ML20023A020

Rev. 45 to Emergency Plan and Emergency Plan Implementing Procedure

ML20023A020
Person / Time
Site:	Arkansas Nuclear
Issue date:	01/15/2020
From:	Entergy Operations
To:	Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
Shared Package
ML20023A021	List: 0CAN012001, Submittal of Emergency Plan and Emergency Plan Implementing Procedure ML20023A020
References
OCAN012001
Download: ML20023A020 (452)

Text

Attachment 1 to 0CAN012001 Summary of Changes to the ANO Emergency Plan to 0CAN012001 Page 1 of 2

SUMMARY

OF CHANGES TO THE ANO EMERGENCY PLAN The following tables provide a brief description or summary of changes made to the Arkansas Nuclear One (ANO) Emergency Plan (EPlan) included in Attachment 2 of this submittal. A detailed assessment of each change is maintained on site and is available upon request. This summary includes changes completed in Revisions 44 and 45 of the EPlan.

Each change is preceded by either "screen or "evaluation", indicating whether the change required a full evaluation in accordance with 10 CFR 50.54(q). Those not requiring a full evaluation are preceded by the term "screen". Note that editorial changes to the Table of Contents are made to support the changes described in the following summary table, where necessary. Table of Contents updates are not discussed further.

The following table lists changes incorporated in Revision 44 of the EPlan. These changes are directly derived from changes made to the NRC-approved OP-1903.010, "Emergency Action Level Classification," basis document (ML18337A247) and, therefore, no 10 CFR 50.54(q) evaluation was required. A copy of OP-1903.010 is included in Attachment 4 of this letter.

Arkansas Nuclear One Emergency Plan, Revision 44 Section Revised Description of Change (Screen) - Changed the following definitions to match the approved OP-1903.010 Pages 19-23, procedure. Emergency Action Level, Emergency Classification Level, Hostile Action, Definitions Protected Area, and Security Owner Controlled Area (SOCA).

(Screen) - Changed "Emergency Class ICs and associated Emergency Action Levels (EALs) that apply to both Unit 1 and Unit 2, are listed in Table D-1, Summary of Section D, Step 1.0 Initiating Conditions" to "Emergency Class ICs and associated Emergency Action Levels (EALs) that apply to both Unit 1 and Unit 2, are in OP-1903.010, "Emergency Action Level Classification.""

(Screen) - Changed "Table D-1 provides examples of initiating conditions used to determine the Emergency Class" to "Table D-1 provides a summary of EAL Categories Section D, Step 6.0 used to determine the Emergency Class. OP-1903.010 Emergency Action Level Classification provides details on initiating conditions."

(Screen) - Changed "Summary of Initiating Conditions" to "Summary of EAL Categories." In addition, Table D-1 was modified, replacing the initiating conditions with Section D, Table D-1 the EAL categories and sub-categories, consistent with the approved changes to OP-1903.010.

(Screen) - Changed "The general criteria described in Section D are used to define the four Emergency Classes for emergency planning purposes. The initiating conditions are shown in Table D-1. The initiating conditions listed in table D-1 are incorporated into the Emergency Plan Implementing Procedures, along with plant specific indicators, to assist the person responsible for Emergency Direction and Control in recognizing and declaring the appropriate Emergency Class." to "The general criteria described in Section I, Step 1.0 Section D are used to define the four Emergency Classes for emergency planning purposes. The Emergency Class categories are listed in Table D-1. Emergency Class ICs and associated Emergency Action Levels (EALs) that apply to both Unit 1 and Unit 2, are in OP-1903.010 Emergency Action Level Classification, along with plant specific indicators, to assist the person responsible for Emergency Direction and Control in recognizing and declaring the appropriate Emergency Class."

to 0CAN012001 Page 2 of 2 Arkansas Nuclear One Emergency Plan, Revision 44 Section Revised Description of Change (Screen) - Changed "It should be noted that, should any of these design basis accidents occur, the category they would be placed in at that time would depend on the actual consequences (Table D-1) rather than on the postulated consequences used to Section I, Step 1.0 develop Tables D-3 and D-4" to "It should be noted that, should any of these design basis accidents occur, the category they would be placed in at that time would depend on the actual consequences (OP-1903.010 Emergency Action Level Classification) rather than on the postulated consequences used to develop Tables D-3 and D-4."

(Screen) - Deleted reference to Super Particulate Iodine and Noble Gas (SPING) radiation monitors 2RX-9845 U-2 Auxiliary Building Extension Turbine Building EL 386 Section I, Table I-5 Door #394 and 2RX-9850 Low Level Radwaste Storage Building Radwaste Building consistent with the approved changes to OP-1903.010.

The following table includes the changes incorporated in Revision 45 of the EPlan.

Arkansas Nuclear One Emergency Plan, Revision 45 Section Revised Description of Change (Screen) - Replaced references to the London Fire Department with reference to the "Local" Fire Department.

This change involves guidance for the Offsite Response Organization fire department services that are utilized during an emergency. This change directs ANO that a local Various fire department is used, which is ensured through a Letter of Agreement. This does not change any equipment of the ANO EPlan and does not affect the activation and operation of the Emergency Response Facilities (ERFs) or the responsibility for classification, notification, dose assessment, or Protective Action Recommendations (PARs). The ability to maintain the EPlan is not affected by this change. No further evaluation is required for this change.

(Screen) - Updated Figure E-1, "Predicted Siren Coverage," with latest information.

This change is a clarifying description of the predicted siren coverage. The new revised figure corrects inaccuracies of the previous figure (added two sirens, corrected Section E, Figure E-1 labeling) to align with the current approved Alert and Notification System (ANS) report.

This does not change any equipment of the ANO EPlan and does not affect the activation and operation of the ERFs or the responsibility for classification, notification, dose assessment, or PARs. The ability to maintain the EPlan is not affected by this change. No further evaluation is required for this change.

(Screen) - Changed "The communication systems available to ANO for use during an emergency consist of a mixture of: Commercial telephone system, Entergy telephone system, ANO plant phone system" to "The communication systems available to ANO for use during an emergency consist of separate in plant communication systems; the Entergy Corporate telephone system". In addition, changed "The direct communication Section H, Step 2.0 links available" to "Communication links are available".

This change is a clarifying description of the communications systems at ANO. This does not change any equipment of the ANO EPlan and does not affect the activation and operation of the ERFs or the responsibility for classification, notification, dose assessment, or PARs. The ability to maintain the EPlan is not affected by this change.

No further evaluation is required for this change.

List of Undefined Acronyms IC Initiating Condition

Attachment 2 to 0CAN012001 Arkansas Nuclear One Emergency Plan Revision 45 (201 pages)

ARKANSAS NUCLEAR ONE EMERGENCY PLAN Revision 45 Facility Operating License Numbers DPR-51 and NPF-6 Docket Numbers 50-313 and 50-368 Effective: January 14, 2020

ARKANSAS NUCLEAR ONE EMERGENCY PLAN TABLE OF CONTENTS Section Title Page TABLE OF CONTENTS ................................................................................................ 1 LIST OF APPENDICES .............................................................................................. 16 LIST OF TABLES ....................................................................................................... 17 LIST OF FIGURES ..................................................................................................... 18 DEFINITIONS ............................................................................................................. 19 ABBREVIATIONS ....................................................................................................... 25 CROSS REFERENCE INDEX TO NUREG-0654 ....................................................... 27 1.0 STATEMENT OF EMERGENCY PLANNING POLICY .............................................. 34 2.0 SCOPE AND APPLICABILITY ................................................................................... 34 2.1 PHYSICAL AREA INVOLVED .................................................................................... 35 2.2 PLANS AND IMPLEMENTING PROCEDURES

SUMMARY

..................................... 35 3.0

SUMMARY

OF EMERGENCY PLAN ......................................................................... 36 3.1 EMERGENCY PLAN OBJECTIVES ........................................................................... 36 3.2

SUMMARY

OF THE EMERGENCY PLANNING LOGIC............................................ 37 3.2.1 Graded Classification System ..................................................................................... 37 3.2.2 Emergency Organizations .......................................................................................... 37 3.2.3 Emergency Measures ................................................................................................. 37 3.2.4 Equipment and Facilities ............................................................................................. 38 3.2.5 Training ....................................................................................................................... 38 A ASSIGNMENT OF RESPONSIBILITY ..................................................................... A-1 1.0 ENTERGY OPERATIONS INCORPORATED .......................................................... A-1 1.1 RESPONSIBILITIES ................................................................................................. A-1 1.2 ENTERGY OPERATIONS/ENTERGY OFFSITE DEPARTMENT/SECTION CAPABILITIES .......................................................................................................... A-2 2.0 OFFSITE SUPPORT ORGANIZATIONS.................................................................. A-3 2.1 ARKANSAS PRIMARY GOVERNMENTAL SUPPORT ORGANIZATIONS............. A-3 2.1.1 Local Government .................................................................................................... A-4 Revision 45 1

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Section Title Page 2.1.2 State Government ..................................................................................................... A-4 2.2 ARKANSAS SECONDARY GOVERNMENTAL SUPPORT ORGANIZATIONS ...... A-6 2.2.1 Arkansas Highway and Transportation Department ................................................. A-7 2.2.2 The Arkansas Military Department (National Guard) ................................................ A-7 2.2.3 County Food and Agricultural Councils .................................................................... A-7 2.2.4 Arkansas Department of Parks and Tourism ............................................................ A-7 2.2.5 Arkansas Game and Fish Commission .................................................................... A-7 2.2.6 Local School Districts ............................................................................................... A-7 2.2.7 Arkansas Department of Human Services ................................................................ A-7 2.2.8 American National Red Cross (ARC) ....................................................................... A-7 2.2.9 Civil Air Patrol ........................................................................................................... A-8 2.2.10 Other State and Local Resources ............................................................................. A-8 2.3 LAW ENFORCEMENT SUPPORT ORGANIZATIONS ............................................ A-8 2.3.1 Sheriff Departments (Pope, Yell, Johnson, and Logan Counties) ............................ A-8 2.3.2 Arkansas State Police ............................................................................................... A-8 2.4 FIRE SUPPORT ORGANIZATIONS ........................................................................ A-8 2.4.1 Local Fire Department .............................................................................................. A-8 2.5 MEDICAL SUPPORT ORGANIZATIONS ................................................................. A-9 2.5.1 Physicians ................................................................................................................. A-9 2.5.2 Hospitals ................................................................................................................... A-9 2.5.3 Pope County Emergency Medical Service ............................................................... A-9 2.5.4 University of Arkansas for Medical Sciences Hospital .............................................. A-9 2.5.5 Other Medical Facilities ............................................................................................ A-9 Revision 45 2

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Section Title Page 2.6 FEDERAL GOVERNMENT SUPPORT ORGANIZATIONS ................................... A-10 2.7 INDUSTRIAL SUPPORT ORGANIZATIONS ......................................................... A-10 B ORGANIZATIONAL CONTROL OF EMERGENCIES .............................................. B-1 1.0 NORMAL PLANT ORGANIZATION ......................................................................... B-1 2.0 INITIAL RESPONSE STAFF .................................................................................... B-1 2.1 SHIFT MANAGER / EMERGENCY DIRECTOR ...................................................... B-2 2.2 SHIFT ENGINEER / SHIFT TECHNICAL ADVISOR ................................................ B-2 2.3 CONTROL ROOM COMMUNICATOR ..................................................................... B-2 2.4 PLANT EMERGENCY RESPONSE TEAMS/GROUPS ........................................... B-3 2.4.1 Staff Augmentation Group (SAG) ............................................................................. B-3 2.4.2 First Aid and Rescue Personnel ............................................................................... B-3 2.4.3 Fire Brigade .............................................................................................................. B-4 2.4.4 Security Personnel .................................................................................................... B-4 2.4.5 Chemistry Group ....................................................................................................... B-4 2.4.6 Maintenance Group .................................................................................................. B-4 2.4.7 Repair and Damage Control Teams ......................................................................... B-4 3.0 EMERGENCY RESPONSE ORGANIZATION ......................................................... B-4 3.1 EMERGENCY OPERATIONS FACILITY ................................................................. B-5 3.1.1 Emergency Director (ED) ......................................................................................... B-5 3.1.2 EOF Offsite Communicator ....................................................................................... B-5 3.1.3 EOF Technical Advisor ............................................................................................. B-6 3.1.4 EOF Communicator .................................................................................................. B-6 3.1.5 Radiological Assessment Coordinator (RAC) ........................................................... B-6 Revision 45 3

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Section Title Page 3.1.6 Dose Assessor .......................................................................................................... B-7 3.1.7 Offsite Team Coordinator ......................................................................................... B-7 3.1.8 EOF Manager ........................................................................................................... B-8 3.1.9 EOF Maintenance Coordinator ................................................................................. B-8 3.1.10 EOF Log Keeper ....................................................................................................... B-9 3.1.11 Admin & Logistics Coordinator ................................................................................. B-9 3.1.12 Public Information Liaison ......................................................................................... B-9 3.1.13 Lead Offsite Liaison .................................................................................................. B-9 3.2 TECHNICAL SUPPORT CENTER ......................................................................... B-10 3.2.1 Emergency Plant Manager (EPM) .......................................................................... B-10 3.2.2 Security Coordinator .............................................................................................. B-10 3.2.3 TSC Manager ......................................................................................................... B-11 3.2.4 TSC ENS Communicator ........................................................................................ B-11 3.2.5 TSC Communicator ................................................................................................ B-11 3.2.6 Reactor Engineer .................................................................................................... B-12 3.2.7 Operations Coordinator .......................................................................................... B-12 3.2.8 Maintenance Coordinator ....................................................................................... B-12 3.2.9 Engineering Coordinator ......................................................................................... B-13 3.2.10 Radiological Coordinator ........................................................................................ B-13 3.3 OPERATIONAL SUPPORT CENTER .................................................................... B-13 3.3.1 OSC Manager ......................................................................................................... B-13 3.3.2 Work Control Coordinator ...................................................................................... B-14 3.3.3 Operations Support ................................................................................................. B-14 Revision 45 4

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Section Title Page 3.3.4 OSC Log Keeper ................................................................................................... B-15 3.3.5 RAD/Chem Coordinator .......................................................................................... B-15 3.3.6 Electrical / I&C Coordinator .................................................................................... B-15 3.3.7 Mechanical Coordinator .......................................................................................... B-16 3.4 JOINT INFORMATION CENTER (JIC) ................................................................... B-16 3.4.1 Company Spokesperson ........................................................................................ B-16 3.4.2 Technical Advisor ................................................................................................... B-16 3.4.3 JIC Manager ........................................................................................................... B-16 3.4.4 Information Coordinator .......................................................................................... B-17 3.4.5 JIC Technical Assistant .......................................................................................... B-17 3.4.6 Press Release Writer .............................................................................................. B-17 3.4.7 Media Liaison .......................................................................................................... B-17 3.4.8 JIC Log Keeper ....................................................................................................... B-17 3.4.9 Logistics Coordinator .............................................................................................. B-17 3.4.10 Credentialing ........................................................................................................... B-18 3.4.11 Inquiry Response Coordinator ................................................................................ B-18 3.4.12 Inquiry Responders ................................................................................................. B-18 3.4.13 Media Monitoring .................................................................................................... B-18 4.0 EMERGENCY RESPONSE ORGANIZATION INTERFACES WITHIN THE ORGANIZATION AND WITH OFFSITE ORGANIZATIONS ................................... B-18 C EMERGENCY RESPONSE SUPPORT AND RESOURCES ................................... C-1 1.0 PERSONNEL AUTHORIZED TO REQUEST AID .................................................... C-1 2.0 FEDERAL RESPONSE ORGANIZATIONS.............................................................. C-1 Revision 45 5

