ML17334B446

Application for Amends to Licenses DPR-58 & DPR-74,deleting TS Table 3.6-1, Containment Isolation Valves,Per Guidance Provided in GL 91-08, Removal of Component Lists from Ts. Lists of Valves Will Be Incorporated Into Plant Procedures

ML17334B446
Person / Time
Site:	Cook
Issue date:	09/24/1992
From:	Fitzpatrick E INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	Murley T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17329A620	List: ML17329A619 ML17334B446
References
AEP:NRC-1178, GL-91-08, GL-91-8, NUDOCS 9210050055
Download: ML17334B446 (109)

Text

ACCELERATED DISTRIBUTlON DEMONSTRATION SYSTEM REGULAT INFORMATION DISTRIBUTIO STEM (RIDS)

ACCESSION NBR:9210050055 DOC.DATE: 92/09/24 NOTARIZED: YES DOCKET I FACIL:50-315 Donald C. Cook Nuclear Power Plant, Unit 1, Indiana M 05000315 50-316 Donald C. Cook Nuclear Power Plant, Unit 2, Indiana M 05000316 AUTH. NAME AUTHOR AFFILIATION FITZPATRICK,E. Indiana Michigan Power Co. (formerly Indiana S Michigan Ele RECIP.NAME RECIPIENT AFFILIATION MURLEY,T.E. Document Control Branch (Document Control Desk)

SUBJECT:

Application for amends to Licenses DPR-58 a DPR-74,deleting R TS Table 3.6-1, "Containment Isolation Valves",per guidance prbvided in GL 91-08, "Removal of Component Lists from TS."

Lists of valves will be incorporated into plant procedures. (r ZQ) 0 DzsTRzBDTzoN coDE: AOOZD copzEs REGEzvED:LTR j ENGL TITLE: OR Submittal: General Distribution i szsE: Il + <5+

S NOTES:

/

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD3-1 LA 1 1 PD3-1 PD 1 1 STANG I J 2 . 2 D t

INTERNAL: NRR/DET/ESGB 1 1 NRR/DOEA/OTSB11 1 1 0 NRR/DST/SELB 7E 1 1 NRR/DST/SICBSH7 1 1 NRR/DST/SRXB 8E 1 1 NUDOCS-ABSTRACT 1 1 S OC 1 0 OGC/HDS2 1 0 EG T'IXE 01 1 1 RES/DSIR/EIB 1 1 EXTERNA : RC PDR 1 1 NSIC 1 1 NOTE TO ALL "RIDS" RECIPIENTS PLEASE HELP US TO REDUCE WASTE!

CONTACT THE DOCUMENT CONTROL DESK.

ROOM PI-S7 ( EXT.. 504- 065) TO ELIMINATE/YOURNAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 16 ENCL 14

Indiana Michigan Power Company

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P.O. Box 16631 Columbus, OH 43216 R

AEP:NRC:1178 Donald C. Cook Nuclear Plant Units 1 and 2 Docket Nos. 50-315 and 50-316 License Nos. DPR-58 and DPR-74 REMOVAL OF CONTAINMENT ISOLATION VALVE LIST FROM TECHNICAL SPECIFICATIONS (GENERIC LETTER"91-08) ~ -.

U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Attn: T. E. Murley September 24, 1992

Dear Dr. Murley:

This letter and its attachments constitute an application for amendment to the Technical Specifications (T/Ss) for the Donald C.

Cook Nuclear Plant Units 1 and 2. Specifically, we are proposing to delete Table 3.6-1, "Containment Isolation Valves," and make other associated changes to the T/Ss in accordance with the guidance provided in Generic Letter 91-08, "Removal of Component Lists from Technical Specifications," dated May 6, 1991. A list of containment isolation valves will be incorporated into Cook Nuclear Plant procedures prior to the 1994 refueling outages. At that time, the procedures will be available for your review. We believe that this will address Unresolved Item 316/90006-01.

Attachment 1 provides a detailed description of the proposed changes, the justification for the changes, and our determination of no significant hazards consideration performed pursuant to 10 CFR 50.92. Attachment 2 contains the existing T/Ss pages marked to reflect the proposed changes. Attachment 3 contains the proposed T/Ss pages.

We believe that the proposed changes will not result in (1) a significant change in the types of any effluent that may be released offsite, or (2) a significant increase in individual or cumulative occupational radiation exposure.

These proposed changes have been reviewed by the Plant Nuclear Safety Review Committee and the Nuclear Safety and Design Review Committee.

qO 1

9210050055, 920924 PDR <'DOCK'. 050003i5 PDR

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Dr. T. E. Murley AEP:NRC:1178 In compliance with the requirements of 10 CFR 50.91 (b)(1), copies of this letter and its attachments have been transmitted to the Michigan Public Service Commission and the Michigan Department of Public Health.

This letter is submitted pursuant to 10 CFR 50.54(f) and, as such, an oath statement is enclosed.

~ S1ncerely-I E. E. Fitzpa rick Vice President rag Attachments CC: D. H. Williams, Jr.

A. A. Blind - Bridgman J. R. Padgett G. Charnoff NFEM Section Chief A. B. Davis - Region III NRC Resident Inspector - Bridgman

STATE OF OHIO)

COUNTY OF FRANKLIN)

E. E. Fitzpatrick;- being duly. sworn;--deposes and.says that he is the Vice President of licensee Indiana Michigan Power Company, that he has read the foregoing Request for Removal of Containment Isolation Valve List From Technical Specifications and knows the contents thereof; and that said contents are true to the best of his knowledge and belief.

Subscribed and sworn to before me this +~

day of I 19 sz NOT PUBLIC RITA D. HILL NOTARY PUBLIC. STATE OF OHIO

EMERGENCY PLAN RECORD OF REVISIONS REVISION R SION NAME NO. DA E Jan. 2, 1981 J. J. arnock Aua. 3 1982 J. . Marnock Sept. 16, 1983 . T, MacRae Sept. 28, 1984 T. G. Harshbarger September 30, 198 T. G. Harshbarger Hov. 24, 1986 T. G. Harshbarger Sept. 15, 1 87 T. G Harshbarger Seotemb 30, 1988 T. G. rshbaraer Nov er 30, 1989 L. M. Bo ds Nov nber 30, 1990 J. S. Lewi 10 N vember 15, 1991 J. S. Lewis

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TABLE OF CONTENTS SECTION TITLE PAGE 12 '-1 12.3.1.1 Purpose 12.3-2 12.3.1.2 Objective 12.3-2 12.3.1.3 Scope 12 ~ 3 2 12.3.1.4 Initiation of Emergency Plan 12 ~ 3 2 12.3.1.5 Definitions 12 ~ 3 3 12.3.2 ORGANIZATIONAL CONTROL 12.3-9 12.3.2.1 Organizational Control 12.3-10 12.3.3 D. C. COOK EMERGENCY RESPONSE ORGANIZATION 12.3-12 12.3.3.1 Normal On-Site Operating Organization 12.3-13 12.3.3.1.1 Plant Manager 12. 3-13 12.3.3 '.2 Assistant Plant Manager Production 12.3-13 12 ~ 3 ~ 3 ~ 1.3 Assistant Plant Manager Technical Support 12.3-14 12.3.3.1.4 Assistant Plant Manager projects 12.3-14 12.3.3.1.5 Licensing Activity Coordinator 12.3-14 12.3 '.1.6 Administrative Superintendent 12.3-14 12.3.3.1.7 Maintenance Superintendent 12.3-15 12.3.3.1.8 Operations Superintendent 12.=3-15 12.3.3.1.9 General Supervisor Scheduling 12 ~ 3-16 12.3.3.1.10 Design Changes Superintendent 12.3-16 12.3.3.1.11 Safety and Assessment Superintendent 12.3-16 f

12.3.3.1.12 Stores Supervisor 12.3-16 i

Revision 9

TABLE OF CONTENTS (cont'd.)

SECTION TITZZ PAGE 12 ~ 3 3 ~ 1. 13 Superintendent, Plant Engineering 12 ~ 3 17 12.3.3.1.14 Technical - Physical Sciences Superintendent 12.3-17 12.3.3.2 Emergency Organization 12 '-17 12 ~ 3 ~ 3 ~ 2 ~ 1 Site Emergency Coordinator 12.3-18 12.3 '.2 ' Shift Technical Advisor 12.3-18 12 ~ 3 ~ 3 ~ 2 ~ 3 Security Director 12.3-18 12.3.3.2.4 Assistant Shift Supervisor 12.3-19 12.3.3.2.5 Operations Staging Manager 12.3-.19 12.3 ' ' ' Skill Supervisors 12.3-19 12.3 ' ' ' Radiation Protection Director 12. 3-20 12.3 '.2.8 Operations Staging Area

'-20 Communicator 12 12.3 '.2.9 Damage Control Team 12 '-20 12.3.3.2.10 Re-entry and Rescue Team 12.3-20 12 ' ' ' 11 Onsite Radiation Monitoring Team 12.3-21 12.3.3.2.12 Technical Director 12. 3-21 12.3.3.2.13 Plant Evaluation Team 12 '-22 12.3.3.2.14 Administrative Coordinator 12.3-22 12.3.3.2.15 Radiological Assessment Coordinator 12.3-23 12.3.3.2.16 Administrative Support Personnel (TSC) 12.3-23 12.3.3.2.17 Emergency Operations Facility Manager 12 ~ 3 23 Revision 10

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TABLE OF CONTENTS (cont'd. )

SECTION TITLE PAGE 12.3.3.3.11 Corporate Support Group Manager 12 '-31 12.3.3.3.12 Administration and Logistics Manager 12 '-31 12.3.3.4 Emergency Public Information Organization 12.3-32 12.3.3.4 ' Emergency News Center Manager 12 ~ 3 32 12.3.3.4.2 Emergency News Center Staff 12 ~ 3 33 12.3.3.4.3 I6M Public Affairs Director 12 ~ 3 33 12 '.3.4 ' JPIC Administrator 12 '-33 10 12.3.3.4.5 Utility Spokesperson 12 ~ 3 33 12.3.3.4.6 Benton Harbor - St. Joseph Division Administrative Assistant 1203-33 12.3.3.4.7 Rumor Control Center Coordinator 12 0 3-33 12.3.3.4.8 Support Office Coordinator 12.3-34 12.3.3.5 Off-Site Group 12.3-34 12.3.3.5.1 Berrien County Sheriff's Department 12.3-34 12.3.3.5.2 State of Michigan 12.3-35 12.3.3.5.3 Federal Government 12.3-39 12.3.3.5.4 Fire Department 12.3-40 12.3.3.6 Overall Organization & Communication 12.3-40 12.3.3.7 Nuclear Transportation Accidents 12.3-40 12.3.3.8 Nuclear Power Plant Accidents 12.3-41 12.3.4 EMERGENCY RESPONSE SUPPORT AND RESOURCES 12.3-57 12.3.4.1 Federal Radiological Assistance 12.3-58 12.3.4.2 Off-Site Liaisons 12.3-59 iv Revision 10.

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Donald C. Cook Nuclear Plant Emer enc Plan 12.3.1'ntroduction 12.3.1.1 ~Pur ose The purpose of the Donald C. Cook Nuclear Plant Emergency Plan is to fulfill the requirements as set forth in 10 CFR 50 and Appendix E and the planning objectives set forth in NUREG-0654/-

FEMA-REP-1 Revision 1.

The Donald C. Cook Nuclear Plant Emergency Plan has the funda-mental objective of protecting the health and safety of the general public, persons temporarily visiting or assigned to the reactor facility, and employees of the plant.

12.3.1.3 ~Sco e The specific details for the implementation of this emergency plan are incorporated in the Donald C. Cook Emergency Plan Procedures, the American Electric Power Service Corporation (AEPSC) Emergency Response Manual, and the I&M Emergency Response Manual pursuant to the requirements specified in Section 12.3.1.1. The Emergency Plan Procedures include or reference procedures developed for plant operating, radiological, security and administrative functions as necessary in order to ensure that all requirements are adequately defined. Additionally the AEPSC Emergency Response Manual and the I&M Emergency Response Manual describe the duties and responsibilities of both AEPSC and I&M personnel in providing support to the Plant Staff in emergency situations. Appendix A to this Plan contains a list of Plant Emergency Plan Procedures while Appendix B to this Plan contains an overview of both the AEPSC Emergency Response Manual and the I&M Emergency Response Manual. This plan is primarily concerned with an accidental release of radioactive material, but it also concerned with non-nuclear major accidents which could prove is hazardous to the safe operation of the plant.

12.3.1.4 Initiation of the Emer enc Plan During emergency conditions, the Shift Supervisor is responsible for the initiation of the Emergency Plan and Emergency Plan Procedures. The Shift Supervisor's first responsibility upon being alerted to an abnormal situation is to immediately take whatever measures are necessary to return to and maintain the safe condition of the plant. In the event that the Shift Supervisor is not immediately available, the initiation of this plan is the responsibility of the senior individual present possessing an NRC license.

12 '-2 Revision 8

operations centers established by State/County authorities.

This area contains access to instrumentation and necessary reference material for the plant management and support personnel.

The primary function of the TSC is to provide an area in close proximity to the control room from which the plant operators can receive technical support and assistance from personnel who have the experience and expertise in nuclear plant operations, maintenance, safety and design. Their function is to mitigate the cause(s) of a nuclear incident and during the short-term activation provide for off-site dose calculations, act as a communication center to off-site response organizations and act as a data gathering center for plant parameters.

Access to the Technical Support Center will typically be limited immediately to those individuals listed in Figure 12-6, and as the situation demands, those individuals required by the Plant Manager or his alternate.

19. Off-Site Monitorin Teams. These are teams released to monitor the radiation levels anywhere outside of the protected area.

