ML18135A146

Attachments I to V: Evaluation of Proposed Changes, Emergency Plan Change Summary, ERO Position Matrix, Summary of Shift Staffing and Letter of Consultation and Concurrence from Off-Site Response Organizations Ack of Opportunity

ML18135A146
Person / Time
Site:	Wolf Creek
Issue date:	05/09/2018
From:	Wolf Creek
To:	Office of Nuclear Reactor Regulation
Shared Package
ML18135A172	List: ML18135A146 WO 18-0016, License Amendment Request for Revision to the Emergency Plan
References
WO 18-0016
Download: ML18135A146 (492)

Text

Attachment I to WO 18-0016 Page 1 of 27 EVALUATION OF PROPOSED CHANGES License Amendment Request for Revision to the Wolf Creek Nuclear Operating Corporation Emergency Plan 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 No Significant Hazards Consideration Determination 4.3 Conclusions

6.0 REFERENCES

Attachment I to WO 18-0016 Page 2 of 27 1.0

SUMMARY

DESCRIPTION Pursuant to 10 CFR 50.90, "Amendment of License or Construction Permit at Request of Holder," Wolf Creek Nuclear Operating Corporation (WCNOC) requests Nuclear Regulatory Commission (NRC) review and approval of a revision to the Wolf Creek Generating Station (WCGS) Radiological Emergency Response Plan (RERP). The proposed revision includes:

1) Reducing the number of required Emergency Response Organization (ERO) positions;

2) Standardizing activation times for the Technical Support Center (TSC) to 75 minutes;

3) Replacing the current full-time normal work hours licensed medical practitioner position with First Aid Responders, and

4) Removing reference to performing dose assessment using containment pressure indication.

WCNOC has reviewed the proposed changes against the planning standards in 10 CFR 50.47(b) and the requirements in 10 CFR Part 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities," and has concluded that the standards and requirements will continue to be met.

2.0 DETAILED DESCRIPTION Currently, the WCGS RERP, Attachment D, "WCGS Minimum Staffing for Emergencies",

specifies the augmentation response times for certain ERO positions ranging from 60 to 90 minutes. This submittal does not change augmentation response times. WCNOC proposes to revise RERP Attachment D to reduce minimum staffing affecting the following Major Functional Areas as established by NUREG-0654/FEMA-REP-1, Revision 1, Table B-1, "Minimum Staffing Requirements or NRC Licensees for Nuclear Power Plant Emergencies":

• Notification/Communication

• Radiological Accident Assessment & Support of Operational Accident Assessment

• Plant System Engineering, Repair & Mitigative Actions

• Protective Actions (In-plant)

The specific standard for establishing a shift emergency organization to respond to emergency events appears in 10 CFR 50.47 (b)(2) which states, in part, "On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times ... " 10 CFR Part 50, Appendix E, Section IV.1 requires licensee emergency plans to contain, in part, the organization for coping with radiological emergencies and the activation of the emergency organization, including individuals assigned to the licensee's ERO with a description of emergency assignments.

WCNOC completed a functional analysis of the augmented ERO positions based on the proposed minimum staffing changes and completion of the major tasks required by NUREG-0654/FEMA-REP-1, Revision 1, (Reference 1). The analysis determined that minimum staffing changes can be made, while maintaining the site's ability to protect public health and safety. A new analysis of on-shift responsibilities in accordance with 10 CFR 50, Appendix E, Section IV.A.9 evaluating the impacts associated with the proposed changes was performed and verified that ERO positions were not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan.

Attachment I to WO 18-0016 Page 3 of 27 NUREG-0654 (Reference 1), Section 11.8, "Onsite Emergency Organization," presents guidance for meeting these requirements. The guidance describes the on-site emergency organization, including the staffing requirements found in Table 8-1, "Minimum Staffing Requirements for NRC Licensees for Nuclear power Plant Emergencies." This table specifies a minimum of ten on-shift responders in four Major Functional Areas. It also specifies seven on-shift response functions where the duties may be performed by shift personnel who are assigned other functions (i.e., there are no dedicated responders to perform these functions). Table 8-1 specifies two Major Functional Areas (i.e., firefighting and site access control/personnel accountability) which must be staffed on a site-specific basis.

The on-shift staff must be able to cope with a spectrum of events until augmenting ERO personnel arrive in accordance with the site's emergency plan commitments. The augmenting ERO responders assume many managerial, engineering, and administrative duties from the on-shift personnel, allowing on-shift personnel to focus more fully on plant operations.

On November 23, 2011, the NRC published a final rule in the Federal Register amending certain emergency preparedness (EP) requirements in its regulations that govern domestic licensing of production and utilization facilities (Reference 2). This final rule amended 10 CFR Part 50, Appendix E, Section IV.A, "Organization," to address the assignment of tasks or responsibilities to on-shift ERO personnel that could potentially overburden them and prevent the timely performance of their emergency plan functions. Specifically,Section IV.A.9 states that licensees shall perform " ... a detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan."

Coincidentally with the rule change in 10 CFR 50, Appendix E, Section IV.A.9, the NRC issued NSIR/DPR-ISG-01, "Interim Staff Guidance - Emergency Planning for Nuclear Power Plants" (Reference 3). The Interim Staff Guidance (ISG) provides information relevant to performing the on-shift staffing analysis. The ISG states that the Nuclear Energy Institute (NEI) developed the document NEI 10-05, "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities," (Reference 5) to establish a standard methodology for a licensee to perform the required staffing analysis, and that the NRC reviewed NEI 10-05 and found it to be an acceptable methodology for this purpose. The ISG also indicates that the completed staffing analyses are required to be part of the emergency plan and the results documented and submitted to the NRC in accordance with 10 CFR 50.54(q)(5).

Significant increases in the number of on-shift positions have occurred over the past several years. Currently a total of 17 positions are identified for on-shift staffing, which is an increase from the regulatory guidance provided by the NUREG-0654, Revision 1, total of 10 persons and the Wolf Creek Generating Station Radiological Emergency Response Plan, Kansas Gas &

Electric Company, Revision 15, dated January, 1985, where the NRC approved an on-shift staffing level of 10 positions. The last Wolf Creek Generating Station Radiological Emergency Response Plan, Kansas Gas & Electric Company reviewed and approved by the NRC was Revision 15, dated January 1985 (Reference 7) approved by NRC Safety Evaluation Report (SER) dated June, 1985.

Attachment I to WO 18-0016 Page 4 of 27 The ERO in Revision 15 of the Wolf Creek Generating Station Radiological Emergency Response Plan, Kansas Gas & Electric Company consisted of 26 positions which were augmented by 38 home office personnel positions to support site response to an emergency.

Then the ERO consisted of approximately 64 positions. Today, the ERO consists of approximately 256 responders. This represents a greater than 100% increase in the number of individuals qualified to meet existing emergency plan requirements. Reducing the number of ERO positions will increase the number of eligible plant personnel available to fill critical ERO positions and add valuable expertise to the responding team.

WCNOC is also proposing to standardize the TSC activation time to 75 minutes. Currently, WCGS RERP, Section 6.6.1 states:

"TSC activation will be performed as soon as practical and within the times as stated in the following:

1. During off-normal working hours, it is the goal to activate the TSC within 75 minutes of declaration of an Alert or higher classification.

2. During normal working hours, it is the goal to activate the TSC within 30 minutes of a declaration of an Alert or higher classification."

Augmentation time for key augmented ERO positions remains unchanged at 60 minutes per RERP, Attachment D, "WCGS Minimum Staffing for Emergencies". It should be noted, at WCNOC the Operations Support Center (OSC) and TSC are co-located. Unless specifically stated, TSC refers to the TSC and OSC.

The third proposed change to the RERP is to remove the current full-time normal work hours licensed medical practitioner position currently credited in addition to the on shift First Aid Responders. RERP Section 6.4.6.1, currently refers to a full-time Licensed Practitioner, while RERP Section 6.4.6.3, states, "Shift personnel, trained in first aid, are available on-site 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day". The deletion of references to a licensed practitioner, who is only available during regular business hours, with retention of reference to the 24-hour on-site first aid responders is consistent with the planning standards and evaluation criteria of NUREG-0654/FEMA-REP-1, Revision 1, Section 11.0.3.

The fourth proposed change would remove reference to performing dose assessment using changes in containment pressure indication. The current RERP Section 6.3.7.3 reference to the dose assessment software model estimating release rates and off-site exposures for an unmonitored, pressure-driven containment release using the containment High Area Radiation Monitor readings and changes in containment pressure is being removed. This software capability erroneously attributes all changes in containment pressure solely to leakage, and fails to account for the more likely and significant sources of pressure decrease (such as steam cloud condensation and/or temperature reduction due to actuation of coolers or the initiation of containment spray). Historically, use of this capability of the software has produced large overestimations of offsite doses during exercise scenarios containing an unmonitored release, leading to unwarranted recommendations of protective actions to the public.

Attachment I to WO 18-0016 Page 5 of 27

3.0 TECHNICAL EVALUATION

Functional Analysis This analysis evaluates the impact of reducing the required number of ERO positions on the ability of the on-shift and augmented ERO positions to perform the major tasks for the major functional areas of the WCNOC RERP. The analysis demonstrates that no degradation or loss of function would occur as a result of the change. This approach makes use of the guidance provided by RIS 2016-10, License Amendment Requests for Changes to Emergency Response Organization Staffing and Augmentation," (Reference 11). Even though the proposed changes to the WCNOC RERP seeks no alteration to augmenting ERO arrival times, this approach was considered suitable since the RIS does "highlight some specific items that NRC staff consider when reviewing shift staffing change requests for augmented ERO positions as provided in NUREG-0654, Table B-1."

The following discusses the rationale based on this functional analysis for concluding that on-shift personnel can satisfactorily implement all EP functions as described in RERP Attachment D, "WCGS Minimum Staffing for Emergencies". Enclosures I and II provide the revised RERP Attachment D with the proposed minimum staffing changes. Attachment IV provides a summary of historical shift staffing and augmentation response time requirements, and proposed minimum staffing changes.

Functional Area: RERP Attachment D, Plant Operations & Assessment of Operational Aspects NUREG-0654 Major Task: NIA The proposed change increases the number of on-shift Nuclear Station Operators from 5 to 7.

These positions are being added to replace the on-shift Radiation Protection (RP) and Chemistry personnel currently used on the Fire Brigade. The additional Operations personnel will also be available to assist with event mitigation when not performing Fire Brigade duties, In accordance with the current WCNOC RERP, the on-shift staffing is in excess of the requirements of NUREG-0654, Revision 1, Table 8-1, as well as that prescribed in the last NRG-approved emergency plan, Revision 15, from January, 1985. (The proposed change also retitles HP to RP to align with station references to this work group.)

The 2012 On-shift Staffing Analysis (OSSA), completed in accordance with 10 CFR 50, Appendix E, Section IV.A.9, provided a total on-shift staffing of 17 personnel. This represented an increase of 7 persons when compared to the regulatory guidance stated in NUREG-0654, Revision 1, Table 8-1, and an increase of 7 persons when compared to the last NRG-approved WCNOC emergency plan, Revision 15, January, 1985. The August 2017 updated OSSA reduced the existing on-shift complement to a total of 16 personnel. This reduction combined the Emergency Notification System (ENS) and Offsite Communicator positions (rationale for this change is fully discussed in the Notification/Communication section below). This change maintains an increase of 6 persons when compared to the regulatory guidance provided by NUREG-0654, Revision 1, Table 8-1, and an increase of 6 persons compared to the last NRC-approved emergency plan, Revision 15, dated January, 1985. The additional on-shift staff helps to ensure prompt response to a wide spectrum of emergency events.

Therefore, the proposed reduction in minimum staffing will not detract from the capability of on-shift personnel to support plant operations or the assessment of operational aspects at the start of an event and until the on-shift staff is augmented.

Attachment I to WO 18-0016 Page 6 of 27 Functional Area: RERP Attachment D, Emergency Direction and Control NUREG-0654 Major Task: NIA RERP Attachment D designates the Shift Manager as the on-shift responder for this Major Functional Area. The Off-Site Emergency Manager is designated in the Attachment as an augmented responder for the Major Functional Area of Radiological Accident Assessment &

Support of Operational Accident Assessment. No changes are made to RERP Attachment D for the Emergency Director in this Major Functional Area.

Functional Area: RERP Attachment D, Notification/Communication NUREG-0654 Major Task: Notify licensee, state, local, and federal personnel and maintain communication RERP Attachment D currently requires 2 on-shift personnel and 3 augmented responders within 60 minutes to perform notifications and communications. The proposed revision would change the 2 on-shift communicators to 1 on-shift communicator. The 3 augmented responders within 60 minutes would remain unchanged. The proposed change results in combination of the Emergency Notification System (ENS) and the Off-site Communicator positions into a single dedicated on-shift Communicator position.

Notification/communication responsibilities require notification of off-site authorities responsible for directing protective actions on behalf of the general public. The State of Kansas and Coffey County are required to be notified within 15 minutes of the declaration of any emergency classification or change in protective action recommendation. The NRG is notified immediately following the state and local notifications and in all cases within 60 minutes of the emergency declaration. For evaluation purposes, NRG notifications were treated as a continuous action in accordance with 10 CFR 50.72(c)(3), meaning that once the initial NRG communications are established, it is assumed that the NRG will request an open line to be continuously maintained with the NRG operations center.

As a result of the 2012 OSSA, Revision 13 of the RERP previously added dedicated communicators (ENS and Off-site) to the on-shift complement. Subsequent drills and exercises have shown that there is not a need for separate responders to successfully complete all the tasks assigned to both responders, and that these tasks could be accomplished by a single responder. Accordingly, the August 2017 updated OSSA, combined these positions to further validate that that on-shift personnel assigned emergency plan implementation functions were not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan.

The ability of a combined ENS and Off-site Communicator position to complete assigned tasks is due to technological improvements in communications equipment. The availability of dedicated telephone circuits and the use of a wireless headset enables NRC notifications to be performed by the same on-shift communicator who performs the state and county notifications.

Using a headset as needed, a single dedicated communicator can maintain an open line with the NRC while making state and county notifications on another line. This capability has been successfully demonstrated in four emergency drills conducted at WCGS to test this function.

Notification of licensee personnel is initiated through an automated call-out process which is initiated by the Communicator. The proposed change does not impact the call-out process or the notifications of licensee personnel.

The assignment of a dedicated on-shift communicator who will use improved communication equipment, and the demonstration of this capability in emergency drills, ensures that the capability to perform the major tasks in this functional area will be maintained.

Attachment I to WO 18-0016 Page 7 of 27 Functional Area: RERP Attachment D, Radiological Accident Assessment & Support of Operational Accident Assessment NUREG-0654 Major Task: EOF Director, Offsite Dose Assessment, Offsite Surveys, Onsite (Out-of-Plant) and In-Plant Surveys, Chemistry/Radiochemistry EOF Director The current RERP requires the EOF Manager and staff to respond within 90 minutes.

No changes are proposed for the response time for the EOF Manager and staff.

Offsite Dose Assessment, Offsite Surveys, Onsite (Out-of-Plant) and In-Plant Surveys, Chemistry/Radiochemistry The current RERP requires 3 RP personnel and 2 Chemistry personnel be on-shift. These numbers were increased, from 2 RP personnel and 1 Chemistry personnel, based on the 2012 staffing analysis, completed in accordance with 10 CFR 50, Appendix E, Section IV.A.9, which included RP and Chemistry as part of the Fire Brigade. The additional personnel were added for Fire Brigade purposes only. Since performance of the initial analysis, the composition of the Fire Brigade has been changed to exclude RP and Chemistry personnel. The proposed change to the RERP includes reducing these positions to the previous numbers - 2 RP and 1 Chemistry on-shift.

The on-shift Chemistry technician is tasked with performing off-site dose assessment. Review of procedures determined that the on-shift Chemistry technician is not required to perform any chemistry/radiochemistry sampling within the first 90 minutes in accordance with Technical Specification requirements. Therefore, the on-shift Chemistry technician can readily perform off-site dose assessment calculations without any collateral duties. All Chemistry technicians assigned on-shift are trained to perform these calculations with a computerized Control Room dose assessment program using effluent radiation monitor readings and meteorological indications, both available in the Control Room. Backup methodologies for inputs are provided should these indications fail or otherwise not be available. The on-shift Chemistry technician is dedicated to perform off-site dose assessment tasks until dose assessment transfers directly to the EOF per the current RERP.

Chemistry/Radiochemistry No chemistry samples are required by Technical Specifications within the 90-minute period after an emergency declaration. RERP Attachment D currently requires 1 augmenting Chemistry technician reporting to the TSC/OSC in 60 minutes to perform chemistry/radiochemistry tasks.

This augmentation is not changing.

Offsite Surveys, Onsite (Out-of-Plant) and In-Plant Surveys RERP Attachment D currently requires 1 augmenting responder with Senior Health Physics expertise, and 8 augmenting RP personnel reporting to the TSC/OSC within 60 minutes to assist with off-site surveys, on-site and in-plant surveys. The proposed change would reduce the number of augmenting RP personnel to 6. Improvements in technology and communication methods enable the reduction in augmenting RP personnel.

Attachment I to WO 1a.:.0016 Page 8 of 27 The on-shift RP technicians and the RP technician augmented responders are qualified to perform assigned tasks, which include off-site surveys, on-site (out-of-plant) surveys, and in-plant surveys. These RP tasks are directed by the Shift Manager to support actions in off-normal procedures, emergency operating procedures and emergency planning procedures (EPPs). The RP technicians report to the Control Room to provide RP support (including in-plant and out of plant surveys) as directed by the Shift Manager. The use of in-plant radiological monitoring instrumentation to determine the radiological conditions in on-site and in-plant areas supports the on-shift personnel in performing these functions until augmenting staff arrives.

Installed in-plant radiological monitoring instrumentation provides a means by which radiological conditions can be determined during an emergency, thereby reducing the need to send RP personnel into the plant to obtain radiological data. The radiological monitoring system ensures that both RP and ERO members are kept informed of current and changing radiological conditions. In-plant radiological instrumentation provides a continuous radiological status of the rooms monitored and provides local and remote alarming capability. Avoiding the dispatch of RP personnel to survey areas unnecessarily by use of the in-plant area radiation monitors (ARMs) satisfies the requirements of 10 CFR 20.1101 (b) because occupational radiation exposure is kept as low as reasonably achievable.

The radiation monitoring system consists of a wide variety of monitoring covering key areas of the plant. These monitors are integrated into the plant computer system (NPIS) and readings are available in the Control Room, RP office, Chemistry laboratory, TSC, OSC, and EOF. The system provides the Emergency Director, RP and Chemistry personnel with the ability to rapidly assess overall plant conditions throughout the site.

• The Radiation Monitoring System consists of individual radiation monitoring channels monitored in the Control Room. The system fulfills the following functions:

• Warn operating personnel of radiological health hazards.

• Provide early warning of plant conditions which may lead to a radiological health hazard.

• Prevent or minimize the effects of inadvertent release of radioactivity to the environment by consequence-limiting automatic responses.

• Provide routine monitoring of controlled off-site releases.

• Provide dose rate information of critical areas during an accident.

• Provide indications for aiding accident assessment.

Radiation monitoring channels provide an output to NPIS. The output signals are processed by NPIS to provide Operations and RP with additional information on the status of plant radiation levels The individual radiation monitoring channels are either process radiation monitors or area radiation monitors. The area radiation monitors provide information useful in assessing radiation exposure to personnel in areas that may have radiation and/or occupancy potential during both normal and abnormal plant conditions. The area monitors are equipped with an indicator and an alarm in the vicinity of the detector.

The process radiation monitors provide information about radioactive concentration in various systems; leakage across boundaries of closed systems; and radioactive concentrations in liquid and gaseous effluents. The process monitors consist of a remote detector and a rack mounted module which provides indication, control functions and alarms. Process radiation detectors are either "in-line", located in the process piping, or "off-line" where part of the process flow is diverted to a separate detector chamber.

Attachment I to WO 18-0016 Page 9 of 27 Area radiation monitors are located in areas where personnel perform routine duties, areas where personnel perform infrequent duties yet have a significant probability for hazardous dose rates, areas where there is a small probability for hazardous dose rates yet continuous surveillance is necessary and critical areas of the plant that may require entry during an accident condition. A local alarm buzzer warns personnel in the area and a common annunciator alerts Control Room personnel.

Air particulate monitors are provided to monitor beta activity which may be carried by particulate matter in the air. These monitors can be used to sample either the containment atmosphere or the unit ventilation stack. Air particulate monitors typically contain a detector, a filter, a pumping system, and a check source. The detector is a scintillation type beta sensitive optically coupled to a photomultiplier tube.

Gas is most easily detected by detecting beta particles using G-M tubes. The gas monitor detectors are designed to measure beta-gamma activity.

The liquid monitors are designed to measure the gamma activity in a liquid process line. Each liquid monitor line uses a Nal scintillation detector and is equipped with a check source to allow detector testing. Both in-line and off-line configurations are used at WCGS.

Integration of the radiation monitoring systems with NPIS has increased the availability of normal and accident condition radiological information which results in enhanced work processes. The improved availability has reduced the need for continuous in plant RP technician support during an emergency condition.

Off-site surveys are not normally initiated during the very early stages of an event because preplanned plant condition-based Protective Action Recommendations (PARs) are designed to provide initial information to offsite officials sufficient to allow them to make timely and well-informed protective action decisions. As additional augmentation personnel become available, these personnel can be used to obtain offsite survey results which are then used to adjust the PAR as necessary. In addition, expected release pathways are monitored release points, allowing the dedicated on-shift dose assessor to factor the impact of actual meteorological conditions on off-site projected doses. Prior to 60-minute augmentation, in-plant radiation monitoring instrumentation would be used to detect a radiological release because radiological release instrument data is easily obtained. In the unlikely event that a survey is needed to

.detect or validate a potential unmonitored release pathway, the 2 on-shift RP technicians provide the capability to perform onsite (out-of-plant) surveys for this purpose.

Off-site radiological monitoring tasks, such as soil, water and vegetation sampling, or retrieval of environmental dosimetry can be performed as additional personnel arrive up to the 60-minute augmentation time. These radiological survey tasks are considered in the recovery phase, following a release of radioactive material, and are not needed for the immediate protection of the public health and safety.

The reduction in RP responders is supported by the use of in-plant instrumentation, installed monitoring capability and in-plant and on-site surveys to support off-site dose assessment. The use of the Chemistry technician as a dedicated on-shift dose assessor facilitates the monitoring and use of installed instrumentation for this purpose. In addition, radiological monitoring of installed plant instrumentation is sufficient to perform off-site dose assessment activities until augmented personnel arrive. The enhanced use of in-plant radiation monitoring instrumentation, information technology, and communications supports a reduction of RP 60-minute augmented responders from 8 to 6.

Attachment I to WO 18-0016 Page 10 of 27 Functional Area: RERP Attachment D, Plant System Engineering, Repair & Mitigative Actions NUREG-0654 Major Task: Technical Support, Repair and Corrective Action RERP, Attachment D identifies on-shift personnel fulfilling the functions of technical support, radwaste operator and electrical maintenance. No change is being made to these assignments.

RERP, Attachment D currently requires 3 augmenting engineers within 60 minutes reporting to the TSC/OSC for technical support. No change is being made to these augmenting requirements.

The Shift Technical Advisor (STA) is the on-shift position assigned for technical support. The STA functions in an oversight role for accident assessment and evaluation of operating conditions, and providing the core/thermal hydraulic technical support function on shift. The STA performs assigned technical support activities as required by operating procedures, Technical Specifications, and emergency implementing procedures. A review of procedural actions for this position demonstrated that failed fuel determinations, as well as establishing recovery/reentry priorities, would not be required until augmenting staff arrives. Initial reactor core stabilization activities are performed by the Operations crew under the direction of an SRO.

Evaluation of the on-shift activities in accordance with 10 CFR 50, Appendix E.IV.A.9 showed that on-shift operations personnel were able to complete required tasks without conflicts. No change is being made to this major task.

RERP Attachment D currently requires 5 augmenting Maintenance technicians reporting to the TSC/OSC within 60 minutes. This includes 2 Mechanical Maintenance, 2 Electrical Maintenance and 1 l&C technician. The proposed change reduces the augmenting Maintenance technicians to 3; eliminating 1 mechanical and 1 electrical maintenance responders.

During initial stages of an event, the scope of repair and corrective actions performed by on-shift personnel are typically limited to actions that promptly restore a non-functional component or system to functional status (e.g., resetting a relay or logic manipulation) or to place a component or system in a desired configuration such as opening a valve or closing a breaker. The WCGS on-shift nuclear station operators have the training and expertise to perform this level of minor maintenance actions as directed by the Control Room Supervisor and are available to satisfy any minor troubleshooting and repair activities that might be needed until augmenting staff arrives. The addition of 2 nuclear station operators for Fire Brigade coverage expands the capabilities of the on-shift complement to provide this function. The augmented maintenance responders (1 electrical, 1 mechanical, 1 l&C) provide additional resources for repair and corrective actions. Due to the time needed to stabilize the plant and assess the event, the initial phase of accidents is not expected to involve a significant need for dedicated and specialized maintenance personnel beyond these augmented responders. A detailed review of emergency and maintenance procedures indicated that more significant repair activities would not be initiated for several hours after the event occurred, allowing time to contact specialized resources as needed. The proposed change does not impact implementation of repair and corrective actions completed by on-shift and augmented resources.

The Plant System Engineering, Repair & Mitigative Actions functions are not adversely impacted by the proposed changes. Core thermal hydraulics and repair and corrective action major tasks will continue to be performed by on-shift and augmented personnel.

Attachment I to WO 18-0016 Page 11 of 27 Functional Area: RERP Attachment D, Protective Actions (In-Plant)

NUREG-0654 Major Task: Radiation Protection - Access Control; RP coverage for repairs

& corrective actions, search and rescue, first aid and firefighting; personnel monitoring; dosimetry The current RERP Attachment D identifies 1 on-shift RP individual assigned other functions.

This is the second RP Technician listed on-shift in the Radiological Accident Assessment &

Support of Operational Accident Assessment function.

The current RERP Attachment D lists 4 augmenting RP personnel reporting to the TSC/OSC within 60 minutes. The proposed change reduces the number of RP augmenting responders to

2. Together with the RP personnel responding in the Radiological Accident Assessment &

Support of Operational Accident Assessment functional area, the proposed change reduces the total number of augmenting RP personnel at 60 minutes from 12 to 8.

The on-shift RP technicians and the RP technician augmented responders are all fully qualified to perform assigned tasks; which include access control duties, RP coverage for workers, personnel monitoring, and dosimetry.

Originally, radiological access control was a labor intensive task. Dedicated RP technicians were required to check dose margins, training qualifications, and ensure workers had read and understood the radiation protection work permit (RWP). Worker access control is now automated because radiation protection work processes have been computerized. RWP access control and electronic dosimeter computer systems work together to provide a fully integrated system allowing workers to sign-in on RWPs and to self-issue electronic dosimeters.

Both systems have been used by plant workers for several years. Worker dose margins and training qualifications are also automatically verified when the RWP access control system is used. If a worker's dose margin is inadequate or training is expired, the worker's access will be precluded and the access control system would not allow issuance of an electronic dosimeter.

The performance of access control and dosimetry activities is primarily completed through the use of electronic dosimetry (ED) which is obtained prior to entry into radiologically controlled areas (RCAs). The ED is also used as a 'key' to unlock turnstiles to gain access to the RCA.

RWPs determine the necessary preset warnings/alarms associated with the use of the ED.

Specific pre-established emergency RWPs have been developed for use during a declared emergency, which automatically provide the ED with emergency dose rate and dose rate alarms. This assumes that the teams dispatched to the in-plant areas to perform any function during a declared emergency will be afforded ample warning/alarm prior to exceeding their allowed dose or dose rate. Use of the EDs and RWP process eliminates the need for continuous access/dosimetry oversight by RP technicians for the initial event response.

Through the use of improved access control technology, reduction of the RP augmented responders does not adversely impact performance of the Access Control/Dosimetry major tasks.

Attachment I to WO 18-0016 Page 12 of 27 Performance of RP coverage for response action activities will continue to be performed initially by the on-shift RP technician. RP coverage will only be performed if the radiological status of a room/area is unknown and there is a definitive need for emergency workers to enter the room/area to perform a task. The decision to provide RP coverage may be based on plant radiological conditions as indicated by installed area radiation monitors (ARMs). During the initial stages of an accident, not all areas of the plant would be affected by releases of radioactive materials. Therefore, continuous RP coverage would not be required for all areas.

If RP coverage is deemed necessary, multiple emergency teams can be covered by a single RP technician. If RP coverage is not provided (for entry into area with low radiological risk or known radiological status), worker protection is ensured because emergency workers are required to wear electronic dosimeters (which alarm at preset dose and dose rate setpoints) and because of the installed ARMs (which alarm locally and remotely at preset dose rates) located throughout the plant. Additionally, use of a remote monitoring (telemetry) system allows the RP technician to monitor multiple work groups simultaneously from remote points reducing the time and effort required for job coverage while maintaining adequate protection for radiation workers. The functions associated with this major task will not be adversely impacted by the proposed change.

Personnel are required to self-monitor for radioactive contamination whenever they exit the RCA. No RP involvement is necessary for this contamination monitoring activity because the workers are trained to perform this task without supervision or oversight. A portal monitor (PM-

12) is used at the exit of the RCA before the worker is processed through the whole body contamination monitor. The PM-12 is a microprocessor based radiation detection system which provides quick indication of contamination on personnel. The monitor has 8 independent scintillation detectors and an internally mounted battery back-up that can maintain unit operation for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The alarm setpoints for the PM-12 are based on site RP procedure requirements.

The whole body contamination monitor used at the exit of the RCA is a Two-Step Exit (TSE) monitor. The monitor is a highly sensitive RP tool which can be used to locate contamination on a body and quantify the contamination activity. The TSE uses beta and gamma scintillation technology for detection of contamination. Measurement is accomplished in a two-step - front then back - sequence. Alarm set points are established in accordance with site RP procedures.

Equipment and process improvements, combined with the establishment of Emergency RWPs and emergency dose limits provide significant enhancements to efficient access control and reduce the need for direct RP technician support.

The proposed changes maintain the existing on-shift RP technicians for the RP coverage task, while reducing the augmenting RP staff for these tasks from 4 to 2. WCGS has implemented improvements in technology in the areas of dosimetry and access control which reduced the need for RP technician actions in each of these areas during early stages of event response.

Attachment I to WO 18-0016 Page 13 of 27 Functional Area: RERP Attachment D, Fire Fighting = Fire Brigade NUREG-0654 Major Task: NIA Per NUREG-0654, Revision 1, the Firefighting functional area is addressed by use of a Fire Brigade and managed in accordance with the site Technical Specifications. WCNOC Technical Requirements Manual (TRM) Section TR5.2.1.b describes the Fire Brigade composition.

The proposed change removes on-shift RP and Chemistry technicians from the Fire Brigade and replaces them with Operations personnel. This change was discussed in the Radiological Accident Assessment & Support of Operational Accident Assessment section.

In Revision 15, of the Wolf Creek Generating Station Radiological Emergency Response Plan, Kansas Gas & Electric Company, Firefighting response was provided by on-site personnel assigned other functions and augmented by the off-site local fire department. The current WCNOC RERP maintains the Firefighting functions commitment through the use of on-shift Fire Brigade members in accordance with the Fire Protection Program. The proposed changes do not impact this function. The current and proposed on-shift fire protection staffing was evaluated in accordance with 10 CFR 50 Appendix E.IV.A.9 and found to be sufficient.

Functional Area: RERP Attachment D, Rescue Operations and First Aid NUREG-0654 Major Task: NIA NUREG-0654, Revision 1, Table 8-1 notes that this function may be provided by on-shift personnel assigned other functions.

RERP, Attachment D includes 2 on-shift personnel assigned other tasks as fulfilling this function. Wolf Creek Generating Station Radiological Emergency Response Plan, Kansas Gas

& Electric Company Revision 15, provided for first aid treatment for injured personnel by qualified on-shift personnel. The current RERP maintains this commitment through the use of on-shift First Aid Responders. The current RERP Section 6.4.6.1 refers to a full-time Licensed Practitioner also being available on site during business hours. The proposed change eliminates this additional position which is not included in RERP Attachment D. The proposed changes to the RERP do not impact the Rescue Operations and First Aid function as indicated in RERP Attachment D.

Functional Area: RERP Attachment D, Site Access Control and Accountability NUREG-0654 Major Task: Security, firefighting communications, personnel accountability NUREG-0654, Revision 1, Table 8-1 requires this functional area be addressed by Security personnel in accordance with the site Security Plan. No changes are being made to this functional area.

Attachment I to WO 18-0016 Page 14 of 27 ERO Staffing.Reductions In addition to the changes discussed in the previous section, WCNOC is proposing to reduce the number of these additional ERO positions through elimination and/or consolidation of job functions. The following changes are proposed:

Reduce Operations Recorders from 2 to 1 Eliminate the Dose Assessment Technician Reduce EOF Team Communicators from 2 to 1 Reduce Survey Team Technicians from 4 to 3 Reduce EOF Administrative Assistants from 4 to 3 Eliminate the EOF Facility Technician Reduce Engineering Team from 5 to 3 Reduce TSC Team Communicators from 2 to 1 Reduce TSC Operations Recorders from 2 to 1 Reduce TSC Administrative Assistants from 4 to 2 Reduce Maintenance Planners from 3 to 1 Eliminate Warehouse Support Eliminate the On-Site Public Information Coordinator (TSC)

Eliminate Media Liaison

• Reduce Technical Support from 2 to 1 Reduce Media Center Registrars from 2 to 1 Reduce Phone Team Members from 4 to 3 Reduce Media Monitoring Team from 4 to 3 Prior to an emergency declaration, the normal plant operating organization is in place. The initial classification of an off-normal event occurs in the Control Room and classification and declaration is performed by the Shift Manager. Upon the classification and declaration of an emergency, the Shift Manager assumes the role of Emergency Manager and retains that role until a designated Emergency Manager can assume control. The on-site emergency organization is activated by personnel notification or when the station alarm is sounded and the emergency is announced over the public address system. Initially, the ERO consists of the normal operating shift personnel who function as the emergency team members. The normal operating staff is augmented, as needed, by plant personnel. Those personnel on-site respond when the station alarm is sounded and the announcement is made or when individuals are notified by another means. Personnel not on-site during off-hours operations will be notified via an automated ERO notification system. The dedicated on-shift Communicator performs notifications. The details of notifying all emergency operations personnel during normal and off-hours are contained in Emergency Plan Procedures (EPPs).

Attachment I to WO 18-0016 Page 15 of 27 WCNOC maintains ERO teams, with one complete team being on duty at any given time.

When the Shift Manager directs activation of the ERO call out system, all ERO members are notified to ensure adequate coverage of all ERO positions at all emergency response facilities (ERFs). ERO members not on call are expected to respond unless they are unavailable or unfit for duty.

WCNOC requires ERO personnel to act promptly in reporting to their assigned ERF even when not on duty. During duty periods, procedures further require that team members respond within the required response time for their ERF (unless a longer time frame is specified for their specific ERO position) and that they remain fit for duty throughout the duty assignment.

Individuals are trained to respond to their ERF even if they are not on duty. Excess personnel that respond may be assigned support responsibilities or be designated as a relief shift. This conservative policy ensures timely activation because some off-duty personnel may respond sooner than the on-duty personnel.

The proposed revisions to the WCNOC RERP will not change the requirements described above. Management's continued expectation is that all duty and support ERO members report to their respective ERF as quickly as possible.

WCNOC has designated ERO members who staff positions required to meet minimum staffing to activate the TSC/OSC, EOF, and JIC. EPPs identify ERO positions assigned to each facility and the minimum staffing required before each facility can be declared operational. All ERO personnel are expected to respond when notified by the ERO notification system.

In addition to the reductions described in the previous Functional Area discussion, the following section provides a discussion of the proposed additional ERO staffing changes in the EOF, TSC, and JIC.

EOF personnel changes:

The proposed ERO staffing changes eliminate 1 ERO position in the EOF described in WCNOC EPPs as a position required for facility activation, the EOF Facility Technician. The role of the facility technician, according to EPP 06-003, Emergency Operations Facility Operation, is to establish and monitor facility habitability. This position was created when the WCNOC EOF was located at the Dwight D. Eisenhower Training Center, within the plume exposure pathway of the plant. At that location it was important for facility habitability to be determined prior to facility activation due to the near-site location of the EOF.

In 2014, WCNOC built a new EOF approximately 12 miles from the plant site, and outside the plume exposure pathway. The new EOF is a dedicated facility which also houses the alternative TSC/OSC. Facility habitability is not the immediate concern that it was for the old near-site EOF location; therefore, the EOF facility technician is no longer necessary for facility activation. Augmenting RP personnel can perform any tasks the facility technician was assigned as the event progresses and additional personnel become available.

Other changes in the EOF staff include reductions in the number of personnel assigned to a position. With technological changes and procedural streamlining, it is not necessary to have multiple personnel in redundant positions; such as the Operations Recorders, Team Communicators, and Administrative Assistants.

Attachment I to WO 18-0016 Page 16 of 27 The reduction in the Survey Team Technicians from 4 to 3 is possible due to coordination with the State of Kansas. Centralized coordination of the off-site radiological assessment effort with all organizations interested in, and/or performing assessments is necessary to ensure that the data and its interpretation are reviewed by WCNOC and off-site response organizations with monitoring and assessment responsibilities. The number and type of organizations performing this effort vary with time and following emergency declarations and off-site notification. Initially, plant emergency response personnel are the only organization performing this function and they are directed from, and their results evaluated, at the EOF. State authorities join the EOF monitoring and assessment activities, forming joint radiological monitoring teams. Commitment RCMS 1985-407 (Reference 10) requires WCNOC to field 3 teams, plus 1 from the State. This reduction in the survey team technicians from 4 to 3 still maintains the capability to meet that commitment.

The Dose Assessment organization at the EOF consists of the Radiological Coordinator, the Dose Assessment Coordinator, and the Dose Assessment Technician. The dose assessment technician performs dose assessment and reports results to the dose assessment coordinator who then reports to the radiological coordinator. The proposed elimination of the dose assessment technician, by having the dose assessment coordinator perform the dose assessment, facilitates rapid dissemination of information to the radiological coordinator. The dose assessment coordinator position is trained to perform dose assessment, so no new task is being added to this position.

To ensure that the elimination of the EOF Dose Assessment Technician, EOF Facility Technician and one EOF Team Communicator will not hinder the ability of the EOF radiological team to maintain effective coordination with off-site response organization (ORO) officials, a new Assistant Radiological Coordinator position is being created in the EOF. This new position will assist the dose assessment coordinator and team communicator as necessary to ensure the radiological coordinator remains in an oversight and coordination role. This new position will also perform liaison duties with ORO responders in the EOF.

TSC personnel changes:

In the TSC, the proposed change eliminates one position, Warehouse Support. Procedural changes no longer require a dedicated person for warehouse support. The maintenance coordinator and planner ensure that teams have access to the warehouse.

Other changes in the TSC staff include reductions in the number of personnel assigned to a position. With technological changes and procedural streamlining, it is not necessary to have multiple personnel in redundant positions, such as the Operations Recorders, Team Communicators, Engineers, Planners, and Administrative Assistants.

Attachment I to WO 18-0016 Page 17 of 27 JIC personnel changes:

In the JIC the proposed change eliminates 2 positions, the On-Site Public Information Coordinator (in the TSC) and the Media Liaison. The on-site public information coordinator reports to the TSC to provide information to the JIC. The off-site public information coordinator reports to the EOF to provide information to the JIC. Procedural and process changes allow the off-site public information coordinator to perform the function.

The Media Liaison ensures the media is familiar with the media center layout and that they are provided with the information they require. The media center manager is also tasked with ensuring the media are provided for at the media center. The media liaison position can be eliminated because the media center manager provides this function.

Other changes in the JIC staff include reductions in the number of personnel assigned to a position. With technological changes and procedural streamlining, it is not necessary to have multiple personnel in redundant positions, such as the Technical Support, Media Registrar, Phone Team, and Media Monitoring Team.

Task Analysis of EOF, TSC, and JIC personnel changes:

The ERO Task Analysis provided in Attachment Ill identifies each current ERO position and the associated duties. The duties of the ERO positions that are being eliminated or reduced were reviewed against WCNOC procedures AP 06-002, Radiological Emergency Response Plan, EPP 06-003, Emergency Operations Facility (EOF) Operation, EPP 06-002, Technical Support Center (TSC) Operations, EPP 06-001, Control Room Operations, and EPP 06-004, Public Information Organization. Each of the eliminated or reduced positions was analyzed to identify the key duties associated with the position and the duties were then evaluated against the planning standards in NUREG-0654.

During the development of the proposed changes to the ERO staffing, documented in 11, WCNOC initiated a multi-disciplined team review of every aspect of the ERO staffing changes. This team included participants from Operations, Training, Engineering, Chemistry, Radiation Protection, Emergency Planning, Regulatory Assurance, and plant management. Membership covered all levels of ERO qualifications, incorporating shift technicians, licensed operators, engineers, and emergency managers. Each proposed change in task alignment was reviewed by this group.

The Table provided in Attachment Ill contains columns with headings "Implementing Actions" and "Task Assigned To?". These columns provide the details regarding the disposition of each task. Some of the duties are identified as being eliminated because they are performed redundantly by other positions in the ERO and will continue to be performed by these positions.

Procedures and training materials depicting the changes presented in Attachment Ill will be developed to align with the revised task assignments. These procedures will be used to support training of ERO staff and for the conduct of drills that will be used to validate the staffing and assignment of tasks.

Attachment I to WO 18-0016 Page 18 of 27 Impact of personnel changes on ORO Radiological Emergency Preparedness Plans:

The proposed changes to the WCNOC RERP, including the changes made to the ERO, have been evaluated for impacts on the ERO and for the ability of OROs to implement their U.S.

Federal Emergency Management Agency (FEMA)-approved Radiological Emergency Preparedness (REP) Plans. Potential impacts on the ability of State and County response organizations to effectively implement their FEMA-approved REPs do not exist because no tasks that require interfacing with State and County response organizations are proposed for elimination. The WCNOC ERO includes technical support staff that have dedicated responsibilities for interfacing with State and County representatives. During an emergency, these personnel are dispatched to the State and County EOCs to act as communication liaisons between the EOCs and plant technical staff and to provide clarification of emergency response information. These positions remain part of the WCNOC ERO. Attachment V provides a letter of concurrence from the State of Kansas and Coffey County.

Proposed Change to a Single Standardized TSC Activation Time The change in TSC activation time during normal work hours from 30 minutes to 75 minutes removes an administrative burden on the WCNOC ERO which unnecessarily restricts assigned TSC duty team personnel from participating in scheduled offsite meetings, training sessions, or other activities which could place them outside the 30 minute response area.

WCNOC is located in a rural location, with most facilities suitable for large group meetings located greater than the practical 30 minute response area. Additionally, the continued growth of Protected Area security controls post-9/11 continues to effectively reduce the size of this 30 minute response area. This means that the new EOF located approximately 12 miles from the plant site, or any facilities in the local municipalities, are outside the practical response area for anyone on the assigned TSC duty team. Since the alternative TSC/OSC is housed in the new EOF, TSC personnel on the assigned duty team are unnecessarily restricted from participating as either players or controller/evaluators in drills involving this alternative facility.

In addition, TSC personnel on the assigned duty team are also restricted from adapting their

• onsite work hours in response to the needs of the plant. Personnel on the assigned TSC duty team normally hold key positions in the WCNOC organizational structure, and cannot always work a normal Monday through Thursday schedule. Their normal non-ERO duties often involve participation in, or observation of, critical plant evolutions or activities that frequently occur outside normal work hours. If these personnel need to shift their schedule to participate in off-hour activities such as repair of critical equipment or management observations of back-shift evolutions, they must either arrange coverage for their ERO duty during normal work hours, or they must also be onsite during that period.

Standardization of the TSC activation time to a single "within 75 minutes of declaration of an Alert or higher classification" would remove this administrative burden and would allow TSC personnel on the assigned duty team to maintain a single standard for availability no matter if it were during or after normal work hours. The potential impact of this change on TSC activation times during normal work hours is mitigated by the WCNOC policy that all ERO are trained to respond even if they are not on duty. This conservative policy expedites facility activation because some off-duty personnel may already be onsite and would therefore respond sooner than the assigned duty team personnel during normal work hours.

Attachment I to WO 18-0016 Page 19 of 27 Proposed Dose Assessment Software Change The current RERP Section 6.3.7.3 reference to the dose assessment software model estimating release rates and off-site exposures for an unmonitored, pressure-driven containment release using the containment High Area Radiation Monitor readings and changes in containment pressure is being removed. This software capability erroneously attributes all changes in containment pressure solely to leakage, and fails to account for the more likely and significant sources of pressure decrease (such as steam cloud condensation and/or temperature reduction due to actuation of coolers or the initiation of containment spray). Historically, use of this capability of the software has produced large overestimations of offsite doses during exercise scenarios containing an unmonitored release, leading to unwarranted recommendations of protective actions td the public. This capability is particularly prone to overestimation of the release rate early in an accident scenario, when the temperature differential between the source term inside containment and the surrounding structures is still considerable. Only after condensation, fan coolers, and containment spray have reduced the source term available for release are the unaccounted-for variables minimized to the point that this software capability would produce accurate release rate estimates. However, by that time the site will have off-site survey teams dispatched and the more accurate and preferable method of estimating release rates and off-site exposures from off-site field team data would be used instead. The capability to calculate release rates and off-site exposures from off-site field team data remains in use by the dose assessment software; therefore, removal of the error likely method using the containment High Area Radiation Monitor readings and changes in containment pressure does not decrease dose assessment capabilities.

Attachment I to WO 18-0016 Page 20 of 27 CONCLUSIONS WCNOC completed an evaluation of the proposed reduction in ERO staffing and an analysis of proposed on-shift staffing to validate the ability of the proposed on-shift and ERO organization to respond to an emergency. The proposed changes continue to support the major functional areas of the emergency plan, continue to ensure the protection of the health and safety of the public and site personnel, and will not present a significant burden to the on-shift personnel.

Increases from the WCNOC RERP Revision 13 on-shift staffing in Operations ensure performance of major tasks can be completed without conflicts.

The proposed reduction in TSC/OSC augmentation staffing does not result in a reduction of the capability of the ERO to effectively respond to the emergency. The proposed reduction in TSC/OSC augmentation staffing continues to ensure the WCNOC RERP will continue to meet 10 CFR 50.54(q)(2), the requirements of 10 CFR 50 Appendix E, and the planning standards of 10 CFR 50.47(b).

The deletion of references to a licensed practitioner with retention of references to existing licensee first aid responders is consistent with the planning standards and evaluation criterion of NUREG-0654/FEMA-REP-1, Revision 1, Section 11.0.3. The RERP, as changed, would continue to meet the standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50.

ERO personnel are trained with the expectation that, even when they are not on duty, they are to respond to an emergency callout when they are fit for duty and otherwise available for timely response. This requirement can and does (as demonstrated during periodic testing) lead to multiple personnel filling augmented response positions with the potential for some responders to be able to respond more quickly than the individual who is on duty at the time. This "all call" response expectation ensures not only a timely response for augmentation, but provides for more than a minimum quantity of responders. The proposed ERO staffing changes do not impact the capabilities of the on-shift staffing or augmented response. The functional responsibilities of the positions eliminated as a result of the changes described within are being reassigned to remaining positions. Attachment Ill provides the task analysis of all ERO positions being eliminated or reduced and evaluates the transfer of tasks to remaining ERO positions. The proposed ERO staffing reductions continue to address the risks to public health and safety and comply with the WCNOC RERP, site commitments, and applicable regulations.

Reference to performing dose assessment using containment pressure reduction is being removed because the reduction of pressure in containment can be for many reasons, such as temperature changes associated with actuation of coolers or containment spray. Historically, use of this capability of the software has produced large overestimations of offsite doses during exercise scenarios containing an unmonitored release, leading to unwarranted recommendations of protective actions to the public. This capability is particularly prone to overestimation of the release rate early in an accident scenario, when the temperature differential between the source term inside containment and the surrounding structures is still considerable. Only after condensation, fan coolers, and containment spray have reduced the source term available for release are the unaccounted-for variables minimized to the point that this software capability would produce accurate release rate estimates. However, by that time the site will have off-site survey teams dispatched and the more accurate and preferable method of estimating release rates and off-site exposures from off-site field team data would be used instead. The capability to calculate release rates and off-site exposures from off-site field team data remains in use by the dose assessment software; therefore, removal of the error likely method using the containment High Area Radiation Monitor readings and changes in containment pressure does not decrease dose assessment capabilities.

Attachment I to WO 18-0016 Page 21 of 27 4.0. REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria The regulatory requirements and guidance applicable to the proposed change are as follows:

10 CFR 50.47(b) states:

(b) The on-site and, except as provided in paragraph (d) of this section, off-site emergency response plans for nuclear power reactors must meet the following standards:

(1) Primary responsibilities for emergency response by the nuclear facility licensee and by State and local organizations within the Emergency Planning Zones have been assigned, the emergency responsibilities of the various supporting organizations have been specifically established, and each principal response organization has staff to respond and to augment its initial response on a continuous basis.*

(2) On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available and the interfaces among various on-site response activities and off-site support and response activities are specified.

10 CFR 50.54(g)(1 )(iii) states:

Emergency planning function means a capability or resource necessary to prepare for and respond to a radiological emergency, as set forth in the elements of section IV, of appendix E to this part [Part 50] and, for nuclear power reactor licensees, the planning standards of §50.47(b).

10 CFR 50.54(g)(1 )(iv) states:

Reduction in effectiveness means a change in an emergency plan that results in reducing the licensee's capability to perform an emergency planning function in the event of a radiological emergency.

10 CFR 50.54(g)(2) states in part:

A holder of a license under this part, ... shall follow and maintain the effectiveness of an emergency plan that meets the requirements in appendix E to this part and, for nuclear power reactor licensees, the planning standards of§ 50.47(b).

10 CFR 50.54(g)(3) states:

The licensee may make changes to its emergency plan without NRG approval only if the licensee performs and retains an analysis demonstrating that the changes do not reduce the effectiveness of the plan and the plan, as changed, continues to meet the requirements in appendix E to this part and, for nuclear power reactor licensees, the

• planning standards of§ 50.47(b).

Attachment I to WO 18-0016 Page 22 of 27 10 CFR 50.54(g)(4) states:

The changes to a licensee's emergency plan that reduce the effectiveness of the plan as defined in paragraph (q)(1)(iv) of this section may not be implemented without prior approval by the NRC. A licensee desiring to make such a change after February 21, 2012 shall submit an application for an amendment to its license. In addition to the filing requirements of§§ 50.90 and 50.91, the request must include all emergency plan pages affected by that change and must be accompanied by a forwarding Jetter identifying the change, the reason for the change, and the basis for concluding that the licensee's emergency plan, as revised, will continue to meet the requirements in appendix E to this part and, for nuclear power reactor licensees, the planning standards of§ 50.47(b).

10 CFR 50, Appendix E, Section IV, Part A states in part:

The organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensee's emergency organization and the means for notification of such individuals in the event of an emergency. Specifically, the following shall be included:

... a detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan.

WCNOC, as required under 10 CFR 50.54(q)(4), is hereby submitting proposed revisions to the WCNOC RERP for NRC approval prior to implementation. The proposed changes continue to meet the provisions of 10 CFR 50.47(b) as the WCNOC RERP will continue to have on-site and off-site emergency responsibilities and provide adequate staffing to provide facility accident responses. Further, the current WC NOC RERP meets the planning standards* of 10 CFR 50.47(b) and 10 CFR 50, Appendix E as required by 10 CFR 50.54(q)(2). The proposed changes reduce on-shift and augmented staffing as described previously. Therefore, the proposed change is considered a reduction in effectiveness as defined in 10 CFR 50.54(q)(1)(iv) and requires submittal of a license amendment request to the NRC based on 10 CFR 50.54(q)(4) in accordance with 10 CFR 50.90.

With the proposed changes the WCNOC RERP will continue to meet the requirements of 10 CFR 50.54(q)(2) by maintaining the effectiveness of the Emergency Plan such that it meets the requirements of 10 CFR 50 Appendix E, and the planning standards of 10 CFR 50.47(b).

Finally, the current WCNOC RERP includes a description of the organization, including definition of authorities, responsibilities and duties of individuals. The current WCNOC RERP is in compliance with 10 CFR 50 Appendix E.IV.A. The LAR proposes to reduce on-shift and augmented staff. Augmentation times remain the same. The proposed changes to the WCNOC RERP will continue to describe the authorities, responsibilities and duties of these individuals.

Therefore, with the changes proposed in the LAR, the requirements of 10 CFR 50 Appendix E continue to be met.

Attachment I to WO 18-0016

Page, 23 of 27 Regulatory Guide (RG) 1.101, Revision 2, "Emergency Planning and Preparedness for Nuclear Power Reactors" (Reference 6), provides guidance on methods acceptable to the NRC staff for implementing specific parts of NRC regulations (i.e. 10 CFR 50.47(b) and Appendix E to 10 CFR Part 50). RG 1.101 endorses NUREG- 0654/FEMA-REP-1 (NUREG-0654), Revision 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants" (Reference 1), which provides specific acceptance criteria for complying with the standards set forth in 10 CFR 50.47(b). These criteria provide a basis for NRC licensees, and state and local governments to develop acceptable radiological emergency plans and improve emergency preparedness.

Regulatory Guide 1.219, Revision 1, "Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors" (Reference 4), provides guidance on methods acceptable to the NRC staff for implementation of 10 CFR 50.54(q) as it relates to making changes to emergency response plans.

In NUREG-0654,Section II, "Planning Standards and Evaluation Criteria," Evaluation Criteria 11.8.1 and 11.8.5 address the 10 CFR 50.47(b)(2) planning standard. Evaluation Criteria 11.8.1 specifies the on-site emergency organization of plant staff personnel for all shifts, and its relation to the responsibilities and duties of the normal shift complement. Evaluation Criteria 11.8.5, states, in part:

Each licensee shall specify the positions or title and major tasks to be performed by the persons to be assigned to the functional areas of emergency activity. For emergency situations, specific assignments shall be made for all shifts and for plant staff members, both on~site and away from the site. These assignments shall cover the emergency functions in Table B-1 entitled, "Minimum Staffing Requirements for Nuclear Power Plant Emergencies." The minimum on-shift staffing levels shall be as indicated in Table B-1. The licensee must be able to augment on-shift capabilities within a short period after

• declaration of an emergency. This capability shall be as indicated in Table B-1.

NUREG-0654 states general guidance concerning the off-site emergency organization to allow licensees some flexibility in the number of on-shift staff required by emergency plans for response to emergency events. NUREG-0654 guidance recommends that there be, in addition to on-shift personnel, 30-minute and 60-minute responders. The augmented ERO responders assume many managerial, engineering, and administrative duties from the on-shift personnel, allowing them to focus more fully on plant operations. NUREG-0654 also provides the guidance that augmentation time be measured from the declaration of the emergency.

The current WCNOC RERP staffing in Attachment D meets the intent of NUREG-0654, Table 8-

1. This LAR proposes to reduce on-shift and augmented staff as previously described. The proposed changes to the E-Plan continue to meet the intent of NUREG-0654, Table 8-1 (i.e.,

continues to cover the emergency functional areas in Table 8-1 ). Therefore, the proposed changes continue to meet NUREG-0654, Section 11.8.5 guidance.

Attachment I to WO 18-0016 Page 24 of 27 In NUREG-0654,Section II, "Planning Standards and Evaluation Criteria," Evaluation Criteria items 11.0.3 and 11.0.4 address the 10 CFR 50.47(b)(15) planning standard. 11.0.3 specifies the type of training to be provided to licensee first aid team members who may be called on to assist in an emergency: "Training for individuals assigned to licensee first aid teams shall include courses equivalent to Red Cross Multi-Media." Item 11.0.4 specifies categories of training to be provided in a training program for instructing and qualifying personnel who will implement radiological emergency response plans. Item 11.0.4.f specifies "First aid and rescue personnel" as one of these categories.

Additionally, the following 10 CFR 50.47(b) standards and their associated NUREG-0654/FEMA-REP-1 evaluation criteria were evaluated with respect to the Licensed Practitioner proposed change:

10 CFR 50.47(b)(12) states:

Arrangements are made for medical services for contaminated, injured individuals.

NUREG-0654 item 11.L.2 specifies provisions for on-site first aid capability.

10 CFR 50.47(b)(14) states, in part:

Periodic drills are (will be) conducted to develop and maintain key skills, and deficiencies are identified as a result of exercises or drills are (will be) corrected."

NUREG-0654 item 11.N.2.c specifies conduct of annual medical emergency drills and items 11.N.3, 11.N.4 and 11.N.5 specify scenario composition, critique and correction.

The practice of having a Licensed Practitioner on-site during business hours is over and above regulatory requirements and guidance. WCNOC maintains qualified first aid responders on-shift 24/7 in accordance with regulations and guidance; therefore elimination of the Licensed Practitioner from the RERP does not impact compliance with regulations.

10 CFR 50.47(b)(9) states:

Adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use.

The current RERP Section 6.3. 7.3 reference to the dose assessment software model estimating release rates and off-site exposures for an unmonitored, pressure-driven containment release using the containment High Area Radiation Monitor readings and changes in containment pressure is being removed. This software capability erroneously attributes all changes in containment pressure solely to leakage, and fails to account for the more likely and significant sources of pressure decrease (such as steam cloud condensation and/or temperature reduction due to actuation of coolers or the initiation of containment spray). Historically, use of this capability of the software has produced large overestimations of offsite doses during exercise scenarios containing an unmonitored release, leading to unwarranted recommendations of protective actions to the public. This capability is particularly prone to overestimation of the release rate early in an accident scenario, when the temperature differential between the source term inside containment and the surrounding structures is still considerable. Only after condensation, fan coolers, and containment spray have reduced the source term available for release are the unaccounted-for variables minimized to the point that this software capability would produce accurate release rate estimates. However, by that time the site will have off-site survey teams dispatched and the more accurate and preferable method of estimating release rates and off-site exposures from off-site field team data would be used instead. The capability

Attachment I to WO 18-0016 Page 25 of 27 to calculate release rates and off-site exposures from off-site field team data remains in use by the dose assessment software; therefore, removal of the error likely method using the containment High Area Radiation Monitor readings and changes in containment pressure does not decrease dose assessment capabilities.

Conclusion WCNOC has evaluated the proposed changes against the applicable regulatory requirements, regulatory guidance and acceptance criteria. The proposed changes continue to assure that regulatory requirements, guidance and emergency planning standards associated with emergency response are met and that personnel and public health and safety are not impacted.

4.2 No Significant Hazards Consideration Determination Pursuant to 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," WCNOC hereby requests an amendment to the Renewed Facility Operating License No. NPF-42 for WCGS. This amendment request proposes a change to the Emergency Response Organization as specified in the WCNOC Radiological Emergency Response Plan.

WCNOC has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed change to the WCNOC Emergency Plan is administrative in nature. This proposed change does not alter accident analysis assumptions, add any initiators, or affect the function of plant systems or the manner in which systems are operated, maintained, modified, tested, or inspected. The proposed change does not require any plant modifications which affect the performance capability of the structures, systems, and components (SSCs) relied upon to mitigate the consequences of postulated accidents, and has no impact on the probability or consequences of an accident previously evaluated.

Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed change to the WCNOC Emergency Plan is administrative in nature. This proposed change does not alter accident analysis assumptions, add any initiators, or affect the function of plant systems or the manner in which systems are operated, maintained, modified, tested, or inspected. The proposed change does not require any plant modifications which affect the performance capability of the SSCs relied upon to mitigate the consequences of postulated accidents, and does not create the possibility of a new or different kind of accident from any accident previously evaluated.

Attachment I to WO 18-0016 Page 26 of 27 Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No Plant safety margins are established through limiting conditions for operation, limiting safety systems settings, and safety limits specified in the technical specifications. The proposed change to the WCNOC Emergency Plan is administrative in nature. Since the proposed change is administrative in nature, there are no changes to these established safety margins.

Therefore the proposed change does not involve a significant reduction in a margin of safety.

Based on the above evaluations, WCNOC concludes that the proposed amendment presents no significant hazards under the standards set forth in 10 CFR 50.92(c) and, accordingly, a finding of "no significant hazards consideration" is justified.

4.3 Conclusions In conclusion, based on the considerations discussed above: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner; (2) such activities will be conducted in compliance with the Commission's regulations; and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

WCNOC has evaluated the proposed change and has determined that the change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluent that may be released off-site, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

L_

Attachment I to WO 18-0016 Page 27 of 27

6.0 REFERENCES

1. NUREG- 0654/FEMA-REP-1 (NUREG-0654), Revision 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants" (ADAMS Accession No. ML040420012).

2. Federal Register, "Enhancements to Emergency Preparedness Regulations", Vol.76, No. 226, pp. 72560-72600, November 23, 2011 (FR DOC# 03-29735).

3. NSIR/DPR-ISG-01, "Interim Staff Guidance - Emergency Planning for Nuclear Power Plants" (ADAMS Accession No. ML113010523).

4. Regulatory Guide 1.219, Revision 1, "Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors" (ADAMS Accession No. ML16061A104).

5. NEI 10-05, "Assessment of On-Shift Emergency Response Organization.Staffing and Capabilities".

6. Regulatory Guide (RG) 1.101, Revision 2, "Emergency Planning and Preparedness for Nuclear Power Reactors" (ADAMS Accession No. ML050730286).

7. Wolf Creek Generating Station Radiological Emergency Response Plan, Kansas Gas & Electric Company, Revision 15, dated January 1985.

8. Wolf Creek Nuclear Operating Corporation On-Shift Staffing Analysis, December 2012.

9. Wolf Creek Nuclear Operating Corporation On-Shift Staffing Analysis, August 2017.

10. Commitment RCMS 1985-407, Letter NRCLK 86-021, January 1986.

11. USN RC RIS 2016-10, License Amendment Requests for Changes to Emergency Response Organization Staffing and Augmentation, August 2016 (ADAMS Accession No. ML16124A002).

12. Procedure AP 06-002, Radiological Emergency Response Plan (RERP), Rev. 18A.

Attachment II to WO 18-0016 Page 1 of 11 Emergency Plan Change Summary

Attachment II to WO 18-0016 Page 2 of 11 Emergency Plan Change Summary Emergency Plan Before (Rev. 18A) After (Pending Revision Number) Reason for Change Section Cover page/Header Revision 18A Revision TBD Reflect the LAR changes.

6.3.7.3 Be capable of estimating release rates and deleted This software capability erroneously off-site exposures for an unmonitored, attributes all changes in containment pressure driven containment release using the pressure solely to leakage, and fails to containment High Area Radiation Monitor account for the more likely and readings and changes in containment significant sources of pressure pressure. decrease. The capability to calculate release rates and off-site exposures from off-site field team data remains in use by the dose assessment software; therefore, removal of the error likely method using the containment High Area Radiation Monitor readings and changes in containment pressure does not decrease dose assessment capabilities.

6.3.16 Under emergency conditions, normal Under emergency conditions, normal Change title from Health Physics to exposure controls are maintained. This is exposure controls are maintained. This is Radiation Protection to align with station ensured by the on-shift Health Physics ensured by the on-shift Radiation Protection references to this work group.

Technician (RP) in the Control Room, the Technician (RP) in the Control Room, the Radiological Coordinators in the TSC and Radiological Coordinators in the TSC and EOF. EOF.

6.4.3.2 The OSC serves as an assembly area for The OSC serves as an assembly area for Change title from Health Physics to plant personnel immediately serving in plant personnel immediately serving in Radiation Protection to align with station emergency repair or Health Physics support emergency repair or Radiation Protection references to this work group.

capacity during an event. The OSC functions support capacity during an event. The OSC include the coordination, formation and functions include the coordination, formation dispatch of Emergency Response Teams. and dispatch of Emergency Response Teams.

Attachment II to WO 18-0016 Page 3 of 11 Emergency Plan Before (Rev. 18A) After (Pending Revision Number) Reason for C_hange Section 6.4.5.5 The Wolf Creek PIO, the State PIO and The Wolf Creek PIO, the State PIO and Reflect elimination of the On-site PIC Coffey County PIO communicate with the Coffey County PIO communicate with the position. The Off-Site PIC will perform Public Information Coordinators (PIC) to Public Information Coordinator (PIC) to obtain this function.

obtain technical information. The PIOs technical information. The PIOs prepare prepare news statements at the JIC and news statements at the JIC and coordinate coordinate their efforts. their efforts.

6.4.6.1 A medical facility located in the Clyde Cessna A medical facility located in the Clyde Cessna Reflect removal of reference to the building, is staffed with a fulltime Licensed building is equipped to provide basic medical Licensed Practitioner. Having a Practitioner. This facility is equipped to response capabilities. Licensed Practitioner available during provide basic medical response capabilities. business hours is above and beyond regulatory requirements. On-shift first aid responders remain available 24/7.

6.5.3 Off-site Communicator Emergency Notification System (ENS)/Off-site Reflect combination of the ENS and Off-Communicator site Communicator on-shift position.

6.5.3.1 The Off-site Communicator reports to the Shift The Emergency Notification System Reflect combination of the ENS and Off-Manager, performs initial notifications, and (ENS)/Off-site Communicator reports to the site Communicator on-shift position.

initiates the Automatic Dialing System (ADS) Shift Manager, performs initial notifications, or Backup ADS to callout the ERO. initiates the Automatic Dialing System (ADS) or Backup ADS to callout the ERO and maintains communications with the NRC.

6.5.4 Emergency Notification System (ENS) deleted Reflect combination of the ENS and Off-Communicator site Communicator on-shift position.

6.5.4.1 The ENS Communicator reports to the Shift deleted Reflect combination of the ENS and Off-Manager and maintains communications with site Communicator on-shift position.

the NRC.

6.5.6 Health Physics Technician Radiation Protection Technician Change title from Health Physics to Radiation Protection to align with station references to this work group.

6.5.10 Shift Technical Advisor Shift Technical Advisor (STA) Editorial - grammatical correction

Attachment II to WO 18-0016 Page 4 of 11 Emergency Plan Before (Rev. 18A) After (Pending Revision Number) Reason for Change Section 6.6.1 TSC activation will be performed as soon as TSC activation will be performed as soon as Standardize activation time for the practical and within the times as stated in the practical and within 75 minutes of a TSC/OSC.

following: declaration of an Alert or higher classification.

6.6.1.1 During off-normal working hours, it is the goal deleted Standardize activation time for the to activate the TSC within 75 minutes of a TSC/OSC.

declaration of an Alert or higher classification.

6.6.1.2 During normal working hours, it is the goal to deleted Standardize activation time for the activate the TSC within 30 minutes of a TSC/OSC.

declaration of an Alert or higher classification 6.6.10.1, 1st bullet Monitoring Dose rates and dose projections. Monitoring dose rates and dose projections. Editorial - grammatical correction 6.6.10.1, 2nd bullet Monitoring Radiological survey teams' results. Monitoring radiological survey teams' results. Editorial - grammatical correction 6.6.10.1, 4th bullet Monitoring Personnel radiation exposures to Monitoring personnel radiation exposures to Editorial - grammatical correction ensure they are maintained in accordance ensure they are maintained in accordance with 10CFR 20 limits unless otherwise with 10CFR 20 limits unless otherwise authorized by the Emergency Manager. authorized by the Emergency Manager.

6.6.14.1 Provides data, progress and plant conditions Provides data, progress and plant conditions Reflect reduction of redundant from the Control Room via the Operations from the Control Room via the Operations Operations Recorders.

Recorders. Recorder.

6.6.15.1, 4th bullet Administrative Assistants perform facility Administrative Assistants perform facility Remove off-site notification from the accountability, assist the Emergency accountability, assist the Emergency TSC. With a dedicated Communicator Manager, faxing and copying, log keeping, Manager, faxing and copying, log keeping, on-shift notifications can transfer and Off-site notifications and communications and communications as directed. directly from the Control Room to the as directed. EOF.

Attachment II to WO 18-0016 Page 5 of 11 Emergency Plan Before (Rev. 18A) After (Pending Revision Number) Reason for Change Section 6.7.2.1 The ERT personnel may be selected from The ERT personnel may be selected from Change title from Health Physics to Health Physics Technicians (Tech), Chemistry Radiation Protection Technicians (Tech), Radiation Protection to align with station Tech, and Instrumentation and Control, Chemistry Tech, and Instrumentation and references to this work group.

Mechanical, or Electrical Maintenance. The Control, Mechanical, or Electrical ERT reports to the Maintenance Assistant and Maintenance. The ERT reports to the is responsible for repairs, surveys, sampling, Maintenance Assistant and is responsible for analysis, and search and rescue. repairs, surveys, sampling, analysis, and search and rescue.

6. 7.3.1, 2nd bullet Maintenance Planners develop repair plans Maintenance Planner develops repair plans Reassign warehouse support task to for use by the emergency repair and damage for use by the emergency repair and damage the Maintenance Planner and reflect control teams. control teams and assists in locating and reduction from multiple planners to one securing parts and equipment from the planner.

warehouse.

6. 7 .3.1, 3rd bullet Warehouse Support Personnel assist in deleted Reflect elimination of Warehouse locating and securing parts and equipment Support position. Maintenance Planner from the warehouse. assumes the task.

6.8.1.1, last bullet EOF Facility Technician deleted Reflect elimination of EOF Facility Technician position. The EOF is outside the 10-mile EPZ eliminating the requirements for the Facility Technician.

6.8.2.2.f Coordinates with the On-site and Off-site Coordinates with the Off-site Public Reflect elimination of the On-site PIC Public Information Coordinators (PICs) in Information Coordinator (PIC) in providing position. The Off-Site PIC will perform providing technical input for news statements. technical input for news statements. this function.

6.8.3.1, 4th bullet Requests through the EOF Administrative Requests through the EOF Administrative Change title from Health Physics to Coordinator additional radiation monitoring Coordinator additional radiation monitoring Radiation Protection to align with station equipment, instrumentation and Health equipment, instrumentation and Radiation references to this work group.

Physics support personnel as necessary. Protection support personnel as necessary.

6.8.5 EOF Facility Technician deleted Reflect elimination of EOF Facility Technician position. The EOF is outside the 10-mile EPZ eliminating the requirements for the Facility Technician.

Attachment II to WO 18-0016 Page 6 of 11 Emergency Plan Before (Rev. 18A) After (Pending Revision Number) Reason for Change Section 6.8.5.1 Reports to the EOF within a goal of 60 deleted Reflect elimination of EOF Facility minutes of declaration of an Alert or higher Technician position. The EOF is outside classification to ensure the EOF is prepared the 10-mile EPZ eliminating the and functional. requirements for the Facility Technician.

6.8.6.1 Reports to the EOF Radiological Coordinator Reports to the EOF Radiological Coordinator Reflect transfer of responsibilities from and is responsible for directing/assisting with and is responsible for providing completed off- the Dose Assessment Technician dose projection and protective action site dose projections and protective action position.

recommendation activities. recommendations.

6.8.7 Dose Assessment Technician deleted Reflect elimination of the Dose Assessment Technician. The Dose Assessment Coordinator is trained to perform dose assessment.

6.8.7.1 Reports to and is responsible for providing deleted Reflect elimination of the Dose completed off-site dose projections to the Assessment Technician. The Dose Dose Assessment Coordinator Assessment Coordinator is trained to perform dose assessment.

51 6.8.12, 1 bullet Team Communicators communicate with Team Communicator communicates with Reflect reduction in Team Off-site Monitoring Teams. Off-site Monitoring Teams. Communicators from 2 to 1. Eliminate redundant position.

6.8.12, 2nd bullet Operations Recorders maintain the Operations Recorder maintains the Reflect reduction in Operations Operations Status Board current. Operations Status Board current. Recorders from 2 to 1. Eliminate redundant position.

6.8.12, last bullet Administrative Assistants perform facility Administrative Assistants assist the Reflect removal of accountability accountability, assist the Emergency Emergency Manager, faxing and copying, log function from Administrative Assistant.

Manager, faxing and copying, log keeping, . keeping, and Off-site notifications and Accountability at the EOF is controlled and Off-site notifications and communications communications as directed. by card key, and staffing boards.

as directed.

Attachment II to WO 18-0016 Page 7 of 11 Emergency Plan Before (Rev. 18A) After (Pending Revision Number) Reason for Change Section 6.9.3.1 The Wolf Creek Public Information Manager is The Wolf Creek Public Information Manager is Reflect elimination of the On-site PIC located in the JIC and reports to the WC PIO. located in the JIC and reports to the WC PIO. position. The Off-Site PIC will perform The WC PIM works closely with the WC PIO, The WC PIM works closely with the WC PIO, this function.

On-site PIC, Off-site PIC, News Writer, and Off-site PIC, News Writer, and Technical Technical Support positions to ensure that Support positions to ensure that information information provided the public is timely and provided the public is timely and accurate.

accurate.

6.9.4 On-Site Public Information Coordinator (PIC) deleted Reflect elimination of the On-site PIC position. The Off-Site PIC will perform this function.

6.9.4.1 The On-site PIC is located in the TSC and deleted Reflect elimination of the On-site PIC reports to the WC PIM. The On-site PIC position. The Off-Site PIC will perform gathers and transmits technical information to this function.

the Joint Information Clearinghouse for use in news statements.

6.9.6 The MC Manager is located at the Media The MC Manager is located at the Media Reflect transfer of tasks from the Media Center and reports to the WC PIM. Center and reports to the WC PIM. Liaison and elimination of the Media Responsibilities include set-up of the Media Responsibilities include set-up of the Media Liaison position.

Center, leadership for the Media Registrar, AV Center, leadership for the Media Registrar, AV Support, and Media Liaison and management Support, and management of the media news of the media news conferences. The Media conferences. Responsibilities include Center Manager maintains contact with the managing the media crowd at the Media Joint Information Clearinghouse to provide Center and assisting the media with news conference schedules. registration and facility orientation, providing general Wolf Creek background information or approved emergency-related information, arranging individual interviews, and announcing and coordinating scheduled news conferences. The Media Center Manager maintains contact with the Joint Information Clearinghouse to provide news conference schedules.

Attachment II to WO 18-0016 Page 8 of 11 Emergency Plan Before (Rev. 18A) After (Pending Revision Number) Reason for Change Section 6.9.7 Media Liaison deleted Reflect elimination of the Media Liaison position. Media Center Manager assumes responsibilities for these tasks.

6.9.7.1 Media Liaison is located in the Media Center deleted Reflect elimination of the Media Liaison and reports to the MC Manager. position. Media Center Manager Responsibilities include managing the media assumes responsibilities for these crowd at the Media Center and assisting the tasks.

media with registration and facility orientation, providing general Wolf Creek background information or approved emergency-related information, arranging individual interviews, and announcing and coordinating scheduled news conferences.

6.9.10.1 The Technical Support staff discusses Technical Support discusses technical details Reflect reduction in Technical Support technical details of the news statement with of the news statement with EOF staff to staff. Elimination of redundant position.

EOF staff to ensure accuracy, updates the ensure accuracy, updates the status log, status log, maintains the media status board maintains the media status board and and provides technical interpretation for the provides technical interpretation for the Wolf Wolf Creek, Coffey County, and State of Creek, Coffey County, and State of Kansas Kansas Public Information Officers. Technical Public Information Officers. Technical Support gathers information from the Support gathers information from the Emergency Facilities to communicate plant, Emergency Facilities to communicate plant, health and safety issues to the public. health and safety issues to the public.

6.19.4 Each scenario variation shall be demonstrated Each scenario variation shall be demonstrated Editorial - grammatical correction at last once during the eight year exercise at least once during the eight year exercise cycle and shall include, but not be limited to, cycle and shall include, but not be limited to, the following. the following.

Attachment C, B.7.d On-site PIC & Off-site Public Information Off-site Public Information Coordinator & Wolf Reflect elimination of On-site PIC Coordinator & Wolf Creek Public Information Creek Public Information Officer. position.

Officer.

Attachment II to WO 18-0016 Page 9 of 11 Emergency Plan Before (Rev. 18A) After (Pending Revision Number) Reason for Change Section Attachment D, Shift Manager (SRO) 1 Shift Manager (SRO) 1 Increase in Nuclear Station Operator Functional Area - personnel to replace RP and Chemistry Plant Operations &

Control Room Supervisor (CRS) 1 Control Room Supervisor (CRS) 1 members on the Fire Brigade.

Assessment of Reactor Operator (RO) 2 Reactor Operator (RO) 2 Operational Aspects

- On-Shift Nuclear Station Operator 5 Nuclear Station Operator 7 Attachment D, On-Shift 2 On-Shift 1 Reflect combination of the on-shift ENS Functional Area - and Off-site Communicator positions.

Notification/Commun 60 Min Augmentation 3 60 Min Augmentation 3 ication Attachment D, Off-Site Emergency Manager and Staff Off-Site Emergency Manager and Staff Reduction in RP and Chemistry Functional Area - personnel on-shift reflects removal from Radiological (90 Min Augmentation) 5 (90 Min Augmentation) 5 Fire Brigade. NSOs have replaced RP Accident Sr. Health Physics Expertise Sr. Radiation Protection Expertise and Chemistry on-shift for Fire Brigade.

Assessment &

60 Min Augmentation 1 60 Min Augmentation 1 Technological advances and procedural Support of improvements allow for staffing Operational Accident RP Personnel - On-Shift 3 RP Personnel - On-Shift 2 changes.

Assessment RP Personnel - 60 Min Augmentation 8 RP Personnel - 60 Min Augmentation 6 Chemistry Personnel - On-shift 2 Chemistry Personnel - On-shift 1 Chemistry Personnel Chemistry Personnel 60 Min Augmentation 1 60 Min Augmentation 1

Attachment II to WO 18-0016 Page 10 of 11 Emergency Plan Before (Rev. 18A) After (Pending Revision Number) Reason for Change Section Attachment D, Shift Technical Advisor 1 Shift Technical Advisor 1 Technological advances and procedural Functional Area - improvements allow for staffing Core/Thermal Hydraulics Eng. Core/Thermal Hydraulics Eng.

Plant System changes.

Engineering, Repair, (60 Min Aug) 1 (60 Min Aug) 1

& Mitigative Actions Electrical Eng. (60 Min Aug) 1 Electrical Eng. (60 Min Aug) 1 Mechanical Eng. (60 Min Aug) 1 Mechanical Eng. ~60 Min Aug) 1 Radwaste Operator 1* Radwaste Operator 1*

Mechanical Maint. (60 Min Aug) 2 Mechanical Maint. (60 Min Aug) 1 Electrical Maint. On-Shift 1* Electrical Maint. On-Shift 1*

Electrical Maint. (60 Min. Aug) 2 Electrical Maint. (60 Min. Aug) 1 l&C Technician (60 Min. Auo) 1 l&C Technician (60 Min. Auo) 1 Attachment D, RP Personnel On-Shift 1* RP Personnel On-Shift 1* Technological advances and procedural Protective Actions improvements allow for staffing RP Personnel (60 Min. Aug) 4 RP Personnel (60 Min. Aug) 2 (In-Plant) changes.

Attachment D, Total 17 16 Reflect combination of the on-shift ENS (On-Shift) and Off-site Communicator positions Attachment D, Total 25 19 Reduction in the following 60 minute (60 Min augmenting ERO staff has been Augmentation) evaluated in the ERO task analysis.

• 4 RP Technicians

• 1 Electrical Maintenance

• 1 Mechanical Maintenance Attachment D, Total 5 5 No change in the number of 90 minute (90 Min augmenting ERO staff.

Augmentation)

Attachment II to WO 18-0016 Page 11 of 11 Emergency Plan Before (Rev. 18A) After (Pending Revision Number) Reason for Change Section Figure 2, Minimum Station Operators (5) Station Operators (7) 2 new Nuclear Station Operator Shift Staffing personnel to replace 1 RP and 1 Chemistry Technician (2) Chemistry Technician (1)

Chemistry members on the Fire RP Technician (3) RP Technician (2) Brigade.

Change title from Health Physics to Radiation Protection to align with station references to this work group.

Figure 3, TSC/OSC Warehouse Support deleted Reflect elimination of TSC Warehouse Organization Support position.

Figure 4, EOF Facility Technician deleted Reflect elimination of EOF Facility Organization Technician and Dose Assessment Dose Assessment Technician Technician positions.

Figure 5, Public On-Site Public Information Coordinator (PIG) deleted Reflect elimination of On-Site PIG and Information Media Liaison positions.

Media Liaison (MC)

Organization

Attachment Ill to WO 18-0016 Page 1 of 13 ERO Position Matrix

Attachment Ill to WO 18-0016 ERO POSITION MATRIX Page 2 of 13 Key Proced u re(s)

Pos ition Min NRC E-Plan (Rev. O) Regulatory Current ERO Positio n Tas ks fT#l Other Procedure Tasks lmDlementirnz Actio ns eliminated? Tas k Asshrn ed to? Sta fnne.? Pl ? sectio n Reau lr emen t EMERGENCY EPP 06-003 OPERATIONS FACILITY Off-Site Emergency Fl. Assumes comm and and control of the emergency and Pl. Coord inat e and di rect off-site em ergency response. N/A No N/A Yes Yes AP 06-002, 5.2 Fl through FlS NUREG 0654 Manager interfaces with off-site agencies. P2. Declare the EOF activated . AP 06*002, 6.8.2 II.A.l.a/ll.A.l .b/ ll .A.1.d/ll.A.4/1 1.8 F2. Support and provide resources or performs t asks as requested P3 . Establish priorities for EOF personnel. AP 06-002, Figure .4/11.B.S/U .B.6/II.B.7.c/ll.C.1.a/11.E by the Site Emergency Manager. P4. Coordinate actions with the Alternate TSC when the on -site 4 .1/ 11 .E.3/ILE.4.a thru F3. Direct all WCGS personn el in the EOF. TSC is inaccessible. EP P 06-002, Att. C n/ll .H.2/II .H.3/ II.F.l.c/11.1.8/11.K.2 F4. Obtain personnel and coordinate efforts of em ergency PS . M aintai n a log. EPP-06-003, 5. 1 response personnel who perform off-site radiological survyes, plus PG. Deactivat e the EOF. EPP 06-003, 7.1.2 any other personnel d eemed usef ul for t he emergency response P7. Forward all logs to the EOF Adm inistrative Coordinator. EPP 06-003, 7.1.3 effort. PB. Conduct turnover. EPP 06-003, 7.2.1 F5. Obtain personnel and coordinate the efforts of o utside P9. Assess pla nt conditions and eval uate t he need to reclassify the EPP 06-003, 7.2.2 contractors and vendors. em ergency. EPP 06-003, 7 .3 F6. Obtain personnel and coordinate the effo rts of additiona l PlO. Ensure the EOF, Security, Cont ro l Room , TSC, ICP and Wolf EPP 06-003, Figure technical resources that may be called in d uring t he emergency for Creek Public Information Organizat ion staffs are provided status 1 further support or shift assignment on-site. changes in a tlmely manner.

F7. Coordinat es with t he Admin istrative Coordin ator in t he Pl l. Conduct initial and periodic briefings for the EOF personnel logistics effort t o supply t he plant with the necessary personnel on t he stat us of t he emergency.

and equipment. PU. Mon it or and determine if facility condit ions warrant facility FB. Brief WCGS Executive Management on matters rela t ed to the evacuation .

emergency. PH . Downgrade or terminate an em ergency.

F9. Coordinate with t he On-Sit e and Off-Site Pu blic Information Coordinators (PICs) in providing technical in put for news st atements.

FlO. Ensure immediate and follow-up notificat ions are made which provide sufficient information on emergency classif ication ,

plant status, off-site dose projections or measurem ents, and issue prot ective actions recommend ations to off-site author ities responsible for off-site emergency measures.

fll . Request federal assist ance through state offlclals per the State Plan .

Fl2. Classify t he emergen cy (non-delegable).

F13. Recommend prot ective actions (non-delega ble).

F14. Authorize off-site notifications (non-delega ble) .

F15. Authorize emergency exposure in excess if 10 CFR 20 (non-delegable).

EOF Operat ions Pl. M aintain a log. N/A No - Reduce to P4 to Operations Coord in ato r No No AP 06*002, Figure Recorders (2) P2. Forward all logs to the EOF Administrative Coordinator. 4 Reduce to 1 P3 . Maintain the Operations St atus current. EPP 06--003, 7 .1.2 P4. M onit or plant stat us for adverse t rends and inform the EOF EPP 06-003, 7.2.2 Operations Coord inator of changes in pla nt status t hat could EPP 06-003, 7.10 affect the em ergency classification. EPP 06-003, Figure PS. Track procedu re progress; list t he procedure being performed 1 by the Cont rol Room.

EOF Rad iological Fl. Responsible for rad iologica l m onitoring and dose assessment Pl. Maintain a log. Pl from EOF Facilit y No N/A Ves Yes AP 06-002, 6.8.3 Fl thru F6 NU REG 0654 Coordinator activities off-site. P2. Forwa rd all logs to the EOF Adm inistrative Coord inat or. Technician AP 06-002, Figure ll.A.l.a/11 .A.l.b/ll.A.1.d/l l.8.5/11 .B F2 . Directs and coordinat es activities of the Dose Assessm ent P3. Ensure t he Facility Technician is available. P6 from EOF Facility 4 .6/II.H.2/11.H.3 Coordinator and staff. P4. Ensure facility habitability has been established. Technician EPP 06-002, Att. C F3 . Assists the Off -Site Emergency Manager in the formulat ion of PS. Provide t he Off-Site Emergency M anager with an evaluat ion of PlO from Dose EPP 06--003, 5.4 recom mended prot ective actio ns. the conditions pot entially req uiring personnel exposure in excess Assessment Coordin at or EP P 06-003, 7.1.2 F4. Provides the PIC wit h an assessment of rad iologica l conditions. of 10CFR20 limits. EPP 06-003, 7. 1.3 F5 . Req uests through the EOF Ad ministrative Coordinator P6. Evaluate conditions and recommend facility evacuation. EPP 06-003, 7.2.2 additional radiation monitoring equipment, inst rumentation and P7 . Evaluate conditions and recommend ingestion of Kl. EPP 06-003, 7.3.2 Health Physics support personnel as necessary. PS. Review and evaluate radiological and meteorological data t o EPP 06-003, 7.6 F6. Int erfaces with St at e and County emergency response assess the consequ ences of any release of radioactive mat erials. EPP 06-003, Figure personnel who are assigned t o the EOF rega rd ing matt ers relat ed P9 . Verify that radiologica l status informa t io n is being provided to 1 to off-site radiologica l assessment . dose assessment personnel and that the information is accurate and updated .

Attachme nt Ill to WO 18-0016 Page 3 of 13 ERO POSITI ON MATRIX Key Procedure( s)

Position Min NRC E-Plan (Rev. 0) Regu latory Curre nt ERO Position Tasks IT#l Other Procedure Tasks l molementin2: Action s eliminated? Tas k AssJon ed to? starnn*? Pl ? sectio n Renuire ment Dose Assessme nt Fl . Provide complet ed off-site dose projections to the Dose Pl. Maintain a log. N/ A Yes Eliminate posit ion No No AP 06-002, 6.8.7 Fl NU REG 0654 Technician Assessment Coordinator . P2. Forward all logs to the EOF Administrative Coordinator. Fl

• eliminate task AP 06-002, Figure II.A.l.a/ll.A.l.b/l l.A.l.d/11 .8.5/11.8 P3. Ensure Dose Assessment Progr am is operable. Pl

• eliminate task 4 .6/11.H.2/II.H.3 P4. Perform dose assesment. P2

• eliminate task EPP 06*003, 7.1.2 P3

• DAC does (P3) EPP 06*003, 7.2.2 P4 - to DAC EPP 06-003, 7.9 EPP 06-003, Figure 1

Dose Assessment Fl. Responsible for directing/assisting with dose projection and Pl. Maintain a tog. P4 . from Dose N( Pl O to Radiologica l No Yes AP 06--002, 6.8 .6 Fl/F2 NUREG 0654 Coordinator (DAC) protective action recommendation activities. P2. Forward all logs to the EOF Administrative Coordinator. Asssessment Technician Coordinator AP 006--002, II.A.1.a/ll.A.1.b/ll.A.1.d/11.B.5/11.B F2. Ensures the Radiologica l Status Board is maintained current. P3 . Ensu re dose assessment equip ment Is in place and functional. Figure 4 .6/II.H.2/11 .H.3 P4. Review th e current Protective Action Recommendations and EPP 06-003, 7 .1.2 inform the EOF Radiological Coordi nator of any changes based on EPP 06-003, 7.2.2 radiological or meteorologica l conditions. EPP 06-003, 7.8 PS . Consu lt with the EOF Operations Coordinator to obtain EPP 06-003, Figure informa tion regarding actual or pot entia l release pat hs, sources, 1 and duration.

P6. Implement the requ irements of EPP 06*012, DOSE ASSESSMENT.

P7 . Compare inputs and results with the State dose assessment staff.

PB . Inform th e EOF Radiological Coordinator of calcu lated resuh s.

P9. Assist in the formulation of Prot ective Action Recommendations.

PlO. Review, evaluate and trend off-site radiological monitoring data and off-site dose projections, t hen brief the EO F Radiologica l Coordinator.

EOF Admin lnistratlve Fl. Responsible for coordinating. directing. and respond ing to Pl. Maintain a tog. P4 from Admin Assistant No N/A Yes No AP 06-002. 6.8.10 Fl/ F2 NUREG 0654 Coordinator requests from the ERO for administrative and logistica l support . P2. Collect all logs and forward to Emergency Planning. PS from Admin Assistant AP 06-002, Figu re 11.A.1.a/ ll.A.1.b/ ll.A.1.d/ ll.A.4/11.8 F2. Ensures off-site not ifications are made. P3. Direct the Control Room to make site announcments as 4 .5/11.8.6/11.H.2/II.H.3 directed by t he Off-Site Emergency Manager . EPP 06-002, Att . C P4. Ensure EOF Administrative Assist ants perform notification s. EPP 06-003, 5.2 PS. Ensure Initial staffing is adequate. EPP 06-003, 7.1.2 P6. Call-out additional staff as needed . EPP 06-003, 7.1.3 P7. Arrange for FFD testing as req uired . EPP 06-003, 7.2.3 PB. Make arrangements for shift relief and mea ls. EPP 06-003, 7.3.2 P9. Assist bu ilding security person nel in est ablishing security posts. EPP 06-003, 7.5 EPP 06-003, Figure 1

EOFTeam Pl. Mai ntain a log. N/A No Reduce to PS t o EOF Team Di rector No No AP 06-002, Figure Communicator (2} P2. Forward all logs to the EOF Administrative Coordinator. 4 Reduce to 1 P3. Ensure the radio is turned on and selected to the correct EPP 06-003, 7.1.2 channel. EPP 06-003, 7.2.2 P4. Notify the Team Director when t he teams are ready t o depart. EPP 06-003, 7.13 PS. Establish and maintain com munications with the off-site EP P 06-003, Figure radiological monitoring teams. 1 P6. Verify team identification and membership when Field Teams esta blish radio communications.

P7 . Record survey data taken by Field Teams.

PB . M aint ain th e field team st atus boards, plot t he locations of the teams, affix t he appropriate stability class isopleths to the map and provide any needed assistance in maintaining the Radiologica l Status Board .

P9. Commu nicate direction s from th e Team Director, ma inta ining a record of all tra nsmissions.

PlO. Inform t he teams of changes to plant statu s and emergency classification s.

I IPll. Submit data to EOF Team Director for review and calculation I I I I I I verifica t ion. I

Attachment Ill to WO 18-0016 ERO POSITION MATRIX Page 4 of 13 Key Procedure(s)

Posi tion Min NRC E-Pl an (Rev. 0) Regulatory Curre nt ERO Position Tas ks (T#l Oth er Procedure Task s Jmol ementln ~ Actions ellrnlnated7 Task Assilmed to? Stafnm!? Pl? section Reoulrement EOF Operations Fl. Briefs the Emergency m anager on plant cond it ions and Pl . Maintain a log. P4 from Operations No N/A Yes No AP 06-002, 6.8.9 Fl NUREG 0654 Coordinator mitigative strategies. P2. Forward all logs t o th e EOF Administrative Coord inator . Recorder AP 06-002, Figure II .A.1.a/l l.A.1.b/ ll.A.1.d/ll.A.4/11 .8 P3 . Cont act Diesel Generator vendor for support as need ed . 4 .5/ 11 .8.6/11.H.2/II .H.3 P4. Post appropriate Emergency Classification signs. EPP 06-002, Att . C PS . Ensure fa cility clocks are synchronized to the Control Room EPP 06-003, 5.5 dock. EPP 06-003, 7.1.2 PG. Mon it or plant conditions for changes w hich could affect t he EPP 06-003, 7.1.3 emergency cla ssifi cation and notify the Off-Site Emergency EPP 06-003, 7.2.2 Manager of the conditions. EPP 06-003, 7.3.2 P7 . Evaluate actual or potentia l radiological releases ba sed o n EPP 06-003, 7.4 plant conditions. EPP 06-003, Figure 1

Survey Team Pl . Esta blish and maintain communications with the EOF Team P4 from EOF Facility No Reduce to N/ A No No EPP 06-002, Att . C Technician (4) Communicato r. Technician EPP 06-003, 7.15 Reduce to 3 P2. Perform monitoring duties. PS from EOF Facilit y Technician EOF Team Director Fl. Responsible for authorizing and su pervising Off-Site Pl . Maintain a log. PS from EOF Team No N/A No No AP 06-002, 6.8.4 Fl thru F3 NUREG 0654 Monitoring Teams. P2. Forwa rd all logs to the EOF Adm inistrative Coordina t or. Communicator AP 06-002, Figure II .A.l.a/ ll.A.l. b/ ll .A.l.d/ll.A.4/ 11.8 F2. Direct Off-Site Monit oring Teams. P3. Obta in and mo nitor radiological data t hat may affect the Field 4 .5/ 11 .8.6/11. H.2/11. H.3/11.1.7 F3. Advise the EOF Radiologica l Coordinator of radiological Team's ability to complete assigned activities. EPP 06-003, 7.1.2 conditions encountered by the Team s. P4. Assign each Emergency Response Team with a team identifier. EPP 06-003, 7.2.2 PS . En sure the logging in and analysis of all incomi ng radiologica l EPP 06-003, 7.12 sa mples. EPP 06-003, Figure PG. Review and document dosimet ry results of emergency 1 respo nse activities.

EOF Admini strattve Pl . M aintain a log. N/A No Reduce to P4 to Ad ministrative No Yes AP 06-002, Figure Assist ant(4) P2. Forwa rd all logs to the EOF Administrative Coordi nat or. Coordinat or (Key 4 Reduce to 3 P3. Ensure the operability of phones and radios to be used for PS to Administrative Comm) EPP 06--003, 7.1.2 County and State notification . Coordinator EPP 06-003, 7.2.2 P4. M aintain EOF accountabilit y. EPP 06-003, 7.11 PS. Provide assistance t o the Off-Site Emergency Manager EPP 06-003, Figure (maintain sequ ence of events log; answer phone; tra ck briefing 1 ti mes, assist in logkeeping).

PG. Copy, fa)(, distribute documents as request ed .

P7. Perform off-site communication s and notification s.

