ML17130A713

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Report of Change and Summary of 50.54(q) Analysis - Emergency Plan Implementing Procedure 5.7.6, Revision 69
ML17130A713
Person / Time
Site: Cooper Entergy icon.png
Issue date: 05/04/2017
From:
Nebraska Public Power District (NPPD)
To:
Office of Nuclear Reactor Regulation
References
NLS2017049 EPIP 5.7.6, Rev 69
Download: ML17130A713 (29)
v • d • e


Text

NLS2017049 Attachment Page 1 of3 Attachment Report of Change and Summary of 50.54(q) Analysis -Emergency Plan Implementing Procedure

5. 7.6, Revision 69 Change Description Emergency Plan Implementing Procedure (EPIP) 5.7.6, Attachment 1 and 3 flowcharts, were revised (boxes SC-14 and OFS-14) to add steps for completing the notification.

Also the EPIP had previously allowed the user to inappropriately skip Step 3 of Attachment 5 for recording meteorological conditions and release status information when completing the notification report. This step was inadvertently omitted during a previous rewrite of the procedure and has been corrected and again is a requirement for completing the notification with CNS-DOSE unavailable.

Change Summary of Analysis (10 CFR 50.54(q) evaluation)

Licensing Basis Affected by Change: Cooper Nuclear Station (CNS) Emergency Plan (E-Plan), Section 6.3.3 discusses that CNS has the capability of performing dose projections during a radiological emergency using two separate techniques.

The section provides additional description of the dose assessment methods, DOSE (computerized) and hand calculation (manual), and further discussion on the field monitoring teams. E-Plan Section 3.5 discusses that the Emergency Response Organization is responsible for on-site emergency operations and for maintaining a continuous flow of accurate radiological and station status information to off-site emergency authorities.

E-Plan Sections 4.1.2.2, 4.1.3 .2, and 4.1.4.1 provide discussion on actions taken at an Alert, Site Area Emergency, and General Emergency declaration.

E-Plan Section 5.1.2.6 discusses that the Shift Communicator is responsible for off-site communication duties. E-Plan Section 5.2.3.3 discusses that the Off-Site Communicator is responsible for gathering and disseminating information to appropriate Off-Site Agencies in accordance with EPIP 5.7.6. E-Plan Section 6.2.4 provides discussion on initial and follow-up notifications to off-site authorities and support agencies.

E-Plan Section 7.2.3 describes the functions of the Emergency Operations Facility in Auburn, Nebraska.

The functions include management of off-site emergency response, coordination of radiological/environmental assessrrient, coordination of emergency response activities with Federal, State, and local agencies, determination of protective actions for the public, event classification, and notification to off-site authorities.

E-Plan Section 7.4 provides more detail on each emergency classification and the notifications made.

NLS2017049 Attachment Page 2 of3 How Change Complies with Regulations and Previous Commitments:

10 CFR 50.47(b)(5) requires procedures have been established for notification of State and local response organizations and for notification of emergency personnel by all organizations; the content of initial and follow-up messages to response organizations and the public has been established; and means to provide early notification and clear instruction to the populace within the plume exposure pathway emergency planning zone have been established.

10 CFR 50.47(b)(9) requires methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use. 10 CFR 50, Appendix E, Section IV.B.l, requires that the means to be used for determining the magnitude of, and for continually assessing the impact of, the release of radioactive materials shall be described, including emergency action levels that are to be used as criteria for determining the need for notification and participation oflocal and State agencies, the Commission, and other Federal agencies, and the emergency action levels that are to be used for determining when and what type of protective measures should be considered within and outside the site boundary to protect health and safety. 10 CFR 50, Appendix E, Section N.E.2, requires adequate provisions are made and described for emergency facilities and equipment including equipment for determining the magnitude of and for continuously assessing the impact of the release of radioactive materials to the environment.

10 CFR 50, Appendix E, Section N.D.l, requires administrative and physical means for notifying local, State, and Federal officials and agencies and agreements reached with these officials and agencies for the prompt notification of the public and for public evacuation or other protective measures, shall be described.

10 CFR 50, Appendix E, Section IV.D.3, requires licensees to have the capability to notify responsible State and local governmental agencies within 15 minutes after declaring an emergency.

The licensee shall demonstrate that the appropriate governmental authorities have the capability to make a public alerting and notification decision promptly on being informed by the licensee of an emergency condition.

The change to EPIP 5.7.6 continues to comply with the above regulatory requirements.

Commitments related to ensuring appropriate local governments are properly informed in the event of an emergency at CNS were reviewed.

The change to the EPIP continues to comply with those commitments.

Affected Emergency Planning Functions/Impact on Effectiveness of Emergency Planning Functions:

10 CFR 50.47(b )(5); Function -Procedures for notification of State and local governmental agencies are capable of alerting them of the declared emergency within 15 minutes after the declaration ofan emergency and providing follow-up notifications.

l NLS2017049 Attachment Page 3 of3 10 CFR 50.47(b)(9);

Function -Methods, systems, and equipment for assessment of radioactive releases are in use. The change corrects gaps in procedure steps to complete the notification process. The change does not adversely impact the capability or method to perform accurate and timely dose assessments or notification to State and local agencies.

The proposed changes do not constitute a reduction in effectiveness of the CNS E-Plan and will continue to meet E-Plan requirements and formal commitments to the Nuclear Regulatory Commission.

Other Changes Various editorial changes were also made to EPIP 5.7.6 which did not require a full IO CFR 50.54( q) evaluation.

NLS2017049 Enclosure Page 1 of26 Enclosure Emergency Plan Implementing Procedure

5. 7.6, Revision 69 A Operations Manual Emergency Preparedness EMERGENCY PLAN IMPLEMENTING PROCIEDURE

5.7.6 NOTIFICATION

Leve! of Use: MULTIPLE Quality: QAPD RELATED Effective Date: 4/13/17 Approval Authority:

ITR-RDM !Procedure Owner: EMERGENCY PREP DRILL SCEN COORD PROCEDURE

5.7.6 REVISION

69 PAGE 1 OF 25 TABLE OF CONTENTS 1.

  • ENTRY CONDITIONS (REFERENCE USE) ....................................................