12 '-6 Revision 9

12.3.3.1.3 Assistant Plant Mana er Technical Su ort The Assistant Plant Manager Technical Support is responsible to the Plant Manager for advising him on plant policies and to assist in providing continuity between all plant departments for the safe and efficient operation of the Cook Nuclear Plant. In the absence of the Plant Manager, one of the Assistant, Plant

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Managers will be assigned to be in charge of the plant. The Assistant Plant Manager Technical Support is responsible for the following major functions:

(1) Assist in planning, organizing, coordinating, directing, and controlling the activities of department heads in effecting harmonious, efficient, safe, and economical operation of the plant, with primary responsibilities for the Technical Physical Science, Technical Engineering and Computer Sciences Departments and Emergency Planning.

(2) Serve as Chairman of the PNSRC Subcommittee on Procedures.

12.3.3.1.4 Assistant Plant Mana er - Pro ects The Assistant Plant Manager Projects is responsible to the Plant Manager for advising him on plant policies and to assist in providing cont'inuity between all plant departments for the safe and efficient operation of the Cook Nuclear Plant. In the absence of the Plant Manager, one of the Assistant Plant Managers will be assigned to be in charge of the plant. The Assistant Plant Manager Projects is responsible for the following:

Assist in planning, organizing, coordinating, directing and controlling the activities of department heads in effecting harmonious, efficient, safe and economical operation of the plant with primary responsibilities for modification, pre-outage and outage activities.

12.3.3.1.5 Licensin Activit Coordinator The Licensing Activity Coordinator is responsible to the Plant Manager for organizing licensing activities at the plant level and to ensure earliest and continuous plant involvement in the licensing process.

12.3.3.1.6 Administrative Su erintendent The Administrative Superintendent reports to the Plant Manager.

He is responsible for the development and efficient implementation of all site centralized Training activities, and for administration of the facility's NRC-approved physical Security Program. The Administrative Superintendent is responsible for the following specific functions:

12.3-14 Revision 8

Administer the centralized facility Training complex, P

simulator, and programs contained therein, assuring that program development is consistent with the systematic approach to training,,INPO standards, regulatory and corporate requirements.

12. 3-14 (a) Revision 5

(2) Administer the physical Security Program in compliance with regulatory standards, Modified Amended Security Plan, and Company policy.

12.3.3.1.7 Maintenance Su erintendent The Maintenance Superintendent is responsible to the Assistant

'Plant Manager Production for supervising, planning, and directing the activities related to the maintenance and installation of all power plant equipment, structures, grounds, and yards; for preparing plant maintenance budgets, construction budgets, improvement requisitions, and work orders; for preparation and maintenance of records and reports pertinent to equipment maintenance, cost histories, regulatory agency requirements; for administering contracts and scheduling outside contractors'ork forces; for advising plant management on matters relating thereto; and for coordinating these activities

-with related plant and system departments.

12.3.3.1.8 0 erations Su erintendent The Operations Superintendent reports directly to the Assistant Plant Manager Production, and is responsible for enforcement and coordination of plant regulations, procedures, policies, and objectives to assure safety, efficiency, and continuity in the operation of a nuclear generating station within the limits of the operating license and the Technical Specifications; formulates policies and procedures related thereto, supervises coordination of Operations Department work with other plant departments, Indiana Michigan Power Company, and American Electric Power Service Corporation. The Operations Superintendent is responsible for the following specific functions:

(1) Plan, schedule, and direct the activities relating to the operation of a nuclear generating station and associated switchyards; cooperate in planning and scheduling of work and procedures for refueling and maintenance of the nuclear generating units; direct and coordinate loading of the nuclear generating units.

(2) Review reports and records and direct general inspection of operating conditions of plant equipment and'investigate any abnormal conditions, making recommendations for repairs.

Establish and administer equipment clearance procedures consistent with company, plant, and radiation protection standards; authorize and arrange for equipment outages to meet normal or emergency conditions. Provide the shift operating crews with appropriate procedures and instructions to assist them in operating the plant safely and efficiently.

12.3-15 Revision 8

(3) Approve operator training programs administered by the Training Department designed to provide operating personnel with the knowledge and skill required for safe operation of the facility and for obtaining and holding NRC operator license. Coordinate training programs in plant safety and emergency procedures for Operating Department personnel to assure that each shift group will function properly in the event of injury of personnel, fire, nuclear incident, or civil disorder.

(4) Secure a facility Senior Reactor Operator's license within two years of not be required incumbency if he has never held one. He shall to maintain the license.

12.3.3.1.9 General Su ervisor Schedulin The General Supervisor Scheduling reports to the Assistant Plant Manager Projects. He is responsible for the advanced planning of scheduled and forced outages, including the scheduling and coordination of all plant activities associated with refueling, preventive maintenance, corrective maintenance, equipment overhaul, Technical Specification surveillances, and design change installations.

12.3.3.1.10 Desi n Chan es Su erintendent The Design Changes Superintendent reports to the Assistant Plant Manager -'rojects. He is responsible for the coordination of all plant activities associated -with the initiation, review, approval, engineering, design, production, examination, inspection, test, turnover, and closeout of design changes.

4 12.3.3.1.11 Safet and Assessment Su erintendent The Safety and Assessment Superintendent reports to the Plant Manager for the development and implementation of an effective Safety program. This encompasses, but is not limited to, the planning and directing of quality control activities to assure that industry codes, Nuclear Regulatory regulations, and company instructions and policies regarding quality control for the nuclear generating station are enforced, and that these activities are properly documented.

12.3.3.1.12 Stores Su ervisor The Stores Supervisor reports to the Planning Superintendent.

The Stores Department, under the direction of the Stores Supervisor, is responsible for the procurement, receiving, quality control receipt inspection, storage, handling, issue, maintaining stock levels, sale, and overall control of stores nuclear and standard grade material, components, and equipment, providing material service and support to all plant departments in accordance with policies and procedures required by AEP Purchasing and Stores, AEP Quality Assurance, and Nuclear Regulatory Commission, which are administered and enforced by the Stores organization in a total effort to ensure safety and plant reliability.

12.3.-16 Revision 8

10 12.3.3.1.13 Su erintendent Plant En ineerin Io The Superintendent, Plant Engineering is responsible to the (

Assistant Plant Manager Technical Support to provide overall planning and direction of engineering and technical studies, nuclear fuel management, and equipment performance. These activities support daily on-site operations in a safe, reliable, and efficient manner in accordance with all corporate policies, applicable laws, regulations, licenses, and Technical Specification requirements.

12.3.3.1.14 Technical Ph sical Sciences Su erintendent The Technical-Physical Sciences Superintendent reports to the Assistant Plant Manager - Technical Support. He is responsible to provide technical and engineering services in the fields of chemistry, radiation protection, ALARA, radioactive material control, and environmental in support of the safe operation of the plant and the health and safety of the employees and the public.

12.3.3.2 Emer enc Or anization The Donald C. Cook Plant Emergency Organization is presented in Figure 12-5 and 12-6. The extent to which the Emergency Organization is manned would be dependent upon the emergency classification and the discretion of the Site Emergency Coordinator. For an Unusual Event only the Control Room will be manned. For an Alert, the TSC, OSC, IAG, and EOF would be activated and manned. All emergency response facilities will be activated during a Site Area or General Emergency. The Donald C. 10 Cook emergency organization is capable of continuous 24-hour

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operations for a protracted period.

The authority for initiation of the emergency plan is delegated to the senior supervisor of the on-duty operating shift (e.g.,

the Shift Supervisor). He is the individual responsible for the emergency response functions until relieved by the Plant Manager (or Alternate).

In the event of an emergency situation, the Shift Supervisor (or Senior NRC licensed individual) will call upon any additional members of the Plant Organization as shown in Figure 12-4. These additional individuals, along with on-duty operating shift, form the Plant Emergency Response Organization. The initiation of ~an aspects of this emergency plan allows for the use of the total plant organization shown in Figure 12-4, at the discretion of the Shift Supervisor.

The major assignments of the on-duty operating shift and the supplemental personnel in the Emergency Plant Organization are delineated in Table 12-1.

12 '-17 Revision 10

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12.3.3.2.13 Plant Evaluation Team The Plant Evaluation Team operates out of the Technical Support Center and is made up of individuals from a variety of disciplines including Nuclear Engineering, Environmental, Chemistry, Control and Instrumentation, Performance Engineering, Shift Technical Advisors, Operations, Computer and Training.

The Plant Evaluation Team reports to the Technical Director and is responsible for but not limited to the following:

(1) Providing an independent technical analysis of plant conditions; (2) Developing corrective action recommendations; (3) Providing technical assistance to operations personnel when requested; (4) Responding to queries from off-site agencies, as directed by the Technical Director; and (5) Maintaining contact with the Initial Assessment Group in Columbus, Ohio.

12.3.3.2'.14 Administrative Coordinator Upon arrival at the Technical Support Center the Accounting Supervisor assumes the position of the Administrative Coordinator. 'The Administrative Coordinator reports directly to the Technical Director and is responsible for but not limited to the following:

(1) Establishing a chronological history log of events that occur by assigning a scribe to maintain the plant status board in the Plant Evaluation Team Room.

(2) Compiling information to be reported off-site, coordinating input from the Plant Evaluation Team and Radiological Assessment Coordinator, and obtaining the approval of the Technical Director prior to release of any information off-site.

(3) Providing communicators for establishing communication with the Initial Assessment Group, Emergency Operations Facility, Operations Staging Area and the Emergency News Center.

Alternates to the Accounting Supervisor are:

10 (1) Budgeting Coordinator.

io (2) Nuclear Records Management Supervisor. (

12 '-22 Revision 10

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12.3.3.2.15 Radiolo ical Assessment Coordinator Upon arrival at the Technical Support Center a Radiation Protection Engineer or Supervisor assumes the position of the Radiological Assessment Coordinator. The Radiological Assessment Coordinator reports to the Technical Director and is responsible for but not limited to performing analysis of on-site radiological conditions and development of appropriate protective actions for on-site response teams.

Alternates to the Radiation Protection Engineer are members of the Technical Physical Science Department or Training Staff.

12.3.3.2.16 Administrative Su ort Personnel TSC Additional personnel needed to provide administrative support to the Technical Support Center include Runners, Scribes, Communicators, Telecopy Operators and Boardwriters. The Plant Emergency Plan Procedures designate individuals to fill Administrative Support positions. These procedures also define the the responsibilities and actions of the Administrative Support Personnel.

12.3.3.2.17 Emer enc 0 erations Facilit Mana er Upon arrival at the Emergency Operations Facility (EOF) the io Superintendent Technical Physical Science assumes the position of the EOF Manager. The EOF Manager reports directly to the Site

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Emergency Coordinator and is responsible for but not limited to the following:

(1) Oversee activation of the EOF.

(2) Ensure the EOF assumes responsibility for communications with off-site organizations.

(3) Ensure the EOF assumes dose assessment responsibilities and responsibilities for off-site protective action recommendations.

(4) Direct the activities of the Environmental Assessment Director in response to the emergency.

(5) Ensure that access and security controls are established at the EOF.

(6) Assist in the development of plans and procedures for sampling and processing liquid, gaseous and solid radioactive waste.

12.3-23 Revision 10

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10 Alternates to the Superintendent - Technical Physical Science are in the following order:

(1) Licensing Activity Coordinator (2) Safety and Assessment Superintendent 12.3.3.2.18 Environmental Assessment Director Upon arrival at the EOF, the Plant Radiation Protection Supervisor assumes the position of the Environmental Assessment Director. The Environmental Assessment Director reports to the EOF Manager and is responsible for the direction and control of all off-site radiological calculations, aspects of the emergency. This protective action includes dose projection recommendation development, and the collection and analysis of radiological samples.

Alternate to the Plant Radiation Protection Supervisor is a Radiation Protection Engineer or designee.

12.3.3.2.19 Communication Director Upon arrival at the EOF a member of the Plant Training Section assumes the position of the Communication Director. The Communication Director reports to the EOF Manager and is responsible for but not limited to the following: ~

(1) Establish a chronological history log of events and make this log available to EOF personnel; (2) Ensure that communications and dose assessment personnel are regularly brought up-to-date on information recpxired to perform their functions; and, (3) Establish communications with the Berrien County Sheriff's Department, Michigan State Police, Nuclear Regulatory Commission, Initial Assessment Group and the Emergency News Center.

Alternates to the Plant Training Section member are other Plant Training Section members.

12.3.3.2.20 Environmental Assessment Coordinator Upon arrival at the EOF a Radiation Protection Engineer or designee assumes the position of Environmental Assessment Coordinator. The Environmental Assessment Coordinator reports to the Environmental Assessment Director and is responsible for but not limited to calculating off-site radiation exposures, accumulating off-site radiation measurement data, keeping track of in-plant effluent radiation monitors, and projecting radiation dose estimates based on expected or potential releases.

12.3-24 Revision 10

I The DOE Operations Office will, to the extent they are available during the protection and recovery stage, continue to advise the Emergency Services Section of the Michigan Department of State Police and provide monitoring and analytical capability as requested.

12.3.3.5.4 Fire De artment The Donald C. Cook Nuclear Plant maintains an on-site fire fighting brigade; this capability is expected to be sufficient for all fires on-site. In the event off-site assistance is desired or needed, local fire departments may be called upon.

The Shift Supervisor is responsible for fire fighting activities on-site as well as notifying off-site departments when assistance is needed.

The assistance of the local Fire Department will not be required for any incident involving only radiological release. For any fires (including those that could result in radiological release), the assistance of a fire department could be requested.

The primary fire departments that will respond to a fire emergency at the Cook Plant are:

Lake Township -F. D.

Bridgman F. D.

Letters of Agreement to provide fire fighting assistance to the D. C. Cook Nuclear Plant can be found in Appendix C of this Plan.

12.3.3.6 Overall Or anization 6 Communication A Functional Organization Chart showing communications links between various emergency centers established as a result of a nuclear incident, is delineated in Figure 12-11.

