,2,9, 10 1,10 10 10

">\\

EPZTowns 5, 10, 12, 13, 19,27 5,10 10 5, 10, 19,20,27 5,10,19 10,19 10 10,12,13 Reception Center Towns 5,10,19,27, 5,10 10 5, 10, 19,20,27 5, 10, 19 10,19 10 10 MEMA 5, 10,19,27 5,10 10 5, 10, 19,20,26,27 5, 10, 19 10,19 10 10 Rhode Island 10 10 10 10,19 10,19 10,19 10 10 NRC 9,10, 18,19,23 9,10,17,18,23 10,23 10,17,18,19,23 10,19 10,19 10 10 Beth Israel Deaconess Hosp 10 10 10 10 10 10 10 10 OMT 4,28 4,28 4,28 4,26,28 4,28 1

1

............. 11*;"*: 1*

1 28 State Police 1,10,11,19 1,10,19 10 1,10,11,19 1,10 10,19 10 1,10,11 EPZTowns Reception Center Towns MEMA Rhode Island NRC OMT Control Room TSC osc EOF AEOF 5,10,20 5, 10,20 5,10,19,20 10 NRC 10 Beth Israel Deaconess Hos 10,21 OMT

7. Rad Data Phone
13. Rin down-Pl mouth Fire
19. Facsimile E ui men!
25. Alt. Shutdown Comm Radio
8. Reserved
14. EOF-Joint Information Center
20. RACES Radio 2 Meter
26. NIAT Radio
9. PNPS Tele hone S stem
21. Medical Radio
27. DNN
10. Local Tele hone S stem
22. S are
28. Cellular Tele hone
5. BECONS
11. Rin down-State Police
23. Fed Telecom S stem FTS
6. Fire Bri ade Radio
12. Rin down-Pl mouth Police
24. Miti ation Line F-6 Revision 46

Cf) 0 0

<(

~

Cf) w z

0 I

Cl.. w

_J w

f-

~

w I f-0 PNPS EMERGENCY PLAN Table F-2:

Communications Equipment Pilgrim Alert Radio PNPS Security Radio NIAT Radio PNPS Offsite Monitoring Team Radio BE CONS RACES Radio (2 Meter)

RACES Radio 440 Dedicated Notification Network (DNN)

PNPS Telephone System Fixed Cellular Telephone System Local Commercial Telephone System Ringdown Plymouth Police Department Ringdown Plymouth Fire Department Ringdown State Police Satellite Telephone Plymouth Fire Radio Plymouth Police Radio Mitigation Line Plant Data Phone (PDP)

Rad Data Phone Emergency Conference Line (ECL)

Emergency Notification System (ENS)

Health Physics Network (HPN)

Onsite Gaitronics Page System Facsimile Equipment 0:::

...I 0

0:::

1-z 0

(.)

[R]

[R]

[R]

[R]

[R]

[R]

[R]

[R]

[R]

[R]

[R]

[R]

[R]

[R]

[R]

[R]

[R]

[RI

[RI F-7

(.)

ti) 0 0 ti)

I-

[R]

[R]

[R]

[R]

[R]

[R]

[R]

[R]

[R]

[R]

[8]

[8]

[8]

[RI

[8]

L1.

0 w

[R]

[8]

[R]

[R]

[8]

[R]

[R]

[R]

[R]

[R]

[R]

[R]

[8]

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PNPS EMERGENCY PLAN FIGURE F-2: DELETED NOTE The decision process to activate EverBridge is specified in appropriate Emergency Plan Implementing Procedures

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F-8 Revision 46

PNPS EMERGENCY PLAN Figure F-3:

PNPS - Medical Communications PNPS Control Room Direct Ring down Telephone Town of Plymouth Fire Department Fire Department Ambulance Dispatch Frequency Ambulance Service CMED Frequency Plymouth County CMED Commercial Telephone Beth Israel Deaconess Hospital -

Plymouth (Primary)

Plymouth C-MED Ambulance/Hospital Frequency Mutual Aid Frequency F-9

  • Backup Hospitals Revision 46

PNPS EMERGENCY PLAN Figure F-4: Initial Notification Scheme PNPS Initial Notification via Dedicated Notification Network Control Room/TSC EOF MEMA Headquarters, EPZ/Host Towns F-10 Revision 46

PNPS EMERGENCY PLAN Section G:

Public Education and Information This section describes the Pilgrim Nuclear Power Station (PNPS) 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 emergency public information publication for PNPS is an annual calendar which is developed in coordination with the Massachusetts Emergency Management Agency, the Massachusetts Department of Public Health (MDPH), and local communities. It is distributed by mail to all residents and businesses within the Plume Exposure Pathway Emergency Planning Zone (EPZ). The contents of the calendar include the following:
a. Educational information on radiation;
b. Commonwealth and EPZ community contacts for additional information;
c.

Definitions of protective measures as well as written descriptions of evacuation routes, locations of reception centers, steps to follow when sheltering or evacuating;

d. Special needs of the handicapped, and
e. Relocation points for school children.
2. Public Education Materials: In addition to the emergency public information calendar, placards are posted throughout the EPZ communities. The placards provide information to visitors about what to do when the *sirens sound, evacuation routes and where to obtain additional emergency information. Emergency information and instructions are also provided in local telephone directories.
3. Joint Information Center
a. The Joint Information Center, located at-the Entergy Industrial Park Training Center in Plymouth, provides a location for the news media to receive information from all involved agencies and companies during an emergency and provide it to the general public.

Work areas are set up for the news media and telephones are installed for their use. If, due to radiological or other conditions, the Joint Information Center is found to be uninhabitable, it will be relocated to the Alternate Joint Information Center at Bridgewater State University in Bridgewater. Comparable facilities for both the Joint Information Center staff and media representatives are available at the alternate facility.

I

b. During an emergency, the Emergency Director may approve access to the Emergency Operations Facility for a limited number of news media. *
4. Coordination of Public Information
a. The PNPS Company Spokesperson is the primary spokesperson for PNPS during an emergency. The Company Spokesperson has direct access to all necessary information (see Section B.5).

G-1 Revision 46

PNPS EMERGENCY PLAN

b. The Joint Information Center is staffed by Federal and Commonwealth emergency management agencies and PNPS to assure timely exchange and coordination of information. Representatives coordinate information prior to distributing news releases and prior to news briefings.
c. Rumors or misinformation are identified during an emergency by the Information Coordinator and Inquiry Response Coordinator located at the Joint Information Center.

They respond to media calls and broadcasts and reports of misinformation or rumors are forwarded to the Inquiry Response Coordinator and Information Coordinator, and then forwarded to the JIC Manager and/or Company Spokesperson for an appropriate response by Joint Information Center staff. Rumor control is also provided for by the Commonwealth of Massachusetts Emergency Management Agency.

5. Media Orientation: The annual PNPS Media Orientation is coordinated with offsite agencies to acquaint the news media with emergency plans, basics of nuclear power operation and radiation fundamentals. The news media typically are provided a tour of the Joint Information Center or other emergency response facilities. Reporters receive information about Joint Information Center activation and accessibility during a declared emergency at PNPS.

G-2 Revision 46

PNPS EMERGENCY PLAN Section H:

Emergency Facilities and Equipment This section describes the emergency facilities and equipment used by the Pilgrim Nuclear Power Station (PNPS) Emergency Response Organization. It outlines the facilities and equipment requirements which aid in the timely and accurate response by the PNPS Emergency Response Organization. It also describes the surveillance programs used to monitor and insure that 'these facilities and equipment are maintained in a high degree of constant readiness.

1. Technical Support Center (TSC). Operations Support Center (OSC). and the Control Room:

PNPS has established an onsite Technical Support Center (TSC) and Operations Support Center (OSC). The TSC and OSC are activated upon declaration of an Alert or above or at the discretion of the Emergency Director (ED) or Shift, Manager. Until they become operational, required functions of these facilities are performed in the Control Room.

The Control Room is located on the 37' elevation of the Turbine Building. The Control Room is the focal point for all plant operational activities. The Control Room contains the instrumentation, control devices and displays necessary for operation of the reactor and turbine generator under normal and emergency situations.

The Control Room is staffed by Licensed Nuclear Plant Operators and Senior Licensed Nuclear Plant Operators. All plant-related operations are directed from the Control Room and supervised by the Shift Manager. During emergency operating conditions, only those personnel who are required for the safe operation of the plant are allowed access to the Control Room.

The TSC and OSC along with the Emergency Operations Facility (EOF) are the primary emergency response facilities in support of the Control Room. The primary emergency response facilities have been designed and built to withstand the most adverse conditions reasonably expected during the design life of the plant including adequate capabilities for earthquakes, high winds and floods. Each facility is equipped with fire alarm and suppression systems, and back-up diesel generated electrical power.

The TSC is located within the Protected Area on the ground floor of the Operations and Maintenance Building. The TSC provides facilities near the Control Room for technical, engineering and management support of operations personnel during emergency conditions. It also permits direct interface of management personnel with the plant operators, if necessary.

The TSC has a large working area with space sufficient to accommodate the pre-designated TSC staff. The TSC is also able to accommodate seven (7) NRC representatives. Working areas are available and a desk has been provided for NRC use.

The TSC is the primary communications link between the Control Room and the EOF. It also acts as an onsite communications center for the plant during an emergency.

Additional engineering support may be activated from the Nuclear Engineering Staff.

Specific personnel assignments are determined at the time of the emergency by the TSC Manager and the Operations Coordinator based on the type of incident occurring at the Station.

I H-1 Revision 46

PNPSEMERGENCYPLAN The OSC is located on the ground floor of the Operations and Maintenance Building next to the TSC. The OSC is an onsite assembly area separated from the Control Room and the TSC where pre-designated support personnel report in an emergency. All personnel dispatched into the Plant in an emergency are coordinated through the OSC after its activation. Response teams dispatched from the OSC may include search and rescue, repair and corrective actions, damage assessment/control, onsite/in-plant survey, first aid, and fire fighting to support accident mitigation activities.

The Chiltonville Training Center is an alternative facility, with communication capabilities for contacting the Control Room, plant security and the EOF, which serves as a staging area for augmented emergency response staff if the site is under threat of or experiencing hostile actions.

In the event the TSC/OSC evacuation becomes necessary, the emergency response procedures identify an alternate location for the TSC/OSC.

2. Emergency Operations Facility (EOF): PNPS has established an Emergency Operations Facility (EOF) located at 44 Obery Street across from the Plymouth North High School in Plymouth, Massachusetts approximately four (4) miles west of PNPS. The building is shielded and equipped with a filtered ventilation system and backup electrical supply system. The EOF is the central facility for the evaluation and coordination of all licensee activities in response to an emergency. Here information is provided to representatives of Federal, Commonwealth, and local authorities who respond to an emergency at PNPS.

The EOF is a PNPS controlled and operated facility. The EOF is equipped with an intrusion detection system. Security personnel may be requested to augment access control of the EOF.

During an emergency, the EOF is staffed and equipped to provide for the overall management of the Station's emergency response; coordination of radiological and environmental assessment; coordination of corporate support; development of protective action recommendations for the general public; coordination of emergency response activities with Federal, Commonwealth and local agencies; and capability to perform offsite notifications.

The EOF consists of an Operations Room, a Communications Room, conference rooms and several office areas. In addition to the pre-designated PNPS emergency response organization staff, the EOF has space to accommodate twelve (12) NRG representatives as well as representatives from FEMA, MDPH, and MEMA and key local authorities. If necessary, the EOF may be used to accommodate outside technical support groups.

In the event an EOF evacuation becomes necessary, operations can be transferred to the Alternate Emergency Operations Facility (AEOF). The AEOF is located in the Town Hall, Carver, MA. and is approximately 10.5 miles west of PNPS. The AEOF has accommodation for up to 40 people. It is equipped with site maps, office furniture, supplies and back-up communication systems..

3. Alternative Facility: The Alternative Facility utilized during a Hostile Action event is located at the Chiltonville Training Center. The facility serves as a staging area for TSC and OSC personnel and is equipped with offsite and onsite communicati.on and engineering assessment a~tivities including damage control team planning and preparation.

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PNPS EMERGENCY PLAN

4. Emergency Operations Centers (EOCs) and Incident Command Post (ICP): Emergency Operations Centers in each of the communities supporting a response to an incident at PNPS have been established to perform direction and control of response functions. PNPS provides support for the local communities in the design and maintenance of their facilities.

The Town of Plymouth EOG is located in Plymouth, Massachusetts. The EOG serves as command and control headquarters for local emergency response activities as well as a center for the coordination of communications to local field units and to the Commonwealth and MEMA Region II EOCs. The EOG has the equipment necessary, (such as facsimile machines, telecommunications equipment, radio gear, photocopiers, wall maps, etc.) to carry out its emergency responsibilities. The other plume exposure EPZ communities of Kingston, Duxbury, Carver, and Marshfield, all in Massachusetts, are similarly equipped. In addition, the Reception Center communities are equipped with similar facilities and equipment.

The Commonwealth EOG is located at MEMA headquarters in Framingham, Massachusetts and serves as the command and control center for offsite emergency response. 1The Commonwealth EOG is capable of continuous (24-hour) operations for a protracted period.

The center contains sufficient communications (radio, telephone and teletype) equipment, maps, emergency plans, and status boards to provide the necessary interfaces with other Commonwealth, local, Federal and PNPS emergency facilities.

The Joint Information Center is located at the Entergy Industrial Park Training Center in Plymouth, approximately 6.5 miles North West of PNPS. The Joint Information Center is staffed by PNPS and government public information representatives who will be the source of public information during an emergency at PNPS. The Joint Information Center is normally activated upon declaration of an Alert or above. If, due to radiological or other conditions, the Joint Information Center is found to be uninhabitable, it will be relocated to the Alternate Joint Information qenter at Bridgewater State University in Bridgewater.

The MEMA Region II EOG is located at MEMA Region II Headquarters in Bridgewater, Massachusetts. The EOG is located near the plume exposure EPZ and serves as the local liaison with the Commonwealth EOG to coordinate emergency operations among local communities.

The State EOG/Office of Public Safety (OPS) is the primary Commonwealth notification point. Continuous communication coverage is provided by dispatcher on a 24-hour basis.

The Incident Command Post (ICP) is an offsite physical location that administers the on-scene incident command and the other major incident management functions and works under Incident Command System (ICS) strategies. ICS has been summarized as a "first-on-scene" structure, where the first responder of a scene has charge of the scene until the incident has been declared resolved, a superior-ranking responder arrives on scene and seizes command, or the Incident Commander appoints another individual Incident Commander. ICS consists of a-'standard management hierarchy and procedures for managing temporary incident(s) of any size. Incidents at Pilgrim Station will have an ICP location as determined by the responding offsite Incident Commander.

H-3 Revision 46

PNPS EMERGENCY PLAN

5. Activation: PNPS has put into place plans and procedures to insure the timely activation of its emergency response facilities. Although the response time will vary due to factors such as weather and traffic conditions, a goal of thirty (30) minutes for some minimum staffing and one (1) hour for full manning has been established for onsite emergency facilities and the EOF. Plans have been developed to insure timely functional activation and staffing of the Joint Information Center.,

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6. Monitoring Equipment for Classification: PNPS has identified and installed onsite monitoring systems that are utilized to assess the incident and make determinations on the proper emergency measures to be implemented. This equipment includes but is not limited to the following:
a. PNPS has two meteorological towers equipped with instrumentation for continuous reading of wind speed, wind direction, air temperature, and difference in air temperature (160' to 33' and 220' to 33'). PNPS has the indirect capability of locally monitoring hydrological data by use of instrumentation installed on process water systems. Seismic monitors are located throughout the plant; data from these monitors is recorded in the Control Room.
b. Installed radiological monitors indicate the status of the plant and any radiological release that may have occurred. The Control Room is equipped with plant radiation monitoring instrumentation for use in both normal and emergency conditions. The Containment High Radiation Monitoring System is designed fo measure post-accident radiation levels in the drywall and the torus during accident conditions. The range of these monitors is 1 to 1.0E+7 R/hr. The Main Stack, the Reactor Building Exhaust Ventilation and the Turbine Building are equipped with high range radiation monitoring systems design~d to measure elevated radiation levels.

The Containment High Radiation Monitoring System will be used to monitor the integrity of the reactor fuel and to assess core damage conditions during the emergency phase of an accident. Contingency chemistry sampling procedures are available as a supplemental means to confirm the integrity of the reactor fuel or core damage in support of post-accident and long-term recovery operations. The contingency chemistry procedures provide the appropriate instructions to obtain and analyze highly radioactive samples from the reactor coolant system and containment (i.e., drywall and torus).

c. 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.

d. The PNPS has installed fire and combustion detection equipment at PNPS in compliance with 1 OCFR50 Appendix R.

Section I provides more details on the accident assessment efforts that can be used to assess the incident and make determinations on the proper emergency measures to be implemented.

H-4 Revision 46

PNPS EMERGENCY PLAN

7. Offsite Monitoring Equipment: PNPS has made provisions to perform offsite monitoring during emergency situations.
a. Offsite sources of information pertaining to geophysical phenomena include the National Weather Service located at Taunton, MA for meteorological data, and local marine forecast data and Coast Guard facilities provide hydrological data, and Weston Observatory provides seismic activity.
b. PNPS has established radiological and environmental radiation sampling and monitoring stations at PNPS and nearby areas as part of the Radiological Environmental Monitoring Program. These Stations are used for continuous long-term radiological background assessment of the environs surrounding PNPS. These Stations monitor a variety of media and pathways including gaseous and particulate sampling equipment and environmental Thermoluminescent Dosimeters (TLDs) (WT-WTPNP-2013-263, CA-05),

which may be used in an emergency for accident assessment. The locations and specific capabilities of these Stations are contained in the PNPS Offsite Dose Calculation Manual.

c.

In addition to the analytical capabilities of the EOF, PNPS has access to outside analytical assistance and laboratory facilities from other non-affected Entergy nuclear sites, Commonwealth and Federal agencies and other utilities through INPO. This support may include but is not limited to the following:

Massachusetts Department of Public Health (MDPH) through the implementation of the Nuclear Incident Advisory Team (NIAT) Handbook has laboratory analysis capability at the Commonwealth/State Contracted laboratories and those laboratories listed in the New England Interstate Radiation Assistance Plan.

The U.S. Department of Energy (DOE) through the implementation of the Federal Radiological Emergency Response Plan (FRERP) or Radiological Assistance Program (RAP) will provide necessary radiological monitoring assistance. The DOE Region Coordinating Office for PNPS is the Brookhaven Area Office located in Upton, New York.

Other environmental monitoring and analysis support can be requested and arranged through INPO. The INPO Emergency Resources Manual includes the information necessary to locate and request specialized equipment and technical assistance in the area of offsite radiological monitoring. INPO member utilities and suppliers agree to provide assistance as outlined in the INPO Emergency Resources Manual.

The above facilities have the capability to perform laboratory analyses of various environmental samples (e.g., terrestrial, marine and air). It is also estimated that the analytical assistance and laboratory support will be able to respond within eight (8) hours from initial notification.

H-5 Revision 46

PNPS EMERGENCY PLAN

8. Offsite Monitoring Equipment Storage: The EOF has been designated as the central point for storing offsite radiological monitoring equipment. Additional equipment is available at, PNPS and other facilities (i.e., Warehouse, Commonwealth and local facilities), if needed.

The EOF contains portable survey, counting, and air sampling instrumentation and other radiological monitoring equipment and supplies to be used by PNPS and Nuclear Incident Advisory Team (NIAT) offsite monitoring teams. Table H-1 illustrates examples of the types of equipment available for offsite monitoring.

Monitoring team equipment is capable of detecting and measuring radioiodine concentrations in air as low as 1.0E-7 µCi/cc under field conditions. Interference from the presence of noble gas and background radiation will be minimized by ensuring that monitoring teams move to areas of low background prior to analyzing the sample cartridge.

9. Meteorological Monitoring: PNPS has installed two meteorological towers equipped with instrumentation for continuous reading of the wind speed, wind direction, air temperature and delta air temperature at 33 foot and either the 160 or 220 foot elevations. The 220 and 160 foot meteorological towers record information and report this data locally at the meteorological tower, to the Emergency Plant Information Computer (220 foot) and to the station's business Local Area Network (160 foot). The 220 foot also reports information to the. Control Room.