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Section Title Page 2.1 NUCLEAR REGULATORY COMMISSION (NRC) ................................................... C-1 2.2 DEPARTMENT OF HOMELAND SECURITY (DHS) / FEDERAL EMERGENCY MANAGEMENT AGENCY (FEMA) .......................................................................... C-1 2.3 DEPARTMENT OF ENERGY ................................................................................... C-2 2.3.1 Department of Energy, Oak Ridge Operations ......................................................... C-2 2.4 NATIONAL WEATHER SERVICE ............................................................................ C-2 2.5 MEMPHIS UNIVERSITY EARTHQUAKE INFORMATION CENTER / NATIONAL EARTHQUAKE INFORMATION CENTER ............................................................... C-2 2.6 U.S. COAST GUARD ............................................................................................... C-2 2.7 U.S. ARMY CORPS OF ENGINEERS ..................................................................... C-2 2.8 ENVIRONMENTAL PROTECTION AGENCY .......................................................... C-2 3.0 LIAISON WITH STATE, LOCAL, AND FEDERAL RESPONSE ORGANIZATIONS C-3 4.0 OFFSITE RADIOLOGICAL/ANALYTICAL ASSISTANCE ........................................ C-3 5.0 EMERGENCY RESPONSE RESOURCES .............................................................. C-3 6.0 ADDITIONAL ASSISTANCE .................................................................................... C-4 6.1 UTILITIES/UTILITY GROUPS .................................................................................. C-4 6.1.1 Entergy Corporation .................................................................................................. C-4 6.1.2 Institute of Nuclear Power Operations ...................................................................... C-5 6.1.3 Miscellaneous Industry Groups ................................................................................ C-5 6.2 CONTRACTORS ...................................................................................................... C-5 D EMERGENCY CLASSIFICATION SYSTEM ............................................................ D-1 1.0 CLASSIFICATION SYSTEM BACKGROUND .......................................................... D-1 2.0 NOTIFICATION OF UNUSUAL EVENT ................................................................... D-2 3.0 ALERT ...................................................................................................................... D-2 Revision 45 6

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Section Title Page 4.0 SITE AREA EMERGENCY ....................................................................................... D-2 5.0 GENERAL EMERGENCY ........................................................................................ D-2 6.0 EMERGENCY CLASS CRITERIA ............................................................................ D-2 7.0 DESIGN BASIS ACCIDENT EMERGENCY CLASSES ........................................... D-3 7.1 CLASSIFICATION OF POSTULATED ACCIDENTS................................................ D-3 E NOTIFICATION METHODS AND PROCEDURES................................................... E-1 1.0 NOTIFICATION ........................................................................................................ E-1 1.1 NOTIFICATION OF UNUSUAL EVENT ................................................................... E-1 1.2 ALERT ...................................................................................................................... E-2 1.3 SITE AREA EMERGENCY ....................................................................................... E-2 1.4 GENERAL EMERGENCY ........................................................................................ E-2 2.0 EMERGENCY MESSAGES ..................................................................................... E-3 3.0 EARLY WARNING SYSTEM .................................................................................... E-3 4.0 PUBLIC WARNING MESSAGES ............................................................................. E-4 F EMERGENCY COMMUNICATIONS .........................................................................F-1 1.0 NOTIFICATION AND ACTIVATION OF STATE, LOCAL, AND SITE EMERGENCY RESPONSE NETWORKS .................................................................F-1 2.0 COMMUNICATIONS .................................................................................................F-1 2.1 COMMUNICATIONS WITH FEDERAL, STATE, AND LOCAL AGENCIES ..............F-1 2.2 ONSITE COMMUNICATIONS ...................................................................................F-1 2.3 COMMUNICATIONS BETWEEN THE SITE AND MEDICAL FACILITIES................F-1 2.4 COMMUNICATIONS BETWEEN ENTERGY OPERATIONS AND OTHER ORGANIZATIONS .....................................................................................................F-2 3.0 ACTIVATION OF EMERGENCY PERSONNEL ........................................................F-2 Revision 45 7

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Section Title Page G PUBLIC EDUCATION AND INFORMATION ............................................................ G-1 1.0 PUBLIC INFORMATION CONTENT AND DISSEMINATION .................................. G-1 1.1 PUBLIC INFORMATION CONTENT ........................................................................ G-1 1.2 PUBLIC INFORMATION DISSEMINATION ............................................................. G-1 2.0 NEWS MEDIA COORDINATION AND FACILITIES ................................................. G-1 3.0 EMERGENCY CLASSIFICATION INFORMATION RELEASES .............................. G-2 4.0 NEWS MEDIA EXPOSURE TO EMERGENCY PLANNING INFORMATION .......... G-2 H EMERGENCY FACILITIES AND EQUIPMENT ....................................................... H-1 1.0 EMERGENCY RESPONSE FACILITIES.................................................................. H-1 1.1 CONTROL ROOMS .................................................................................................. H-1 1.2 TECHNICAL SUPPORT CENTER ........................................................................... H-1 1.3 OPERATIONAL SUPPORT CENTER ...................................................................... H-1 1.4 EMERGENCY OPERATIONS FACILITY ................................................................. H-2 1.5 FEDERAL GOVERNMENT EMERGENCY OPERATIONS CENTER ...................... H-3 1.6 STATE GOVERNMENT EMERGENCY OPERATIONS CENTERS......................... H-3 1.7 COUNTY EMERGENCY OPERATIONS CENTERS ................................................ H-3 1.8 ENTERGY OPERATIONS/ENTERGY ARKANSAS, INC. CORPORATE OFFICES H-3 1.9 ENTERGY ARKANSAS, INC. RUSSELLVILLE SERVICE CENTER ....................... H-4 2.0 COMMUNICATIONS SYSTEMS .............................................................................. H-4 2.1 COMMUNICATIONS WITHIN ENTERGY ................................................................ H-4 2.2 COMMUNICATIONS WITH GOVERNMENT AGENCIES ........................................ H-5 2.3 COMMUNICATIONS WITH THE MEDIA ................................................................. H-5 2.4 COMMUNICATIONS WITH THE PUBLIC ................................................................ H-5 Revision 45 8

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Section Title Page 3.0 ASSESSMENT FACILITIES ..................................................................................... H-5 3.1 ONSITE SYSTEMS AND EQUIPMENT ................................................................... H-5 3.2 FACILITIES AND EQUIPMENT FOR OFFSITE MONITORING............................... H-6 4.0 PROTECTIVE FACILITIES AND EQUIPMENT ........................................................ H-7 5.0 FIRST AID AND MEDICAL FACILITIES ................................................................... H-7 6.0 DAMAGE CONTROL EQUIPMENT AND SUPPLIES .............................................. H-7 7.0 TRANSPORTATION ................................................................................................. H-7 7.1 GROUND .................................................................................................................. H-7 7.2 AIR ............................................................................................................................ H-7 I ACCIDENT ASSESSMENT ........................................................................................ I-1 1.0 ACCIDENT ASSESSMENT

SUMMARY

.................................................................... I-1 2.0 ASSESSMENT CAPABILITIES .................................................................................. I-2 2.1 RESOURCES FOR DETECTION/ASSESSMENT OF NON-RADIOLOGICAL EVENTS ..................................................................................................................... I-2 2.1.1 Fire Detection ............................................................................................................. I-2 2.1.2 Seismic Monitoring ..................................................................................................... I-2 2.1.3 River Level Detection .................................................................................................. I-2 2.2 RESOURCES FOR DETECTION/ASSESSMENT OF RADIOLOGICAL RELEASES ................................................................................................................. I-2 2.2.1 Plant Process Instrumentation .................................................................................... I-2 2.2.2 Radiation Monitor for Failed Fuel Detection ............................................................... I-3 2.2.3 Radiation Monitoring ................................................................................................... I-3 2.2.4 Meteorological Instrumentation ................................................................................... I-5 2.2.5 Water Analyses ........................................................................................................... I-6 Revision 45 9

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Section Title Page 2.2.6 Post Accident Sampling .............................................................................................. I-6 2.2.7 Radiological Dose Assessment Computer System (RDACS)..................................... I-6 2.2.8 Safety Parameter Display System (SPDS) ................................................................. I-6 2.2.9 Emergency Response Data System (ERDS) ............................................................. I-6 2.3 RADIATION TEAM MONITORING ............................................................................. I-7 2.3.1 Operation of Monitoring Teams .................................................................................. I-7 2.3.2 Personnel.................................................................................................................... I-7 2.3.3 Equipment ................................................................................................................... I-8 3.0 ASSESSMENT OF RADIOLOGICAL RELEASES ..................................................... I-8 3.1 METHOD OF ASSESSMENT ..................................................................................... I-8 J PROTECTIVE RESPONSE ....................................................................................... J-1 1.0 PROTECTIVE RESPONSE FOR ONSITE PERSONNEL ......................................... J-1 1.1 NOTIFICATION ......................................................................................................... J-1 1.2 LOCALIZED EVACUATION ...................................................................................... J-1 1.3 PLANT EVACUATION ............................................................................................... J-1 1.3.1 Visitors, Contractor and Construction Personnel, and Employees Not Assigned a Role in the Emergency Organization ......................................................................... J-2 1.3.2 Personnel Assigned a Role in the Emergency Organization ..................................... J-2 1.3.3 Shift Personnel .......................................................................................................... J-2 1.4 EXCLUSION AREA EVACUATION ........................................................................... J-2 1.5 EOF EVACUATION ................................................................................................... J-2 1.6 SECURITY AND ACCOUNTABILITY ........................................................................ J-3 1.6.1 Security ...................................................................................................................... J-3 1.6.2 Accountability............................................................................................................. J-3 Revision 45 10

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Section Title Page 1.7 PROTECTIVE MEASURES ....................................................................................... J-4 1.7.1 Whole Body Exposure ............................................................................................... J-4 1.7.2 Clothing...................................................................................................................... J-4 1.7.3 Respiratory Protection ............................................................................................... J-4 1.7.4 Radioprotective Drugs ............................................................................................... J-5 1.7.5 Contamination Controls ............................................................................................. J-5 2.0 PROTECTIVE RESPONSE FOR INDIVIDUALS WITHIN THE PLUME EXPOSURE PATHWAY ............................................................................................ J-5 2.1 PROTECTIVE ACTION RECOMMENDATIONS ....................................................... J-5 2.1.1 ANO Guidelines ......................................................................................................... J-5 2.1.2 Initiation of Recommendations .................................................................................. J-5 2.1.3 Population Distribution ............................................................................................... J-6 2.2 NOTIFICATION ......................................................................................................... J-6 2.3 EVACUATION ........................................................................................................... J-6 2.4 SHELTERING / STAY INDOORS .............................................................................. J-7 2.5 RADIOLOGICAL ENVIRONMENTAL MONITORING................................................ J-7 K RADIOLOGICAL DOSE CONTROL ......................................................................... K-1 1.0 DOSE GUIDELINES ................................................................................................. K-1 1.1 DOSE LIMITS ........................................................................................................... K-1 1.2 PERSONNEL DOSIMETRY ..................................................................................... K-1 2.0 CONTAMINATION CONTROL ................................................................................. K-2 2.1 AREA ACCESS ........................................................................................................ K-2 2.2 PERSONNEL ............................................................................................................ K-2 2.2.1 Under Normal Conditions ......................................................................................... K-2 Revision 45 11

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Section Title Page 2.2.2 Under Emergency Conditions ................................................................................... K-2 2.3 WATER AND FOOD SUPPLY .................................................................................. K-3 2.3.1 Onsite Supplies ......................................................................................................... K-3 2.3.2 Offsite Supplies ......................................................................................................... K-3 2.4 TOOLS AND EQUIPMENT ....................................................................................... K-4 2.4.1 Site Equipment Contamination Control ..................................................................... K-4 2.4.2 Plant Equipment Contamination Control ................................................................... K-4 3.0 DECONTAMINATION ............................................................................................... K-4 3.1 PERSONNEL DECONTAMINATION ....................................................................... K-4 3.1.1 Decontamination Facilities ........................................................................................ K-4 3.1.2 Decontamination Process ......................................................................................... K-5 3.2 AREA DECONTAMINATION .................................................................................... K-5 3.2.1 Clean Areas .............................................................................................................. K-5 3.2.2 Contamination Areas ................................................................................................ K-5 3.2.3 Priorities for Area Decontamination .......................................................................... K-5 4.0 WASTE DISPOSAL UNDER EMERGENCY CONDITIONS..................................... K-5 L MEDICAL AND PUBLIC HEALTH CONDITIONS...................................................... L-1 1.0 ONSITE FIRST AID ................................................................................................... L-1 2.0 MEDICAL TRANSPORTATION ................................................................................. L-1 3.0 OFFSITE MEDICAL FACILITIES .............................................................................. L-1 3.1 MEDICAL SERVICES PERSONNEL ........................................................................ L-1 3.2 SAINT MARYS REGIONAL MEDICAL CENTER ..................................................... L-1 3.3 UNIVERSITY OF ARKANSAS FOR MEDICAL SCIENCES HOSPITAL ................... L-2 Revision 45 12

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Section Title Page 3.4 OAK RIDGE ASSOCIATED UNIVERSITY MEDICAL DIVISION .............................. L-2 M RECOVERY AND REENTRY PLANNING AND POST ACCIDENT OPERATIONS M-1 1.0 ORGANIZATIONAL BACKGROUND ....................................................................... M-1 2.0 ORGANIZATIONAL ARRANGEMENT, ASSIGNMENT, AND RESPONSIBILITIES M-2 2.1 SITE VICE PRESIDENT ........................................................................................... M-2 2.2 GENERAL MANAGER, PLANT OPERATIONS ....................................................... M-2 2.3 DIRECTOR, ENGINEERING .................................................................................... M-2 2.4 MANAGER, OPERATIONS ...................................................................................... M-2 2.5 OTHER ENTERGY OPERATIONS RESOURCES................................................... M-3 2.6 POST ACCIDENT RECOVERY MEASURES ......................................................... M-3 2.7 POST ACCIDENT REPORTING ............................................................................. M-3 3.0 RE-ENTRY ............................................................................................................... M-3 3.1 PURPOSE ................................................................................................................ M-3 3.2 AUTHORITY ............................................................................................................. M-3 3.3 IMPLEMENTING ORGANIZATION .......................................................................... M-4 3.4 REENTRY - EMERGENCY RADIATION EXPOSURE DOSE JUSTIFICATION ...... M-4 3.5 REENTRY GUIDELINES .......................................................................................... M-4 N EXERCISES AND DRILLS ....................................................................................... N-1 1.0 EXERCISES ............................................................................................................. N-1 2.0 DRILLS ..................................................................................................................... N-1 2.1 COMMUNICATIONS DRILLS ................................................................................... N-1 2.2 FIRE EMERGENCY ................................................................................................. N-2 2.3 MEDICAL EMERGENCY .......................................................................................... N-2 Revision 45 13

ARKANSAS NUCLEAR ONE EMERGENCY PLAN TABLE OF CONTENTS (Continued)

Section Title Page 2.4 RADIOLOGICAL MONITORING .............................................................................. N-2 2.5 HEALTH PHYSICS DRILLS ..................................................................................... N-2 2.5.1 Radiological Dose Assessment ................................................................................ N-2 2.6 OFF-HOURS ERO UNANNOUNCED DRILLS ......................................................... N-2 3.0 SCENARIOS ............................................................................................................. N-3 4.0 CRITIQUES .............................................................................................................. N-3 O RADIOLOGICAL EMERGENCY RESPONSE TRAINING........................................ O-1 1.0 EMERGENCY RESPONSE ORGANIZATION TRAINING ....................................... O-1 2.0 TRAINING FOR OTHER ANO EMERGENCY RESPONSE GROUPS .................... O-2 2.1 FIRE BRIGADE ........................................................................................................ O-2 2.2 REPAIR AND DAMAGE CONTROL TEAM .............................................................. O-2 2.3 SECURITY PERSONNEL ........................................................................................ O-3 2.4 FIRST AID AND RESCUE PERSONNEL ................................................................. O-3 3.0 LOCAL SERVICES PERSONNEL TRAINING ......................................................... O-3 3.1 LOCAL EMERGENCY SERVICES PERSONNEL ................................................... O-3 3.1.1 Local Fire Department .............................................................................................. O-3 3.1.2 Pope County Emergency Medical Service ............................................................... O-3 3.1.3 Miscellaneous Personnel .......................................................................................... O-3 3.2 MEDICAL SUPPORT PERSONNEL ........................................................................ O-3 3.2.1 Saint Marys Regional Medical Center Personnel .................................................... O-3 3.2.2 Medical Services Personnel ..................................................................................... O-4 4.0 GENERAL EMPLOYEE TRAINING .......................................................................... O-4 5.0 TRAINING EVALUATION ......................................................................................... O-4 Revision 45 14

ARKANSAS NUCLEAR ONE EMERGENCY PLAN TABLE OF CONTENTS (Continued)

Section Title Page P RESPONSIBILITY FOR THE PLANNING EFFORT: DEVELOPMENT, PERIODIC REVIEW, AND DISTRIBUTION ............................................................. P-1 1.0 RESPONSIBILITY FOR RADIOLOGICAL EMERGENCY RESPONSE PLANNING ............................................................................................................... P-1 2.0 REVIEW AND UPDATE OF THE EMERGENCY PLAN AND IMPLEMENTING PROCEDURES ........................................................................................................ P-1 3.0 UPDATE OF EMERGENCY TELEPHONE NUMBERS ........................................... P-2 4.0 TRAINING OF PERSONNEL RESPONSIBLE FOR THE PLANNING EFFORT...... P-2 Revision 45 15

