ML17334A033

The ISFSI - Revised Emergency Plan Implementing Procedures

ML17334A033
Person / Time
Site:	San Onofre
Issue date:	11/27/2017
From:	Southern California Edison Co
To:	Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
0123-VIII-ADMIN-2, Rev 3, 0123-VIII-ER0-1, Rev 2
Download: ML17334A033 (36)

Text

Attachment 1 Revised Emergency Plan Implementing Procedures

Reference Use Emergency Preparedness Program Training Procedure Usage Requirements Review and understand the procedure before performing any steps, including the prerequisite section.

Have a copy or applicable pages/sections open at the work site.

Use Placekeeping method according to S0123-XV-HU-3.

If any portion of the document is performed from memory, do so in the sequence specified. Perform each step as written, except when an approved process specifically allows deviation.

Refer to the procedure or instruction at least once to ensure completion of the task in accordance with the requirements.

Review the document at the completion of the task to verify that all appropriate steps are performed and documented.

Color Usage 50123-VIII-ADMIN-2 REV: 3 Page 1 of 18 I

Sections ALL Location This Document Contains Relevant Color QA PROGRAM AFFECTING 50.59 DNA/ 72.48 DNA/ 50.54(q) APPLIES Procedure Type Procedure Owner General Kelli Gallion

S0123-VIII-ADMIN-2 Emergency Preparedness Program Training REV:3 Page 2 of 18 TABLE OF CONTENTS Section Page 1.0 PURPOSE AND SCOPE................................................................................................................ 3 2.0 RESPONSIBILITIES....................................................................................................................... 3 3.0 DEFINITIONS................................................................................................................................. 5 4.0 PRECAUTIONS AND LIMITATIONS.............................................................................................. 5 5.0 PREREQUISITES................................... :....................................................................................... 5 6.0 PROCEDURE................................................................................................................................. 6 6.1 ERO Training Program Structure......................................................................................... 6 6.2 ERO Training.,...................................................................................................................... 8 6.3 ERO Evaluation................................................................................................................. 11 6.4 ERO Remediation.............................................................................................................. 11 6.5 Training of Support Personnel............................................................................................ 11 6.6 Emergency Preparedness Staff Training........................................................................... 12 6.7 Training of the Offsite Response Organizations................................................................. 14 7.0 RETENTION OF RECORDS................................................ *........................................ :................ 14

8.0 REFERENCES

/ COMMITMENTS................................................................................................ 15 ATTACHMENT 1

Emergency Plan Training Program Curriculum.............................................................................. 16 2

Ownership of Emergency Preparedness Training Elements.......................................................... 17 3

Summary of Changes.................................................................................................................... 18 REFERENCE USE

S0123-VIII-ADMIN-2 Emergency Preparedness Program Training REV:3 Page 3 of 18 1.0 PURPOSE AND SCOPE 1.1 To describe the San Onofre Nuclear Generating Station (SONGS) Emergency Preparedness Training Program which implements the requirements contained in SONGS Permanently Defueled Emergency Plan, Volume 1.

1.2 The Emergency Preparedness Training Program is designed to train emergency response organization (ERO) personnel to perform response duties as described in initial and continuing training. The initial training program ensures personnel have the required knowledge and skills to perform the duties as Emergency Responders. Continuing training ensures the incumbents maintain and improve job performance through development of job-related knowledge and skills.

1.3 S023-XXI-TRN, Conduct of Training, identifies the level and depth to which individuals are to be trained. Appropriate personnel are trained in the areas such as radiation protection, respiratory protection, and first aid or its equivalent, as part of the applicable training program.

2.0 RESPONSIBILITIES Some Emergency Preparedness training program elements are administered by other department programs within Southern California Edison (SCE) or SONGS Decommissioning Solutions (SOS) with EP oversight. Reference, Ownership of Emergency Preparedness Training Elements, to identify the Program Owner for specific instruction modules listed in this procedure.

2.1 Emergency Preparedness Manager 2.1.1

. The Emergency Preparedness training program.

2.1.2 Administration of emergency preparedness-related training, including: identifying, developing, maintaining and revising this procedure.

2.1.3 Assisting the Responsible Manager ir:i coordinating and/or providing emergency preparedness-related training implemented by this procedure.

2.1.4 Assuring any person facilitating emergency preparedness-related training or evaluation has the certifications, experience, or skills necessary to effectively train or evaluate personnel.

2.1.5 Ensuring the contents of each training program meet the applicable requirements.

2.1.6 Scheduling, developing, conducting, and documenting drills and exercises.

2.1. 7 En$uring proper records are maintained to document training of the ERO.

REFERENCE USE

50123-VIII-ADMIN-2 Emergency Preparedness Program Training REV: 3 Page 4 of 18 2.2 Operations Manager (SCE) 2.2.1 Operations personnel ERO performance and remediation.

2.2.2 Administration of Operations and On-Shift ERO positions' emergency preparedness-related training, including: identifying, developing, maintaining, and revising training materials.

2.3 Radiation Protection and Chemistry Managers (SOS) 2.3.1 Radiation Protection Technician ERO performance and remediation.

2.3.2 Administration of Radiation Protection and Chemistry emergency preparedness-related training, including: identifying, developing, maintaining and revising training materials.

2.4 Radiation Protection and Waste Manager (SCE) 2.4.1 Radiation Protection Coordinator ERO performance and remediation.

2.5 Managers and Supervisors (SCE and SOS) 2.5.1 Ensuring their personnel assigned to ERO positions obtain and maintain their ERO qualifications, and have an active Security Photo Identification Badge.

2.5.2 Notifying the Emergency Preparedness Manager or designee of vacancies in ERO positions and assisting with the candidate selection and assignment process.

2.6 ERO Members (SCE and SOS) 2.6.1 Completing ERO training requirements.

2.6.2 Meeting the requirements of S0123-VIII-ER0-1.

REFERENCE USE

50123-VIII-ADMIN-2 Emergency Preparedness Program Training REV: 3 Page 5 of 18 3.0 DEFINITIONS SONGS Permanently Defueled Emergency Plan (PDEP) contains additional definitions and acronyms applicable to Emergency Preparedness Program.

3.1 Drill

A controlled scenario event conducted to provide training and practice for the participants.

Drills may also include evaluated objectives and demonstration criteria as part of meeting periodic performance objective requirements as pre-designated by the scenario.