Representative at Fl. Respo nd to req uest s from County person nel for cla rification or Pl. Ma int ain a log. N/ A No N/ A No No AP 06--002, 6.8.11 Fl NUREG 0654 County verification of dat a received from t he TSC or EOF . P2. Forwa rd aU logs to the EOF Ad ministrative Coordinator. AP 06-002, Figu re II.A.l .a/ ll.A.l.b/l l.A.l .d/ il.A.4/ 11.8 P3. Keep the Off-Site Emergency M anager apprised of the stat us 4 .5/11. 8.6/11. 8.7a/ll .H. 2/11. H.3 of the implementation of Protective Action Recommendations. EPP 06-003, 7.1.2 EPP 06-003, 7 .2.2 EPP 06-003, 7.16 EPP 06-003, Figure 1

HPN Communicator Fl . Mainta in communicat ion s with the NRC via the Health Ph ysics Pl. Maintain a log. N/ A No N/A No No AP 06-002, 6.8.8 Fl NU REG 0654 Network (HPN) telephone. P2. Forwa rd all logs to the EO F Administ rative Coord inator . AP 06-002, Figure II.A.1.a/ ll .A.1.b/l l.A.1.d/ ll.B.5/11 .B P3. Inform th e EO F Radioliogica l Coordinator of the NRC's areas of 4 .6/II.H .2/11 .H.3 concern . EPP 06-003, 7 .1.2 EPP 06-003, 7.2.2 EPP 06-003, 7. 14 EPP 06-004, Figure 1

Attachment Ill to WO 18-0016 ERO POSITION MATRIX Page 5 of 13 Key Procedure(s)

Position Min NRC E-Plan (Rev. OJ Regula tory Current ERO Position Tas ks (T# ) Other Procedure Tas ks Implementing Actions eliminated? Task Assl2ned to? Staffing? Pl? sectio n Requirement EOF Facility Technician Fl. Ensure the EOF is prepared and functio nal. Pl. Establish and monitor facility habitability. N/A Yes Eliminate position Yes No AP 06-002, 6.8.S Fl NUREG 0654 P2 . Maintain a log. Fl - eliminate task AP 06*002, Figure II .A.l .a/ll.A. l.b/11.A.l.d/ll.B.5/11.B P3. Forwa rd alt logs to the EOF Administrative Coordinator. Pl - to Radiological 4 .6/II.H.2/ 11.H.3 P4. Ensure the source cabi net s in th e Kit Room are unlocked. Coordinator EPP 06-002, Att . C PS . Identify and label inoperable equipment . P2

• eliminate t ask EPP 06-003, 5.3 P6. Esta blish a radiologically controlled area boundary in the P3

• eliminat e t ask EPP 06-003, 7.1.2 ga rage as conditions warrant. P4

• to Survey t eams EPP 06-003, 7.1.3 PS

• to Survey Teams EPP 06-003, 7.2.2 PG

• to Radiological EPP 06-003, 7.3.2 Coordinator EPP 06-003, 7.7 EPP 06-003, Figure 1

TECHNICAL SUPPORT EPP 06-002 CENTER/ OPERATIONS SUPPORT CENTER Site Emergency Fl. Assume command and control of the emergency and directs Pl. Establish priorities for accident mit igation and emergency N/A No N/A Yes Yes AP 06-002, 5.1 Fl thru FlO NUREG 0654 Manager on-site response to stabilize plant cond itions. repair. AP 06-002, 6.6.5 II .A.l .a/U.A. 1.b/ ll.A.1.d/ 11.B.3/ll.B F2. Assess and verify the situation and assure that appropriate P2. Aut horize deviations from normal work processes. AP 06*002, Figure .4/ll. 8.5/11.8.6/11 .E.1/ II.E.3/ll.4.a mitigating efforts are being t aken . P3. Decla re the TSC or ATSC activated . 3 thru n/ ll .F.l .c/ ll.H.1/11. 1.8/IIJ.l .a F3. Review initial event classification and recla ssify as appropriate. P4. Perform TSC deactivation . EPP 06-002, 5.1 thru d/ 11.J.S/U.K.2 F4. Determine the necessity for evacuation of personnel on-site . PS. Ensure all logs are transmitted to the TSC Administrative EPP 06-002, 6.0 FS. If a release is occurring, make the necessary assessment of the Coordinator. EPP 06-002, 7.1.4 off-site concentration of rad ioactivity resulting from a release. PG. Perform turnover. EPP 06-002, 7.2.l F6. Ensure Immediate and follow-up notifications are made which P7. Direct the TSC Administrative Coord inator to make site EPP 06-002, 7.2.2 provide sufficient information on emergency classification, plant announcement regarding TSC activation . EPP 06-002, 7.3 status, off-slt e dose proj ections or measurements, and issue PB. Conduct initial and periodic briefings. EPP 06*002, Figure recommendations for off-site protective actions t o authorities P9. Authori ze deviations from normal work practices . 1 responsible for off-site emergency measures. PlO. Coordinate shift relief for Control Room and TSC personnel F7. Classify the emergency. (non-delegable) with the EOF .

FS. Recommend protective actions. (non -delegable) Pll . Determine evacuation route.

F9. Authorize off-site notifications. (non -delegable) P12 . Downgrade or terminate an event .

FlO. Authorize emergency exposure in excess of 10 CFR 20 lim its.

lnon-dele11:able)

TSC ENS Communicator Fl. Maintain communication with the NRC. Pl. Transmit log to the TSC Administrative Coordinator . N/A No N/A No No AP 06-002, 6.6.9 Fl NUREG 0654 AP 06-002, Figure II .A. l .a/11.A.1.b/ll.A.l.d/ll.B.5/11.8 3 .6/11 .F.l.c/ll .F.l.f/ll.H .l EPP 06-002, 7.2.2 EPP 06-002, 7. 14 EPP 06-002, Att . C EPP 06-002, Figure 1

Attachment Ill to WO 18-0016 ERO POSITION MATRIX Page 6 of 13 Key Procedu re(sJ Position Min NRC E* Plan (Rev. OJ Regu latory Current ERO Pos ition Tas ks IT#l Other Procedure Tasks l molementtn2 Action s eliminated? Task Asshmed to? Stafnn2? Pl ? sectio n Reaulrement TSC Radiological Fl . Responsible for preventing or minimizing d irect exposure to, or Pl. Provide direction for radiological conditions associated with N/A No N/A Yes Yes AP 06.002, 6.6.10 Fl thru F6 NUREG 0654 Coordinator ingestion/inhalation of, radioactive materials during a radiok>gical activit ies controlled by the Control Room and TSC. AP 06-002, Figure II.A. l .a/ll.A.1.b/ll.A.1.d/lLB.S/11.B emergency. P2. Transmit log to the TSC Administrative Coordinator. 3 .6/11.H.1 F2. Monitor dose rates and dose projections. P3. Ensure the TSC Facility Technician and one other person to EPP 06-002, 5.4 F3. Monitor radiological survey teams' results. m ake a t eam are available. EPP 06-002, 7.1.4 F4. Assist the On*site Emergency Manager in the formulation of P4. Ensure facilit y habitability has been established. EPP 06*002, 7.2.2 recommended protective actions . PS. Ensure dosimetry devices are placed in the facility or issued t o EPP 06-002, 7.3.2 FS. Monitor personnel radiation exposures t o ensure they are personnel as appropriate. EP P 06-002, 7.6 maintained in accordance wit h 10 CF R 20 lim it s unless otherwise P6. Initiate surveys. EPP 06-002, Att . C authorized by th e Emergency M anager. P7 . Communicat e as necessary with th e HP Technician in the EPP 06-002, Figu r e F6. Provide radiological dat a and concerns to plant teams for the Control Room regarding the radlological st atus and dosimetry 1 team briefs. results of emergency workers dispat ched from the Control Room.

PS. If off-site medical assistance is needed, then ensure Health Physics support requirements are met .

P9. Assist in evacuation by, dispatching an HP Technician to the Security Building to establish radiological control and conduct personnel monitoring.. if required.

PlO. Assist in evacuatton by, informing the Security Shift Lieutenant of appropriate radiologica l plant data and direction of the plume for dissemination to evacuating personnel.

Pll . If no release is in progress, dispatch one JRMT to appropriate sit e downwind PMP to obtain dose rat e reading and report the results to the o n-site PIC.

Engineering Fl. Direct activities of the Engineering Team to t echnically assess Pl. Transmit log t o th e TSC Administ rative Coordinator . N/A No N/A No Yes AP 06-002, 6.6.7 Fl NUREG 0654 Coordinat or plant status an d the severit y of emergency conditions. P2 . Direct accident assessment and m it igation activities. AP 06-002, Figure II.A.1.a/U .A.1.b/ ll.A.1.d/l l.B.5/11 .B P3 . Advise the TSC Operations Coord inator on technical matters 3 .6/11.H.l relating to fuel Integrit y, plant systems, equipment, and EPP 06--002, 5.7 instrumentation . EPP 06--002, 7.2.2 P4 . Support maintenance items assigned to Emergency Response EPP 06--002, 7.9 Teams. EPP 06-002, Figure PS . Provide the key to the lock box located in the kit room, if 1 renuested .

Enaineerina Team (S . Fl. Evaluate current and histortul plant parameters. Pl. Transmit log to the TSC Administrative Coordinator. N/A N, Reduce to N/A No No AP 06--002, 6.6.8 Fl thru F3 NUREG 0654 Nuclear, Electrical, F2. Assess the severity of the emergency conditions and P2. Assist with trouble-shooting and restoration of equipment . 3 AP 06--002, Att . 0 II.A.l .a/ll.A.l .b/ll.A.1.d/ll.B.S/11.B Mechanical magnitude of fuel damage. P3 . Monitor on -site and off* site electric distributk>n and sources. AP 06-002, Figure .6/11.H.1 (AU></BOP/NSSS)) F3 . Recommend correcttve and preventive actions. P4 . The Nuclear Engineer should assess the degree of fuel da mage. 3 Reduce to 3 EPP 06--002, 7.2.2 EPP 06* 002, 7.15 EPP 06-002, Att. C EPP 06-002, Figure 1

TSC Team Director Fl. Prov;de advice on all matters concerning Emergency Response Pl. Transmit log to the TSC Administrative Coordinator. N/A N, N/A No No AP 06-002, 6.6.12 Fl NUREG 0654 Team activities. P2. Assume control of all teams dispatched from the Control Room AP 06-002, Figure II.A.l .a/ll .A.l .b/ll.A.1.d/11.8.5/11 .B except on* shift Nuclear Station Operators. 3 .6/11.H.1 P3. Assign each Emergency Response Team with a t eam ident ifier. EPP 06--002, 7 .2.2 P4. Inform the TSC Team Communicator of the formation of EPP 06-002, 7.12 Emergency Response Teams. EPP 06-002, Figure PS. Eva luate the need for Health Physics sup port for all dispatched 1 teams.

P6. Coordinate with the Maintenance Assist ant to complete a brief for Emergency Response Teams.

TSCTeam Pl. Transmit log to the TSC Administ rative Coordinator. N/A Nn Reduce to N/A No No AP 06-002, Figure Communicat or (2) P2. Establish and maintain com munications with site Emergency 3 Reduce to l Response Teams. EPP 06--002, 7.2.2 P3. Inform the teams of changes to plant status and emergency EPP 06--002, 7.13 classifications. EPP 06-002, Figure P4. Ensure all pertinent directions to the teams from the TSC Team 1 Director are logged .

Attachment Ill to WO 18-0016 ERO POSITION MATRIX Page 7 of 13 Key Procedure(s)

Position Min NRC E-Pla n (Rev. OJ Regu latory Current ERO Position Tasks rT#l Other Proced ure Tasks lm olementl n2 Actio ns e li minated? Tas k Asslened to? s1a rnn27 Pl? section Requirement TSC Operations Fl. Supervise reactor plant operations (Operations Recorder, Pl. Coord inate overall emergency response activities with the P3 from Operations No N/A Yes Yes AP 06-002, 6.6.6 Fl/F2 NUREG 0654 Coordinator Engineering Coordinator, Engineering Team, ENS Communicator). Control Room staff. Recorder AP 06--002, Figure II.A.l.a/ll .A.l .b/ ll .A.l.d/ 11.B.S/ II.B F2. Keep the Site Emergency Manager advised of plant conditions P2. Transmit log to the TSC Admin istrative Coordinat or. PS from Operations 3 .6/11.H.1 and operationa l m anipulations. P3. En sure normal power supply to TSC is available, if not , ensure Recorder EPP 06-002, 5.2 diesel generator is started . EPP 06-002, 7 .1.4 P4. Post the appropriate Emergency Classification sign. EPP 06-002, 7.2.2 PS . If radioactive release is In progress or imminent, ensure EPP 06-002, 7.3.2 Filtration and the Iodine Monitor are EPP 06-002, 7.4 placed in service. EPP 06-002, Figure PG. Verify EROS is connected and transmitting data . 1 P7. If EROS is not connected, activate ERDS.

PB. Evaluate actual or potential radiological relea ses based on plant conditions and discuss with Site Emergency Manager and TSC Radiological Coordinat or.

TSC Adm inistrative Fl. Ensure emergency not ifications are made. Pl. Provide direction for the TSC Administrative Assistants. P4 from Administrative No N/A Yes No AP 06-002, 6.6.11 Fl/F2 NUREG 0654 Coordinator F2. Responsible for logistical support in the areas ofTSC P2. Collect all logs and transmit to Emergency Planning. Assistant AP 06-002, Figure II.A.l.a/ll.A.l .b/ll.A.l .d/ll.B.5/11.B personnel, Control Room , procurement and warehouse support, P3 . Make TSC activation announcement as directed by Site PS reword from " Ensure" 3 .6/11 .H.1 commu nications support and equipment repair services. Emergency Manager. to "Notify" EPP 06-002 . S.3 P4. Ensur e personnel accountability is being performed and EPP 06-002, 7.1 .4 maintained . EPP 06-002, 7.1.5 PS . Ensure the State and Cou nty are notified that the TSC is EPP 06-002, 7.2.3 activated . EPP 06-002, 7.2.6 PG. Ensure site augmentation ha s been m et. EPP 06-002, 7.2.7 P7 . Ensure initia l TSC staffing is adequate. EPP 06-002, 7.3.2 PB. Make arrangements for shift relief and meals. EPP 06-002, 7.5 P9. Ensure the TSC Administrative Assistants are briefed on Site EPP 06-002, Figure Emergency Manager's updates and emergency st atus. 1 PIO. Ensure the Security Shift Lieutenant is briefed on plant and radiological conditions that may impact Security operations.

Pll . If an evacuation has been ordered , det ermine from the Secu rity Shift Lieutenant the st atus of an Exclusion Area Boundary evacuation .

TSC M aintenance Fl . Direct the Maintenance Assistant in the coordination of Pl. Determine the need for and appoint members to Emergency N/A No N/A Yes Yes AP 06-002, 6.6.13 Fl/F2 NUREG 0654 Coor dinator emergency team activities. Response Teams. AP 06-002, Figure 11.A.1.a/ll.A.1.b/ ll.A. l .d/1 1.B.S/ II.B F2 . Direct the formation of t eams to be assigned to search and P2 . Transmit log to th e TSC Administr ative Coordinator. 3 .6/11.H.1 rescue. P3 . Verify personnel are present and ready to perform Emergency EPP 06-002, 5.6 Response Team tasks. EPP 06-002, 7.1.4 P4 . Provide the Site Emergency Manager with an assessment of EPP 06-002, 7.2 .2 pre-emergency maintenance activities. EPP 06-002, 7.3.2 PS . Coordinate with the Site Emergency Manager to determine EPP 06-002, 7.8 what information to list on the Priority Board and maintain the EPP 06-002, Figure board up-t o-date. 1 PG. Obtain the status of and eva luate teams dispatched by the Control Room fro m the TSC Operations Recorder.

P7 . Direct the Maintenance Planners to d evelop a r epair plan for equipment repair.

PB. Authorize deviation s from norma l work processes.

P9. Initiate EPF 06-011-01, PLANT TEAM BRIEFING CHECKLIST, and coordinat e with Maintenance Assistant on field team assignment .

PlO. Advise the Site Emergency Manager of Emergency Response Team status.

IPll. Provid e the key t o the lock box loca ted in the kit room, as I r eauested . I I I I I I I

Attachment Ill to WO 18-0016 ERO POSITION MATRIX Page 8 of 13 Key Procedure(s)

Position Min NRC E-Plan (Rev. OJ Regulatory Curre nt ERO Position Tas ks rT#l Oth er Procedure Tasks lmol ementlne: Actions eliminated? Tas k Asslened to? stamn2? Pl? section Requirement TSC Facility Technician Pl . Perform radiological duties in th e TSC as directed. N/A No N/A No No AP 06--00 2, Figure P2. Transmit log to the TSC Adm inistrat ive Coordinator. 3 P3. Establish and maintain facility hab it a bility. EPP 06-002, 5.5 P4. Inform the TSC Radiological Coordinator of all faci lity EPP 06-002, 7.2.2 habitability surveys. EPP 06-002, 7.7 PS. Identify and label inoperable equipment. EPP 06-002, Figure P6. Ensure 10 sets of 0*1000 mR and 0* 5 R dosimet ers are 1 functional and ready for use.

P7. Determine dose margin and respirat or qualifications of personnel assigned to Emergency Response Teams.

PS. Ensure the logging in and ana lysis of all incomin g radiological samples.

P9. Review and docum ent dosimetry results of emergency response activities.

PlO. Discuss the decontamination of on* sit e personnel with th e TSC Radiologica l Coordinator.

Operations Fl. Provide data , progress and plant cond it ions from the Control Pl. If unable to report to the Control Room, report to the EOF N/A No N/A No No AP 06-002, 6.6.14 Fl NUREG 0654 Communicator Room via the Operations Recorders. (alternate TS(). AP 06--002, Figure JI.A.l .a/ll.A.l .b/l l.A.1.d/11.8.5/ 11 .B (located in the Contro l P2. Set *up communications system . 3 .6/11.H.l Room) P3. If NPIS is inoperable, provide Operations Status Board EPP 06-001, 5.6 Information to Ops Recorders. EPP 06--001, 7.7 EPP 06-002, Figu re 1

Security Coordinator Pl. Tra nsmit log to the TSC Administrative Coordinator. N/A No N/A No No AP 06-002, Figure P2. Ensure the safety of Security personnel is maintained by 3 coordin ating Security activities with activities of the TSC. EPP 06* 002, 7 .2 .2 P3. Provid e coordination of activities (Emergency vehicle arriva l; EPP 06* 002, 7. 20 Search and rescue outside the PAB; Access to vita l areas; EMT EPP 06-002, Figure support; Activities concerning Security). 1 P4. Inform t he Em ergency M anager that personnel account ability ha s been established .

TSC Operations Pl. Tran smit log to the TSC Admi nistrative Coordinator. N/A No Reduce to P3 t o Operations Coordinator No No AP 06--002, Figure Recorder (2) P2. Maintain Operations Status cu rrent. PS t o Operations Coordinat or 3 Reduce to 1 P3. Monitor plant status for adverse trend s and inform the TSC EPP 06* 002, 7 .2.2 Operations Coordinator of changes in plant st atus which could EPP 06-002, 7.10 affect th e emergency classification . EPP 06* 002, Figure P4. Track procedure progress; list the procedure being performed 1 by the Control Room.

PS. Commun ica te information, concerni ng emergency tea m s dispatched from the Control Room, d irectly to the TSC Maintenance Coordin ator.

P6. If assisting th e Administrative Assistant, maint ain t he Sequence of Events log.

TSC Administ ra tive Pl . Transmit log to the TSC Administrative Coordinator. N/A No Reduce to P2

• eliminate task No Yes AP 06--002, Figure Assistant (4) P2 . Ensure the o perability of phones and radios to be used for P4

• to Administ rative (Key 3 Reduce to 2 County and St ate not ifications. Coordin at or Comm) EPP 06*002, 7.2.2 P3. Maintain TSC accountabUit y. P6

• eliminate ta sk EPP 06--002, 7.11 P4. Provide assistance to the Site Emergency Manager (sequence EPP 06-002, Att . C of events log, logkeeping, answer telephone, track briefing EPP 06--002, Figure schedules).

PS. Copy, fax and distribute documents as requested .

P6. Provide off.site communications.

Maintenance Planner Pl. Tran sm it log to the TSC Administrative Coordinator. P2 from Warehouse Supp No Reduce to N/A No No AP 06--002, Figure (3 - Elec/Mech/l&C) P2. Assist in the briefing of Emergency Response Teams. 3 Reduce to 1 P3. Provide maintenance support as appropriate to the EPP 06-002, 7.2.2 Maintenance Coordinator. EPP 06-002, 7.18 P4. Develop repair plans for equipment repairs as directed . EPP 06*002, Figure 1

Attachment Ill to WO 18-0016 ERO POSITION MATRIX Page 9 of 13 Key Procedure(s)

Position Min NRC E-Plan (Rev. O) Regu latory Current ERO Position Tas ks rT#l Othe r Procedure Tasks lmnlementi no Actions e liminated? Task Asshrn ed to? stamne? Pl ? section Reoulrement Warehouse Support Pl. Transmit log to the TSC Administrative Coordinator. N/A Yes Pl - eliminate task No No AP 06-002, Figure P2. Locate and secure parts and equipment from the warehouse P2 - to Maintenan ce Planner 3 as directed. EPP 06*002, 7.2.2 EPP 06-002, 7.19 EPP 06-002, Figure 1

Emergency Response Fl. Responsible for repairs, surveys, sam pling. analysis, and sea rch Pl. Transmit log to the TSC Administrative Coordinator. N/A No N/A No No AP 06-002, 6.7.2 Fl NUREG 0654 Team (ERT) (HP and rescue. P2 . Health Ph ysics Technicians will provide th e necessary AP 06-002, Att. 0 II.A.1.b/ll.B.5/II.B.6/11 .H.1 Technicians, Chemistry radiological guidance for the ta sk which the team will perform . AP 06-002, Figure Technicians, l&C, P3 . Health Physics Technicians sh ould provide status updates to 3 M ech anical, Electrical the Radiological Coordinator du r ing the time the team is in the EP P 06-002, 7.16 Maintenance) field . EPP 06-002, Att . C P4. Perform operability checks on equipment and instruments EPP 06-002, Figure before leaving the TSC. 1 PS. Ch em istry Technician s pr ovide analysis r esults to the TSC Radiologica l Coordinator.

PG. Immediately report major anomalies encountered in the plant to th e TSC Team Commu nicator.

P7. Track Emergency Response Team exposure.

M ainte nance Assis tant Fl. Coordinates repair and damage control activities. Pl . Transm it log to the TSC Administrative Coordinator. N/A No N/A No No AP 06-002, 6.7.1 Fl NUREG 0654 F2. Coordinates dep loyment of on-site teams. P2. Assign p ersonnel to Emergency Response Teams for AP 06-002, Figure II.A.1.b/ll.B.5/ II.B.6/11 .H.1 F3 . Coordinates the activities of the Maintenance Planners . equipment repair, surveys, o r search and re scue. 3 P3. Coordinate with the TSC Team Director and brief Emergency EPP 06-002, 7.17 Response Teams on team o bjectives . EPP 06-002, Figure P4. Brief th e Maintenance Coordinator on the status of Emergency 1 Response Teams.

PS. Debrief Emeraenrv Resnonse Tea m s.

JOINT INFORMATION EPP 06-004 CENTER Public Informat ion Fl. Authority and resp onsibility for WCGS Public Informat ion Pl. Transmit log t o the PIM. N/A No N/A Yes No AP 06-002, 6.9.2 Fl thru F3 NUREG 0654 Officer (PIO) Organization and all Plant information dissemin ated to the media. P2 . Approve n ews statement s. AP 06-002, Figure 11.A.l.a/U.A.1.b/ll.A.l.d/ll.B.5/11 .B F2. Responsible for en suring the timely issua n ce o f accurate P3 . Approve EPF 06-004-07, PH ONE TEAM INFORMATION REPORT, 5 .6/11.B.7.d/l l.G.4.a/ll .G.4.b information to the public and media during an emergency at and EPF 06-004-10, MEDIA TEAM REPORT. EPP 06-004, 5.1 WCGS. P4. Coordinate with and keep WCNOC Corpo rat e Communication s EPP 06-004, 7.1.2 F3. Coordinate wit h th e County and State fo r inform ation t o be staff infor med of Public Inform ation Or gan ization actions . EPP 06-004, 7.3 released to the public. PS . Maintain a log. EPP 06-004, Figure PG. Coordinate development of news statements and responses to 1 Phone Team or Media Monitor ing Team rumors.

P7. Coordinate the schedu ling. prepa r ation and implementation of news conferen ces.

Attachment Ill to WO 18-0016 ERO POSITION MATRIX Page 10 of 13 Key Procedu re(s)

Position Mi n NRC E-Plan (Rev. 0) Regula tory Current ERO Positio n Tasks rT#l Other Proced ure Tas ks lm olemen tl n"' Actions eli minated? Tas k Assl 0 ned to? sta mn *? Pl ? section Ren ulre mcnt Public Informat ion Fl . Ensure that information provided to the publlc is timely and Pl. Mainta in a log. N/A No N/ A No No AP 06-002, 6.9.3 Fl thru F3 NUREG 0654 Man11er (PIM ) accurate. P2. Coordinate turnover from Wolf Creek Corporate AP 06-002, Figure II .A.1.a/ll.A.1.b/ll.A.l.d/U .8.5/11.8 F2. Responsible for ensuring the Public Information Organization is Communicat ions. 5 .6/11 .B.7.d activated and fu nctions as d irected ln the EPPs. P3. Brief Wolf Creek PIO on Information received from Wolf Creek EPP 06-004, 5.2 F3 . Determines and coordinates the activation of the Joint Corporate Communications. EPP 06*004, 7.1.2 Information Clearing House, Media Center, Phone Team and P4. Approve news statements in the absence of the Wolf Creek EPP 06-004, 7.2 Media Monitoring. Public Information Officer. EPP 06-004, 7.4 PS. Approve EPF 06--004-10, MEDIA TEAM REPORT, in the absence EPP 06-004, Figure of the Wolf Creek Public Information Officer. 1 PG. Ensure all event documentation is collected and forwarded to Emergency Planning at the termination of an event .

P7. Ensure the JIC is restored to its original condition and an inventory is completed at the termination of the event.

PB. Direct deactivation .

P9. Ensure initia l staffing is adequate.

PlO. call in additional staff as needed .

Pll. En sure Phone Team Manager is briefed on event status and informa tio n applicable to the Phone Team or Media Monitoring Team .

P12. Direct Technical Support Staff activities.

PB. Perform briefs to keep personnel informed of events in progress.

P14. En sure news statements are prepared, approved and distributed in a timely manner.

P1S. Continually assess the impact of the emergency on the Public Information Organization .

P16. Ensure staffing needs for shift change or facility relocation are implemented .

P17. Coord inate scheduling and advanced preparation of news conferenc es.

P18. Ensure rumors are addressed in a timely manner.

P19. Ensure the JIC is restored to its original cond ition and an invent ory is completed at the term ination of the event .

P20. Forward all Public Informa tion documentation to Emergency Planning.

On-Site Public Fl. Gather and transm it technical information to the Joint Pl. Transmit log to th e TSC Administrative Coordinator. N/A Yes Eliminat e position No No AP 06-002, 6.9.4 N/A Information Information Clearinghouse for use in news statements. P2 . Maintain a log. Off-Site Public Information AP 06-002, Figure Coordinat or (TSC) P3 . Check personal WCNOC e-mail as necessary to obt ain copies of Coordinator duplicates all 5 approved, distributed news statements. tasks EPP 06--004, 7.1.2 P4. Print news statem ents and provide to th e Administrative EPP 06-004. 7.5 Assistant for distribution . EPP 06--004, Figure 1

Off-Site Public Fl. Gather and transmit technical information related to th e Pl. Transmit log to th e EOF Administrative Coordinator. P4 distribute to EOF & No N/A No No AP 06-002, 6.9.5 Fl NUREG 0654 Information health and safety of the public to the Joint Informat ion P2. Maintain a log. TSC Admin Coordinators AP 06--002, Figure II.A. l .a/11.A. l .b/ll .A. l. d/11. B.S/11.B Coordinator (EOF) Clearinghouse for use in news statements. P3 . Check personal WCNOC e-mail as necessary to obtain copies of 5 .6/ 11.B.7.d approved, distributed news statements. EPP 06-004, 7.1.2 P4. Print news statements and provide to the Administrat ive EPP 06-004, 7.6 Assistant for distribution . EPP 06-004, Figure 1

M edia Ce nter M anager Fl . Set -up the Media Center. Pl . Transmit log t o the PIM . Fl thru F5 from Media No N/A No No AP 06-002, 6.9.6 Fl thru F3 NUREG 0654 F2 . Provide leadership for the Media Registrar, AV Su pport, and P2 . Ensu re the Media Center Is restored to its original condit ion liaison AP 06-002, Figure II.A.l .a/ll.A.l.b/ ll .A.l.d/ll.B.5/ 11.B Media Liaison and management of the news media conferences. and an inventory is completed at the termination of the event. P3 from Media Liaison 5 .6/11.B.7.d F3 . Maintain contact with the Joint Information Clearinghouse to P3. Maintain a log. P4 from Media Liaison EPP 06--004, S.3 provide news conference schedu les. P4. Coord inate logistics for conducting news conferences. EPP 06-004, 7.1 .2 PS. Ensure the Media Liaison is aware of all news conference start EPP 06--004, 7.10 and end times. EPP 06-004, Figure 1

Attachment Ill to WO 18-0016 ERO POSITION MATRIX Page 11 of 13 Key Procedure(s)

Position Min NRC E-Pla n ( Rev. OJ Regula tory Current ERO Position Tas ks (T# } Other Procedure Tasks lmolementlne. Actio ns eliminated? Tas k Assllim ed to? s1a mn2? Pl? sectio n Reoulre ment Me dia liaison Fl. Manage the media at the Med ia Center. Pl. Transm it log to the PIM. N/ A Yes Elim inate position No No AP 06-002, 6.9.7 Fl thru FS NUREG 0654 F2. Assist the media with registration and faclll ty orientation. P2. Maintain a log. Fl thru FS to Media Center AP 06-002, Figure li .A.1.a/il.A.1.b/ ll .A.l.d/ 11.8.5/li .8 F3. Provide genera l Wolf Creek background information. P3. Provide approved news statements and news confernence Manager 5 .6/11 .8.7.d F4. Arrange ind ividual Interviews. Information to med ia representatives . Pl - eliminate ta sk EPP 06*004, 7.1.2 FS. Announce and coordinate scheduled news conferences. P4. Initiat e scheduled news conferences by setting ground rules P2 - eliminate ta sk EPP 06-004, 7.11 and tim e limit for t he news conferen ce and introducing persons P3 to Media Center Manager EPP 06-004, Figure Involved in the news conference . P4 to Media Center Manager 1 News Writer Fl. Provide support to the PIO (answering telephones, writing and Pl. Tra nsmit log to the PIM. N/ A No N/A No No AP 06--002, 6.9.8 Fl/Fl NUREG 0654 distributing news statem ents ). P2. Mainta in a log. AP 06--002, Figure li .A.1.a/li .A.1.b/li.A.1.d/11.8.5/11.8 F2. Maintain a chronologica l log of the events and news P3. Prepare news statements. 5 .6/11 .8.7.d statements. P4. Ensure news statements are accurate and contain proper EPP 06-004, 7.1.2 approva ls. EPP 06--004, 7.8 PS. Ensure news statements are distributed. EPP 06-004, Figure 1

Phone Team M anager Fl. Coordinate the rumor control activities of the Phone Team . Pl . Transmit log to the PIM. N/ A No N/A No No AP 06-002, 6.9.9 Fl NUREG 0654 P2. Ensure the Phone Team Room Is setup and ready for use . AP 06-002, Figure li .A.1.a/ll.A.1.b/li .A.1.d/ll.8.5/11.8 P3. Control information being provided to the Phone Team and 5 .6/11 .8.7.d Media Monitoring Team. EPP 06-004, 5.4 P4 . Con t rol activation and rumor control activities of the Phon e EPP 06-004, 7.1.2 Team and Med ia Monitoring Team . EPP 06-004, 7.14 PS. Direct t he activities of the Phone Team and Media Monit oring EPP 06-004, Figure Team t o identify misinformation being released t o the public. 1 PG. Com plete an inventory at the termination of the event .

P7. M aintain a log.

PS. Validate the plant status of the emergency with the Public Information Officer or Public Information Manager.

P9. Brief the Phone Team Room on the emergency status.

PIO. Coordinate functions of the Phone Team and Media Monitoring Team .

PU . Conduct turnover.

Pl2. Notify Wolf Creek Public Informat ion Manager of specia l request s or problems.

Technical Support (2) Fl. Ensure accuracy of news statements. Pl. Transmit log to the P1M N/A No - Reduce to N/A No No AP 06--002, 6.9.10 Fl thru F4 NUREG 0654 Reduce to 1 F2. Maintain the media status board . P2. Maintain a log. 1 AP 06-002, Figure II.A.l.a/ll.A.l .b/ll.A.l .d/ lt .B.5/11.B F3. Provide technical interpretation for the Wolf Creek, Coffey P3. Act as primary contact with t he On -Site and Off-Sit e PICs. 5 .6/11.8.7.d County, and State of Kansas Public Information Officers. P4. Validat e Emergency Notification Form informations with the EPP 06-004, 7.1.2 F4. Gather information from Emergency Facilities to commun icate On-Site or Off-Site PIC. EPP 06-004, 7.4.6 plant, health and sa fety issues to the public. PS. Address rumor and Media Monitoring Team issues. EPP 06-004, 7.7 P6. Ensure signs in the JIC reflect current emergency classification. EPP 06-004, Figure P7. Assist with news confernecne develop ment and 1 implementation .

Represent attve t o t he Fl. Respond to requests from State personnel for clarification or Pl. Transmit log to the PIM. N/A No N/A No No AP 06-002, Fl NUREG 0654 State verification of information pertaining to Wolf Creek. P2. Mainta in a log. AP 06-002, Figure 11.A.l.a/ll.A.l .b/ll.A.l.d/ll.8.5/11 .8 5 .6/11.8.7.d EPP 06-004, 7.1 .l EPP 06--004, Figure 1

Information Messenger Pl. Transmit log to the PIM . N/A No N/ A No No AP 06-002, Figure P2. Maintain a log. 5 P3. Establish communications with the Media Center. EPP 06-004, 7.1.l P4. Copy and distribute approved documents as requested . EPP 06-004, 7.9 EPP 06-004, Figure 1

11 to WO 18-00 16 ERO POSITION MATRIX Page 12 of 13 Key Procedure(s)

Position Min NRC E-Plan (Rev. OJ Regulatory Current ERO Position Tasks IT#l Other Procedure Tasks lmnl emen tl n" Actions eliminated ? Ta sk Ass hmed to? Statnne:? Pl? section Reaulrement M edia Center Registrar Pl . Transmit tog to the PIM. N/ A No . Reduce to N/ A No No AP 06-002, Figure (2) P2 . Maintain a log. 1 s Reduce to 1 P3 . Ensure med ia kits and news statements are readily available to EPP 06-004, 7.1.2 all media representatives. EPP 06-004, 7.12 P4. Register news media representatives upon their arrival at the EPP 06-004, Figure Med ia Center. 1 PS . Inform the M edia Uaison or Media Center Manager of media Inuestions and concerns.

A/VSupport Pl. Transmit log to the PIM . N/A No N/A No No AP 06-002, Figure P2. Mai nta in a log. s P3. Provide A/V support for au news conferences held in Media EPP 06-004, 7.1.2 Center. EPP 06*004, 7.13 EPP 06-004, Figure 1

Phone Team M ember Pl. Transm it log to the PIM . N/A No - Reduce to N/A No No AP 06-002, Figure (4) P2. Maintain a log. 3 s Reduce to 3 P3. Assist in the set-up of the Phone Team Room . EPP 06-004, 7.1.2 P4. Answer phone calls from th e public. EPP 06-004, 7.15 PS. Document phone ca lls. EPP 06-004, Figure PG. Document rumors or misinformation. 1 P7. Promptly report rumors or misinformation to the Phone Team Manaaer.

M edia Monitoring Pl. Transmit log to the PIM. N/A No - Reduce to N/ A No No AP 06-002, Figure Team (4) P2 . Maintain a tog. 3 s Reduce to 3 P3 . Assist in th e set -up of the Phone Team Room . EPP 06-004, 7.1.2 P4. Monitor major networks and local stations. EPP 06-004, 7.16 PS . Log news stories observed, heard, or read . EPP 06-004, Figure PG. Prom ptly report rumors or misinformation to the Phone Team 1 Manager .

CONTROL ROOM EPP 06--001 Shift Manager Fl. Respon sible for the initial evaluation and classification of any Pl . Emergency classification . (non-delegable) N/A No N/A Yes Yes AP 06-002, 6.5 .1 Fl thru FlO NUREG 0654 abnormal situation and for directing the appropriate response, P2. Authorize off-site notifications. (non-delegable) AP 06-002, 6.5.2 II.A.1.a/ 11.A.1.b/ tl.A.l.d/ll.A.1.e/ll including initial activation of a ca llout . P3 . Make Protective Action Recommendation s. (non -delegable) AP 06-002, Att . D .B.1/ 11. B. 2/11 .B. 3/11. B.4/11 .B.5/ 11. B.

F2. Initiate appropriate technical measures to mitigate the event. P4 . Authorize emergency exposures in excess of 10 CFR 20 limits. AP 06-002, Figure 6/11.E.l / 11.E.3/ 11.E.4.a thru F3 . Determine if releases have occurred, make necessary (non -delegable) 2 n/ll.F.1.a/ll.F.1.b/ ll .F.1.c/11 .F.1.f/ ll assessment of the off-site concentration of radioactivity resu lting PS . Complete notification form and provide to Off-Site EPP 06-001, 5.1 .1.8/11.K.2 from a release, and evacuate non-essential personnel if necessary. Comm unicator. EPP 06-001, 7.1.3 F4. Direct activitation of the Control Room ENS and Off-Site P6. Determine evacuation route. EPP-06-001, 7.2 Commu nicators. P7. Complete Emergency Notification Form .

FS . Ensure immediate and follow -up notifications are made which PB. Ensure personnel accounta bility is completed.

provide sufficient information on emergency classification, plant P9. If a relea se is in progress ensure unit vent monitor is in sta tus, off-site dose projections or measurements, and issue accident mode.

recommendations for off-site protective actions t o authorities PlO. Request off-site support as needed.

responsible for off-site emergency measures. Pll . Direct on-site protective measures.

F6. Ensure NRC Resident Inspector is notified as soon as possible P12 . Perform turnover.

after the State and County are notified .

F7. Ensure notifications to the NRC are made as soon as possible within 60 mlnuites of classifications of an emergency.

FB. Ensu re other notification s are made in accordance with EPPs.

IF9. Activate on-site emergency teams if required .

FlO. Not ifv lant nersonnel of the cha nae in nlant statu s. I I I I I I I I

Attachment Ill to WO 18-0016 ERO POSITION MATRIX Page 13 of 13 Key Procedure(s)

Position Min NRC E*Pla n (Rev. 0) Regulato ry Curre nt ERO Pos iti on Tas ks fT #l Other Procedure Tasks lmplementin2 Action s eliminated? Task Assl2n ed to? sramma Pl ? section Requirement Off-Site Communicator Fl. Perform initial notifications. Pl. Perform foltow-up notifications. Fl from ENS No N/A Yes Yes AP 06-002, 6.S.3 Fl/F2 NU REG 0654 F2. Initiate Automatic Diali ng System (ADS) or Backup ADS to call P2. Perform ERO call-out . Communicat or AP 06-002, Att. D ll .A.1.a/ ll .A.1.b/ ll .A.1.d/ ll .B.1/11.B out the ERO. (Manual ca ll out if ADS is not functioning.) P3. Perform Site announcements. AP 06-002, Figure .5/II.B.6/tl.E.2/11.F.l .a/ll,F.l .e P4. Provide Secu rity with classification announcement an d badge 2 numbers of those retained by the Shift Manager, but not in the EP P 06-001, 5.2.1 Control Room for accounta bility. EPP 06-001, 7.3 PS. Perform turnover.

ENS Communicator Fl . Maintain communications with the NRC. Pl. Transm it log to the TSC Admin istrative Coord inator. N/A Yes Fl t o Off-Site Commu nicator Yes No AP 06-002, 6.5.4 Fl NUREG 0654 AP 06-002, Att. 0 II.A.1.a/ll.A.1.b/ ll.A.1.d/ll. B.1/11.B AP 06-002, Figure .S/l l.B.6/U.F.1.a/11 .F.l.f 2

EPP 06-001, 5.3 EPP 06-001, 7.4 Chemistry Technician Fl. Perform dose assessment until relieved by Dose Assessment Pl. Perform in-plant sa mpling and ana lysis during a declared N/A No N/A Yes No AP 06-002, 6.5.5 Fl NUREG 0654 (2) personnel in the EOF. emergency. AP 06-002, Att. D ll .A.1.a/ll .A.1.b/l l.A.1.d/ ll .B.1/11.B Reduce to 1 (remove P2. Perform turnover. AP 06-002, Figu re .S/II.B.6/11.F.1.a Fire Brigade} 2 EPP 06--001, 5.4 EPP 06--001, 7.5 Health Physics Fl . Performs radia tion monitoring for person nel sent from and in Pl. Provide radiological data to the Sh ift Manager. N/A No N/A Yes No AP 06-002, 6.5 .6 Fl NUREG 0654 Technician (3) the Control Room . P2 . Mon it or Control Room habit ability. AP 06-00 2, Att. D ILA.1.a/ll.A.l .b/ ll.A.l .d/11.B.1/tl.B Reduce to 2 (remove P3 . Brief workers being dispatched from the Control Room . AP 06-002, Figure .5/11.8.6/1 1.F.1.a Fire Brigade) P4 . Review and document dosimetry results for emergency 2 workers who are dispatched to th e field from th e Control Room . EPP 06--001, 5.5 PS . Perform Access Control for the Radiological Controlled Area EPP 06-001, 7.6 (RCA) as direct ed by th e Shift Manager.

P6. Perform in -plant surveys and provide job coverage during a decla red emergency.

Control Room Fl. Provides direction ro Reactor Operat ors and Nu clea r Station Pl. Transmit 1og to the TSC Administ rative Coordinator. N/A No N/A Yes No AP 06*002, 6.5 .7 Fl NUREG 0654 Supervisor Operators for sa fe operation of the unit . AP 06--002, Att . D II.A.1.a/ll.A.1.b/ ll .A.1.d/ ll .B.1/11.B AP 06--002, Figure .S/II .B.6/11.F.1.a 2

Reactor Operators (2) Fl. Perform plant monitoring and reactor manipulations as Pl. Transmit log to the TSC Ad min istrat ive Coordinator. N/A No N/A Yes No AP 06*002, 6.5.8 Fl NUREG 0654 needed from the Control Room. AP 06--002, Att. D II.A.1.a/ll.A.1.b/ll .A.1.d/ ll .B.1/ 11.B AP 06--002, Figure .5/II .B.6/11.F.1.a 2

Nuclear Station Fl. Perform local plant monitoring and manipulations as directed . Pl. Transmit log to the TSC Adm inistrative Coordinat or. N/ A No N/ A Yes No AP 06--002, 6.5.9 Fl NUREG 0654 Operators (5) AP 06--002, Att . 0 II.A.1.a/ll.A.l.b/ 11 .A.1.d/ll.B.1/11.B Increase to 7 to cover AP 06--002, Figure .5/11 .B.6/II.F.1.a Fire Brigade 2 Shift Technical Advisor Fl. Performs STA requirements as assigned by the NRC. Pl. Initiate the Emergency Response Data System (EROS) within 60 N/A No N/A Yes No AP 06-002, 6.5.10 Fl NUREG 0654 minut es of an Alert or higher classification . AP 006*002, Att. 0 II.A.l.a/ll.A.l .b/ ll.A.1.d/ll.B.1/ 11.B AP 06--002, Figure .5/11 .8.6/ 11.F.1.a 2

EPP 06-001, 5.7 EPP 06-001, 7.8

Attachment IV to WO 18-0016 Page 1 of 3 Summary of Shift Staffing and Augmentation Response Time Historical Requirements and Proposed Changes

Attachment IV to WO 18-0016 Page 2 of 3 Summary of Shift Staffing and Augmentation Response Times WCNOC On-Shift Table Comparison Major Functional Area Major tasks Position Title/Expertise Table WCGS WCNOC WCNOC 8-1 Rev 15 Rev 18A Proposed On-Shift On-Shift On-Shift On-Shift Plant Operations & Assessment of Shift Manager (SRO) 1 1 1 1 Operational Aspects Control Room Supervisor 1 1 1 1 (SRO)

Reactor Operator (RO) 2 2 2 2 Nuclear Station Operator 2 4 5 7 Emergency Direction and Control Site Emergency Manager 1** 1** 1** 1**

Notification/Communication Notify licensee, state, local and Emergency Communicator 1 1** 2 1 federal personnel, and maintain communication Radiological Accident Assessment & EOF Director RP Personnel 1 1 3 2 Support of Operational Accident Off-Site Dose Assessment Chemistry Personnel 1 1 2 1 Assessment Off-Site Surveys On-Site (Out-of-Plant) and In-Plant surveys Chemistrv/Radiochemistrv Plant System Engineering, Repair & Technical Support Shift Technical Advisor 1 1** 1 1 Mitigative Actions Repair and Corrective Action Radwaste Operator 1** 1** 1** 1**

Electrical Maintenance 1** 1** 1** 1**

Protective Actions (In-Plant) Radiation Protection - RP Personnel 2** 1** 1** 1**

Access Control RP coverage for repairs &

corrective action, search and rescue, first aid and firefighting Personnel monitoring dosimetry Firefighting = Fire Brigade Fire Fire FB per FB per Brigade Brigade TRM TRM per TS per TS Rescue Operations and First Aid 2** 2** 2** 2**

Site Access Control and Security Security Personnel All per All per All per All per Accountability Firefighting communications Security Security Security Security Personnel Accountability Plan Plan Plan Plan Total On-Shift 10 12 17 16

• • May be provided by shift personnel assigned other functions

Attachment IV to WO 18-0016 Page 3 of 3 WCNOC 60-Minute Augmented ERO Table Comparison Major Functional Area Major tasks Position Title/Expertise Table WCGS WCNOC WCNOC 8-1 Rev 15 Rev 18A Proposed Augment Augment Augment Augment (30/60 (60 Min) (60 Min) (60 Min)

Min)

Notification/Communication Notify licensee, state, local and Emergency Communicator 1/2 3 3 3 federal personnel, and maintain communication Radiological Accident EOF Director Off-Site Emergency Manager 0/1 0 0 0 Assessment & Support of Off-Site Dose Assessment and Staff Operational Accident Off-Site Surveys Sr. Health Physics Expertise 0/1 1 1 1 Assessment On-Site (Out-of-Plant) and In-Plant surveys RP Personnel 1/0 8 8 6 Chemistry/Radiochemistry 4/4 Chemistry Personnel 0/1 1 1 1 Plant System Engineering, Technical Support Core/Thermal Hydraulics Eng. 1/0 1 1 1 Repair & Mitigative Actions Repair and Corrective Action Electrical Eng. 0/1 1 1 1 Mechanical Eng. 0/1 1 1 1 Mechanical Maintenance 0/1 2 2 1 Electrical Maintenance 1/1 2 2 1 l&C Technician 1/0 1 1 1 Protective Actions (In-Plant) Radiation Protection - RP Personnel 2/2 4 4 2 Access Control RP coverage for repairs &

corrective action, search and rescue, first aid and firefighting Personnel monitoring dosimetry Total 60 Minute Augmented 25 25 25 19 Total On-Shift and 60 Minute Augmented ERO 35 35 42 35

Attachment V to WO 18-0016 Page 1 of 2 Letter of Consultation and Concurrence from Off-site Response Organizations Acknowledgement of Opportunity to Review and Support WCNOC License Amendment Request

Attachment V of WO 18-0016 Page 2 of 2 Letter of Consultation and Concurrence from Off-site Response Organizations Acknowledgement of Opportunity to Review and Support WCNOC License Amendment Request During meetings on September 7 and October 17, 2017 with off-site response organizations (ORO), Emergency Preparedness (EP) representatives from WCNOC provided a briefing to the Coffey County Emergency Management organization, and the state of Kansas (ORO stakeholders). Note that if an organization was not in attendance, a one-on one meeting was conducted to update the stakeholder with information contained in the license amendment request {LAR). WCNOC EP staff reviewed with the ORO stakeholders the proposed license amendment request (LAR), including seeking NRC approval for extension of the goal for staffing its augmented TSC/OSC Emergency Response Organization {ERO) from the current goal of 60 minutes to one of 90 minutes and reduction of the total number of ERO responders. During the reference meeting, WCNOC EP Staff provided assurances that the proposed changes will not adversely affect existing capabilities for prompt notification to the stakeholders of an Emergency Classification Level, for radiological monitoring and assessment support, and for ongoing communication and coordination of emergency information. In addition to maintaining notification capabilities to notify the stakeholders of a declared emergency within 15 minutes, WCNOC will continue to deploy a liaison to the Emergency Operations Centers (EOCs) after declaration of an Alert or higher emergency classification level. The staffing levels at the EOCs wil~ not change. The ERO will continue to support the state for/off-site radiological monitoring an~ assessment. Coordination arrangements between WCNO.C and the ORO stakeholders will continue to allow for timely dissemination of emergency information to the public. Activation tije for the EOF is not changing and remains at 90 minutes. ~

With the assurances noted above, the ORO stakeholders repr senting the named organization haye received information on the Emergency Response Orga, ,ization (ERO) augmentation 1

License Amendment Request (LAR) to the Nuclear Regulatory Commission (NRC) and support the requested changes.

ORGANIZATION DATE

. ' DigitallysignedbyMORGAN.ANGELYNN.T.1392188815 MORGAN

• ANGELYNN *T* 139:\ DN: c=US, o=U.S. Government, ou=DoD, ou=PKI,

,' 'ou=USA,cn=MORGAN.ANGELYNN.T.1392188815 2188815  :

1

- Date:2017.J0.3008:01:29-05'00' Kansas Division of Emergency Management (KDEM)

Kansas Depart ealth and Environment (KDHE) 10-25-17

~~

Coffey Count~ergencyMaagement

Enclosure I to WO 18-0016 Proposed Markup of Procedure AP 06-002, Radiological Emergency Response Plan (RERP)

(110 pages)

AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN (RERP)

Responsible Manager SUPERINTENDENT EMERGENCY PLANNING Revision Number TBD!f-B.-8 Use Category I n f ormation Administrative Controls Procedure Yes Management Overs i ght Evolution No Program Number 06

Revision : -l-&18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Informa t ion Use Page 1 of 108 TABLE OF CONTENTS SECTION TITLE PAGE 1.0 PURPOSE ---:r-2.0 SCOPE 3

3.0 REFERENCES

AND COMMITMENTS 4 4.0 DEFINITIONS 5 5.0 RESPONSIBILITIES 11

6. 0 PROCEDURE 12 6.1 Site Description 12 6.2 Emergency Clas s if i cations 15

6. 3 Emergency Measures 17

6. 4 Emergency Facilities 25

6. 4. 1 Control Room Facilities 25

6. 4. 2 Techn i cal Support Center Facilities 25

6. 4. 3 Opera t ions Support Center 27

6. 4. 4 Emergency Operations Facility (EOF) 27

6. 4. 5 Public Information Facilities 28

6. 4. 6 On - site Medical Facility 30

6. 4. 7 State and County Facilities 31 6.5 Control Room Organization 31

6. 6 Technical Support Center (TSC) Organization 34 6.7 Operations Support Center (OSC) Organization 39

6. 8 Emergency Operations Facility (EOF) Organization 40

6. 9 Public Information Organization 47 6 . 10 Local Off-site Organizations 52 6 . 10 . 2 Coffey County Commissioners 52 6.10 . 3 Coffey County Sheriff ' s Office 53 6 . 10 . 4 Coffey County Fire District #1 (CCFD) 54 6 . 10 . 5 Off - site Medical Treatment 54 6 . 10.6 Coffey County Emergency Medical Service (EMS) 54 6 . 10 . 7 Radiological Emergency Assistance Center/Training Site (REAC/TS) 55 6 . 11 State Organizations 55 6 . 11 . 3 Kansas Division of Emergency Management (KDEM) 56 6 . 11 . 4 Kansas Department of Health and Environment (KDHE)56 6 . 11 . 5 Kansa s Highway Patrol (KHP) 57 6 . 11 . 6 Kansas National Guard 57 6 . 11 . 7 Kansas Department of Transportation (KDOT) 58 6 . 12 Federal Organizations 58 6 .1 2 . 2 Federal Emergency Management Agency ( FEMA) 58 6 . 12 . 3 Department of Energy (DOE ) 58 6 . 12 .4 Nuclear Regulatory Commission (NRC) 58 6 . 12 . 4 Nuclear Regulatory Commission (NRC) 59 6 . 13 Additional Support Agencies 59 6 . 13 . 1 Vendor and Architect/Engineers (A/E) 59 6 . 13 . 2 Regional Utility Support 61 6.13 . 3 Institute of Nuclear Power Operations (INPO) 61 6 . 13 . 4 American Nuclear Insurers (ANI) 61 6 . 14 Plant Monitoring 61

Revision : -+/--8-18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 2 of 108 TABLE OF CONTENTS SECTION TITLE PAGE 6 . 14.1 Nuclear Plant Inf ormation System (NPIS) or 6 . 14 . 2 On - site Radiological Monitors 62 6.14 . 3 Meteorological Monitoring System 63 6.14 . 4 Seismic Monitoring System 63 6 . 14 . 5 Hydrologic Monitoring 63 6.14 . 6 Fire Protect i on 64 6 . 14 . 7 Laboratory Facilities 64 6 . 15 Emergency Supp l ies 64 6 . 16 Communicati on s 65 6 . 16 . 1 Communication Equipment 65 6 . 16 . 2 Communication Dissemination 65 6 . 17 Emergency Plan Training 67 6.18 Emergency Plan Dril l s 69 6.19 Emergency Planning Exercises 71 6.20 Emergency Plan And Procedures Administrative Controls 74 6.21 Recovery Plan 75

7. 0 RECORDS 76 8.0 FORMS 76 ATTACHMENT A EFFECTIVE 10 - MILE EPZ POPULATION 77 ATTACHMENT B SUBZONE EVACUATION TIMES 78 ATTACHMENT C CROSS REFERENCE BETWEEN NUREG 0654 , RERP , & WCGS PROCEDURES 81 ATTACHMENT D WCGS MINIMUM STAFFING FOR EMERGENCIES 89 ATTACHMENT E EPA/KANSAS PROTECTIVE ACTION GUIDES 91 ATTACHMENT F USAR CHAPTER 15 POSTULATED EVENTS 94 ATTACHMENT G LETTERS OF AGREEMENT 96 ATTACHMENT H REPORTING OF INCIDENTS PER 10 CFR 20 97 FIGURE 1 EFFECTIVE 10 - MILE EPZ , SUBZONES AND EVACUATION ROUTES 98 FIGURE 2 MINIMUM SHIFT STAFFING 99 FIGURE 3 TSC/OSC ORGANIZATION 100 FIGURE 4 EOF ORGANIZATION 101 FIGURE 5 PU BLIC INFORMATION ORGANIZATION 1 02 FIGURE 6 EMERGENCY ORGANIZATION INTE RFAC ES 103 FI GURE 7 WCGS EMERGENCY RESPONSE FACILITIES 1 04 FIGURE 8 AIRBORNE PATHWAY SAMPLING LOCATIONS 105 FIGURE 9 DIRECT RADIATION PATHWAY SAMPLING LOCATIONS 106 FIGURE 10 WATERBORNE PATHWAY SAMPLING LOCATIONS 107 FIGURE 11 FIXED SIREN SITING 108

Revision: -+/--8-18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 3 of 108 1.0 PURPOSE 1.1 The purpose of the Wolf Creek Generating Station (WCGS)

Radiological Emergency Response Plan (RERP) is to classify emergencies , assign responsibilities for actions , and to establish the lines of authority and communications to protect the public and plant personnel in the event of an emergency .

2.0 SCOPE 2.1 The RERP has been developed in accordance with 10CFR Part 50, Paragraph 50.47 and Appendix E, Regulatory Guide 1.101 and generally follows the guidelines of NUREG 0696 and 0654 . The RERP is sensitive to a broad spectrum of emergency conditions which have been postu l ated for a commercial pressurized water reactor. Although the probability of an accident is low , the RERP is maintained to assure the safety and well-being of plant personnel and members of the public in the vicinity of WCGS .

2.2 The RERP interfaces with several related documents such as the Administrative Procedures (APs) and Emergency Plan Procedures (EPPs) . Detailed instructions necessary to support the RERP are included in these procedures and are available for training ,

drill , and actual emergency use. The RERP references the WCGS Fire and Security Plans , Vendor contingency plans as well as those of medical support facilities and the Institute of Nuclear Power Operations (INPO) . This document has been designed to coordinate with the State Emergency Operations Plan and the Coffey County Contingency Plan for Incidents Involving Commercial Nuclear Power , which govern the activities of these support groups in response to events at WCGS.

2.3 The RERP is based on a graduated , escalating level of emergency response which is activated as conditions at the plant warrant .

This approach provides the flexibility necessary to ensure adequate emergency response to a spectrum of possible events .

The RERP is designed to control emergency response activities ranging from initial event detection , classification of the event , notification of off-site authorities and providing protective action recommendations to the county and state.

2.4 The RERP reflects three chief phases of activation . First the response is dominated solely by the site staff , next the on-site and off-site public information facilities are jointly activated , and finally the recovery efforts are performed by site, public information facilities, vendor , and other critical support groups.

Revision : +&18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 4 of 108 2.5 The WCGS normal operating organization and its functional responsibilities are described in the WCGS Technical Specifications , Administrative Procedures, Human Resources company organization charts and the WCGS Updated Safety Analysis Report (USAR) . No further discussion of the normal operating organization i s contained within the RERP.

2.6 The WCGS design bases accidents and various plant systems are listed and described in the WCGS Technical Specifications and USAR . No further discussion of these accidents or systems is contained within the RERP.

2.7 The owners of WCGS do not respond to the site during emergency events for augmentation . The Wolf Creek Nuclear Operating Corporation organization functions from the site during normal everyday operations .

3.0 REFERENCES

AND COMMITMENTS 3.1 References 3 . 1.1 Coffey County Contingency Plan for Incidents Involving Commercial Nuclear Power (County Plan) 3 .1. 2 The State of Kansas Radiological Emergency Response Plan for Nuclear Facilities 3 .1. 3 Updated Safety Analysis Report (USAR) 3 .1. 4 NUREG 0654, Criteria For Preparation And Evaluation Of Radiological Emergency Response Plans And Preparedness In Support Of Nuclear Power Plants 3 . 1. 5 NUREG 0696 , Functional Criteria For Emergency Response Facilities 3 . 1. 6 NUREG 0737, Clarification Of TMI Action Plan Requirements 3 .1. 7 Title 10, Code Of Federal Regulations, Part 50 3 . 1. 8 Regu l atory Guideline 1.101 3 .1. 9 Regulatory Guide 1.145 3 .1. 10 PIR 2002 - 1524, Minimum Staffing Requirements 3 . 1.11 Wolf Creek On - Shift Staffing Analysis 3.1.12 Wolf Creek Generating Station Development of Evacuation Time Estimate (October 2012)

Revision : -+/--8-18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 5 of 108 3.2 Commitments 3 . 2.1 RCMS #93 - 325 , Emergency Action Levels Converted To NUMARC EALs 3 . 2.2 APF 06 - 002 - 01 , EMERGENCY ACTION LEVE LS, required to have a 50 . 54(q) r e view performed for each rev i sion.

3 . 2.3 RCMS #05 - 115 , NRC Regulatory Guide 1 . 101 Guidance Definitions 3.2.4 RCMS #05 - 118 , NRC Bulletin 2005 - 02 Guidance For Drills And Exercises 3.2.5 CR 00086306 , Minimum Staffing Requirements not Met 4 .0 DEFINITIONS 4.1 Administrative Procedures (APs) 4 . 1.1 Procedures which provide programmatic responsibilities and are typically used t o solve problems, assemble documentation , process i nformation , and present resu l ts of administrative functions .

4 .1. 2 Administrative procedures control activities affecting quality or nuclear safety .

4.2 As Low As Reasonably Achievable (ALARA) 4 . 2 .1 Making every reasonable effort to maintain exposures to radiation as far below dose limits as is practical ,

consistent with the purpose for which the licensed activity is undertaken , taking in t o account the state of technology , the economics of improvements in relation to benefits to the public health safety , and other societal and socioeconomic considerations .

4.3 Alert 4.3.1 Events are in progress or have occurred which involve an actua l or potential substan t ial d e gradat i on of the level of safety o f the p l ant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION . Any releases are expected to be l i mi t ed to s ma l l fractions of the Env i ronmenta l Protection Agency (EPA) Protective Action Guideline (PAG) exposure levels . [Commitment Step 3.2.3]

Revision : +8-18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 6 of 108 4.4 Assessment Actions

4. 4.1 Those actions taken during or after an accident to obtain and process information that is necessary to make decisions to implement spec i fic emergency measure s.

4.5 Coffey County Emergency Operations Center (County EOC) 4 . 5. 1 The base of operations for the Coffey County Emergency Response Organization .

4. 6 Consultant/Vendor 4.6.1 The Nuclear Steam System Supplier (NSSS) ,

Architect/Engineer , and other organizations who have available multidiscipline teams ready to support emergency response and Recovery Operations .

4.7 Control Room 4 . 7. 1 The location at the WCGS from which the reactor and its auxiliary systems are normally controlled .

4.8 Drill 4.8.1 A supervised activity used to develop and maintain skills . On the spot correction of erroneous performance is permitted .

4. 9 Emergency Action Levels (EALs )

4. 9.1 Radiological dose rates; specific contamination levels of airborne , wate r borne or surface - deposited concentrations of radioactive materials; or specific instrument indications that may be used as thresholds fo r designating a part i cular class of eme r gency .

4 . 10 Emergency Alert System (EAS) 4.10 . 1 A coordinated network of broadcasters (e.g. Radio ,

Television , Cable) that allows the Preside nt to address the nation , Governors to address their State and public safety officials to address local citizens with emergency information .

Revision : -+/--8-18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 7 of 108 4 . 11 Emergency Classification 4 . 11.1 A system used to define the severity of emergencies into one of four categories based upon projected or conf i rmed emergency action le ve ls. Classifications listed in order of increasing severity are Notification of Unusual Event (NU E) , Alert , Site Area (SAE) and General Emergency (GE) .

4.12 Emergency Operations Facil i ty (EOF) 4 . 12 . 1 This facility serves as a base of opera ti ons for all emergency plant support activities, site environmental surveil la nce , communications with supporting agencies ,

and the WCGS Emergency Organization .

4.13 Emergency Plan Procedures (EPPs) 4 . 13 . 1 Specific procedures providing step - by - step actions to implement the WCGS Radiological Emergency Response and Recovery Plans , and t o provide guidance to improve o r terminate an emergency situation .

4 . 14 Evacuat i on Registrat i on Cente r 4 . 14 . 1 . Facility designated for receiving personnel evacuating the Emergency Planning Zone (EPZ) f o r accountability ,

contamination monitoring and decontamination .

4.15 Exclusion Area 4 .15 . 1 That area with in a 1200 - meter radius of the Conta inmen t Building in which WCGS has the authority to determine all activities including exclusion or removal of persons and property from the area .

4.16 Executive Management 4 . 16 . 1 Those members of WCGS management at the vice president level and above .

4 . 17 Exercise 4 . 17. 1 An event that simulates a radiological emergency condition , incorporates the integrated capability of the basic elements existing within the Radiological Emergency Response Plan (RERP ) . These events are normally evaluated by FEMA / NRC .

Revision : -l-&18 RADIOLOGICAL EMERGENCY RES PONSE PLAN AP 06 - 002 (RERP)

Information Use Page 8 of 108 4 . 18 General Emergency (GE) 4 . 18 . 1 Events are in process or have occurred which involve actual or imminent substantial core degradation or melting with the potent i al for loss of containment integrity or HOSTILE ACTION that result s in an actual loss of physical control o f the facility . Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels off -s ite for more than the immediate site area . [Commitment Step 3.2.3]

4 . 19 Hostile Action 4 . 19 . 1 An act toward a Nuclear Power Plant (NPP) or its personnel that includes the use of violent force to destroy equipment , take hostages , and/or intimidates the licensee to achieve an end . This includes attack by air , land , or water using guns , explosives ,

project i les , vehicle s, or other devices used to deliver destructive force . Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP . Non - terror ism-based EALs should be used to address such activities (e . g ., violent acts between individuals in the owner controlled area) . [Commitment Step 3.2.3]

4 . 20 Hostile Force 4 . 20 . 1 One or more individuals who are engaged in a determined assault , overtly , or by stealth and deception , equipped with suitable weapons capable of killing , maiming , or causing destruction . [Commitment Step 3.2 . 3]

4 . 21 Immediate Notification 4 . 21 . 1 Notification made to State of Kansas and Coffey County authorities within 15 minutes of a declared emergency at WGCS .

4 . 22 Joint Information Clearinghouse (JIC) 4.22.1 The facility where news statement and news conference materials for the media are prepared .

4 . 23 Kansas State Emergency Operations Center (State EOC) 4 . 23 . 1 The command- and-control center for the state.

Revision : -+/--&18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 9 of 108 4 . 24 Licensed Operato r s 4 . 24 . 1 WCGS Re a ctor Operators and Senior Reactor Operators who are licensed under 10CFR55 and who stand watches on shift and report to the Sh if t Manager .

4 . 25 Media Center (MC) 4 . 25 . 1 Facility utilized as a focal point for giving informa ti on to the med i a th r ough news con f erences .

4 . 26 Notification of Unusual Event 4 . 26 . 1 Events are in process or have occurred wh i ch indicate a potenti al degradation of the level of safety of the plant o r indicate a securi t y threat to facility protection has been initiated. No releases of radioactive material requi ri ng off - site response or monitor i ng are expected unl e ss further degradation of safety s ystems occurs . [Commitment Step 3.2.3]

4 . 27 Off - site 4 . 27 . 1 Any area out side the Exclu s ion Area of WCGS .

4 . 28 On - site 4 . 28 . 1 Any area inside the Exclusion Area of WCGS .

4 . 29 Operations Support Center (OSC) 4 . 29 . 1 A staging area for emergency teams to support the emergency response effort .

4 . 30 Owner Controlled Area 4 . 30 . 1 Prop erty contiguous to the reactor site and acquired by fee , tit l e or easement for Wolf Creek Generating Station f or which public access is limited .

4 . 31 Protective Actions 4 . 31 . 1 Those eme rgency measures t a ken before or after a release of radioactive material has occurred for the purpose of preventing or minimizing radiological exposure s to personnel .

4 . 32 Protective Action Guides (PAGs)

Revision : -l-8-18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 10 of 108 4 . 32 . 1 Guides promulgated by the Environmental Protection Agency (EPA) which set dose limits for the evacuation of the public during an accident condition at a nuclear power plant .

Revision : -+/--8-18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 11 of 108 4.33 Radiologically Controlled Area (RCA) 4.33 . 1 An area to which access is controlled by WCGS for purposes of protection of individuals from exposure to radiation or radioa ct ive materials .

4 . 34 Recovery 4 . 34 .1 Post-emergency efforts initiated to restore WCGS to ful l ope ration or place the plant in a safe shutdown condition until full operation can be resumed .

4 . 35 Site Area Emergency (SAE) 4.35.1 Events are in process or have occurr ed which involve an actual or likely major failure of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage o r malicious acts ;

(1) t ow ard site personnel or equipment that could lead to the likel y failure of or ; ( 2) that prevent effective access to equipment needed for the protection of the public . Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.

[ Commitme nt Step 3.2.3]

4 . 36 Technical Support Center (TSC) 4 . 36 . 1 The TSC serves as a center outside of the Control Room that acts in support of the command-and- control function and houses the OSC organization . Plant status and diagnostic information are available at this location for use by technica l and management personnel in support o f reactor command-and-control functions.

5.0 RESPONSIBILITIES 5.1 Site Emergency Manager 5 .1.1 Assumes command and control of the emergency and directs on - site response to stabilize plant condit i ons .

5.2 Of f - site Emergency Manager 5.2.1 Assumes command and control of the emergency and interfaces with o ff - site agencies.

Revision : -l-8-18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 12 of 108 5.3 Superintendent Emergency Planning 5 . 3 .1 Ensures the Emergency Planning and Preparedness Program is implemented and maintained as required to protect the health and safety of the public.

5.3.2 Ensures changes to the overall Emergency Planning and Preparedness Program meets the standards of 10CFR50 . 47(b) and the requirements of 10CFR50, Appendix E.

5.4 Manager Quality

5. 4 .1 Ensures a review of the WCGS Emergency Planning and Preparedness Program will be performed at least once every twelve months in accordance with 10CFR 50.54(t).

5.5 President and Chief Executive Officer 5.5.1 Maintains overall authority and responsibility for the WCGS Emergency Preparedness Program .

5.6 Public Information Officer (PIO) 5.6.1 The PIO has the authority and responsibility for the WCGS Public Information Organization and all plant information disseminated to the media .

5.7 Shift Manager (SM)

5. 7 . 1 The Senior Reactor Operator designated by WCGS management with immediate on - site authority and responsibility for the safe and proper operation of the plant . This position is staffed at all times . The Shift Manager is responsible for the initial evaluation of any abnormal or emergency situation and for directing the appropriate response . He assumes responsibilities of the Emergency Manager until relieved .

6.0 PROCEDURE 6.1 Site Description 6 . 1. 1 WCGS is a Pressurized Water Reactor (PWR) nuclear generating station operated by Wolf Creek Nuclear Operating Corporation (WCNOC) .

Re v is io n: -l-8-18 RADIO LOG I CAL EMERGENCY RESPONS E PLAN AP 06 - 002 (RERP)

Info r ma t ion Use Page 13 of 108 6 . 1. 2 WCGS is located near the center of Coffey County ,

Kansas (KS) , a bout 3 . 5 miles nor t heas t of Bur l ington ,

the county seat , 90 miles southwest of Kansas City , MO and 55 miles south of the state capital Topeka , KS .

Revision : -+/--&18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 14 of 108 6.1.3 The immediat e site environs are sparsely populated.

Burl i ngton and New Strawn are the major population centers . John Redmond Reservoir (JRR) and Coffey County Lake (CCL) are the major recreational facilit i es . Most of the seasonal or daily shifts in population are associated with recreational areas around JRR and CCL . Approximately 70 % of the annual visitors to the John Redmond Reservoir and Coffey County Lake come t o the area during the summer months.

6.1. 4 The 10 - mile Plume Exposure Emergen cy Planning Zone (EPZ) is a major consideration in the RERP .

Approximately 99 % of the 10 - mile EPZ is located within Coffey County and 1 % within Anderson County . The EPZ has been defined by developing sub - zones based upon natural and political subdivisions . These have been described for evacuation zones approximating 2 , 5 and 10 - mile radial rings . This distribution allows ready identificati on of areas t o be evacuated and facilitates public re cogn iti on of subzones in which they work or reside . FIGURE 1 , EFFECTIVE 10 MILE EPZ , SUBZONES AND EVACUATION ROUTES , presents the 2 , 5 and 10-mile radi al zones and subzones which provides the basis for the design of an alert and n ot ification system .

6.1. 5 The total population of the effective 10-mile EPZ is shown in ATTACHMENT B, SUBZONE EVACUATION TIMES . With the exception of Burlington and the other population centers listed in ATTACHMENT A, EFFECTIVE 10-MILE POPULATION CENTERS , the population density of the effective 10 - mile EPZ is approximately 4.4 persons per square mile . Other than the WCGS , there are no large industries i n the area .

6.1. 6 Principal geographical features within the effective 10 - mile EPZ are the Neosho River, JRR , and CCL . The land around WCGS is flat with scattered l ow hills .

Dense vege tati on i n the form of large trees exists on the banks of the river and in recreational areas .

There are no topographical features within the effective 10 - mile EPZ that significantly influence the design of the Alert and Notification System.

1. Sparsely populated farm land comprises the majority of the effective 10 - mile EPZ.

2. The site also demonstrates favorable topography ,

demography , and meteorology, which have been factored into many analyses that support the emergency planning effort .

Revision : -+/--8-18 RADIOLOGICAL EMERGENCY RESPONS E PLAN AP 06 - 002 (RERP)

Information Use Page 15 of 10 8

3. The Neosho River is oriented northwest - southeast and extends to within 3 miles southwest of the plant.

4. The main darn of the John Redmond Reservoir is 3.5 miles west of the plant . This water conservation pool is approximately 4 miles in diameter with a surface area of 15 square miles .

5. The Coffey County Lake is approximately 7 miles long with a normal surface area of 8 square miles.

6 .1. 7 The meteorological conditions within the effective 10-rnile EPZ are characterized by a distinctly continental climate with warm humid summers and highly variable winter weather . Maritime tropical air originating over the Gulf o f Mexico is the dominant air mass from June through August . This air mass is quite humid resulting in considerable thunderstorm activity. From November through February, continental polar air dominates the climate .

6.2 Emergency Classifications

6. 2 . 1 10 CFR Part 50, Appendix E, Section IV.C, requires a classification scheme of four specific levels of emergencies . NUMARC/NESP 007 is identified within REGULATORY GUIDE 1 . 101 and is considered by the NRC as an acceptable alternative method t o that described in Appendix 1 to NUREG 0654 . [Commitment Step 3.2 . 1]

6.2. 2 An emergency class is a qualitative estimate of the status of the plant. Inputs to the emergency classification system include the status of plant systems and the levels of radiation in plant areas and effluents. However, an emergency class does not give a qualitative or quantitative estimate of the subsequent status of the plant or radioactive release.

6.2.3 The emergency classes are used by off - site authorities to determine the level of preplanned actions to be taken by their emergency organizations . Protective actions taken on behalf of members of the public are the legal responsibility of state and local government.

1. The functional interfaces between WCGS and other emergency organizations are shown in FIGURE 6 ,

EMERGENCY ORGANIZATIONS INTERFACES .

Revision : -l-&18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 16 of 108 6.2 . 4 The classification system used at WCGS is an approach that ranges from primarily event - based for Unusual Event to primarily symptom or barrier-based for General Emergencies . This is to better assure that timely recognition and notification occurs, that events occurring during refueling and co ld shutdown are appropriately covered, and that multiple events can be effectively treated .

6 . 2 .5 The Emergenc y Action Le vel s (EAL ) are contained in APF 06 - 002 - 01 , EMERGENCY ACTION LEVELS . The EAL have been developed and agreed upon by WCGS, the State of Kansas and Coffey County and approved by the NRC. [Commitment Step 3.2.1]

1. The EAL are reviewed annually by the State and County .

6. 2. 6 10 CFR Part 50, Appendix E, Section IV.C . 2 , requires licensees to establish and maintain the capability to assess, classify , and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded and shall promptly declare the emergency .

6.2.7 Each emergency classification causes certain actions to happen such as notifications, activation and evacuation .

1. An NOE requires plant personnel, the County and State to be notified. No evacuation or activation required .

2. An Alert requires plant personnel, the County and State to be notified . The Emergency Response Organization (ERO) is called out and the emergency facilities are activated . Accountability may be performed if necessary.

3. A Site Area Emergency requires plant personnel , the County and State t o be notified. The ERO is called out and the emergency facilities are activated .

The protected area is evacuated of non - responding personnel for accountability. JRR and CCL are evacuated. Accountability for site personnel is performed .

Revision : -l-&18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 17 of 108

4. A General Emergency requires plant personnel, the County and State to be notified . The ERO is called o ut and the emergency facilities are activated .

The site is evacuated of non - responding personnel .

JRR and CCL are evacuated . Accountabil i ty for s i te personnel is performed .

6.3 Emergency Measures

6. 3.1 Protective actions to minimize personnel exposure are taken when an incident has occurred , or may occur ,

which could result in a fission product barrier challenge or breach . In addition , protective actions are taken for personnel on - site for situations such as f i r es o r flooding , where personnel safety is threatened .

6.3.2 Emergency measures consist of assessment , corrective ,

and protective actions . The Shift Manager and Senior Reactor Operators assume immediate responsibility for accident assessment and mitigation. The RERP and detailed emergency actions are based on the assumption that , in an emergency , licensed operators take appropriate measures to maintain or return the facility to a safe condition , in accordance with operating license conditions and the technical specifications.

1. Callout of the ERO to augment the on - shift staff and to activate the Emergency Facilities is perf o rmed at an Alert or higher classification o r whenever augmentati o n is deemed necessary .

6. 3. 3 Immediate and Follow - up notifications made to State and County authorities provide information f o r their use in making prompt decisi o ns f o r notifying the public and ordering off - site protective actions .

1. Immediate notifications are made for each emergency classification .

2. Immediate not i fications are made to the Coffey County Sheriff dispatcher and t he Kansas Division of Emergency Management State Duty Officer within 15 minutes.

3. The notification form contains information agreed upon by WCGS , the State and County for each of the Immediate and Follow - up notifications . The following is a list of information that may be on the form :

Revision : H 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 18 of 108 o Name of facility o Date and time of classification o Classification o Release status, type of material and estimated duration

Revision: -+/--8-18 RADIO LOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 19 of 108 o Message authentication of phone call o Subzones recommended for protective actions o Meteorological conditions o Dose rates at site boundary o Event Prognosis , worsening or termination 6.3.4 Actions to protect the general public , and criteria for their implementation, are described in the State Plan.

Protective action recommendations are made to the County and State authorities.

1. ATTACHMENT E, EPA/KANSAS PROTECTIVE ACTION GU I DES ,

illustrates the EPA/Kansas PAGs for members of the public in the vicinity of WCGS and contains information typical of what may be used for the PAR guidelines . The ATTACHMEN T p r ovide s guidelines and action levels to be used to develop protective action recommendations . Wolf Creek makes PARs for releases beyond the 10 mile EPZ . County and State officials have authority to take protective actions off - site .

2. Evacuation is the normally anticipated off - si t e protective action . Sheltering may be the pre f erred protecti v e action when it will provide protection equal to or greater than evacuation. ATTACHMENT B, SUBZONE EVACUATION TIMES , contains evacuation times for the general and transient public .

3. An Alert and Notification System , made up of a number of sirens , is one means o f alerting the public . Tone Alert radios are also used for notifications .

6.3 . 5 Contact point for information concerning the County Plan , protective measures , and special needs of the handicapped is the County Emergency Management Of fi ce .

6. 3. 6 Additional resources ava ilab le for accident assessment include accident monitoring and in - plant iodine instrumentation under accident conditions . Detailed discussions of these resources and their capabilities are found in the USAR .

Revision : tt-18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 20 of 108 6.3 . 7 The Emergency Dose Calculation Program (EDC P) is a computerized method to provide dose estimates using actual or estimated meteorological data (wind speed, wind direction , degree of cloud cover , day or night determination) and radiological effluent data (actual measurements , estimated values based upon USAR source terms, or field measurements). EDCP is designed to :

[Reference Step 3 . 1 . 9]

1. Use radiological and meteorological information to provide an estimate of off -s ite exposure .

2. Be capable of estimating release rates and off -sit e exposures from off -site field team data.

containment pressure .

4 3 . Off -site dose predictions when combined with actual release duration information and meteorological data during an event , provide sufficient data to estimate the cumulative population dose resulting from the event . The actual off-site population dose is confirmed by off - site monitoring, sampling and analysis.

6.3.8 Radiological monitoring teams have a goal of 60 minutes from the declaration of Alert or greater emergency to be ready for deployment to confirm effluent readings and verify plume emission and locations .

6. 3 . 9 FIGURE 7, WCGS EMERGENCY RESPONSE FACILITIES, provides a view of the off - site area , showing the location of the EOF . FIGURE 8 , AIRBORNE PATHWAY SAMPLING LOCATIONS shows the fixed air sampling locations. FIGURE 9, DIRECT RADIATION PATHWAY SAMPLING LOCATIONS, shows the direct radiation pathway sampling dosimeter locations .

FIGURE 10, WATERBORNE PATHWAY SAMPLING LOCATIONS , shows l ocat i ons f or collecting water samples .

6 . 3 .10 At a Site Area Emergency, General Emergency, or when accountability is required , all personnel not responding to an Emergency Response Facility report to an assembly area for accountability and additional information . ERO personnel report to their assigned emergency facility . Security reports the results of accountability to the TSC.

Revision : -+/--8-18 RAD I OLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 21 of 108

Revision : -+/--8-18 RAD I OLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 22 of 108 6 . 3 . 11 IF the Exclusion Area is evacuated ,

THEN Security shall direct an inspection of the lake and land area within the Exclusion Area but outside of the Protected Area to ensu r e that all personnel not re s pond i ng to an Emergency Response Facility are evacuat e d from the Exclusion Area .

6 . 3 . 12 WCGS procedures contain decontamination instructions and guidelines . Methods for determining if the individual is a potential inhalation or ingestion contamination case are a l so provided . The Radiological Coordinator or appropriate Radiation Protection supervisory personnel will review the records generated by decontamination procedures .

1. Decontamination can be performed in the access control area of the Control Building , in the HVAC room of the TSC , and in the garage in the EOF .

2. Other decontamination areas are setup as designated by the Radiation Protection personnel on the ERO.

6 . 3 . 13 Respiratory protective d e vices and protective clothing are stored at several locations on - site and at the EOF .

The use of protective clothing and respiratory protection equipment is governed by normal WCGS procedures .

6.3 . 14 A supply of potassium iodide (KI) is maintained at the Control Room , TSC and the EOF to be used in the event that an individual may be exposed to radioiodine .

6 . 3 . 15 There are suggested levels of exposure to be accepted in emergencies . Immediate reentry may be necessary to save a life , account for missing personnel , or secure vital equipment . The Emergency Managers are ultimately responsible for exposure control and can permit the receiving of up to 5 REM per person for work activities , 10 REM for saving valuable equipment and 25 REM for lifesaving after consulting with the NRC , if feasibl e. Exposure which might exceed 25 REM, for lifesaving activities , must be approved by an Emergency Manager . Although EPA and NRC do not provide specific guidance for the upper bounds for lifesaving exposure ,

WCGS has chosen to use the following criter i a :

Revision: -l-8-18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 23 of 108

1. Emergency Managers shall not knowingly permit an ind i vidual ' s exposure to exceed 25 REM , unless it is for lifesaving activities or protection of large populations . Emergency Managers shall not knowingly permit an i ndiv i dual to enter a high dose area if the projected Total Effective Dose Equivalent (TEDE) is expected to exceed 75 REM.

o Those individuals designated to exceed 25 REM must be volunteers and be fully aware of the risks involved .

2. Emergency Managers should obtain the advice and concurrence of the Radiological Coordinators in approving additional exposure .

6 . 3 . 16 Under emergency conditions , normal exposure controls are maintained . This is ensured by the on - shift ~=~lt h Physics Radiation Protection Technician (RHP) in the Control Room , the Radiological Coordinators in the TSC and EOF.

6 . 3 . 17 The Radiological Coordinator has responsibility f or maintaining exposure control for site activities ,

including establishment of access control at alternate locations . Strict exposure control of individuals passing through the access point is maintained on a 24-hour - per - day basis .

6 . 3 . 18 In order to enhance the exposure control process and to provide dosimetry for an expanded number of people ,

dosimetry vendors are available to expedite shipment of extra dosimetry devices to supplement existing on - site supplies of dosimetry equipment and to supply personnel to assist in on-site appraisal of exposures .

6 . 3 . 19 When activated , the Emergency Response Team covers emergency sampling , surveying, analysis , and hazard evaluation .

6 . 3 . 20 Personnel , instruments , and equipment are to be monitored at the access control point . Personnel and equipment decontamination is controlled in accordance with WCGS procedures.

6 . 3 . 21 WCGS maintains control over the Exclusion Area as necessary , restoring affected on - site areas to acceptable conditions for access .

Revision : -l-8-18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 24 of 108

1. Reentry into affected areas is a controlled evolution . Surveys are performed , environmental samples are obtained and analyzed , and areas posted or decontaminated .

Revision : -+/--&18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 25 of 108 6.3 . 22 Contamination limits for food supplies and drinking water are based upon the State of Kansas Protective Action Guides.

6.4 Emergency Facilities 6 . 4.1 Control Room Facilities

1. The Control Room is designed to be habitable under emergency conditions . The Control Room contains controls, instruments , and communications equipment necessary for operation of the plant under both normal and emergency conditions. The ventilation system, shielding , and structures are designed and built to permit continuous occupancy during a postulated design basis accident .

2. Equipment available in the Control Room gives early warning and continuous evaluation of potential emergency situations. Portable radiation survey instruments are readily available within the Control Room .

3. Access to the Control Room is controlled by the Shift Manager .

6 . 4.2 Technical Support Center Facilities

1. The TSC is a brisk 2 minutes and 15 seconds walk from the Control Room inside the Protected Area.

This is sufficiently close to permit face-to-face interaction between personnel in the Control Room and the TSC, should telephone communications become inoperable.

2. The TSC is activated in the event of an Alert or higher emergency . The TSC may be activated during an NUE at the discretion of the Shift Manager .

3. The TSC is designed to the seismic criteria of the Uniform Building Code . It is designed to withstand 100 - year-recurrence winds and is located above the probable maximum flood level .

Revi s ion : -l-8-18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

I nformation Use Page 26 of 108 a . The manually activated single - train , non - seismic Category I TSC vent i lat i on system utilizes high -

efficiency particulate air and charcoal filters.

The radioiodine monitor i ng equipment in the TSC prov i des a designed min i mum detectable level of l .OE - 07 uCi/cc r ad i o i od i ne . A r ad i ation monitor (including the monitor for radioiodines) alarms to alert TSC personnel if radiation levels may affect the habitability of the TSC .

b . Portable radiation monitoring equipment is provided in the TSC for backup radiation monitoring capability.

c . Equipment for Emergency Response Teams is avai l able in the TSC . This equipment includes protective clothing , dosimetry , survey meters and respirators .

d . A diesel generator is available to provide backup power to the TSC . Until the diesel is loaded , batteries are available for Nuclear Plan t Information System (NP IS) .

e . The TSC is sized to accommodate a minimum of 25 persons and has the same radiological habitability as t he Control Room under accident conditions .

4. Personnel in the TSC have access to the following materials :

o WCGS USAR , Environmenta l Report , and Technical Specifications o Plant operating and emergency procedures o WCGS , State , and Coffey County emergency response plans o System drawings , schemat i cs , and diagrams 5 . An Alternate TSC is l ocated at the EOF . The Alternate TSC would be used in the case of a hostile action or other event impeding site access . The Al ternate TSC provides access to the same material s as the primary TSC . The Alternate TSC has the capability to:

Revision : +/-8-18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 27 of 108 o Communicate with the EOF , Contro l Room and Security personnel o Perform off - site notifications of a plant eme rgency o Perform engineering assessment activities ,

including damage control team planning and preparation 6.4.3 Operat i on s Support Cente r

1. The OSC is housed in the TSC and is activated whenever the TSC is activated.

2. The OSC serves as an assembly area f or plant personnel immediately serving in emergency repair or Health Physics Radiation Protection support capacity during an event . The OSC functions include the coordina ti on , formation and dispatch of Emergency Response Teams.

3. The basement of the Security Building has been identified as an alternate location for the OSC funct i on . It contains telephones and a Gai - Tronic call box , which will allow direct communications with the other emergency centers . Portable radios are available to key personnel to further provide communications with other emergency centers .

4. An alternative OSC muster area is included with the Alternate TSC at the EOF . The Alternative OSC muste r area would be used in conjunction with the Alternate TSC .

6.4.4 Emergency Operations Facility (EOF)

1. The EOF i s located approximately 12 mil es north northwest of WCGS , near the junction of I - 35 and US - 75 , and is activated at an Alert or higher emergency . Following facility activation , overall emer gency response is managed from the EOF .

a . This facility serves as a center for evaluation and coordination of environmental activities related to the emergency including r a diological assessment and the evaluation of pot e ntial or actual radioactive releases from the plant .

2. The EOF is a commercial building that is well engineered for the de si gn life of the p la nt .

Revi si on : -l-8-1 8 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 28 of 108 a . A diesel generator i s available to provide backup power to the EOF . Until the diesel is loaded , UPS backup is available for equipment used to access plant data upon loss of AC power .

b . The EOF is sized to accommodate at le a st 35 persons .

3. Accommodations and telephones are provided for a limi ted number of County , State and Fe de r al personnel . Facilities are provided for staging field survey efforts from the EOF .

4. The EO F serves as the base of operations for evacuation as s essments and for commun i cations with federal , state , and local response organizations .

Radio and telephone links are available to the TSC ,

and Control Room .

5. Personnel in the EOF have access to the f ollowing materials :

o WCGS USAR , Environmental Report , and Technical Specifications o Plant operating and emergency procedures o WCGS , State , and Coffey County emergency response plans o System drawings , schematics , and diagrams

6. 4. 5 Public Information Facilities

1. The Public Information Facilities include the Joint Information Clearinghouse (JIC) , Media Center (MC) ,

Phone Team , and Media Monitoring . These facilities may be established a s follows :

a . The JIC , Phone team and Media Monitoring in either the Wolf Creek Dwight D. Eisenhower Learning Center o r in Topeka at th e Kansas State Defense Building .

b . The MC in either the Wolf Creek Dwight D.

Eisenhower Learning Center or in Topeka at the Nickell Memorial Armory .

Revision : +&18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 29 of 108

2. At an NUE , information is provided to the public by Corporate Communications . The Wolf Creek Public Information Facilities may be staffed at any time, as determined by the Wolf Creek Public Information Officer , to support the distribution of information to the public.

3. The Public Information Organization activates at an Alert or higher emergency .

4. The JIC , MC , and the Phone Team are kept in close proximity to each other to facilitate coordination of information in the form of news statements , news conferences or telephone conversations .

a. Dedicated telephone lines allow contact between the JIC , TSC , and the EOF. The JIC contains status boards, appropriate office supplies ,

computer(s) , printer(s) , faxing and photocopy capabilities , and outside telephone lines.

5. The Wolf Creek PIO, the State PIO and Coffey County PIO communicate with the Public Information Coordinators (PIC) to obtain technical inf ormation .

The PIOs prepare news statements at the JIC and coordinate their efforts .

6. The MC will accommodate media representatives in an auditorium and adjoining Media Room for news conferences . The Media Room is a facility setup to provide the media with a work area , audio/visual material, outside telephone lines and public information status boards.

7. Media Monitoring and Rumor Control functions for WCGS, the State and Cof fey County are performed by members of the Public Informati on Organiza ti on .

Appropriate equipment and supplies , fax and telephone communications with the JIC are available . Approved news statements and information are transmitted to the Media Monitoring Team after the JIC is activated .

a . The Media Monitoring Team reports any rumors or misinformation heard or observed from their monitoring of the media to the JIC .

Revision : -l-8-18 RAD I OLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 30 of 108 6.4. 6 On - site Medical Facility

1. A medical facility located in the Clyde Cessna building , is staffed with a full time Licensed Practitioner . This facility is equipped to provide bas i c medical response capabilities .

2. First aid kits , emergency equipment and supplies are available to ensure that assistance can be provided to injured and/or contaminated personnel .

3. Shift personnel , trained in first aid , are available on - site 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day . Priority should be given to treating those with the most urgent medical needs .

4. In the case of contamination , efforts are made to decontaminate injured personnel on - site , as soon as practicable. However , first aid or removal of the indiv i dual from a hazardous environment , takes precedence over decontamination efforts . If decontamination is not possible , the victim is covered i n such a manner as to avoid any spread of contamination until medical aid can be obtained or hospitalization accomplished .

5. Personnel leaving the RCA are monitor e d for contamination . All personnel are monitored for contamination before leaving the site .

a . Personnel may be monitored by portal monitors or friskers when entering or leaving WCGS facilities .

b . Personnel found to be contaminated must undergo decontamination under the direction of health physics personnel using health phy s ics supplies and equipment available during routine activities . Release limits for personnel decontamination are found in the Ra diation Pr otection Manual .

Revision : -+/--8-18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 31 of 108

6. 4. 7 State and County Facilities

1. Coffey County Emergency Operations Center (County EOC) is located in the Coffey County Courthouse ,

Burlington , KS. The County EOC is a command center for county agencies and a mustering area for personnel who arrive in the WCGS area in response to an emergency. The County EOC is activated at the Alert level with the additional support staff activated upon declaration of an SAE or GE . Other centers are established as the emergency needs dictate.

2. Kansas State Emergency Operations Center (State EOC) , located in the State Defense Building, 2800 South Topeka Boulevard , Topeka , KS , is the command-and-control center for the State.

3. The State Forward Staging Area is located about 11 miles north of WCGS in the roadside park at the intersection of Old Highway 50 and U.S. 75 . When it becomes necessary for the State to dispatch emergency personnel to the plume exposure pathway emergency planning zone (EPZ), the State activates the State Forward Staging Area to serve as a secondary base of operations for state personnel and a local contact point with Coffey County .

6. 4. 8 Evacuation Registration Center

1. People in the EPZ should evacuate to the Lyon County Reception Center using I - 35 south toward Emporia, take Exit 141 for KS - 130 toward Neosho Rapids/Hartford, travel two and one - half miles and go to the Neosho Rapids Grade School.

6.5 Control Room Organization 6 . 5.1 The Shift Manager is responsible for the initial evaluation and classification of any abnormal situation and for directing the appropr i ate response , including initial activation of a callout .

1. Control Room personnel are on shift 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day.

The shift complement is shown in Figure 2 , MINIMUM SHIFT STAFFING .

Revision : -l-8-18 RAD I OLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 32 of 108 6 . 5.2 Upon declaration of an emergency , the Shift Manager assumes the duties of Emergency Manager . The Shift Manager normally goes to and remains in the Control Room unless it is necessary for him to leave the Control Room in order to perform specific a s sessment ,

correct i ve , or protective actions . The Shift Manager performs the following actions:

o Initiate appropriate technical measures to mitigate the event o Determine if releases have occurred , make the necessary assessment of the off-site concentration of rad i oactivity resulting from a release , and evacuate non - essential personnel if necessary o Direct the activities of the Control Room Emergency Notification System (ENS)/ and Off - site Communicators-o Ensure immediate and follow - up notifications are made which provide sufficient information on emergency classification , plant status , off - s ite dose projections or measurements , and issue recommendations for off - site protective actions to authorities responsible for off-site emergency measures o Ensure NRC Resident Inspector is notified as soon as possible after the State and County are notified o Ensure notifications to the NRC are made as soon as possible within 60 minutes of classification of an emergency in accordance with 10CFR50 . 72 (a) (3) o Ensure other notifications are made in accordance with EPPs o Activate on - site emergency teams if required o Notify plant personnel of the change in plant status

Revision: -l-&18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 33 of 10 8 6 . 5.3 Emergency Notification System (ENS )/Of f - site Communicator

1. The Emergency Notification System (ENS)/Off-site Communicator reports to the Shift Manager, performs initial notifications, aftl---initiates the Automatic Dialing System (ADS) or Backup ADS to callout the ERO and maintains communications with the NRC.

a. A manual callout of personnel to staff the ERO is performed if the ADS and Backup ADS are not functioning .