ARKANSAS NUCLEAR ONE EMERGENCY PLAN LIST OF APPENDICES Appendix No. Title 1 Letters of Agreement with Supporting Organizations 2 Deleted 3 Emergency Plan Implementing Procedures 4 Emergency Supplies and Equipment 5 Evacuation Time Estimate 6 Emergency Messages Revision 45 16

ARKANSAS NUCLEAR ONE EMERGENCY PLAN LIST OF TABLES Table No. Title Page B-1 Minimum Staffing Requirements ................................................................................... B-20 D-1 Summary of EAL Categories ........................................................................................... D-4 D-2 Deleted D-3 Correlation of Design Basis Accidents to Emergency Classes (Unit 1) ....................... D-11 D-4 Correlation of Design Basis Accidents to Emergency Classes (Unit 2) ....................... D-12 F-1 Communication Links Available For Onsite/Offsite Emergency Response Facilities .... F-3 I-1 Area Radiation Monitors (Unit 1) ....................................................................................... I-9 I-2 Process Radiation Monitoring System (Unit 1) ...............................................................I-10 I-3 Area Radiation Monitors (Unit 2) .....................................................................................I-12 I-4 Process Radiation Monitors (Unit 2) ................................................................................I-13 I-5 SPING Monitors ...............................................................................................................I-16 J-1 Estimated Evacuation Times - ANO Environs ................................................................. J-8 K-1 Dose Limits ....................................................................................................................... K-6 Revision 45 17

ARKANSAS NUCLEAR ONE EMERGENCY PLAN LIST OF FIGURES Figure No. Title Page B-1 Normal Plant Organization ............................................................................................. B-21 B-2 Initial Response Staff ..................................................................................................... B-22 B-3 Initial Response Staff Interfaces with Offsite Agencies................................................. B-23 B-4 ERO Key Facility Reporting Chain ................................................................................ B-23 B-5 EOF Emergency Director's Staff .................................................................................... B-24 B-6 TSC Emergency Plant Managers Staff......................................................................... B-25 B-7 OSC Managers Staff ..................................................................................................... B-26 B-8 Emergency Response Organization Offsite Interfaces ................................................. B-27 B-9 Management Interfaces between Response Centers and Support Resources .......... B-28 B-10 Working Level Interfaces With Federal, State, and Local Agencies ............................ B-29 B-11 Control Room Shift Managers Staff .............................................................................. B-30 B-12 Joint Information Center (JIC) Staff ............................................................................... B-30 E-1 Predicted Siren Coverage ................................................................................................ E-5 F-1 Schedule for Emergency Notification .............................................................................. F-4 F-2 Communications with Information and Support Services ............................................... F-5 H-1 Entergy Arkansas, Inc. Russellville Service Center (Alternate EOF) ............................. H-8 J-1 Exclusion Area................................................................................................................... J-9 J-2 10-Mile EPZ Radiological Field Monitoring Points ......................................................... J-10 J-3 50-Mile EPZ ..................................................................................................................... J-11 J-4 ANO Emergency Operations Facility Location and Site Evacuation Routes ................ J-12 J-5 Distribution of Thermoluminescent Dosimeters (TLDs) ................................................. J-13 J-6 Estimates of Population Relocating to Care Centers by Evacuation Area ................... J-14 J-7 One Mile EPZ Environmental Sampling Stations........................................................... J-15 M-1 Corporate Positions Assigned Recovery Responsibilities ..............................................M-5 P-1 Emergency Planning Organization .................................................................................. P-3 Revision 45 18

ARKANSAS NUCLEAR ONE EMERGENCY PLAN DEFINITIONS Listed below are terms used in this Emergency Plan and the definitions that should be applied to these terms when used in the context of this Emergency Plan.

Activation - Actions taken to staff and setup an emergency response facility to make it operational. Actions include but are not limited to notification of emergency personnel, equipment setup and equipment operability testing.

ALARA - (As Low As Reasonably Achievable) - The level at which Entergy Operations strives to maintain personnel radiation exposure.

Alternate Emergency Operations Facility - The Entergy Arkansas, Inc. Russellville Service Center located in Russellville, Arkansas.

Assessment Actions - Those actions taken during or after an accident to obtain and process information on which decisions to implement specific emergency measures will be based.

Collocation - The process by which counterparts from ANO, ADH, ADEM, NRC, FEMA, and other agencies work side by side (collocate) in order to more efficiently respond to an emergency.

Contamination - Any license or byproduct material that can be detected above background radiation levels for a particular counting system. Verified alarm on an automated personnel contamination monitor or have detectable activity from direct frisk.

Corrective Actions - Those emergency measures taken to mitigate or terminate an emergency situation in order to prevent an uncontrolled release of radioactive material or to reduce the magnitude of a release, e.g., shutting down equipment, fire-fighting, repair and damage control.

Design Basis Accident (DBA) - Malfunctions or failures of equipment postulated for purposes of analysis to select limiting conditions for operations, safety systems setting and design specifications for equipment, components and systems from the standpoint of protection of public health and safety.

Dose - A generic term which means absorbed dose (RAD) or dose equivalent (REM) and is the quantity of radiation absorbed, per unit of mass, by the body or by any portion of the body.

Dose Rate Projections - The calculated estimate of a radiation dose rate to individuals at a given location, determined from the rate of radioactive material release and the appropriate meteorological transport and dispersion parameters (units typically in millirem, i.e., mrem/hr).

Dose Projections - The calculated estimate of a radiation dose to individuals at a given location, determined from the Dose Rate Projection at that location and the Projected Exposure Time interval during which the dose rate is expected to exist (units typically in millirem, i.e., mrem).

Revision 45 19

ARKANSAS NUCLEAR ONE EMERGENCY PLAN DEFINITIONS (Continued)

Emergency Direction and Control - Overall direction of facility response which must include the non-delegable responsibilities for the decision to notify and to recommend protective actions to Arkansas Department of Health personnel and other authorities responsible for offsite emergency measures. The direction of facility operations to mitigate accident consequences remains with the Emergency Plant Manager in the Technical Support Center and/or the Shift Manager/ED in the Control Room.

A pre-determined, site-specific, observable threshold for an INITIATING CONDITION that, when met or exceeded, places the plant in a given emergency classification level.

Emergency Action Level (EAL) - A pre-determined, site-specific, observable threshold for an INITIATING CONDITION that, when met or exceeded, places the plant in a given emergency classification level.

Emergency Classification Level (ECL) - One of a set of names or titles established by the US Nuclear Regulatory Commission (NRC) for grouping off-normal events or conditions according to (1) potential or actual effects or consequences, and (2) resulting onsite and offsite response actions. The emergency classification levels, in ascending order of severity, are:

Unusual Event (UE)

Alert Site Area Emergency (SAE)

General Emergency (GE)

Emergency Notification System (ENS) - Dedicated emergency phones to the Nuclear Regulatory Commission Operations Center used as the primary means for the site to report emergencies and other significant events to the NRC.

Emergency Operations Center (EOC) - An offsite location used by State, local, and other governmental agencies to coordinate their activities during a response to an emergency situation.

Emergency Operations Facility (EOF) - A near-site emergency facility located approximately 0.65 miles northeast of the reactor buildings (Figure J-4 indicates the location of the Emergency Operations Facility).

Emergency Director (ED) - The designated senior management position who assumes Emergency Direction and Control from the Shift Manager/ED to direct the overall emergency response. Duties are discussed in Section B.

Revision 45 20

ARKANSAS NUCLEAR ONE EMERGENCY PLAN DEFINITIONS (Continued)

Emergency Planning Zones (EPZ) - Those areas around the nuclear facility which form the basis for emergency planning activities.

a. 10-mile EPZ (Plume Exposure Pathway) - The area within a 10-mile radius of ANO in which the principal sources of exposure are whole body external exposure to gamma radiation from the plume and from deposited materials and/or inhalation exposure from the passing radioactive plume. The duration of principal potential exposures could range in length from hours to days. This area is also referred to as the "inhalation exposure pathway."

b. 50-mile EPZ (Ingestion Exposure Pathway) - The area within a 50-mile radius of the ANO reactor buildings that may be affected by deposition from a radiological release.

The principle exposure would be from the ingestion of water or foods and the potential exposure time could range from hours to months.

Emergency Response Organization (ERO) - The emergency organization composed of the Initial Response Staff, the Emergency Operations Facility staff, the Technical Support Center Staff, the Operational Support Center Staff, and the Emergency Team members. It has the capability to provide manpower and other resources necessary for immediate and long-term response to an emergency situation.

Exclusion Area - That area surrounding Arkansas Nuclear One within a minimum radius of 0.65 miles of the reactor buildings and controlled to the extent necessary by Entergy Operations during an emergency. This area includes certain portions of the bed and banks of the Dardanelle Reservoir which are owned by the United States. An easement has been obtained from the U. S. Army Corps of Engineers which entitles Entergy Operations, as an agent of Entergy Arkansas, Inc., to exclude all persons from these areas during an emergency. A map of the Exclusion Area is provided in Figure J-1.

Health Physics Network (HPN) - The primary means of communicating radiological data (onsite and offsite measurements and dose assessment information) from the licensee to the Nuclear Regulatory Commission.

Hostile Action - An act toward ANO or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate 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 ANO. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the SECURITY OWNER CONTROLLED AREA).

Hostile Force - 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.

Revision 45 21

ARKANSAS NUCLEAR ONE EMERGENCY PLAN DEFINITIONS (Continued)

Initial Response Staff (IRS) - The emergency organization primarily composed of plant personnel which must be able to augment the onsite plant personnel in accordance with Table B-1 of the Emergency Plan.

Joint Information Center (JIC) - An offsite location used by Entergy Operations, the state, local, and other governmental agencies for the purpose of addressing the news media of conditions at ANO.

Nuclear Planning and Response Program (NP&RP) - Office of the Arkansas Department of Health located at the Entergy Arkansas, Inc. Russellville Service Center for the purposes of assistance to local government.

Operational - Status of an emergency facility declared by the appropriate facility manager upon determining that the facility is adequately staffed and equipment is setup and available to assume/perform the emergency functions assigned to that facility.

Operational Support Center (OSC) - Emergency response center within the ANO Maintenance Facility where support is coordinated for the following functions: Onsite radiological monitoring, maintenance, chemistry, emergency medical support, fire-fighting support. The OSC, located in the Maintenance Facility, serves as the briefing area for repair and damage control teams. The "OSC Assembly Area", located in the Maintenance Facility serves as the designated assembly area for the repair and damage control teams.

Owner Controlled Area (OCA) - The external area contiguous to the designated reactor site Protected Area over which site Security exercises control. The OCA extends outward to the Entergy site property lines.

Plant Evacuation - The orderly withdrawal of all personnel from the protected area except for those personnel required to respond to the situation.

Primary Access Point - The primary location at the plant protected area boundary for entry/exit of personnel at ANO.

Projected Exposure Time - The estimated period of time that the population in the area surrounding Arkansas Nuclear One may be exposed to radiation, as a result of an accidental radioactive release.

Protected Area - An area clearly demarcated by a fence or building wall with an entrance portal that is regulated by Security Personnel to control access.

Protective Actions - Those measures taken during and after an emergency situation to minimize or eliminate the hazard to the health and safety of the general public and plant personnel.

Protective Action Advisory (PAA) - Recommendations by the State TOCD (or authorized representative) to local government for actions to protect the health and safety of the general public.

Revision 45 22

ARKANSAS NUCLEAR ONE EMERGENCY PLAN DEFINITIONS (Continued)

Protective Action Guide (PAG) - Projected absorbed dose to individuals in the general population which warrants protective action.

Protective Action Recommendation (PAR) - Recommendations of actions to be taken by offsite authorities that are based on plant conditions/radiological releases and resulting Emergency Classes. PAR's are discussed in Section J.2.1.

Protective Action Zone (PAZ) - An area of the 10-mile EPZ with readily identifiable geographical or political boundaries used for control of protective actions for the general public.

Rad - A measure of the dose of any ionizing radiation to body tissues in terms of the energy absorbed per unit mass of the tissue. One rad is the dose corresponding to the absorption of 100 ergs per gram of tissue (one millirad (mrad) - 0.001 rad).

Radiological Response Team Leader - The emergency position in the Arkansas Department of Health emergency response organization that is responsible for dose assessment, notification of local governments, and offsite Protective Action Advisories.

Recovery Actions - Those actions taken after the emergency to restore the plant as nearly as possible to its pre-emergency condition, or to a safe shutdown condition.

Rem - A measure of the dose of any ionizing radiation to body tissues in terms of its estimated biological effect relative to a dose of one roentgen (r) of X-rays (one millirem (mrem) - 0.001 rem).

Route Alerting - The process used to notify persons in the 10-mile EPZ of the need to listen to local broadcast stations if those persons are in an area with a known siren failure or NOAA radio system failure.

Secondary Operational Support Center - Locations within the Emergency Operations Facility which serve as alternate locations for the OSC Staff in the event of an evacuation of the OSC.

Secondary Technical Support Center - A location within the Emergency Operations Facility equipped with instrumentation and communications systems which serves as an alternate location for the TSC staff in the event of an evacuation of the TSC.

Security Owner Controlled Area (SOCA) - The SOCA is the area demarcated as a Vehicle Barrier System (VBS) consisting of passive elements including a series of large concrete blocks on the inside of a delay fence with early warning capabilities. The SOCA is the area between the SOCA Fence and the PROTECTED AREA Boundary.

State Emergency Operations Facility (SEOF) - The designated location from which State offsite incident management is coordinated. The SEOF will house the TOCD and designated staff as well as representatives for the Arkansas Department of Emergency Management designated by the ADEM Director.

Supplemental Notification - The process used to notify persons in the 10-mile EPZ who may not have received an initial notification to listen to local broadcast stations.

Revision 45 23

ARKANSAS NUCLEAR ONE EMERGENCY PLAN DEFINITIONS (Continued)

Technical Operations Control Director (TOCD) - The Arkansas Department of Health official, or a designated alternate, who is authorized to exercise technical operational control of offsite emergency response to radiological incidents.

Technical Support Center (TSC) - A location within the Arkansas Nuclear One Plant Administration Building equipped with instrumentation and communication systems and facilities useful in monitoring the course of an accident.

Vital Area - Any area within a protected area containing any equipment, system or device which, by result of failure, destruction or associated release, could directly or indirectly endanger the health and safety of the public.

Warning Points - Communications contact points, usually at the County Sheriff Department, established by the State of Arkansas to relay initial notification information from ANO to local, State and Federal agencies, and to the general public.

Revision 45 24

ARKANSAS NUCLEAR ONE EMERGENCY PLAN ABBREVIATIONS Listed below are abbreviations used in this Emergency Plan and the terms that should be applied to these abbreviations when used in the context of this Emergency Plan.