3.2 Evaluator

An Individual who observes and assesses the trainee's performance during the qualification process.

3.3 Exercise

An event that evaluates the integrated capability and a major portion of the basic elements against designated objectives and demonstration criteria. An exercise may involve participation of personnel from *state, Local, or Federal governments.

3.4 Walkthrough

One-on-one or small group training session in an interactive lecture-type environment. A walkthrough will usually take place in the Command Center or in the field, and it will cover equipment, communications, procedures, and activities necessary to fulfill the responsibilities of a specific position.

4.0 PRECAUTIONS AND LIMITATIONS 4.1 ERO Qualification Records (EQRs) should be created for new ERO positions (reference NNs 203242554 and 203259165).

5.0 PREREQUISITES 5.1 VERIFY this document is current by using one of the methods described in S0123-XV-HU-3.

5.2 VERIFY Level of Use requirements on the first page of this procedure.

REFERENCE USE

6.0 6.1 S0123-VIII-ADMIN-2 Emergency Preparedness Program Training REV: 3 Page 6 of 18 PROCEDURE ERO Training Program Structure ERO Personnel Training consist of an Initial Training and Continuing Training.

6.1.1 ERO Training Program Objectives 6.1.1.1 To instruct each ERO member in the educational topics relevant to the function of the ERO positions.

6.1.1.2 To instruct each ERO member in the duties and responsibilities specific to their ERO position according to Emergency Plan Implementing Procedures.

6.1.1.3 To improve performance and maintain proficiency through mini-drills, table tops, and classroom training.

6.1.1.4 To provide a means of evaluating the ERO position's qualification by use of an EQR.

6.1.2 ERO Training Program Overview 6.1.2.1, Section 1, describes the Emergency Plan Training Program Curriculum for SONGS ERO positions.

6.1.2.2 The skills and knowledge required to perform plant stabilization and mitigation are a normal function of Operations specific positions. Subsequent stabilization and restoration is pursued using station procedures. Operators receive routine training to ensure proficiency in this area.

6.1.2.3 Those positions that are called to assist Operators with accident assessment, corrective actions, protective actions, and related activities receive appropriate training.

6.1.2.4 In addition to training received to qualify for their normal duties, Radiation Protection personnel receive specific emergency response training on dose assessment, basic meteorology, and transportation of contaminated injured persons.

6.1.2.4.1 Training for the transport of Contaminated Injured Persons is provided to Radiation Protection Technicians by Radiation Protection and it is performed in accordance with SDS-RP1-PCD-1004. EP supports training during the annual medical emergency drill.

REFERENCE USE

6.1.2.5 6.1.2.6 6.1.2.7 6.1.2.8 6.1.2.9 S0123-VIII-ADMIN-2 Emergency Preparedness Program Training REV: 3 Page 7 of 18 On-Shift ERO personnel are trained as Radiation Workers and to perform limited RP duties. The table below describes the RP duties performed by different On-Shift ERO personnel:

RP DUTY RP SHIFT MANAGER/

SECURITY TECHNICIAN OPERATOR Access Control Yes No No RP Coverage for Yes Yes (limited)

No repair, corrective actions, search and rescue, first aid, and firefiqhtinq Personnel Yes Yes (limited)

No Monitorinq Dosimetry Yes Yes (limited)

Yes (limited)

Training and position specific qualification is implemented by completion of an EQR specific to the position and includes knowledge-based and performance-based training and evaluation where individuals satisfactorily demonstrate their proficiency in performing their ERO functions.

The Emergency Preparedness Manager or designee ensures new individuals fulfilling ERO positions receive training before assignment to their ERO position.

If training requirements are revised, then ensure T2000 qualification manager matches the new requirements.

Supplemental positions may be assembled as emergency needs dictate.

Personnel with badges for unescorted access to SONGS who do not have a specific emergency response role are considered supplemental.

Personnel requiring badges for unescorted access to SONGS receive initial and annual refresher training on general station procedures and policy. This training includes required actions to be taken if an emergency is declared at the station.

(S0123-XXI-TPD-GET) 6.1.3 6.1.3.1 ERO Personnel Selection 6.1.3.2 6.1.3.3 REFERENCE USE ERO assignments shall parallel the candidate's normal job knowledge, skills, and abilities as much as possible.

ERO personnel are selected based on input from SONGS management.

The Emergency Preparedness Manager or designee shall notify the respective Manager of a vacancy in an ERO position and request assistance in identifying a candidate to fill the vacancy.

6.1.3.4 6.1.3.4.1 6.1.3.4.2 6.1.3.5 S0123-VIII-ADMIN-2 Emergency Preparedness Program Training REV: 3 Page 8 of 18 WHEN a candidate is selected for an ERO position, THEN generate an Action Request (AR) to assign the ERO position to the candidate.

Include the following information in the AR for tracking purposes:

Add the term "ERO Position Qualification" in the AR Description Field.

Add the text "Programmatic Issue. EPPR: Emergency Planning Program" in the AR Description field.

Create an Assignment for the candidate that contains sufficient information to support the qualification completion, such as:

ERO position name; Required training to be completed for the ERO position per S0123-VIII-ADMIN-2; Date training is due to be completed; Initiation of form EP(123) ERPA, Emergency Response Personnel Assignment.

Completion of applicable sections of form EP(123) ERPA and turn over to Emergency Preparedness staff.

WHEN ERO candidate has completed the required ERO position training, Emergency Preparedness will complete the applicable section of form EP(123) ERPA.

6.2 ERO Training 6.2.1

.Initial Knowledge-Based Training 6.2.1.1 ERO personnel receive an initial overview course that familiarizes them with the PDEP fundamentals by providing basic information in the following areas:

Planning Basis Emergency Classifications Emergency Response Organization and Responsibilities Call out of Emergency Organization Emergency Response Facilities REFERENCE USE

6.2.1.2 6.2.1.3 50123-VIII-ADMIN-2 Emergency Preparedness Program Training REV:3 Page 9 of 18 Planning Basis:

An introduction to emergency preparedness and regulatory requirements A summary of the role of off-site radiological emergency support groups with emphasis on related emergency plans A summary of the role of the ERO during an emergency Emergency Response Organization and Responsibilities:

A review of the emergency response facilities, emergency response actions, emergency classifications, notification procedures, call-out of Emergency Organization, and associated forms A review of the appropriate procedures and emergency position responsibilities/duties Completion of the applicable EQR section.