3 2. INSTRUCTIONS (REFERENCE USE) ..........................................................

3 ATTACHMENT 1 SHIFT COMMUNICATOR FLOWCHART (REFERENCE USE) ... 4 ATTACHMENT 2 EOF OFF-SITE COMMUNICATOR FLOWCHART (REFERENCE USE) .........................................................

5 ATTACHMENT 3 OFF-SITE NOTIFICATION FROM EOF FLOWCHART (REFERENCE USE) ........................................................

6 ATTACHMENT 4 . COOPER NUCLEAR STATION NOTIFICATION REPORT (INFORMATION USE)©5 ................................................

7 ATTACHMENT 5 COMPLETING NOTIFICATION REPORT WITH CNS-DOSE NOT AVAILABLE (INFORMATION USE)1 ...............**..*.....

8 ATTACHMENT 6 AGENCY NOTIFICATION RECORD AND TURNOVER SHEET (INFORMATION USE) ........................................

13 ATTACHMENT 7 ALTERNATIVE CONTACT METHODS (INFORMATION USE) .........................................................................

17 ATTACHMENT 8 INFORMATION SHEET (INFORMATION USE) ...................

19 PROCEDURE

5.7.6 REVISION

69 PAGE 2 OF 25

1. ENTRY CONDITIONS (REFERENCE USE) 1.1 EAL dedared a*nd notification required per EPIP 5. 7 .2. 2. INSTRUCTIONS (REFERENCE USE) 2.1. IF Off-Site Communicator reporting to EOF, THEN PERFORM Attachment 2 to assume off-site communication role. 2.2 Emergency Director (ED) DIRECTS that Notification Report be prepared.© 9 2.2.1 IF Shift Communicator directed to initiate Notification Report from Control Room, THEN PERFORM Attachment
1. 2.2.1.1 WHEN TSC ENS Communicator and EOF Off-Site Communicator ready to transfer communication responsibilities, THEN Shift Communicator:
  • PERFORM Attachment 6, Section 6.
  • INFORM Shift Manager/ED.

2.2.2 IF Off-Site Communicator directed to initiate Notification Report from Emergency Off-Site Facility (EOF), THEN PERFORM Attachment

3. PROCEDURE
5. 7. 6 REVISION 69 PAGE 3 OF 25 ATTACHMENT 1 SHIFT COMMUNICATOR FLOWCHART (REFERENCE USE) ATIACHMENT 1 SHIFT COMMUNICATOR FLOWCHART (REFERENCE USE) SHIFT COMMUNICATOR FLOWCHART CCOPERNUCl.E.Q.RSTATION OPEAAnONSt.t:WlUU.

s HI FT EldERGENCY Pl.AN NOTE 1 Initial Notification to state/local agencies SHAU. be completed within 15 min. after dedaration of EAL .QC a change in Protective Action Recommendations (PARs). ©2-4 CONTINUOUSLY EVALUATE THROUGHOUT EVENT lE any difficulties or delays in completing offsite notification occur; lE airborne radioactive release rate exceeds NOLIE limits, IE communication lost to one or more stateflocal agencies during transmlttal of notification, lE Alternate means for state .aad local communication required, COMM

-1 I. OBTAIN Dose Assessment from Dose Assessor.

2. COMPLETE Seal on 10 Rad Release of Notification Report .If not Included on Initial Notification.
3. PERFORM 121 immediate follow-up notification to state/local.
1. COMPLETE commun;cation with cema;ning on-line parties. -----2. INITIATE contact with absent agency to complete communication.

PERFORM Att-7 to establish alternate communication.

IE event terminated,

  • Dose Assessor PROVIDE Dose Assessment, .. REPLICATE dose assessment into notification portion of CNS-Dose lE Dose Assessment inacrurate, lliElll'
  • RE-PERFORM Dose Assessment .
  • COMPLETE notification

@ report (Att-4) manually per Att-5. ENSURE completeness:

  • VERIFY correct Event Type In ReP.Ort Header; Emergency orDnll.
  • PRINT name and call back number (extension 4511) on Notification Re ort Block 1. OBTAIN ED review .and add remarks on Section 9, as appropriate:
  • IE dose projections at IO miles are <!:!REM TEDE or 2:.SREM COE, lliElll 1. ENTER "Projected dose at or beyond 10 miles exceed evacuation criteria.
2. RECOMMEND evacuation (or shelter if impediments exist) in sectors out to 15 miles" as detennined by EPIP 5.7.20. Dose Assessment .Qt2t1mlaL YES COMPLETE Notification Report:
  • PRESS DOSE on IDT keyboard.
  • SELECT "F4'" .Q.C"NOtify Only." *ANSWER GE questtcn(s).
  • ENTER remaining notification

@ PROCEDURE

5. 7. 6 NOTE2 PAR changes do not affect Emergency Declaration Time. IE Dose Assessment inacrurate, Il:!.EN PERFORM one of followlng:
  • GOTO Im
  • COMPLETE notification

@ report {Att-4) manualiy per Att-5. lf Dose Assessment accurate, Il::LEN PERFORM following:

  • SELECT "F3" or "Results"'
  • ENTER remaining notification information.
  • SELECT "FS'" to print. SCAN .a.ad SEND Notification Report to SNET: I. PLACE report face up in document feeder. 2. SELECT Scan .mi;! Send fearure. 3. PRESS One Touch. 4. PRESS SNET. 5. PRESS OK. 6. PRESS Green START button. COMPLETE saipted message to State/Local agencies per Att-6:
  • USE Step l lf initial notification for EAL dedaration
  • USE Step 2 if PAR dlange notification.
  • RECORD time of first ager.cy on line on Att-6, Step 3.I
  • COMMUNICATE Att-6, scripted message to each State/LOcal agency:
  • RECORD names aad. times on Att-6 Table I. lf emailed notification report ruitreceived, Itl..B!il CALL eadl missed agency directly:
  • DIRECT agency to obtain blank notification report.
  • READ notification report line-by-line to eadl missed State/Local agency
  • RECORD names an.d times on Att-6, Table l. .. USE Alternate means of communication per Att-7, if necessary.

