ML18331A256

Operating Corporation (Wcnoc), Unit 1 - Response to Requests for Additional Information (RAI) Regarding License Amendment Request (LAR) for Revision to the Emergency Plan

ML18331A256
Person / Time
Site:	Wolf Creek
Issue date:	11/19/2018
From:	Wolf Creek
To:	Office of Nuclear Reactor Regulation
References
WO 18-0045
Download: ML18331A256 (140)

Text

{{#Wiki_filter:Attachment to WO 18-0045 Page 1 of 11 WOLF CREEK NUCLEAR OPERATING CORPORATION (WCNOC), UNIT 1 RESPONSE TO REQUESTS FOR ADDITIONAL INFORMATION (RAI) REGARDING LICENSE AMENDMENT REQUEST (LAR) FOR REVISION TO THE EMERGENCY PLAN RAl-1(a): Based on a review of the current and proposed WCGS RERP, the NRC staff could not clearly determine who relieves the Shift Manager from the Emergency Direction and Control Function or when the Shift Manager would be relieved by an augmenting ERO member. It appears that the Shift Manager could be relieved as described by any of the following conditions:

• Enclosure I, "Proposed Markup of Procedure AP 06-002," Section 6.6.1 provides that the TSC will be activated within 75 minutes of the declaration of an Alert or higher classification. Upon activation, the TSC will have a Site Emergency Manager who will assume command-and-control functions;
• Enclosure I, Section 6.6.5 provides that the TSC Site Emergency Manager, who is available 24 hours a day, may assume command-and-control functions from the Shift Manager if so requested by the Shift Manager; or
• Enclosure I, Section 6.8.1 provides that Emergency Operations Facility (EOF) will be activated within 90 minutes of the declaration of an Alert or higher classification. Upon activation, the EOF will have a Site Emergency Manager who will assume command-and-control functions and direct the emergency from the EOF.

In order for the staff to clearly understand the authorities, responsibilities, and duties of the individual(s) who will take charge during an emergency, as described in Evaluation Criteria 11.8.4 to NUREG-0654, please explain the following: (a) Explain who assumes the responsibility for Emergency Direction and Control for Alert or greater emergency classifications at WCGS. This explanation should include discussions on the 24 hours a day availability of a Site Emergency Manager that can relieve the Shift Manager, when requested, during an Unusual Event declaration, as well as the availability of the Site Emergency Manager at the TSC within 75 minutes of an Alert or greater emergency classification. RAl-1 (a) Response: , Updated Procedure Markups to AP 06-002, "Radiological Response Plan (RERP)" describes the following revision to Section 5.8:

5. 8 Command and Control 5.8.1 Transfer of command-and-control flows from the Control Room to the Technical Support Center (TSC) and then to the Emergency Operations Facility (EOF). Upon classifying an event, the Shift Manager assumes the role of Emergency Manager. The Site Emergency Manager relieves the Shift Manager of the Emergency Manager duties at an Alert (or higher) emergency classification.

The Site Emergency Manager may relieve the Shift Manager of Emergency Manager duties at an

Attachment to WO 18-0045 Page 2 of 11 Unusual Event upon request from the Shift Manager. After the EOF has been activated, the duties of Emergency Manager are transferred from the Site Emergency Manager to the off-site Emergency Manager. Section 6.5.2 currently states, "Upon declaration of an emergency, the Shift Manager assumes the duties of Emergency Manager." Section 6.6 currently describes the TSC organization. describes the following revision to Section 6.6.1:

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.

Section 6.6.2 currently states, "The TSC is considered activate~ when the following positions are present, the Site Emergency Manager determines the facility is ready to activate, and declares the facility activated:

• Site Emergency Manager
• TSC Operations Coordinator
• TSC Administrative Coordinator
• TSC Radiological Coordinator
• Maintenance Coordinator" Section 6.6.5.1 currently states, '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 hours a day. The assigned Site Emergency Manager may assume command-and-control functions from the Shift Manager during an NUE if so required by the Shift Manager."

Section 6.8 currently describes the EOF organization describes the following revision to Section 6.8.1.1:

6. 8. 1. 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:

• Off-site Emergency Manager
• EOF Operations Coordinator
• EOF Administrative Coordinator
• EOF Radiological Coordinator

Attachment to WO 18-0045 Page 3 of 11 Section 6.8.2 currently states, "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 hours a day." Note: Wolf Creek Nuclear Operating Corporation maintains Emergency Response Organization (ERO) teams providing 24-hour coverage for the Site Emergency Manager and off-site Emergency Manager positions. RAl-1(b): (b) Explain why Enclosure I, "Proposed Markup of Procedure AP 06-002," of the WCNOC submittal, and Attachment D, "WCGS Staffing Table Staffing," of the WCGS RERP, do not clearly indicate a transfer of responsibility from the Shift Manager to the Site Emergency Manager at 75 minutes of an Alert or greater emergency classification. RAl-1(b) Response: Transfer of command-and-control is discussed in response to RAl-1 (a), above. Attachment D to AP 06-002, "WCGS Minimum Staffing for Emergencies," (partially below) will be revised to indicate that transfer of command-and-control is from the Shift Manager to the Site Emergency Manager. (Enclosure 4) Attachment D WCGS Minimum Staffing for Emergencies Capability for On Additions: Functional Area (1J Major Tasks Position Title or Expertise Shift 60 mins 90 mins Plant Operations & Shift Manager (SRO) 1 - - Assessment of Control Room Supervisor 1 - - Operational Aspects (CRS) - - Reactor Operator (RO) 2 - - Nuclear Station Operator 7*** Emergency Direction and Shift Manager (Emergency 1* - - Control Manager) - 1 - Site Emeroencv Manaaer

• • • May be provided by a Reactor Operator Transfer from the Site Emergency Manager to the off-site Emergency Manager is indicated in the Radiological Accident Assessment and Support of Operational Accident Assessment section of Attachment D. This will not change in the revision. is an updated ERO Position Matrix.

Attachment to WO 18-0045 Page 4 of 11 RAl-2: Page 3 of 3 to Attachment IV of the LAR, "Summary of Shift Staffing and Augmentation Response Time Historical Requirements and Proposed Changes," provides that the number of Radiation Protection (RP) Personnel assigned the major tasks of off-site surveys, on-site (out-of-plant) surveys, and in-plant surveys is being reduced from 8 to 6. This table also proposes to reduce the number of RP technicians performing the Protective Actions (In-Plant) function from 4 to 2. However, it is not clear to the staff who actually was going to perform those specific task and where the reduction is occurring. In order for the staff to clear understand how the minimum staffing levels in Evaluation Criteria 11 .B.5 to NUREG-0654 are being met and where the reductions are specifically being proposed, please provide a more detailed breakdown (in a table format) of how the RP Personnel are utilized by major task. This table should include the RP Personnel that perform the applicable major tasks in the Radiological Accident Assessment & Support of Operational Accident Assessment, Protective Actions (In-Plant), as well as the survey team technicians who perform off-site field monitoring. RAl-2 Response: Attachment D to AP 06-002, "WCGS Minimum Staffing for Emergencies," (partially below) will be revised to indicate the breakdown of how RP are utilized for the applicable major tasks in the Radiological Accident Assessment & Support of Operational Accident Assessment, Protective Actions (In-Plant), as well as the survey team technicians who perform off-site field monitoring . (Enclosure 4) Attachment D WCGS Minimum Staffing for Emergencies Capability for Additions: Position Title or 60 mins 90 Functional Area !1 l Major Tasks Expertise On Shift mins Radiological Accident Emergency Operations Facility (EOF Off-site Emergency 1 Assessment & Support of Director) Manager 1 Operational Accident Off-site Dose Assessment Sr. Radiation 1* 1 Assessment Protection Expertise Off-site Surveys RP Personnel 3 Onsite (out-of-plant) RP Personnel 2 In-Plant Surveys RP Personnel 2 1 Chemistry/Radiochemistry Chemistry Personnel 1 1 Protective Actions (In- Radiation Protection: RP Personnel 1* 2 - Plant) Access Control Coverage for repair, mitigative actions , search & rescue, first-aid & firefighting Functional analyses for these major tasks are described in the respective sections of the License Amendment Request (LAR).

Attachment to WO 18-0045 Page 5 of 11 RAl-3: Page 2 of 2 to Attachment V, "Letter of Consultation and Concurrence from Off-site Response Organizations Acknowledgement of Opportunity to Review and Support WCNOC License Amendment Request," provides that the State of Kansas and Coffey County were informed of the following, in part:

        ... NRC approval for extension of the goal for staffing its augmented TSC/OSC [Operations Support Center] 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.

However, this is not consistent with the proposed WCNOC submittal. Please explain the reasoning for this apparent discrepancy or provide an updated letter that reflects the proposed changes in the WCNOC application. RAl-3 Response: An updated "Letter of Consultation and Concurrence from Off-site Response Organizations Acknowledgement of Opportunity to Review and Support WCNOC License Amendment Request," is provided (Enclosure 5). RAl-4{a) Page 16 of 27 to Attachment I states, in part, 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 [Emergency Operations Facility]. 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. WCNOC is requesting to reduce the number of survey team tJchnicians from the current value of four (4) tp a proposed level of three (3). WCNOC provides that the reduction in the number of Survey Team Technicians is possible due to coordination with the State of Kansas. To allow the staff to clearly understand the requested action based on the staffing levels in Table 8-1 "Minimum Staffing Requirements for NRC Licensees for Nuclear Power Plant Emergencies," and Evaluation Criteria 11.1.7, "Accident Assessment," to NUREG-0654, please address the following:

Attachment to WO 18-0045 Page 6 of 11 (a) Describe the survey team composition and level of training. For example, are there two (2) radiation protection technicians and two (2) drivers or four (4) radiation protection technicians, and are the survey team members qualified radiation protection technicians or are they individuals who are survey qualified. RAl-4(a) Response: EPP 06-011, "Emergency Team Formation," Section 4.3.1 currently states, "Teams designated to perform assessment of the off-site consequences of a radiological release. Joint Radiological Monitoring Teams (JRMTs) are comprised of at least two people in any combination from Wolf Creek and the Kansas Department of Health and Environment. County personnel become part of the JRMTs as requested." , Section 6.8.4.1.c, currently states, "County and State personnel may become part of the Emergency Response Teams and assist with off-site monitoring in accordance with EPP 06-011." , Section 6.11.4.1 currently states: "6.11.4 Kansas Department of Health and Environment {KDHE)

1. The KDHE provides assistance as described below:

• Acts as the lead state agency for operational radiological emergency response
• Conducts radiological monitoring in affected areas
• Provides radiological monitoring in affected areas
• Provides radiological advice to hospitals
• Develops and establishes State PAGs
• Provides information and guidance to the public about protective actions, via the KDEM
• Assesses off-site contamination of the environment
• Provides technical guidance and coordination in recovery activities
• Supports the development and conduct of radiological response training
• Reviews, evaluates, and maintains dosimetry records for non-licensed emergency workers and other affected individuals"

Attachment to WO 18-0045 Page 7 of 11 Survey team members are Radiation Protection (RP) personnel. Attachment D, "WCGS Minimum l Staffing for Emergencies," (partially below) will be revised to clarify that three (3) RP personnel arrive within 60 minutes to perform off-site surveys. (Enclosure 4) Attachment D WCGS Minimum Staffing for Emergencies Capability for Additions : Position Title or On 60 90 Functional Area 111 Major Tasks Expertise Shift mins mins Radiological Accident Emergency Operations Facility Off-site Emergency 1 Assessment & Support of (EOF Director) Manager 1 Operational Accident Off-site Dose Assessment Sr. Radiation 1* 1 Assessment Protection Expertise Off-site Surveys RP Personnel 3 Onsite (out-of-plant) RP Personnel 2 In-Plant Surveys RP Personnel 2 1 Chemistry/Radiochemistry Chemistry Personnel 1 1 Protective Actions (In-Plant) Radiation Protection : RP Personnel 1* 2 - Access Control Coverage for repair, mitigative actions, search & rescue , first-aid & firefighting describes the following revision to Section 6.3.8: 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. In accordance with EPP 06-011, joint radiological monitoring teams (JRMTs) are comprised of at least two people in any combination from WCGS, KDHE, or Coffey County personnel. , Section 6.8.4.1.b, currently states, "Monitoring teams are specially trained in field sampling techniques. Each team will be equipped with equipment capable of detecting and measuring radiological concentrations in the air at levels as low as 10-7 uCi/cc." , Section 6.17 .5.1, currently states: "1. Position specific training is provided for personnel filling positions in the following areas:

• Manager/Coordinators of the emergency
• Personnel responsible for accident assessment
• Radiological monitoring teams
• Fire brigade members
• Emergency response teams
• Medical support personnel
• Security personnel
• Support personnel"

Attachment to WO 18-0045 Page 8 of 11 - RAl-4(b): (b) Explain to whom the survey team technicians report to, as they are identified as 60-minute responders with and the TSC and EOF activating at 60 and 90 minutes respectively. RAl-4{b) Response: describes the following revision to Section 6.8.4:

"6.8.4 EOF Team Director

1. The EDF Team Director assumes responsibility for authorizing and supervising off-site Monitoring Teams. The EOF Team Director directs Emergency Response Teams and advises the EDF Radiological Coordinator on radiological conditions encountered by the Teams.

a. Off-site Monitoring Team authorization should be made promptly upon activation of the EDF.

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 in accordance with EPP 06-011." describes the following addition to the bulleted items in Section 6.6.10:

• Authorizing and supervising off-site Monitoring Teams until the EOF is activated.

RAl-4(c): (c) Explain the difference, if any, between the survey team technicians and the radiological monitoring teams, as described in Section 6.3.8 of the WCGS RERP. RAl-4(c) Response: There is no difference between the survey team technicians and the radiological monitoring teams. , ERO Position Matrix, has been modified to indicate that they are one and the same.

Attachment to WO 18-0045 Page 9 of 11 RAl-4{d): (d) Explain how coordination with the State of Kansas supports the elimination of a WCGS ERO augmentation survey team technician. RAl-4{d) Response: In accordance with procedure EPP 06-011, Attachment A, "Guidelines for JRMT Control," one JRMT is dispatched close to the plant to find the centerline of the plume and two JRMTs are sent out to locate the edges of the plume. In the past, a fourth JRMT remained at the EOF to operate as a counting station. Since all Wolf Creek. JRMT members are trained to count samples, it is more expeditious to have each JRMT perform sample counts in the field instead of transporting the samples back to the EOF prior to counting. The elimination of the separate counting team reduces the need for the fourth survey team position. EPP 06-011, "Emergency Team Formation," Section 4.3.1 currently states, "Teams designated to perform assessment of the off-site consequences of a radiological release. JRMTs are comprised of at least two people in any combination from Wolf Creek and the Kansas Department of Health and Environment. County personnel become part of the JRMTs as requested." , Section 6.8.4.1.c, currently states, "County and State personnel may become part of the Emergency Response Teams and assist with off-site monitoring in accordance with EPP 06-011." , Section 6.11.4.1 currently states: "6.11.4 Kansas Department of Health and Environment (KDHE)

2. The KDHE provides assistance as described below:

• Acts as the lead state agency for operational radiological emergency response
• Conducts radiological monitoring in affected areas
• Provides radiological advice to hospitals
• Develops and establishes State PAGs
• Provides information and guidance to the public about protective actions, via the KDEM
• Assesses off-site contamination of the environment
• Provides technical guidance and coordination in recovery activities
• Supports the development and conduct of radiological response training
• Reviews, evaluates, and maintains dosimetry records for non-licensed emergency workers and other affected individuals"

Attachment to WO 18-0045 Page 10 of 11 Enclosure 1 describes the following revision to Section 6.3.8:

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. In accordance with EPP 06-011, joint radiological monitoring teams (JRMTs) are comprised of at least two people in any combination from WCGS, KDHE, or Coffey County personnel.