The chart shows the relationship between various emergency centers and organizations after the incident has occurred and all channels of communication have been established. It is not intended to cover the initial procedure for notifying State/Local authorities of the incident. Initial notification flow sequence is shown in Figure 12-12.

12.3.3.7 Nuclear Trans ortation Accidents A Voluntary Assistance Agreement has been entered into between electric utilities involved in the transportation of source material, special nuclear material and by-product material received, possessed, used or transferred. This agreement sets forth the understanding and agreement with respect to the mutual undertaking to each other in the situation where an emergency occurs by reason of a nuclear materials transportation accident and*assistance is provided by one utility to another. A copy of this agreement can be found in Appendix C.

12.3-40 Revision 8

FIGU 12 4 INDIANA MICHIGAN POWER COMPANY ORGANIZATION CHART FOR THE DONALD C. COOK NUCLEAR PLANT Plant Manager Licensing Activity Coordinator Human Safety dc Administration Accounting Resources Assessment Superintendent Supervisor Supervisor Superintendent tO M

I as Assistant Assistant Assistant Plant Manager Plant Manager Plant Manager Production Technical Support Projects Operations Maintenance Emergency Design Construction planning Changes Superintendent Superintendent Coordinator Manager, Plant Superintendent Stores Technical Superintendent Computer General Supervisor Superintendent Plant Sciences Supervisor Physical Science Engineering Superintendent Scheduling O

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FIGURE j.2 7 IAG ORGANIZATIONAL CHART IAG MANAGER Vice President Nuclear Operations IAG MEMBER PUBLIC AFFAIRS Nuclear Operations REPRESENTATIVE Staff Member Senior Vice President Public Affairs IAG MEMBER IAG MEMBER IAG MEMBER IAG MEMBER Nuclear Engineering Rodlologlcol Support Nuclear Safety and Nuclear Engineerfng Electrical Systems Section Llcensfng Sect(on Plant Engineering Dlvlslcn Division IAG MEMBER IAG MEMBER IAG MEMBER IAG MEMBER Nuclear Operations Nuclear Operations Nucleor Fuels and Design Staff Member Support Section Anal~is Section Division IAG hIEMBER/ IAG MEhIBER IAG MEMBER COMMUNICATOR Nuclear Maintenonce Civil Engineering NOD Personnel Support Section Dlvlslan IAG COORDINATOR Radiological Suppc rt Sect(on TATUS REPORTE IAG RUNNERS OUTSIDE AGENCY NOD Personnel NOD Secretaries LIAISONS NOD Personnel Indfcates individuals who may remain fn their office to per(orm assigned duties 12.3-51 Revision 10

BYPASS & INOPERABLE STATUS INDICATION SYSTEM BISI The BISI system provides the operators and technical support personnel with a clear indication of the availability of the plant safety systems (ESF Systems).

Additional data display terminals in the TSC provide the capabilities described below.

MIDAS TERMINAL To access the MIDAS (Meteorological Information and Dispersion Assessment System) system, a Tektronix Graphics Display Terminal is available in the TSC. The system can be used to provide meteorological information for dose assessment purposes.

PERSONAL COMPUTER To access the AEPSC in-house .dose assessment program, DAP, a personal computer (PC) and hard copy unit are available in the TSC and the Control Room.

RADIATION DATA DISPLAY SYSTEM Color graphic CRTs for the TSC and EOF are installed. The CRTs are connected to the Plant Radiation Monitoring System control terminals via modems and redundant communication channels.

The TSC will not contain, but will have ready access to plant records, drawings and other documentation as required. In addition, the TSC will be in communication with technical support personnel in the IAG (located in the AEPSC offices) during the initial phase of the event until the EOF in Benton Township is activated. The concept of operation of the Emergency Response Facilities is described in Section 12.3.9.4.

12. 3. 9. 2 Emer enc 0 erations Facilit EOF 12.3.9.2.1 Emer enc 0 erations Facilit Functions The Emergency Operations Facility (EOF) provides coordination and evaluation of licensee activities during an emergency. The EOF shall be activated during an Alert, Site Area and General Emergencies.

Once fully activated and staffed, the function of the EOF shall provide for:

Management of overall licensee emergency response, Coordination of radiological and environmental assessment, Determination of recommended public protective actions, and 12.3-124 Revision 9

Meteorological data from the on-site meteorological tower is input into the program. The data is used to calculate the atmospheric diffus'ion factor, X/Q.

Other features included in the program are as follows:

straight-line Gaussian Transport model radioactive decay after reactor shutdown no decay or daughter in-growth during transit O

ground level release finite cloud correction option to input off-site field survey data.

The program is run on personal computers. Two (2) PCs are available in the EOF to provide redundant dose assessment capabilities.

The DAP program will be used as the primary means of performing a dose assessment.

2) MIDAS (Meteorological Information and Dispersion Assessment System) is a computer-based system developed by Pickard, Lowe and Garrick, Inc. that performs the basic functions of meteorological data collection and quality checking. MIDAS is designed to perform three basic meteorological functions:

a) Data Collection b) Data Storage c) Computation and Retrieval The program was designed to assist nuclear plants in evaluating the meteorological conditions that exist during a plant emergency.

3) PLANT SAFETY SYSTEM DISPLAY is part of a technical support complex system from Westinghouse that provides information on safety system availability and plant safety status. Display of plant parameters at the EOF is via a TSC "Command" console, to the TSC computer for either Unit 1 or Unit 2, as the need arises. The EOF console will have the capability to call up the displays associated with the Control Room BISI (Bypassed and Inoperable Status Indication) consoles and the displays associated with the Control Room PSSD with the exception of the iconic (vector graphics) displays as described in Section 12.3.9.1.4.

12.3-128 Revision 9

FIGURE l.

ON-SITE ENVIRONMENTAL SA ING LOCATIONS UN R ESTRICTED A R EA TRUE PLANT NORTH NORTH PROPERTY LINE

-Wl-"A'j ':::: '::::::""-"'":::::::::::::~:.,,::,

a i::."

Lo/re T5 --.TI ROAD A2 M/ ch/ gon =t 5 RAILROAD TRACK Ll 'lT2 545kV

=-W5 YARD

==W6 E-W ,, (:,~r-'-:~

j'll

/ PLANT r li',i)I."'";:::/

W5 CHESAPEAKE 8 OHIO R.R.

SHORE LINE PLANT T4,84

~L g,Pp rrk rr ref

~N: r r

r sr r A Air, TLD Stations rr rrpr~grr ija.travr r

W Well Water Sample Stations 0 1000 2000 3000 4000 FEET L Lake Water Sample Stations.

SCALE T TLD Stations only

l llI

MAIDEN LANE FIGURE 12-17 L NLORD ROAD RO.

0 0

IC MA ROVETTE WOODS RD.

TLD STATIONS WITHIN 4-5 MILE PLANT RADIUS 0 QA3 QAa JOHN BEERS RD.

'TEVE 5 IV VILLE Z OERSY C

I 0 ANTLD STATIONS JI 0 0IC CC WEED ROAD

'Z 0 I/2 1.0 2.0 A 0z 0 I 0IJ O

0 0 Z Z

II/a vl MILE CC IV 0 0 I

L IN CO 0 ROAD 0 A4 MARRS ROAD OONALC C. COON NVCLCAN PLANT JERICHO I HIN HMAN I R A C I BOSTON ROAD 0 0 0 QA6 0 0 CC 0

IC z?

Vl 'EMON CREEK ROAD BAR OOA rArrrL

~4~ a ROAD o) +

HAWN A5 A7 0 0 Z Z IV 0 BRIOGMA I 0 IV I 0 0 Vl SKALA ROAD IJ AAV I- AID 0 SNOW ROAD SNOW Z QA6 QA6 ~

0 0 QADI V. IZ OTT RD.

BROWNTOWN ROAD 12.3-143 Revision 10

l ~ ',

I~

~'

FIGURE 12-18'FF-SITE ENVIRONMENTAL SAHPLING LOCATIONS 2

I$ 6 ZO MILES A Air, TLD Stations L Lake Woter Sample Stations Coioma A iwa tervli et Qh M Milk Sample Sfotions BENTON HARBOR g':

p ST. JQ PH. y+

StevensvI e Eau U)

Claire DDWABIAC A D. C. COOK PLANT Bridg man Her rien M Springs M I

%h slat

/

/

/

NlLES:j e: /

New Buffalo U2 12 A MICHIGAN WOSANA MlCHlGA .~

New CITY'"

Carlisle 20 U5 20 11102 SOUTH BEND 20 SCALE OF MILES 12.3-144 Revision 10

TABLE 12-2 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM xposure Pathway Sampling and Type 6 Frequency Sam le Locations Collection Fre uenc of Anal sis

1. Airborne Al-A6 (Site) Continuous operation Radioiodine canister

a. Radioiodine of sampler with Sample Analyze:

and New Buffalo, Collection as required Weekly for I-131 Particulates South'end, by Dust Loading but at Dowagiac, and Least once per 7 days Particulate sampler Coloma are Gross Beta Radio-Background activity following Filter Change a composite (by location) for gamma isotopic quarterly

2. Direct Radiation a) Tl-T12 (Site) At least once per Gamma Dose.'t 10 b) New Buffalo 92 days least once per South Bend 92 days Dowagiac Coloma c) 11 TLD Monitor Locations in the Five'Mile Radius

• 10

3. Waterborne Ll, Isotopic O a. Surface L2, L3 Composite Sample Over one-month Period Gamma Analysis monthly.

Composite for tritium analysis-quarterly.

i

b. Ground Wl-Wj Quarterly Gamma Isotopic and Tritium analysis quarterly.

c. Drinking St. Joseph Composite* Sample Gross Beta and Lake Township Collected over a Gamma Isotopic period of ( 31 days Anal sis of each Composite* Sample composite sample. 1O Over a 2 week Tritium Analysis period if I-131 of composite Analysis is Performed. Quarterly. I 131 analysis on each composite when the dose calculated for the consumption of the water is greater than 1 mrem per year

• Composite sample shall be collected by collecting an aliquot at intervals not exceeding 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

a Particulate sample filters should be analyzed for gross beta 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, or more after sampling to allow for radon and thoron daughter decay. If gross beta activity in air or water is greater than 10 times the yearly mean of control samples for any medium, gamma isotopic analysis should be performed on the individual samples.

12.3-145 Revision 10

~P J:

'E

TABLE 12-2 (Cont'd.)

10

d. Sediment from L2, L3, L4, L5 2/year Gamma Isotopic Shoreline Analyses Semi-Annually.

4. Ingestion For indicator farm At least once per Gamma Isotopic

a. Milk and a *background 15 days when animals and I-131 Analysis farm are on pasture. At of each sample.

least once per 31 days at other times.

b. Fish Plant Site 2/year Gamma Isotopic Off-Site Analysis on Edible Portion.

c. Food Products Plant Site At time of Harvest Gamma Isotopic Off-Site one sample of each Analysis on (approx. 20 mi.) of the following edible portion classes of food products

1. Grapes Plant Site At time of harvest Gamma Isotopic one sample of broad Analysis leaf vegetation 3 indicator samples Monthly when available Gamma Isotopic and of broad leaf I-131 monthly when vegetation grown available.

nearest to the offsite locations of the highest calculated annual average ground level D/Q if at least three indicator milk samples and one background milk sample cannot be obtained.

1 background sample Monthly when available Gamma Isotopic and of each of the I-131 monthly when similar vegetation available.

grown 15-25 miles distant and in one of the less prevalent wind directions if at least three indicator milk samples and one background milk sample cannot be obtained.

An indicator farm is defined as the nearest milk producer in each of the land sectors within 8 miles of the plant site who is willing to participate in the radiological environmental monitoring program. A background farm is defined as a milk producer in one of the less prevalent wind directions at a distance greater than 15 miles 12.3-146 Revision 10,

II+

A'L E'

tt

~~

TABLE 12.3 POST-ACCIDENT MONITORING INSTRUMENTATION NUMBER OF DISPLAY INSTRUMENT TRANSMITTERS f) RANGE INDICATION RECORD COMPUTER

1. Containment Pressure 8 (2) -1 to 2 psig YES YES YES

2) -5 ta 36 psig (4) -5 to 12 psig

2. Reactor Coolant Outlet Temp. - THOT (Wide Range) 1 per loop 0 - 700 F YES YES YES

3. Reactor Coolant Inlet Temp. - TCOLD (Wide Range) 1 per loop 0 - 700 F YES YES YES

4. Reactor Coolant Pressure - Wide Range 2 0-3000 psig YES YES YES

5. Pressurizer Water Level 3 0-100K YES YES YES

6. Steam Line Pressure 3 per S.G 0-1200 psig YES YES YES

7. Steam Generator Water Level - Narrow Range 3 per S.G 0-100K Top 12ft YES YES YES

8. Refueling Water Storage Tank Water Level :2 0-100K YES YES NO

9. Boric Acid Tank Solution Level 1 per tank 0-100K YES NO NO

10. Auxiliary Feedwater Flow Rate (a) 1 per S.G .0-250 X 10 lb/hr YES NO NO ll. Reactor Coolant System Subcooling Margin 35 F S/H to 200 F YES YES YES Monitar (b) 1 set/valve subcool 0-500 psi margin

12. PORV Position Indicator - Limit Switches (c) 1 set/valve apen/clased YES NO NO

13. PORV Block Valve Position Indicatar-1 set/valve open/closed YES NO NO Limit Switches

14. Safety Valve Position Indicator- 1 channel open/closed YES NO Acoustic Monitor per valve

~ 15.

<<.16.