6. 5. 4 Emergency Notification System (ENS) ComIRunicator

1. The ENS ComIRunicator reports to the Shift Manager and maintains comIRunications with the NRG.

6 . 5. 4 Chemistry Technician

1. The Chemistry Technician reports to the Shift Manager and performs dose assessment until relieved by Dose Assessment personnel in the EOF .

6 . 5. -65 Health Physics Radiation Protection Technician

1. The Health Physics Technician reports to the Sh ift Manager and performs radiation monitoring for personnel sent from and in the Control Room .

6 . 5 . -=7- 6 Control Room Supervisor

1. Reports t o the Shift Manager and provides direction to Reactor Operators and Nuclear Station Operators for the safe operation of the unit.

6.5. 7 Reactor Operator s

1. The Reactor Operators report to the Contro l Room Supervisor and perform plant monitoring and reactor manipulations as needed from the Control Room.

Nuclear Station Operators

1. Nuclear Station Operators report to the Control Room Supervisor and perform local plant monitoring and manipulations as directed.

Revision : +/--8-18 RAD I OLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 34 of 108 6 . 5 . G- 9 Shift Technical Advisor (STA)

1. The Shift Technical Advisor reports to the Shift Manager and performs STA requirements as assigned by the NRC .

6 . 5 . -l--+/--10 Initial emergency respon s e to the major functional areas is within the capa bilities of the minimum operations shift complem ent .

6 . 5 . -+/--2-11 On - shift staff augrnentat ion is available, when deemed necessary , in accordance with ATTACHMENT D, WCGS MINIMUM STAFFING FOR EMERGENCIES .

6. 6 Technical Support Center (TSC) Organization

6. 6.1 TSC activation will be performed as soon as practical and within the times as stated in the following :

1. During off normal working hou r s , it is the goal to activate the TSC wi t hin 75 minutes of a declaration of an Alert or higher classification .

2.

of an ~lert or higher classification .

6. 6.2 The TSC is considered activated when the following positions are present , the Site Emergency Manager determines the facility is ready to activate , and declares the facility activated :

o Site Emergency Manager o TSC Operations Coordinator o TSC Administrative Coordinator o TSC Radiological Coordinator o Maintenance Coordinator

6. 6 . 3 The TSC organization is shown in FIGURE 3 , TSC/OSC ORGANIZATION .

6 . 6.4 Additional personnel to support repair efforts and recovery functions will be added as necessary .

Personnel reporting from off-site may initially report to the EOF/Alternate TSC , and then proceed to the TSC as plant/site conditions allow .

Revision : -l-&18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 35 of 108

6. 6. 5 Site Emergency Manager

1. The assigned Site Emergency Manager will assume command-and-control functions and will be the top line manager respons i b l e for the emergency . An assigned Site Emergency Manager is available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day . The assigned Site Emergency Manager may assume command-and- control functions from the Shift Manager during an NUE if so requested by the Shift Manager .

2. The Shift Manager will transfer the Site Emergency Manager duties to the assigned Site Emergency Manager i n accordanc e with EPPs . The Shift Manager resumes Control Room duties and reports to the Site Emergency Manager.

3. The Site Emergency Manager directs the on - site emergency effort , implements the applicable EPPs and , as appropriate , performs the following :

o Assess and verify the situation and assure that appropriate mitigating efforts are being taken o Review initial event classification and reclassify as appropriate o Determine the necessity f o r evacuation o f per s onnel on - site o IF a release has occurred ,

THEN make the necessary assessment of the off -

site concentration of radioactivity resulting from a release o Ensure immediate and follow - up notifications are made which provide sufficient information on emergency classification , plant status , off-site dose projections or measurements , and issue recommendations for off - site protective actions to authorities responsible for off - site emergency measures

Revision : -+/--8-18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Inf ormation Use Page 36 of 108

4. The following responsibilities are those of the Emergency Managers and may not be delegated. These responsibilities may be divided between the Site and Off-site Emergency Managers:

o Classification of the emergency o Protective action recommendations o Authorization for notification of off - site authorities o Authorization of emergency exposure in excess of 10 CFR 20 limits

6. 6. 6 TSC Operations Coordinator

1. The TSC Operations Coordinator reports to the Site Emergency Manager and is responsible for the following:

o Supervise reactor plant operations , which includes the Ope rati ons Recorder, Engineering Coordinator , Engineering Team and ENS Communica t or .

o Keep the Site Emergency Manager advised of plant condi ti on s and operational manipulations

2. The TSC Operations Coordinator may supervise other positions as directed by WCGS procedures .

6.6.7 Engineering Coo rdinat or

1. The Engineering Coordinator reports t o the TSC Operations Coordinator and directs the activities of the Engineering Team to technically assess plant status and the severity of emergency conditions .

6. 6.8 Engineering Team

1. The Engineering Team reports to the Engineering Coordinator. The Team evaluates current and historical plant parameters, assesses the severity of the emergency conditions and magnitude of fuel damage, and recommends corrective or preventive actions .

6 . 6. 9 TSC Emergency Notification System (ENS) Communicator

Revision : -l-8-18 RADIOLOG I CAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 37 of 108

1. The TSC ENS Communicator reports to the TSC Operations Coordinator and maintains communications with the NRC .

Revision : -l-&18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 38 of 108 6 . 6 . 10 TSC Radiological Coordinator

1. The TSC Radiological Coordinator reports to the Site Emergency Manager and is responsible for preventing or minimiz i ng direct exposure to , or inge s tion/inhalation of , radioactive materials during a radiological emergency . Responsibilities are as follows :

o Monitoring dBose rates and dose projections o Monitoring r Radiological survey teams ' results o Assists the On-site Emergency Manager in the formulation of recommended protective actions o Monitoring pF ersonnel radiation exposures to ensure they are maintained in accordance with 10CFR 20 limits unless otherwise authorized by the Emergency Manager o Provides radiological data and concerns to plant teams for the team briefs

2. The TSC Radiological Coordinator will transfer off -

site duties to the EOF when the EOF is activated .

6 . 6.11 TSC Administrative Coordinator

1. The TSC Administrative Coordinator reports to and assists the Site Emergency Manager to ensure that emergency notifications are performed . The TSC Administrative Coordinator is responsible for logistical support in the areas of TSC personnel, Control Room , procurement and warehouse support, communications support and equipment repair services .

2. After EOF activation , the TSC Administrative Coordinator directs requests for logistical support beyond on - site staff capabilities to the EOF Administrative Coordinator .

6 . 6.1 2 TSC Team Director

1. The TSC Team Director reports to the TSC Maintenance Coordinator and provides advice on all matters concerning Emergency Response Team activities.

Revision: -+/--8-18 RADIOLOG I CAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 39 of 108 6.6 .1 3 Maintenance Coordinator

1. The Maintenance Coordinator reports to the Site Emergency Manager and directs the Maintenance Ass i stant in the coordination of emergency team act i vities . The Maintenance Coordinator also directs the formation of teams to be assigned to search and rescue .

6 . 6.14 Operations Communicator

1. Provides data , progress and plant conditions from the Control Room via the Operations Recorders .

6.6.15 Additional Personnel

1. The following are examples of positions that are not needed for activation and operation of the TSC but supplement those personnel which are essential to an emergency response :

o Operations Recorder maintains the Operations Status Board current .

o Team Communicator reports to the Team Director and is responsible for communicating with On-site Teams .

o Emergency Response Team Members perform tasks as assigned by the Maintenance Assistant .

o Administrati v e Assistants perf o rm facility accountability , assist the Emergency Manager ,

faxing and copying , log keeping , and Off site notifications and communications as directed.

o Security Coordinator maintains a line of communicat i ons between the TSC and Security to cover security concerns .

6.7 Operations Support Center (OSC) Organization 6 . 7.1 Maintenance Assistant

1. The Maintenance Assistant rep o rts to the Maintenance Coordinator and coordinates emergency repair and damage control activities , coordinates deployment of on-site teams , and coordinates the activities of the Maintenance Planners .

Revision : -l-8-18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 40 of 108 6.7.2 Emergency Response Team (ERT)

1. The ERT personnel may be selected from Health Physics Radiation Protection Technicians (Tech) ,

Chemi stry Tech , and Instrumentation and Control ,

Mechanical , or Electrical Maintenance . The ERT reports to the Maintenance Assistant and is responsible for repairs , surveys , sampling, analysis , and search and rescue .

6. 7. 3 Additional Personnel

1. The following are examples of positions that are not needed for activation and operation of the OSC but supplement those personnel which are essential to an emergency response .

o Chemistry Technicians perform emergency chemical sampling and provide post - accident sample analysis.

o Maintenance Planners develops repair plans for u s e by the emergency repair and damage control teams~ and assists in locating and securing parts and equipment from the warehouse .

o Warehouse Support Personnel assist in locating and securing parts and equipment f r om the warehouse.

6. 8 Emergency Operations Facility (EOF) Organization 6.8.1 EOF activation will be performed as soon as practical and within a goal of 90 minutes of a declaration of an Alert or higher Emergency .

1. The EOF is considered activated when t he following positions are present , the Off - site Emergency Manager determines facility readiness , and declares the facility activated :

o Off-si te Emergency Manager o EOF Operations Coordinator o EOF Administrative Coordinator o EOF Radiological Coordinator o EOF Facility Technician

Revision : -l-&18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 41 of 108

2. The complete EOF organization is shown in FIGURE 4 ,

EOF ORGANIZATION .

Revis i on : -+/--8-18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 42 of 108 6.8.2 Off-site Emergency Manager

1. The Off-site Emergency Manager will assume the command-and- control functions and direct the emergency from EOF . An assigned Off-site Emergency Manager is available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day .

2. The Off-site Emergency Manager is the official WCGS interface with government authorities . The Manager may discuss events in progress wi th the County and State personnel present in the EOF when making decisions concerning the emergency.

Responsibilities include the following :

a . Supports and provides resources or performs tasks as requested by the Site Emergency Manager b . Directs all WCGS personnel in the EOF c . Obtains personnel and coordinates the efforts of the following :

o Emergency response personnel who perform off - site radiological surveys , plus any other personnel deemed useful for the emergency response effort o Outside contractors and vendors, such as consultants, laboratories under contract, the Nuclear Steam Supply System (NSSS) vendor , the Architect/Engineer , and regional utilities o Additional technical resources may be called in during the emergency for further support or shift assignment on-site .

d. Coordinates with the Administrative Coordinator in the logistics effort to supply the plant with the necessary personnel and equipment e . Br iefs WCGS Executive Management on mat t ers related to the emergency f . Coordinates with the On site and Off-site Public Information Coordinators (PICs ) in providing technical input for news statements

Revision : -+/--8-18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 43 of 108 g . Ensure immediate and follow - up notifications are made which provide sufficient information on emergency classification, plant status , off - site dose projections or measurements , and issue protective actions recommendations to off - site authorities responsible for off - site emergency measures h . Requests federal assistance through state officials per the State Plan

3. The following responsibilities are those of the Emergency Managers and may not be delegated. These resp onsibilit ies may be divided between the Si t e and Off - site Emergency Managers:

o Emergency classification o Pr otective action recommendations o Authorizat i on f or notification of of f-site authorities o Authorization o f emergency exposure in excess of 10CFR 20

6. 8. 3 EOF Radiological Coordinat or

1. The EOF Radiological Coordinator reports to the Off - site Emergency Manager and is responsible f or radiological monitoring and dose assessment activities off - site. Responsibilities are as follows :

o Directs and coordinates activities of the Dose Assessment Coordinator and staff o Assists the Off - site Emergency Manager in the formulati on of recommended protective actions o Provides the PIC with an assessment of radiological conditions o Requests through the EOF Administrative Coordinator additional radiation monitoring equipment , instrumentation - and Health Physics Radiation Protection support personnel as necessary

Revis i on : -l-&18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 44 of 108 o I nterfaces with State and County emergency response personnel who are assigned to the EOF regarding matters related to off - site radiological assessment

Revision : -l-&18 RADIOLOG I CAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 45 of 108 6.8. 4 EOF Team Director

1. The EO F Team Director assumes responsibility for authorizing and supervising Off-site Monitoring Teams . The EOF Team Direc t or di re c ts Eme r gency Response Teams and advises the EOF Radiological Coordinator on radiological conditi ons encountered by the Teams .

a. Off - site Moni t or i ng Team authorization should be made p r omptly upon activation of th e EOF .

b . Monitoring teams are specially trained in field sampling techniques . Each team will be equipped with equipment capable of detecting and measuring radioiodine concentrations in the air at levels as low as 10- 7 uCi/cc.

c. County and State personnel may become part of th e Emergency Response Teams and assist with off - site monitoring.

6.8 . 5 EOF Facility Technic i an 1.

is prepared Dose As sessment Coordinator

1. Reports to the EOF Radiological Coordinator and is responsible for directing/assisting withproviding completed off - site dose projections and protective action recommendations act i vities .

2. Ensures the Radiological Status Board is maintained current .

6.8 . 7 Dose ~ssessment Technician

1. Reports to and is responsible for providing comp l e t ed off site dose projections to the Do s e

~ssessment Coordinator .

HPN Communicator

1. Th e HPN Communicator reports to the EOF Radiological Coordinator and maintains communications with the NRC via the Health Physics Network (HPN) telephone.

Revision : -+/--8-18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 46 of 108 EOF Operations Coordinator

1. Reports to and briefs the Emergency Manager on plant conditions and mitigative strategies .

6 . 8. -l-G-8 EOF Administrative Coordinator

1. The Administrative Coordinator is responsible for coordinating , directing, and responding to requests from the ERO for administrative and logistical support. The techniques and procedures used during this effort are adapted from normal WCGS procurement practices . The Administrative Coordinator also ensures notifications to off - site authorities are made .

6 . 8. -l--+/--9 Representative At County

1. The Representative at the County is located in the County Emergency Operations Center in Burlington ,

KS , and reports to the Off-site Emergency Manager .

The Representative responds to requests from County personnel for clarification or verification of data received from the TSC or EOF .

6 . 8. -+/--2-10 Additional Personnel

1. The following are examples of positions that are not needed for activation and operation of the EOF but supplement those personnel which are essential to an emergency response .

o Team Communicators communicates with Off-site Monitoring Teams .

o Operations Recorders maintains the Operations Status Board current .

o Administrative Assistants perform facility accountability , assist the Emergency Manager, faxing and copying, log keeping, and Off - site notifications and communications as directed .

Revision : M 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 47 of 108 6.9 Public Information Organ izati on 6.9 . 1 The Public Information Organization is activated at an Alert o r higher emergency declaration. Information released to the public during an NUE will be provided by Corporate Communications . If deemed necessary , the Wolf Creek Public Information Facilities may be staffed to assist in releasing news statements during an NUE.

6. 9.2 Wolf Creek Public Information Officer (WC PIO)

1. The WC PIO is the public vo i ce for plant information . The WC PIO is responsible for ensuring the timely issuan ce of accurate information to the public and media during an emergency at WCGS . Public inte rac ti on may be as a formal news conference or a telephone call .

a . The WC PIO coordinates with the Coun t y and State f or information to be released t o the public .

2. The WC PIO has overall responsibility for the Public Information Organizati on .

6. 9 . 3 Wolf Creek Public Information Manager (WC PIM)

1. The Wolf Creek Public Information Manager is located i n the JIC and reports to the WC PIO . The WC PIM works closely with the WC PIO , On site PIG ,

Off - site PI C, News Writer , and Technical Support positions to ensure that information provided the public is timely and accurate .

2. The Wo l f Creek Public Information Manager has responsibility for ensuring the Public Information Organization is activated and functions as directed in EPPs .

3. During a declared emergency the Public Informati on Manager determines and coordinates the activation of the Joint I nformation Clearinghouse , Media Center , Ph one Team and Media Monitoring . The Public Information Manager operates from the appropriate Joint Information Clearinghouse .

4. The complete Public Information organization is shown in FIGURE 5 , PUBLIC INFORMATION ORGANIZATION.

Rev i sion : -l-&18 RADIOLOGICAL EMERGENCY RES PONS E PLAN AP 06 - 002 (RERP)

Information Use Page 48 of 108

6. 9 . 4 On Site Public Information Coordinator (PIG)

l. The On site PIG is located in the TSC and reports to the WC PI~!. The On site PIG gathers and transmits technical information to the Joint Information Clearinghouse for use in news statements.

6 . 9 . .§.4 Off-Site Public Information Coordinator (PIC)

1. Th e Off- s i te PI C i s l ocated i n the EOF and reports to th e WC PIM . The Off - site PIC ga t hers and transmits information related to the health and safety of the public to the Joint Information Clear i nghouse for use in news statement s.

6. 9 . -65 Media Center Manager (MC Manager)

1. The MC Manage r is located at the Media Center and reports to the WC PIM . Responsibil i ties include set - up of the Media Center , l eadership for the Media Registrar , AV Support , and Media Liaison and management of the media news conferences .

Re s ponsib i lit i es i nc l ude managing the media crowd at the Media Center and assisting the media with registrat i on and facility orientation , providing-general Wolf Creek background information or approved emergency - related information , arranging individual interv i ew s, and announcing and coordinating scheduled news con f erences . The Media Center Manager maintains contact with the Joint Information Clear i nghouse to provide news conference schedules .

6.9 . 7 Hedia Liaison

1. Media Liaison is located in the Media Center and reports to the HG Manager. Respons ibili ties include managing the media crowd at the Media Center and assisting the media with registration and facility orientation , providing general Wolf Creek background information or approved emergency related information, arranging individual interviews, and announcing and coordinating scheduled news conferences.

6 . 9 . 6 News Wri ter

Revision : -l-8-18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 49 of 108

1. The News Writer reports to and provides suppor t f or the WC PI M. The News Writer provides support to the PI O including: answering telephones , writing and distributing news statements . The News Writer maintains a c h ronolog i ca l log of t h e events and new s statements .

6 . 9 .S) 7 Phone Team Manager

1. The Phone Team Manag e r repo r ts to the WC PIM and coordinates the rumor control activities of the Phone Team .

Revision : -l-&18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 50 of 108 6 . 9 . -l-G-8 Technical Support

1. !ffie-Technical Support staff discusses technical details of the news statement with EOF staff to ensure accuracy , updates the status log, maintains the media status board and provides technical interpretation for the Wolf Creek , Coffey County ,

and State of Kansas Public Information Officers .

Technical Support gathers information from the Emergency Facilities to communicate plant , health and safety issues t o the public .

6 . 9 .11 Representative at the State

1. The Representative at the State is located in the Kansas State Emergency Operations Center in Topeka ,

KS , and reports to the WC PIO . The Representative responds to requests from State personnel for clarification or verification of information pertaining to Wolf Creek .

6 . 9 . 12 Additional Personnel

1. The following are examples of additional personnel used to fill ERO positions such as clerical , log keeping , or status board posting . Staffing of these positions does not affect the activation of the facility .

o Media Center Registrar monitors access to the Media Center , records news conference attendance , provides media packets , provides directions for telephone use and work space information to the media representatives.

o Audio/Visual Support records on video and audio tape the proceedings of news conferences presented in the Media Center .

o Information Messenger performs clerical and administrative duti es at the direction of the Public Information Manager .

o The Phone Team may make initial media notifications at PIO discretion, addresses media and public questions to the extent possible and reports rumors or misinformation to the Phone Team Manager .

Revision : -l-8-18 RADIOLOGICAL EMERGENCY RESPONS E PLAN AP 06-002 (RERP)

Information Use Page 51 of 108 o The Media Monitoring Team notifies the Phone Team Manager of any rumors or misinformation heard or observed from their monitoring of the media.

Revision : -+/--8-18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 52 of 108 6 . 10 Local Off - site Organizations 6 . 10.1 The Coffey County Contingency Plan for Incidents Involving Commercial Nuclear Power describes the authorities , responsibilities , and agreements to which various county agencies are a party in their response to emergencies at WCGS . Information is provided therein about the various agencies' interrelationships and support roles provided to WCGS .

o The updated evacuation time estimate (ETE) report contains the evacuation times for each subzone.

(Reference 3 . 1.12) 6 . 10 . 2 Coffey County Commissioners

1. The Coffey County Board of Commissioners maintains the executive authority and responsibility for planning and coordinating the county response .

They have delegated responsibilities and tasks to the local support agencies and have established operating procedures .

2. After declaring a State of Local Disaster Emergency , the Chairman of the Coffey County Commissioners is responsible for making the decision to activate the alert and notification system . Emergency authority , as stated in County Plan , is given in an established line of succession.

3. If a State of Emergency has not been declared ,

after receipt of notification and in accordance with the County Plan , the Chairman decides which protective actions would be appropriate .

o When a protective action is decided upon, the County may notify the State to activate EAS or they may activate EAS.

Revision: -+/--S-18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 53 of 108 6 . 10 . 3 Coffey County Sheriff's Office

1. The Coffey County Sheriff ' s Office provides local notification, access control , and law enforcement support in accordance with the Coffey County Plan .

2. If time does not permit , or if he is unable to contact the Chairman or other members o f the County Emergency Response Organizat ion , the County Sheriff has the authority to make protective action decisions based upon recommendations by WCGS.

3. The County Dispatcher may contact the Kansas Division of Emergency Management t o activate EAS o r they may activate EAS.

4. Specific services provided by the Coffey County Sheriff's Office include:

o Perform notifications as defined within the County Plan and associated implementing procedures o Provide a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day manning of communications links between the County and WCGS, and between the County and State o Implement o ff - site protective actions as necessary and as specified in the County Plan implementing procedures o Initiate warning and initial notification of the population o Direct the evacuation of specific subzones of the EPZ upon the decision t o evacuate o Provide traffic control and roadblocks per implementing procedures o Obtain additional assistance as necessary to secure the evacuated areas o Control access to the County EOC

Revision : -l-&18 RADIOLOGICAL EMERGENCY RESPONS E PLAN AP 06 - 002 (RERP)

Information Use Page 54 of 108 6 .1 0 . 4 Coffey County Fire District #1 (CCFD)

1. Contractual arrangements have been made with the Board of Trustees of Fire District No . 1 , Coffey County , KS, for the provision of fire fighting support . Services cont racted are summarized in the Letter o f Agreement and maintained in an Emergen cy Planning file .

2. The WCGS Fire Brigade Leader is also responsible for directing all fire fighting acti v ities on site.

Once on site , Fire District members and equipment shall be escorted by Security.

6 .1 0 . 5 Of f-site Medical Treatment

1. Coffey County Hospital and Newman Memorial Hospital each have developed emergency procedures to provide guidance in the rendering of medical treatment to contaminated patients.

2. Coffey County Hospital , loca ted in Burlington , KS ,

approximately 9 road miles from the WCGS site , has agreed to provide aid to injured/contaminated personnel.

3. Newman Memori al Hospital serves as a backup to Coffey County Hospital and is located in Emporia ,

KS , approximately 40 miles from WCGS .

4. Contaminated injured personnel transported from WCGS to off -site medical facilities are attended by personnel qualified in radiol ogical practices .

Once the patient(s) has been stabilized , WCGS personnel survey patient(s) , attending personnel, vehicles , and equipment to ensure they have been decontami nated in acc o rdance with WCGS , County , or State procedures .

6 . 10.6 Coffey County Emergency Medical Service (EMS )

1. Cof fey County EMS provides medical assistance and transports victims to medical facilities for personnel requiring treatment for injuries ,

exposure to radiation , and contamination . WCGS notifies the Ambulance Service by tel ep hon e or through the Coffey County Sheriff ' s Office .

2. If condit i ons warrant, any vehicle at WCGS may be used to transport affected personnel .

Revision : -l-&18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 55 o f 108 6 . 10.7 Radiological Emergency Assistance Center/Training Site (REAC/TS)

1. REAC/TS maintains a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Hospital Disaster Network. Consultation is available for medical emergencies involving radiologically contaminated patients.

6 . 11 State Organizations 6.11.1 The Governor , by law , is the Chief Executive Officer o f the State of Kansas and is responsible for the safety and well-being of all citizens within the State. The State Plan describes the responsibilities of local ,

federal , state , and volunteer agencies during nuclear emergencies . Upon declaration of a State of Disaster Emergency the State has primary responsibility for responding t o an off - site nuclear emergency .

Activation of the State EOC , located in the lower level of the State Defense Building , Topeka , KS , is the responsibility of the Governor or authorized representatives, depending on the nature of the emergency . The Kansas Di v i s i o n o f Emergency Management , Technological Hazards Section , provides overall coordination as the responding state agency during a Fixed Nuclear Facilities Incident .

6 . 11.2 The State of Kansas Radiological Emergency Response Plan for Nuclear Facilities describes in detail , the authorities, responsibilities , and agreements to which various state agencies of their response to emergencies at WCGS. Reference to this document is made for detailed information on each agency ' s interrelation and support role pr ov ided to WCGS .

1. Upon decla r ation of an SAE or GE representatives of Kansas Division of Emergency Management (K DEM) and Kansas Department of Health and Environment (KDHE) go to the EOF . They act as the interface between WCGS, the County , and the State .

Re vision : -l-8-18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 56 of 108 6 . 11 . 3 Kansas Division of Emergency Management (KDEM)

1. The KDEM provides the following assistance :

a . Eva l uates information presented by WCGS to dec i de off - site protective actions b . Coordinates nuclear incident response planning ,

training , and not i ficat i on . Activities include :

o Not i ficat i on of KDH E o Notification of Key federal and state agencies o No t ificat i on of the Governor ' s Of fice o Provides radiological monitoring coordination o Reques t s federal assistance and coordinates federal and state support on behalf of affected areas o Provides 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> pe r day point of contact to receive noti f ication o Activates the State EOC o Activates the Kansas Emergency Alert System 6 . 11.4 Kansas Department of Health and Environment (KDHE)

1. The KDHE provides assistance as described below :

o Acts as the lead state agency for operational radiologic a l emergency response o Conducts radiological monitoring in affected areas o Pr ovi des r a dio l ogica l advice t o hospita l s o Develops and establi s hes State PAGs o Provides information and guidance to the publ i c about p r otective actions , via the KDEM o Assesses off - site contamination of the environment

Revision : -+/--8-18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 57 of 108 o Provides technical guidance and coordination in recovery activities o Supports the development and conduct of radi ological response training o Reviews, evaluates, and maintains dosimetry records for non-licensee emergency workers and other affected individuals 6.11.5 Kansas Highway Patrol (KHP)

1. The KHP provides communications and notification support including backup notification means for the following:

o Coffey County Sheriff ' s Office o KDEM, Technological Hazards Section o The Governor's Office

2. The KHP augments local law enforcement in securing the area and establishing evacuation routes and providing traffic control.

3. The KHP provides self-support radiological monitoring.

4. The KHP maintains emergency communications systems 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day.

6 .11. 6 Kansas National Guard

1. The Kansas National Guard may be directed by the Governor to provide assistance as needed such as the following :

o Evacuation of communiti es o Area security o Media Center Security

Revision : ~ 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 58 of 108 6 . 11 . 7 Kansas Department of Transportation (KDOT)

1. KDOT provides assistance as follows:

o Provides emergency traffic barriers and signs o Supplements emergency traffic control o Supplies construction equipment o Provides communications support 6.12 Federal Organizations 6 .1 2 . 1 Should an emergency situation or accident occur at WCGS , notification and reports must be made to various federal agencies and organizations , and requests for assistance may also be made.

6 .1 2 . 2 Federal Emergen cy Management Agency (FEMA)

1. FEMA is the lead agency supporting implementation of the state and local emergency plans . Region VII FEMA response t ime is estimated to be four hours .

6 . 12 . 3 Department of Energy (DOE)

1. The DOE Radiological Assistance Program provides monitoring assistance and radiological consultation to the KDHE. The DOE provides assistance under the Nuclear / Radiological Incident Annex to the National Response Framework and responds to authorized requests for assistance by the KDHE . It is expected that initial responders , to assist with off -sit e radiological monitoring , will arrive within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> .

6 . 12 . 4 Nuclear Regulatory Commiss ion (NRC)

1. The NRC provides advice to other federal , state ,

and l oca l agencies on the radiological health consequences of va ri ous emergency protective actions . The NRC requires notification and reports as indicated in ATTACHMENT H, REPORTING OF INCIDENTS PER 10CFR20 and as specified in the WCGS Technical Specifications. NRC Region IV response time is estimated to be 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> .

Revision : -+/--8-18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 59 of 108 6.12 . 5 Licensee resources available to support the federa l response include the following :

o Space and equipment in the TSC and EOF provided for key federal personne l o Telecommunications equipment at these centers is available to federal personnel for use o Parking space adjacent to the EOF provides an area for the location of federal response vehicles , with power and sanitary services available at the EOF o Open fields west of the parking lot at the EOF provide access for helicopters o Coffey County Airport is available for air traffic 6.12 . 6 Federal Radiological Monitoring and Assessment Center (FRMAC) 1 . FRMAC is a federal asset available on request by the Department of Homeland Security (OHS) and state and local agencies to respond to a nuclear or radiological incident. The FRMAC is an interagency organization with representation from the NNSA , the Department of Defense (DOD), the Environmental Protection Agency (EPA), the Department of Health and Human Services (HHS) , Federal Bureau of Investigations (FBI), and other federal agencies .

Full Federal response (FRMAC) is expected within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> .

6 . 13 Additional Support Agencies 6 . 13 . 1 Vendor and Architect/Engineers (A/E)

1. NSSS supplier , Westinghouse , is the chief vendor who may be involved with emergency response for WCGS . Westinghouse has emergency response plans which are activated upon notice and is expected to provide the following services :

o Personnel with expertise in various areas o Technical analysis o Operational analysis o Accident/transient analysis

Revision: -+/--8-18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 60 of 108 o Recommendations

Revision: -l-&18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 61 of 108 6.13. 2 Regional Utility Support

1. WCGS shares the Standardized Nuclear Unit Power Plant System (SNUPPS) power-block design with the Union Electric Callaway Plant. Because of this design concept and s i mi larity with the WCGS layout, assistance from Union Electric is possible . A specific mutual aid agreement between WCGS and Callaway Energy Center , Ameren Missouri d/b/a Union Electric has been established. While this assistance may be available within a short period of time, it shows greatest promise in the case of a prolonged emergency where extended , around the clock coverage is required. The Site Emergency Manager may authorize the temporary use of th i s resource, should staff augmentation be necessary .

Union Electric Company is a signatory of the INPO FIXED FACILITY EMERGENCY RESPONSE VOLUNTARY ASS I STANC E AGREEMENT.

6 . 13 . 3 Institute of Nuclear Power Operations (INPO)

1. WCGS has signed the INPO FI XED FACILITY EMERGENCY RESPONSE VOLUNTARY ASSISTANCE AGREEMENT . This agreement is by and among electric utilities which have responsibility f o r the c o nstruction and operation of commercial U. S . nuclear power plants .

Assistance may be requested from any of the signat o ry companies in the form of technical and administrati v e aid or pers o nnel, fa c ility , o r equipment resources. Requested assistance is rendered acc o rding to the agreement.

6.13 . 4 American Nuclear Insurers (ANI )

1. ANI is notified at emergency classifications of Alert or higher. ANI is available to provide insurance services as necessary.

6 . 14 Plant Monitoring 6 .1 4 .1 Nuclear Pl ant Information System (NPIS)

1. The integration and display o f selected and critical data is performed by NPIS which is a non -

safety , non - Class lE system . Isolation is provided to ensure that NPIS does not degrade the performance of safety system equipment or displays .

2. NPIS provides data storage and recall capability.

Revision : -+/--8-18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 62 of 108

3. Certain parameters are also transmitted to the NRC Operations Center via the Emergency Response Data System (EROS) link of NPIS. EROS is activated through NPIS within 60 minutes of an Alert or high e r class i f i cation .

4. The NPIS computer feeds key plant parameters to individual terminals in the Control Room , TSC, and via *RTime Viewer to the EOF which display data identical in accuracy , r esolution, and rel i ability .

Support personnel may assist the Control Room staff to analyze and diagnose plant abnormalities so that mitigative action may be taken and then monitored .

5. The Safety Parameter Display System (SPDS) provides for continuous indication of plant parameters or derived variables representative of the safety status of the plant. The primary function of the SPDS is to aid the user in the rapid detection of abno r mal operating conditions. As a plant safety information and diagnostic tool , SPDS concentrates on a minimum set of plant parameters from which the plant safety status can be assessed .

6.14 . 2 On-site Radiological Monitors

1. Process monitors monitor the radiation intensity of materials within plant systems . These monitors continuously measure , indicate and record the radioactive material concentrations located within systems being monitored . Each monitor includes an adjustable alarm to provide indication of a significant change or the existence of a concentration of radioactive material above pre -

selected values . The USAR, Chapter 11.5 , includes a listing and range of plant monitors.

2. The Area Radiation Monitoring System monitors provide information about radiation intensity at specific plant locations . These monitors provide the f ollowing :

a . Warnings of excessive gamma radiation levels in areas where nuclear fuel is stored or handled b . Control Room personnel with a continuous indication of gamma radiation levels at selected locations within the various plant buildings

Revision : -l-8-18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 63 of 108 c . Assistance in detecting unauthorized or inadve r tent movement of radioactive material in the plant , including the radwaste area

d. Supplementation o f other systems , such as process radiation monitoring or leak detection ,

i n detecting abnormal migrations of radioactive material e . Local alarms to warn personnel in the area

3. Effluent monitors provide information about the concentration of radioactive material in plant effluent pathways . Each significant effluent pathway from the plant includes an effluent monitor to enable the quantification of the radioactive material concentration exiting the plant.

6 .14. 3 Meteoro l ogical Mon itoring System

1. The Meteorological Monitoring System is composed of a 90 -meter instrument tower and a temperature controlled she l ter at the base of the tower housing assoc i ated instrumentation and equipment .

2. The function of the meteorological system is to monitor and record meteorological conditions .

3. Information provided by instruments at the meteorological tower is available from the NPIS computer system .

4. Time interval measurements are used in calculating 15 - minute averages for all parameters .

5. When needed , Meteorological data can be obtained from the National Weather Service .

6 . 14.4 Seismic Monitoring System

1. The seismic warning panel in the Control Room provides local v i sual and audible indication when a seismic event has occurred .

6.14 . 5 Hydrologic Monitoring

1. Hydrologic monitoring is not requ ired as WCGS is a

" dry site " as defined by Regulatory Guide 1.102.

The plant site is located above the design basis flood level .

Revision : -l-8-18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 64 of 108 6 . 14 . 6 Fire Protection

1. WCGS is protected by an independent fire protection s ystem consisting of two subsystems , a detection/alarm system and a suppression system.

2. Activation of the fire systems results in an audible alarm throughout the plant. Alarms are also displayed in the Control Room .

6.14 . 7 Laboratory Facilities

1. A radiochemistry (hot) laboratory, radwaste laboratory, and turbine building chemistry laborat ory are located in the power block . The chemistry shop laboratory is l ocated in the Walter P . Chrysler Building . Further information on on -

site laboratory equipment can be found in USAR ,

Chapter 12.5 .

2. The chemistry shop laboratory on site may be used for processing of routine and emergency field samples . The Kansas Health and Env ironmental Laboratory in Topeka , KS , is available to further augment the processing of emergency samples .

3. Private laboratories under contract to WCGS or laborat ories of neighboring utilities who are si gnatories of the INPO Voluntary Assistance Agreement may be considered for use .

6 . 15 Emergency Supplies 6 . 15.1 Emergency supplies include protective, communications ,

and radiological monitoring equipment , check sources ,

and other supplies . The EPPs list emergency supplies and their locations .

6 . 15 . 2 Emergency supplies are maintained , inventoried , and inspected on a quarterly basis in accordance with EPPs .

The EP Ps conta in an inventory list o f WCGS equipment for emergency supplies. This equipment may be augmented by othe r on - site equipment.

6 . 15.3 Instruments are calibrated in accordance with WCGS Radiation Protection Procedures . For any items removed from the emergency supplies for calibration or repair, an operable equivalent instrument is used to replace it . Sufficient quantities of spare instruments/equipment are on site to provide replacements .

Revi s ion : -l-8-18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 65 of 108 6 . 16 Communications 6 . 16 . 1 Communication Equipment

1. Telephones provide primary communications contact with the State and County EOCs . The on - site system i n the Olive Beech Building and the off - site system in EOF are p owered by their own battery and charger . The battery will supply the system if the charge r fails .

a . The Emergency Telecommunications System (ETS) is used for NRC communications.

b . Trunk lines are available for communications with outside agencies .

c . Cell phones o r o ther comparable equipment are used as a backup means of communications with joint radiol ogical monitoring teams .

2. Radio communications provide backup communications with the State and County EOCs . Fixed AC - powered transmitter/receiver units and a number of portable and hand - held units are als o capable of providing fixed and mobile communications to joint radiological mo nit o ring teams .

a . Radio communication is the primary communication method f o r the j o int radiol o gical monitoring teams .

3. A paging system is used for initial notificati o n of key personnel . Pager coverage is provided in and around the cities o f Burlington , Empo ria, Topeka ,

Ottawa and Lawrence .

6 . 16 . 2 Communica tion Dissemination

1. The methods of employee communications may be employee meetings , announcements , or literature handouts.

2. The Public Information Organization is responsible for interfacing with the media. Communication between WCGS and media organizations are performed in accordance with EPPs .

Revision : -l-&18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 66 of 108

3. Annually , WCGS offers the news me dia with the following information :

o Information concerning the emergency plan o Information concerning rad i ation o Facilities available for media o Points of contact for statements of public information o Differences between normal and emergency plant operations

4. Standardized public announcements for broadcast during an emergency have been written by the state ,

county , and WCGS and are found in the State Plan .

5. WCGS , state , and local emergency organizations provide members of the public , including transients , public education information on how they are notified and what their init i a l actions should be during an emergency.

a . Emergency planning information is provided within local telephone directories . The information , developed jointly by WCGS , Coffey County and the State of Kansas , is distributed to residences of the EPZ.

b . Information includes educational facts on radiation , protec t ive measures , special needs of the handicapped and the points of contact for additional information .

c . An annual mail - out to the public provides information regarding operation of Tone Alert Radios .

6. Emergency planning information , displayed on informat i on boards , is provided for t r ansient s in the public us e areas of John Redmond Reservoir (JRR) , Coffey County Lake (CCL) , and other WCGS controlled areas . Transients have access to emergency plan information within motel rooms and telephone books .

Revision : -l-&18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 67 of 108 6 . 17 Emergency Plan Training 6 . 17 . 1 WCGS has developed an emergency preparedness training program which meets the requirements of 10CFR50, Appendix E, Section IV. F .

6 . 17 . 2 The Super intendent Emergency Planning ensures required training is provided for ERO personnel in accordance with plant procedures .

6.17.3 The Supe ri ntendent Emergency Planning ensures corrective actions for any Emergency Planning weakness or deficiencies identified are initiated and corrected using the WCGS corrective action process .

6 . 17 . 4 Personnel receive general RERP training as a portion of Plant Access Training prior to receiving unescorted access to WCGS .

6 . 17 . 5 Initia l and re - qualification training is provided for personne l on the ERO . This training may be in the form of self study , class room training , drills , tabletops, or any combination of these .

1. Po si tion specific tra ini ng is provided for personnel filling positions in the following areas :

o Managers/Coordinator s of the emergency o Personnel responsible for accident assessment o Radiological monitoring teams o Fi re brigade members o Emergency response teams o Medical support per s onnel o Security personnel o Support personnel

2. Critiques are performed after each training class to identify weak or deficient areas .

Revision: -l-8-18 RADIOLOGICAL EMERGENCY RESPONS E PLAN AP 06 - 002 (RERP)

Information Use Page 68 of 10 8

6. 1 7. 6 Where Letters of Agreement exist between WCGS and local agencies and for each off -si te response organization's emergency support role, training is offered annually.

Training is als o offered to the participants in the Interlocal Agreement between Coffey County and host county Lyon.

Revision : -+/--&18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 69 of 108

1. Thi s tra i ning cons i sts of an orientation to plant operations and site access procedures , basic radiation protection and monitoring information ,

procedures for notification , an overview of the ERO duties and activities , and training materials as s ociated with performance of their expected roles .

6 . 17 . 7 Drills are considered part of the Emergency Plan Training Program . Periodic drills conducted between the biennial exercise ensure that the ERO is capable of executing the principal functional areas of emergency response including activities such as management and coordination of emergency response , accident assessment , event clas si fication , notificat i on of off -

site authorities , assessment of the on - site and off -

site impact of radiological releases , protective action decision making , plant system repair and mitigative action implementation .

1. State and County participation in drills will be allowed if they so desire .

6 . 18 Emergency Plan Dr ills 6 . 18 . 1 Annual communication drills between WCGS , State and County EOCs , and field assessment teams ensure that contact can be made and that messages are comprehended .

1. Monthly communication tests verify communications with the local County and State authorities .

Communications tests are made with the NRC Headquarters via the Emergency Telecommunications System (ETS) . These tests are performed in accordance with EPPs .

6 . 18 . 2 Fire drills are conducted in accordance with plant adminis t rative procedures .

6 . 18 . 3 Annual medical emergency drills include transportation and tre a tmen t of s imulated contaminated individuals by ambulance and off - site medical treatment facilities .

6 . 18 . 4 Annual radiological monitoring drills include collection and analysis of sample media , field activit i es , and provisions for communications and record keeping .

Revision: H 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 70 of 108 6 . 18 . 5 Semi - annual Health Phys i cs drills involve response to and analysis of simulated elevated airborne and liquid samples and direct radiation measurements in the environment .

Revision : -l-8-18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 71 of 108 6 . 18 . 6 Each calendar quarter , a ca llout drill is conducted to verify the operability of the notification system .

6 .1 8 . 7 Critiques are conducted following each drill to identify and correct noted weaknesses and deficiencies .

6 .1 8 . 8 Terrorist - based- event drills will be conducted as directed by FEMA and the NRC . [Commitment Step 3 . 2.4]

6 . 19 Emergency Planning Exercises 6 . 19.1 In accordance with 10CFR50 Appendix E, Section IV.F, emergency exercises will test the adequacy of timing and content of implementing procedures and methods, test emergency equipment and communication networks ,

test the public notification system , and ensure that ERO personnel are familiar with their duties .

6 . 19 . 2 Exercises will be conducted biennially to test the on -

site and o ff - site emergency plans . Exercises ensure that the ERO is capable of executing the principal functional areas of emergency response including activities such as management and coordination of emergency resp onse , accident assessment, event classification, notification of off-site authorities, assessment of the on - site and off -site impact of radiological releases , protective action decision making , plant system repair and mitigative acti on implementation .

6 . 19 . 3 To meet NRC and FEMA requirements, the exercises are varied so as to test, at least once every eight years ,

all major components of the WCGS, State, and County plans and resp onse organ izations . The State and County actively participate in these exercises .

6.19.4 Each scenario variation shall be demonstrated at least once during the eight year exercise cycle and shall include, but not be limited to , the following :

1. Exercises should be conducted under v arious weather conditions .

2. Hostile action directed at the plant site involving the integration of off -site resources with on - site response .

3. An initial classification of or rapid esca l ation to a Site Area Emergency or General Emergency .

Revisio n: -l-&18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 72 of 108

4. No radiological release or an unplanned minimal rad i ological release that requires the site to declare a Site Area Emergency , but does not require declaration of a General Emergency .

5. Implementation of strategies , procedure s and guidance developed under 10 CFR 50 . 54(hh) (2) .

6. Start a drill or exercise between 6 : 00 p . m. and 4 : 00 a . m. Some drills or exercises should be unannounced .

7. Large radiological release requiring ingestion pathway protective act i ons beyond the 10 mile EPZ .

6.19 . 5 Terrorist - based- event exercises will be conducted as directed by FEMA and the NRC . [Commitment Step 3.2.4]

6 . 19 . 6 Designa t ed observers from federal , state , local governments , and WCGS observe the required exercises .

Certain of these observers also evaluate the exercise .

1. The Superintendent Emergency Planning has the lead respon s ibility for ensuring corrective actions associated with emergency planning are initiated .

2. Critiques are conducted following each exercise to identify and correct noted weaknesses and deficiencies.

6 . 19 . 7 Prior to an exercise a scenario package is prepared which contains the following :

o Basic objective of each exercise and appropriate evaluation criteria that support demonstration o f key skills in principle functional areas o Simulated events o Dates , time periods , places , and participating organizations o Time schedule of all initiating events o Descriptive scenario addressing the conduct of the exercise which should include public information activities , off - site fi r e department assistance ,

simulated casualties , rescue of personnel , use of protective clothing and radiological monitoring teams

Revision: -l-8-18 RADIOLOGICAL EMERG ENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 73 of 108 o Description of the arrangements for , and advance materials to be provided to official observers

Revision : -+/--8-18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 74 of 108 6 .1 9 . 8 Records of exercises conducted during the e i ght year cycle shall be maintained that document the content of scenarios used to comply with scenario variation requirements.

6. 19 . 9 The exercise scenario shall be submitted to the NRC under 10 CFR 50 . 4 at least 60 days prior to the evaluated exercise .

6.19 .1 0 Remedial exercises will be conduc ted for exercises which do not satisfactorily test the emergency response plan as determined by FEMA and the NRC .

6 . 20 Emergency Plan And Procedures Administrative Controls 6.20.1 The Qua lit y Assurance Organization is responsible for assuring that a review of the WCGS Emergency Planning and Preparedness Program will be performed , at least once every twelve months, in accordance with 10CFR 50.54(t) .

1. Personnel performing this review will have no direct responsibility for implementation of the Emergency Planning and Preparedness Program .

2. The review shall evaluate interfaces with state and local governments, licensee drills , exercises, capabi lities, procedures and emergency facilities .

3. The results of the review are reported to owner representatives and WCGS Senior Management and shall be retained for at l east five years.

4. Correction of review findings are evaluated and implemented using normal WCGS procedures .

5. The applicable portions of the review shall be made available to the State and local governments.

6.20 . 2 The Superintendent Emergency Planning ensures the coordination and documentation of RERP re views and revisions and the RERP distribution . The RERP is revised annually to incorporate changes identified during drills, exercises and the 10CFR 50 . 54(t) review.

1. The RERP and approved changes are distributed to all organizat i ons and individuals with responsibility for implementation of the RERP .

Revi s io n: -+/--&1 8 RADIO LOG I CAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

I nformation Use Page 75 of 108 6 . 20 . 3 The Superintendent Emergency Planning ensu r es emergency p l anning personnel a r e properly trained .

6.20 . 4 Action items required to be performed in a time period are allowed a 1 . 25 time s frequency g r ace pe ri od to complet e the item .

6 . 21 Recovery Plan 6 . 2 1. 1 The Recovery Pl an is activated in a progre ss ive manne r when the S i te , i f EO F not a ct i vated , or Of f- site Emergency Manager determines stab i l i zed p l ant conditions warrant the transition of the emergency r e spons e efforts to t he recovery phase.

6.21 . 2 IF a General Emergency has been reached ,

THEN NRC and KDEM concurrence shall be obtained prior to downgrading .

6 . 2 1. 3 Th e EPPs provide the general p l an s for r eentry and recovery and describe the means by which decisions to relax protective measures are r eached .

1. Evaluation of the s t atus of the three fission product barriers is used for de-escalation . As the situation improves and barriers are restored , the nex t lower level of event may be declared .

2. De - escalation may also occur if conditions have stabilized such that the potential for re -

escalation to a higher level has been removed and a con t rolled situa t ion exists . A declara t ion of de -

escalation is provided by the Emergency Manager based on known information and recommendations of the ERO .

3. Gu i de li nes are p r ov i ded fo r Reentry Te am ( s ) to per f orm surveys and monitoring activities to be employed for initial reentry .

6 . 21 . 4 During the recove r y process th e normal procedu r es employed for conf i guration con t rol , report i ng ,

interfaces with regulatory agencies and support groups ,

exposure control , environmental monitoring , and procurement of supplies and services shall be utiliz e d .

Revision : -+/--&18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 76 of 108 6 . 21 . 5 The Recovery Plan utilizes the necessary technical ,

administrative, managerial and support personnel that may be required for the recovery phase of emergency response , as determined by Site or Off-site Emergency Managers. The responsibilities and functions of the Emergency Managers and staff are detailed in the EPPs.

7.0 RECORDS 7.1 None 8.0 FORMS 8.1 APF 002 - 01, EMERGENCY ACTION LEVELS

- END -

Revision : -+/--8-18 RADIOLOGICAL EMERGENCY RESPONS E PLAN AP 06 - 002 (RERP)

Information Use Page 77 of 108 ATTACHMENT A (Page 1 of 1)

EFFECTIVE 10 - MILE EPZ POPULATION Distance (miles) And Significant Approximate Direction From The Site Population Centers Population Subzone To Population Center Burlingt on , KS 2 , 674 SW- 1 3 . 5 Southwest New Strawn , KS 394 W- 1 3 . 4 West-Northwest Waverly , KS 592 NE - 2 1 1. 5 North - Northeast LeRoy , KS 561 SE-3 11.1 South-Southeast Alicevi ll e , KS 40 SE - 2 9 . 3 Southeast Ottumwa , KS 20 NW - 1 6.8 West-Northwest Sharpe , KS 10 N- 1 2 . 4 North Jacob ' s Creek 70 W- 2 10 . 0 West The city population numbers were taken from the 20 10 census .

- END -

Rev i s i on : -l-8-18 RADIOLOGICAL EMERGENCY RESPONS E PLAN AP 0 6- 002 (RERP)

Inf o rmati o n Use Page 7 8 o f 10 8 ATTACHMENT B

( Page 1 o f 3 )

SUBZONE EVACUATION TIMES B.l Table B. l l is ts ea c h s ubzone and the population in that subzone .

TABLE B.1 POPULATION BY SUBZONE Evacuation Subzone Evacuation Zone Po2ulation Cente r (CTR) 0 - 2 132 North - 1 (N - 1) 2 - 5 27 Northeast - 1 (NE - 1) 2 - 5 48 East - 1 (E - 1) 2 - 5 62 Southeast - 1 (SE - 1) 2 - 5 57 South- 1 (S - 1) 2 - 5 45 Southwest - 1 (SW - 1) 2 - 5 2 , 854 West - 1 (W - 1) 2 - 5 480 Northwest - 1 (NW - 1 ) 2 - 5 112 North - 2 (N - 2) 5 - 10 1 63 Northeast - 2 (NE - 2) 5 - 10 682 Northeast - 3 (NE - 3) 5 - 10 115 East - 2 (E - 2) 5 - 10 54 Southeast - 2 (SE - 2) 5 - 10 124 Southeast - 3 (SE - 3) 5 - 10 662 Southeast - 4 (SE - 4) 5 - 10 45 South- 2 (S - 2) 5 - 10 81 Southwest - 2 (SW - 2) 5 - 10 137 West - 2 (W - 2) 5 - 10 167 Northwest - 2 (NW - 2) 5 - 10 149 B. 2 To tal Co ff ey County p opul at i on e quals 8 , 601 p e r sons (2010 ce nsus ) .

Effe c ti v e 10 -Mile Emer g en cy Pl a nning Zo ne Subt o tals a re as f o ll o ws :

0 Effecti v e 0 mile zo ne = 8 persons 0 Eff e ctive 2 mile z on e = 3 , 345 person s 0 Effe c ti v e 5 1 0 - mile zo n e 2 , 8 4 3 p e rs o ns 0 Effe c ti v e 0 - 1 0 - mile zo n e = 6 , 1 96 pe r s ons B. 3 Tab l e B . 2 lists e v acuat i o n confirmati o n time parame ter s.

TABLE B.2 EVACUATION CONFIRMATION TIME PARAMETERS Speed Vehicles EPZ Mi les Number Between Effo rt in Assumed Confirma t ion Location Traveled of Houses Veh i cle Ava i lable Time Houses Burlington 36 1 , 183 5 mph 105 Hrs 11 9 . 5 Hrs New Strawn 3 229 5 mph 20 Hrs 3 6 . 6 Hrs LeRoy 9 289 5 mph 43 Hr s 5 8 . 6 Hrs Waverly 7 280 5 mph 33 Hrs 4 8 . 3 Hrs Remaining 289 64 9 30 mph 80 . 5 Hrs 8 10 . 3 Hrs EPZ*

Revision : -+/--8-18 RADIOLOGI CAL EMERGENCY RESPONSE PLAN AP 06 - 00 2 (RERP)

Information Use Page 79 of 108 ATTACHMENT B (Page 2 o f 3)

SUBZONE EVACUATION TIMES

• Includes the evacuation confirmation of the U. S . Army Corps of Engineers areas at John Redmond Reservoir , Coffey County Lake , and the U. S . Fish and Wildlife Service area north of the Neosho River .

Revision : -l-&18 RAD I OLOG I CAL EMERGENCY RESPONS E PLAN AP 06 - 002 (RERP)

Information Use Page 80 of 108 ATTACHMENT B

( Page 3 of 3)

SUBZONE EVACUATION TIMES B. 4 Coffey County has Letters of Agreement or Mutual Aid Agreements with surrounding medical transport groups and the Coffey County Public Transp o rtat i on to assist with transportation for non -

ambu l atory persons . For all transportat i o n - dependent people ,

including the non - ambulatory occupants of the Burlington Life Care Center , Sunset Manor Nursing Home , and the Coffey County Hospital, an e v acuation time of 2 . 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> is estimated us i ng area resources .

B. 5 Tables B . 3 and B. 4 list the 10-mile e v acuati o n times f o r a v erage and adverse weather conditi o ns .

TABLE B . 3 TABLE B.4 10-MILE EVACUATI ON TIMES 1 0 - MILE EVACUATI ON TIME S FOR AVERAGE WEATH ER FOR ADVERSE WEATHER CONDITIONS (HOURS) CONDITIONS (HOURS)

Subzone Effective 10 - mile Subzone Ef fective 10 - mile CTR 1 : 20 CTR 2 : 00 CCL 1 : 20 CC L 2 : 00 JRR 1 : 20 JRR 2 : 00 N- 1 1 : 30 N- 1 2 : 15 NE - 1 1 : 20 NE - 1 2 : 00 E- 1 1 : 25 E- 1 2 : 00 SE - 1 1 : 25 SE - 1 2 : 00 S- 1 1 : 30 S- 1 2 : 15 SW- 1 1 : 45 SW - 1 2 : 25 W- 1 1 : 45 W- 1 2 : 25 NW- 1 1 : 45 NW - 1 2 : 25 N- 2 1 : 45 N- 2 2 : 20 NE - 2 1 : 40 NE - 2 2 : 20 NE - 3 1 : 30 NE - 3 2 : 05 E- 2 1 : 35 E- 2 2 : 10 SE - 2 1: 35 SE - 2 2 : 10 SE- 3 1 : 45 SE- 3 2 : 25 SE - 4 1 : 40 SE- 4 2 : 20 S- 2 1 : 45 S- 2 2 : 25 SW - 2 1 : 50 SW- 2 2 : 30 W- 2 1 : 50 W- 2 2 : 25 NW- 2 1 : 40 NW- 2 2 : 25

- END -

Revision : 18 RADIOLOG I CAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Inf o rmation Use Page 81 of 108 ATTACHMENT C

( Page 1 of 8)

CROSS REFERENCE BETWEEN NUREG 065 4 , RERP , & WCGS PROCEDURES 0654 RERP Comments Procedure Section Section A. - ASSIGNMENT OF RESPONSIBILITY (Organization Control)

l. a 6 . 5, 6 . 6, WCGS on - site and off - EPP 06 - 002 , TECHNICAL SUPPORT 6.8, 6. 9 site organizations CENTER OPERATIONS EPP 06 - 003 , EMERGENCY OPERATION FACILITY OPERAT I ONS EPP 06 - 004 , PUBLIC INFORMATION ORGANIZATION

l. a 6 . 10 , Outside organ i zations 6 . 11 ,

6 . 12 ,

6 . 13

l. b 6.5 -

6 . 13

1. C FIGURE 6 l.d 6 . 5, 6 . 6, EPP 06 - 001 , CONTROL ROOM 6 . 8, 6 . 9 OPERATIONS EPP 06 - 002 , TECHNICAL SUPPORT CENTER OPERATIONS EPP 06 - 003 , EMERGENCY OPERATION FACILITY OPERATIONS l.e 6.5.2 Notifications are made from the control room , at the direction of the Site Emergency Manager .

2.a & 2.b N/A

3. ATTACH . G

4. 6.8.2 Off - site Emergency EPP 06 - 003 , EMERGENCY OPERATION Manager FACILITY OPERATIONS 6 . 6 . 11 , Administrative EPP 06 - 002 , TECHNICAL SUPPORT 6 . 8 . 10 Coordinators CENTER OPERATIONS EPP 06 - 003 , EMERGENCY OPERATION FACILITY OPERATIONS B. - ON- SITE EMERGENCY ORGANIZATION

1. 6. 5, EPP 06 - 001 , CONTROL ROOM Figure 2 OPERATIONS

2. 6.5.2 Site Emergency EPP 06 - 001 , CONTROL ROOM Manaqe r OPERATIONS

3. 5 . 1.1, Transfer of control EPP 06 - 001 , CONTROL ROOM 5 . 2 . 1, from the Shift OPERATIONS

6. 5.2, Manager to the Site EPP 06 - 002 , TECHNICAL SUPPORT

6. 6.5, Emergency Manager . CENTER OPERATIONS

6. 6. 5 . 1, EPP 06 - 003 , EMERGENCY OPERATION 6.8.2 FACILITY OPERATIONS

Re v isi on : 18 RAD I OLOGI CAL EMERGENCY RES PONS E PLAN AP 06 - 00 2 (RERP )

In f o r ma t i o n Us e Page 82 of 108 ATTACHMENT C (Page 2 of 8)

CROSS REFE RENC E BETWEE N NUREG 0654 RERP- & WCGS PROC EDURES 0654 RERP Comments Procedure Se cti on Se ction I B . - ON-SITE EMERGENCY ORGANIZATI ON

4. 6.5.2, Resp o nsibilities of the EPP 06 - 001 , CONTROL ROOM

6. 6.5, Shift Manager , Site OPERATIONS 6.8. 2 Emergen cy Manager , Off - EPP 06 - 002 , TECHNICAL SUPPORT site Emergency Manager CENTER OPERATIONS EPP 06 - 003 , EMERGENCY OPERATION FACILITY OPERAT I ONS 5 6 . 5, 6 . 6, Major ERO positions and EPP 06 - 001 , CONTROL ROOM 6.7, 6 . 8, their functions OPERATIONS 6.9 EPP 06 - 002 , TECHNICAL SUPPORT CENTER OPERATIONS EPP 06 - 003 , EMERGENCY OPERATION FACILITY OPERATIONS

6. 6 . 5, 6 . 6, Interfaces between WCGS 6 . 7, 6. 8, and outs ide 6 . 9 , Fig . organ i zations 5 & 6 7a . 6 . 8 . 11 Administrative EP P 06 - 003 , EMERGEN CY OP ERATION Coordinator FACILITY OPERATIONS 7b . 6 . 21 Re covery Plan EPP 06 - 003 , EMERGENCY OPERATION FACILITY OPERATIONS 7c . 6.8.2 Duty Emergency Manager EPP 06 - 003 , EMERGENCY OP ERATION FACILITY OPERATIONS 7.d 6.9 8fl s:i:1::e & Off - site EPP 06 - 002 , TECHNICAL SUPPORT Public Information CENTER OPERATI ONS Coordinator & Wolf EPP 06 - 003 , EMERGENCY OPERATION Creek Public FACILITY OPERATIONS Information Officer EPP 06 - 004 , PUBLIC INFORMATION ORGANIZATION

8. 6 . 13 Specify contractors I organizations available on r equest

9. 6 . 10 Identify local support aqencies C. - EMERGENCY RES PONSE SUPPORT AND RESOURCES

l. a 6.8.2 Persons authorized to request assistance l.b 6 . 12 Expe cted Federal resources

l. c 6. 4.1, Space is provided for

6. 4.2, NRC personnel in the 6 . 4. 4, Control Room , TS C, and 6 . 12 . 5 EOF . The EOF also has limited space for state and local personnel .

2a . N/A 2 .b 6 . 8 . 12

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 83 of 108 ATTACHMENT C (Page 3 of 8)

CROSS REFERENCE BETWEEN NUREG 0654. RERP & WCGS PROCEDURES 0654 RERP Comments Procedure Section Section C. - EMERGENCY RESPONSE SUPPORT AND RESOURCES

3. 6.14.7 Identify radiological laboratories

4. 6.13 and Identify other ATTACH G facilities and organizations which could assist D. - EMERGENCY CLASSIFICATION SYSTEM

1. 6.2 Emergency EPP 06-005, EMERGENCY Classifications CLASSIFICATION

2. 6.2 Initiating conditions EPP 06-005, EMERGENCY CLASSIFICATION

3. & 4. N/A E. - NOTIFICATION METHODS AND PROCEDURES

1. 6.3.3, Notifications EPP 06-007, EMERGENCY 6.5.2, NOTIFICATIONS 6.6.5, 6.8.2

2. 6.16.1, Notification of EPP 06-015, EMERGENCY RESPONSE 6.5.3 responding personnel ORGANIZATION CALLOUT

3. 6.3.3,. Initial notifications EPP 06-007, EMERGENCY 6.5.2, NOTIFICATIONS 6.6.5, 6.8.2 4 .a thru 6.5.2, Follow-up Notifications EPP 06-007, EMERGENCY 4.n 6.6.5, NOTIFICATIONS 6.8.2

5. N/A

6. 6.10.3, Evacuation times 6.3.4.3, Attach B

7. 6.16.2.4 F. - EMERGENCY COMMUNICATIONS l.a 6.5 l.b 6.5.2 l.c 6.5.2, 6.5.4, 6.6.5, 6.6.9, 6.8.2 l.d 6.4.4, 6.16 l.e 6.5.3, ERO Callout EPP 06-015, EMERGENCY RESPONSE 6.16.1 ORGANIZATION CALLOUT

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 84 of 108 ATTACHMENT C (Page 4 of 8)

CROSS REFERENCE BETWEEN NUREG 0654 RERP. & WCGS PROCEDURES 0654 RERP Comments Procedure Section Section F. - EMERGENCY COMMUNICATIONS

1. f 6. 4. 4, EPP 06-001, CONTROL ROOM 6.5.2, OPERATIONS 6.5.4, EPP 06-002, TECHNICAL SUPPORT 6.6.9, CENTER OPERATIONS 6.16.1 EPP 06-003, EMERGENCY OPERATION FACILITY OPERATIONS

2. 6.10.6

3. 6.15, EPP 06-018, MAINTENANCE OF 6.18.1, EMERGENCY FACILITIES AND 6.18.6 EQUIPMENT/COMMUNICATION CHECKS G. - PUBLIC EDUCATION AND INFORMATION

1. 6.16.2

2. 6.17.5, 6.17.6 3.a 6.4.5, EPP 06-004, PUBLIC INFORMATION 6.16.2 ORGANIZATION 3.b 6.4.5 4.a 6.9.2 EPP 06-004, PUBLIC INFORMATION ORGANIZATION 4 .b 6.9.2, EPP 06-004, PUBLIC INFORMATION

6. 9.11 ORGANIZATION

4. C 6. 4. 5, EPP 06-004, PUBLIC INFORMATION 6.9.10 ORGANIZATION

5. 6.16.2 H. - EMERGENCY FACILITIES AND EQUIPMENT

1. 6.4.2, EPP 06-002, TECHNICAL SUPPORT 6.4.3, CENTER OPERATIONS

6. 6, 6.7

2. 6. 4. 4, EPP 06-003, EMERGENCY OPERATION 6.8 FACILITY OPERATIONS

3. 6.8 Establish EOF.

4. 6.6.1, 6.8.1, Fig.2,3,4 ATTACH. D 5.a 6.14.3, 6.14.4, 6.14.5 5.b 6. 4 .1, EPP 06-011, EMERGENCY TEAM 6.4.2, FORMATION AND CONTROL 6.14.2 5.c 6.2.2, 6.14.2 5.d 6.14.6 6.a 6.14.1

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 85 of 108 ATTACHMENT C (Page 5 of 8)

CROSS REFERENCE BETWEEN NUREG 0654. RERP. & WCGS PROCEDURES 0654 RERP Comments Procedure Section Section I H. - EMERGENCY FACILITIES AND EQUIPMENT 6.b 6.14.1, EPP 06-011, EMERGENCY TEAM Figure 8 & FORMATION AND CONTROL Figure 9 6.c 6 .. 14. 7

7. 6.15 EPP 06-011, EMERGENCY TEAM FORMATION AND CONTROL

8. 6.14.3

9. 6.4.3 EPP 06-002, TECHNICAL SUPPORT CENTER OPERATIONS

10. 6.15 EPP 06-018, MAINTENANCE OF EMERGENCY FACILITIES AND EQUIPMENT/COMMUNICATION CHECKS

11. 6.15

12. 6.14.7 EPP 06-011, EMERGENCY TEAM FORMATION AND CONTROL I. - ACCIDENT ASSESSMENT

1. 6.2 APF 06-002-01, EMERGENCY ACTION LEVELS

2. 6.3.8, EPP 06-017, CORE DAMAGE 6.14.2 ASSESSMENT METHODOLOGY 3.a 6.3.7 EPP 06-012, DOSE ASSESSMENT 3.b 6.3.7 EPP 06-012, DOSE ASSESSMENT

4. 6.3.7 EPP 06-012, DOSE ASSESSMENT

5. 6.14.3

6. 6.3.7 EPP 06-012, DOSE ASSESSMENT

7. 6.3.8, EPP 06-011, EMERGENCY TEAM

6. 8. 4 FORMATION AND CONTROL

8. 6.3.7,

6. 5. 2, 6.6.5, 6.8.2

9. 6. 4. 2, Lower bound for

6. 4. 4 iodine measurement capability is 1.0E-7uCi/cc.

10. 6.3.7 EPP 06-012, DOSE ASSESSMENT

11. 6.3.8 EPP 06-011, EMERGENCY TEAM FORMATION AND CONTROL J. - PROTECTIVE RESPONSE 1.a thru 6.3.10, EPP 06-010, PERSONNEL 1.d 6. 3.11, ACCOUNTABILITY AND EVACUATION 6.6.5

2. 6.3.10, 6.3.11, Figure 1

Revision:* 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 86 of 108 ATTACHMENT C (Page 6 of 8)

CROSS REFERENCE BETWEEN NUREG 0654 RERP. & WCGS PROCEDURES 0654 RERP Comments Procedure Section Section J. - PROTECTIVE RESPONSE

3. 6. 3. 9, 6.3.12, 6.4.8,

4. 6. 3. 9, 6.3.12

5. 6.3.10, EPP 06-010, PERSONNEL 6.3.11, ACCOUNTABILITY AND EVACUATION 6.6.5 6.a thru 6.3.13, EPP 06-013, EXPOSURE CONTROL AND 6.c 6.3.14 PERSONNEL PROTECTION EPP 06-011, EMERENCY TEAM FORMATION AND CONTROL

7. 6.3.3 EPP 06-006, PROTECTIVE ACTION RECOMMENDATION

8. Attach. B

9. N/A 10.a & Fig. 1 10.b 10.c 6 .1. 6, 6 .1. 7, 6.10.2 10.d & N/A 10.1 10.m 6. 3. 4. 2 EPP 06-006, PROTECTIVE ACTION RECOMMENDATION

11. & 12. N/A K. - RADIOLOGICAL EXPOSURE CONTROL 1.a thru 6.3, 1.g 6. 4. 6, 6.10.5, 6.10.6

2. 6.3.15, EPP 06-001, CONTROL ROOM 6.3.16, OPERATIONS 6.5.2, EPP 06-002, TECHNICAL SUPPORT 6.6.5, CENTER OPERATIONS 6.8.2 EPP 06-003, EMERGENCY OPERATION FACILITY OPERATIONS 3.a & 3.b 6.3.16, 6.3.17, 6.3.18, 6.4.2, 6.15.1

4. N/A 5.a & 5.b 6.3.20, 6.3.21

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 87 of 108 ATTACHMENT C (Page 7 of 8)

CROSS REFERENCE BETWEEN NUREG 0654, RERP, & WCGS PROCEDURES 0654 RERP Comments Procedure Section Section 6.a thru 6.3.21, 6.c 6.3.22, ATTACH. E

7. 6.3.13,

6. 4. 6 L. - MEDICAL AND PUBLIC HEALTH SUPPORT

1. 6.10.5

2. 6. 4. 6

3. N/A

4. 6.10. 6 M. - RECOVERY AND REENTRY PLANNING AND POST-ACCIDENT OPERATIONS

1. 0 6.21

2. 6.21 EPP 06-008, RE-ENTRY, RECOVERY,

3. 6.21 AND TERMINATION OPERATIONS

4. 6. 3. 7 This is not specifically identified as a post-accident function N. - EXERCISES AND DRILLS 1.a & 1.b 4 .1 7, 6.19 2.a 6.18 2.b 6.18.2 2.c 6.18.3 2.d 6.18.4 EPP 06-009, DRILL AND EXERCISE 2.e(l) 6.18.5 REQUIREMENTS 2.e(2) 6.18.5 3.a thru 6.19.5 3.f

4. 6.19.4

5. 6.19.4

0. - RADIOLOGICAL EMERGENCY RESPONSE TRAINING 1.a 6.17 1.b N/A

2. 6.17.2, EPP 06-021, TRAINING PROGRAMS 6.17.4

3. 6. 4. 6

4. 6.17. 4

5. 6.17 P. - RESPONSIBILITY FOR THE PLANNING EFFORT: DEVELOPMENT, PERIODIC REVIEW AND DISTRIBUTION OF EMERGENCY PLANS

1. 6.17

2. 5.3, 6.17.2

3. 6.20.2

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 88 of 108 ATTACHMENT C (Page 8 of 8)

CROSS REFERENCE BETWEEN NUREG 0654. RERP. & WCGS PROCEDURES 0654 RERP Comments Procedure Section Section P. - RESPONSIBILITY FOR THE PLANNING EFFORT: DEVELOPMENT, PERIODIC REVIEW AND DISTRIBUTION OF EMERGENCY PLANS

4. 6.20.2

5. 6.20.2

6. 6.10, 6.11

7. ATTACH. C

8. Table of Contents and ATTACH. C

9. 6.20.1

10. 6.20.2

- END -

Revi s ion : -l-&TBD RADIOLOGI CAL EMERGENCY RESPONSE PLAN AP 06 - 00 2 (RERP)

Inf o rmation Use Page 89 of 1 08 ATTACHMENT D (Page 1 of 2)

WCGS MI NIMUM STAFFING FOR EMERGEN CIE S (Refe rence Step 3.1.10/Step 3 . 1 . 11/)

Capability For Additions : **

FUNCTIONAL AREA Cl) POSITION TITLE OR EXPERTISE ON SHIFT 60 mins 90 mins Plant Operations & Shift Manager (SRO) 1 - -

Assessment of Control Room Supervisor (CRS) 1 - -

Opera tional Aspects Reactor Ope rator (RO) 2 - -

Nuclear Station Operator Jf}7*** - -

Emergency Direction Site Emergency Manager l* - -

and Control Noti f ication/ Emergency Communicat o r ~l 3 -

Communicat i on Radiological Accident Off - site Emergency Manager and Assessment & Support staff - - 5 o f Operational Accident Assessment Sr . Health Physies Radiation - 1 -

Protection Expertise H-P----RP Personnel ~2 ~6 -

Chemistry Personnel ~l 1 -

Plant System Shift Technical Advisor l**** - -

Engineering , Repair &

Mitigative Actions Co re / Thermal Hydraulics Eng . - 1 -

Electrical Eng . - 1 -

Mechanical Eng . - 1 -

Radwaste Operat o r l* - -

Me c hanical Maint . - ~l -

Electrical Maint . l* ~l -

I&C Technician - 1 -

Protective Acti o ns H-P----RP Personnel l* 42 -

( In-Plant )

Fire fighting = Fire -- FB per TRM Local Local Brigade (FB ) (TRS . 2 . 1.b Suppo rt Suppo rt

)

Rescue Operations and -- 2* Local Local First Aid Support Suooort Site Access Control Secu r ity Personnel All per and Accountability Security Plan TOTAL +16 fl l9 5

• May be provided by shift per s onnel assigned to other functions .

• • It is a goal to add , in accordance with this table , to the on - shift capabilities when determined necessary after a declared Emergency .

• • • May be pr o vided by a Reactor Operator (RO) .

• • • • STA is required in Modes 1- 4 . An SRO capable of performing STA functions is r equired in Modes 5 , 6 and defueled .

Cll Discipline - specific skills training for personnel in the above table are contained in discipline - specific training documents such as AP 30D- 006 ,

CHEMISTRY TRAINING PROGRAM and AP 30D- 100 , RAD I ATION PROTECTION TRAINING PROGRAM . Emergency Plan training is contained in EPP 06 - 021 , TRAINING PROGRAMS .

[Commitment Step 3.2.5]

Re v i s i o n: -l-&TB D RA DI OLOG I CAL EMERG ENCY RE S PONS E PLAN AP 06 - 002 (RERP )

Information Use Page 90 of 108 ATTAC HMENT D

( Page 2 o f 2)

WCGS MINIMUM STAFFING FOR EMERGENCIES

- END -

Re v isi o n: -l-&TBD RADI OLOG I CAL EMERG EN CY RESPONS E PLAN AP 06 - 002 (RE RP)

I nformati o n Use Page 91 of 10 8 ATTACHMENT E

( Page 1 o f 3 )

EPA / KANSAS PROTECTIVE ACTI ON GUIDES E.1 Popula ti o n Pro te c ti ve Act i on Guide s (PAG) For Exposu r e To A Pl ume - Ea rl y Phas e Protective Action PAG (Projected Dose) Comments Evacua t ion 1 - 5 rem (Note 1) Evacuation (o r sheltering s h ou l d no r mally b e initiated a t 1 r em .

Admi nistrat i on of stable 5 rem (Note 3) Special Populat i on s iodine (Note 2)

(1) Dose is TEDE , wh i ch includes effective dose equiva l ent from e xternal and i nt er nal sou rc e s and committed effect i ve dose equival e nt f r om i nha l ation .

Committed do se equivalents to the t hyro i d and to the s kin may be 5 and 50 times large r , r espectively .

(2) Use of KI is not planned for general population in Kansas . The State considers prompt e vacuation of the public to b e a more effect i ve protective mea s ure th a n admi nis t ration of KI.

(3) Committ ed dose equival e nt to b e thyroid f rom r adioiodine .

E. 2 Emergency Wo rker Do se Limits (f o r all t ypes o f radi o l o gi c al i nc ide nts )

E. 2 . 1 Keep a l l doses ALARA and limi t doses to t h e f o l lowing TEDE levels :

Dose Limit (Re m) Activi t y Cond ition 5 All 10 Protecting valuable Lower dose not property practicable 25 Life saving or protection Lower dose not of large populations practicabl e

>25 Li fe sav i ng or prot e ction On l y on a voluntary basis o f large populations to persons fully aware of the risks involved E. 3 Emerg e ncy Worke r I o di ne Dos e Limi ts E. 3 . 1 Keep all d o ses ALARA and l imit i o dine doses to the fo l l owing c ommi tted dose equivalent through use o f KI a nd/or r es p i ra t ory p r otect i o n :

Dose Limit (Rem) Activity 10 Any worker , any phase No Limit - Li f e saving No specific upper limit i s given for thyroid dose activ i t i es or p r otection s ince i n life sav i ng activi ti es , comp l ete thyroid o f la r ge populations lo ss mi ght be an acceptabl e s acrific e i f a life can be saved . However , this shoul d no t be nece s sary i f respirators and/or thyroid protections for rescue personnel are available as a result of adequate planning .

Rev i sion : -l-&TBD RAD I OLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 92 of 108 ATTACHMENT E (Page 2 of 3)

EPA/KANSAS PROTECTIVE ACTION GUIDES

Revision: 8-TBD RADIOLOGICAL EMERGENCY RESPONS E PLAN AP 06 - 002 (RER P )

Informati o n Use Page 93 o f 108 ATTACHMENT E (Page 3 of 3)

EPA /KANSAS PROTE CTIVE ACTION GUIDES E. 4 Protective Action Guides For Ex p o sure To Deposited Radioactivity During the Intermediate Phase of a Nuclear Incident Protective Action PAG (Projected Dose) (1) Comments Relocate the general > 2 rem Beta dose to skin may be population (2) up to 50 times higher .

Doses in any single year after the first will not exceed 0 . 5 rem , and the cumulative dose over 50 years will not exceed 5 rem .

Apply simple dose <2 rem These protective actions reduction techniques (3) should be taken to reduce doses to as low as practicable levels (1) The projected sum of effective dose equivalent from external gamma radiation and committed effective dose equivalent from inhalation suspended materials ,

from exposure or intake during the first year . Projected dose refers to the dose that would be received in the absence of shielding from structures of the application or dose reduction techniques. These PAGs may not provide adequate protection for some l ong- live r adionuclides .

(2) Persons previ ous l y evacuated from areas outside the relocation zone defined by this PAG may return to occupy their res i dences . Cases involving relocation of persons at high risk from such action (e . g . patients under intensive care) should be evaluated individually .

(3) Simple dose reducti on techn i ques include scrubbing and/or flushing hard surfaces , soaking or plowing soil , minor removal of soil from spots whe r e radioactive materials have concentrated , and spending more time than usual indoors or in other low exposure rate areas .

- END -

Revision: -l-&TBD RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP )

Information Use Page 94 of 108 ATTACHMENT F (Page 1 of 2)

USAR CHAPTER 15 POSTULATED EVENTS USAR CHAPER 15 POSTULATED EVENTS Feedwater system malfunctions that result in decrease of feedwater temperature Feedwater system malfunctions that result in increase of feedwater system flow Excessive increase in secondary steam flow Inadvertent opening and failure to close of SG ARV or safety vlv Steam system piping failure (inside containment)

Steam system piping failure (outs ide conta inment )

Loss o f external load (Main Generator trip)

Turbine Trip Inadvertent closure of MSIVs Loss of condenser vacuum & other events resulting in turbine trip Loss of non - emergency AC power to station auxiliaries Loss of normal feedwater Feedwater system pipe break Partial loss of forced RCS flow Complete loss o f for ced RCS flow RCP shaft seizure (l ocked rotor)

RCP shaft break Uncontrolled RCCA bank withdrawal from a subcritical of low-power startup condition Uncontrolled RCCA withdrawal at power RCCA misalignment Startup of ina ct ive RCP at an incorrect temperature eves malfunction resulting in a decrease in the boron concentration in the RCS Inadvertent loading and operation o f a fuel assembly in improper position RCCA ejection accidents Inadvertent ECCS operation at power eves malfunction that increases RCS inventory I nadvertent open ing , with failure to close, of pressurizer safety or relief valve Break in instrument line or other lines from RCS pressure boundary that penetrate containment SG tube rupture LOCA spectrum Radioactive waste gas decay tank failure Postulated radioactive releases due to liquid tank failure Fuel handling accident ( inside containment)

Fuel handling accident ( Fuel Building)

Spent fuel cask drop Anticipated transients without scram

Revis i on: -l-&TBD RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 95 of 108 ATTACHMENT F (Page 2 of 2 )

USAR CHAPTER 15 POSTULATED EVENTS

- END -

Revi si on : -l-&TBD RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 96 of 108 ATTACHMENT G (Page 1 of 1)

LETTERS OF AGREEMENT Party :

The Coffey County Sheriff ' s Office Board of Trustees Fire District No . 1 , Coffey County , KS Newman Memorial Hospital Coffey County Hospital and EMS Topeka Air Ambulance Inc . (d . b . a . Life Star)

AirMD , LLC d/b/a Life Team Wolf Creek Nuclear Operating Corporation/Callaway Energy Center ,

Ameren Missouri d/b/a Union Electric Co . Emergency Mutual Assistance Agreement INPO (Support During an Emergency)

Department of Energy**

Nuclear Regulatory Commission**

National Weather Service***

EPRI/INPO/NEI/Member Utilities Coordination Agreement on Emergency Information****

Westinghouse Law Enforcement*****

• As of January 1 , 1987 , the Letters of Agreement in this Supplement are transferred from Kansas Gas and Electric Company to the Wolf Creek Nuclear Operating Corporation . These Letters of Agreement are maintained on file and may be reviewed upon request .

• • These LOAs will no t be updated . They h a ve been superseded by the publication of the " Federal Radiological Emergency Response Plan " in the Federal Register on 11/8/85 .

• • • As of 8/25 / 93 , the Nati onal Weather Se rvi ce stated in writing that a Letter of Agreement with WCGS is unnece ss ary . Their " National Plan for Radiological Emergencies at Commercial Nuclear Power Plants ,"

November 1982, remains in effect .

• • • • INPO 03-001 , INPO Letter Of Agreement , is maintained on the INPO web page .

• • • • • Agreements with Law Enforcement are safeguards information and ,

therefore , are controlled by Security .

- END -

Revis i on : -l-8-TBD RADIOLOG I CAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 97 of 108 ATTACHMENT H (Page 1 of 1)

REPORTING OF INCIDENTS PER 10 CFR 2 0

.2202 I Telephone & Telegraph .2203 Written Immediate Notification 24 Hour Notification 30 Dav Notification RADIATION INCIDENTS VALUES WCGS NRC KDEM WCGS NRC KDEM WCGS NRC KDEM TEDE 25 REM (.25 Sv) X X X X X X 5 REM (.05 Sv) X X X X X X MPE . 1201 X X X X Shallow dose to 250 Rad X X X X X X skin or extremities 50REM X X X X X X in excess of MPE .1201 X X X X Lens dose 75 REM (.75 Sv) X X eq ui valent 15 REM (.15 Sv) X X X MPE . 120 1 X X X The release of 5 ALI X X X X X X radioactive IALI X X X X X X material inside or MPE .120 1 X X X X outside of a restricted area X Indica t es notif i c a tion is required MP E Maximum Permissi ble Exposure DAC Derived Air Concentration WCGS Wolf Creek Generat i ng Station NRC Nuclea r Regulatory Commission KDEM Kansas Division of Emergency Management ALI Annua l Limit on I ntake

- END -

Rev isi on : ~ TBD RADIO LOGICAL EMERGENCY RES PONSE PLAN AP 06 - 002 (RERP)

Information Use Page 98 of 108 FIGURE 1 EFFECTIVE 10 - MIL E EPZ , SUBZONES AND EVACUATION ROUTES

, I

, , , J I

, , I *. Q I I Q I , ., I, , Q I l // I Q

,,~

Q I p

' I Q

Q l' l  ;

~

~

I / I ,, I I mr1t_

~ i I # ~ $

~~+ iaIMHl ~ [1 1

J

...... JI ~

~

I *t I I II I \

1'1T1'1*o D'D*o NW-2~ N-2

, - tL -- ~~ -- -

Ha ll's I

I 5 I I -r--

mm,

--. I I _L__J 21STM>

1 e --<--+-1 NE-3 l ffHIIO I '.-, ~, I- ,"T"!- ;a.:, *-****** ;-,r C"' r---t--.1

- -; r-- - i - - - ~

rr To Neosho Ripids Regktration Center

\ \ \ \ \ \ \ \ . \l, ) \ \ l,

\ \I \ \\\\\\\ \

l, l, l, " l, l, \ t l,

l, \ l, l,

\

, " l, t,

l, l, I

l, l, I

- END -

Revision : -+/--&TBD RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 99 of 108 FIGURE 2 MINIMUM SHIFT STAFFING NOTE STA is required in Modes 1-4. An SRO capable of performing STA functions is required in Modes 5, 6 and defueled .

SHIFT MANAGER (SM)

(1 SRO) .-------,

I I

I ENS COMMUNICATOR I

( 1) ~ I SHIFT TECHNICAL ADVISOR (STA)

( 1)

OFFSITE COMMUNICATOR I

( 1) ~ I I

I I

I

,, I I

I CONTROL ROOM SUPERVISOR (CRS)

(1 SRO) .------'

REACTOR OPERATORS (RO) _. STATION OPERATORS (2) (5)

-- CHEMISTRY TECHNICIAN (2)

-- HEALTH PHYSICS TECHN ICIAN (3)

. Direction Techn ica l Guidance SRO = Senior Reactor Operator STA= Sh ift Techn ical Advisor

- END -

Revision : -l-&TBD RAD I OLOGICAL EMERG ENCY RESPONS E PLAN AP 06 - 002 (RERP)

Inf o rmation Use Page 100 of 10 8 FI GURE 3 TSC/OS C ORGANIZATI ON SI TE EMERGENCY MANAGER RADIOLOGICAL MAINT ENANCE ADMINISTRATIVE OPERATIONS COORDINATOR COORDINATOR COORDINATOR COORDINATOR

- FACILITY TECHNICIAN

- MAINTENANCE PLANNER ADMINISTRATIVE ASSISTANT

- ENS COMMUNICATOR

- TEAM DIRECTOR

- WAREHOUSE SUPPORT SECURITY COORDINATOR

>-- - OPERATIONS RECORDER TEAM MAINTENANCE . .. . . .. .. ... .. *- ENGINEERING

~

COMMUNICATOR

- ASSIS TANT COORDINATOR LOCATED IN C;:ON'I'ROI.. ROOM I

EMERGENCY

.... . RESPONSE OPERATIONS ENGINEERING COMMUNICATOR TEAM TEAM

- END -

Revision : -l-8-TBD RADIOLOG I CAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 101 of 108 FI GURE 4 EOF ORGANIZATION OFF-SITE EMERGENCY MANAGER OPERATIONS RADIOLOGICAL ADMINISTRATIVE COORDINATOR COORDINATOR COORDINATOR OPERATIONS HPN FACILITY ADMINISTRATIVE RECORDER COMMUNICATOR TECHNICIAN ASSISTANT DOSE ASSESSMENT TEAM DIRECTOR COORDINATOR I

DOSE ASSESSMENT TECHNICIAN - TEAM COMMUNICATOR LOCATED AT COUNTY EOC EMERGENCY RESPONSE TEAM REPRESENTATIVE AT COUNTY

- END -

Revision : -l-&TBD RAD I OLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 102 of 108 FI GURE 5 PUBLIC INFORMATION ORGANIZATION KGE/KCPU COFFEY COUNTY WOLF CREEK STATE OF FEMA PUBLIC NRC PUBLIC KEPCo PUBLIC PUBLIC KANSAS PUBLIC INFORMATION INFORMATION REPRESENTATI INFORMATION INFORMATION INFORMATION OFFICER OFFICER VE OFFICER OFFICER OFFICER (JIC) (JIC)

(JIC) (JIC) (JIC) (JIC)

WOLF CREEK PUBLIC REPRESENTATIVE INFORMATION TO THE STATE MANAGER (SEOC)

(JIC)

I I I ONSITE PUBLIC TECHNICAL INFORMATION NEWS WRITER INFORMATION SUPPORT MESSENGER (JIC) COORDINATOR (JIC) (JIC)

(TSC)

I OFFSITE PUBLIC PHONE TEAM MEDIA CENTER INFORMATION MANAGER MANAGER COORDINATOR (JIC) (MC)

(EOF)

MEDIA LIAISON (MC)

MEDIA PHONE TEAM MONITORING (JIC)

TEAM MEDIA REGISTRAR (MC)

AUDIO VISUAL SUPPORT (MC)

- END -

6

H ,::,

l (I)

EMERGENCY ORGANIZATIONS INTERFACES rt, 0

H I-' *

{/)

3 I-'*

.* . . . . . . .~

(AT UNUS UAL EVENT LEVE L)

CONTROL ROOM OJ rt I-'

• 0 0

..::l

l C:

t t-3

• (AT ALERT OR HIGHEF CLASSIFICATION)

{/)

(I) ttJ 0

• TECH NICAL/OPE RATIONS ~

• * * * *

• I tr]

SUPPORT CENTER 3: 0 tr] H

• * ,::, 0 t-<

MEDIA Gl 0

• ON SITE ONSITE MONITORING PHON E TEAM

• tr]

z Gl H

OFFSITE OFFSITE TEAM * ()

()

i

::,

0 t-<

• I I ,::,

Gl tr]

rrJ

i

::, H 3:

• EMERGEN CY OP ERATION S INFORMATI ON CLEARINGHOUSE

• z (j)

~ tr]

H tr] FACI LITY (EOF) C: tr] Gl z *

• MEDIA CENTER

• N

i

::, ,::, ,::, tr]

0

• I t-3 t:rl H

0 m

-z

'1:J

()

I I I I z H

tr]

COUNTY STATE OTHER z (/)

'1:J EMERGENCY EMERGENCY OFFSITE t-3 USNRC LOCAL tr] 0 OPERATIONS OPERATIONS SUPPORT SUPPORT ,::, z

(/)

CENTER CENTER rrJ tr]

i

::,

()

I tr]

U)

'1:J t-<

i

::,

OTHER z SUPPORT STATE FEMA

'1:J AGENCIES OJ lQ (I)

i

::,

NORMAL INTERFACE f-' '1:J 0

w 0

• *

• TE MPORARY INTERFACE 0

m I

rt, 0

• Any of these functions may be activated at any emergency classification level. 0 f-' N 0

00

Revision : ~ TBD RADIOLOG I CAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 104 of 108 FIGURE 7 WCGS EMERGENCY RESPONSE FACILITIES

~ I I~

ti

!cp I; ~  ::i Ii~

~~

i 3'

n~ (EJJ;m J

'-=:J__

0 t-w C HI 1111 0 II. "

w .,§ 0

1 - END -

Revision : -+/--&TBD RADIOLOGICAL EMERG ENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 105 of 108 FI GURE 8 AIRBORN E PATHWAY SAMPLING LOCAT I ONS Q

D N E

• FIXED SAMPLING LOCATIONS

- END -

Revision : -+/--8-TBD RAD I OLOGICAL EMERG ENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 106 of 108 FIGURE 9 DIRECT RADIATION PATHWAY SAMPLING LOCATIONS Q C D

N E

• DOSIMETER LOCATIONS

- END -

Revision : -+/--8-TBD RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 107 of 108 FIGURE 10 WATERBORNE PATHWAY SAMPLING LOCATIONS Q C D

N E WATERBORNE PATHWAY SAMPLING LOCATIONS e = DRINKING WATER A = SURFACE WATER

• = GROUND WATER * = SHORELINE SEDIMENT

Revision : +/--8-TBD RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Information Use Page 108 of 108 FIGURE 11 FIXED SIREN SITING 2!!TH RD. 28TH RD 27TH AO. 27TH RD TO (~PORIA.

OLD HWY. 50 26TH RO.

TO GAANETT 25TH ~D I rNV. 31 24TH f1D. 24TH AO ZJRO RO 1f.iTH RO.

14TH AD.

E 13TH AD.

101.25 TO GARl'ETT 12TH AD 11TH RD 10TH RD F

1ST AD SIREN LOCATIONS END END

Enclosure II to WO 18-0016 Revised Procedure AP 06-002, Radiological Emergency Response Plan (RERP)

(107 pages)

1 FCREEK NUCLEAR OPERATING CORPORATION AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN (RERP)

Responsible Manager SUPERINTENDENT EMERGENCY PLANNING Revision Number TBD Use Category Information Administrative Controls Procedure Yes Management Oversight Evolution No Program Number 06

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 1 of 105 TABLE OF CONTENTS SECTION TITLE PAGE

1. 0 PURPOSE ~

2.0 SCOPE 3

3.0 REFERENCES

AND COMMITMENTS 4 4.0 DEFINITIONS 5 5.0 RESPONSIBILITIES 11 6.0 PROCEDURE 12 6.1 Site Description 12 6.2 Emergency Classifications 15 6.3 Emergency Measures 17 6.4 Emergency Facilities 24 6.4.1 Control Room Facilities 24 6.4.2 Technical Support Center Facilities 24 6.4.3 Operations Support Center 26 6.4.4 Emergency Operations Facility (EOF) 26 6.4.5 Public Information Facilities 27 6.4.6 On-site Medical Facility 29 6.4.7 State and County Facilities 30 6.5 Control Room Organization 30 6.6 Technical Support Center (TSC) Organization 33 6.7 Operations Support Center (OSC) Organization 38 6.8 Emergency Operations Facility (EOF) Organization 39 6.9 Public Information Organization 45 6.10 Local Off-site Organizations 49 6.10.2 Coffey County Commissioners 49 6.10.3 Coffey County Sheriff's Office 50 6.10.4 Coffey County Fire District #1 (CCFD) 51 6.10.5 Off-site Medical Treatment 51 6.10.6 Coffey County Emergency Medical Service (EMS) 51 6 .10. 7 Radiological Emergency Assistance Center/Training Site (REAC/TS) 52 6.11 State Organizations 52 6.11.3 Kansas Division of Emergency Management (KDEM) 53 6.11.4 Kansas Department of Health and Environment (KDHE)53 6.11.5 Kansas Highway Patrol (KHP) 54 6.11.6 Kansas National Guard 54 6.11.7 Kansas Department of Transportation (KDOT) 55 6.12 Federal Organizations 55 6.12.2 Federal Emergency Management Agency (FEMA) 55 6.12.3 Department of Energy (DOE) 55 6.12.4 Nuclear Regulatory Commission (NRC) 55 6.12.4 Nuclear Regulatory Commission (NRC) 56 6.13 Additional Support Agencies 56 6.13.1 Vendor and Architect/Engineers (A/E) 56 6.13.2 Regional Utility Support 58 6.13.3 Institute of Nuclear Power Operations (INPO) 58 6.13.4 American Nuclear Insurers (ANI) 58 6.14 Plant Monitoring 58

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 2 of 105 TABLE OF CONTENTS SECTION TITLE PAGE 6.14.1 Nuclear Plant Information System (NPIS) --sg--

6.14.2 On-site Radiological Monitors 59 6.14.3 Meteorological Monitoring System 60 6.14.4 Seismic Monitoring System 60 6.14.5 Hydrologic Monitoring 60 6.14.6 Fire Protection 61 6.14.7 Laboratory Facilities 61 6.15 Emergency Supplies 61 6.16 Communications 62 6.16.1 Communication Equipment 62 6.16.2 Communication Dissemination 62 6.17 Emergency Plan Training 64 6.18 Emergency Plan Drills 66 6.19 Emergency Planning Exercises 68 6.20 Emergency Plan And Procedures Administrative Controls 71 6.21 Recovery Plan 72 7.0 RECORDS 73 8.0 FORMS 73 ATTACHMENT A EFFECTIVE 10-MILE EPZ POPULATION 74 ATTACHMENT B SUBZONE EVACUATION TIMES 75 ATTACHMENT C CROSS REFERENCE BETWEEN NUREG 0654, RERP, & WCGS PROCEDURES 78 ATTACHMENT D WCGS MINIMUM STAFFING FOR EMERGENCIES 86 ATTACHMENT E EPA/KANSAS PROTECTIVE ACTION GUIDES 88 ATTACHMENT F USAR CHAPTER 15 POSTULATED EVENTS 91 ATTACHMENT G LETTERS OF AGREEMENT 93 ATTACHMENT H REPORTING OF INCIDENTS PER 10 CFR 20 94 FIGURE 1 EFFECTIVE 10-MILE EPZ, SUBZONES AND EVACUATION ROUTES 95 FIGURE 2 MINIMUM SHIFT STAFFING 96 FIGURE 3 TSC/OSC ORGANIZATION 97 FIGURE 4 EOF ORGANIZATION 98 FIGURE 5 PUBLIC INFORMATION ORGANIZATION 99 FIGURE 6 EMERGENCY ORGANIZATION INTERFACES 100 FIGURE 7 WCGS EMERGENCY RESPONSE FACILITIES 101 FIGURE 8 AIRBORNE PATHWAY SAMPLING LOCATIONS 102 FIGURE 9 DIRECT RADIATION PATHWAY SAMPLING LOCATIONS 103 FIGURE 10 WATERBORNE PATHWAY SAMPLING LOCATIONS 104 FIGURE 11 FIXED SIREN SITING 105

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 3 of 105 1.0 PURPOSE 1.1 The purpose of the Wolf Creek Generating Station (WCGS)

Radiological Emergency Response Plan (RERP) is to classify emergencies, assign responsibilities for actions, and to establish the lines of authority and communications to protect the public and plant personnel in the event of an emergency.