Procedure EPP 06-011, "Emergency Team Formation," includes a statement that any changes to the procedure must be approved by all entities (WCGS, State and County). By approval of the procedure, the State, specifically KDHE, is agreeing to support joint radiological monitoring. Evaluation Criteria 11.1.7 of NUREG-0654 states: Each organization shall describe the capability and resources for field monitoring within the plume exposure Emergency Planning Zone which are an intrinsic part of the concept of operations for the facility. Evaluation Criteria 11.1.8 of NUREG-0654 states, in part: This shall include activation, notification means, field team composition, transportation, communication, monitoring equipment and estimated deployment times. Based on a NRC staff review of the information provided in the submittal, it was not clear who is performing field monitoring. Please explain where in the WCGS RERP describes the capability and resources for field monitoring within the Plume Exposure Pathway Emergency Planning Zone. RAl-5 Response: , Section 6.3.8, currently states, "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." The revised Appendix D (Enclosure 4) indicates that three (3) RP personnel arriving within 60 minutes to perform off-site surveys. , Section 6.8.4.1.b, specifies that each team is "equipped with equipment capable of detecting and measuring radioiodine concentrations in the air at levels as low as 10-1 µCi/cc." Also, Section 6.15, emergency supplies includes radiological monitoring equipment.

Attachment to WO 18-0045 Page 11 of 11 , Section 6.3. 7 .3, provides that "actual off-site population dose is confirmed by off-site monitoring, sampling and analysis." , Sections 6.16.1.1.c and 6.16.1.2, describe the primary and backup communication methods used by the JRMTs. Detailed information regarding formation and dispatch of JRMTs is included in procedure EPP-06-011. describes the following revision to Section 6.3.8:

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. In accordance with EPP 06-011, joint radiological monitoring teams (JRMTs) are comprised of at least two people in any combination from WCGS, KDHE, or Coffey County personnel.

Summary of

Enclosures:

Updated Procedure Markups to AP 06-002, "Radiological Response P.lan (RERP)" : Updated Emergency Plan Change Summary : Updated ERO Position Matrix. : Updated Attachment D to AP 06-002, "WCGS Minimum Staffing for Emergencies" : Updated "Letter of Consultation and Concurrence from Off-site Response Organizations Acknowledgement of Opportunity to Review and Support WCNOC License Amendment Request" to WO 18-0045 Updated Procedure Markups to AP 06-002, "Radiological Response Plan (RERP)"

(110 pages)

, Updated Procedure Markups to AP 06-002, "Radiological Emergency Response Plan (RERP)"

AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN (RERP) Responsible Manager SUPERINTENDENT EMERGENCY PLANNING Revision Number J.l?PJ'BD Use Category Information Administrative Controls Procedure Yes Management Oversight Evolution No Program Number 06

Revision: IDil RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 1 of 110 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 13 6.1 Site Description 13 6.2 Emergency Classifications 15 6.3 Emergency Measures 17 6.4 Emergency Facilities 25 6.4.1 Control Room Facilities 25 6.4.2 Technical Support Center Facilities 25 6.4.3 Operations 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 40 6.8 Emergency Operations Facility (EOF) Organization 41 6.9 Public Information Organization 48 6.10 Local Off-site Organizations 53 6.10.2 Coffey County Commissioners 53 6.10.3 Coffey County Sheriff's Office 54 6.10.4 Coffey County Fire District #1 (CCFD) 55 6.10.5 Off-site Medical Treatment 55 6.10.6 Coffey County Emergency Medical Service (EMS) 55 6.10.7 Radiological Emergency Assistance Center/Training Site (REAC/TS) 56 6.11 State Organizations 56 6.11.3 Kansas Division of Emergency Management (KDEM) 57 6.11.4 Kansas Department of Health and Environment (KDHE)57 6.11.5 Kansas Highway Patrol (KHP) 58 6.11.6 Kansas National Guard 58 6.11.7 Kansas Department of Transportation (KDOT) 59 6.12 Federal Organizations 59 6.12.2 Federal Emergency Management Agency (FEMA) 59 6.12.3 Department of Energy (DOE) 59 6.12.4 Nuclear Regulatory Commission (NRC) 59 6.12.4 Nuclear Regulatory Commission (NRC) 60 6.13 Additional Support Agencies 60 6.13.1 Vendor and Architect/Engineers (A/E) 60 6.13.2 Regional Utility Support 62 6.13.3 Institute of Nuclear Power Operations (INPO) 62 6.13.4 American Nuclear Insurers (ANI) 62 6.14 Plant Monitoring 62

Revision: ;;l=-8-1~ RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 2 of 110 TABLE OF CONTENTS SECTION TITLE PAGE 6.14.1 Nuclear Plant Information System (NPIS) 62 6.14.2 On-site Radiological Monitors 63 6.14.3 Meteorological Monitoring System 64 6.14.4 Seismic Monitoring System 64 6.14.5 Hydrologic Monitoring 64 6.14.6 Fire Protection 65 6.14.7 Laboratory Facilities 65 6.15 Emergency Supplies 65 6.16 Communications 66 6.16.1 Communication Equipment 66 6.16.2 Communication Dissemination 66 6.17 Emergency Plan Training 68 6.18 Emergency Plan Drills 70 6.19 Emergency Planning Exercises 72 6.20 Emergency Plan And Procedures Administrative Controls 75 6.21 Recovery Plan 76 7.0 RECORDS 77 8.0 FORMS 77 ATTACHMENT A EFFECTIVE 10-MILE EPZ POPULATION 78 ATTACHMENT B SUBZONE EVACUATION TIMES 79 ATTACHMENT C CROSS REFERENCE BETWEEN NUREG 0654, RERP, & WCGS PROCEDURES 82 ATTACHMENT D WCGS MINIMUM STAFFING FOR EMERGENCIES 90 ATTACHMENT E EPA/KANSAS PROTECTIVE ACTION GUIDES 93 ATTACHMENT F USAR CHAPTER 15 POSTULATED EVENTS 96 ATTACHMENT G LETTERS OF AGREEMENT 98 ATTACHMENT H REPORTING OF INCIDENTS PER 10 CFR 20 99 FIGURE 1 EFFECTIVE 10-MILE EPZ, SUBZONES AND EVACUATION ROUTES 100 FIGURE 2 MINIMUM SHIFT STAFFING 101 FIGURE 3 TSC/OSC ORGANIZATION 102 FIGURE 4 EOF ORGANIZATION 103 FIGURE 5 PUBLIC INFORMATION ORGANIZATION 104 FIGURE 6 EMERGENCY ORGANIZATION INTERFACES 105 FIGURE 7 WCGS EMERGENCY RESPONSE FACILITIES 106 FIGURE 8 AIRBORNE PATHWAY SAMPLING LOCATIONS 107 FIGURE 9 DIRECT RADIATION PATHWAY SAMPLING LOCATIONS 108 FIGURE 10 WATERBORNE PATHWAY SAMPLING LOCATIONS 109 FIGURE 11 FIXED SIREN SITING 110

Revision~~],(( RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 3 of 110

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.

Revisionf:::;:rus' RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 4 of 110 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)

Revisiont "1::§-1,~ RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 5 of 110 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. [Conunitment Step 3.2.3]

I Revision~~l~. RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 6 of 110 4.4 Assessment Actions 4.4.l 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.l 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.

RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 7 of 110 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.l 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.

i I Revisionf;'_;f*l8 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 8 of llO 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~]~a RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 9 of 110 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)

Revis i onm'..'°~}'.'g RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) \ Information Use Page 10 of 110 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.

RevisionG.::),.&lS RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 I (RERP) Information Use Page 11 of 110 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.

Revisio~'l-8-18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 12 of 110 5.3 Superintendent Emergency Planning 5.3.l 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.l 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.l 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.

;s. f30_

• Command and C6nt:roi1 ----------------------------------------------------------------------------------- .----*( Formatted: Underline, Highlight

Revision'.?:~1~ RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 I (RERP) Information Use Page 13 of 110

                                                                         -* Formatted: Font: (Default) Courier New, Highlight 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).

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::.. *'J:::&18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 14 of 110 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[~i'! RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 15 of 110

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 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!,.;:, :!&_l!l RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 16 of 110 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 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 NUE requires plant personnel, the County and State to be notified. No evacuation or activation required.

2. An Alert requires plant personnel, the Courity 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.

Revisionr:1° "-3:-&l~ RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 I (RERP) Information Use Page 17 of llO

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~ RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 18 of 110 o Name of facility o Date and time of classification o Classification o Release status, type of material and estimated duration

Revisio~-:1@-Ta' RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 19 of 110 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 acti~n 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.

Revisionf;*'3c&--ni' RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 20 of 110 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. Be capable bf *estimating re+/-ease rates q.nd off site. 1

                         --'enposurcs              for .an unmonitored, prcss.u°rt                               s'l:riven  r***--r
                                                                                                                           ------1 1cs.*                                                     ~                     ..   -.       L-~-
                              'COfiEaififfiCnt release using* the Containment High Area:

Radiation t-'.i:; *; >,* Monitor readings*

                                                       ,*   *         ,'.,    \n<-

Eind changes in r*~

                                                                                   *=--"---"""---*-**=a* s*Y><=~*-*-*-*'
                              §1Cl!1~.§:1_Il!)3~1:}_t,:_p?;'<S:'?_::ll!!'.9-*~

f§-".:_Off-sitc dose:p:redictionswlJen combined }fith- actuaJ:J release dura_tion information *and meteoro1ogica1 1 data during ah event, *provide sufficient;.<:l.ata to-*l

                              ~stimate the c11mulativepopulation.d6se:}esultin9J frqm the e~<::nt. The actuaU bff-si te poplllation 1
                              ~\'.5;e is .confi:mie<'l.J?Y.2!'t-s'+/-'.t~~!U.O.riJi:,o:r.:Jgg:t ~a_t11pJ,_i:rig_:i
                              'and_analysis .I

5*_*3:a-:- .....Ra-cl:fofogicaCmonl:toring teams have a goal .of. 60 l

        '--*-------~~inutes .from the declaration of Alert or greater]
                         ~mergency to be .ready for deployment to C\Jnfirm j effluent .readings ,and :verify p),:µme emission. and i locati.ons. In acc'6rdancc wi thPP-o6-011, J9int 1
                         ~adiC>l:pgical m*ol).itoring teams (cTRMTs)* are c9inpris~.-~0"-=

p.t least two people in any combination from Wolf i

                         /:reek, Kansas Department of Health and Environmentl

lKDHE},._or Coffey,?,C9untY,.person.\1.e1 r**-----**-------

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.

Revision;;_~_J,_g RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 I (RERP) Information Use Page 21 of 110 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~*l'.ij RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 I (RERP) Information Use Page 22 of 110 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*::.* ~Ia'. RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 23 of 110

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.i-g:- *.Under emergency conditions,~ riorrnal exposure controls                      i
       "*---~-l.***.r.e:*mafota1ned*:*. .T.his*.**is*. . *ensu.*red.. by' the.... on-'-shif~ Heagli,;I PhysicsRadiation 01Protect-ion Technic:i!an (RHP) in the I
                   ~onfrol Ro6m; :the Rad+/-ological Coor<linators in the TSCJ
                   §.Ild EOF ,J 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.

RevisionL-'J:13-l~ RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 24 of 110

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

Revision[:~lB RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 25 of llO 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.l Control Room Facilities

l. 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

l. The TSC is a brisk 2 minutes and l5 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 lOO-year-recurrence winds and is located above the probable maximum flood level.

RevisioniF:-+/-;§-18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 I (RERP) Information Use Page 26 of 110

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[L~:;l:-8I~ RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 27 of 110 o Communicate with the EOF, Control Room and Security personnel o Perform off-site 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.

it:. . . _The OSC;1s. erveJi' as ari'fi:isse~ly area for p}ant i persc;mnei . immeclia tely serving ,in. emergen'cy rep'iir J or Health PhysiesRadi'a"tion Protection support I 1

c~pacity,;duriflg ane~ent. '. 1:rh~ osc funct-;Lons r

                              ~~*c 1 ude *~he_ CO<=:rdin'afion,lfarma tion:: and Ja; spat&" "oE !

Emergencyyesponse Teams .j

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 the 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!;~~;!,& RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 28 of 110

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.

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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.

Revisiont!f:l.#!;J] RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 I (RERP) Information Use Page 30 of 110 6.4.6 On-site Medical Facility Q,, .. r-~j~edicai ,factJ::Lty located },n- the Clyde ,Cessna~ nU,i'.l.ding, :rs staffed. *.iith _a*:~full time Licensed : I

                           ;D~actitionc"t;, *:.* Tl;iis faciJ.:Ltyf is. eq1.d:pp~-~{.t2.J?I-C?£i"?fe'.i ba:sic medfoaQesponse .cap:ab+/-l:'ities            J

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 hours 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.

RevisionL-3,ftJ.,Jl RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 31 of 110 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 hours a day.

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

Revisionr.f'.&Ts RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 32 of 110 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

                ~yirect

• the' activities of. th.e, contro1ioo~inerg~flgy_1

                    ~otifi~ation ,sy;;t~m (ENS) /~Off-sitej               I Commum.cat.<Lr§:

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

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        ~;*:-:5.3 ... Emergency Notific<ifI'on System~dENS) /Off-sT'Eei;.J

Communicator,

                              !1~"2'1,'.tie ,Emergenc'yt11'l0tificatio:h2System (ENS)}~t.f-site [~ I
                                        ;c9mmu,n:i cator~,:i:E:!pprts * ,to* :i:.ti~t:.~h:i ft Ma,ni9'i:rf;: perfonn,s j
                                        '.ti:fiTfial riot'ij:i:Ca.bons' anct:*~nitiates ,* th,c:::Aut:oma ticJ I J)~'aJ.f.ng System (ADS) .or Ba<:iJs:,~2 ADS *.to.;c?lt¥.ut::,thc: j

ERO, and maihta:Lri.~L~ cotnmugica't:"'{ons wi th .. ~t.i}NRC .I

                                        'i:i;;:[: *.manual' ddl}:>ut        of per":<;~el *to.. s.t9-{:t;;*;.the. ERO J 1

1 s 2erforme<3: *:if the ADSJlnd Backu2~ADS ,are notj

£tinction;U1g.1

        '.6.'U-:-        ,Effl6rgency Notifi6at'ion¥tem'                           (fillS) Comm~afo'P 1-_,_'}?l:J.e '.ENS Coffiffiu~cator rc:port,8' to . the !QhiJ.t .f1...@.Q9'Ss~

gnd mai~ains. q,p~mttnieat'.ions',]j:th tlie_:.m~gj" 6'~ ~:'.&4 ,, -* Chemistry Techriic.i.a'."n

                              ;:!._;_,::1Tf&c:,Chemistr1t}l'i'eic:hnici~rr~r~po;'.'ts 'i:o tM*~gifb L.*--- ' j Maria'ger *and ,'t>?;r~orms dose .~~;sessment untfi-L rel_:i,,~_ved 1 by:)lose Assessm~ personnaj;,in the EORj p ~:22 {;,S __ Health; Physi esRadial:'ion .' Protectfuo:n 'Techni ciar.i Cl,,: "-* ,The ;rHea:l th '.Pb.y~Jc s Techni ~;'ia.r;i" re2orts f,1l)[§!ie . ~hi j: \is Mapager and 2e:tforms

• rc!B:i;a~i6n *moni toiing.,:for J 2:ei:~onnel: sent:;;from J@d i~the Control' *Roo.!!iJ.