ADEM Arkansas Department of Emergency Management ADH Arkansas Department of Health AEOF Alternate Emergency Operations Facility ALARA As Low As Is Reasonably Achievable ANO Arkansas Nuclear One ANS American Nuclear Society AWIN Arkansas Wireless Information Network CFR Code of Federal Regulations DLR Dosimeter of Legal Record DOE Department of Energy EAL Emergency Action Level ED Emergency Director ENS Emergency Notification System EOC Emergency Operations Center EOF Emergency Operations Facility EP Emergency Planner EPIP Emergency Plan Implementing Procedure EPM Emergency Plant Manager EPRI Electric Power Research Institute EPZ Emergency Planning Zone ERO Emergency Response Organization ERON Emergency Response Organization Notification FEMA Federal Emergency Management Agency FSAR Final Safety Analysis Report HPN Health Physics Network I&C Instrument & Control I&E Inspection and Enforcement Office of the NRC Revision 45 25

ARKANSAS NUCLEAR ONE EMERGENCY PLAN ABBREVIATIONS (Continued)

INPO Institute of Nuclear Power Operations IRS Initial Response Staff JIC Joint Information Center NP&RP Nuclear Planning and Response Program NRC Nuclear Regulatory Commission NUMARC Nuclear Management and Resources Council NUREG-0654 Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants NUREG-0728 NRC Incident Response Plan (IRP)

OSC Operational Support Center PAA Protective Action Advisory PAG Protective Action Guide PAP Primary Access Point PAR Protective Action Recommendation PAZ Protective Action Zone PSC Public Service Commission of the State of Arkansas RAC Radiological Assessment Coordinator RDACS Radiological Dose Assessment Computer System SAG Staff Augmentation Group SE/STA Shift Engineer / Shift Technical Advisor SEOF State Emergency Operations Facility SOCA Security Owner Controlled Area STSC Secondary Technical Support Center TLD Thermoluminescent Dosimeter TOCD Technical Operations Control Director TSC Technical Support Center UAMS University of Arkansas for Medical Sciences Hospital 10 CFR 20 Title 10 of the Code of Federal Regulations, Part 20 10 CFR 50 Title 10 of the Code of Federal Regulations, Part 50 Revision 45 26

ARKANSAS NUCLEAR ONE EMERGENCY PLAN CROSS REFERENCE INDEX NUREG-0654 / EMERGENCY PLAN NUREG-0654 PLANNING STANDARD EMERGENCY PLAN REFERENCE A.1.a A.2.0; C A.1.b A.1.0; C A.1.c Figure B-5, B-6, B-8, B-9, B-10 A.1.d B; Table B-1; Figures B-4, B-6, B-11 A.1.e B.4.0; F.1.0, F.2.0 A.2.a N/A A.2.b N/A A.3 A; C; Appendix 1 A.4 B.2.0, B.3.0, B.4.0; Figures B-2, B-4, B-5, B-6 B.1 B.1.0, B.2.0, B.3.0; Table B-1; Figures B-2, B-3, B-11 B.2 B.2.0, B.2.1; Figures B-2, B-11 B.3 B B.4 B.2.1, B.3.1 B.5 B.2.0, B.3.0, B.4.0; Table B-1 Figures B-5, B-6, B-11, B-12; M.2.0 B.6 A; B.4.0; Figures B-5, B-7, B-8; C B.7 B.2.0, B.3.0, B.4.0; Table B-1; Figures B-2, B-4, B-8, B-9, B-10; M.2.0 B.7.a B.3.1.11; M.2.4; Figure B-5 B.7.b B.3.2, B.3.3; M.2.1, M.2.2, M.2.5, M.2.6, M.2.7 B.7.c B.3.0, B.4.0; Figures B-3, B-8, B-10 B.7.d B.3.4; G.2.0, G.3.0; Figure B-12 B.8 A.2.7, C.6.0; Figure B-9 B.9 A.2.3, A.2.4, A.2.5; C.3.0; Figure B-8; Appendix 1 Revision 45 27

ARKANSAS NUCLEAR ONE EMERGENCY PLAN CROSS REFERENCE INDEX NUREG-0654 / EMERGENCY PLAN (Continued)

NUREG-0654 PLANNING STANDARD EMERGENCY PLAN REFERENCE C.1.a C.1.0 C.1.b C.2.0 C.1.c C.5.0 C.2.a N/A C.2.b A.2.1.1; C.3.0 C.3 C.4.0 C.4 A.2.6, A.2.7; C.2.0, C.6.0; Appendix 1 D.1 D.1.0, D.2.0, D.3.0, D.4.0, D.5.0, D.6.0; Table D-1 D.2 D.6.0; Table D-1 D.3 N/A D.4 N/A E.1 E.1.0 E.2 E.1.0; F.3.0 E.3 E.2.0 E.4 E.2.0 E.5 N/A E.6 E.3.0, E.4.0; H.2.4 E.7 E.4.0; G.1.0, G.2.0, G.3.0; J.2.0; Appendix 6 F.1.a E.1.0; F.1.0; Figure F-1 F.1.b F.2.1; Figure F-1; Table F-1 F.1.c F.2.1; Figure F-1; Table F-1 F.1.d F.2.1, F.2.2, F.2.4; Table F-1; H.2 F.1.e E.1.0; F.1.0; Figure F-1 Revision 45 28

ARKANSAS NUCLEAR ONE EMERGENCY PLAN CROSS REFERENCE INDEX NUREG-0654 / EMERGENCY PLAN (Continued)

NUREG-0654 PLANNING STANDARD EMERGENCY PLAN REFERENCE F.1.f F.2.0; Table F-1; H.2.0 F.2 F.2.3, Table F-1; Figure F-1 F.3 E.3.0; F.2.1; H.2.0 G.1 INTRO; G.1.1, G.1.2 G.2 G.1.2 G.3.a G.2.0 G.3.b G.2.0 G.4.a G.3.0 G.4.b G.3.0 G.4.c G.3.0 G.5 G.4.0 H.1 H.1.2, H.1.3 H.2 H.1.4 H.3 N/A H.4 B; E; F; H.1.0 H.5 H.3.1, H.6.0; I.2.0 H.5.a H.3.1; I.2.1.2 H.5.b H.3.1; I.2.2 H.5.c H.3.1; I.2.2 H.5.d H.6.0; I.2.1.1 H.6.a I.2.1.2 H.6.b I.2.2.3.c, I.2.3.3; K.1.2 H.6.c H.3.2 Revision 45 29

ARKANSAS NUCLEAR ONE EMERGENCY PLAN CROSS REFERENCE INDEX NUREG-0654 / EMERGENCY PLAN (Continued)

NUREG-0654 PLANNING STANDARD EMERGENCY PLAN REFERENCE H.7 H.3.2; J.2.5 H.8 H.3.1; I.2.2.4 H.9 H.1.3, H.1.4; Appendix 4 H.10 H.3.2 H.11 Appendix 4 H.12 H.1.4, H.3.2; I.2.3.2 I.1 D.6.0, D.7.0 I.2 I.2.2.2, I.2.2.3, I.2.2.6 I.3.a I.2.2.7 I.3.b I.2.2.7 I.4 I.3.0 I.5 I.2.2.4 I.6 I.2.2.3, I.2.2.6, I.2.2.7 I.7 I.2.3 I.8 E; F; H.2.1, H.3.2, H.7.0; I.2.3 I.9 I.2.3.3 I.10 I.3.1 I.11 N/A J.1 J.1.1, J.1.2, J.1.3, J.1.4, J.2.2, J.2.3 J.2 J.1.2, J.1.3, J.1.7 J.3 J.1.3.1, J.1.7.1 J.4 J.1.1, J.1.3.1; K.3.1.1 J.5 J.1.6.2 Revision 45 30

ARKANSAS NUCLEAR ONE EMERGENCY PLAN CROSS REFERENCE INDEX NUREG-0654 / EMERGENCY PLAN (Continued)

NUREG-0654 PLANNING STANDARD EMERGENCY PLAN REFERENCE J.6 J.1.7 J.7 J.2.1, J.2.2 J.8 J.2.3 J.9 N/A J.10.a J.2.1.3 J.10.b J.2.1.3 J.10.c J.2.2, J.2.3 J.10.d through J.10.e NA J.11 N/A J.12 N/A K.1 K.1.1; M.3.5 K.2 K.1.1; M.3.5 K.3.a K.1.2 K.3.b K.1.2 K.4 N/A K.5.a K.3.0 K.5.b K.3.0, K.4.0 K.6.a K.2.1 K.6.b K.2.3 K.6.c K.3.0 K.7 K.3.1 L.1 L.3.0 L.2 L.1.0; O.2.4 Revision 45 31

ARKANSAS NUCLEAR ONE EMERGENCY PLAN CROSS REFERENCE INDEX NUREG-0654 / EMERGENCY PLAN (Continued)

NUREG-0654 PLANNING STANDARD EMERGENCY PLAN REFERENCE L.3 N/A L.4 L.2.0 M.1 M.1.0, M.3.0 M.2 M.2.0 M.3 M.1.0 M.4 I.3.1 N.1.a N.1.0 N.1.b N.1.0 N.2.a N.2.1 N.2.b N.2.2 N.2.c N.2.3 N.2.d N.2.4 N.2.e N.2.5 N.3 N.3.0 N.4 N.3.0, N.4.0 N.5 N.4.0 O.1.a O.3.0 O.1.b N/A O.2 N; O.1.0, O.2.0, O.3 O.2.4 O.4 O.1.0, O.2.0, O.3.0 O.5 O.1.0, O.2.0, O.3.0 P.1 P.4.0 Revision 45 32

ARKANSAS NUCLEAR ONE EMERGENCY PLAN CROSS REFERENCE INDEX NUREG-0654 / EMERGENCY PLAN (Continued)

NUREG-0654 PLANNING STANDARD EMERGENCY PLAN REFERENCE P.2 P.1.0 P.3 P.1.0 P.4 P.2.0 P.5 P.2.0 P.6 INTRO - 2.2 P.7 Appendix 3 P.8 Table of Contents Cross Reference Index P.9 P.2.0 P.10 P.3.0 Revision 45 33

ARKANSAS NUCLEAR ONE EMERGENCY PLAN INTRODUCTION 1.0 STATEMENT OF EMERGENCY PLANNING POLICY It is the policy of Entergy Operations, Incorporated that unusual events or accidents which may occur at its nuclear facilities are responded to in an organized and planned manner in order that potential hazards and concerns of the public as a result of the event or incident may be minimized.

This response is based on the best understanding of the actual situation, with prudent actions and defined plans for possible complications. It is an essential part of this policy to provide prompt and publicly understandable information about these events to the nearby community and the public at large so that theirs may be an informed response.

The Arkansas Nuclear One Emergency Plan implements this Entergy Operations policy by establishing a company-wide organization for emergency response and planned response program to be activated should incidents at the Company's nuclear facilities have the potential for an external impact. Because these incidents may range from minor events requiring only a public information release to major events involving serious offsite consequences, the Emergency Plan was prepared with consideration to this variance. The Emergency Plan incorporates an orderly and timely decision-making process which ensures that the response is appropriate to the situation. The Emergency Plan creates a foundation of required information and guidelines for responsive decision-making, and, in addition, ensures the availability of the necessary facilities, equipment, supplies, services and personnel to handle emergency situations.

The Emergency Plan provides assurance that an effective interface between Entergy Operations and the Federal, State and local government agencies responsible for radiological response planning has been established. The Plan assures that appropriate measures are taken promptly to protect the health, safety, and property of the public for situations involving potential radiological hazards.

The Emergency Plan includes by reference the Arkansas Nuclear One Emergency Plan Implementing Procedures; defines the division of responsibilities and the support of site and corporate groups; and serves as a preparedness document for site and corporate response guidance. Details of implementation of the Emergency Plan such as step-by-step instructions, checklists, and telephone numbers are contained in the Emergency Plan Implementing Procedures and the Emergency Telephone Directory.

2.0 SCOPE AND APPLICABILITY This section of the Emergency Plan defines the unit, station, and area to which the Plan applies and presents a summary of the Plan's interrelationships with (1) its implementing procedures; (2) plant operating, radiological control, and industrial security procedures; and (3) emergency plans of participating agencies, particularly the Arkansas Comprehensive Emergency Management Plan (ARCEMP), Annex V - Arkansas Nuclear One Radiological Incident Response Plan and the individual County Plans for Pope, Johnson, Yell, Conway, and Logan Counties which are discussed in Section A.

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ARKANSAS NUCLEAR ONE EMERGENCY PLAN 2.1 PHYSICAL AREA INVOLVED This Emergency Plan is for incidents which may occur at either Unit 1 or Unit 2 of Arkansas Nuclear One located in Pope County, Arkansas, approximately five miles west-northwest of the town of Russellville. This Emergency Plan is primarily applicable to the Arkansas Nuclear One Exclusion Area and the Emergency Planning Zones within a ten mile and fifty mile radius of Arkansas Nuclear One as shown on Figures J-1, J-2, and J-3, respectively, although provisions exist for extending these areas in the unlikely event this coverage is necessary. Figure J-2 is divided into sixteen 221/2-degree sectors (designated as sectors 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16) and ten lettered radial zones at one mile radii from the center of the plant in order to identify the area surrounding the plant by sector and zone nomenclature. Figure J-4 depicts the location of the Arkansas Nuclear One Emergency Operations Facility and the site evacuation routes. The location of thermoluminescent dosimeters (TLDs) in the area surrounding the plant is provided in Figure J-5.

2.2 PLANS AND IMPLEMENTING PROCEDURES

SUMMARY

Entergy Operations, Incorporated is responsible for overall emergency response planning and implementation. The Emergency Plan describes the provisions made by Entergy Operations to respond to emergency situations within the Exclusion Area, and establishes the interfaces between Entergy Operations and local, State and Federal organizations capable of responding to plant-related emergencies which may extend outside the Exclusion Area. Details concerning implementation of the Emergency Plan which are reasonably expected to change from time-to-time (e.g., names and telephone numbers, specific items of equipment and supplies, inventory lists, and step-by-step procedures or checklists that may be altered as a result of experience or exercises) are contained in the Emergency Plan Implementing Procedures maintained at Arkansas Nuclear One and other designated emergency response facilities.

The titles of these Emergency Plan Implementing Procedures are provided in Appendix 3. In the event of an emergency, the normal plant operating and radiological procedures are followed unless superseded by one of the Emergency Plan Implementing Procedures.

The local and state governmental agency response to plant-related emergencies which may extend outside the Exclusion Area is coordinated by the Arkansas Department of Health/Arkansas Department of Emergency Management and is described in the State of Arkansas Emergency Operations Plan, Annex V, a summary of which is included in Section A. Like the Arkansas Nuclear One Emergency Plan, details concerning implementation of the State Emergency Operations Plan are contained in implementing procedures which are maintained in the appropriate government offices. A summary of the individual plans for Pope, Johnson, Yell, Conway, and Logan counties are included in Section A.

Arkansas Nuclear One Emergency Instructions are made available to Pope, Yell, Logan and Johnson Counties. The Emergency Instructions are prepared and distributed by the state and local governments and Entergy Operations. Distribution of these instructions within the 10-Mile Emergency Planning Zone is made by one of three means. First, communication media are mailed annually to each rural and urban postal patron for use by the permanent population.

Second, communication media are posted in public use areas such as State and Federal parks for use by the transient population. Third, communication media is distributed to public facilities and businesses. Dissemination of Public Information and its content is further explained in Section G.

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ARKANSAS NUCLEAR ONE EMERGENCY PLAN The Emergency Plan includes security threats to the plant as emergency situations. The responses to these situations are described in the Arkansas Nuclear One Security Plan. Security during emergency situations is maintained in accordance with the Security Plan which is implemented by separate Security Plan Implementing Procedures.

Fire-fighting equipment installed at Arkansas Nuclear One is described in the Fire Hazards Analysis. Fire-fighting activities during emergency situations are conducted in accordance with the Pre-Fire Plans and the Plant Procedures. Additional fire-fighting support may be provided by the Local Fire Department.

Arrangements have been made for local assistance from medical, law enforcement, fire-fighting and other support organizations in the event such assistance should be required to supplement the plant organization. These arrangements include letters of agreement/contracts between Entergy Operations and the individual support organizations and the development of Emergency Plan Implementing Procedures for the coordination of any assistance which may be requested.

These letters of agreement/contracts are summarized in Appendix 1.

3.0

SUMMARY

OF EMERGENCY PLAN This section summarizes the objectives of the Emergency Plan and describes the principal elements of the overall emergency planning logic.

3.1 EMERGENCY PLAN OBJECTIVES The objectives of the Emergency Plan are to:

a. establish an emergency organization to cope with emergency situations,

b. identify personnel and delineate their duties and responsibilities in the emergency organization,

c. identify emergency conditions, establish criteria for classifying emergency situations, implement prompt corrective and mitigating actions, perform dose assessment and issue appropriate Protective Action Recommendations,

d. establish a system for reporting emergency situations to local, State, and Federal governmental agencies in compliance with the criteria for notification,

e. establish a system for requesting emergency assistance,

f. establish procedures which coordinate the response of local, State, and Federal governmental agencies for emergency situations,

g. establish a system of communications for use during emergencies, and

h. identify the equipment and facilities available to respond to emergency conditions.

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ARKANSAS NUCLEAR ONE EMERGENCY PLAN 3.2

SUMMARY

OF THE EMERGENCY PLANNING LOGIC 3.2.1 Graded Classification System This Emergency Plan is based on a system of classification of unusual or emergency situations that present, or have the potential for creating, a hazardous condition. The classification system divides these situations into four subgroups, each of an increasingly hazardous nature, and provides specific criteria, responsibilities, and actions for each of these subgroups. The subgroups are referred to as Emergency Classes. As emergency situations develop or continue, they might be upgraded or downgraded from one Emergency Class to another. This graded classification system is described in Section D.

3.2.2 Emergency Organizations This Emergency Plan describes emergency organizations which are capable of assembling and effectively utilizing sufficient resources in response to each of the four Emergency Classes.

These organizations consist of the Initial Response Staff, which can quickly respond to the immediate needs of the situation, and the Emergency Response Organization, which can provide sufficient resources to respond to the more long-term needs of the situation. These emergency organizations are described in Section B.

3.2.3 Emergency Measures This Emergency Plan describes the measures that are taken in response to each Emergency Class, and assigns specific duties to members of the emergency organization. These measures are categorized as assessment actions, protective actions, corrective actions and recovery actions. These actions are directed toward the following:

a. termination of the incident;

b. establishment of channels of information;

c. limitation of the area of effect;

d. protection of equipment and facilities;

e. care of directly involved personnel;

f. definition of the boundaries of the emergency area; and

g. establishment of access control.