2.0 SCOPE 2.1 The RERP has been developed in accordance with 10CFR Part 50, Paragraph 50.47 and Appendix E, Regulatory Guide 1.101 and generally follows the guidelines of NUREG 0696 and 0654. The RERP is sensitive to a broad spectrum of emergency conditions which have been postulated for a commercial pressurized water reactor. Although the probability of an accident is low, the RERP is maintained to assure the safety and well-being of plant personnel and members of the public in the vicinity of WCGS.

2.2 The RERP interfaces with several related documents such as the Administrative Procedures (APs) and Emergency Plan Procedures (EPPs). Detailed instructions necessary to support the RERP are included in these procedures and are available for training, drill, and actual emergency use. The RERP references the WCGS Fire and Security Plans, Vendor contingency plans as well as those of medical support facilities and the Institute of Nuclear Power Operations (INPO). This document has been designed to coordinate with the State Emergency Operations Plan and the Coffey County Contingency Plan for Incidents Involving Commercial Nuclear Power, which govern the activities of these support groups in response to events at WCGS.

2.3 The RERP is based on a graduated, escalating level of emergency response which is activated as conditions at the plant warrant.

This approach provides the flexibility necessary to ensure adequate emergency response to a spectrum of possible events.

The RERP is designed to control emergency response activities ranging from initial event detection, classification of the event, notification of off-site authorities and providing protective action recommendations to the county and state.

2.4 The RERP reflects three chief phases of activation. First the response is dominated solely by the site staff, next the on-site and off-site public information facilities are jointly activated, and finally the recovery efforts are performed by site, public information facilities, vendor, and other critical support groups.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 4 of 105 2.5 The WCGS normal operating organization and its functional responsibilities are described in the WCGS Technical Specifications, Administrative Procedures, Human Resources company organization charts and the WCGS Updated Safety Analysis Report (USAR). No further discussion of the normal operating organization is contained within the RERP.

2.6 The WCGS design bases accidents and various plant systems are listed and described in the WCGS Technical Specifications and USAR. No further discussion of these accidents or systems is contained within the RERP.

2.7 The owners of WCGS do not respond to the site during emergency events for augmentation. The Wolf Creek Nuclear Operating Corporation organization functions from the site during normal everyday operations.

3.0 REFERENCES

AND COMMITMENTS 3.1 References 3 .1.1 Coffey County Contingency Plan for Incidents Involving Commercial Nuclear Power (County Plan) 3 .1. 2 The State of Kansas Radiological Emergency Response Plan for Nuclear Facilities 3.1. 3 Updated Safety Analysis Report (USAR) 3 .1. 4 NUREG 0654, Criteria For Preparation And Evaluation Of Radiological Emergency Response Plans And Preparedness In Support Of Nuclear Power Plants 3 .1. 5 NUREG 0696, Functional Criteria For Emergency Response Facilities 3 .1. 6 NUREG 0737, Clarification Of TMI Action Plan Requirements 3 .1. 7 Title 10, Code Of Federal Regulations, Part 50 3 .1. 8 Regulatory Guideline 1.101 3 .1. 9 Regulatory Guide 1.145

3. 1. 10 PIR 2002-1524, Minimum Staffing Requirements

3. 1. 11 Wolf Creek On-Shift Staffing Analysis

3. 1. 12 Wolf Creek Generating Station Development of Evacuation Time Estimate (October 2012)

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 5 of 105 3.2 Commitments 3.2.1 RCMS #93-325, Emergency Action Levels Converted To NUMARC EALs 3.2.2 APF 06-002-01, EMERGENCY ACTION LEVELS, required to have a 50.54(q) review performed for each revision.

3.2.3 RCMS #05-115, NRC Regulatory Guide 1.101 Guidance Definitions 3.2.4 RCMS #05-118, NRC Bulletin 2005-02 Guidance For Drills And Exercises 3.2.5 CR 00086306, Minimum Staffing Requirements not Met 4.0 DEFINITIONS 4.1 Administrative Procedures (APs) 4 .1.1 Procedures which provide programmatic responsibilities and are typically used to solve problems, assemble documentation, process information, and present results of administrative functions.

4 .1. 2 Administrative procedures control activities affecting quality or nuclear safety.

4.2 As Low As Reasonably Achievable (ALARA) 4.2.1 Making every reasonable effort to maintain exposures to radiation as far below dose limits as is practical, consistent with the purpose for which the licensed activity is undertaken, taking into account the state of technology, the economics of improvements in relation to benefits to the public health safety, and other societal and socioeconomic considerations.

4.3 Alert

4. 3 .1 Events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the Environmental Protection Agency (EPA) Protective Action Guideline (PAG) exposure levels. [Commitment Step 3.2.3]

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 6 of 105 4.4 Assessment Actions 4.4.1 Those actions taken during or after an accident to obtain and process information that is necessary to make decisions to implement specific emergency measures.

4.5 Coffey County Emergency Operations Center (County EOC)

4. 5 .1 The base of operations for the Coffey County Emergency Response Organization.

4.6 Consultant/Vendor

4. 6 .1 The Nuclear Steam System Supplier (NSSS),

Architect/Engineer, and other organizations who have available multidiscipline teams ready to support emergency response and Recovery Operations.

4.7 Control Room

4. 7 .1 The location at the WCGS from which the reactor and its auxiliary systems are normally controlled.

4.8 Drill 4.8.1 A supervised activity used to develop and maintain skills. On the spot correction of erroneous performance is permitted.

4.9 Emergency Action Levels (EALs)

4. 9 .1 Radiological dose rates; specific contamination levels of airborne, waterborne or surface-deposited concentrations of radioactive materials; or specific instrument indications that may be used as thresholds for designating a particular class of emergency.

4.10 Emergency Alert System (EAS) 4.10.1 A coordinated network of broadcasters (e.g. Radio, Television, Cable) that allows the President to address the nation, Governors to address their State and public safety officials to address local citizens with emergency information.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 7 of 105 4.11 Emergency Classification 4.11.1 A system used to define the severity of emergencies into one of four categories based upon projected or confirmed emergency action levels. Classifications listed in order of increasing severity are Notification of Unusual Event (NUE), Alert, Site Area (SAE) and General Emergency (GE).

4.12 Emergency Operations Facility (EOF) 4.12.1 This facility serves as a base of operations for all emergency plant support activities, site environmental surveillance, communications with supporting agencies, and the WCGS Emergency Organization.

4.13 Emergency Plan Procedures (EPPs) 4.13.1 Specific procedures providing step-by-step actions to implement the WCGS Radiological Emergency Response and Recovery Plans, and to provide guidance to improve or terminate an emergency situation.

4.14 Evacuation Registration Center 4.14.1. Facility designated for receiving personnel evacuating the Emergency Planning Zone (EPZ) for accountability, contamination monitoring and decontamination.

4.15 Exclusion Area 4.15.1 That area within a 1200-meter radius of the Containment Building in which WCGS has the authority to determine all activities including exclusion or removal of persons and property from the area.

4.16 Executive Management 4.16.1 Those members of WCGS management at the vice president level and above.

4.17 Exercise 4.17.1 An event that simulates a radiological emergency condition, incorporates the integrated capability of the basic elements existing within the Radiological Emergency Response Plan (RERP). These events are normally evaluated by FEMA / NRC.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 8 of 105 4.18 General Emergency (GE) 4.18.1 Events are in process or have occurred which involve actual or imminent substantial core degradation or melting with the potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility. Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels off-site for more than the immediate site area. [Commitment Step 3.2.3]

4.19 Hostile Action 4.19.1 An act toward a Nuclear Power Plant (NPP) or its personnel that includes the use of violent force to destroy equipment, take hostages, and/or intimidates the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, projectiles, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (e.g., violent acts between individuals in the owner controlled area). [Commitment Step 3.2.3]

4.20 Hostile Force 4.20.1 One or more individuals who are engaged in a determined assault, overtly, or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction. [Commitment Step 3.2.3]

4.21 Immediate Notification 4.21.1 Notification made to State of Kansas and Coffey County authorities within 15 minutes of a declared emergency at WGCS.

4.22 Joint Information Clearinghouse (JIC) 4.22.1 The facility where news statement and news conference materials for the media are prepared.

4.23 Kansas State Emergency Operations Center (State EOC) 4.23.1 The command-and-control center for the state.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 9 of 105 4.24 Licensed Operators 4.24.1 WCGS Reactor Operators and Senior Reactor Operators who are licensed under 10CFR55 and who stand watches on shift and report to the Shift Manager.

4.25 Media Center (MC) 4.25.1 Facility utilized as a focal point for giving information to the media through news conferences.

4.26 Notification of Unusual Event 4.26.1 Events are in process or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring off-site response or monitoring are expected unless further degradation of safety systems occurs. [Commitment Step 3.2.3]

4.27 Off-site 4.27.1 Any area outside the Exclusion Area of WCGS.

4.28 On-site 4.28.1 Any area inside the Exclusion Area of WCGS.

4.29 Operations Support Center (OSC) 4.29.1 A staging area for emergency teams to support the emergency response effort.

4.30 Owner Controlled Area 4.30.1 Property contiguous to the reactor site and acquired by fee, title or easement for Wolf Creek Generating Station for which public access is limited.

4.31 Protective Actions 4.31.1 Those emergency measures taken before or after a release of radioactive material has occurred for the purpose of preventing or minimizing radiological exposures to personnel.

4.32 Protective Action Guides (PAGs)

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 10 of 105 4.32.1 Guides promulgated by the Environmental Protection Agency (EPA) which set dose limits for the evacuation of the public during an accident condition at a nuclear power plant.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 11 of 105 4.33 Radiologically Controlled Area (RCA) 4.33.1 An area to which access is controlled by WCGS for purposes of protection of individuals from exposure to radiation or radioactive materials.

4.34 Recovery 4.34.1 Post-emergency efforts initiated to restore WCGS to full operation or place the plant in a safe shutdown condition until full operation can be resumed.

4.35 Site Area Emergency (SAE) 4.35.1 Events are in process or have occurred which involve an actual or likely major failure of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts; (1) toward site personnel or equipment that could lead to the likely failure of or; (2) that prevent effective access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.

[Commitment Step 3.2.3]

4.36 Technical Support Center (TSC) 4.36.1 The TSC serves as a center outside of the Control Room that acts in support of the command-and-control function and houses the OSC organization. Plant status and diagnostic information are available at this location for use by technical and management personnel in support of reactor command-and-control functions.

5.0 RESPONSIBILITIES 5.1 Site Emergency Manager 5 .1.1 Assumes command and control of the emergency and directs on-site response to stabilize plant conditions.

5.2 Off-site Emergency Manager 5.2.1 Assumes command and control of the emergency and interfaces with off-site agencies.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 12 of 105 5.3 Superintendent Emergency Planning 5.3.1 Ensures the Emergency Planning and Preparedness Program is implemented and maintained as required to protect the health and safety of the public.

5.3.2 Ensures changes to the overall Emergency Planning and Preparedness Program meets the standards of 10CFR50.47(b) and the requirements of 10CFR50, Appendix E.

5.4 Manager Quality 5.4.1 Ensures a review of the WCGS Emergency Planning and Preparedness Program will be performed at least once every twelve months in accordance with 10CFR 50.54(t).

5.5 President and Chief Executive Officer 5.5.1 Maintains overall authority and responsibility for the WCGS Emergency Preparedness Program.

5.6 Public Information Officer (PIO)

5. 6.1 The PIO has the authority and responsibility for the WCGS Public Information Organization and all plant information disseminated to the media.

5.7 Shift Manager (SM) 5.7.1 The Senior Reactor Operator designated by WCGS management with immediate on-site authority and responsibility for the safe and proper operation of the plant. This position is staffed at all times. The Shift Manager is responsible for the initial evaluation of any abnormal or emergency situation and for directing the appropriate response. He assumes responsibilities of the Emergency Manager until relieved.

6.0 PROCEDURE 6.1 Site Description 6 .1.1 WCGS is a Pressurized Water Reactor (PWR) nuclear generating station operated by Wolf Creek Nuclear Operating Corporation (WCNOC).

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 13 of 105 6 .1. 2 WCGS is located near the center of Coffey County, Kansas (KS), about 3.5 miles northeast of Burlington, the county seat, 90 miles southwest of Kansas City, MO and 55 miles south of the state capital Topeka, KS.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 14 of 105 6.1.3 The immediate site environs are sparsely populated.

Burlington and New Strawn are the major population centers. John Redmond Reservoir (JRR) and Coffey County Lake (CCL) are the major recreational facilities. Most of the seasonal or daily shifts in population are associated with recreational areas around JRR and CCL. Approximately 70% of the annual visitors to the John Redmond Reservoir and Coffey County Lake come to the area during the summer months.

6.1.4 The 10-mile Plume Exposure Emergency Planning Zone (EPZ) is a major consideration in the RERP.

Approximately 99% of the 10-mile EPZ is located within Coffey County and 1% within Anderson County. The EPZ has been defined by developing sub-zones based upon natural and political subdivisions. These have been described for evacuation zones approximating 2, 5 and 10-mile radial rings. This distribution allows ready identification of areas to be evacuated and facilitates public recognition of subzones in which they work or reside. FIGURE 1, EFFECTIVE 10 MILE EPZ, SUBZONES AND EVACUATION ROUTES, presents the 2, 5 and 10-mile radial zones and subzones which provides the basis for the design of an alert and notification system.

6.1.5 The total population of the effective 10-mile EPZ is shown in ATTACHMENT B, SUBZONE EVACUATION TIMES. With the exception of Burlington and the other population centers listed in ATTACHMENT A, EFFECTIVE 10-MILE POPULATION CENTERS, the population density of the effective 10-mile EPZ is approximately 4.4 persons per square mile. Other than the WCGS, there are no large industries in the area.

6.1.6 Principal geographical features within the effective 10-mile EPZ are the Neosho River, JRR, and CCL. The land around WCGS is flat with scattered low hills.

Dense vegetation in the form of large trees exists on the banks of the river and in recreational areas.

There are no topographical features within the effective 10-mile EPZ that significantly influence the design of the Alert and Notification System.

1. Sparsely populated farm land comprises the majority of the effective 10-mile EPZ.

2. The site also demonstrates favorable topography, demography, and meteorology, which have been factored into many analyses that support the emergency planning effort.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 15 of 105

3. The Neosho River is oriented northwest-southeast and extends to within 3 miles southwest of the plant.

4. The main dam of the John Redmond Reservoir is 3.5 miles west of the plant. This water conservation pool is approximately 4 miles in diameter with a surface area of 15 square miles.

5. The Coffey County Lake is approximately 7 miles long with a normal surface area of 8 square miles.

6.1.7 The meteorological conditions within the effective 10-mile EPZ are characterized by a distinctly continental climate with warm humid summers and highly variable winter weather. Maritime tropical air originating over the Gulf of Mexico is the dominant air mass from June through August. This air mass is quite humid resulting in considerable thunderstorm activity. From November through February, continental polar air dominates the climate.

6.2 Emergency Classifications 6.2.1 10 CFR Part 50, Appendix E, Section IV.C, requires a classification scheme of four specific levels of emergencies. NUMARC/NESP 007 is identified within REGULATORY GUIDE 1.101 and is considered by the NRC as an acceptable alternative method to that described in Appendix 1 to NUREG 0654. [Commitment Step 3.2.1]

6.2.2 An emergency class is a qualitative estimate of the status of the plant. Inputs to the emergency classification system include the status of plant systems and the levels of radiation in plant areas and effluents. However, an emergency class does not give a qualitative or quantitative estimate of the subsequent status of the plant or radioactive release.

6.2.3 The emergency classes are used by off-site authorities to determine the level of preplanned actions to be taken by their emergency organizations. Protective actions taken on behalf of members of the public are the legal responsibility of state and local government.

1. The functional interfaces between WCGS and other emergency organizations are shown in FIGURE 6, EMERGENCY ORGANIZATIONS INTERFACES.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 16 of 105 6.2.4 The classification system used at WCGS is an approach that ranges from primarily event-based for Unusual Event to primarily symptom or barrier-based for General Emergencies. This is to better assure that timely recognition and notification occurs, that events occurring during refueling and cold shutdown are appropriately covered, and that multiple events can be effectively treated.

6.2.5 The Emergency Action Levels (EAL) are contained in APF 06-002-01, EMERGENCY ACTION LEVELS. The EAL have been developed and agreed upon by WCGS, the State of Kansas and Coffey County and approved by the NRC. [Commitment Step 3.2.1]

1. The EAL are reviewed annually by the State and County.

6. 2. 6 10 CFR Part 50, Appendix E, Section IV.C.2, requires licensees to establish and maintain the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to pl~nt operators that an emergency action level has been exceeded and shall promptly declare the emergency.

6.2.7 Each emergency classification causes certain actions to happen such as notifications, activation and evacuation.

1. An NUE requires plant personnel, the County and State to be notified. No evacuation or activation required.

2. An Alert requires plant personnel, the County and State to be notified. The Emergency Response Organization (ERO) is called out and the emergency facilities are activated. Accountability may be performed if necessary.

3. A Site Area Emergency requires plant personnel, the County and State to be notified. The ERO is called out and the emergency facilities are activated.

The protected area is evacuated of non-responding personnel for accountability. JRR and CCL are evacuated. Accountability for site personnel is performed.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 17 of 105

4. A General Emergency requires plant personnel, the County and State to be notified. The ERO is called out and the emergency facilities are activated.

The site is evacuated of non-responding personnel.

JRR and CCL are evacuated. Accountability for site personnel is performed.

6.3 Emergency Measures 6.3.1 Protective actions to minimize personnel exposure are taken when an incident has occurred, or may occur, which could result in a fission product barrier challenge or breach. In addition, ,protective actions are taken for personnel on-site for situations such as fires or flooding, where personnel safety is threatened.

6.3.2 Emergency measures consist of assessment, corrective, and protective actions. The Shift Manager and Senior Reactor Operators assume immediate responsibility for accident assessment and mitigation. The RERP and detailed emergency actions are based on the assumption that, in an emergency, licensed operators take appropriate measures to maintain or return the facility to a safe condition, in accordance with operating license conditions and the technical specifications.

1. Callout of the ERO to augment the on-shift staff and to activate the Emergency Facilities is performed at an Alert or higher classification or whenever augmentation is deemed necessary.

6.3.3 Immediate and Follow-up notifications made to State and County authorities provide information for their use in making prompt decisions for notifying the public and ordering off-site protective actions.

1. Immediate notifications are made for each emergency classification.

2. Immediate notifications are made to the Coffey County Sheriff dispatcher and the Kansas Division of Emergency Management State Duty Officer within 15 minutes.

3. The notification form contains information agreed upon by WCGS, the State and County for each of the Immediate and Follow-up notifications. The following is a list of information that may be on the form:

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 18 of 105 o Name of facility o Date and time of classification o Classification o Release status, type of material and estimated duration

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 19 of 105 o Message authentication of phone call o Subzones recommended for protective actions o Meteorological conditions o Dose rates at site boundary o Event Prognosis, worsening or termination 6.3.4 Actions to protect the general public, and criteria for their implementation, are described in the State Plan.

Protective action recommendations are made to the County and State authorities.

1. ATTACHMENT E, EPA/KANSAS PROTECTIVE ACTION GUIDES, illustrates the EPA/Kansas PAGs for members of the public in the vicinity of WCGS and contains information typical of what may be used for the PAR guidelines. The ATTACHMENT provides guidelines and action levels to be used to develop protective action recommendations. Wolf Creek makes PARs for releases beyond the 10 mile EPZ. County and State officials have authority to take protective actions off-site.

2. Evacuation is the normally anticipated off-site protective action. Sheltering may be the preferred protective action when it will provide protection equal to or greater than evacuation. ATTACHMENT B, SUBZONE EVACUATION TIMES, contains evacuation times for the general and transient public.

3. An Alert and Notification System, made up of a number of sirens, is one means of alerting the public. Tone Alert radios are also used for notifications.

6.3.5 Contact point for information concerning the County Plan, protective measures, and special needs of the handicapped is the County Emergency Management Office.

6. 3. 6 Additional resources available for accident assessment include accident monitoring and in-plant iodine instrumentation under accident conditions. Detailed discussions of these resources and their capabilities are found in the USAR.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 20 of 105 6.3.7 The Emergency Dose Calculation Program (EDCP) is a computerized method to provide dose estimates using actual or estimated meteorological data (wind speed, wind direction, degree of cloud cover, day or night determination) and radiological effluent data (actual measurements, estimated values based upon USAR source terms, or field measurements). EDCP is designed to:

[Reference Step 3.1.9]

1. Use radiological and meteorological information to provide an estimate of off-site exposure.

2. Be capable of estimating release rates and off-site exposures from off-site field team data.

3. Off-site dose predictions when combined with actual release duration information and meteorological data during an event, provide sufficient data to estimate the cumulative population dose resulting from the event. The actual off-site population dose is confirmed by off-site monitoring, sampling and analysis.

6.3.8 Radiological monitoring teams have a goal of 60 minutes from the declaration of Alert or greater emergency to be ready for deployment to confirm effluent readings and verify plume emission and locations.

6. 3. 9 FIGURE 7, WCGS EMERGENCY RESPONSE FACILITIES, provides a view of the off-site area, showing the location of the EOF. FIGURE 8, AIRBORNE PATHWAY SAMPLING LOCATIONS shows the fixed air sampling locations. FIGURE 9, DIRECT RADIATION PATHWAY SAMPLING LOCATIONS, shows the direct radiation pathway sampling dosimeter locations.

FIGURE 10, WATERBORNE PATHWAY SAMPLING LOCATIONS, shows locations for collecting water samples.

6.3.10 At a Site Area Emergency, General Emergency, or when accountability is required, all personnel not responding to an Emergency Response Facility report to an assembly area for accountability and additional information. ERO personnel report to their assigned emergency facility. Security reports the results of accountability to the TSC.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 21 of 105 6.3.11 IF the Exclusion Area is evacuated, THEN Security shall direct an inspection of the lake and land area within the Exclusion Area but outside of the Protected Area to ensure that all personnel not responding to an Emergency Response Facility are evacuated from the Exclusion Area.

6.3.12 WCGS procedures contain decontamination instructions and guidelines. Methods for determining if the individual is a potential inhalation or ingestion contamination case are also provided. The Radiological Coordinator or appropriate Radiation Protection supervisory personnel will review the records generated by decontamination procedures.

1. Decontamination can be performed in the access control area of the Control Building, in the HVAC room of the TSC, and in the garage in the EOF.

2. Other decontamination areas are setup as designated by the Radiation Protection personnel on the ERO.

6.3.13 Respiratory protective devices and protective clothing are stored at several locations on-site and at the EOF.

The use of protective clothing and respiratory protection equipment is governed by normal WCGS procedures.

6.3.14 A supply of potassium iodide (KI) is maintained at the Control Room, TSC and the EOF to be used in the event that an individual may be exposed to radioiodine.

6.3.15 There are suggested levels of exposure to be accepted in emergencies. Immediate reentry may be necessary to save a life, account for missing personnel, or secure vital equipment. The Emergency Managers are ultimately responsible for exposure control and can permit the receiving of up to 5 REM per person for work activities, 10 REM for saving valuable equipment and 25 REM for lifesaving after consulting with the NRC, if feasible. Exposure which might exceed 25 REM, for lifesaving activities, must be approved by an Emergency Manager. Although EPA and NRC do not provide specific guidance for the upper bounds for lifesaving exposure, WCGS has chosen to use the following criteria:

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 22 of 105

1. Emergency Managers shall not knowingly permit an individual's exposure to exceed 25 REM, unless it is for lifesaving activities or protection of large populations. Emergency Managers shall not knowingly permit an individual to enter a high dose area if the projected Total Effective Dose Equivalent (TEDE) is expected to exceed 75 REM.

o Those individuals designated to exceed 25 REM must be volunteers and be fully aware of the risks involved.

2. Emergency Managers should obtain the advice and concurrence of the Radiological Coordinators in approving additional exposure.

6.3.16 Under emergency conditions, normal exposure controls are maintained. This is ensured by the on-shift Radiation Protection Technician (RP) in the Control Room, the Radiological Coordinators in the TSC and EOF.

6.3.17 The Radiological Coordinator has responsibility for maintaining exposure control for site activities, including establishment of access control at alternate locations. Strict exposure control of individuals passing through the access point is maintained on a 24-hour-per-day basis.

6.3.18 In order to enhance the exposure control process and to provide dosimetry for an expanded number of people, dosimetry vendors are available to expedite shipment of extra dosimetry devices to supplement existing on-site supplies of dosimetry equipment and to supply personnel to assist in on-site appraisal of exposures.

6.3.19 When activated, the Emergency Response Team covers emergency sampling, surveying, analysis, and hazard evaluation.

6.3.20 Personnel, instruments, and equipment are to be monitored at the access control point. Personnel and equipment decontamination is controlled in accordance with WCGS procedures.

6.3.21 WCGS maintains control over the Exclusion Area as necessary, restoring affected on-site areas to acceptable conditions for access.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 23 of 105

1. Reentry into affected areas is a controlled evolution. Surveys are performed, environmental samples are obtained and analyzed, and areas posted or decontaminated.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 24 of 105 6.3.22 Contamination limits for food supplies and drinking water are based upon the State of Kansas Protective Action Guides.

6.4 Emergency Facilities 6.4.1 Control Room Facilities

1. The Control Room is designed to be habitable under emergency conditions. The Control Room contains controls, instruments, and communications equipment necessary for operation of the plant under both normal and emergency conditions. The ventilation system, shielding, and structures are designed and built to permit continuous occupancy during a postulated design basis accident.

2. Equipment available in the Control Room gives early warning and continuous evaluation of potential emergency situations. Portable radiation survey instruments are readily available within the Control Room.

3. Access to the Control Room is controlled by the Shift Manager.

6.4.2 Technical Support Center Facilities

1. The TSC is a brisk 2 minutes and 15 seconds walk from the Control Room inside the Protected Area.

This is sufficiently close to permit face-to-face interaction be~ween personnel in the Control Room and the TSC, should telephone communications become inoperable.

2. The TSC is activated in the event of an Alert or higher emergency. The TSC may be activated during an NUE at the discretion of the Shift Manager.

3. The TSC is designed to the seismic criteria of the Uniform Building Code. It is designed to withstand 100-year-recurrence winds and is located above the probable maximum flood level.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 25 of 105

a. The manually activated single-train, non-seismic Category I TSC ventilation system utilizes high-efficiency particulate air and charcoal filters.

The radioiodine monitoring equipment in the TSC provides a designed minimum detectable level of 1.0E-07 uCi/cc radioiodine. A radiation monitor (including the monitor for radioiodines) alarms to alert TSC personnel if radiation levels may affect the habitability of the TSC.

b. Portable radiation monitoring equipment is provided in the TSC for backup radiation monitoring capability.

c. Equipment for Emergency Response Teams is available in the TSC. This equipment includes protective clothing, dosimetry, survey meters and respirators.

d. A diesel generator is available to provide backup power to the TSC. Until the diesel is loaded, batteries are available for Nuclear Plant Information System (NPIS).

e. The TSC is sized to accommodate a minimum of 25 persons and has the same radiological habitability as the Control Room under accident conditions.

4. Personnel in the TSC have access to the following materials:

o WCGS USAR, Environmental Report, and Technical Specifications o Plant operating and emergency procedures o WCGS, State, and Coffey County emergency response plans o System drawings, schematics, and diagrams

5. An Alternate TSC is located at the EOF. The Alternate TSC would be used in the case of a hostile action or other event impeding site access. The Alternate TSC provides access to the same materials as the primary TSC. The Alternate TSC has the capability to:

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 26 of 105 o Communicate with the EOF, Control Room and Security personnel o Perform off-sit~ notifications of a plant emergency o Perform engineering assessment activities, including damage control team planning and preparation 6.4.3 Operations Support Center

1. The OSC is housed in the TSC and is activated whenever the TSC is activated.

2. The OSC serves as an assembly area for plant personnel immediately serving in emergency repair or Radiation Protection support capacity during an event. The OSC functions include the coordination, formation and dispatch of Emergency Response Teams.

3. The basement of the Security Building has been identified as an alternate location for the OSC function. It contains telephones and a Gai-Tronic call box, which will allow direct communications with the other emergency centers. Portable radios are available to key personnel to further provide communications with other emergency centers.

4. An alternative OSC muster area is included with the Alternate TSC at ~he EOF. The Alternative OSC muster area would be used in conjunction with the Alternate TSC.

6. 4. 4 Emergency Operations Facility (EOF)

1. The EOF is located approximately 12 miles north northwest of WCGS, near the junction of I-35 and US-75, and is activated at an Alert or higher emergency. Following facility activation, overall emergency response is managed from the EOF.

a. This facility serves as a center for evaluation and coordination of environmental activities related to the emergency including radiological assessment and the evaluation of potential or actual radioactive releases from the plant.

2. The EOF is a commercial building that is well engineered for the design life of the plant.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 27 of 105

a. A diesel generator is available to provide backup power to the EOF. Until the diesel is loaded, UPS backup is available for equipment used to access plant data upon loss of AC power.

b. The EOF is sized to accommodate at least 35 persons.

3. Accommodations and telephones are provided for a limited number of County, State and Federal personnel. Facilities are provided for staging field survey efforts from the EOF.

4. The EOF serves as the base of operations for evacuation assessments and for communications with federal, state, and local response organizations.

Radio and telephone links are available to the TSC, and Control Room.

5. Personnel in the EOF have access to the following materials:

o WCGS USAR, Environmental Report, and Technical Specifications o Plant operating and emergency procedures o WCGS, State, and Coffey County emergency response plans o System drawings, schematics, and diagrams 6.4.5 Public Information Facilities

1. The Public Information Facilities include the Joint Information Clearinghouse (JIC), Media Center (MC),

Phone Team, and Media Monitoring. These facilities may be established as follows:

a. The JIC, Phone team and Media Monitoring in either the Wolf Creek Dwight D. Eisenhower Learning Center or in Topeka at the Kansas State Defense Building.

b. The MC in either the Wolf Creek Dwight D.

Eisenhower Learning Center or in Topeka at the Nickell Memorial Armory.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 28 of 105

2. At an NUE, information is provided to the public by Corporate Communications. The Wolf Creek Public Information Facilities may be staffed at any time, as determined by the Wolf Creek Public Information Officer, to support the distribution of information to the public.

3. The Public Information Organization activates at an Alert or higher emergency.

4. The JIC, MC, and the Phone Team are kept in close proximity to each other to facilitate coordination of information in the form of news statements, news conferences or telephone conversations.

a. Dedicated telephone lines allow contact between the JIC, TSC, and the EOF. The JIC contains status boards, appropriate office supplies, computer(s), printer(s), faxing and photocopy capabilities, and outside telephone lines.

5. The Wolf Creek PIO, the State PIO and Coffey County PIO communicate with the Public Information Coordinator (PIC) to obtain technical information.

The PIOs prepare news statements at the JIC and coordinate their efforts.

6. The MC will accommodate media representatives in an auditorium and adjoining Media Room for news conferences. The Media Room is a facility setup to provide the media with a work area, audio/visual material, outside telephone lines and public information status boards.

7. Media Monitoring and Rumor Control functions for WCGS, the State and Coffey County are performed by members of the Public Information Organization.

Appropriate equipment and supplies, fax and telephone communications with the JIC are available. Approved news statements and information are transmitted to the Media Monitoring Team after the JIC is activated.

a. The Media Monitoring Team reports any rumors or misinformation heard or observed from their monitoring of the media to the JIC.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 29 of 105

6. 4. 6 On-site Medical Facility

1. A medical facility located in the Clyde Cessna building is equipped to provide basic medical response capabilities.

2. First aid kits, emergency equipment and supplies are available to ensure that assistance can be provided to injured and/or contaminated personnel.

3. Shift personnel, trained in first aid, are available on-site 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day. Priority should be given to treating those with the most urgent medical needs.

4. In the case of contamination, efforts are made to decontaminate injured personnel on-site, as soon as practicable. However, first aid or removal of the individual from a hazardous environment, takes precedence over decontamination efforts. If decontamination is not possible, the victim is covered in such a manner as to avoid any spread of contamination until medical aid can be obtained or hospitalization accomplished.

5. Personnel leaving the RCA are monitored for contamination. All personnel are monitored for contamination before leaving the site.

a. Personnel may be monitored by portal monitors or friskers when entering or leaving WCGS facilities.

b. Personnel found to be contaminated must undergo decontamination under the direction of health physics personnel using health physics supplies and equipment available during routine activities. Release limits for personnel decontamination are found in the Radiation Protection Manual.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 30 of 105 6.4.7 State and County Facilities

1. Coffey County Emergency Operations Center (County EOC) is located in the Coffey County Courthouse, Burlington, KS. The County EOC is a command center for county agencies and a mustering area for personnel who arrive in the WCGS area in response to an emergency. The County EOC is activated at the Alert level with the additional support staff activated upon declaration of an SAE or GE. Other centers are established as the emergency needs dictate.

2. Kansas State Emergency Operations Center (State EOC), located in the State Defense Building, 2800 South Topeka Boulevard, Topeka, KS, is the command-and-control center for the State.

3. The State Forward Staging Area is located about 11 miles north of WCGS in the roadside park at the intersection of Old Highway 50 and U.S. 75. When it becomes necessary for the State to dispatch emergency personnel to the plume exposure pathway emergency planning zone (EPZ), the State activates the State Forward Staging Area to serve as a secondary base of operations for state personnel and a local contact point with Coffey County.

6. 4. 8 Evacuation Registration Center

1. People in the EPZ should evacuate to the Lyon County Reception Center using I-35 south toward Emporia, take Exit 141 for KS-130 toward Neosho Rapids/Hartford, travel two and one-half miles and go to the Neosho Rapids Grade School.

6.5 Control Room Organization 6.5.1 The Shift Manager is responsible for the initial evaluation and classification of any abnormal situation and for directing the appropriate response, including initial activation of a callout.

1. Control Room personnel are on shift 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day.

The shift complement is shown in Figure 2, MINIMUM SHIFT STAFFING.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 31 of 105 6.5.2 Upon declaration of an emergency, the Shift Manager assumes the duties of Emergency Manager. The Shift Manager normally goes to and remains in the Control Room unless it is necessary for him to leave the Control Room in order to perform specific assessment, corrective, or protective actions. The Shift Manager performs the following actions:

o Initiate appropriate technical measures to mitigate the event o Determine if releases have occurred, make the necessary assessment of the off-site concentration of radioactivity resulting from a release, and evacuate non-essential personnel if necessary o Direct the activities of the Control Room Emergency Notification System (ENS)/Off-site Communicator o Ensure immediate and follow-up notifications are made which provide sufficient information on emergency classification, plant status, off-site dose projections or measurements, and issue recommendations for off-site protective actions to authorities responsible for off-site emergency measures o Ensure NRC Resident Inspector is notified as soon as possible after the State and County are notified o Ensure notifications to the NRC are made as soon as possible within 60 minutes of classification of an emergency in accordance with 10CFR50. 72 (a) (3) o Ensure other notifications are made in accordance with EPPs o Activate on-site emergency teams if required o Notify plant personnel of the change in plant status

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 32 of 105 6.5.3 Emergency Notification System (ENS)/Off-site Communicator

1. The Emergency Notification System (ENS)/Off-site Communicator reports to the Shift Manager, performs initial notifications, initiates the Automatic Dialing System (ADS) or Backup ADS to callout the ERO and maintains communications with the NRC.

a. A manual callout of personnel to staff the ERO is performed if the ADS and Backup ADS are not functioning.

6.5.4 Chemistry Technician

1. The Chemistry Technician reports to the Shift Manager and performs dose assessment until relieved by Dose Assessment personnel in the EOF.

6.5.5 Radiation Protection Technician

1. The Health Physics Technician reports to the Shift Manager and performs radiation monitoring for personnel sent from and in the Control Room.

6. 5. 6 Control Room Supervisor

1. Reports to the Shift Manager and provides direction to Reactor Operators and Nuclear Station Operators for the safe operation of the unit.

6.5.7 Reactor Operators

1. The Reactor Operators report to the Control Room Supervisor and perform plant monitoring and reactor manipulations as needed from the Control Room.

6.5.8 Nuclear Station Operators

1. Nuclear Station Operators report to the Control Room Supervisor and perform local plant monitoring and manipulations as directed.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 33 of 105

6. 5. 9 Shift Technical Advisor (STA)

1. The Shift Technical Advisor reports to the Shift Manager and performs STA requirements as assigned by the NRC.

6.5.10 Initial emergency response to the major functional areas is within the capabilities of the minimum operations shift complement.

6.5.11 On-shift staff augmentation is available, when deemed necessary, in accordance with ATTACHMENT D, WCGS MINIMUM STAFFING FOR EMERGENCIES.

6.6 Technical Support Center (TSC) Organization

6. 6 .1 TSC activation will be performed as soon as practical and within 75 minutes of a declaration of an Alert or higher classification.

6. 6. 2 The TSC is considered activated when the following positions are present, the Site Emergency Manager determines the facility is ready to activate, and declares the facility activated:

o Site Emergency Manager o TSC Operations Coordinator o TSC Administrative Coordinator o TSC Radiological Coordinator o Maintenance Coordinator

6. 6. 3 The TSC organization is shown in FIGURE 3, TSC/OSC ORGANIZATION.

6. 6. 4 Additional personnel to support repair efforts and recovery functions will be added as necessary.

Personnel reporting from off-site may initially report to the EOF/Alternate TSC, and then proceed to the TSC

• as plant/site conditions allow.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 34 of 105 6.6.5 Site Emergency Manager

1. The assigned Site Emergency Manager will assume command-and-control functions and will be the top line manager responsible for the emergency. An assigned Site Emergency Manager is available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day. The assigned Site Emergency Manager may assume command-and-control functions from the Shift Manager during an NUE if so requested by the Shift Manager.

2. The Shift Manager will transfer the Site Emergency Manager duties to the assigned Site Emergency Manager in accordance with EPPs. The Shift Manager resumes Control Room duties and reports to the Site Emergency Manager.

3. The Site Emergency Manager directs the on-site emergency effort, implements the applicable EPPs and, as appropriate, performs the following:

o Assess and verify the situation and assure that appropriate mitigating efforts are being taken o Review initial event classification and reclassify as appropriate o Determine the necessity for evacuation of personnel on-site o IF a release has occurred, THEN make the necessary assessment of the off-site concentration of radioactivity resulting from a release o Ensure immediate and follow-up notifications are made which provide sufficient information on emergency classification, plant status, off-site dose projections or measurements, and issue recommendations for off-site protective actions to authorities responsible for off-site emergency measures

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 35 of 105

4. The following responsibilities are those of the Emergency Managers and may not be delegated. These responsibilities may be divided between the Site and Off-site Emergency Managers:

o Classification of the emergency o Protective action recommendations o Authorization for notification of off-site authorities o Authorization of emergency exposure in excess of 10 CFR 20 limits

6. 6. 6 TSC Operations Coordinator

1. The TSC Operations Coordinator reports to the Site Emergency Manager and is responsible for the following:

o Supervise reactor plant operations, which includes the Operations Recorder, Engineering Coordinator, Engineering Team and ENS Communicator.

o Keep the Site Emergency Manager advised of plant conditions and operational manipulations

2. The TSC Operations Coordinator may supervise other positions as directed by WCGS procedures.

6.6.7 Engineering Coordinator

1. The Engineering Coordinator reports to the TSC Operations Coordinator and directs the activities of the Engineering Team to technically assess plant status and the severity of emergency conditions.

6. 6. 8 Engineering Team

1. The Engineering Team reports to the Engineering Coordinator. The Team evaluates current and historical plant parameters, assesses the severity of the emergency conditions and magnitude of fuel damage, and recommends corrective or preventive actions.

6. 6. 9 TSC Emergency Notification System (ENS) Communicator

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 36 of 105

1. The TSC ENS Communicator reports to the TSC Operations Coordinator and maintains communications with the NRC.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 37 of 105 6.6.10 TSC Radiological Coordinator

1. The TSC Radiological Coordinator reports to the Site Emergency Manager and is responsible for preventing or minimizing direct exposure to, or ingestion/inhalation of, radioactive materials during a radiological emergency. Responsibilities are as follows:

o Monitoring dose rates and dose projections o Monitoring radiological survey teams' results o Assists the On-site Emergency Manager in the formulation of recommended protective actions o Monitoring personnel radiation exposures to ensure they are maintained in accordance with 10CFR 20 limits unless otherwise authorized by the Emergency Manager o Provides radiological data and concerns to plant teams for the team briefs

2. The TSC Radiological Coordinator will transfer off-site duties to the EOF when the EOF is activated.

6.6.11 TSC Administrative Coordinator

1. The TSC Administrative Coordinator reports to and assists the Site Emergency Manager to ensure that emergency notifications are performed. The TSC Administrative Coordinator is responsible for logistical support in the areas of TSC personnel, Control Room, procurement and warehouse support, communications support and equipment repair services.

2. After EOF activation, the TSC Administrative Coordinator directs requests for logistical support beyond on-site staff capabilities to the EOF Administrative Coordinator.

6.6.12 TSC Team Director

1. The TSC Team Director reports to the TSC Maintenance Coordinator and provides advice on all matters concerning Emergency Response Team activities.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 38 of 105 6.6.13 Maintenance Coordinator

1. The Maintenance Coordinator reports to the Site Emergency Manager and directs the Maintenance Assistant in the coordination of emergency team activities. The Maintenance Coordinator also directs the formation of teams to be assigned to search and rescue.

6. 6 .14 Operations Communicator

1. Provides data, progress and plant conditions from the Control Room via the Operations Recorder.

6.6.15 Additional Personnel

1. The following are examples of positions that are not needed for activation and operation of the TSC but supplement those personnel which are essential to an emergency response:

o Operations Recorder maintains the Operations Status Board current.

o Team Communicator reports to the Team Director and is responsible for communicating with On-site Teams.

o Emergency Response Team Members perform tasks as assigned by the Maintenance Assistant.

o Administrative Assistants perform facility accountability, assist the Emergency Manager, faxing and copying, log keeping, and communications as directed.

o Security Coordinator maintains a line of communications between the TSC and Security to cover security concerns.

6.7 Operations Support Center (OSC) Organization 6.7.1 Maintenance Assistant

1. The Maintenance Assistant reports to the Maintenance Coordinator and coordinates emergency repair and damage control activities, coordinates deployment of on-site teams, and coordinates the activities of the Maintenance Planners.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 39 of 105 6.7.2 Emergency Response Team (ERT)

1. The ERT personnel may be selected from Radiation Protection Technicians (Tech), Chemistry Tech, and Instrumentation and Control, Mechanical, or Electrical Maintenance. The ERT reports to the Maintenance Assistant and is responsible for repairs, surveys, sampling, analysis, and search and rescue.

6.7.3 Additional Personnel

1. The following are examples of positions that are not needed for activation and operation of the OSC but supplement those personnel which are essential to an emergency response.

o Chemistry Technicians perform emergency chemical sampling and provide post-accident sample analysis.

o Maintenance Planner develops repair plans for use by the emergency repair and damage control teams and assists in locating and securing parts and equipment from the warehouse.

0 6.8 Emergency Operations Facility (EOF) Organization 6.8.1 EOF activation will be performed as soon as practical and within a goal of 90 minutes of a declaration of an Alert or higher Emergency.

1. The EOF is considered activated when the following positions are present, the Off-site Emergency Manager determines facility readiness, and declares the facility activated:

o Off-site Emergency Manager o EOF Operations Coordinator o EOF Administrative Coordinator o EOF Radiological Coordinator

2. The complete EOF organization is shown in FIGURE 4, EOF ORGANIZATION.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 40 of 105 6.8.2 Off-site Emergency Manager

1. The Off-site Emergency Manager will assume the command-and-control functions and direct the emergency from EOF. An assigned Off-site Emergency Manager is available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day.

2. The Off-site Emergency Manager is the official WCGS interface with government authorities. The Manager may discuss events in progress with the County and State personnel present in the EOF when making decisions concerning the emergency.

Responsibilities include the following:

a. Supports and provides resources or performs tasks as requested by the Site Emergency Manager

b. Directs all WCGS personnel in the EOF

c. Obtains personnel and coordinates the efforts of the following:

o Emergency response personnel who perform off-site radiological surveys, plus any other personnel deemed useful for the emergency response effort o Outside contractors and vendors, such as consultants, laboratories under contract, the Nuclear Steam Supply System (NSSS) vendor, the Architect/Engineer, and regional utilities o Additional technical resources may be called in during the emergency for further support or shift assignment on-site.

d. Coordinates with the Administrative Coordinator in the logistics effort to supply the plant with the necessary personnel and equipment

e. Briefs WCGS Executive Management on matters related to the emergency

f. Coordinates with the Off-site Public Information Coordinator (PIC) in providing technical input for news statements

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 41 of 105

g. Ensure immediate and follow-up notifications are made which provide sufficient information on emergency classification, plant status, off-site dose projections or measurements, and issue protective actions recommendations to off-site authorities responsible for off-site emergency measures

h. Requests federal assistance through state officials per the State Plan

3. The following responsibilities are those of the Emergency Managers and may not be delegated. These responsibilities may be divided between the Site and Off-site Emergency Managers:

o Emergency classification o Protective action recommendations o Authorization for notification of off-site authorities o Authorization of emergency exposure in excess of 10CFR 20 6.8.3 EOF Radiological Coordinator

1. The EOF Radiological Coordinator reports to the Off-site Emergency Manager and is responsible for radiological monitoring and dose assessment activities off-site. Responsibilities are as follows:

o Directs and coordinates activities of the Dose Assessment Coordinator and staff o Assists the Off-site Emergency Manager in the formulation of recommended protective actions o Provides the PIC with an assessment of radiological conditions o Requests through the EOF Administrative Coordinator additional radiation monitoring equipment, instrumentation and Radiation Protection support personnel as necessary

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 42 of 105 o Interfaces with State and County emergency response personnel who are assigned to the EOF regarding matters related to off-site radiological assessment

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 43 of 105

6. 8. 4 EOF Team Director

1. The EOF Team Director assumes responsibility for authorizing and supervising Off-site Monitoring Teams. The EOF Team Director directs Emergency Response Teams and advises the EOF Radiological Coordinator on radiological conditions encountered by the Teams.

a. Off-site Monitoring Team authorization should be made promptly upon activation of the EOF.

b. Monitoring teams are specially trained in field sampling techniques. Each team will be equipped with equipment capable of detecting and measuring radioiodine concentrations in the air at levels as low as 10- 7 uCi/cc.

c. County and State personnel may become part of the Emergency Response Teams and assist with off-site monitoring.

6.8.5 Dose Assessment Coordinator

1. Reports to the EOF Radiological Coordinator and is responsible for providing completed off-site dose projections and protective action recommendations.

2. Ensures the Radiological Status Board is maintained current.

6.8.6 HPN Communicator

1. The HPN Communicator reports to the EOF Radiological Coordinator and maintains communications with the NRC via the Health Physics Network (HPN) telephone.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 44 of 105

6. 8. 7 EOF Operations Coordinator

1. Reports to and briefs the Emergency Manager on plant conditions and mitigative strategies.

6. 8. 8 EOF Administrative Coordinator

1. The Administrative Coordinator is responsible for coordinating, directing, and responding to requests from the ERO for administrative and logistical support. The techniques and procedures used during this effort are adapted from normal WCGS procurement practices. The Administrative Coordinator also ensures notifications to off-site authorities are made.

6.8.9 Representative At County

1. The Representative at the County is located in the County Emergency Operations Center in Burlington, KS, and reports to the Off-site Emergency Manager.

The Representative responds to requests from County personnel for clarification or verification of data received from the TSC or EOF.

6.8.10 Additional Personnel

1. The following are examples of positions that are not needed for activation and operation of the EOF but supplement those personnel which are essential to an emergency response.

o Team Communicator communicates with Off-site Monitoring Teams.

o Operations Recorder maintains the Operations Status Board current.

o Administrative Assistants assist the Emergency Manager, faxing and copying, log keeping, and Off-site notifications and communications as directed.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 45 of 105 6.9 Public Information Organization

6. 9. 1 The Public Information Organization is activated at an Alert or higher emergency declaration. Information released to the public during an NUE will be provided by Corporate Communications. If deemed necessary, the Wolf Creek Public Information Facilities may be staffed to assist in releasing news statements during an NUE.

6. 9. 2 Wolf Creek Public Information Officer (WC PIO)

1. The WC PIO is the public voice for plant information. The WC PIO is responsible for ensuring the timely issuance of accurate information to the public and media during an emergency at WCGS. Public interaction may be as a formal news conference or a telephone call.

a. The WC PIO coordinates with the County and State for information to be released to the public.

2. The WC PIO has overall responsibility for the Public Information Organization.

6. 9. 3 Wolf Creek Public Information Manager (WC PIM)

1. The Wolf Creek Public Information Manager is located in the JIC and reports to the WC PIO. The WC PIM works closely with the WC PIO, Off-site PIC, News Writer, and Technical Support positions to ensure that information provided the public is timely and accurate.

2. The Wolf Creek Public Information Manager has responsibility for ensuring the Public Information Organization is activated and functions as directed in EPPs.

3. During a declared emergency the Public Information Manager determines and coordinates the activation of the Joint Information Clearinghouse, Media Center, Phone Team and Media Monitoring. The Public Information Manager operates from the appropriate Joint Information Clearinghouse.

4. The complete Public Information organization is shown in FIGURE 5, PUBLIC INFORMATION ORGANIZATION.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 46 of 105

6. 9. 4 Off-Site Public Information Coordinator (PIC)

1. The Off-site PIC is located in the EOF and reports to the WC PIM. The Off-site PIC gathers and transmits information related to the health and safety of the public to the Joint Information Clearinghouse for use in news statements.

6.9.5 Media Center Manager (MC Manager)

1. The MC Manager is located at the Media Center and reports to the WC PIM. Responsibilities include set-up of the Media Center, leadership for the Media Registrar, AV Support, and management of the media news conferences. Responsibilities include managing the media crowd at the Media Center and assisting the media with registration and facility orientation, providinggeneral Wolf Creek background information or approved emergency-related information, arranging individual interviews, and announcing and coordinating scheduled news conferences. The Media Center Manager maintains contact with the Joint Information Clearinghouse to provide news conference schedules.

6.9.6 News Writer

1. The News Writer reports to and provides support for the WC PIM. The News Writer provides support to the PIO including: answering telephones, writing and distributing news statements. The News Writer maintains a chronological log of the events and news statements.

6. 9. 7 Phone Team Manager

1. The Phone Team Manager reports to the WC PIM and coordinates the rumor control activities of the Phone Team.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 47 of 105

6. 9. 8 Technical Support

1. Technical Support discusses technical details of the news statement with EOF staff to ensure accuracy, updates the status log, maintains the media status board and provides technical interpretation for the Wolf Creek, Coffey County, and State of Kansas Public Information Officers.

Technical Support gathers information from the Emergency Facilities to communicate plant, health and safety issues to the public.

6.9.11 Representative at the State

1. The Representative at the State is located in the Kansas State Emergency Operations Center in Topeka, KS, and reports to the WC PIO. The Representative responds to requests from State personnel for clarification or verification of information pertaining to Wolf Creek.

6.9.12 Additional Personnel

1. The following are examples of additional personnel used to fill ERO positions such as clerical, log keeping, or status board posting. Staffing of these positions does not affect the activation of the facility.

o Media Center Registrar monitors access to the Media Center, records news conference attendance, provides media packets, provides directions for telephone use and work space information to the media representatives.

o Audio/Visual Support records on video and audio tape the proceedings of news conferences presented in the Media Center.

o Information Messenger performs clerical and administrative duties at the direction of the Public Information Manager.

o The Phone Team may make initial media notifications at PIO discretion, addresses media and public questions to the extent possible and reports rumors or misinformation to the Phone Team Manager.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 48 of 105 o The Media Monitoring Team notifies the Phone Team Manager of any rumors or misinformation heard or observed from their monitoring of the media.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 49 of 105 6.10 Local Off-site Organizations 6.10.1 The Coffey County Contingency Plan for Incidents Involving Commercial Nuclear Power describes the authorities, responsibilities, and agreements to which various county agencies are a party in their response to emergencies at WCGS. Information is provided therein about the various agencies' interrelationships and support roles provided to WCGS.

o The updated evacuation time estimate (ETE) report contains the evacuation times for each subzone.

(Reference 3.1.12) 6.10.2 Coffey County Commissioners

1. The Coffey County Board of Commissioners maintains the executive authority and responsibility for planning and coordinating the county response.

They have delegated responsibilities and tasks to the local support agencies and have established operating procedures.

2. After declaring a State of Local Disaster Emergency, the Chairman of the Coffey County Commissioners is responsible for making the decision to activate the alert and notification system. Emergency authority, as stated in County Plan, is given in an established line of succession.

3. If a State of Emergency has not been declared, after receipt of notification and in accordance with the County Plan, the Chairman decides which protective actions would be appropriate.

o When a protective action is decided upon, the County may notify the State to activate EAS or they may activate EAS.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 50 of 105 6.10.3 Coffey County Sheriff's Office

1. The Coffey County Sheriff's Office provides local notification, access control, and law enforcement support in accordance with the Coffey County Plan.

2. If time does not permit, or if he is unable to contact the Chairman or other members of the County Emergency Response Organization, the County Sheriff has the authority to make protective action decisions based upon recommendations by WCGS.

3. The County Dispatcher may contact the Kansas Division of Emergency Management to activate EAS or they may activate EAS.

4. Specific services provided by the Coffey County Sheriff's Office include:

o Perform notifications as defined within the County Plan and associated implementing procedures o Provide a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day manning of communications links between the County and WCGS, and between the County and State o Implement off-site protective actions as necessary and as specified in the County Plan implementing procedures o Initiate warning and initial notification of the population o Direct the evacuation of specific subzones of the EPZ upon the decision to evacuate o Provide traffic control and roadblocks per implementing procedures o Obtain additional assistance as necessary to secure the evacuated areas o Control access to the County EOC

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 51 of 105 6.10.4 Coffey County Fire District #1 (CCFD)

1. Contractual arrangements have been made with the Board of Trustees of Fire District No. 1, Coffey County, KS, for the provision of fire fighting support. Services contracted are summarized in the Letter of Agreement and maintained in an Emergency Planning file.

2. The WCGS Fire Brigade Leader is also responsible for directing all fire fighting activities on site.

Once on site, Fire District members and equipment shall be escorted by Security.

6.10.5 Off-site Medical Treatment

1. Coffey County Hospital and Newman Memorial Hospital each have developed emergency procedures to provide guidance in the rendering of medical treatment to contaminated patients.

2. Coffey County Hospital, located in Burlington, KS, approximately 9 road miles from the WCGS site, has agreed to provide aid to injured/contaminated personnel.

3. Newman Memorial Hospital serves as a backup to Coffey County Hospital and is located in Emporia, KS, approximately 40 miles from WCGS.

4. Contaminated injured personnel transported from WCGS to off-site medical facilities are attended by personnel qualified in radiological practices.

Once the patient(s) has been stabilized, WCGS personnel survey patient(s), attending personnel, vehicles, and equipment to ensure they have been decontaminated in accordance with WCGS, County, or State procedures.

6.10.6 Coffey County Emergency Medical Service (EMS)

1. Coffey County EMS provides medical assistance and transports victims to medical facilities for personnel requiring treatment for injuries, exposure to radiation, and contamination. WCGS notifies the Ambulance Service by telephone or through the Coffey County Sheriff's Office.

2.* If conditions warrant, any vehicle at WCGS may be used to transport affected personnel.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 52 of 105 6.10.7 Radiological Emergency Assistance Center/Training Site (REAC/TS)

1. REAC/TS maintains a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Hospital Disaster Network. Consultation is available for medical emergencies involving radiologically contaminated patients.

6.11 State Organizations 6.11.1 The Governor, by law, is the Chief Executive Officer of the State of Kansas and is responsible for the safety and well-being of all citizens within the State. The State Plan describes the responsibilities of local, federal, state, and volunteer agencies during nuclear emergencies. Upon declaration of a State of Disaster Emergency the State has primary responsibility for responding to an off-site nuclear emergency.

Activation of the State EOC, located in the lower level of the State Defense Building, Topeka, KS, is the responsibility of the Governor or authorized representatives, depending on the nature of the emergency. The Kansas Division of Emergency Management, Technological Hazards Section, provides overall coordination as the responding state agency during a Fixed Nuclear Facilities Incident.

6.11.2 The State of Kansas Radiological Emergency Response Plan for Nuclear Facilities describes in detail, the authorities, responsibilities, and agreements to which various state agencies of their response to emergencies at WCGS. Reference to this document is made for detailed information on each agency's interrelation and support role provided to WCGS.

1. Upon declaration of an SAE or GE representatives of Kansas Division of Emergency Management (KDEM) and Kansas Department of Health and Environment (KDHE) go to the EOF. They act as the interface between WCGS, the County, and the State.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 53 of 105 6.11.3 Kansas Division of Emergency Management (KDEM)

1. The KDEM provides the following assistance:

a. Evaluates information presented by WCGS to decide off-site protective actions

b. Coordinates nuclear incident response planning, training, and notification. Activities include:

o Notification of KDHE o Notification of Key federal and state agencies o Notification of the Governor's Office o Provides radiological monitoring coordination o Requests federal assistance and coordinates federal and state support on behalf of affected areas o Provides 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day point of contact to receive notification o Activates the State EOC o Activates the Kansas Emergency Alert System 6.11.4 Kansas Department of Health and Environment (KDHE)

1. The KDHE provides assistance as described below:

o Acts as the lead state agency for operational radiological emergency response o Conducts radiological monitoring in affected areas o Provides radiological advice to hospitals o Develops and establishes State PAGs o Provides information and guidance to the public about protective actions, via the KDEM o Assesses off-site contamination of the environment

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 54 of 105 o Provides technical guidance and coordination in recovery activities o Supports the development and conduct of radiological response training o Reviews, evaluates, and maintains dosimetry records for non-licensee emergency workers and other affected individuals 6 .11. 5 Kansas Highway Patrol (KHP)

1. The KHP provides communications and notification support including backup notification means for the following:

o Coffey County Sheriff's Office o KDEM, Technological Hazards Section o The Governor's Office

2. The KHP augments local law enforcement in securing the area and establishing evacuation routes and providing traffic control.

3. The KHP provides self-support radiological monitoring.

4. The KHP maintains emergency communications systems 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day.

6 .11. 6 Kansas National Guard

1. The Kansas National Guard may be directed by the Governor to provide assistance as needed such as the following:

o Evacuation of communities o Area security o Media Center Security

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 55 of 105 6.11.7 Kansas Department of Transportation (KDOT)

1. KDOT provides assistance as follows:

o Provides emergency traffic barriers and signs o Supplements emergency traffic control o Supplies construction equipment o Provides communications support 6.12 Federal Organizations 6.12.1 Should an emergency situation or accident occur at WCGS, notification and reports must be made to various federal agencies and organizations, and requests for assistance may also be made.

6.12.2 Federal Emergency Management Agency (FEMA)

1. FEMA is the lead agency supporting implementation of the state and local emergency plans. Region VII FEMA response time is estimated to be four hours.

6.12.3 Department of Energy (DOE)

1. The DOE Radiological Assistance Program provides monitoring assistance and radiological consultation to the KDHE. The DOE provides assistance under the Nuclear/Radiological Incident Annex to the National Response Framework and responds to authorized requests for assistance by the KDHE. It is expected that initial responders, to assist with off-site radiological monitoring, will arrive within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

6.12.4 Nuclear Regulatory Commission (NRC)

1. The NRC provides advice to other federal, state, and local agencies on the radiological health consequences of various emergency protective actions. The NRC requires notification and reports as indicated in ATTACHMENT H, REPORTING OF INCIDENTS PER 10CFR20 and as specified in the WCGS Technical Specifications. NRC Region IV response time is estimated to be 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 56 of 105 6.12.5 Licensee resources available to support the federal response include the following:

o Space and equipment in the TSC and EOF provided for key federal personnel o Telecommunications equipment at these centers is available to federal personnel for use o Parking space adjacent to the EOF provides an area for the location of federal response vehicles, with power and sanitary services available at the EOF o Open fields west of the parking lot at the EOF provide access for helicopters o Coffey County Airport is available for air traffic 6.12.6 Federal Radiological Monitoring and Assessment Center (FRMAC)

1. FRMAC is a federal asset available on request by the Department of Homeland Security (OHS) and state and local agencies to respond to a nuclear or radiological incident. The FRMAC is an interagency organization with representation from the NNSA, the Department of Defense (DOD), the Environmental Protection Agency (EPA), the Department of Health and Human Services (HHS), Federal Bureau of Investigations (FBI), and other federal agencies.

Full Federal response (FRMAC) is expected within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

6.13 Additional Support Agencies 6.13.1 Vendor and Architect/Engineers (A/E)

1. NSSS supplier, Westinghouse, is the chief vendor who may be involved with emergency response for WCGS. Westinghouse has emergency response plans which are activated upon notice and is expected to provide the following services:

o Personnel with expertise in various areas o Technical analysis o Operational analysis o Accident/transient analysis

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 57 of 105 o Recommendations

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 58 of 105 6.13.2 Regional Utility Support

1. WCGS shares the Standardized Nuclear Unit Power Plant System (SNUPPS) power-block design with the Union Electric Callaway Plant. Because of this design concept and similarity with the WCGS layout, assistance from Union Electric is possible. A specific mutual aid agreement between WCGS and Callaway Energy Center, Ameren Missouri d/b/a Union Electric has been established. While this assistance may be available within a short period of time, it shows greatest promise in the case of a prolonged emergency where extended, around the clock coverage is required. The Site Emergency Manager may authorize the temporary use of this resource, should staff augmentation be necessary.

Union Electric Company is a signatory of the INPO FIXED FACILITY EMERGENCY RESPONSE VOLUNTARY ASSISTANCE AGREEMENT.

6.13.3 Institute of Nuclear Power Operations (INPO)

1. WCGS has signed the INPO FIXED FACILITY EMERGENCY RESPONSE VOLUNTARY ASSISTANCE AGREEMENT. This agreement is by and among electric utilities which have responsibility for the construction and operation of commercial U.S. nuclear power plants.

Assistance may be requested from any of the signatory companies in the form of technical and administrative aid or personnel, facility, or equipment resources. Requested assistance is rendered according to the agreement.

6.13.4 American Nuclear Insurers (ANI)

1. ANI is notified at emergency classifications of Alert or higher. ANI is available to provide insurance services as necessary.

6.14 Plant Monitoring 6 .14 .1 Nuclear Plant Information System (NPIS)

1. The integration and display of selected and critical data is performed by NPIS which is a non-safety, non-Class lE system. Isolation is provided to ensure that NPIS does not degrade the performance of safety system equipment or displays.

2. NPIS provides data storage and recall capability.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 59 of 105

3. Certain parameters are also transmitted to the NRC Operations Center via the Emergency Response Data System (ERDS) link of NPIS. ERDS is activated through NPIS within 60 minutes of an Alert or higher classification.

4. The NPIS computer feeds key plant parameters to individual terminals in the Control Room, TSC, and via *RTime Viewer to the EOF which display data identical in accuracy, resolution, and reliability.

Support personnel may assist the Control Room staff to analyze and diagnose plant abnormalities so that mitigative action may be taken and then monitored.

5. The Safety Parameter Display System (SPDS) provides for continuous indication of plant parameters or derived variables representative of the safety status of the plant. The primary function of the SPDS is to aid the user in the rapid detection of abnormal operating conditions. As a plant safety information and diagnostic tool, SPDS concentrates on a minimum set of plant parameters from which the plant safety status can be assessed.

6.14.2 On-site Radiological Monitors

1. Process monitors monitor the radiation intensity of materials within plant systems. These monitors continuously measure, indicate and record the radioactive material concentrations located within systems being monitored. Each monitor includes an adjustable alarm to provide indication of a significant change or the existence of a concentration of radioactive material above pre-selected values. The USAR, Chapter 11.5, includes a listing and range of plant monitors.

2. The Area Radiation Monitoring System monitors provide information about radiation intensity at specific plant locations. These monitors provide the following:

a. Warnings of excessive gamma radiation levels in areas where nuclear fuel is stored or handled

b. Control Room personnel with a continuous indication of gamma radiation levels at selected locations within the various plant buildings

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 60 of 105

c. Assistance in detecting unauthorized or inadvertent movement of radioactive material in the plant, including the radwaste area

d. Supplementation of other systems, such as process radiation monitoring or leak detection, in detecting abnormal migrations of radioactive material

e. Local alarms to warn personnel in the area

3. Effluent monitors provide information about the concentration of radioactive material in plant effluent pathways. Each significant effluent pathway from the plant includes an effluent monitor to enable the quantification of the radioactive material concentration exiting the plant.

6.14.3 Meteorological Monitoring System

1. The Meteorological Monitoring System is composed of a 90-meter instrument tower and a temperature controlled shelter at the base of the tower housing associated instrumentation and equipment.

2. The function of the meteorological system is to monitor and record meteorological conditions.

3. Information provided by instruments at the meteorological tower is available from the NPIS computer system.

4. Time interval measurements are used in calculating 15-minute averages for all parameters.

5. When needed, Meteorological data can be obtained from the National Weather Service.

6.14.4 Seismic Monitoring System

1. The seismic warning panel in the Control Room provides local visual and audible indication when a seismic event has occurred.

6.14.5 Hydrologic Monitoring

1. Hydrologic monitoring is not required as WCGS is a "dry site" as defined by Regulatory Guide 1.102.

The plant site is located above the design basis flood level.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 61 of 105 6.14.6 Fire Protection

1. WCGS is protected by an independent fire protection system consisting of two subsystems, a detection/alarm system and a suppression system.

2. Activation of the fire systems results in an audible alarm throughout the plant. Alarms are also displayed in the Control Room.

6.14.7 Laboratory Facilities

1. A radiochemistry (hot) laboratory, radwaste laboratory, and turbine building chemistry laboratory are located in the power block. The chemistry shop laboratory is located in the Walter P. Chrysler Building. Further information on on-site laboratory equipment can be found in USAR, Chapter 12.5.

2. The chemistry shop laboratory on site may be used for processing of routine and emergency field samples. The Kansas Health and Environmental Laboratory in Topeka, KS, is available to further augment the processing of emergency samples.

3. Private laboratories under contract to WCGS or laboratories of neighboring utilities who are signatories of the INPO Voluntary Assistance Agreement may be considered for use.

6.15 Emergency Supplies 6 .15 .1 Emergency supplies include protective, communications, and radiological monitoring equipment, check sources, and other supplies. The EPPs list emergency supplies and their locations.

6.15.2 Emergency supplies are maintained, inventoried, and inspected on a quarterly basis in accordance with EPPs.

The EPPs contain an inventory list of WCGS equipment for emergency supplies. This equipment may be augmented by other on-site equipment.

6.15.3 Instruments are calibrated in accordance with WCGS Radiation Protection Procedures. For any items removed from the emergency supplies for calibration or repair, an operable equivalent instrument is used to replace it. Sufficient quantities of spare instruments/equipment are on site to provide replacements.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 62 of 105 6.16 Communications 6.16.1 Communication Equipment

1. Telephones provide primary communications contact with the State and County EOCs. The on-site system in the Olive Beech Building and the off-site system in EOF are powered by their own battery and charger. The battery will supply the system if the charger fails.

a. The Emergency Telecommunications System (ETS) is used for NRC communications.

b. Trunk lines are available for communications with outside agencies.

c. Cell phones or other comparable equipment are used as a backup means of communications with joint radiological monitoring teams.

2. Radio communications provide backup communications with the State and County EOCs. Fixed AC-powered transmitter/receiver units and a number of portable and hand-held units are also capable of providing fixed and mobile communications to joint radiological monitoring teams.

a. Radio communication is the primary communication method for the joint radiological monitoring teams.

3. A paging system is used for initial notification of key personnel. Pager coverage is provided in and around the cities of Burlington, Emporia, Topeka, Ottawa and Lawrence.

6.16.2 Communication Dissemination

1. The methods of employee communications may be employee meetings, announcements, or literature handouts.

2. The Public Information Organization is responsible for interfacing with the media. Communication between WCGS and media organizations are performed in accordance with EPPs.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 63 of 105

3. Annually, WCGS offers the news media with the following information:

o Information concerning the emergency plan o Information concerning radiation o Facilities available for media o Points of contact for statements of public information o Differences between normal and emergency plant operations

4. Standardized public announcements for broadcast during an emergency have been written by the state, county, and WCGS and are found in the State Plan.

5. WCGS, state, and local emergency organizations provide members of the public, including transients, public education information on how they are notified and what their initial actions should be during an emergency.

a. Emergency planning information is provided within local telephone directories. The information, developed jointly by WCGS, Coffey County and the State of Kansas, is distributed to residences of the EPZ.

b. Information includes educational facts on radiation, protective measures, special needs of the handicapped and the points of contact for additional information.

c. An annual mail-out to the public provides information regarding operation of Tone Alert Radios.

6. Emergency planning information, displayed on information boards, is provided for transients in the public use areas of John Redmond Reservoir (JRR), Coffey County Lake (CCL), and other WCGS controlled areas. Transients have access to emergency plan information within motel rooms and telephone books.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 64 of 105 6.17 Emergency Plan Training 6.17.1 WCGS has developed an emergency preparedness training program which meets the requirements of 10CFR50, Appendix E, Section IV. F.

6.17.2 The Superintendent Emergency Planning ensures required training is provided for ERO personnel in accordance with plant procedures.

6.17.3 The Superintendent Emergency Planning ensures corrective actions for any Emergency Planning weakness or deficiencies identified are initiated and corrected using the WCGS corrective action process.

6.17.4 Personnel receive general RERP training as a portion of Plant Access Training prior to receiving unescorted access to WCGS.

6.17.5 Initial and re-qualification training is provided for personnel on the ERO. This training may be in the form of self study, class room training, drills, tabletops, or any combination of these.

1. Position specific training is provided for personnel filling positions in the following areas:

o Managers/Coordinators of the emergency o Personnel responsible for accident assessment o Radiological monitoring teams o Fire brigade members o Emergency response teams o Medical support personnel o Security personnel o Support personnel

2. Critiques are performed after each training class to identify weak or deficient areas.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 65 of 105 6 .17. 6 Where Letters of Agreement exist between WCGS and local agencies and for each off-site response organization's emergency support role, training is offered annually.

Training is also offered to the participants in the Interlocal Agreement between Coffey County and host county Lyon.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06~002 (RERP)

Information Use Page 66 of 105

1. This training consists of an orientation to plant operations and site access procedures, basic radiation protection and monitoring information, procedures for notification, an overview of the ERO duties and activities, and training materials associated with performance of their expected roles.

6.17.7 Drills are considered part of the Emergency Plan Training Program. Periodic drills conducted between the biennial exercise ensure that the ERO is capable of executing the principal functional areas of emergency response including activities such as management and coordination of emergency response, accident assessment, event classification, notification of off-site authorities, assessment of the on-site and off-site impact of radiological releases, protective action decision making, plant system repair and mitigative action implementation.

1. State and County participation in drills will be allowed if they so desire.

6.18 Emergency Plan Drills 6.18.1 Annual communication drills between WCGS, State and County EOCs, and field assessment teams ensure that contact can be made and that messages are comprehended.

1. Monthly communication tests verify commqnications with the local County and State authorities.

Communications tests are made with the NRC Headquarters via the Emergency Telecommunications System (ETS). These tests are performed in accordance with EPPs.

6.18.2 Fire drills are conducted in accordance with plant administrative procedures.

6.18.3 Annual medical emergency drills include transportation and treatment of simulated contaminated individuals by ambulance and off-site medical treatment facilities.

6.18.4 Annual radiological monitoring drills include collection and analysis of sample media, field activities, and provisions for communications and record keeping.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 67 of 105 6.18.5 Semi-annual Health Physics drills involve response to and analysis of simulated elevated airborne and liquid samples and direct radiation measurements in the environment.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 68 of 105 6 .18. 6 Each calendar quarter, a callout drill is conducted to verify the operability of the notification system.

6.18.7 Critiques are conducted following each drill to identify and correct noted weaknesses and deficiencies.

6.18.8 Terrorist-based-event drills will be conducted as directed by FEMA and the NRC. [Commitment Step 3.2.4]

6.19 Emergency Planning Exercises 6 .19 .1 In accordance with 10CFR50 Appendix E, Section IV.F, emergency exercises will test the adequacy of timing and content of implementing procedures and methods, test emergency equipment and communication networks, test the public notification system, and ensure that ERO personnel are familiar with their duties.

6.19.2 Exercises will be conducted biennially to test the on-site and off-site emergency plans. Exercises ensure that the ERO is capable of executing the principal functional areas of emergency response including activities such as management and coordination of emergency response, accident assessment, event classification, notification of off-site authorities, assessment of the on-site and off-site impact of radiological releases, protective action decision making, plant system repair and mitigative action implementation.

6.19.3 To meet NRC and FEMA requirements, the exercises are varied so as to test, at least once every eight years, all major components of the WCGS, State, and County plans and response organizations. The State and County actively participate in these exercises.

6.19.4 Each scenario variation shall be demonstrated at least once during the eight year exercise cycle and shall include, but not be limited to, the following:

1. Exercises should be conducted under various weather conditions.

2. Hostile action directed at the plant site involving the integration of off-site resources with on-site response.

3. An initial classification of or rapid escalation to a Site Area Emergency or General Emergency.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 69 of 105

4. No radiological release or an unplanned minimal radiological release that requires the site to declare a Site Area Emergency, but does not require declaration of a General Emergency.

5. Implementation of strategies, procedures and guidance developed under 10 CFR 50.54(hh) (2).

6. Start a drill or exercise between 6:00 p.m. and 4:00 a.m. Some drills or exercises should be unannounced.

7. Large radiological release requiring ingestion pathway protective actions beyond the 10 mile EPZ.

6.19.5 Terrorist-based-event exercises will be conducted as directed by FEMA and the NRC. [Commitment Step 3.2.4]

6.19.6 Designated observers from federal, state, local governments, and WCGS observe the required exercises.

Certain of these observers also evaluate the exercise.

1. The Superintendent Emergency Planning has the lead responsibility for ensuring corrective actions associated with emergency planning are initiated.

2. Critiques are conducted following each exercise to identify and correct noted weaknesses and deficiencies.

6.19.7 Prior to an exercise a scenario package is prepared which contains the following:

o Basic objective of each exercise and appropriate evaluation criteria that support demonstration of key skills in principle functional areas o Simulated events o Dates, time periods, places, and participating organizations o Time schedule of all initiating events o Descriptive scenario addressing the conduct of the exercise which should include public information activities, off-site fire department assistance, simulated casualties, rescue of personnel, use of protective clothing and radiological monitoring teams

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 70 of 105 o Description of the arrangements for, and advance materials to be provided to official observers

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 71 of 105 6.19.8 Records of exercises conducted during the eight year cycle shall be maintained that document the content of scenarios used to comply with scenario variation requirements.

6 .19. 9 The exercise scenario shall be submitted to the NRC under 10 CFR 50.4 at least 60 days prior to the evaluated exercise.

6.19.10 Remedial exercises will be conducted for exercises which do not satisfactorily test the emergency response plan as determined by FEMA and the NRC.

6.20 Emergency Plan And Procedures Administrative Controls 6.20.1 The Quality Assurance Organization is responsible for assuring that a review of the WCGS Emergency Planning and Preparedness Program will be performed, at least once every twelve months, in accordance with 10CFR 50.54(t).

1. Personnel performing this review will have no direct responsibility for implementation of the Emergency Planning and Preparedness Program.

2. The review shall evaluate interfaces with state and local governments, licensee drills, exercises, capabilities, procedures and emergency facilities.

3. The results of the review are reported to owner iepresentatives and WCGS Senior Management and shall be retained for at least five years.

4. Correction of review findings are evaluated and implemented using normal WCGS procedures.

5. The applicable portions of the review shall be made available to the State and local governments.

6.20.2 The Superintendent Emergency Planning ensures the coordination and documentation of RERP reviews and revisions and the RERP distribution. The RERP is revised annually to incorporate changes identified during drills, exercises and the 10CFR 50.54(t) review.

1. The RERP and approved changes are distributed to all organizations and individuals with responsibility for implementation of the RERP.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 72 of 105 6.20.3 The Superintendent Emergency Planning ensures emergency planning personnel are properly trained.

6.20.4 Action items required to be performed in a time period are allowed a 1.25 times frequency grace period to complete the item.

6.21 Recovery Plan 6.21.1 The Recovery Plan is activated in a progressive manner when the Site, if EOF not activated, or Off-site Emergency Manager determines stabilized plant conditions warrant the transition of the emergency response efforts to the recovery phase.

6.21.2 IF a General Emergency has been reached, THEN NRC and KDEM concurrence shall be obtained prior to downgrading.

6.21.3 The EPPs provide the general plans for reentry and recovery and describe the means by which decisions to relax protective measures are reached.

1. Evaluation of the status of the three fission product barriers is used for de-escalation. As the situation improves and barriers are restored, the next lower level of event may be declared.

2. De-escalation may also occur if conditions have stabilized such that the potential for re-escalation to a higher level has been removed and a controlled situation exists. A declaration of de-escalation is provided by the Emergency Manager based on known information and recommendations of the ERO.

3. Guidelines are provided for Reentry Team(s) to perform surveys and monitoring activities to be employed for initial reentry.

6.21.4 During the recovery process the normal procedures employed for configuration control, reporting, interfaces with regulatory agencies and support groups, exposure control, environmental monitoring, and procurement of supplies and services shall be utilized.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 73 of 105 6.21.5 The Recovery Plan utilizes the necessary technical, administrative, managerial and support personnel that may be required for the recovery phase of emergency response, as determined by Site or Off-site Emergency Managers. The responsibilities and functions of the Emergency Managers and staff are detailed in the EPPs.

7.0 RECORDS 7 .1 None 8.0 FORMS 8 .1 APF-06-002-01, EMERGENCY ACTION LEVELS

- END -

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 74 of 105 ATTACHMENT A (Page 1 of 1)

EFFECTIVE 10-MILE EPZ POPULATION Distance (miles) And Significant Approximate Direction From The Site Population Centers Population Subzone To Population Center Burlington, KS 2,674 SW-1 3.5 Southwest New Strawn, KS 394 W-1 3.4 West-Northwest Waverly, KS 592 NE-2 11. 5 North-Northeast LeRoy, KS 561 SE-3 11.1 South-Southeast Aliceville, KS 40 SE-2 9.3 Southeast Ottumwa, KS 20 NW-1 6.8 West-Northwest Sharpe, KS 10 N-1 2.4 North Jacob's Creek 70 W-2 10.0 West The city population numbers were taken from the 2010 census.

- END -

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 75 of 105 ATTACHMENT B (Page 1 of 3)

SUBZONE EVACUATION TIMES B.1 Table B.1 lists each subzone and the population in that subzone.

TABLE B.1 POPULATION BY SUBZONE Evacuation Subzone Evacuation Zone Po12ulation Center (CTR) 0 - 2 132 North-1 (N-1) 2 - 5 27 Northeast-1 (NE-1) 2 - 5 48 East-1 (E-1) 2 - 5 62 Southeast-1 (SE-1) 2 - 5 57 South-1 (S-1) 2 - 5 45 Southwest-1 (SW-1) 2 - 5 2,854 West-1 (W-1) 2 - 5 480 Northwest-1 (NW-1) 2 - 5 112 North-2 (N-2) 5 - 10 163 Northeast-2 (NE-2) 5 - 10 682 Northeast-3 (NE-3) 5 - 10 115 East-2 (E-2) 5 - 10 54 Southeast-2 (SE-2) 5 - 10 124 Southeast-3 (SE-3) 5 - 10 662 Southeast-4 (SE-4) 5 - 10 45 South-2 (S-2) 5 - 10 81 Southwest-2 (SW-2) 5 - 10 137 West-2 (W-2) 5 - 10 167 Northwest-2 (NW-2) 5 - 10 149 B.2 Total Coffey County population equals 8,601 persons (2010 census).

Effective 10-Mile Emergency Planning Zone Subtotals are as follows:

0 Effective 0 mile zone = 8 persons 0 Effective 2 mile zone = 3,345 persons 0 Effective 5 10-mile zone 2,843 persons 0 Effective 0 mile zone = 6,196 persons B.3 Table B.2 lists evacuation confirmation time parameters.

TABLE B.2 EVACUATION CONFIRMATION TIME PARAMETERS Speed Vehicles EPZ Miles Number Between Effort in Assumed Confirmation Location Traveled of Houses Vehicle Available Time Houses Burlington 36 1,183 5 mph 105 Hrs 11 9.5 Hrs New Strawn 3 229 5 mph 20 Hrs 3 6.6 Hrs LeRoy 9 289 5 mph 43 Hrs 5 8. 6 Hrs Waverly 7 280 5 mph 33 Hrs 4 8.3 Hrs Remaining 289 64 9 30 mph 80.5 Hrs 8 10.3 Hrs EPZ*

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 76 of 105 ATTACHMENT B (Page 2 of 3)

SUBZONE EVACUATION TIMES

• Includes the evacuation confirmation of the U.S. Army Corps of Engineers areas at John Redmond Reservoir, Coffey County Lake, and the U.S. Fish and Wildlife Service area north of the Neosho River.

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 77 of 105 ATTACHMENT B (Page 3 of 3)

SUBZONE EVACUATION TIMES B.4 Coffey County has Letters of Agreement or Mutual Aid Agreements with surrounding medical transport groups and the Coffey County Public Transportation to assist with transportation for non-ambulatory persons. For all transportation-dependent people, including the non-ambulatory occupants of the Burlington Life Care Center, Sunset Manor Nursing Home, and the Coffey County Hospital, an evacuation time of 2.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> is estimated using area resources.

B.5 Tables B.3 and B.4 list the 10-mile evacuation times for average and adverse weather conditions.

TABLE B.3 TABLE B.4 10-MILE EVACUATION TIMES 10-MILE EVACUATION TIMES FOR AVERAGE WEATHER FOR ADVERSE WEATHER CONDITIONS (HOURS) CONDITIONS (HOURS)

Subzone Effective 10-mile Subzone Effective 10-mile CTR 1:20 CTR 2:00 CCL 1:20 CCL 2:00 JRR 1:20 JRR 2:00 N-1 1:30 N-1 2:15 NE-1 1:20 NE-1 2:00 E-1 1:25 E-1 2:00 SE-1 1:25 SE-1 2:00 S-1 1:30 S-1 2:15 SW-1 1:45 SW-1 2:25 W-1 1:45 W-1 2:25 NW-1 1:45 NW-1 2:25 N-2 1:45 N-2 2:20 NE-2 1:40 NE-2 2:20 NE-3 1:30 NE-3 2:05 E-2 1:35 E-2 2:10 SE-2 1:35 SE-2 2:10 SE-3 1:45 SE-3 2:25 SE-4 1:40 SE-4 2:20 S-2 1:45 S-2 2:25 SW-2 1:50 SW-2 2:30 W-2 1:50 W-2 2:25 NW-2 1:40 NW-2 2:25

- END -

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 78 of 105 ATTACHMENT C (Page 1 of 8)

CROSS REFERENCE BETWEEN NUREG 0654, RERP, & WCGS PROCEDURES 0654 RERP Comments Procedure Section Section A. - ASSIGNMENT OF RESPONSIBILITY (Organization Control) l.a 6.5, 6.6, WCGS on-site and off- EPP 06-002, TECHNICAL SUPPORT

6. 8, 6.9 site organizations CENTER OPERATIONS EPP 06-003, EMERGENCY OPERATION FACILITY OPERATIONS EPP 06-004, PUBLIC INFORMATION ORGANIZATION l.a 6.10, Outside organizations 6.11, 6.12, 6.13 l.b 6.5 -

6.13 l.c FIGURE 6 l.d 6.5, 6.6, EPP 06-001, CONTROL ROOM 6.8, 6.9 OPERATIONS EPP 06-002, TECHNICAL SUPPORT CENTER OPERATIONS EPP 06-003, EMERGENCY OPERATION FACILITY OPERATIONS l.e 6.5.2 Notifications are made from the control room, at the direction of the Site Emergency Manager.

2.a & 2 .b N/A

3. ATTACH. G

4. 6.8.2 Off-site Emergency EPP 06-003, EMERGENCY OPERATION Manager FACILITY OPERATIONS 6.6.11, Administrative EPP 06-002, TECHNICAL SUPPORT 6.8.10 Coordinators CENTER OPERATIONS EPP 06-003, EMERGENCY OPERATION FACILITY OPERATIONS B. - ON-SITE EMERGENCY ORGANIZATION

1. 6.5, EPP 06-001, CONTROL ROOM Figure 2 OPERATIONS

2. 6.5.2 Site Emergency EPP 06-001, CONTROL ROOM Manager OPERATIONS

3. 5 .1.1, Transfer of control EPP 06-001, CONTROL ROOM 5.2.1, from the Shift OPERATIONS 6.5.2, Manager to the Site EPP 06-002, TECHNICAL SUPPORT 6.6.5, Emergency Manager. CENTER OPERATIONS 6.6.5.1, EPP 06-003, EMERGENCY OPERATION 6.8.2 FACILITY OPERATIONS

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 79 of 105 ATTACHMENT C (Page 2 of 8)

CROSS REFERENCE BETWEEN NUREG 0654, RERP, & WCGS PROCEDURES 0654 RERP Comments Procedure Section Section B. - ON-SITE EMERGENCY ORGANIZATION

4. 6.5.2, Responsibilities of the EPP 06-001, CONTROL ROOM 6.6.5, Shift Manager, Site OPERATIONS 6.8.2 Emergency Manager, Off- EPP 06-002, TECHNICAL SUPPORT site Emergency Manager CENTER OPERATIONS EPP 06-003, EMERGENCY OPERATION FACILITY OPERATIONS 5 6.5, 6. 6, Major ERO positions and EPP 06-001, CONTROL ROOM 6.7, 6.8, their functions OPERATIONS 6.9 EPP 06-002, TECHNICAL SUPPORT CENTER OPERATIONS EPP 06-003, EMERGENCY OPERATION FACILITY OPERATIONS

6. 6.5, 6.6, Interfaces between WCGS

6. 7, 6.8, and outside

6. 9, Fig. organizations 5 & 6 7a. 6. 8 .11 Administrative EPP 06-003, EMERGENCY OPERATION Coordinator FACILITY OPERATIONS 7b. 6.21 Recovery Plan EPP 06-003, EMERGENCY OPERATION FACILITY OPERATIONS 7c. 6.8.2 Duty Emergency Manager EPP 06-003, EMERGENCY OPERATION FACILITY OPERATIONS 7 .d 6.9 Off-site Public EPP 06-002, TECHNICAL SUPPORT Information Coordinator CENTER OPERATIONS

& Wolf Creek Public EPP 06-003, EMERGENCY OPERATION Information Officer FACILITY OPERATIONS EPP 06-004, PUBLIC INFORMATION ORGANIZATION

8. 6.13 Specify contractors I organizations available on request

9. 6.10 Identify local support agencies C. - EMERGENCY RESPONSE SUPPORT AND RESOURCES 1.a 6. 8. 2 Persons authorized to request assistance l.b 6.12 Expected Federal resources

1. C 6.4.1, Space is provided for 6.4.2, NRC personnel in the

6. 4. 4, Control Room, TSC, and 6.12.5 EOF. The EOF also has limited space for state and local personnel.

2a. N/A 2.b 6.8.12

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 80 of 105 ATTACHMENT C (Page 3 of 8)

CROSS REFERENCE BETWEEN NUREG 0654 RERP, & WCGS PROCEDURES 0654 RERP Comments Procedure Section Section C. - EMERGENCY RESPONSE SUPPORT AND RESOURCES

3. 6.14.7 Identify radiological laboratories

4. 6.13 and Identify other ATTACH G facilities and organizations which could assist D. - EMERGENCY CLASSIFICATION SYSTEM

1. 6.2 Emergency EPP 06-005, EMERGENCY Classifications CLASSIFICATION

2. 6.2 Initiating conditions EPP 06-005, EMERGENCY CLASSIFICATION

3. & 4. N/A E. - NOTIFICATION METHODS AND PROCEDURES

1. 6.3.3, Notifications EPP 06-007, EMERGENCY 6.5.2, NOTIFICATIONS

6. 6. 5, 6.8.2

2. 6.16.1, Notification of EPP 06-015, EMERGENCY RESPONSE 6.5.3 responding personnel ORGANIZATION CALLOUT

3. 6.3.3, Initial notifications EPP 06-007, EMERGENCY 6.5.2, NOTIFICATIONS 6.6.5, 6.8.2 4 .a thru 6.5.2, Follow-up Notifications EPP 06-007, EMERGENCY 4 .n 6.6.5, NOTIFICATIONS 6.8.2

5. N/A

6. 6.10.3, Evacuation times 6.3.4.3, Attach B

7. 6.16.2.4 F. - EMERGENCY COMMUNICATIONS 1.a 6.5 l.b 6.5.2 1.c 6.5.2,

6. 5. 4,

6. 6. 5, 6.6.9, 6.8.2 1.d 6. 4. 4, 6.16 1.e 6. 5. 3, ERO Callout EPP 06-015, EMERGENCY RESPONSE 6.16.1 ORGANIZATION CALLOUT

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 81 of 105 ATTACHMENT C (Page 4 of 8)

CROSS REFERENCE BETWEEN NUREG 0654 RERP & WCGS PROCEDURES 0654 RERP Comments Procedure Section Section F. - EMERGENCY COMMUNICATIONS

1. f 6. 4. 4, EPP 06-001, CONTROL ROOM 6.5.2, OPERATIONS 6.5.4, EPP 06-002, TECHNICAL SUPPORT

6. 6. 9, CENTER OPERATIONS 6.16.1 EPP 06-003, EMERGENCY OPERATION FACILITY OPERATIONS

2. 6.10.6

3. 6.15, EPP 06-018, MAINTENANCE OF 6.18.1, EMERGENCY FACILITIES AND 6.18.6 EQUIPMENT/COMMUNICATION CHECKS G. - PUBLIC EDUCATION AND INFORMATION

1. 6.16.2

2. 6.17.5, 6.17.6 3.a 6. 4. 5, EPP 06-004, PUBLIC INFORMATION 6.16.2 ORGANIZATION 3.b 6.4.5

4. a 6.9.2 EPP 06-004, PUBLIC INFORMATION ORGANIZATION 4 .b 6. 9. 2, EPP 06-004, PUBLIC INFORMATION

6. 9.11 ORGANIZATION 4.c 6. 4. 5, EPP 06-004, PUBLIC INFORMATION 6.9.10 ORGANIZATION

5. 6.16.2 H. - EMERGENCY FACILITIES AND EQUIPMENT

1. 6. 4. 2, EPP 06-002, TECHNICAL SUPPORT 6.4.3, CENTER OPERATIONS

6. 6, 6.7

2. 6. 4. 4, EPP 06-003, EMERGENCY OPERATION 6.8 FACILITY OPERATIONS

3. 6.8 Establish EOF.

4. 6. 6 .1,

6. 8 .1, Fig.2,3,4 ATTACH. D 5.a 6 .14. 3, 6 .14. 4, 6.14.5 5.b 6. 4 .1, EPP 06-011, EMERGENCY TEAM

6. 4. 2, FORMATION AND CONTROL 6.14.2 5.c 6.2.2, 6.14.2 5 .d 6.14.6 6.a 6.14.1

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 82 of 105 ATTACHMENT C (Page 5 of 8)

CROSS REFERENCE BETWEEN NUREG 0654. RERP. & WCGS PROCEDURES 0654 RERP Comments Procedure Section Section I H. - E:MERGENCY FACILITIES AND EQUIP:MENT 6.b 6 .14 .1, EPP 06-011, EMERGENCY TEAM Figure 8 & FORMATION AND CONTROL Figure 9 6.c 6.14.7

7. 6.15 EPP 06-011, EMERGENCY TEAM FORMATION AND CONTROL

8. 6.14.3

9. 6.4.3 EPP 06-002, TECHNICAL SUPPORT CENTER OPERATIONS

10. 6.15 EPP 06-018, MAINTENANCE OF EMERGENCY FACILITIES AND EQUIPMENT/COMMUNICATION CHECKS

11. 6.15

12. 6.14.7 EPP 06-011, EMERGENCY TEAM FORMATION AND CONTROL I. - ACCIDENT ASSESS:MENT

1. 6.2 APF 06-002-01, EMERGENCY ACTION LEVELS

2. 6.3.8, EPP 06-017, CORE DAMAGE 6.14.2 ASSESSMENT METHODOLOGY 3.a 6.3.7 EPP 06-012, DOSE ASSESSMENT 3.b 6.3.7 EPP 06-012, DOSE ASSESSMENT

4. 6.3.7 EPP 06-012, DOSE ASSESSMENT

5. 6.14.3

6. 6.3.7 EPP 06-012, DOSE ASSESSMENT

7. 6.3.8, EPP 06-011, EMERGENCY TEAM

6. 8. 4 FORMATION AND CONTROL

8. 6.3.7,

6. 5. 2, 6.6.5, 6.8.2

9. 6.4.2, Lower bound for 6.4.4 iodine measurement capability is 1.0E-7uCi/cc.