       '§;i;.'$:C+,6 .:.. . . Control Room Supervisoi                               .. *.         . . .* *. * .     .  .. 1 Q,~4~l\J;~~t~~**. ~:;~t;t ::~?;i[;~::~ .*.~~;~tltgi~~:~;~~-J'*

for> the saf~.*operation of. tlie unit.!

        ~~;,&7 .*             Reactor Opera~
                              ,1, ..:~:'J'h:C' Reactor <0P~.rators* rep~rd?to ,the Contt'§I' Room l
                                        $u~ervisor:,aild,bperform .2la'.rit;;monitoring~aiia reactcii:                   !

f!lctuipma ti~nefgas ,needed Jrjitn' thx ContrBf R~om ,r-- **- 6 .M8 ' *.Nuclear StationOperators 1

                                 ._*    ~~;~t:~2!~};~~~:]~~r::~;~J~t~;;l~;l_:;J,~~:t~~~J aJjd     man,i]2ulatiOp$.,,.,.i!_S dir~s:te§,.j
                                                                                                                      ~]

2

Revisionrf~1g RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 34 of 110

        ,6. 5 .;HJ.::. ShiftrTechnical Advisor ,=(STAD a.. The '.Shift 'Technical Advisor reports to the Shi:Et l
                       ----~anager and_pe);"form~~, STA r3quirements as a§signy,d~j by the_.NRc"J
        &..:.~,~::1:1.0_Init;ial \~mergency"re~pon,se ,to the:majJ>r functionaJ:£!
                       ~reas is within ti.ie c.apabii:Lties of the _minimumj pperati6ris :~hi:ft comp).ementj
        §_,_?.,,:!§-l.1_~11-shift staff "augmentation is available/ when de,em_ed                i pecessary-, *.in .~ccord~?ce with ATT~~I:IME!'f'.!'.J?..!_.::.}'.i,C:~§§J
                       ~IMUM :sTAFFING_E_OR EMERGENCIESJ
'.6 :*6 Technical* Support< Center (TSC)* Organizatlorl
        §_,.§~'1_._._TSC activation.will be p'erformed                  as soon 'as practic_itJ 13-nd _within' the - timed as stated _in ,the" following.:J
        *1~-:~---~i:!t!t:f:h;o:;:\~:t':~::n~ ~~~:~~e~~~;~~~ t~=g~;;!t:l~~~~i(j - - - (

ari_Alert or::higher cl:assification.l 5 Formatted: Normal Ll.1

                       ?.:    ~tl-r+/-l.'l~e-rf!la~or--hl-ng~urs, it is t11e-'g~

acti,mt/3 the TBC \dthin: 30 reinutd of: a ,declaration; p:: _fl:P. . .AJ..9it_or __ hi2Jlei: _dass;ifipation,r-----~-- -------* 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: 0 Site Emergency Manager 0 TSC Operations Coordinator 0 TSC Administrative Coordinator 0 TSC Radiological Coordinator 0 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.

Revisionf:__ MiJl: RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 35 of 110 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 hours 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

Revisionf:'.~:1:-§:18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 36 of 110

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~~lf! RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 37 of 110

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

Revi sion'.;;!_WM RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 38 of 110 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:

                      ~Monitoring ~ s e rfait~hd* dose p)'.'Ojf©:{~

91** Mcini to,Eing; ~ad.ioiog1.ca:l~ S1,!pey .teatriJi'.:JJr~ul t~ r,,,__, *+h>*;*.~'e-<*ra--~ .'"' ~.----Y!"-*-,*-~=*"_.,,....,_,.,,._...->'-<<>'l3,o.+<<+<, £ "-""<'- * ----><*.*> * ~W""""'. o,*o<>-'<~_,..,

                      ,Q:'_,Assists tire1on-site El)le:i;gen.cy.Manager;g,n* the 1 Jorrnufa tionffof'. recommenc:iE@{]2rOte_f!:J_ye;'~c ti'OI!_~

2~Mcirii toring:~i;TPersonne+/-=:rao:i:iflon expos,:u:r;es - tol ensure they,'.ii:tre maintained/in, accordahce with '1 incFR,. 2,§ ii~'ts .u,nleS/%'..Qtl;t~r:Yv.1.f;l~.-~Yih<?fA;e:~sl..!:ii] the Emerg}:m,¢"y,: _Manag~r i;:'Provides:*1;-a,:a;+/-o1ogi.ciaf". d1Ita;and ccinceffis t*o' p):ant:'1

                               ;teams
                               --.~--.,----~   for the team briefs' a
                                                                  ~~

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

Revision~--~1~ RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 39 of 110

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 40 of llO 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 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.

                    '<2.:..._Ad.rni:r,:i.isfrative As~istants perform;.fa9ility i_._

p.cco1;:pta)JHity, a,;isist tp.e .Emergel).cy Manager1 J faxing and copying; log Reeping, and**on site_; potificati9ns. and;'.communicatioµs .. ap .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.

Revis ionr:'.;"~1£! RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 41 of llO 6.7.2 Emergency Response Team (ERT)

+ ~ _'The ERT pers_O~er may **be*' Sel_eCted, irom~~~aI't_h--;

                   ' --- ---physic sRadiat{~h Protec tiop: 'Technicians'~ (Tet:h) ~
                           'chemistry Tech~,: .and InstrU:mehtat_ion and';_;Cqntrol, -i r

Mechanical; ?'o~'tinectrical Maintenance. The ERT

reports. to the':};1aint~nand(Assistant, an{ is 1

_;r:esponsible _fo::p:, repairs, sur:v;eys,,__~~]:_~g,,---l

                                                                                       --~
                           .2malypisL and%arch and rescue.I 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. Q :_Maintenance'. Pfanner-s- develops repair~pfans for j

use by "the *emergency repair and damage cont:r:2:L_i

teams7 and assists in locating and sc;curing '

parts an~eguipment from'the warehoui~.r*-- --

                           ,o, _~larehousc;

• fupport .Personnel assist. i~ca,!:_gi.g_j and securlng_partLand e~quipment . from;tlic* :

pmrehouse .: 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

                           ,o *. EOF_ Facilit3-C:Techniciatj

RevisionlLc.~Js' RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 I (RERP) Information Use Page 42 of 110

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

RevisionCi-8-is' RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 43 of 110 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 hours 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
                                                                                    .*.*. *.---<<*on
                                                                                                 ...........,.- ---->arrd site         ... -*--*' *" -.'. "**-----.

Off-'si *.-------- j*1 te Public

                     --=-;Inforriiatioh\Coordinat~re (PICs). *ih 'p_:r}:r'7-j,__dj,ggj__ _.
                                 ;technical. input for news ,state~nt~                                   2

Revis ionLJ:;:&~ RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 44 of 110

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.Administrati vel

                     **- "'coordfnator\'.iidditional radiatio~ .monitodng1 equipment, ..instrumentation -and.Health;
                                                                     .. r--* -*

Physj_csRadicltioff.Protection support_personne:L*as' I necessary

Revision[::- +/-&k~ RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 45 of 110 o Interfaces with State and County emergency response personnel who are assigned to the EOF regarding matters related to off-site radiological assessment

Revision~:':li!:f~ RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 46 of 110 6.8.4 EOF Team Director

l. 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.

                            's~~,County'* qnd,~J:a_te perso*ifa::1- may becomi_;'part of)
                                 ;the Emergeris:y ;Response , 't~}ms and assYst . with L bff"-.,§ite monitoring in )pc9£dance wj,.th_EPP _06j QJ,1.:.:
       µ.£.5 __ .Dose         11.*ssessmemt* Coordinator

~; - 'R,;ports to~ tl:i~ 'EOF.Radial<<ifcal Coordimito:1'." -and isJ

                            'ie'sp~msible fen:,, d.i'recting/t&g;sisting witfiproviding l Cbmpleted off~ls'ite dose 'projections and :i;,rbtectivef,
                            'adtion .recom!llen.dations_ actf;iities _;*---*-~ ....... **------**

2. **- Ensures;the

                    ~~*~          .

Radiological. 'Status Board-is'.~rnaintainecfl r - - - - * * .....,.~. . . . . . -----~ ~---* - - - - - - - --~ ----~-----~----"'--~-***~-~~*¥-- f£~r.enLJ

                    ~_,__Itcports to. arid* ., d responsil:ifc. for provid1n~

completed off site dose .proj cctions to f_he Do.scJ A'g;sessment_Coo~¢Linator.f

       ,6;_8.46 ___ HPN Coi:nmi.micatori iJ.. _)he"iiPN.Commuriicat*or reports to the EOF:

Radiological Coordinator and mai.ntains r communications. with the NRC via the_Heal'tii_.PhysTcsl

                           'Network_* (HPN) te:lephone .!

RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 47 of 110

                              . RaQ,iologi~a:J,"
                               .co'5rdinai:6r *a:
                              "r~'.~pecess;iry~

_ort@~£c.rt~s.i~i~~off'.:.5ffe}j

Revision~~.~ RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 48 of 110 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.'llorks c£ostlYy1th the WC PIO, en:(sitc_Plft~

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.

Revisionj;:>>49-:1;13- RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 49 of 110

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RevisionCi\::/3-18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 50 of llO i, ~..The N~ws.;w:i:::,i t1:?.r .r,1:?por~s .to Fand provides.* Sllppbrt; fi.:r:: i

the WC PIM'. 'I'.he; NEJws/Wri t~r ,provides. s1:pport; to !

                           'the no    lnciuding: an'.sweri:iig'telephones> writing*!
                           ,and di'stribµting,;'.news :statements ...*.* The' News Write~

maintains a chronological log,of the events and h~ws stat~mentsj r

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                     ~ ~LT].ie'!;Phone, T~ai!i Manager. r ~ r t s fo fhe* WC PIM ;and.J coordinates, the rumoncop.trol aqtivities of the*j Phone Te<3.aj

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                                   .ensure accuracy I updates the status ,log;: maintains. i

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                                   .and State of .Kansas Public* ITnformation*Q_fficers.,_J
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                                   ~mergency Faci"Hties* to communicate pia,g!:.,1_:.:..healthl E111d ,safety _issue& to__ the _publigj

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~ #1~ RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 I (RERP) Information Use Page 52 of 110 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~ij RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 53 of 110 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[,.:MrES RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 54 of 110 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 hour 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 55 of 110 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[: :1--&J?: RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 56 of 110 6.10.7 Radiological Emergency Assistance Center/Training Site (REAC/TS)

1. REAC/TS maintains a 24 hour 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.

Revisioni: :::l-B-1S: RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 57 of llO 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 hour 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

Revisionk'.il-8:1'8: RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 58 of 110 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 hours 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[: +/-8-J.% RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 59 of 110 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 hours.

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 hours.

RevisionC+/--43-lS RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 60 of 110 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)

l. FRMAC is a federal asset available on request by the Department of Homeland Security (DHS) 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 hours. 6.13 Additional Support Agencies 6.13.l Vendor and Architect/Engineers (A/E)

l. 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

Revisio~*BHS RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 61 of 110 o Recommendations

Revision[ -3:-B:l'.8 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 62 of 110 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.

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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 adj~stable 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

Revis ionl;_::¥!--18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 64 of 110

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~-~ie'. RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 65 of 110 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.

Revisioni:"'"1--8-1$ RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 66 of 110 6.16 Communications 6.16.1 Communication Equipment

l. 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.

0 Revision':' ~1~ RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 67 of 110

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.

Revisionr-:-'3::B-18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 68 of llO 6.17 Emergency Plan Training 6.17.1 WCGS has developed an emergency preparedness training program which meets the requirements of 10CFRSO, 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': .. c*J:8' RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 69 of llO 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.

Revis i on1:'l'.4B:J!B RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 70 of 110

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 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 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:::~W:t_ti RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 71 of 110 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!':: -3:--&1:g RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 72 of llO 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 10CFRSO 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.

Revisionf:"" i::!3-l~ RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 73 of 110

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

Revisionr:= ~1~ RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 I (RERP) Information Use Page 74 of 110 o Description of the arrangements for, and advance materials to be provided to official observers

Revisio~+/--8-18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 75 of 110 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 representatives 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) re.view.

1. The RERP and approved changes are distributed to all organizations and individuals with responsibility for implementation of the RERP.

Revision':, -:1-8-1,8' RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 76 of 110 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.