When control of the incident has been attained and there is no further danger to personnel and the emergency phase is at an end, recovery and restoration operations are then carried out. The emergency measures for each Emergency Class and for recovery measures are described in Section D and Section M, respectively.

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ARKANSAS NUCLEAR ONE EMERGENCY PLAN 3.2.4 Equipment and Facilities This Emergency Plan describes the equipment and facilities which have been provided for the protection of plant personnel and the public, and the responsibilities for using the equipment and facilities for each Emergency Class. Additional equipment is assembled at the time of an emergency as is appropriate to the situation. Equipment and facilities available are described in Section H.

3.2.5 Training In order for this Emergency Plan to be effective and to maintain a high level of effectiveness, training of plant personnel, support groups and the public must be performed periodically.

Section O describes the training provided for plant personnel and support groups to maintain their emergency preparedness. Public education is discussed in Section G.

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ARKANSAS NUCLEAR ONE EMERGENCY PLAN A ASSIGNMENT OF RESPONSIBILITY This section describes the agreements between Entergy Operations and other organizations on assignments of responsibilities for the overall response to emergency situations at Arkansas Nuclear One (ANO). The functions and responsibilities of the Company, offsite support organizations, and State, Federal, and local governments are specifically discussed.

1.0 ENTERGY OPERATIONS, INCORPORATED Entergy Operations, Incorporated has overall responsibility for all emergency planning associated with Arkansas Nuclear One. Therefore, Entergy Operations has entered into agreements with the State of Arkansas, local organizations, and Federal organizations to establish an emergency plan which delineates the roles of Entergy Operations and other response organizations. The response role of the State of Arkansas is described in detail in the Arkansas Emergency Operations Plan, Annex V.

The Emergency Plan describes the provisions to activate an emergency response organization to manage the emergency response within the Exclusion Area; coordinate mutual support activities between ANO and offsite response organizations; provide recommendations to the State on emergency actions; and assure communications between response organizations.

Once the Emergency Response Organization (ERO) is activated, Entergy Operations contacts with senior management of State agencies responding to the incident are coordinated by the EOF Emergency Director (ED) or his designee. Initial notification of and continued coordination with the Governor of the State of Arkansas is the responsibility of the Chief Executive Officer of Entergy Operations, Incorporated and the ED. In general, Entergy Operations coordinates its response with the Arkansas Department of Health (ADH), and this agency, in conjunction with the Arkansas Department of Emergency Management (ADEM), coordinates the support of other State agencies which may be required to respond.

During the initial response, notification of, and coordination with local support services (fire, medical, police), when their support is required at ANO, is the responsibility of ANO personnel.

1.1 RESPONSIBILITIES The responsibilities of Entergy Operations are described within the Emergency Plan as follows:

Section(s)

a. establish an emergency organization; B

b. identify personnel and delineate their duties and responsibilities A, B in the emergency organization;

c. establish criteria for classifying emergency situations; D

d. establish a system for reporting emergency situations to local, State, E, F and Federal governmental agencies in compliance with the criteria for notification;

e. establish a system for requesting emergency assistance; C, F

f. establish procedures which coordinate the response of Entergy B, C, F, Operations and local, State, and Federal governmental G, H, J, agencies for emergency situations; K, L, M

g. establish a system of communications for use during emergencies; and F

h. identify possible emergency conditions and the equipment and H, I facilities available to respond to such conditions.

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ARKANSAS NUCLEAR ONE EMERGENCY PLAN 1.2 ENTERGY OPERATIONS/ENTERGY OFFSITE DEPARTMENT/SECTION CAPABILITIES This section of the Emergency Plan summarizes the capabilities of major offsite departments within the Company. Generally these services are not required except for events which require extended ERO activation (greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />). Interface between the ERO and offsite organizations are discussed in the appropriate subsection and/or implementing procedure.

Details for implementing responsibilities and actions which are interdepartmental in nature are contained in implementing procedures for this Plan.

The effectiveness of Entergy Operations in rapidly and effectively responding to an emergency condition at ANO is predicated upon having defined methods to obtain the service capabilities within the organization and being able to appropriately utilize these capabilities in a coordinated effort with other emergency response agencies in specific emergency situations. Certain capabilities already designated as sectional or departmental responsibilities under normal company-wide activities are available, including:

Engineering Services Government Liaison Public Relations Financial, Regulatory and Legal Services Administering Nuclear Property Insurance Safety, Health, and Claims Transportation Communications Offsite Security Computer Technical, Analytical, and Programming Assistance Quality Assurance Other specialized capabilities which exist in the corporate organization are available to the plant operating staff and emergency response agencies to assist their efforts in coping with the emergency situation, including:

Coordination of Emergency Response Efforts Transient and Accident Analyses Radiological Monitoring and Analyses Area Logistical Support Materials Procurement Construction Services Meteorology The release of information within Entergy Operations and Entergy regarding an incident is approved by the ED and coordinated by the JIC Manager. The JIC Information Coordinator provides approved updates to Entergy Operations and Entergy employees through Entergy Information Center and the Customer Services Department.

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ARKANSAS NUCLEAR ONE EMERGENCY PLAN 2.0 OFFSITE SUPPORT ORGANIZATIONS Entergy Operations has overall responsibility for establishing and implementing emergency planning. Entergy Operations has agreements with other organizations to provide offsite support to implement emergency actions. This section discusses the State, local, federal, and private sector organizations that are a part of the overall response organization. The following areas are discussed: 1) primary responsibilities of the various supporting organizations for emergency response; 2) the operational role of the various organizations; and 3) the interface of these organizations with the ANO emergency response staff and other organizations, as applicable.

2.1 ARKANSAS PRIMARY GOVERNMENTAL SUPPORT ORGANIZATIONS Local and State government have the responsibility for implementation of the State and local emergency plans for the ten and fifty mile emergency planning zones. The general concept of operations used to insure the health and safety of the public is to carry out emergency actions at the lowest level of government having adequate resources to do so.

Under this concept it has been recognized that the local jurisdictions ordinarily will not have the capability for assessing the radiological impacts of an incident. This function is therefore performed by the State and ANO. ANO provides offsite Protective Action Recommendations (PAR). The State has the capability to assess ANO's recommendations and issue protective action advisories to the public.

Local authorities implement initial logistical support activities in coping with emergencies and request relief from the next higher level of government or ANO if resources at that level prove inadequate.

The total offsite State of Arkansas radiological emergency response plan is composed of five county plans for Johnson, Logan, Yell, Conway, and Pope Counties, and the State Emergency Operations Plan. The interfaces between the state and county response plans are defined in Annex V of the State Emergency Operations Plan. Within this plan are provisions for warning and notification of local government and the public, radiological accident assessment, offsite Protective Action Advisories, and State resource assistance for local government. Annex V, being part of the State Emergency Operations Plan, interfaces with all emergency plans for State agencies with response roles in all types of emergencies. This allows considerable resources to become available to protect the public health and safety.

The Arkansas Department of Emergency Management coordinates requests for additional assistance to support the offsite emergency response and recovery efforts of State, county, and municipal agencies and departments as provided in the Arkansas Emergency Operations Plan.

The Arkansas Department of Health (ADH) coordinates with ANO on assessment and provides advisories for the emergency precautions and recovery precautions needed to protect the general public. The five county response plans contain the mechanism for local government to implement the protective actions recommended. The plans for local governments follow the same format, modified to conform to the resource limitations of a given jurisdiction.

The responsibilities of the various participating agencies are described in this section. Interfaces between the Initial Response Staff, the Emergency Response Organization, and participating government agencies are shown in Figures B-3, B-8, and B-10.

Revision 45 A-3

ARKANSAS NUCLEAR ONE EMERGENCY PLAN 2.1.1 Local Government The Arkansas Emergency Services Act 511 of 1973, as amended, requires the highest elected official of political subdivisions to be responsible for pre-emergency logistical planning and response actions to a radiological incident affecting the lives and property within their political jurisdictions. County Radiological Emergency Response Plans have been established for those counties within the 10-mile Emergency Planning Zone. Each county judge has appointed a local Emergency Management Coordinator to administer the emergency preparedness program.

Responsibilities of local governments include providing citizens of the affected area with protection to minimize adverse health effects and a plan of action for orderly response to an incident; specifying the means for immediate notification of the population at risk within the 10-mile Emergency Planning Zone; and upon receipt of notification that a radiological incident has occurred or is imminent, implementing the County Radiological Response Plan to a degree consistent with the magnitude of the incident.

The Technical Operations Control Director (TOCD) of the ADH acts as liaison between ANO and local officials. Upon notification of an emergency, the county officials activate the County Emergency Operations Center and implement the Radiological Emergency Response Plan as necessary. Local requests for additional assistance or equipment are coordinated through the TOCD with the Director of the Arkansas Department of Emergency Management. Examples of actions which can be taken by local officials upon the recommendation of the TOCD include:

a. Evacuation or sheltering of the public;

b. restriction of unnecessary movement of personnel into areas; and

c. discontinuance of use of contaminated food and water supplies.

ANO provides, upon request by the county, liaison personnel at each local Emergency Operations Center in Pope, Logan, Yell, Conway, and Johnson Counties.

2.1.2 State Government Ultimate responsibility for the welfare of citizens and continuity of government of the State of Arkansas rests with the Governor. Under the emergency management system of the State of Arkansas, authorized by the Arkansas Emergency Services Act and the ARKANSAS EMERGENCY OPERATIONS PLAN which is published by directive of the Governor, each emergency function assigned to State and volunteer agencies requires that some agency assume primary responsibility for accomplishment of the task. In each instance, one or more other State agencies are assigned supporting roles to provide specialized assistance to the primary agency.

In keeping with the federal regulations and guidelines on which it is based, the responsibilities of "principal organization" for off-site radiological emergency response planning and preparedness in support of Arkansas Nuclear One are shared between two agencies:

Revision 45 A-4

ARKANSAS NUCLEAR ONE EMERGENCY PLAN

a. The Arkansas Department of Health (ADH)

The ADH under State law has the primary responsibility for protecting the health and safety of the general public from radiological incidents. Therefore, it has the authority to recommend any precautions (such as evacuation or sheltering) which are required to protect the general public. Additionally, the ADH is responsible for the control of all agricultural products and agricultural production for the purpose of reducing the possible radiation health hazards. Responsibilities of the ADH include providing personnel and equipment to the Radiological Response Team, as outlined in Chapter 4 of Annex V of the Arkansas Emergency Operations Plan; and, coordinating with the Offsite Monitoring Section of the ANO Emergency Radiation Team through the Radiological Assessment Coordinator, or designee, for sharing information regarding:

1. monitoring

2. decontamination

3. determination of magnitude of release and radiation levels

4. dose assessment The ADH coordinates the warning of, and communications with, the general public in affected areas.

Recommendation of precautionary actions to the public during and after an incident at Arkansas Nuclear One are made by the ADH. The ADH coordinates, to the extent possible, all information disseminated to the public regarding the severity and magnitude of an incident at Arkansas Nuclear One. The ADH is responsible for the initial notification and coordination of local services support to the public.

The individual with Emergency Direction and Control is responsible for the decision to notify the ADH and local officials of the declaration of an Emergency Class at Arkansas Nuclear One.

The ADH maintains a 24-hour communications center which receives the notification from ANO. Annex V of the State Emergency Operations Plan describes the activation of the State response organization and the interfaces and duties of these organizations.

Initial liaison during an incident at ANO is established through the Shift Manager/ED and the ADH Technical Operations Control Director (TOCD) or their respective designees.

Upon formal turnover, the Shift Manager/ED transfers this responsibility to the EOF Emergency Director (ED). Coordination of the response during a protracted incident at ANO is between the ED and the Technical Operations Control Director or their respective designees. ANO recommendations are provided to the TOCD. The TOCD issues advisories to local government officials and activates the local broadcast stations and emergency warning systems as described in Annex V to the State Emergency Operations Plan as appropriate.

For a Notification of Unusual Event emergency class, the ADH may dispatch the State Radiological Response Team to the site.

Revision 45 A-5

ARKANSAS NUCLEAR ONE EMERGENCY PLAN For an Alert, Site Area Emergency, or General Emergency, the ADH dispatches the State Radiological Response Team to the site. Team members perform appropriate measurements and analyses in the vicinity of the site and the Accident Assessment Officer makes an assessment of the public health hazard. On the basis of that assessment, the team leader recommends implementation of protective actions as set forth in the Arkansas Comprehensive Emergency Management Plan (ARCEMP).

The Radiological Assessment Coordinator is responsible for direct interfaces with the Arkansas Department of Health at the working level regarding radiological releases and radiological monitoring activities in the vicinity of ANO.

In accordance with Section H of the ANO Emergency Plan, designated ADH personnel collocate in the EOF with ANO personnel. As a result, a direct communications link is established in the EOF between ADH and ANO personnel during emergencies at ANO.

The JIC Manager, or designee, coordinates press releases with the Arkansas Department of Health's Public Information Team. A Letter of Agreement between Entergy Operations, Inc. and the ADH is summarized in Appendix 1.

b. The Arkansas Department of Emergency Management (ADEM)

The Arkansas Department of Emergency Management is responsible for coordinating requests for additional assistance in the event of an emergency situation at Arkansas Nuclear One.

Responsibilities of the Arkansas Department of Emergency Management include coordinating requests for additional assistance to support the offsite emergency response and recovery efforts of State, county, and municipal agencies and departments as provided in the Arkansas Emergency Operations Plan; assuring mutual coordination with the Department of Health concerning an incident at Arkansas Nuclear One and providing backup communications to the ADH in accordance with procedures set forth in Annex V, Chapter 4 of the Arkansas Emergency Operations Plan; and assuring that the necessary/available State and local manpower and equipment as well as proper utilization of such resources provided to respond effectively to the situation.

A Letter of Agreement between Entergy Operations, Inc. and the Arkansas Department of Emergency Management is summarized in Appendix 1.

2.2 ARKANSAS SECONDARY GOVERNMENTAL SUPPORT ORGANIZATIONS The Arkansas Department of Emergency Management (ADEM) coordinates requests for assistance from the following State agencies as discussed in the Letter of Agreement between Entergy Operations and ADEM summarized in Appendix 1.

Information on the response capabilities of these organizations is provided in detail in the State Emergency Operations Plan and Annex V to the State Emergency Operations Plan.

Revision 45 A-6

ARKANSAS NUCLEAR ONE EMERGENCY PLAN 2.2.1 Arkansas Highway and Transportation Department (AHTD)

Provides backup communications and assists in setting up road blocks to control traffic in the vicinity of any area that is to be evacuated and any designated care center being activated. AHTD provides signs and barriers for traffic control points and provide personnel and equipment to ensure evacuation routes remain passable.

2.2.2 Arkansas Military Department (National Guard)

Supports the ADEM on a mission-type basis (e.g., physical security, emergency evacuations).

2.2.3 County Food and Agricultural Councils County Food and Agricultural Councils provide information and advice to the Arkansas Department of Health concerning agricultural matters. Information is provided concerning the location of growing food crops, grain, forage, etc., so that samples may be taken by the ADH to determine if there is a hazard to persons or animals. If the ADH declares a particular area quarantined for cattle grazing, the County Food and Agricultural Councils provide farmers information concerning availability of uncontaminated feeds.

2.2.4 Arkansas Department of Parks and Tourism Provides notification of the public within the park system and, when necessary, ensures the evacuation of the state parks within the ANO emergency planning zones.

2.2.5 Arkansas Game & Fish Commission Provides backup communications and notification of the public in the national forests and on rivers and lakes. In addition, uniformed personnel are made available to assist in traffic control and law enforcement.

2.2.6 Local School Districts The local school districts coordinate use of school resources for transportation, housing, and feeding of evacuees.

2.2.7 Arkansas Department of Human Services (DHS)

Makes USDA food available to satisfy the short-term requirements of the designated care centers.

DHS arranges for delivery of USDA foods to designated care centers to replenish depleted stocks and provides supplies for feeding personnel who are sheltered in the designated care centers.

2.2.8 American Red Cross (ARC)

Arranges for registration of evacuees and perform other shelter management activities in accordance with the local EOP and/or Letters of Agreement executed between the ARC and the individual counties within the EPZ.

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ARKANSAS NUCLEAR ONE EMERGENCY PLAN 2.2.9 Civil Air Patrol (CAP)

Provides aerial reconnaissance, and logistic support for aerial monitoring and search and rescue activities.

2.2.10 Other State and Local Resources For Federal agencies responding to an emergency at ANO, the Bill and Hillary Clinton National Airport/Adams Field located in Little Rock is the nearest airport with commercial flight service.