IE any state/local agency liQI on Initial EAL or PAR dlange notificalion call, I!:::1fN, CALL missed agency directly:

  • USE Alternate means of communication per Att-7, if necessary.
  • COMMUNICATE Att-6 Step I or Step 2 scripted message.
  • RECORD names and times onAtt-6, Table l. .. REPEAT unlil all state/local agencies Informed.

c NOTE3 ONLY information on Notification Report is allowed to be communicated unless authorized by ED. RECORD last time .all State/ Local agencies received Att-5 Step l or Step 2 information a

on @ INFORM Emergency Director of"llme of Transmittal" to State/Local agencies was complete.

Immediately CONTACT NRC HQ via ENS per Att-6 Step 5 but nc later than 60 minutes after dedarat!on of EAL:

  • RECORD In Att-6, Table 3. ©© Support Agencies as roflows per Att-6, Table 2: *ANI. Procedure 2.0.S Reports To NRC Operations Center are lli2.t required for lOCFRS0.72 reports made during declared emergencies.

a 5 NRC may require information in addition to notification report:

  • Reaaor Power and MODE before/after emergency declaration.
  • Explanation for basis of declaring emergency.

.. Status of notification to Resident Inspector.

-Any off-site assistance requested.

  • A news release being planned. a NRC Follow-Up Notification required:
  • Level of plant safety degrades further.
  • Recerpt of evaluation/assessment results.
  • Effectiveness of response or protective measures taken.
  • Information related to plant anomaly. NOTE7 IE Initial Notification did not indude Radiological Release .aruJ release rate exceeds NOUE, Il:ifil immediate follow-up notiflcalion with radiological release required
  • NOTES At ALERT or higher, follow-up notification to state/local agencies is required approximately every 60 minutes or soone if slgniflcant change in emergency status. ©2 REVISION 69 PAGE 4 OF 25 ATTACHMENT 2 EOF OFF-SITE COMMUNICATOR FLOWCHART (REFERENCE USE) ATTACHMENT 2 EOF OFF-SITE COMMUNICATOR FLOWCHART (REFERENCE USE) EOF OFF-SITE COMMUNICATOR FLOWCHART SITE COMM COOPER NUCLEAR STATION OPERATIONS MANUAL OFS-1 EMERGENCY PLAN IMPLEMENTING PROCEOURE EP1P5.7.6 ATTACHMENT2 REV:O IE Control Room evacuation required prior to transfer 1 THEN of off-site communication responsibilities to EOF, Shift Communicator shall PERFORM off-site notifications using State Notification Telephone System from any CNS PBX telephone OFS-8 SIGN in on EOF staffing board VERIFY telephone and State Notification Telephone System functional OBTAIN copies of previously transmitted notification reports from FAX CONT ACT Shift Communicator i!ill! OBTAIN current status of event i!ill! Ii' off-site notification reports NOTIFY ED when ready to assume off-site communication ASSUME Off-site Communicator role i!ill! INFORM state/local agencies of EOF activation CONTINUOUSLY EVALUATE THROUGHOUT EVENT If any difficulties or delays in completing the offsite notification

!f event is TERMINATED, OFS-9 NOTE 1 Preferred method of contacting Shift Communicator in Control Room is to dial ext.8500 from Off-site Communicator phone ext.5500 I!:!fl! Immediately NOTIFY the ED It:lfil! PERFORM return to readiness (Table 1) PERFORM CONCURRENTLY EOF OPERATION PROVIDE pertinent information to EOF staff concerning off-site notifications PROVIDE completed off-site notification reports to Clerical Coard PROVIDE appropriate off-site notification status to EOF Log Keeper to in facility log PERFORM shift turnover as required, then go to m OFF-SITE NOTIFICATIONS OFS-14 PERFORM Off-site Notifications from EOF 1 GO TO Att-3, Off-Site Notifications From EOF Flowchart RETURN TO READINESS ENSURE the following:

EP Workstations returned to standby EP documents returned to storage location Emergency response equipment returned to standby Records and notes provided to EP Coordinator PROCEDURE

5. 7. 6 REVISION 69 PAGE 5 OF 25 ATTACHMENT 3 OFF-SITE NOTIFICATION FROM EOF FLOWCHART (REFERENCE USE) ATIACHMENT 3 OFF-SITE NOTIFICATION FROM EOF FLOWCHART (REFERENCE USE) OFF-SITE NOTIFICATION FROM EOf FLOWCHART COOPER NUC..EAR STATION OFF-SITE NOTIF NOTE 1 Initial Notification to state/local agencies SHALL be completed within 15 min. after dedaratlon or EAL 2t' a change in Protective Action Recommendations (PARs), ©i.4 CONTINUOUSLY EVALUATE THROUGHOUT EVENT lE NOUE and plant status changes significantly during performance of Initial Notification, EOF EPIP5.7.6ATTACJ-fllENT3 COMPLETE initial notification and. PERFORM follow-up notification_

IE airborne radioaaive release rate exceeds NOUE limits, Il::IEN 1. OBTAIN Dose Assessment from Radiological Control Manager (RCM). 2. COMPLETE Section 10 Rad Release of Notification Report if not included on Initial Notification report. 3. PERFORM [£j immediate follow-up notification to statetlocal agencies.

!------------------------------

IE communication lost to ont? or more state/local agencies during transmittal of notification, I!:::1fN 1. COMPLETE communication with remaining on-line parties. 2. INmATE contact with absent agency to complete communication.

IE Alternate means for state a.mt local ccmmunicalion required, D:LEN PERFORM Att-7 to establiSh alternate communication.

FOLLOW-UP IE rad release above NOUE, IlJEN;

  • RCM PROVIDE Dase Assessment.
  • REPUCATE dose assessment Into notification portion of CNS-Dose IE Dose Assessment inaccurate, Il:!EJ'I:
  • RE-PERFORM Dose Assessment
  • COMPLETE notification

@ report (ATr -4) manually per Att-5 ENSURE completeness:

  • VERIFY' correct Event Type ln Report Header; Emergency or Drill.
  • PRINT name and call back number (extension 5500) on Notification Report Blade l. OBTAIN ED review and ADD remarks on Section 9, as appropriate:
  • IF dose projections at 10 miles are ::?: lREM TEDE or REM COE, THEN ED ADD following:
1. ENTER "Projected dose at or beyond 10 miles exceed evacuation criteria.
2. RECOMMEND evacuation (or shelter if impediments exist) out to __ miles" in sectors ____ os determined by EPIP 5.7.20. OBTAIN ED approval on Notification Report; signature, date, and time. @ .Il:iEr::j PERFORM termination not.lflcatlon to off-site agencies within one hour. Dose Assessment .aalli2.nal.