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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: -Hl-18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP)* Information Use Page 78 of 110 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 79 of 110 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.l 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 - 2-mile zone = 8 persons 0 Effective 2 - 5-mile zone = 3,345 persons 0 Effective 5 - 10-mile zone 2,843 persons 0 Effective 0 - 10-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 289 649 30 mph 80.5 Hrs 8 10.3 Hrs EPZ*

Revision: *3:tl-18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 80 of 110 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: +/-B-18 RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 81 of 110 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 hours 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) 8ubzone Effective 10-mile 8ubzone

                                              -  --        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 8E-1                1:25               8E-1               2:00 8-1                 1:30               8-1                2:15 8W-1                1:45               8W-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 8E-2                1: 35              8E-2               2:10 8E-3                1:45               8E-3               2:25 8E-4                1:40               8E-4               2:20 8-2                 1:45               8-2                2:25 8W-2                1:50               8W-2               2:30 W-2                 1:50               W-2                2:25 NW-2               1:40                NW-2               2:25
                                     -  END -

Revision: [a' RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 82 of 110 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 Manaqer 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: !fa: RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 83 of 110 ATTACHMENT C (Page 2 of 8) CROSS REFERENCE BETWEEN NUREG 0654 RERP & WCGS PROCEDURES 0654 RERP Collllllents 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 p '?7. -"* ._,_. EPP 06-002, TECHNICAL SUPPORT Public Information CENTER OPERATIONS 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 request

9. 6.10 Identify local support agencies

c. - EMERGENCY RESPONSE SUPPORT AND RESOURCES 1.a 6.8.2 Persons authorized to request assistance 1.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

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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: [g RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 85 of 110 ATTACHMENT C (Page 4 of 8) CROSS REFERENCE BETWEEN NUREG 0654 RERP & WCGS PROCEDURES 0654 RERP Comments Procedure Section Section F. - EMERGENCY COMMUNICATIONS l.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: :j;~ RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 86 of 110 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 Fiqure 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

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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 l.a thru 6. 3, l.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

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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 l.a & l.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(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 l.a 6.17 l.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

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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

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Revision: t-8-TBD RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06 - 002 (RERP ) Informati on Use Page 90 of 110 ATTACHMENT D (Page 1 of 4) WCGS MINIMUM STAFFING FOR EMERGENCI ES (Reference Step 3.1.10/Step 3.1.11 /) eapah-i-1-i-l>y-Fe-r-Md-i-t:'3:ons *-:*-***- FUMCTIOllAL l\RBA-t>> Plant Operatieas Ii Shift Mana!J-" (SRO) As3e.3SffiCE.t of CoRtrel Reem St1pen,ieer (CRS) Ol[leratieaal AsjCle ets Rea,-ter Op *. rater (RO)

                                          !It.clear Ctatien (Ji3eFate-Emergeae 1 DiFection                     Site EmeF:!Jeae; Hana,rer aa<i Centrel Notifiea.tion/                            BF.1.crgeneJ _co_ff:fflcu'!icat:o:

GomHuH1ieation "' Raeliele,rieal AeeiEleRt Off site EmergeRer Manager a.aE::l Aoseosm.cnt & Support 9-taH ':, ef OfLratienal Ae~ideRt .r*:OSCSS'fHCEt s_. r:eah,a Pa,sies E..pertise +/- HP P_rse.mel -a

                                                                                                          +/-

Plant c_, stem. Shift Te-lmieal .n.e.iser l**** Engin~~.:iH~, UeI3air & Hitigati v-c tsetio:as Cere/1'aern.al :r,-,h-ae.lies Ei.,r. +/- Eleetrieal E,.,r. +/- Meehani<.al En!)'. +/- MeeflanicJ:l Maint. ,: E:1:eetfl-ea+....P..Ta*:i:fl:&-;* ,:

                                          'f-&C-Teelrnie-i-c.l-n                                          +/-                 .;;
*P f:'Oteet:-:i-ve**-:AC-'.i :Gfr9-*     HP---P.e-r,-sonne-1:                                            4
 -f-!-<i---Ncafi-t+

fire fighting Fire PB p-.r TRI! beea+/- heea+/- Bl'i!'faele (FB) (TRS .2. l.b ~ ~ t R,_3E.t1C O:perations and f,eea-1. heeil-1 r~rst hia ~ ~ s.:te l'icees.J Centro: 8eeurit) Pefsorn1el t.11 per and Aeeew.tabi lity Gceuritt l?tiffi

• 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: MTBD RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 91 of 110 ATTACHMENT D (Page 2 of 4) WCGS MINIMUM STAFFING FOR EMERGENCIES

  - END -

Capability for Functional Position Title or Additions: Area U> Major Tasks Expertise On Shift 60 mins 90 mins Plant Shift Manager (SRO) 1 Operations & Control Room 1 Assessment of Supervisor (CRS) 2 Operational Reactor Operator 7*** Aspects (RO) Nuclear Station Operator Emergency Shift Manager l* Direction {Emergency Manager} 1 and Control Site Emergency Manager Notification Jotify licensee, Emergency 1

/Communicati  ~tate, local and      Communicator on            tFede.ral personnel &

rnaintain k:ommunication Radiological !Emergency Operations Off_-site Emergency 1 Accident "'acility (EOF Manager l* 1 1 Assessment & birector) Sr. Radiation 3 Support of bff-site Dose Protection Expertise 2 Operational ~ssessment RP Personnel 2 l Accident bff-site Surveys RP Personnel 1 l Assessment bnsite {out-of- RP Personnel

              ~lant)                Chemistry Personnel
              ~n-Plant Surveys
              ~hemistry/Radiochemi

,,try Plant System technical Support Shift Technical l****

Engineering, Advisor 1 Repair & Core Thermal 1 Mitigative Hydraulics Engineer 1 Actions Repair and Electrical Engineer l* Mitigative Actions Mechanical Engineer Radwaste Operator 1* 1 Mechanical 1 Maintenance Electrical Maintenance I&C '!'echnician Protective Radiation RP Personnel 2 Actions (In- Protection: Plant) Access Control Coverage for repair, mitigative actions, search & rescue, first-aid & firefighting Fire.fighting FB per TRM Local Support Local Fire (TR5.2 .1.b) Support Brigade(FB) Rescue 2* Local Support Local Operations anc Support First Aid Site Access Security, Security Personnel All per

• control and firefighting Security Plari

Revision: -Hl-TBD RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 I (RERP) Information Use Page 92 of 110 ATTACHMENT D (Page 3 of 4) WCGS MINIMUM STAFFING FOR EMERGENCIES Accountability ~ornmunications, rersonnel

              ~ccountability TOTAi   16         20          2

Revision: -:!:-&TBD RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 93 of llO ATTACHMENT E (Page 1 of 3) EPA/KANSAS PROTECTIVE ACTION GUIDES E..l 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: 'r-8-TBD RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 94 of 110 ATTACHMENT E (Page 2 of 3) EPA/KANSAS PROTECTIVE ACTION GUIDES

Revision: -l-8-TBD RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 95 of 110 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: '1-8-TBD RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 96 of 110 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: t&TBD RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 97 of 110 ATTACHMENT F (Page 2 of 2) USAR CHAPTER 15 POSTULATED EVENTS

                               - END -

Revision: -3:-B-TBD RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 98 of 110 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: -:l:-8-TBD RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 99 of 110 ATTACHMENT H (Page 1 of 1) REPORTING OF INCIDENTS PER 10 CFR 20

                                .2202 I       Telephone &  Telegraph          .2203 Written Immediate             24 Hour       30 Day Notification Notification          Notification RADIATION INCIDENTS        VALUES     WCGS   NRC     KDEM   WCGS    NRC   KDEM WCGS     NRC    KDEM TEDE             25 REM ( .25    X      X        X                         X       X       X Sv) 5 REM ( .05   X                             X      X    X       X       X Sv)

MPE .1201 X X X X Shallow dose 250 Rad X X X X X X to skin or 50 REM X X X X X X extremities in excess of MPE .1201 X X X X Lens dose 75 REM (. 75 X X Sv) equivalent 15 REM ( .15 X X X Sv) MPE .1201 X X X r The release 5 ALI X X X X X X of radioactive l ALI X X X X X X material MPE .1201 X X X X inside or outside of a 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 -

Revisi o n: -Hl-TBD RADI OLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) In f ormat i on Use Page 100 of llO FIGURE 1 EFFECTIVE 10-MILE EPZ, SUBZONES AND EVACUATION ROUTES

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Revision: +/-B-TBD RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 101 of 110 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 (1 SRO)

I I I I I SHIFT TECHNICAL ADVISOR (STA) (1) OFFSITE COMMUNICATOR/ENS COMMUNICATOR I (1) I I I I I I I I CONTROL ROOM SUPERVISOR (CRS) (1 SRO)

                                                                -----~

REACTOR OPERATORS (RO) STATION OPERATORS (2) (7) CHEMISTRY TECHNICIAN (1) HEALTH PHYSICS TECHNICIAN

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Direction

- - - - - - -   Technical Guidance SRO= Senior Reactor Operator STA= Shift Technical Advisor
                                                -  END -

Revision: -3:-B-TBD RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 102 of 110 FIGURE 3 TSC/OSC ORGANIZATION SITE EMERGENCY MANAGER RADIOLOGICAL MAINTENANCE ADMINISTRATIVE OPERATIONS COORDINATOR COORDINATOR COORDINATOR COORDINATOR FACILITY MAINTENANCE ADMINISTRATIVE ENS TECHNICIAN PLANNER ASSISTANT . COMMUNICATOR TEAM SECURITY OPERATIONS COORDINATOR RECORDER TEAM MAINTENANCE ENGINEERING COMMUNICATOR ASSISTANT COORDINATOR _LOC_AT!>_D ;m ~ON'.J.'R91, _ROO~ EMERGENCY OPERATIONS ENGINEERING

RESPONSE

COMMUNICATOR TEAM TEAM

                                            - END -

Revision: -3:-8-TBD RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 I (RERP) Information Use Page 103 of 110 FIGURE 4 EOF ORGANIZATION OFF-SITE EMERGENCY MANAGER OPERATIONS RADIOLOGICAL ADMINISTRATIVE COORDINATOR COORDINATOR COORDINATOR ASSISTANT OPERATIONS HPN ADMINISTRATIVE RADIOLOGICAL RECORDER COMMUNICATOR ASSISTANT COORDINATOR DOSE ASSESSMENT TEAM DIRECTOR COORDINATOR TEAM COMMUNICATOR LOCATED AT COUNTY EOC EMERGENCY RESPONSE TEAM REPRESENTATIVE AT COUNTY

                                               -  END -

Revision: -3:-&TBD RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 104 of 110 FIGURE 5 PUBLIC INFORMATION ORGANIZATION COFFEY COUNTY STATE OF KANSAS WOLF CREEK PUBLIC FEMAPU BLIC NRCPUBLIC KGE/ KCPL/KEPCo PUBLIC PUBLIC INFORMATION INFORMATION INFORMATION REPR ESENTATIVE INFORMATION INFORMATION OFFICER OFFICER OFFICER (JIC) OFFICER OFFICER (JIC) (JIC) (JIC) (JIC) (JIC) I I REPRESENTATIVE WOLF CREEK PUBLIC TO THE STATE INFORMATION MANAGER (SEOC) (JIC) I I INFORMATION TECHNICAL SUPPORT NEWS WRITER MESSENGER (JIC) (JIC) (JIC) I I OFFSITE PUBLIC PHONE TEAM MEDIA CENTER INFORMATION MANAGER MANAGER COORDINATOR (JIC) IMC) (EDF) I MEDIA LIAISON IMC) MEDIA PHONETEAM MONITORING (JIC) I I I TEAM MEDIA REGISTRAR (MC) AUDIO VISUAL SUPPORT (MC)

                                                                      -    END -

6

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Revision: MTBD RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) I n f ormation Use Page 1 06 of 110 FI GUR E 7 WCGS EMERGENCY RESPONS E FACILITIES

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Revision : +/-&TBD RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Informat i on Use Page 10 7 of llO FIGURE 8 AIRBORNE PATHWAY SAMPLING LOCATIONS

• FI XED SAMPLING LO CATIONS

                                -   END -

Revision : +/--8-TBD RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 (RERP) Information Use Page 108 of llO FI GURE 9 DIRECT RADIATION PATHWAY SAMPLING LOCATIONS

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• DOS I METER LOCATIONS

                                    -   END -

Revision: +/-8-TBD RADIOLOGICAL EMERGENCY RESPONSE PLAN AP 06-002 I (RERP) Information Use Page 109 of 110 FIGURE 10 WATERBORNE PATHWAY SAMPLING LOCATIONS 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 110 of 110 FIGURE 11 FIXED SIREN SITING f>/ , ~ ,;,* ., .,- ., I ., - .,. "- /- "-/

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                                                                                       -    END -
                                                                                          -    END -

to WO 18-0045 Updated Emergency Plan Change Summary (1 page)

Enclosure 2 Updated Emergency Plan Change Summary Section 5.0- add: 5.8 Command and Control 5.8.1 Transfer of command and control flows from the Control Room to the Technical Support Center (TSC) and then to the Emergency Operations Facility (EOF). Upon classifying an event, the Shift Manager assumes the role of Emergency Manager. The Site Emergency Manager relieves the Shift Manager of Emergency Manager duties at an Alert or higher emergency classification. The Site Emergency Manager may relieve the Shift Manager of Emergency Manager duties at an Unusual Event upon request from the Shift Manager. After the EOF has been activated, the duties of Emergency Manager are transferred from the Site Emergency Manager to the Off-site Emergency Manager. Section 6.0 - revise: 6.3.8 Radiological monitoring teams have a goal of 60 minutes from the declaration of an Alert or greater emergency to be ready for deployment to confirm effluent readings and verify plume emission and locations. In accordance with EPP 06-011, joint radiological monitoring teams (JRMTs) are comprised of at least two people in any combination from Wolf Creek, Kansas Department of Health and Environment (KDHE), or Coffey County personnel. 6.6.10.1 - add bullet:

• Authorizing and supervising Off-site Monitoring Teams until the EOF is staffed.

6.8.4.1.c County and State personnel may become part of the Emergency Response Teams and assist with off-site monitoring, in accordance with EPP 06-011. Attachment D - Revise table to include major tasks; clarify use of RP personnel and command and control transfer. to WO 18-0045 Updated ERO Position Matrix (10 pages)