6.2.2 6.2.2.1 Initial Performance-Based Training 6.2.2.2 REFERENCE USE Performance-based training using observat,ions, instructional walkthrough, and/or drill participation is typically scheduled upon completion of the knowledge based training requirements.

Performance requirements are designed to provide a practical element to the ERO Training Program and a familiarization with the conduct of operations associated with the assigned ERO position.

6.2.2.3 6.2.2.4 6.2.2.5 50123-VIII-ADMIN-2 Emergency Preparedness Program Training REV: 3 Page 10 of 18 Performance requirements are presented in the form of observations, instructional walkthrough, and/or drill participation.

Observations are designed to provide the trainee with an opportunity to observe their perspective ERO position "in action" during a drill or exercise.

It is preferred that performance training is completed in a drill/exercise setting and in the prospective ERO member's emergency response facility (ERF) versus a walkthrough, such that a trainee can perform their ERO position tasks under the control of a qualified ERO position holder.

Walkthroughs are designed to provide one-on-one or small group training sessions in an interactive lecture-type environment by Emergency Preparedness or a qualified ERO position holder. The walkthrough will usually take place within the ERF where the position is assigned and will cover the equipment, communications, procedures and activities necessary to fulfill the responsibilities and actions of that position.

Drills are designed to provide facility or organizational training sessions through interactive scenarios. Drills are conducted as part of the overall training program for the ERO and may sometimes be used to demonstrate periodically required objectives. Participation in a drill for purposes of training will not include an evaluation of an EP objective specific to that position, as this is designed to be a guided instructional period for the trainee, in which they may receive coaching and mentoring.

The ERO function may permit a training exemption based on previous experience in a similar position in accordance with S023-XXI-TRN, Conduct of Training*.

If an individual is re-qualifying for the same ERO position, then the Emergency Preparedness Manager or designee evaluates the differences between the initial and continuing training qualifications and how long the individual has been out of the position, and the individual completes the differences.

6.2.3 6.2.3.1 Annual Retraining 6.2.3.2 6.2.3.3 REFERENCE USE The annual retraining provides an overview of SONGS PDEP and position specific responsibilities.

This training is accomplished via completion of required training or demonstrating proficiency of the position during drills.

An individual who does not receive annual retraining is automatically removed from their ERO position in T2000 or equivalent.

50123-VIII-ADMIN-2 Emergency Preparedness Program Training REV: 3 Page 11 of 18 6.3 ERO Evaluation 6.4 6.3.1 After completion of knowledge and performance based training, the ERO trainee completes evaluation requirements of the EQR, by demonstrating the generic and key functions and tasks related to their ERO position during observations, instructional walkthrough, and/or drill participation.

6.3.2 Performance based elements are observed and assessed by individuals who have been designated as Evaluators.

6.3.3 Evaluation will involve practical demonstrations of the ability to perform the assigned duties and responsibilities for the position.

6.3.3.1 The evaluation process includes generic performance tasks and position-specific tasks for the ERO position.

6.3.3.2 Trainee proficiency may be demonstrated by successfully performing, simulating, or discussing how the task is performed.

6.3.3.3 The criteria for satisfactory demonstration of the ERO trainee's capability to perform their ERO duties and responsibilities are determined by the Evaluator in accordance with the EQR and applica.ble instructions and tasks.

6.3.3.4 Once the Evaluator determines the applicable performance tasks have been completed successfully by the trainee, the Evaluator's initials and signature on the EQR verifies the trainee has demonstrated the knowledge and skills to independently perform the ERO position.

• 6.3.3.5 The ERO candidate provides the completed EQR to the Emergency Preparedness Manager or designee for approval.

ERO Remediation 6.4.1 Unsatisfactory exercise or drill performance or failure to satisfactorily complete a portion of a training program may require some form of remediation. If remediation is required, then the Emergency Preparedness Manager or designee and the ERO member's Manager prepares a remedial action plan on a case-by-case basis.

6.5 Training of Support Personnel 6.5.1, Section 2, describes the curriculum for Support Personnel.

6.5.2 Key SCE Communications Department personnel assigned to act as spokespersons or to coordinate public information receive training on Emergency Plan fundamentals and dissemination of information during declared events at the station.

6.5.3 Outside contracted personnel or SCE personnel who are brought in to assist with mitigating or recovery actions who have not received emergency plan training will receive just-in-time training prior to performing response actions.

REFERENCE USE

6.6 50123-VIII-ADMIN-2 Emergency Preparedness Program Training REV:3 Page12of18 6.5.4 Personnel not requiring badges for unescorted access, including visitors, receive a copy of the Emergency Preparedness Information Card. This card lists the actions to take when sirens are sounded and the assembly area locations.

Figure 1: Typical Emergency Response Information Card Emergency Preparedness Staff Training 6.6.1 6.6.1.1 6.6.1.2 6.6.1.3 6.6.1.4 6.6.2 6.6.3 Emergency Preparedness staff is to maintain an adequate knowledge of regulations, planning techniques, and the latest applications of emergency equipment and supplies.

Training may include:

Training courses specific or related to emergency preparedness.

ObseNation of or participation in drills and/or exercises at other stations.

Participation in industry review and evaluation programs.

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

Emergency Preparedness Manager or designee shall use the Emergency Planning Staff Training Qualification Manual (EPSTQM) to select qualifications for completion and/or exemption. Attachment 1, Section 3, describes the curriculum for Emergency Planning Staff.

The Emergency Planning Staff Training Initial Qualification (EPSTQ 1) is required training for Emergency Preparedness personnel assigned to permanent positions and is a prerequisite to subsequent Qualification Guide Sections.

REFERENCE USE

S0123-VIII-ADMIN-2 Emergency Preparedness Program Training REV:3 Page 13 of 18 If an industry sponsored training program cannot be scheduled and attended, then the Emergency Preparedness Manager or designee may select an alternate training method.

6.6.4 EPSTQ1 requires assigned Emergency Preparedness Staff members to attend Emergency Planning training provided by the nuclear industry. This section is to be completed within one year of the staff assignment date.

6.6.5 Additional assigned qualification of the EPSTQM is to be completed as directed by the Emergency Preparedness Manager.