Reactor Vessel Water Level Indication High Range Containment Area Monitor 6

10 l

to 20'ES, 10 R/Hr YES (h)

YES YES (h)

LATER YES (h)

Phd;on Radiation4 g 17. Unit Vent Effluent Radiation Monitor- 5.8 x 10 ~ to 1.6 x I;/c(ES (e) YES (d,e) YES (g)

Noble Gas 4X (4pi eff 364 KEV Iodine) 90 6Ã (4 pi eff. Sr-Y )

Particulate

18. Lower Containment AirborneRadiation Monitor (Same as 17) YES (e) YES (d,e ) YES (g)

NUMBER OF DISPLAY INSTRUMENT TRANSMITTERS f) RANGE INDICATION RECORD COMPUTER 2

19. Steam Generator Power Operated 1 per S,G O.l to 1.0 x 10 Ucl cc YES (e) YES (d,e) YES (g)

Relief Valves Radiation Monitors Noble Gas

> 8 x 10 'c 1.6 x 10~@cg~c

20. Gland Seal Steam Condenser Vent YES (d,'e) YES (g)

~ I gqdiqtjon Monitors

21. Steam Jet Air Ejector Radiation Monitors 1 '5.8 x 19 to 1.6 x.)) yEg (e) YES (d e) YES (g Noble Gas

22. In-Core thermocouples 65 0 - 2500 F YES YES YES (a) STEAM GENERATOR WATER LEVEL CHANNELS CAN BE USED AS A SUBSTITUTE E FOR THE CORRESPONDING CO AUXILIARY FEEDMATER FLOM RATE CHANNEL INSTRUMENT.

(b) PRODAC 250 SUBCOOLING MARGIN READOUT IS AN E(UIVALENT SOURCE FOR TOE S>J LING INSTRUMENT.

BCOO'ONITORING (c) ACOUSTIC MONITORING OF PORV POSITION (1 CHANNEL PER THREE VALVES - HEADERED DISCHARGE) CAN BE USED AS A SUBSTITUTE FOR THE PORV POSITION INDICAlOR-LIMIT SWITCHES INSTRUMENTS.

CHANNELS'ISTORY FILES MAINTAINED AT LOCAI PROCESSORS.

(d)

(e) ON DEMAND AT CONTROL TERMINALS AND CRT'S.

(f) QUANTITIES IDENTIFIED ARE PER UNIT UNLESS OTHERWISE NOTED.

(g) AT COWTRQL ROOMS AWD RDDS CRT'S TO PROVIDE RECORD (h) DEDICATED INDICATOR PLUS ANALOG INPUT TO EBERLIWE LOCAL PROCESSOR PER (d), AND ADDITIONAl INDICATION PER (e); AND COMPUTER INPUT PER (g). ALSO, ANALOG INPUT TO WESTINGHOUSE P-2500 fOR APPLICABLE TSC DISPLAYS.

APPENDIX C A reements With Off-Site Su ort A encies Date

1. Sheriff Department, Berrien County, Michigan Augus't 16, 1990

2. Department of State Police, State of Michigan August 16, 1990

3. Mercy-Memorial Medical Center, Inc. August 16, 1990

4. U. S. Department of Energy August 21, 1990

5. Lake Township Fire Department November 27, 1990

6. City of Bridgman Fire Department November 8, 1990

7. Voluntary Assistance Agreement for Electric Utilities Involved in Transportation Accidents July 1, 1990

8. Consumers Power Reciprocal Laboratory Use Agreement August 9, 1990

9. Medic 1 Community Emergency Service August 28, 1990

10. Lake Township Ambulance and Rescue November 27, 1990 ll. Mutual Assistance Agreement September 28, 1990

12. Nuclear Power Plant Emergency Response Voluntary Assistance Agreement July 1, 1990

13. Institute of Nuclear Power Operations Emergency Resources August 20, 1991

14. Coordination Agreement on Emergency Information Among U.S. Council for Energy Awareness, Electric Power Research Institute, Institute of Nuclear Power Operations, Nuclear Management and Resources Council and their member utilities April 1988

15. Pawating Hospital September 10, 1990 Revision 10

~, g I SHERIFF DEPARTMENT - BERRIEN COUNTY - MICHIGAN 919 PORT STREET ST. JOSEPH, MICHIGAN49085.1184 TELEPHONE: (616) 983 7141 FORREST L. JEWELL Sf ff

))I I ~ > ~ < i I I I I I I 1 II II RII'I'OBERT 0 E. KIMMER LY VEDI II.SIII-:all:I:

aN I'l DONALD E. JEWELL Cl Ill PU'I')'ugust 16, 1990 Milton P. Alexich Vice President Nuclear Operations American Electric Power Service Corporation 1 Riverside Plaza Columbus, OH 43215

Dear Mr. Alexich:

We wish to reaffirm the willingness of the Berrien County Sheriff's Department to respond upon request to any emergency which could occur at your facility.

The Office of Emergency Preparedness has the obligation to respond upon notification that an emergency exists. Berrien County would implement their Nuclear Power Plant plan and take appropriate actions as outlined therein.

In addition, the Sheriff's Department has basic patrol and investigative services and currently has three certified bomb technicians who have successfully completed the United States Army Hazardous Device School at Redstone Arsenal in Huntsville, Alabama,. a special Tactical Unit whose members were trained by the Federal Bureau of Investigation at Quantico, Virginia, and a Hazardous Materials Response Team who have received training by Safety Systems Emergency Response Schools at Jacksonville, Florida.

May we again assure you that the services of the Berrien County Sheriff's Department will be available to you upon request in any area within the jurisdiction of this agency.

Sincerely, Forrest L. Jewell Sheriff & Director

STATE OF MICHIGAN EMERGENCY MANAGEMENTDIVISION KNAPPS CENTRE, SUITE 300 300 SOUTH WASHINGTONSQUARE JAMES J. BLANCHARD,GOVERNOR LANSING, MICHIOAN 480I3 DEPARTMENT OF STATE POLICE PHONP 517 373.0371 COI ILT, DAVIS, DIRECTOR August 16, 1990 Hr. M. P. Alexich, Vice President American Electric Power Service Corp.

1 Riverside Plaza Columbus, OH 43215

Dear Hr. Alexich:

This letter serves to confirm that the State of Michigan is committed to respond to an accident at the Donald C. Cook Nuclear Power Plant. This response, if necessary, wi 11 be in accordance with statutory authority and the Michigan Emergency Management Plan.

If I may be of further service, please contact me.

Sincerely, F t. J~ M. Tyler ommanding Officer Pre-Disaster Services Section JHT/sc RSCYCLED PAPUA

iVlercy Memorial Medical Center Inc.

HEPE FOP YOUP HEALTH August 16, 1990 Mr. Milton P. Alexich Vice President Nuclear Operations American Electric Power Service Corp.

1 Riverside Plaza Columbus, OH 43215

Dear Mr. Alexich:

This letter will serve to confirm that the Mercy Memorial Medical Center, Inc., has established a working arrangement with the Donald C. Cook Nuclear Power Plant at Bridgman, Michigan to provide emergency. medical services in the . event of a radiation or contamination injury to personnel on site, or members of the general public off side, resulting from operation of the Plant.

We have developed a system for receiving patients in an isolated area of the hospital. Also, the necessary hospital personnel have 0 been trained in the specific methods of treating patients contaminated with radioactive materials. Retraining will be done at frequent intervals. Any further questions can be directed to Ms. Laurie Fleming, Director Emergency Department, who is MMMC's liaison. Ms. Fleming's phone number is (616) 983-8558.

It is our understanding that all procedures, training and equipment for this purpose will be provided by the Donald C. Cook Nuclear Power Plant.

se h, A. Wasserman resident JAW:ja cc: L. Fleming 1234 Napier Ave. St. Joseph, MI 49085-2158 (616) 983-8300

~

f~

AT Department of Energy Chicago Operations Office 9800 South Cass Avenue Es (g Argonne, Illinois 60439 August 21, 199O Mr. Milton P. Alexich Vice President Nuclear Operations American Electric Power Service Corp.

1 Riverside Plaza Columbus, OH 43215

Dear Mr. Alexich:

The U.S. Department of Energy (DOE) will respond to requests for radiological assistance from licensees, Federal, State, and local agencies, private organizations, or individuals involved in or cognizant of an incident believed to involve source, byproduct, or special nuclear material as defined by the Atomic Energy Act of 1954, as amended, or other ionizing radiation sources.

Unless DOE or a DOE contractor is responsible for the activity, ionizing radiation source, or radioactive material involved in an incident, DOE radiological assistance will be limited to advice and emergency action essential for the control of the immediate hazards to health and safety.

Radiological emergency assistance will be terminated as soon as the emergency situation is under control. Therefore, responsibility for postincident recovery, including further action for the protection of individuals and public health and safety, should be assumed by the appropriate responsible Federal, State, or local government, or private authority as soon as the emergency conditions are stabilized.

If we can be of further assistance, please feel free to contact us.

Sincerely, ZZr>Ms.

Acting Manager cc: Director, Office of Nuclear Safety Technology, HQ (EH-332/GTN)

U.S. Nuclear Regulatory Commission, Office of Inspection and Enforcement, Region III

Indiana Michigan Power Company Cook Nuclear Plant One Cook Place Bridgman. Ml 49106 616 465 5901 PP~.

INDIANA AIICHIGAN POWER Emer enc Plannin A reement Between the Lake Townshi Fire De artment and Donald C. Cook Nuclear Plant Upon receipt of a request for fire fighting assistance from the indiana Michigan Power Company's Donald C. Cook Nuclear Plant Security Department, the Lake Township Fire Department agrees to respond by sending personnel, apparatus, and equipment to the Cook Nuclear Plant site.

The Cook Nuclear Plant agrees to lead such Township Fire Fighting Assistance from the Security Operations Building to the scene of the fire and agrees to provide escorts for Township Fire Fighting vehicles and personnel while in the Protected Area, or other owner controlled area.

The Cook Nuclear Plant and the Lake Township Fire Department agree that for all fires in the Plant Protected Areas the Plant Fire Brigade Leader will be responsible for fire extinguishment with the assistance of Lake Township Fire Department personnel and advice and counsel of the Lake Township Fire Chief or his designee. Fire fighting by members of the Lake Township Fire Department in the Auxiliary Building will be done only with the concurrence of the Plant Manager.

For fires outside the Plant Protected Area the Township Fire Chief shall be responsible for fire extinguishment with the advice and counsel of the Plant Fire Brigade Leader or designee if they are present.

The Cook Nuclear Plant agrees to provide and the Lake Township Fire Department agrees to participate in annual site specific training and drills conducted at the Cook Nuclear Plant site.

This agreement shall remain in effect from the date of signing unless and until terminated.

Any party upon ninety (90) days prior written notice to the other party, may terminate this agreement.

As an Sincer ely i A. Blind

++<day of Norman Zel r

'~,

indication of your agreement to the above statements concerning our mutual responsibilities, please sign below.

Accegted and a reed po this 1990.

Plant Manager Fire Chief Donald C. Cook Nuclear Plant Lake ownship Fire partment Q~

Page 2

Indiana Micnigan Powec Company P,o, Box '663 CommcUs, GH -:2i6 INDIANA NICHIGAN POWM Emer enc Plannin A reement Between the Bifid man Cit Fire De artment and Donald C. Cook Nuclear Plant Upon receipt of a request for fire fighting assistance from the Endia'na Michigan Power Company's Donald C. Cook Nuclear Plant Security Department, the Bridgman City Fire Department agrees to respond by sending personnel, apparatus and equipment to the Cook Nuclear Plant site.

The Cook Nuclear Plant agrees to lead such City Fire Fighting Assistance from the Security Operations Building to the scene of the fire and agrees to provide escorts for City Fire Fighting vehicles and personnel while in the Protected Area, or other owner controlled area.

The Cook Nuclear Plant understands that the Lake Township Fire Department is the primary response fire department for the Cook Nuclear Plant, and under normal situations the Lake Township Fire Chief, or his designee shall be responsible for fire extinguishment at the Cook Nuclear Plant. However, in the event of a situation in which the Lake Township Fire Department is unable to respond, the Bridgman City Fire Chief, or his designee, shall be responsible for fire extinguishment with the advice and consent of the Cook Nuclear plant Site Fire Brigade leader. Firefighting in the Auxiliary Building will be done only with concurrence of the Plant Manage'r.

The Cook Nuclear Plant Site Fire Brigade will assist and aid the City Fire Fighting personnel.

The Cook Nuclear Plant agrees to provide and the Bridgman City Fire Department agrees to participate in annual site specific training and drills conducted at the Cook Nuclear Plant site.

This agreement shall remain in effect from the date of signing unless and until terminated.

Any party upon ninety (90) days prior written notice to the other party, may terminate this agreement.

As an indication of your agreement to the above statements concerning our mutual responsibilities, please sign belo~.

Sincerely, Accepted and agreed to this day of k ~'-'.4~h~r, 1990.

Bridgman City Fire Department A. A. Blind t I Plant Manager By: i~

Donald C. Cook Nuclear Plant William H. Boyd, Sr., Fire Chief

6.1 Si natories to the Voluntar Assistance A reement 8 and Amon Electric Utilities Involved in Trans ortation of Nuclear Materials The following organizations have signed the Voluntary Assistance Agreement By and Among Electric Utilities Involved in Transportation of Nuclear Materials. This list is current as of July I, 1990.

Alabama Power Company Arizona Public Service Company Baltimore Gas and Electric Company Boston Edison Company Carolina Power & Light Company Centerior Energy Corporation Commonwealth Edison Company Consolidated Edison Company of New York, Incorporated Consumers Power Company The Oetroit Edison Company Ouke Power Company Ouquesne Light Company Entergy Operations, Incorporated Florida Power Corporation Florida Power & Light Company Georgia Power Company GPU Nuclear Corporation Gulf States Utilities Company Houston Lighting & Power Company Illinois Power Company Iowa Electric Light and Power Company Long Island Lighting Company Maine Yankee Atomic Power Company Nebraska Public Power Oistrict New York Power Authority Niagara Mohawk Power Corporation.