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PNPS has the capability for making remote interrogation of the atmospheric measurements and predictions. Additional capabilities are available to obtain representative current meteorological information from other sources, such as the National Weather Service.

1 O. Protective and Damage Control Equipment: The TSC, OSC, and EOF are equipped with ventilation systems similar to the Control Room ventilation system. The ventilation systems use both High Efficiency Particulate and charcoal filters.

Radiological monitoring is performed in each emergency response facility. Radiation dose rates and airborne radioactivity concentrations are measured inside each facility while it is in use during an emergency. This monitoring will detect adverse conditions that may affect the habitability of the facility. Equipment is available which can distinguish the presence of radioiodine at concentrations as low as 1.0E-07 µCi/cc.

Radiation protection equipment (i.e., protective clothing, respiratory protection gear and other health physics equipment and supplies) is stored and maintained at each emergency response facility. Table H.2 illustrates the equipment typically available to each facility.

This equipment is for re-entry team activities. If necessary, this equipment will be used for emergency response personnel within the facility to allow them to function during the presence of low-level airborne radioactivity or radioactive surface contamination. Sufficient potassium iodide is available for use by Control Room, TSC, OSC, JIG and EOF personnel, and is also stored at the Chiltonville staging area.

1 One-hour self-contained breathing apparatus (SCBA) packs and bottles have been placed at strategic points within the Station. A cascade air compressor is maintained onsite. A back-up compressor is located at Plymouth Fire Department ~eadquarters approximately 2.5 miles from the site. Arrangements exist to permit PNPS 24-hour access to this back-up compressor if the station compressor is inoperable, or if the air in station environs is contaminated.

H-6 Revision 46

PNPS EMERGENCY PLAN The Medical Building, located near the main parking lot, is supplied with an assortment of first aid and medical treatment equipment and supplies that are used on a daily basis.

Emergency medical treatment equipment and supplies are also stored in the Engineering Support Building and TSC Communications Cabinet (CR-PNP-2014-323,CA-02). In addition to normal Station decontamination equipment, the EOF is equipped with personnel decontamination supplies and a decontamination shower for use in an emergency. The EOF is also equipped with a holding tank to secure contaminated materials. Table H-3 and H-4 illustrate the supplies found in the medical and decontamination kits.

Damage Control Equipment is available in the OSC and additionally in maintenance shops or PNPS warehouses locat~d inside the Protected Area. This equipment includes items such as portable lighting and portable communications equipment. See Table F-1 for the matrix of communications capability. For a complete description of communications equipment available during an emergency, refer to Section F of-this Emergency Plan.

11. Facility and Equipment Readiness: Emergency facilities and equipment are inspected and inventoried in accordance with departmental administrative procedures. The inspection includes 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/equipment are maintained to replace those which are removed from emergency kits or lockers for calibration or repair. Dedicated communications equipment between Federal, Commonwealth _and local government agencies within the plume exposure pathway EPZ are checked periodically in accordance with Section N.2.

The results of tests, inventories, and inspections conducted in accordance with PNPS Procedures, are submitted to the Emergency Planning Manager for review. The Emergency Planning Manager is responsible for the evaluation of these results and assignment of corrective actions for deficienc.!es identified, if any.

The Emergency Planning Manager will be informed of select system inoperability determinations resulting from any tests, inventories or inspections conducted on the systems identified in Table H-5, as the availability of these systems can have significant impact on the Emergency Plan. When notified of Table H-5 system inoperability, the Emergency Planning Manager will inform the Regulatory and Performance Improvement

  • Director within one business day of the inoperable condition, as well as of compensatory measures taken, if any.
12. General Use Emergency Equipment: Tables H-1, H-2, H-3, and H-4 identify by general category the equipment that typically make up emergency kits used in an emergency situation. Table F-1 shows available communications equipment. PNPS cooperates with local and Commonwealth officials to insure that sufficient and appropriate emergency kits are made available.
13. Collection Point for Field Samples: The EOF 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 EOF for initial sampling. Monthly su,rveillance and maintenance is performed to insure the readiness of field monitoring equipment.

Instrumentation and equipment utilized for activity determination are routinely calibrated to insure timely availability.

H-7 Revision 46

PNPS EMERGENCY PLAN Table H-1:

Typical Offsite Monitoring Equipment PRM-4A Coveralls HP 240 Hand Probe Hoods TLDs Rubber Gloves Pocket Dosimeters 0-500 mR Cotton Gloves Pocket Dosimeters 0-1 R Paper Pads Dosimeter Chargers Pens Smears Bullhorn Filter Paper Scissors Silver Zeolite Cartridges Screwdriver Air Sampler Pliers Sample Timer Flashlight Sample Labels Allen Wrench Set Plastic Bags Health Physics Procedures Batteries 9 V Area Maps Batteries 1.5 V Cs-137 Check Source Contaminated Materials Stickers Portable Radio Masking Tape Clipboard Petri Dishes SAM-2 Counting System Portable Generator Pocket Knife H-8 Revision 46

PNPS EMERGENCY PLAN Table H-2:

Typical Radiation Protection Equipment R02A or Equivalent Coveralls 120 V Air Sampler Hoods RAS Air Sampler Rubber Boots E-520 or Equivalent Rubber Gloves TL Os Cotton Gloves Pocket Dosimeters 0-1 R Plastic Slip-Ons Pocket Dosimeters 0-5R Pens Dosimeter Chargers Paper Pads Smears & Folders Clipboards Air Sample Filter paper Masking Tape Sample Timer Radiation Warning Tape Sample Labels Radiation Warning Signs Plastic Bags Area Maps Batteries 9 V Cs-137 Check Source Batteries 1.5 V Health Physics Procedure H-9 Revision 46

PNPS EMERGENCY PLAN Table H-3:

Typical Medical Equipment Penlight Gauze Pads, 4x4, Sterile Gauze Pads, 3x3, Sterile Gauze Pads, 2x2, Sterile Alcohol Prep Swabs ABO Pads Airway Cotton Tip Swabs Arm Splints Leg Splints Tincture of Green Soap Specimen Jars Sanitary Pads Thermometer Surgical Brush Scalpels (size 15, 11 and 10)

Scalpel Handle Normal Saline Solution

  1. 11 Blades Bandage Scissors Adult Airway Stethoscope 3" Ace Bandage 4" Ace Bandage Large Straight Scissors Ophthalmoscope Kit w/batteries H-10 Revision 46

PNPS EMERGENCY PLAN Table H-4:

Typical Decontamination Equipment Plastic Tub Caps Masks Gauze Pads,Ax4, Sterile Non-allergic Tape Disposable Paper Lab Coats Plastic Slip-Ons Rubber Gloves Cotton Gloves Decontamination Soap Radiological Health Handbook Potassium Permanganate Solution Bottle for Liquid Radioactive Waste Masking Tape Paper Pad Pens & Pencils Clipboard Scissors Plastic Bags Plastic Wrap Surgeon Brushes Normal Saline Solution Towels Titanium Dioxide Paste H-11 Revision 46

PNPS EMERGENCY PLAN Table H-5 Pilgrim Station Systems requiring Emergency Preparedness Notification Technical Support Center Diesel Generator Technical Support Center HVAC System Pilgrim Station Gaitronics System Pilgrim Plant Process Computer (EPIC/SPDS)

Technical Support Center Electrical System (including UPS)

H-12 Revision 46

PNPS EMERGENCY PLAN Section I:

Accident Assessment To effectively coordinate and direct all facets of the response to an emergency situation at Pilgrim Nuclear Power Station (PNPS), 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 utilized in the determination of accident severity and subsequent emergency classification. Environmental and meteorological events are also determining factors in emergency classification.

An emergency condition can be the result of just one parameter or condition change, or the combination of several. The specific symptoms, parameter values or events for each level of emergency classification are detailed in the PNPS Emergency Plan Implementing Procedures.

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. The detailed instrumentation and equipment capabilities available for each emergency facility are described in Section H of the PNPS Emergency Plan.

2. Onsite Accident Assessment Capabilities Contingency Chemistry Procedures - The Commission has approved and issued License Amendment 204 to PNPS that eliminates the requirement to have and maintain the Post Accident Sampling System (PASS) to support emergency response decisions during the initial phase of an accident (USNRC Letter Number 1.03.128, dated November 14, 2003). However, there is a significant benefit to having information from radioisotope sampling as a supplemental means to address decisions in support of long-term recovery operations under a severe accident condition. Therefore, contingency chemistry procedures are available to obtain and analyze highly radioactive samples from the reactor coolant system and containment (i.e.; drywell and torus) when deemed appropriate or necessary to support decisions during long-term recovery operations. The sample results will be used to confirm the integrity of the reactor fuel or core damage conditions with other plant indicators such as Area Radiation and Process Radiation Monitors.

Area Radiation & Process Radiation Monitors - PNPS has Area Radiation Monitors (ARM) for the direct measurement of in-plant exposure rates and Process Radiation Monitors (PRM) for the measurement of noble gas and radioactive iodine concentrations in plant effluents. The ARM readings allow in-plant exposure rate determinations to be made remotely without requiring local hand-held meter surveys.

This inforrnation may' be used, initially, to aid in the determination of plant area accessibility. The Process Radiation Monitors provide an immediate indication of a radiological release of effluents. The PRM readings can be used as an input into the Unified RASCAL Interface (URI) computer program which displays the projected whole body and thyroid exposures to the populace in the plume exposure pathway.

1-1 Revision 46

PNPS EMERGENCY PLAN Containment High Radiation Monitoring System - A primary method to estimate core damage is based on radiation monitor readings from the Containment High-Radiation Monitoring System (CHRMS), which monitors the radiation levels inside the primary containment (Drywell and Torus areas). This is accomplished by comparing the radiation monitoring readings inside the primary containment with established Drywell and Torus CHRMS curves. The curves provide an estimate of the amount of core damage by plotting the detector dose rate response versus time after shutdown corresponding to various assumed source term scenarios. The assumed source term scenarios include full core melt, gap activity and spiked primary coolant releases.

3. Release Source Term Determination
a. The potential for release of radioactive material and the magnitude of the release can be assessed through use of the Containment High Radiation Monitoring System (CHRMS) and Process Radiation Monitors. The Containment High Radiation Monitoring System readings can be used to estimate the percentage of core damage and establish the total number of curies available for release.
b. If a liquid or gaseous release occurs, the routine or high range process monitors will indicate the release rate in counts per second or Roentgens per hour. If the release is from an unmonitored point, technicians will take grab samples to be analyzed.

Routine and high range monitors are located on the Main Stack and the Reactor Building. A high range monitor is located in the Turbine Building. The readings obtained from these monitors are converted to actual release rates through the use of the Unified RASCAL Interface (URI) computer program.

4. Effluent Monitor Data and URI: The correlation between effluent monitor data and onsite and offsite exposure rates is accomplished through use of the Unified RASCAL Interface (URI) computer program. URI is a computer program which allows for the direct input of effluent monitor and meteorological data. The computer will generate release rates, projected dose rates and doses to the whole body and thyroid as well as downwind halogen and particulate concentrations via the 10-mile Plume and 50-mile Ingestion exposure pathways.
5. Meteorological Information: Meteorological data are available from two meteorological towers, a 220 foot primary and a 160 foot back-up. The data available includes wind speed, wind direction, temperature, and delta temperature. These data are utilized by the site, Commonwealth and NRC to provide near real-time predictions of the atmospheric effluent transport and diffusion.

Meteorological data from the 220 foot tower is available to the Control Room, the Technical Support Center SPDS, and Emergency Operations Facility SPDS. Meteorological data is available from the 160 foot tower via the station's business Local Area Network. Data from both towers is also available via local readout. The National Weather Service, or other official commercial or governmental meteorological gathering services, are possible alternate sources for obtaining meteorological data.

1 Revision 46 IJ

PNPS EMERGENCY PLAN

6. Unmonitored Release: If during an actual release, via an unmonitored flow path or in situations in which effluent monitors are either off-scale or inoperative, dose projections can be made through use of actual sample data.
7. Field Monitoring: In the event of an airborne or liquid release, PNPS maintains the resources and capabilities to take air, soil, water, and vegetation samples as well as to directly measure gamma dose rates. Samples are taken at locations specified by the Radiological Assessment Coordinator. Environmental measurements are utilized as an aid in the determination of protective and recovery actions for the general public.
8. Offsite Monitoring Teams (OMTs): Offsite Monitoring Teams are available at an Alert or higher classification to make rapid assessments of the actual or potential magnitude and location of any radiological hazards from the liquid or gaseous release pathways. OMTs are composed of two individuals, at least one of whom is a qualified Radiation Protection technician.

OMTs establish and maintain direct radio communications with the Emergency Operations Facility (EOF). The teams are controlled by the Offsite Monitoring Team Coordinator in the EOF. The OMTs locate and monitor the radioactive plume while taking air samples as directed.

Survey data from OMTs are used_ to define affected areas, verify or modify dose projections and protective action recommendations, and assess the extent and significance of a release.

9. Iodine Monitoring: OMTs collect air samples while in the plume exposure pathway. The teams carry procedures and equipment for sampling and measuring radioiodine concentrations in air as low as 1.0E-7 µcuries per cubic centimeter in the presence of noble gases.
10. Dose Estimates: Specific procedures exist for the correlation of air activity levels to dose rate for key isotopes. Provisions have been established for estimating integrated dose from the projected and actual dose rates and for the comparison of these estimates with the protective action guides.
11. Commonwealth Monitoring Capabilities: The Commonwealth of Massachusetts has the

, ability to dispatch its own field monitoring teams to track the airborne radioactive plume.

The Commonwealth also has the ability and resources to interpret radiological data in coordination with federal and site monitoring teams to compare sample results.

1-3 Revision 46

PNPS EMERGENCY PLAN 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 to protect onsite personnel during hostile action is provided to ensure the continued ability to safely shut down the reactor and perform the functions of the emergency plan. A combination of restricted movement, movement to safe locations and site evacuation may be used depending on the nature of the event and available advance warning. A range of protective actions has been developed for emergency workers and the general public in the plume exposure pathway Emergency Planning Zone (EPZ). Additionally, guidelines have been established to aid in choosing protective actions during an emergency that are consistent with federal guidance. PNPS is responsible for onsite actions, while the responsibility for offsite actions rests with the Commonwealth of Massachusetts, local authorities and other offsite response agencies.

1. Notification of Onsite Personnel: For all emergency classifications, all personnel within the Protected Area are notified of the declaration, escalation or termination of an emergency by alarms and verbal announcements over the Station Public Address System (Gaitronics).

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

Upon declaration of an Alert or higher classification, if open, public access areas are closed and persons advised, by dispatching a security officer(s) to evacuate those areas.

2. Evacuation Locations: If Protected Area evacuation is required, personnel are directed to evacuate to an assembly area. The Engineering and Support Building cafeteria is designated as the primary assembly area. Should conditions warrant, personnel may be directed to evacuate via personal automobiles to the alternate assembly area, the Chiltonville Training Center. The assembly area is chosen on the basis of wind direction.

Visitors to the station assemble with their escorts.

3. Radiological Monitoring: In the event of Protected Area evacuation, radiation protection personnel are dispatched to the designated assembly area to provide radiological monitoring and, if necessary, decontamination of evacuees.
4. Evacuation: Evacuation is the primary protective action anticipated for onsite personnel not having emergency response assignments. Contractors who do not have emergency responsibilities, visitors, and handicapped personnel are evacuated immediately at the Alert or higher classification.

Evacuation of non-essential PNPS personnel is initiated upon declaration of either a Site Area Emergency or General Emergency. The shorefront recreation area is closed at the declaration of an Alert or higher classification, and visitors asked to leave.

J-1 Revision 46

PNPS EMERGENCY PLAN

5. Accountability: At the declaration of Site Area Emergency or General Emergency, all non-essential personnel are evacuated. All individuals onsite are accounted for and the names of missing individuals are ascertained within 30 minutes of the initiation of accountability.

Once established, accountability within the Protected Area is maintained throughout the course of the event. Should missing personnel be identified, search and rescue operations are initiated. Accountability is coordinated by the TSC Security Coordinator and the results forwarded to the Emergency Plant Manager. For Hostile Action events, accountability may be delayed in lieu of other onsite protective actions required to ensure safety of the site and its personnel. In these cases, accountability will be completed once safe conditions have been established.

6. Provisions for Onsite Personnel: PNPS maintains an inventory of respiratory protection equipment, anti-contamination clothing, and radio protective drugs which are made available to emergency workers remaining onsite should conditions warrant.
a. Self-contained breathing apparatus (SCBAs) are used as the primary method of respiratory protection in an emergency. Emergency response personnel use SCBAs 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 radiation protection personnel to use full-face filter type respirators.
b. Anti-contamination clothing, located in the Operations Support Center (OSC) lockers and dress out area, is available for use by onsite re-entry personnel.
c.

Procedures are in place for the use of thyroid-blocking agents by emergency response personnel. Administration of such agents may be authorized only by the Emergency Director for offsite PNPS emergency workers or by the Emergency Plant Manager for onsite PNPS emergency workers.

J-2 Revision 46

PNPS EMERGENCY PLAN

7. Protective Action Recommendations for the General Public: Plant conditions, projected doses, and/or field monitoring data are evaluated to develop protective action recommendations for the purpose of preventing or minimizing exposure to the general public. Protective action recommendations for the plume exposure pathway are based on the Environmental Protection Agency (EPA) Protective Action Guides (PAGs) discussed in EPA-400-R-92-001 - "Manual of Protective Action Guides and Protective Actions for Nuclear Incidents" and the NRC/FEMA guidance in Supplement 3 to NUREG-0654/FEMA-REP "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Guidance for Protective Action Strategies."

Protective action recommendations are made directly to the Commonwealth agencies that are responsible for implementing protective actions for the general public within the plume exposure EPZ. Protective action recommendations are made by the Emergency Director to MEMA, through the MDPH EOF Liaison. In an emergency which requires immediate protective actions be taken prior to activation of emergency facilities, notification is given by-:

the Emergency Director in the Control Room directly to the Commonwealth, EPZ, and,

reception communities via the DNN.

The possible Protective Action Recommendations (PARs) issued by PNPS in accordance with EP-IP-400, "Protective Action Recommendations", at a General Emergency ir,iclude:

For a Rapidly Progressing Severe Accident (RPSA), a General Emergency distinguished by a rapid loss of containment integrity and loss of ability to cool the core, a plant-based PAR to evacuate the 2-mile ring and 5 miles downwind of the affected EPZ subareas along with sheltering of all other EPZ subareas will be recommended.

The 5-10 downwind area will be re-evaluated for evacuation by the EOF, or At a minimum, based on plant conditions, (for a non-RPSA), evacuation of the 2 mile ring and 5 miles downwind of the affected EPZ sub-areas along with sheltering of all other EPZ sub-areas will be recommended unless sheltering as an alternative to evacuation is recommended; or In event of a short duratio"n emergency radioactive release (i.e., <1 hour for the entire event), or a General Emergency is declared because of Hostile Action, then sheltering instead of evacuation for the affected, land-based EPZ sub-areas will be recommended.

In addition to the plant-condition PARs, off-site dose projections will be used to determine whether plant-condition PARs are adequate. This will include evaluating the off-site dose projection results in accordance with the threshold for dose-based evacuation PARs. Table J-1 summarizes the PNPS PARs for the general public based on projected dose to the population-at-risk.

In all of the above cases, a reminder is provided that Commonwealth and local authorities should consider the administration of Potassium Iodide (Kl) for the general public in accordance with their plans and procedures.