ERO POSITION MATRIX Pos ition Min Key Procedure(s) Regulato ry Current ERO Position Tasks CT#) Other Procedure Tasks lmplementinl! Actions eliminate d? Tas k Assi11ned t o? Staffing? NRC Pl? E-Plan (Rev. OJ section Reauir ement EMERGENCY OPERATIONS EPP 06-003 FACILITY Off-Site Emergency Manager fl. Assumes command and control of the emergency and interfaces with off-site agencies. Pl. Coordinate and direct off-site emergency response. N/A No N/A Yes Yes A P 06-002 , 5 .2 Fl through F15 NUREG 0654 F2 . Support and provide resources or performs tasks as requested by the Site Emergency M anager. P2 . Declare the EOF activated. AP 06-002 , 6.8. 2 11.A. l .a/I I.A. l .b/ll.A.l.d/11.A.4/11 .8 .4/11. B.5/11. 8.6 F3 . Direct all WCGS personnel in the EOF. P3 . Establish pr iorities for EOF perso nne l. AP 06-002, Figure 4 /11.B. 7.c/ll.C.1.a/ll.E.1/II .E.3/11 .E.4.a thru F4. Obta in personnel and coordinate efforts of emergency response personnel who perform off-site P4. Coord inate actions with the Alternate TSC when the on-site TSC is inaccessible. EPP 06-002, Att. C n/ll.H.2/11.H .3/ ll.f .l .c/11.1.8/11.K .2 rad iolog ical survyes, plus any other personnel deemed usefu l for the emergency response effort. PS. Maintain a log. EPP-06-003 , 5.1 FS . Obta in personnel and coordinate the efforts of outside contractors and vendors. P6 . Deactivate the EOF . EPP 06-003 , 7.1.2 F6. Obtain personnel and coordinate the efforts of additiona l technica l resources that may be ca lled in P7 . Forward all logs to the EOF Adm inistrative Coord inator. EPP 06-003, 7.1.3 during the emergency for further support or shift assignment on-site. PB . Conduct turnover. EPP 06-003, 7. 2.1 F7. Coordinates w ith the Administrative Coord inator in the logistics effort to supply the plant w ith the P9 . Assess plant cond itions and evaluate the need to reclassify the emergency. necessary personnel and equ ipment. EPP 06-003, 7.2.2 PlO. Ensure the EOF, Security, Contro l Room, TSC, ICP and Wolf Creek Pub lic Information Organ ization F8. Bri ef WCGS Execut ive Management on matters related to the emergency . staffs are provided status changes in a timely manner. EPP 06-003, 7.3 F9. Coordinate with the On -Site and Off-Site Public Information Coordinators (PICs) in providing Pll. Conduct init ial and periodic briefings for the EOF personnel on the st atus of the emergency. EPP 06-003, Figure 1 technical input for news statements . Pl2 . Mon itor and determ ine if facili ty conditions warrant facility evacuat ion. HO. Ensure immediate and follow-up not ifications are made wh ich provide sufficient information on P13 . Downgrade or terminate an emergency. emergency classificat ion, plant status, off-site dose projections or measurements, and issue protect ive actions recommendations to off-site authorities responsible for off-site emergency measures. Fll. Request federal assista nce through state officials per the State Plan . F12 . Class ify the emergency (non-delegable). F13 . Recommend protective actions (non-delegable) . F14 . Authorize off-site notifications (non-de legable). FlS . Authorize emergency exposure in excess if 10 CFR 20 (non -delegable). EOF Operations Recorders (2) Pl . Mainta in a log. N/A No - Reduce to P4 to Operations Coordinator No No AP 06-002, Figure 4 Reduce to 1 P2 . Forward all logs to the EOF Admin istrative Coord inator. EPP 06-003, 7.1.2 P3 . Ma inta in the Operations Status current . EPP 06-003, 7.2.2 P4 . Monitor plant status for adverse trends and inform the EOF Operat ions Coordinator of changes in EPP 06-003 , 7.10 plant status that could affect the emergency classification. EPP 06-003 , Figure 1 PS . Track procedu re progress; list the procedure being performed by the Control Room . EOF Radi ological Coord inator Fl. Responsible for radiological monitoring and dose assessment activities off-site. Pl . Mainta in a log. Pl from EOF Facility Technician No N/A Yes Yes AP 06-002 , 6.8.3 fl thru F6 NUREG 0654 F2 . Directs and coordinates activit ies of the Dose Assessment Coordinator and staff. P2 . Forward all logs to the EOF Adm inistrative Coord inator. P6 from EO F Facility Tec h nician A P 06-002 , Figure 4 II .A .l.a/11 .A. l.b/ ll .A. l. d/11 .B.5/11 .B. 6/11.H .2/11. H.3 F3 . Assists the Off-Site Emergency Manager in the formulation of recommended protective actions. P3 . Ensure the Facility Technicia n is ava il ab le. PlO from Dose Assessment Coordi n ator EP P 06-002, Att. C F4. Provides the PIC w ith an assessment of radiological cond itions . P4 . Ensure facility habitab ility has been establ ished .  ; EPP 06-003, 5.4 FS. Requests through the EOF Adm inistrative Coordinator add itiona l ra diation monitoring equipment, PS . Provide the Off-Site Emergency Manager w it h an evaluation of the conditions potentially requ iri ng I EPP 06-003, 7.1.2 inst rumentation and Hea lth Physics sup port personnel as necessary. personne l exposure in excess of 10CFR20 limits. EPP 06-003, 7.1.3 F6. Interfaces with State and County emergency response personnel who are assigned to the EOF P6 . Eva luate condit ions and recommend fac ility evacuation . EPP 06-003, 7.2.2 regard ing matters related to off-site radiological assessment. P7 . Eva luate condit ions and recommend ingestion of Kl. EPP 06-003, 7.3.2 PB . Review and eva luate radiologica l and meteorological data to assess the consequences of any EPP 06-003, 7.6 re lease of radioactive materials. P9 . Verify that rad iological status informat io n is be ing provided to dose assessment personnel and that EPP 06-003, Figure 1 Dose Assessment Technician Fl. Provide completed off-site dose project ions to the Dose Assessment Coordinator. Pl. Ma inta in a log. N/A Yes Eliminate posit ion No No AP 06-002, 6.8.7 Fl NU REG 0654 P2 . Forward all logs to the EOF Administrative Coordinator. Fl - eliminate task AP 06-002, Figure 4 11 .A.1.a/ 11 .A. 1.b/ ll .A. l .d/11. B.5/11. B. 6/11. H. 2/ 11.H. 3 P3 . Ensure Dose Assessment Program is operab le. Pl - eliminate task EPP 06-003 , 7.1.2 P4 . Perform dose assesment. P2 - eliminate task EPP 06-003 , 7.2.2 P3

• DAC does (P3)

EPP 06-003, 7.9 P4

• to DAC EPP 06-003, Figure 1 1 OF 10

ERO POSITION MATRIX Position Min Key Procedure (s) Regulatory Current ERO Pos itio n Tasks fT#l Oth er Procedure Tasks lmplementim! Actions eliminate d? Tas k Assilmed to? Staffinl!? NRC Pl? E- Plan (Rev. OJ s ection Requirement Dose Assessment Coordi nator Fl . Responsible for directing/assisti ng with dose projection and protective action Pl. Maintain a log. P4

• from Dose Asssessment Technician No PlO to Radio logical Coordinator No Yes AP 06-002, 6.8.6 Fl/F2 NU REG 0654 (DAC) recommendation activ ities. P2. Forward all logs to the EOF Administrative Coordinator. AP 006-002, Figure 4 11.A.l .a/ll .A.1.b/11.A.1.d/ll .B. 5/11. 8.6/11 .H.2/11 .H. 3 F2. Ensures the Radiological Status Board is maintained current . P3 . Ensure dose assessment equipment is in place and functional. EPP 06-003, 7.1. 2 P4. Review the current Protect ive Action Recomme ndations and inform the EOF Radiological EPP 06-003, 7.2.2 Coordinator of any changes based on radiological or meteorologica l conditions . EPP 06-003, 7.8 PS . Consult with the EDF Operations Coordinator to obta in information regarding actual or EPP 06-003, Figu re 1 potentia l release paths, sources, and duration.

P6. Implement the requirements of EPP 06-012, DOS E ASSESSMENT . P7. Compare inputs and results with the State dose assessment staff. PS. Inform the EDF Ra diological Coordinator of calcul ated results. P9. Assist in the formulation of Protect ive Action Recommendations. PlO. Review, evaluate and trend off-site radiological m onitoring data and off-s ite dose projections, then brief the EDF Rad iological Coord inator. ffiFAdmi ni nistrative Fl. Responsible for coordinating, directing, and responding to requests from the ERO for Pl . Maintain a log. P4 from Admln Assistant No N/A Yes No AP 06-002 , 6.8.10 Fl/F2 NU REG 0654 Coordinator admin istrat ive and logistical support. P2 . Collect all logs and forward to Emergency Plann ing. PS from Adm ln Ass istant AP 06-002 , Figu re 4 II .A.l.a/ll .A.l .b/ll .A.l .d/ll.A.4/II .B.5/II .B.6/11 .H.2 F2. Ensures off-site notifications are made. P3 . Direct the Control Room to make site announcments as directed by the Off-Site Emergency EPP 06-002, Alt. C /11 .H.3 Manager. EPP 06-003, 5.2 P4. Ensure EOF Adm inistrative Assistants perform notifications . EPP 06-003, 7.1.2 PS. Ensure init ial staffing is adequate. EPP 06-003, 7.1.3 P6. Ca ll-out addit iona l staff as needed. EPP 06-003 , 7.2.3 P7. Arrange for FFD testing as required . EPP 06-003, 7.3.2 PS. Make arrangements for shift relief and mea ls. P9. Assist bu ilding security personnel in establ is hing security posts. EPP 06-003, 7.5 EPP 06-003, Figure 1 EOF Team Communicator (2) Pl. Maintain a log.

                                                                                                                                                                                               -                              N/A
                                                                                                                                                                                                                                                 -                  No - Reduce to PB to EOF Team Director          No         No      AP 06-002, Figure 4 Reduce to 1                                                                                                           P2. Forward all logs to the EOF Administrative Coordinator.                                                                                    1                                                                  EPP 06-003, 7 .1.2 P3. Ensure the radio is turned on and selected to the correct channel.                                                                                                                                            EPP 06-003 , 7.2.2 P4. Notify the Team Director when the teams are ready to depart.                                                                                                                                                  EPP 06-003, 7.13 PS. Establish and ma intain communicat ions with the off-site rad iologica l monitoring teams.

EPP 06-003, Figure I P6. Verify team identificat ion and membership when Field Teams establish radio commun ications . P7. Record survey data taken by Field Teams. PB. Maintain the field team status boards, plot the locations of the teams, affix the appropriate stability class isopleths to the map and provide any needed assistance in ma intaining the Radiologica l Status Board. P9. Communicate directions from the Team Director, maintaining a record of al l transm issions. PlO. Inform the teams of changes to plant status and emergency classifications. Pll. Submit data to EOF Team Director for review and calcu lation ver ifica t ion. 2 OF 10

ERO POSITION MATRIX Position Min Key Procedure(s) Regulatory Current ERO Position Tasks fT#1 Other Procedure Tasks lmnlementin" Actions eliminated? Task Assi1>ned to? Staffin1>? NRC Pl? E* Plan (Rev. 01 section Requirement EOF Operations Coordinator Fl. Briefs the Emergency manager on plant conditions and mitigat ive strategies. Pl . Maintain a log. P4 from Operations Recorder No N/A Yes No AP 06-002, 6.8.9 Fl NUREG 0654 P2 . Forward all logs to the EOF Administrat ive Coordinator. AP 06-002, Figu re 4 11.A.l.a/ll .A .1.b/l l.A.l .d/ll.A.4/11 .B.5/II .B.6/II. H.2 P3 . Contact Diesel Generator vendor for support as needed. EPP 06-002, Att. C /11. H.3 P4 . Post appropr iate Emergency Classification signs. EPP 06-003, 5.5 PS . Ensure facil ity clocks are synchronized to the Contro l Room clock. EPP 06-003, 7 .1.2 P6 . Monitor pla nt conditions for changes which could affect the emergency classification and notify EPP 06-003, 7.1.3 the Off.Site Emergency Manager of the conditions. EPP 06-003, 7.2.2 P7 . Evaluate actual or potential radiological releases based on pla nt conditions . EPP 06-003, 7.3.2 EPP 06-003, 7.4 EPP 06-00 3, Figure 1 Off-site Radiological Pl. Estab lish and ma intain communications w ith the EOF Team Commun icator. P4 from EDF Facility Technician No - Reduce to N/A No No EPP 06-002, Att. C Monitoring Team/Survey Team P2. Perform monitoring duties. PS from EOF Facility Techn icia n 3 EPP 06-003, 7.15 Technician (4) Reduce to 3 EOF Team Director Fl. Responsible for authorizing and supervising Off-Site Monitori ng Teams . Pl . Mainta in a log. PS from EOF Team Communicator No N/A No No AP 06-002, 6.8.4 Fl thru F3 NUREG 0654 F2. Direct Off-Site Monitoring Teams. P2. Forward alt logs to the EOF Administrative Coord inator. A P 06-002, Figure 4 11.A.l .a/ll .A. l.b/ ll .A.1.d/ll .A.4/11. B.S/II.B.6/II.H.2 F3 . Advise the EOF Radiologica l Coord inator of ra dio logica l cond it io ns encountered by the Teams . P3 . Obta in and mon itor rad iological data that may affect the Field Team's ability to complete assigned EPP 06-003, 7.1 .2 /1 1.H.3/1 1. 1.7 act ivit ies. EPP 06-003, 7.2. 2 P4 . Assign each Emergency Response Team w ith a team identifier. EPP 06-003, 7.12 PS . Ensure the logging in and analysis of all incom ing radiological samples. EPP 06-003, Figure 1 P6 . Review and document dosimetry results of emergency response activities. EOF Adm inistrative Assistant Pl . Mainta in a log. N/A No - Reduce to P4 to Administrative Coordinator No Yes (Key AP 06-002, Figure 4 (4) P2 . Forward all logs to the EOF Administrat ive Coord ina tor. 3 PS to Administrat ive Coordinator Comm) EPP 06-003, 7.1.2 Reduce to 3 P3. Ensure the operability of phones and radios to be used for County and State notifica t ion. EPP 06-003, 7.2.2 P4. Ma inta in EOF accountability . EPP 06-003, 7. 11 PS . Provide assistance to the Off-Site Emergency Manager (maintain sequence of events log; answer EPP 06-003, Figure 1 phone; track briefing t imes, assist in logkeeping). P6 . Copy, fax, distribute documents as requested. P7 . Perfor m off-site communications and notifications. Representative at County Fl. Respond to requests from County personne l for clarification or verification of data rece ived from Pl. Mainta in a log. N/A No N/A No No A P 06-002, 6.8.11 Fl NU REG 0654 the TSC or EOF . P2 . Forwa rd all logs to the EOF Administrative Coord inator. A P 06-002, f igure 4 11.A. l .a/II .A . l.b/ 11.A. l. d/l l. A.4/11. B.5/11. B.6/11. B.7 P3 . Keep the Off-Site Emergency Manager apprised of the status of the implementation of Protective EPP 06-003, 7.1.2 a/ll.H.2/11.H .3 Act ion Recommendations. EPP 06-003 , 7.2.2 EPP 06-003, 7.16 EPP 06-003, Figu re 1 HPN Communicator Fl. Maintain communications with the NRC via the Health Physics Network (HPN) te lephone . Pl. Maintain a log. N/A No N/A No No AP 06-002 , 6.8.8 Fl NU REG 0654 P2 . Forward al l logs to the EOF Adm inistrative Coordinator . AP 06-002, Figure 4 I I .A. l.a/ll .A. l .b/l I .A. l.d/11 .B. 5/11. B.6/11. H .2/ 11 .H.3 P3 . Inform the EOF Rad ioliogical Coordinator of the NRC's areas of concern . EPP 06-003, 7. 1.2 EPP 06-003, 7.2.2 EPP 06-003, 7.14 EPP 06-004, Figure 1 3 OF 10

ERO POSITION MATRIX Position Min Key Procedure(s) Regulatory Current ERO Position Tasks rT#l Other Procedure Tasks lmplem e ntine: Actions eliminated? Task Assie:ned to? Stafline:? NRC Pl ? E-Plan (Rev. OJ section Reauire ment EOF Facility Technician FL Ensure the EOF is prepared and functional. Pl . Establish and monitor facility habitabil ity. N/A Yes Elim inate position Yes No AP 06-002, 6 .8 .5 Fl NUREG 0654 P2. Maintain a log . Fl - eliminate task AP 06-002, Figure 4 11.A.l .a/ll .A.l .b/ll.A .l .d/ ll .B.5/11. 8 .6/11.H .2/I I.H.3 P3. Forward all logs to the EDF Administrative Coordinator. Pl - to Rad io logical Coord inator EPP 06-002, Att. C P4. Ensure the source cabi nets in the Kit Room are unlocked . P2 - el im inate task EPP 06-003, 5.3 P3

• el im ina te task EPP 06-003, 7.1.2 PS. Identify and label inoperable equipment.