The Russellville Airport can accommodate Falcon 10 jet traffic or its equivalent.

The Russellville Airport is the closer of the two located approximately 8 miles from the site. The State of Arkansas Backup SEOF is located at the Entergy Arkansas, Inc. Russellville Service Center. This facility is referenced in the State and county emergency plans.

2.3 LAW ENFORCEMENT SUPPORT ORGANIZATIONS Support from local, State, and/or Federal law enforcement agencies may be required to supplement the Arkansas Nuclear One Emergency Response Organization and to direct emergency efforts conducted beyond the ANO property boundary. The agencies listed below assist in the event of an emergency at Arkansas Nuclear One. Letters of agreement with these agencies are contained in Appendix 1. Interfaces between the Initial Response Staff, the Emergency Response Organization, and support groups are shown in Figures B-3, B-8 and B-10.

2.3.1 Sheriff Departments (Pope, Yell, Johnson, and Logan Counties)

When requested, the Sheriff Departments aid in security, traffic control, evacuations, emergency transportation and provide backup communications as required. The support of the Pope, Yell, Johnson, and Logan County Sheriff Departments are coordinated through the Arkansas Department of Emergency Management.

2.3.2 Arkansas State Police The Arkansas State Police provides traffic control, law enforcement, security and backup communications support where necessary.

2.4 FIRE SUPPORT ORGANIZATIONS The local fire organization which has agreed to support the Arkansas Nuclear One Emergency Response Organization is listed below. A letter of agreement with this agency is contained in Appendix 1. Interfaces between the Initial Response Staff, Emergency Response Organization and the local fire department are shown in Figures B-3, B-8, and B-10.

2.4.1 Local Fire Department When requested, the Local Fire Department dispatches men and equipment to assist in fighting fires. The Local Fire Department assists the Fire Brigade, as required. The Local Fire Department coordinates the support efforts of other fire departments in the area.

Revision 45 A-8

ARKANSAS NUCLEAR ONE EMERGENCY PLAN 2.5 MEDICAL SUPPORT ORGANIZATIONS Emergency medical services are available through the agencies listed below. Letters of Agreement with these agencies are summarized in Appendix 1. Interfaces between the Initial Response Staff, the Emergency Response Organization, and medical support organizations are shown in Figures B-3, B-8, and B-10.

2.5.1 Physicians Monfee Medical Clinic has been retained by Entergy Operations to provide medical consultants for Arkansas Nuclear One. At least two of the licensed physicians on the staff have received training in the treatment of patients that are contaminated and/or overexposed to radiation. These physicians treat personnel from Arkansas Nuclear One, including patients who may be injured or contaminated.

2.5.2 Hospitals The Saint Marys Regional Medical Center treats individuals who are injured and/or contaminated with radioactive material. Procedures have been established between the Saint Marys Regional Medical Center, the consulting physicians and Arkansas Nuclear One for the treatment of contaminated individuals at the Saint Marys Regional Medical Center. Individuals may be transferred to the University of Arkansas for Medical Sciences Hospital for further tests, examinations, or treatment, as required, if they:

a. have received an overexposure to radiation sufficient to warrant special treatment or observation, or;

b. have, or are suspected of having, inhaled or ingested significant quantities of radioactive materials, or;

c. cannot be readily decontaminated at the Saint Marys Regional Medical Center.

2.5.3 Pope County Emergency Medical Service The Pope County Emergency Medical Service provides emergency transportation of injured or contaminated individuals as requested.

2.5.4 The University of Arkansas for Medical Sciences Hospital The University of Arkansas for Medical Sciences Hospital is responsible for providing medical treatment for radiologically contaminated or overexposed individuals.

2.5.5 Other Medical Facilities Entergy Operations Incorporated has written confirmation that the following medical facilities are willing to accept and have adequately trained personnel and facilities available to provide the required care for injured individuals, regardless of whether or not they are radioactively contaminated or overexposed:

a. The Saint Marys Regional Medical Center

b. The University of Arkansas for Medical Sciences Hospital

c. Oak Ridge Associated University Medical Division Revision 45 A-9

ARKANSAS NUCLEAR ONE EMERGENCY PLAN 2.6 FEDERAL GOVERNMENT SUPPORT ORGANIZATIONS Section C.2 discusses the support organizations available to provide assistance from the Federal government. These organizations include the Nuclear Regulatory Commission (NRC), the Federal Emergency Management Agency (FEMA), the Department of Energy, the National Weather Service, the National Earthquake Information Center, the U.S. Coast Guard, the U.S.

Army Corps of Engineers, and the Environmental Protection Agency.

Initial notification and continued contact with the Arkansas Congressional delegation is the responsibility of the JIC Manager, or designee.

2.7 INDUSTRIAL SUPPORT ORGANIZATIONS Section C.6 discusses the industrial support organizations that can be contacted for support services in the event of an emergency at Arkansas Nuclear One. These organizations include utilities, Entergy Services Inc., INPO, Areva NP, and Westinghouse Electric. These organizations are kept informed of the incident as appropriate.

Revision 45 A-10

ARKANSAS NUCLEAR ONE EMERGENCY PLAN B ORGANIZATIONAL CONTROL OF EMERGENCIES Starting with the normal plant operating organization as a foundation, this section of the Emergency Plan describes the emergency organization at ANO. The Initial Response Staff (IRS),

is augmented by the Emergency Response Organization (ERO) at an Alert, or higher, Emergency Class.

The responsibility for Emergency Direction and Control (ED&C) at ANO during an emergency event includes the overall direction of the facility response and the non-delegable responsibilities for the decision to notify and to recommend protective actions to the Arkansas Department of Health personnel and other authorities responsible for offsite emergency measures. This responsibility will be transferred from the Shift Manager/ED with ED&C to the EOF Emergency Director (ED) once the ED has received a formal turnover and the ED is staffed and capable to perform ED&C functions from the EOF, or other designated location.

1.0 NORMAL PLANT ORGANIZATION The normal plant organization is shown in Figure B-1. During normal weekday, day shift hours, this entire organization and its staff are typically available on site. Outside normal weekday day shift hours the normal plant operating staff for Units 1 and 2 meets the minimum shift crew composition in the respective Technical Specifications for each unit and is supplemented by security personnel. The staff which is available to respond to the site within approximately 60 -

90 minutes is shown in Table B-1.

The Shift Manager for each unit is responsible for that unit and has the authority and responsibility for declaring an emergency at his unit in accordance with the guidelines in Section D of the Emergency Plan. Responsibility for emergency situations which are not specific to a unit is determined by a mutual agreement between the Shift Managers.

2.0 INITIAL RESPONSE STAFF The Initial Response Staff (IRS) has the capability to provide manpower and other resources to assist the normal plant organization within approximately 60 - 90 minutes if an emergency situation arises. The emergency duties of the normal plant staff are transferred to the Initial Response Staff as the corresponding members arrive on site.

If an emergency situation arises, the Shift Manager/ED will activate the Initial Response Staff, as appropriate, to supplement the normal operating staff. Those members of the Initial Response Staff who are not on site at the time of the emergency will be able to augment the normal plant organization within approximately 60 - 90 minutes of an emergency. Figure B-2 provides a diagram of the Initial Response Staff and their onsite interfaces.

Figure B-3 provides a diagram of the interfaces between the IRS and offsite response organizations. Modifications to the IRS may be made as necessary by the Shift Manager as required by the situation.

Following are general descriptions of the duties of IRS personnel. Duties are discussed in more detail in the Emergency Plan Implementing Procedures.

Revision 45 B-1

ARKANSAS NUCLEAR ONE EMERGENCY PLAN 2.1 SHIFT MANAGER / EMERGENCY DIRECTOR (ED)

The Shift Manager/ED has immediate responsibility for the unit to which he is assigned, and is responsible for recognizing and declaring the appropriate Emergency Class. Once an emergency classification is declared, the Shift Manager/ED is responsible for activating and directing the Initial Response Staff to the extent required by the emergency and assuming Emergency Direction and Control responsibilities until relieved of these duties through formal turnover. Once relieved, the Shift Manager's responsibilities are directed toward overseeing the operation of the unit.

Responsibilities of the Shift Manager/ED (until relieved by the EOF Emergency Director) include the following:

a. Initiating activation of the Emergency Response Organization and coordinating turnover of responsibility from the IRS to the ERO;

b. Issuing instructions directly to the plant emergency response personnel/teams;

c. Authorizing, requesting and coordinating assistance from outside groups and Federal agencies as required;

d. Initiating notification of and establishing communications with local, State, and Federal officials; and

e. Approving offsite Protective Action Recommendations (PARs) provided to State and local officials and other appropriate offsite authorities.

The Shift Manager/ED cannot delegate the responsibility to make decisions concerning notification of offsite authorities or the responsibility to make offsite Protective Action Recommendations. The Shift Manager/ED transfers these responsibilities to the EOF Emergency Director (ED) through a formal turnover when the EOF Emergency Director position is staffed and prepared to assume emergency direction and control responsibilities for the site.

Upon activation of the ERO, the Control Room Log Keeper will report to the Shift Manager/ED.

The Control Room Log Keeper will communicate with the TSC Communicator and the EOF/OSC Log Keepers to promote information flow between the facilities.

2.2 SHIFT ENGINEER / SHIFT TECHNICAL ADVISOR The primary duty of the Shift Engineer / Shift Technical Advisor is to assist the Shift Manager/ED in accident mitigation. There is a Shift Engineer / Shift Technical Advisor assigned on a shift basis to each unit.

2.3 CONTROL ROOM COMMUNICATOR At least one person per unit per shift is trained to coordinate communications to and from the affected unit's Control Room.

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ARKANSAS NUCLEAR ONE EMERGENCY PLAN 2.4 PLANT EMERGENCY RESPONSE TEAMS/GROUPS Members of the plant emergency response teams/groups are personnel assigned to the Arkansas Nuclear One staff. These personnel are trained in the respective procedures and practices which describe the performance of their duties as team/group members or leaders. The emergency teams/groups and brief descriptions of their functions are listed below. The plant emergency response team/group leaders initially report to the Shift Manager/ED. Team/group leaders and alternates are selected from plant personnel and are assigned as described in the Emergency Plan Implementing Procedures. As required by the emergency conditions, the Shift Manager/ED may temporarily assign other plant personnel to the emergency teams/groups to assist the regular team/group members during the emergency.

2.4.1 Staff Augmentation Group (SAG)

The capability exists to augment the on-shift staff through selective notification, depending upon the needs identified by the Shift Manager/ED, or by the Emergency Response Organization Notification (ERON) system if full ERO activation is necessary. An alternate notification method is available using a combination of pagers and telephone notifications, in the event of an ERON system failure. The on-shift staff can be augmented by one or all of the following groups:

2.4.1.A Emergency Radiation Team This team is responsible for the determination of radiological hazards which result from fires, radioactive spills, or other unplanned radioactive releases. When activated, the Emergency Radiation Team functions in two sections, as follows:

1. Onsite Radiological Monitoring Section This section is responsible for determining and evaluating onsite radiological hazards and for conducting the required surveys, monitoring, and sampling. This section, as necessary, assists the emergency medical support personnel, the Fire Brigade, and Repair and Damage Control Teams.

2. Offsite Radiological Monitoring Section This section is responsible for determining offsite radiological hazards and for conducting the required offsite surveys, monitoring, and sampling in the field and at the EOF/Alternate EOF.

2.4.1.B Engineering Group This group is responsible for providing engineering support to the TSC Engineering Coordinator in the areas of Mechanical, Electrical, Civil and Nuclear (Core Thermal/Hydraulics) Engineering.

The TSC Reactor Engineer coordinates with the TSC Engineering Coordinator and the Engineering group as it relates to core assessments.

2.4.2 First Aid and Rescue Personnel Emergency medical support personnel are responsible for providing first aid and coordinates onsite rescue operations.

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ARKANSAS NUCLEAR ONE EMERGENCY PLAN 2.4.3 Fire Brigade The Fire Brigade, as provided for in the Unit 1 and Unit 2 SARs (Sections 9.8 and Appendix 9A, respectively), is responsible for assessment of fires and implementation of appropriate fire control measures.

2.4.4 Security Personnel Security personnel are responsible for security at ANO and the evacuation of plant areas in the event of a Localized, Plant or Exclusion Area Evacuation. During an emergency they help maintain road blocks and perform personnel accountability duties.

2.4.5 Chemistry Group This group provides chemistry/radiochemistry and post-accident sampling support. Chemistry performs offsite dose projections if a radiological release occurs.

2.4.6 Maintenance Group This group is responsible for providing maintenance support in the areas of Instrumentation and Control, Electrical and Mechanical Maintenance. Initial repairs and corrective actions are performed by on-shift operations personnel with augmentation provided by maintenance personnel within 60 - 90 minutes (refer to Table B-1).

Initial repairs and corrective actions are defined as immediate actions intended to prevent or mitigate the consequences of an emergency. Actions anticipated within the first 60 - 90 minutes of an emergency are addressed in Abnormal Operating Procedures (AOPs) and Emergency Operating Procedures (EOPs).

2.4.7 Repair and Damage Control Teams These teams are composed of personnel that are familiar with the disciplines necessary to respond during emergency conditions. The repair and damage control teams are formed as required for the existing emergency condition.

3.0 EMERGENCY RESPONSE ORGANIZATION The Emergency Response Organization (ERO) has the capability to provide manpower and other resources to augment the IRS in an emergency situation. Emergency duties are transferred to ERO personnel in accordance with Emergency Plan Implementing Procedures.

When the ERO is activated, the EOF, TSC and OSC facilities are required to be operational within 60 - 90 minutes of the declaration of an Alert, or higher, Emergency Class. The goal for the offsite JIC is to be operational within 120 minutes of an Alert, or higher, Emergency Class. The EOF Emergency Director provides Emergency Direction and Control of the ERO. Figure B-4 provides a diagram of the ERO showing the reporting chain within the ERO. Figure B-8 provides a diagram of the interfaces between the ERO and offsite response organizations. Modifications to the ERO may be made by the EOF Emergency Director or Emergency Plant Manager (EPM) as required by the situation.

Revision 45 B-4

ARKANSAS NUCLEAR ONE EMERGENCY PLAN Following are general descriptions of the duties of ERO personnel. These descriptions are grouped according to the facility to which ERO personnel respond. Duties are discussed in more detail in the Emergency Plan Implementing Procedures.

3.1 EMERGENCY OPERATIONS FACILITY (EOF) 3.1.1 Emergency Director (ED)

The EOF Emergency Director position is an individual whose position in the normal organization is a senior management position. The ED is responsible for the direction of the total emergency response following turnover of Emergency Direction and Control from the Shift Manager/ED. The ED reports to Entergy Operations, Inc. management. The ED may request one or more assistants. These assistants are typically qualified as Emergency Directors. Assistants perform duties as assigned by the ED. The ED may release assistants if the assistance is no longer required. The Emergency Plant Manager, Radiological Assessment Coordinator, EOF Manager, EOF Offsite Communicator, EOF Technical Advisor and EOF Log Keeper report directly to the ED. The EDs responsibilities include:

A. Activation and operation of the EOF; B. Classification and declaration of the emergency; C. Makes Protective Action Recommendations (PARs) to the offsite agencies; D. Directs and approves notification of the event to the offsite agencies; E. Coordinates accident information with other offsite governmental agencies (NRC, etc.);

F. Requests assistance from offsite agencies excluding requests for offsite medical or fire-fighting assistance; G. Authorizes radiation exposure in excess of 10 CFR 20 limits and issuance of Potassium Iodide (KI) for ERO members outside of the protected area; H. Approves press releases; I. Directs the activities of the EOF organization in support of the Technical Support Center and offsite agencies; J. Ensures that Entergy Operations, Inc. executive management is kept informed of the emergency situation; 3.1.2 EOF Offsite Communicator The EOF Offsite Communicator reports to the ED in the EOF. Responsibilities of the EOF Offsite Communicator include:

A. Completes and performs initial and follow-up offsite notifications, in accordance with site procedures and regulatory requirements, to State/Local/NRC relating to emergency classification events; B. Verifies that State/Local agencies have received and understand all offsite notifications; Revision 45 B-5

ARKANSAS NUCLEAR ONE EMERGENCY PLAN C. Initiates and/or verifies that ERDS data is being transmitted to the NRC.

D. Maintains records of all notifications and communications 3.1.3 EOF Technical Advisor The EOF Technical Advisor reports to the ED in the EOF. Responsibilities of the EOF Technical Advisor include:

A. Maintains communications with the Control Room and TSC to obtain current plant and emergency status; B. Monitors plant computer parameters for prompt identification of changing conditions; C. Recommends actions to the Emergency Director on classification of emergencies; D. Supports PAR decision making/determination.