NOTE2 PAR changes do not affect Emergency Declaration Time. Is Dose YES Assessment Included NO COMPLETE Notification Report:

  • PRESS DOSE on JOT keyboard.
  • SELECT .Qr "Notify Only." *ANSWER GE question(s).
  • ENTER remaining notification

..

@ IE Dose Assessment inaca.irate, I:1::iEN PERFORM one of following: -GOTO m '2'

  • COMPLETE notification

\::/ report (Att-4) manually per Att-5 lE Dose Assessment accurate, Il:iEN PERFORM following:

  • SELECT "F3" or "Results"'

SCAN aod SEND Notification Report to SNET: 1. PLACE report face up in document feeder. 2. SELECT Scan and Send feature. 3. PRESS One Touch. 4. PRESS SNET. 5. PRESS OK. 6. PRESS Green srART button

  • CONTACT state/local agencies using State Notification Telephone System with one of following:
  • DEPRESS GROUP GILL. .. Dial '"7450" on PBX Phone. CFS-22 time of first agenc;b. on-line on Att-6, Step 3.1 COMMUNICATE Att*6, Step 1 or Step 2 scripted message to eadl State/Local agency:
  • ENTER remaining notification
  • RECORD names .am! information.

times on Att-6, Table l.

  • SELECT "FS" to print. NOTE3 EDF Director may sign Initial Notification Forms with ED verbal approval arnl facility log entries.©1 IE emailed notification report oat received, Il:IEN CALL each missed agency directly:
  • DIRECT agency to obtain blank notification report. *READ notification report line*by-line to each missed State/Local agency
  • RECORD names 20.Q times on Att-6, Table 1.
  • USE Alternate means of communication per Att-7, if necessary.

IE any state/local agency nm on Initial notification call, Il:iB!l, CALL missed agency directly

  • IE initial notification Il:iEM COMMUNICATE Att*6 Step l or 2 scripted message.
  • RECORD names and times on Att-6, Table l.
  • USE Alternate means of communication per Att-7, if necessary.
  • REPEAT until all state/local a enctes informed.

NOTE4 ONLY information on Notification Report is allowed to be communicated unless authorized by ED. NOTE'S Time of first agency reporting line during notification satisfies NEI 99-02 requirement for NRC Perfonnance Indicator.

NOTES lOCFRSO Appendix E initial notification requirements are met when an State and Local agencies have scripted initial notification message read to them. lE at or above ALERT, lliEN NOTIFY following Support Agencies as follows per Att-6, Table 2: *ANl.

  • INPO.G/ NOTE7 IE Initial notification did not include Radiological Release a..ru1 release rate exc.eeds NOLIE, Il:IEN immediate follow-up notification with radiological release is required.

NOTES At ALERT or higher, follow-up notification to state/local agencies required approximately every 60 minutes or sooner If significant change in emergency status. @l PROCEDURE

5. 7 .6 REVISION 69 PAGE 6 OF 25 AlTACHMENT 4 COOPER NUCLEAR STATION NOTIFICATION REPORT (INFORMATION USE)©5 ATTACHMENT 4 COOPER NUCLEAR STATION NOTIFICATION REPORT (INFORMATION USE}©5 1) [ ] Emergency [ ] This is a Drill 2} Notification Report Number: _____ _ Time of Transmittal:

[]Initial Report (Complete Sections 1-7 only) [ ] Follow-Up Report 3) Name of CNS Communicator:

Call Back Number: 402-825-4) Classification: [ ] NOUE; [ ] Alert; [ ] Site Area; [ ] General __ J EAL Number:

5)

Wind Speed:

From: DegreeJ Precipitation: [ ] YES; [ ] NO on 1 ions :j Stab i I ity Class: [ ] A; [ ] B; [ ] C; [ ] D; [ ] E; [ ] F; [ ] G 6) NOUE Airborne Release Values: There [ ] is [ ] no ERP= 2.24E5 µCi/sec TG Building=

9.02E4 µCi/sec RX Building=

8.48E4 µCi/sec ARW Building = 9.08E4µCi/sec

[]was []will be [ ] an airborne [ ] a liquid Release of Radioactive Material Greater than NOUE Limits. 7) Protective Action Recommendations (PARS): General Emergency Automatic PAR -Evacuate 2 mile radius/5 mile downwind, go indoors, and monitor EAS remainder 10 mile EPZ .. ! ! [ ] Evacuate Sectors i I None i [ ] Shelter Sectors I Go indoors and monitor EAS in Sectors --. -----1---------:-------------------t-------------------------------*---i 0-2 Miles 1 : i-------+!-----;---------------+i-------*---------------------

2-5 Miles l 5-10 Miles ! 8) Prognosis: [ ] Stable; ] Unstable Plant Status: [ ] at Power; [ ] Shutdown 9) Remarks:

10) Release Information (required on follow-up notification with airborne release > NOUE limits): >---*----------------------------------------

---Release From: [ ] ERP; [ ] Reactor Building; [ ] Turbine Building; [ ] Aug Radwaste Building; [ ] Other:

Rate (µC-i/

*

Estimated Duration:

_______ (Hours) Start Time: ______ _ Stop Time: ______ _ Distance From Plant Projected Integrated Dose (Rem) TEDE COE (Thyroid)

Site Boundary 2 Miles 5 Miles 10 Miles Emergency Director Signature:

PROCEDURE

5.7.6 Noble

Gas: ______ µCi/sec Iodides: N/A Particulate:

N/A Projected Dose Rate (Rem/hr) TEDE COE (Thyroid)

Date: Time: REVISION 69 PAGE 7 OF 25

) / ATTACHMENT 5 COMPLETING NOTIFICATION REPORT WITH CNS-DOSE NOT AVAILABLE (INFORMATION USE)1 ATrACHMENT 5 COMPLETING NOTIFICATION REPORT WITH CNS-DOSE NOT AVAILABLE (INFORMATION USE)1 1. OBTAIN blank copy of Attachment 4, Notification Report.