P4 - to Survey teams P6. Establish a radiologically controlled area boundary in the garage as conditions warrant . EPP 06-003, 7 .1.3 PS - to Survey Teams EPP 06-003, 7 .2.2 P6 - to Radiologica l Coord inator EPP 06-003, 7 .3.2 EPP 06-003, 7.7 EPP 06-003, figure l TECHNICAL SUPPORT CENTER/ OPERATIONS EPP 06-002 SUPPORT CENTER Site Emergency Manager Fl. Assum e command and contro l of the emergency and directs on-site response to stabi lize plant PL Establish priorities for accident m itigation and emergency repair. N/A No N/ A Yes Yes AP 06-002, 5 .1 fl thru FlO NUREG 0654 conditions. P2 . Authorize devia tio ns fro m normal work processes. AP 06-002 , 6 .6.5 11.A.l .a/11 .A.l .b/ll.A.l.d/ll.B.3/11.8 .4/II .B.5/II. B.6 F2. Assess and verify the situation and assure that appropriate mitigating efforts are being taken . P3 . Declare the TSC or ATSC activated . AP 06-002 , figure 3 /II.E .l / ll.E .3/11. 4 .a thru F3 . Review initial event classification and reclassify as appropriate. P4 . Perform TSC deact ivat ion. EPP 06-002, 5.1 n/ll.f .l .c/ll.H .l / 11.1.8/ 11.J .l .a thru d/ll.J .5/11.K.2 F4 . Determine the necessity for evacuation of personnel on-site. PS . Ensure all logs are transmitted to the TSC Administrative Coord inator. EPP 06-002, 6 .0 FS. If a release is occurring, make the necessary assessment of the off-site concentrat ion of P6. Perform turnover. EPP 06-002, 7 .1.4 rad ioactivity result ing from a release . P7 . Direct the TSC Adm inistrative Coord inator to make site announcement regarding TSC activat ion. EPP 06-002, 7 .2.l F6 . Ensure immediate and follow-up notifications are made wh ich provide sufficient information on PS . Conduct init ial and period ic briefings. EPP 06-002, 7 .2.2 emergency classification, plant status, off-site dose project ions or measurements, and issue P9 . Authorize deviat ions from norma l work practices. EPP 06-002, 7 .3 recommendat ions for off-site protective actions to authorities responsible for off-site emergency PlO. Coord inate shift relief for Contro l Room and TSC personne l with the EOF. measures. Pll. Determine evacuation route. EPP 06-002 , f igure 1 F7 . Classify the emergency. (non-delegable) P12. Downgrade or term inate an event. FB. Recommend protective actions. (non-delegable) F9. Authorize off-s ite notifications. (non-delegable) HO. Authorize emergency exposure in excess of 10 CFR 20 limits . (non-delegable) f--- TSC ENS Communicator Fl . Maintain communication with the NRC. Pl. Trans mit log to the TSC Adm inistrat ive Coordinator. N/ A No N/A No No AP 06-002, 6.6.9 Fl NUREG 0654 AP 06-002, f igure 3 11.A.l .a/ lI.A.l .b/ll .A. l .d/11 .8 . 5/11. 8 .6/11 .f . l .c/11 .f . EPP 06-002, 7.2.2 l.f/11.H .l EPP 06-002, 7.14 EPP 06-002, Att . C EPP 06-002, f igure l TSC Radiological Coordinator Fl . Responsible for preve nting or minimizing direct exposure to, or ingestion/i nhalation of, Pl. Provide direction for radiological conditio ns associated with activities controlled by the N/A No N/ A Yes Yes AP 06-002 , 6 .6.10 Fl thru F6 NU REG 0654 radioactive materials during a radiological emergency. Control Room and TSC. AP 06-002 , figure 3 II.A. l .a/11.A. l . b/11.A. l .d/11. 8 . 5/11.8 .6/11. H. l F2 . Monitor dose rates and dose projections. P2 . Transmit log to the TSC Adm inistrative Coordinator. EPP 06-002 , 5.4 F3 . Monitor radiolog ical survey teams' results . P3. Ensure the TS( Facility Technician and one other person to make a team are available. EPP 06-002 , 7.1.4 F4 . Assist the On-site Emergency Manager in the formulation of recommended protective P4. Ensure facility habitability has been established . EPP 06-002 , 7.2.2 act ions . PS. Ensure dosimetry devices are placed in the facility or issued to personnel as appropriate. EPP 06-002, 7.3 .2 FS . Monitor personnel radiation exposures to ensure they are maintained in accordance with PG . Init iate surveys. EPP 06-002, 7.6 10 CFR 20 limits unless otherwise autho rized by the Emergency Manager. P7. Communicate as necessary with the HP Technician in the Control Room regarding the EPP 06-002 , Att. C F6 . Provide radiological data and concerns to plant teams for the team briefs. radiologica l status and dosimetry results of emergency workers dispatched from the Control EPP 06-002 , figure 1 Room . PB. If off-site medical assistance is needed, then ensure Health Phys ics support requirements are met. P9. Assist in evacuation by, d ispatching an HP Techn ician to the Security Building to establish radiological control and conduct personnel monitoring, if requ ired . PlO. Assist in evacuation by, informing the Security Shift Lieutenant of appropriate radiological plant data and direction of the plume for disse mination to evacuating personnel. Pll. If no release is in progress, dispatch one JRMT to appropriate site downwind PMP to obtain dose rate readi ng and report the results to the on-site PIC. 4 OF 10

ERO POSITION MATRIX Position Min Key Procedure(s) Regulatory Current ERO Position Tasks fT#) Other Procedure Tasks lmnlementine Actions eliminated? Task Ass iened to? Staffine? NRC Pl? E-Plan fR ev. 01 section Requirement Engineering Coordinator Fl. Direct activit ies of the Engineering Team to technically assess pla nt status and the severity of Pl. Transmit log to the TSC Adm inistrative Coordinator. N/A No N/A No Yes AP 06-002, 6 .6.7 Fl NU REG 0654 emergency conditions . P2 . Direct accident assessment and mitigation act ivities. AP 06-002, Figure 3 II .A.1.a/ll .A.1.b/ll .A.1.d/ll .B.5/II .B.6/11. H.1 P3 . Advise the TSC Operations Coordinator on technical matters relating to fue l integrity, plant EPP 06-002, 5.7 systems, equipment, and instrumentation . EPP 06-002, 7.2.2 P4 . Support ma intenance items assigned to Eme rgency Response Teams. EPP 06-002 , 7 .9 PS . Provide the key to the lock box located in the kit room, if requested. EP P 06-002, Fig ure 1 Engineering Team (5 - Nuclear, Fl. Eva luate current and historica l pla nt parameters. Pl. Transmit log to the TSC Administrat ive Coord inator.

                                                                                                                                                                                                                 -    --                           N/ A                                 No - Reduce to N/A             No        No      AP 06-002, 6 .6.8         Fl thru F3 NU REG 0654 F2 . Assess the severity of the emergency condit ions and magn itude of fue l damage.                  P2 . Assist w ith troub le-shooting and restoration of equipment .                                                                                3                                                AP 06-002, Att. D         1I.A. l.a/11 .A. l . b/11 .A. l.d/lI. B.5/11. B.6/11.H.l Electrical, Mechanical F3 . Recommend corrective and preventive actions .                                                     P3 . Mon itor on-site and off-site electric distribution and sources.                                                                                                                              AP 06-002 , Figure 3 (AUX/BOP/NSSS))

P4 . The Nuclear Engineer should assess the degree of fuel damage. EP P 06-002, 7.2.2 Reduce to 3 EPP 06-002, 7.15 EPP 06-002, Att. C EPP 06-002, Figure 1 >-- No N/ A No No AP 06-002, 6.6.12 Fl NUREG D654 TSC Team Director Fl . Provide advice on all matters concerning Emergency Response Team activities . Pl. Transmit log to the TSC Adm inistrative Coordinator. N/A P2 . Assume control of all teams d ispatched from the Control Room except on-shift Nuclear Stat ion AP 06-002, Figure 3 I1.A. l.a/1 1.A.1. b/11 .A. l. d/1 1.B. 5/11 .B.6/ 11. H.1 Operators . EPP 06-002, 7.2.2 P3 . Assign each Emergency Response Team w ith a team ident ifier. EPP 06-002, 7 .12 P4 . Inform the TSC Team Commun icator of the formation of Emergency Response Teams. EPP 06-002, Figure 1 PS . Eva luate the need for Hea lth Physics support for all d ispatched teams. P6 . Coo rdinate w ith the Ma intenance Assistant to complete a brief for Emergency Response Teams. AP 06-002, Figure 3 TSC Team Communicator (2) Pl . Transmit log to the TSC Adm inistrative Coordinator. N/ A No - Reduce to N/A No No P2 . Establish and mai ntain com m unicatio ns wit h site Emerge ncy Response Teams . 1 EPP 06-002, 7.2.2 Reduce to 1 P3 . Inform the teams of ch anges to pla nt status and e m e rgency classifications. EPP 06-002 , 7.13 P4 . Ensure all pertinent directions to the teams from the TSC Team Director are logged . EPP 06-002, figure 1 ~ ati ons Coordinator Fl . Supervise reactor plant operat ions (Operations Recorder, Engineeri ng Coord inator, Engineering Pl. Coord inate ove rall emergency response act ivit ies w ith the Control Room staff. P3 from Operations Recorder No N/A Yes Yes AP 06-002 , 6 .6.6 Fl/F2 NUREG 0654 Team, ENS Communicator) . P2 . Transmit log to the TSC Adm inistrative Coordina tor. PS from Operat ions Recorder AP 06-002, Figure 3 II.A. l .a/ 11 .A. l.b/ll .A. l . d/ll .B.5/11 .B.6/11. H.1 F2 . Keep the Site Emergency Manager advised of plant condit ions and operational manipulations. P3 . Ensure norma l power supply to TSC is ava ilable, if not, ensure diesel generator is started. EPP 06-002, 5.2 P4 . Post the appropria te Emergency Classification sign . EP P 06-002, 7.1.4 PS . If radioactive re lease is in progress or imm inent, ensure Filtration and the Iodine Monitor are EPP 06-002, 7.2.2 placed in service . EPP 06-002, 7.3.2 P6. Verify EROS is connected and transm itting data. EPP 06-002, 7.4 P7 . If EROS is not connected, act ivate EROS. EPP 06-002 , Figure 1 PS. Evaluate actual or potential radiologica l releases based on plant condit ions and discuss w ith Site Emergency Manager and TSC Radiological Coordinator. TSC A d ministrative Fl . Ensure emergency notifications are made . Pl . Provide direct ion for the TSC Adm inistrat ive Assistants . P4 from Administrative Assistant No N/ A Yes No AP 06-002 , 6 .6.11 Fl/F2 NUREG 0654 F2 . Responsi ble for logistical support in the areas of TSC personne l, Control Room, procurement and P2 . Co ll ect all logs and transm it to Emergency Planning . PS reword from "Ensure" to "Notify" AP 06-002 , Figure 3 I I .A.l .a/II .A. l.b/11.A. l .d/ ll .B.5/11 .B. 6/11. H.1 Coordinator warehouse support, communications support and equipment repair services . P3 . Make TSC activation announcement as directed by Site Emergency Manager. EP P 06-002. 5.3 P4. Ensure personne l accountabil ity is being performed and ma intai ned. EPP 06-002, 7.1.4 PS . Ensure the State and County are notified t hat the TSC is activated . EPP 06-002, 7.1.5 P6. Ensure site augmentat ion has been met. EPP 06-002, 7.2.3 P7 . Ensure initial TSC staffing is adequate . EPP 06-002, 7.2.6 PS. Make arrangements for shift relief and mea ls. EPP 06-002, 7.2.7 P9. Ensure the TSC Adm inistrat ive Assistants are briefed on Site Emergency Manager's updates and EPP 06-002, 7.3 .2 emergency status. EPP 06-002, 7.5 PlO. Ensure the Security Shift lieutenant is briefed on plant and radiologica l conditions that may EPP 06-002, Figure 1 impact Security operat ions . Pll . If an evacuation has been ordered, dete rmine from the Security Shift lieutenant the status of an 5 OF 10

ERO POSITION MATRIX Position Min Key Procedure(s) Regulatory Current ERO Position Tasks (T#) Other Procedure Tas ks Implementing Actions eliminated? Task Assigned to? Staffing? NRC Pl? E* Plan (Rev. Ol section Requirement TSC Maintenance Coordinator Fl . Direct the Ma intenance Assistant in the coordination of emergency team activities. Pl. Determine the need for and appoint members to Emergency Response Teams. N/A No N/ A Yes Yes AP 06-002 , 6.6.13 Fl/F2 NUREG 0654 F2 . Direct the format ion of teams to be assigned to sea rch and rescue. P2 . Transmit log to the TSC Adm inistrative Coordinator. AP 06-002, Figure 3 II .A.l.a/ ll .A.1.b/ll .A.l .d/ll .B.5/II .B.6/11.H.l P3 . Verify personnel are present and ready to perfo rm Emergency Response Team tasks. EPP 06-002, 5.6 P4 . Provide the Site Emergency Manager w ith an assessment of pre-emergency maintenance EPP 06-002, 7.1.4 activit ies. EPP 06-002, 7.2.2 PS . Coord inate with the Site Emergency Manager to determ ine what information to list on the Priority EPP 06-002, 7.3.2 Board and ma inta in the board up-to-date. EPP 06-002 , 7.8 P6 . Obtain the status of and evaluate team s d ispatched by the Contro l Room from the TSC Operations EPP 06-002 , Figure 1 Recorder. P7 . Direct the Ma intenance Planners to deve lop a repair plan for equipment repair. PS . Authorize deviations from normal work processes. P9 . Init iate EPF 06-011-01, PLANT TEAM BRIEFING CHECKLIST, and coordinate w ith Ma intenance Assistant on field team assignment. PlO. Advise the Site Eme rgency Manager of Eme rgency Response Team status . PU . Provide the key to the lock box located in the kit room, as requested. TSC Facility Techni cian Pl. Perfo rm rad iol ogical duties in the TSC as directed. N/ A No N/ A No No AP 06-002, Figure 3 P2 . Transmit log to the TSC Adm inistrative Coordinator. EPP 06-002, 5.5 P3 . Establ ish and ma inta in facility habitab ility. EPP 06-002 , 7.2.2 P4 . Inform the TSC Rad io log ica l Coordinator of all facility habitab ility surveys. EPP 06-002, 7.7 PS . Identify and labe l inoperab le equ ipment. EPP 06-002, Figure 1 P6 . Ensure 10 sets of 0-1000 mR and 0-5 R dosimete rs are functiona l and ready for use . P7 . Determine dose margin and res pirator qua lifica tions of pe rsonnel assigned to Emergency Response Teams . Operations Communicator Fl . Provide data, progress and pla nt conditions from the Control Room via the Operations Recorders . Pl. If unab le to report to the Contro l Room, report to the EOF (alternate TSC) . N/A No N/ A No No AP 06-002, 6.6.14 Fl NUREG 0654 (located in the Control Room) P2 . Set-up communications system. AP 06-002 , Figure 3 II .A . l.a/ 11 .A. l .b/ ll .A.1.d/ 11 .B. 5/11.B.6/ 11 .H .1 P3 . If NPIS is inoperable, provide Ope ra t ions Status Boa rd Information to Ops Recorders. EPP 06-001, 5.6 EPP 06-001, 7.7 EPP 06-002, Figure 1 Security Coordinator Pl. Transmit log to the TSC Adm inistrative Coo rdinato r. N/ A No N/ A No No AP 06-002, Figure 3 P2 . Ensure the safety of Security person ne l is ma inta ined by coordinating Security act ivities with EPP 06-002, 7.2.2 act ivities of the TSC. EPP 06-002 , 7. 20 P3 . Provide coord inat ion of activit ies (Emergency vehicle arriva l; Search and rescue outside the PAB; EPP 06-002, Figure 1 Access to vita l areas ; EMT support; Activit ies concerning Security). P4 . Inform the Emergency Manager that personne l accountability has been established. TSC Operations Recorder (2) Pl . Trans mit log to the TSC Adm inistrative Coo rd inator. N/ A No - Reduce to P3 to Operations Coord inato r No No AP 06 -002 , Figure 3 Reduce to 1 P2 . Ma intain Operations Status current. 1 PS to Operations Coordinato r EPP 06-002, 7.2.2 P3 . Mon itor plant status for adverse trends and info rm the TSC Operatio ns Coordinator of changes in EPP 06-002, 7.10 pla nt status which could affect the emergency classificat io n. EPP 06-002, Figure 1 P4 . Track procedure progress; list the procedure be ing performed by the Control Room . PS . Communicate inform ation, concern ing emergency teams dispatched from the Contro l Room, directly to the TSC Ma intenance Coord inato r. ID< ' >ho TSC Administrative Assistant

                                                                                                                                          ,f
                                                                                                                                                       *he.Administra' '""

Pl. Transmit log to the TSC Administrative Coordinator .