1 J-3 Revision 46

PNPS EMERGENCY PLAN

8. Evacuation Time Estimates: An independent evacuation time study has been performed to provide estimates, by subarea, of the time required to evacuate resident and transient
  • populations surrounding Pilgrim Station under favorable and adverse conditions (see Appendix 5). These evacuation time estimates are used in the formulation of protective action recommendations using Guidance in NUREG-0654/FEMA-REP-1, Rev.1, Supplement 3, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants". Estimates of EPZ permanent resident population changes are conducted annually.
9. Protective Measure Implementation: The responsibility for implementing protective measures based on protective action guides rests with Commonwealth and local agencies.
10. Factors Affecting Protective Measure Implementation: The PNPS, Commonwealth, and local 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 evacuating population will travel in their own vehicles, leaving the EPZ via designated evacuation routes. Figures J-1 through J-5 are maps showing the evacuation routes, evacuation subareas, reception centers in host areas, and mass care shelters.
b. The population distribution around Pilgrim Nuclear Power Station is presented in the Evacuation Time Estimates, Appendix 5.
c. As indicated in Section E, offsite agencies are notified in the event the Emergency Plan is activated. Commonwealth and local agencies have the capability to notify all members of the transient and resident population within the plume exposure EPZ.,
d. Means for protecting those persons whose mobility may be impaired due to such factors as institutional or other confinement are described in Commonwealth and local plans and procedures.
e. Provisions for the use of radio protective drugs, particularly for emergency workers and institutionalized persons within the plume exposure EPZ whose immediate evacuation may be infeasible or very difficult, including quantities, storage, and means of distribution are described in Commonwealth and local plans and procedures.
f.

Commonwealth and local plans include the method by which decisions are made by the Massachusetts Department of Public Health for administering radio protective drugs to emergency workers and the general public.

g. Means of relocation of the general public are described in Commonwealth and local plans and procedures.
h. Relocation centers in host areas which are at least 5 miles, and preferably 10 miles, beyond the boundaries of the plume exposure emergency planning zone are described in Commonwealth and local plans and procedures.

I.

Projected traffic capacities of evacuation routes under emergency conditions are described in Appendix 5, Evacuation Time Estimates.

J-4 Revision 46

j.

Control bf access to evacuated areas and organization responsibilities for such control are described in Commonwealth and local plans and procedures and in Appendix 5, Evacuation Time Estimates.

k.

Identification of and means for dealing with potential impediments to use of evacuation routes, (e.g., seasonal impassability of roads) and contingency measures are described in Commonwealth and local plans and procedures 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 pathway emergency planning zone have been performed and are contained in Appendix 5, Evacuation Time Estimates. Estimates of EPZ permanent resident population changes are conducted annually.

m. The bases for dose driven protective action recommendations are as follows:

If projected doses exceed minimum EPA PAGs, evacuation is considered for affected subareas and sheltering is considered for remaining subareas.

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

11. Ingestion Pathway Protective Measures: The responsibility for specifying protective measures to be used for the ingestion pathway rests with the Commonwealth of Massachusetts and the State of Rhode Island. These measures include the methods for protecting the public from consumption of contaminated water and foodstuffs.
12. Monitoring of Evacuees: The Commonwealth and local organizations have the capability to register and monitor evacuees at 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.

J-5 Revision 46

j PNPSEMERGENCYPLAN Table J-1:

Protective Action Recommendation Decision Chart IF:

THEN:

1.

Projected dose is:

No actions are necessary.

2.

< 1 Rem Whole Body (EPA TEDE) and

< 5 Rem Thyroid (EPA COE)

Projected dose is:

2 1 Rem Whole Body (EPA TEDE) or 2 5 Rem Thyroid (EPA COE)

Evacuate*

Consider the administration of Potassium Iodide (Kl) to the general public t PNPS personnel normally do not have the necessary information to determine whether off site conditions would require sheltering instead of an evacuation. An effort to base Protective Action Recommendations on external factors (such as road conditions, traffic/traffic control, weather, non-security impediments or offsite emergency response capabilities) is usually performed by the Commonwealth.

t Consideration of administering Potassium Iodide (Kl) to the general public would be recommended by PNPS at the General Emergency classification in accordance with offsite plans and procedures.

1 J-6 Revision 46

PNPSEMERGENCYPLAN Figure J-1:

Evacuation Routes r

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J-7 Revision 46

PNPS EMERGENCY PLAN Figure J-2:

10-Mile EPZ With Subareas Figure J.2 10-Mlle EPZ with Subarea$

- 10 Mlle

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J-8 Revision 46

L PNPS EMERGENCY PLAN Figure J-3:

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Rw. 10 1Ml4 Revision 46

Figure J-4:

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Revision 46

Figure J-5:

PNPS EMERGENCY PLAN Braintree Reception Center and Host School/Mass Care Shelters Braintree Reception Centers Mass Care Shelters r---~

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Revision 46

PNPS EMERGENCY PLAN 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 PNPS to provide necessary assistance to persons injured or exposed to radiation and/or radioactive materials.

Exposure guidelines in this section are consistent with EPA Manual of Protective Action Guides and Protective Actions for Nuclear Incidents, EPA 400-R-92-001.

1. Emergency Exposure Guidelines: Radiation exposure in an emergency is controlled, taking every reasonable effort to minimize exposure. However, circumstances may warrant exposure in excess of the EPA-400 general activities limit (5 Rem). Situations in which actions are taken to save vital equipment or property, circumvent substantial exposure to the general public or to save a life are examples of conditions which may necessitate extended emergency exposure authorization. The following are the exposure guidelines for emergency worker activities:

Dose Limit*

Activity All Conditions 5

10 25

>25 Protecting valuable property.

Lower dose not practical.

Life saving or protection of large Lower dose not practical.

populations.

Life saving or protection of large populations.

Only on a voluntary basis to persons fully aware of the risks involved.

EPA TEDE values for non-pregnant adults from exposure and intake during an emergency situation in Rem. Workers performing services during emergencies shquld limit dose to the eyes to three times the listed value and dose to any other organ (including skin and body extremities) to ten times the listed value.

2. Emergency Radiation Protection Program: The Radiological Coordinators ensure that proper personnel radiological monitoring equipment is provided for all personnel during emergencies, that exposure accountability is maintained and that personnel are not sent into known or potential high radiation areas (radiation, contamination or airborne) without adequate protection and exposure controls.

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 personnel exposures.

Assembly areas (or alternate assembly areas) are established to relocate and monitor evacuated personnel.

The authority to allow radiation exposure above the EPA-400 general activities limits is held by the Emergency Director for offsite (outside th~ protected area) ERO personnel through recommendations from the Radiological Assessment Coordinator and the Emergency Plant Manager for onsite ERO personnel through recommendations from the Radiological*

Coordinator and may not be delegated further.

\\

K-1 Revision 46

PNPS EMERGENCY PLAN In any emergency response action requiring greater exposure than 1 OCFR20 limits, volunteers over forty-five years of age are considered first. Females of childbearing age shall not be permitted to receive exposures in excess of 1 OCFR20 limits.

Access to high radiation areas is only permitted with prior approval of the applicable Radiological Coordinator or Radiological Assessment Coordinator. Prior to entry into a suspected high radiation area, the individual's current year exposure is evaluated based upon previous thermoluminescent dosimeter (TLD) readings, and self-indicating dosimeter estimates since the last TLD reading.

3. Personnel Monitoring
a. A Dosimeter of Legal Record (DLR) is issued to all emergency response personnel in the protected area. All Level'll GET responders wear a DLR every work day; Level I GET responders are provided with a DLR at their onsite emergency facilities upon activation. This, in addition to both low and high range self-indicating dosimetry, is used to monitor emergency workers exposure during an accident. The capability exists for the emergency processing of DLRs on a 24-hour per day basis, if necessary, through Entergy company dosimetry service agreements. Emergency workers are instructed to read self-indicating dosimeters frequently, and DLRs may be processed with increased periodicity.
b. Emergency worker dose records are maintained in accordance with Station Radiation Protection Procedures.
4. Non-PNPS Personnel Exposure Authorization: The responsibility for authorizing non-PNPS emergency workers (i.e. Commonwealth and local agency emergency workers) and visitors to receive exposures in excess of the EPA General Public Protective Action Guides rests with the Commonwealth and local organizations, except when such emergency workers and visitors are onsite. Authorization of exposures in excess of EPA General Public Protective Action Guides, in this latter instance, rests with the Emergency Plant Manager.
5. Decontamination and First Aid
a. Normal contamination control limits apply in emergency conditions. However, these limits may be modified by the Radiological Coordinator or Radiological Assessment Coordinator should conditions warrant.
b. Decontamination materials are stored in the Medical Building. Portable first-aid kits are available in the Engineering and Support Building and Medical Building. A personnel injury onsite involving possible radioactive contamination is initially treated by an on-shift EMP. Prompt attention is given to life endangering injuries such as extensive burns, serious wounds or fractures, in preference to decontamination. If the injury permits, all reasonable effort is made to decontaminate the individual prior to movement. If decontamination is impractical, the patient is covered in such a manner as to minimize the spread of contamination until medical aid can be obtained or the patient can be hospitalized.

K-2 Revision 46

\\

PNPS EMERGENCY PLAN The ambulance service contracted to the Plymouth Fire Department provides prompt transportation of persons requiring medical attention from the Pilgrim Nuclear Power Station to area hospitals. This service is available on a 24-hour per day basis. For accidents involving contamination, Radiation Protection (RP) personnel accompany the patient to the hospital to assist and advise ambulance personnel.

Patients requiring Emergency Room care, laboratory work, X-rays or lifesaving procedures are transported to the Beth Israel Deaconess Hospital - Plymouth (primary) or to Morton Hospital (backup). Hospital personnel have been trained and hospitals are equipped to handle contaminated or radiation injured individuals. Medical personnel may recommend transportation to other medical facilities equipped for severe trauma, long term or intensive care for radiation injuries. RP personnel are available to assist medical personnel with decontamination, radiation exposure and contamination control.

6. Contamination Control
a. Areas in the plant found to be contaminated are isolated as restricted areas with appropriate radiological protection and access control as directed by the Radiological Coordinator.
b. In order to preclude the spread of contamination from restricted areas, all personnel and equipment are monitored for radioactive contamination prior to exiting the restricted areas. Contaminated personnel are decontaminated. Emergency supplies of food and drinking water are stored in sealed containers to prevent contamination. Eating, drinking and smoking are prohibited in all Emergency Response facilities until such time as habitability surveys indicate that such activities are permissible.
c. Restricted areas will be returned to normal use when contamination levels have been returned to acceptable levels.
7. Decontamination of Relocated Personnel: Non-essential onsite personnel and non-PNPS personnel are evacuated to the Engineering and Support Building cafeteria, as discussed in Section J, "Protective Response". RP personnel at that location monitor evacuees and perform decontamination, as needed. Provisions for extra clothing, as well as suitable decontaminants are available. If radiological or plant conditions warrant evacuation of onsite personnel to the offsite assembly area, Chiltonville Training Center will be used.

Radiation Protection personnel are dispatched to the assembly area to monitor for personnel contamination.

K-3 Revision 46

PNPS EMERGENCY PLAN Section L:

Medical and Public Health Support This section describes Pilgrim Nuclear Power Station (PNPS) arrangements for medical services for contaminated injured individuals sent from the Station.

1. Hospital Services: Beth Israel Deaconess Hospital - Plymouth is the primary care facility for treatment of contaminated injured persons, and evaluation of radiation exposure and radionuclide uptake. Beth Israel Deaconess Hospital - Plymouth is located in Plymouth, Massachusetts, and five miles from PNPS.

Morton Hospital, located in Taunton, Massachusetts is designated as a back-up to Beth Israel Deaconess Hospital - Plymouth. This hospital is equipped and trained to handle contaminated injured individuals (See Appendix 3, Sample Copies of Letters of Agreement.)

2. Onsite First Aid Capability: Personnel injuries involving possible radioactive contamination are initially treated by an on-shift EMP. Prompt attention is given to life endangering injuries in preference to decontamination. (See Section 0, Emergency Response Training, for training requirements).
3. Medical Service Facilities: The Commonwealth of Massachusetts maintains a list of public, private and military hospitals and other emergency medical facilities considered capable of providing medical support for any contaminated injured individuals.
4. Medical Transportation:

PNPS has arranged with a local ambulance service for transporting victims of radiological accidents to medical support facilities. This service is contracted through the Plymouth Fire Department and is continuously available. (See Appendix 3, Sample Copies of Letters of Agreement).

L-1 Revision 46

PNPS EMERGENCY PLAN Section M:

Reentry and Recovery Planning This section describes the measures to be taken for reentry into the areas of Pilgrim Nuclear Power Station (PNPS) which have been evacuated as a result of an accident. It also outlines the PNPS Recovery Organization and its concepts of operation.

1. Reentry: During an emergency, immediate actions are directed toward limiting the consequences of the accident, so as 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 re-established, a more methodical approach to reentry is taken. This Emergency Plan therefore divides reentry into two separate categories:
a. Plant damage control, mitigation, repair and rescue activities are conducted during the emergency phase of an accident. This category of reentry is performed using emergency exposure controls and limits. Briefings for task activities and radiological controls may be provided verbally to dispatched personnel and documented afterwards.

Procedures provided to dispatched personnel for emergency activities can be taken from existing plant documents or developed on a case basis for the task.

All personnel dispatched from the onsite emergency facilities are authorized by the Emergency Plant Manager and coordinated through the Operations Support Center Manager, the assigne9 Team Coordinator and the Radiological Coordinator if necessary.

The following items are considered when planning the dispatch of personnel during an emergency:

Team composition which considers:

Previous non-emergency exposure for ALARA considerations.

Exposure accumulated during the course of the emergency.

Experience with the assigned task.

Familiarity with any existing procedures or processes.

Physical capacity to perform the task.

Nature of the task including applicable procedures if available.

Equipment, tools, instrumentation and materials necessary for the task.

Physical location where the task is performed.

Safety precautions pertaining to both the task and to personnel.

Communications equipment, channels, backup and reporting expectations.

M-1 Revision 46

PNPS 'EMERGENCY PLAN Any special instructions applicable to the task or evolution.

Radiological controls associated with the activity.

b. Plant control, restoration, repair and maintenance activities are conducted during the recovery phase of an accident. This category of reentry is performed using exposure controls based on 1 O CFR 20 limits and normal PNPS levels. Either existing procedures or procedures developed specifically for the task (developed, reviewed and approved through the normal plant administrative control process) are utilized for all recovery activities.

All personnel dispatched into hazardous areas, radiological or otherwise, during the recovery phase are authorized by the Recovery Plant Manager. The dispatch of personnel is coordinated through the applicable organizational structure (recovery or normal plant organization depending on the extent of the recovery).

2. Recovery: Recovery is defined as those steps taken to return the plant to its pre-accident condition. The Emergency Director, with concurrence from the EOF Manager and the Emergency Plant Manager, has the responsibility for determining when an emergency situation is stable and the Station is ready to enter the recovery phase. Prior to terminating an emergency and entering the recovery phase, the following conditions are considered:

Do conditions still meet an Emergency Action Level? If so, does it appear unlikely that conditions will deteriorate?

Radioactive releases are under control and are no longer in excess of Technical Specification limits.

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.

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

The potential for uncontrolled radioactive release is acceptably low.

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

Drywall pressure is within Technical Specification limits.

Any fire, flood, earthquake or similar emergency condition no longer exists.

All required notifications have been made.

Discussions have been held with Federal, Commonwealth and local agencies and agreement has been reached to*terminate the emergency.

At an Alert or higher classification (non-transitory classification), the Emergency Response Organization is in place and emergency facilities are activated.

Any contaminated injured person has been treated and/or transported to a medical care facility.

Offsite conditions do not unreasonably limit access of outside support to the station.

M-2 Revision 46

PNPS EMERGENCY PLAN It is not necessary that all conditions listed above be met; however, all items must be considered prior to entering the recovery phase. For example, it is possible after a severe accident that some conditions remain which exceeds an Emergency Action Level, but entry into the recovery phase is appropriate.

Once the decision is made to enter the recovery phase, the extent of the staffing required for the PNPS Recovery Organization is determined.

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 PNPS Emergency Response Organization, or portions thereof, should be adequate to perform the recovery tasks prior to returning to the normal Station organization.

For events involving major damage to systems required to maintain safe shutdown of the plant and offsite radioactive releases have occurred, (i.e. for SITE AREA EMERGENCY or GENERAL EMERGENCY classifications) the PNPS Recovery and Corporate organization is put in place.

The specific members of the PNPS 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 bf the PNPS Recovery Organization is as follows:

a. The Recovery Director is charged with the responsibility for directing the activities of the PNPS Recovery organization. These responsibilities include:

Ensuring that sufficient personnel from PNPS and other organizations are available to support recovery.

Directing the development of a recovery plan and procedures.

Ensuring that adequate engineering activities to restore the plant, are properly reviewed and approved.

Deactivating any of the PNPS Emergency Response Organization which was retained to aid in recovery, in the appropriate manner. D~pending upon the type of accident and the onsite and offsite affects of the accident, portions of the PNPS Emergency Response Organization may remain in place after initiation of the recovery phase.

Coordinating the integration of available Federal and Commonwealth assistance into onsite recovery activities.

Coordinating the integration of PNPS support with Federal, Commonwealth and local authorities into required offsite recovery activities.

Approving information released by the public information organization which pertains to the emergency or the recovery phase of the accident.

Determining when the recovery phase is terminated.

The Senior Nuclear Executive or a designated alternate is the Recovery Director.

M-3 Revision 46

PNPS EMERGENCY PLAN

b. The Recovery Plant Manager reports to the Recovery Director and is responsible for:

Coordinating the development and implementation of the recovery plan and procedures.

Directing all onsite activities in support of the recovery of PNPS.

Designating other PNPS recovery positions required in support of onsite recovery activities.

The Plant Operations General Manager or a designated alternate will become the Recovery Plant Manager.

c. The Recovery Offsite Manager reports to the Recovery Director and is responsible for:

Providing liaison with offsite agencies and coordinating PNPS assistance for offsite recovery activities.

Coordinating PNPS ingestion exposure pathway EPZ sampling activities and the development of an offsite accident analysis report.

Developing a radiological release report.

Designating other PNPS recovery positions required in support of offsite recovery activities.

A senior Regulatory and Performance Improvement Group Management individual or a designated alternate is the Recovery Offsite Manager.

d. The Company Spokesperson reports to the Recovery Director and is responsible for:

Functioning as the official spokesperson to the media for PNPS on all matters relating to the accident or recovery.

Coordinating non-PNPS public information groups (Federal, Commonwealth, local, etc.).

Coordinating media monitoring and rumor control.

Determining what public information portions of the PNPS Emergency Response Organization will remain activated.

A senior PNPS management individual is designated as the Company Spokesperson.

The remainder of the PNPS Recovery Organization is established and 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 PNPS organizations. Individual recovery supervisors may be designated in any or all of the following areas:

Training Radiation Protection Chemistry Technical Support Engineering Support M-4 Revision 46

PNPS EMERGENCY PLAN Quality Assurance Operations Security Maintenance Special Offsite Areas (Community Representatives, Environmental Samples, Investigations, etc.)

3.

Recovery Phase Notifications: When the decision is made to enter the recovery phase, all members of the PNPS Emergency Respqnse Organization are informed of the change. All personnel in the PNPS Nuclear Organization are instructed of the PNPS Recovery Organization and their responsibilities to the recovery effort.

4.

Total Population Exposure: A method has been developed for estimating the total population exposure resulting from the accident. Total population exposure calculations are performed during the recovery phase of an accident. Cumulative data are collected from PNPS Emergency Response Organization records and release pathway filter analyses to estimate the source term. Data are obtained from offsite agencies to estimate the total exposed population. Environmental TLDs will be analyzed to provide additional data.

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PNPS EMERGENCY PLAN Section N:

Drill and Exercise Program This section describes the Drill and Exercise Program that PNPS has implemented to:

Verify the adequacy of the Pilgrim Nuclear Power Station (PNPS) Emergency Preparedness Program.

Develop, maintain and evaluate the capabilities of the PNPS Emergency Response Organization to respond to emergency conditions and safeguard the health and safety of Station personnel and the general public.

Identify deficiencies in the PNPS Emergency Plan and the associated procedures, or in the training of response personnel, and ensure that they are promptly corrected.

Ensure the continued adequacy of emergency facilities, *supplies and equipment, including communications networks.