6.6.6 Personnel performing 10 CFR 50.54(q) screenings and evaluations shall have completed training per qualification EPSTQS. In addition, 6.6.6.1 Personnel performing 10 CFR 50.54(q) screenings and evaluations should have adequate expertise in technical or administrative matters related to the activity being addressed, or 6.6.6.2 If the scope of 10 CFR 50.54(q) screening or evaluation extends beyond expertise of preparer or reviewer, then assistance by a subject matter expert should be requested via the Emergency Preparedness Manager.

6.6.6.3 Continuing training on a calendar two year frequency for personnel retaining 1 O CFR 50.54(q) program qualifications is required. Training frequency and content could be augmented as needed to maintain good health of the 10 CFR 50.54(q) program.

6.6. 7 Waivers/ exemptions may be granted to contractors or SONGS staff that possess the necessary experience to complete the 10 CFR 50.54(q) Screening and Evaluations.

6.6.8 Continuing training course work selection and professional development for Emergency Preparedness personnel is to be reviewed and updated by the Emergency Preparedness Manager (or designee).

REFERENCE USE

Emergency Preparedness Program Training 6.7 Training of the Offsite Response Organizations 50123-VIII-ADMIN-2 REV: 3 Page 14 of 18 6.7.1 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 provided to these organizations:

6.7.1.1 Non-SONGS organizations that may provide specialized services during an emergency (i.e., Local law enforcement, firefighting, rescue, medical services, transport of injured) are provided or formally offered annual training.

6. 7.1.2 The training made available is designed to acquaint the. participants with the special problems potentially encountered during a nuclear plant emergency (including effects of radiation exposures and radiological contamination), notification procedures and their expected roles. Organizations that must enter the site also receive site-specific emergency response training and are instructed as to the identity (by position and title) of those persons in the onsite organization who will control their support activities.

6.7.1.3 Records for training offered and/or provided for the offsite responders are to be documented and maintained.

6.7.1.4 Provisions are in place to provide "Just in Time" training to emergency workers responding to the site during a large-scale event. This includes training on radiological and plant specific hazards.

6.7.2 Support for training of offsite emergency response organizations may be provided by SONGS when requested.

7.0 RETENTION OF RECORDS 7.1 The qualification records of individuals participating in the Emergency Plan Training Program shall be maintained in T2000 and archived in eDMRM under RPA# 92-0011.

7.2 The 50.54(q) Evaluator qualification record of personnel will be maintained in T2000 and archived in eDMRM under RPA# 92-0011.

REFERENCE USE

S0123-VIII-ADMIN-2 Emergency Preparedness Program Training REV: 3 Page 15 of 18

8.0 REFERENCES

/ COMMITMENTS 8.1 Implementing Reference 8.1.1 Procedures 8.1.1.1 S0123-XV-HU-3, Written Instruction Use and Adherence 8.1.1.2 S023-XXI-TRN, Conduct of Training 8.1.2 Other 8.1.2.1 EP(123) ERPA, Emergency Response Personnel Assignment 8.1.2.2 EPSTQM, Emergency Planning Staff Training Qualification Manual 8.2 Developmental References 8.2.1 Commitments 8.2.1.1 SONGS Permanently Defueled Emergency Plan, Volume 1 8.2.1.2 SONGS Permanently Defueled Emergency Plan, Volume 2, EAL Technical Bases Manual 8.2.2 Procedures 8.2.2.1 S0123-XXI-TPD-GET, General Employee Training Program Description 8.2.2.2 S0123-VIII-ER0-1, PDEP Standards and Expectations 8.2.2.3 SDS-RP1-PCD-1004, Survey and Release of Personnel REFERENCE USE

S0123-VIII-ADMIN-2 Emergency Preparedness Program Training REV: 3 Page 16 of 18 Emergency Plan Training Program Curriculum 1.

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1 ERO ONSHIFT ERO D1 Shift Manager I Emergency Director 7D1EQR X

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ONSHIFT ERO D2 ERO Certified Operator 7D2EQR X

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ONSHIFTERO D3 ERO Shift RP Technician 7D3EQR X

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ONSHIFT ERO D4 Security Personnel 7D4EQR X

ONSHIFT ERO D5 ERO Nuclear Security Shift Supervisor 7D5EQR X

X Augmented ERO D6 Duty ERO Coordinator 7D6EQR X

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Augmented ERO D7 RP Coordinator 7D7EQR X

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X Pre-designated Supplemental ERO DB Technical Coordinator 7D8EQR X

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Supplemental ERO No designated position [3]

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Support [4]

Support Personnel Key SCE Communications [5]

3 Emergency Preparedness Staff EP Staff EP Staff Notes:

[1]

[2]

Personnel with unescorted access to SONGS receive REDBADGE, which includes general PDEP overview (encode EPTBAS).

Selected station personnel receive basic training in first aid ( encode MT8216).

(3]

[4]

[5]

[6]

Supplemental positions may be assembled as emergency needs dictate.

Personnel who are brought in to assist who have not received Emergency Plan Training will receive Just in Time training.

Dissemination of information is part of SCE Communications Department requisite knowledge.

As directed by Emergency Preparedness Manager.

REFERENCE USE Page 1 of 1

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50123-VIII-ADMIN-2 Emergency Preparedness Program Training REV:3 Page 17 of 18 Ownership of Emergency Preparedness Training Elements PROGRAM OWNER: OPERATIONS (SCE)

ENCODE DESCRIPTION EPTB5B Mitigation Strategies Overview (RQ0832)

EPTMIT ERO - Mitigating Strategies MT8216 Adult/Infant/Child CPR/AED/First Aid PROGRAM OWNER: RADIATION PROTECTION/ CHEMISTRY (SDS)

ENCODE/

DESCRIPTION QUALIFICATION EP4100 Dose Assessment APRAD RESP [1]

Air Purifying Respirator Qualification - Radiological Surveys and Postings BRS40P Basic Radiation Survey GETRWT Radiation Worker Qualification SSCH35 Obtaining Radiation Samples SSCH36 Radioisotopic Analysis HPQ104 Surveys and Postings PROGRAM OWNER: EMERGENCY PREPAREDNESS (SCE)

ENCODE DESCRIPTION XXXEQR ALL ERO Qualification Records EPTERO ERO Responder EPTBAS General PDEP Overview (module of REDBAGE)

OSERO Offsite Emergency Response Training EPSTQ1 Emergency Planner Initial Qualification EPSTQ5 Emergency Plan and Procedure 50.54(q) Revision PROGRAM OWNER: SECURITY (SCE)

NON-ATTAINMENT I DESCRIPTION REDBADGE [2]

I Security Photo Identification Notes:

[1]

Air Purifying Respirator Qualification - Radiological includes a Physical Exam, Training, and Fit Test.