                                                                                                                                                                                                                 '"'"        '""                     N/A                       No - Reduce to P2 - el iminate task                 No        Yes (Key AP 06-002 , Figure 3 (4)                                                                                                                                   P2 . Ensure the operabil ity of phones and rad ios to be used for County and State notifications.                                         2              P4 - to Adm inistrative Coord inator           Comm)    EPP 06-002 , 7.2.2 Reduce to 2                                                                                                                           P3 . Ma intain TSC accountability .                                                                                                                      P6 . eli minate task                                    EPP 06-002, 7.11 P4 . Provide assistance to the Site Emergency Manager !sequence of events log, logkeeping,                                                                                                                       EPP 06-002, Att. C answer telephone, track briefing schedules).                                                                                                                                                                     EPP 06-002, Figure 1 PS . Copy, fax and distribute documents as requested .

P6 . Provide off-site communicatio ns. Maintenance Planner (3 - Pl . Tran sm it log to the TSC Adm inistrative Coord inator. P2 from Warehouse Support 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 . 1 EPP 06-002, 7.2.2 Reduce to 1 P3 . Provide maintenance support as appropriate to the Maintenance Coordinator . EPP 06-002, 7.18 P4 . Develop repair plans for equ ipment repairs as directed . EPP 06-002, Figure 1 Wareho use Support Pl. Tra nsmit log to the TSC Adm inistrative Coordinator. N/ A Yes Pl - eli minate task No No AP 06-002 , Figure 3 P2 . locate and secure parts and equ ipment from the warehouse as d irected. P2 . to Ma intenance Pla nner EPP 06-002, 7.2.2 EPP 06-002, 7.19 EPP 06-002, Figure 1 6 OF 10

ERO POSITION MATRIX Position Min Key Procedure [s) Re gulatory Curre nt ERO Position Tasks (T# ) Other Pro cedure Tasks Imple m e ntin2 Actions eliminate d? Task Ass i2ne d to? Sta ffin2? NRC PI? E- Pla n (Rev. O) section Require m ent Emergency Response Team Fl. Responsible for repa irs, su rveys, sampling, analysis, and sea rch and rescue . Pl . Transmit log to the TSC Administrative Coordinator. N/A No N/A No No AP 06-002, 6.7.2 Fl NUREG 065411.A.1.b/ll. B.5/II.B.6/II.H .1 (ERT) (HP Tech nicians, P2. Health Physics Technicians will provide the necessary radiolog ical guidance for the task AP 06-002, Att. D Chemistry Technicians, l&C, which the team w ill perform. AP 06-002, Figure 3 Mechanical, Electrical P3 . Health Physics Technicians should provide status updates to the Rad iological Coord inator EPP 06-002, 7.16 Maintenance) during the time t he team is in the field . EPP 06-002, Att . C P4. Perform operability checks on equipment and instruments before leaving the TSC. EPP 06-002, Figure 1 PS. Chemistry Techn icians provide analysis results to the TSC Rad iological Coordinator. P6. Immediately report major anomalies encountered in the plant to t he TSC Team Communicator. P7 . Track Eme rgency Response Team exposure. Maintenance Assistant Fl . Coordinates repair and damage control activities. Pl . Transm it log to the TSC Administrative Coord inator. N/A No N/ A No No AP 06-002, 6.7.1 Fl NUREG 065411.A.1.b/l l.B.5/II. B.6/II.H. l F2. Coordinates deployment of on-site teams . P2 . Assign person nel to Emergency Response Teams for equipment repair, surveys, or search AP 06-002, Figure 3 F3. Coordinates the activit ies of the Ma intenance Planners. and rescue . EPP 06-002, 7.17 P3. Coordinate with the TSC Team Director and brief Emergency Response Teams on team EPP 06-002, Figure 1 objectives. P4. Brief the Maintenance Coordinator on the status of Emergency Response Tea m s. PS. Debrief Emergency Response Teams. JOINT INFORMATION EPP 06-004 CENTER Public Information Officer Fl. Authority and responsibility for WCGS Public Information Organ ization and all Plant information Pl . Transmit log to the PIM . N/A

                                                                                                                                                                                                                                                                       - No           N/ A                                                Yes        No      AP 06 -002, 6.9.2         Fl thru F3 NUREG 0654 (PIO)                       di sseminated to the media.                                                                              P2. Approve news stateme nts.                                                                                                                                                                                            AP 06-002, Figure 5       I I .A. l .a/II .A.l .b/11.A. l . d/ 11 .B. 5/11 .B. 6/11.B.7 .d/11 .G F2. Responsible for ensuring the t imely issuance of accurate information to the public and media        P3. Approve EPF 06-004-07, PHONE TEAM INFORMATION REPORT, and EPF 06-004-10, MEDIA                                                                                                                                       EPP 06-004, 5.1           .4.a/11.G.4 .b during an emergency at WCGS.                                                                             TEAM REPORT .                                                                                                                                                                                                            EPP 06-004, 7.1.2 F3. Coord inate with the County and State for information to be released to the public.                                                                                                                                                                                                                                           EPP 06-004, 7.3 P4. Coordinate with and keep WCNOC Corporate Communications staff i nformed of Public Information Organization actions .                                                                                                                                                                                       EPP 06-004, Figure 1 PS. Maintain a log.

P6. Coordinate development of news statements and respon ses to Phone Tea m or Media Monitoring Team rumors . P7. Coordinate the sc heduling, preparation and implementation of new s co nferences . Publk Information Manager Fl. Ensure that information provided to the public is t imely and accurate. Pl . Maintain a log. N/A No N/ A

                                                                                                                                                                                                                                                                                                         -                                No         No      AP 06-002, 6.9.3          Fl thru F3 NUREG 0654 (PIM)                       F2. Responsible for ensuring the Public Information Organ ization is activated and functions as directed P2 . Coord inate turnover from Wo lf Creek Corporate Commun ications.                                                                                                                                                    AP 06-002, Figure 5       II .A.1.a/ll .A.l .b/ ll .A.l.d/ll.B.5/11.B.6/II .B. 7.d in the EPPs.                                                                                             P3 . Brief Wo lf Creek PIO on information rece ived from Wolf Creek Corporate Communications.                                                                                                                            EPP 06-004, 5.2 F3. Determines and coordinates the activation of the Joint Information Clearing House, Media Center,     P4. App rove news statements in the absence of the Wolf Creek Pub lic Information Officer.                                                                                                                               EPP 06-004, 7.1.2 Phone Team and Media Monitoring.                                                                         PS. Approve EPF 06-004-10, MEDIA TEAM REPORT, in the absence of the Wolf Creek Pub lic                                                                                                                                   EPP 06-004, 7.2 Information Officer.

EPP 06-004, 7.4 P6. Ensure al l event documentation is collected and forwarded to Emergency Planning at the EPP 06-004, Figure 1 term ination of an event. P7. Ensure the JIC is restored to its original co ndition and an inventory is completed at the termination of the event. PB . Direct dea ctiva t ion . P9 . Ensure initial staffing is adequate. PlO. Ca ll in addit iona l staff as needed . PU. Ensu re Phone Team Manager is briefed on event status and information applicable to the Phone Team or Media Monitori ng Team . Pl2. Direct Technical Support Staff activit ies. PU. Perform briefs to keep personnel informed of events in progress. Pl4. Ensure news statements are prepared, approved and distributed in a timely manner. PlS. Continually assess the impact of the emergency on the Pub lic Information Orga nization . Pl6. Ensure staffing needs for shift change or facility re locat ion are implemented. P1 7. Coord inate scheduling and advanced preparation of news conferences . PlB. Ensure rumors are addressed in a timely manner. Pl 9. Ensure t he JI( is restored to its origina l condit ion and an inventory is comp leted at the termination of the event. P20. Forward all Public Information documentation to Emergency Planning. On-Site Public Information Fl . Gather and transmit technical information to the Joint Information Clearinghouse for use in Pl. Transmit log to the TSC Adm inistrative Coordinator. N/ A Yes El iminate position No No AP 06-002, 6.9.4 N/ A Coordi nator (TSC) news statements. P2 . Mainta in a log. Off*Site Public Information Coo rdinator duplicates AP 06-002, Figure 5 P3 . Check personal WCNOC e-mail as necessary to obta in copies of approved, distributed news all tasks EPP 06-004, 7.1.2 statements. EPP 06-004, 7.5 P4. Print news statements and prov ide to the Administrative Assistant for distribution. EPP 06-004, Figure 1 7 OF 10

ERO POSITION MATRIX Pos ition Min Key Procedure(s) Regulatory Current ERO Pos ition Tasks (T#) Othe r Procedure Tasks lmnlementinl! Actions eliminated? Task Assil!ned to? Staffin P? NRC Pl? E- Plan (Rev. OJ section Requirement Off-Site Public Information Fl. Gather and transmit technical information related to the health and safety of the public to Pl . Transmit Jog to the EOF Administrative Coordinator. P4 distribute to EDF & TSC Admin No N/ A No No AP 06-002, 6.9 .5 Fl NUREG 0654 Coordinator (EOF) the Joint Information Clearinghouse for use in news statements. P2 . Maintain a log. Coordinators AP 06-002, Figure 5 I 1.A. l .a/11 .A. l . b/11.A. l .d/l l.B. 5/11 .B. 6/1 1.B.7 .d P3 . Check personal WCNOC e-mail as necessary to obtain copies of approved, d istributed news EPP 06-004, 7.1. 2 statements. EPP 06-004, 7 .6 P4 . Print news state ments and provide to the Administrative Assistant for distribution . EPP 06-004 , Figure 1 Media Center Manager Fl . Set-up the Media Center. Pl. Transmit log to the PIM . Fl thru FS from Media lia ison No N/ A No No AP 06-002 , 6 .9 .6 Fl thru F3 NUREG 0654 F2 . Provide leadership for the Media Reg istrar, AV Support, and Med ia Liaison and P2. Ensure the Media Center is restored to its original cond ition and an inventory is completed P3 from Media Liaison AP 06-002, Figure 5 I 1.A. l.a/11 .A. l . b/l I.A. l .d/11.B. 5/11 .B. 6/11 .B.7 .d management of the news media conferences . at the termination of the event. P4 from Media Lia ison EPP 06-004, 5 .3 F3 . Maintain contact with the Joint Information Clearinghouse to provide news conference P3. Maintain a log. EPP 06-004, 7 .1.2 schedules. P4. Coordinate logistics for conducting news conferences . EPP 06-004, 7.10 PS . Ensure the Media Liaison is aware of all news conference start and end t imes. EPP 06-004, Fig ure 1 Media l iaison Fl . Manage the media at the Media Center. Pl. Transmit log to the PIM . N/A Yes Eliminate position No No AP 06-002, 6 .9 . 7 Fl thru F5 NUREG 0654 F2 . Assist the media with registration and facility orientation. P2 . Ma intain a log. Fl thru FS to Media Center Manager AP 06-002 , Figure 5 11.A. l.a/ ll .A. l. b/l I.A. l .d/ 11.B. 5/11 .B. 6/ 11 .B.7 .d F3. Provide general Wolf Creek background information . P3 . Provide approved news statements and news confernence information to media Pl - eliminate task EPP 06-004, 7 .1.2 F4 . Arrange individual interviews. representatives . P2 - eliminate task EPP 06-004, 7.11 P3 to Media Center Manager EPP 06*004, Figure 1 FS . Announce and coordinate scheduled news conferences . P4. Initiate scheduled news conferences by setting ground rules and t ime limit for the news P4 to Media Center Manager conference and introduc ing persons involved in the news conference .