10. 6.3.7 EPP 06-012, DOSE ASSESSMENT

11. 6.3.8 EPP 06-011, EMERGENCY TEAM FORMATION AND CONTROL J. - PROTECTIVE RESPONSE 1.a thru 6.3.10, EPP 06-010, PERSONNEL 1.d 6.3.11, ACCOUNTABILITY AND EVACUATION 6.6.5

2. 6.3.10, 6.3.11, Figure 1

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 83 of 105 ATTACHMENT C (Page 6 of 8)

CROSS REFERENCE BETWEEN NUREG 0654, RERP. & WCGS PROCEDURES 0654 RERP Comments Procedure Section Section J. - PROTECTIVE RESPONSE

3. 6.3.9, ,*

6.3.12,

6. 4. 8,

4. 6.3.9, 6.3.12

5. 6.3.10, EPP 06-010, PERSONNEL 6.3.11, ACCOUNTABILITY AND EVACUATION 6.6.5 6.a thru 6.3.13, EPP 06-013, EXPOSURE CONTROL AND 6.c 6.3.14 PERSONNEL PROTECTION EPP 06-011, EMERENCY TEAM FORMATION AND CONTROL

7. 6.3.3 EPP 06-006, PROTECTIVE ACTION RECOMMENDATION

8. Attach. B

9. N/A 10.a & Fig. 1 10.b 10.c 6 .1. 6, 6 .1. 7, 6.10.2 10.d & N/A 10.1 10.m 6.3.4.2 EPP 06-006, PROTECTIVE ACTION RECOMMENDATION

11. & 12. N/A K. - RADIOLOGICAL EXPOSURE CONTROL 1.a thru 6.3, 1.g 6. 4. 6, 6.10.5, 6.10.6

2. 6.3.15, EPP 06-001, CONTROL ROOM 6.3.16, OPERATIONS 6.5.2, EPP 06-002, TECHNICAL SUPPORT 6.6.5, CENTER OPERATIONS 6.8.2 EPP 06-003, EMERGENCY OPERATION FACILITY OPERATIONS 3.a & 3.b 6. 3 .16, 6.3.17, 6.3.18,

6. 4. 2, 6.15.1

4. N/A 5.a & 5.b 6.3.20, 6.3.21

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 84 of 105 ATTACHMENT C (Page 7 of 8)

CROSS REFERENCE BETWEEN NUREG 0654, RERP, & WCGS PROCEDURES 0654 RERP Comments Procedure Section Section 6.a thru 6.3.21, 6.c 6.3.22, ATTACH. E

7. 6.3.13,

6. 4. 6 L. - MEDICAL AND PUBLIC HEALTH SUPPORT

1. 6.10.5

2. 6. 4. 6

3. N/A

4. 6.10.6 M. - RECOVERY AND REENTRY PLANNING AND POST-ACCIDENT OPERATIONS

1. 0 6.21

2. 6.21 EPP 06-008, RE-ENTRY, RECOVERY,

3. 6.21 AND TERMINATION OPERATIONS

4. 6.3.7 This is not specifically identified as a post-accident function N. - EXERCISES AND DRILLS

1. a & 1.b 4.17, 6.19 2.a 6.18 2.b 6.18.2 2.c 6.18.3 2 .d 6.18.4 EPP 06-009, DRILL AND EXERCISE 2 .e (1) 6.18.5 REQUIREMENTS 2.e(2) 6.18.5 3.a thru 6.19.5 3.f

4. 6.19.4

5. 6.19.4

0. - RADIOLOGICAL EMERGENCY RESPONSE TRAINING 1.a 6.17 1.b N/A

2. 6.17.2, EPP 06-021, TRAINING PROGRAMS 6.17.4

3. 6. 4. 6

4. 6.17.4

5. 6.17 P. - RESPONSIBILITY FOR THE PLANNING EFFORT: DEVELOPMENT, PERIODIC REVIEW AND DISTRIBUTION OF EMERGENCY PLANS

1. 6.17

2. 5.3, 6.17.2

3. 6.20.2

Revision: 18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 85 of 105 ATTACHMENT C (Page 8 of 8)

CROSS REFERENCE BETWEEN NUREG 0654. RERP. & WCGS PROCEDURES 0654 RERP Comments Procedure Section Section P. - RESPONSIBILITY FOR THE PLANNING EFFORT: DEVELOPMENT, PERIODIC REVIEW AND DISTRIBUTION OF EMERGENCY PLANS

4. 6.20.2

5. 6.20.2

6. 6.10, 6.11

7. ATTACH. C

8. Table of Contents and ATTACH. C

9. 6.20.1

10. 6.20.2

- END -

Revision: TBD RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 86 of 105 ATTACHMENT D (Page 1 of 2)

WCGS MINIMUM STAFFING FOR EMERGENCIES (Reference Step 3.1.10/Step 3.1.11/)

Capability For Additions: **

FUNCTIONAL AREA (l) POSITION TITLE OR EXPERTISE ON SHIFT 60 m.ins 90 m.ins Plant Operations & Shift Manager (SRO) 1 - -

Assessment of Control Room Supervisor (CRS) 1 - -

Operational Aspects Reactor Operator (RO) 2 - -

Nuclear Station Operator 7*** - -

Emergency Direction Site Emergency Manager l* - -

and Control Notification/ Emergency Communicator 1 3 -

Communication Radiological Accident Off-site Emergency Manager and Assessment & Support staff - - 5 of Operational Accident Assessment Sr. Radiation Protection - 1 -

Expertise RP Personnel 2 6 -

Chemistry Personnel 1 1 -

Plant System Shift Technical Advisor l**** - -

Engineering, Repair &

Mitigative Actions Core/Thermal Hydraulics Eng. - 1 -

Electrical Eng. - 1 -

Mechanical Eng. - 1 -

Radwaste Operator 1* - -

Mechanical Maint. - 1 -

Electrical Maint. l* 1 -

I&C Technician - 1 -

Protective Actions RP Personnel l* 2 -

(In-Plant)

Fire fighting = Fire -- FB per TRM Local Local Brigade(FB) (TRS. 2 .1.b Support Support

)

Rescue Operations and -- 2* Local Local First Aid Support Support Site Access Control Security Personnel All per and Accountability Security Plan TOTAL 16 19 5

• May be provided by shift personnel assigned to other functions.

• • It is a goal to add, in accordance with this table, to the on-shift capabilities when determined necessary after a declared Emergency.

• • • May be provided by a Reactor Operator (RO).

• • • • STA is required in Modes 1-4. An SRO capable of performing STA functions is required in Modes 5, 6 and defueled.

(1)

Discipline-specific skills training for personnel in the above table are contained in discipline-specific training documents such as AP 30D-006, CHEMISTRY TRAINING PROGRAM and AP 30D-100, RADIATION PROTECTION TRAINING PROGRAM. Emergency Plan training is contained in EPP 06-021, TRAINING PROGRAMS.

[Commitment Step 3.2.5]

Revision: TBD RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 87 of 105 ATTACHMENT D (Page 2 of 2)

WCGS MINIMUM STAFFING FOR EMERGENCIES

- END -

Revision: TBD RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 88 of 105 ATTACHMENT E (Page 1 of 3)

EPA/KANSAS PROTECTIVE ACTION GUIDES E.1 Population Protective Action Guides (PAG) For Exposure To A Plume - Early Phase Protective Action PAG (Projected Dose) Comments Evacuation 1-5 rem (Note 1) Evacuation (or sheltering should normally be initiated at 1 rem.

Administration of stable 5 rem (Note 3) Special Populations iodine (Note 2)

(1) Dose is TEDE, which includes effective dose equivalent from external and internal sources and committed effective dose equivalent from inhalation.

Committed dose equivalents to the thyroid and to the skin may be 5 and 50 times larger, respectively.

(2) Use of KI is not planned for general population in Kansas. The State considers prompt evacuation of the public to be a more effective protective measure than administration of KI.

(3) Committed dose equivalent to be thyroid from radioiodine.

E.2 Emergency Worker Dose Limits (for all types of radiological incidents)

E.2.1 Keep all doses ALARA and limit doses to the following TEDE levels:

Dose Limit (Rem) Activity Condition 5 All 10 Protecting valuable Lower dose not property practicable 25 Life saving or protection Lower dose not of large populations practicable

>25 Life saving or protection Only on a voluntary basis of large populations to persons fully aware of the risks involved E.3 Emergency Worker Iodine Dose Limits E.3.1 Keep all doses ALARA and limit iodine doses to the following committed dose equivalent through use of KI and/or respiratory protection:

Dose Limit (Rem) Activity 10 Any worker, any phase No Limit - Life saving No specific upper limit is given for thyroid dose activities or protection since in life saving activities, complete thyroid of large populations loss might be an acceptable sacrifice if a life can be saved. However, this should not be necessary if respirators and/or thyroid protections for rescue personnel are available as a result of adequate planning.

Revision: TBD RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 89 of 105 ATTACHMENT E (Page 2 of 3)

EPA/KANSAS PROTECTIVE ACTION GUIDES

Revision: TBD RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 90 of 105 ATTACHMENT E (Page 3 of 3)

EPA/KANSAS PROTECTIVE ACTION GUIDES E.4 Protective Action Guides For Exposure To Deposited Radioactivity During the Intermediate Phase of a Nuclear Incident Protective Action PAG (Projected Dose) (1) Comments Relocate the general > 2 rem Beta dose to skin may be population (2) up to 50 times higher.

Doses in any single year after the first will not exceed 0.5 rem, and the cumulative dose over 50 years will not exceed 5 rem.

Apply simple dose <2 rem These protective actions reduction techniques (3) should be taken to reduce doses to as low as practicable levels (1) The projected sum of effective dose equivalent from external gamma radiation and committed effective dose equivalent from inhalation suspended materials, from exposure or intake during the first year. Projected dose refers to the dose that would be received in the absence of shielding from structures of the application or dose reduction techniques. These PAGs may not provide adequate protection for some long-live radionuclides.

(2) Persons previously evacuated from areas outside the relocation zone defined by this PAG may return to occupy their residences. Cases involving relocation of persons at high risk from such action (e.g. patients under intensive care) should be evaluated individually.

( 3) Simple dose reduction techniques include scrubbing and/ or flushing hard surfaces, soaking or plowing soil, minor removal of soil from spots where radioactive materials have concentrated, and spending more time than usual indoors or in other low exposure rate areas.

- END -

Revision: TBD RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 91 of 105 ATTACHMENT F (Page 1 of 2)

USAR CHAPTER 15 POSTULATED EVENTS USAR CHAPER 15 POSTULATED EVENTS Feedwater system malfunctions that result in decrease of feedwater temperature Feedwater system malfunctions that result in increase of feedwater system flow Excessive increase in secondary steam flow Inadvertent opening and failure to close of SG ARV or safety vlv Steam system piping failure (inside containment)

Steam system piping failure (outside containment)

Loss of external load (Main Generator trip)

Turbine Trip Inadvertent closure of MSIVs Loss of condenser vacuum & other events resulting in turbine trip Loss of non-emergency AC power to station auxiliaries Loss of normal feedwater Feedwater system pipe break Partial loss of forced RCS flow Complete loss of forced RCS flow RCP shaft seizure ( locked rotor)

RCP shaft break Uncontrolled RCCA bank withdrawal from a subcritical of low-power startup condition Uncontrolled RCCA withdrawal at power RCCA misalignment Startup of inactive RCP at an incorrect temperature eves malfunction resulting in a decrease in the boron concentration in the RCS Inadvertent loading and operation of a fuel assembly in improper position RCCA ejection accidents Inadvertent ECCS operation at power eves malfunction that increases RCS inventory Inadvertent opening, with failure to close, of pressurizer safety or relief valve Break in instrument line or other lines from RCS pressure boundary that penetrate containment SG tube rupture LOCA spectrum Radioactive waste gas decay tank failure Postulated radioactive releases due to liquid tank failure Fuel handling accident (inside containment)

Fuel handling accident (Fuel Building)

Spent fuel cask drop Anticipated transients without scram

Revision: TBD RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 92 of 105 ATTACHMENT F (Page 2 of 2)

USAR CHAPTER 15 POSTULATED EVENTS

- END -

Revision: TBD RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 93 of 105 ATTACHMENT G (Page 1 of 1)

LETTERS OF AGREEMENT Party:

The Coffey County Sheriff's Office Board of Trustees Fire District No. 1, Coffey County, KS Newman Memorial Hospital Coffey County Hospital and EMS Topeka Air Ambulance Inc. (d.b.a. Life Star)

AirMD, LLC d/b/a Life Team Wolf Creek Nuclear Operating Corporation/Callaway Energy Center, Ameren Missouri d/b/a Union Electric Co. Emergency Mutual Assistance Agreement INPO (Support During an Emergency)

Department of Energy**

Nuclear Regulatory Commission**

National Weather Service***

EPRI/INPO/NEI/Member Utilities Coordination Agreement on Emergency Information****

Westinghouse Law Enforcement*****

• As of January 1, 1987, the Letters of Agreement in this Supplement are transferred from Kansas Gas and Electric Company to the Wolf Creek Nuclear Operating Corporation. These Letters of Agreement are maintained on file and may be reviewed upon request.

• • These LOAs will not be updated. They have been superseded by the publication of the "Federal Radiological Emergency Response Plan" in the Federal Register on 11/8/85.

• • • As of 8/25/93, the National Weather Service stated in writing that a Letter of Agreement with WCGS is unnecessary. Their "National Plan for Radiological Emergencies at Commercial Nuclear Power Plants,"

November 1982, remains in effect.

• • • • INPO 03-001, INPO Letter Of Agreement, is maintained on the INPO web page.

• • • • • Agreements with Law Enforcement are safeguards information and, therefore, are controlled by Security.

- END -

Revision: TBD RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 94 of 105 ATTACHMENT H (Page 1 of 1)

REPORTING OF INCIDENTS PER 10 CFR 20

.2202 I Teleohone & Tele2raoh .2203 Written Immediate Notification 24 Hour Notification 30 Day Notification RADIATION INCIDENTS VALUES WCGS NRC KDEM WCGS NRC KDEM WCGS NRC KDEM TEDE 25 REM (.25 Sv) X X X X X X 5 REM (.05 Sv) X X X X X X MPE .1201 X X X X Shallow dose to 250 Rad X X X X X X skin or extremities 50REM X X X X X X in excess of MPE .1201 X X X X Lens dose 75 REM (.75 Sv) X X equivalent 15 REM (.15 Sv) X X X MPE .1201 X X X The release of SALi X X X X X X radioactive 1 ALI X X X X X X material inside or MPE .1201 X X X X outside ofa restricted area X Indicates notification is required MPE Maximum Permissible Exposure DAC Derived Air Concentration WCGS Wolf Creek Generating Station NRC Nuclear Regulatory Commission KDEM Kansas Division of Emergency Management ALI Annual Limit on Intake

- END -

Revision : TBD RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP)

Inf ormation Use Page 95 of 105 FI GURE 1 EFFECTIVE 10-MILE EPZ , SUBZONES AND EVACUATI ON ROUTES ii I l I" I

" I*,l ," lI " I" "

! ,.r" I" ~

I

/" f I"

l " Il l " I " .I! "

" # ~ 4 I

=~

I NW-2 i N-2 ______________

NE-2 .....,.........,

t N- 1 NE* l J

NE-3 T

_]

To Neosho Rapids Registration Center

\\ \\ \ \ \ \. \ \\ . \ \ \ \ \ \ \ \

" \ \

\ \

\ \

\

\

" \ " t, t, \\\

\

t,

- END -

Revision: TBD RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 96 of 105 FIGURE 2 MINIMUM SHIFT STAFFING NOTE STA is required in Modes 1-4. An SRO capable of performing STA functions is required in Modes 5, 6 and defueled.

SHIFT MANAGER (SM) i.---------,

(1 SRO)

I I

I ENS COMMUNICATOR I

~ I

( 1)

-- SHIFT TECHNICAL ADVISOR (STA)

( 1)

OFFSITE COMMUNICATOR I (1) f-----+ I I

I I

I I

1f I

I CONTROL ROOM SUPERVISOR (CRS) i.---- - - - _I (1 SRO)

REACTOR OPERATORS (RO) _____. STATION OPERATORS (2) (5)

CHEMISTRY TECHNICIAN

-- (2)

- HEALTH PHYSICS TECHNICIAN (3)

... Direction Technical Guidance SRO = Senior Reactor Operator STA= Shift Technical Advisor

- END -

Revision: TBD RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 97 of 105 FIGURE 3 TSC/OSC ORGANIZATION SITE EMERGENCY MANAGER RADIOLOGICAL MAINTENANCE ADMINISTRATIVE OPERATIONS COORDINATOR COORDINATOR COORDINATOR COORDINATOR

-- FACILITY TECHNICIAN 1---

MAINTENANCE PLANNER ADMINISTRATIVE ASSISTANT 1---

ENS COMMUNICATOR

'TEAM WAREHOUSE SECURITY OPERATIONS

- DIRECTOR 1---

SUPPORT COORDINATOR

- 1---

RECORDER TEAM MAINTENANCE ENGINEERING

- COMMUNICATOR ASSISTANT

• • • • • • • • • • • • • • • • • • • • - COORDINATOR I

EMERGENCY OPERATIONS ENGINEERING

RESPONSE

COMMUNICATOR TEAM TEAM

- END -

Revision: TBD RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 98 of 105 FIGURE 4 EOF ORGANIZATION OFF-SITE EMERGENCY MANAGER OPERATIONS RADIOLOGICAL ADMINISTRATIVE COORDINATOR COORDINATOR COORDINATOR OPERATIONS HPN FACILITY ADMINISTRATIVE RECORDER COMMUNICATOR TECHNICIAN ASSISTANT DOSE ASSESSMENT TEAM DIRECTOR COORDINATOR I

DOSE TEAM ASSESSMENT COMMUNICATOR TECHNICIAN LOCATED AT COUNTY EOC EMERGENCY

- RESPONSE TEAM REPRESENTATIVE AT COUNTY

- END -

Revision: TBD RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 99 of 105 FIGURE 5 PUBLIC INFORMATION ORGANIZATION KGE/KCPU COFFEY COUNTY WOLF CREEK STATE OF FEMA PUBLIC NRC PUBLIC KEPCo PUBLIC PUBLIC KANSAS PUBLIC INFORMATION INFORMATION REPRESENTA Tl INFORMATION INFORMATION INFORMATION OFFICER OFFICER VE OFFICER OFFICER OFFICER (JIC) (JIC)

(JIC) (JIC) (JIC) (JIC)

WOLF CREEK PUBLIC REPRESENTATIVE INFORMATION TO THE STATE MANAGER (SEOC)

(JIC)

I I I ONSITE PUBLIC TECHNICAL INFORMATION NEWS WRITER INFORMATION SUPPORT MESSENGER (JIC) COORDINATOR (JIC) (JIC)

(TSC)

I OFFSITE PUBLIC PHONE TEAM MEDIA CENTER INFORMATION MANAGER MANAGER COORDINATOR (JIC) (MC)

(EOF)

MEDIA LIAISON (MC)

MEDIA PHONE TEAM MONITORING (JIC)

TEAM MEDIA REGISTRAR (MC)

AUDIO VISUAL SUPPORT (MC)

- END -

6

H  :;a

~ (D H) <:

EMERGENCY ORGANIZATIONS INTERFACES 0 1-i I-'*

(/)

s I-'*

PJ 0 (AT UNUSUAL EVENT LEVEL) rt I-'* ..

~

• * * * * *

• CONTROL ROOM 0

~ f-3

• to C: 0

• (AT ALERT OR HIGHEF, CLASSIFICATION)

(/)

(D

• TECHNICAL/OPERATIONS ~

tr:!

SUPPORT CENTER 2 0 H

tr:!

• *  :;a 0 t----1 MEDIA G) 0 PHONE

• ONSITE ONSITE MONITORING TEAM*

tr:!

z G'J H

OFFSITE OFFSITE TEAM* 0 0 i-<  ::i,:,

0 t----1

• I I  :;a G) hj tr:!

r,:, 2

• EMERGENCY OPERATIONS INFORMATION CLEARINGHOUSE* z H

G)

~tr:!

a

;a FACILITY (EOF) H C: tr:! G'J tr:!

z *

• MEDIA CENTER

• N  :;cJ

i,:, tr:!

a tr

!

'1j z 0 f-3

• -o I HO'\

0 i-<

I I I I I z  :;a H tr:!

COUNTY STATE OTHER z (/)

'1j EMERGENCY EMERGENCY OFFSITE f-3 LOCAL tr:! 0 OPERATIONS OPERATIONS USNRC SUPPORT SUPPORT  :;a z(/)

CENTER CENTER hj

i,:, tr:!

0 I I tr:!

(/)

'1j t----1

i,:,

OTHER z SUPPORT FEMA STATE '1j AGENCIES PJ LO (D

i,:,

f-' '1j NORMAL INTERFACE 0 0 0

• *

• TEMPORARY INTERFACE 0

(j)

I H) 0

• Any of these functions may be activated at any emergency classification level. 0 f-' N 0

(Jl

H  ::,::,

~ (D Hi 0

I-'*

-o o= ~o o~-

EOF@BETO r; (/)

• Junction L'J<Fl1EW  ;:l Pl I-'*

0

. 1-~-- rt I-'* ..

~

J § .. 0

~ 1-3 td

________j CONFERENCE C<NTER j~ C:

(/)

tJ

=~(/1 JI I

(D V.Ull<\MAUEN\\llllE

=PflOCESSING 0 *---: PABFENCf

- 1 f:1 FBlETR.

~

0 G}

(/)

~

tJ H

0 t-1

-u M 0 ED'IIAADP. 3: G}

Mcel\BE M H SUPPOOT  ::,::, 0 BIJilOING G}

AMAAEARHAAT  ::i:i BIACl<BEAA BOSIN REOlfATION AAEA MAlERWS C<NTER M t-1 z

0 M I-<; 3:

~M

~

M M M G}

z '1/AAOOUSE <MRFlOW S10llAGE (/)  ::,::, M tJ OlM ANN l<EUY BlllG --EJ '"d 0

z M

--.J hj z

-o I-<;

BEECH CL'!DECESSW. (/)

OPS ADMIN ADM.'Jll1llAIION BlllG M  ::,::,

BlllG M

~

(/)

hj 0 0 H z t-1 (/)

H M 1-3 H hj M t-1

~ ~ (/)  ::i:i

!gi z

~~i hj Pl lQ (D

i:i I-' hj 0

I-' 0 0,

~-x X X X X 0 I Hi 0 0

I-' N 0

(Jl

Revision: TBD RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 102 of 105 FIGURE 8 AIRBORNE PATHWAY SAMPLING LOCATIONS

• FIXED SAMPLING LOCATIONS

- END -

Revision: TBD RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 103 of 105 FIGURE 9 DIRECT RADIATION PATHWAY SAMPLING LOCATIONS

• DOSIMETER LOCATIONS

- END -

Revision: TBD RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 104 of 105 FIGURE 10 WATERBORNE PATHWAY SAMPLING LOCATIONS Q C D

N E WATERBORNE PATHWAY SAMPLING LOCATIONS e = DRINKING WATER A = SURFACE WATER

• = GROUND WATER * = SHORELINE SEDIMENT

Revision: TBD RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)

Information Use Page 105 of 105 FIGURE 11 FIXED SIREN SITING 28TH AD. 28TH RD 27lli RD. . - .... , .. 27TH RD.

TO DJIPORIA }

OLD HWY.SO 26Tli RD.

TO GAANETT 25TH l,D.

I IWY.31 24TH f10. 24Ti't RO.

23RD RD 22.ND RD.

56.25 21ST no.

'(ITH RD.

D 16TH RD.

. ....... l 19TH RD .

18TH RD .

17TH AD. 17TH RD .

. 78.75

-*--~-

~ I,;

16TH RD. TO GAA!'ETT 16TH RD .

/ 15TH RD.

15TH RD.

14TH RD. 14TH RD.

E 13TH RD. 13TH AD.

101.25

• ,rn RD. TO GAAIEIT t2TH RD.

11TH RD. 11TH RD.

10TH RD.

9TH AD.

10TH RD.

F 8TH RD.

Tn--i RD.

6TH RD 5TH RD HWY.58 3RD RD.

2ND RD.

1ST RO.

SIREN LOCATIONS END END

Enclosure Ill to WO 18-0016 Wolf Creek Nuclear Operating Corporation On-Shift Staffing Analysis Report (192 pages)

Wolf Creek Nuclear Operating Corporation On-Shift Staffing Analysis Report r

Prepared by:- ~JJ)1o-,u____- I 10/26/2017 Reviewed by: 11/8/2017 Superintendent, Emergency Planning Approved by:

Site Vice President Rev 1

On-Shift Staffing Analysis Report Revision 1

Purpose:

The 2011 amendments to 10 CFR 50 Appendix E required nuclear power plant licensees to perform a detailed staffing analysis for specified scenarios to demonstrate that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of the assigned functions. Revision O of the Wolf Creek On-Shift Staffing Analysis (OSSA) Report was completed on December 12, 2012.

Quick Hit QH-2017-1438, "Assessment of Chemistry and Health Physics use within the On-Shift Staffing Analysis," was initiated on February 27, 2017 to determine if the number of chemistry and HP (Health Physics) personnel required to be on shift could be reduced. The QH concluded that the OSSA should be re-performed. Condition Report 111422 was initiated on 3/6/2017 to re-perform the OSSA. The OSSA has been re-analyzed with Revision 1 being completed 12/5/2017 when the License Amendment Request was reviewed by the Plant Safety Review Committee. In addition to determining if the number of HP and chemistry personnel could be reduced, this reanalysis also evaluated if the emergency notification system communicator (ENS) and the off-site communicator (OSC) could be combined into one position with one person fulfilling the position.

Since the revised OSSA supports reductions to staffing levels on shift that must be approved by the NRC prior to implementation in accordance with 50.54(q), a draft of this document and associated Corrective Action Program documents will be included in a License Amendment Request. Once the License Amendment Request is approved, the OSSA and associated Corrective Action Program documents will be issued by the licensee.

Note that HP technicians will be hereafter referred to as Radiation Protection (RP) technicians to align with station references to this work group, unless quoting a procedure step verbatim.

Analysis Process:

Interim Staff Guidance (NSIR/DPR ISG-01) supporting the Emergency Preparedness Rule endorses the staffing analysis methodology provided in NEI 10-05, Revision 0, "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities," as an acceptable methodology for conducting the detailed staffing analysis. NEI 10-05 methodology was used for the reanalysis.

A multi-disciplinary team performed the reanalysis. The team included:

• Operations - Ed Winn

• Radiation Protection - Ryan Adams

• Chemistry - Neil Woydziak

• Licensing - Lucille Stone 1

On-Shift Staffing Analysis Report Revision 1 NEI 10-05 methodology includes the following elements:

• Define the on-shift emergency response organization (ERO) staffing and response time requirements

• Define site-specific event scenarios meeting ISG requirements

• Perform an OSSA for each event

• Perform a Time Motion Study (TMS) to analyze the results of the OSSA, if deemed necessary The result of the assessment is to be incorporated into the site Emergency Plan and is considered part of the licensing basis.

Minimum Shift Staffing and Response Times The minimum staffing reflected in procedure AP 06-002, Radiological Emergency Response Plan (REMP), Attachment D, WCGS Minimum Staffing for Emergencies, is the Minimum Shift Crew Composition as listed in Table 5.2.1-1 of the Technical Requirements Manual.

AP 06-002, Radiological Emergency Response Plan (on hold pending approval)

Attachment D WCGS Minimum Staffing for Emergencies Position Revised On-Shift (pending approval)

Shift Manager (SRO) 1 Control Room Supervisor (CRS) 1 Reactor Operator (RO) 2 Nuclear Station Operator (NSO) 1 7 Shift Technical Advisor (STA) 1 Radiation Protection (RP) Personnel 2 Chemistrv Personnel 1 Communicator (NSO) 1 Total 16 Fire Brigade 2 5 First Aid & Rescue 3 2 Security Per Security Plan 1

One NSO 1s a dedicated Emergency Communicator (ENS and OSC) and cannot be on Fire Brigade, referred to as NSO #1/2 in the OSSA.

2 Fire Brigade is a collateral duty of 5 NSOs.

3 First Aid & Rescue is a collateral duty provided by Fire Brigade/Security.

Augmentation for RP technicians, chemistry technicians and emergency communicators is expected within 90 minutes. For the purposes of this analysis 90 minutes was used as the time period for the conduct of on-shift ERO response actions.

2

On-Shift Staffing Analysis Report Revision 1 The Operations Watch Bill (on hold pending approval) was used to conduct the OSSA re-analysis.

Position Primary Functions Shift Manager Mitigation & Emergency Planning Control Room Supervisor Mitigation & Emergency Planning Shift Technical Advisor Mitigation & Emergency Planning Reactor Operator Mitigation & Emergency Planning Balance of Plant (RO) Mitigation & Emergency Planning OFN KC-016 Dutv Person Fire Response Turbine Building Watch (NSO) Mitiqation Auxiliary Building Watch (NSO) Mitigation Site Watch (NSO) Mitiqation Emergency Notification System / Emergency Planning Off-Site Communicator (NSO)

Fire Brigade Leader (NSO) Mitiqation Nuclear Station Operator Mitigation Nuclear Station Operator Mitiqation Radiation Protection Technician Control Room Technician/Access Control and Habitability Radiation Protection Technician Survey and Job Coverage Chemistry Technician Control Room/Dose Assessment Identification of Required Scenarios The rule requires that the following events which result in classification by the approved emergency action level scheme be analyzed:

1. Condition IV events as described in the Updated Safety Analysis Report

2. Station Design Basis Threat

3. Response actions for an "aircraft probable threat" in accordance with 10 CFR 50.54(hh}(1) and as discussed in RG 1.214, "Guidance for Assessment of Beyond-Design-Basis Aircraft Impacts;" and

4. Control room fire leading to evacuation and remote shutdown , as referenced in Information Notice 95-48 "Results of On-Shift Staffing Study."

The rule requires additional analyses to be performed unless justification exists that would allow the licensee to not perform them for:

1. Station Blackout (using existing USAR assumptions)

2. Appendix R Fire Response

3. SAMG Response (to the extent performed by on-shift personnel prior to augmentation) 3

On-Shift Staffing Analysis Report Revision 1 The team verified that the fourteen events analyzed per guidance provided in the NRC Interim Staff Guidance and NEI 10-05 for Revision O of the OSSA still applied. The events include:

• Eight Condition IV design basis accidents from the USAR

• Design Basis Threat and Probable Aircraft Threat

• Station Blackout

• Fire with control room evacuation and alternate shutdown

• SAMG

• Appendix R Fire Response.

It was determined that SAMG and Appendix R Fire Response are bounded by other events.

Twelve events were carried forward for analysis. Appendix A to this report documents identification of the required scenarios.

The OSSA was conducted by a multi-disciplined team using site procedures to determine if tasks have been sufficiently analyzed for performance by the minimum on-shift staff as designated in the Emergency Plan/Operations Watch Bill. Task areas analyzed included:

• Event Mitigation (EOP/AOP, other site procedures)

• Fire Response (as determined by the scenario)

• RP/Chemistry Functions (as specified in site response procedures)

• Emergency Preparedness Functions (NUREG-0654 Table B-1/ISG -01)

This part of the analysis was not designed to identify staffing deficiencies. This part of the analysis documents areas requiring further study as designated in NEI 10-05.

Summary of Areas Requiring Further Evaluation Based on Initial Analysis:

1. Design Basis Threat Response Further evaluation is required for Nuclear Station Operator #1 /2 due to performance of NRC notifications (T5/L 13 function) per NEI 10-05, Table 3.1.

The majority of shift personnel take refuge as directed by site procedure.

2. Steam System Piping Failure (Major)

Further evaluation required for Nuclear Station Operator #1/2 due to performance of NRC notifications (T5/L 13 function) per NEI 10-05, Table 3.1.

3. Feedwater System Piping Break Further evaluation is required for Nuclear Station Operator #1 /2 due to performance of NRC notifications (T5/L 13 function) per NEI 10-05, Table 3.1.

4

On-Shift Staffing Analysis Report Revision 1

4. Reactor Coolant Pump Shaft Seizure (Locked Rotor)

Further evaluation is required for Nuclear Station Operator #1 /2 due to performance of NRG notifications (T5/L 13 function) per NEI 10-05, Table 3.1.

5. Reactor Coolant Pump Shaft Break Bounded by the analysis for Event #4.

6. Spectrum of Rod Cluster Control Assembly Ejection Accidents Further evaluation is required for Nuclear Station Operator #1/2 due to performance of NRG notifications (T5/L 13 function) per NEI 10-05, Table 3.1.

7. Steam Generator Tube Failure Further evaluation is required for Nuclear Station Operator #1/2 due to performance of NRG notifications (T5/L 13 function) per NEI 10-05, Table 3.1.

8. Loss of Coolant Accident - Large Break Further evaluation is required for Nuclear Station Operator #1/2 due to performance of NRG notifications (T5/L 13 function) per NEI 10-05, Table 3.1.

9. Design Basis Fuel Handling Accident This event would not occur when only the minimum on-shift staff is present.

The staffing requirements were not included in the OSSA, since the "minimum on-shift staff' scenario would not apply.

10. Aircraft Probable Threat Further evaluation is required for Nuclear Station Operator #1/2 due to performance of NRG notifications (T5/L 13 function) per NEI 10-05, Table 3.1.

11. Station Blackout Further evaluation is required for Nuclear Station Operator #1/2 due to performance of NRG notifications (T5/L 13 function) per NEI 10-05, Table 3.1.

12. Fire with Control Room Evacuation and Remote Shutdown Further evaluation is required for Nuclear Station Operator #1/2 due to performance of NRG notifications (T5/L 13 function) per NEI 10-05, Table 3.1.

Preliminary analysis indicates a need for additional personnel to respond to this event:

a. Five personnel would be needed for Fire Brigade. Other on-shift NSO, personnel would be performing EP and remote shutdown functions; and therefore would not be available to fight the fire.

5

On-Shift Staffing Analysis Report Revision 1 Preliminary Report by Department:

• Operations - For all events: NRC Communication (per NEI 10-05, this task should be treated as a continuous action per 10 CFR 50.72(c)(3) and 73.71(b)(1) which requires licensees reporting events to "maintain an open and continuous communications channel with the NRC Operations Center upon request by the NRC.") All emergency communications and notifications will be performed by one communicator.

For events requiring activation of the Fire Brigade - Five nuclear station operators, and one person to perform OFN KC-016 actions.

• Radiation Protection - During this analysis, no conflicts with current staffing were identified.

• Chemistry - During this analysis, no conflicts with current staffing were identified.

• Security - Not evaluated. Security staffing is per the Security Plan.

Functional Analysis of Collateral Duties (TMS)

Using the event analysis results that identified positions with multiple/collateral duties assigned, the team performed a function/responsibility analysis. The event narratives describe the assignment of tasks for each position. Specific resources needed to perform initial event response actions were identified from the procedures and documented.

The team determined when other on-shift resources would be required and identified the time required to perform expected emergency plan functions. Times were determined based on Time Critical Action/Time Sensitive Action documentation and review of videotaped simulator scenarios involving the analyzed events.

Based on the analysis, the following conflicting collateral duty functions were identified:

Position Primary Functions Conflicting Collateral Duties Shift Manager Mitigation & Emergency Planning Control Room Supervisor Mitigation & Emergency Planning Shift Technical Advisor Mitioation & Emeroency Planning Reactor Operator Mitigation & Emergency Planning Balance of Plant (RO) Mitigation & Emergency Planning OFN KC-016 Duty Person Fire Response Turbine Building Watch (NSO) Mitigation Fire Brigade Auxiliary Building Watch (NSO) Mitigation Fire Brigade Fire Brigade Leader (NSO) Mitigation Fire Brigade Nuclear Station Operator (NSO) Mitigation Fire Brigade Nuclear Station Operator (NSO) Mitigation Fire Brigade Site Watch (NSO) Mitioation Emergency Notification System / Emergency Planning Off-Site Communicator (NSO)

Radiation Protection Technician Control Room/Access Control &

Habitability Radiation Protection Technician Job Coverage - In-Plant surveys Chemistry Technician Control Room/Dose Assessment 6

On-Shift Staffing Analysis Report Revision 1 The following Condition Reports, which will be initiated upon approval of the OSSA, were initiated to confirm current practices:

OOxxxxxx - As a result of Revision 1 of the On Shift Staffing Analysis, the following procedures need revised. AP 15C-003 and applicable EMGs/OFNs/ALRs need revised to state that chemistry samples will not be collected following an emergency

_classification declaration until the TSC is staffed (90 minutes). The chemistry technician on-shift will be in the control room performing dose calcs and will be unable to collect samples until the TSC is staffed. The request for a sample may be communicated to the chemistry technician in the control room at any time. The control room chemistry technician would then be responsible for communicating this request to the augmenting chemistry technician upon their arrival at the technical support center.

OOxxxxxx - As a result of Revision 1 of the On Shift Staffing Analysis, the following procedures need revised. AP 15C-003 and EPP 06-001 need to be revised to allow the RP technician to go to the control room when an emergency classification declaration is announced to perform habitability and to set up the access control entrance and exit of the control room. Following those activities, the RP tech is to communicate with the SM that habitability has been performed and the access control station has been set up prior to leaving the CR to return to Access Control area.

The responses to these CRs will be included in the bases package for the OSSA re-analysis.

Details:

The NRC amended 10 CFR Part 50, Appendix E, Section IV.A, "Organization," to address concerns regarding the assignment of tasks or responsibilities to on-shift emergency response organization (ERO) personnel that would potentially overburden them and prevent the timely performance of their emergency plan functions. Licensees must have enough on-shift staff to perform specified tasks in various functional areas of emergency response. All shifts must have the capability to perform these emergency functions 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, 7 days a week, to minimize the impact of radiological emergencies and to provide for the protection of public health and safety. Events identified for analysis are listed in Appendix A.

The OSSA (Phase II of NEI 10-05) was conducted using NEI 10-05, "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities."

The analysis was conducted in three steps:

• Identification of events for analysis

• Determination of minimum shift staffing complement

• Tabletop analysis of the on-shift staffing resources required for response to the identified events.

Revision O of the OSSA Report was completed on December 12, 2012. Quick Hit QH-2017-1438, "Assessment of Chemistry and HP use within the On-Shift Staffing Analysis," was initiated on February 27, 2017 to determine if the number of chemistry and RP personnel required to be on shift could be reduced. This reanalysis also evaluated if the emergency notification system communicator (ENS) and the off-site communicator (OSC) could be 7

On-Shift Staffing Analysis Report Revision 1 combined into one position with one person fulfilling the position. The QH concluded that the OSSA should be re-performed demonstrate that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent timely performance of their assigned functions as a result of staffing adjustments. Condition Report 111422 was initiated on 3/6/2017 to re-perform the OSSA. The OSSA has been re-analyzed with Revision 1 being completed 12/5/2017.

The minimum shift staffing complement for the OSSA re-analysis was determined from the Operations Watch Bill. Each position was given a unique designator for inclusion in the analysis tables.

Position OSSA Identification Primary Function Shift Manaoer SM Mitioation & Emeroencv Plannino Control Room Supervisor CRS Mitioation & Emeroencv Plannino Shift Technical Advisor STA Mitigation & Emergency Planning Reactor Operator R0#1 Mitioation & Emeroencv Plannino Balance of Plant (RO) R0#2 Mitigation & Emergency Planninq OFN KC-016 Duty Person Extra RO/NSO Fire Response Emergency Notification System / NS0#1/2 Emergency Planning Off-Site Communicator (NSO)

Site Watch (NSO) NS0#3 Mitiqation Fire Brioade Leader (NSO) NS0#4 Mitioation Auxiliary Building Watch (NSO) NSO#S Mitiqation Turbine Buildino Watch (NSO) NS0#6 Mitioation Nuclear Station Operator (NSO) NS0#7 Mitiqation Nuclear Station Operator (NSO) NS0#8 Mitioation Radiation Protection Technician RP#1 Control Room/Access Control &

Habitability Radiation Protection Technician RP#2 Job Coverage- In-plant surveys Chemistry Technician CH Control Room/Dose Assessment The Emergency Notification System and Off-Site Communicator are one position. Numbering for the single position will remain NS0#1/2.

Fire Brigade composition:

Nuclear Station Operator #4 - Fire Brigade Leader Nuclear Station Operator #5 - Fire Brigade Member Nuclear Station Operator #6 - Fire Brigade Member Nuclear Station Operator #7 - Fire Brigade Member Nuclear Station Operator #8 - Fire Brigade Member Using the guidance in NEI 10-05, the team re-performed a tabletop review of on-shift actions in response to those events identified in Appendix A. This review included the identification of needed resources and the time required to complete identified actions until augmentation of the on-shift ERO. Each event was analyzed separately and documented in the applicable event analysis tables.

8

On-Shift Staffing Analysis Report Revision 1 The reanalysis was conducted by first reviewing the event described in Appendix A. This review provided the team with a basic understanding of the event and resulting emergency classification. The team reviewed emergency, off-normal and other operating procedure actions and identified the on-shift person responsible for performing each action. Specific resources needed to perform initial event response actions were identified from the procedures and documented as per the guidance in NEI 10-05.

The team determined when other on-shift resources would be required and identified the time required to perform expected emergency plan functions. Times were determined based on Time Critical Action/Time Sensitive Action documentation. This information was documented on the applicable tables identified in NEI 10-05.

The Emergency Plan functions for the event were reviewed and assigned to the on-shift resource responsible for performance of the identified function and documented as per NEI 10-

05. Finally, the on-shift resources and their actions were summarized in a table (NEI 10-05 Table 1), with conflicts requiring additional analysis identified as per NEI 10-05.

NEl-10-05 presents certain assumptions and limitations to be used during the analysis. The team used these assumptions and limitations in this re-analyses.

On-Shift Staffing Analysis Assumptions (NEI 10-05)

1. Unless otherwise specified by initial conditions, it is assumed that the site is in Mode 1, Power Operations and operating at 100% power:

2. The event being analyzed occurs during off-normal work hours at a time when most ERO responders are not on site. Per AP 06-002, Radiological Emergency Response Plan, Attachment D, WCGS Minimum Staffing for Emergencies, augmentation for RP Technicians, Chemistry Technicians and Communicators is expected within 90 minutes.

For the purposes of this analysis -90 minutes was used as the time period for the conduct of on-shift ERO response actions.

3. The on-shift complement is limited to the minimum required number and composition as described in the Emergency Plan/Operations Watch Bill.

4. All on-shift positions are filled.

5. The DBT assumes a HOSTILE FORCE breached the Protected Area Fence but was neutralized with no adverse consequences to plant safety.

6. On-shift personnel can report to their assigned locations within time frames to allow for performance of assigned actions.

7. However, the DBT analysis must account for expected constraints on the movement of personnel.

8. The on-shift staff possesses the necessary Radiation Worker qualifications to obtain normal dosimetry and to enter Radiologically Controlled Areas (not high, locked high or very high radiation areas) without the aid of RP Technicians.

9

On-Shift Staffing Analysis Report Revision 1

9. Operations personnel are qualified per regulation. Any "safety-related operator action" will be done by a member of the on-shift staff.

10. Fire Brigade actions will not be evaluated as part of this assessment UNLESS a role/function/task from another major response area is assigned as a collateral duty.

11. RP and Chemistry Technicians are qualified to perform the range of tasks expected by their position.

12. Security actions will not be evaluated UNLESS a role/function/task from another major response area is assigned as a collateral duty.

13. Simple and brief communications are acceptable collateral duties (i.e., plant page announcement/call for offsite assistance). This DOES NOT include initial notifications to Off-site Response Organization or NRC.

14. Performing a peer check is an acceptable collateral duty.

Site- Specific On-Shift Staffing Analysis Assumptions

• Scenarios #2 through #8 and #11 have concurrent loss of offsite power.

• Loss of offsite power renders the normal control access point non-functional. However, fast access dosimetry is maintained available for emergency situations.

• Fire Brigade is a collateral duty for 5 NSO's.

• First Aid and Rescue is a collateral duty provided by Fire Brigade and Security.

• Procedures require dose assessment and habitability for any classification of Alert or higher (EPP 06-001).

• OFN KC-016 Operator required for Appendix R commitments (License Amendment

1. 191 12/16/2012) and cannot be assigned other functions (TRM 5.2.1 ).

10

On-Shift Staffing Analysis Report Revision 1 In addition to site Emergency Planning procedures, the following procedures were used in the analysis. Any future changes to these documents will need to be evaluated for impact on the analysis. (Revision dates effective as of 9/27/2017)

Event Procedure Title Procedure Basis Document Number Revision/Date Revision/Date All Al 21-016, Operator Time Critical Actions R/14, 9/14/2017 N/A Validation All AP 21-001, Conduct of Operations R/80, 5/10/2017 N/A All AP 21-004, Operator Response Time Program R/4B, 7/6/2015 N/A 11 EMG C-0, Loss of All AC Power R/41, 9/27/2017 R/24, 8/3/2017 7 EMG C-31, STGR with Loss of Reactor R/25A, 1/30/2017 R/15A, 1/30/2017 Coolant - Subcooled Recovery Desired 7 EMG C-32, SGTR with Loss of Reactor R/24A, 1/30/2017 R/12A, 1/30/2017 Coolant - Saturated Recovery Desired 1, 2, 3, 4, 5, EMG E-0, Reactor Trip or Safety Injection R/39, 11/7/2016 R/27, 11/7/2016 6, 7, 8, 11 2, 3, 8 EMG E-1, Loss of Reactor or Secondary R/27A, 3/30/2017 R/17, 12/15/2016 Coolant 2,3, 7 EMG E-2, Faulted Steam Generator Isolation R/21, 8/5/2015 R/13, 8/5/2015 7 EMG E-3, Steam Generator Tube Rupture R/34B, 7/13/2017 R/21A, 7/13/2017 3,4, 5,6 EMG ES-03, SI Termination R/24, 3/21/2015 R/15A, 2/2/2017 2,6 EMG ES-11, Post LOCA Cooldown and R/24, 2/28/2017 R/12, 2/28/2017 Depressurization 6,8 EMG ES-12, Transfer to Cold Leg R/22A, 9/11/2014 R/15, 3/27/2017 Recirculation 2,4, 5,6, 8 EMG F-0, Critical Safety Function Status Trees R/17, 4/23/2014 R/13A, 8/20/2015 6 EMG FR-C3, Response to Saturated Core R/8, 6/19/2007 R/4A, 8/19/2010 Conditions 2 EMG FR-S1, Response to Nuclear Power R/23, 4/24/2015 R/13, 4/24/2015 Generation/A TWS 9 OFN KE-018, Fuel Handling Accident R/14A, 6/22/2017 N/A 1, 11 OFN KJ-032, Local Emerqencv Diesel Startup R/13B, 10/27/2016 N/A 10 OFN MA-038, Rapid Plant Shutdown R/28A, 9/7/2017 R/18, 7/7/2016 11 OFN NB-030, Loss of AC Emergency Bus R/34, 4/20/2017 N/A NB01 (NB02) 12 OFN RP-017, Control Room Evacuation R/49, 7/6/2017 N/A 1, 10 OFN SK-039, Security Events R/24, 1/3/2017 N/A 2, 7,8, 11 STN KAT-001, Technical Support Diesel R/31A, 7/6/2016 N/A Generator Operation All STN TCA-001, Manual Time Critical Action R/5, 5/19/2016 N/A Timinq 10 SYS AC-322, MSR 2nu Stage Reheat R/19, 1/17/2017 N/A Operations 1 SYS GK-122, Manual CRVIS Lineup R/24, 5/11/2017 N/A 1 SYS GK-123, Control Building NC Unit Startup R/31, 10/28/2016 N/A and Shutdown 4, 5,6 SYS KJ-121, Diesel Generator NE01 and R/52A, 10/26/2016 N/A NE02 Lineup for Automatic Operation 11 SYS SY-120, Sharpe Diesel Operation and R/13, 5/22/2017 N/A Alignment to Site 11

On-Shift Staffing Analysis Report Revision 1 APPENDIX A Analyzed Events and Accidents Analysis Plant ECL Analysis Summary Description of Event or Accident Reference Document(s)

1. Mode Required?

1 Land and/or waterborne HOSTILE ACTION directed 1 Safeguards Plan OFN SK-39, Site Area Yes against the Protected Area by a HOSTILE FORCE. Security Procedures Emergency Assume adversary characteristics defined by the Design Basis Threat (DBT).

2 Steam system piping failure (major) 2 USAR § 15.1.5 & Fig. 15.0-10; Site Area Yes APF 06-002-01 EAL-4, MSLB-13 Emergency (main steam line broken);

however, APF 06-002-01 EAL-1 RER3 (thyroid dose > 500 mrem),

based on USAR Tables 15.1-3 &

15.1-4.

3 Feed-water system pipe break 1 USAR § 15.2.8 & Fig. 15.0-14; Alert Yes APF 06-002-01 EAL-4, MSLB-6 (faulted SG, and can't isolate the pipe).

4 Reactor coolant pump shaft seizure (locked rotor) 1 USAR § 15.3.3 & Fig. 15.0-15; Site Area Yes APF 06-002-01 EAL-1, RER3 Emergency (thyroid dose > 500 mrem), based on USAR Tables 15.3-3 & 15.3-4.

5 Reactor coolant pump shaft break (bounded by Event #4) 1 USAR § 15.3.4 & Fig. 15.0-15; Site Area Yes assume same radiological as #4, Emergency above, based on statement in § 15.3.4.2 that "consequences are no worse than ... "

6 Spectrum of rod cluster control assembly ejection 1 USAR § 15.4.8 & Fig. 15.0-16; General Yes accidents APF 06-002-01 EAL-1, RER3 Emergency (thyroid dose > 500 mrem), based on USAR Table 15.4-4.

12

On-Shift Staffing Analysis Report Revision 1 Analysis Plant ECL Analysis Summary Description of Event or Accident Reference Document(s)

1. Mode Required?

7 Steam generator tube failure 1 USAR § 15.6.3 & Fig 15.0-24; General Yes APF 06-002-01 EAL-2, STGF5 Emergency (assumes ruptured SG that's also faulted, with some failed fuel).

See also USAR Tables 15.6-4 § lll(a) & 15.6-5.

8 Loss-of-coolant accidents, resulting from the spectrum of 1 USAR § 15.6.5; Figs 15.0-25 & General Yes postulated piping breaks within the reactor coolant 15.6-4; Tables 15.6-6 & 15.6-8; Emergency pressure boundary (large break) APF 06-002-01 EAL-1, RER4 (thyroid dose > 5 rem).

9 Design basis fuel handling accidents (inside reactor 6 USAR § 15.7.4; Fig. 15.0-29 & Alert Yes building) 15.0-30; APF 06-002-01 EAL-7, RER2 or RER3. (Inside the buildings, workers can get thyroid doses > 5 rem over 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, per USAR Table 15.7-8).

10 Aircraft Probable Threat - 10 CFR 50.54(hh)(1) 1 EAL-9, Contingency Safeguards Alert Yes OFN SK-039, SEC 50-002 11 Station Blackout (SBO) 1 EAL-6, 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> General Yes Emergency 12 Fire with a Control Room Evacuation and Remote 1 EAL OFN RP-017 Site Area Yes Shutdown Emergency 13 Severe Accident Management Guidance (SAMG)* 1 Scenarios bounded by events #7 N/A No and #8, above.

14 Appendix R Fire Response 1 Event #12, above, is more N/A No bounding.

• The entry conditions for SAMG actions do not occur prior to the arrival of the augmenting ERO for any of the FSAR Category IV events or other scenarios performed within this analysis. SAMGs are implemented by the TSC.

13

Analysis 1 Design Basis Threat On-Shift Staffing Analysis Report Revision 1 Event #1 Narrative Design Basis Threat This is a scenario as categorized by the NRC, which is outside the scope of the classical design basis accidents as defined by the USAR.

NEI 10-05 rev O (6/11 ), "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities," describes the event as:

Land and/or waterborne HOSTILE ACTION directed against the Protected Area by a HOSTILE FORCE. Assume adversary characteristics defined by the Design Basis Threat (DBT).

For this analysis, the design basis threat, per NEI 10-05, § 3.1, assumptions 5 and 7 states:

With respect to the DBT staffing analysis, it may be assumed that a HOSTILE FORCE breached the Protected Area fence but was neutralized with no adverse consequences to plant safety. Damage inflicted on plant systems, structures and components is not sufficient to prevent safe shutdown or cause a radiological release. There is no fire significant enough to warrant firefighting efforts prior to the arrival of offsite resources and/or the augmented ERO. The analysis should confirm that sufficient staff is available to simultaneously implement both the emergency plan and the security plan.

.. .the analysis of the DBT event must account for the expected constraints on the movement of personnel (e.g., movement not allowed, limited movement using the 2-person rule, etc.). Specifically, individuals must usually be in, or readily able to respond to, assigned response locations before being credited with performing a function/task that implements the emergency plan. The inability of an individual to reach their assigned response location may introduce a collateral duty assignment to another individual.

Operator actions start with procedure OFN SK-039, "Security Event."

OFN SK-039:

Step #1 has operator check for a credible threat. The normal path is followed; the protected area fence has been breached. (SM)

Steps #2 and #3 have operator contact the NRC to relay information on the threat. (Abbreviated NRC notification per NEI 10-05 Table 5). (SMINS0#112)

Step #4 has operator check on the nature of the threat (airborne or non-airborne-based). The normal path is followed; this is a non-airborne threat. (SM)

The operator goes to Attachment A, "Response to a Specific Credible Threat," while continuing with this procedure.

14

Analysis 1 Design Basis Threat On-Shift Staffing Analysis Report Revision 1 Attachment A: Response to a Hostile Action:

Step #A.1 has the operator trip the reactor and proceed procedure EMG E-0, "Reactor Trip or Safety Injection," while continuing with this procedure. (CRS/R0#1)

Step #A.2 has the operator start EDGs. (R0#2)

Step #A.3 has an operator place the control room in CRVIS lineup. Since the attack is assumed to have been neutralized with no adverse consequences to plant safety, the operator has sufficient time to perform the CRVIS lineup, using procedure GK-122, "Manual CRVIS Line-Up."

(R0#2)

Step #A.4 has an operator manually actuating CPIS if a containment purge is in progress or any containment purge dampers are open. (R0#2)

Step #A.5 has an operator starting the motor driven fire pump or diesel driven fire pump.

(R0#2)

Step #A.6 has an operator secure any surveillance or maintenance activities in progress.

(R0#2/SM)

Step #A. 7 has an operator returning safety related equipment that can be controlled from the control room to an operable status. (R0#2)

Step #A.8 has an operator checking to maximize makeup water sources and systems and ensure that all tanks are at their maximum level. (R0#2/NS0#6)

Steps #A.9 and A.10 discusses actions during a refueling outage or spent fuel handling. The plant is assumed be at full power at the start of this event, so these steps are skipped.

Step #A. 11 has operators commencing RCS cooldown to cold shutdown as soon as possible per applicable procedure once EMG ES-02, "Reactor Trip Response" is complete. (CRS/R0#1)

Step #A.12 has the operator return to the main procedure.

OFN SK-039: (cont.)

Step #5 checks for a bomb threat or sabotage. The normal path is that this is not the cause of the event. The normal path is followed, due to the NEI 10-05 assumptions stated earlier.

Step #6 has an operator provide "hostile action" and "take cover" announcements via the plant's telephone paging system. The plant's gai-tronics system is used if the telephone paging system doesn't work. (SM)

Step #7 ensures the Shift Manager determines emergency classification level. (STA/NS0#1/2)

Step #8 coordinates personnel movements with security shift lieutenant or incident commander.

(SM) 15

Analysis 1 Design Basis Threat On-Shift Staffing Analysis Report Revision 1 Step #9 direct operations crew, chemistry technician, and RP technician to report to the control room. (SM)

Step #10 checks all personnel expected to safely reach control room and ensure missile door is secured. (SM)

Step #11 has personnel dispatched through the CAS to locations as follows:

• One SRO and one NSO to the Aux shutdown panel (ASP). (SM/NS0#5)

• One RO or NSO to the NB switchgear room. (R0#2/NS0#6)

Finally, after the RO or NSO leave for the NB switchgear room, an operator needs to ensure the control room back stairway door has the "ultra-dog" installed. (R0#2/NS0#6)

Step #12 has an operator start the "A" and "B" emergency diesel generators. The RNO path for this step has the RO or NSO at the NB switchgear room directed to start the EDGs using procedure OFN KJ-032, "Local Emergency Diesel Startup." For this scenario, the EDGs are assumed to need manual starting, so the RNO path is followed. (R0#1)

OFN KJ-032:

An operator attempts to start both diesel generators locally. The procedure outlines manual operations to try to start emergency diesel generator A using a mallet switch, then by trying a local start pushbutton, then by trying an air start valve. A similar progression of actions is followed to start emergency diesel generator B. For this analysis, it's assumed that both emergency diesel generators do finally start. The operator returns to procedure OFN SK-039, Step #11. (R0#2 or NS0#6)

OFN SK-039: (cont.)

Step #13 directs the CAS personnel to place the Aux Shutdown panel door in locked mode.

(CRS)

Step #14 directs an over-ride of all power block elevators, by placing key switches in the SM office to the ON position. (CRS)

Step #15 directs coordinating with security shift lieutenant to determine if two person rule should be implemented. (CRS)

Step #16 has an operator monitor progress of the intrusion on the control room radio. The normal path assumes that the breach of the control room is not imminent, which is consistent with the scenario assumptions in NEI 10-05. (NS0#4)

On-site E-Plan announcements directing personnel to report to their emergency response positions are deferred until the hostile action has been terminated. (NS0#1/2)

Step #17 increases awareness of control board indicators to assess plant stability and safety system status. (CRS/R0#1) 16

Analysis 1 Design Basis Threat On-Shift Staffing Analysis Report Revision 1 Step #18 is a check to see that the security event is terminated. This is a "hold point" before continuing with step #18. (CRSIR0#1)

Step #19 is a check to determine if announcement to take cover has been made. (CRS)

Step #20 makes announcement over telephone page system that the security event has been terminated. (CRS)

Step #21 informs local, county, state, federal agencies of event status, as necessary.

(NS0#112)

Step #22 makes any required E-Plan announcements. (NS0#112)

Step #23 ensures notifications for accountability to security is complete. (NS0#112)

EMG E-0:

For operator checks and actions from step #1 through step #4, this assessment does not assume additional "RNO" events occurred, since they are outside the scope of the scenario as defined by NEI 10-05.

Steps #1 - #4 identify manual operations, but no local operations and no explicit radiological hazards are listed. The intruders are assumed be neutralized at PAB fence with no adverse consequences to plant safety, so these steps are skipped. No safety injection actuated.

EMG ES-02: (All steps performed by remaining 2 operators in the Control room are to place the plant in a stable condition.) Completion of these actions expected to occur beyond the first 90 minutes of the event Step #1 checks RCS temperature control. (CRSIR0#1)

Step #2 checks RCS cold leg temperature. (CRSIR0#1)

Step #3 checks main generator breakers and exciter breaker OPEN. (CRSIR0#1)

Step #4 checks feedwater status. (CRSIR0#1)

Step #5 evaluates service water/essential service water status. (CRSIR0#1)

Step #6 verifies instrument air compressor is running. (CRSIR0#1)

Step #7 verifies instrument air to containment. (CRSIR0#1)

Step #8 checks charging pumps, at least one running. (CRSIR0#1)

Step #9 verifies charging system aligned for normal injection. (CRSIR0#1) 17

Analysis 1 Design Basis Threat On-Shift Staffing Analysis Report

. Revision 1 Step #10 checks charging flow, established. (CRS/R0#1)

Step #11 checks all control rods, fully inserted. (CRS/R0#1)

Step #12 checks PZR level, greater than 17%. (CRS/R0#1)

Step #13 checks if letdown should.be established. (CRS/R0#1)

Step #14 establishes excess letdown. (CRS/R0#1)

Step #15 checks PZR level control. (CRS/R0#1)

Step #16 checks PZR pressure, greater than 1830psig. (CRS/R0#1)

Step #17 checks PZR PORVs. (CRS/R0#1)

Step #18 checks normal spray valves. (CRS/R0#1)

Step #19 checks AC emergency busses, energized by offsite power. (CRS/R0#1)

Step #20 checks PZR pressure heater control. (CRS/R0#1)

Step #21 controls PZR pressure. (CRS/R0#1)

Step #22 checks S/G levels. (CRS/R0#1)

Step #23 checks spent fuel pool status. (CRS/R0#1)

Step #24 checks all non-class 1E AC busses and load centers, energized by offsite power.

(CRS/R0#1)

Step #25 establishes S/G pressure control. (CRS/R0#1)

Step #26 checks if RCPs should be started. (CRS/R0#1)

Step #27 establishes conditions for starting desired RCPs. (CRS/R0#1)

Step #28 starts desired RCPs. (CRS/R0#1)

Step #29 checks if source range detectors should be energized. (CRS/R0#1)

Step #30 shuts down unnecessary plant equipment, as directed by SM or CRS. (CRS/R0#1)

Step #31 checks if a diesel driven fire pump should be started. (CRS/R0#1)

Step #32 maintains stable plant conditions. (CRS/R0#1) 18

Analysis 1 Design Basis Threat On-Shift Staffing Analysis Report Revision 1 Step #33 directs senior reactor operator to perform procedure AP 20-002, "Post-Trip Review."

(CRS/R0#1)

Step #34 directs chemistry to perform required post trip samples, using procedure AP 02-007, "Abnormal Conditions Guidelines." (CRS/R0#1)

Step #35 directs chemistry to sample RCS for boron. (CRS/R0#1/CH)

Step #36 determines if ESW train A or B underwent a transient event. (CRS/R0#1)

Step #37 determines if natural circulation cooldown is required. (CRS/R0#1) 19

Analysis 1 Design Basis Threat On-Shift Staffing Analysis Report Revision 1 This On-Shift Analysis (OSA) is applicable to Analysis# 1 as identified in Appendix A. (DBT)

TABLE 1 - On-shift Positions Augmentation Role in Unanalyzed TMS Line On-shift Position Emergency Plan Reference Elapsed Time (min) Table#/Line# Task? Required?

Shift Manager REMP, Figure 2, "Minimum Shift N/A T2/L 1 No No Staffing" & Attachment D, "WCGS TS/L1 Minimum Staffing for Emergencies" TS/L2 TS/L3 TS/L4 1

TS/LS TS/L7 TS/LS TS/L 10 Shift Technical Advisor REMP, Figure 2, "Minimum Shift N/A T2/L3 No No Staffing" & Attachment D, "WCGS 2

Minimum Staffing for Emergencies" Control Room Supervisor REMP, Figure 2, "Minimum Shift N/A T2/L2 No No Staffing" & Attachment D, "WCGS 3

Minimum Staffing for Emergencies" Reactor Operator #1 REMP, Figure 2, "Minimum Shift N/A T2/L4 No No Staffing" & Attachment D, "WCGS 4

Minimum Staffing for Emergencies" 20

Analysis 1 Design Basis Threat On-Shift Staffing Analysis Report Revision 1 Augmentation Role in Unanalyzed TMS Line On-shift Position Emergency Plan Reference Elapsed Time (min) Table#/Line# Task? Required?

Reactor Operator #2 REMP, Figure 2, "Minimum Shift N/A T2/L5 No No Staffing" & Attachment D, "WCGS 5

Minimum Staffing for Emergencies" Extra Reactor Operator I REMP, Figure 2, "Minimum Shift N/A T2/L6 No No Nuclear Station Operator Staffing" & Attachment D, "WCGS 6

Minimum Staffing for Emergencies" Nuclear Station Operator REMP, Figure 2, "Minimum Shift N/A T4/L7 No Yes*

1. 1/2 Staffing" & Attachment D, "WCGS T4/L8 Minimum Staffing for Emergencies" T5/L6 T5/L9 7

T5/L 11 T5/L 13*

T5/L 14 T5/L 15 Nuclear Station Operator #4 REMP, Figure 2, "Minimum Shift N/A T2/L8 No No Staffing" & Attachment D, "WCGS 8

Minimum Staffing for Emergencies" Nuclear Station Operator #5 REMP, Figure 2, "Minimum Shift N/A T2/L9 No No Staffing" & Attachment D, "WCGS 9

Minimum Staffing for Emergencies" 21

Analysis 1 Design Basis Threat On-Shift Staffing Analysis Report Revision 1 Augmentation Role in Unanalyzed TMS Line On-shift Position Emergency Plan Reference Elapsed Time (min) Table#/Line# Task? Required?

Nuclear Station Operator #6 REMP, Figure 2, "Minimum Shift N/A T2/L 10 No No Staffing" & Attachment D, "WCGS 10 Minimum Staffing for Emergencies" Chemistry Technician REMP, Figure 2, "Minimum Shift 90 No No Staffing" & Attachment D, "WCGS N/A 11 Minimum Staffing for Emergencies" Radiation Protection REMP, Figure 2, "Minimum Shift 90 No No Technician #1 Staffing" & Attachment D, "WCGS N/A 12 Minimum Staffing for Emergencies" Radiation Protection REMP, Figure 2, "Minimum Shift 90 N/A No No Technician #2 Staffing" & Attachment D, "WCGS 13 Minimum Staffing for Emergencies" Security REMP, Attachment D, "WCGS N/A TS/L 15 No No 14 Minimum Staffing for Emergencies"

• Based on functional analysis ENS communicator required for continuous NRC communications. This individual also fulfills the OSC communicator role.

22

Analysis 1 Design Basis Threat On-Shift Staffing Analysis Report Revision 1 TABLE 2 - Plant Operations & Safe Shutdown Analysis#1 One Unit - One Control Room Minimum Operations Crew Necessary to Implement AOPs and EOPs, or SAMGs if applicable Task Analysis Line Generic Title/Role On-Shift Position Controlling Method 1 Shift Manager Shift Manager Operations Training 2 Unit Supervisor Control Room Supervisor Operations Training 3 Shift Technical Advisor Shift Technical Advisor Operations Training 4 Reactor Operator #1 Reactor Operator #1 Operations Training 5 Reactor Operator #2 Reactor Operator #2 Operations Training Extra Reactor Operator/ OFN KC-016 Operations Training 6

Auxiliary Operator 7 Auxiliary Operator #1/2 Nuclear Station Operator #1/2 Operations Training Auxiliary Operator #4 Nuclear Station Operator #4 Operations Training 8

(FBL)

Auxiliary Operator #5 Nuclear Station Operator #5 Operations Training 9

(Aux)

Auxiliary Operator #6 Nuclear Station Operator #6 Operations Training 10 (TB)

Other (non-Operations) Personnel Necessary to Implement AOPs and EOPs, or SAMGs if applicable Task Analysis Line Generic Title/Role On-Shift Position Controlling Method 11 Mechanic N/A N/A 12 Electrician N/A N/A 13 l&C Technician N/A N/A 14 Other N/A N/A 23

Analysis 1 Design Basis Threat On-Shift Staffing Analysis Report Revision 1 TABLE 3 - Firefighting Analysis# 1 Task Analysis Line Performed By Controlling Method N/A - there is no fire associated with this N/A 1

event.

2 N/A N/A 3 N/A N/A 4 N/A N/A 5 N/A N/A 24

Analysis 1 Design Basis Threat On-Shift Staffing Analysis Report Revision 1 TABLE 4- Radiation Protection & Chemistry & ENSIOSC Communicator Analysis# 1 Performance Time Period After Emeri:1enc '/ Declaration (minutes)

Line Position Performing Function/Task o- I 5- 1o- I 15- I 20- I 25- I 30- I 35- I 40- I 45 55- I 60- I 65- I 70- I 75- , 80- I 85-5 10 1 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 In-Plant Survey 1 On-Shift Position: N/A - Personnel on lock-down for DBT event.

On-Site Survey 2 On-Shift Position: N/A - Personnel on lock-down for DBT event.

Personnel Monitoring 3 On-Shift Position: N/A - Personnel on lock-down for DBT event.

Job Coverage 4 On-Shift Position: N/A - Personnel on lock-down for DBT event.

Offsite Radiological Assessment 5 On-Shift Position: Chemistry Tech N/A - Personnel on lock-down for DBT event.

Other Site-Specific RP - Describe:

On-Shift Positions:

6 N/A - Personnel on lock-down for DBT event.

RP Tech in CR RP for survey and job coverage OSC Communicator - Describe:

REMP Functions:

7 N/A - Personnel on lock-down for DBT event.

Initiate Staffing of ERO Perform Emergency Notifications ENS Communicator - Describe:

8 REMP Functions: N/A - Personnel on lock-down for DBT event.

ENS Communications with NRC 25

Analysis 1 Design Basis Threat On-Shift Staffing Analysis Report Revision 1 TABLE 5 - Emergency Plan Implementation Analysis#1 Task Analysis Line Function/Task On-Shift Position Controlling Method Declare the Emergency Shift Manager Operations Training and EP 1

Classification Level (EGL) Training/Drill Program Approve Offsite Protective Shift Manager Operations Training and EP 2

Action Recommendations Training/Drill Program Approve content of Shift Manager Operations Training and EP 3

State/local notifications Training/Drill Program Approve extension to Shift Manager Operations Training and EP 4

allowable dose limits Training/Drill Program Notification and direction to Shift Manager Operations Training and EP 5 on-shift staff (e.g., to Training/Drill Program assemble, evacuate, etc.)

ERO notification Table 4 - Nuclear Station Operations Training and EP 6 Operator #1/2 Training/Drill Program Abbreviated NRG Shift Manager Operations Training and EP 7 notification for DBT event Training/Drill Program Complete State/local Shift Manager Operations Training and EP 8 notification form Training/Drill Program Perform State/local Table 4 - Nuclear Station Operations Training and EP 9 notifications Operator #1/2 Training/Drill Program Complete NRG event Shift Manager Operations Training and EP 10 notification form Training/Drill Program Activate EROS Table 4 - Nuclear Station Operations Training and EP 11 Operator #1/2 Training/Drill Program Offsite radiological NIA - Table 4 - Chemistry Chemistry Training and EP 12 assessment Tech Training/Drill Program Perform NRG notifications Table 4 - Nuclear Station Operations Training and EP 13 Operator #1/2 Training/Drill Program Perform other site-specific Table 4 - Nuclear Station Operations Training and EP 14 event notifications (e.g., Operator #1/2 Training/Drill Program INPO, ANI, etc.)

Personnel accountability Security Security Training and 15 Table 4 - Nuclear Station Operations Training and EP Operator #1/2 Training/Drill Program 26

Analysis 2 Steam System Piping Failure (Major)

On-Shift Staffing Analysis Report Revision 1 Event #2 Narrative Steam System Piping Failure (Major)

This is one of the Design-Basis Condition IV Limiting Fault events as listed in the USAR, § 15.0.1.4, "Condition IV - Limiting Faults." USAR § 15.1.5.1, "Identification of Causes and Accident Description," states:

The steam release arising from a rupture of a main steam line would result in an initial increase in steam flow* that decreases during the accident as the steam generator pressure decreases.

The energy removal from the RCS causes a reduction of coolant temperature and pressure. In the presence of a negative moderator temperature coefficient, the coo/down results in an insertion of positive reactivity. If the most reactive RCCA is assumed stuck in its fully withdrawn position after reactor trip, there is [a] possibility that the core will become critical and return to power. A return to power following a steam line rupture is a potential problem mainly because of the high power peaking factors which exist, assuming the most reactive RCCA to be stuck in its fully withdrawn position. The core is ultimately shut down by the boric acid solution delivered by the emergency core cooling system.

A detailed discussion of potential accidents in this category, including analytical methods used and the scenario consequences expected, can be found in USAR § 15.1.5, "Steam System Piping Failure," and are diagrammed in USAR Figure 15.0-10, "Depressurization of Main Steam System."

An analysis performed by the WCGS staff has concluded that the most serious consequences occur for:

.. .the largest double-ended steamline rupture at end-of-life, hot zero-power (Mode 2) conditions, with the most reactive RCCA in the fully withdrawn position, bounds all other power levels and other Modes for the post-trip phase of the transient.

Which signals cause the reactor trip depends on the location of the rupture, as outlined in USAR

§ 15.1.5.1, "Identification of Causes and Accident Description."

Document APF 06-002-01, Emergency Action Levels, identifies the above as an EAL-4 /

BASES-4, "Main Steam Line Break." MSLB-13 (main steam line broken) would classify the event as no worse than a Notification of Unusual Event. However, there is a potential for one category of piping failure to vent outside of containment. Assuming a 1 gpm leak rate from the primary to secondary cooling system, noble gas inventory (equivalent to 1% failed fuel and a pre-accident iodine spike as described in USAR § 15.1.5.2, "Analysis of Effects and Consequences":

a. End-of-life shutdown margin at no-load, equilibrium xenon conditions, and the most reactive RCCA stuck in its fully withdrawn position. Operation of the control rod banks during each operating cycle is restricted by the insertion limits so that addition 27

Analysis 2 Steam System Piping Failure (Major)

On-Shift Staffing Analysis Report Revision 1 of positive reactivity in a steam line break accident will not lead to a more adverse condition than the case analyzed.

b. A negative moderator coefficient corresponding to the end-of-life rodded core with the most reactive RCCA in the fully withdrawn position.

c. Minimum capability for injection of boron solution corresponding to the most restrictive single failure in the safety injection system.

d. The following cases have been considered in determining the core power and RCS transients:

1. Complete severance of a pipe, with the plant initially at no-load conditions, full reactor coolant flow with offsite power available.

2. Case with Joss of offsite power simultaneous with the steam line break, which causes initiation of the safety injection signal. Loss of offsite power results in reactor coolant pump coast down.

e Power peaking factors corresponding to one stuck RCCA and non-uniform core inlet coolant temperatures are determined at end of core life. The coldest core inlet temperatures are assumed to occur in the sector with the stuck rod. The power peaking factors account for the effect of the local void in the region of the stuck RCCA during the return to power phase following the steam line break.

Given the above assumptions and conditions and USAR § 15.1.5.3.2, "Identification of Uncertainties and Conservatisms in the Analysis," the sequence as described in USAR § 15.1.5.3.1.1, "Physical Model," involves:

The radiological consequences of a MSLB inside the containment are Jess severe than the one outside the containment because the radioactivity released will be held up inside the containment, allowing decay and plate out of the radionuclides. To evaluate the radiological consequences due to a postulated MSLB outside the containment, it is assumed that there is a complete severance of a main steam line outside the containment.

It is also assumed that there is a simultaneous loss of offsite power, resulting in reactor coolant pump coast down. The safety injection system is actuated and the reactor trips.

The main steam line isolation valves, their bypass valves, and the steam line drain valves isolate the steam generators and the main steam lines upon a signal initiated by the engineered safety features actuation system under the conditions of high steam negative pressure rate or low steam line pressure. The main steam isolation valves are installed in the main steam lines from each steam generator downstream from the safety and atmospheric relief valves outside the containment. The break in the main steam line is assumed to occur outside of the containment. The affected steam generator (steam 28

Analysis 2 Steam System Piping Failure (Major)

On-Shift Staffing Analysis Report Revision 1 generator connected to a broken steam line) blows down completely. The steam is vented directly to the atmosphere.

In case of Joss of offsite power, the remaining steam generators are available for dissipation of core decay heat by venting steam to the atmosphere via the atmospheric relief valves. Venting continues until the reactor coolant temperature and pressure have decreased sufficiently so that the RHR system can be utilized to cool the reactor.

As summarized in USAR Tables 15.1-3, "Parameters Used in Evaluating the Radiological Consequences of a Main Steam Line Break," and 15.1-4, "Radiological Consequences of a Main Steam Line Break":

For evaluating the radiological consequences due to a postulated MSLB, the activity released from the affected steam generator (steam generator connected to the broken steam line) is released directly to the environment. The unaffected steam generators are assumed to continually discharge steam and entrained activity via the safety and atmospheric relief valves up to the time initiation of the RHRS can be accomplished.

Since the activity is released directly to the environment with no credit for plateout or retention, the results of the analysis are based on the most direct leakage pathway available. Therefore, the resultant radiological consequences represent the most conservative estimate of the potential integrated dose due to the postulated MSLB.

Referring back to APF 06-002-01, the radiological consequences classify this event as EAL-1 /

BASES-1, "Radioactive Effluent Release." RER-3 (thyroid dose > 500 mrem at the site boundary) escalates the classification to a Site Area Emergency.

The event as diagrammed in USAR Figure 15.0-10, "Depressurization of Main Steam System,"

is assumed to cause a reactor trip either at hot zero power or hot full power. For this assessment, it is assumed that procedure EMG E-0, "Reactor Trip or Safety Injection," was the entry point for operator actions.

EMG E-0:

The procedure starts out with a caution that "Accident conditions can cause higher than normal radiation levels. Radiation protection monitoring may be required while performing local operator actions."

Step #1 verifies reactor trip. (R0#1)

Step #2 verifies turbine trip. (R0#2)

Step #3 checks that at least one of the AC emergency busses is energized. (R0#1)

Step #4 checks if safety injection is actuated. (R0#1)

Step #5 checks if SI is required. (R0#1) 29

Analysis 2 Steam System Piping Failure (Major)

On-Shift Staffing Analysis Report Revision 1 Step #6 verifies automatic actions using Attachment F, Automatic Signal Verification. (R0#1)

Step #7 checks main generator breakers and exciter breaker open. (R0#2)

Step #8 checks total AFW flow is greater than 270,000 lbm/hr. (R0#2)

Step #9 checks RCS cold leg temperatures. (R0#2)

Step #10 establishes S/G pressure control. (R0#2)

For steps #11 - #13, the normal path is followed. USAR Figure 15.1-22, "Pressurizer Pressure and Pressurizer Liquid Volume SLB Without Offsite Power" shows a rapid drop in volume for the

• first 20 seconds and a rapid drop in pressure for the first 60 seconds, stabilizing at an RCS pressure of approximately 1050 psia and a liquid volume less than 30 ft3

• As noted above, a pressurizer valve failure is outside the scope of this event. (R0#2)

Step #14 follows the normal path. The reactor coolant pumps tripped when the reactor tripped.

(R0#2)

Step #15 .directs the operator to monitor the critical safety functions using EMG F-0, "Critical Safety Function Status Trees (CSFST)", based on "safety injection has not been terminated and no accident condition has been identified". (STA)

EMG F-0: (STA)

USAR Figure 15.1-21, "Normalized Core Power and Normalized Core Heat Flux SLB without Offsite Power" shows that Core Power (fan) climbing from minimal to greater than 5% within 40 seconds after the event, due to positive reactivity insertion via borated moderator in the aftermath of the cooldown of the RCS from the steam line break. This scenario was also described in USAR § 15.1.5.1 "Identification of Causes and Accident Description" as described above. The reactor is going through a re-criticality. This puts the operator into a potential RED PATH via critical safety function status tree F-01, Subcriticality.

The re-criticality causes a jump from EMG F-0 to EMG FR-S1, "Response to Nuclear Power Generation/ATWS."

EMG FR-S1:

Step #1 verifies reactor trip. (R0#1)

Step #2 verifies turbine trip. (R0#2)

Step #3 verifies AFW pumps running. (R0#2)

Step #4 checks main generator breakers and exciter breaker open. (R0#2)

Step #5 checks SI - not in progress. (R0#1) 30

Analysis 2 Steam System Piping Failure (Major)

On-Shift Staffing Analysis Report Revision 1 Step #6 initiates emergency boration of RCS. (R0#1)

Step #7 verifies charging flow path. (R0#1)

Step #8, checks for emergency borate flow greater than 30 gpm. There is an RNO path to go to this procedure's "Attachment A" jf the RWST flow through the charging system is less than 90 gpm. (R0#1)

R0#1 and NS0#5 will be branched to Att. A. Rest of crew will continue in EMG FR-S1 at step

1. 9 proceeding through the procedure using Step #13 as a continuous action to get to step #25 when R0#1 and NS0#5 are successful. The crew may complete all or part of steps #9 - #25 in this time; it depends on how quickly R0#1 and NS0#5 can complete their tasks. Ultimately the crew will arrive at step #25 using the continuous action from step #13 and continue through EMG FR-S1 and back to EMG E-0. It is expected that the CRS and R0#2 will not have progressed beyond step #13 before R0#1 and NS0#5 return from Att. A.

Attachment A, "Establishing Alternate Boration Flowpath," has step #A2, "Open Boric Acid to Boric Acid Blending Tee Valve". The RNO path has an operator locally fail open the valve by isolating the instrument air to the valve and then venting air pressure from the valve. (NS0#5)

Step #A6 verifies that boration flow is greater than 30 gpm. The RNO path has an operator continue with the steps in Attachment A. The normal path reverts back to the procedure mainline at step #9. (R0#1)

Step #A7, "Establish Manual Boration," has a normal path step to locally unlock and open the boric acid* to charging pump suction isolation valve. There is a remark in the basis document that "High dose could exist for local operator actions." The RNO path for this sub-step is to continue to step #AB. (R0#1/NS0#5)

Continuing the sub-steps in step #A7, the normal path is to check for normal boration flow. The RNO path is to jump to step #A9. If both of these sub-steps follow the normal path, the operator reverts back to the procedure mainline at step #9. (R0#2)

Step #AB, "Establish Manual Emergency Boration," has a normal path step to locally open the emergency borate to charging pump suction valve. There is a remark in the basis document that "High dose could exist for local operator actions." If the step is successful, the operator reverts back to the procedure mainline at step #9. The RNO path is to continue to step #A9, which can be bypassed until additional staff arrive beyond the first 90 minutes of the event.

(R0#1/ NS0#5)

Step #A10, "Check if Alternate Boration Flow has been Established," has a normal path to verify flow is greater than 30 gpm and an RNO path to continue efforts to raise the flow rate to that level. (R0#1/NS0#5)

Step #A 11 reverts back to the procedure mainline at step #9.

31

Analysis 2 Steam System Piping Failure (Major)

On-Shift Staffing Analysis Report Revision 1 Steps #9 - #12 follows the normal path (the RNO path assumes additional problems outside the scope of the event). (R0#2)

Step #13 is a check to ensure the reactor is subcritical. Based on the description of this event, the boration action is assumed to eventually succeed in bringing the reactor subcritical, as outlined in USAR Table 15.1-1, "Time Sequence of Events for Incidents That Result in an Increase in Heat Removal by the Secondary System," sheet #2, "Steam System Piping Failure,"

case #2, "concurrent loss of offsite power". The RWST boron solution starts reaching the core in 82 seconds. USAR Figure 15.1-21, "Normalized Core Power and Normalized Core Heat Flux SLB without Offsite Power," shows the power starts decreasing within 120 seconds. Once the reactor has been successfully brought subcritical, the procedure jumps to step #25. (R0#1)

Step #25 is assumed to follow the normal path (the RNO path assumes additional problems outside the scope of this event). (R0#1)

Step #25 has the operator continue boration until adequate shutdown margin is achieved.

(R0#1)

Step #26 is a check on the CROM fans, to keep the CRDMs below 165°F. The RNO path has an operator manually start the fans. (R0#2)

Step #27 reverts back to the procedure EMG E-0, step #16. (CRS)

EMG E-0:

Step #16 checks to see if any (or all) of the steam generators are faulted. Based on USAR Figures 15.1-25, "Normalized Feedwater Flow and Break Flow SLB without Offsite Power," and 15.1-26, "Steamline Pressure and Core Inlet Flow, SLB without Offsite Power," there are sharp differences in the behavior of S/Gs with intact loops vs. faulted loops. Intact loops stabilize pressure; the faulted loop continues to drop pressure. Since there is a double-ended break in a large steam line, this is a failure in the secondary pressure boundary. The procedure has the operator jump to procedure EMG E-2, "Faulted Steam Generator Isolation." (R0#2)

EMG E-2:

EMG E-2, step #1 has the operator check to see if the steam lines on all S/Gs are isolated. This involves ensuring the main steam line valves, bypass valves and low point drain valves are closed. The RNO path has manual operations, but no local operations were identified. (R0#2)

Step #2 has the operator check to see if limitations for fault in Area 5 are required (which will depend on where the break is located). The procedure adds a warning to local operators in the affected area. (R0#2/NS0#6)

Step #3 checks to see if any S/Gs are not faulted. Based on the scenario for this event, S/Gs that are not connected to the broken main steam line are not faulted. (R0#2) 32

Analysis 2 Steam System Piping Failure (Major)

On-Shift Staffing Analysis Report Revision 1 Step #4 identifies SIGs that are faulted. The normal path has "any SIG pressures decreasing in an uncontrolled manner OR "any SIG completely depressurized," which is consistent with USAR Figures 15.1-25 and 15.1-26. (R0#2)

Step #5 isolates the faulted SIGs. The normal path involves closing the AFW flow controls to the faulted SIGs. The RNO path has an operator locally isolate the affected lines. The Turbine Driven AFW pump always has the steam supply line locally closed by the operator.

The SIG atmospheric relief valves (ARVs) on the faulted SIGs are checked closed, and the RNO path has an operator locally isolate the affected SIG ARVs. (R0#2/NS0#5/NS0#6)

Step #6 addresses isolating feedwater lines. The RNO path for this section involves manual closure of valves. If manual closure of valves also fails, then a subsequent RNO path has a dispatch operator isolate valves locally. The valves in question are the main feedwater reg valves, the main feedwater reg bypass valves and the main feedwater chemical injection valves.

(R0#2/NS0#5)

Step #7 covers isolation of blowdown and sampling lines. There is. an RNO path to locally isolate the affected blowdown and/or sampling line(s) for the affected SIGs. (R0#2)

Step #8 discusses situations where the pressurizer PORV opens due to high pressure. For the event described, the RCS pressure drops with the cooldown and the pressurizer empties 18 seconds into the event (see USAR Table 15.1-1, sheet #2, as described above). The event follows the normal path. (R0#1)

Step #9 discusses continued uncontrolled cooldown. The core inlet temperature for the intact loops and the core average temperature start to stabilize after the first 30 seconds of the event.

See USAR Figure 15.1-23, "Core Inlet Temperature and Core Average Temperature SLB Without Offsite Power." The normal path is followed, based on the accident description.

(R0#2)

Step #10 has specific extreme caution statements regarding performing local surveys if the steam lines in Area 5 of the Aux Building are not intact, if there is a need to establish a sampling capability to determine secondary radiation levels. Radiation protection is directed to locally survey the steam lines in this area. Chemistry is directed to sample all SIGs for activity. In this case, per the scenario, no steam generator tubes are ruptured. (R0#2/RP#1/CH)

Step #11, on the RNO path, involves using an operator to locally open the ESW A or B to air compressor, to insure instrument air compressors are available to supply air to instruments and to restore instrument air to the containment. (R0#2/NS0#5)

Step #12 checks for intact SIG tubes. Based on the scenario, the SIG tubes are intact and the operator follows the normal path. (R0#2/RP#1/CH)

• Step #13 checks if containment spray should be stopped. (R0#2)

Step #14 checks for EGGS flow. The operator follows the normal path and jumps to EMG E-1, "Loss of Reactor or Secondary Coolant." (R0#1/R0#2) 33

Analysis 2 Steam System Piping Failure (Major)

On-Shift Staffing Analysis Report Revision 1 Procedure EMG E-1 is entered into after the faulted SIG has been identified and isolated.

EMG E-1:

Step #1 has the RCS pressure checked. In this scenario, the RCS pressure drops below 1400 psi within the first 40 seconds, causing the operator to follow the RNO path and skip to step #2.

See USAR Figure 15.1-22, "Pressurizer Pressure and Pressurizer Liquid Volume SLB Without Offsite Power," top graph, for more details. (R0#1)

The SIGs are specifically checked in step #2. Based on the scenario, the assumption is the operations in the previously executed EMG E-2 procedure, listed above, have already succeeded in isolating the faulted SIG. The operator follows the normal path. (R0#2)

Steps #3 - #5 follow the normal path, based on the scenario description. The RNO path would require assuming additional problems with the SIGs beyond the scope of the event.

(R0#1/R0#2)

The caution before step #6 echoes the earlier specific extreme caution statements on performing local surveys if the steam lines in Area 5 of the Aux Building are not intact. Step #6 has radiation protection performing surveys and chemistry performing sampling of all S/Gs for activity. (R0#2/RP#2/CH)

Step #7 continues .the local surveys (in Control Room) to check secondary radiation levels.

This scenario assumes that no SGTR occurred, so operators follow the normal path.

(R0#2/RP#2/CH)

Step #8 involves the pressurizer, which is assumed to be functioning in accordance with the scenario described and USAR Figure 15.1-22, "Pressurizer Pressure and Pressurizer Liquid Volume SLB Without Offsite Power." No stuck PORVs, failed heaters, malfunctioning sprays, etc. are assumed. (R0#1)

Step #9 has the same RNO path discussion on locally opening ESW A or B to air compressor as was described above. (R0#2/NS0#5/NS0#6)

Steps #1 O - #12 do not involve local operations. (R0#1/R0#2)

Step #13 is a check on RCS Pressure. RCS pressure and pressurizer level are stable after the first 100 seconds, based on USAR Figure 15.1-22. The normal path is followed. (R0#2)

Step #14 is a check on RCS and SIG pressures. (R0#2)

Step #15 discusses availability of offsite power. In this case, the assumption is there is no offsite power, so the RNO path is followed. (R0#2)

Step #16 has local operations to reset and close the boric acid transfer pump breakers and the emergency borate valve breaker. (NS0#5/NS0#6) 34

Analysis 2 Steam System Piping Failure (Major)

On-Shift Staffing Analysis Report Revision 1 Steps #17 (R0#2) and #18 (R0#2/NS0#3) involve closing battery charger breakers and checking busses and load centers energized by offsite power. The event assumes there is no onsite power available. Step #18's RNO path is followed.

Step #19 (place hydrogen analyzers in service) has no local operations identified. This event does not assume core damage beyond the 1% failed fuel, noble gas release and iodine spike as described earlier. (R0#1)

Step #20 involves verifying the Cold Leg Recirculation Capacity, but this accident doesn't assume a LOCA. The normal path is followed. (R0#2)

Step #21 checks the fuel/auxiliary building radiation levels to assure there is no primary leakage into the aux building. This accident does not assume primary leakage beyond the 1 gpm primary to secondary rate as was described earlier. The normal path is followed, which includes directing radiation protection to survey the fuel and aux buildings. (R0#2/RP#2)

Step #22 requests chemistry obtain boron and activity samples for the RCS and pressurizer liquid space. Since this scenario assumes that a re-criticality requiring boration occurred, this step is assumed to have been followed. (RP#2/CH)

Step #23 evaluates plant status. The event does not assume additional malfunctions, so the normal path is followed. (SM/CRS)

Step #24 has the RCS pressure > 325 psig per USAR Figure 15.1-22. This triggers a move to procedure EMG ES-11, "Post LOCA Cooldowns and Depressurization", since the RCS pressure is greater than the shutoff head pressure of the RHR pumps. (Note that the initiating event here is a steamline break causing loss of secondary coolant, not a LOCA on the primary side).

(R0#1)

Continuing with EMG ES-11, step #1:

EMG ES-11:

Steps #1 and #2 reset the SI and Containment Isolation Phase A and B. (R0#1/R0#2)

Step #3 and 4 has an RNO path to locally open ESW A or ESW B to the Air Compressor, reset and close breaker reset switches, and dispatch an operator to reset alarms and restart compressors. There are also actions to locally open the instrument air supply containment isolation valve. This is the same RNO path discussion on locally opening ESW A or B to air compressor, as was described in procedure EMG E-2, above .. (R0#2)

Step #5 checks on whether the diesel generators should be shut off. The scenario assumes a loss of offsite power, so the emergency diesel generators need to keep running. Follow the RNO path. (R0#2)

Step #6 is an alignment of the pressurizer heaters. (R0#1) 35

Analysis 2 Steam System Piping Failure (Major)

On-Shift Staffing Analysis Report Revision 1 Step #7 requires local reset and close of the boric acid transfer pump breakers and the emergency borate valve breaker. (R0#2)

Step #8 is to close the Non-Class 1E battery charger breakers, to re-energize equipment.

(R0#2)

Step #9 - This event assumes loss of offsite power, so the RNO path is taken for Site Watch to start the TSC diesel using procedure STN KAT-001, "Technical Support Diesel Generator Operation." (R0#2)

STN KAT-001:

Operator locally performs the prerequisite checks listed in§ 7, "Prerequisites." (NS0#3)

Operator locally performs § 8.1.1, "Testing Installed TSC Diesel Generator," OR § 8.2.1, "Testing Temporary TSC Diesel Generator." (NS0#3)

• Operator locally performs § 8.1.2, "Placing TSC Diesel Generator In-service," OR § 8.2.2, "Placing Temporary TSC Diesel Generator In-service." (NS0#3)

Note that if the TSC Diesel Generator runs for more than an hour, refer to Attachment B, "TSC Diesel Generator Reading", or if applicable, Attachment C, "TSC Temporary Diesel Generator Readings," for hourly checks on the diesel generator in question. (NS0#3)

EMG ES-11 (continued):

Step #10 checks if RHR pumps are running. The RCS pressure is > 325 psig (see discussion, above), so the pumps should not be running. (However, later they will need to be started manually per the basis document). The operator continues to step #10. (R0#2)

Step #11 checks for intact SIG levels. The intact SIGs are expected to behave normally, per the event description. The faulted SIG should have been resolved earlier in this procedure. None of the SIGs has a tube rupture. The operator follows the normal path. (R0#2)

Step #12 - Check if condenser air removal should be returned to normal. In this case, we had a steamline break with isolation, and loss of offsite power. The condenser is assumed unavailable, so the operator follows the RNO path and continues to step #12. (R0#2)

Step #13 checks for blocking safety injection signals. The RCS pressure drops below 1970 psig within 15 seconds of the event and continues rapidly dropping to approximately 1150 psig within 80 seconds of the event, as shown in USAR Figure 15.1-22, top graph. The normal path is followed. (R0#1) 36

Analysis 2 Steam System Piping Failure (Major)

On-Shift Staffing Analysis Report Revision 1 Termination path (expected actions are beyond the first 90 minutes of the event):

Step #14 Initiates RCS cooldown to cold shutdown: The initial cooldown of approximately 150

~F occurs in the first 30 seconds of the event, as shown in USAR Figure 15.1-23. The steam dump occurs using the intact SIG ARVs, given the loss of offsite power. (CRS/R0#2)

EMG FR-S1: (continued)

Step #A9, "Locally Check Boric Acid Filter LiP - Less than 20 psid," has a normal path step to check pressure differential on the boric acid filter, and an RNO path to conduct a series of valve manipulations, with maintenance to change boric acid filter ASAP. There is a remark in the basis document that "High dose could exist for local operator actions."

The operators continue along the termination path listed in procedure EMG ES-11 until reactor is in stable cold shutdown.

37

Analysis 2 Steam System Piping Failure (Major)

On-Shift Staffing Analysis Report Revision 1 This OSA is applicable to Analysis# 2_ as identified in Appendix A. (Steam System Piping Failure)

TABLE 1 - On-shift Positions Augmentation Unanalyzed Role in TMS Line On-shift Position Emergency Plan Reference Elapsed Time Task?

Table#/Line# Required?

(min)

Shift Manager REMP, Figure 2, "Minimum Shift Staffing" & NA T2/L 1 No No Attachment D, "WCGS Minimum Staffing for TS/L 1 Emergencies" T5/L2 T5/L3 1

T5/L4 T5/L5 TS/LB T5/L 10 Shift Technical Advisor REMP, Figure 2, "Minimum Shift Staffing" & NA T2/L3 No No 2 Attachment D, "WCGS Minimum Staffing for Emergencies" Control Room Supervisor REMP, Figure 2, "Minimum Shift Staffing" & NA T2/L2 No No 3 Attachment D, "WCGS Minimum Staffing for Emergencies" Reactor Operator #1 REMP, Figure 2, "Minimum Shift Staffing" & NA T2/L4 No No 4 Attachment D, "WCGS Minimum Staffing for Emergencies" Reactor Operator #2 REMP, Figure 2, "Minimum Shift Staffing" & NA T2/L5 No No 5 Attachment D, "WCGS Minimum Staffing for Emergencies" 38

Analysis 2 Steam System Piping Failure (Major)

On-Shift Staffing Analysis Report Revision 1 This OSA is applicable to Analysis# 2_ as identified in Appendix A (Steam System Piping Failure)

TABLE 1 - On-shift Positions Augmentation Unanalyzed Role in TMS Line On-shift Position Emergency Plan Reference Elapsed Time Task?

Table#/Line# Required?