NOTE 1 -Initial Notifications:

Step 2, Step 3, and Step 5 or 6 are required.

NOTE 2 -Follow.-Up Notifications:

Steps 2 through Step 5 or 6 are required.

NOTE 3 -Termination Notifications:

Steps 2 through 2.4.4 and Step 5 or 6 are

_____________________________________________________________________________________________________________________

2. Communicator PERFORM following to initiate Notification Report: 2.1 Section 1, SELECT Event Type: 2.1.1 CHECK if an Emergency (Actual Event) or This is a Drill. 2.2 Section 2, RECORD Notification Report information:

2.2.1 RECORD

Notification Report number: 2.2.1.1 ENTER 1 or next sequential number if more than one report has been generated during event. 2.2.2 Time of Transmittal:

LEAVE blank. 2.2.3 SELECT Initial or Follow-Up Report: 2.2.3.1 CHECK "Initial Report" for EAL classifications or change in PAR. 2.2.3.2 CHECK "Follow-Up Report" for all others, including termination.

2.3 Section

3, RECORD name of CNS Communicator.

2.3.1 RECORD

call back number. 2.4 Section 4, PROVIDE Emergency Classification information.

2.4.1 CHECK

Emergency Classification being declared.

2.4.2 ENTER

EAL number (e.g., AU1.1). PROCEDURE

5. 7.6 REVISION 69 PAGE 8 OF 25

) ATTACHMENT 5 COMPLETING NOTIFICATION REPORT WITH CNS-DOSE NOT AVAILABLE (INFORMATION USE)1 2.4.3 RECORD event declared (Date/Time):

2.4.3.1 ENTER time and date of Emergency Declaration in military format (e.g., 1418).©5 2.4.4 RECORD Event Terminated (Date/Time) as applicable:

2.4.4.1 ENTER time and date of termination in military format (e.g., 1418). 2.5 Section 7, RECORD Protective Action Recommendations (PARs) as determined by EPIP 5. 7.20. 2.5.1 VERIFY PAR includes previous PARs if they have changed. 2.5.2 IF EAL Classification is below GENERAL EMERGENCY (GE), THEN PLACE "ALL" in each of three rows in NONE column to indicate recommended PAR is NONE. 2.5.3 For any GE PAR: 2.5.3.1 CHECK appropriate box indicating if PAR is an Evacuation or Shelter PAR. 2.5.3.2 ENTER sectors in appropriate rows for distance from site. 2.6 Section 8, SELECT event Prognosis and Plant Status: 2.6.1 IF event is not likely to degrade, THEN CHECK "Stable".

2.6.2 IF event is degrading (e.g., RPV level is lowering or Containment Rad Monitors are trending upward), THEN CHECK "Unstable".

2.6.3 IF reactor is shutdown under all conditions, THEN CHECK "Shutdown".

2.6.4 IF reactor is not shutdown under all conditions (with or without boron), THEN CHECK "at Power". PROCEDURE

5.7.6 REVISION

69 PAGE 9 OF 25

.. ) ATTACHMENT 5 COMPLETING NOTIFICATION REPORT WITH CNS-DOSE NOT AVAILABLE (INFORMATION USE)1 3. Dose Assessor or Radiological Assessment Supervisor (RAS) in EOF if activated, PERFORM EPIP 5.7.16 and 5.7.17.1, as applicable, to complete following sections of notification report: 3.1 Section 5, RECORD meteorological conditions obtained from hand calculated dose assessment method from EPIP 5.7.17.1.

3.2 Section

6, RECORD Release Status information based on results from hand calculated release rate methods per EPIP 5. 7 .16.©11 3.2.1 IF release rate currently at or above NOUE limits, THEN CHECK "Is" to indicate a radiological release in-progress.

3.2.2 IF release rate has lowered and is now less than NOUE limits, THEN CHECK "Was" to indicate that past radi.ological release occurred.

3.2.3 IF release rate rising and expected to exceed NOUE limits, THEN CHECK "Will Be" to indicate anticipation of a radiological release. 3.2.4 IF release rate currently or expected to remain below NOUE limits, THEN CHECK "No" to indicate no radiological release in-progress or expected at this report time. 3.2.5 SELECT Release Type (Airborne/Liquid):

3.2.5.1 IF release that is, was, or wili be above NOUE limits is airborne, THEN CHECK "an airborne".

3.2.5.2 IF release that is, was, or will be above NOUE limits is liquid, THEN CHECK "a liquid" . PROCEDURE

5. 7. 6 REVISION 69 PAGE 10 OF 25

_/ ) ATTACHMENT 5 COMPLETING NOTIFICATION REPORT WITH CNS-DOSE NOT AVAILABLE (INFORMATION USE)1 4. IF both of following conditions are met:

  • Report is Follow-up Notification.
  • Release of airborne radioactive material greater than NOUE limits is occurring or occurred during event. THEN COMPLETE Section 10 as follows: 4.1 Release From: 4.1.1 CHECK release source(s) that was or is contributing to exceeding NOUE limits. 4.2 Release Height: 4.2.1 IF ERP release source was or is contributing to exceeding NOUE limits, THEN CHECK "100 M". 4.2.2 IF .any other building was or is contributing to exceeding NOUE limits, THEN CHECK "10 M". 4.2.3 IF any other structure (e.g. tank, container, etc.) was or is contributing to exceeding NOUE limits, THEN CHECK "Other". a. RECORD height in feet for other release source, if applicable.

4.2.4 IF multiple releases are occurring and not affecting same sectors, THEN CHOOSE height associated with release source that results in greatest dose. 4.3 Release Duration:

ENTER expected duration.