                                                                                                                                                                                                             ---                                                                                   ---                                AP 06-002 , 6.9 .8        Fl/ F2 NUREG 0654

~ Writer Fl . Provide support to the PIO (answering telephones, wr iting and distributing news Pl. Transmit log to the PIM . N/A No N/ A No No statements) . P2 . Maintain a log. AP 06-002 , Figure 5 I I .A. l.a/ 11 .A.1.b/ ll .A. l.d/ll .B.5/11. B. 6/11. B.7 .d F2 . Maintain a chronological log of the events and news statements. P3. Prepare news statements. EPP 06-004, 7.1.2 P4. Ensure news statements are accurate and contain proper approval s. EPP 06-004, 7.8 PS. Ensure news statements are distributed . EPP 06-004, Figure 1 N/ A No No AP 06-002 , 6 .9 .9 Fl NU REG 0654 Phone Team Manager Fl . Coordi nate the rumor control activities of the Phone Team. Pl. Transm it log to the PIM . N/A No P2. Ensure the Phone Team Room is setup and ready for use. AP 06-002 , Figure 5 I I .A. l.a/ll .A .l.b/ 11 .A. l .d/ll .B. 5/11 .B. 6/ 11. B.7 .d P3. Control information being provided to the Phone Team and Media Monitoring Team . EPP 06-004, 5.4 P4. Control activation and rumor control activities of the Phone Team and Media Monitoring EPP 06-004, 7.1.2 Team. EPP 06-004, 7.14 PS . Direct the activities of the Phone Team and Media Monitoring Team to identify EPP 06-004, Fig ure 1 misinformation being released to the public. P6. Complete an inventory at the termination of the event. P7. Maintain a log. PS. Validate the plant status of the emergency w ith the Public Information Officer or Public Information Manager. P9. Brief the Phone Team Room on the emergency status. PlO. Coordinate funct ions of the Phone Team and Media Monitoring Team. Pll. Conduct turnover. Pl 2. Notify Wolf Creek Public Information Manager of special requests or problems. Techn ical Support (2) Fl . Ensure accuracy of news statements. Pl. Transmit log to the PIM N/A No - Reduce to N/ A No No AP 06-002 , 6 .9 .10 Fl thru F4 NU REG 0654 Reduce to 1 F2 . Maintain the media status board . P2. Maintain a log. 1 AP 06-002 , Figure 5 11.A. l .a/l I .A. l .b/11.A.l .d/ 11 .B. 5/11 .B. 6/11. B.7 .d F3 . Provide technical interpretation for the Wolf Creek, Coffey County, and State of Kansas P3 . Act as primary contact with the On-Site and Off-Site PICs. EPP 06-004, 7 .1.2 Public Information Officers. P4 . Validate Emergency Notification Form informations with the On-Site or Off-Site PIC. EPP 06-004, 7.4 .6 F4 . Gather information from Emerge ncy Facili t ies to commun ica te plant, health and safety PS . Address rumor and Media Monitoring Team issues. EPP 06-004, 7 .7 issues to the public. P6. Ensure signs in the JIC reflect curre nt emergency classification. EPP 06-004, Figure 1 P7 . Assist with news confernecne development and implementation. Repres entative to t h e St ate Fl . Respond to requests from State personnel for clarification or verification of information Pl. Transmit log to the PIM . N/A No N/ A No No AP 06-002 , Fl NUREG 0654 pertaining to Wolf Creek. P2 . Maintain a log. AP 06-002, Figure 5 11.A. l.a/l I .A. l .b/11.A.l .d/11 .B. 5/11 .B. 6/ 11. B.7 .d EPP 06-004, 7 .1.2 EPP 06-004, Figure 1 Information Messenger Pl . Transm it log to the PIM . N/ A No N/ A No No AP 06-002, Figure 5 P2. Maintain a log. EPP 06-004, 7 .1.2 P3 . Establish communications w ith the Media Center. EPP 06-004, 7 .9 P4 . Copy and distribute approved documents as requested . EPP 06-004, Figure 1 8 OF 10

ERO POSITION MATRIX Position Min Key Procedure(s) Regulatory Current ERO Position Tasks (T#) Other Procedure Tasks Imolementine: Actions eliminated? Task Assigned to? Staffine:? NRC Pl? E-Plan [Rev. OJ section Requirement Media Center Registrar (2) Pl . Transmit log to the PIM . N/A No - Reduce to N/A No No AP 06-002, Figure 5 Reduce t o 1 P2. Maintain a log. 1 EPP 06-004, 7.1.2 P3 . Ensure media kits and news statements are readily availa ble to all media representatives. EPP 06-004, 7 .12 P4. Register news media represe ntatives upon their arrival at the Media Center. EPP 06-004, Figure 1 PS . Inform the Media liaison or Media Center Manager of media questions and conce rns . A/V Support Pl. Transmit log to the PIM. N/ A No N/ A No No AP 06-002, Figure 5 P2 . Maintai n a log. EPP 06-004, 7.1.2 P3 . Provide AN support for all news conferences held in Media Ce nter. EPP 06-004, 7.13 EPP 06-004, Figure 1 Phone Team Mem be r {4) Pl . Transmit log to the PIM. N/A No - Reduce to N/A No No AP 06-002, Figure 5 Reduce to 3 P2 . Maintain a log . 3 EPP 06-004, 7.1.2 P3 . Assist in the set-up of the Phone Team Room. EP P 06-004, 7.15 P4 . Answer phone calls from the pub lic. EPP 06-004, Figure 1 PS . Document phone calls . P6. Document rumors or misi nformation. P7. Promptly report rumors or misinformation to the Phone Team Manager. Media M onitoring Tea m (4) Pl. Transmit log to the PIM . N/A No - Reduce to N/A No No A P 06-002, Figure 5 Reduce to 3 P2 . Maintain a log. 3 EPP 06-004, 7.1.2 P3 . Assist in the set-up of the Pho ne Tea m Room . EPP 06-004, 7.16 P4 . Monitor major networks and local stations. EP P 06-004, Figure 1 PS . Log news stories observed, heard, or read . P6 . Promptly re po rt rumors or misinformation to the Phone Team Manager. CONTROL ROOM EPP 06-001 Shift M anager Fl . Respo nsible for the initial evaluation an d cl assificatio n of any abnormal situation and fo r Pl. Emergency classificatio n. {non -d elegable) N/A No N/A Yes Yes AP 06-002, 6.5.1 Fl thru FlO NUREG 0654 directing the appropriate response, including initial activation of a callout . P2. Authori ze off-site notifications. (non-delegable) AP 06-002, 6.5. 2 11.A. l .a/11 .A .1.b/11.A . l .d/ 11 .A. l .e/l l .B.1/11 .B.2/1 1.B F2 . Initiate appropriate tech nical measures to m itigate the event. P3. Make Protective Action Recommendations. {non-delegable) AP 06-002 , Att. D .3/II.B .4/II.B.5/II.B.6/11 .E.1/ II .E.3/II .E.4.a thru F3. Determi ne if releases have occurred, m ake necessary assessment of the off-site P4. Authorize emergency exposures in excess of 10 CFR 20 limits. (non-delegable) AP 06-002 , Figure 2 n/11. F.1.a/11 .F.l.b/11.F . l.c/11 .F.1.f/ 11.1 .8/11 . K. 2 concentration of radioact ivi ty resulting from a release, and evacuate non-essential pe rsonnel if PS. Complete notification form and provide to Off-Site Com municator. EP P 06-001, 5 .1 necessary. P6. Determine evacuation route . EPP 06-001, 7.1.3 F4. Direct activitation of the Control Room ENS and Off-Site Communicators. P7. Complete Em ergency Notification Form . EPP-06-00 1, 7 .2 FS. Ensure immediate and follow-up notifications are made which provide sufficient PS. Ensure personnel accountability is com pleted. information on emergency classification, plant status, off-site dose projections or P9 . If a release is in progress ensure unit vent monitor is in accident mode. mea surem ents, and issue recommenda t ions for off-site protective actions to 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 after the State and County Pl2 . Perform turnover. are notified. F7. Ensure notifications to the NRC are made as sson as possible within 60 minuites of classificatio ns of an emergency. FS. Ensu re other notifications are made in accordance with EPPs. F9. Activate on-site emergency teams if requ ired. HO. Notify plant personnel of the change in plant status. 9 OF 10

ERO POSITION MATRIX Position Min Key Procedure(s) Regulatory Current ERO Position Tasks (T#) Other Procedure Tasks lmplementine Actions eliminated? Task Assiened to? Staffine? NRC Pl? E-Plan (Rev. OJ section Requirement Off-Site Communicator Fl . Perform initial notifications. Pl . Perform follow-up not ifications. Fl from ENS Communicator No N/A Yes Yes AP 06-002, 6.5 .3 Fl/F2 NU REG 0654 F2. Initiate Automatic Dialing System (ADS) or Backup ADS to call out the ERO. (Manual call out P2 . Perform ERO call-out. AP 06-002, Att. D II .A.l.a/ll .A.l.b/ll .A.1.d/ll.B.l / ll .B.5/11.B.6/II .E.2 if ADS is not functioning .) P3 . Perform Site announcements. AP 06-002, Figu re 2 /11.F .1.a/ll.F .1.e P4. Provide Security with classification announcement and badge numbers of those retained EPP 06-001, 5.2.1 by the Shift Manager, but not in the Control Room for accountability. EPP 06-001, 7 .3 PS. Perform turnover . ENS Communicator Fl . Maintain communications with the NRC. Pl. Transmit log to the TSC Adm inistrative Coordinator. N/A Yes Fl to Off-Site Communicator Yes No AP 06-002, 6 .5.4 Fl NU REG 0654 AP 06-002, Att. D 1I.A. l.a/11 .A. l . b/ll .A. l.d/11. B.1/ 11. B. 5/11.B.6/II .F.1. AP 06-002, Figure 2 a/11.F .1.f EPP 06-001, 5.3 EPP 06-001, 7 .4 Chemistry Technician (2) Fl . Perform dose assessment until relieved by Dose Assessment personnel in the EOF . Pl. Perform in-plant sampling and analysis during a declared emergency. N/A No N/A Yes No AP 06-002, 6 .5.5 Fl NUREG 0654 Reduce to 1 (remove Fire P2 . Perform turnover. AP 06-002, Att . D 11.A. l.a/ll .A.l .b/ll.A.1.d/ll .B.1/11 .B. 5/11. B.6/11. F.1. Brigade) AP 06-002, Figure 2 a EPP 06-001, 5 .4 EPP 06-001, 7.5 Health Physics Technician (3) Fl . Performs radiation monitoring for personnel sent from and in the Control Room . Pl . Provide radiological data to the Shift Manager. N/A No N/A Yes No AP 06-002, 6.5 .6 Fl NU REG 0654 Reduce to 2 (remove Fire P2 . Monitor Control Room habitability. AP 06-002, Att. D II.A.1.a/11 .A.1. b/ll .A. l.d/11. B.1/11. B. 5/11.B.6/II .F.1. Brigade) P3 . Brief workers being dispatched from the Control Room . AP 06-002, Figure 2 a P4 . Review and document dosimetry results for emergency workers who are dispatched to the EPP 06-001, 5.5 field from the Control Room . EPP 06-001, 7 .6 PS . Perform Access Control for the Rad iologi cal Controlled Area (RCA) as directed by the Shift Manager. P6 . Perform in-plant surveys and provide job coverage during a declared emergency. Control Room Supervisor Fl . Provides direction ro Reactor Operators and Nuclear Station Operators for safe operation Pl . Transm it log to the TSC Administrative Coordinator. N/A No N/A Yes No AP 06-002, 6 .5 .7 Fl NUREG 0654 of the unit. AP 06-002, Att. D 11.A.1.a/11 .A.1. b/11 .A.1.d/11 . B.1/ 11 . B.5/II.B.6/11 .F.1. AP 06-002, Figure 2 a Reactor Operators (2) Fl. Perform plant monitoring and reactor manipulations as needed from the Control Room . Pl . Transmit log to the TSC Administrative Coordinator.

                                                                                                                                                                                                          -                    N/A                      No          N/ A                        Yes       No      AP 06-002 , 6 .5 .8      Fl NU REG 0654 AP 06-002 , Att. D       II.A. l .a/11 .A. l . b/ll.A. l.d/11. B.1/ 11. B. 5/11.B.6/II.F.1.

AP 06-002 , Figure 2 a Nuclear Station Operators (5) Fl . Perform local plant monitoring and manipu la tions as directed. Pl . Transm it log to the TSC Administrative Coordinator. N/A No N/ A Yes No AP 06-002 , 6.5 .9 Fl NU REG 0654 Increase to 7 to cover Fire AP 06-002, Att. D II.A. l .a/11 .A.1.b/ll .A.1.d/l I. B.1/11. B. 5/11. B.6/11. F.1. Brigade AP 06-002, Figure 2 a Shift Technical Advisor Fl. Performs STA requirements as assigned by the NRC. Pl. Initiate the Emergency Response Data System (EROS) within 60 minutes of an Alert or N/A No N/ A Yes No AP 06-002, 6 .5 .10 Fl NUREG 0654 higher classification. AP 006-002 , Att . D 11.A.1.a/l I.A.1.b/11.A.l. d/l I.B.1/ 11 . B.5/11 . B.6/11 . F.1. AP 06-002 , Figu re 2 a EPP 06-001, 5 .7 EPP 06-001, 7 .8 10 OF 10 to WO 18-0045 Updated Attachment D to AP 06-002, "WCGS Minimum Staffing for Emergencies" (1 page)

Enclosure 4 Updated Attachment D to AP 06-002, "WCGS Minimum Staffing for Emergencies," Capability for Additions: Functional Area 111 Major Tasks Position Title or Expertise On Shift 60 mins 90 mins Plant Operations & Assessment of Shift Manager (SRO) 1 - - Operational Aspects Control Room Supervisor (CRS) 1 - - Reactor Operator (RO) 2 - - Nuclear Station Operator 7*** - - Emergency Direction and Control Shift Manager (Emergency Manager) 1* - - Site Emergency Manager - 1 - Notification/Communication Notify licensee, State, local and Federal personnel & Emergency Communicator 1 3 - maintain communication Radiological Accident Assessment & Emergency Operations Facility (EOF Director) Off-site Emergency Manager 1 Support of Operational Accident Off-site Dose Assessment Sr. Radiation Protection Expertise 1* 1 1 Assessment Off-site Surveys RP Personne l 3 Onsite (out-of-plant) RP Personnel 2 In-Plant Surveys RP Personnel 2 1 Chemistry/Radiochemistry Chemistry Personnel 1 1 Plant System Engineering, Repair & Technical Support Shift Technica l Advisor 1**** - - Mitigative Actions Core Thermal Hydraulics Engineer - 1 - Electrical Engineer - 1 - Mechanical Engineer - 1 - Repair and Mitigative Actions Radwaste Operator 1* - - Mechanical Maintenance - 1 - Electrical Maintenance 1* 1 - l&C Technician - 1 - Protective Actions {In -Plant) Radiation Protection : RP Personnel 1* 2 - Access Control Coverage for repair, mitigative actions, search & rescue, first-aid & firefighting Firefighting= Fire Brigade(FB) FB perTRM Local Local (TRS.2.1.b) Support Support Rescue Operations and First Aid 2* Local Local Support Support Security, firefighting communications, personnel Security Personnel All per Site Access Control and Accountability accountability Security Plan TOTAL 16 20 2

• 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 111 Discipline-specific skills training for personnel in the above table are contained in discipline-specific tra ining documents such as AP 30D-006, CHEMISTRY TRAINING PROGRAM and AP 30D-100, RADIATION PROTECTION TRAINING PROGRAM . Emergency f'lan training is contained in EPP 06-021, TRAINING PROGRAMS. [Commitment Step 3.2.5) to WO 18-0045 Updated "Letter of Consultation and Concurrence from Off-site Response Organizations Acknowledgement of Opportunity to Review and Support WCNOC License Amendment Request" (1 page)

Enclosure 5 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, and again on March 15, 2018, 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 reduction of the total number of ERO responders. During the reference meeting, WCNOC EP Staff provided assurances that the proposed changes wlll not adversely affect existing capabllltles for prompt notification to the stakeholders of an Emergency Classification Level, for radlologlcal monitoring and assessment support, and for ongoing communication and coordination of emergency Information. In addition to maintaining notification capabllltles 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 classlflcatlon level. The staffing levels at the EOCs will not change. The ERO will continue to support the state for off*site radiological monitoring and assessment. Coordination arrangements between WCNOC and the ORO stakeholders will continue to allow for timely dissemination of emergency Information to the publlc. Activation time for the EOF Is not changing and remains at 90 minutes. With the assurances noted above, the ORO stakeholders representing the named organization, have received Information on the Emergency Response Organization (ERO) License Amendment Request (LAR) to the Nuclear Regulatory Commission (NRC) and support the requested changes. ORGANIZATION DATE 10//5-/18 l<ansasDepartmeoiHealth and Environment (KDHE)

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