1. Exercises/Drills
a. Exercises are conducted biennially which involve implementation of the participants' emergency plan(s) and activation of major portions of participating emergency organizations. Where full participation by offsite agencies occurs, the sequence of events may simulate an emergency that results in the release of radioactivity to the offsite environs, sufficient in magnitude to warrant a response by offsite authorities. For exercises involving only partial participation by these agencies, emphasis is placed on development and conduct of an exercise that is more mechanistically and operationally realistic. Players will 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 are prerequisites for demonstration of all objectives. Scenarios for biennial exercises are submitted to the NRC at least 60 days in advance of the exercise date as required by 10 CFR 50 Appendix E.IV.F.2.a.
b. Exercises/Drills provide an opportunity to evaluate the ability of participating organizations to implement a coordinated response to postulated emergency conditions, In accordance with the PNPS Eight-Year Drill/Exercise Plan, drills and exercises are conducted to ensure that all major elements of the emergency plan and preparedness program are demonstrated at least once in each eight-year period. At least one drill every eight years is started off-hours. Drills/Exercises are scheduled to be conducted at different times of the year. An unannounced drill is performed.twice per eight-year cycle in accordance with the Eight-Year Plan.
c. Scenario elements to be addressed in the eight-year Drill/Exercise Plan, as described in 10 CFR 50 Appendix E.IV.F.2.j include:

Hostile Action directed at the site I

No/Minimal Radiological Release not requiring protective actions Initial classification or rapid escalation to Site Area Emergency or General Emergency Implementation of strategies developed under 10 CFR 50.54(hh)(2)

Integration of offsite resources with onsite response N-1

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Revision 46

PNPS EMERGENCY PLAN

2. Specialized Drills: PNPS conducts specialized drills for the purpose of testing, developing and maintaining the proficiency of emergency responders. The specialized drills may include, but are not limited to the following:
a. Communication Drills: Communications capabilities with the Commonwealth of Massachusetts and local emergency operating centers (Carver, Kingston, Duxbury, Marshfield, and Plymouth) are tested monthly.

Operability of communication equipment between PNPS and the State of Rhode Island is tested quarterly.

Communications between PNPS and the PNPS Offsite Monitoring Teams are tested annually.

Other communication checks/drills are conducted in accordance with 1 OCFR50, Appendix E.IV.E.

Each of these drills includes provisions to ensure that all participants in the test are able to understand the content of the messages (e.g. by requesting repeat-backs of information or verification of message transmittal forms).

b. Fire Drills: Drills for the PNPS Fire Brigade are conducted in accordance with Nuclear Organization and Station procedures.
c. Medical Emergency Drills: Medical emergency drills, involving an individual who is simulated to be injured and contaminated, are conducted at least annually. These drills include participation by an ambulance service and at least one hospital who has agreed to provide assistance to PNPS in the event of an emergency at the Station.
d. Offsite Monitoring Team Drills: Offsite Monitoring Team (OMT) drills are conducted at least annually and include provisions for the collection and analysis of environmental sample media (e.g. water, snow, vegetation, soil, and air), and the monitoring of radiological conditions outside the PNPS Protected Area. These drills include provisions for communications and record keeping.
e. Health Physics Drills: At least semi-annually, drills are conducted which involve response to, and analysis of, simulated_ airborne and liquid samples with elevated l~vels of activity. These drills also involve direct measurements of radiation levels in the Station. Normal station health physics rules and procedures are followed.
f.

Augmentation Drills: At least semi-annually, drills are conducted to test the ability to augment the on-shift organization. These drills are conducted using the following methods:

Activation of the EverBridge notification system with responders calling in their anticipated arrival times. The anticipated arrival times are then checked to confirm that the PNPS Emergency Response Organization could have been activated in a reasonable amount of time.

Activation of EverBridge, with actual response to Emergency Response Facilities.

N-2 Revision 46

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PNPS EMERGENCY PLAN

g. Combined Functional Drills: Periodically, drills are conducted to test the interfacility coordination, communication, and operation among emergency facilities including the EOF, TSC, OSC, Joint Information Center (JIC), Incident Command Post {ICP) and Entergy Corporate.
3. Conduct of Drills and Exercises: For each emergency preparedness exercise or drill conducted, a scenario package is developed which includes at least the following information:

The objectives to be demonstrated during the drill or exercise, Evaluation criteria to be used in determining the success of the drill or exercise, Date(s), time(s), and place(s) of postulated events, Scope of the drill or exercise and list of participating organizations, The simulated sequence of events and the estimated schedule for major events A narrative summary which includes at least the following information:

Events that are postulated to occur Extent of simulation (e.g. will protective clothing be worn or simulated? Will offsite support be simulated? To what extent will the public information organization be exercised?)

Briefing materials to be provided to official observers and information on arrangements made for them.

Prior approval of appropriate PNPS management is obtained for all drills and exercises conducted in support of the Emergency Preparedness Program.

4. Criteria and Evaluation: At the conclusion of each drill or exercise, a critique is conducted to evaluate the ability of the participants to implement the PNPS emergency plan and procedures. For drills or exercises involving only partial participation by offsite agencies, PNPS conducts a full, self-evaluation of activities; NRC representatives may be requested to observe these drills or exercises. For full participation exercises both the NRC and FEMA will observe and evaluate.
5.

Resolution of Drill and Exercise Findings: The critique and evaluation process is used to identify areas of the PNPS emergency preparedness program, which require improvement.

The Regulatory and Performance Improvement Director or his designee is responsible for evaluation of all recommendations and comments, and the determination regarding which of the items is to be incorporated into the Emergency Preparedness Program. Items identified for incorporation will be tracked through resolution using the appropriate station action tracking system.

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PNPS EMERGENCY PLAN 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 PNPS to both its employees and offsite support personnel requiring site access.

1. Assurance of Training: PNPS assures the training of appropriate company personnel through implementation of the Emergency Organization Training portion of the PNPS Nuclear Training Manual or EN-TQ-110, "Emergency Response Organization Training".

The required training for the PNPS Emergency Response Organization (ERO) positions that are defined in Section B is described here.

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. Specialized training is offered to the following offsite agencies that may be called upon to provide onsite assistance in the event of an emergency:

Plymouth Fire Department Plymouth Police Department Ambulance Service Training consists of the following:

Notification Process Training Site Orientation Training Basic Radiation Protection Training Specific Interface Training In addition, the individual in the PNPS Emergency Response Organization who controls the support activities is identified by position and title. These courses do not qualify offsite personnel for unescorted access. Escorts are provided to assist support personnel.

b. PNPS offers training support, as requested, for Commonwealth and local agencies whose function is to provide assistance during an emergency at PNPS. Training is offered on an annual basis, or as needed.
2. Classroom and Hands-On Training: Members of the PNPS Emergency Response Organization receive general and specialized classroom and hands-on emergency response training. Hands-on 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.

Walkthrough Sessions: Consists of a facility walk through to familiarize PNPS Emergency Response Organization personnel with procedures, communications equipment and facility layout. Walkthrough Sessions also provide the opportunity to discuss facility activities, responsibilities and procedures with an instructor.

0-1 Revision 46

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PNPS EMERGENCY RLAN 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 ability to perform 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: On-shift Emergency Medical Personnel (individuals qualified as EMTs; RNs, First Responders, and Paramedics) are trained to respond to medical emergencies.
4. 12NPS Emergency Response Organization Training Program: PNPS Emergency Response Organization personnel who are responsible for implementing this Plan receive initial, specialized and annual requalification training. Tables 0-1a and 0-1b are sample training matrices. The detailed training matrix is maintained in the PNPS Nuclear Training Manual or EN-TQ-110, "Emergency Response Organization Training".

Commonwealth and local EOC personnel receive training as outlined in the MEMA Training Program for the PNPS Emergency Planning Zone, with support provided by PNPS.

PNPS emergency response position assignments are based upon an individual's normal daily function and area(s) of expertise. Position-specific training provides the individual with the skills and knowledg~ to satisfactorily perform emergency assignments.

New PNPS Emergency Response Organization personnel receive -an initial overview course which familiarizes them with the Plan by providing basic information in the following areas as well as specific information as delineated in the sections below:

Planning Basis Emergency Classifications PNPS Emergency Response Organization and Responsibilities Callout of Emergency Organization Emergency Response Facilities Communications Protocol/Emergency Public lnfprmation Offsite Organizations Annual requalification training is provided to ensure personnel are informed of changes in the Plan, procedures, organization and facilities.

0-2 Revision 46

PNPS EMERGENCY PLAN

a. Personnel Responsible for Management of an Emergency Emergency Director. Emergency Plant Manager These positions receive specialized training in the areas of:

Notifications Emergency Classifications Protective Action Recommendations Emergency Action Levels Emergency Exposure Control

b. Personnel Responsible for Accident Assessment The skills and knowledge required to perform plant stabilization and mitigation are a normal function of specific Nuclear Operation's positions, as identified in Section B of this Plan. Power changes, planned and unplanned reactor shutdowns are handled on a normal operation basis. Subsequent plant stabilization and restoration is pursued utilizing normal operating procedures. Licensed Nuclear Plant Operators receive routine classroom and simulator training to ensure proficiency in this area.

To remove peripheral duties from the Nuclear Operations shift, those Emergency Organization positions responsible for accident assessment, corrective actions, protective actions, and related activities receive training as follows:

Core Damage Assessment: 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:

  • , Isotopic Assessment and Interpretation Available Instrumentation and Equipment Computerized and Manual Core Damage Assessment
c. Offsite Monitoring Teams and Radiological Analysis Personnel Offsite Radiological Monitoring: Offsite radiological monitoring is performed by trained individuals who provide samples and direct readings for dose assessment calculations.

Offsite Monitoring Team (OMT) members receive classroom and hands-on training in the following areas:

Equipment and Equipment Checks Communications Plume Tracking Techniques 0-3 Revision 46

PNPS EMERGENCY PLAN Personnel Monitoring: Personnel monitoring is performed by trained individuals who monitor Station personnel and their vehicles for contamination during an emergency.

Personnel Monitoring Team members receive classroom and hands-on training in the following areas:

Personnel Monitoring Equipment and Techniques Decontamination Techniques for Personnel Decontamination Techniques for Vehicles 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 any meteorological condition. Individuals responsible for performing dose assessment are trained in the following areas:

Computerized Dose Assessment Protective Action Recommendations Offsite Monitoring Team Interface Protective Action Guidelines associated with offsite plume exposure doses Basic Meteorology

d. Police, Security and Fire Fighting Personnel Local Police and Fire Fighting Personnel: The Plymouth Police and Fire Departments are invited to receive training as outlined in Part 1.a of this section.

Security: The PNPS emergency security response is based upon a normal daily security function which is to safeguard the site. Security personnel receive specialized training in the foll<?wing areas:

Accountability Evacuation Search and Rescue

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Emergency Response Facility Activation and Access Control Radiation Protection for Security Outpost Additionally, security management receives specialized training in the areas of:

Interfacing with Outside Support Organizational Interface 0-4 Revision 46 J

PNPS EMERGENCY PLAN Onsite Fire Fighting Personnel: Onsite fire fighting personnel are selected from the Operations and Security sections and receive their emergency response training as part of those groups.

e. Repair and Damage Control/Corrective Action Teams: Repair and damage control team members receive emergency team training specific to reentry.
f.

First Aid and Rescue Personnel: First aid and rescue team members receive training as outlined in Part 3 of this section.

g. Local Suooort Service Personnel: Local support service personnel providing assistance during an emergency are invited to receive training as outlined in Parts 1.a and 1.b of this section.
h. Medical Suooort Personnel: Onsite medical personnel receive specialized training in the handling of contaminated victims and hospital interface.
i.

Communications Personnel: PNPS Emergency Response Organization personnel receive training on communications protocol as a part of the initial Emergency Response Overview Course. Personnel using specialized communications equipm'ent 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.

j.

Corporate Support Personnel: Entergy corporate personnel responsible for responding to requests from Pilgrim Station receive training in,accordance with existing corporate emergency response procedures and appropriate elements of the PNPS Emergency Plan and Implementing Procedures.

5. General. Initial and Annual Training Program Maintenance
a. General Employee Training (GET): GET provides initial training and annual requalification training on the basic elements of the PNPS Emergency Plan for all personnel working at PNPS. These elements include:

Station emergency alarms and their meaning Assenibly areas Site evacuation procedure Special precautions and limit(3tions during an emergency Purpose of the PNPS Emergency Plan Role of the worker during' an emergency Related industry events 0-5 Revision 46

PNPS EMERGENCY PLAN

b. Initial Training: Prior to becoming a qualified PNPS Emergency Response Organization member, personnel receive a first-time course that provides introductory knowledge to new memb'ers of the organization. PNPS provides initial emergency response overview and specific training to assigned PNPS Emergency Response Organization members as outlined in the Emergency Organization Section of the PNPS Nuclear Training Manual or EN-TQ-110, "Emergency Re$ponse Organization Training". Additionally, PNPS offers initial training to those offsite organizations that provide onsite support, as discussed in Part 1.a of this Section.

When a PNPS employee successfully completes the training requirements for an assigned emergency position, training is documented and the employee'.s name placed in the PNPS Emergency Response Organization Training Matrix. The completed training documents certify that the individual is qualified to perform their emergency functions.

c.

Requalification Training: Annual requalification training is provided to PNPS Emergency Response Organization personnel. Requalification training consists of one or more of the following:

Annual Requalification Test Classroom and/or hands-on training addressing changes to the. PNPS Emergency Response organization, facilities, procedures and equipment Drill participation

d. Update Training: In some cases, it may be necessary to provide additional training prior to the annual requalification training. Changes to this Plan, PNPS Emergency Response Organization, procedures, facilities or equipment may require training in an effort to maintain a proficient PNPS Emergency Response Organization.

Program changes or deficiencies identified during drills, exercises or audits may require training to be performed prior to annual requalification training. Emergency Planning management evaluates the impact of these changes or deficiencies upon the effectiveness of the organization. As a result of this evaluation process, one or more of the following may occur:

Specialized Classroom Training Hands-On Training Required Reading Drills 0-6 Revision 46

PNPS EMERGENCY PLAN Table 0-1a:

Emergency Preparedness Training Modules Sample Matrix Module Curriculum File No.

Module Title 08 PCBT-EP-08 OSC Activation and Response 09 PCBT-EP-09 Senior Emergency Management 10 PCBT-EP-10 Emergency Plan Overview 13 PCBT-EP-13 Emergency Public Information 14 PCBT-EP-14 TSC Activation and Response 30 PCBT-EP-30 Classifying Emergencies 41 PCBT-EP-41 Emergency Exposure Controls 43 PCBT-EP-43 Offsite Monitoring Team Activation and Response 48 PCBT-EP-48 Personnel Monitoring Team Activation and Resoonse 50 PCBT-EP50 Communications Support 58 T-ER010158 Emergency Response Training for Security 62 T-ER010162 OSC and TSC Walkthrough 64 T-ER010164 EOF Walkthrouqh 65 PCBT-EP-65 EOG Walkthrough 67 T-ER010167 JIG Walkthrough 70 PCBT-EP-70 Estimating Core Damage 78 PCBT-EP-78 Using URI to Perform a Rapid Assessment 83 PCBT-EP-83 Offsite Dose Assessment Using the URI Software 84 PCBT-EP-84 An Overview of Radiological Dose Assessment Using the

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URI Software 85 T-ER010185 Introduction to SPDS 90 T-ER010190 Sever Accident Guidelines - SAG-01 and SAG-02 91 T-ER010191 Severe Accident Management: Accident Phenomenoloay 92 T-ER010192 Overview of Severe Accident Guidelines 93 T-ER010193 Technical Support Guidelines 94 T-ER010194 Emerqency Management Guidelines PCBT-EP-EXPECT Emergency Response Organization Personal Responsibilities PCBT-.EP-OFFSITE Instructions for Off-site Liaisons PCBT-EP-STRA TEGY Strategies for B5b Scenarios PCBT-EP-WEBEC1 Overview of WebEOC PCBT-EP-INFORM Notifying Off-site Agencies PLP-EP-USWEOC Using WebEOC FCBT-EP-CONEVAL Emergency Planninq Controller and Evaluator FCBT-EP-1 MP EQT Equipment Important to Emergency Preparedness FCBT-EP-ICSNIMS Incident Command System and NIMS Overview 0-7 Revision 46

PNPS EMERGENCY PLAN Table 0-1 b:

Emergency Response Organization Training Requirements Sample Matrix Position Module#

Training Required Dose Assessor 10 Emergency Plan Overview 64 EOF Walkthrough 84 An Overview of Radiological Dose Assessment Using the URI Software 83 Offsite Dose Assessment Using the URI Software WEBEC1 Overview of WebEOC Electrical Engineer 14 TSC Activation and Response 62 OSC and TSC Walkthrough 91 Severe Accident Management: Accident Phenomenology 92 Overview of Severe Accident Guidelines 93 Technical Support Guidelines WEBEC1 Overview of WebEOC Electrical Pool 08 OSC Operations for OSC Pool Personnel 62 OSC and TSC Walkthrough Electrical/l&C Coordinator 08 OSC Activation and Response 62 OSC and TSC Walkthrough WEBEC1 Overview of WebEOC Offsite Communicator 10 Overview 50 Communications/Notifications 64 EOF Walkthrough INFORM Notifying Off-site Agencies WEBEC1 Overview of WebEOC Emergency Director 09 Senior Emergency Management 64 EOF Walkthrough

' 91 Severe Accident Management: Accident Phenomenology 92 Overview of Se\\lere Accident Guidelines 94 Emergency Management Guidelines ICSNIMS Incident Command System and NIMS Overview WEBEC1 Overview of WebEOC EOF Log Keeper 10 Overview 64 EOF Walkthrough USWEOC Usinq WebEOC EOF Manager 10 Emergency Plan Overview 30 Classifying Emergencies STRATEGY Strategies for B5b Scenarios

, 64 EOF Walkthrough 0-8 Revision 46

PNPS EMERGENCY PLAN Section P: Responsibility for the Maintenance of the Planning Effort This section describes the responsibilities for development, review ana distribution of the Pilgrim Nuclear Power Station (PNPS) Emergency Plan and actions which must be performed to maintain the PNPS Emergency Preparedness Program. It also outlines the criteria for insuring that personnel who perform the planning are properly trained.

Emergency Planning Staff

1. At least once each calendar year all members of the Emergency Planning staff are involved in at least one of the following activities:

Training courses specific to emergency preparedness.

Training courses related to emergency preparedness management, such as I

problem solving, stress management or confrontation/media relations courses.

Observation of or participation in drills and/or exercises at other utilities.

Participation in industry review and evaluation programs.

PNPS training courses in related areas, such as systems, operations, or radiological protection training.

Other relevant training as determined by the Emergency Planning Manager.

2. Authority for Emergency Preparedness Effort: The Senior Nuclear Executive has overall authority and responsibility for the PNPS Emergency Preparedness Program. This includes the authority to provide the necessary resources to ensure the continuous state of readiness for the PNPS Emergency Response Organization.
3. Regulatorv and Performance Improvement Director: The Nuclear Safety Assurance Director is responsible for the maintenance of the PNPS Emergency Preparedness Program. In maintaining the program, the Regulatory and Performance lmprovement_Director ensures the following:

Development, maintenance and revision of the PNPS Emergency Plan and implementing procedures is accomplished in accordance with applicable regulations and industry standards.

Ensures the proper amount of PNPS support is provided to ensure the maintenance of offsite emergency response plans and procedures for the Commonwealth of Massachusetts and the local communities involved in response to an incident at Pilgrim Station.

The training program for offsite response personnel is properly supported by PNPS.

Development and maintenance of a strong working relationship with Commonwealth and local authorities responsible for Emergency Preparedness.

Consistency is maintained between this plan and its implementing procedures and the emergency plans and procedures of the Commonwealth and local authorities.

P-1 Revision 46

PNPS EMERGENCY PLAN Preparation for and conduct of the Station's drill and exercise program, and ensuring the program meets all regulations and guidelines of the NRC.

Emergency Response Facilities are maintained in a constant state of readiness.

Appropriate files are maintained to document the activities of the Emergency Preparedness Program as required by law and regulations.