(min)

Nuclear Station Operator REMP, Figure 2, "Minimum Shift Staffing" & NA T2/L6 No Yes*

1. 1/2 Attachment D, "WCGS Minimum Staffing for T4/L7 Emergencies" T4/L8 T5/L6 6 T5/L9 TS/L 11 TS/L 13*

TS/L 14 T5/L 15 Nuclear Station Operator REMP, Figure 2, "Minimum Shift Staffing" & NA T2/L7 No No 7 #3 Attachment D, "WCGS Minimum Staffing for Emergencies" Nuclear Station Operator REMP, Figure 2, "Minimum Shift Staffing" & NA T2/L8 No No 8 #5 Attachment D, "WCGS Minimum Staffing for Emergencies" Nuclear Station Operator REMP, Figure 2, "Minimum Shift Staffing" & NA T2/L9 No No 9 #6 Attachment D, "WCGS Minimum Staffing for Emergencies" Chemistry Technician REMP, Figure 2, "Minimum Shift Staffing" & 90 T4/L6 No No 10 Attachment D, "WCGS Minimum Staffing for Emergencies" 39

Analysis 2 Steam System Piping Failure (Major)

On-Shift Staffing Analysis Report Revision 1 This OSA is applicable to Analysis# 2_ as identified in Appendix A (Steam System Piping Failure)

TABLE 1 - On-shift Positions Augmentation Unanalyzed Role in TMS Line On-shift Position Emergency Plan Reference Elapsed Time Task?

Table#/Line# Required?

(min)

Radiation Protection REMP, Figure 2, "Minimum Shift Staffing" & 90 T4/L 1 No No 11 Technician #1 Attachment D, "WCGS Minimum Staffing for T4/L3 Emergencies" Radiation Protection REMP, Figure 2, "Minimum Shift Staffing" & 90 T4/L4 No No 12 Technician #2 Attachment D; "WCGS Minimum Staffing for Emergencies" Security REMP, Attachment D, "WCGS Minimum N/A T5/L 15 No No 13 Staffing for Emergencies"

• Based on functional analysis ENS communicator required for continuous NRC communications. This individual also fulfills the OSC communicator role.

40

Analysis 2 Steam System Piping Failure (Major)

On-Shift Staffing Analysis Report Revision 1 TABLE 2 - Plant Operations & Safe Shutdown Analysis # 2.

One Unit - One Control Room Minimum Operations Crew Necessary to Implement AOPs and EOPs, or SAMGs if applicable Task Analysis Line Generic Title/Role On-Shift Position Controlling Method 1 Shift Manager Shift Manager Operations Training 2 Unit Supervisor Control Room Supervisor Operations Training 3 Shift Technical Advisor Shift Technical Advisor Operations Training 4 Reactor Operator #1 Reactor Operator #1 Operations Training 5 Reactor Operator #2 Reactor Operator #2 Operations Training Auxiliary Operator #1/2 Nuclear Station Operator Operations Training 6

1. 1/2 Auxiliary Operator #3 Nuclear Station Operator #3 Operations Training 7

(Site)

Auxiliary Operator #5 Nuclear Station Operator #5 Operations Training 8

(Aux)

Auxiliary Operator #6 Nuclear Station Operator #6 Operations Training 9

(TB)

Other (non-Operations) Personnel Necessary to Implement AOPs and EOPs, or SAMGs if applicable Task Analysis Line Generic Title/Role On-Shift Position Controlling Method 10 Mechanic N/A N/A 11 Electrician N/A N/A 12 l&C Technician N/A N/A 13 Other N/A N/A 41

Analysis 2 Steam System Piping Failure (Major)

On-Shift Staffing Analysis Report Revision 1 TABLE 3 - Firefighting Analysis # 2_

Task Analysis Line Performed By Controlling Method N/A - there is no fire associated with this N/A 1

event.

2 N/A N/A 3 N/A N/A 4 N/A N/A 5 N/A N/A 42

Analysis 2 Steam System Piping Failure (Major)

On-Shift Staffing Analysis Report Revision 1 TABLE 4 - Radiation Protection & Chemistry & OSC/ENS Communicators Analysis#i Performance Time Period After Erner~ ency Declaration (minutes)

Position Performing Line 0- 5- 10- 15- 20- 25- 30- 35 45- 50- 55- 60- 65- 70- 75- 80- 85-Function/Task 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 In-Plant Survey On-Shift Position: RP 1 X X X X X Tech #1 Main Steam Line Survey On-Site Survey N/A - The performance of an on-site survey is not necessary for initial implementation of the Emergency Plan and not 2

On-Shift Position required bv any procedure.

Personnel Monitoring 3 On-Shift Position: X X X X X X X X X X X X X CR RP Tech #1 Job Coverage On-Shift Position:

4 X X X X X X X X X X X X X X X X X X RP Tech #2 as needed for NSO actions Offsite Radiological Assessment*

5 X X X X X X X X X X X X X X X X X X On-Shift Position:

CR Chemistry Tech Chemistry function/task

1. 1-Sampling N/A- No sampling required until the Technical Support Center is staffed per AP 15C-003 (on hold pending approval 6 On-Shift Position:

by NRC).

Chemistry Tech

• Dose assessment passes directly to the EOF, so this function is not relieved at 90 minutes.

43

Analysis 2 Steam System Piping Failure (Major)

On-Shift Staffing Analysis Report Revision 1 TABLE 4- Radiation Protection & Chemistry & OSC/ENS Communicators Analysis# 6 Performance Time Period After Emergency Declaration (minutes)

Position Performing Line 0 10- 15- 20- 25- 30- 35- 40 50- 55- 60- 65- 70- 75 85-Function/Task 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 OSC Communicator function/task-1- Initiate staffing of ERO 2- Emerg Notifications 7 3- Notify State/ County X X X X X X 4- Notify NRC SRI /

X Westar 5-ANI / INPO X ENS Communicator function/task-Continuous 8 X X X X X X X X X X communication with NRC 44

Analysis 2 Steam System Piping Failure (Major)

On-Shift Staffing Analysis Report Revision 1 t ABLE 5 - Emergency Plan Implementation Analysis # 2.

Task Analysis Line Function/Task On-Shift Position Controlling Method Declare the Emergency Shift Manager Operations Training and EP 1

Classification Level (ECL) Training/Drill Program Approve Offsite Protective Action Shift Manager Operations Training and EP 2

Recommendations Training/Drill Program Approve content of State/local Shift Manager Operations Training and EP 3

notifications Training/Drill Program Approve extension to allowable Shift Manager Operations Training and EP 4

dose limits Training/Drill Program Notification and direction to on- Shift Manager Operations Training and EP 5 shift staff (e.g., to assemble, Training/Drill Program evacuate, etc.)

ERO notification Table 4 - Nuclear Operations Training and EP 6 Station Operator #1 /2 Training/Drill Program Abbreviated NRC notification for N/A for this event N/A 7 DBT event Complete State/local notification Shift Manager Operations Training and EP 8 form Training/Drill Program Perform State/local notifications Table 4- Nuclear Operations Training and EP 9 Station Operator #1 /2 Training/Drill Program Complete NRC event notification Shift Manager Operations Training and EP 10 form Training/Drill Program Activate EROS Table 4- Nuclear Operations Training and EP 11 Station Operator #1 /2 Training/Drill Program Offsite radiological assessment N/A- Table 4 - Chemistry Training and EP 12 . Chemistry Tech Training/Drill Program Perform NRC notifications Table 4 - Nuclear Operations Training and EP 13 Station Operator #1 /2 Training/Drill Program Perform other site-specific event Table 4- Nuclear Operations Training and EP 14 notifications (e.g., INPO, ANI, Station Operator #1 /2 Training/Drill Program etc.)

Personnel accountability Security/ Security Training and 15 Table 4- Nuclear Operations Training and EP Station Operator #1/2 Training/Drill Program 45

Analysis 3 Feedwater System Piping Break On-Shift Staffing Analysis Report Revision 1 Event Narrative #3 Feedwater System Piping Break This is one of the Design-Basis Condition IV Limiting Fault events as listed in the USAR, § 15.0.1.4, "Condition IV - Limiting Faults". USAR § 15.2.8.1, "Identification of Causes and Accident Description," states:

A major feedwater line rupture is defined as a break in a feedwater line large enough to prevent the addition of sufficient feedwater to the steam generators to maintain shell side fluid inventory in the steam generators. If the break is postulated in a feedwater line between the check valve and the steam generator, fluid from the steam generator may also be discharged through the break. Further, a break in this location could preclude the subsequent addition of auxiliary feedwater to the affected steam generator. (A break upstream of the feedwater line check valve would affect the NSSS only as a loss of feedwater) ...

Depending upon the size of the break and the plant operating conditions at the time of the break, the break could cause either an RCS coo/down (by excessive energy discharge through the break) or an RCS heatup. Potential RCS coo/down resulting from a secondary pipe rupture is evaluated in Section 15.1.5 [as described above].

Therefore, only the RCS heatup effects are evaluated for a feedwater line rupture ...

The main feedwater control system is assumed to fail due to an adverse environment, The water levels in all steam generators are assumed to decrease equally until the low-low steam generator level reactor trip setpoint is reached. After reactor trip, a double-ended rupture of the largest feedwater line is assumed. These assumptions conservatively bound the most limiting feedwater line rupture that can occur. Analyses have been performed at full power, with and without loss of offsite power, and with no credit taken for the pressurizer power-operated relief valves. For the case without offsite power available, the power is assumed to be lost at the time of reactor trip. This is more conservative than the case where power is lost at the initiation of the event.

A detailed discussion of possible accidents in this category, analytical methods used and consequences assessed can be found in USAR § 15.2.8, "Steam System Piping Failure," and are diagrammed in USAR Figure 15.0-14, "Major Rupture of a Main Feedwater Line."

Document APF 06-002-01, Emergency Action Levels, classifies the above as EAL-4 / BASES-4, "Main Steam Line Break." MSLB-6 (faulted steam generator and can't isolate the line) would classify the event as an Alert.

The event as diagrammed in USAR Figure 15.0-14 is assumed to generate a reactor trip from full power. For this assessment, it is assumed that procedure EMG E-0, "Reactor Trip or Safety Injection" was the entry point for operator actions. EMG E-0 is followed through step #16, when a jump to procedure EMG E-2, "Faulted Steam Generator Isolation," occurs. Other paths (e.g.,

EMG E-2, § 2, "Symptoms or Entry Conditions") are available; most of those listed assume an actual steam generator tube rupture occurred, or assume that all of the steam generators are uncontrollably losing pressure. EMG E-1, "Loss of Reactor or Secondary Coolant," was also 46

Analysis 3 Feedwater System Piping Break On-Shift Staffing Analysis Report Revision 1 reviewed. In step #2 of EMG E-1, the RNO path sends the operator to EMG E-2 if the faulted feedline cannot be isolated.

EMG E-0:

For operator checks and actions from step #1 through step #16, this assessment does not assume additional "RNO" events occurred which are outside the scope of the USAR description (e.g., an ATWS, an un-trippable turbine, etc.).

• As noted in a CAUTION box near the beginning of EMG E-0, "Abnormal conditions can cause higher than normal radiation levels. Health Physics monitoring may be required while performing local operator actions."

Steps #1 - #7 identify manual operations, but no local operations and no explicit radiological hazards are listed. For some steps, if a manual closure of valves also fails, then a subsequent RNO path step has valves operated locally. (NS0#112 depending on step and location.)

Step #1 verifies reactor trip. (R0#1)

Step #2 verifies turbine trip. (R0#2)

Step #3 checks AC emergency busses - at least one energized. (R0#1)

Step #4 checks if safety injection is actuated. (R0#1)

Step #5 checks if SI is required. (R0#1)

Step #6 verifies automatic actions using Attachment F, Automatic Signal Verification. (R0#1)

Step #7 checks main generator breakers and exciter breaker - open. (R0#2)

Step #8 checks total AFW flow >270,000 lbm/hr. The RNO path for this event involves manual operations described in Attachment F, "Automatic Signal Verification". Control manipulations are identified, with the RNO paths to attempt to manually close specified valves. (R0#2)

Steps #9 and #10 checks RCS cold leg temperatures and establish steam generator (SG) pressure control. There are no specific instructions requiring local operator actions. (R0#2)

For steps #11 - #13, the normal path is followed .. USAR Figure 15.1-22, "Pressurizer Pressure and Pressurizer Liquid Volume SLB Without Offsite Power," shows a rapid drop in volume for the first 20 seconds and a rapid drop in pressure for the first 60 seconds, stabilizing at an RCS pressure of approximately 1050 psia and a liquid volume less than 30 ft3

• As noted above, a pressurizer valve failure is outside the scope of this event. (R0#2)

Step #14 follows the normal path. The reactor coolant pumps tripped when the reactor tripped.

(R0#2) 47

Analysis 3 Feedwater System Piping Break On-Shift Staffing Analysis Report Revision 1 Step #15 directs an operator to monitor Critical Safety Functions using EMG F-0, "Critical Safety Function Status Trees." (STA)

Step #16 checks to see if "S/Gs Are Not Faulted." The RNO path (which reflects this narrative) sends the operator to EMG E-2, "Faulted Steam Generator Isolation," step #1. (R0#2)

EMG E-2:

Step #1 has the operator check to see if the steam lines on all S/Gs are isolated. This involves ensuring the main steam line valves, bypass valves and low point drain valves are closed. The RNO path has manual operations, but no local operations were identified. (R0#2)

Step #2 has the operator check to see if limitations for fault in Area 5 are required (which will depend on where the break is located). The procedure adds a warning to local operators in the affected area. (R0#2/NS0#6)

Step #3 checks to see if any S/Gs are not faulted. Based on the scenario for this event, S/Gs that are not connected to the broken main steam line are not faulted. (R0#2)

Step #4 identifies S/Gs that are faulted. The normal path has "any SIG pressures decreasing in an uncontrolled manner" OR "any SIG completely depressurized", which is consistent with USAR Figures 15.1-25 and 15.1-26. (R0#2)

Step #5 isolates the faulted S/Gs. The normal path involves closing the AFW flow controls to the faulted S/Gs. The RNO path has an operator locally isolate the affected lines. The Turbine Driven AFW pump always has the steam supply line locally closed by the operator. The SIG atmospheric relief valves (ARVs) on the faulted S/Gs are checked closed, and the RNO path has an operator locally isolate the affected SIG ARVs. (R0#2/NS0#5/NS0#6)

Step #6 addresses isolating feedwater lines. The RNO path for this section involves manual closure of valves. If manual closure of valves also fails, then a subsequent RNO path has a dispatch operator isolate valves locally. The valves in question are the main feedwater reg valves, the main feedwater reg bypass valves and the main feedwater chemical injection valves.

(R0#2/NS0#5)

Step #7 covers isolation of blowdown and sampling lines. There is an RNO path to locally isolate the affected blowdown and/or sampling line(s) for the affected S/Gs. (R0#2)

Step #8 discusses situations where the pressurizer PORV opens due to high pressure. For the event described, the RCS pressure drops with the cooldown and the pressurizer empties 18 seconds into the event (see USAR Table 15.1-1, sheet #2, as described above). The event follows the normal path. (R0#1)

Step #9 discusses continued uncontrolled cooldown. The core inlet temperature for the intact loops and the core average temperature start to stabilize after the first 30 seconds of the event.

See USAR Figure 15.1-23, "Core Inlet Temperature and Core Average Temperature SLB 48

Analysis 3 Feedwater System Piping Break On-Shift Staffing Analysis Report Revision 1 Without Offsite Power". The normal path is followed, based on the accident description.

(R0#2)

Step #10 has specific extreme caution statements regarding performing local surveys if the steam lines in Area 5 of the Aux Building are not intact, if there is a need to establish a sampling capability to determine secondary radiation levels. Radiation protection is directed to locally survey the steam lines in this area. Chemistry is directed to sample all SIGs for activity. In this case, per the scenario no steam generator tubes are ruptured. (R0#2/RP#1/RP#2/CH)

Step #11, on the RNO path, involves using an operator to locally open the ESW A or B to air compressor, to insure instrument air compressors are available to supply air to instruments and to restore instrument air to the containment. (R0#2/NS0#5)

Step #12 checks for intact SIG tubes. Based on the scenario, the SIG tubes are intact and the operator follows the normal path. (R0#2/RP#2/CH)

Step #13 checks if containment spray should be stopped. (R0#2)

Step #14 checks for ECCS flow. The operator follows the normal path and jumps to procedure EMG E-1 or EMG ES-03. (R0#1/R0#2)

EMG ES-03:

Neither the normal path steps nor the RNO steps appear to cause local operator issues to "be in play" unless other complications outside the scope of the narrative occur. Steps #14, "Control Charging Flow to Maintain PZR Level Greater than 6% [33%]" and #15, "Check if SI Pumps Should be Stopped" have specific RNO "do not continue" commentary based on faulted SIGs.

(R0#1/R0#2/NS0#3/NS0#5/NS0#6)

EMG E-1:

Procedure EMG E-1 is entered into after the faulted SIG has been identified and isolated, as noted in "Symptom or Entry Conditions" item #2.5. The SIGs are specifically checked in step

1. 2, where the jump to the previously discussed EMG E-2 occurs.

Steps #1 R0#1/R0#2 The caution box before step #6 has the same specific extreme caution statements regarding performing local surveys if the steamlines in Area 5 of the Aux Building are not intact as were identified earlier. Step #6 has health physics performing surveys in this area and chemistry sampling all SIGs for activity. (R0#2/RP#1/RP#2/CH)

Step #7 continues to check for radiation affecting the secondary side of the coolant system.

(R0#2)

Step #8 involves checking the pressurizer PORVs and block valves. The normal path is followed. (R0#1/NS0#1/2) 49

Analysis 3 Feedwater System Piping Break On-Shift Staffing Analysis Report Revision .1 Step #9 has the same RNO path discussion on locally opening ESW A or B to air compressor, as noted above. (R0#1/NS0#5/NS0#6)

Step #10 verifies instrument air to containment. (R0#1)

At step #11, for this scenario (feedwater break without additional complications outside the scope of the analyzed design basis event}, the operator jumps to procedure EMG ES-03, "SI Termination," Step #1. (R0#1/R0#2)

EMG ES-03:

Steps #1/2 reset ESFAS signals to allow for component repositioning. (CRS/R0#1)

Steps #3/4 establish Instrument Air-and aligns it to Containment. (CRS/R0#2)

Steps #5/6/7 reduces charging flow rates to 1 CCP (CRS/R0#1)

Steps #8/9/10 establish CCW flow to Containment (CRS/R0#2)

Steps #11- 15 Establish normal charging and secure BIT Flow (CRS/R0#1)

Steps #16-18 Secures remaining ECCS Pumps and determine if SI is still not needed.

(CRS/R0#2)

Termination path (expected actions are beyond the firsf 90 minutes of the event):

The longer-term closure to this event is assumed to involve completion of procedure EMG ES-03, "SI Termination".

If a LOCA should occur during the termination path, the procedure EMG ES-11, "Post-LOCA Cooldown and Depressurization" may be invoked.

50

Analysis 3 Feedwater System Piping Break On-Shift Staffing Analysis Report Revision 1 This OSA is applicable to Analysis #ias identified in Appendix A. (Feedwater System Piping Break)

TABLE 1 - On-shift Positions Augmentation Role in Unanalyzed TMS Line On-shift Position Emergency Plan Reference Elapsed Time (min) Table#/Line# Task? Required?

Shift Manager REMP, Figure 2, "Minimum Shift NA T2/L1 No No Staffing" & Attachment D, "WCGS T5/L1 Minimum Staffing for Emergencies" T5/L3 T5/L4 1

T5/L5 T5/L8 T5/L 10 Shift Technical Advisor REMP, Figure 2, "Minimum Shift NA T2/L3 No No Staffing" & Attachment D, "WCGS 2

Minimum Staffing for Emergencies" Control Room Supervisor REMP, Figure 2, "Minimum Shift NA T2/L2 No No Staffing" & Attachment D, "WCGS 3

Minimum Staffing for Emergencies" Reactor Operator #1 REMP, Figure 2, "Minimum Shift NA T2/L4 No No Staffing" & Attachment D, "WCGS 4

Minimum Staffing for Emergencies" 51

Analysis 3 Feedwater System Piping Break On-Shift Staffing Analysis Report Revision 1 This OSA is applicable to Analysis #ias identified in Appendix A. (Feedwater System Piping Break)

TABLE 1 - On-shift Positions Augmentation Role in Unanalyzed TMS Line On-shift Position Emergency Plan Reference Elapsed Time (min) Table#/Line# Task? Required?

Reactor Operator #2 REMP, Figure 2, "Minimum Shift NA T2/L5 No No Staffing" & Attachment D, "WCGS 5

Minimum Staffing for Emergencies" Nuclear Station Operator REMP, Figure 2, "Minimum Shift NA T2/L6 No Yes*

1. 1/2 Staffing" & Attachment D, "WCGS T4/L7 Minimum Staffing for Emergencies" T4/L8 T5/L6 6 T5/L9 T5/L 11 T5/L 13*

T5/L 14 T5/L 15 Nuclear Station Operator #3 REMP, Figure 2, "Minimum Shift NA T2/L7 No No Staffing" & Attachment D, "WCGS 7

Minimum Staffing for Emergencies" Nuclear Station Operator #5 REMP, Figure 2, "Minimum Shift NA T2/L8 No No Staffing" & Attachment D, "WCGS 8

Minimum Staffing for Emergencies" 52

Analysis 3 Feedwater System Piping Break On-Shift Staffing Analysis Report Revision 1 This OSA is applicable to Analysis #.]_as identified in Appendix A. (Feedwater System Piping Break)

TABLE 1 - On-shift Positions Augmentation Role in Unanalyzed TMS Line On-shift Position Emergency Plan Reference Elapsed Time (min) Table#/Line# Task? Required?

Nuclear Station Operator #6 REMP, Figure 2, "Minimum Shift NA T2/L9 No No Staffing" & Attachment D, "WCGS 9

Minimum Staffing for Emergencies" Chemistry Technician REMP, Figure 2, "Minimum Shift 90 T4/L5* No Yes Staffing" & Attachment D, "WCGS T4/L6 10 Minimum Staffing for Emergencies" Radiation Protection REMP, Figure 2, "Minimum Shift 90 T4/L3 No No Technician #1 Staffing" & Attachment D, "WCGS 11 Minimum Staffing for Emergencies" Radiation Protection REMP, Figure 2, "Minimum Shift 90 T4/L 1 No No Technician #2 Staffing" & Attachment D, "WCGS 12 T4/L4 Minimum Staffing for Emergencies" Security REMP, Attachment D, "WCGS NA T5/L 15 No No 13 Minimum Staffing for Emergencies"

• Based on functional analysis ENS communicator required for continuous NRC communications. This individual also fulfills the OSC communicator role.

53

Analysis 3 Feedwater System Piping Break On-Shift Staffing Analysis Report Revision 1 TABLE 2 - Plant Operations & Safe Shutdown Analysis# J One Unit - One Control Room Minimum Operations Crew Necessary to Implement AOPs and EOPs, or SAMGs if applicable Task Analysis Line Generic Title/Role On-Shift Position Controlling Method 1 Shift Manager Shift Manager Operations Training 2 Unit Supervisor Control Room Supervisor Operations Training 3 Shift Technical Advisor Shift Technical Advisor Operations Training 4 Reactor Operator #1 Reactor Operator #1 Operations Training 5 Reactor Operator #2 Reactor Operator #2 Operations Training Auxiliary Operator #1/2 Nuclear Station Operator Operations Training 6

1. 1/2 Auxiliary Operator #3 Nuclear Station Operator #3 Operations Training 7

(Site)

Auxiliary Operator #5 Nuclear Station Operator #5 Operations Training 8

(Aux)

Auxiliary Operator #6 Nuclear Station Operator #6 Operations Training 9

(TB)

Other (non-Operations) Personnel Necessary to Implement AOPs and EOPs, or SAMGs if applicable Task Analysis Line Generic Title/Role On-Shift Position Controlling Method 10 Mechanic N/A N/A 11 Electrician N/A N/A 12 l&C Technician N/A N/A 13 Other N/A N/A 54

Analysis 3 Feedwater System Piping Break On-Shift Staffing Analysis Report Revision 1 TABLE 3 - Firefighting Analysis#~

Task Analysis Line Performed By Controlling Method NIA - there is no fire associated with this NIA 1

event.

2 NIA NIA 3 NIA NIA 4 NIA NIA 5 NIA NIA 55

Analysis 3 Feedwater System Piping Break On-Shift Staffing Analysis Report Revision 1 TABLE 4 - Radiation Protection & Chemistry & OSC/ENS Communicator Analysis# J Performance Time Period After Emergency Declaration (minutes)

Position Performing Line 0- 5- 10- 15- 20- 25- 30- 35 45 55 65 75- 80- 85-Function/Task 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 In-Plant Survey On-Shift Position:

1 RP Tech #1 X X X X X Main Steam Line Survey On-Site Survey N/A - The performance of an on-site survey is not necessary for initial implementation of the Emergency Plan and 2 On-Shift Position not required by any procedure.

Personnel Monitoring On-Shift Position:

3 X X X X X X CR RP Tech #1 Job Coverage On-Shift Position:

RP Tech #2 4 X X X X X X X X X X X X X X X X X X As needed for NSO actions Offsite Radiological Assessment*

5 On-Shift Position: X X X X X X X X X X X X X X X X X X CR Chemistry Tech Chemistry function/task

1. 1 - Sampling N/A- No sampling required until the Technical Support Center is staffed per AP 15C-003 (on hold pending approval 6 On-Shift Position:

by NRC).

Chemistry Tech

• Dose assessment passes directly to the EOF, so this function 1s not relieved at 90 minutes.

56

Analysis 3 Feedwater System Piping Break On-Shift Staffing Analysis Report Revision 1 TABLE 4 - Radiation Protection & Chemistry & OSC/ENS Communicator Analysis#~

Performance Time Period After Emergency Declaration (minutes)

Position Performing Line 0- 5- 10- 15- 20- 25- 30- 35- 40 50 60 70- 75 85-Function/Task 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 OSC Communicator function/task-1- Initiate staffing of ERO X X X X X X 2- Emerg Notifications 7

3- Notify State/ County 4- Notify NRC SRI /

Westar X

5-ANI / INPO X ENS Communicator function/task-Continuous 8 X X X X X X X X X X communication with NRC 57

Analysis 3 Feedwater System Piping Break On-Shift Staffing Analysis Report Revision 1 TABLE 5 - Emergency Plan Implementation Analysis# J Task Analysis Line Function/Task On-Shift Position Controlling Method Declare the Emergency Shift Manager Operations Training and EP 1

Classification Level (ECL) Training/Drill Program Approve Offsite Protective N/A at an Alert N/A 2

Action Recommendations Approve content of State/local Shift Manager Operations Training and EP 3

notifications Training/Drill Program Approve extension to Shift Manager Operations Training and EP 4

allowable dose limits Training/Drill Program Notification and direction to Shift Manager Operations Training and EP 5 on-shift staff (e.g., to Training/Drill Program assemble, evacuate, etc.)

ERO notification Table 4- Nuclear Operations Training and EP 6 Station Operator #1 /2 Training/Drill Program Abbreviated NRC notification N/A for this event N/A 7

for DBT event Complete State/local Shift Manager Operations Training and EP 8

notification form Training/Drill Program Perform State/local Table 4- Nuclear Operations Training and EP 9

notifications Station Operator #1 /2 Training/Drill Program Complete NRC event Shift Manager Operations Training and EP 10 notification form Training/Drill Program Activate EROS Table 4- Nuclear Operations Training and EP 11 Station Operator #1 /2 Training/Drill Program Offsite radiological N/A - Table 4 - Chemistry Training and EP 12 assessment Chemistry Tech Training/Drill Program Perform NRC notifications Table 4 - Nuclear Operations Training and EP 13 Station Operator #1 /2 Training/Drill Program Perform other site-specific Table 4- Nuclear Operations Training and EP 14 event notifications (e.g., Station Operator #1 /2 Training/Drill Program INPO, ANI, etc.)

Personnel accountability Security/ Security Training and 15 Table 4- Nuclear Operations Training and EP Station Operator #1 /2 Training/Drill Program 58

Analysis 4 Reactor Coolant Pump Shaft Seizure (Locked Rotor)

On-Shift Staffing Analysis Report Revision 1 Event Narrative #4 Reactor Coolant Pump Shaft Seizure (Locked Rotor)

This is one of the Design-Basis Condition IV Limiting Fault events as listed in the USAR, § 15.0.1.4, "Condition IV - Limiting Faults.,".,. USAR § 15.3.3.1, "Identification of Causes and Accident Description," states:

The accident postulated is an instantaneous seizure of a reactor coolant pump rotor, as discussed in Section 5.4. Flow through the affected reactor coolant loop is rapidly reduced, leading to an initiation of a reactor trip on a low flow signal.

Following initiation of the reactor trip, heat stored in the fuel rods continues to be transferred to the coolant, causing the coolant to expand. At the same time, heat transfer to the shell side of the steam generators is reduced - first, because the reduced flow results in a decreased tube side film coefficient, and then, because the reactor coolant in the tubes cools down while the shell side temperature increases (turbine steam flow is reduced to zero upon plant trip). The rapid expansion of the coolant in the reactor core, combined with reduced heat transfer in the steam generators, causes an insurge into the pressurizer and a pressure increase throughout the RCS. The insurge into the pressurizer compresses the steam volume, actuates the automatic spray system, opens the power-operated relief valves, and opens the pressurizer safety valves, in that sequence. The two power-operated relief valves are designed for reliable operation, and would be expected to function properly during the accident. However, for conservatism, their pressure-reducing effect, as well as the pressure-reducing effect of the spray, are not included in the analysis.

A detailed discussion of possible accidents in this category, analytical methods used, and consequence analysis can be found in USAR § 15.3.3, "Reactor Coolant Pump Shaft Seizure (Locked Rotor) and are diagrammed in USAR Figure 15.0-15, "Loss of Forced Reactor Coolant Flow."

The USAR § 15.3.3.2, "Analysis of Effects and Consequences," elaborates on the conditions assumed for the accident:

At the beginning of the postulated locked rotor accident, i.e., at the time the shaft in one of the reactor coolant pumps is assumed to seize, the plant is assumed to be in operation under the most adverse steady state operating conditions, i.e., maximum guaranteed steady state thermal power, maximum steady state pressure, and maximum steady state coolant average temperature. Plant characteristics and initial conditions are further discussed in Section 15. 0. 3.

For the peak pressure evaluation, the initial pressure is conservatively set at 30 psi above nominal pressure (2,250 psia) to allow for errors in the pressurizer pressure measurement and control channels. This is done to obtain the highest possible rise in the coolant pressure during the transient. To obtain the maximum pressure in the primary side, conservatively high loop pressure drops are added to the calculated pressurizer pressure.

59

Analysis 4 Reactor Coolant Pump Shaft Seizure (Locked Rotor)

On-Shift Staffing Analysis Report Revision 1 USAR Tables 15.3-1, "Time Sequence of Events for Incidents Which Result in a Decrease in Reactor Coolant System Flow Rate," and 15.3-2, "Summary of Results for Locked Rotor Transients," outline the accident sequence.

USAR § 15.3.3.3, "Radiological Consequences," assesses:

The instantaneous seizure of a reactor coolant pump rotor results in a reactor trip on a low coolant flow signal. With the coincident Joss of offsite power, the condensers are not available, so the excess heat is removed from the secondary system by a steam dump through the steam generator safety and atmospheric relief valves. Steam generator tube leakage is assumed to continue until the pressures in the reactor coolant and secondary systems are equalized. The reactor coolant will contain the gap activities of the fraction of the fuel which undergoes DNB in addition to its assumed equilibrium activity.

More specifically, as described in USAR § 15.3.3.3.1.2, "Assumptions and Conditions":

• Offsite power is Jost.

• Following the incident, secondary steam is released to the environment for heat removal.

The total quantity of steam released is given in Table 15.3-3.

• Primary-to-secondary leakage continues after the accident for a period of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. At that time, reactor coolant and secondary system pressures are equalized. Until the pressure equalizes, the leakage rate is assumed to be constant and equal to the rate existing prior to the incident of 1 gpm (500 lbs/hr).

• Fission products released from the fuel-cladding gap of the damaged fuel rods are assumed to be instantaneously and homogeneously mixed with the reactor coolant.

• The noble gas activity released is equal to the amount present in the reactor coolant, which leaks into the secondary system after the accident.

• The iodine activity present in the primary to secondary leakage is assumed to mix homogeneously with the iodine activity initially present in the steam generators.

• A partition factor of 0. 01 between the vapor and liquid phases for radioiodine in the steam generators is utilized to determine iodine releases to the environment via steam venting from the steam generators.

• The activity released from the steam generators is immediately vented to the environment.

The radiological source term is summarized in USAR Tables 15.3-3, "Parameters Used in Evaluating the Radiological Consequences of a Locked Rotor Accident," and 15.3-4, "Radiological Consequences of a Locked Rotor Accident." The loss of offsite power provides an external pathway for release of radioactive material, as noted in USAR § 15.3.3.3.2, "Identification of Uncertainties and Conservative Elements in the Analysis":

The coincident Joss of offsite power with the occurrence of a reactor coolant pump locked rotor is a highly conservative assumption. In the event of the availability of offsite station power, the condenser steam dump valves will open, permitting steam dump to the condenser. Thus there is no direct release to the environment.

60

Analysis 4 Reactor Coolant Pump Shaft Seizure (Locked Rotor)

On-Shift Staffing Analysis Report Revision 1 A detailed discussion of the models used is located in USAR Appendix 15A, "Accident Analysis Radiological Consequences Evaluation Models and Parameters.'\ USAR Table 15.3-4 projects a thyroid dose of 882 millirem at the exclusion area boundary.

Based on radiological consequences, Document APF 06-002-01, Emergency Action Levels, classifies the above as an EAL-1 / BASES - 1. RER3, "Valid dose assessment indicates a dose greater than 500 mR thyroid (CDE) at site boundary, would classify the event as a Site Area Emergency.

The event as diagrammed in USAR Figure 15.0-15 and summarized in USAR Table 15.3-1, Sheet #2, is assumed to generate a reactor trip from full power due to "Low RCS Flow in One Loop." The event is also assumed to cause the pressurizer safety valves to open to relieve RCS pressure. For this assessment, it is assumed that procedure EMG E-0, "Reactor Trip or Safety Injection," was the entry point for operator actions.

The USAR Table 15.3-2, "without offsite power column, gives a maximum clad temperature at the core hot spot of 1,942 °F (affecting 0.4 % of the Zr*H 20 by weight). USAR Figure 15.3-19, "Outer Clad Temperature for Locked Rotor without Offsite Power," shows that for localized area of the core the peak occurs 4 seconds into the incident and then decreases to 1,600 °F within 6 more seconds. USAR Figure 15.3-18, "Core Average Temperature Locked Rotor With and without Offsite Power," shows that, in the "without offsite power case, the core temperature is back to "pre-event" levels within 8 seconds. The combination suggests increased activity in the core but no sustained temperature rise.

• EMG E-0:

For procedure E-0, following the operator checks and actions from step #1 through step #10, this assessment does not assume additional "RNO" events that are outside the scope of the USAR description (e.g., ATWS, un-trippable turbines, etc.). (CRS/R0#1/R0#2)

Step #1 verifies reactor trip. (R0#1)

Step #2 verifies turbine trip. (R0#2)

Step #3 checks AC emergency busses - at least one energized. (R0#1)

Step #4 checks if safety injection is actuated. (R0#1)

Step #5 checks if SI is required. (R0#1)

Step #6 verifies automatic actions using Attachment F, Automatic Signal Verification. (R0#1)

Step #7 checks main generator breakers and exciter breaker - open. (R0#2)

Step #8 checks total AFW flow > 270,000 lbm/hr. (R0#2)

Step #9 checks RCS cold leg temperatures. (R0#2) 61

Analysis 4 Reactor Coolant Pump Shaft Seizure (Locked Rotor)

On-Shift Staffing Analysis Report Revision 1 Step #10 establishes SIG pressure control. (R0#2)

Step #11 has the operator checking the status of the pressurizer PORVs (which the above scenario assumes have opened to deal with the pressure transient when one of the reactor coolant pumps had a rotor lock, but are functioning properly). (R0#2) The RNO path for being unable to close the PORVs is to use and monitor procedure EMG F-0, "Critical Safety Function Status Trees (CSFST)," (STA/R0#2) and then to procedure EMG E-1, "Loss of Reactor or Secondary Coolant."

Step #12 has the operator check normal PZR spray valves closed. (R0#2)

Step #13 has the operator check PZR safety valves closed. (R0#2)

(Again, the scenario assumes that the Pressurizer Safety Values will operate properly for the duration of the accident).

Step #14 checks that the reactor coolant pumps are off. (R0#2)

At step #15, the operator is directed to monitor procedure EMG F-0. The procedure EMG E-0 continues while the Critical Status Function Status Tree (CSFST) is monitored. (STA)

Step #16 has the operator check for faulted steam generators. (For the RNO path, see the above section, "Feed-water System Pipe Break," for more details). Faulted steam generators are not part of the scenario being analyzed here. (R0#2)

Step #17 has the operator check if the steam generator tubes are intact. For this scenario, we're assuming a primary to secondary leak of 1 gallon/minute with the coolant having some elevated activity due to the "hot spot" and localized cladding failure. This is the RNO step that would direct to ES-03. (R0#2)

Step #18 has the operator check if RCS is intact in containment. (CRS/R0#1)

Step #19 has the operator check if ECCS flow should be reduced. (CRS/R0#1)

Step #20 has the operator reset SI. (R0#1)

Step #21 has the operator reset containment isolation phase A and B. (R0#1)

The possibility of a loss of offsite power during this event is within the scope of this event. Steps

1. 22 - #23 on the RNO path, involves using an operator to locally open the ESW A or B to air compressor valves, in order to ensure instrument air compressors are available to supply air to instruments and to restore instrument air to the containment. An operator may also be dispatched to locally reset alarms and restart air compressors as needed.

(R0#2/NS0#5/NS0#6)

Step #24 involves checking steam generator levels (again, this scenario assumes a one gallon per minute leakage from the primary to secondary, but no other issues with the steam generators). (R0#2) 62

Analysis 4 Reactor Coolant Pump Shaft Seizure (Locked Rotor)

On-Shift Staffing Analysis Report Revision 1 Step #25 is a repeat of the actions of Step #17. (R0#2/RP#2/CH)

Steps #26 through #28 are assumed to be conducted on the "normal" path.- (R0#1/RP#2)

Step #29 involves checking if the diesel generators should be stopped (e.g., is there offsite power available yet?). Procedure SYS KJ-121, "Diesel Generator NE01 and NE02 Lineup for Automatic Operation" is called out on the normal path, while continuing procedure E-0. The diesel generator procedure does have local actions (annunciator panel checks, oil level checks, governor speed checks, valve manipulations, etc.) called out throughout the document.

(R0#2/NS0#6)

Step #30 involves an operator locally resetting the boric acid transfer pump breakers and the emergency borate valve breakers. (R0#1/NS0#5/NS0#6)

Steps #31 through #33 are assumed to be conducted on the "normal" path. Step #34 loops back to step #9, "Check RCS Cold Leg Temperatures." (R0#1/NS0#3)

The operator continues looping through the procedure until the step #20, "Check If ECCS Flow Should be Reduced" can be answered with the action "Go to EMG ES-03, SI Termination, step

1. 1."

EMG ES-03:

Steps #1/2 reset ESFAS signals to allow for component repositioning. (CRS/R0#1)

Steps #3/4 establish Instrument Air -and aligns it to Containment. (CRS/R0#2)

Steps #5/6/7 reduces charging flow rates to 1 CCP (CRS/R0#1)

Steps #8/9/10 establish CCW flow to Containment (CRS/R0#2)

Steps #11- 15 Establish normal charging and secure BIT Flow (CRS/R0#1)

Steps #16-18 Secures remaining ECCS Pumps and determine if SI is still not needed.

(CRS/R0#2)

Termination path (expected actions are beyond the first 90 minutes of the event):

The longer-term closure to this event is assumed to involve completion of procedure EMG ES-03, "SI Termination".

If a LOCA should occur during the termination path, the procedure EMG ES-11, "Post-LOCA Cooldown and Depressurization" may be invoked.

63

Analysis 4 Reactor Coolant Pump Shaft Seizure (Locked Rotor)

On-Shift Staffing Analysis Report Revision 1 This OSA is applicable to Analysis# 1 as identified in Appendix A. (Reactor Coolant Pump Shaft Seizure)

TABLE 1 - On-shift Positions Augmentation Role in Unanalyzed TMS Line On-shift Position Emergency Plan Reference Elapsed Time (min) Table#/Line# Task? Required?

Shift Manager REMP, Figure 2, "Minimum Shift NA T2/L 1 No No Staffing" & Attachment D, "WCGS TS/L 1 Minimum Staffing for Emergencies" TS/L2 TS/L3 1

TS/L4 TS/LS TS/L8 TS/L 10 Shift Technical Advisor REMP, Figure 2, "Minimum Shift NA T2/L3 No No Staffing" & Attachment D, "WCGS 2

Minimum Staffing for Emergencies" Control Room Supervisor REMP, Figure 2, "Minimum Shift NA T2/L2 No No Staffing" & Attachment D, "WCGS 3

Minimum Staffing for Emergencies" Reactor Operator #1 REMP, Figure 2, "Minimum Shift NA T2/L4 No No Staffing" & Attachment D, "WCGS 4

Minimum Staffing for Emergencies" 64

Analysis 4 Reactor Coolant Pump Shaft Seizure (Locked Rotor)

On-Shift Staffing Analysis Report Revision 1 This OSA is applicable to Analysis # 1 as identified in Appendix A. (Reactor Coolant Pump Shaft Seizure)

TABLE 1- On-shift Positions Augmentation Role in Unanalyzed TMS Line On-shift Position Emergency Plan Reference Elapsed Time (min) Table#/Line# Task? Required?

Reactor Operator #2 REMP, Figure 2, "Minimum Shift NA T2/L5 No No Staffing" & Attachment D, "WCGS 5

Minimum Staffing for Emergencies" Nuclear Station Operator REMP, Figure 2, "Minimum Shift NA T2/L6 No Yes*

1. 1/2 Staffing" & Attachment D, "WCGS T4/L7 Minimum Staffing for Emergencies" T4/L8 T5/L6 6 T5/L9 TS/L 11 T5/L 13*

TS/L 14 TS/L 15 Nuclear Station Operator #3 REMP, Figure 2, "Minimum Shift NA T2/L7 No No Staffing" & Attachment D, "WCGS 7

Minimum Staffing for Emergencies" Nuclear Station Operator #5 REMP, Figure 2, "Minimum Shift NA T2/L8 No No Staffing" & Attachment D, "WCGS 8

Minimum Staffing for Emergencies" 65

Analysis 4 Reactor Coolant Pump Shaft Seizure (Locked Rotor)

On-Shift Staffing Analysis Report Revision 1 This OSA is applicable to Analysis# 1 as identified in Appendix A. (Reactor Coolant Pump Shaft Seizure)

TABLE 1 - On-shift Positions Augmentation Role in Unanalyzed TMS Line On-shift Position Emergency Plan Reference Elapsed Time (min) Table#/Line# Task? Required?

Nuclear Station Operator #6 REMP, Figure 2, "Minimum Shift NA T5/L9 No No Staffing" & Attachment D, "WCGS 9

Minimum Staffing for Emergencies" Chemistry Technician REMP, Figure 2, "Minimum Shift 90 T4/L5* No No Staffing" & Attachment D, "WCGS 10 T4/L6 Minimum Staffing for Emergencies" Radiation Protection REMP, Figure 2, "Minimum Shift 90 T4/L3 No No Technician #1 Staffing" & Attachment D, "WCGS 11 Minimum Staffing for Emergencies" Radiation Protection REMP, Figure 2, "Minimum Shift 90 T4/L 1 No No Technician #2 Staffing" & Attachment D, "WCGS 12 T4/L4 Minimum Staffing for Emergencies" Security REMP, Attachment D, "WCGS NA T5/L 15 No No 13 Minimum Staffing for Emergencies"

• Based on functional analysis ENS communicator required for continuous NRC communications. This individual also fulfills the OSC communicator role.

66

Analysis 4 Reactor Coolant Pump Shaft Seizure (Locked Rotor)

On-Shift Staffing Analysis Report Revision 1 TABLE 2 - Plant Operations & Safe Shutdown Analysis#1 One Unit - One Control Room Minimum Operations Crew Necessary to Implement AOPs and EOPs, or SAMGs if applicable Task Analysis Line Generic Title/Role On-Shift Position Controlling Method 1 Shift Manager Shift Manager Operations Training 2 Unit Supervisor Control Room Supervisor Operations Training 3 Shift Technical Advisor Shift Technical Advisor Operations Training 4 Reactor Operator #1 Reactor Operator #1 Operations Training 5 Reactor Operator #2 Reactor Operator #2 Operations Training Auxiliary Operator #1/2 Nuclear Station Operator Operations Training 6

1. 1/2 7 Auxiliary Operator #3 Nuclear Station Operator #3 Operations Training 8 Auxiliary Operator #5 Nuclear Station Operator #5 Operations Training 9 Auxiliary Operator #6 Nuclear Station Operator #6 Operations Training Other (non-Operations) Personnel Necessary to Implement AOPs and EOPs, or SAMGs if applicable Task Analysis Line Generic Title/Role On-Shift Position Controlling Method 10 Mechanic N/A N/A 11 Electrician N/A N/A 12 l&C Technician N/A N/A 13 Other N/A N/A 67

Analysis 4 Reactor Coolant Pump Shaft Seizure (Locked Rotor)

On-Shift Staffing Analysis Report Revision 1 TABLE 3 - Firefighting Analysis#~

Task Analysis Line Performed By Controlling Method N/A- there is no fire associated with this N/A 1

event.

2 N/A N/A 3 N/A N/A 4 N/A N/A 5 N/A NIA 68

Analysis 4 Reactor Coolant Pump Shaft Seizure (Locked Rotor)

On-Shift Staffing Analysis Report Revision 1 TABLE 4 - Radiation Protection & Chemistry & OSC/ENS Communicator Analysis#1.

Performance Time Period After Emergency Declaration (minutes)

Position Performing Line 0- 5- 10- 15- 20- 25- 30- 35 45- 50- 55 65- 70- 75- 80- 85-Function/Task 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 In-Plant Survey On-Shift Position:

1 RP Tech #1 X X X X X Main Steam Line Survey On-Site Survey N/A - The performance of an on-site survey is not necessary for initial implementation of the Emergency Plan and 2 On-Shift Position not required by any procedure.

Personnel Monitoring 3 On-Shift Position: X X X X X X X X X X X X X CR RP Tech #1 Job Coverage On-Shift Position:

RP Tech #2 4 X X X X X X X X X X X X X X X X X X As needed for NSO actions Offsite Radiological Assessment*

5 On-Shift Position: CR X X X X X X X X X X X X X X X X X X Chemistry Tech Chemistry function/task #1

-Sampling No sampling required until Technical Support Center is staffed per AP 15C-003 (on hold pending approval by NRC).

6 On-Shift Position:

Chemistry Tech

• Dose assessment passes directly to the EOF, so this function is not relieved at 90 minutes.

69

Analysis 4 Reactor Coolant Pump Shaft Seizure (Locked Rotor)

On-Shift Staffing Analysis Report Revision 1 TABLE 4- Radiation Protection & Chemistry & OSC/ENS Communicator Analysis#1_

Performance Time Period After Emergenc" Declaration (minutes)

Position Performing Line 0- 5- 10- 15- 20- 25- 30- 35- 40- 45- 50 60 70- 75 85-Function/Task 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 OSC Communicator function/task-1- Initiate staffing of ERO 2- Emerg Notifications X X X X X X 7 3- Notify State/ County 4- Notify NRC SRI /

Westar X

5-ANI / INPO X ENS Communicator function/task-8 Continuous communication X X X X X X X X X X with NRC 70

Analysis 4 Reactor Coolant Pump Shaft Seizure (Locked Rotor)

On-Shift Staffing Analysis Report Revision 1 TABLE 5 - Emergency Plan Implementation Analysis#1 Task Analysis Line Function/Task On-Shift Position Controlling Method Declare the Emergency Shift Manager Operations Training and EP 1

Classification Level (EGL) Training/Drill Program Approve Offsite Protective Action Shift Manager Operations Training and EP 2

Recommendations Training/Drill Program Approve content of State/local Shift Manager Operations Training and EP 3

notifications Training/Drill Program Approve extension to allowable Shift Manager Operations Training and EP 4

dose limits Training/Drill Program Notification and direction to on- Shift Manager Operations Training and EP 5 shift staff (e.g., to assemble, Training/Drill Program evacuate, etc.)

ERO notification Table 4 - Nuclear Operations Training and EP 6 Station Operator #1 /2 Training/Drill Program Abbreviated NRG notification for N/A for this event N/A 7 DBT event Complete State/local notification Shift Manager Operations Training and EP 8 form Training/Drill Program Perform State/local notifications Table 4 - Nuclear Operations Training and EP 9 Station Operator #1 /2 Training/Drill Program Complete NRG event notification Shift Manager Operations Training and EP 10 form Training/Drill Program Activate EROS Table 4 - Nuclear Operations Training and EP 11 Station Operator #1 /2 Training/Drill Program Offsite radiological assessment N/A- Table 4 - Chemistry Training and EP 12 Chemistry Tech Training/Drill Program Perform NRG notifications Table 4 - Nuclear Operations Training and EP 13 Station Operator #1/2 Training/Drill Program Perform other site-specific event Table 4 - Nuclear Operations Training and EP 14 notifications (e.g., INPO, ANI, Station Operator #1 /2 Training/Drill Program etc.)

Personnel accountability Security I Security Training and 15 Table 4- Nuclear Operations Training and EP Station Operator #1 /2 Training/Drill Program 71

Analysis 5 Reactor Coolant Pump Shaft Break On-Shift Staffing Analysis Report Revision 1 Event Narrative #5 Reactor Coolant Pump Shaft Break (Bounded by Event #4)

The USAR § 15.3.4.1, "Identification of Causes and Accident Description," states:

The accident is postulated as an instantaneous failure of a reactor coolant pump shaft, as discussed in Section 5.4. Flow through the affected reactor coolant loop is rapidly reduced, though the initial rate of reduction of coolant flow is greater for the reactor coolant pump rotor seizure event. Reactor trip is initiated on a low flow signal in the affected loop.

Following initiation of the reactor trip, heat stored in the fuel rods continues to be transferred to the coolant, causing the coolant to expand. At the same time, heat transfer to the shell side of the steam generators is reduced - first, because the reduced flow results in a decreased tube side film coefficient and then because the reactor coolant in the tubes cools dowh while the shell side temperature increases (turbine steam flow is reduced to zero upon plant trip). The rapid expansion of the coolant in the reactor core, combined with reduced heat transfer in the steam generators, causes an insurge into the pressurizer and a pressure increase throughout the RCS. The insurge into the pressurizer compresses the steam volume, actuates the automatic spray system, opens the power-operated relief valves, and opens the pressurizer safety valves, in that sequence. The two power-operated relief valves are designed for reliable operation and would be expected to function properly during the accident. However, for conservatism, their pressure-reducing effect, as well as the pressure-reducing effect of the spray, are not included in the analysis.

The document continues, in USAR § 15.3.4.2, "Conclusions":

The consequences of a reactor coolant pump shaft break are no worse than those calculated for the locked rotor incident (see Section 15.3.3). With a failed shaft, the impeller could conceivably be free to spin in a reverse direction as opposed to being fixed in position as assumed in the Jocked rotor analysis. However, the net effect on core flow is negligible, resulting in only a slight decrease in the end point (steady state) core flow. For both the shaft break and Jocked rotor incidents, reactor trip occurs very early in the transient. In addition, the Jocked rotor analysis conservatively assumes that DNB occurs at the beginning of the transient.

Thus, the analysis for this accident is considered bounded by the above analysis for the Reactor Coolant Pump Shaft Seizure (Locked Rotor) accident (Event #4).

72

Analysis 6 Spectrum of Rod Cluster Control Assembly Ejection Accidents On-Shift Staffing Analysis Report Revision 1 Event #6 Narrative Spectrum of Rod Cluster Control Assembly Ejection Accidents This is one of the Design-Basis Condition IV Limiting Fault events as listed in the USAR, § 15.0.1.4, "Condition IV - Limiting Faults". The USAR § 15.4.8.1, "Identification of Causes and Accident Description," states:

This accident is defined as the mechanical failure of a control rod mechanism pressure housing, resulting in the ejection of an RCCA and drive shaft. The consequence of this mechanical failure is a rapid positive reactivity insertion and system depressurization together with an adverse core power distribution, possibly leading to localized fuel rod damage.

A detailed discussion of possible accidents in this category, analytical methods used, and consequence analysis can be found in USAR § 15.4.8, "Spectrum of Rod Cluster Control Assembly Ejection Accidents", and are diagrammed in USAR Figure 15.0-21, "Rupture of Control Rod Drive Mechanism Housing".

The USAR § 15.4.8.2, "Analysis of Effects and Consequences," elaborates on the conditions assumed for the accident:

The values for ejected rod worths and hot channel factors are calculated. No credit is taken for the flux flattening effects of reactivity feedback. The calculation is performed for the maximum allowed bank insertion at a given power level, as determined by the rod insertion limits. Adverse xenon distributions are considered in the calculation.

The minimum design shutdown margin available for this plant at hot zero power (HZP) may be reached only at end-of-life in the equilibrium cycle. This value includes an allowance for the worst stuck rod and adverse xenon distribution, conservative Doppler and moderator defects, and an allowance for calculational uncertainties. Physics calculations for this plant have shown that the effect of two stuck RCCAs (one of which is the worst ejected rod) is to reduce the shutdown by about an additional 1 percent iJ.k.

Therefore, following a reactor trip resulting from an RCCA ejection accident, the reactor will be subcritical when the core returns to HZP.

It is assumed that fission products are released from the gaps of all rods experiencing DNB. In all cases considered, less than 10 percent of the rods experienced the DNB.

Although limited fuel melting at the hot spot was predicted for the full power cases, in practice melting is not expected since the analysis conservatively assumed that the hot spots before and after ejection were coincident.

USAR Table 15.4-1, "Time Sequence of Events for Incidents Which Result in Reactivity and Power Distribution Anomalies," Sheet #2, provides information on the timing for Rod cluster control assembly ejection accidents. Tables 15.4-2, "Parameters Used in the Analysis of the Rod Cluster Control Assembly Ejection Accident," and 15.4-3, "Parameters Used in Evaluating the RCCA Ejection Accident," elaborate further on the chain of events for this scenario.

73

Analysis 6 Spectrum of Rod Cluster Control Assembly Ejection Accidents On-Shift Staffing Analysis Report Revision 1 USAR §15.4.8.3, "Radiological Consequences," assesses:

Prior to the accident, it is assumed that the plant has been operating with simultaneous fuel defects and steam generator tube leakage for a time sufficient to establish equilibrium levels of activity in the reactor coolant and secondary systems.

The RCCA ejection results in reactivity being inserted to the core which causes the local power to rise. In a conseNative analysis, it is assumed that partial cladding failure and fuel melting occurs. The fuel pellet and gap activities are assumed to be immediately and uniformly released within the reactor coolant ...

The activity released to the containment from the reactor coolant through the ruptured control rod mechanism pressure housing is assumed to be mixed instantaneously throughout the containment and is available for leakage to the atmosphere. The only removal processes considered in the containment are iodine plateout, radioactive decay, and leakage from the containment.

The model for the activity available for release to the atmosphere from the relief valves assumes that the release consists of the activity in the secondary system plus that fraction of the activity leaking from the reactor coolant through the steam generator tubes. The leakage of reactor coolant to the secondary side of the steam generator continues until the pressures in the reactor coolant and secondary systems equalize.

Primary and secondary pressures are equalized at 1100 seconds following the accident, thus terminating primary to secondary leakage in the steam generators ... Thereafter, no mass transfer from the reactor coolant system to the secondary system due to the steam generator tube leakage is assumed. Thus, in the case of coincident loss of offsite power, activity is released to the atmosphere from a steam dump through the relief valves.

The USAR § 15.4.8.3.1.2, "Assumptions and Conditions," makes a number of major assumptions regarding the radiological releases, including:

• 10 percent of the fuel rod gap activity, except for Kr-85 and 1-131, which are 30 percent and 12 percent respectively, is additionally released to the reactor coolant.

• 0. 25 percent of the fuel is assumed to melt.

• Following the incident until primary and secondary side pressures equalize, secondary steam is released to the environment.--;-;-:

• Offsite power is assumed lost.

There are three release pathways for this accident, per USAR § 15.4.8.3.1.4, "Identification of Leakage Pathways and Resultant Leakage Activity":

1. Direct steam dump to the atmosphere through the secondary system relief valves for the secondary steam

2. Primary-to-secondary steam generator tube leakage and subsequent steam dump to the atmosphere through the secondary system relief valves 74

Analysis 6 Spectrum of Rod Cluster Control Assembly Ejection Accidents On-Shift Staffing Analysis Report Revision 1

3. The resultant activity released to the containment is assumed available for leakage directly to the environment.

Radiological consequences for the worst-case scenario (RCCA Ejection Accident with no offsite power) are described in USAR Tables 15.4-3 (discussed above) and 15.4-4, "Radiological Consequences of a Rod-Ejection Accident." For the worst-case accident, occurring at "Hot Full Power," (HFP) near the beginning or ending of core life, the exclusion boundary dose to the thyroid is projected at 11,700 millirem. The whole body dose is projected at 58.5 millirem.

Document APF 06-002-01, Emergency Action Levels, could classify the rod ejection accident as an EAL-3 / BASES-3, "Loss of Reactor Coolant Boundary," LRCB3, (Greater than 2% Fuel Clad Damage), which would fall under a Site Area Emergency. However, given the effects of the rod ejection accident on the fuel, the projected doses to the site boundary classify the accident as EAL-1 / BASES-1, "Radioactive Effluent Release," RER4, (Valid dose assessment indicates a dose greater than 1000 mR TEDE or 5000 mR thyroid (CDE) at the Site boundary). This escalates the classification to a General Emergency.

The event as diagrammed in USAR Figure 15.0-21, "Rupture of Control Rod Drive Mechanism Housing," is assumed to generate a reactor trip from full power, based on the USAR § 15.4.8.2.2, "Calculation of Basic Parameters," statement:

... reactor protection for a rod ejection is provided by high neutron flux trip (high and low setting) and high rate of neutron flux increase trip.

The event has also caused a LOCA, based on the statement:

Depressurization calculations have been performed for a typical four-loop plant, assuming the maximum possible size break (2. 75-inch diameter) located in the reactor pressure vessel head. The results show a rapid pressure drop and a decrease in system water mass due to the break. The safety injection system is actuated on low pressurizer pressure within 1 minute after the break. The RCS pressure continues to drop and reaches saturation (1,200 psi) in about 2 to 3 minutes. Due to the large thermal inertia of primary and secondary systems, there has been no significant decrease in the RCS temperature below no-load by this time.

EMG E-0:

The procedure starts out with a caution that "Accident conditions can cause higher than normal radiation levels. RP monitoring may be required while performing local operator actions."

Step #1 verifies reactor trip. (R0#1)

Step #2 verifies turbine trip. (R0#2)

Step #3 checks AC emergency busses - at least one energized. (R0#1)

Step #4 checks if safety injection is actuated. (R0#1) 75

Analysis 6 Spectrum of Rod Cluster Control Assembly Ejection Accidents On-Shift Staffing Analysis Report Revision 1 Step #5 checks if SI is required. (R0#1)

Step #6 verifies automatic actions using Attachment F, Automatic Signal Verification. (R0#1)

Step #7 checks main generator breakers and exciter breaker - open. (R0#2)

Step #8 checks total AFW flow > 270,000 lbmlhr. (R0#2)

Step #9 checks RCS cold leg temperatures. (R0#2)

Step #10 establishes SIG pressure control. (R0#2)

For steps #11 - #13, the normal path is followed. USAR Figure 15.1-22, "Pressurizer Pressure and Pressurizer Liquid Volume SLB Without Offsite Power," shows a rapid drop in volume for the first 20 seconds and a rapid drop in pressure for the first 60 seconds, stabilizing at an RCS pressure of approximately 1050 psia and a liquid volume less than 30 ft3 . As noted above, a pressurizer valve failure is outside the scope of this event. (R0#2)

Step #14 follows the normal path. The reactor coolant pumps tripped when the reactor tripped.

(R0#2)

Step #15 directs the operator (STA) to monitor the critical safety functions using procedure EMG F-0, "Critical Safety Function Status Trees (CSFST)," based on "safety injection has not been terminated and no accident condition has been identified".

Step #16 checks if SIGs are not faulted. (R0#2)

Step #17 checks if SIG tubes are intact. (R0#2)

Step #18 checks if RCS is intact in containment. (R0#1)

EMG E-1:

Step #1 checks if the RCPs have been stopped. The scenario has the RCPs tripped when the reactor tripped, with the loss of offsite power. Follow the RNO path and go to step #2. (R0#2)

Step #2 checks if the SIGs are faulted. This is a repeat of procedure EMG E-0, step #16. The operator follows the normal path. (R0#2)

Step #3 checks if the SIGs are intact (e.g., are not ruptured). (R0#2)

Step #4 has the operator reset the safety injection (SI), and Step #5 has the operator reset the containment isolation phase A and B. (R0#1/R0#2)

Step #6 determines the secondary radiation levels. One sub-step has radiation protection survey steam lines in Area 5 of the Auxiliary Building, which was already to have been started in procedure E-0, step #17. (R0#2/RP#2/CH) 76

Analysis 6 Spectrum of Rod Cluster Control Assembly Ejection Accidents On-Shift Staffing Analysis Report Revision 1 Step #6, sub-step (e), opens all SIG sample isolation valves. At that point, chemistry is directed to sample all S/Gs for activity. (R0#2/RP#2/CH)

Step #7 is a check on the secondary radiation levels. No local actions were identified.

(R0#2/RP#2)

Step #8 checks pressurizer PORV valves, which are assumed in this scenario to be acting normally. The loss of RCS pressure is due to a double-ended guillotine break in the cold leg, not due to a pressurizer valve lifting. The pressurizer valves remained closed and the RCS pressure has rapidly dropped below 2185 psig. Accumulator injection occurred 14-19 seconds into the event, as noted in USAR Table 15.6-10, "Time Sequence of Events for Loss-Of-Coolant Accidents." (R0#1)

Step #9 verifies instrument air alignment. This scenario assumes a loss of offsite power at the beginning of the LOCA. The RNO path involves using an operator to locally open the ESW A or B to air compressor valves, in order to insure instrument air compressors are available to supply air to instruments and to restore instrument air to the containment.

An operator may also be dispatched to locally reset alarms, restart air compressors and open instrument air supply containment isolation valves as needed. (R0#2/NS0#5/NS0#6)

Step #10 verifies instrument air to containment. (R0#2)

Step #11 checks to see if the ECCS flow should be reduced. In this scenario, the RCS has blown down to the bottom of the core and is re-filling. Much of the initial RCS inventory has flashed to steam, heating and pressurizing the containment building. The RCS pressure is rapidly decreasing. The operator goes to step #12. (R0#1)

Step #12 checks to see if the containment sprays should be stopped. The spray pumps are assumed to be running, and the containment pressure is between 3 psig and 60 psig. (Per USAR Figure 6.2.1-6 has the containment pressure at 27 psig and decreasing at 1000 seconds.

This step is assumed to follow the normal path. If 2 or more of the 4 available containment fan coolers are running in emergency mode, only one running spray pump will be required. As noted in USAR § 6.2.1.4.3.2, "Input Parameters and Assumptions," the containment fan coolers are operable using power from the emergency diesel generators. (R0#2)

Step #13 checks if RHR pumps should be stopped. The RHR pumps should continue running, as the RCS has blown down to the bottom of the core and is re-filling. The operator follows the normal path. (R0#2)

Step #14 checks the RCS and SIG Pressures. The RCS pressure is stable or decreasing due to the large double-ended guillotine break in the cold leg. The SIG pressures are not decreasing in an uncontrolled manner. The operator follows the normal path. (R0#1/R0#2)

Step #15 checks whether the diesel generators should be stopped. This scenario assumes that there was a loss of offsite power when the event started. Operators will try to restore offsite 77

Analysis 6 Spectrum of Rod Cluster Control Assembly Ejection Accidents On-Shift Staffing Analysis Report Revision 1 power to NB01 and NB02, but until that is successful, the emergency diesel generators will be kept running and loaded to their respective busses. (R0#2)

Step #16 has an operator locally reset and close the boric acid transfer pump breakers and the emergency borate valve breaker. (R0#1/NS0#5/NS0#6)

Step #17 has the operator close the non-class 1E battery charger breakers. (R0#2)

Step #18 involves checking for the availability of offsite power. The RNO path is to "try to restore offsite power using applicable SYS procedure(s)." One of the additional RNO sub-steps involves energizing the TSC diesel using procedure STN KAT-001, while this procedure continues. (R0#2/NS0#3)

Moving to procedure EMG ES-12 will happen at some point, but is based on the situation not the step being performed.

EMG ES-12: (CRS/R0#1)

In EMG ES-12, there is a cautionary warning that switchover to recirculation may cause high radiation in the Auxiliary Building. (NS0#5/RP#2)

Step #2 on the RNO path, has an operator locally open the CCW to RHR heat exchanger valves, if radiation levels permit. (NS0#5/RP#2)

Step #3, the RNO path, has an operator locally close the Fuel Building A & B SFP heat exchanger room valves, if radiation levels permit. (NS0#5/RP#2)

The EMG ES-12 scenario does not have local operations listed until Step #7. At that step, the RNO path for closing the RHR train hot leg recirculation values is to have an operator locally close the Aux Building RHR Train A&B hot leg recirculation valves, if radiation levels permit.

(NS0#5/RP#2)

Steps #7- #10, has RNO paths for an operator to locally manipulate, if radiation levels permit any or all of the following: (NS0#5/RP#2)

• Close both RHR Train Hot Leg Recirc Valves

• Isolate SI Pump Miniflow to RWST

• Align CCP and SI Pump Suctions to RHR Pump Discharge

• Isolate RWST from Charging and SI Step #11 checks if the Phase A and Phase B containment isolation and the containment sprays can be reset. The RNO path skips to Step #15, "Verify Flow Path from Sump to RCS." (R0#1)

Steps #12 - #16 do not have any local operator actions listed. The RNO path for step #15 assumes there aren't any flow paths from the containment sump at all, which would put the reactor into procedure EMG C-11, "Loss of Emergency Coolant Recirculation." Such an event is well beyond the design basis accident assessed here. (R0#1) 78

Analysis 6 Spectrum of Rod Cluster Control Assembly Ejection Accidents On-Shift Staffing Analysis Report Revision 1 Step #17 opens breakers for both CCP suction from RWST valves. (NS0#6)

Step #18 records time of fuel pool heat exchanger CCW isolation in control room log. There are no local operator actions. (R0#1)

Step #19 monitors ECCS leakage - normal. (R0#2/NS0#5)

Step #20 determines if transfer to hot leg recirc will be required. (CRS)'

Step #21 initiates refill of RWST. (R0#1/NS0#5)

Step #22 verifies ECCS pumps not affected by sump blockage. (R0#1)

Step #23 returns the operator to the procedure step in effect. (CRS) 79

Analysis 6 Spectrum of Rod Cluster Control Assembly Ejection Accidents On-Shift Staffing Analysis Report Revision 1 This OSA is applicable to Analysis # §. as identified in Appendix A (Spectrum of Rod Cluster Control Assembly Ejection)

TABLE 1 - On-shift Positions Augmentation Role in Unanalyzed TMS Line On-shift Position Emergency Plan Reference Elapsed Time (min) Table#/Line# Task? Required?

Shift Manager REMP, Figure 2, "Minimum Shift N/A T2/L 1 No No Staffing" & Attachment D, "WCGS T5/L 1 Minimum Staffing for Emergencies" T5/L2 T5/L3 1

T5/L4 T5/L5 T5/L8 T5/L 10 Shift Technical Advisor REMP, Figure 2, "Minimum Shift N/A T2/L3 No No Staffing" & Attachment D, "WCGS 2

Minimum Staffing for Emergencies" Control Room Supervisor REMP, Figure 2, "Minimum Shift N/A T2/L2 No No Staffing" & Attachment D, "WCGS 3

Minimum Staffing for Emergencies" Reactor Operator #1 REMP, Figure 2, "Minimum Shift N/A T2/L4 No No Staffing" & Attachment D, "WCGS 4

Minimum Staffing for Emergencies" 80

Analysis 6 Spectrum of Rod Cluster Control Assembly Ejection Accidents On-Shift Staffing Analysis Report Revision 1 This OSA is applicable to Analysis # §. as identified in Appendix A. (Spectrum of Rod Cluster Control Assembly Ejection)

TABLE 1 - On-shift Positions Augmentation Role in Unanalyzed TMS Line On-shift Position Emergency Plan Reference Elapsed Time (min) Table#/Line# Task? Required?

Reactor Operator #2 REMP, Figure 2, "Minimum Shift N/A T2/L5 No No Staffing" & Attachment D, "WCGS 5

Minimum Staffing for Emergencies" Nuclear Station Operator REMP, Figure 2, "Minimum Shift N/A T2/L6 No Yes*

1. 1/2 Staffing" & Attachment D, "WCGS T4/L7 Minimum Staffing for Emergencies" T4/L8 T5/L6 6 T5/L9 T5/L 11 T5/L 13*

T5/L 14 T5/L 15 Nuclear Station Operator #3 REMP, Figure 2, "Minimum Shift N/A T2/L7 No No Staffing" & Attachment D, "WCGS 7

Minimum Staffing for Emergencies" Nuclear Station Operator #5 REMP, Figure 2, "Minimum Shift N/A T2/L8 No No Staffing" & Attachment D, "WCGS 8

Minimum Staffing for Emergencies" 81

Analysis 6 Spectrum of Rod Cluster Control Assembly Ejection Accidents On-Shift Staffing Analysis Report Revision 1 This OSA is applicable to Analysis # §. as identified in Appendix A. (Spectrum of Rod Cluster Control Assembly Ejection)

TABLE 1 - On-shift Positions Augmentation Role in Unanalyzed TMS Line On-shift Position Emergency Plan Reference Elapsed Time (min) Table#/Line# Task? Required?

Nuclear Station Operator #6 REMP, Figure 2, "Minimum Shift N/A T2/L9 No No Staffing" & Attachment D, "WCGS 9

Minimum Staffing for Emergencies" Chemistry Technician REMP, Figure 2, "Minimum Shift 90 T4/L5* No No Staffing" & Attachment D, "WCGS 10 T4/L6 Minimum Staffing for Emergencies" Radiation Protection REMP, Figure 2, "Minimum Shift 90 T4/L3 No No Technician #1 Staffing" & Attachment D, "WCGS 11 Minimum Staffing for Emergencies" Radiation Protection REMP, Figure 2, "Minimum Shift 90 T4/L1 No No Technician #2 Staffing" & Attachment D, "WCGS 12 T4/L4 Minimum Staffing for Emergencies" Security REMP, Attachment D, "WCGS N/A T5/L 15 No No 13 Minimum Staffing for Emergencies"

• Based on functional analysis ENS commumcator required for continuous NRC commumcat1ons. This md1v1dual also fulfills the OSC commumcator role .

82

Analysis 6 Spectrum of Rod Cluster Control Assembly Ejection Accidents On-Shift Staffing Analysis Report Revision 1 TABLE 2 - Plant Operations & Safe Shutdown Analysis # §.

One Unit - One Control Room Minimum Operations Crew Necessary to Implement AOPs and EOPs, or SAMGs if applicable Task Analysis Line Generic Title/Role On-Shift Position Controlling Method 1 Shift Manager Shift Manager Operations Training 2 Unit Supervisor Control Room Supervisor Operations Training 3 Shift Technical Advisor Shift Technical Advisor Operations Training 4 Reactor Operator #1 Reactor Operator #1 Operations Training 5 Reactor Operator #2 Reactor Operator #2 Operations Training Auxiliary Operator #1/2 Nuclear Reactor Operator Operations Training 6

1. 1/2 Auxiliary Operator #3 Nuclear Reactor Operator Operations Training 7

1. 3 Auxiliary Operator #5 Nuclear Reactor Operator Operations Training 8

1. 5 Auxiliary Operator #6 Nuclear Reactor Operator Operations Training 9

1. 6 10 Other N/A N/A Other (non-Operations) Personnel Necessary to Implement AOPs and EOPs, or SAMGs if applicable Task Analysis Line Generic Title/Role On-Shift Position Controlling Method 11 Mechanic N/A N/A 12 Electrician N/A N/A 13 l&C Technician N/A N/A 14 Other N/A N/A 83

Analysis 6 Spectrum of Rod Cluster Control Assembly Ejection Accidents On-Shift Staffing Analysis Report Revision 1 TABLE 3 - Firefighting Analysis # §.

Task Analysis Line Performed By Controlling Method N/A - there is no fire associated with this N/A 1

event.

2 N/A N/A 3 N/A N/A 4 N/A N/A 5 N/A N/A 84

Analysis 6 Spectrum of Rod Cluster Control Assembly Ejection Accidents On-Shift Staffing Analysis Report Revision 1 TABLE 4- Radiation Protection & Chemistry & OSC/ENS Communicator Analysis#§ Performance Time Period After Erner 1ency Declaration (minutes)

Position Performing Line 0- 5- 10- 15- 20- 25- 30- 35 45 55 65- 70- 75- 80- 85-Function/Task 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 In-Plant Survey On-Shift Position:

RP Tech #1 1 X X X X X Main Steam Line Survey On-Site Survey N/A - The performance of an on-site survey is not necessary for initial implementation of the Emergency Plan and not 2 On-Shift Position required by any procedure.

Personnel Monitoring 3 On-Shift Position: X X X X X X X X X X X X X CR RP Tech #1 Job Coverage On-Shift Position:

RP Tech #2 4 X X X X X X X X X X X X X X X X X X As needed for NSO actions Offsite Radiological Assessment*

5 On-Shift Position: CR X X X X X X X X X X X X X X X X X X Chemistry Tech Chemistry function/task #1 -

N/A- No sampling required until the Technical Support Center is staffed per AP 15C-003 (on hold pending approval by 6 Sampling NRC).

On-Shift Position:

Chemistry Tech

• Dose assessment passes directly to the EOF, so this function is not relieved at 90 minutes.

85

Analysis 6 Spectrum of Rod Cluster Control Assembly Ejection Accidents On-Shift Staffing Analysis Report Revision 1 TABLE 4- Radiation Protection & Chemistry & OSC/ENS Communicator Analysis#§ Position Performance Time Period After Emergenc~ Declaration (minutes)

Line Performing 0- 5- 10- 15- 20-: 25- 30- 35- 40 50 60- 65- 70 80 Function/Task 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 OSC Communicator function/task-1- Initiate staffing of ERO 2- Emerg X X X X X X Notifications 7

3- Notify State /

County 4- Notify NRG SRI/

Westar X

5-ANI / INPO X ENS Communicator function/task-Continuous 8 X X X X X X X X X X communication with NRG 86

Analysis 6 Spectrum of Rod Cluster Control Assembly Ejection Accidents On-Shift Staffing Analysis Report Revision 1 TABLE 5 - Emergency Plan Implementation Analysis # §.

Task Analysis Line Function/Task On-Shift Position Controlling Method Declare the Emergency Shift Manager Operations Training and EP 1

Classification Level (ECL) Training/Drill Program Approve Offsite Protective Action Shift Manager Operations Training and EP 2

Recommendations Training/Drill Program Approve content of State/local Shift Manager Operations Training and EP 3

notifications Training/Drill Program Approve extension to allowable Shift Manager Operations Training and EP 4

dose limits Training/Drill Program Notification and direction to on- Shift Manager Operations Training and EP 5 shift staff (e.g., to assemble, Training/Drill Program evacuate, etc.)

ERO notification Table 4 - Nuclear Operations Training and EP 6 Station Operator #1 /2 Training/Drill Program Abbreviated NRC notification for N/A for this event N/A 7 DBT event Complete State/local notification Shift Manager Operations Training and EP 8 form Training/Drill Program Perform State/local notifications Table 4- Nuclear Operations Training and EP 9 Station Operator #1 /2 Training/Drill Program Complete NRC event notification Shift Manager Operations Training and EP 10 form Training/Drill Program Activate EROS Table 4- Nuclear Operations Training and EP 11 Station Operator #1 /2 Training/Drill Program Offsite radiological assessment NIA-Table 4- Chemistry Training and EP 12 Chemistry Tech Training/Drill Program Perform NRC notifications Table 4 - Nuclear Operations Training and EP 13 Station Operator #1 /2 Training/Drill Program Perform other site-specific event Table 4 - Nuclear Operations Training and EP 14 notifications (e.g., INPO, ANI, Station Operator #1 /2 Training/Drill Program etc.)

Personnel accountability Security/ Security Training and 15 Table 4 - Nuclear Operations Training and EP Station Operator #1 /2 Training/Drill Program 87

Analysis 7 Steam Generator Tube Failure On-Shift Staffing Analysis Report Revision 1 Event Narrative #7 Steam Generator Tube Failure This is one of the Design-Basis Condition IV Limiting Fault events as listed in the USAR, § 15.0.1.4, "Condition IV - Limiting Faults." USAR § 15.6.3.1.1, "Identification of Causes and Accident Description," states:

The accident examined is the complete severance of a single steam generator tube. The accident is assumed to take place at power with the reactor coolant contaminated with

• fission products corresponding to continuous operation with a limited number of defective fuel rods. The accident leads to an increase in the contamination of the secondary system due to the leakage of radioactive coolant from the RCS. Loss of off-site power is assumed to occur coincident with reactor trip. Discharge of activity to the atmosphere takes place via the steam generator safety and/or atmospheric relief valves.

Following the occurrence of the SG tube rupture, the primary to secondary leakage causes the pressurizer level and the RCS pressure to decrease. As the RCS pressure continues to decrease, automatic reactor trip occurs on low pressurizer pressure or over-temperature delta-T (OT.t:. T) signal. Because of the assumed loss of offsite power, the steam dump system will not be available, and the secondary side pressure increases rapidly after reactor trip until the steam generator ARVs and/or SV lift to dissipate the energy. After reactor trip, the RCS pressure continues to decrease and the safety injection is automatically initiated on low pressurizer pressure signal. Due to the assumed loss of offsite power at the reactor trip, normal feedwater flow is terminated and the AFW is initiated.

The analysis assumes failure of the AFW control valve on the discharge side of the motor-driven AFW pump feeding the ruptured steam generator. It is assumed that this valve fails in the wide-open position to maximize the flow to the ruptured steam generator. Failure of this valve coupled with the contribution from the turbine-driven AFW pump has a greater potential for overfilling the ruptured steam generator.

A detailed discussion of possible accidents in this category, analytical methods used and consequences assessed can be found in USAR § 15.6.3, "Steam Generator Tube Rupture (SGTR)," and are diagrammed in USAR Figure 15.0-24, "Steam Generator Tube Rupture":

The steam generator tube rupture (SGTR) examined is the complete severance of one single steam generator tube which results in the leakage of reactor coolant into the secondary side of the steam generator. The consequences of SGTR depend largely upon the ability of the operator to take the necessary actions to terminate the primary to secondary leakage. If the leakage continues for an extended period of time, the secondary side of the steam generator may become filled and water may enter the steam line. As a result, the release of liquid through the secondary side safety/relief valves to the atmosphere may occur that could result in an increase in the radiological doses.

88

Analysis 7 Steam Generator Tube Failure On-Shift Staffing Analysis Report Revision 1 The overfill SGTR scenario assumes failures in the auxiliary feedwater (AFW) system such that if operators do not respond quickly enough to terminate feedwater, then the affected steam line may fill with water. The specific failure involves the control valve on the discharge side of the motor driven feedwater pump feeding the faulted steam generator. To maximize flow to the faulted steam generator, it is assumed that this valve fails in the wide-open position. Failure of this valve, coupled with the contribution from the turbine driven AFW pump, has the potential for overfilling the faulted steam generator and subsequently, relieve water via a safety valve. The radionuclide releases are maximized by assuming the safety valve is stuck-open following water relief, with an effective flow area equal to 5% of the total safety valve flow area.

It has been determined that the most severe radiological consequences will result from the forced steam generator overfill scenario with a stuck-open safety valve.

Document APF 06-002-01, Emergency Action Levels, identifies the above as EAL-2 I BASES-2, SGTF5 (the steam generator with a tube rupture is also faulted). This classifies the event as a General Emergency.

The USAR § 15.6.3.1.2, "Assumptions and Conditions," states:

It is important to note that only steam is released from the ruptured steam generator, prior to steam generator overfill. However, affer overfill occurs, the releases from the ruptured steam generator may be water and/or steam depending upon the conditions in the steam generator. Affer the water and steam mixture is discharged through the safety valves, a consequential failure of the safety valve was assumed. With a failed-open safety valve on the ruptured steam generator, the ruptured steam generator will continue to depressurize (Figure 15. 6-3d). Thus, primary and secondary pressure equalization can not be achieved, and the primary to secondary leakage and release to the atmosphere will continue until cold shutdown conditions are reached.

USAR § 15.6.3.3.1.2, "Assumptions and Limitations," models the radiological source term given the following:

• The analysis yields 195,371 pounds of reactor coolant transferred to the secondary side of the faulted steam generator.

• It is assumed that all of the iodine in the fraction of reactor coolant that flashes to steam upon reaching the secondary side is released to the steam phase. No credit is taken for scrubbing.

• A 1-gpm primary-to-secondary leak is assumed to occur to the unaffected steam generators, through the accident sequence.

• All noble gas activity in the reactor coolant that is transported to the secondary system via the tube rupture and the primary-to-secondary leakage is released to the atmosphere.

• The iodine partition fraction between the liquid and steam in the steam generator is assumed to be 0.01.

89

Analysis 7 Steam Generator Tube Failure On-Shift Staffing Analysis Report Revision 1 The sequence of events for this accident are summarized in USAR Table 15.6-1, "Time Sequence of Events for Incident Which Results in a Decrease in Reactor Coolant Inventory,"

using the section labeled "Steam generator tube rupture: Failed-open auxiliary feedwater control valve and safety valve."

The system status and radiological inventory of this accident are listed in USAR Table 15.6-4, "Parameters Used in Evaluating the Radiological Consequences of a Steam Generator Tube Rupture with Forced Overfill." The offsite radiological consequences are summarized in USAR Table 15.6-5, "Radiological Consequences of a Steam Generator Tube Rupture." The projected thyroid dose at the site boundary was 51,769 millirem. This is high enough to classify the accident under EAL-1 / BASES-1, "Radioactive Effluent Release," RER4, (Valid dose assessment indicates a dose greater than 1000 mR TEDE or 5000 mR thyroid (CDE) at the Site boundary). This is an additional path that classifies the accident as a General Emergency.

USAR § 15.6.3.2.2, "Analysis of Effects and Consequences," describes the sequence:

Reactor trip occurs automatically as a result of low pressurizer pressure or over temperature Delta T. Loss of offsite power occurs at reactor trip.

For this assessment procedure EMG E-0, "Reactor Trip or Safety Injection," was the entry point for operator actions. USAR Figures 15.6-3A, "Pressurizer Pressure Transient SGTR Forced Overfill with Stuck-Open Steam Generator Safety Valve," through 15.6-3J, "Faulted Steam Generator Mixture Volume Transient SGTR Forced Overfill with Stuck-Open Steam Generator Safety Valve," help inform the sequence of events that follow.

EMG E-0:

As noted in a CAUTION box near the beginning of EMG E-0, "Abnormal conditions can cause higher than normal radiation levels. Health Physics monitoring may be required while performing local operator actions."

The reactor has tripped and one steam generator has both a tube rupture and a fault. EMG E-0, follows the "normal path" through step #6 (the emergency diesel generators started without incident).

Normally, fold-out page Step #4 would isolate feed flow by this point. (R0#1)

Step #6 jumps to Attachment F, "Automatic Signal Verification," to ensure feedwater isolation has occurred. This step, as noted in the basis document, addresses the problem that: (R0#1)

The main feedwater system is isolated on a feedwater isolation signal to prevent uncontrolled filling of any SIG and the associated excessive RCS coo/down, which could aggravate the transient, especially if it were a.steamline break. The SIG b/owdown and sample valves close on an SI signal but are included in the verification of feedwater isolation in order that they may be checked at this time.

In this case, the scenario specifically involves uncontrolled filling of a faulted SIG.

90

Analysis 7 Steam Generator Tube Failure On-Shift Staffing Analysis Report Revision 1 For any local operator actions called out in Attachment F, see specifically:

• F1, "Verifying Feedwater Isolation", the RNO path and actions in Attachment A, "Valves Closed by SIG Slowdown and Sample Isolation Signal." (NS0#6)

• F2, "Verifying Containment Isolation", the RNO path and actions in Attachment B, "Valves Closed by Containment Isolation Signal Phase A." (NS0#5)

• F8, "Verify Containment Purge Isolation", the RNO path and actions in Attachment C, "Valves Closed by Containment Purge Isolation Signal." (NS0#5)

• F10, "Verify Main Steamline Isolation Not Required", the RNO path and actions in Attachment D, "Valves Closed by Steamline Isolation Signal." (NS0#6)

• F11, "Verify Containment Spray Not Required", the RNO path and actions in Attachment E, "Valves Closed by Containment Isolation Signal Phase B." (NS0#5)

Step #8 has a check for total AFW flow> 270,000 lbm/hr. The RNO path for this event involves manual operations and jumps to procedures needed if this event was more serious than the scenario assessed here. (R0#2)

Steps #9 and #10 checks RCS cold leg temperatures and establish steam generator (SG) pressure control. There are no specific instructions requiring local operator actions. (R0#2)

For steps #11 - #13, the normal path is followed. USAR Figure 15.1-22, "Pressurizer Pressure and Pressurizer Liquid Volume SLB Without Offsite Power," shows a rapid drop in volume for the first 20 seconds and a rapid drop in pressure for the first 60 seconds, stabilizing at an RCS pressure of approximately 1050 psia and a liquid volume less than 30 ft 3 . As noted above, a pressurizer valve failure is outside the scope of this event. (R0#2)

Step #14 follows the normal path. The reactor coolant pumps tripped when the reactor tripped.

(R0#2)

Step #15 directs an operator to monitor critical safety functions using procedure EMG F-0, "Critical Safety Function Status Trees," while continuing with this procedure. (STA)

Step #16 checks to see if "S/Gs Are Not Faulted." The RNO path (which reflects this narrative) sends the operator to procedure EMG E-2, "Faulted Steam Generator Isolation," step #1.

(R0#2)

EMG E-2:

Step #1 has the operator check to see if the steam lines on all S/G's are isolated. This involves ensuring the main steam line valves, bypass valves and low point drain valves are closed. The RNO path has manual operations, but no local operations were identified. (R0#2)

Step #2 has the operator check to see if limitations for fault in Area 5 are required (which will depend on where the break is located). The procedure adds a warning to local operators in the affected area. (R0#2/NS0#6)

Step #3 checks to see if any S/G's are not faulted. Based on the scenario for this event, S/Gs that are not connected to the broken main steam line are not faulted. (R0#2) 91

Analysis 7 Steam Generator Tube Failure On-Shift Staffing Analysis Report Revision 1 Step #4 identifies S/G's that are faulted. The normal path has "any S/G pressures decreasing in an uncontrolled manner" OR "any S/G completely depressurized", which is consistent with USAR Figures 15.1-25 and 15.1-26. (R0#2)

Step #5 isolates the faulted S/G's. The normal path involves closing the AFW flow controls to the faulted S/Gs. The RNO path has an operator locally isolate the affected lines. The Turbine Driven AFW pump always has the steam supply line locally closed by the operator. The SIG atmospheric relief valves (ARVs) on the faulted S/Gs are checked closed, and the RNO path has an operator locally isolate the affected SIG ARVs. (R0#2/NS0#5/NS0#6)

Step #6 addresses isolating feedwater lines. The RNO path for this section involves manual closure of valves. If manual closure of valves also fails, then a subsequent RNO path has a dispatch operator isolate valves locally. The valves in question are the main feedwater reg valves, the main feedwater reg bypass valves and the main feedwater chemical injection valves.

(R0#2/NS0#5)

Step #7 covers isolation of blowdown and sampling lines. There is an RNO path to locally isolate the affected blowdown and/or sampling line(s) for the affected S/G's. (R0#2)

Step #8 discusses situations where the pressurizer PORV opens due to high pressure. For the event described, the RCS pressure drops with the cooldown and the pressurizer empties 18 seconds into the event (see USAR Table 15.1-1, sheet #2, as described above). The event follows the normal path. (R0#1)

Step #9 discusses continued uncontrolled cooldown. The core inlet temperature for the intact loops and the core average temperature start to stabilize after the first 30 seconds of the event.

See USAR Figure 15.1-23, "Core Inlet Temperature and Core Average Temperature SLB Without Offsite Power. The normal path is followed, based on the accident description.

(R0#2)

Step #10 has specific extreme caution statements regarding performing local surveys if the steam lines in Area 5 of the aux building are not intact, if there is a need to establish a sampling capability to determine secondary radiation levels. Health physics is directed to locally survey the steam lines in this area. Chemistry is directed to sample all S/G's for activity. In this case, per the scenario, no steam generator tubes are ruptured. (R0#2/RP#2/CH)

The basis document comments:

Since it may be difficult to sample a depressurized steam generator for activity, the operator should suspect a rupture if the steam generator does not dry out following isolation of feed to it. A faulted, ruptured steam generator will stay at some low pressure and continue to cool that loop and the RCS. In addition, the operator should suspect a rupture if there is no indication of a RCS leak to containment. If the operator suspects that a faulted steam generator is not drying out and cannot confirm that it is ruptured by sampling because a sample cannot be drawn, a couple of options exist. A check for radiation in the area of the break (if it is outside the containment) to confirm that a rupture exists may be performed or the conclusion that the faulted generator is ruptured 92

Analysis 7 Steam Generator Tube Failure On-Shift Staffing Analysis Report Revision 1 if it is not practical to check for radiation based on response of the faulted steam generator or the response of the RCS may be made.

Step #11, on the RNO path, involves using an operator to locally open the ESW A or B to air compressor, to insure instrument air compressors are available to supply air to instruments and to restore instrument air to the containment. (R0#2INS0#5)

Step #12 checks for intact SIG tubes. Based on the scenario, the SIG tubes are intact and the operator follows the normal path. (R0#2/RP#2ICH)

EMG E-3:

Step #1 's (Loss of offsite power, RCPs are already tripped) RNO path assumes a small-break LOCA with a delayed reactor trip (see the basis document for more details). This scenario assumes the reactor has already tripped, as described earlier (see USAR Figures 15.0-24 and 15.6-3A). (R0#1)

Step #2 involves identifying ruptured S/Gs. The steam line surveys and/or SIG chemistry samples conducted on either the normal or RNO paths are assumed to have already been started, based on EMG E-2, step #10, above. (R0#2)

Step #3 involves isolating the flow from ruptured S/Gs. The SIG ARV is assumed not closable, since liquids are venting from the valve. The RNO path for locally isolating the ARV is followed.

The remainder of the sub-steps on the normal path have local actions to close the steam supply to the turbine driven AFW pump and local isolation of the main steam line low point drain valve from ruptured S/Gs. However, these steps are assumed to have already been started during EMG E-2, steps #5 through #7, above. (R0#2/NS0#5)

Step #4 has an RNO path for local isolation of affected blowdown or sample lines. Again, these steps are assumed to have already been started during EMG E-2, steps #5 through #7, above.

(R0#2/ NS0#5)

Step #5 has a potential RNO path for local isolation of the main steam header. (R0#2)

Step #6 has no local actions. (R0#2)

Step #7 has an RNO path to locally isolate the AFW flow control valves for the Motor-Driven and Turbine-Driven AFW pumps from a ruptured SIG. (R0#2/NS0#6)

Step #8 has no local actions. (R0#2)

Step #9 checks the ruptured S/G's pressure >380 psig since the scenario assumes the TDAFW pump is not stopped in a timely manner and is over-filling the ruptured SIG and should follow normal path. (R0#2)

• Step #10 checks if low steam line pressure SI should be stopped. It is assumed to follow the normal path, given the pressure diagram in USAR Figure 15.6-30, "Steam Generator Pressure Transients SGTR Forced Overfill with Stuck-Open Steam Generator Safety Valve". (R0#1) 93

Analysis 7 Steam Generator Tube Failure On-Shift Staffing Analysis Report Revision 1 Step #11 (Determine Target Plant Conditions from Table Below). USAR Figure 15.6-3D shows the lowest SIG Pressure for the ruptured SIG drops to about 750 psia at about 1400 seconds into the event. (R0#2)

Step #12 determines the method used to cooldown at maximum rate. (R0#2)

Step #13 follows the RNO path, since the loss of offsite power means the steam dumps are not available. This path bypasses step #14 and goes to step #15. (The basis document also provides a clarifying historical reference to the Ginna 1982 event). (R0#2)

Step #15 follows the normal path, since this scenario assumes only one SIG is ruptured and faulted. The other S/Gs are intact. This event does not have ARVs "failing open" for any SIG except for the ruptured/faulted one. This scenario also assumes the remaining SIG ARVs are still controllable by the operators. (R0#2)

Steps #16 and #17 follow the normal path. Any additional pressurizer problems would be outside the scope of this event. (R0#1)

Steps #18 and #19 cover scenarios where offsite power is lost after SI has reset. This scenario, in contrast, assumes that offsite power was lost at the beginning of the event. (R0#1)

Step #20 on the RNO path involves using an operator to locally manipulate the ESW A or B to air compressor valves. Circuit breakers are reset to insure instrument air compressors are available to supply air to instruments and to restore instrument air to the containment. An operator may be dispatched to locally reset alarms and restart air compressors as needed.

(R0#1/NS0#5/NS0#6)

Step #21 on the RNO path has an operator locally open the instrumentation air supply containment isolation valve. (R0#1/NS0#5)

Steps #22 checks if RHR pumps should be stopped and has no local operations. (R0#1)

Step #23 has no local operations and provides a "hold point" to complete the cool-down of the RCS before continuing with RCS decompression. USAR Figure 15.6-3E, "Steam Generator Temperature Transients SGTR Forced Overfill with Stuck-Open Steam Generator Safety Valve" shows the RCS starting its cool-down at about 2000 seconds and completing the cool-down a few hundred seconds later. Control is maintained using the intact S/G's ARVs and/or the turbine-driven AFW pump. (R0#2) 94

Analysis 7 Steam Generator Tube Failure On-Shift Staffing Analysis Report Revision 1 Step #24 checks the pressure behavior of the ruptured SIG. (R0#2) USAR Figure 15.6-3D shows the ruptured SIG pressure falling below the intact SIG pressures almost immediately after reactor trip, and staying below for the first 1200 seconds. Once the aux feedwater is terminated to the ruptured SIG, the steam pressure in the ruptured SIG rises steadily until 3000 seconds into the event. Pressure reaches levels near those that occurred during the initial reactor trip. At approximately 3000 seconds, water relief occurs and the pressure starts dropping thereafter. This series of events sends the operator down the RNO path and jumps to procedure EMG C-31, "SGTR with Loss of Reactor Coolant- Subcooled Recovery Desired".

See the basis document and USAR § 15.6.3.1.1, "Identification of Cause and Accident Description", item (g), for more details.

EMG C-31:

Steps #1 through #4 are assumed to have been conducted during the earlier procedures and follow the normal path.