[2]

The non-attainment code "REDBADGE" requires an active Security Photo Identification Badge to maintain ERO qualification. This code is automatically posted once the ERO member has been issued a Security Photo Identification Badge (satisfying 10 CFR 26 requirements). If the ERO member's Security Photo Identification Badge becomes terminated, deactivated, or expired, then they will become unqualified for any position in Attachment 1 that requires an active badge.

REFERENCE USE Page 1 of 1

S0123-VIII-ADMIN-2 Emergency Preparedness Program Training REV:3 Page 18 of 18 Summary of Changes

\\ Attachment 3 Action Request tracking 10 CFR 50.54 (q):

1017-57551 Author:

Frank Grovich AR 1017-57551 Updated to reflect transition to SOS by various SONGS departments, including stating the decommissioning organization (SCE of SOS) associated with the department e.g., Operations is part of SCE See Table Betterment Updated called out procedure references due to Transition Radiation Protection Program to SOS.

Updated terminology due to transition from SAP to the AR System.

Emergency Planning [50.54(q)]

L. Sischo Cyber Security NOD (Nuclear Oversight Division)

NOD Final Approval:

Cognizant Supervision Final Approval:

Mike Chandler Anita Kowal Anita Kowal L. Sischo REFERENCE USE below.

Throughout Procedure Page 8 Page 1 of 1

PDEP Standards and Expectations Procedure Usage Requirements Information Use The user may complete the task from memory. However, the user is responsible for performing the activity according to the procedure.

Information use documents that contain a specific process order are performed in the given order unless otherwise specified within the document.

Color Usage I

This Document Does Not Contain Relevant Color LEVEL 1 QA PROGRAM AFFECTING 50.59 DNA/ 72.48 DNA/ RX DNA/ 50.54(q) APPLIES S0123-VIII-ER0-1 REV:2 Page 1 of 14 I

Sections ALL Location ALL Procedure Type Procedure Owner General Kelli Gallion

S0123-VIII-ER0-1 PDEP Standards and Expectations REV: 2 Page 2 of 14 TABLE OF CONTENTS Section Page 1.0 PURPOSE AND SCOPE................................................................................................................ 3 2.0 RESPONSIBILITIES....................................................................................................................... 3 3.0 DEFINITIONS................................................................................................................................. 7 4.0 PRECAUTIONS.............................................................................................................................. 7 5.0 PREREQUISITES................................................................................................................,.......... 7 6.0 PROCEDURE................................................................................................................................. 7 6.1 Emergency Plan Exercises and Drills.................................................................................. 7 6.2 Emergency Response Facilities and Emergency Plan Equipment Surveillance................... 8 6.3 Coordination with Offsite Response Organizations.............................................................. 8 6.4 Coordination of Offsite Response Organizations Training.................................................... 9 6.5 Audits [10 CFR 50.54 (t)]..................................................................................................... 9 6.6 Nuclear Regulatory Affairs Notification............................................................................... 1 O 6.7 Emergency Response Personnel.................................................................. :.................... 10 6.8 Permanently Defueled Emergency Plan Implementing Procedures................................... 11 6.9 Emergency Plan Training................................................................................................... 11 7.0 RETENTION OF RECORDS......................................................................................................... 11

8.0 REFERENCES

/ COMMITMENTS................................................................................................ 12 ATTACHMENT 1

Summary of Changes.................................................................................................................... 14 INFORMATION USE

50123-VIII-ER0-1 PDEP Standards and Expectations REV: 2 Page 3 of 14 1.0 PURPOSE AND SCOPE 1.1 To assign responsibilities and define organizational jurisdiction for the control of emergencies at SONGS in accordance with the Permanently Defueled Emergency Plan (PDEP).

1.2 To identify the requirements for maintaining an effective emergency preparedness program.

These requirements relate to the:

Emergency Response Organization PDEP Drills Emergency Facilities and Equipment Surveillance PDEP Implementing Procedures PDEP Training 1.3 To identify the requirements for coordination and management of the local, State, and Federal offsite emergency preparedness activities associated with SONGS in accordance with the PDEP, State, and Federal guidance and requirements (Reference Section 8.2.1).

2.0 RESPONSIBILITIES 2.1 Southern California Edison (SCE) is responsible for the safe and reliable maintenance of SONGS.

2.2 SONGS has primary responsibility for planning and implementing emergency measures within the Exclusion Area Boundary including overall accident assessment. These emergency measures include mitigation, corrective actions, protective measures, and aid for personnel onsite.

2.3 SONGS Decommissioning Solutions (SOS), as the decommissioning general contractor for SONGS, is responsible for supporting the planning and implementation of emergency preparedness at SONGS. SOS support includes areas such as Radiation Protection, Chemistry, Effluents, Environmental, Facilities, Training, Maintenance, Work Control, and Engineering.

2.4 The state and counties are responsible for maintaining plans that specify the responsibilities and functions for the major agencies, departments, and key individuals of their organizations. These plans address multiple types of accidents that may occur at facilities within their jurisdictions.

State and county information dissemination is performed in accordance with state and local plans.

Notifications and messages to the public are delivered through the media in accordance with state and local plans.

2.5 The company's Corporate Communications Department is responsible for the dissemination of information during an event at the station. The Communications Department will disseminate information to the public through press releases and media conferences in accordance with current Corporate Communications Department protocols.

INFORMATION USE

50123-VIII-ER0-1 PDEP Standards and Expectations REV:2 Page 4 of 14 2.6 The Emergency Preparedness Manager is responsible for the overall radiological emergency preparedness program associated with the station and for administering the program to ensure availability of resources in the event of an emergency. Specific responsibilities include the following:

Maintaining and updating the PDEP and associated procedures Documenting review of PDEP and associated procedures Coordinating PDEP with other station programs and procedures.