Development and implementation of the Emergency Preparedness Public Information program.

PNPS is appropriately represented at Commonwealth and local meetings by a representative empowered to represent PNPS in emergency preparedness matters.

Preparation of reports to the NRC, FEMA and other agencies on emergency preparedness matters.

Alert and notification systems are maintained and tested in accordance with approved procedures.

Emergency Planning staff is involved in a program to maintain sufficient knowledge of state of the art planning techniques and the latest applications of emergency equipment and supplies.

Emergency Planning staff provides technical assistance to other PNPS organizations in areas of emergency preparedness.

Adequate PNPS and EP staff support is provided to support Pilgrim and Offsite emergency response plans.

The Regulatory and Performance Improvement Director is assisted in these responsibilities by the following Emergency Planning staff:

a. The Emergency Planning Manager is responsible for the development, implementation, and maintenance of the PNPS Emergency Preparedness Program. Specifically, this position is responsible for:

Overseeing the development and maintenance of this Plan and its implementing procedures while ensuring that regulatory guidance and industry standards are met.

Reviewing the Emergency Preparedness Training Program, including review of lesson plans.

Developing and conducting drills and exercises to maintain the state of readiness of the PNPS Emergency Preparedness Program.

Developing and maintaining administrative procedures and manuals required to assure the maintenance of the PNPS Emergency Preparedness Program.

Ensuring the resolution of emergency preparedness deficiencies discovered through drills, audits, and training.

Interfacing with Nuclear Training to ensure that an adequate number of personnel are trained and qualified to respond to an emergency at PNPS.

Coordinating the development and annual distribution of the public information publication.

Maintaining the PNPS Emergency Telephone Directory.

P-2 Revision 46

PNPS EMERGENCY PLAN Maintaining emergency radio and telephone communications systems between PNPS and offsite emergency response facilities including the Prompt Alert and Notification System (PAN?)..

Maintaining an emergency preparedness activity tracking system.

Maintaining PNPS emergency response facilities.

Providing assistance to local and Commonwealth officials in their emergency plan/procedure development and revision efforts.

Assisting in the development, implementation and revision of the local and Commonwealth training program.

Scheduling the cond,uct of the biennial exercise in cooperation with local and Commonwealth officials.

Coordinating with the Onsite Emergency Preparedness program to ensure consistency with the emergency plans and procedures of the Commonwealth and local authorities.

Assessing the completion and quality of any work performed by Emergency Planning Staff.

Coordinating with Corporate Emergency Preparedness senior management and PNPS site senior management with oversight responsibility for Emergency Preparedness to assure sight emergency preparedness and fleet emergency procedures resources, priorities, and performance standards are balanced for best performance.

b. Emergency Planning staff members are responsible both for maintaining the operational readiness of the station Emergency Preparedness program and the local offsite and related emergency preparedness programs. Emergency Planning staff report to the Emergency Planning Manager.

Operational readiness activities include:

Audits the Emergency Preparedness Training Program and provides staff support as required to ensure quality Emergency Organization Training.

Acts as a training coordinator for the Offsite Emergency Preparedness Training Program regarding onsite interface.

Assists in developing onsite training materials for the Local and Commonwealth Radiological Emergency Preparedness Training Programs.

Analyzes manpower needs and implements necessary actions to ensure sufficient resources are available to maintain the Emergency Preparedness Program.

Oversees the construction, maintenance, and surveillance of the local emergency operation centers and reception centers.

Oversees the maintenance and readiness of Pilgrim Station's emergency communications equipment.

Oversees the operation and maintenance of Pilgrim Nuclear Power Station's emergency communications equipment.

P-3 Revision 46

PNPS EMERGENCY PLAN Oversees the operational readiness of PNPS emergency response Facilities (i.e.,

Emergency Operations Facility (EOF), Operations Support Center (OSC), Technical Support Center (TSC), Joint Information Center (JIC), Alternate Emergency Operations Facility (AEOF), and Alternate Joint Information Center (AJIC).

Oversees the maintenance of the emergency preparedness activity tracking systems.

Oversees the development and maintenance of the Emergency Telephone Directory (ETD).

Oversees the maintenance and readiness of Station Prompt Alert and Notification System (Sirens).

Acts as Lead Controller for, and develops and conducts the Station Drill and Exercise Program.

Investigates and develops summary reports for incidents at the Station classifiable in accordance with the Station's Emergency Plan (i.e., Notification of Unusual Event, Alert, and higher).

Local offsite and related activities include:

Oversees the development and maintenance of the Pilgrim Nuclear Power Station Emergency Plan and Implementing Procedures.

Ensures that the Pilgrim Nuclear Power Station Emergency Plan and Procedures are maintained and consistent with related Commonwealth and local Emergency Response Plans and Procedures.

Coordinates the development and maintenance of administrative procedures and manuals required to assure the maintenance of the Station's Emergency Preparedness Program.

Ensures that the Emergency Public Information Program is developed and maintained to achieve consistency and compatibility with the Pilgrim Nuclear Power Station program.

Oversees offsite emergency preparedness activities and provides assistance to local and Commonwealth officials in their emergency plan development and revision efforts.

Oversees local and Commonwealth training program development, implementation,

_1 and revision.

Coordinates the review and distribution of the Emergency Public Information and notification materials.

Ensures compliance with terms of Local Civil Defense Grant agreements between the Company and towns.

Establishes and maintains liaison with elected and appointed local and Commonwealth officials by representing the PNPS Emergency Planning Department at meetings and functions.

Ensures that the Emergency Planning Manager is aware of trends and relationships in community activities and actions.

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P-4 Revision 46 1

PNPS EMERGENCY PLAN Coordinates the development and maintenance of corporate emergency response procedures and training materials with the Entergy Corporate.

Participates in the development and implementation of strategies associated with Offsite Emergency Preparedness programs that are responsive to current emergency preparedness regulations.

Develops and maintains with the State of Rhode Island Emergency Management Agency Radiological Emergency Plans and Procedures for the Ingestion Pathway.

Emergency Planning Staff Members report to the Emergency Planning Manager and are selected based upon qualifications that meet those outlined in position descriptions maintained in Emergency Planning Department files.

4. PNPS Emergency Plan Revisions: This plan is reviewed and updated as necessary, on an annual basis. The annual update includes required changes identified during training, drills and exercises. The Regulatory and Performance Improvement Director is responsible for determining which recommended changes are incorporated into the Plan.

Minor changes in the Emergency Plan such as a change in wording or set point that do not affect the intent of the original statement are incorporated in an annual update of the plan.

Changes in this plan, which add or remove a requirement to or from the Emergency Plan or change the intent of the Emergency Plan, require consideration for an immediate update to the plan.

Revisions to the Plan are reviewed by the Onsite Safety Review Committee (OSRC) and all organizations affected by the change prior to approval, in accordance with administrative procedures.

Changes to the Plan are made without NRC approval only if such changes do not reduce the effectiveness of the Plan, and the Plan as changed continues to meet the standards of 10CFR50.47 (b) and 10CFR50, Appendix E, and other licensing documents. 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.

5. Emergency Plan Distribution: Controlled copies of the PNPS Emergency Plan are issued to all appropriate organizational heads in the PNPS Nuclear Organization, the Commonwealth of Massachusetts and the Nuclear Regulatory Commission. Controlled copies of the Plan and Implementing Procedures are also provided in all appropriate Emergency Response Facilities. An Emergency Preparedness Administrative Procedure (in conjunction with Station Procedures) controls the distribution of changes to the Plan. Procedure requirements include use of revision bars and required page identifications (i.e. section of plan, revision number, etc.).

P-5 Revision 46

PNPS EMERGENCY PLAN

6. Supporting Emergency Response Plans: Other plans which support this Plan are:

Federal Radiological Emergency Response Plan Commonwealth of Massachusetts Radiological Emergency Response Plan Commonwealth of Massachusetts Radiological Emergency Response Plan Area II Town of Plymouth Radiological Emergency Response Plan Town of Carver Radiological Emergency Response Plan Town of Duxbury Radiological Emergency Response Plan Town of Kingston Radiological Emergency Response Plan Town of Marshfield Radiological Emergency Response Plan Town of Bridgewater Radiological Emergency Response Plan Town of Braintree Reception Community Radiological Emergency Response Plan City of Taunton Radiological Emergency Response Plan State of Rhode Island Nuclear Power Plant Incident Ingestion Exposure Pathway Emergency Response Plan Each of these plans has associated Implementing Procedures.

7. Implementing and Supporting Procedures: Appendix 2 of this Plan contains a listing, by number and title, of those procedures which implement this Plan during an emergency.

This appendix also provides a cross-referenced listing of PNPS Administrative Procedures to applicable PNPS Emergency Plan sections that help maintain the PNPS Emergency Preparedness Program.

All of these procedures are periodically reviewed and approved in accordance with document control requirements established in PNPS procedures and Entergy Quality Assurance ~rogram Manual.

8. Cross Reference to Planning Criteria: The Plan is formatted in the same manner as NUREG-0654, FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in support of Nuclear Power Plants",

Revision 1. This allows for ease in auditing evaluation criteria and eliminates the need for a cross-reference.

9. PNPS Emergency Preparedness Program Review: The Pilgrim Emergency Plan is independently reviewed as part of the Pilgrim In-plant Audit Program. The review is conducted as part of the Entergy Quality Assurance Program in accordance with 10 CFR 50.54(t). All aspects of emergency preparedness, including exercise documentation, capabilities, procedures and interfaces with Commonwealth, state and local governments are reviewed.
10. Maintenance of PNPS Emergency Telephone Directory: The PNPS Emergency Telephone Directory contains telephone numbers used by the PNPS Emergency Response Organization during an emergency. An Emergency Preparedness Administrative Procedure provides for verifying and updating these numbers at least quarterly.

P-6 Revision 46

PNPSEMERGENCYPLAN Appendix 1: References

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1.

10CFR50.47, Emergency Plans

2.

1 OCFR50 Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities

3.

10CFR20, Standards for Protection Against Radiation

4.

1 OCFR72.32, Emergency Plan

5.

NUREG-0654, FEMA-REP-1, Revision 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants

6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.

- 25.

26.

NUREG-0696, Functional Criteria for Emergency Response Facilities EPA-400-8-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents FEMA-Guidance Memorandum, MS-1 "Medical Services" PNPS FSAR PNPS Tech Specs HI-STORM 100 Cask System FSAR Reg. Guide 1.101, "Emergency Planning & Preparedness for Nuclear Power Reactors" Entergy Corporate Emergency Response/Recovery 1 OCFR50, Appendix R SANDIA 77-1725 PNPS Nuclear Training Manual INPO Emergency Resources Manual Nuclear Organization Procedure 88A4, "Assignment of Responsibilities in Support of the PNPS Emergency Preparedness Program" National Response Framework (NRF) lnteragency Radiological Assessment Program (IRAP)

Entergy Quality Assurance Program Manual PNPS Offsite Dose Calculation Manual (ODCM)

USNRC Generic Letter 82-33 dated 12/17/1982 ANSI N 18.7-1976, American National Standard, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants Federal Register Notice Final Rule, "Consideration of Potassium Iodide in Emergency Plans", Volume 66, Number 13, page 5427, dated January 19, 2001 FEMA Guidance Memorandum, "R1-TH-88-19, "Unannounced and Off-hours REP Exercises", dated August 2, 1988 Appendices-1 Revision 46

PNPS EMERGENCY PLAN

27. Supplement 3, NUREG-0654/FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Guidance for Protective Action Strategies" published November 2011
28. Nuclear Energy Institute (NEI) 99-01, "Methodology for Development of Emergency Action Levels", revision 5, dated February 2008.
29. 76FR72560, "Enhancements to Emergency Preparedness Regulations", Federal Register, Volume 76, p. 72560, Washington, DC, November 23, 2011
30. Reg. Guide 1.219, "Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors", November, 2011 Appendices-2 Revision 46

PNPS EMERGENCY PLAN Appendix 2: Procedure Cross-Reference to Sections of the Plan Number Title PNPS Emergency Plan Section(s)

EN-EP-313 Offsite Dose Assessment using the Unified 1.3, 1.4 RASCAL Interface EP-IP-100 Emergency'Classification and Notification D.1, D.2, Table D-1, E.1, E.2, E.3, E.4, J.1 EP-1P-100.1 Emerqencv Action Levels (EALs)

Table D-1 EP-IP-260, 9.1 Emergency Director 8.2 8.3, 8.4, Table 8-1 EP-IP-261, 9.1 Emerqencv Plant Manager 8.5, Table 8-1 EP-Pl-261, 9.1 Company Spokesperson

,8.5 EP-IP-210 Control Room Augmentation 8.5, Table 8-1 EP-IP-261 Technical Suooort Center (TSC) Operations 8.5, Table 8-1 EP-IP-225 Severe Accident Management Support 1.1 EP-IP-261,9.15 TSC/OSC Equipment Operation 8.5, Table 8-1 EP-IP-262 Operations Support Center (OSC) Operations 8.5, Table 8-1 EP-IP-261, 9.5 Radioloqical Coordinator 8.5, Table 8-1 EP-IP-240 Emergency Security Organization Activation 8.5, Table 8-1 and Response EP-IP-260, 9.2 EOF Manager 8.5, C.2.b, Table 8-1 EP-IP-260, 9.3 Radioloqical Assessment Coordinator 8.5, Table 8-1 EP-IP-260, 9.5 Administration and Logistics Coordinator 8.5, Table 8-1 EP-IP-260, 9.2, EOF Manager, Alternate EOF Setup, H.2 9.25, 9.26 Directions to AEOF EP-IP-260, 9.6 Offsite Communicator, EOF Communicator 8.5, F.1 and 9.7 EP-IP-260, 9.27 EOF Equipment Operation 8.5, Table 8-1 EP-IP-310 Offsite Monitoring Team Activation and 1.7, 1.8, 1.9

Response

EP-IP-315 Offsite Personnel Monitoring Team Activation J.3 and Response EP-IP-330 Core Damage 1.2 EP-IP-400 Protective Action Recommendations E.3, J.7, J.8 EP-IP-410 Evacuation/ Assembly J.2, J.4, J.5, K.3 EP-IP-420 Search and Rescue J.5 EP-IP-440 Emergency Exposure Controls J.6, K.1, K.2 EP-IP-520 Transition and Recovery M.1, M.2, M.3, M.4 EP-Pl-XXX Emergency Public Information Procedure Set G.3, G.4 PNPS 5.3.3 Medical Emerqencv Response Procedure K.5, L.1, L.4 Appendices-3 Revision 46

PNPS EMERGENCY PLAN Appendix 2: Procedure Cross-Reference to Sections of the Plan (Cont.)

Number Title PNPS Emergency Plan Section(s)

EP-AD-xxx

program for the applicable sections of the Plan.

EP-AD-100 Emergency Preparedness Controlled P.4 Documents EP-AD-110 Emergency Preparedness Organization and P.1, P.2, P.3 Responsibilities EP-AD-122 Maintenance of the Emergency Telephone P.10 Directory EP-AD-133 Emeroencv Public Information Program G-1, G-2 EP-AD-302 Facilities and Equipment Surveillances E.1, E.2, F.3, H.10 EP-AD-413 Emeroencv Communications Test F.3, N.2.a EP-AD-601 Emergency Action Levels Technical Basis D.1, D.2, 1.1, 1.4, J.7 Document EN-AD-01.01 NMM Procedure Writer Manual P.4 EN-EP-306 Drills and Exercises N.1.b, N.2.a, N.2.c, N.2.e.1, N.2.e.2 EN-EP-308 Emergency Planning Critiques N.1.b, N.2.a, N.2.c, N.2.e.1, N.2.e.2 EN-EP-310 Emergency Response Organization Notification E.1, E.2 Svstem EN-Ll-102 Corrective Action Process N.5 PNPS 8.E.71 Surveillance~ Maintenance, and Calibration of H.9 160' Met Tower MeDAP Equipment PNPS 8.E.72 Surveillance, Maintenance, and Calibration of H.9 220' Met Tower MeDAP Equipment PNPS 8.E.73 Meteoroloqical Tower Inspection Guideline H.9 Appendices-4 Revision 46

PNPS EMERGENCY PLAN Appendix 3: Sample Copies of Letters of Agreements: Beth Israel Deaconess Hospital -

Plymouth PNPS EMERGENCY PtAN The Nuclear Opero1ions, Jm:;, (lhe *company'), in preparing plfur\\" a&~

pn:meduras for inant11J@lnonl or 1adiolo.gioa1 emerww~ M itl! ?ilgtim NtX1ear FY.>w&i Sta!ian at Plymoulh, Mas:<acf\\vijQJhL 1ms made arn:mgemems w1th 1h& lJelh brae!

('.k~r10iJ!Wil$

l!osp!al-?i)'mouth, in.::.

(the "IJID Plvrr-0ulh'),

Ptymouth.

1Ma;;.sa:h:rse1ta. for \\h;, n;t1;<:>ptk.m and lrealment of radla!lm1 (<Ccidt;11l C!!iS'-"E.

BfD Pqirrn:iuth has <Jgresd to designa~e a ?11\\*'Jk:ian !o cnnsult ;:,11 sutl' cases Gr~tcs of mdkitlon &l!f'Al!ll;!e 01 cr;rt1Dminmion will be t)rougl>t WJ SID Plyinoum and tr>i!<l!~ h'f !he phyi¢;;ian sa* designamd OJ ()U1¢1 <rl!lrriMnl or BID Ply,mou1ll's &1afl Wl'*lCh 810 Plymou'.h has asked l~> 1\\Ml$t il'1 primary or S.\\C©n:iary con::; of 1110 wci1a".ion cases.

'l'he C<WlJ1*rty agrB*lB fo notfy the S£:lh ltrr101 C:k,aconas& Hoopii!al PiymtllAtl tif Hie ooo..rrrBnoo d any is1u1n ra<ftlologicnl cm;:;*r;ency at li'\\l']:f;111 fltn!kl!i prior ro sending n;<:Jl;;t,<i11 ¢<*ties io BID Plymcu1h f¢r ueamKmL Tho Corr4)an*; lurlh~ir' 10 transport 1hese: ~allf'A to GID P!ymoolh ih a mam1er ~fh?<';ffied by Beth Israel f.1;~CQ.r>eirs litll!PilsJ Pf)rrnouih aml \\o bring p;1!J<11!ls only io the 1l8!ldon of (lf!J Pi~*mouth clssl!fnated and p1W,:taf¢d k> lwn1ile suoh rfil.llation C;il$t*!li.

Ptior lo admitting the!W! patlelll!I< i:'lil'.l BID Plymouth, 1he Compnny will use its best efforts. tc* e'\\1ab.J£le Ille "'*W and tn carry ou! deroo1amlnaiion and fits1 a:d ptl.X:e!l"to~.

whl<:h '<! duoms ITTM:es1J2ry and "11ith i'it& v.-11i1in its c~billties.

All radiation aoci:ieril JX!1l0S fot <idmlssion ta BlD PlymQ!dh wm t:e mo*cmpar.:ied by a Compemy repw:;'011ta1i'IB who is kn::r>i!lf~i*lsf4 i!!1d irainad in mctdilte11 j)n'.l!ectian.

Thu:;B irdivii:lual~ Wili tBlllil(fl "'1111 fue patiel'li to a~..;iiM 8![} Pl~'.rnOUll'li in liH#:lri\\4Jdr1\\l fti; mrJi01ogie'11 concerns as Jong mi ne&.::~JSill'J'. Once tilB prili\\enl ls ;idmittsd for medl~!l;J trc-almef!l air.¢ lhe rmliok>gical roru:ems ol (lib ?,~*mouth hm*e been <N'4int1ssed. thc-C:irnfJ<.HY)" mdiaibn pmJei::;ti¢rr tuprccst.m!ative's -"$P9'1>;ibi!1ffes shart be c::..w.ktmoo compietf:L 4\\ti'.Jm#yw* foos) arising iri C:)nnectio0 w&lh or as a result of foe pm*>>ISi<M! of seNi~

undi;;t this Agra<!?rnenL Nolhing in lhhi A.9r!2llmenf, '101 rmy act of either the Coinp;,i~'l or EID Pl~'ll1at.Jlh.

shall oo deem;;;d at ce.t:%.<hued by &ilner cl !f]<!rn, or by !hird' per-,,ona, to *~r0ml.¢ any rela1iar1$hip witateoe>'!lr im<1Jlvln9 !ha Company lrr¢:.tidlni:t bwl limited !o.

smploym<.H1t;,igee<:y or o<.:mtr.artor rela!ianship$ bo!:wee-n the Company und an emplo~'0!) 'X au!harzed of BIO Piymau:h, err e¥rn1pt m> provided 0bo*110;,

(2) to <Jfeaie Bfl1f fi!jh\\ Cl>

p:tirt of E:iJ) Pl:f'l!0111h or Bi1}' ;hird perJV;>I) Wilh ro:;;;::.eci W tl'<r; C<mioany and i:s pn;perty, Beth,ISJ'aei De."!CtJtkits Hospital.