Northeast Utilities Northern States Power Company Omaha Public Power Oistrict Pacific Gas and Electric Company 6-3

Si natures to the Voluntar Assistance A reements B and Amon Electrical Utilities Involved in Trans ortation of Nuclear Materials Cont'd Pennsylvania Power & Light Company Philadelphia Electric Company Portland General Electric Company Public Service Company of Colorado Public Service Company of New Hampshire Public Service Electric and Gas Company Rochester Gas and Electric Corporation South Carolina Electric & Gas Company Southern California Edison Company Tennessee Valley Authority TU Electric The Toledo Edison Company Union Electric Company Vermont Yankee Nuclear Power Corporation Virginia Power Washington Public Power Supply System Wisconsin Electric Power Company Wisconsin Public Service Corporation Wolf Creek Nuclear Operating Corporation Yankee Atomic Electric Company 6-4

6.2 Voluntar Assistance A reement 8 and Amon Electric Utilities Involved in Trans ortation of Nuclear Materials This Voluntary Assistance Agreement (hereinafter "Agreement" ) has been entered into by and among electric utilities involved in transportation of source material, special nuclear material, or byproduct material received, possessed, used, or transferred under a general or specific license issued by the U.S. Nuclear Regulatory Commission pursuant to Title 10 of the Code of Federal Regulations (hereinafter "nuclear materials" ) and which have subscribed counterpart signature pages in the form attached hereto (hereinafter "Parties" ).

The Parties wish to set forth herein their understanding and agreement with respect to their mutual undertaking to each other in the situation wherein an Emergency arises during the transportation of nuclear materials shipped by or on behalf of a Party and a request for assistance is issued to another Party in respect to such Emergency and such assistance is provided. This Agreement is intended only to define the terms and conditions under which such assistance, if volunteered, will be rendered and received.

It is understood that this Agreement does not impose any obligation on any Party to render or continue to render any such assistance, but this Agreement does record the understanding of the Parties with respect to the rights and obligations which will be incurred in responding to requests for assistance.

6-5

NOW, THEREFORE, it is agreed, that:

l. Assistance rendered by a party as described hereunder shall be entirely voluntary and, when given in response to a request by any Party for help during an Emergency arising by reason of the transportation of nuclear materials, shall be rendered in accordance with the terms and conditions herein.

2. The Party that requests assistance shall be known as the "Requesting Company" and the Party furnishing assistance shall be known as the "Responding Company." Attachment A is a suggested letter confirming an agreement whereby assistance will be furnished pursuant to this Agreement.

3. (a) Requesting Company shall notify Responding Company of the type of assistance requested and the anticipated duration during which such assistance is desired. Requesting Company may also provide general direction as to the actions to be taken by Responding Company. Responding Company shall furnish. such assistance as it may decide. Except as such companies may agree otherwise, Responding Company shall be responsible for determining the procedures to be followed in furnishing such assistance and for supervising work at the site of the Emergency. Requesting Company, in cooperation with Responding Company, shall make any report to governmental authorities and the news media. Requesting Company will notify Responding Company when its assistance is no longer needed.

(b) The furnishing of assistance hereunder shall be deemed to have commenced when personnel of the Responding Company are assigned to other than normal duties or transportation of equipment commences pursuant to a determination by the Responding Company to provide assistance to a Requesting 6-6

Company under this Agreement and shall be deemed to have terminated when the transportation of such personnel or equipment back to their working base, or home (for personnel returning at other than regular working hours), is completed.

(c) The Responding Company shall make all arrangements for the transportation of its personnel and equipment from and to their working base or home.

4. (a) Employees of Responding Company shall at all times continue to be employees of and remain under the supervision and control of the Responding Company and shall at no time and for no purpose be deemed to be servants, agents, employees, or representatives of the Requesting Company.

(b) Mages, hours, and other terms and conditions of employment applicable to personnel of the Responding Company, including work procedures and/or safety rules, shall be those of the Responding Company.

(c) All personnel of the Responding Company shall be equipped by the Responding Company with such normal working and protective equipment as shall be compatible with the circumstances under which said personnel shall function hereunder; Requesting Company shall inform Responding Company of any specific equipment which may be required in a particular situation.

5. (a) Responding Company shall furnish the requested personnel and equipment to the extent that the Responding Company may determine to do so in its sole judgment and discretion.

6-7

(b) Responding Company shall have the right, at any time and in its sole judgment and discretion, to withdraw personnel and equipment furnished to the Requesting Company and return such personnel and equipment to their working base. Responding Company shall give written notice at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in advance to Requesting Company of the permanent withdrawal of personnel or equipment furnished. Responding Company's withdrawal of personnel or equipment shall not affect any obligations which may have been incurred hereunder prior to such withdrawal or which may arise out of events occurring prior to such withdrawal.

6. All time sheets and work records pertaining to Responding Company personnel and equipment shall be kept by the Responding Company. The Responding Company shall furnish the Requesting Company with a detailed statement of all costs and expenses paid or incurred by the Responding Company in connection with the furnishing of assistance to the Requesting Company, which statement shall be paid by Requesting Company within thirty (30) days after receipt.

7. The Requesting Company shall reimburse Responding Company for all direct and indirect costs and expenses, not including a profit, incurred by Responding Company in giving assistance pursuant to this Agreement, including but not limited to costs and expenses related to or resulting from compliance with governmental requirements such as Title 10 of the Code of Federal Regulations, Part 20. Such costs and expenses shall be computed in accordance with Responding Company's standard rates and accounting practices including such overheads as are determined by Responding Company to be applicable to such direct and indirect costs and expenses incurred by Responding Company. Requesting Company shall have the right to audit the 6-8

records of Responding Company relative to work performed pursuant to this Agreement.

8. (a) In addition, and subject to the provisions of paragraph 8(b) hereof, Requesting Company shall indemnify and hold Responding Company, its officers, director s, and employees, jointly and severally, harmless from and against any and all liability or loss, damage, cost, or expense which any of them may incur by reason of bodily injury, including but not limited to death, to any person or persons, or by reason of damage to or destruction of any property, including but not limited to the loss of the use thereof, which.

results from furnishing assistance pursuant to this Agreement, whether due in whole or in part to any act, omission, or negligence of Responding Company, its officers, directors, or employees.

(b) Mhere payments are made by Responding Company or its insurers to Responding Company's officers, directors, or employees or their beneficiaries for bodily injury or death resulting from furnishing assistance pursuant to this Agreement, including but not limited to disability, hospitalization, or other workers'ompensation, pension plan, medical and such payments, Requesting Company shall make reimbursement to Responding Company to the extent such payments increase the Responding Company's employee-related costs, whether such increase in costs occurs in the form of an increase in premiums or contributions, a reduction in dividends or premium refunds, or otherwise. Requesting Company shall also reimburse Responding Company for any deductible amounts or for any amounts paid by Responding Company as a self-insurer. Responding Company will request its insurer to waive any right of subrogation it may have against Requesting Company as a result of any payment described in this paragraph 8(b) which such insurer may 6-9

make on behalf of Responding Company because of Responding Company's furnishing of assistance pursuant to this Agreement.

(c) In the event any claim or demand is made or suit, action, or proceeding is filed against Responding Company, its officers, directors, or employees, jointly or severally, alleging liability for which Requesting Company shall indemnify and hold harmless Responding Company, its officers, directors and employees under paragraph 8(a) hereof, Responding Company shall promptly notify Requesting Company thereof, and Requesting Company, at its sole cost and expense, shall settle, compromise, or defend the same in such manner as it in its sole discretion deems necessary or prudent. Responding Company shall cooperate with Requesting Company in the resolution of any such matter.

(d) Each party to this Agreement agrees to carry financial protection required by the Atomic Energy Act of 1954, as amended, and self-insurance or comprehensive liability insurance, including contractual liability coverage covering the indemnification and defense obligations set For th herein, subject to such types and amounts of selF-insurance, retentions, or deductibles as are consistent with good business practice in the industry.

(e) In the event a Responding Company provides assistance pursuant to this Agreement through an affiliate or subsidiary, the indemnification provided in this paragraph 8 to the'fficers, directors, and employees of that Responding Company shall apply with equal force to the officers, directors, and employees of that affiliate or subsidiary.

9. Each Party shall provide the Institute of Nuclear Power Operations (hereinafter " INPO") with an executed counterpart signature page to 6-10

this Agreement and to any amendments hereto. This Agreement shall become effective when counterpart signature pages executed by at least two Parties shall have been received by INPO. This Agreement shall remain in effect as to any Party until such Party has withdrawn from the Agreement as provided below. Any electric utility involved in the transportation of nuclear materials may become a Party upon execution of the Agreement.

10. (a) INPO may provide certain administrative and emergency response support services in furtherance of this Agreement, such as maintaining and distributing to the Parties a roster of the signatories to this Agreement; providing copies of the Agreement and any amendments thereto to all Parties; and preparing and distributing to the Parties other documents, such as list of sources of emergency manpower and equipment. INPO may provide such other services as may be requested of INPO from time to time by the Parties. The Parties recognize that INPO shall not be responsible for implementing, enforcing, or interpreting this Agre ment.

(b) The Parties shall defend, indemnify, and hold harmless INPO, its officers, directors, and employees, jointly and severally, from and against any and all liability or loss, damage, cost, or expense which results from performance of INPO functions described in paragraph 10(a) of this Agreement, except as may result from the sole negligence or willful misconduct of INPO, its officers, directors, or employees. Each Party hereby expressly waives any right it may have to assert any claim against INPO, its officers, directors, or employees arising out of its or their performance of the duties described in paragraph 10(a), except as may result from the sole negligence or willful misconduct of INPO, its officers, directors, or employees.

6-11

(c) Following the occurrence of an emergency involving the transportation of nuclear materials INPO may, if asked to do so by a Requesting Company, help to locate sources of emergency manpower and equipment with which the Requesting Company may contract for assistance. If INPO does furnish such assistance and, unless otherwise agreed by INPO and the Requesting Company, the Requesting Company and INPO shall have the same rights and obligations as if INPO were a Responding Company (including but not limited to the Requesting Company's obligations to INPO, its officers, directors, and employees under paragraph 8 hereof), except that paragraphs 6 and 7 shall not apply either to Requesting Company or INPO and paragraph 8(d) shall not apply to INPO.

11. This Agreement will not create any rights or defenses in favor of an entity or person not a signatory to this, Agreement except to the extent provided in this paragraph and in paragraphs 8 and 10 of this Agreement. This Agreement shall be binding upon and inure to the benefit oF each signatory to this Agreement and the subsidiaries and affiliates of each such signatory.

12. Except as otherwise provided in paragraph 13, any Party may withdraw from this Agreement upon at least thirty (30) days prior written notice to INPO with a copy to all of the other Parties. Notice of withdrawal shall not affect any obligations which may have been incurred hereunder prior to the effective date of such notice or which may arise out of events occurring prior to that date. No party may withdraw from this Agreement while it is receiving assistance pursuant to this Agreement.

13. This Agreement may be amended by agreement of a majority of the Parties hereto. Such amendment shall be effective and binding upon all Parties thirty (30) days after INPO has received counterpart signature pages 6-12

for the amendment executed by at least a majority of the Parties to the Agreement. INPO shall notify all Parties when at least a majority of the Parties have executed an amendment to the Agreement. Ho amendment shall affect any obligation which may have been incurred hereunder prior to the effective date of such amendment or which arises out of events occurring prior to that date. Notwithstanding the first sentence of paragraph 12, any Party may withdraw from this Agreement by submitting written notice to INPO at any time during the thirty (30) day period prior to the effective date of such amendment with a copy to all of the other Parties.

14. If any provision of this Agreement is determined to be invalid or unenforceable as to any Party or otherwise, such determination shall not affect the validity or enforceability of the other provisions of this Agreement as to that Party or otherwise.

6-13

COUNTERPART SIGNATURE PAGE The undersigned company hereby agrees to become a Party to the Voluntary Assistance Agreement By and Among Electric Utilities Involved in Transportation of Nuclear Materials dated J~ul 1, 1982.

Oate Company By Corporate Officer Signature 6-14

ATTACHMENT A Re uestin Com an Letterhead Date 19 (Name and Address of Responding Company)

T~h << f<<<<1 I Q

~time between our and your in which our company requested assistance pursuant to the terms of the Voluntary Assistance Agreement By and Among Electric Utilities Involved in Transportation of Nuclear Materials dated , 1982 and your company agreed to provide assistance pursuant to that Agreement.

please acknowledge your agreement to the foregoing by signing and returning to me the enclosed copy oF this letter.

Requesting Company Name and Address Corporate Officer Signature Responding Company Name and Address Corporate Officer Signature and Oate 6-15

RECIPROCAL LABORATORY USE AGREEMENT THIS AGREENENT, made as of the 9th day of August 1990, by and between INDIANA MICHIGAN POWER COMPANY, an Indiana corporation (hereinafter called "I&M") and CONSUMERS POWER COMPANY, a Michigan corporation (hereinafter called "Consumers Power" ),

W IT N E S S E T H T H A T WHEREAS, I&M and Consumers Power have chemical and radiochemical analytical laboratories at their Donald C Cook Nuclear Plant and Palisades Nuclear Plant, respectively, which laboratory facilities are suitable for performing chemical analyses following a nuclear-related accident (NRA), and WHEREAS, I&M and Consumers Power each desire to provide the temporary use of their respective existing laboratory facilities and personnel to perform chemical analyses for the other in the event the other has lost use of its laboratory facilities due to a NRA.

NOW, THEREFORE, the parties hereto do hereby mutually agree as follows:

1. In the event either party hereto is unable to use its laboratory facilities due to a NRA, the other party agrees to temporarily use its existing laboratory facilities and personnel, to the extent practical, to analyze, without charge, samples delivered to it by the party which suffered the NRA.