Overseeing Emergency Preparedness Training Program and ensuring proper records are maintained to document training and retaining of the ERO.

Overseeing and documenting Emergency Preparedness Drill and Exercise Program Documenting and maintaining Emergency Preparedness Facilities and Equipment Documenting and maintaining Emergency Preparedness interfaces with offsite agencies.

Performing and documenting appropriate evaluations of program and of classified emergency events Ensuring onsite personnel and offsite response organizations are notified of updates to the Emergency Plan or procedures.

Ensuring all Letters of Agreement are reviewed annually and updated as needed.

2.7 The Emergency Response Organization (ERO) is responsible for implementing the actions described in the PDEP. The ERO is made up of on-shift personnel, augmented by the Duty ERO Coordinator, Radiation Protection Coordinator, and other supplemental positions.

2.8 On-shift personnel are responsible to provide the initial response to an event. 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 necessary response actions until the augmenting ERO arrives or the event is terminated. The normal shift st~ffing assignments include the roles and responsibilities for their emergency response functions. The relationship between normal and emergency response positions for the shift personnel is unchanged when an event occurs. The skills and knowledge required to perform plant stabilization and mitigation are a normal function of operations specific positions. Operators receive routine training to ensure proficiency in this area.

INFORMATION USE

L S0123-VIII-ER0-1 PDEP Standards and Expectations REV: 2 Page 5 of 14 2.9 The Shift Manager is the on-shift individual responsible for declaring the initial emergency classification and assumes the role of Emergency Director upon event declaration. The Shift Manager has the authority and responsibility to immediately and unilaterally initiate any emergency actions. In accordance with 10 CFR 50.54(x) and (y), the Shift Manager has the authority to suspend any security measure described in the Physical Security Plan or any license condition or technical specification as necessary to facilitate response to emergency conditions.

2.9.1 Non-delegable responsibilities of the Emergency Director include the following:

Event classification and declaration Authorize notification of offsite authorities (State/local and NRC notifications)

Authorization for the use of EPA-400 emergency exposure controls (emergency worker dose limits that exceed 10 CFR 20 occupational exposure limits).

2.9.2 Key delegable responsibilities of the Emergency Director include the following:

Management of available station resources Initiation of assessment and mitigative/corrective actions Initiation of onsite protective actions Decision to call for offsite police, fire or ambulance assistance Augment the emergency staff as deemed necessary Notify SCE corporate officers and the company's duty spokesperson 2.10 The RP Technician is the on-shift individual responsible for radiological assessmentand radiation protection duties. Additional RP Technicians may be called to supplement the ERO. When an event is classified and the PDEP is implemented, the Technicians report to the Radiation Protection Coordinator if this position is activated. Responsibilities when implementing the PDEP include:

Performing radiological monitoring and surveys as directed Ensuring the habitability of the occupied areas of the plant Monitoring personnel exposures Performing radioisotopic analysis as directed (e.g. air and water samples).

Establishing and monitoring Radiological Control Areas (RCAs)

Providing radiological and first aid support to search and rescue and medical emergencies.

Maintaining a record of event activities and surveys performed Performing decontamination functions as necessary INFORMATION USE

50123-VIII-ER0-1 PDEP Standards and Expectations REV: 2 Page 6 of 14 2.11 The Certified Operator is the on-shift individual responsible to perform system and component manipulations and basic radiation surveys as needed. If the Shift Manager is unavailable or incapacitated for any reason the Certified Operator will assume duties until another Shift Manager arrives.

2.12 Station Security personnel are on-shift individuals responsible to assist the Emergency Director as directed.

2.13 The Duty ERO Coordinator responsibilities when implementing the PDEP include:

Reporting to the Command Center and assist Emergency Director with assessment, mitigation, and communications tasks.

Assisting the Emergency Director to supplement the emergency staff as deemed necessary.

Coordinating supplemental personnel and resource to support for emergency response.

2.14 The Radiation Protection Coordinator responsibilities when implementing the PDEP include:

Monitoring personnel accumulated dose Advising the Emergency Director concerning Radiological EALs Augmenting the emergency staff as deemed necessary Establishing Radiological Controls Performing Dose Assessment Establishing and maintaining communications as desired by the Emergency Director Maintaining a record of event activities 2.15 The Technical Coordinator may be called to supplement the ERO. The responsibilities of the Technical Coordinator when implementing the PDEP include:

Assisting with and arrange for other resources to evaluate technical data pertinent to plant conditions Augmenting the emergency staff as deemed necessary Assisting with incident assessment and recommend mitigative and corrective actions Assisting with search and rescue actions Coordinating maintenance and equipment restoration Establishing and maintain communications as desired by the Emergency Director Maintaining a record of event activities 2.16 Director, Nuclear Regulatory Affairs (NRA) is responsible for supporting the 10 CFR 50.54(t) evaluation.

INFORMATION USE

50123-VIII-ER0-1 PDEP Standards and Expectations REV:2 Page 7 of 14 2.17 Director, Nuclear Oversight Division (NOD) is responsible for perforn:iing the 10 CFR 50.54(t) evaluation.

2.18 Directors and Division Managers are responsible for:

Ensuring the Emergency Response Personnel staffing for their respective section(s) is maintained sufficiently to mitigate any emergency event.

Conducting assigned Emergency Plan equipment surveillances.

Implementing drill deficiency corrective actions.

Ensuring the coordination and appropriate identification of emergency response training program requirements.

3.0 DEFINITIONS 3.1 None.

4.0 PRECAUTIONS 4.1 None 5.0 PREREQUISITES 5.1 VERIFY this document is current by using one of the methods described in S0123-XV-HU-3.

5.2 VERIFY Level of Use requirements on the first page of this procedure.

6.0 PROCEDURE 6.1 Emergency Plan Exercises and Drills 6.1.1 A biennial Emergency Plan exercise shall be conducted to verify the integrated capability and adequacy of a major portion of the basic elements of the Emergency Plan.

6.1.2 Emergency Plan drills shall be conducted per the PDEP, at a minimum.

6.1.3 All exercise and drill evaluations/critiques shall include corrective actions for any identified weaknesses or deficiencies. Such corrective actions shall be completed in accordance with the Corrective Action Program.