Step #4 is a check on availability of offsite power to the NB01 and NB02 busses. The scenario assumes loss of offsite power at the beginning of the event, so the RNO path is followed. For this scenario, it's assumed the EDGs have started and loaded up properly. (If there was a loss of both onsite and offsite power, that event would be covered in the Station Blackout (SBO) narrative, which is beyond the scope of this scenario). (R0#2)

Step #5 involves de-energizing the pressurizer heaters and has no local operations. (R0#1)

Step #6 de-energizes the PZR heaters. (R0#11STA)

Step #7 has an operator perform a local reset and closure of the boric acid transfer pump and emergency borate valve breakers. This ensures boration capability is available for the RCS cool-down. (R0#2/NS0#5/NS0#6)

Steps #8 and #9 reenergize equipment and close breakers. These steps have no local operations. (R0#2)

Step #10 involves checking availability of offsite power. The RNO path is to "try to restore offsite power using applicable SYS procedure(s)". One of the additional RNO sub-steps involves energizing the TSC diesel using procedure STN KAT-001, while this procedure continues. (R0#2/ NS0#3)

STN KA T-001:

Operator locally performs the prerequisite checks listed in§ 7, "Prerequisites.".,. (NS0#3)

Operator locally performs § 8.1.1, 'Testing Installed TSC Diesel Generator" OR§ 8.2.1, "Testing Temporary TSC Diesel Generator." (NS0#3)

Operator locally performs § 8.1.2, "Placing TSC Diesel Generator In-service" OR § 8.2.2, "Placing Temporary TSC Diesel Generator In-service." (NS0#3) 95

Analysis 7 Steam Generator Tube Failure On-Shift Staffing Analysis Report Revision 1 Note that if the TSC Diesel Generator runs for more than an hour, refer to Attachment B, "TSC Diesel Generator Reading," or if applicable, Attachment C, 'TSC Temporary Diesel Generator Readings," for hourly checks on the diesel generator in question. (NS0#3)

EMG C-31 (continued):

Step #11 involves checking the status of the containment sprays, which are not expected to be operating (or need to), given the details of the scenario. The RNO path moves to step #12.

(R0#1)

Step #12 checks for the level of a ruptured S/G. Given the scenario and USAR Figure 15.6-3J, "Faulted Steam Generator Mixture Volume Transient SGTR Forced Overfill with Stuck-Open Steam Generator Safety Valve," the secondary side has a forced overfill. The RNO path step

1. 12(a) goes directly to the normal path step #12(c), to stop feeding the ruptured and faulted SIG. Cool-down will continue with the intact S/Gs. (R0#2)

As noted in USAR § 15.6.3.1.2:

Eighteen minutes following the initiation of the safety injection signal, the AFW from the motor-driven AFW pump to the ruptured steam generator is terminated by locally closing the failed AL-HV valve. AFWflow to the intact steam generators maintains the narrow range level between 6% and 50% as indicated in the Emergency Operating Procedure EMG E-3.

Step #13 follows the RNO path, as the RCS is expected to depressurize. Go to step #14.

(R0#1)

Step #14 aligns CCW sampling systems. (R0#2)

EMG C-31 (continued):

Step #15 places the hydrogen analyzers in service. This step has no local actions. (R0#2)

Step #16 checks the radiation levels in the Fuel and Auxiliary buildings. Radiation protection is directed to survey fuel and auxiliary buildings with priority being pipe penetration areas and piping tunnels. Some of these surveys were expected to have been previously addressed in EMG E-2, step #10. (R0#2IRP#2)

Step #17 has chemistry check the boron and activity levels at the following locations: RCS, PZR Liquid Space and Steam Generators. The S/G activity checks were expected to have been previously addressed in EMG E-2, step #10. (CHIRP#2IR0#1)

Step #18 is a check on plant status and has no local actions. (CRS)

Step #19 checks pressure on all S/Gs to see if any still have an uncontrolled pressure decrease.

For this scenario, it's assumed that the actions started in EMG E-2 have successfully isolated the ruptured and faulted S/G. The operator stays on the normal path. (R0#2) 96

Analysis 7 Steam Generator Tube Failure On-Shift Staffing Analysis Report Revision 1 Step #20 checks on the water levels and feed flows for the intact S/Gs. The intact S/Gs are under control. The only S/G overfill occurred with the ruptured and faulted S/G, which has been isolated. The operator stays on the normal path. (R0#2)

Step #21 checks if condenser air removal should be returned to normal. The scenario assumes a loss of offsite power at the beginning of the event, so the condensers were never available.

The operator follows the RNO path and goes to step #22. (R0#2)

Step #22 checks if low steamline pressure SI should be blocked. (R0#1)

Step #23 initiates RCS cooldown to cold shutdown. Given the loss of offsite power, cooldown will be through the atmospheric relief valves rather than by the condenser. See USAR § 15.6.3.1.2, "Analysis of Effects and Consequences," item (g), for more details. At step 22(d),

the RNO path is followed. (R0#2)

Steps #24 and #25 check the appropriateness and adequateness of subcooled recovery. No additional uncontrolled pathways for losing RCS inventory are identified in this scenario. The normal path is followed. (R0#1)

Step #26 checks whether safety injection pumps are running. Per USAR Table 15.6-1, they have been running since 219 seconds into the event. The normal path is followed. (R0#2)

Step #27 initiates RCS depressurization to refill the pressurizer. Per USAR Figure 15.6-3F, "Pressurizer Water Level Transient SGTR Forced Overfill with Stuck-Open Steam Generator Safety Valve," the water level is at 20 ft when RCS cooldown is initiated and is at approximately 14 ft at the end of RCS cooldown. The operator follows the RNO path and goes to step #27.

(R0#1)

Step #28 checks operability of the RCPs. There is no offsite power, so the RCPs are not available. The operator follows the RNO path and goes to step #31. (R0#2)

Step #31 checks to see if one CCP should be stopped. Per USAR Figure 15.6-3F and USAR Table 15.6-1, the steps to terminate safety injection (except for one CCP left running) occur within 3334 seconds of the start of the event. Per USAR Figure 15.6-3C, "Intact Loop RCS Temperature Transients SGTR Forced Overfill with Stuck-Open Steam Generator Safety Valve," the hot leg temperature is greater than 480 °F and the cold leg is approximately 440°F at this point. (R0#1)

Step #32 checks to see if SI pumps should be stopped. Pressurizer level is recovering, per USAR Figure 15.6:-3F. The normal path is followed. (R0#2)

Once the pressurizer level has recovered to greater than 23%, one SI pump is stopped. Again, this will happen 3334 seconds into the event. The operator loops to the beginning of this step and continues checking RCS sub-cooling vs. SI pump status until all SI pumps have been stopped. Then the RNO path is followed and the operator goes to step #32.

97

Analysis 7 Steam Generator Tube Failure On-Shift Staffing Analysis Report Revision 1 Step #33 checks to see if normal charging should be established. Per Figure 15.6-3F, all but one of the CCP pumps are stopped. The RCPs are not running, given the loss of offsite power.

The pressurizer level is recovering. (R0#1)

EMG C-32, may be entered if the Control room staff feels that they do not have enough RWST/SG inventory available to do the controlled coo/down during recovery.

EMG C-32:

Step #1 evaluates the RWST level to determine if level is adequate for cooldown rates required.

(R0#1)

Step #2 checks the ruptured SIG level to ensure adequate water levels to secure feeding the generator. (R0#2)

Step #3 checks if RHR pumps should be stopped. (R0#2)

Step #4 checks if SIG(s) are not faulted to allow any faulted generators to be isolated prior to recovery.. (R0#2)

Step #5 checks intact SIG levels to ensure adequate heat sing for cooldown. (R0#2)

Step #6 checks if the low steam line pressure SI should be blocked. (R0#1)

Step #7 initiates RCS cooldown to cold shutdown at a rate of 1OOFlhr using RHR/Dumping steam from Intact ARVs. (R0#2)

Step #8 checks RCS subcooling greater than 30 degrees F. (R0#2)

Step #9 checks if any of the following conditions are satisfied - any SI pumps running or BIT not isolated or RHR pumps running in SI mode. (R0#2)

Step #10 depressurizes RSC to refill the PZR. (R0#1)

Step #11 checks if RCP(s) should be started. If RCP(s) are all stopped, then skip to step #14.

(R0#2)

Step #14 checks if one CCP should be stopped if RCS subcooling temperature is greater than required subcooling. (R0#1)

Step #15 checks if SI pumps should be stopped if RCS subcooling temperature is greater than required subcooling. (R0#2)

Step #16 checks if normal charging should be established. (R0#1)

Step #17 and step #18 verify CCW to service loop and to containment. (R0#2)

Step #19 verifies RCP thermal barrier cooling. (R0#2) 98

Analysis 7 Steam Generator Tube Failure On-Shift Staffing Analysis Report Revision 1 Step #20 aligns CCPs for normal charging. (R0#1)

Step #21 aligns the charging system. (R0#1)

Step #22 isolates the BIT. (R0#2)

Termination path (expected actions are beyond the first 90 minutes of the event):

The CCP flow is throttled back to 100 gpm per USAR Table 15.6-1, 3933 seconds into the event. The closing actions to this event, as described in USAR § 15.6.3.1.2, accomplish the following:

Following termination of the RCS coo/down, the RCS is depressurized by opening a pressurizer PORV to assure an adequate coolant inventory prior to terminating SI flow.

Primary depressurization is initiated at 8 minutes following the termination of the RCS coo/down and continues until the RCS pressure is less than the ruptured steam generator pressure.

Following the depressurization, termination of SI is delayed to ensure enough liquid enters the ruptured steam generator steam line to force the safety valve open and cause water relief It is assumed that 5 minutes following the termination of the RCS depressurization that the safety injection flow is reduced to just one centrifugal charging pump. At 15 minutes following the termination of the RCS depressurization, the one CCP is throttled back to 100 gpm and at 30 minutes following termination, letdown is initiated such that the net flow due to SI and letdown depressurization is zero.

99

Analysis 7 Steam Generator Tube Failure On-Shift Staffing Analysis Report Revision 1 This OSA is applicable to Analysis# I as identified in Appendix A. (Steam Generator Tube Failure)

TABLE 1 - On-shift Positions Augmentation Role in Unanalyzed TMS Line On-shift Position Emergency Plan Reference Elapsed Time (min) Table#/Line# Task? Required?

Shift Manager REMP, Figure 2, "Minimum Shift N/A T2/L 1 No No Staffing" & Attachment D, "WCGS T5/L 1 Minimum Staffing for Emergencies" T5/L2 T5/L3 1

T5/L4 T5/L5 T5/L8 T5/L 10 Shift Technical Advisor REMP, Figure 2, "Minimum Shift N/A T2/L3 No No Staffing" & Attachment D, "WCGS 2

Minimum Staffing for Emergencies" Control Room Supervisor REMP, Figure 2, "Minimum Shift N/A T2/L2 No No Staffing" & Attachment D, "WCGS 3

Minimum Staffing for Emergencies" Reactor Operator #1 REMP, Figure 2, "Minimum Shift N/A T2/L4 No No Staffing" & Attachment D, "WCGS 4

Minimum Staffing for Emergencies" 100

Analysis 7 Steam Generator Tube Failure On-Shift Staffing Analysis Report Revision 1 This OSA is applicable to Analysis# zas identified in Appendix A. (Steam Generator Tube Failure)

TABLE 1 -On-shift Positions Augmentation Role in Unanalyzed TMS Line On-shift Position Emergency Plan Reference Elapsed Time (min) Table#/Line# Task? Required?

Reactor Operator #2 REMP, Figure 2, "Minimum Shift N/A T2/L5 No No Staffing" & Attachment D, "WCGS 5

Minimum Staffing for Emergencies" Nuclear Station Operator REMP, Figure 2, "Minimum Shift N/A T2/L6 No Yes*

1. 1/2 Staffing" & Attachment D, "WCGS T4/L7 Minimum Staffing for Emergencies" T4/L8 T5/L6 6 T5/L9 T5/L 11 T5/L 13*

T5/L 14 T5/L 15 Nuclear Station Operator #3 REMP, Figure 2, "Minimum Shift N/A T2/L7 No No Staffing" & Attachment D, "WCGS 8

Minimum Staffing for Emergencies" Nuclear Station Operator #5 REMP, Figure 2, "Minimum Shift N/A T2/L8 No No Staffing" & Attachment D, "WCGS 9

Minimum Staffing for Emergencies" 101

Analysis 7 Steam Generator Tube Failure On-Shift Staffing Analysis Report Revision 1 This OSA is applicable to Analysis# zas identified in Appendix A. (Steam Generator Tube Failure)

TABLE 1 - On-shift Positions Augmentation Role in Unanalyzed TMS Line On-shift Position Emergency Plan Reference Elapsed Time (min) Table#/Line# Task? Required?

Nuclear Station Operator #6 REMP, Figure 2, "Minimum Shift N/A T2/L9 No No Staffing" & Attachment D, "WCGS 10 Minimum Staffing for Emergencies" Chemistry Technician REMP, Figure 2, "Minimum Shift 90 T4/L5* No No Staffing" & Attachment D, "WCGS 11 T4/L6 Minimum Staffing for Emergencies" Radiation Protection REMP, Figure 2, "Minimum Shift 90 T4/L3 No No Technician #1 Staffing" & Attachment D, "WCGS 12 Minimum Staffing for Emergencies" Radiation Protection REMP, Figure 2, "Minimum Shift 90 T4/L 1 No No Technician #2 Staffing" & Attachment D, "WCGS 13 T4/L4 Minimum Staffing for Emergencies" Security REMP, Attachment D, "WCGS N/A T5/L 15 No No 14 Minimum Staffing for Emergencies"

• Based on functional analysis ENS communicator required for continuous NRC communications. This individual also fulfills the OSC communicator role.

102

Analysis 7 Steam Generator Tube Failure On-Shift Staffing Analysis Report

. Revision 1 TABLE 2 - Plant Operations & Safe Shutdown Analysis# I One Unit - One Control Room Minimum Operations Crew Necessary to Implement AOPs and EOPs, or SAMGs if applicable Task Analysis Line Generic Title/Role On-Shift Position Controlling Method 1 Shift Manager Shift Manager Operations Training 2 Unit Supervisor Control Room Supervisor Operations Training 3 Shift Technical Advisor Shift Technical Advisor Operations Training 4 Reactor Operator #1 Reactor Operator #1 Operations Training 5 Reactor Operator #2 Reactor Operator #2 Operations Training Auxiliary Operator #1/2 Nuclear Station Operator Operations Training 6

1. 1/2 Auxiliary Operator #3 Nuclear Station Operator #3 Operations Training 7

(Site)

Auxiliary Operator #5 Nuclear Station Operator #5 Operations Training 8

(Aux)

Auxiliary Operator #6 Nuclear Station Operator #6 Operations Training 9

(TB)

Other (non-Operations) Personnel Necessary to Implement AOPs and EOPs, or SAMGs if applicable Task Analysis Line Generic Title/Role On-Shift Position Controlling Method 10 Mechanic N/A N/A 11 Electrician N/A N/A 12 l&C Technician N/A N/A 13 Other N/A N/A 103

Analysis 7 Steam Generator Tube Failure On-Shift Staffing Analysis Report Revision 1 TABLE 3 - Firefighting Analysis# I Task Analysis Line Performed By Controlling Method N/A - there is no fire associated with this NIA 1

event.

2 N/A N/A 3 N/A N/A 4 N/A N/A 5 N/A N/A 104

Analysis 7 Steam Generator Tube Failure On-Shift Staffing Analysis Report Revision 1 TABLE 4 - Radiation Protection & Chemistry & OSC/ENS Communicators Analysis #Z Position Performance Time Period After Emeraencv Declaration (minutes)

Line Performing 0- 5- 10- 15- 20 30 40- 45 55- 60- 65- 70- 75- 80- 85-Function/Task 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 In-Plant Survey On-Shift Position:

RP Tech #1 1 X X X X X Main Steam Line Survey On-Site Survey N/A - The performance of an on-site survey is not necessary for initial implementation of the Emergency Plan and not 2 On-Shift Position required by any procedure.

Personnel Monitoring 3 On-Shift Position: X X X X X X X X X X X X X CR RP Tech #1 Job Coverage On-Shift Position:

RP Tech #2 4 X X X X X X X X X X X X X X X X X X As needed for NSO actions Offsite Radiological Assessment*

5 On-Shift Position: X X X X X X X X X X X X X X X X X X CR Chemistry Tech Chemistry function/task #1 -

N/A- No sampling required until the Technical Support Center is staffed per AP 15C-003 (on hold pending approval 6 Sampling by NRG).

On-Shift Position:

Chemistry Tech

• Dose assessment passes directly to the EOF, so this function is not relieved at 90 minutes.

105

Analysis 7 Steam Generator Tube Failure On-Shift Staffing Analysis Report Revision 1 TABLE 4- Radiation Protection & Chemistry & OSC/ENS Communicators Analysis# I Position Performance Time Period After Emeraencv Declaration (minutes}

Line Performing 0- 5- 10- 15 25 35- 40- 45- 50 60- 65- 70- 75 85-Function/Task 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 osc Communicator function/task-1- Initiate staffing of ERO 2- Emerg X X X X X X 7 Notifications 3- Notify State/

County 4- Notify NRC SRI X

/Westar 5-ANI / INPO X ENS Communicator function/task-8 Continuous X X X X X X X X X X communication with NRC 106

Analysis 7 Steam Generator Tube Failure On-Shift Staffing Analysis Report Revision 1 TABLE 5 - Emergency Plan Implementation Analysis #I Task Analysis Line Function/Task On-Shift Position Controlling Method Declare the Emergency Shift Manager Operations Training and EP 1

Classification Level (ECL) Training/Drill Program Approve Offsite Protective Action Shift Manager Operations Training and EP 2

Recommendations Training/Drill Program*

Approve content of State/local Shift Manager Operations Training and EP 3

notifications Training/Drill Program Approve extension to allowable Shift Manager Operations Training and EP 4

dose limits Training/Drill Program Notification and direction to on- Shift Manager Operations Training and EP 5 shift staff (e.g., to assemble, Training/Drill Program evacuate, etc.)

ERO notification Table 4 - Nuclear Operations Training and EP 6 Station Operator #1 /2 Training/Drill Program Abbreviated NRC notification for N/A for this event N/A 7 DBT event Complete State/local notification Shift Manager Operations Training and EP 8 form Training/Drill Program Perform State/local notifications Table 4 - Nuclear Operations Training and EP 9 Station Operator #1/2 Training/Drill Program Complete NRC event notification Shift Manager Operations Training and EP 10 form Training/Drill Program Activate ERDS Table 4 - Nuclear Operations Training and EP 11 Station Operator #1/2 Training/Drill Program Offsite radiological assessment N/A - Table 4 - Chemistry Training and EP 12 Chemistry Tech Training/Drill Program Perform NRC notifications Table 4- Nuclear Operations Training and EP 13 Station Operator #1 /2 Training/Drill Program Perform other site-specific event Table 4 - Nuclear Operations Training and EP 14 notifications (e.g., INPO, ANI, Station Operator #1/2 Training/Drill Program etc.)

Personnel accountability Security/ Table 4 - Security Training and EP 15 Nuclear Station Training/Drill Program Operator #1/2 107

Analysis 8 Loss of Coolant Accidents On-Shift Staffing Analysis Report Revision 1 Event Narrative #8 Loss of Coolant Accidents This is one of the Design-Basis Condition IV Limiting Fault events as listed in the USAR, § 15.0.1.4, "Condition IV - Limiting Faults." USAR § 15.6.5.1, "Identification of Causes and Accident Description," states:

A loss-of-coolant accident (LOCA) is the result of a pipe rupture of the reactor coolant system (RCS) pressure boundary. -;-;-:A major break (large break) is defined as a rupture with a total cross-sectional area equal to or greater than 1. 0 ff ..,.,..,.

USAR § 15.6.5.2, "Sequence of Events and Systems Operations," continues:

Before the break occurs, the unit is in an equilibrium condition; i.e., the heat generated in the core is being removed via the secondary system. During blowdown, heat from fission product decay, hot internals, and the vessel continues to transfer to the reactor coolant.

At the beginning of the blowdown phase, the entire RCS contains subcooled liquid which transfers heat from the core by forced convection with some fully developed nucleate boiling. After the break develops, the time to departure from nucleate boiling is calculated ... Thereafter, the core heat transfer is unstable, with both nucleate boiling and film boiling occurring. As the core becomes uncovered, both transition boiling and forced convection are considered as the dominant core heat transfer mechanisms. Heat transfer due to radiation is also considered.

When the RCS depressurizes to 600 psia, the accumulators begin to inject borated water into the reactor coolant loops. The conservative assumption is made that all of the accumulator water injected during the bypass period is subtracted from the RCS after the bypass period terminates (called end-of bypass).

End-of-bypass (EOB) occurs when the expulsion or entrainment mechanisms responsible for the bypassing are calculated not to be effective ...

Since loss of offsite power (LOOP) is assumed, the reactor coolant pumps are assumed to trip at the inception of the accident. The effects of pump coastdown are included in the blowdown analysis.

The blowdown phase of the transient ends when the RCS pressure (initially assumed at 2300 psia) falls to a value approaching that of the containment atmosphere. Prior to, or at the end of, the blowdown, termination of bypass occurs and refill of the reactor vessel lower plenum begins. Refill is completed when emergency core cooling water has filled the lower plenum of the reactor vessel to the bottom of the active fuel region (BOC time).

The ref/ood phase of the transient is defined as the time period lasting from BOC recovery until the reactor vessel has been filled with water to the extent that the core temperature rise has been terminated. From the latter stage of blowdown and then the beginning of ref/ood, the accumulator tanks rapidly discharge borated cooling water into the RCS, thus contributing to the filling of the reactor vessel downcomer. The 108

Analysis 8 Loss of Coolant Accidents On-Shift Staffing Analysis Report Revision 1 downcomer head provides the driving force required for the reflooding of the reactor core.

The RHR (low head), safety injection, and high head centrifugal charging pumps aid in the filling of the downcomer and subsequently supply water to maintain a full downcomer and complete the ref/ooding process. Continued operation of the EGGS pumps supplies water during long-term cooling.

Core temperatures have been reduced to Jong-term steady state levels associated with dissipation of residual heat generation. After the water level of the refueling water storage tank (RWST) reaches a minimum allowable value, coolant for long-term cooling of the core is obtained by switching to the cold leg recirculation phase of operation.

Spilled borated water is drawn from the engineered safety features (ESF) containment sump by the RHR (low head) pumps and returned to the RCS cold legs. The containment spray pumps are manually aligned to the containment sump and continue to operate to further reduce containment pressure and temperature. Approximately 10. 0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> after initiation of the LOCA, the EGGS is realigned to supply water to the RCS hot legs in order to control the boric acid concentration in the reactor vessel.

The reactor parameters that bound the radiological consequences of a LOCA can be found in USAR Tables 15A-1, "Parameters Used in Accident Analysis," and 15.6-6, "Parameters Used in Evaluating the Radiological Consequences of a Loss-of-Coolant-Accident." As outlined in USAR § 15.6.5.4, "Radiological Consequences," the radiological source term includes the assumptions: *

a. The reactor core equilibrium noble gas and iodine inventories are based on long-term operation at the ultimate core power level of 3,565 MWt.

b. One hundred percent of the core equilibrium radioactive noble gas inventory is immediately available for leakage from the containment.

c. Twenty-five percent of the core equilibrium radioactive iodine inventory is immediately available for leakage from the containment. *

d. Of the iodine fission product inventory released to the containment, 91 percent is in the form of elemental iodine, 5 percent is in the form of particulate iodine, and 4 percent is in the form of organic iodine.

e. Credit for iodine removal by the containment spray system is taken, starting at time zero and continuing until a decontamination factor of 100 for the elemental and particulate species has been achieved.

USAR Table 15.6-8, "Radiological Consequences of a Loss-of-Coolant-Accident," lists exclusion area boundary doses of 88,820 millirem to the thyroid and 1,530 millirem whole body.

• Document APF 06-002-01, Emergency Action Levels, classifies the large break LOCA as an EAL-1 / BASIS-1, "Radioactive Effluent Release," RER4 (greater than 5000 mR thyroid COE),

based on the above projected exclusion area boundary dose projections. This event is a potential General Emergency.

The event as diagrammed in USAR Figure 15.0-25, "Loss of Coolant Accident," is assumed to generate a reactor trip from full power, based on the USAR § 15.6.5.2 statement:

109

Analysis 8 Loss of Coolant Accidents On-Shift Staffing Analysis Report Revision 1

" .. .depressurization of the RCS results in a pressure decrease in the pressurizer. The reactor trip signal subsequently occurs when the pressurizer low pressure trip setpoint is reached."

A loss of offsite power (LOOP) is also assumed, per USAR § 15.6.5.2.

A conceptual timeline of the events is shown in USAR Figure 15.6-;4, "Sequence of Events for Large Break LOCA Analysis."

EMG E-0:

For this assessment, it was assumed that procedure EMG E-0, "Reactor Trip or Safety Injection," was the entry point for operator actions. The reactor has tripped, and a large (greater than one square foot) break in the reactor coolant system has caused a LOCA. Offsite power was lost at the beginning of the event, but the emergency diesel generators started and loaded onto the busses properly.

EMG E-0, the "normal path," is followed through Step #8. (R0#1/R0#2)

Steps #9 and #10 checks RCS cold leg temperatures and establish steam generator (SG) pressure control. In this scenario, the coolant is being ejected through a large-break LOCA.

The condenser is unavailable due to the loss of offsite power and the main steam lines have been automatically isolated due to the reactor trip and loss of offsite power. See USAR § 10.3.2.3, "System Operation," [of the Steam System] for more details on the equipment response. For this scenario, the large break LOCA predominates. The operator follows the normal path. (R0#2)

Steps #11 through #13 looks for loss of RCS inventory due to problems with the pressurizer (stuck-open PORV, actions of the pressurizer spray values, or open pressurizer safety valves).

In this case, the loss of RCS inventory is due to the large-break LOCA. The operator follows the normal path. (R0#2)

Step #14 checks whether the RCPs should be stopped. The RCPs are already stopped, since a loss of offsite power occurred at the beginning of the event. The operator follows the RNO path.

(R0#2)

Step #15 has the operator monitor procedure EMG F-0, "Critical Safety Function Status Trees,"

while continuing this procedure. (STA)

EMG F-0: (STA)

In this case, the LOCA caused a blowdown of reactor coolant into the containment building.

This generated a rapid increase in containment pressure, as much of the coolant flashed to steam.

USAR § 6.2.1.2.1, "Design Basis," describes the LOCA as:

110

Analysis 8 Loss of Coolant Accidents On-Shift Staffing Analysis Report Revision 1

" ... a double-ended cold leg guillotine break within the reactor cavity. Pipe restraints are employed to limit the break flow area to less than 10 square inches."

USAR Table 6.2.1-2, "Principal Containment Design Parameters," shows the containment pressure for a LOCA peaking at 4 7. 3 psig and the temperature peaking at 306.1 °F. USAR Table 6.2.1-8, "Comparative Results: Summary of Results of Containment Pressure and Temperature Analysis for the Spectrum of Postulated Accidents" shows peak pressure is reached within 130 seconds and peak temperature is reached within 60 seconds of the start of the event, for a variety of double-ended guillotine pipe breaks.

For this analysis, it's assumed the operator observed the rapidly increasing containment pressure and followed the critical safety function status tree F-05, "Containment." Containment pressure is less than 60 psig, but is greater than 27 psig. The containment spray pumps are running, as noted in USAR Figure 15.6-4. This status tree follows a yellow path condition. As this is not a red or orange path condition the crew will stay in EMG E-0.

EMG E-0 (continued):

Step #16 checks to see if any SIG is faulted. The SIGs in this scenario are not faulted. The operator follows the normal path. (R0#2)

Step #17 checks to see if the SIG tubes are intact. (At this point, the containment building is pressurizing to greater than 40 psig and a temperature greater than 300°F). (R0#2)

Step #18 checks to see if the RCS is intact in containment. The containment pressure is rising, so the operator follows the RNO path to procedure EMG E-1, "Loss of Reactor or Secondary Coolant," step #1. (R0#1)

EMG E-1:

Step #1 checks if the RCPs have been stopped. The scenario has the RCPs tripped when the reactor tripped, with the loss of offsite power. Follow the RNO path and go to step #2. (R0#2)

Step #2 checks if the S/Gs are faulted. This is a repeat of procedure EMG E-0, step #16. The operator follows the normal path. (R0#2)

Step #3 checks if the SIGs are intact (e.g., are not ruptured). (R0#2)

Step #4 has the operator reset the safety injection (SI), and Step #5 has the operator reset the containment isolation phase A and B. (R0#1/R0#2)

Step #6 determines the secondary radiation levels. One sub-step has health physics surveys steam lines in Area 5 of the Auxiliary Building, which was already to have been started in procedure E-0, step #17. (R0#2/RP#2ICH)

Step #6, sub-step (e), opens all SIG sample isolation valves. At that point, chemistry is directed to sample all S/Gs for activity. (R0#2/CH) 111

Analysis 8 Loss of Coolant Accidents On-Shift Staffing Analysis Report Revision 1 Step #7 is a check on the secondary radiation levels. No local actions were identified.

(R0#2/RP#2)

Step #8 checks pressurizer PORV valves, which are assumed in this scenario to be acting normally. The loss of RCS pressure is due to a double-ended guillotine break in the cold leg, not due to a pressurizer valve lifting. The pressurizer valves remained closed and the RCS pressure has rapidly dropped below 2185 psig. Accumulator injection occurred 14-19 seconds into the event, as noted in USAR Table 15.6-10, "Time Sequence of Events for Loss-Of-Coolant Accidents." (R0#1)

Step #9 verifies instrument air alignment. This scenario assumes a loss of offsite power at the beginning of the LOCA. The RNO path involves using an operator to locally open the ESW A or 8 to air compressor valves, in order to insure instrument air compressors are available to supply air to instruments and to restore instrument air to the containment.

An operator may also be dispatched to locally reset alarms, restart air compressors and open instrument air supply containment isolation valves as needed. (R0#2/NS0#5/NS0#6)

Step #10 verifies instrument air to containment. (R0#2)

Step #11 checks to see if the ECCS flow should be reduced. In this scenario, the RCS has blown down to the bottom of the core and is re-filling. Much of the initial RCS inventory has flashed to steam, heating and pressurizing the containment building. The RCS pressure is rapidly decreasing. The operator goes to step #12. (R0#1)

Step #12 checks to see if the containment sprays should be stopped. The spray pumps are assumed to be running, and the containment pressure is between 3 psig and 60 psig. (Per USAR Figure 6.2.1-6 has the containment pressure at 27 psig and decreasing at 1000 seconds.

This step is assumed to follow the normal path. If 2 or more of the 4 available containment fan coolers are running in emergency mode, only one running spray pump will be required. As noted in USAR § 6.2.1.4.3.2, "Input Parameters and Assumptions," the containment fan coolers are operable using power from the emergency diesel generators. (R0#2)

Step #13 checks if RHR pumps should be stopped. The RHR pumps should continue running, as the RCS has blown down to the bottom of the core and is re-filling. The operator follows the normal path. (R0#2)

Step #14 checks the RCS and SIG Pressures. The RCS pressure is stable or decreasing due to the large double-ended guillotine break in the cold leg. The S/G pressures are not decreasing in an uncontrolled manner. The operator follows the normal path. (R0#1/R0#2)

Step #15 checks whether the diesel generators should be stopped. This scenario assumes that there was a loss of offsite power when the event started. Operators will try to restore offsite power to NB01 and NB02, but until that is successful, the emergency diesel generators will be kept running and loaded to their respective busses. (R0#2)

Step #16 has an operator locally reset and close the boric acid transfer pump breakers and the emergency borate valve breaker. (R0#1/NS0#5/NS0#6) 112

Analysis 8 Loss of Coolant Accidents On-Shift Staffing Analysis Report Revision 1 Step #17 has the operator close the non-class 1E battery charger breakers. (R0#2)

Step #18 involves checking for the availability of offsite power. The RNO path is to "try to restore offsite power using applicable SYS procedure(s)." One of the additional RNO sub-steps involves energizing the TSC diesel using procedure STN KAT-001, while this procedure continues. (R0#2/NS0#3)

STN KA T-001: (NS0#3)

Operator locally performs the prerequisite checks listed in§ 7, "Prerequisites."*

Operator locally performs § 8.1.1, Testing Installed TSC Diesel Generator OR § 8.2.1, "Testing Temporary TSC Diesel Generator."

Operator locally performs § 8.1.2, "Placing TSC Diesel Generator In-service" OR § 8.2.2, "Placing Temporary TSC Diesel Generator In-service."

Note that if the TSC Diesel Generator runs for more than an hour, refer to Attachment B, "TSC Diesel Generator Reading," or if applicable, Attachment C, "TSC Temporary Diesel Generator Readings," for hourly checks on the diesel generator in question.

EMG E-1 (continued):

Step #19 places the hydrogen analyzers in service. No local actions were identified. (R0#2)

Step #20 verifies cold leg recirculation capability. The USAR Figure 15.6-4 shows recirculation on the RWST low-low-1 level alarm. This scenario assumes no additional complications for conducting this step, so the normal path is followed. (R0#1)

Step #21 checks to see if the fuel/auxiliary building radiation levels are normal. Radiation protection is directed to survey the fuel and auxiliary buildings with priority being pipe penetration areas and piping tunnels. Based on the scenario, a loss of RCS inventory outside of containment is not assumed. The normal path is followed. (R0#2/RP#2)

Step #22 requests chemistry obtain boron and activity samples for the RCS and pressurizer liquid space. (R0#2/CH/RP#2)

Step #23 initiates evaluation of plant status. (R0#2/CRS/NS0#5) Based on the scenario, this step is assumed to follow the normal path. As the basis document notes:

An evaluation of plant equipment available following a LOCA is necessary in determining long-term recovery actions. Hence, this evaluation is initiated at this time and any additional equipment that would assist in the plant recovery is started.

Perform step #23.c RNO for SFP cooling.

113

Analysis 8 Loss of Coolant Accidents On-Shift Staffing Analysis Report Revision 1 Step #24 checks to see if the RCS cooldown and depressurization is complete. Based on the blowdown and refill events, the RCS pressure is less than 325 psig and the operator follows the RNO path to step #25. (R0#1)

Step #25 checks to see if the RWST level is less than 36%. If not, the operator loops back to step #20. Once the RWST level has dropped to less than 36%, the operator goes to procedure EMG ES-12, "Transfer to Cold Leg Recirculation," step #1. It should be noted that USAR Table 6.2.1-7, "Chronology of Events, DEPSG Break w/Max SI," which is one of the potential large-break LOCA scenarios, shows ECCS recirculation could be started as quickly as 849 seconds into the event. (R0#1/CRS)

EMG ES-12:

One of the notes ahead of step #1 cautions that switching to recirculation may cause high radiation in the auxiliary building.

Step #1 resets all SI signals. (R0#1/CRS)

Step #2 verifies CCW to the RHR heat exchangers. Based on the scenario description, this step is assumed to proceed normally. The RNO path (not followed) has cautionary remarks about radiation levels if valves needed to be locally opened. (R0#1/CRS)

Step #3 ensures both CCW from spent fuel pool heat exchangers are closed. Again, based on the scenario description, this step is assumed to proceed normally. The RNO path (not followed) has cautionary remarks about radiation levels if valves needed to be locally closed.

(R0#1/CRS)

Steps #4 and #5 verify the "red train" and "yellow train" RWST switchovers have occurred (e.g.,

suction is now being pulled from the containment sump rather than the RWST). The operator follows the normal path for both steps. The RNO paths have manual operations, but no local operations were identified. (R0#1/CRS)

Step #6 checks to see that the RHR pumps are both running. For this scenario, the step is assumed to proceed normally. (R0#1/CRS)

Step #7 involves closing both RHR train hot leg recirculation valves. The operator follows the normal path. The RNO path (not followed) has cautionary remarks about radiation levels if valves need to be locally closed. (R0#1/CRS)

Step #8 isolates SI pump miniflow to the RWST (to prevent release of containment sump water to the RWST). This step is assumed to follow the normal path. (R0#1/CRS)

Step #9 aligns the CCP and SI pump suctions to the RHR pump discharge and is assumed to follow the normal path. The RNO path (not followed) has cautionary remarks about radiation levels if valves need to be locally opened. (R0#1/CRS) 114

Analysis 8 Loss of Coolant Accidents On-Shift Staffing Analysis Report Revision 1 Step #10 isolates the RWST from charging and SI pumps, and is assumed to follow the normal path. The RNO path (not followed) has cautionary remarks about radiation levels if valves need to be locally closed. (R0#1/CRS)

At this point, Functional Restoration (FR) procedures may now be implemented as required by EMG F-0, Critical Safety Function Status Trees (CSFST). (R0#1/CRS - RO only for duration of ES-12)

Step #11 checks to see if phase A, phase 8 and containment spray actuation can be reset.

Given this scenario, it's assumed that the containment spray pumps are running. (R0#1/CRS)

Step #12 checks to see if containment spray system should be aligned for recirculation. Once the RWST level reaches 12%, actions in step #13 align the containment spray system for recirculation. Both steps follow the normal path. (R0#1/CRS)

Step #14 checks to see if the spray additive tank should be isolated. (R0#1/CRS) The normal path is followed. The function of the spray additive tank, per USAR § 6.5.2.2.1, "General Description," is:

The containment spray additive portion of the CSS provides for eduction of 30 weight percent (nominal) sodium hydroxide into the spray injection water. This yields a spray mixture with a pH of from 9. 0 to 11. 0 during the initial period of operation, when radioiodine is being removed from the containment atmosphere.

Step #15 verifies the "red train" and "yellow train" flow paths from the sump to the RCS. This step's normal path is followed. (R0#1ICRS)

Step #16 verifies core cooling. However, the RCPs are NOT running (loss of offsite power), so the required RVLIS level would need to be in the natural circulation range. USAR § 18.2.13.2, "The Operating Agent Response" notes that for large-break LOCAs, the RVLIS system is expected to provide unambiguous indications as early as 30 seconds after the initiation of a double-ended guillotine rupture of a main coolant pipe. The operator follows the normal path.

(R0#1/CRS)

Step #17 opens the breakers for both CCP suction from RWST valves. (R0#1/NS0#6)

• Step #18 records the time of fuel pool heat exchanger CW isolation in the control room log. At this point, the time elapsed since fuel pool heat exchanger isolation is less than 3.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />, so the RNO path is followed and the operator proceeds to step #19. (R0#1/CRS)

Step #19 monitors for ECCS leakage, which is assumed to be normal for the plant conditions.

(Additional ECCS *1eakage is a more complex event and is beyond the scope of the design basis scenario). (R0#2/CRS)

Step #20 determines if transfer to hot leg recirculation will be required. This procedure has been entered into from EMG E-1, so this follows step the normal path. It should be noted that hot leg recirculation of the sump water normally starts approximately 1O hours following an 115

Analysis 8 Loss of Coolant Accidents On-Shift Staffing Analysis Report Revision 1 accident. See USAR § 6.3.2.5, "System Reliability" for more details on the potential problem of boron precipitation. (R0#1/CRS)

Termination path (expected actions are beyond the 90 minutes of the event).

116

I Analysis 8 Loss of Coolant Accidents On-Shift Staffing Analysis Report Revision 1 This OSA is applicable to Analysis # §. as identified in Appendix A. (LOCA - large break)

TABLE 1 -On-shift Positions Augmentation Role in Unanalyzed TMS Line On-shift Position Emergency Plan Reference Elapsed Time (min) Table#/Line# Task? Required?

Shift Manager REMP, Figure 2, "Minimum Shift N/A T2/L 1 No No*

Staffing" & Attachment D, "WCGS T5/L 1 Minimum Staffing for Emergencies" T5/L2 T5/L3 1

T5/L4 T5/L5 T5/L8 T5/L 10 Shift Technical Advisor REMP, Figure 2, "Minimum Shift N/A T2/L3 No No Staffing" & Attachment D, "WCGS 2

Minimum Staffing for Emergencies" Control Room Supervisor REMP, Figure 2, "Minimum Shift N/A T2/L2 No No Staffing" & Attachment D, "WCGS 3

Minimum Staffing for Emergencies" Reactor Operator #1 REMP, Figure 2, "Minimum Shift N/A T2/L4 No No Staffing" & Attachment D, "WCGS 4

Minimum Staffing for Emergencies" 117

Analysis 8 Loss of Coolant Accidents On-Shift Staffing Analysis Report Revision 1 This OSA is applicable to Analysis # §. as identified in Appendix A. (LOCA - large break)

TABLE 1 - On-shift Positions Augmentation Role in Unanalyzed TMS Line On-shift Position Emergency Plan Reference Elapsed Time (min) Table#/Line# Task? Required?

Reactor Operator #2 REMP, Figure 2, "Minimum Shift N/A T2/L5 No No Staffing" & Attachment D, "WCGS 5

Minimum Staffing for Emergencies" Nuclear Station Operator REMP, Figure 2, "Minimum Shift N/A T2/L6 No Yes*

1. 1/2 Staffing" & Attachment D, "WCGS T4/L7 Minimum Staffing for Emergencies" T4/L8 T5/L6 T5/L9 6

T5/L 11 T5/L 13*

T5/L 14 T5/L 15 Nuclear Station Operator #3 REMP, Figure 2, "Minimum Shift N/A T2/L7 No No Staffing" & Attachment D, "WCGS 7

Minimum Staffing for Emergencies" Nuclear Station Operator #5 REMP, Figure 2, "Minimum Shift N/A T2/L8 No No Staffing" & Attachment D, "WCGS 8

Minimum Staffing for Emergencies" 118

Analysis 8 Loss of Coolant Accidents On-Shift Staffing Analysis Report Revision 1 This OSA is applicable to Analysis#§. as identified in Appendix A. (LOCA- large break)

TABLE 1 - On-shift Positions Augmentation Role in Unanalyzed TMS Line On-shift Position Emergency Plan Reference Elapsed Time (min) Table#/Line# Task? Required?

Nuclear Station Operator #6 REMP, Figure 2, "Minimum Shift N/A T2/L9 No No Staffing" & Attachment D, "WCGS 9

Minimum Staffing for Emergencies" Chemistry Technician REMP, Figure 2, "Minimum Shift 90 T4/L5* No No Staffing" & Attachment D, "WCGS 10 T4/L6 Minimum Staffing for Emergencies" Radiation Protection REMP, Figure 2, "Minimum Shift 90 T4/L3 No No Technician #1 Staffing" & Attachment D, "WCGS 11 Minimum Staffing for Emergencies" Radiation Protection REMP, Figure 2, "Minimum Shift 90 T4/L 1 No No Technician #2 Staffing" & Attachment D, "WCGS 12 T4/L4 Minimum Staffing for Emergencies" Security REMP, Attachment D, "WCGS N/A T5/L 15 No No 13 Minimum Staffing for Emergencies"

• Based on functional analysis ENS communicator reqwred for continuous NRC communrcat1ons. Thrs rnd1v1dual also fulfills the OSC communicator role .

119

Analysis 8 Loss of Coolant Accidents On-Shift Staffing Analysis Report Revision 1 TABLE 2 - Plant Operations & Safe Shutdown Analysis # §.

One Unit - One Control Room Minimum Operations Crew Necessary to Implement AOPs and EOPs, or SAMGs if applicable Task Analysis Line Generic Title/Role On-Shift Position Controlling Method 1 Shift Manager Shift Manager Operations Training 2 Unit Supervisor Control Room Supervisor Operations Training 3 Shift Technical Advisor Shift Technical Advisor Operations Training 4 Reactor Operator #1 Reactor Operator #1 Operations Training 5 Reactor Operator #2 Reactor Operator #2 Operations Training Auxiliary Operator #112 Nuclear Station Operator Operations Training 6

1. 112 Auxiliary Operator #3 Nuclear Station Operator #3 Operations Training 7

(Site)

Auxiliary Operator #5 Nuclear Station Operator #5 Operations Training 8

(Aux)

Auxiliary Operator #6 Nuclear Station Operator #6 Operations Training 9

(TB)

Other (non-Operations) Personnel Necessary to Implement AOPs and EOPs, or SAMGs if applicable Task Analysis Line . Generic Title/Role On-Shift Position Controlling Method 10 Mechanic NIA NIA 11 Electrician NIA NIA 12 l&C Technician NIA NIA 13 Other NIA NIA 120

Analysis 8 Loss of Coolant Accidents On-Shift Staffing Analysis Report Revision 1 TABLE 3 - Firefighting Analysis # §.

Task Analysis Line Performed By Controlling Method NIA- there is no fire associated with this N/A 1

event.

2 N/A N/A 3 N/A N/A 4 N/A N/A 5 N/A N/A 121

Analysis 8 Loss of Coolant Accidents On-Shift Staffing Analysis Report Revision 1 TABLE 4 - Radiation Protection & Chemistry & OSC/ENS Communicator Analysis # §.

Performanc,e Time Period After Emen ency Declaration (minutes)

Position Performing Line 0- 5- 10- 15- 20- 25- 30- 35 45- 50- 55- 60- 65- 70- 75- 80- 85-Function/Task 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 In-Plant Survey On-Shift Position:

1 RP Tech #1 X X X X X Main Steam Line Survey On-Site Survey N/A - The performance of an on-site survey is not necessary for initial implementation of the Emergency Plan and not 2 On-Shift Position required by any procedure.

Personnel Monitoring On-Shift Position:

3 X X X X X X X X X X X X X CR RP Tech #1 Job Coverage On-Shift Position:

RP Tech #2 4 X X X X X X X X X X X X X X X X X X As needed for NSO actions Offsite Radiological Assessment*

5 On-Shift Position: X X X X X X X X X X X X X X X X X X Chemistry Tech Chemistry function/task

1. 1 -Sampling N/A- No sampling required until the Technical Support Center is staffed per AP 15C-003 (on hold pending approval 6

On-Shift Position: by NRC).

Chemistry Tech

• Dose assessment passes directly to the EOF, so this function 1s not relieved at 90 minutes.

122

Analysis 8 Loss of Coolant Accidents On-Shift Staffing Analysis Report Revision 1 TABLE 4 - Radiation Protection & Chemistry & OSC/ENS Communicator Analysis # §.

Performance Time Period After Emergency Declaration (minutes)

Position Performing 15 Line 0- 5- 10- 20- 25- 30- 35- 40- 45 55- 60- 65- 70 80 Function/Task 5 10 15

- 25 30 35 40 45 50 55 60 65 70 75 80 85 90 20 OSC Communicator function/task-1- Initiate staffing of ERO 2- Emerg Notifications 7

3- Notify State/ County X X X X X X 4- Notify NRC SRI /

Westar X 5-ANI / INPO X ENS Communicator function/task-Continuous X X 8 X X X X X X X X communication with NRC 123

Analysis 8 Loss of Coolant Accidents On-Shift Staffing Analysis Report Revision 1 TABLE 5 - Emergency Plan Implementation Analysis # §.

Task Analysis Line Function/Task On-Shift Position Controlling Method Declare the Emergency Shift Manager Operations Training and EP 1

Classification Level (ECL) Training/Drill Program Approve Offsite Protective Action Shift Manager Operations Training and EP 2

Recommendations Training/Drill* Program Approve content of State/local Shift Manager Operations Training and EP 3

notifications Training/Drill Program Approve extension to allowable Shift Manager Operations Training and EP 4

dose limits Training/Drill Program Notification and direction to on- Shift Manager Operations Training and EP 5 shift staff (e.g., to assemble, Training/Drill Program evacuate, etc.)

ERO notification Table 4 - Nuclear Operations Training and EP 6 Station Operator #1 /2 Training/Drill Program Abbreviated NRC notification for N/A for this event N/A 7 DBT event Complete State/local notification Shift Manager Operations Training and EP 8 form Training/Drill Program Perform State/local notifications Table 4- Nuclear Operations Training and EP 9 Station Operator #1 /2 Training/Drill Program Complete NRC event notification Shift Manager Operations Training and EP 10 form Training/Drill Program Activate EROS Table 4 - Nuclear Operations Training and EP 11 Station Operator #1 /2 Training/Drill Program Offsite radiological assessment N/A- Table 4 - Chemistry Training and EP 12 Chemistry Tech Training/Drill Program Perform NRC notifications Table 4 - Nuclear Operations Training and EP 13 Station Operator #1 /2 Training/Drill Program Perform other site-specific event Table 4- Nuclear Operations Training and EP 14 notifications (e.g., INPO, ANI, Station Operator #1 /2 Training/Drill Program etc.)

Personnel accountability Security/ Security Training and EP 15 Table 4- Nuclear Training/Drill Program Station Operator #1 /2 124

Analysis 9 Design Basis Fuel Handling Accident On-Shift Staffing Analysis Report Revision 1 Event Narrative #9 Design Basis Fuel Handling Accident This is one of the Design-Basis Condition IV Limiting Fault events as listed in the USAR, § 15.0.1.4, "Condition IV - Limiting Faults.".,. USAR § 15.7.4.1, "Identification of Causes and Accident Description" states:

The accident is defined as the dropping of a spent fuel assembly onto the fuel storage area floor or refueling pool floor, resulting in the rupture of the cladding of all the fuel rods in the assembly despite many administrative controls and physical limitations imposed on fuel handling operations. All refueling operations are conducted in accordance with prescribed procedures.

A detailed discussion of potential accidents in this category, including analytical methods used and the scenario consequences expected, can be found in USAR § 15.7.4, "Fuel Handling Accidents" and are diagrammed in USAR Figures 15.0-29, "Fuel Handling Accident Inside Fuel Building" and 15.0-30, "Fuel Handling Accident Inside Containment."

USAR § 15.7.4.2, "Sequence of Events and System Operations" continues:

The postulated fuel handling accident is assumed to occur during a core offload at least 76 hours8.796296e-4 days <br />0.0211 hours <br />1.256614e-4 weeks <br />2.8918e-5 months <br /> after shutdown in either the reactor containment building, or in the fuel building subsequent to the transfer of a fuel assembly through the fuel storage pool transfer gate and prior to placement in a fuei storage pool storage rack designated location.

Although both accidents are Condition IV limiting faults, the radiological consequences of the accident inside containment are more severe than for an accident inside the spent fuel building, as discussed in USAR Tables 15.7-7, "Parameters Used in Evaluating the Radiological Consequences of a Fuel-Handling Accident" and 15.7-8, "Radiological Consequences of a Fuel Handling Accident." Accordingly, the containment building accident is the one selected for analysis in this scenario.

• USAR § 15.7.4.5, "Radiological Consequences," elaborates on the initiating conditions for an accident inside the containment building, involving spent fuel:

During fuel-handling operations, the containment is kept in an isolatable condition, with all penetrations to the outside atmosphere either closed or capable of being closed on an alarm signal from one of the redundant radiation monitors, indicating that radioactivity is above the prescribed limits.

In addition to the area radiation monitors in the containment, portable monitors capable of sounding audible alarms are to be located in the fuel-handling area. Should a fuel assembly be dropped and release activity above a prescribed level, the radiation monitors would sound an audible alarm, the containment would be isolated, and personnel would be evacuated.

During movement of irradiated fuel and core alterations, one door in the emergency air lock must be closed. The other emergency air lock door may be open provided it is 125

Analysis 9 Design Basis Fuel Handling Accident On-Shift Staffing Analysis Report Revision 1 capable of being closed. The equipment hatch may be open provided it is capable of being closed, and penetration flow paths providing direct access may be unisolated under administrative controls. Administrative controls are imposed for the closure of a personnel air Jock door, closure of the equipment hatch, and to isolate open penetration flow paths in the event of a fuel handling accident.

Assumptions and conditions for the accident scenario, per USAR § 15. 7.4.5.1.2, "Assumptions and Conditions" include:

• The dropped fuel assembly is assumed to be the assembly containing the peak fission product inventory. All the fuel rods contained in the dropped assembly are assumed to be damaged. In addition, for the analyses for the accident in the reactor building the dropped assembly is assumed to damage 20 percent of the rods of an additional assembly.

For the inside the reactor building case, the containment personnel airlock doors and equipment hatch are assumed to be open at the time of the accident. For added conservatism, the gaseous effluent escaping from the refueling water pool in the Reactor Containment Building is assumed to be released immediately to the environment through the open personnel and equipment hatch and the adjacent Auxiliary Building without mixing in the surrounding atmosphere. The activity releases continue until the containment personnel airlock doors and equipment hatch are closed (assumed to be accomplished within two hours). The Auxiliary Building atmosphere is normally exhausted through filter absorbers designed to remove iodine. However, no credit is taken for iodine removal by the atmosphere filtration system filters. It is also assumed that no containment coolers or hydrogen mixing fans are operating and 99. 99% of the activity escaping from the pool to the containment building is released to the environment over a two-hour period following the accident.

Additional remarks on the radiological source term can be found in USAR § 15.7.4.5.2, "Identification of Uncertainties and Conservatisms in Analysis."

Document APF 06-002-01, Emergency Action Levels, identifies the above as an EAL-7 /

BASES-7, "Fuel Handling Accident." FHA-3 (Radioactivity is released to the Reactor Building) classifies the event as an Alert.

The scenario assumes the reactor is in a refueling outage. The accident occurs while the outage is in Phase Ill - Fuel Handling. As discussed in USAR § 9.1.4.2.3.1, "Fuel Handling System Operations":

The reactor shall be determined to have been subcritica/ for at least 76 hours8.796296e-4 days <br />0.0211 hours <br />1.256614e-4 weeks <br />2.8918e-5 months <br /> by verification of the date and time of sub criticality prior to movement of irradiated fuel in the reactor vessel. With the reactor subcritica/ for Jess than 76 hours8.796296e-4 days <br />0.0211 hours <br />1.256614e-4 weeks <br />2.8918e-5 months <br />, suspend all operations involving movement of irradiated fuel in the reactor vessel. This requirement is consistent with the assumptions of Section 15. 7. 4. 5. 1. 2.

126

Analysis 9 Design Basis Fuel Handling Accident On-Shift Staffing Analysis Report Revision 1 The event as diagrammed in USAR Figure 15.0-30, "Fuel Handling Accident Inside Containment," is assumed to occur at 76 hours8.796296e-4 days <br />0.0211 hours <br />1.256614e-4 weeks <br />2.8918e-5 months <br /> post shutdown. The reactor is in Mode 6, cold shutdown.

This event would not occur when only the minimum on-shift staff is present. In addition, any new fuel received would occur only during the day shift, when additional staff is available to manage the consequences of any potential events.

Given the above constraints, the staffing requirements were not included in the On-Shift Staffing Analysis, since the "minimum on-shift staff' scenario would not apply.

127

Analysis 10 Aircraft Probable Threat On-Shift Staffing Analysis Report Revision1 Event Narrative #10 Aircraft Probable Threat This is a scenario as categorized by the NRG, which is outside the scope of the classical design basis accidents as defined by the USAR.

NEI 10-05 rev O (6/11), "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities," discusses analysis of a 10 CFR 50.54(hh)(1) event in § 2.13:

This analysis should include all emergency response actions taken prior to an aircraft impact in accordance with RG 1.214 [an NRG Regulatory Guide with restricted distribution] for an aircraft threat that is greater than 5 minutes, but Jess than 30 minutes, from the site, and should consider the dispersal of the site fire brigades away from target areas for firefighting.

OFN SK-039, "Security Event," classifies aircraft threats in three categories, as defined in § 2.3:

1. Imminent threat - the site is in the flight path of a track of interest, the estimated time to the site is 5 minutes or less, and the altitude changes align the aircraft with the site OR there's specific, credible intelligence that a small aircraft presents a greater threat than it!s size would indicate and the estimated time to the site is 5 minutes or Jess. The other paths to an imminent threat declaration are a locally observed large aircraft threat OR upon order from an NRG imminent security threat authority.

2. Probable threat - the site is in the flight path of a track of interest, and either the estimated time to the site is more than 5 minutes but Jess than 30 minutes, or the site receives specific, credible intelligence that a small aircraft presents a greater threat than its size would indicate and the estimated time to the site is greater than 5 minutes but Jess than 30 minutes.

3. Informational threat - The site is in the flight path of a track of interest and either the estimated time to the site is 30 minutes or more, or the threat is a small aircraft and the site has not received specific, credible intelligence information that the aircraft presents a greater threat than its size would indicated. Another path to an informational threat declaration is a locally observed small aircraft threat.

As noted in OFN SK-039, Attachment B, for an informational threat, the plane is assumed to be smaller than a 737, DC9, MD80, MD90 or 717, and further, that there is no credible information that the smaller aircraft represents a "disproportionate threat" compared to its size.

NEI 12-05 requirements for the 10 CFR 50.54(hh)(1) analysis classify the aircraft event as a "Probable Threat."

For the purposes of this narrative, the scenario assumes that even if the initial aircraft probable threat resolves itself in under an hour, uncertainties about the threat environment 128

Analysis 10 Aircraft Probable Threat On-Shift Staffing Analysis Report Revision1 and the time needed to coordinate across multiple federal agencies will delay final resolution of the event. The 9/11 terrorist attacks help inform the scenario.

This timeline differs from the site's real-world experience with a small aircraft flyover on 6/11/2007, which resolved itself in 30 minutes, but the actual event would have fallen under the lesser "Informational Threat" classification.

Operator actions start with procedure OFN SK-039, "Security Event."

OFN' SK-039:

Step #1 checks for a credible threat. The normal path is followed; the aircraft is considered a probable threat, per NEI 10-05, § 2.13. (SM)

Step #2 has the NRC contacted to relay information on the threat. (SM/NS0#1/2)

Step #3 is a check on the nature of the threat (airborne or non-airborne-based). The RNO path is followed for the airborne threat. (SM)

The operator the goes to Attachment 8, "Response to an Airborne Threat."

Attachment B: Response to an Airborne Threat:

Step #8.1 has the Shift Security Lieutenant notified. Continuous communications with the NRC are established. (SM/NS0#1/2)

Per the NOTES, the shift manager can implement the remaining actions below in the order appropriate for the specific event. The steps from #8.2 through #8.9 should be performed.

Implementing the remaining steps may or may not be desirable, depending on the nature of the specific threat.

Step #8.2 has the authenticity of the report validated. Actions in Attachment 8 continue while the authenticity is validated. (SM)

Step #8.3 has possible protective measures evaluated, using Attachment C, "Guidance for Protective Measures." (SM)

Attachment C: Guidance for Protective Measures For this scenario, the plant is assumed to have been at full power at the start of the event.

The probable threat aircraft is assumed to be inbound, between 5 minutes and 30 minutes out.

Step #C.1 discusses consideration of protective measures for general site personnel. (SM)

Step #C.2 provides a table that lists possible protective measures, factoring in weather conditions and the ETA of the inbound aircraft. (SM) 129

Analysis 10 Aircraft Probable Threat On-Shift Staffing Analysis Report Revision1 If weather conditions are not severe, and the available warning time is between 15 and 30 minutes, the guidelines are to evacuate PAB to the E-plan assembly areas. If the warning time is between 5 and 15 minutes, the guidelines are to shelter in severe weather shelters.

Under adverse weather conditions, step # C.2 has the individuals' shelter in severe weather shelters for both time ranges. (For an imminent threat, which is beyond the scope of this scenario, the guidelines are to shelter in place).

Step #C.3 has operator personnel relocate to the following locations:

• CRS or SRO at the controls and R0#1 stay in the control room.

• The STA/SE and R0#2 go to the Aux Shutdown Panel.

• The site watch (NS0#3) and any accompanying crew members go to the Circ Water Screen House. (If persons are already at ESW, they stay at ESW).

• The SM or SRO outside the control room, aux building watch, turbine building watch, fire brigade leader and fire brigade members and all other ops personnel, the shift RP and shift chemist, go the GOB 1st floor computer training room across from the heartland cafe by the mail room. (FBL - NS0#4, FBM - NS0#5, FBM -

NS0#6, FBM - NS0#7, FBM - NS0#8, RP and CH)

The operator (SM) then returns to Attachment 8 .

. Attachment B: Response to an Airborne Threat (continued)

Step #8.4 directs that if protective measures are needed, security is to be* notified. The security and plant personnel relocation/evacuation process is started, as necessary.

Notification is performed using the telephone paging system, or by using the plant's Gai-tronics system if the phones don't work. (SM)

Step #8.5 has the shift manager determine the emergency action level of the event. For the scenario specified, APF 06-002-01, "Emergency Action Levels," EAL-9 / 8ASES-9, "Loss of Plant Control/ Security Compromise," under LPC/SC2, "Security Hostile Action declared

• in accordance with WCGS Safeguard Contingency Plan," would classify this event as an Alert. (SM/NS0#1/2)

Steps #8.6 and #8. 7 are skipped. The former assumes the plant is in a refueling outage; the latter discusses an "Imminent Airborne Threat." Neither assumption reflects the scenario being analyzed for this narrative.

Step #8.8 has the operator (CRS/R0#1) commence a rapid down-power of the reactor, per procedure OFN MA-038, "Rapid Plant Shutdown," concurrently with this procedure.

Step #8.8 continues with directions to Security to implement a site lighting blackout. An operator places the control room in CRVIS lineup. This narrative assumes the operator doesn't have time to follow the normal procedures for a CRVIS lineup, (SYS GK-122 and SYS GK-123), so the CRVIS is manually actuated. (SM)

Step #8.9 is skipped. The step is relevant for an "Informational Airborne Threat," which is not the scenario analyzed here.

130

Analysis 10 Aircraft Probable Threat On-Shift Staffing Analysis Report Revision1 As noted in the NOTES before step #8.2, performing the remaining steps in this attachment may or may not be desirable, depending on the nature of the specific threat.

Step #810 has an operator (CRS/R0#1) ensure that the reliability of off-site power sources is maintained.

Step #8.11 has an operator (CRS/R0#1) ensure that both emergency diesel generators are in standby.

Step #8.12 has an operator (CRS/R0#1) ensure that the site has backed out of/stopped in-progress surveillance testing/maintenance. Equipment is to be returned to functional status.

Step #8.13 starts the motor driven fire pump or diesel driven fire pump. (CRS/R0#1)

Step #8.14 instructs to place a temporary fire pump in service, if installed. (This scenario assumes the regular fire pumps are in service, so this step is skipped).

Step #8.15 checks for restoration of inoperable ECCS equipment. (CRS/R0#1)

Step #8.16 has an operator close the control room missile door. (CRS/R0#1)

Step #8.17 checks for securing the containment pump and verifying that containment penetrations are closed. (CRS/R0#1)

Step #8.18 checks to ensure that systems are available for reactor shutdown and A TWS.

(CRS/R0#1)

Step #8.19 checks to maximize makeup water sources and systems, and ensure that all tanks are at their maximum level. (CRS/R0#1/NS0#5/NS0#6, if available)

Step #8.20 ensures that decay heat removal systems are available. (CRS/R0#1)

Step #8.21 (if plant conditions permit), checks to isolate the spent fuel pool cleanup systems. (CRS/R0#1/NS0#6, if available)

Step #8.22 (as plant conditions allow), checks to shutdown ventilation systems, secures all possible site building fans, and minimizes the number of operating turbine building fans.

(CRS/R0#1)

Step #8.23 jumps back to the mainline procedure, step #18.

OFN SK-039: (continued)

Step #18 is a check to see that the security event is terminated. This is a "hold point" before continuing with step #19. Step #19 is expected to occur beyond the first 90 minutes of the event.

OFN MA-038: (CRS/R0#1, everyone else is sheltered or use as available) 131

Analysis 10 Aircraft Probable Threat On-Shift Staffing Analysis Report Revision1 This step occurs during OFN SK-039, step #8.8, which is implemented concurrently. The unloading rate is greater than the 1% per minute of a normal shutdown, but does not exceed 5% per minute. This rate limit is to reduce the risk of turbine vibration during the down-power. See the procedures basis document for more information.

Step #1 has an operator determine the turbine unloading method to be used. Use of AUTO is assumed, in order to reduce the operator workload.

Step #2 has an operator set the turbine for automatic unloading. The normal path is followed.

Step #2.c has an operator borate the reactor cooling system (RCS) and adjusts the control rods, taking advantage of the automated control systems.

Steps #2.d through #6 has an operator energize the pressurizer backup heaters to limit the drop in pressurizer pressure as Tavg is decreased. The pressurizer PORVs are checked to verify pressure; valves and block valves are aligned as necessary. The operator checks the trending of the pressurizer pressure and level. The RNO paths, if they had been followed, would have required manual operations but no local operations were identified.

Step #7 has an operator check the S/G levels. The automatic level control system should be maintaining the proper S/G level. The RNO path, if followed, would have an operator taking manual control of the main feed regulating valves. The scenario assumes the normal path is taken.

Step #8 has an operator notify radiation protection that increased monitoring of potentially changing radiation levels in the RCS and other connecting systems is needed (the driving concern here is over the potential for a crud burst). This step does not require any monitoring while personnel are sheltered.

Step #11 has an operator enable the turbine high vibration trip, per Attachment B, "Restoring Turbine High Vibration Trip."

Attachment B: (may be deferred until sheltering is complete)

The operator jumps to the mainline procedure, continuing with step #12.

Step #12 has an operator check whether the generator is being taken offline. For this scenario, the assumption is the reactor is going to be tripped, shutdown and brought to hot standby. The normal path is followed and the generator is to be taken offline.

Step #13 has an operator begin removing the 2nd stage re-heaters from service, using procedure SYS AC-322, "MSR 2nd Stage Reheat Operations.".,. The note before this procedure step advises, "During an emergency shutdown, if time is not available to completely cool-down the reheat lines the shutdown should not be delayed." Step #13 is deferred until sheltering is complete.

132

Analysis 10 Aircraft Probable Threat On-Shift Staffing Analysis Report Revision1 Step #14 checks for reactor power less than 60%. The ultimate end point of this narrative is assumed to be a reactor that is shut down and at hot standby, so this step acts as a "hold point" before continuing with step #16.

Step #15 checks whether one main feedwater pump should be stopped, but this step may be bypassed at the option of the CRS. Given the time constraints, the operator bypasses this step.

Step #16 checks if the heater drain should be stopped, but this step may be bypassed at the option of the CRS. The operators are assumed pressed for time, so this step is bypassed.

Step #17 checks for reactor power less than 30%. This is a hold point before continuing with step #18.

Step #24 is conducted at the direction of the SM/CRS per RNO step #18, while continuing with the remaining steps of the procedure. Based on the procedure's basis document, feedwater preheating is not placed in-service, because we're headed for reactor shutdown rather than attempting to keep the plant operating at low power levels for a sustained piece of time.

The auxiliary boiler is assumed not started due to time constraints.

(These actions do increase the risk of SIG level instability during the down-power).

Step #25 has the operator transfer feedwater control to the bypass valves. The main feed regulating bypass valves are placed in automatic. (The scenario assumes that controls are placed in automatic to reduce the workload on the operator).

Step #26 checks to see if rod control should be placed in manual. Rod control is placed in manual once reactor power is at 15% (the C-5 interlock lights). Control rods are adjusted to.

maintain the desired reactor power (which in this scenario is to shutdown the reactor to hot standby). A recorder has its ranges transferred appropriate to the new power level.

Step #27 has the operator transfer loads to the startup transformer, as the final desired turbine load is less than 180 MW(e). Here, the final turbine load is to zero, as the reactor is brought to shutdown, hot standby.

Step #28 checks for reactor power between 8% and 10%. For this scenario, this will be treated as a "hold point", as the reactor is trending to shutdown and the reactor power will not be maintained stable between 8% and 5%. Once the reactor power is less than 8%, the operator continues with step #36.a.

Step #36.a has an RNO path to manually trip the reactor, using procedure EMG E-0, "Reactor Trip or Safety Injection." The RNO path is followed, given the scenario assumptions. At this point, further actions are assumed to be beyond the first hour of the event.

133

Analysis 10 Aircraft Probable Threat On-Shift Staffing Analysis Report Revision1 Termination path (expected actions are beyond the first 90 minutes of the event):

OFN SK-039:

Steps #19 through #21 (the procedures end-point). The longer-term closure of this event is assumed to involve termination of the security event and making "all clear announcements over the telephone paging system or plant Gai-tronics system, making necessary offsite notifications, making e-plan announcements and executing the plant's accountability process.

OFN MA-038:

Step #13 has an operator begin removing the 2nd stage re-heaters from service, using procedure SYS AC-322, "MSR 2nd Stage Reheat Operations." The note before this procedure step advises, "During an emergency shutdown, if time is not available to completely cool-down the reheat lines the shutdown should not be delayed."

Step #15, which was bypassed earlier due to time constraints, is conducted now. One main feedwater pump is stopped, using Attachment A, "Shutdown of One Main Feedwater Pump."

Step #16,

• which was bypassed earlier due to time constraints, is conducted now. One heater drain pump is stopped.

SYS AC-322:

This procedure provides instructions for removing the second stage reheaters from service at power. The cool-down rate is not to exceed 125°F / hour, a process which typically takes 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to complete. Operations in this procedure are assumed to be local.

This procedure begins with step #6.1, "Removing 2nd Stage Reheat from Service."

Step #6.1.1 has an operator at the MSR control panel ensure that the main steam supply low load valves air-loading controllers are in manual. The operator hooks up a laptop if a LAN connection is installed, or contacts the control room if a LAN connection is not available. The operator continues at the MSR control panel, slowly opening the main steam supply load valves until the valves are full open.

Step #6.1.3 has the operator record temperatures every 5 minutes using Attachment A, "Hot Reheat Line to CIV Temperatures (3.1.3)," until the temperatures stabilize.

The CAUTION statement remarks that the low load valves should be adjusted to ensure the rate of change of temperature and difference in temperature between systems is within limits. The cool-down process is expected to take 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. The NOTE statement references the valve locations and the need to monitor MSR outlet temperatures with a laptop or through maintaining communications with the control room.

Steps #6.1.4 through #6.1.6 involve closing the main steam supply load valves, decreasing the reheat inlet manual loading regulator pressure to zero, closing the main steam supply to 134

Analysis 10 Aircraft Probable Threat On-Shift Staffing Analysis Report Revision1 MSR 2nd stage isolation, and removing the 2nd stage reheater from service. Step #6.1.6 is the last step conducted in this procedure.

EMG E-0:

The reactor is tripped and this procedure is followed to bring the reactor to hot standby.

Ultimately, a decision is made by a cognizant authority as to whether to bring the plant back to power or bring the plant to cold shutdown.

135

Analysis 10 Aircraft Probable Threat On-Shift Staffing Analysis Report Revision1 This OSA is applicable to Analysis# 10 as identified in Appendix A. (Aircraft Probable Threat)

TABLE 1 - On-shift Positions Augmentation Unanalyzed Role in TMS Line On-shift Position Emergency Plan Reference Elapsed Time Task?

Table#/Line# Required?

(min)

Shift Manager REMP, Figure 2, "Minimum Shift N/A T2/L 1 No No Staffing" & Attachment D, "WCGS T5/L 1 Minimum Staffing for Emergencies" T5/L3 T5/L4 1

T5/L5 T5/L7 T5/L8 T5/L 10 Shift Technical Advisor REMP, Figure 2, "Minimum Shift N/A T2/L3 No No 2 Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" Control Room Supervisor REMP, Figure 2, "Minimum Shift N/A T2/L2 No No 3 Staffing" & Attachment D, "WCGS T5/L 11 Minimum Staffing for Emergencies" Reactor Operator #1 REMP, Figure 2, "Minimum Shift N/A T2/L4 No No 4 Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" Reactor Operator #2 REMP, Figure 2, "Minimum Shift N/A T2/L5 No No 5 Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" 136

Analysis 10 Aircraft Probable Threat On-Shift Staffing Analysis Report Revision1 This OSA is applicable to Analysis# 10 as identified in Appendix A (Aircraft Probable Threat)

TABLE 1 - On-shift Positions Augmentation Unanalyzed Role in TMS Line On-shift Position Emergency Plan Reference Elapsed Time Task?

Table#/Line# Required?

(min)

Nuclear Station Operator REMP, Figure 2, "Minimum Shift N/A T2/L6 No Yes*

1. 1/2 Staffing" & Attachment D, "WCGS T5/L6 Minimum Staffing for Emergencies" T5/L9 6

T5/L 13*

T5/L 14 T5/L 15 Nuclear Station Operator #3 REMP, Figure 2, "Minimum Shift N/A T2/L7 No No 7 Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" Nuclear Station Operator #4 REMP, Figure 2, "Minimum Shift N/A T2/L8 No No 8 Staffing" & Attachment D, "WCGS T3/L 1 Minimum Staffing for Emergencies" Nuclear Station Operator #5 REMP, Figure 2, "Minimum Shift N/A T2/L9 No No 9 Staffing" & Attachment D, "WCGS T3/L2 Minimum Staffing for Emergencies" Nuclear Station Operator #6 REMP, Figure 2, "Minimum Shift N/A T2/L 10 No No 10 Staffing" & Attachment D, "WCGS T3/L3 Minimum Staffing for Emergencies" Nuclear Station Operator #7 REMP, Figure 2, "Minimum Shift N/A T2/L 11 No No 11 Staffing" & Attachment D, "WCGS T3/L4 Minimum Staffing for Emergencies" 137

Analysis 10 Aircraft Probable Threat On-Shift Staffing Analysis Report Revision1 This OSA is applicable to Analysis# .1Q as identified in Appendix A. (Aircraft Probable Threat)

TABLE 1 - On-shift Positions Augmentation Unanalyzed Role in TMS Line On-shift Position Emergency Plan Reference Elapsed Time Task?

Table#/Line# Required?

(min)

Nuclear Station Operator #8 REMP, Figure 2, "Minimum Shift N/A T2/L 12 No No 12 Staffing" & Attachment D, "WCGS T3/L5 Minimum Staffing for Emergencies" Chemistry Technician REMP, Figure 2, "Minimum Shift 90 No No 13 Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" Radiation Protection REMP, Figure 2, "Minimum Shift 90 No No 14 Technician #1 Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" Radiation Protection REMP, Figure 2, "Minimum Shift 90 No No 15 Technician #2 Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" Security REMP, Attachment D, "WCGS Minimum N/A T5/L 15 No No 16 Staffing for Emergencies"

• Based on functional analysis ENS communicator required for continuous NRC communications. This individual also fulfills the OSC communicator role.

138

Analysis 10 Aircraft Probable Threat On-Shift Staffing Analysis Report Revision1 TABLE 2 - Plant Operations & Safe Shutdown Analysis # .1Q One Unit - One Control Room Minimum Operations Crew Necessary to Implement AOPs and EOPs, or SAMGs if applicable Task Analysis Line Generic Title/Role On-Shift Position Controlling Method 1 Shift Manager Shift Manager Operations Training 2 Unit Supervisor Control Room Supervisor Operations Training 3 Shift Technical Advisor Shift Technical Advisor Operations Training 4 Reactor Operator #1 Reactor Operator #1 Operations Training 5 Reactor Operator #2 Reactor Operator #2 Operations Training Auxiliary Operator #1/2 Nuclear Station Operator Operations Training 6

1. 1/2 Auxiliary Operator #3 Nuclear Station Operator #3 Operations Training 7

(Site)

Auxiliary Operator #4 Nuclear Station Operator #4 Operations Training 8

(FBL)

Auxiliary Operator #5 Nuclear Station Operator #5 Operations Training 9

(Aux)

Auxiliary Operator #6 Nuclear Station Operator #6 Operations Training 10 (TB) 11 Auxiliary Operator #7 Nuclear Station Operator #7 Operations Training 12 Auxiliary Operator #8 Nuclear Station Operator #8 Operations Training Other (non-Operations) Personnel Necessary to Implement AOPs and EOPs, or SAMGs if applicable Task Analysis Line Generic Title/Role On-Shift Position Controlling Method 13 Mechanic N/A N/A 14 Electrician N/A N/A 15 l&C Technician N/A N/A 16 Other N/A N/A 139

Analysis 10 Aircraft Probable Threat On-Shift Staffing Analysis Report Revision1 TABLE 3 - Firefighting Analysis # 1Q Task Analysis Line Performed By Controlling Method Station Operator #4 (Fire Brigade Leader) - Fire Program Training and Drills 1

dispatched for pre-staging Station Operator #5 (Fire Brigade Member) Fire Program Training and Drills 2

- dispatched for pre-staging Station Operator #6 (Fire Brigade Member) Fire Program Training and Drills 3

- dispatched for pre-staging Station Operator #7 (Fire Brigade Member) Fire Program Training and Drills 4

- dispatched for pre-staging Station Operator #8 (Fire Brigade Member) Fire Program Training and Drills 5

- dispatched for pre-staging 140

Analysis 10 Aircraft Probable Threat On-Shift Staffing Analysis Report Revision1 On-Shift Staffing Analysis (Aircraft Probable Threat)

TABLE 4 - Radiation Protection & Chemistry & OSC/ENS Communicator Analysis # 1O Position Performance Time Period After Emergenc, Declaration (minutes)

Line Performing o- I 5- I 1o- I 15- I 20- I 25- I 30- I 35- I 40- I 45- I 50- 55- I 60- I 65- I 70- I 75- I 80- I 85-Function/Task 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 In-Plant Survey N/A - The performance of an in-plant survey is not necessary for initial implementation of the Emergency Plan and 1 On-Shift Position:

not required by any procedure. No radiological release for this event.

RP Tech #1 On-Site Survey N/A - The performance of an on-site survey is not necessary for initial implementation of the Emergency Plan and 2 On-Shift Position not required by any procedure. No radiological release for this event.

Personnel Monitoring N/A - Personnel can out-process from the Radiologically Controlled Area (RCA) using portal and small article 3

On-Shift Position: monitors. If necessary, site evacuees would be monitored after arrival of augmented ERO personnel.

RP Tech #1 Job Coverage On-Shift Position:

4 NIA-Will be dispersed to GOB 1st Floor to await further direction.

RP Tech #2 Offsite Radiological Assessment 5 N/A- Will be dispersed to GOB 1st Floor to await further direction. No radiological release for this event.

On-Shift Position:

Chemistry Tech Chemistry function/task #1 -

N/A- No sampling required until the Technical Support Center is staffed per AP 15C-003 (on hold pending 6 Sampling approval by NRC).

On-Shift Position:

Chemistry Tech

• Dose assessment passes directly to the EOF, so this function 1s not relieved at 90 minutes.

141

Analysis 10 Aircraft Probable Threat On-Shift Staffing Analysis Report Revision1 TABLE 4- Radiation Protection & Chemistry & OSC/ENS Communicator Analysis # .1Q Performance Time Period After Emergency Declaration minutes)

Position 10 Line Performing 0- 5- 15- 20- 25- 30- 35- 40- 45- 50- 55- 60- 65- 70- 75- 80 Function/Task 5 10

- 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 15 osc Communicator function/task-1- Initiate staffing of ERO 2- Emerg 7 Notifications NIA-Will be dispersed to GOB 1st Floor to await further direction. No radiological release for this event.

3- Notify State /

County 4- Notify NRC SRI

/Westar 5-ANI / INPO ENS Communicator function/task-8 Continuous NIA-Will be dispersed to GOB 1st Floor to await further direction. No radiological release for this event.

communication with NRC 142

Analysis 10 Aircraft Probable Threat On-Shift Staffing Analysis Report Revision1 TABLE 5- Emergency Plan Implementation Analysis # 1Q Task Analysis Line Function/Task On-Shift Position Controlling Method Declare the Emergency Shift Manager Operations Training and EP 1

Classification Level (ECL) Training/Drill Program Approve Offsite Protective Action NA for Alert N/A 2

Recommendations Approve content of State/local Shift Manager Operations Training and EP 3

notifications Training/Drill Program Approve extension to allowable Shift Manager Operations Training and EP 4

dose limits Training/Drill Program Notification and direction to on- Shift Manager Operations Training and EP 5 shift staff (e.g., to assemble, Training/Drill Program evacuate, etc.)

ERO notification Table 4- Nuclear Operations Training and EP 6 Station Operator #1 /2 Training/Drill Program Abbreviated NRC notification for Shift Manager Operations Training and EP 7 DST event Training/Drill Program Complete State/local notification Shift Manager Operations Training and EP 8 form Training/Drill Program Perform State/local notifications Table 4 - Nuclear Operations Training and EP 9 Station Operator #1/2 Training/Drill Program Complete NRC event notification Shift Manager Operations Training and EP 10 form Training/Drill Program Activate EROS Control Room Operations Training and EP 11 Supervisor Training/Drill Program Offsite radiological assessment N/A- Table 4- Chemistry Training and EP 12 Chemistry Tech Training/Drill Program Perform NRC notifications Table 4- Nuclear Operations Training and EP 13 Station Operator #1 /2 Training/Drill Program Perform other site-specific event Table 4 - Nuclear Operations Training and EP 14 notifications (e.g., INPO, ANI, Station Operator #1 /2 Training/Drill Program etc.)

Personnel accountability Security/ Security Training and EP 15 Table 4- Nuclear Training/Drill Program Station Operator #1 /2 143

Analysis 11 Station Blackout On-Shift Staffing Analysis Report Revision 1 Event Narrative #11 Station Blackout Station blackout is considered a "Beyond Design Basis" accident that is outside the scope of USAR § 15.0, "Accident Analysis." The regulatory basis for addressing "Loss of all alternating current power AKA "station blackout" is specified in 10 CFR 50.63 and described in NRC Reg Guide 1.155, "Station Blackout":

The term "station blackout" refers to the complete loss of alternating current electric power to the essential and nonessential switchgear buses in a nuclear power plant.

Station blackout therefore involves the loss of offsite power concurrent with turbine trip and failure of the onsite emergency ac power system, but not the loss of available ac power to buses fed by station batteries through inverters or the loss of power from "alternate ac sources. *~

The Reg Guide continues:

Because many safety systems required for reactor core decay heat removal and containment heat removal are dependent on ac power, the consequences of a station blackout could be severe. In the event of a station blackout, the capability to cool the reactor core would be dependent on the availability of systems that do not require ac power from the essential and nonessential switchgear buses and on the ability to restore ac power in a timely manner.

As a minimum, the following potential causes for loss of offsite power should be considered:

1. Grid under-voltage and collapse

2. Weather-induced power loss

3. Preferred power distribution system faults (includes such failures as the distribution system hardware, switching and maintenance errors, and lightning-induced faults) that could result in the loss of normal power to essential switchgear buses.

The evaluation should be performed assuming that the station blackout event occurs while the reactor is operating at 100% rated thermal power and has been at this power level for at least 100 days.

USAR § Appendix 8.3A addresses the station blackout capacity of the plant. The WCGS electrical power system reliability and environmental characteristics were evaluated in USAR § 8.3A.3.1, "AC Power Design Characteristic Group":

Group P1 includes those sites characterized by redundant and independent power sources that are considered less susceptible to loss as a result of plant-centered and weather-initiated events. Based upon NUMARC 87-00 guidance, Wolf Creek is determined to be in AC Power Design Characteristic Group, P1.

144

Analysis 11 Station Blackout On-Shift Staffing Analysis Report Revision 1 USAR § 8.3A.3.2, "Emergency AC Power Configuration Group," continues:

Wolf Creek is determined to be in the emergency AC power configuration group C (EAC Group CJ. After the likelihood of losing off-site power, the redundancy of the emergency AC power system is the next most important contributor to station blackout risk. With greater EAC system redundancy, the potential for station blackout diminishes, as does the likelihood of core damage. The importance of EAC redundancy is reflected through the use of four distinct EAC configuration groups. Those sites in group C have typical redundant and independent EAC sources to safe shutdown equipment.

The Wolf Creek designation of Group C is based on the following:

1) There are two emergency AC power supplies not credited as alternate AC power sources; and

2) One emergency AC power supply is necessary to operate safe shutdown equipment following a Joss of off-site power.

The conclusion was made that WCGS could sustain a station blackout condition for up to four (4) hours.

Document APF 06-002-01, Emergency Action Levels, identifies this as an EAL-6 / BASES-6, "Loss of Electrical Power/Assessment Capability." LEP/AC4 classifies the event as a Site Area Emergency. This scenario assumes the power is recovered within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. If it is determined that a station blackout would continue for more than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, the event would escalate to a General Emergency.

Consistent with assumptions described in Reg Guide 1.155, Appendix B, "Guidance Regarding System and Station Equipment Specifications," the initiating event and analysis is assumed to involve a station blackout, without the additional complications of a design-basis accident.

For this event, the operators start with procedure EMG E-0, "Reactor Trip or Safety Injection."

(A loss of all power will cause the control rods to drop automatically).

EMG E-0:

Steps #1 (R0#1) (verify reactor trip) and #2 (R0#2) (verify turbine trip) follow the normal path.

Step #3 (R0#1) involves checking the AC emergency busses. The normal path assumes at least one AC emergency bus is energized. Since this event involves a station blackout, the RNO path is followed instead. The emergency diesel generators fail to energize any AC emergency bus. The operator then goes to procedure EMG C-0, "Loss of All AC Power."

EMG C-0:

EMG C-0 starts with the caution "Accident conditions can cause higher than normal radiation levels. Radiation protection monitoring may be required while performing local operator actions."

145

Analysis 11 Station Blackout On-Shift Staffing Analysis Report Revision 1 Steps #1 (R0#1) and #2 (R0#2) are duplicative of the above EMG E-0 steps #1 and #2, and were added to this procedure in case an operator (seeing the loss of power), jumped to EMG C-O directly rather than going through EMG E-0 first.

Step #3 (R0#2) provides a cautionary remark on indications of potential steam leakby powering the turbine and requests the operator verify the generator and exciter breakers are open, to avoid the generator being "motored." The RNO path lists manual operations, but no local operations were identified.

Step #4 (R0#1/NS0#5) involves checking if the RCS is isolated. The last sub-step requires an operator to locally close the RCS and pressurizer sample line isolation valves at 3 locations in the aux building.

Steps #5 - #7 - the RNO paths have manual operations, but no local operations were identified.

(R0#2) Bus fault clearance can be performed by NSO if required.

Step #8 evaluates the availability of EDG's. (R0#1/NS0#6)

Step #9 involves manually starting both diesel generators from the control room. The RNO path goes to procedure OFN KJ-032, "Local Emergency Diesel Startup,") if starting the diesels from the control room fails. EMG C-0 steps continue concurrently with OFN KJ-032. (R0#2/NS0#6)

OFN KJ-032:

An operator (NS0#6) attempts to start both diesel generators locally. (For this analysis, "Fire in the Control Room," is outside the scope of the event).

The procedure outlines manual operations (NS0#6) to try to start emergency diesel generator A using a mallet switch, then by trying a local start pushbutton, then by trying an air start valve.

The last RNO step, if emergency diesel generator A fails to start, is to notify mechanical maintenance with a repair request. The same chain of events is followed for attempts to start emergency diesel generator B. Repair will occur when augmented staff arrives.

For this analysis, it's assumed that neither emergency diesel generator starts. Mechanical maintenance is contacted to repair both of the generators. Mitigating actions will continue and repair will occur when augmented staff arrives. The operator jumps back to procedure EMG C-

.Q, Step #10 which is already in progress.

EMG C-0:

Step #10 involves ensuring electrical power to at least one emergency bus. Based on the scenario, the RNO path is followed. Any emergency diesel generators that had been successfully started, but weren't able to be loaded onto a bus are stopped. The RNO path continues, with an operator trying to energize affected AC busses from any available power supply, going with procedure OFN NB-030, "Loss of AC Emergency Bus NB01 (NB02)," while continuing with the current procedure. (R0#1/NS0#6) 146

Analysis 11 Station Blackout On-Shift Staffing Analysis Report Revision 1 OFN NB-030:

Step #1, the RNO path, directs anyone entering into this procedure from EMG C-0 to jump immediately to Attachment A, Step #A14 (for NB01) or Attachment B, step #814 (for NB02).

(Extra RO/NSO)

Step #A14 checks the bus lockout relay. The RNO path acts to shut down the emergency diesel generators if they had started but were unable to load to the NE01 and NE02 busses.

(Extra RO/NSO)

Step #A 15, the RNO path, assumes the emergency diesel generators are not running, which is consistent with the scenario. There are attempts to energize NB01 from a non-diesel source, XNB01 or XNB02 (Engineered Safety Features transformers). There are also discussions on trying to start emergency diesel generator "A", following the same procedure as was previously discussed in EMG C-0, Step #8; those actions are therefore assumed to already be in progress.

(Extra RO/NSO)

Step #A 16 checks if NB01 is energized from NE01. The RNO path assumes that NB01 is NOT energized (emergency diesel generator A hasn't started). There are also actions to reset the anti-pumping circuit, by ensuring the NB01 normal, alternate and emergency supply breakers are properly set. Given the station blackout scenario, NB01 is assumed not energized. (Extra RO/NSO)

Step #A 17 has steps to manually energize the NB01 bus; the RNO path is followed and the emergency diesel generators are assumed to not be running. (Extra RO/NSO)

Step #A 18 starts a search for any available offsite power. (See USAR § 8.2, "Offsite Power Systems," for a description of the available ac power sources). Following the RNO path that the ESF transformer is not energized by offsite power, the event assumes that the SL? bus (13.8 kV) is not energized either. The next RNO sub-step, #A 18(b)(2) is to perform procedure SYS SY-120, "Sharpe Diesel Operation and Alignment to Site," to energize XNB01. (Extra RO/NSO)

SYS SY-120:

SYS SY-120 provides the instructions to "black-start" the Sharpe Diesel to provide power to the Wolf Creek Switchyard. Note that the Sharpe Station can only supply one NB bus. NB01 is preferred over NB02. (Extra RO/NSO)

For the purpose of this analysis, per Reg Guide 1.155, § B, "Discussion," and consistent with the 10 CFR 50.2 definitions for "Alternate ac source" and "Station blackout," the operations of SYS SY-120 are assumed successful.

• The SYS SY-120 procedure starts with step 6.1, "Sharpe Diesel Generator Availability Checks,"

which requires local operations in the Sharpe sub-station house. The substation north of Sharpe Station is checked for items that could degrade the ability of the Sharpe Station to provide power to Wolf Creek. (Extra RO/NSO) 147

Analysis 11 Station Blackout On-Shift Staffing Analysis Report Revision 1 Step 6.2 involves "Starting the Diesels." The 69 kV bus breakers are opened. Also, Westar and Lyon Coffey Electric Coop are directed to take actions. The remaining actions are performed in the Sharpe sub-station house. Operations include starting the Sharpe diesel and closing feeder breakers. (R0#1/NS0#3)

Step 6.3 involves "Aligning Sharpe Diesels to NB01 / NB02." Note that Attachment C of OFN NB-030 has nearly identical steps listed, but since the operator is already in the switchyard, this procedure's series of steps should be followed when energizing the bus. Breakers are manipulated in the switchyard. Bus-side disconnects using hot sticks are performed by qualified individuals. Also, Lyon Coffey Electric Coop is directed to take actions. Various breakers continue to be manipulated as an NB bus is supplied (NB01 is preferred over NB02).

(R0#1/NS0#3)

After a 2-minute delay, the operator jumps back to procedure OFN NB-030.

OFN NB-030:

Continuing with step #A 18, using the RNO path, the operator goes to the next step. (R0#1)

Step #A 19 re-energizes the NB01 bus from the offsite power supply. (If that fails, the RNO path is to re-energize NB02). Based on the scenario, re-energizing NB01 is assumed successful.

The procedure jumps to step #A24. (R0#1)

• Step #A24 has a check that EMG C-0, "Loss of All AC Power," is not in effect. The RNO path has a provision that if bus NB02 is not energized (it isn't; the Sharpe Diesel can energize either NB01 or NB02, but not both simultaneously), the RNO path sends the operator (R0#1) to step

1. 814 to try to energize NB02.

Step #814 checks the NB02 bus lockout relays. (R0#1)

Step #815 checks for a running emergency diesel generator NE02. Based on the scenario, the RNO path is followed and NE02 cannot be started from the control room. Procedure OFN KJ-032, local emergency diesel startup would normally be followed, however this step has already been executed using EMG C-0, Step #8. (R0#1/NS0#1/2) The next action jumps to step #818.

Step #818 checks to see if a normal offsite power supply is available. Per the scenario, it is not and the RNO path is followed. (R0#1) The next action jumps to step #820.

Step #820 checks for alternate offsite power. (R0#1) A sub-step checks that XNB01 is energized from offsite power. The RNO path jumps to Attachment C, "Placing XNB01 on SL?,"

however as noted above, Step #6.3 of procedure SYS SY-120 has already executed this step.

Continue to step #821.

Step #821 checks for the ability to energize NB02. Based on the RNO path and the constraint that the Sharpe diesel can energize either NB01 or NB02, but not both simultaneously, the actions for this procedure "loops" steps #815 through #823 until NB02 can be energized (either using offsite power or by getting emergency diesel generator NE02 started and successfully loaded to the bus). (R0#1/NS0#1/2) 148

Analysis 11 Station Blackout On-Shift Staffing Analysis Report Revision 1 Step #824 is to check that EMG C-0, "Loss of All AC Power" is not in effect. The RNO path is to return to the calling procedure and step in effect. Based on the scenario, the operator jumps to procedure EMG C-0, step #9, which was already in progress. As the basis document notes, "if power is available to only one train, the operator should initiate attempts to restore power to the other train while continuing in the procedure to deal with the emergency condition." (R0#1)

EMG C-0:

Based on Reg Guide 1.155, no complicating 'design basis events' have occurred concurrently with the station blackout, so any RNO paths involving non-blackout-related equipment malfunctions, fuel damage, etc., or other situations that could place the plant into a design-basis or beyond-design-basis accident are outside the scope of this scenario.

Step #11 checks that at least one NB bus is energized. Here the RNO path is followed, based on the emergency busses NB01 ad NB02 not being energized yet. (R0#1/NS0#4) The actions jump to step #14.

Steps #15 has the operator place the ECCS pump switches and other equipment in the "pull to lock" position, in order to defeat automatic loading of large loads on the AC emergency bus.

(R0#2/NS0#5)

Step #16 has operators locally close valves to isolate the reactor coolant pump seals.

(R0#2/NS0#5)

Step #17 checks if AC power can be restored within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. (STA/NS0#7/NS0#8)

Step #18 evaluates whether the TSC diesel and/or a diesel driven fire pump should be started.

(NS0#3) The bus supplying the motor driven fire pump is checked to see if it is energized.

Another check is made to determine whether the permanent diesel driven fire pump is running.

The RNO path regarding the permanent diesel driven fire pump is to place a temporary diesel driven fire pump in-service per SYS FP-290, "Temporary Fire Pump Operations." For this particular scenario, the permanent diesel driven fire pump is assumed to be properly running.

This event assumes loss of offsite power, so the site watch (NS0#3) is directed to start the TSC diesel using procedure STN KAT-001, "Technical Support Diesel Generator Operation."

STN KA T-001:

An operator locally performs the prerequisite checks listed in§ 7, "Prerequisites." (NS0#3)

An operator locally performs § 8.1.1, "Testing Installed TSC Diesel Generator" OR § 8.2.1, "Testing Temporary TSC Diesel Generator." (NS0#3)

An operator locally performs § 8.1.2, "Placing TSC Diesel Generator In-service" OR § 8.2.2, "Placing Temporary TSC Diesel Generator In-service." (NS0#3)

Note that if the TSC Diesel Generator runs for more than an hour, then refer to Attachment 8, "TSC Diesel Generator Reading,", or if applicable, Attachment C, "TSC Temporary Diesel Generator Readings," to conduct hourly checks on the diesel generator in question.

149

Analysis 11 Station Blackout On-Shift Staffing Analysis Report Revision 1 EMG C-0 (continued):

Step #19 involves operators (NS0#6) establishing emergency ventilation to provide emergency cooling to vital plant equipment. An operator is dispatched to locally open doors for the Turbine Driven Auxiliary Feedwater Pump Room using Attachment A, "Door Alignment in Auxiliary Feedwater Corridor for Loss of All AC." (Attachment A identifies specific locations of the doors and is a single page long). An operator also opens cabinet doors and control building doors, using Attachment B, "Door Alignment in Control Room for Loss of All AC" (Attachment B identifies equipment cabinet and control building door locations and is 3 pages long). Security will be performing compensatory measures.