3.1.4 EOF Communicator The EOF Communicator reports to the EOF Manager in the EOF. Responsibilities of the EOF Communicator include:

A. Maintains communications with the Control Room, TSC and OSC for prompt identification of information that needs to be posted in WebEOC, or other acceptable method; B. Ensuring that the EOF staff is informed of significant changes in plant conditions; C. Assisting the EOF Manager with other non-regulatory notifications and communications.

D. Supports the ED / EOF Manager, as requested.

3.1.5 Radiological Assessment Coordinator (RAC)

The RAC reports to the ED in the EOF. The RAC is responsible for conducting assessment activities for offsite radiological conditions. The Offsite Team Coordinator and the EOF Dose Assessor report directly to the RAC. Responsibilities of the RAC include:

A. Evaluates dose assessment results and recommendations, determines dose consequences and communicates dose projection results to the ED to determine classification/PAR; B. Provides overall liaison and coordination of efforts in the area of offsite monitoring teams with State Radiological personnel; C. Briefs offsite authorities and supplemental/relief personnel responding to the EOF on radiological information; D. As requested, ensures that communications on the NRC Health Physics Network (HPN) phone is assigned; E. Monitors status of the emergency ventilation and habitability monitoring results in the EOF and keeps the EOF staff updated; Revision 45 B-6

ARKANSAS NUCLEAR ONE EMERGENCY PLAN F. Recommends EOF relocation based on environmental conditions and provides radiological guidance for EOF evacuation; G. As required, provides recommendations to the ED relating to extension of emergency exposure limits and the administration of KI for EOF ERO / offsite monitoring teams and coordinates the administration of KI.

3.1.6. Dose Assessor The Dose Assessor reports to the RAC in the EOF. The Dose Assessor is responsible for conduct/oversight of offsite dose projection calculation activities performed in the EOF. Trained dose assessment personnel report to the OSC and can be dispatched to the EOF as needed to assist the Dose Assessor with this responsibility. Responsibilities of the Dose Assessor include:

A. Supports the radiological activities in the EOF by keeping informed of offsite monitoring team data results, plant data and current/forecasted meteorological conditions; B. Performance of dose projection calculations using plant data and offsite monitoring team data; C. Coordination with the Offsite Team Coordinator for offsite monitoring team data / dose projection comparison; D. Support coordination of efforts in the area of dose projection calculations with State dose assessment personnel; C. Provides offsite dose projection information to the RAC.

3.1.7 Offsite Team Coordinator (OTC)

The OTC coordinates offsite monitoring team activities and coordinates data from offsite monitoring teams with the Dose Assessor. The OTC reports to the RAC in the EOF.

Responsibilities of the OTC include:

A. Assigns and maintains communication with offsite monitoring teams and EOF monitoring personnel; B. Directs offsite monitoring teams based upon radiological/meteorological information and coordinates survey locations with the Dose Assessor; C. Provides offsite monitoring team information to the Dose Assessor and the RAC; D. Supports coordination of efforts in the area of offsite monitoring team data with State radiological personnel; E. Briefs and coordinates the administration of KI for offsite monitoring teams.

Revision 45 B-7

ARKANSAS NUCLEAR ONE EMERGENCY PLAN 3.1.8 EOF Manager The EOF Manager coordinates emergency response efforts outside of the Protected Area and oversees operation of the EOF. The EOF Maintenance Coordinator, EOF Communicator, Admin

& Logistics Coordinator, Public Information Liaison and Lead Offsite Liaison report to the EOF Manager in the EOF. The EOF Manager reports to the ED in the EOF. Responsibilities of the EOF Manager include:

A. Assures staffing and timely activation of the EOF; B. Obtains additional resources through the Admin and Logistics Coordinator in support of the Site/EOF; C. Briefs and assists offsite authorities reporting to the EOF; D. Assists the RAC with facility habitability and emergency ventilation system operation; E. Provides oversight for timely offsite notifications performed by the EOF Offsite Communicator F. Ensures that WebEOC or status boards are maintained in the EOF; G. Provides information to the Entergy Corporate Office and the Corporate Emergency Center (CEC).

H. As requested during a security-related event, provide a Security Management individual to staff the Pope County OEM Security Liaison function in the Incident Command Center.

3.1.9 EOF Maintenance Coordinator The EOF Maintenance Coordinator coordinates the initial setup of work areas/equipment in the EOF. The EOF Maintenance Coordinator reports to the EOF Manager. Responsibilities of the EOF Maintenance Coordinator include:

A. Ensures that the EOF emergency ventilation system is in operation in the EOF, as required, and the appropriate EOF personnel have been notified of status.

B. Ensures that the EOF emergency diesel generator is in operation in the EOF, as required, and the appropriate EOF personnel have been notified of status.

C. Coordination for setup of the Secondary OSC/TSC, as requested.

D. Coordination for setup of the Alternate EOF, as requested.

E. Coordination of equipment setup with responding agencies (NRC, FEMA, etc.).

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ARKANSAS NUCLEAR ONE EMERGENCY PLAN 3.1.10 EOF Log Keeper The EOF Log Keeper reports to the Emergency Director. Responsibilities of the EOF Log Keeper include:

A. Maintains a chronological log of emergency status and EOF activities; B. Ensures timeliness of facility briefs by prompting the ED of the briefing schedule, if necessary.

C. Distributes Emergency Notification Forms.

3.1.11 Admin & Logistics Coordinator The Admin & Logistics Coordinator provides support to the EOF Manager and the TSC staff, as requested. IT support for the EOF also reports to the Admin & Logistics Coordinator. The Admin

& Logistics Coordinator reports to the EOF Manager. Responsibilities for the Admin & Logistics Coordinator include:

A. Management of 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> staffing for all of the emergency response facilities; B. Management of logistics in support of the ERO involving requests for additional support personnel, equipment, meals, lodging, etc.;

C. Coordination of security access measures in the EOF, as required.

3.1.12 Public Information Liaison The Pubic Information Liaison provides the primary interface between the JIC and EOF. The Public Information Liaison reports to the EOF Manager. Responsibilities of the Public Information Liaison include:

A. Ensuring that the JIC is provided with the current plant status information; B. Ensuring that classification upgrades are communicated to the Company Spokesperson; C. Perform reviews of press releases prior to ED review and approval.

3.1.13 Lead Offsite Liaison The Lead Offsite Liaison reports to the EOF Manager. Offsite Liaisons will report to the Lead Offsite Liaison and are dispatched to County EOCs upon request by the EOC. Responsibilities of the Lead Offsite Liaison include:

A. Providing routine briefings on plant conditions with offsite agencies located in the EOF, with County EOC officials and with Offsite Liaisons that have been dispatched to the County EOCs.

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ARKANSAS NUCLEAR ONE EMERGENCY PLAN 3.2 TECHNICAL SUPPORT CENTER (TSC) 3.2.1 Emergency Plant Manager (EPM)

The EPM reports to the EOF Emergency Director (ED). The EPM has the responsibility for the command and control of all accident mitigation actions at the site and performs these duties from the TSC. The OSC Manager, TSC Manager and Security Coordinator report to the EPM.

Responsibilities of the EPM include:

A. Directing the activation, operation and deactivation of the TSC; B. Assuming command and control of the TSC and OSC and the onsite mitigation efforts; C. Providing information and recommendations to the ED regarding classification of emergencies and core damage assessments; D. Prepare and facilitate facility briefings; E. Coordination of activities with the CR, TSC and OSC and prioritizing mitigation actions and the coordination of repair/damage control teams; F. Ensuring timely ENS notifications in the TSC; G. Directing onsite protective actions and personnel evacuation, assembly and accountability of non-essential personnel; H. Authorizing emergency radiation exposure and issuance of KI to recommended personnel in the CR, TSC, OSC or Security personnel; I. Implementing the severe accident management procedure strategies, as required; J. Directing the relocation of the TSC/OSC to alternate locations, as required.

3.2.2 Security Coordinator The Security Coordinator reports to the EPM. Responsibilities of the Security Coordinator include:

A. Overall coordination of the offsite assistance for a security related response; B. Coordination of accountability and security officer support relating to plant and exclusion area evacuations; C. Updating of the security force concerning the emergency status; D. Coordination with the TSC Radiological Coordinator regarding protective actions for the security force; E. Ensuring that the ED/EPM is informed of any security contingency event which may be occurring and the response in progress.

Revision 45 B-10

ARKANSAS NUCLEAR ONE EMERGENCY PLAN 3.2.3 TSC Manager The TSC Manager reports to the EPM. The TSC ENS Communicator, TSC Communicator, Reactor Engineer, Maintenance Coordinator, Engineering Coordinator, Radiological Coordinator, and Operations Coordinator report to the TSC Manager. Responsibilities of the TSC Manager include:

A. Oversight for the staffing and timely activation of the TSC and notification to the EPM when the TSC is considered operational; B. Recognizing and implementing all technical aspects of accident mitigation for the emergency; C. Performing technical assessments and communicating the conclusions to the EPM; D. Setting priorities for the TSC personnel; E. Assisting the EPM to make operational decisions concerning the safety of the plant; F. Overseeing the activities for relocation to an alternate location; G. Directing the tracking of plant configuration changes; H. Deactivating the TSC when the emergency is terminated.

3.2.4 TSC ENS Communicator The TSC ENS Communicator in the TSC reports to the TSC Manager. Responsibilities of the TSC ENS Communicator include:

A. Establishing and maintaining communications with the NRC via the ENS phone; B. Monitoring plant computer parameters and providing plant status to the NRC; 3.2.5 TSC Communicator The TSC Communicator reports to the TSC Manager. Responsibilities of the TSC Communicator include:

A. Establishing communications with the CR, TSC, OSC and EOF counterparts for obtaining plant status reports and significant events; B. Maintaining the TSC status boards in WebEOC or other acceptable method; C. Supporting the EPM and TSC Manager as requested.

Revision 45 B-11

ARKANSAS NUCLEAR ONE EMERGENCY PLAN 3.2.6 Reactor Engineer The Reactor Engineer reports to the TSC Manager. Responsibilities of the Reactor Engineer include:

A. Determining and providing estimation of core damage assessment information; B. Assisting in Severe Accident Management Guideline implementation; C. Providing core parameter information results to the TSC Manager.

3.2.7 Operations Coordinator The Operations Coordinator reports to the TSC Manager. Operations support personnel report to the Operations Coordinator to assist with accident assessment relating to plant conditions.

Responsibilities of the Operations Coordinator included:

A. Coordination of TSC efforts in determining the nature and extent of emergencies pertaining to equipment and plant facilities in support of Control Room actions; B. Providing interface between the TSC and Control Room; C. Providing technical assistance to the Shift Manager and coordinating requests from the Control Room for operations activities and additional staffing needs; D. Recommending strategies and actions to prevent severe core damage, containment failure and the reducing radiological releases; E. Perform accident assessment activities and recommending changes in plant priorities.

3.2.8 Maintenance Coordinator The Maintenance Coordinator reports to the TSC Manager. The Maintenance Coordinator, with input from the Engineering Coordinator and Operations Coordinator is responsible for the development of rescue/ repair and damage control plans. The Maintenance Coordinator works closely with the OSC Manager and the Work Control Coordinator to ensure that these plans are carried out in a timely manner. Additional responsibilities of the Maintenance Coordinator include:

A. Assisting in the development and prioritization of repair and corrective actions with other TSC staff personnel; B. Communicating requests for rescue/repair and damage control teams corrective actions to the OSC Manager and/or Work Control Coordinator; C. Providing corrective action status to the TSC staff for rescue/repair and damage control teams dispatched from the OSC.

Revision 45 B-12

ARKANSAS NUCLEAR ONE EMERGENCY PLAN 3.2.9 Engineering Coordinator The Engineering Coordinator reports to the TSC Manager. TSC Support Engineers and IT support personnel report to the Engineering Coordinator. Responsibilities of the Engineering Coordinator include:

A. Providing technical guidance to support repair activities; B. Coordinating the Engineering work requests with the Engineering support team; C. Tracking of plant configuration changes and directing development of emergency repair procedures to support emergency teams.

3.2.10 Radiological Coordinator The Radiological Coordinator reports to the TSC Manager. The Radiological Coordinator is responsible for providing Radiation Protection coverage for the site during an emergency event The Radiological Coordinator is responsible for directing onsite monitoring and decontamination activities, for overseeing radwaste processing and monitoring activities, and for ensuring that personnel exposures are maintained As Low As is Reasonably Achievable (ALARA). Additional responsibilities of the Radiological Coordinator include:

A. Keeping the TSC Manager informed of the radiological conditions; B. Recommending authorization of personnel emergency exposure limits; C. Advising the TSC Manager when use of KI should be considered and coordinating the issuance of KI, if approved; D. Advising the TSC Manager and EOF RAC of changes in radiological release status; E. Coordinating with the Security Coordinator to determine the routes to be used for evacuation of non-essential personnel and BREs; F. Advising the RAD/Chem Coordinator in the OSC of changes in plant conditions or equipment that may change radiological conditions onsite.

3.3 OPERATIONAL SUPPORT CENTER (OSC) 3.3.1 OSC Manager The OSC Manager reports to the EPM in the TSC. The OSC Log Keeper, Work Control Coordinator and Operations Support positions report to the OSC Manager. The OSC Manager may request one or more assistants. These assistants are typically qualified as OSC Managers.

Assistants perform duties as assigned by the OSC Manager. The OSC Manager may release assistants if the assistance is no longer required. The OSC Manager is responsible for the implementation of rescue/repair and damage control plans. He provides additional support to the Shift Manager for problems directly related to plant operations, such as a fire or medical emergency. The plant Fire Brigade and the Emergency Medical Team report to the Shift Manager in the normal organization. Upon activation of the OSC, medical response personnel onsite will Revision 45 B-13

ARKANSAS NUCLEAR ONE EMERGENCY PLAN report to the OSC and the OSC Manager can, upon mutual agreement with the Shift Manager, assume the responsibility for offsite fire and medical response. Responsibilities of the OSC Manager include:

A. Directing the activation, operation and deactivation activities of the OSC; B. Supporting the formation, briefing, and debriefing of rescue/repair and damage control teams and onsite monitoring teams; C. Ensuring the timely dispatch of the rescue/repair and damage control teams, onsite monitoring teams and mobilization of other required support personnel; D. Ensuring work task priorities are being maintained; E. Maintaining OSC accountability and coordination of the OSC facility to an alternate facility, as necessary.

3.3.2 Work Control Coordinator The Work Control Coordinator reports to the OSC Manager. Responsibilities of the Work Control Coordinator include:

A. Coordinating the formation, briefing and debriefing of rescue/repair and damage control teams and onsite monitoring teams; B. Maintaining communications with the TSC; C. Ensuring timely dispatch of rescue/repair and damage control teams and assist with the mobilization of other required support personnel.

D. Tracking rescue/repair and damage control teams.

3.3.3 Operations Support The Operations Support position in the OSC reports to the OSC Manager. Responsibilities of the OSC Operations Support position include:

A. Supporting the OSC in locations of plant equipment; B. Ensuring that the Shift Manager is informed of the formation of OSC teams and other activities; C. Identifying and assisting with potential operational support needs including assistance with briefings for rescue/repair and damage control teams and keeping the OSC Manager updated on changing plant parameters.

Revision 45 B-14

ARKANSAS NUCLEAR ONE EMERGENCY PLAN 3.3.4 OSC Log Keeper The OSC Log Keeper reports to the OSC Manager. Responsibilities of the OSC Log Keeper include:

A. Maintaining facility status boards on WebEOC of other acceptable method; B. Supporting the OSC Manager as requested.

3.3.5 RAD/Chem Coordinator The RAD/Chem Coordinator reports to the Work Control Coordinator. The RAD/Chem Coordinator is responsible for directing the Onsite Section of the Emergency Radiation Team and for providing an up-to-date status of the site radiological conditions to the TSC and Control Room.

Additional responsibilities of the RAD/Chem Coordinator include:

A. Coordinating RP activities, including on-site radiological assessment, personnel exposure control and Radiation Protection programs; B. Ensuring habitability of the TSC, OSC and Control Room; C. Conducting and providing assistance for the radiological briefings to support the dispatch of rescue/repair and damage control teams and Chemistry/RP sampling; D. Communicating radiological and chemistry sample/survey results to the TSC and/or Control Room; E. Coordinating the transport of potentially contaminated or highly exposed personnel to offsite medical facilities; F. Determining the necessity for emergency exposure limits and KI issuance and communicating conditions to the TSC; G. Providing radiological support for evacuations, medical response, fire response and search and rescue; H. Participate in team dispatch and field operations; I. Direct and support chemistry sampling.