INFORMATION USE

S0123-VIII-ER0-1 PDEP Standards and Expectations REV:2 Page 8 of 14 6.2 Emergency Response Facilities and Emergency Plan Equipment Surveillance 6.2.1 All Emergency Response Faeility surveillances and Emergency Plan equipment surveillances shall be performed and documented in accordance with approved procedures or instructions.

6.2.2 Discrepancies discovered in Emergency Response Facilities and equipment, noted in scheduled surveillances and/or Emergency Plan drills, shall be corrected in accordance with station procedures.

6.3 Coordination with Offsite Response Organizations The National Response Framework (NRF) is the guide to how the Nation responds to all types of disasters and emergencies. It is built on scalable, flexible, and adaptable concepts identified in the National Incident Management System (NIMS) to align key roles and responsibilities across the Nation. The NRF describes the principles, roles, and responsibilities, and coordinating structures for delivering the core capabilities required to respond to an incident and further describes how response efforts integrate with those of the other mission areas. The federal organizational response for an emergency at a SONGS station is made up of the following:

Nuclear Regulatory Commission (NRC),

Department of Homeland Security (OHS)

Marine Corps Base, Camp Pendleton Federal Bureau of Investigation (FBI) 6.3.1 Activities relative to state and local agencies SHALL be coordinated to ensure compliance with emergency plans, regulations, and guidance.

6.3.2 The agreements between SONGS and other support organizations SHALL be reviewed annually and updated as needed.

6.3.3 Liaison with the United States Marine Corps (USMC), Camp Pendleton, for SONGS Emergency Preparedness issues SHALL be provided.

6.3.4 Initial Emergency Action Levels (EALs) SHALL be reviewed and agreed upon by the State and local agencies jurisdictions.

6.3.4.1 EALs SHALL be reviewed annually with the State and local agencies.

INFORMATION USE

50123-VIII-ER0-1 PDEP Standards and Expectations REV:2 Page 9 of 14 6.4 Coordination of Offsite Response Organizations Training 6.4.1 Non-SONGS organizations that may provide specialized services during an emergency (i.e., local law enforcement, firefighting, rescue, medical services, transport of injured) are provided or formally offered annual training.

6.4.2 Training of offsite emergency response organizations is described in their respective local agencies emergency plans, with support provided by SONGS as requested.

6.4.3 Records for training offered and/or provided for the offsite responders is to be documented and maintained.

6.5 Audits [10 CFR 50.54 (t)l 6.5.1 To meet the requirements of 10 CFR 50.54 (t), SONGS coordinates an annual independent review of the Emergency Preparedness Program to examine conformance with 10 CFR 50.47, 10 CFR 50.54, and 10 CFR 50 Appendix E. Included in the audit/assessment are the following:

6.5.2 6.5.3 6.5.3.1 The PDEP and associated Implementing Procedures.

The emergency preparedness training including drills and exercises as well as any activation of the PDEP since the last program audit.

The readiness of the station Emergency Response Organization to perform its function.

The readiness of facilities and equipment to perform as outlined in the PDEP and procedures.

The interfaces between SONGS and local agencies pertaining to the overall Emergency Preparedness Program.

Results of this review are submitted to the Chief Nuclear Officer and Corporate Management's Internal Nuclear Managing Group (INMG).

The Emergency Preparedness Manager ensures any findings that deal with offsite interfaces are reviewed with the appropriate agencies.

Written notification will be provided to State and local agencies of the performance of the audit and the availability of the audit records for review at SONGS facilities.

INFORMATION USE

S0123-VIII-ER0-1 PDEP Standards and Expectations REV: 2 Page 10 of 14 6.6 Nuclear Regulatory Affairs Notification 6.6.1 Nuclear Regulatory Affairs SHALL be notified within 15 days of PDEP or PDEP Implementing Procedures issuance to facilitate NRC submittal requirements per S0123-XV-3.3, NRC Reporting Requirements and Assessments.

6. 7 Emergency Response Personnel 6.7.1 Emergency Response Personnel shall meet the criteria set forth in the PDEP, PDEP Implementing Procedures, and other applicable approved procedures and instructions.

6.7.2 Personnel with assigned Emergency Response Personnel (ERP) qualification codes shall:

6.7.2.1 Receive documented training regarding their specific responsibilities and duties during an emergency event.

6.7.2.2 Maintain ERO qualifications and Protected Area access.

6.7.2.3 Review the posted drill/ training schedule to ensure participation when assigned.

6.7.2.4 Review this procedure section annually. (Emergency Preparedness will issue an annual required reading assignment to document the procedure section review.)

6.7.2.5 Read all Emergency Preparedness Bulletins that are distributed.

6.7.2.6 Maintain contact and call-in information up-to-date.

6.7.2.7 Be available and prepared to provide relief support to the immediate ERO responders in the event of an actual emergency or drill.

6.7.3 When on duty for an ERO position:

• 6.7.3.1 Ensure no concurrent assignment to another on-duty ERO position or on-shift ERO position.

6. 7.3.2 Be prepared to arrive ready to perform responsibilities at the Command Center or other report location within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of alert declaration.

6.7.3.3 Be prepared with Southern California Edison (SCE) identification (i.e., security photo ID badge), second identification, proper attire, and PPE.

6.7.3.4 Remain Fit-for-Duty and refrain from alcohol consumption during the entire period of time on-duty. This includes the 5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> period prior to beginning on duty.

6.7.3.5 Ensure home arrangements (e.g., child care, transportation availability, etc.) are made in advance in preparation of being called-in in response to an emergency or drill.

INFORMATION USE

6.7.3.6 6.7.3.7 6.7.3.8 S0123-VIII-ER0-1 PDEP Standards and Expectations REV:2 Page 11 of 14 Ensure access to a well maintained vehicle with sufficient fuel.

IF unable to fulfill on-duty responsibilities, THEN arrange for duty coverage by another fully qualified individual in the same ERO position and inform the SM to update required documents (e.g., SM Turnover).

Maintain Duty Week coverage from 0700 hours0.0081 days <br />0.194 hours <br />0.00116 weeks <br />2.6635e-4 months <br /> on the Monday the corresponding Crew is on Day Shift to 0700 hours0.0081 days <br />0.194 hours <br />0.00116 weeks <br />2.6635e-4 months <br /> the next Monday.

6.8 Permanently Defueled Emergency Plan Implementing Procedures 6.8.1 PDEP Implementing Procedures shall be provided to direct the actions of Emergency Response Personnel during emergency conditions in accordance with PDEP.