Each party agrees, in connection with such sampling handling and analyses, to comply with the requirements of NUREG-0578 and NUREG-0737 and such other requirements as may be specified by the Nuclear Regulatory Commission in regard to post-accident sample analysis. Detailed procedures for sample transport, handling and analysis will be developed by mutual agreement, in writing, of Consumers Power's Radiological Services Manager at the Palisades Nuclear Plant and I&M's Technical Department Superintendent at the D C Cook Nuclear Plant.

MI0790-0006A-NU02

2. Each party agrees, in performing analyses for the other, to provide a high standard of professional service, provided, however, that neither party shall have any obligation or liability for damages, including, but not limited to, consequential damages, arising out of or in connection with the other's use of, or reliance on, the results of such analyses.

3. If, at any time, either party anticipates the temporary unavailability of its laboratory facilities or personnel for any reason or such facilities or personnel are rendered unavailable due to an event beyond the reasonable control of the party, such party shall promptly notify the other party of the anticipated or actual unavailability of such facilities or personnel and the expected duration thereof in order that the other party may make other suitable r

temporary arrangements for analyses, the expenses of which arrangements shall be borne by the party making the arrangements. Neither party shall have any obligation or liability of any kind, arising out of or in connection with, the o unavailability of its facilities or personnel as provided in this Section 3.

4. This agreement shall be effective on the date hereof and shall continue until terminated as hereinafter set forth. Either party hereto may terminate this agreement at any time hereafter upon sixty (60) days written notice of such termination to the other party.

"IN WITNESS WHEREOF, the parties hereto have hereunto set their hands the day and year first above written.

INDIANA MICHIGAN POWER COMPANY CONSUMERS POWER COMPANY t~g ~l 8

M P exich id Hoffman Vice President, Nuclear Operations Vice President, uclear Operations MI0790-0006A-NU02

COMMUNITY EMERGENCY SERVICE August 26, 1990 Mr. Milton P. Alexich Vice President, Nuclear Operations American Electric Power Set vice Corp.

Riverside Plaza Columbus, Ohio 43216

Dear Mr. Alexich:

This letter is in response to your request for an updated letter of agreement with Medic I Ambulance regarding our assistance during an emergency situation at the Donald C. Cook Nuclear Plant. I again would like to state that we will act as back-up ambulance set vice to you.

As you are aware, the Lake Township Ambulance Service is your primary response service. In the event of a situation which Lake Township cannot handle alone, we will provide ambulance service to your facility, if we have an available unit. We will continue to provide this service during the emergency as long as we do not have emergency calls in our own set vice area which must be handled.

I hope that this letter meets your requirement Sincerely, William M. Gebhard Director P Q. Box 1563 ~ Benton Harbor, Ml 49022 ~ Phone (616) 925-214 I

MUTUAL ASSISTANCE AGREEMENT BETWEEN DETROIT EDISON, CONSUMERS POWER COMPANY, THE TOLEDO EDISON COMPANY, THE INDIANA MICHIGAN POWER COMPANY AND THE CLEVELAND ELECTRIC ILLUMINATINGCOMPANY

0.1 The Consumers Power Company, a Michigan corporation; Detroit Edison, a Michigan and New York corporation; The Toledo Edison Company, an Ohio corporation; The Indiana Michigan Power Company, an Indiana corporation; and The Cleveland Electric Illuminating Company, an Ohio corporation, WITNESSETH 0.2 WHEREAS, Consumers Power Company, Detroit Edison, and The Indiana Michigan Power Company own electric facilities, including nuclear generation stations, and are engaged in the generation, transmission, distribution and sale of electric power and energy in Michigan; and 0.3 WHEREAS, The Toledo Edison Company, and the Cleveland Electric Illuminating Company own electric facilities, including nuclear generating stations, and are engaged in the generation, transmission, distribution, and sale of electric power and energy in Ohio; and 0.4 WHEREAS, the parties desire to help assure the availability of adequately trained and experienced emergency personnel in the event of an emergency situation at any of their nuclear generating stations; 0.5 NOW, THEREFORE, in consideration of the promises and mutual covenants herein set forth, the parties agree as follows:

ARTICLE I DEFINITIONS 1.1 "Alert" shall be defined as a situation in which events are in process or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant.

1.2 "Emergency" shall be defined consistent with the definition of "site area emergency" as set forth in NUREG 0654 as a situation in which events are in process or have occurred which involve actual or likely major failures of plant functions needed for protection of the public.

1.3 "Requesting party" shall be defined as any party to this Agreement who, upon the occurrence of an emergency at one of its nuclear generating stations, seeks emergency assistance, pursuant to this Agreement, from one or more of the parties hereto.

1.4 "Responding party" or "responding parties" shall be defined as any party or parties to this Agreement who are presented with a request for emergency assistance pursuant to this Agreement.

ARTICLE II REQUESTS FOR EMERGENCY ASSISTANCE 2.1 In the event of an alert at one of its nuclear generating stations, any party to this Agreement may notify any or all of the other parties that an alert exists and that their emergency assistance may be required.

2.2 In the event of an emergency at one of its nuclear generating stations, any party to this Agreement may request emergency assistance from any or all of the other parties.

2.3 Requests for emergency assistance shall be made between and among the following party personnel:

Consumers Power Company Vice President Nuclear Operations Detroit Edison Senior Vice President Nuclear Generation The Toledo Edison Company Vice President Nuclear The Indiana Michigan Power Company Vice President The Cleveland Electric Illuminating - Vice President - Nuclear Company ARTICLE III EXCUSED FAILURE TO RESPOND 3.1 Failure to respond to a request for emergency assistance pursuant to this Agreement shall be excused if, in order to respond, the requested party or parties would be forced in its or their sole judgment or judgments to:

3.1.1 Violate its duties relating to the care and staffing at its own nuclear generating stations; or 3.1.2 Jeopardize the public health or safety at a location other than the location of the requesting party's emergency.

ARTICLE IV SCOPE OF ASSISTANCE 4.1 If requested under this Agreement, the responding party or parties will provide trained and experienced personnel to perform off-site radiation protection activities to the requesting party as those persons may be available to the responding party up to a maximum of six (6) such persons.

All equipment intended for use by the responding personnel, except personal dosimeters and certification documents (such as certifications of Health Physics training, instrument training and dose exposure records), shall be the responsibility of the requesting party to provide. The responding party or parties may use their own equipment if agreeable to the requesting party. However, use by the responding party or parties of their own equipment shall in no way alter the duties and obligations imposed upon the parties by this Agreement.

4.2 Emergency assistance provided by the responding party or parties shall continue until their personnel are relieved by the requesting party, the Federal or State emergency teams, or by the need of the responding party to answer an emergency at its own facilities.

4.3 Responding party or parties'ersonnel exposure shall be limited to off-site radiation, and such exposure shall be kept as low as reasonably achievable.

4.4 Wages, hours and other terms and conditions of employment applicable to loaned personnel shall be those of the party providing such personnel.

4.5 Personnel provided by the responding party or parties shall, at all times during the period in which emergency assistance is being provided, continue to be employees of the responding party or parties and shall at no time and for no purpose be deemed employees of the requesting party.

ARTICLE V REIMBURSEMENT FOR EMERGENCY ASSISTANCE RENDERED 5.1 The requesting party shall reimburse each responding party for all costs and expenses incurred by each responding party in providing emergency assistance hereunder. Such costs and expenses shall include.

5.1.1 Salaries and wages paid to loaned personnel (including supervisors) for paid time spent in the requesting party's service area, and paid time for travel to and from such service area; 5.1.2 A percentage of the total of such wages and salaries, as determined by the responding party, reflecting expenses incurred for:

5.1.2.1 Compliance with Worker's Compensation laws; 5.1.2.2 Payroll taxes; 5.1.2.3 Hospitalization, surgical and medical coverage; 5.1.2.4 Pensions and life insurance;

5.1.2.5 Vacation, holiday and sick pay; 5.1.2.6 Travel accident insurance; 5.1.3 Transportation to and from the requesting party's service area, including the cost of travel accident insurance purchased expressly for coverage during such transportation; 5.1.4 Food and lodging; 5.1.5 Personal expenses specifically agreed to between the requesting and responding parties; 5.1.6 Charges, at the rates internally used by the responding party, for the use of transportation equipment and other equipment requested; and 5.1.7 Any further costs specifically agreed to between the requesting and responding parties.

5.2 All time sheets and work records pertaining to loaned personnel shall be maintained by the responding party.

5.3 All charges shall be paid by the requesting party to each responding party within ten (10) days after receipt of an invoice, itemized to the satis-faction of the requesting party.

ARTICLE VI INDEMNIFICATION 6.1 The requesting party shall indemnify and hold harmless each responding party from and against any and all liability for loss, damage, cost or expense which the responding party shall incur by reason of bodily injury, including death, to any person or persons, or by reason of damage to or destruction of any property, including the loss of use thereof, arising out of or in any manner connected with the giving of emergency assistance to the requesting party.

6.2 In the event of bodily injury, including death, to any employee of the responding party, or in the event of damage to or destruction of any property of the responding party, the requesting party shall indemnify the responding party for such loss in the following manner:

6.2.1 If such loss is covered by an insurance policy purchased by the responding party from a third party carrier, the requesting party shall make reimbursement to the extent such losses increase the responding party's insurance costs, whether such increase in premium refunds, or both;

6.2.2 If such loss is not covered by an insurance policy purchased by the responding party or exceeds such coverage, the requesting party shall make reimbursement to the extent of the claims or benefits actually paid or the losses sustained by the responding party.

ARTICLE VII MODIFICATION 7.1 At any time after the date of this Agreement any party, by giving not less than thirty days written notice to the other parties, may from time to time call for reconsideration of the terms and conditions of this Agreement.

If such reconsideration is called for, the authorized representatives of the parties shall meet as promptly as convenient and discuss any of the terms and conditions of this Agreement. No party shall be under any obligation to agree to any modification or supplement not satisfactory to it. Any agreement modifying or supplementing such terms and conditions shall be in writing, signed by all parties, and shall specify the date such modification or supplement shall become effective.

ARTICLE VIII PLAN EXERCISING 8.1 The parties agree to provide, at their own expense, personnel to observe or assist in demonstrating the effectiveness of a nuclear generating station's emergency plan as may be required by that nuclear generating station's NRC approved emergency plan.

ARTICLE IX TERM OF AGREEMENT 9.1 This Agreement shall be for a term of three (3) years unless and until terminated as provided for in Section 9.2 below.

9.2 Any party, upon sixty (60) days prior written notice to all other parties, may terminate this Agreement.

IN WITNESS WHEREOF, the parties hereto cause this Agreement to be executed by their duly authorized officers on duplicate original pages attached hereto and made a part hereof.

DETROIT EDISON THE INDIANA MICHIGAN POWER COMPANY By: By:

Title:

l i( J tt+ef

Title:

V Jdr l~

Date: 7Cjo Date:

CONSUMERS POWER COMPANY THE CLEVELAND ELECTRIC ILLUMINA COMPANY By:

P flu.&m

Title:

D.t'. Date: ~ ZP~o THE TOLEDO ED S N COMPANY e

By:

V Nuclear, Centerior Service Corp.,

Title:

as A ent for Toledo Edison Date:

CT0790-0079A-TP11

ATTACHMENT A Re uestin Com an Letterhead Date t 19 (Name and Address of responding organization)

This letter confirms the telephone conversation on insert date and

~time between our and your in which our company requested assistance pursuant to the terms of the Nuclear Power Plant Emergency Response Voluntary Assistance Agreement dated and your organization agreed to provide assistance pursuant to that Agreement.

Please acknowledge. your agreement to the foregoing by signing and returning to me the enclosed copy of this letter.

Requesting Company Name and Address Corporate Officer Signature Responding Organization Name and Address Corporate Officer Signature and Oate 6-30

6.3 Si natories to the Nuclear Power Plant Emer enc Res onse Voluntar Assistance A reement The following organizations have signed the Nuclear Power Plant Voluntary Assistance Agreement. This list is current as of July 1, 1990.

Alabama Power Company Arizona Public Service Company Saltimore Gas and Electric Company 8oston Edison Company Carolina Power & Light Company Centerior Energy Corporation Commonwealth Edison Company Consolidated Edison Company of New York, Incorporated Consumers Power Company The Oetroit Edison Company Ouke Power Company Ouquesne Light Company Entergy Operations, Incorporated Florida Power Corporation Florida Power & Light Company Georgia Power Company GPU Nuclear Corporation Gulf States Utilities Company Houston Lighting & Power Company Illinois Power Company Indiana Michigan Power Company Iowa Electric Light and Power Company Long Island Lighting Company Maine Yankee Atomic Power Company Nebraska Public Power Oistrict New York Power Authority Niagara Mohawk Power Corporation Northeast Utilities Northern States Power Company Omaha Public Power Oistrict 6-17

Si nature to the Nuclear Power Plant Comoan Res onse Voluntar Assistance A reement Cont'd Pacific Gas and Electric Company Pennsylvania Power E Light Company Philadelphia Electric Company Port1and General E1ectric Company Public Service Company of Colorado Public Service Company of New Hampshire Public Service Electric and Gas Company Rochester Gas and Electric Corporation South Carolina Electric- & Gas Company Southern California Edison Company Tennessee Valley Authority TU Electric The Toledo Edison Company Union E1ectric Company Vermont Yankee Nuclear Power Corporation Virginia Power Washington Public Power Supply System Wisconsin Electric Power Company Wisconsin Public Service Corporation Wolf Creek Nuclear Operating Corporation Yankee Atomic Electric Company 6-18

6.4 Nucl ear Power Pl ant Emer enc Res onse Voluntar Assistance A reement This Nuclear Power Plant Emergency Response Voluntary Assistance Agreement (hereinafter "Agreement" ) has been entered into by and among electric utilities which have responsibility for the construction or operation of commercial nuclear power plants under a license issued by the U.S. Nuclear Regulatory Commission pursuant to Title 10 of the Code of Federal Regulations (hereinafter "nuclear power plants" ) and which have subscribed counterpart signature pages in the form attached hereto (hereinafter "Parties" ).