4.3.1 IF duration is unknown, THEN USE default of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. 4.3.2 Start Time: ENTER release start time (e.g., 1418). 4.3.3 Stop Time: ENTER release stop time. if known; otherwise, ENTER. "UNK". PROCEDURE

5. 7. 6 REVISION 69 PAGE 11OF25

_,) ATTACHMENT 5 COMPLETING NOTIFICATION REPORT WITH CNS-DOSE NOT AVAILABLE (INFORMATION USE)1 4.4 Release Rate (µCi/sec):

4.4.1 OBTAIN

release rate from release source that was or is contributing to exceeding NOUE limits*by hand calculated release rate determination per EPIP 5. 7 .16. 4.4.2 ENTER Noble Gas release rate in µCi/sec. 4.5 Projected Integrated Dose (Rem) and Projected Dose Rate (Rem/hr):

4.5.1 OBTAIN

TEDE and COE Dose, and Dose Rates from hand calculated dose assessment per EPIP 5. 7 .17 .1. 4.5.2 ENTER Projected Integrated Dose (Rem) TEDE and COE (Thyroid) values for each distance from plant. 4.5.3 ENTER Projected Dose Rate (Rem/hr) TEDE and COE (Thyroid) values for each distance from plant. 5. IF notification sent from Control Room, THEN RETURN to Attachment 1, Step SC-15. 6. IF notification sent from EOF, THEN RETURN to Attachment 3, Step OFS-15. PROCEDURE

5. 7 .6 REVISION 69 PAGE 12 OF 25

) ._ .. ,/ ATTACHMENT 6 AGENCY NOTIFICATION RECORD AND TURNOVER SHEET (INFORMATION USE) ATTACHMENT 6 AGENCY NOTIFICATION RECORD AND TURNOVER SHEET (INFORMATION USE) Notificatnoin Report Number: ________ _ 1. IF notification is an initial notification for an EAL declaration, THEN SCRIPT initial notification message as follows: This is Cooper Nuclear Station. At Time ___ , a(n) Circle One: (Unusual Event, Alert, Site Area Emergency, General Emergency) was declared on EAL --------------

2. IF notification is for change in Protective Action Recommendations, THEN SCRIPT initial notification message as follows: This is Cooper Nuclear Station. At Time _____ , a Change to Protective Action Recommendations was issued for General Emergency declared under EAL The change in Protective Action Recommendations is as follows: _____ _ Reasonforchangeisdueto:

PROCEDURE

5.7.6 REVISION

69 PAGE 13 OF 25

) AlTACHMENT 6 AGENCY NOTIFICATION RECORD AND TURNOVER SHEET (INFORMATION USE) 3. STATE AND LOCAL AGENCIES 3.1 RECORD first State or Local agency on-line (Time): _______ _ AGENCY PHONE NAME TIME Nebraska Emergency Management Agency (NEMA) or Nebraska State 8511 Patrol Nemaha County EOC or Nemaha 8512 County Sheriff Richardson County EOC or 8517 Richardson County Sheriff Missouri State Emergency 8515 Management Agency (SEMA) or 8514 Missouri Highway Patrol Atchison County EOC or 8516 Atchison County 911 Center 8513 4. SUPPORT AGENCIES AGENCY PHONE PERSON CONTACTED TIME (404) 290-3980 (AED) INPO or ( 404) 290-3977 (ED) American Nuclear (877) 680-2644 Insurers (ANI) (202) 739-8000 Nuclear Energy (Business Hours) Institute (NEI) or (703) 644-8805 PROCEDURE

5. 7.6 REVISION 69 PAGE 14 OF 25 ATTACHMENT 6 AGENCY NOTIFICATION RECORD AND TURNOVER SHEET (INFORMATION USE) 5. NRC HEADQUARTERS; N/A if NRC communications turned over to TSC ENS Communicator.
  • 5.1 PROVIDE additional information to NRC in addition to that provided on Notification Report; examples may include:
  • Reactor power and mode before/after emergency declaration.
  • Reason for declaring emergency. Additional lOCFRSO. 72 categories that may be applicable.
  • Status of notification to NRC Resident Inspector.
  • Any off-site assistance that has been requested.
  • News release being planned. CNS TELEPHONE ALTERNATE PERSON CONTACTED TIMIE Dial# on ETD or Speed Phone Sticker Dial -10 PROCEDURE

5.7.6 REVISION

69 PAGE 15 OF 25

' \ , ATTACHMENT 6 AGENCY NOTIFICATION RECORD AND TURNOVER SHEET (INFORMATION USE) NOTE -Shift Communicator shall turn over NRC notification responsibilities to ENS Communicator in TSC and State/Local agency notification responsibilities to

___ _ 6. SHIFT COMMUNICATOR TURNOVER TO TSC AND EOF 6.1 WHEN contacted by ENS Communicator in TSt, THEN TRANSFER NRC notification responsibilities and NOTIFY SM/ED. NAME OF ENS COMMUNICATOR TIME 6.2 WHEN contacted by Off-Site Communicator in EOF, THEN TRANSFER off-site notification responsibilities and NOTIFY SM/ED. NAME OF OFF-SITE COMMUNICATOR

6.3 Shift

Communicator Signature:

_________

_ Date: 6.4 INFORM Shift Manager that Off-Site and NRC communication responsibility have been transferred.

TIME ----PROCEDURE

5. 7.6 REVISION 69 PAGE 16 OF 25 ATTACHMENT 7 ALTERNATIVE CONTACT METHODS (INFORMATION USE) AITACHMENT 7 ALTERNATIVE CONTACT METHODS (INFORMATION USE) i NOTE -SNET is an email address in NPPD Global Address Book for delivery of i Notification Reports and other documents to State and Local agencies, and NRC L_Q __ ---------------------------------------------------------------------------------------------------
1. IF State Notification Telephone System is inoperable, THEN PERFORM "Group Call" by dialing 7450 from any PBX extension.
2. IF individual agency contact is required, THEN USE table below with following options:
  • DIAL 4-digit number using CNS PBX phone extension.
  • DIAL 10 digit number on any phone connected to an off-site phone system.
  • DIAL speed dial number from Shift Manager phone. AGENCIES CNS PIBX # EXTERNAL PHONE # SM SPEED DIAL # NEMA or Nebraska 8511 402-471-4545 04 State Patrol Nemaha County EOC or County 8512 402-274-3298
  • 20 Sheriff Richardson County 8517 402-245-2479 21 EOC or Sheriff Missouri SEMA or Highway 8514 or 8515 573-751-1000 22 Patrol Atchison County 8513 or 8516 660-744-6271 19 EOC or 911 Center PROCEDURE

5.7.6 REVISION

69 PAGE 17 OF 25 ATTACHMENT 7 ALTERNATIVE CONTACT METHODS (INFORMATION USE) 3. IF PBX/extensions are THEN USE Brownville Central Office (C.O.) lines from any of following to attempt communication:

  • Control Room.
  • JIC. 4. IF both State Notification Telephone System and commercial (normal) telephone system are inoperable or congested, THEN USE Government Emergency Telephone System (GETS) cards located in following ERFs: 4.1 Control Room (Shift Manager's cubicle).