6.9 Emergency Plan Training 6.9.1 Training for Emergency Response personnel shall be conducted in accordance with applicable Training Procedures.

7.0 RETENTION OF RECORDS 7.1 Training records shall be transmitted to Training in accordance with S023-XXI-REC.

7.2 The independent review of the Emergency Preparedness Program performed in accordance with 1 O CFR 50.54 (t) shall be forwarded to Records Management for a minimum 5-year retention (Reference Section 6.5).

INFORMATION USE

50123-VIII-ER0-1 PDEP Standards and Expectations REV: 2 Page 12 of 14

8.0 REFERENCES

/ COMMITMENTS 8.1 Implementing Reference 8.1.1 Procedures 8.1.1.1 S0123-XV-HU-3, Human Performance Program 8.1.1.2 S0123-VIII-ADMIN-1, Emergency Preparedness Program Maintenance 8.1.1.3 S0123-VIII-ADMIN-2, Emergency Preparedness Training Program Description 8.1.1.4 S0123-VIII-ADMIN-3, Emergency Preparedness Program Drill Development and Evaluation 8.1.1.5 S0123-VIII-ER0-2, Shift Manager/Emergency Director Checklist 8.1.1.6 S0123-VIII-ER0-3, Duty ERO Coordinator Checklist 8.1.1.7 S0123-VIII-ER0-4, Technical Coordinator Checklist 8.1.1.8 S0123-VII I-ER0-5, Radiation Protection Coordinator Checklist 8.1.1.9 S023-XXI-REC, Training Records 8.1.1.10 S0123-XV-3.3, NRG Reporting Requirements and Assessments 8.2 Developmental References 8.2.1 Commitments 8.2.1.1 SONGS Permanently Defueled Emergency Plan, Volume 1 8.2.1.2 SONGS Permanently Defueled Emergency Plan, Volume 2, EAL Technical Bases Manual 8.2.1.3 10 CFR 50.47, Emergency Plans 8.2.1.4 10 CFR 50.54 (t), Conditions of licenses 8.2.1.5 1 O CFR 50, Appendix E, Emergency Planning and Preparedness for Production arid Utilization Facilities INFORMATION USE

50123-VIII-ER0-1 PDEP Standards and Expectations REV:2 Page 13 of 14 8.2.2

()ther 8.2.2.1 NUREG-0728, US Nuclear Regulatory Commission, Concept of ()perations: NRC Incident Response 8.2.2.2 National Response Framework 8.2.2.3 State of California Emergency Response Plan INFORMATION USE

PDEP Standards and Expectations Summary of Changes Notification tracking 10 CFR 50.54 (q):

1017-57551 Author:

Lucia Sischo AR 1017-57551 Added step to indicate SOS is responsible for supporting the planning and implementation of emergency preparedness at SONGS.

NOD Final Approval:

CFDM / Designee Final Approval:

INFORMATION USE Anita Kowal Kelli Gallion 50123-VIII-ER0-1 REV:2 Page 14 of 14 I Attachment 1 See Below 3

Page 1 of 1 Report and Analysis Summaries

Reference:

S0123-VIII-ADMIN-4 San Onofre Nuclear Generating Station Report and Analysis Summary 10 CFR 50.54(q)(5)

Document Number: S0123-VIII-ADMIN-2 Revision 3

Title:

Emergency Preparedness Program Training SONGS Action Request: 1017-57551 Change Description The 10CFR50.54(q) evaluation for S0123-VIII-ADMIN-2 Revision 3 was performed under AR 1017-57551 assignment 14. This revision:

Identifies the different organizations involved in the Emergency Preparedness training due to the transition of programs to SONGS Decommissioning Solutions (SOS), and updates the respective organizations responsibilities.

Incorporates editorial changes.

PREPARED BY: Lucia Sischo DATE: 11/8/2017 Analysis Summary After incorporation of the changes in S0123-VIII-ADMIN-2 Revision 3, the Permanently Defueled Emergency Plan continues to maintain:

• Specific content and frequency for the training provided to the Emergency Response Organization

• ERO personnel position specific responsibilities The Permanently Defueled Emergency Plan continues to meet the regulatory requirements of 10CFR50.47(b) and 10CFR50 Appendix E, Section IV, as exempted.

The changes do not modify the licensing basis with regards to a reduction in effectiveness. The capability and timeliness to perform the planning function is not altered by the changes. The capability and timeliness to perform the associated elements are also maintained.

The changes can be implemented without prior NRG approval.

REVIEWED BY: Kevin Sheek DATE: 11/8/2017 Page 1 of 1 EP(123) SOA Rev 2 09/2017

Reference:

S0123-VIII-ADMIN-4 San Onofre Nuclear Generating Station Report and Analysis Summary 10 CFR 50.54(q)(5)

Document Number: S0123-VIII-ER0-1 Revision 2

Title:

PDEP Standards and Expectations SONGS Action Request: 1017-57551 I Change Description The 10CFR50.54(q) evaluation for S0123-VIII-ER0-1 Revision 2 was performed under AR 1017-57551 assignment 14. This revision:

lddentifies the different groups that support Emergency Preparedness due to the transition of programs to SONGS Decommissioning Solutions (SOS).

Incorporates editorial changes.

PREPARED BY: Lucia Sischo DATE: 11/8/2017 I Analysis Summary I

After incorporation of the changes in S0123-VIII-ER0-1 Revision 2, the Permanently Defueled Emergency Plan continues to maintain:

Personnel to respond and to augment its initial response on a continuous basis On-shift responsibilities for emergency response Adequate staffing to provide initial facility accident response at all times Timely augmentation of response capabilities The Emergency Preparedness Manager responsibility for the overall radiological emergency preparedness program The Permanently Defueled Emergency Plan continues to meet the regulatory requirements of 1 OCFR50.47(b) and 1 OCFR50 Appendix E,Section IV, as exempted.

The changes do not modify the licensing basis with regards to a reduction in effectiveness. The capability and timeliness to perform the applicable planning functions is not altered by the changes. The capability and timeliness to perform the associated elements are also maintained.

The changes can be implemented without prior NRC approval.

REVIEWED BY: Kevin Sheek DATE: 11/8/2017 Page 1 of 1 EP(123) SOA Rev 2 09/2017