The Parties wish to set forth herein their understanding and agreement with respect to their mutual undertaking to each other in the situation wherein an emergency occurs at a nuclear power plant under the control of or operated on behalf of a Party and a request for assistance is issued to another Party hereto in respect to such emergency and such assistance is provided. This Agreement is intended only to define the terms and conditions under which such assistance, if volunteered, will be rendered and received. It is understood that this Agreement does not impose any obligation on any Party to render or continue to render any such assistance but this Agreement does record the understanding of the Parties with respect to the rights and obligations which will be incurred in responding to requests for assistance.

NOM, THEREFORE, it is agreed, that:

1. Assistance rendered by a Party as described hereunder shall be entirely voluntary and, when given in response to a request by any Party for I

6-19

help following an emergency arising at a nuclear power plant, shall be rendered in accordance with the terms and conditions herein.

2. The Party that requests assistance shall be known as the "Requesting Company" and the Party furnishing assistance shall be known as the "Responding Company." Attachment A is a suggested letter confirming an agreement whereby assistance will be furnished pursuant to this Agreement.

3. (a) Requesting Company shall notify Responding Company of the type of assistance requested and the anticipated duration during which such assistance is desired. Responding Company shall furnish such assistance as it may decide. Except as such companies may agree otherwise, Requesting Company shall be responsible for determining the procedures to be followed relative to the furnishing of such assistance, directing the work and making any reports to governmental authorities and the news media regarding the emergency or the furnishing of assistance pursuant to this Agreement. Requesting Company shall notify Responding Company when its assistance is no longer needed.

(b) The furnishing of assistance hereunder shall be deemed to have commenced when personnel of the Responding Company are assigned to other than normal duties or transportation of equipment commences pursuant to a determination by the Responding Company to provide assistance to a Requesting Company under this Agreement and shall be deemed to have terminated when the transportation of such personnel or equipment back to their working base, or home (for personnel returning at other than regular working hours), is completed.

6-20

(c) The Responding Company shall make all arrangements for the transportation of its personnel and equipment from and to their working base or home.

4. (a) Employees of Responding Company shall at all times continue to be employees of the Responding Company and shall at no time and for no purpose be deemed to be servants, agents, employees, or representatives of the Requesting Company.

(b) Wages, hours, and other terms and conditions of employment applicable to personnel of the Responding Company shall be those of the Responding Company. Work procedures, security, and safety rules for such personnel shall be those of the Requesting Company.

(c) Unless otherwise agreed, all personnel of the Responding Company shall be equipped by the Responding Company with such normal working and protective equipment as shall be compatible with the circumstances under which said personnel shall function hereunder; Requesting Company shall inform Responding Company of any specific equipment which may be required in a particular situation.

5. (a) Responding Company shall furnish the requested personnel and equipment to the extent that the Responding Company may determine to do so in its sole judgment and discretion.

(b) Any information which Responding Company may provide to Requesting Company (including drawings, reports, and analyses), or which Requesting Company provides to Responding Company, which either the Responding Company or the Requesting Company consi'ders proprietary or confidential, shall be so designated. Such proprietary information shall be held in confidence 6-21

and shall be used exclusively in connection with the emergency at the nuclear power plant at which the emergency has occurred (including necessary disclosures on a proprietary basis to others in that connection) and shall not be published or otherwise disclosed to others, except as may be required by 1 aw.

(c) Responding Company shall have the right, at any time and in its sole judgment and discretion, to withdraw personnel and equipment furnished to the Requesting Company and return such personnel and equipment to its working base. Without limiting Responding Company's rights under the preceding sentence, Responding Company shall attempt to schedule any such withdrawal of its personnel or equipment to accommodate the needs of Requesting Company.-

Responding Company shall give written notice at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in advance to Requesting Company of the permanent withdrawal of personnel or equipment furnished. Responding Company's withdrawal of personnel or equipment shall not affect any obligations which may have been incurred hereunder prior to such withdrawal or which may arise out of events occurring prior to such withdrawal.

6. All time sheets and work records pertaining to Responding Company personnel and equipment shall be kept by the Responding Company. The Responding Company shall furnish the Requesting Company with a detailed statement oF all costs and expenses paid or incurred by the Responding Company in connection with the furnishing of assistance to the Requesting Company, which statement shall be paid by Requesting Company within thirty (30) days after receipt.

7. The Requesting Company shall reimburse Responding Company for all direct and indirect costs and expenses, not including a profit, incurred 6-22

by Responding Company in giving assistance pursuant to this Agreement, including but not limited to costs and expenses related to or resulting from compliance with governmental requirements such as Title 10 of the Code of Federal Regulations Part 20. Such costs and expenses shall be computed in accordance with Responding Company's standard rates and accounting practices including such overheads as are determined by Responding Company to be applicable to such direct and indirect costs and expenses incurred by Responding Company. Requesting Company shall have the right to audit the records of Responding Company relative to work performed pursuant to this Agreement.

8. (a) ln addition, and subject to the provisions of paragraph 8(b) hereof, Requesting Company shall indemnify and hold Responding Company, its officers, directors, and employees, jointly and severally, harmless from and against any and all liability or loss, damage, cost, or expense which any of them may incur by reason of bodily injury, including but not limited to death, to any person or persons, or by reason of damage to or destruction of any property, including but not limited to any property located at the site of the Requesting Company's nuclear power plant or the loss of use of any property, which results from furnishing assistance pursuant to this Agreement, whether due in whole or in part to any act, omission, or negligence of Responding Company, its officers, directors, or employees.

(b) Mhere payments are made by Responding Company or its insurers to Responding Company's officers, directors, or employees or their beneficiaries for bodily injury or death resulting from furnishing assistance pursuant to this Agreement, including but not limited to disability, pension plan, medical and hospitalization, or other workers'ompensation, 6-23

such payments, Requesting Company shall make reimbursement to Responding Company to the extent such payments increase the Responding Company's employee-related costs, whether such increase in costs occur in the form of an increase in premiums or contributions, a reduction in dividends or premium refunds, or otherwise. Requesting Company shall also reimburse Responding Company for any deductible amounts or for any amounts paid by Responding Company as a self-insurer. Responding Company will request its insurer to waive any right of subrogation it may have against Requesting Company as a result of any payment described in this paragraph 8(b) which such insurer may make on behalf of Responding Company because of Responding Company's furnishing of assistance pursuant to this Agreement.

(c) Responding Company makes no warranty with respect to any goods or services provided to Requesting Company and NO WARRANTY, EITHER EXPRESS OR IMPLIED, ORAL OR WRITTEN, SHALL APPLY TO THE GOODS OR SERVICES PROVIDED%

INCLUDING, WITHOUT LIMITATION,. THE WARRANTIES OF MERCHANTABILITY AND OF FITNESS FOR SPECIFIED OR INTENDED PURPOSE. All equipment and services furnished by Responding Company pursuant to this Agreement are furnished as is.

(d) In the event any claim or demand is made or suit, action, or proceeding is filed against Responding Company, its officers, directors, or employees, jointly or severally, alleging liability for which Requesting Company shall indemnify and hold harmless Responding Company, its officers, directors, and employees under this paragraph 8 hereof, Responding Company shall promptly notify Requesting Company thereof, and Requesting Company, at its sole cost and expense, shall settle, compromise, or defend the same in such manner as it in its sole discretion deems necessary or prudent.

6-24

Responding Company shall cooperate with Requesting Company in the resolution of any such matter.

(e) Each Party to this Agreement agrees to carry the amount of financial protection required by the Atomic Energy Act of 1954, as amended, and self-insurance or comprehensive liability insurance, including contractual liability coverage, covering the indemnification and defense obligations set forth herein, subject to such types and amounts of self-insurance, retentions, or deductibles as are consistent with good business practice in the industry.

(f) In the event a Responding Company provides assistance pursuant to this Agreement through an affiliate or subsidiary, the indemnification provided in this paragraph 8 to the officers, directors, and employees of that Responding Company shall apply with equal force to the officers, directors, and employees of that affiliate or subsidiary.

9. Each Party shall provide the Institute of Nuclear Power Operations (hereinafter " INPO") with an executed counterpart signature page to this Agreement and to any amendments hereto. This Agreement shall become effective when counterpart signature pages executed by at least two Parties shall have been received by INPO. This Agreement shall remain in effect as to any Party until such Party has withdrawn from the Agreement as provided below. Any electric utility with responsibilities for the construction or operation of a nuclear power plant may become a Party upon execution of the Agreement.

10. (a) INPO may provide certain administrative and emergency response support services in furtherance of this Agreement, such as maintaining and distributing to the Parties a roster of the signatories to 6-25

this Agreement; providing copies of the Agreement and any amendments thereto to all Parties; and preparing and distributing to the Parties other documents, such as a list of sources of emergency manpower and equipment. INPO may provide such other services as may be requested of IHPO from time to time by the Parties. The Parties recognize that INPO shall not be responsible for implementing, enforcing, or interpreting this Agreement.

(b) The Parties shall defend, indemnify, and hold harmless INPO, its officers, directors, and employees, jointly and severally, from and against any and all liability or loss, damage, cost, or expense which results .

from performance of INPO's functions described in paragraph 10(a) of this Agreement, except as may result from the sole negligence or willful misconduct of INPO, its officers, directors, or employees. Each Party hereby expressly waives any right it may have to assert any claim against IHPO, its officers, directors, or employees arising out of its or their performance of INPO's functions described in paragraph 10(a), except as may result from the sole negligence or willful misconduct of INPO, its officers, directors, or employees.

(c) Following an emergency at a nuclear power plant, INPO may, if asked to do so by a Requesting Company, help to locate sources of emergency manpower and equipment with which the Requesting Company may contract for assistance. The Requesting Company may ask IHPO to furnish personnel or equipment following an emergency arising at a nuclear power plant. If INPO does furnish such assistance and unless otherwise agreed by INPO and the Requesting Company, the Requesting Company and INPO shall have the same rights and obligations as if INPO were a Responding Company (including but not limited to the Requesting Company's obligations to INPO, its officers, 6-26

directors, and employees under paragraph 8 hereof), except that paragraphs 6 and 7 shall not apply either to Requesting Company or INPO and paragraph 8(e) shall not apply to INPO.

11. This Agreement will not create any rights or defenses in favor of any entity or person not a signatory to this Agreement except to the extent provided in this paragraph and in paragraphs 8 and 10 of this Agreement. This agreement shall be binding upon and inure to the benefit of each signatory to this Agreement and the subsidiaries and affiliates of each such signatory.

12. Except as otherwise provided in paragraph 13, any Party may withdraw from this Agreement upon at least thirty (30) days prior written notice to INPO with a copy to all of the other Parties. Notice of withdrawal shall not affect any obligations which may have been incurred hereunder prior to the effective date of such notice or which may arise out of events occurring prior to the date. No Party may withdraw from this Agreement while it is receiving assistance pursuant to this Agreement.

13. This Agreement may be amended by the agreement of a majority of the Parties hereto. Such amendment shall be effective and binding upon all Parties thirty (30) days after INPO has received counterpart signature pages for the amendment executed by at least a majority of the Parties to the Agreement. INPO shall notify all Parties when at least a majority of the Parties have executed an amendment to the Agreement. No amendment shall affect any obligation which may have been incurred hereunder prior to the effective date of such amendment or which may arise out of events occurring prior to that date. Notwithstanding the first sentence of paragraph 12, any Party may withdraw from this Agreement by submitting written notice to INPO at 6-27

any time during the thirty (30) day period prior to the effective date of such amendment with a copy to all of the other Parties.

14. If any provision of this Agreement is determined to be invalid or unenforceable as to any Party or otherwise, such determination shall not affect the validity or enforceabi lity of the other provisions of this Agreement as to that Party or otherwise.

15. In the event (i) an emergency occurs at a nuclear power plant under the control of or operated on behalf of a Party; (ii) a request for assistance is issued to another Party hereto in respect to such emergency; and (iii) such assistance is provided, this Agreement shall be construed in accordance with the law of the State in which the nuclear power plant is located with respect to all ~ights and obligations arising out of such emergency.

6-28

COUNTERPART SIGNATURE PAGE The undersigned company hereby agrees to become a Party to the Nuclear Power Plant Emergency Response Voluntary Assistance Agreement dated J~ll 1999.

Oate Company By Corporate Officer Signature 6-29

Institute of Nuclear Pottier Operations Suite 1500 1100 Circle 75 Parkway Atlanta, Georgia 30339-3064 Telephone 404 953-3600 Telefax 404 953-7549 August 20, 1991 Mr. Thomas A. McClimans Consulting Engineer American Electric Power Service Corporation One Riverside Plaza P. O. Box 16631 Columbus, OH 43216-6631

Dear Mr. McClimans:

In support of your utility's emergency plan, this letter provides the annual certification of the assistance agreement between INPO and its member utilities. In the event of an emergency at your utility, INPO willassist you in acquiring the help of other organizations in the industry, as described in Section 1 of the Emergency Resources Maniacal, INPO 86-032. In addition, INPO willprovide assistance by utilizing its own resources, as requested and as appropriate.

This agreement willremain in effect until terminated in writing. Please forward a copy of this letter to your emer ency preparedness department for use in updating your emergency p an.

Should you have questions, please contact me at (404) 951-4742 or Sam Newton, manager, Emergency Preparedness Department, at (404) 953-7646.