Plyrnaulh,. Inc.

It~ Prooident ~ CEO Appendices-5 Revision 46

PNPS EMERGENCY PLAN Appendix 3: Sample Copies of Letters of Agreements: Morton Hospital ENTERGY NUCLEAR OPERATlONS, INC.

EXPENSE REIMBURSEMENT AGREEMENT This agreement is enlered into by and bet.veen Entergy Nuclear Operations, !nc. (the

""Company) and the Morton Hospitat and Medical Center, !no, (the ~contractor :),

The Company owns anct operates the Pifgrim Nuclear Power Station ("Pilgrim Station*),

which Is located in Plymouth. l\\*1assachusetts, and as such has an interest rn the preparation and irnp!ementatlon of plans developed to respond to radiolo.gical emergencies at the Pilgrim Stallon.

The Contractor ha$ agreed to participate in the Radloh:igicai Emergency Plan fc.r the P!lgtfim Station. Such participation will require that the Contractor or its employees, in coordination with various support agencies (Le,. Al'V1R Ambulance Service, Plymouth Fire Department) pm11fda supplles and equipment in the care and treatment of contaminated and injured personnel sent. from Pilgrim Station, Such participation includes training and drilts.

Reimbursement for material used in the course of treating contaminated and injured personnel from P rim Station wilt be through the normal b!tllng process. Whereas, Jn consideratl0r1 of ntractor tor care and treatment of contaminated and injured personnel for training and drills, the Company agrees to reimburse 1.he Contractor for all medical suppl1es and equipment used in decontamination and treatment Radiological supplies and equipment will be l~ventoried and replaced by the Company.

It shall be the responsibiHty of the Contractor to complfe, re'llew and approve ln writing, aH requests for payment of materlaf and equipment described herein arid to submit satd requests to the Company on a monthly basis. All requests shall include the name(s) of individual(s) treated, teason (i.e., training, drill, medical treatment) and a list of all material used during treatment that has to be replaced, The Company shall make payment to the Contractor within forty-five (45) days of its receipt of the Contractor's request fur payment The Contractor acknowledges that the obligation of the Company is limited to reimbursement of expenses in the manner and on the terms set forth in this Agreement Nothing in this Agreement, nor any act at either the Company or the Contractor, shall be deemed or construed by elther of them. or by third persons, {1) to create any relationship 1..vhatsoever involving the Company induding, but not limited to, employment, agency or contractor refattonships between the Company and an employ*ce or ~tJ!hori:i:.ed representative of the Contractor. or except as provided above,

{2) to cre8ite arty ri?ht on the part of the Con(mctor or any third person with respect to the Go11lj'.H:ilny and ils property,

!!\\!

WHEREOF the undersigned hereunto se! iheir respec!ive hands this Day of __ *, Tc.. :v. if. _____, 21Jf4.

~*~

-~-~---"""'-

/

/j \\

ENTERGY NUCLEAR OPERATION$,

ITAL AND

INC, NC.

Appendices-6 Revision 46

PNPSEMERGENCYPLAN Appendix 3: Sample Copies of Letters of Agreements: Plymouth Police TO\\VN OF PL11\\40UTH POLICE DEPARTMEN"f 20 t,ong Pond Road Ptymouth. M11s..-;ach1;1sett$ 0236-0 FAX ($08! 8:)0-4:227

{508) 820-42 HJ February 14, 20l4 Mr. John Dent VP Pilgrim, Entergy Plymouth, MA 02360 The Prymouth f'.olice Dt?partrnent agrees to respond to the request of the Pilgrim Nudear Power Station operat1ng personnel or security in the event of an emergency, Including those from ho$till! actions to the sit~.. in the following areas:

1. Control and limit m::cess to the Town roads in too v.ldnity of the S:ite i11duding the erection of lramers on Hocky Hi!! Road,
2. Ass1st in the evacuation of the public from the site,
3. Provide focaticm off site for emerganey equipment.

Tile Plymouth Pollt:fl Department wm carry out their emergency duties and ell;ercise their powers gra rited to them pursuant to the General Law:s Qf the turnrnonwealth of Massachusetts ("MG L's,"

spcciflc;dly MGL41, S~ttion 96), the Code of Mauadtus:etts Re~ulatlons ("CMR'sN} the Commonwealth of Massachusetts Ci:m1prehensive Emergency Management Plan, the Metropolitan Law Enforcement Co1mcil {uMetro-LEC"). and the laws of the Town of Plymouth.

This agreement is valld until Oetember.H, 2.014 Si11cernfy, Cc Eriterljly Folder Appendices-?

Revision 46

PNPS EMERGENCY PLAN Appendix 3: Sample Copies of Letters of Agreements: Plymouth Fire Department Agreement between the Plymouth Fire Dcpm*tmcnt And Entergy Nuclear Generation Company (Entergy Nuclear), or its Predecessor Company ln the event of an incident at the Pilgrim Nuclear Po\\.\\rer Station (PNPS)

. This agree~~mt is valid until December 3 l, 2014 Tile Plymouih Fire Department and Eri~rgy Nuclear herewith agree to foe following:

L Plymouth Fire Dcpat*ttmmt wil! pt'ovide Vire Protection and.

Suppression Agsfotance t-Or the Pilgrim Station Site and activate the.Plymouth Emergency Opei*ations C~nter in the event of an emergency including those resulting from hostile actlous at ihe site.

a) While pn.ividing Fire Protection a.nd Si1ppression Assiatance tile senior Plymouth Fire Department Ofiker on scene and the pilgrim Station Fire Brigade Leader shall remain in continuous communications ro co-ordluate tile fire fighting. life saving and prop-0rty protection activities.

In practice tQis means that Pllgrhn Statkmwm. deter to PJymouth. Fi.re Dcparimcnt expertise and authority for fire fighting:. I ire saving and property ptoteetion activities and Plymmath FlreDept11'fment wm defer to Pilgrim Station expcl'tise and authori:y i11vo!vi11g reactor pJant safety

  • b) Et1tcrgy Nuclear and Plymouth Fire realize the need fur force rendrness training for fire crews and \\nternetfon of PNPS pet'!l-Onnel ?Ud fire crews to ensure !late and e fficicnt operatiom, To ensure force re~dincss. Etitcrgy Nuclear shall ammgefor and provide funding on an annual basis for; I. The Plymouth Pi re Department to train and drill on-site with the Siation's Fii:a B~*igadc; Radiological mon[toring rmd iti~trumentati;mtmitdr:g fur Plymouth Firef!glttcrn; "t. Plyrm:m!h Fire D!!purhmmt wi U carry oot their emergency dutle!l nnd exercise ihi; powers grunted to them t,mr:m:mt to the Gen~i Laws of the Cmu11mnwealti1 of Massachu:sena (i'.IGL), thi; Ccdr: of Ma'f£m:ihusetf'J,

Ke~u:.uw::ms (GMR), the Commonweuith ofMR3sru::husi:::ttsComprehcn.sive F'"'"~"'""""' Mmiagcment Pfon ;\\m:! (he bylaws of the Town of Plymouth, J. The Plymouth Fire Dupartment wi H dispatch crews to Pi !grim Station to

~rovicle emergency medical :services when.1*equesled.

Appendices-8 Revision 46

PNPSEMERGENCYPLAN

-Appendix 3: Sample Copies of letters of Agreements: Plymouth Fire Department (Cont.)

4. The Plymouth Fire Depmtment will provide stomge facmlles (as !i:tlclt space and facilltics are available) for the storage of off.site emergency equipment stipplkd by Bntergy Nuckm.* and required hy Planning Section H, Emergency Fnc!Utlcs and Equipment, ofNUREG.0654.

\\.,

<a) This is inteniliid to include all equipment curreni!y stored (a eompres:mr to fill SCBA bottles).~ A1iy additional equipment stom~c needs wm be subject to negotiations between d1e Plymouth Fu-e Department and Entergy Nuclear and wiU be sub,iect to available space that the. Department can p1-ovidc.

Approved Entet'BY Nuclear PlJgrlm Nuclear Power Statk>n Approved Plymouth Fire Date Q/Ju:1YJ~r,/::,':.,:.;lr."f/t/

Appendices-9 Revision 46

PNPS EMERGENCY PLAN Appendix 3: Sample Copies of Letters of Agreements: Town of Carver

'Board of Sefectmen Richard J. La Fond Town Administrator Carver, Massachusetts 02330 508-$66-3400

  • Fax 508*BG6-421a Jeanne M. Roby Administrative Assistant Jack Alexander Director, Nuclear Assessment Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth,. MA 02360

Dear :

Mr. Alexander:

The Town of Carver agrees to allow Pilgrim Nuclear Power Station (PNPS) Emergency Response personnel tu utilize a. contereoce room in the basement of Carver Town Hall for an Alternate Emergency Operations Facility (,.\\EOF), in case the PNPS primary EOF, located in Plymouth., is declared uninhabitable for any reason. The T O\\\\<'Tl of Carver ft1rther agrees to:

1. Allow for storage of PNPS equipment ln conjunction with the Carver Emergency Mimagement Agency EOC; and
2. Permit Pilgrim Station Emergency Preparedness Department personnel acceS-'> to the AEOF equipment for routing maintenance and surveillance; and
3. Ii" necessruy, provide Pilgrim Station Emergency preparedness Department personnel off-hour access to activate the AEOF.

This agrnemenl will continue until either the Town of Carver nr Pilgrim Nuclear Power Station provides a 60-day written notice that it can no longer support this.agreement Appendices-10 Revision 46

PNPS EMERGENCY PLAN Appendix 3: Sample Copies of Letters of Agreements: Bridgewater State College

/

July 13, 2000

VIr. Jack Alexander Director, Nuclear Assessment Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360

Subject:

Letter of Agreement

Dear Mr. Alexander:

BRIDGEWATER STATE COLLEGE Bridgewater State College agrees to allow Pilgrim Nuclear Power Station (PNPS)

Emergency R~-ponse personnel to utilize the auditorium and two conference.rooms in the John Joseph Moakley Center for an Alternate Media Center (AMC), in the event the PNPS primary Media Center, located in Plymouth, must be relocated during an emergency. Bridgewater State College further agrees to:

1.

Allow for the use of existing equipment resources at the facility;

2.

If necessary, provide Pilgrim Station Emergency Response personnel off-hours access to activate the Alternate Media Center.

This agreement will continue until either Bridgewater State College or Pilgrim Nuclear Power Station provides a 60-day written notice that it can no longer support this agreement.

  • Sincerely, OFFICE Of ADMINISTRAr!ON & FlNANCE
  • BOYDE.'! Hnt!., ROOM 100 BR!DGEWATE.q STATE CotLEGE
  • BRmcaW.,TER, MASSACHusms 02315 (508) };H10i *FAX (508) S}l*0!'.1.7 Appendices-11 Revision 46

PNPS EMERGENCY PLAN Appendix 4: Glossary of Terms Any abbreviation followed by a lower case 's' denotes the plural form of the term.

ac..................................................................................................................... alternating current AEOF............................................................................ Alternate Emergency Operations Facility ALARA................................................................................... As Low As Reasonably Achievable ANI..................................................................................................... American Nuclear Insurers ANSI................................................................................. American National Standards Institute ARM......................................................................................................... Area Radiation Monitor BECONS............................................................... PNPS Community Offsite Notification System BEEPS.................................................................................... PNPS Emergency Paging System BWR.......................................................................................................... Boiling Water Reactor CB............................................................................................................................ Citizen Band cc........................................................................................................................ cubic centimeter CERP...... ~.......... Commonwealth of Massachusetts Comprehensive Emergency Response Plan CFR................................................................................................ Code of Federal Regulations CHRMS.............................................................. Containment High Radiation Monitoring System cm2.................................................................................................................. square centimeter CR........................................................................................................................... Control Room Cs.................................................................................................................................... Cesium dc............... :............................................................................................................. direct current DLR.................................................................................................... Dosimeter of Legal Record DNN............................................................................................. Dedicated Notification Network DOE..................................................................... :............................ U. S. Department of Energy DOT....................................................................................... U.S. Department of Transportation dpm........................................................................................................ disintegration per minute EAL........................................................................................................ Emergency Action Level EAS....................................................................................................... Emergency Alert System ENS.................................................................................... NRC Emergency Notification System EOC............................................................................................... Emergency Operating Center EOF............................................................................................. Emergency Operations Facility EOP.......................................................................................... Emergency Operating Procedure EPA.................................................................................. U.S. Environmental Protection Agency EPZ..................................................................................................... Emergency Planning Zone E&S....................................................................................................... Engineering and Support ERON................................................................ Emergency Response Organization Notification EWMDS................................................ Emergency Worker Monitoring Decontamination Station FEMA.......................................................................... Federal Emergency Management Agency FRERP............................................................. Federal Radiological Emergency Response Plan FSAR............................................................................................... Final Safety Analysis Report Ge.............................................................................................................................. Germanium GET........................................."......................................................... General Employee Training HEPA....................................................................... :..................... High Efficiency Particulate Air HPN............................................................................................... NRC Health Physics Network hr.............................................................................................. :............................................ hour Appendices-12 Revision 46

PNPS EMERGENCY PLAN Appendix 4: Glossary of Terms (Cont.)

I........................................................................................................................................... Iodine ICP.......................................................................................................... Incident Command Post INPO.................................................................................. Institute of Nuclear Power Operations IRAP..................................................................... lnteragency Radiological Assistance Program ISFSI....................................................................... Independent Spent Fuel Storage Installation JIC.......................................................................................................... Joint Information Center Li....................................................................................................................................... Lithium LOCA.................................................................................................... Loss of Coolant Accident MDPH...................................................................... Massachusetts Department of Public Health MEMA.............................................................. Massachusetts Emergency Management Agency mR......... ~.................... :.......................................................................................... milliroentgen NOP........................................................................................... Nuclear Organization Procedure NRC................................................................................... U.S. Nuclear Regulatory Commission OMT....................................................................................................... Offsite Monitoring Team OSC.................................................................................................... Operations Support Center*

OSRC....................................................................................... Onsite Safety Review Committee PAG........................................................................................................ Protective Action Guide PANS.................................................................................. Prompt Alert and Notification System PAR...................................................................................... Protective Action Recommendation PASS................................... '...................................................... Post Accident Sampling System PDP.................................................................................................................. Plant Data Phone PNPS............................................................................................ Pilgrim Nuclear Power Station R............................................ ~....................................................................................... roentgen RACES......................................................................... Radio Amateur Civil Emergency Services RASCAL........................................ Radiological Assessment System for Consequence Analysis RERP............................................................................ Radiological Emergency Response Plan SCBA.................................................................................... Self-Contained Breathing Apparatus SGTS......................................................................................... Standby Gas Treatment System SPDS....................................................................................... Safety Parameter Display System Sr...................................................................... :........................................................... Strontium TTY............................................................................................. [.......................... Teletypewriter TLD.............................................................................................. Thermoluminescent Dosimeter TSC...................................................................................................... Technical Support Center

µCi............................................................................................................................. microcuries URI...................................................................................................... Unified RASCAL Interface Appendices-13 Revision 46

PNPS EMERGENCY PLAN Appendix 5: Evacuation Time Estimates THIS APPENDIX IS CONTAINED IN ANOTHER VOLUME AND HAS LIMITED DISTRIBUTION Appendices-14 Revision 46

ATTACHMENT 9.2 10 CFR 50.54(Q)(3) SCREENING 5HEET1OF3 Procedure/Document Number: EP-PP-01 I Revision: 46 Equipment/Facility/Other: Pilgrim Nuclear Power Station

Title:

PNPS Emergency Plan Part I. Description of Activity Being Reviewed (This is generally changes to the emergency plan, EALs, EAL bases, etc. - refer to step 3.0[6]):

1.

Deletion of the word: "voice". Sections E.2 and F.1

2.

Deletion of the words: "Interactive Voice Response (telephone)". Section F.1

3.

Change "alternate voice activated system capability" to "alternate activation capability". Section F.1.c.

Part II. Activity Previously Reviewed?

Is this activity fully bounded by an NRC approved 10 CFR 50.90 submittal or Alert and Notification System Design Report?

If YES, identify bounding source document number/approval reference and ensure the basis for concluding the source document fully bounds the proposed change is documented below:

Justification:

D Bounding document attached (optional)

Part Ill. Applicability of Other Regulatory Change Control Processes DYES 50.54(q)(3)

Evaluation is NOT required.

Enter justification below and complete Part VI.

~NO Continue to next part Check if any other regulatory change processes control the proposed activity.(Refer to EN-Ll-100)

APPLICABILITY CONCLUSION

~ If there are no other controlling change processes, continue the 50.54(q)(3) Screening.

D One or more 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. Identify the applicable controlling change processes below.

D One or more controlling change processes are selected and fully bounds all aspects of the activity. 50.54(q)(3)

Evaluation is NOT reQuired. ldentifv controllina change orocesses below and complete Part VI.

CONTROLLING CHANGE PROCESSES 10 CFR 50.54(q)

Part IV. Editorial Change Is this activity an editorial or typographical change such as formatting, paragraph numbering, spelling, or punctuation that does not change intent?

Justification:

DYES

~NO 50.54(q)(3)

Continue to next Evaluation is part NOT required.

Enter justification and continue to next part or complete Part Vias aoolicable.

EN-EP-305 REV 4

ATTACHMENT 9.2 10 CFR 50.54(Q)(3) SCREENING 5HEET20F3 Procedure/Document Number: EP-PP-01 I Revision: 46 Equipment/Facility/Other: Pilgrim Nuclear Power Station

Title:

PNPS Emergency Plan Part V. Emergency Planning Element/Function Screen (Associated 10 CFR 50.47(b) planning standard function identified in brackets) Does this activity affect any of the following, including program elements from NUREG-0654/FEMA REP-1 Section II?

1.

Responsibility for emergency response is assigned. [1]

D

2.

The response organization has the staff to respond and to augment staff on a continuing basis (24/7 D

staffing) in accordance with the emergency plan. [1]

3.

The process ensures that on shift emergency response responsibilities are staffed and assigned. [2]

D

4.

The process for timely augmentation of onshift staff is established and maintained. [2]

D

5.

Arrangements for requesting and using off site assistance have been made. [3]

D

6.

State and local staff can be accommodated at the EOF in accordance with the emergency plan. [3]

D

7.

A standard scheme of emergency classification and action levels is in use. [4]

D

8.

Procedures for notification of State and local governmental agencies are capable of alerting them of D

the declared emergency within 15 minutes after declaration of an emergency and providing follow-up notifications. [5]

9.