4.2 TSC (TSC Director).

4.3 OSC (OSC Supervisor).

4.4 EOF (EOF Director).

4.5 JIC (JIC Director).

PROCEDURE

5.7.6 REVISION

69 PAGE 18 OF 25

) ATf ACHMENT 8 INFORMATION SHEET (INFORMATION USE) ATTACHMENT 8 INFORMATION SHEET (INFORMATION USE) 1. PURPOSE2©6*7 1.1 Perform. initial 1 follow-up, an_d termination emer9ency plan notifications to responsible State and Local governmental agencies, NRC notifications 1 and notifications to other off-site support agencies.

2. PRECAUTIONS AND LIMITATIONS 2.1 ED may not delegate decision to notify authorities responsible for off-site emergency measures.© 3 3. DISCUSSION 3.1 All notifications and communications will be handled from Control Room (CR) until Technical Support Center (TSC) and Emergency Operations Facility (EOF) are activated.

3.2 During

declared Emergency at CNS, Emergency notifications to State of Nebraska; State of Missouri; Atchison County, Missouri; and Nemaha and Richardson Counties in Nebraska are accomplished through State Notification Telephone System.

  • 3.2.1 CNS State Notification Telephone System is conference-calling system. When handset to this hotline is picked up and "Group Call" button pushed, dedicated telephones will automatically ring at: " Nebraska State Patrol and Emergency Management Agency EOC. e Missouri State Highway Patrol and Emergency Management Agency EOC.
  • Atchison County 911 Center and EOC. Q Nemaha County Sheriff and EOC.
  • Richardson County Sheriff and EOC. 3.2.2 Utilization of law enforcement agencies and emergency services dispatch centers as initial points of contact provides for 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> coverage.

3.2.3 Once EOCs become operational, notifications may be made using extension lines at EOCs with concurrence between respective EOC and law enforcement/911 agencies.

PROCEDURE

5. 7.6 REVISION 69 PAGE 19 OF 25 ATTACHMENT 8 INFORMATION SHEET (INFORMATION USE) 3.3 Primary means of generating notification reports is through automated CNS-DOSE Program on PMIS. 3.3.1 CNS-DOSE combines the means to collect meteorological and
  • radiological data as *part of the notification report. 3.3.2 For Initial Notifications, Communicators use CNS-DOSE to generate a notification only report that includes meteorological data, but does not include radiological information.

3.3.3 CNS-DOSE provides option of generating notification only without radiological information such as release rates and dose . assessment.

Dose Assessor in Control Room or Radiological Assessment Supervisor (RAS) in EOF typically generate CNS-DOSE dose assessment printout with MET, RAD, and PAR information, as necessary.

3.3.4 CNS-DOSE gathers current available radiological and meteorological data from plant instrumentation to assess release conditions.

3.3.5 CNS-DOSE provides tutorial to guide user through questions and topics required to be filled-in as part of report. 3.4 Primary and backup communication systems are available.

Backup communication methods are listed below:

  • Alternate telephones:

Alternate telephone numbers are listed in Emergency Telephone Directory.

  • National Warning System (NAWAS).
  • Base station radio.
  • Relay through third party. PROCEDURE
5. 7. 6 REVISION 69 PAGE 20 OF 25 ATTACHMENT 8 INFORMATION SHEET (INFORMATION USE) 3.5 Public Affairs Duty Officer (PADO) is notified by pager by CNS Automated Notification System and instructed to contact Control Room. Upon being contacted by PADO, Control Room will relay following information to PAD0:©10
  • Emergency Classification.
  • Time of EAL Classification.
  • Brief description of event.
  • Request telephone number in which PADO can be reached. 3.6 PADO functions are superseded by activation of Joint Information Center (JIC). JIC receives follow-up information from EOF. 3.7 Emergency Preparedness Coordinator (EPC) is responsible for coordinating news releases after notification and responding to Notification of Unusual Event (NOUE) by reporting to Control Room. Duties include following:

©8

  • Assists Control Room in ensuring communication is established with the PADO per EPIP 5.7.23.
  • Responsibility is for period immediately after declaration of NOUE and continues until responsibility is transferred to appropriate NPPD Corporate Communications Department personnel.
  • Any news release generated during this period should be reviewed and approved by Emergency Director.

3.8 Authorized

Representatives of Governors of Nebraska and Missouri may be represented in EOF and set up Forward Command Posts at some other location.

3.9 FLOWCHARTS

ORGANIZATION

3.9.1 Shift

Communicator Flowchart from Attachment 1 and Off-Site Notification from EOF Flowchart from Attachment 3 are each printed on 18 inch by 24 inch laminated sheet and mounted on foam board. 3.9.2 EOF Off-Site Communicator Flowchart from Attachment 2 is printed on 11 inch by 17 inch laminated sheet and mounted on foam board. 3.9.3 Header data for each flowchart will contain revision number. PROCEDURE

5.7.6 REVISION

69 PAGE 21OF25

) ---

ATTACHMENT 8 INFORMATION SHEET (INFORMATION USE) 3.9.4 Table below specifies current revision of each flowchart.

Flowchart Revision Number Attachment 1, Shift Communicator Revision 1 Attachment 2, EOF Off-Site Communicator Revision 0 Attachment 3, Off-Site Notification From EOF Revision 1 3.9.5 It is not necessary that flowchart revision number be revised with each revision of this procedure.