Sincerely, ice President and Director Analysis Division JFG:ds cc: Mr. A. Alan Blind

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April 1988 6.5 Coordination A reement on Emer enc Information

~Amon U.S. Council for Ener Awareness USCEA Electric Power Research Institute EPRI Institute of Nuclear Power 0 erations INPO Nuclear Mana ement and Resources Council NUMARC and Their Member Utilities In order to provide for the efficient and timely transfer of technical and public information regarding classified emergencies at nuclear power stations and to maximize their assistance roles to their utility members and the industry, the U.S. Council for Energy Awareness, the Electric Power Research Institute, the Institute of Nuclear Power Operations and Nuclear Management and Resources Council have agreed to coordinate their actions and activities as outlined in this agreement.

It is explicitly recognized that the primary responsibility for release of appropriate information concerning an Emergency situation to the public and the news media rests with the affected utility. The purpose of this agreement is to provide a coordinated process by which these organizations can effectively convey information to the rest of the industry and to the media, in order to lessen the burden on the affected utility.

6-31

A. Among the four organizations involved in this coordination agreement, USCEA will provide information concerning industrywide implications of an Emergency, and will use existing mechanisms and media contacts to disseminate timely information on the events themselves.

1. USCEA will develop and issue, in coordination with the affected utility, appropriate public statements to the news media, as necessary.

2. USCEA will use INFOWIRE to relay information about the Emergency to the industry.

3. USCEA will place its statements issued to the news media on INFOWIRE and provide the INFOWIRE to INPO to be placed on the Emergency Hot Line topic of NUCLEAR NETWORK.

4. USCEA will make its information available to EEI, EPRI, NUMARC, and ANEC.

8. INPO will provide the NUCLEAR NETWORK electronic communications system to its members, USCEA, NUMARC, and EPRI to facilitate the flow of media and technical information about the Emergency to other INPO members and participants.

C. INPO will coordinate the flow of technical information among the parties to the agreement.

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1. INPO will furnish to EPRI and NUMARC technical information relevant to the Emergency as obtained from the utility and/or available in its own data bank.

2. INPO wi 11 maintain information on utility industry assistance capabilities and coordinate the deployment of persons and material under its Nuclear Plant and Transportation Agreements, as requested by the affected utility.

3. INPO will develop and disseminate to its members significant event reports regarding the Emergency as appropriate.

0. EPRI will maintain an emergency response capability and wi 11 be available for consultation and to conduct in-depth analyses of the Emergency as appropriate.

E. Both EPRI and INPO will be available to assist the affected utility through their analysis capabilities. EPRI and INPO will coordinate such efforts with each other.

F. NUMARC will maintain an emergency response capability for consultation on regulatory issues.

G. USCEA, EPRI, NUMARC, and INPO will encourage the use of USCEA and INFOWIRE for media information and the INPO NUCLEAR NETWORK for technical information flow.

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H. USCEA, EPRI, NUMARC, and INPO agree to develop and share written procedures governing emergency notifications and points of contact that provide for cross-notification for emergencies classed at the "alert" or higher level.

Richard E. Balzhiser Bryon Lee, Jr.

President President Electric Power Research Institute Nuclear Management and Resources Council lack T. Pate Harold B. Finger President President Institute of Nuclear Power Operations U.S. Council for Energy Awareness 6-34

EMERGENCY MEDICAL ASSISTANCE AGREEMENT BETWEEN THE PAWATING HOSPITAL AND THE DONALD C. COOK NUCLEAR PLANT This letter establishes an agreement between Indiana Michigan Power Company's Donald C. Cook Nuclear Plant (" Plant" ) and the Pawating Hospital in Niles, Michigan ("Hospital" ). In the event of a radiation or contamination injury to personnel on site, or members of the general public off site, resulting from operation of the Plant, Hospital agrees to provide emergency medical services sup'port to the Plant and the Michigan State Police/Emergency Management Division.

Hospital agrees to maintain the necessary hospital personnel trained in the specific methods of treating patients contaminated with radioactive materials. Retraining will be performed no less than annually. The Hospital will maintain a system for receiving patients in a designated area of the hospital.

Hospital agrees to maintain emergency medical service on a 24-hour per day, seven days per week basis for both on site personnel at the Plant and members of the general public off site who may be injured as a result of an emergency event at the plant. The Hospital will have at least one physician and one nurse available within about two hours who can supervise the evaluation and treatment of radiologically contaminated persons.

Plant agrees that as part of this agreement, Hospital may utilize on-call consultation services available from Radiation Management Consultants

("RMC") pursuant to RMC's contract with the Plant, in the event of a radiation or contamination injury requiring additional support or expertise.

Plant agrees to provide trained Health Physics personnel to supplement the Hospital staff in the event of a contamination injury at the Plant site.

The Plant will coordinate with the Michigan State Police/Emergency Management Division to provide this support in the event of a contamination injury off site resulting from an emergency at the Plant.

Plant agrees to provide all unique procedures, training, equipment, equipment maintenance and consumable materials required to enable Hospital to provide this service.

Plant agrees to decontaminate all Hospital equipment and facilities that become contaminated as a result of treatment of a victim, and to dispose of the associated waste.

Plant agrees to conduct and Hospital agrees to participate in joint drills that include Plant personnel and Hospital personnel.

Emergency Medical Assistance Agreement Between the Pawating Hospital and the Donald C. Cook Nuclear Plant Page 2 Both parties agree that, upon loss of the Plant Operating License issued by the U. S. Nuclear Regulatory Commission or loss of the Hospital JCAH accreditation, this agreement will terminate immediately.

Any party, upon ninety (90) days prior notice by registered letter to the other party, may terminate this agreement.

As indication of your agreement to the above statements concerning our mutual responsibilities, please sign below.

+ )v,o Dated:

M. P. exich ~ 4 Vice Preside t Indiana Michigan Power Company Pawating Hospital Dated: /

C.

Holiday Inn Benton Harbor 616-925-3234 Holiday Inn - St. Joseph 616-983-7341 Ramada Inn Benton Harbor 616-927-1172 Carlton Lodge Benton Harbor . 616-925-3000 D. Trans ortation Available:

Hertz: 6 16.-927-2 16 1 Avis: 616-926-2151 E. Police Escorts May be required. Coordinate requirement with County and/or State Police.

F. Police Vehicles for -Communication Au entation:

Coordinate specific requirements and request with Berrien County and/or State Police as available.

State Police Frequency 42.58 Hz County Sheriff 155.370 Hz e G. Travel Routes:

From Argonne: Take Take Interstate 80/94 east.

I-94 east to the Pipestone Road exit.

Turn right to Meadowbrook Road.

Left on Meadowbrook to the IGM Power Company Service Building.

H. Medical Facilit Location:

Mercy-Memorial Medical Center 1234 Napier Avenue Saint Joseph, MI 616-983-8300 Pawating Hospital 31 North St. Joseph Avenue Niles, MI 616-683-5510 I. Ma s of Sam lin Points Provided as required.

(Appendix F) Revision 10

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12

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0 I 4 0 lop St ~oot 0 0 0

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'o 222 S 2497 l23 S>0 q,Q I35 ep, y4B 572 SSI 320 i077 2+2 y45 124 B5

~<0 I07 22I3 2736 5I594 TOTAL SEGMENT POPULATION 0 TO IO MILES

• 1989 survey indicated 12 "summer only" residents inside Sector A. Area to be POPULAT10N TOTALS RING CUMULATIVE included in Sector B protective actions. RING, MILES POPULATION TOTAL MILES POPULATION These residents are not included in the 0- I 203 0- I 203 population totals. I -2 78I 0-2 984 2-3 3I50 0-3 4I34 3-4 4088 0-4 8222 4 5 6054 0- 5 l4 276 5-6 5I05 0 -6 l938I 6-7 6427 0-7 25808 7 8 653I 0 ,8 32329 8-9 5925 0-9 38254 9- IO l3340 0 IO 5I 594 REF: BASED ON 1980 POPULATION CENSUS Revision

SIX TEAR PLAN FOR GENCY PREPAREDNESS ACTIVITIES AT THE DONALD C. COOK NUCLEAR PLANT SIX YEAR ITENS 1988 1989 1991 1992 1993 1994

1. Exercise uith full State and. Catty parti~ipation involving the ingestion exposure pathNay.

2. Exercise with State and Catty participation.

3. Unarnouxed exercise Mith full State and Cuaty participation.

4. Exercise with full State and Catty participation initiated between 6t00 p.m. and 4:00 a.m.

5. Exercise Mith full State and Cecity participation.

1 Notes: For those requirements related to the six-year compliance period for selected exercise activities delineated above, the first six year cycle for the Donald C. Cook Plant ends in 19M. The second six year cycle russ from 1989 to 1994.

The plan presented above ensures coaplience uith both the NRC and FENA periodic exercise requirements.

SIX YEAR PLAN FOR EHERGENC EPAREDNESS ACTIVITIES AT THE DONALD C. COX NUCLEAR PLANT ANNUAL ITEHS 1991 1992 87 88 89 90 91 92 93 94 OCT NOV DEC JAN FEB HAR APR HAY JUN JUL AUG SEP OCT NOV DEC

1. Annual Graded Exercise 1a. Heating Mith State and Catty to X X X X 0 0 0 0 finalize exercise objectives.

1b. Exercise scope, objectives and X X X X X 0 0 0 timeline submitted to NRC/FEHA.

1c. Exercise scenario submitted to NRC/FEHA. X X X X X 0 0 0 1d. Train controllers/evaluators. 0 X X X X X 0 0 0 1e. Conduct the exercise. X X X X X 0 0 0 I

1f. NRC/FEHA critiques. X X X X X 0 0 0 1

2. Annual Hedia Briefing X X X X X 0 0 0

3. Revieu Emergency Action Levels 0 X X X'X X 0 0 0 uith State and Caaty authorities

4. Verify dates of letter of agreement in the Emergency Plan X X 0 X 0 0 0 0

5. RevieM docunentation to ensure 0 X X X X X 0 0 0 Emergency Response Organization perseacl have received required training in the past year.

SIX YEAR PLAN FOR ENERGEH EPAREDNESS ACTIVITIES AT THE DONALD C. COOK NUCLEAR PLANT ANNUAL ITENS 1991 1992 87 88 89 90 91 92 93 94 OCT NOV DEC JAH FEB NAR APR NAY JUH JUL AUG SEP OCT NOV DEC

6. Test of camxnications betueen the X X X X X 0 0 0 Cook Plant, State and County EOCs and Field Assessment Teams

7. Revieu of Emergency Preparedness X X X X X 0 0 0 Progras pursuant to 10CFR50.54(t)

(NSDRC Audit)

8. Letter to State and Caaty making X X X X X 0 0 0 interface evaluation portion of 50.54(t) revieH available to them.

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9. Distribution of Emergency Preparedness 0 X X X X 0 0 0 0 Public Information Brochure

10. Fire drill Hith off-site support X X X X X 0 0 0 participation (conducted per Plant Technical Specifications).

11. Training for plant, hospital, and X X X X X 0 0 0 ambulance persornel on the handling and treatment of contasinated/injured persornel.

SIX YEAR PLAN FOR EHERGEN REPAREDNESS ACTlVlTlES AT THE DONALD C. COOK NUCLEAR PLANT ANNUAL lTEHS 1991 1992 87 88 89 90 91 92 93 94 OCT NOV DEC JAN FEB HAR APR HAY JUN JUL AUG SEP OCT NOV DEC

12. Hedical emergency drill involving X X X X X 0 0 0 a contaminated individual.

13. Annual PNSRC revieu of the X X X X X 0 0 0 Emergency Plan Procedure

14. Radiological Honitoring Drill X X X X X 0 0 0 (both on-site and off-site). Dr3ll to include collect3on and analysis I

of Hater, vegetation, soil and I

a3r samples. Coordinated Mith the bNlUIL exercise I

15. Health Physics Dr3LL. Drill to X X X X X 0 0 0 involve analysis of inplant Liquid samples Mith actual radiat3on levels including use of the post-accident sampling system. Coordinated Nith the annual exercise.

16. Test of the Public Notification System. X X 0 X X 0 0 0

SIX YEAR PLAN FOR EHERGEN PAREDNESS ACTIVITIES AT THE DONALD C COOK NUCLEAR PLANT SENI-ANNUAL ITENS 1991 87 88 89 90 91 92 93 94 OCT NOV DEC JAN FEB NAR APR NAY JUN JUL AUG SEP OCT NOV DEC

1. Semi-annual backshift augmentation 0 X X X X 0 0 0 0 drill.

2. Semi-aawal Health Physics Drill X X X X X 0 0 0 involving the response to and analysis of siaaiated airborne and liquid saaples end direct radiation measurements in the envirolaent.

OUARTERLY ITENS I

~

1. Verification of plant persormel 0 X X X X 0 0 0 0 Notification Telephone Numbers.

(see PNP 2080 EPP.107)

2. Verification of Initial Notification 0 X X X X 0 0 0 0 Telephone Numbers (see PNP 20M EPP.106 Exhibits 8 f C).

3. Fire Emergency Drill. X X X X X 0 0 0

4. Operability checks, per Radiation X X X X X 0 0 0 Protection Procedures.

5. Inventories, per, 12 THP 6010 RPP.009 and X X X X X 0 0 0 m 12 SHP 2270 FIRE.006.

0

SIX YEAR PLAN FOR EKERGEN EPAREDNESS ACTIVITIES AT THE DONALD C. COOK NUCLEAR PLANT KONI'HLY I TENS 1991 1992 87 88 89 90 91 92 H 94 OCT NOV DEC JAN FEB KAR APR KAY JUN JUL AUG SEP OCT NOV DEC State and CoIslty EOC (IIithin EPZ) X X 0 0 0 0 0 0 0 0 0 0 0' 0 X X X X 0 0 0, 0 coaImslication tests.

2. NRC HeadqUarters and Regional X X 0 0 0 0 0 0 0 0 0 0 0 0 0 X X X X 0 0 0 0 of f lce cocnsll cat'ions test (CR, TSC, EOF) ~

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