Administrative and physical means have been established for alerting and providing prompt D

instructions to the public within the plume exposure pathway. [5]

10. The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert and D

Notification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANS design report and supporting FEMA approval letter. [5]

11. Systems are established for prompt communication among principal emergency response D

organizations. [6]

12. Systems are established for prompt communication to emergency response personnel. [6]

[81

13. Emergency preparedness information is made available to the public on a periodic basis within the D

plume exposure pathway emergency planning zone (EPZ). [7]

14. Coordinated dissemination of public information during emergencies is established. [7]

LJ

15. Adequate facilities are maintained to support emergency response. [8]

D

16. Adequate equipment is maintained to support emergency response. [8]

D

17. Methods, systems, and equipment for assessment of radioactive releases are in use. [9]

D

18. A range of public PARs is available for implementation during emergencies. [1 O]

D

19. Evacuation time estimates for the population located in the plume exposure pathway EPZ are D

available to support the formulation of PARs and have been provided to State and local governmental authorities. [1 O]

20. A range of protectiv~ actions is available for plant emergency workers during emergencies, including D

those for hostile action events.[10]

21. The resources for controlling radiological exposures for emergency workers are established. [11]

u

22. Arrangements are made for medical services for contaminated; injured individuals. [12]

u

23. Plans for recovery and reentry are developed. [13]

0

24. A drill and exercise program (including radiological, medical, health physics and other program D

areas) is established. [14]

25. Drills, exercises, and training.evolutions that provide performance opportunities to develop, D

EN-EP-305 REV 4

ATTACHMENT 9.2 10 CFR 50.54(0)(3) SCREENING SHEET3 OF 3 Procedure/Document Number: EP-PP-01 I Revision: 46 Equipment/Facility/Other: Pilgrim Nuclear Power Station

Title:

PNPS Emergency Plan maintain, and demonstrate key skills are assessed via a formal critique process in order to identify weaknesses. [14]

26. Identified weaknesses are corrected. [14]

D

27. Training is provided to emergency responders. [15]

D

28. Responsibility for emergency plan development and review is established. [16]

D

29. Planners responsible for emergency plan development and maintenance are properly trained. [16]

D APPLICABILITY CONCLUSION 0 If no Part V criteria are checked, a 50.54(q)(3) Evaluation is NOT required; document the basis for conclusion below and complete Part VI.

0 If any Part V criteria are checked, complete Part VI and perform a 50.54(q)(3) Evaluation.

BASIS FOR CONCLUSION Items 1-3: These changes remove references to alternate voice activation capability of the Emergency Response Organization Notification (ERON) system. With the new Everbridge Mass Notification system, alternate messages are pre-programmed in the system and therefore a vojce activation capability is no longer available or necessary.

The impact on Planning Standard 10 CFR 50.47(b)(6) due to the change to the new Everbridge Mass notification system from the Everbridge Aware system was evaluated in a 10 CFR 50.54(q)(3) Evaluation performed for EN-EP-310 Revision 5 that found there was no reduction in effectiveness of the PNPS Emergency Plan (see attached). No further evaluation is required for these changes.

Part VI. Signatures:

Preparer Name (Print/)

~

111-rs ~ tar lh < ref:e f""

(Optional) Reviewer Name (Print)

Reviewer Name (Print)

Tom Sowdon Nuclear EP Project Manager Approver Name (Print)

~~f~~~signee Date:

Date:

Reviewer Signature Date:

~<-/~Lt-8-22-2016 Date:

EN-EP-305 REV 4

NUCLEAR NON*QUALITY RELATED EN-EP-305 I REV.4

~Entergy MANAGEMENT MANUAL INFORMATIONAL Use PAGE 1 OF4 Emergency Planning 10CFR50.54(q) Review Program

~

An:ACHMENT 9.3

~

10 CFR 50.54(Q)(3) EVALUATION Procedure/Document Nu~r: EN-EP-310 I Revision: 5

)

Equipment/Facility/othet Pilgrim Nuclear Power Station

__,.,/'

Title:

ERO Notification System SHEET1 OF4 Part I. Description of Proposed Change:

This revision to Fleet procedure EN-EP-31 b incorporates changes to address the transition from EverBridge Aware software to EverBridge Mass Notification software for ERO Notification as a result of a Vendor-initiated upgrade to this notification system..

10 CFR 50.47(b) planning standard function 6 is affected by changes associated with Items B, 16, 34, 46 and 47 of the attached matrix. These changes are described and the bases for conclusion are contained within the Revision Matrix for 50.54(q) Review of Changes, Revision 5 of EN-EP-310, ERO Notification System, attached Part II. Description and Review of Licensing Basis Affected by the Proposed Change:

The potentially affected sections of the PNPS Emergency Plan include Section E, Notification Methods and Proc~dures, and Section F, Emergency Communications.

PNPS Licensing Correspondence Logs from 1976 through 2006 and the Licensing Basis History were reviewed to determine if any commitments would be affected by the revision of the EverBridge Notification System. No commitments that were applicable were found.

These proposed changes were reviewed in consideration of changes Identified within the PNPS Emergency Plan Chronology of changes, with no identified potential impact due to the proposed changes EN-EP-310 ls excluded from the Process Applicability Review for Pilgrim Station. Review of the changes being proposed under Revision 5 to this procedure continues to support this position.

The relevant criteria or process Identified was_ the Emergency Plan (10CFR50.54(q)/EN-EP-305) review which is addressed bv this evaluation.

e NUCLEAR NON-QUALITY RELATED EN-EP-305 I REV.*4

-=-Entergy MANAGEMENT MANUAL INFORMATIONAL Use PAGE 20F4 Emergency Planning*10CFR50.54(q) Review Program ATTACHMENT 9.3 10 CFR 50.54(Q)(3) EVALUATION Procedure/Document Number: EN-EP-310 I Revision: 5 Equipment/Facility/Other: Pilgrim Nuclear Power Station

Title:

ERO Notification System SHEET20F4 Part Ill. Describe How the Proposed Change Complies with Relevant Emergency Preparedness Regulation(s) and Previous Commitment(s) Made to the NRC:

10 CFR 50.47(b)(6) - Emergency Communications; Provisions exist for prompt communications among principal response organizations to emergency personnel and the public.

Appendix E IV.D.1 & D.2 - Notification Procedures Appendix E IV.E - Emergency Facilities and Equipment Site Compliance: Through implementation of revisions identified within the attached matrix, reference to the upgraded backup notification procedure available through the EverBridge Mass Notification system is confirmed. The use of the voice method for initiating backup notification to the ERO is no longer applicable with the current version and has therefore been eliminated to ensure consistency with the upgraded electronic system.

Previous Commitments to the NRC - PNPS Emergency Plan Chronological Change listing, PNPS EP Procedure Listing and the current listing of NRC commitments associated with the PNPS EPIPs or PNPS Emergency Plan changes were reviewed for potential NRG commitment impact as a result of this procedure revision. Also, the PNPS Licensing Correspondence Logs from 1976 through 2006 and the Licensing Basis History were reviewed to determine if any commitments would be affected by the revision of this procedure. No applicable commitments were found.

Part IV. Description of Emergency Plan Planning Standards, Functions and Program Elements Affected by the Proposed Change:

10 CFR 50.47(b)(6)- Emergency Communications Provisions exist for prompt communications among principal response organizations to emergency personnel and the public.

Sections IV.D.1, IV.D.2 and VI of Appendix E to 10 CFR 50 provide supporting requirements. Informing criteria appear in Section 11.F of Nureg-0654 and the PNPS Emergency Plan.

NUCLEAR NON*QUALITY RELATED EN~EP-305 I REV.4

~Entergy MANAGEMENT MANUAL INFORMATIONAL USE PAGE 30F4 Emergency Planning 1 OCFR50.54(q) Review Program ATTACHMENT 9.3 10 CFR 50.54(Q)(3) EVALUATION Procedure/Document Number: EN-EP-310 I Revision: 5 Equipment/Facility/Other: Pilgrim Nuclear Power Station

Title:

ERO Notification System 5HEET30F4 Part V. Description of Impact of the Proposed Change on the Effectiveness of Emergency Plan Functions:

This revision to EN-EP-310 reflects the changes being made to the ERO notification process due to the fleet-wide.

transition from Everbridge Aware software to EverBridge Mass Notification software. These changes came as a result of program upgrades being made by the vendor, Everbridge, as part of an Incremental process to upgrade the system.

This change recognizes many years of experience with and observed possible improvements from the older system, with technical advancements allowing increased functionality, performance and ease of use, and new and more stable platforms. Everbridge provided detailed and supportive technical assistance during the migration of this program to ensure successful and Integrated transition and support to the program users. Everbridge advised that this transition was the final 100% of their user migration goal. While this system Is primarily used for notification of the emergency response organization, it has the ability to, and is available, to provide timely messages to employees with critical information in a variety of situations such as emergency declarations, plant issues, forced outages, storm/severe weather. Testing specific to Pilgrim Station was conducted with a Pilgrim test message programmed to notify station contacts with satisfactory results.

As with Everbridge Aware, employees maintain current contact information within their Everbr!dge data profile and receive notifications on all the devices listed in each profile. As part of the change management of this process, Employees were asked to create a username and password, set a security question, accept terms of use and update contact information, as needed. Employees continue to have the capability to set the device order when completing registration.

The Emergency Response Organization Notification (ERON) program user interface (API) used to activate the system remains the same as does the responsibility to activate the ERO notification system. No changes were made that affect when the system would be activated and Mass Notification system will be activated at the same emergency classification levels as the Aware system.

ERO members will receive notifications from Mass Notification system through various methods/paths including telephones, pagers, SMS text messages, and email as with the Aware system Items 8, 16, 34, 46 and 47 of the attached the Revision Matrix for 50.54(q) Review of Changes, Revision 5 of EN-EP-310, ERO Notification System affect planning standard function 6of10 CFR 50.47(b). The basis for conclusion for each of these Items Is Included with that matrix.

Based on the discussion and bases for conclusion, the proposed changes to EN-EP-31 O Revision 5 continue to meet the planning standards outlined in 10 CFR 50.47(b)(6). This proposed revision does not represent a reduction in the effectiveness to the emergency plan and can be incorporated without prior NRC approval.

e NON-QUALITY RELATED EN-EP*305 REV.4

-===-Entergy NUCLEAR MANAGEMENT MANUAL INFORMATIONAL USE PAGE 40F4 1 OCFRS0.54 Review Pro ram ATTACHMENT 9.3 10 CFR 50.54(a)(3) EVALUATION Procedure/Document Number: EN-EP*31 o Revision: 5 Equipment/Facility/Other: Pilgrim Nuclear Power Station

Title:

ERO Notification System SHEET40F4 Part VI. Evaluation Conclusion Answer the following questions about the proposed change.

1..

Does the proposed change comply with 10 CFR 50.47(b) and 10 CFR 50 Appendix E?

2.

Does the proposed change maintain the effectiveness of the emergency plan (I.e., no reduction In effectiveness)?

3.

Does the proposed change constitute an emergency action level scheme change?

18JYES0NO 181YES D NO DYES 181 NO If questions 1 or 2 are answered NO, or question 3 answered YES, reject the proposed change, modify the proposed change and perform a new evaluation or 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). Refer to step 5.8[8].

Part Vil. Signatures Preparer Name (Print)

Karen Larson-Sullivan (Optional) Reviewer Name (Print)

Reviewer Name (Print)

David Townsend Nuclear EP Project Manager Approver Name (Print)

Donna Calabrese Manager, Emergency Preparedness or deslgnee Date: 8//16/2016 Date:

Date:

Date:

Item 1

2 Revision Matrix for 50.54( q): Review of Changes Revision 5 of EN-EP-310, ERO Notification System Affect on 10 Editorial CFR 50.47(b)

Change Planning Planning Description of Change Section per Reg Standards or standard Basis for Conclusion Gulde NUREG 0654 affected 2.129?

program elements?

Revise "[11 Alias ID -The alias ID and associated password can contain both letters and numbers. Once This change makes use of the more established a member can accepted practice of use of use the alias member ID and "Usemame" for the login vehicle.

password to Jog in to the The definition for usemame Is more EverBridge System." to "[17]

inclusive regarding acceptable types Username - a contact will and numbers of characters to ease use this to login to the 3.0, development of the login vehicle.

EverBridge system.

Procedures, No No N/A This change does not change Intent, Usemames are case-

[1]

facilities, equipment or processes sensitive and must be a for this procedure or affect any minimum of four acceptable planning standard elements. This characters. Acceptable change does not affect the PNPS characters are: uppercase Emergency Plan. No further and lowercase letters, evaluation is required for this numbers, dash(-), and change.

underscore L). No other characters or symbols are permitted at this time.

Replace definition for This change provides a title change

"[11].Group Member-a and means of_identifying an person assigned to a group.

individual listed and assigned to a A group member may group in EverBridge. It clarifies the receive* messages, but a role of the recipient within the member may not send 3.0, program. This change does not messages or administer the Procedures, No No N/A change intent, facilities, equipment system in any way" with " [4]

[11]

or processes for this procedure or Contact - a person listed in affect any planning standard the EverBrldge database elements. This change does not that can be sent a affect the PNPS Emergency Plan.

notification and assigned to No further evaluation is required for a group(s).".

this change.

'.I of 20

Item 3

4 5

6 Revision Matrix for 50.54(q): Review of Changes Revision 5 of EN-EP-310, ERO Notification System Affect on 10 Editorial CFR 50.47(b)

Change Planning Planning Description of Change Section per Reg Standards or standard Basis for Conclusion Guide NUREG0654 affected 2.129?

program elements?

This change provides a title and Revise: "[5] Data means of identifying a subset of members who can manage material Manager-a user assigned in EverBridge. It expands the this role can only manage means of identifying elements of the contact records (add, edit, 3.0, program. This change does not and remove). Data Procedures,

  • No No NIA change intent, facilities, equipment Managers pan access

[1]

or processes for this procedure or functionality at the affect any planning standard Organization level to the I

elements. This change does not following EverBridge Suite affect the PNPS Emergency Plan.

tabs: Contacts and Reports."

No further evaluation is required for this change.

This change provides a title change only. This change does not change intent, facilities, equipment or Revise "Employee Profile" 3.0, processes for this procedure or to "Profile" and relocate Procedures, Yes No NIA affect any planning standard.

within Definitions Section

[5]

elements. This change does not affect the PNPS Emergency Plan.

No further evaluation is required for this change.

This change provides a title change only. This change does not change intent, facllltles, equipment or Revise "Group Leader" to 3.0, processes for this procedure or Procedures, Yes No NIA affect any planning standard "Data Manager"

[10]

elements. This change does not affect the PNPS Emergency Plan.

No further evaluation is required for

\\

this change.

This change provides a title change only. This change does not change intent, facilities, equipment or 3.0, processes for this procedure or Revise "person" to "user" Procedures, Yes No NIA affect any planning standard

[10]

elements. This change does not affect the PNPS Emergency Plan.

No further evaluation is required for this change.

2of20

Item 7

8 9

Revision Matrix for 50.54(q): Review of Changes Revision 5 of EN-EP-310, ERO Notification System Affect on 10 Editorial CFR 50.47(b)

Change Planning Planning Description of Change Section per Reg Standards or standard Basis for Conclusion Guide NUREG0654 affected 2.129?

program elements?

This change reflects the new terminology for positions within the document itself. This change does not change intent, facilities, Remove definition for "Group 3.0, equipment or processes for this Member.

Procedures, No No N/A procedure or affect any planning

[11]

standard elements. This change does not affect the PNPS Emergency Plan. No further I

evaluation is_ required for this change.

YES -10 CFR 50.47(b) planning standard function 6 in Part V of the screening form is affected by this change. A 10CFR50.54(q) evaluation is performed to Replace definition for determine whether or not the "Interactive Voice Response 3.0, effectiveness of the emergency plan (IVR)" with definition for Procedures, No Yes 6

is reduced and prior NRC approval "Launch Notification by (12]

is required. This changes reflects Phone (LBP)"

the new means of conveying the backup EverBridge communication capability via phone initiation/template versus voice interactive Issuance. See Item 46 for detailed evaluation of this new capability.

This change makes use of the more accepted practice of use of "Username" for the login vehicle.

The definition for username is more inclusive regarding acceptable types and numbers of characters to ease Replace definition for 3.0, development of the login vehicle.

"Member ID" with Procedures, No No NIA This change does not change intent, "Username"

[13]

facilities, equipment or processes for this procedure or affect any planning standard elements. This change does not affect the PNPS Emergency Plan. No further evaluation is required for this change.

3of20

Item 10 11 12 Revision Matrix for 50.54( q): Review of Changes Revision 5 of EN-EP-310, ERO Notification System Affect on 10 Editorial CFR 50.47(b)

Change Planning Planning Description of Change Section per Reg Standards or standard Basis for Conclusion Guide NUREG 0654 affected 2.129?

program elements?

This change provides a title change only. This change does not change intent, facilities, equipment or Revise "Leader" to 3.0 [14), 4.0 processes for this procedure or Yes No N/A affect any planning standard "Administrator"

[4]

elements. This change does not affect the PNPS Emergency Plan.

No further evaluation Is required for this change.

This addition to the Site EverBridge Rep provides greater clarity in the existing responsibilities of the Add "Site EverBridge Rep EverBridge site administrators.

for each site will maintain all This change does not change intent, groups used by the 4.0[3]

No No N/A facilities, equipment or processes EverBridge system and the for this procedure or affect any ERON Program for their planning standard elements. This respective site" change does not affect the PNPS Emergency Plan. No further evaluation is required for this change.

This addition to the Site EverBridge Add "Organization Rep provides greater clarity in the Administrators are responsibilities of the EverBridge responsible for overall site administrators and embraces administration of ERON and the new terms for Mass Notification EverBridge Mass and Users. This change does not Notification. They are 4.0 [5]

No No N/A change intent, facilities, equipment responsible for creating or processes for this procedure or Roles in EverBridge Mass affect any planning standard Notification and assigning elements. This change does not Users to the appropriate affect the PNPS Emergency Plan.

roles."

No further evaluation Is required for this change.

4 of20

Item 13 14

~---------------

Revision Matrix for 50.54(q): Review of Changes Revision 5 of EN-EP-310, ERO Notification System Affect on 10 Editorial CFR 50.47(b)

Change Planning Planning Description of Change Section per Reg Standards or standard Basis for Conclusion Guide NUREG0654 affected 2.129?

program elements?

The addition of the word "ERON" is an editorial change which reinforces the ERON title in the notification process. This change does not Add "ERON" 5.3, 5.3[1],

Yes No change intent, facilities, equipment 5.3[5], 5. 7[5]

N/A or processes for this procedure or affect any planning standard elements. This change does not affect the PNPS Emergency Plan.

No further evaluation is required for this change.

Add: "NOTE: Control of This Note is an editorial relocation ERON access codes and of wording from Section 5.3 [4].

pass codes for Individual This change does not change Intent, facilities and events ensures facilities, equipment or processes that the ERO Notification 5.3[4]

Yes No N/A for this procedure or affect any System Is not Inadvertently planning standard elements. This activated and does not send change does not affect the PNPS unintended or Incorrect Emergency Plan. No further event notifications."

evaluation is required for this change.

5of20

Item

)

15 15 cont.

Revision Matrix for 50.54(q): Review of Changes Revision 5 of EN-EP-310, ERO Notification System Affect on 10 Editorial CFR 50.47(b}

Change Planning Planning Description of Change Section per Reg Standards or standard Basis for Conclusion Guide NUREG0654 affected 2.129?

program elements?

Revise "For example, the Access code and pass code for a Drill event forces the system into a configuration that modifies the outgoing message with a header stating "This is a DRILL" and This wording ls revised for ease of ONLY sends the notification

/

reading in the use of the access and to the recipients who are pass codes to appropriately send members of the Drill Group out the correct message, no change for the specific facility was made to responsibilities or associated with that access actions in the process. This code and pass code.

5.3[4]

No No N/A change does not change intent, Therefore, it is difficult to facilities, equipment or processes inadvertently send an for this procedure or affect any incorrect notification to an planning standard elements. This incorrect group of recipients change does not affect the PNPS if a user has only the correct Emergency Plah. No further access code and pass evaluation Is required for this code." to "[4] The ERON change.

Access code and pass code for events (Emergency, Drill, Test, Training) configures the system into the proper mode, adds the proper header to the message (i.e. This is a DRILL, This is a Test) and sends the notification to the proper Group for the specific facility associated with that ERON access code and pass code.

II

/

6of20

Item 16 17 18 19 Revision Matrix for 50.54(q): Review of Changes Revision 5 of EN-EP-310, ERO Notification System Affect on 10 Editorial CFR 50.47(b)

Change Planning Planning Description of Change Section per Reg Standards or standard Basis for Conclusion Guide NUREG0654 affected 2.129?

program elements?