Step #20 checks whether the safety injection (SI) accumulator tank outlet isolation valves are open. (R0#2)

Step #21 checks to see if the condensate storage tank (CST) is isolated from the hotwell. The RNO path has an operator locally close the isolation valves. (R0#2/NS0#6)

Step #22 checks to ensure the main steam line isolation valves, main steam line isolation bypass valves and main steam line low point drain valves are closed. The RNO path for isolating the bypass valves is having an operator locally closing the valves. The RNO path for isolating the drain valves is to have an operator locally close the valves. (R0#2/NS0#5)

Step #23 verifies feedwater isolation. The RNO path for most of the sub-steps is manually closing the valves. Sub.:.step (e) RNO path has a further step to have an operator locally isolate the main feedwater chemical injection valves. (R0#2/NS0#5)

Step #24 verifies blowdown isolation on all SIG's. The RNO path has the operator try to close the valves manually. If that fails, an operator locally isolates the lines. (R0#2/NS0#5)

Step #25 checks to see whether the SIG's are faulted. The scenario assumes the SIGs are intact, as there is no design-basis or beyond-design-basis accident to complicate matters.

(R0#2)

Step #26 checks to see whether the SIG tubes are intact. Radiation protection is directed to survey steam lines in Area 5 of the Auxiliary building, and to locally check SIG steam line radiation monitors and turbine driven auxiliary feedwater pump exhaust levels. The normal path is followed ("no complicating design basis events.") (R0#2/RP#2)

Step #27 checks for intact SIG levels. The normal path is followed for this scenario. (R0#2)

Step #28 has operators (R0#2/NS0#4) locally shed non-essential AC and DC loads, using Attachment C, "AC and DC Load Shedding." This step also discusses disconnecting the NK batteries from the bus when the voltage drops below 105 VDC. Design capacity of the Class 1E batteries is 240 minutes, so this voltage drop is not expected to be an issue during the first hour of the event.

Step #29 to depressurize the main generator is assumed conducted after the first hour.

Step #30 checks the condensate storage tank level. Thus, the normal path is followed. (R0#2) 150

Analysis 11 Station Blackout On-Shift Staffing Analysis Report Revision 1 Steps #31 and #32 monitor the RCS inventory and checks if intact S/G~s should be depressurized to 310 psig. The scenario assumes a normal cooldown, so the operator follows the normal path. No local operations have been identified for either step. (R0#2)

Step #33 checks if reactor is subcritical. (R0#1)

Step #34 checks if S/G depressurization should be stopped. (R0#1)

Step #35 checks for SI signal actuation. The scenario assumes the RNO path this early in the event, given an assumed cooldown rate no greater than 100 °F/hr. (R0#1)

Step #36 resets SI. (R0#1)

Step #37 verifies containment isolation phase A. This step has manual operator actions.

(R0#1/NS0#5)

Step #38 verifies containment purge isolation. (R0#2)

Step #39 verifies containment isolation phase B - not required. (R0#2)

Step #40 checks core temperature < 1200°F (this tests for a severe accident). The scenario assumes a station blackout without the additional complications of a design-basis or beyond design-basis accident, per Reg Guide 1.555. The normal path is followed. (R0#1)

Step #41 checks plant conditions. RNO path directs to go to Step #43. (R0#2)

Step #43 monitors the spent fuel pool parameters and is assumed conducted after the first hour.

(R0#2)

Step #44 checks to see if emergency AC power is restored yet. The scenario assumes a station blackout, so the RNO path is followed. Sub-part (a) of the RNO path includes operator steps to check the status of local actions, and to locally check the boric acid tank (BAT) temperatures. (R0#2/NS0#5)

Operator loops back to step #25, "Check if S/Gs are not Faulted" and continues the loop until the Step #44 question, "Check if AC Emergency Power is Restored" can be answered with a normal path. (R0#1/R0#2/CRS)

Termination path (expected actions are beyond the first 90 minutes of the event):

EMG C-0 Step #30 has operators check CST to AFP suction header pressure. The RNO path has operators locally close valves to the condensate store tank, acquire appropriate tooling from an emergency locker, and connect a fire hose. Once the fire hose is connected, operator ensures diesel driven pump is. running, locally operate valves and pressurize the fire hose.

(R0#2/NS0#3/NS0#5/NS0#6) 151

Analysis 11 Station Blackout On-Shift Staffing Analysis Report Revision 1 Step #43 checks the spent fuel pool level. The normal path is assumed to be followed at this stage of the scenario, since this procedure's Figure 1, "SFP Time to Boil" graph shows boiling doesn't start to occur until at least 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> into the event. (NS0#5)

The longer-term closure to this event is assumed to involve executing Steps #45 to #54 of this procedure. Operator actions specifically include, stabilizing S/G pressures, re-setting safety injection to permit manual loading of equipment on the AC emergency bus, loading up equipment on energized AC emergency busses (once the busses are restored), re-energizing DC loads and battery chargers, restoring power to Security inverters and verifying the Red Train and Yellow Train ESW operations.

At the end of step #54, sub-step (d), the operator is assumed to ultimately jump to procedure EMG CS-01, "Loss of All AC Power Recovery Without SI Required," step #1, to close out the event.

152

Analysis 11 Station Blackout On-Shift Staffing Analysis Report Revision 1 This OSA is applicable to Analysis# 11 as identified in Appendix A. (Station Blackout)

TABLE 1 - On-shift Positions Augmentation Unanalyzed Role in TMS Line On-shift Position Emergency Plan Reference Elapsed Time Task?

Table#/Line# Required?

(min)

Shift Manager REMP, Figure 2, "Minimum Shift NA T2/L 1 No No Staffing" & Attachment D, "WCGS TS/L 1 Minimum Staffing for Emergencies" TS/L2 TS/L3 1 TS/L4 TS/LS TS/L8 TS/L 10 Shift Technical Advisor REMP, Figure 2, "Minimum Shift NA T2/L3 No No 2 Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" Control Room Supervisor REMP, Figure 2, "Minimum Shift NA T2/L2 No No 3 Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" Reactor Operator #1 REMP, Figure 2, "Minimum Shift NA T2/L4 No No 4 Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" Reactor Operator #2 REMP, Figure 2, "Minimum Shift NA T2/LS No No s Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" 153

Analysis 11 Station Blackout On-Shift Staffing Analysis Report Revision 1 This OSA is applicable to Analysis # 11 as identified in Appendix A. (Station Blackout)

TABLE 1 -On-shift Positions Augmentation Unanalyzed Role in TMS Line On-shift Position Emergency Plan Reference Elapsed Time Task?

Table#/Line# Required?

(min)

Nuclear Station Operator REMP, Figure 2, "Minimum Shift NA T2/L6 No Yes*

1. 1/2 Staffing" & Attachment D, "WCGS T5/L6 Minimum Staffing for Emergencies" T5/L9 6 T5/L 11 T5/L 13*

T5/L 14 T5/L 15 Nuclear Station Operator #3 REMP, Figure 2, "Minimum Shift NA T2/L7 No No 7 Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" Nuclear Station Operator #4 REMP, Figure 2, "Minimum Shift NA T2/L8 No No 8 Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" Nuclear Station Operator #5 REMP, Figure 2, "Minimum Shift NA T2/L9 No No 9 Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" Nuclear Station Operator #6 REMP, Figure 2, "Minimum Shift NA T2/L 10 No No 10 Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" 154

Analysis 11 Station Blackout On-Shift Staffing Analysis Report Revision 1 This OSA is applicable to Analysis # 11 as identified in Appendix A. (Station Blackout)

TABLE 1 - On-shift Positions Augmentation Unanalyzed Role in

• TMS Line On-shift Position Emergency Plan Reference Elapsed Time Task?

Table#/Line# Required?

(min)

Nuclear Station Operator #7 REMP, Figure 2, "Minimum Shift NA T2/L 11 No No 11 Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" Nuclear Station Operator #8 REMP, Figure 2, "Minimum Shift NA T2/L 12 No No 12 Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" Chemistry Technician REMP, Figure 2, "Minimum Shift 90 T4/L5* No No 13 Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" Radiation Protection REMP, Figure 2, "Minimum Shift 90 T4/L3 No No 14 Technician #1 Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" Radiation Protection REMP, Figure 2, "Minimum Shift 90 T4/L 1 No No 15 Technician #2 Staffing" & Attachment D, "WCGS T4/L4 Minimum Staffing for Emergencies" Security REMP, Attachment D, "WCGS Minimum N/A T5/L 15 No No 16 Staffing for Emergencies"

• Based on functional analysis ENS communicator required for continuous NRC communications. This individual also fulfills the OSC communicator role.

155

Analysis 11 Station Blackout On-Shift Staffing Analysis Report Revision 1 TABLE 2 - Plant Operations & Safe Shutdown Analysis # 11 One Unit - One Control Room Minimum Operations Crew Necessary to Implement AOPs and EOPs, or SAMGs if applicable Task Analysis Line Generic Title/Role On-Shift Position Controlling Method 1 Shift Manager Shift Manager Operations Training 2 Unit Supervisor Control Room Supervisor Operations Training 3 Shift Technical Advisor Shift Technical Advisor Operations Training 4 Reactor Operator #1 Reactor Operator #1 Operations Training 5 Reactor Operator #2 Reactor Operator #2 Operations Training Auxiliary Operator #1/2 Nuclear Station Operator Operations Training 6

1. 1/2 Auxiliary Operator #3 Nuclear Station Operator #3 Operations Training 7

(Site)

Auxiliary Operator #4 Nuclear Station Operator #4 Operations Training 8

(FBL)

Auxiliary Operator #5 Nuclear Station Operator #5 Operations Training 9

(aux)

Auxiliary Operator #6 Nuclear Station Operator #6 Operations Training 10 (TB) 11 Auxiliary Operator #7 Nuclear Station Operator #7 Operations Training 12 Auxiliary Operator #8 Nuclear Station Operator #8 Operations Training Other (non-Operations) Personnel Necessary to Implement AOPs and EOPs, or SAMGs if applicable Task Analysis Line Generic Title/Role On-Shift Position Controlling Method 13 Mechanic N/A N/A 14 Electrician N/A NIA 15 l&C Technician N/A N/A 16 Other N/A N/A 156

Analysis 11 Station Blackout On-Shift Staffing Analysis Report Revision 1 TABLE 3 - Firefighting Analysis # 11 Task Analysis Line Performed By Controlling Method NIA- there is no fire associated with this NIA 1

event.

2 NIA NIA 3 NIA NIA 4 NIA NIA 5 NIA NIA 157

Analysis 11 Station Blackout On-Shift Staffing Analysis Report Revision 1 TABLE 4- Radiation Protection & Chemistry & ENS/OSC Communicator Analysis # 11 Performance Time Period After EmerJency Declaration (minutes)

Line Position Performing Function/Task 0- 5- 10- 15 25 35 45 55 65 75- 80- 85-5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 In-Plant Survey 1 On-Shift Position: RP Tech #1 X X X X X Main Steam Line surveys On-Site Survey N/A- The performance of an on-site survey is not necessary for initial implementation of the Emergency 2 On-Shift Position Plan and not required by any procedure. No radiological release for this event.

Personnel Monitoring On-Shift Position:

3 X X X X X X X X X X X X X CR RP Tech #1 Job Coverage On-Shift Position:

4 X X X X X X X X X X X X X X X X X X RP Tech #2 Offsite Radiological Assessment*

5 X X X X X X X X X X X X X X X X X X On-Shift Position: Chemistry Tech Chemistry function/task #1 -

Sampling No sampling required until the Technical Support Center is staffed per AP 15C-003 (on hold pending 6

On-Shift Position: Chemistry Tech approval by NRC).

• Dose assessment passes directly to the EOF, so this function is not relieved at 90 minutes.

158

Analysis 11 Station Blackout On-Shift Staffing Analysis Report Revision 1 TABLE 4- Radiation Protection & Chemistry & ENS/OSC Communicator Analysis # 11 Performance Time Period After Emer1 ency Declaration (minutes)

Position Performing Line 0- 5- 10- 15 25 35 45 55 65 75 85-Function/Task 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 OSC Communicator function/task-1- Initiate staffing of ERO 2- Emerg Notifications X X X X X X 7 3- Notify State/ County 4- Notify NRC SRI / Westar X 5-ANI / INPO X ENS Communicator function/task-Continuous communication with 8 NRC X X X X X X X X X X 159

Analysis 11 Station Blackout On-Shift Staffing Analysis Report Revision 1 TABLE 5 - Emergency Plan Implementation Analysis # .11 Task Analysis Line Function/Task On-Shift Position Controlling Method Declare the Emergency Shift Manager Operations Training and EP 1

Classification Level (ECL) Training/Drill Program Approve Offsite Protective Action Shift Manager Operations Training and EP 2

Recommendations Training/Drill Program Approve content of State/local Shift Manager Operations Training and EP 3

notifications Training/Drill Program Approve extension to allowable Shift Manager Operations Training and EP 4

dose limits Training/Drill Program Notification and direction to on- Shift Manager Operations Training and EP 5 shift staff (e.g., to assemble, Training/Drill Program evacuate, etc.)

ERO notification Table 4 - Nuclear Operations Training and EP 6 Station Operator #1/2 Training/Drill Program Abbreviated NRC notification for N/A for this event NIA 7 DBT event Complete State/local notification Shift Manager Operations Training and EP 8 form Training/Drill Program Perform State/local notifications Table 4 - Nuclear Operations Training and EP 9 Station Operator #1 /2 Training/Drill Program Complete NRC event notification Shift Manager Operations Training and EP 10 form Training/Drill Program Activate EROS Table 4 - Nuclear Operations Training and EP 11 Station Operator #1 /2 Training/Drill Program Offsite radiological assessment N/A- Table 4 - Chemistry Training and EP 12 Chemistry Tech Training/Drill Program Perform NRC notifications Table 4 - Nuclear Operations Training and EP 13 Station Operator #1/2 Training/Drill Program Perform other site-specific event Table 4 - Nuclear Operations Training and EP 14 notifications (e.g., INPO, ANI, Station Operator #1 /2 Training/Drill Program etc.)

Personnel accountability Security/ Security Training and EP 15 Table 4 - Nuclear Training/Drill Program Station Operator #1 /2 160

Analysis 12 Fire with Control Room Evacuation and Remote Shutdown On-Shift Staffing Analysis Report Revision 1 Event Narrative #12 Fire with Control Room Evacuation And Remote Shutdown This is a scenario as categorized by the NRG, which is outside the scope of the classical design basis accidents as defined by the USAR.

As noted in USAR § 1.2.6, "Plant Instrumentation and Control Systems":

Additional controls at appropriate locations outside the control room (in particular, an auxiliary shutdown panel in the auxiliary building) ensure the capability of reaching and maintaining a post-accident or post-fire shutdown condition in the unlikely event that the control room becomes uninhabitable.

USAR Table 7.4-1.1, "Auxiliary Shutdown Panel Controls and Monitoring Instruments," list the controls and monitoring indications available at the plant. USAR Table 7.4-1.2, "Controls at Switchgear Motor Control Centers, and Other Locations," identifies other locations available to support remote shutdown of the plant.

USAR §7.4.6 discusses the problem of "Safe Shutdown from Outside the Control Room,"

including identifying the locations and capabilities of the remote shutdown panels.

If temporary evacuation of the control room is required because of some abnormal plant condition, the operators can establish and maintain the plant in a hot standby condition from outside the control room through the use of controls located at the auxiliary shutdown panel, at the switchgear, or at motor control centers, and other local stations.

Hot standby is a stable plant condition, automatically reached following plant shutdown.

The hot standby condition can be maintained safely for an extended period of time. In the unlikely event that access to the control room is restricted, the plant can be safely kept at a hot standby, until the control room can be reentered, by the use of the essential monitoring indicators and the controls listed in Tables 7.4-1.1 and 7.4-1.2.

The auxiliary shutdown panel room is located in the northeast comer of the auxiliary building one level below the control room at Elevation 2026. There are two distinct auxiliary shutdown panels at this location; one panel is associated with instrumentation and control circuits used for controlling safe shutdown equipment in train A, and the other panel is associated with instrumentation and control circuits used for controlling safe shutdown equipment in train B. Both panels are electrically separated and are associated with the same safety-grade circuits that serve their respective trains.

The auxiliary shutdown panel design also provides electrical isolation of instrumentation and control circuits for the equipment controlled between train B auxiliary shutdown panel and the control room. Switches are provided on B auxiliary shutdown panel to isolate and remove control from the control room for the train B safe shutdown

• equipment necessary to take the plant to and maintain the plant in a safe hot standby condition independent of the control room. This capability is assured in the event a postulated fire causes damage in the control room and subsequent evacuation of the operators.

161

Analysis 12 Fire with Control Room Evacuation and Remote Shutdown On-Shift Staffing Analysis Report Revision 1 USAR Table 9.5.2-1, "Communications Systems in Plant Areas Required to be Manned for Post Fire Safe Shutdown Following Control Room Evacuation," lists locations around the plant and communications equipment available for responding to this category of event.

Document APF 06-002-01, Emergency Action Levels, identifies this as an EAL-9 / BASES-9, "Loss of Plant Control/Security Compromise." LPC/SC5 classifies the event as an Alert.

Should establishing control at the auxiliary shutdown panel require more than 15 minutes, LPC/SC6 escalates the event to a Site Area Emergency.

Operator actions start with procedure OFN RP-017, "Control Room Evacuation."

OFN RP-017:

The procedure starts with a note prefacing Step #1:

The fire brigade is dedicated to fighting the Control Room fire. They are not responsible for performing any of the operator actions described in this procedure.

Step #1 - The scenario evaluated here postulates that the control room has a fire and that loss of the control room controls is imminent. The scenario is not so drastic as to assume an "instant evacuation" of the control room is required, so the normal path is followed. (SM)

Step #2 has the operator trip the reactor. (R0#1)

Step #3 has the operator close MSIVs. (R0#2)

R0#2 and STA are now available to perform OFN Auxiliary and Turbine Building actions.

Step #4 on the normal path has an operator make an announcement over the Gai-tronics that the control room is being evacuated due to the fire. The fire brigade is called out. Fire brigade response actions are detailed in procedure AP 10-106, "Fire Preplans." (SM)

At this point, the plant is at an ALERT. The control room is being evacuated. Should the operators be unable to establish control of the plant at the remote shutdown panel within 15 minutes, the plant will escalate this to a SITE AREA EMERGENCY.

Step #4.d.2 has the offsite communicator make pre-approved ALERT or SITE AREA EMERGENCY notification, as appropriate, for the plant conditions. (NS0#1/2)

Step #5 has the CRS obtain dosimetry and protective equipment from the control room emergency locker. CAS personnel receive directions, various breakers are switched off, a radio is picked up, and Attachment A, "SRO Actions,", is entered.

Step #6.A has the operator performing turbine building actions, proceed to PA01/PA02 and perform actions of ATTACHMENT B, TURBINE BUILDING ACTIONS. (STA)

Step #6.B has the reactor operator proceed to NK switchgear rooms and perform actions of ATTACHMENT C, REACTOR OPERATOR ACTIONS. (R0#1) 162

Analysis 12 Fire with Control Room Evacuation and Remote Shutdown On-Shift Staffing Analysis Report Revision 1 Step #6.C has the operator performing aux building actions, proceed to 2026' RDMG set room and perform actions of ATTACHMENT D, AUXILIARY BUILDING ACTIONS. (R0#2)

Step #6.D has the offsite communicator proceed to TSC. (NS0#1/2)

Step #6.E has the ENS communicator proceed to TSC and establish and maintain continuous communications with the NRC via the ENS emergency telecommunications system (ETS) telephone. (NS0#1/2)

Step #6.F has operator closing BN HV-8812A, RWST to RHR PUMP A SUCTION ISOLATION VALVE proceed to ESF switchgear room 8 and perform actions of ATTACHMENT E, BN HV-8812A AND AUX FEEDWATER VALVE CLOSURE. (Extra RO/NSO)

If the supply of operators is constrained, the steps in Attachment F, "Actions to Protect Train A Equipment" are deferred until all of the steps in Attachments A through E are complete. If there are available personnel, the steps in Attachment F may be executed concurrently with Attachments A through E. (STA)

Attachment A: SRO Actions Step #A 1 has the CRS place several control rooni isolation switches to isolate.

Step #A2 has the CRS close the SIG A and SIG C ARVs.

Step #A3 has the CRS check to see if the RCS cold leg temperatures are stable at or trending to 561 °F. The RNO path has an operator locally dump steam using the SIG 8 and D ARVs, until the temperature is less than 561 °F and decreasing.

Steps #A4 through #A6 checks that the CST to MD-AFW 8 is open, the AFW valves are lined up, and that the reactor operator is notified that the Motor Driven AFW Pump 8 valve lineup steps are complete. (CRS/R0#1)

Step #A7 has the CRS assess the stability of plant conditions. Specific checks are conducted to verify that the RCS pressure, pressurizer level, SIG wide range levels and RCS cold leg temperatures are all within acceptable ranges. The RNO path for sub-step (b) tasks the operator performing turbine-building actions (STA) to locally throttle the boron injection tank (BIT) outlet valve as needed.

Step #AB checks that the ESW to TDAFW pump isolation valve is closed. (CRS)

Step #A9, has the CRS contacts the operator (STA) performing Attachment 8, "Turbine Building Operations," to verify an open valve .. The RNO path shows manual operations as needed.

Steps #A 10 and #A 11 has the CRS place the turbine driven aux feedwater pump governor control to local and verifies the aux feedwater valve line-up for the turbine-driven aux feedwater pump.

163

Analysis 12 Fire with Control Room Evacuation and Remote Shutdown On-Shift Staffing Analysis Report Revision 1 Steps #A12 through #A14 has the CRS ensure the Loop 8 steam line isolation to the AFP turbine is open, the Loop C steam isolation is closed, and the turbine mechanical trip/throttle valve is open.

Step #A 15 has the CRS contact the operator (Extra ROINSO) performing Attachment E, "8N HV-8812A and Aux Feedwater Valve Closure," to ensure the AFW valves are closed. This is a "hold point" before continuing on with step #A 16.

Step #A 16 has the CRS establish turbine driven AFW pump control.

Step #A 17 has the CRS align alternative AFW pump water source, when CST level is less than 14% or local CST level is less than 6'5". (The RNO path has the rest of this step conducted after those levels are achieved, and otherwise continues with step #A 18).

Step #A18 directs an available operator to perform Attachment F, "Actions to Protect Train A Equipment,", if that hasn't already been started earlier. (CRS/R0#1)

Step #A 19 has the SM/CRS check plant cooldown status. The normal path assumes that cooling the plant down from "Hot Standby" to "Cold Shutdown" is not desired. For this scenario, the RNO path is taken instead. The scenario assumes that if the control room is (or was) on fire, WCGS is not going to be back at power until after the NRC has investigated the incident.

The CRS then jumps to procedure OFN RP-17A, "Hot Standby to Cold Shutdown From Outside the Control Room Due to Fire," when TSC augmentation is complete.

Attachment B: Turbine Building Actions Step #81 has an operator locally trip the RCPs. (STA)

Steps #82 and #83 have the operator proceed to 2033' turbine to obtain a copy of the procedure, a radio, a flashlight, and dosimetry from the emergency locker. (STA)

Steps #84 and #85 have the operator open breakers for DC control power to PA01 and PA02.

(STA)

Step #86 has the operator ensure the RCP breakers are tripped. (STA)

Step 87 verifies with CRS at ASP that Step #5(c), "placing breakers on NG03C are off is completed. This is a "hold point" before continuing with Step #87(b). The operator then ensures the CST to turbine driven AFP suction isolation valve is open. (STA)

Step #88 has the operator go through a hatch, descend a ladder, and enter the RCA. (STA)

Step #89 has the operator close the CCP to regen HX valves in the NCP room. (STA)

Step #81 O has the operator isolate the CCW from RCP thermal barriers in the north mechanical penetration room. There is a statement echoing step #87 that the operator needs to verify with the SRO that step 5(c), "placing breakers on NG03C are off' is completed. This is a "hold point" before continuing with step #81 O(b). The operator then ensures that EG HV-61 is ensured 164

Analysis 12 Fire with Control Room Evacuation and Remote Shutdown On-Shift Staffing Analysis Report Revision 1 closed. The operator then verifies with the operator at the aux building that Attachment D, step 010 is complete. This is a "hold point" before continuing with step #81 O(d), where EG HV-133 is ensured closed. (STA)

Step #811 has the operator locally close valves to isolate the RCP seals in Aux Building Filter Alley. The operator then informs the reactor operator that Steps 810 and 811 are done. (STA)

Step #812 has the operator fail the MSIV bypass valves closed at RP209, across from the north mechanical penetration room. (STA)

Step #813 has the operator verify the BIT isolation valves open. Sub-step (a) has the operator verify with person performing aux building actions that Attachment D, steps 04 through 05 are complete. This is a "hold point" before continuing with step B13(b). (STA)

The operator then goes to the north piping penetration room to locally close a BIT outlet valve and locally throttle open a BIT outlet isolation valve. The CRS is notified that the BIT is lined up for injection, and then EM HV-8801 B is throttled as directed by the CRS to control the pressurizer level. (STA)

• Step #814 has the CRS contacted at the ASP for further direction. (STA)

Attachment C: Reactor Operator Actions Step #C1 has the operator exit the control room, has the operator ensure that at least one control room outer door is closed and then has the operator proceed to the NK switchgear rooms. (R0#1)

Step #C2 has the operator turn off a series of NK breakers. (R0#1)

Steps #C3 and #C4 have the operator proceed to the NB02 switchgear room to obtain a copy of the OFN RP-017 procedure, a radio and flashlight from the emergency locker. (R0#1)

Steps #CS and #C6 have the operator ensure the train B pump breakers are open and the feeder breakers to NB02 are also open. (R0#1)

Step #C7 has the operator ensure the ESA and ESB relays are energized. (R0#1)

Step #CB has the operator align EOG B to the bus. The RNO path assumes the diesel has not started. If the RNO path is followed, the operator obtains a handle from the emergency locker and places it at one of the available air start valves. The handle is then pulled down until the diesel starts. The scenario assumes the rest of the sub-steps follow the normal path, once the diesel has started. The EOG output breaker is closed and the NB02 voltage on the breaker is verified as normal. (R0#1)

Steps #C9 and #C 10 have the operator ensure the ESW pump B breaker is closed and the load center and ESW pumphouse MCC breakers are closed. The RNO path uses Attachment G, "Manual Charging of Siemens Circuit Breakers" to charge the breaker closing springs. (R0#1) 165

• Analysis 12 Fire with Control Room Evacuation and Remote Shutdown On-Shift Staffing Analysis Report Revision 1 Steps #C11 through #C13 have the operator isolate control power to NG02, position a valve for the ESW B/Service Water Cross-Connect, and isolate control power to NG04. (R0#1)

Step #C14, sub-step (a) has the operator verify that- the CRS performing Attachment A has completed steps A4 through AS. This is a "hold point" before continuing with step #C14(b).

(R0#1)

Sub-steps (b) and (c) have the operator start the motor driven AFW pump Band then notify the CRS that the pump is running. (The RNO path, not followed for this scenario, would direct the operator to Attachment G). (R0#1)

Steps #C15 ensures the containment spray pump A is also stopped. (R0#1)

Step #C16, has the operator align the ESW pump room ventilation. (R0#1)

Steps #C17 through #C21 have the operator position switches for the ESW to UHS isolation valves, the RWST to RHR pump B isolation valves, the RWST to CCP B suction valves, close the VCT outlet isolation valve, and open a charging pump mini flow isolation valve. (R0#1)

Step #C22, sub-step (a) contacts the operator performing Turbine Building Attachment B to ensure step #810 is complete. This is a "hold point" before continuing with step #C22(b).

(R0#1)

Sub-step (b) closes NB0206. The RNO path (not followed for this scenario) has the operator close NB0207 to start CCW pump D, and then if no CCW pump can be started, to go to Attachment G. (R0#1)

Step #C23, sub-step (a) ensures the Turbine Building Attachment B, Step 811, is complete and auxiliary building, steps D4 through D10 are also complete. These are both "hold points" before continuing with step #C23(b). (R0#1)

Sub-step (b) closes NB0201. The RNO path would have directed the operator to go to Attachment G. (R0#1)

Step #C24 has the operator inform the CRS that the CCW and CCP pumps have been started.

(R0#1)

Step #C25, has the operator align the diesel generator building ventilation. (R0#1)

Step #C26 has the operator isolate possible RCS leakage paths. (R0#1)

Step #C27 has the operator open breaker for SIG blowdown isolation valves. (R0#1)

Step #C28 has the operator start the EDG fuel oil transfer pump. (R0#1)

Step #C29 has the operator verify the EDG B room temperature is between 65 °F and 11 O °F.

(R0#1) 166

Analysis 12 Fire with Control Room Evacuation and Remote Shutdown On-Shift Staffing Analysis Report Revision 1 Step #C31 has the operator contact the CRS at the auxiliary shutdown panel for further direction. (R0#1)

Attachment D: Auxiliary Building Actions (R0#2) (NS0#4 is FBL)

Step #D1 has an operator in the Rod Drive M/G Room, isolate normal letdown at the RC and Support Systems Control Panel. (R0#2)

Steps #D2 and #D3 has an operator proceed to the emergency locker at the 2026' level and obtain a copy of procedure OFN RP-017, get a radio, a flashlight, a FR jump suit, and a pair of circular soft-jawed pliers. (R0#2)

Steps #D4 and #D5 have the operator operate breakers and switches, then isolate power to the BIT outlet valve. (R0#2)

Step #D6, sub-step (a), has the operator verify with the CRS at ASP that step 5.c is complete.

This is a "hold point" before continuing with step #D6(b). (R0#2)

Sub-step (b) has the operator ensure the CCW return from nuclear auxiliary components to Train A CCW is closed. (R0#2)

Step #D7 has the operator locally check if the ESW train B from CCW HX B valve is c.losed.

(R0#2)

Step #D8, in the south electrical penetration room, has the operator place the boron injection upstream test line switch to iso/closed. (R0#2)

Steps #D9 and #D10 have the operator start the electrical penetration room cooler and isolate power to the thermal barrier CCW return bypass is valve on NBG02B. (R0#2)

Step #D11, has the operator inform the reactor operator that CCW alignment is completed.

(R0#2)

Steps #D12 and #D13 have the operator open the ESW to/from containment isolation valves.

(R0#2)

Step #D14 has the operator open the ESW to/from containment air cooler valves. (R0#2)

Step #D15 has the operator start containment cooler fans B and D. (R0#2)

Step #D16 has the operator place boron injection downstream test line switch to iso/closed in north electrical penetration room. (R0#2)

Steps #D17 and #D18, has the operator ensure the MSIVs are closed by unplugging the Amphenol connectors and then notify the CRS at the aux shutdown panel of the status of the MSIVs. (R0#2)

Step #D19 requests the CRS at the auxiliary shutdown panel to ensure SIG A and SIG C ARVs are closed. (R0#2) 167

Analysis 12 Fire with Control Room Evacuation and Remote Shutdown On-Shift Staffing Analysis Report Revision 1 Steps #D20 and #D21 have the operator isolate air and nitrogen to the SIG A and SIG C ARVs.

(R0#2)

Step #D22, in the SGK04B room, has the operator start the Class 1E electrical equipment A/C unit. (R0#2)

Step #D23 has the operator proceed as directed by the CRS at the ASP. (R0#2)

Attachment E: BN HV-8812A and Aux Feedwater Valve Closure Step #E1 has the operator proceed to the NB02 switchgear room to obtain a copy of procedure OFN RP-017 and a flashlight. (Extra RO/NSO)

Step #E2 ensures motor driven AFW pump A is stopped. (Extra RO/NSO)

Step #E3 has the operator place the RWST to RHR pump A suction isolation valve breaker to off. (Extra RO/NSO)

Steps #E4 and #E5 have the operator, in RHR pump room A, close the RWST to RHR pump A isolation valve and then informs the CRS that the valve is closed. (Extra RO/NSO)

Step #E6 has the operator ascend ladder to the 2000' elevation AFW pump room area. The operator then closes valves in the TDAFW valve room, the "B" aux feed pump valve room, and the SE room at the end of the corridor. (Extra RO/NSO)

Step #E7 has the operator notify Radiation Protection of the entry. (The operator has entered a non-RCA from an RCA). (Extra RO/NSO)

Step #EB has the operator inform the CRS that the AFW valves are closed. The operator proceeds back down the ladder and then to the ASP. (Extra RO/NSO)

Attachment F: Actions to Protect Train A Equipment- actions completed as operators become available (ST A)

Step #F1 has either R0#1 or an extra NSO go to diesel room A, ensure the master transfer switch is set to local/manual, and that Diesel A is stopped. The operator also ensures selected breakers at NB01 are open.

Step #F2 has either the operator performing aux building actions or an extra NSO locally open PB031 to NCP and locally stop containment coolers A and C.

Step #F3 has either R0#1 or an NSO ensure the Train A control room AC unit is stopped, the filtration fan is stopped and the train A class 1E ventilation unit is stopped, Step #F4 dispatches operators to ensure support equipment operation; ensure the turbine lube oil pumps start as the turbine coasts down; ensures that the turbine is on the turning gear when the turbine speed approaches zero, and ensures the main feed pump(s) are on the turning gear when the main feed pump speed approaches zero.

168

Analysis 12 Fire with Control Room Evacuation and Remote Shutdown On-Shift Staffing Analysis Report Revision 1 Termination path (expected actions require TSC/E-Plan activation).

The longer-term closure to this event is assumed to involve a jump to procedure OFN RP-017A, "Hot Standby to Cold Shutdown from Outside the Control Room Due to Fire."

Take fire brigade actions in accordance with procedure AP 10-106, "Fire Preplans," Attachment B, "Control, Diesel and Communications Corridor Fire Preplans."

169

Analysis 12 Fire with Control Room Evacuation and Remote Shutdown On-Shift Staffing Analysis Report Revision 1 This OSA is applicable to Analysis# 12 as identified in Appendix A (Fire with CR Evacuation and Remote Shutdown)

TABLE 1 - On-shift Positions Augmentation Unanalyzed Role in TMS Line On-shift Position Emergency Plan Reference Elapsed Time Task?

Table#/Line# Required?

(min)

Shift Manager Radiological Emergency Response NA T2/L 1 No No Plan, Figure 2, "Minimum Shift Staffing" T5/L 1

& Attachment D, "WCGS Minimum Staffing for Emergencies" T5/L2 T5/L3 1 T5/L4 T5/L5 T5/L8 T5/L 10 Shift Technical Advisor Radiological Emergency Response NA T2/L3 No No Plan, Figure 2, "Minimum Shift Staffing" 2

& Attachment D, "WCGS Minimum Staffing for Emergencies" Control Room Supervisor Radiological Emergency Response NA T2/L2 No No Plan, Figure 2, "Minimum Shift Staffing" 3

& Attachment D, "WCGS Minimum Staffing for Emergencies" Reactor Operator #1 Radiological Emergency Response NA T2/L4 No No Plan, Figure 2, "Minimum Shift Staffing" 4

& Attachment D, "WCGS Minimum Staffing for Emergencies" 170

Analysis 12 _

Fire with Control Room Evacuation and Remote Shutdown On-Shift Staffing Analysis Report Revision 1 This OSA is applicable to Analysis# 12 as identified in Appendix A (Fire with CR Evacuation and Remote Shutdown)

TABLE 1 - On-shift Positions Augmentation Unanalyzed Role in TMS Line On-shift Position Emergency Plan Reference Elapsed Time Task?

Table#/Line# Required?

(min)

Reactor Operator #2 REMP, Figure 2, "Minimum Shift NA T2/L5 No No 5 Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" (Extra RO/NSO) REMP, Figure 2, "Minimum Shift NA T2/L6 No No 6 Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" Nuclear Station Operator REMP, Figure 2, "Minimum Shift NA -T2/L7 No Yes*

1. 1/2 Staffing" & Attachment D, "WCGS T4/L6 Minimum Staffing for Emergencies" T4/L7 T5/L6 7 T5/L9 T5/L 11 T5/L 13*

T5/L 14 T5/L 15 Nuclear Station Operator# 4 REMP, Figure 2, "Minimum Shift _ NA T2/L8 No No 8 Staffing" & Attachment D, "WCGS T3/L 1!

Minimum Staffing for Emergencies" Nuclear Station Operator #5 REMP, Figure 2, "Minimum Shift NA T2/L9 No No 9 Staffing" & Attachment D, "WCGS T3/L2 Minimum Staffing for Emergencies" 171

Analysis 12 Fire with Control Room Evacuation and Remote Shutdown On-Shift Staffing Analysis Report Revision 1 This OSA is applicable to Analysis # if. as identified in Appendix A. (Fire with CR Evacuation and Remote Shutdown)

TABLE 1 - On-shift Positions Augmentation Unanalyzed Role in TMS Line On-shift Position Emergency Plan Reference Elapsed Time Task?

Table#/Line# Required?

(min)

Nuclear Station Operator #6 REMP, Figure 2, "Minimum Shift NA T2/L 10 No No 10 Staffing" & Attachment D, "WCGS T3/L3 Minimum Staffing for Emergencies" Nuclear Station Operator #7 REMP, Figure 2, "Minimum Shift NA T2/L 11 No No 11 Staffing" & Attachment D, "WCGS T3/L4 Minimum Staffing for Emergencies" Nuclear Station Operator #8 REMP, Figure 2, "Minimum Shift NA T2/L 12 No No 12 Staffing" & Attachment D, "WCGS T3/L5 Minimum Staffing for Emergencies" Chemistry Technician REMP, Figure 2, "Minimum Shift 90 No No 13 Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" Radiation Protection REMP, Figure 2, "Minimum Shift 90 No No 14 Technician #1 Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" Radiation Protection REMP, Figure 2, "Minimum Shift 90 T4/L4 No No 15 Technician #2 Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" 16 Security REMP, Attachment D, "WCGS Minimum N/A T5/L 15 No No Staffing for Emergencies"

• Based on functional analysis ENS communicator required for continuous NRC communications. This individual also fulfills the OSC communicator role.

Operations Fire Brigade - dedicated to fighting CR fire 172

Analysis 12 Fire with Control Room Evacuation and Remote Shutdown On-Shift Staffing Analysis Report Revision 1 TABLE 2 - Plant Operations & Safe Shutdown Analysis # .1l One Unit - One Control Room Minimum Operations Crew Necessary to Implement AOPs and EOPs, or SAMGs if applicable Task Analysis Line Generic Title/Role On-Shift Position Controlling Method 1 Shift Manager Shift Manager Operations Training 2 Unit Supervisor Control Room Supervisor Operations Training 3 Shift Technical Advisor Shift Technical Advisor Operations Training 4 Reactor Operator #1 Reactor Operator #1 Operations Training 5 Reactor Operator #2 Reactor Operator #2 Operations Training 6 (Extra ROINSO) OFN KC-016 Operations Training Auxiliary Operator #112 Nuclear Station Operator Operations Training 7

1. 112 Auxiliary Operator #4 Nuclear Station Operator #4 Operations Training 8

(FBL)

Auxiliary Operator #5 Nuclear Station Operator #5 Operations Training 9

(Aux)

Auxiliary Operator #6 Nuclear Station Operator #6 Operations Training 10 (TB) 11 Auxiliary Operator #7 Nuclear Station Operator #7 Operations Training 12 Auxiliary Operator #8 Nuclear Station Operator #8 Operations Training Other (non-Operations) Personnel Necessary to Implement AOPs and EOPs, or SAMGs if applicable Task Analysis Line Generic Title/Role On-Shift Position Controlling Method 13 Mechanic NIA NIA 14 Electrician NIA NIA 15 l&C Technician NIA NIA 16 Other NIA NIA 173

Analysis 12 Fire with Control Room Evacuation and Remote Shutdown On-Shift Staffing Analysis Report Revision 1 TABLE 3 - Firefighting Analysis # 12 Task Analysis Line Performed By*

Controlling Method Nuclear Station Operator #4 Fire Program Training 1

(Fire Brigade Leader)

Nuclear Station Operator #5 Fire Program Training 2

(Fire Brigade Member)

Nuclear Station Operator #6 Fire Program Training 3

(Fire Brigade Member)

Nuclear Station Operator #7 Fire Program Training 4

(Fire Brigade Member)

Nuclear Station Operator #8 Fire Program Training 5

(Fire Brigade Member)

• OFN KC-016 Operator required for Appendix R commitments (License Amendment #191 12/16/2012) and cannot be assigned other functions (TRM 5.2.1 and AP 21-001, Att. L, Note 4).

174

Analysis 12 Fire with Control Room Evacuation and Remote Shutdown On-Shift Staffing Analysis Report Revision 1 TABLE 4- Radiation Protection & Chemistry Analysis # 12 Performance Time Period After Emergenc',i Declaration (minutes)

Lin Position Performing 0- 5- 10- 15- 20- 25- 30 I 40 50- 55 65-170- 75- 80- 85-e Function/Task 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 In-Plant Survey N/A - The performance of an in-plant survey is not necessary for initial implementation of the Emergency Plan and 1 On-Shift Position:

not required by any procedure.

RP Tech #1 On-Site Survey N/A - The performance of an on-site survey is not necessary for initial implementation of the Emergency Plan and 2 On-Shift Position not required by any procedure.

• Personnel Monitoring N/A - Personnel can out-process from the Radiologically Controlled Area (RCA) using portal and small article 3 On-Shift Position:

monitors. If necessary, site evacuees would be monitored after arrival of augmented ERO personnel.

RP Tech #1 Job Coverage On-Shift Position:

4 X X X X X X X X X X X X X X X X X X RP Tech #2 Offsite Radiological Assessment*

5 On-Shift Position: X X X X X X X X X X X X X X X X X X Chemistry Tech Chemistry function/task #1

-Sampling N/A- No sampling required until the Technical Support Center is staffed per AP 15C-003 (on hold pending 6

On-Shift Position: approval by NRC).

Chemistry Tech

• Dose assessment passes directly to the EOF, so this function is not relieved at 90 minutes.

175

Analysis 12 Fire with Control Room Evacuation and Remote Shutdown On-Shift Staffing Analysis Report Revision 1 TABLE 4 - Radiation Protection & Chemistry Analysis # 12.

Performance Time Period After Emergenc~ Declaration (minutes)

Position Performing Line 0- 5- 10- 15- 20- 25- 30 40- 45- 50- 55 65- 70 80 Function/Task 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 OSC Communicator function/task-1- Initiate staffing of ERO 7

2- Emerg Notifications X X X X X X 3- Notify State/ County 4- Notify NRC SRI / Westar X 5-ANI / INPO X ENS Communicator function/task-8 Continuous communication X X X X X X X X X X with NRC 176

Analysis 12 Fire with Control Room Evacuation and Remote Shutdown On-Shift Staffing Analysis Report Revision 1 TABLE 5 - Emergency Plan Implementation Analysis # 12.

Task Analysis Line Function/Task On-Shift Position Controlling Method Declare the Emergency Shift Manager Operations Training and EP 1

Classification Level (ECL) Training/Drill Program Approve Offsite Protective Action Shift Manager Operations Training and EP 2

Recommendations Training/Drill Program Approve content of State/local Shift Manager Operations Training and EP 3

notifications Training/Drill Program Approve extension to allowable Shift Manager Operations Training and EP 4

dose limits Training/Drill Program Notification and direction to on- Shift Manager Operations Training and EP 5 shift staff (e.g., to assemble, Training/Drill Program evacuate, etc.)

ERO notification Table 4 -Nuclear Station Operations Training and EP 6 Operator #1 /2 Training/Drill Program Abbreviated NRC notification for N/A for this event N/A 7 DBT event Complete State/local notification Shift Manager Operations Training and EP 8 form Training/Drill Program Perform State/local notifications Table 4 -Nuclear Station Operations Training and EP 9 Operator #1/2 Training/Drill Program Complete NRC event notification Shift Manager Operations Training and EP 10 form Training/Drill Program Activate EROS Table 4 -Nuclear Station Operations Training and EP 11 Operator#1/2 Training/Drill Program Offsite radiological assessment NA-Table 4- Chemistry Training and EP 12 Chemistry Tech Training/Drill Program Perform NRC notifications Table 4 -Nuclear Station Operations Training and EP 13 Operator #1/2 Training/Drill Program Perform other site-specific event Table 4 -Nuclear Station Operations Training and EP 14 notifications (e.g., INPO, ANI, Operator #1/2 Training/Drill Program etc.)

Personnel accountability Security/ Table 4 - Security Training and EP 15 Nuclear Station Training/Drill Program Operator #1/2 177

Attachment 1 On-Shift Staffing Analysis Report - Revision 1 On-Shift Staffing Analysis Documents/Bases Analysis # All Event Title/Function/Task Governing Procedure Training Material TABLE 2- Plant Operations & Safe Shutdown Design Basis Threat OFN SK-039, Security Events L01732447, OFN 00-036; OFN SK-039; and OFN SK-043 Security Procedures (Safeguards) LO 1733210, Security LR1002005, OFN SK-039 Tabletop LR2471101, Security Event Workbook OFN KJ-032, Local Emergency Diesel Startup L01706401, OFN KJ-032, Local Emergency Diesel Startup EMG E-0, Reactor Trip or Safety Injection L01732312, Intro to EMG Usage & Executive Volume L01732313, EMG E-0; Reactor Trip or Safety Injection (and Bases)

LR0032300, EMG/OFN Overview and Bases LR0032302, EMG Executive Volume & Background Issues LR0032303, EMG E-0 Series 1 OJT/TPE - NO 64-000-00 Auxiliary Building Completion Guide EMG ES-02, Reactor Trip Response L01732315, EMG ES Reactor Trip Response L04710529, Reactor Trip Response (Station Operators) LR0032303, EMG E-0 Series N01251300, Site Watch OFN EMG Local Actions N01350000, Turbine Building EMG and OFN Actions N01351300, Turbine Building Watchstation OFN/EMG Local Actions N01450001, EMG/OFN Actions -Auxiliary Building N01451300, Auxiliary Building Watchstation OFN/EMG Local Actions N04310500, NSO Sim Obs. (OFN/EMG Usage)

NR1350000, EMG/OFN Walkdown - Turbine Building NR1632301, OFN/EMG Local Actions Walkdown 178

Attachment 1 On-Shift Staffing Analysis Report - Revision 1 On-Shift Staffing Analvsis Documents/Bases Event Title/Function/Task Governing Procedure Training Material Steam system piping EMG E-0, Reactor Trip or Safety Injection L01732312, Introduction to EMG Usage and Executive Volume failure (major) L01732313, EMG E-0; Reactor Trip or Safety Injection (and Bases)

LR 0032300, EMG/OFN Overview and Bases LR0032302, EMG Executive Volume and Background Issues LR 0032303, EMG E-0 Series EMG E-1, Loss of Reactor or Secondary L01732320, EMG E-1; Loss of Reactor or Secondary Coolant Coolant LR 1400201, E-1 and Recovery Procedures EMG E-2, Faulted Steam Generator Isolation L01732324, EMG E-2; Faulted Steam Generator Isolation L04710553, Faulted SIG LR0032305, EMG E-2 Bases Faulted SG Isolation EMG ES-11, Post-LOCA Cooldown and L01732321, EMG ES-11; Post LOCA Cooldown and Depressurization Depressurization L04710552, LOCA with Cooldown/Depressurization and Recirc LR1400201, E-1 and Recovery Procedures 2 EMG F-0, Critical Safety Function Status L01732338, EMG F-0; Critical Safety Function Status Trees (CSFSTS)

Trees L01732339, EMG FR-S1/S2; Loss of Subcriticality EMG FR-S1, Response to Nuclear Power N01221804, Miscellaneous Site Diesel Generators Generation/ATWTS OJT/TPE NO 62-000-00, Site Operator Completion Guide STN KAT-001, Technical Support Diesel N01251300, Site Watch OFN EMG Local Actions Generator Operation N01350000, Turbine Building EMG and OFN Actions N01351300, Turbine Building Watchstation OFN/EMG Local (Station Operators)

Actions N01450001, EMG/OFN Actions -Auxiliary Building N01451300, Auxiliary Building Watchstation OFN/EMG Local Actions N040310500 NSO Simulator Observation (OFN/EMG Usage)

NR1350000, EMG/OFN Walkdown - Turbine Building NR1632301, OFN/EMG Local Actions Walkdown 179

Attachment 1 On-Shift Staffing Analysis Report - Revision 1 On-Shift Staffing Analysis Documents/Bases Event Title/FunctionfTask Governing Procedure Training Material Feed-water system piping EMG E-0, Reactor Trip or Safety Injection L01732312, Introduction to EMG Usage and Executive Volume break L01732313, EMG E-0; Reactor Trip or Safety Injection (and Bases)

LR 0032300, EMG/OFN Overview and Bases LR0032302, EMG Executive Volume and Background Issues LR 0032303, EMG E-0 Series EMG E-1, Loss of Reactor or Secondary L01732320, EMG E-1; Loss of Reactor or Secondary Coolant Coolant LR1400201, E-1 and Recovery Procedures EMG E-2, Faulted Steam Generator Isolation L01732324, EMG E-2; Faulted Steam Generator Isolation L04710553, Faulted SIG LR0032303, EMG E-0 Series 3

EMG ES-03, SI Termination L04710528, Safety Injection Recovery and Termination L01732316, EMG ES-03 SI Termination LR0032303, EMG E-0 Series (Station Operators) N01251300, Site Watch OFN EMG Local Actions N01350000, Turbine Building EMG and OFN Actions N01351300, Turbine Building Watchstation OFN/EMG Local Actions N01450001, EMG/OFN Actions -Auxiliary Building N01451300, Auxiliary Building Watchstation OFN/EMG Local Actions N040310500 NSO Simulator Observation (OFN/EMG Usage)

NR1350000, EMG/OFN Walkdown -Turbine Building NR1632301, OFN/EMG Local Actions Walkdown 180

Attachment 1 On-Shift Staffing Analysis Report - Revision 1 On-Shift Staffing Analysis Documents/Bases Event Title/Function/Task Governing Procedure Training Material Reactor coolant pump EMG E-0, Reactor Trip or Safety Injection L01732312, Introduction to EMG Usage and Executive Volume shaft seizure (locked L01732313, EMG E-0; Reactor Trip or Safety Injection rotor) (and Bases)

LR 0032300, EMG/OFN Overview and Bases LR0032302, EMG Executive Volume and Background Issues LR 0032303, EMG E-0 Series EMG ES-03, SI Termination L04710528, Safety Injection Recovery and Termination L01732316, EMG ES-03 SI Termination LR0032303, EMG E-0 Series EMG F-0, Critical Safety Function Status L01732338, EMG F-0; Critical Safety Function Status Trees (CSFSTS) 4 Trees OJT/TPE NO 63-000-00 Turbine Building Completion Guide SYS KJ-121, Diesel Generator NE01 and N01251300, Site Watch OFN EMG Local Actions NE02 Lineup for Automatic Operation N01350000, Turbine Building EMG and OFN Actions N01351300, Turbine Building Watchstation OFN/EMG Local (Station Operators) Actions N01450001, EMG/OFN Actions -Auxiliary Building N01451300, Auxiliary Building Watchstation OFN/EMG Local Actions N040310500 NSO Simulator Observation (OFN/EMG Usage)

NR1350000, EMG/OFN Walkdown -Turbine Building NR1632301, OFN/EMG Local Actions Walkdown 5 Reactor coolant pump Bounded by event #4 above Bounded by event #4 above shaft break 181

Attachment 1 On-Shift Staffing Analysis Report - Revision 1 On-Shift Staffing Analysis Documents/Bases Event Title/Function/Task Governing Procedure Training Material Spectrum of rod cluster EMG E-0, Reactor Trip or Safety Injection L01732312, Introduction to EMG Usage and Executive Volume control assembly ejection L01732313, EMG E-0; Reactor Trip or Safety Injection accidents (and Bases)

LR0032300, EMG/OFN Overview and Bases LR0032302, EMG Executive Volume and Background Issues LR0032303, EMG E-0 Series EMG ES-03, SI Termination L04710528, Safety Injection Recovery and Termination L01732316, EMG ES-03 SI Termination LR0032303, EMG E-0 Series EMG ES-11, Post-LOCA Cooldown and L01732321, EMG ES-11; Post LOCA Cooldown and Depressurization Depressurization L04710552, LOCA with Cooldown/Depressurization and Recirc LR1400201, E-1 and Recovery Procedures EMG ES-12, Transfer to Cold Leg L01732322, EMG ES-12; Transfer to Cold Leg Recirculation Recirculation LR1400201, E-1 and Recovery Procedures 6 L04710552, LOCA with Cooldown/Depressurization and Recirc EMG F-0, Critical Safety Function Status L01732338, EMG F-0; Critical Safety Function Status Trees Trees (CSFSTS)

EMG FR-C3, Response to Saturated Core L01732341, EMG FR-C 1/C2/C3 Inadequate/Degraded/Saturated Conditions Core Conditions LR1432304, EMG FR-C (Core Cooling) Series Procedures SYS KJ-121, Diesel Generator NE01 and OJT/TPE NO 63-000-00 Turbine Building Completion Guide NE02 Lineup for Automatic Operation (Station Operators) N01251300, Site Watch OFN EMG Local Actions N01350000, Turbine Building EMG and OFN Actions N01351300, Turbine Building Watchstation OFN/EMG Local Actions N01450001, EMG/OFN Actions - Auxiliary Building N01451300, Auxiliary Building Watchstation OFN/EMG Local Actions N04310500 NSO Simulator Observation (OFN/EMG Usage)

NR1350000, EMG/OFN Walkdown -Turbine Building NR1632301, OFN/EMG Local Actions Walkdown 182

Attachment 1 On-Shift Staffing Analysis Report - Revision 1 On-Shift Staffing Analysis Documents/Bases Event Title/Function/Task Governing Procedure Training Material Steam generator tube EMG E-0, Reactor Trip or Safety Injection L01732312, Introduction to EMG Usage and Executive Volume failure L01732313, EMG E-0; Reactor Trip or Safety Injection (and Bases)

LR 0032300, EMG/OFN Overview and Bases LR0032302, EMG Executive Volume and Background Issues LR0032303, EMG E-0 Series EMG C-31, STGR with Loss of Reactor L01732335, EMG C-31/32/33: SGTR Contingency Procedures Coolant - Subcooled Recovery Desired EMG E-2, Faulted Steam Generator Isolation L01732324, EMG E-2; Faulted Steam Generator Isolation L04710553, Faulted SIG LR0032305, EMG E-2 Bases Faulted SG Isolation EMG E-3, Steam Generator Tube Rupture L01732325, EMG E-3; Steam Generator Tube Rupture L04710501, Introduction to Steam Generator Tube Rupture LR4403502, EMG E-3 changes and practice 7

EMG F-0, Critical Safety Function Status L01732338, EMG F-0; Critical Safety Function Status Trees Trees (CSFSTS)

STN KAT-001, Technical Support Diesel OJT/TPE NO 62-000-00 Site Operator Completion Guide Generator Operation (Station Operators) N01251300, Site Watch OFN EMG Local Actions N01350000, Turbine Building EMG and OFN Actions N01351300, Turbine Building Watchstation OFN/EMG Local Actions N01450001, EMG/OFN Actions -Auxiliary Building N01451300, Auxiliary Building Watchstation OFN/EMG Local Actions N04310500 NSO Simulator Observation (OFN/EMG Usage)

NR1350000, EMG/OFN Walkdown -Turbine Building NR1632301, OFN/EMG Local Actions Walkdown 183

Attachment 1 On-Shift Staffing Analysis Report - Revision 1 On-Shift Staffino Analysis Documents/Bases Event Title/Function/Task Governing Procedure Training Material Loss of coolant accidents EMG E-0, Reactor Trip or Safety Injection L01732312, Introduction to EMG Usage and Executive Volume (large break) L01732313, EMG E-0; Reactor Trip or Safety Injection (and Bases)

LR 0032300, EMG/OFN Overview and Bases LR0032302, EMG Executive Volume and Background Issues LR 0032303, EMG E-0 Series EMG E-1, Loss of Reactor or Secondary L01732320, EMG E-1; Loss of Reactor or Secondary Coolant Coolant LR1400201, E-1 and Recovery Procedures EMG ES-12, Transfer to Cold Leg L01732322, EMG ES-12; Transfer to Cold Leg Recirculation Recirculation L04710552, LOCA with Cooldown/Depressurization and Recirc LR1400201, E-1 and Recovery Procedures EMG F-0, Critical Safety Function Status L01732338, EMG F-0; Critical Safety Function Status Trees 8 Trees (CSFSTS)

STN KAT-001, Technical Support Diesel OJT/TPE NO 62-000-00 Site Operator Completion Guide Generator Operation N01221804, Miscellaneous Site Diesel Generators (Station Operators) N01251300, Site Watch OFN EMG Local Actions N01350000, Turbine Building EMG and OFN Actions N01351300, Turbine Building Watchstation OFN/EMG Local Actions N01450001, EMG/OFN Actions -Auxiliary Building N01451300, Auxiliary Building Watchstation OFN/EMG Local Actions N04310500 NSO Simulator Observation (OFN/EMG Usage)

NR1350000, EMG/OFN Walkdown -Turbine Building NR1632301, ORN/EMG Local Actions Walkdown Design basis fuel handling OFN KE-018, Fuel Handling Accident L01732428, Fuel Handling Accident 9

accident 184

Attachment 1 On-Shift Staffing Analysis Report - Revision 1 On-Shift StaffinQ Analysis Documents/Bases Event Title/Function/Task Governing Procedure Training Material Aircraft probable threat OFN SK-039, Security Events L01732447, OFN 00-036; OFN SK-039; and OFN SK-043 Security Procedures (Safeguards) LO 1733210, Security LR1002005, OFN SK-039 Tabletop LR2471101, Security Event Workbook OFN MA-038, Rapid Plant Shutdown L01732446, OFN MA-038: Rapid Plant Shutdown L04710563, Rapid Plant Shutdown SYS AC-322, MSR 2nd Stage Reheat SY1503900, Main and Reheat Steam System Operations L01732312, Introduction to EMG Usage and Executive Volume EMG E-0, Critical Safety Function Status L01732313, EMG E-0; Reactor Trip or Safety Injection (and Bases) 10 Trees LR 0032300, EMG/OFN Overview and Bases LR0032302, EMG Executive Volume and Background Issues LR 0032303, EMG E-0 Series N01251300, Site Watch OFN EMG Local Actions N01350000, Turbine Building EMG and OFN Actions (Station Operators) N01351300, Turbine Building Watchstation OFN/EMG Local Actions N01450001, EMG/OFN Actions -Auxiliary Building N01451300, Auxiliary Building Watchstation OFN/EMG Local Actions N04310500 NSO Simulator Observation (OFN/EMG Usage)

NR1350000, EMG/OFN Walkdown -Turbine Building NR1632301, OFN/EMG Local Actions Walkdown 185

Attachment 1 On-Shift Staffing Analysis Report - Revision 1 On-Shift Staffino Analysis Documents/Bases Event Title/Function/Task Governing Procedure Training Material Station Blackout EMG C-0, Loss of All AC Power L04710555, Loss of All AC Power and Recovery L01732329, EMG C-0; Loss of All AC Power OP3310501, Loss of all AC Power Local Actions J ITT LR5002013, Loss of All AC LR1029804, C-0 Procedures EMG E-0, Reactor Trip or Safety Injection L01732312, Introduction to EMG Usage and Executive Volume L01732313, EMG E-0; Reactor Trip or Safety Injection (and Bases)

LR 0032300, EMG/OFN Overview and Bases LR0032302, EMG Executive Volume and Background Issues LR0032303, EMG E-0 Series 11 OFN KJ-032, Local Emergency Diesel Startup L01706401, OFN KJ-032, Local Emergency Diesel Startup OFN NB-030, Loss of AC Emergency Bus L04710562, Loss of Bus NB01(NB02)

NB01(NB02) L01732444, OFN NB-030 - Loss of NB01(NB02)/0FN NB-042 -

Loop with EOG Paralleled STN KAT-001, Technical Support Diesel N01221804, Miscellaneous Site Diesel Generators Generator Operation OJT/TPE NO 62-000-00 Site Operator Completion Guide SYS SY-120, Sharpe Diesel Operation and N01206202, Sharpe Substation Diesel Generator Alignment to Site OJT/TPE NO 62-000-00 Site Operator Completion Guide Fire with control room OFN RP-017, Control Room Evacuation L01732427, OFN RP-017 Control Room Evacuation evacuation and remote L04710541, Auxiliary Shutdown Panel Operation shutdown LR5002020, OFN RP-017 SRO/SO Actions 12 (Station Operators) N01351300, Turbine Watchstation OFN/EMG Local Actions N01451300, Auxiliary Watchstation OFN/EMG Local Actions Severe accident Bounded by events #7 & #8 above Bounded by events #7 & #8 above 13 management guidance 186

Attachment 1 On-Shift Staffing Analysis Report - Revision 1 0 n- Sh'ft I Staffrng A na1ys1s I . Documen t s/8 ases Event Title/Function/Task Governing Procedure Training Material 14 Appendix R fire response Bounded by event #12 above Bounded by event #12 above Table 2 - Plant Operations & Safe Shutdown Shift Manager (SM) Al 17C-005, Shift Manager Selection, Initial Initial training for Shift Manager position includes Transient & Accident Training and Continuing Training Program Analysis (Att. B, Step B24, AC-1), Emergency Operating Procedures (Att.

All B, Step B25, AC-2), and Emergency Planning (Att. B, Step B23, EP-1) tasks Shift Technical Advisor AP 30B-003, Shift Technical Advisor Initial Initial training for STA position includes Transient & Accident Analysis, All (STA) Training Program Emergency Operating Procedures, and Emergency Planning tasks Licensed Operator AP 30B-005, Licensed Operator Initial Initial training for Licensed Operator positions includes Transient &

(CRS/R0#1 /R0#2) Training Program Accident Analysis, Emergency Operating Procedures, and Emergency All Planning tasks Station Operator AP 30B-008, Non-Licensed Operator (NLO) Initial training for Station Operator positions includes Emergency All (S0#1 /S0#2/S0#3/S0#4) Initial Training Program Operating Procedures, and Emergency Planning tasks TABLE 3 - Firefighting Fire Brigade Leader AP 10-105, Fire Protection Training and Drills FL 1224000, Fire Brigade Leader FB1231427, Fire Brigade Leader Member Incident Management AP 10-100, Fire Protection Program FB1231423, Fire Control Part 1 of 2 Requalification All FB1231426, Fire Control Part 2 of 2 Requalification AP 10-106, Fire Preplans FB1231424, Industry Specific Fire Hazards and Fire Control Methods Fire Brigade Member AP 10-105, Fire Protection Training and Drills FB1231400, Initial Fire Brigade Member FB1231427, Fire Brigade Leader Member Incident Management FB1231423, Fire Control Part 1 of 2 Requalification AP 10-100, Fire Protection Program All FB1231426, Fire Control Part 2 of 2 Requalification AP 10-106, Fire Preplans FB1231424, Industry Specific Fire Hazards and Fire Control Methods; 187

Attachment 1 On-Shift Staffing Analysis Report - Revision 1 I Sta ffmo A na1vs1s 0 n-Sh'ft I . D ocumen t s /B ases Event Title/Function/Task Governing Procedure Training Material TABLE 4 - Radiation Protection & Chemistry Chemistry Technician EPP 06-001, Control Room Operations GE1135621, E-Plan for Chemistry Technicians EPP 06-012, Dose Assessment CE1135620, NPIS for Dose Projection CE1235620, NPIS Review CE1135610, Emergency Dose Calculation Program (EDCP)

All CE1235610, Off-site Dose Projection Using EDCP AP 30D-006, Chemistry Technician Training Sampling and analysis covered in accredited initial and continuing Program Chemistry Training Program RP Technician EPP 06-001, Control Room Operations GE1135620., E-Plan for HP Technicians GE0135614, Survey Team Techniques All AP 30D-100, Health Physics Training Survey and monitoring covered in accredited initial and continuing Program Health Physics Training Program TABLE 5 - Emergency Plan Implementation Declare the Emergency EPP 06-001, Control Room Operations GE1135628, E-Plan for Licensed Control Room Personnel Classification Level (ECL)

L01733215, Emergency Classification and Protective Action All EPP 06-005, Emergency Classification Recommendations LR 1007001, Emergency Classification and Protective Action Recommendations Approve Offsite Protective EPP 06-001, Control Room Operations GE1135628, E-Plan for Licensed Control Room Personnel Action Recommendations L01733215, Emergency Classification and Protective Action All EPP 06-006, Protective Action Recommendations Recommendations LR 1007001, Emergency Classification and Protective Action Recommendations Approve content of EPP 06-001, Control Room Operations GE1135628, E-Plan for Licensed Control Room Personnel All State/local notifications EPP 06-007, Emergency Notifications Approve extension to EPP 06-001, Control Room Operations GE1135628, E-Plan for Licensed Control Room Personnel All allowable dose limits EPP 06-013, Exposure Control and Personnel Protection 188

Attachment 1 On-Shift Staffing Analysis Report - Revision 1 0 n- Sh"ft I . D ocumen t s/8. ases I Sta ff1ng A na1ys1s Event Title/Function/Task Governing Procedure Training Material Notification and direction EPP 06-001, Control Room Operations GE1135628, E-Plan for Licensed Control Room Personnel All to on-shift staff (e.g., to EPP 06-010, Personnel Accountability and assemble, evacuate, etc.) Evacuation ERO notification EPP 06-001, Control Room Operations GE1135628, E-Plan for Licensed Control Room Personnel All EPP 06-015, Emergency Response GE1135619, E-Plan for Off-Site Communicators Organization Callout Abbreviated NRG OFN SK-039, Security Event L01732447, OFN 00-036, OFN SK-039 and OFN SK-043 notification for DBT event L01733210, Security All LR1002005, Security Procedure Review Complete State/local EPP 06-001, Control Room Operations GE1135628, E-Plan for Licensed Control Room Personnel notification form All EPP 06-007, Emergency Notifications GE1135619, E-Plan for Off-Site Communicators Perform State/local EPP 06-001, Control Room Operations GE1135628, E-Plan for Licensed Control Room Personnel notifications All EPP 06-007, Emergency Notifications GE1135619, E-Plan for Off-Site Communicators Complete NRG event EPP 06-001, Control Room Operations GE1135628, E-Plan for Licensed Control Room Personnel notification form All EPP 06-007, Emergency Notifications GE1135618, E-Plan for Control Room ENS Communicators Activate EROS EPP 06-001, Control Room Operations GE1135628, E-Plan for Licensed Control Room Personnel All Offsite radiological EPP 06-001, Control Room Operations GE1135628, E-Plan for Licensed Control Room Personnel assessment GE1135621, E-Plan for the Chemistry Technician EPP 06-012, Dose Assessment CE1135620, NPIS for Dose Assessment All CE1235620, Nuclear Plant Information System (NPIS) Review CE1135610, Emergency Dose Calculation Program (EDCP)

CE1235610, Off-Site Dose Projection Using EDCP 189

Attachment 1 On-Shift Staffing Analysis Report - Revision 1 I StaffmQ A na1vs1s 0 n- Sh.ft I . Document s/8 ases Event Title/Function/Task Governing Procedure Training Material Perform NRC notifications EPP 06-001, Control Room Operations GE1135628, E-Plan for Licensed Control Room Personnel All EPP 06-007, Emergency Notifications GE1135618, E-Plan for Control Room ENS Communicators Perform other site-specific EPP 06-001, Control Room Operations GE1135628, E-Plan for Licensed Control Room Personnel event notifications (e.g.,

All INPO, ANI, etc.) EPP 06-007, Emergency Notifications GE1135619, E-Plan for Off-Site Communicators Personnel accountability EPP 06-001, Control Room Operations GE 1135628, E-Plan for Licensed Control Room Personnel All EPP 06-010, Personnel Accountability and GE1135672, E-Plan for Security Coordinators Evacuation 190

Enclosure IV to WO 18-0016 Wolf Creek Nuclear Operating Corporation FLEX Staffing Study (27 pages)

Wolf Creek Nuclear Operating Corporation FLEX Staffing Study Prepared by: - ~~);~o--t-<-- I 11/8/2017 Reviewed by: 11/8/2017 Superintendent / Emergency Planning Approved by:

Site Vice President Rev 1

TABLE OF CONTENTS 1.0 Introduction ...................................................................................................................................2 2.0 Analysis Summary .......................................................................................................................3 3.0 Analysis Overview .......................................................................................................................3 4.0 Assumptions ................................................................................................................................5 5.0 Event Staffing Analysis ...............................................................................................................7 Attachments -Acronyms .................................................................................................................14 - References ...............................................................................................................15 - NEI 10-05 Tables ..........................................................................................16 - Participants ..................................................................................................25 1

1. Introduction In May, 2012, NEI published NEI 12-01, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities". This guideline provide criteria to assist with the preparation of assessments used to determine the required staff needed to respond to a Beyond Design Basis External Event (BDBEE) that affect multiple units at a site, and the identification of enhancements that could provide a means to power equipment needed to communicate with on-site and offsite personnel during an extended loss of AC power event. These assessments were necessary for responding to certain information requests contained in US Nuclear Regulatory Commission (NRC) letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(£) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review oflnsights from the Fukushima Dai-Ichi Accident, dated March 12, 2012. As discussed in SECY-11-0137, "Prioritization of Recommended Actions to be taken in Response to Fukushima Lessons Learned',

dated October 3, 2011, responses to the information requests will be used to inform possible future regulatory actions.

Recommendation 4.2 requires a three-phase approach for mitigating beyond-design-basis external events. The Initial Phase requires the 'use of installed equipment and resources to maintain or restore the functions of core cooling, containment and spent fuel pool cooling. The Transition Phase requires providing sufficient, portable, on-site equipment and consumables to maintain or restore these functions until they can be accomplished with resources brought from off site. The Final Phase requires obtaining sufficient offsite resources to sustain those functions indefinitely.

Additionally, the event analyzed impedes site access such that for the first 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> no personnel from off-site can access the site, from 6 to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> there is limited site access and after 24+ hours there is improved site access.

Section IV.A.9 of 10 CPR 50, Appendix E, states that nuclear power reactor licensees shall perform "a detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan." The Nuclear Energy Institute (NEI) On-Shift ERO Staffing Task Force developed NEI 10-05, "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities" to establish a standard methodology for performing analyses of the ability of on-shift staff to perform all required functions and tasks necessary to respond to a declared emergency. Licensees used this methodology to meet the requirement of 10 CFR 50, Appendix E, Section IV.A.9 in a manner acceptable to the US Nuclear Regulatory Commission (NRC) staff. The methodology provided in this guidance was used to perform the Wolf Creek Nuclear Operating Corporation (WCNOC) On-Shift Staffing Assessment (OSSA), initially conducted in November 2015.

2

This report provides Draft Revision 1 of the staffing assessment results for Wolf Creek Generating Station (WCGS) as required by the US Nuclear Regulatory Commission (NRC) letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review oflnsights from the Fukushima Dai-Ichi Accident, dated March 12, 2012. The WCNOC FLEX Staffing Study Draft Revision 1 will be approved after the NRC approval of the License Amendment Request for Revision to the Emergency Plan.

2. Analysis Summary The assessment concluded that the on-shift staff as defined in the current WCNOC Emergency Plan and augmented ERO is adequate to implement existing and planned BDBEE and ELAP strategies while continuing to perform required Emergency Planning tasks without unacceptable collateral duties. Gaps identified during the Staffing Assessment process should be addressed through the WCNOC Corrective Action Program.

Revision Ogaps identified:

a. The staffing assessment was not performed with the final approved versions of procedures and guidelines that will be used during an ELAP. (CR00050727-01-I0)

b. FLEX Support Guideline task training/qualification is not yet developed and incorporated into the appropriate training programs. (CR00050727-01-I0)

c. Current drill and exercise procedures do not include objectives or demonstration criteria for FLEX implementation. (CR00066747-02-46)

3. Analysis Overview Staffing Analysis Scope The Wolf Creek Generating Station (WCGS) staffing assessment was performed using the guidance ofNEI 12-01 to conduct the staffing assessment. This assessment considers the staffing necessary to implement actions that address functions related to Fukushima NTTF Recommendation 4.2. The intent of this assessment was to perform the following:

1. Evaluate the ability of the on-shift staff to implement Initial Phase coping actions and, consistent with the site access assumption, evaluate Transition Phase actions which must be performed prior to the end of the "no site access" time period.

• Initial Phase - Implementation of strategies that generally rely upon installed plant equipment.

3

• Transition Phase - Implementation of strategies involving the use of on-site portable equipment and consumables to extend the coping period, and prevent a loss of functions needed for core cooling, containment integrity, and spent fuel pool cooling. Setup for these strategies may be performed prior to the end of the Initial Phase as determined by procedure.

2. Evaluate the ability of the on-shift staff to implement the Station Blackout (SBO) coping strategies in place before Extended Loss of AC Power (ELAP) is declared.

3. Evaluate the EOPs and FSGs for responding to an ELAP affecting the unit. (Note:

Draft FSGs were used.)

4. Evaluate whether the ability of the on-shift staff to perform any required emergency response functions would be degraded or lost prior to the arrival of the augmented ERO.

5. Consistent with the site access assumption, evaluate the ability of the on-shift staff and augmented staff to implement Transition Phase coping strategies performed after the end of the "no site access" time period.

The staffing level determined as a result of the Phase 2 assessment have been verified and validated in the process used to reasonably assure required tasks, manual actions and decisions for FLEX strategies are feasible and may be executed.

Methodology A tabletop assessment was performed to determine what operational and emergency response actions were procedurally required during an ELAP. Representatives from WCNOC Operations, Maintenance, Radiation Protection, Chemistry, Procedure Writers, Engineering, Security, and Emergency Preparedness met with an industry consultant in a tabletop exercise in November 2015. The participants reviewed the assumptions and applied procedural guidance, including draft FLEX Support Guidelines (FSGs) for coping with a BDBEE using minimum on-shift staffing.

Particular attention was given to the sequence and timing of each procedural step, its duration, and the on-shift individual performing the step. Because the FSGs were not finalized, the results of the Revision Oassessment were preliminary and were validated prior to FLEX implementation. All gaps identified were addressed through the WCNOC corrective action program.

4

The team reviewed the tasks of each member of the minimum on-shift staff in responding to the ELAP and constructed a timeline (Table 5.1) recording the tasks and the approximate time at which they were performed following the event. In reviewing on-shift staffing tasks, the team was alert to identify instances where staff members were assigned conflicting tasks or collateral duties that would distract from their ability to fulfill Plan responsibilities.

The assessment team used the guidance ofNEI 10-05 to determine if the number and composition of the on-shift staff was sufficient to implement the Emergency Plan, Initial Phase actions, and, with the assistance from augmented staff, Transition Phase actions intended to maintain or restore core cooling, containment integrity, and spent fuel pool makeup for both units. The NEI 10-05 data tables (Attachment 3) were modified to include tasks associated with FLEX strategies.

4. Assumptions NEI 12-01 Assumptions for Staffing Analysis The set of standard assumptions that were used in the development of this report:

1. A large-scale external event occurs that results in:

• all on-site units affected

• extended loss of AC power

• impeded access to the units

2. All on-site reactors are operating at full power and are successfully shut down.

3. A Hostile Action directed at the affected site does not occur during the period that the site is responding to the event.

4. The event impedes site access as follows:

A. Post event time: 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> - No site access. This duration reflects the time necessary to clear roadway obstructions, use different travel routes, mobilize alternate transportation capabilities (e.g., private resource providers or public sector support), etc.

B. Post event time: 6 to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> - Limited site access. Individuals may access the site by walking, personal vehicle or via alternate transportation capabilities (e.g., private resource providers or public sector support).

C. Post event time: 24+ hours - Improved site access. Site access is restored to a near-normal status and/or augmented transportation resources are available to deliver equipment, supplies and large numbers of personnel.

5

5. The on-shift personnel complement is limited to the minimum required number and composition as described in the site emergency plan. If the plan commitments allow for different minimum staffing levels ( e.g., a variance between a normal dayshift and a backshift), use the staffing with the smallest total number of personnel.

NEI 10-05 Applicable Assumptions In accordance with this guidance, the following assumptions and limitations apply to the Phase 2 OSSA:

1. On-shift personnel can report to their assigned response locations within the timeframes sufficient to allow for performance of assigned actions.

2. The on-shift staff possesses the necessary Radiation Worker qualifications to obtain normal dosimetry and to enter Radiologically Controlled Areas (but not high, locked high or very high radiation areas) without the aid of a Radiation Protection Technician.

3. Personnel assigned to the major response area of Plant Operations and Safe Shutdown meet the requirements and guidance established by NRC regulations and are able to satisfactorily perform the functions and tasks necessary to achieve and maintain safe shutdown.

Note: Staff performance within this area was not evaluated as part of this assessment, unless a role/function/task from another major response area is assigned as a collateral duty.

4. Performance of the on-site security organization's function is regularly analyzed through other station programs and was not evaluated in the OSSA, unless a role or function from another major response area was assigned as a collateral duty.

5. Individuals holding the position of Radiation Protection Technician or Chemistry Technician are qualified to perform the range of tasks expected of their position.

6. The task of making a simple and brief communication has minimal impact on the ability to perform other assigned functions/tasks, and was therefore an acceptable collateral duty for all positions. Examples include making a plant page announcement or placing a call for assistance to an offsite resource such as local law enforcement. This assumption does not apply to emergency notification to an Offsite Response Organization (ORO) or the NRC. Communications methods will be different, i.e. Satellite phones instead of dedicated phone lines. Satellite phones require clear view of southern sky and therefore the communicator must go outside or set up an outside antenna. As such the communication to the State, 6

Counties and the NRC will be done in series as each phone must be dialed separately. The satellite phones have simple usage cards with each phone and the use is similar to the use of a cellular phone within the capability of the communicator.

7. The task of performing a peer check had minimal impact on the ability to perform other assigned functions/tasks, and was therefore an acceptable collateral duty for all positions. Examples include performing a peer check on a recommended emergency classification or notification form for transmittal to offsite authorities.

8. The analyzed events occur during off-normal work hours at a time when augmented ERO responders are not at the site (e.g., during a backshift, weekend or holiday).

5. Event Staffing Analysis Minimum On-Shift Staffing The shift staffing requirements for Wolf Creek Generating Station are listed in the table below. The methodology ofNEI 12-01 requires that only personnel required to be on-shift can be credited in the staffing analysis.

AP 06-002, Radiological Emergency Response Plan, (on hold pending approval)

WCGS Minimum Staffing for Emergencies Position On-Shift Shift Manager (SRO) 1 Control Room Supervisor (CRS) 1 Reactor Operator (RO#l & R0#2) 2 Nuclear Station Operator (NSO AB) 1 Nuclear Station Operator (NSO TB) 1 Nuclear Station Operator (NSO Site) 1 Nuclear Station Operator (NSO FBL) 1 Nuclear Station Operator (NSO OFN 16) 1 Nuclear Station Operator (Fire Brigade) 1 Nuclear Station Operator (Fire Brigade) 1 Shift Technical Advisor (STA) 1 RP Personnel (RP #1 & RP #2) 2 Chemistry Personnel (Chem) 1 Communicators (NSO Comm) 1 Total 16 Security Per Security Plan 7

Scenario Overview The BDBEE assumes a loss of off-site power combined with a failure of the emergency diesel generators to load. All remaining power is supplied by the station batteries. The loss of AC power to emergency buses initially results in the declaration of a Site Area Emergency. When it becomes apparent that power will be unavailable for a prolonged period, the event classification is escalated to a General Emergency.

Wolf Creek utilizes a three-phase approach for mitigating beyond-design-basis external events. The Initial Phase utilizes installed equipment and resources to monitor, maintain or restore the functions of core cooling, containment and spent fuel pool cooling. The Transition Phase requires providing sufficient, portable, on-site equipment and consumables to maintain or restore these functions until they can be accomplished with resources brought from off site. The Final Phase uses offsite resources to sustain those functions indefinitely. Portable and off-site equipment location and operation during the Transition and Final Phases is addressed through the FSG's.

EMG E-0 and EMG C-0 are the governing procedures for the BDBEE initial response. Actions are focused on response to the unit trip, restoration of electrical power and establishing ventilation in different areas of the plant.

FLEX strategies are focused on maintaining or restoring key plant safety functions and are not tied to any specific damage state or mechanistic assessment of external events.

Staffing Analysis Summary Tables 5.1 & 5.2 provide the results of the actions taken to the BDBEE transient using installed plant and portable equipment and the available staffing complement.

The on-shift staff performed actions required by operating and emergency plan procedures in the 6-hour period, relying only on installed structures, systems and components available in the Initial Phase of the response.

The assessment concluded that the on-shift staff as defined in the current WCNOC Emergency Plan and augmented ERO is adequate to implement existing and planned BDBEE and ELAP strategies while continuing to perform required Emergency Planning tasks without unacceptable collateral duties.

8

Table 5.1 On-Shift Staff Actions (Within the first seven hours)

Resources Tasks by Time (min) 0 20 40- 50- 60- 75- 90- 105- 120- 150- 180- 240- 300- 360-10 20 30 40 so 60 75 90 105 120 150 180 240 300 360 420 Shift Manager (SM) 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 Shift Technical Advisor 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 (STA)

Control Room 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 Supervisor (CRS)

Reactor Operator 3 3 12 3 3 3 3 3 3 3 3 3 3 3 3 3 (RO #1 )

Reactor Operator 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 (RO #2 )

Nuclear Station Operator

1. 5 6 8 14 14 18 18 18 19 (NSO AB) 9

Resources Tasks by Time (min) 0- 10 30- 40- 50- 60- 75- 90- 105- 120- 150- 180- 240- 300- 360-10 20 30 40 50 60 75 90 10S 120 150 180 240 300 360 420 Nuclear Station Operator 13/

1. 6 7 11 13 14 21 21 14 (NSO TB)

Nuclear Station Operator

1. 3 9 9 16 16 20 20 (NSO Site)

Nuclear Station Operator

1. 4 10 10 (NSO FBL)

Nuclear Station Operator 15 15 17 17 17 17 (NSO OFN 16)

Radiation Protection 17 17 17 17 Technician (RP #1)

Radiation Protection 36 36 36 36 Technician (RP #2)

Chemistry Technician s 5 s s 5 5 s s s 5 s 5 5 s s 5 Communicator NSO #1/2 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 Security

. . .- ~. . ." -

Note: Numbers in this table refer to the task numbers in Table 5.2 Task Listing 10

Table 5.2 Task Listing Task Performer Task Description Time Emergency Coordinator (Control Room) Duration SM 1.

Engineering Oversight (Control Room) Duration STA 2.

Emergency Procedures Implementation/ Monitoring and Duration CRS/RO

3. Control (Control Room)

Emergency Communications Duration Communicator 4.

Dose Assessment Duration Chem 5.

Locally close the RCS and pressurizer sample line isolation 10 NSO (AB)

6. valves at 3 locations in the aux building Attempt to start EDG's locally/ Attempt to restore electrical lOMin NSO (TB)

7. power to at least one emergency bus Isolate RCP seals 5 Min NSO (AB) 8.

Manually start the diesel fire pump 15 Min NSO (Site) 9.

TSC diesel - local start 20Min NSO (FBL)*

10.

Emergency ventilation - TDAFW doors opened 5 Min NSO (TB) 11.

Emergency ventilation - Cabinet doors in the control 15 Min ROI

12. building Check DC bus loads (Load shed) 15 Min NSO (TB) 13.

NSO (TB)

Damage assessment of buildings/ equipment 30Min 14.

NSO (AB)

Debris Removal (as required) - Including gate removal/

30 Min NSO (OFN 16)

15. access Deploy cables/ generator 480 VAC generator 30Min NSO (Site) 16.

11

Task Table 5.2 Task Listing Performer Task Description Time NSO (OFN 16)

SFP Ventilation 60Min RP#l 17.

Security SFP Hose - to SFP location 45Min NSO (AB) 18.

Deploy SFP hose 30Min NSO (AB) 19.

Deploy 120 VAC generator, 4 ventilation panels and associated cables (two trips with Polaris/ one trip with the 30Min NSO (Site) 20.

truck)

Load Centers NG-01 thru 4/ - open circuit breakers (FSG-4, 20Min NSO (TB)

21. Attachment A)

NSO (TB)

Run cables/ hook up to panels 45 Min 22.

NSO (FBL)

Tasks Performed Following First Six Hours/ Augmented Staff Available NSO (TB)

Energize NG-01 load center from FLEX generator 60Min

23. (Attachment B), generator running, ready to load the bus NSO (FBL)

NSO (TB)

Energize loads (Attachment C) 90Min 24.

NSO (FBL)

NSO (OFN 16)

Control Building Ventilation deployment 90Min 25.

RP NSO Deploy FLEX Air Compressors 60Min 26.

1 Aug 12

NSO Deploy FLEX Core Cooling Pump -includes deployment 30Min

27. and three hoses 1 Aug 2NSOs Place FLEX Core Cooling pump in service 60Min 28.

1 Aug Aug Start to Refueling of portable equipment

29. end Security FLEX RCS Make-Up Pump- calculations required 60Min RO 30.

Deploy RCS Make-up suction & discharge path (pump pre-60Min 2NSOs

31. staged)

Place CST Make-Up pump in service- stage (pump pre-240 Min 6Aug

32. staged) hoses RP surveys will be required when cooldown commences 600 Min RP 33.

Start to The chemist will be in control room for dose assessment CHEM

34. End RO Accumulator isolation from control room (prior to

35. cooldown to 120#) or vent to containment NSO 30 CR HP Coverage RP#2

36. minutes Notes:

I. Security will be present for Task #17 as part of normal response to the roll-up door

2. RO#l assists with emergency ventilation by opening cabinet doors in the control building

3. Augmented staff utilized after 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> when site access is partially restored (Task #26) 13

Attachment 1 Acronyms AOP Abnormal Operating Procedure BDBEE Beyond Design Basis External Event CFR Code of Federal Regulations EDG Emergency Diesel Generator EOP Emergency Operating Procedure ERO Emergency Response Organization NEI Nuclear Energy Institute NSO Nuclear Station Operator NRC Nuclear Regulatory Commission NTTF Near Term Task Force RCP Reactor Coolant Pump RCS Reactor Coolant System RP Radiation Protection Technician SAMG Severe Accident Management Guidelines SBO Station Blackout SFP Spent Fuel Pool TSC Technical Support Center 14

Attachment 2 References

1. EMG C-0, Loss of All AC Power

2. EMG E-0, Reactor Trip or Safety Injection

3. OFN KJ-032, Local Emergency Diesel Startup

4. OFN NB-030, Loss of AC Emergency Bus NBOl (NB02)

5. STN KAT-001, Technical Support Diesel Generator Operation

6. SYS SY-120, Sharpe Diesel Operation and Alignment to Site

7. FSG-1 Long Term Inventory Control

8. FSG-3 Alternate Low Pressure Feedwater

9. FSG-4 ELAP DC Load Shed/ Management

10. FSG-5 Initial Assessment and FLEX Equipment Staging

11. FSG-6 Alternate CST Makeup

12. FSG-7 Loss of Vital Instrumentation or Control Power

13. FSG-8 Alternate RCS Boration

14. FSG-9 Low Decay Heat Temperature Control

15. FSG-10 Passive RCS Injection Isolation

16. FSG-11 Alternate SFP Makeup and Cooling

17. FSG-12 Alternate Containment Cooling

18. FSG-13 Transition from FLEX Equipment

19. NEI 10-05 (Rev. 0), Assessment of On-Shift Emergency Response Organization Staffing and Capabilities

20. NEI 12-01 (Rev. 0), Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities 15

Attachment 3 NEI 10-05 Table 1 - On-Shift Positions Augmentation Role in Unanalyzed TMS Line On-Shift Position Emergency Plan Reference Elapsed Time Table#/ Line Task? Required?

(min) #

1 Shift Manager Radiological Emergency Response NA T2/Ll No No Plan, Figure 2, "Minimum Shift T5/Ll Staffing" & Attachment D, "WCGS T5/L2 Minimum Staffing for T5/L3 Emergencies" T5/L4 T5/L5 T5/L8 T5/L10 T5/Ll3 Shift Technical Radiological Emergency Response NA T2/L3 No No 2 Advisor Plan, Figure 2, "Minimum Shift T5/Ll 1 Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" 3 Control Room Radiological Emergency Response NA T2/L2 No No Supervisor Plan, Figure 2, "Minimum Shift Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" 16

Line On-Shift Position Emergency Plan Reference Augmentation Role in Unanalyzed TMS

• Elapsed Time Table#/ Line Task? Required?

(min) 4 Reactor Operator # 1 Radiological Emergency Response NIA T2/L4 No No Plan, Figure 2, "Minimum Shift Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" 5 Reactor Operator #2 Radiological Emergency Response NIA T2IL5 No No Plan, Figure 2, "Minimum Shift Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" 6 Reactor Operator #3 Radiological Emergency Response NIA T2IL6 No No Plan, Figure 2, "Minimum Shift Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" 7 Nuclear Station Radiological Emergency Response NIA T2IL7 No No Operator #5 Plan, Figure 2, "Minimum Shift Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" 8 Nuclear Station Radiological Emergency Response NIA T2/L8 No No Operator#6 Plan, Figure 2, "Minimum Shift Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" 17

Line On-Shift Position Emergency Plan Reference Augmentation Role in Unanalyzed TMS Elapsed Time Table#/ Line Task? Required?

(min) 9 Nuclear Station Radiological Emergency Response NIA T2IL9 No No Operator #3 Plan, Figure 2, "Minimum Shift Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" 10 Nuclear Station Radiological Emergency Response NIA T2IL10 No No Operator #4 Plan, Figure 2, "Minimum Shift Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" 11 Chemistry Radiological Emergency Response 90 T21 Lll No No Technician Plan, Figure 2, "Minimum Shift T4IL5 Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" 12 RP Tech#l Radiological Emergency Response T21 L12 No No Plan, Figure 2, "Minimum Shift T41Ll Staffing" & Attachment D, "WCGS T4IL3 Minimum Staffing for Emergencies" 13 RP Tech#2 Radiological Emergency Response T21 LI3 No No Plan, Figure 2, "Minimum Shift T4IL4 Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" 18

Line On-Shift Position Emergency Plan Reference Augmentation Role in Unanalyzed TMS Elapsed Time Table#/ Line Task? Required?

(min) 14 Communicator Radiological Emergency Response T2/ L14 No No (Nuclear Station Plan, Figure 2, "Minimum Shift Operator #1/2) Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" 15 Security Radiological Emergency Response NIA T5/Ll5 No No Plan, Figure 2, "Minimum Shift Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" 19

Attachment 3 NEI 10-05 TABLE 2 - Plant Operations, Safe Shutdown & FLEX Operations Line Generic Title/Role On-Shift Position Task Analysis Controlling Method 1 Shift Manager Shift Manager Operations Training 2 Unit Supervisor Control Room Supervisor Operations Training 3 Shift Technical Advisor Shift Technical Advisor Operations Training 4 Reactor Operator # 1 Reactor Operator # 1 Operations Training 5 Reactor Operator #2 Reactor Operator #2 Operations Training 6 Nuclear Station Operator #5 NSO (AB) Operations Training 7 Nuclear Station Operator #6 NSO (TB) Operations Training 8 Nuclear Station Operator #3 NSO (Site) Operations Training 9 Nuclear Station Operator #4 NSO (FBL) Operations Training 10 Nuclear Station Operator NSO (OFN 16) Operations Training Other (non-Operations) Personnel Necessary to Implement AOPs and EOPs, or SAMGs if applicable Line Generic Title/Role On-Shift Position Task Analysis Controlling Method 11 Chemistry Tech Chemistry Technician Chemistry Training 12 Radiation Protection Tech Radiation Protection Technician Radiation Protection

1. 1 Training 13 Radiation Protection Tech Radiation Protection Technician Radiation Protection

1. 2 Training 14 Communicator (Nuclear As assigned Emergency Plan Station Operator #1/2) Training 15 Security NIA Security Training 20

Attachment 3 NEI 10-05 TABLE 3 - Firefighting Line Performed By Task Analysis Controlling Method 1 NIA - there is no fire NIA associated with this event.

2 NIA NIA 3 NIA NIA 4 NIA NIA 5 NIA NIA 21

Attachment 3 NEI 10-05 TABLE 4 - Radiation Protection & Chemistry Performance Time Period After Emer~ency Declaration (minutes)

Line Position 0- 5- 10- 15 25 35 45 55 65 75- 85-performing 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 90 Function/ Task 1 In-Plant Survey On-Shift Position: X X X X X X X X X X X X X X X X X RP Tech#l Surveys 2 On-Site Survey On-Shift NIA The performance of an on-site survey is not necessary for implementation of the Emergency Plan and Position is not required by any procedure. No radiological release for this event.

3 Personnel Monitoring X X X X X X On-Shift Position:

CRRP Tech#2 4 Job Coverage On-Shift X X X X X X X X X X X Position:

RP Tech#2 As needed 5 Offsite Radiological X X X X X X X X X X X X X X X X X Assessment On-Shift Position:

Chemistry Tech.

22

Attachment 3 NEI 10-05 TABLE 5 - Emergency Plan Implementation Line Function/Task On-Shift Position Task Analysis Controlling Method 1 Declare the Emergency Operations Training Classification Level (ECL) and Shift Manager EP Training/Drill Program 2 Approve Offsite Protective Action Operations Training Recommendations and Shift Manager EP Training/Drill Program 3 Approve content of State/local Operations Training notifications and Shift Manager EP Training/Drill Program 4 Approve extension to allowable Operations Training dose limits and Shift Manager EP Training/Drill Program 5 Notification and direction to On- Operations Training shift staff (e.g., to assemble, and Shift Manager evacuate, etc.) EP Training/Drill Program 6 ERO notification Operations Training Nuclear Station and Operator # 1/2 EP Training/Drill Program 7 Abbreviated NRC notification for NIA for this event NIA DBTevent 8 Complete State/local notification Operations Training Form and Shift Manager EP Training/Drill Program 9 Perform State/local notifications Operations Training Nuclear Station and Operator # 1/2 EP Training/Drill Program 10 Complete NRC event notification Operations Training form and Shift Manager EP Training/Drill Program 23

r Line Function/Task On-Shift Position Task Analysis Controllin2 Method 11 Activate ERDS Nuclear Station EP Training/ Drill Operator # 1/2 Program 12 Offsite radiological assessment NIA-Table 4 Chemistry Training Chemistry Tech and EP Training/Drill Program 13 Perform NRC notifications Nuclear Station Maintenance Training Operator # 1/2 and EP Training/Drill Program 14 Perform other site-specific event Nuclear Station Operations Training notifications (e.g., INPO, ANI, Operator # 1/2 and etc.) EP Training/Drill Program 15 Personnel accountability Security/ Nuclear Security Training and Station Operator #1/2 EP Training/Drill Program 24

Attachment 4 Tabletop Participants (Revision 0)

Rick Foust Engineering Chad Carmen Chemistry Joe Franks FLEX Procedure Writer Jim Gilmore FLEX Procedure Writer Monty Thomas Security Marcus Stice Operations Frank Buchman Emergency Planning John Schepers Radiation Protection Revision 1 Team Ed Winn Operations Ryan Adams Radiation Protection Neil Woydziak Chemistry Lucille Stone Licensing 25