3.9.6 If any flowchart is revised, then Attachment 8 is revised to reflect new flowchart revision data. 4. RECORDS 4.1 Attachments 4 and 6 from actual events shall be forwarded to EP Manager within 5 working days of their completion (quality record upon completion).

5. REFERENCES

5.1 CODES

AND STANDARDS 5.1.1 10CFR50. 5.1.2 NPPD Emergency Plan for CNS. 5.2 PROCEDURES

5.2.1 Conduct

of Operations Procedure 2.0.5, Reports to NRC Operations Center. 5.2.2 Emergency Plan Implementing Procedure 5.7.1, Emergency Classification.

5.2.3 Emergency

Plan Implementing Procedure

5. 7 .20, Protective Action Recommendations.

5.2.4 Emergency

Plan Implementing Procedure

5. 7.23, Activation of the Joint Information Center (JIC). PROCEDURE
5. 7.6 REVISION 69 PAGE 22 OF 25

) ___ _,,/ ATIACHMENT 8 INFORMATION SHEET (INFORMATION USE) 5.3 MISCELLANEOUS 5.3.1 CNS Emergency Telephone Directory.

5.3.2 NCR 93-52. 5.3.3 NRC Inspection Report 89-35, Item 1. 5.3.4 NRC Inspection Report 94-11. 5.3.5 NRC Inspection Report 94-29, Item 1. 5.3.6 NRC RIS 2009-10. 5.3.7 NRC Safety Evaluation Report (SER), TAC Number ME0849 -ADAMS Accession Number ML100080231.

5.3.8 Nuclear

Energy Institute (NEI) Document 99-01, Revision 5, Methodology for Development of Emergency Action Levels. 5.3.9 Nuclear Energy Institute (NEI) Document 99-02, Revision 7, Regulatory Assessment Performance Indicator Guideline.

5.3.10 QA Observation 93-05A. 5.3.11 QA Report 86-06. 5.3.12 RCR 2002-0181, Action 2, Require State/Local Notification within 15 minutes of PAR or change in PAR. 5.3.13 1 SOER 99-1, Addendum, Loss of Grid. Assure that off-site communication and notification capabilities are maintained under loss of grid conditions.

Affects Attachment

5. 5.3.14 2 TIP Action Plan 5.2.2.1, Revision 1, Action 1. Major revision 6/28/02 to clarify Control Room tasks. Affects Attachment 8, Section 1. 5.3.15 3 IER 13-10, Recommendation lla. Notifying NEI at NOUEs or higher and INPO at ALERTs or higher. Affects Attachment 1, Steps SC-30 and SC-31, and Attachment 3, Steps OFS-30 and OFS-31. PROCEDURE
5. 7.6 REVISION 69 PAGE 23 OF 25

/ ATTACHMENT 8 INFORMATION SHEET (INFORMATION USE) 5.4 NRC COMMITMENTS 5.4.1 ©1 Commitment Numbers 921110-02-06 and NSD921204-10.

Allow Facility Directors to sign initial Notification Forms with ED verbal approval and appropriate log entries. Commitment affects Attachment 3, Step OFS-17, Note 3. 5.4.2 ©2 Commitment Number NLS980074-02.

Response to IR 98-12 to include clarification of requirements for making follow-up off-site notifications in a timely manner. Commitment affects Attachment 1, Notes 1 and 10, and Attachment 3, Notes 1 and 8. 5.4.3 ©3 Commitment Number CNSS854100-01.

EPIPs will clearly state non-delegable authorities and responsibilities.

Commitment affects Attachment 8, Step 2.1. 5.4.4 ©4 Commitment Number CNSS854100-03.

Provide greater visibility of time reqljirements for notifying state and local governments within 15 minutes after declaration of an emergency.

Commitment affects Attachment 1, Note 1, and Attachment 3, Note 1. 5.4.5 ©5 Commitment Number NLS8700649-02.

Declaration time will be reflected in Notification Form used by Control Room Communicator.

Commitment affects Attachment 4, Event Declared (Date/Time) block (not annotated to preclude confusion with, Off-Site authorities)

Attachment 4 and Attachment 5, Step 2.4.3.1. 5.4.6 ©6 Commitment Number 811217-01-06.

An EPIP has been written to ensure that appropriate local governments will be properly informed in the event of an emergency at Cooper Nuclear Station. Commitment affects Attachment 8, Section 1. 5.4.7 ©7 Commitment Number 811217-01-08.

Facility (TSC, OSC, EOF) activation procedures, as well as a notification procedure, have been included in the revised EPIPS. Commitment affects Attachment 8, Section 1. 5.4.8 ©8 Commitment Number 811217-01-16.

The specific functional responsibilities and authorities for the role of the Emergency Planning Coordinator have been developed and will be discussed in the revised Emergency Plan and appropriate EPIPS. Commitment affects Attachment 8, Step 3. 7. PROCEDURE

5. 7.6 REVISION 69 PAGE 24 OF 25

) __ ./ ATTACHMENT 8 INFORMATION SHEET (INFORMATION USE) 5.4.9 ©9 Commitment Number 820806-01-10.

The CNS emergency organizatton will be revised to provide personnel to make calls for the Emergency Director at his direction.

Commitment affects Step 2.2; Attachment 1, Step SC-18; and Attachment 3, Step OFS-18. 5.4.10 ©1° Commitment Number NLS8400261-01.

The District will provide pagers for appropriate General Office personnel that are key to the off-hours notification of the Emergency Preparedness response team located in the corporate offices. The pagers will be activated by a single telephone call from the CNS Shift Supervisor or his designee.

The appropriate sections of the CNS Emergency Plan, EPIPS, and General Office guidelines will be revised to include this alternate means of notification.

Commitment affects Attachment 8, Step 3.5. 5.4.11 ©11 Commitment Number NLS950004-01.

Emergency Plan procedures will be revised to include the definition of a release as it relates to off-site notifications.

Commitment affects Attachment 5, Step 3.2. PROCEDURE

5. 7 .6 REVISION 69 PAGE 25 OF 25
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