YES -10 CFR 50.47(b) planning standard function 6 in Part V of the screening form is affected by this change. A 10CFR50.54(q)

Add: "(a) Bulld notification evaluation is performed to templates under the determine whether or not the Notification Tabo Notification effectiveness of the emergency plan Template for all possible is reduced and prior NRC approval messages to be launched by is required. This new section telephone. Messages should 5.5[1](a)

No Yes 6

introduces the intent of Section 5.5 be developed for to develop templates needed for Emergency, Drill, Test and use in the alternate notification Training modes. Each method. This change reflects the message Is assigned a new means of conveying the backup unique Template ID."

EverBridge communication capability via phone initiation/template versus voice I

interactive issuance. See Item 46 for detailed evaluation of this new capability.

This change provides a title change and numbering change only.This Revise "member ID" to "role" and Section "5.10" to "5.16" 5.5(a)

Yes No N/A change does not affect the PNPS Emergency Plan. No further evaluation is required for this change.

This change provides a title change 5.5(b}, (c),

Revise "member ID" to only.This change does not affect the "user" (d), and Yes No N/A PNPS Emergency Plan. No further NOTE evaluation is required for this change.

This added wording clarifies the intent of assigning individual roles and uses Grand Gulf as an example Add: "and assigned a to clarify the activity.This change corresponding role (i.e. User does not change intent, facilities,

- GGNS Emergency should 5.5. c No No NIA equipment or processes for this be assigned the GGNS procedure or affect any planning Emergency Role, etc.)."

standard elements. This change does not affect the PNPS Emergency Plan. No further evaluation is required for this change.

7 of20

Item 20 21 22 Revision Matrix for 50.54(q): Review of Changes Revision 5 of EN-EP-310, ERO Notification System Affect on 10 Editorial CFR 50.47(b)

Change Planning Planning Description of Change Section per Reg Standards or standard Basis for Conclusion Guide NUREG 0654 affected 2.129?

program elements?

This wording is revised to reflect the Revise "email the new wording/titles and abbreviated authorization codas to the instruction replacing the former members in accordance with Section 5.15. This clarifies the section 5.15 of this guidance in reference to the new procedure." to "send the activity. This change does not registration email to the Site 5.5(d)

No No NIA change intent, facilities, equipment or processes for this procedure or EverBridge Reps by clicking affect any planning standard on the envelope under the elements. This change does not "Registered" tab in User's affect the PNPS Emergency Plan.

list."

No further evaluation is required for this change.

This revision provides greater clarity on the information that is needed to Revise "(f) Print a copy for be saved and updated to reflect the your records when you finish current program.This change does registering the members." to*

not change intent, facilities,

"(g) Record the User Name 5.5 (f)

No No NIA equipment or processes for this and password and th:S procedure or affect any planning Launch Notification by standard elements. This change Phone User ID and does not affect the PNPS Password for your records."

Emergency Plan. No further evaluation is required for this change.

The assignment of contacts to a Remove: "(h) Enterthe group is now found at a new section members created above into 5.13, "Adding Contracts to a Group".

the appropriate Group as a This change removes redundancy Group Leader in accordance and corrects the procedure to reflect with section 5.13 (i.e.

the new process.This change does Member ID GGNS 5.5(h)

No No NIA not change intent, facilities, Emergency as a Group equipment or processes for this Leader for GGNS-procedure or affect any planning Emergency Group, Member standard elements. This change ID IPEC Drlll as a Group does not affect the PNPS Leader for IPEC-Drill Group, Emergency Plan. No further etc.)."

evaluation is required for this change.

8 of20

Item 23 24 25 Revision Matrix for 50.54(q): Review of Changes Revision 5 of EN-EP-310, ERO Notification System Affect on 10 Editorial CFR 50.47{b)

Change Planning Planning Description of Change Section per Reg Standards or standard Basis for Conclusion Guide NUREG 0654 affected 2.129?

program elements?

Replace; "(I) Passwords for these Member IDs can be This change reflects the new reset I changed in terminology for positions and accordance with section relocates the process of changing 5.16." with "(i) Passwords for passwords within the document these User IDs can be itself. This change supports the changed by logging in as the changes in the new program while User, clicking on the User's maintaining the ability to reset name in upper right hand 5.5(i)

No No N/A passwords, a well-used function of corner of the screen and the mission.This change does not then clicking on the Change change intent, facilities, equipment Password link and the or processes for this procedure or password for Launch affect any planning standard Notification by Phone can be elements. This change does not changed by clicking on affect the PNPS Emergency Plan.

Launch Notification by No further evaluation is required for Phone tab and then clicking this change.

on the Change Password" This change reflects the transition from EverBrldge Aware to EverBrldge Mass Notification and is a title change only.This change does not change intent, facilities, Delete: "Aware" 5.7[2](a),

Yes No N/A equipment or processes for this 5.8[4]

procedure or affect any planning standard elements. This change does not affect the PNPS Emergency Plan. No further evaluation is required for this change.

This change reflects the transition from EverBridge Aware to EverBridge Mass Notification and Is a title change only.This change does not change intent, facilities, Change "Aware" to "Mass 5.7[6], 5.8[5],

Yes No N/A equipment or processes for this Notification" 5.9[1]

procedure or affect any planning standard elements. This change does not affect the PNPS Emergency Plan. No* further evaluation is required for this change.

9 of20

Item 26 27 28 Revision Matrix for 50.54(q): Review of Changes Revision 5 of EN-EP-310, ERO Notification System Affect on 10 Editorial CFR 50.47(b)

Change Planning Planning Description of Change Section per Reg Standards or standard Basis for Conclusion Guide NUREG 0654 affected 2.129?

program elements?

This change reflects the transition from EverBridge Aware to EverBridge Mass Notification and is a title change only.This change does not change intent, facilities, Change "Broadcast reports" 5.7[6]

Yes No NIA equipment or processes for this to "Notification report" procedure or affect any planning standard elements. This change does not affect the PNPS Emergency Plan. No further evaluation is required for this change.

This change reflects the transition from EverBridge Aware to EverBridge Mass Notification and is a title change only.This change does not change Intent, facilities, Change "member" to 5.8[2]

Yes No NIA equipment or processes for this "contact" procedure or affect any planning standard elements. This change does not affect the PNPS Emergency Plan. No further evaluation is required for this change.

This is an administrative change of Revise "an email with wording to ease reading of this instructions on how to section and reference to the use of register with their instructions available for registration Authorization Code and purposes. This change does not Member ID" to "an email 5.8[2]

No No NIA change intent, facilities, equipment using the Everbridge system or processes for this procedure or which contains the affect any planning standard instructions on how to elements. This change does not register in the system."

affect the PNPS Emergency Plan.

No further evaluation is required for this change.

10 of 20

Item 29 30 31 Revision Matrix for 50.54(q): Review of Changes Revision 5 of EN-EP-310, ERO Notification System Affect on 10 Editorial CFR 50.47(b)

Change Planning Planning Description of Change Section per Reg Standards or standard Basis for Conclusion Gulde NUREG0654 affected 2.129?

program elements?

This change reflects the changes to the existing program which removed "Alias" references and to ensure accurate reference to individual employee profile information. This Revise "numeric password, change does not change intent, Alias ID, Alias Password" to 5.8{2]

No No NIA facilities, equipment or processes "usemame and password" for this procedure or affect any planning standard elements. This change does not affect the PNPS Emergen<?Y Plan. No further evaluation is required for this change.

This is an administrative change of wording to ease reading OT this section and reference to the use of appropriate Instructions needed for registration purposes. This change does not change Intent, facilities, Add: "pertinent" 5.8[2]

No No N/A equipment or processes for this procedure or affect any planning standard elements. This change does not affect the PNPS Emergency Plan. No further evaluation is required for this change.

Revise: "ERO members must provide an office telephone number, pager This change reorganizes the number (if provided by the required information that is to be company), company email entered Into EverBridge Into a address and Home structured format to ease readability telephone or cellular and to update the information to telephone number at a reflect current configurations. This minimum; Employees with 5.8[3]

No No NIA change does not change intent, an Alpha pager must enter facilities, equipment or processes the pager number as an for this procedure or affect any email address (Pager planning standard elements. This Number@PagerService.net change does not affect the PNPS or.com) (e.g.

Emergency Plan. No further 8005551212@usamobiltiy.n evaluation is required for this etor8005551212@

change.

pageme.teletouchpaging.co m)" to 11 of20

Item 31, cont.

32 33 Revision Matrix for 50.54(q): Review of Changes Revision 5 of EN-EP-310, ERO Notification System Affect on 10 Editorial CFR 50.47(b)

Change Planning Planning Description of Change Section per Reg Standards or standard Basis for Conclusion Guide NUREG 0654 affected 2.129?

program elements?

"ERO members must provide the following:

{a) Office telephone number

{If Individually assigned.

Shops numbers, control room numbers, shared numbers, etc. do not have to be listed)

(b) ERO Notification device (Pager number, Cell phone numbers, etc.)

(c) Company email address (d) Home telephone or cellular telephone number (e) Employees with an Alpha pager must enter the pager number as an email address (Pager Number@Pager Service.net or.com) (e.g.

8005551212@usan:iobiltiy.n etor8005551212@

pageme.criticalalert.com)

This is a rewording to ease readability, only. This change does not change intent, facilities, Revise "[4] A scheduled equipment or processes for this message should be 5.8[4]

No No N/A procedure or affect any planning broadcast " to "[4] A standard elements. This change notification should be sent" does not affect the PNPS Emergency Plan. No further evaluation is required for this change.

This change clarifies that the unique identifier ID being suggested for use is their Entergy Employee ID number. This change does not change intent, facilities, equipment Add "(External ID)"

5.8[5]

No No N/A or processes for this procedure or affect any planning standard elements. This change does not affect the PNPS Emergency Plan.

No further evaluation Is required for this change.

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~

Item 34 35

--~---------------------------------

Revision Matrix for 50.54(q): Review of Changes Revision 5 of EN-EP-310, ERO Notification System Affect on 10 Editorial CFR 50.47(b)

Change Planning Planning Description of Change Section per Reg Standards or standard

_ Basis for Conclusion Guide NUREG0654 affected 2.129?

program elements?

YES -10 CFR 50.47(b) planning standard function 6 in Part V of the screening form is affected by this change. A 10CFR50.54(q) evaluation is perfonned to determine whether or not the effectiveness of the emergency plan Revise "Non-Entergy is reduced and prior NRC approval personnel added to the is required. This change to the system will not have a process provides a specific unique identifier." to "Non-5.8(5]

No Yes 6

identifying number/process for each Entergy personnel added to non-Entergy person assigned to the the system will be assigned system. This ensures that all a unique identifier (minimum individuals have specific and unique 6 digit numeric number)."

attributes to which they can be identified, providing increased control over the system. This change does not affect the PNPS Emergency Plan. No further evaluation is required for this change.

This change updates the email address of the EverBrldge Mass Notification site from the internet browser. This change does not Revise "www.everbridge.net" change intent, facilities, equipment to 5.9(1)

No No N/A or processes for this procedure or "https://manager.everbrldge.

affect any planning standard net/login".

elements. This change does not affect the PNPS Emergency Plan.

No further evaluation is required for this change.

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' Item 36 37 Revision Matrix for 50.54(q): Review of Changes Revision 5 of EN-EP-310, ERO Notification System Affect on 10 Editorial CFR 50.47(b)

Change Planning Planning Description of Change Section per Reg Standards or standard Basis for Conclusion Guide NUREG 0654 affected 2.129?

program elements?

Multiple changes were made to the procedural steps to reflect the changes to the new system, including title changes, order of actions, and title/position of field selections. These changes update the guidance to reflect the updated Revisions to "5.9 Updating program, and the intent of the Individual Member Contact 5.9 No No NIA actions remain the same. This Information" charige does not change intent, facilities, or equipment for this procedure or affect any planning standard elements. This change does not affect the PNPS Emergency Plan. No further evaluation is required for this change.

Multiple changes were made to the procedural steps to reflect the changes to the new system, including title changes, order of actions, and title/position of field selections. These changes update the guidance to reflect the updated Revise "5.10, Adding program, and the intent of the Individual Members into the 5.1 No No N/A actions remain the same. This Everbridge System" change does not change intent, facilities, or equipment for this procedure or affect any planning standard elements. This change does not affect the PNPS Emergency Plan. No further evaluation is required for this change.

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Item 38 39 Revision Matrix for 50.54(q): Review of Changes Revision 5 of EN-EP-310, ERO Notification System Affect on 10 Editorial CFR 50.47(b)

Change Planning Planning Description of Change Section per Reg Standards or standard Basis for Conclusion Guide NUREG0654 affected 2.129?

program elements?

\\

Multiple changes were made to the procedural steps to reflect the changes to the new system, including title changes, order of actions, and title/position of field selections. These changes update the guidance to reflect the updated Revise "5.11, Removing program, and the intent of the Individual Members into the 5.11 No No NIA actions remain the same. This Everbridge System" change does not change intent, facilities, or equipment for this procedure or affect any planning standard elements. This change does not affect the PNPS Emergency Plan. No further evaluation is required for this change.

According to the site EverBridge SME, this section is redundant to the procedure, as the act of adding or change personnel information

)

within the groups is contained in the individual sections. Therefore, Remove: "5.12, Group removing this section was removing Personnel Roster 5.12 No No NIA redundancy in the procedure. This Additions/Changes" change does not change intent, facilities, or equipment for this procedure or affect any planning standard elements. This change does not affect the PNPS

' )

Emergency Plan. No further evaluation is required for this change.

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Item 40 41 Revision Matrix for 50.54( q): Review of Changes Revision 5 of EN-EP-310, ERO Notification System Affect on 10 Editorial CFR 50.47(b)

Change Planning Planning Description of Change Section per Reg Standards or standard Basis for Conclusion Guide NUREG 0654 affected 2.129?

program elements?

Multiple changes were made to the procedural steps to reflect the changes to the new system, Including title changes, order of actions, and title/position of field selections. These changes update Revise: "5.13, Adding the guidance to reflect the updated Groups and program, and the intent of the Members/Leaders to the 5.13 No No NIA actions remain the same. This Groups" to "5.13 Adding change does not change intent, Contacts to Groups" facilities, or equipment for this procedure or affect any planning standard elements. This change does not affect the PNPS Emergency Plan. No further evaluation is required for this change.

Multiple changes were made to the procedural steps to reflect the changes to the new system, Including title changes, order of actions, and title/position of field selections. These changes update the guidance to reflect the updated Revise: "5.14, Deleting program, and the intent of the 5.14 No No N/A actions remain the same. This Group Members" change does not change intent, facilities, or equipment for this procedure or affect any planning standard elements. This change does not affect the PNPS Emergency Plan. No further evaluation Is required for this change.

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Item 42 43 44 Revision Matrix for 50.54(q}: Review of Changes Revision 5 of EN-EP-310, ERO Notification System Affect on 10 Editorial CFR 50.47(b)

Change Planning Planning Description of Change Section per Reg Standards or standard Basis for Conclusion Guide NUREG 0654 affected 2.129?

program elements?

Multiple changes were made to the procedural steps to reflect the changes to the new system, including title changes, order of actions, and title/position of field selections. These changes update Revise: "5.15, Emailing the guidance to reflect the updated Authorization Codes to program, and the intent of the Members" to "Emailing 5.15 No No N/A actions remain the same. This Registration Request to change does not change intent, Contacts" facilities, or equipment for this procedure or affect any planning standard elements. This change does not affect the PNPS Emergency Plan. No further evaluation is required for this.

change.

This section* was removed as redundant since this information is now covered in the wording of the document under 5.5(i).This change Remove "5.16 Changing a does not change intent, facilities, or Members Password" 5.16 No No NIA equipment for this procedure or

  • affect any planning standard elements. This change does not affect the PNPS Emergency Plan.

No further evaluation is required for this change.

This section provided instruction in the new software program for creating roles in the system and guides the activity of this identified element. This change does not Add new "5.16 Creating New5.16 No No NIA change intent, facilities, or Roles in Mass Notification" equipment for this procedure or affect any planning standard I

elements. This change does not affectthe PNPS Emergency Plan.

No further evaluation is required for this change.

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Item 45 46 Revision Matrix for 50.54(q): Review of Changes Revision 5 of EN*EP-31 o*, ERO Notification System Affect on 10 Editorial CFR 50.47(b)

Change Planning Planning Description of Change Section per Reg Standards or standard Basis for Conclusion Guide NUREG 0654 affected 2.129?

program elements?

This section provided instruction in the new software program for creating Users in the system and

  • guides the activity of this identified element. This change does not Add new "5.17 Creating New 5.17 No No N/A change Intent, facilities, or Users in Mass Notification" equipment for this procedure or affect any planning standard elements. This change does not affect the PNPS Emergency Plan.

No further evaluation is required for this change.

YES -10 CFR 50.47(b) planning standard function 6 in Part V of the screening form is affected by this change. A 10CFR50.54(q) evaluation is performed to determine whether or not the effectiveness of the emergency plan is reduced and prior NRC approval is required. This revised Attachment proceduralizes the intent to develop templates needed for use in the alternate notification method. This I

change reflects the new means of conveying the backup EverBridge.2 Alternate communication capability via phone ERO Notification System Attachment No Yes 6

initiation/template versus voice 9.2 interactive issuance and was Activation Instructions rewritten to envelope the new preforrnatted feature of the backup notification process under EverBridge Mass Notification. The change maintains the need for a member/user ID and Password numbers to maintain control of entry into the system. Also consistent is the use of the identical decision flowchart for determining which message should be conveyed to the ERO based on ECL, additional support, conditions warranting activation of alternate facilities, and Security event.

18 of 20

Revision Ma~rix for 50.54(q): Review of Changes Revision 5 of EN-EP-310, ERO Notification System Affect on 10 Editorial CFR 50.47(b)

Change Planning Planning Item Description of Change Section per Reg Standards or standard Basis for Conclusion Guide NUREG 0654 affected 2.129?

program elements?

However, where the former system required the actual reading and

\\J recording of the message to be sent from a flowchart and the audio review and pctential re-recording of the message, the new procedure provides the rapid determination of the message to be sent via identification of a 4 digit number and an automated distribution of the message without the need to verbalize the message over the phone. Although Revision 5 cautions of a latent time for the 46 system to access the templates that cont.

"May take up to 30-45 seconds",

discussion with the procedure writer confirmed that the actual time for accessing the templates is observed at between 15-20 seconds, with the reference to 30-45 seconds used to ensure confidence in continuation of the computer messaging sequence.

Use of the new digital system removes the chance for background noise and alarms to be caught on the recording, thereby causing potential audibility challenges and need for re-recording of the message, and provides expanded delivery to text 19 of 20

J' Item 46 cont.

47 Revision Matrix for 50.54(q): Review of Changes Revision 5 of EN-EP-310, ERO Notification System Affect on 10 Editorial CFR 50.47{b)

Change Planning Planning Description of Change Section per Reg Standards or standard Basis for Conclusion Guide NUREG 0654 affected 2.129?

program elements?

and email devices not available in the prior system, thereby Improving the overall delivery capability.

The changes made to the Alternate, or backup, Everbridge notification method ensures that the delivered message appears and sounds exactly as the primary method to the message recipient. The use of message template confirmation versus repetition of the full message content facilitates rapid issuance of the message. Pilgrim Procedure EP IP-100, Emergency Classification and Notification, has incorporated a Pilgrim-specific Everbridge Template listing and Everbridge Activation Message Content listing to maintain visual presentation of the specific messages to be initiated. This change does not affect the PNPS Emergency Plan.

No further evaluation is required for this change.

YES -10 CFR 50.47{b) planning standard function 6 in Part V of the screening form is affected by this change. A 10CFR50.54(q) evaluation is performed to determine whether or not the effectiveness of the emergency plan is reduced and prior NRC approval is required. Multiple changes were.4 Quarterly Attachment made to the procedural steps to Member Profile Update 9.4 No Yes 6

reflect the changes to the new system, including title changes, order of actions, and title/position of field selections. These changes update the guidance to reflect the updated program, and the intent of the actions remain the same. This change does not affect the PNPS Emergency Plan. No further evaluation Is required for this change.

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