3.3.6 Electrical / I&C Coordinator The Electrical / I&C Coordinator reports to the Work Control Coordinator. Responsibilities of the Electrical / I&C Coordinator include:

A. Assigning team members to the repair and damage control teams; B. Conducting or participating in the pre-job briefing for the assigned tasks; C. Ensuring repair and damage control teams are tracked; D. Ensuring communication with the teams is maintained.

Revision 45 B-15

ARKANSAS NUCLEAR ONE EMERGENCY PLAN 3.3.7 Mechanical Coordinator The Mechanical Coordinator reports to the Work Control Coordinator. Responsibilities of the Mechanical Coordinator include:

A. Assigning team members to the repair and damage control teams; B. Conducting or participating in the pre-job briefing for the assigned tasks; C. Ensuring repair and damage control teams are tracked; D. Ensuring communication with the teams is maintained.

3.4 JOINT INFORMATION CENTER (JIC) 3.4.1 Company Spokesperson The Company Spokesperson is responsible for overall public information. The JIC Manager and the Technical Advisor report to the Company Spokesperson. Responsibilities of the Company Spokesperson include:

A. Obtaining a briefing from the ED to ensure timely development of press releases and serving as the spokesperson at media briefings; B. Ensuring that news media briefings are held regularly during the course of the event; C. Keeping the Entergy Vice President, Nuclear Communications, or designee, informed throughout the emergency; D. Resolving any known rumors or misinformation to the Media.

3.4.2 Technical Advisor The Technical Advisor reports to the Company Spokesperson. Responsibilities include:

A. Answering technical questions from the news media regarding the emergency situation; B. Advising the Inquiry Response Coordinator on questions about radiation or nuclear technology to respond to phone questions from the public and media.

3.4.3 JIC Manager The JIC Manager reports to the Company Spokesperson. The Information Coordinator, Media Liaison, Logistics Coordinator and JIC Log Keeper report to the JIC Manager. Responsibilities of the JIC Manager include:

A. Directing the activation, operation and deactivation of the JIC; B. Obtaining ED approval for all developed press releases; C. Ensuring that press releases are coordinated with and communicated to offsite agencies; D. Ensuring appropriate timing, content and distribution of press releases; E. Establishing media briefing schedule and ensuring the activation of the rumor control/public inquiry activities in response to questions from the general public.

Revision 45 B-16

ARKANSAS NUCLEAR ONE EMERGENCY PLAN 3.4.4 Information Coordinator The Information Coordinator reports to the JIC Manager. Responsibilities include:

A. Providing press releases for distribution; B. Supervising media monitoring and response activities and public response activities; C. Establishing and maintaining frequent contact with the communications personnel in the Entergy CEC and corporate offices.

3.4.5 JIC Technical Assistant The JIC Technical Assistant reports to the Information Coordinator. Responsibilities include assisting the Press Release Writer for technical accuracy.

3.4.6 Press Release Writer The Press release writer reports to the JIC Manager and coordinates information with the Information Coordinator. Responsibilities include:

A. Coordinates with the Information Coordinator to ensure that press releases include the latest information for the event; B. Delivering copies of the press releases to the CEC/Corporate Communications.

3.4.7 Media Liaison The Media Liaison reports to the JIC Manager. Responsibilities include:

A. Verifying the readiness of the JIC briefing area; B. Ensuring the media is informed of protocol and schedules established for media briefings; C. Receive and distribute press release information to the media in the JIC briefing area.

3.4.8 JIC Log Keeper The JIC Log Keeper reports to the JIC Manager. Responsibilities include: Maintaining a JIC facility log on WebEOC or other acceptable method and supporting the JIC Manager, as requested.

3.4.9 Logistics Coordinator The Logistics Coordinator reports to the JIC Manager. JIC Credentialing personnel report to the Logistics Coordinator. Responsibilities of the Logistics Coordinator include:

A. Activating facility security actions and facility briefing area and maintaining access control to the JIC; B. Ensuring distribution of all press releases to the offsite agencies, JIC/EOF facilities and to the Media Liaison.

Revision 45 B-17

ARKANSAS NUCLEAR ONE EMERGENCY PLAN 3.4.10 Credentialing Credentialing personnel report to the Logistics Coordinator. Responsibilities include:

A. Establishing security to restrict access to the JIC to authorized Utility and Government JIC responders and to restrict access to the JIC media/briefing areas to individuals with media credentials.

3.4.11 Inquiry Response Coordinator The Inquiry Response Coordinator reports to the Information Coordinator. Public Inquiry Responders report to the Inquiry Response Coordinator. Responsibilities include:

A. Ensuring the activation of rumor control activities for response to questions from the general public and the media; B. Monitoring and responding to the pubic/media inquiry calls and tracking trends; C. Referring questions on radiation or nuclear technology received by the Inquiry Responders to the Technical Advisor.

3.4.12 Inquiry Responders The Inquiry Responders report to the Inquiry Response Coordinator. Responsibilities include:

A. Responding to telephone inquiries from the general public and the media; B. Logging questions that require a callback and logging rumors and providing rumors to the Inquiry Response Coordinator.

3.4.13 Media Monitoring Media Monitoring personnel report to the Information Coordinator. Responsibilities include monitoring TV and radio broadcasts for inaccuracies and reporting the inaccuracies to the Information Coordinator to ensure that they are addressed in the media briefings.

4.0 EMERGENCY RESPONSE ORGANIZATION INTERFACES WITHIN THE ORGANIZATION AND WITH OFFSITE ORGANIZATIONS The EOF Emergency Director provides the management level interface with Federal, State, and local officials. The Emergency Director interfaces with the State Health Officer and the Technical Operations Control Director (TOCD) of the Arkansas Department of Health (ADH) and with representatives of the NRC. The Emergency Director also interfaces with representatives of other Federal agencies responding to the ANO site. The Emergency Director interfaces with local officials upon request or, as required, by the situation.

Interfaces are also maintained at the working level within the ERO (interfaces through the normal chain of command are not described). Refer to Figures B-4, B-5, B-6, B-7, B-11 and B-12 for ERO member assignments within the assigned facilities. Although key ERO members will communicate with each other as necessary, the following interfaces are key facility reporting Revision 45 B-18

ARKANSAS NUCLEAR ONE EMERGENCY PLAN paths between the emergency response facilities: (1) the Operations Coordinator receives information about plant status from the Shift Manager or the Assistant Operations Manager in the Control Room, (2) the TSC Radiological Coordinator communicates with the OSC RAD/Chem Coordinator to obtain onsite radiological conditions, (3) the Maintenance Coordinator confers with the OSC Work Control Coordinator concerning repair planning and the status of repairs in progress, (4) the TSC Reactor Engineer and/or the Engineering Coordinator consult with the OSC RAD/Chem Coordinator to obtain post-accident sample results, (5) the EOF Admin & Logistics Coordinator receives and processes requests from the TSC Manager or TSC Communicator for additional personnel, material, etc., (6) the EOF Radiological Assessment Coordinator (RAC), or designee, interfaces with the designated laboratory if their services are required, (7) an interface is maintained between the RAC/Dose Assessor and the TSC Radiological Coordinator to exchange data on onsite radiological conditions affecting dose assessment, (8) interfaces are maintained among the managers/coordinators in the TSC to assure a coordinated response to the incident by onsite personnel, and (9) interfaces are maintained between the EOF/TSC Manager positions and the Admin & Logistics Coordinator to allow the Admin & Logistics Coordinator to provide technical and non-technical support to the ERO, as approved by the Emergency Director.

Working level interfaces are maintained between ERO positions and offsite agencies and response organizations. These interfaces operate upon the approval of the ED and/or as described in the Emergency Plan Implementing Procedures. The Radiological Assessment Coordinator maintains an interface with the ADH Radiological Response Team Leader to coordinate information on offsite monitoring and dose assessment. The RAD/Chem Coordinator maintains interfaces with the representatives of Areva NP, as necessary, in the event post-accident sample analyses are requested. The Emergency Plant Manager, or designee, maintains interfaces as necessary with local law enforcement officials, medical and hospital personnel, and fire department officials when these organizations are requested to respond on site. The Emergency Plant Manager, or designee, maintains an interface with the U.S. Coast Guard if assistance is requested from this organization.

The Admin & Logistics Coordinator maintains interfaces with consultants, INPO, the Entergy Operations Corporate Emergency Center, and other utilities to provide information and coordinate support, as requested, from these organizations. Based on emergency conditions, and as deemed necessary, other employees of Entergy may be requested to assist in a response to an emergency based on their normal day-to-day expertise. These other employees will perform duties under the direct supervision of qualified ERO personnel.

The Company Spokesperson, JIC Manager, JIC Information Coordinator, JIC Media Liaison and Lead Offsite Liaison (or their designees) maintain interfaces with the media, local officials, government officials, utilities, and internal Entergy communication services to assure that information concerning the incident is disseminated appropriately.

Revision 45 B-19

ARKANSAS NUCLEAR ONE EMERGENCY PLAN TABLE B-1 MINIMUM STAFFING REQUIREMENTS (ANO On-Shift Staffing Analysis Final Report Revision 2 (OSRC Approved: 07/24/2017)

(Including Capability for Additional Staffing)

On-Shift1 Available3 Available3 Major Functional Area Position/Title or Expertise U-1 U-2 In 60 Min In 90 Min Plant Operations Manager, Shift Ops (SRO) 1 1 - -

Supervisor, Control Room (SRO) 1 1 - -

Control Room Operators 2 2 - -

Auxiliary Operators 2 2 - -

Shift Technical Advisor (Shift Engineer) 1 1 - -

Waste Control Operator (Radwaste) 1 1 - 1 Emergency Direction & 14 14 - 1 Control (Emerg. Director)

Notification/ Communicator 1 1 - -

Communication Control Room/EOF - - - 1 Communications Personnel Radiological Accident EOF Dose Assessor - - - 1 Assessment and Support Chemist (Offsite Dose Projections) 19 19 1 Operational Accident Radiation Protection Technician (In-Plant Surveys) 110 110 1 1 Assessment, and Radiation Protection Technician - - 1 1 Protective Actions (Onsite Out-of-Plant Surveys)

(in plant) Radiation Protection Technicians 32 32 2 2 (Protective Actions - In Plant)

Radiation Protection Technicians (Offsite Surveys) - - 2 2 Chemistry/Radiochemistry Chemists 19 19 - 1 Repair and Electrical Maintenance 32.12 32,12 15 15 Corrective Actions I&C Technician - - 16 16 Mechanic 32,12 32,12 - 213 System & Component Core/Thermal Hydraulics 18 18 1 -

Engineering Electrical Engineer - - 1 Mechanical Engineer - - 1 Firefighting --- 52,11 Local Support (30 Minute Response)

Rescue Operations and --- 22 Local Support First-Aid (30 Minute Response)

Site Access Control and Security Personnel All per Security Plan Personnel Accountability The Total Number of Personnel on Shift is 23.

1 These ERO positions may be vacant for not more than two hours in order to provide for unexpected absences, provided immediate action is taken to fill the require position.

2 May be provided by shift personnel assigned other functions.

3 Once notified, emergency responders are to report to their assigned facility as soon as possible and without delay.

4 The Manager, Shift Ops initially assumes the responsibility for Emergency Direction and Control, then is relieved by the EOF Emergency Director.

5 Electrical Maintenance personnel.

6 I&C Maintenance personnel.

7 Deleted.

8 STA duties encompass the Core/Thermal Hydraulics function.

9 There are two Chemists on shift qualified to perform offsite dose projections and chemistry/radiochemistry functions for either unit.

10 On-Shift Radiation Protection Technicians are qualified to perform Protective Actions In-Plant and In-Plant Surveys.

11 Includes an additional Operator not counted elsewhere in the table.

12 ANO Nuclear Plant Operators are trained to perform the actions associated with Repair and Corrective Action. This an acceptable collateral duty per the guidance of NEI 10-05 section 2.5 (On-Shift Staffing Analysis Final Report section II.D).

13 Mechanical Maintenance personnel.

Revision 45 B-20

ARKANSAS NUCLEAR ONE EMERGENCY PLAN FIGURE B-1 NORMAL PLANT ORGANIZATION Site Vice President General Manager, Director, Director, Plant Operations Regulatory & Engineering Performance Improvement Sr. Manager, Sr. Manager, Manager, Operations Maintenance Manager, Systems &

Emergency Components Planning Manager, Manager, Radiation Manager, Design Chemistry Manager, & Program Protection Security Engineering Sr. Manager, Site Sr. Manager, Manager, Projects & Maint Production Regulatory Services Assurance Manager, Outage Manager, Performance Improvement Manager, Training Revision 45 B-21

ARKANSAS NUCLEAR ONE EMERGENCY PLAN FIGURE B-2 INITIAL RESPONSE STAFF*

(IRS)

Manager, Shift Ops / ED Communicator Operations Staff Security Shift Engineer / Emergency Chemistry Maintenance Control Room/TSC Shift Technical Response Team Personnel Personnel Communications Advisor Leaders Personnel I&C Radiation Protection Electrical Fire Brigade Mechanical Medical

• This organization is available to respond within approximately 60 - 90 minutes to any emergency class.

Revision 45 B-22

ARKANSAS NUCLEAR ONE EMERGENCY PLAN FIGURE B-3 INITIAL RESPONSE STAFF Interfaces With Offsite Agencies Shift Manager / ED Communicator ADH / ADEM NRC County Warning Points Direct Interface Initial Interface FIGURE B-4 ERO KEY FACILITY REPORTING CHAIN Emergency Director Company (EOF) Spokesperson (JIC)

Emergency Plant Shift Manager Manager (TSC) (Control Room)

OSC Manager (OSC)

Revision 45 B-23

ARKANSAS NUCLEAR ONE EMERGENCY PLAN FIGURE B-5 EOF EMERGENCY DIRECTORS STAFF Emergency Director Offsite Technical EOF Log EOF Manager Communicator Advisor Keeper Admin & Logistics EOF Public Information Coordinator Communicator Liaison Lead Offsite Radiological *IT Specialist Liaison Assessment Coordinator Offsite EOF Maintenance Liaison(s)

Coordinator Offsite Team Dose Assessor Coordinator Offsite Monitoring Offsite Monitoring Team No. 1 Team No. 2

• One IT Specialist required for Standard ERO, may be in TSC or EOF Revision 45 B-24

ARKANSAS NUCLEAR ONE EMERGENCY PLAN FIGURE B-6 TSC EMERGENCY PLANT MANAGERS STAFF EPM TSC Manager Security Coordinator TSC Communicator ENS Communicator Reactor Engineer Radiological Coordinator Maintenance Coordinator Engineering Coordinator Operations Coordinator Ops Support Mechanical Engineer IT Specialist Electrical / I&C Engineer Revision 45 B-25

ARKANSAS NUCLEAR ONE EMERGENCY PLAN FIGURE B-7 OSC MANAGERS STAFF OSC Manager WORK CONTROL OPERATIONS OSC LOG KEEPER COORDINATOR SUPPORT MECHANICAL RAD/CHEM ELECTRICAL / I&C COORDINATOR COORDINATOR COORDINATOR OSC SUPPORT and Teams Revision 45 B-26

ARKANSAS NUCLEAR ONE EMERGENCY PLAN FIGURE B-8 EMERGENCY RESPONSE ORGANIZATION OFFSITE INTERFACES Arkansas Dept. of Health NRC

- Governor

- ADEM Emergency Entergy CEC

- FEMA Director (ED) Manager Technical Operations Control Director Emergency Plant

- Radiological Assessment Teams Manager (EPM)

- County Governments Fire

- Local Fire Department Shift Manager / Direct Interface OSC Manager*

Medical Indirect Interface

- Pope County EMS

- Saint Marys Regional Medical Center

- UAMS

• The OSC Manager may assist the Shift Manager with the coordination Admin & Logistics of these groups as requested.

Security Coordinator

- Pope County Sheriff Revision 45 B-27

ARKANSAS NUCLEAR ONE EMERGENCY PLAN FIGURE B-9 MANAGEMENT INTERFACES* BETWEEN RESPONSE CENTERS AND SUPPORT RESOURCES INDUSTRIAL SUPPORT

- ENTERGY

- INPO EOF

- UTILITIES AGREEMENT - EMERG. DIRECTOR

- ADMIN/LOGISTICS COORDINATOR TECHNICAL SUPPORT CENTER CEC Manager CONSULTANT SERVICES

- EMERGENCY PLANT MANAGER - AREVA NP

- TSC STAFF - WESTINGHOUSE ELECTRIC CONTROL ROOM

- OPERATIONS STAFF OPERATIONS SUPPORT CENTER

- OSC STAFF

• AFTER INITIAL CONTACT AND APPROVAL BY THE EMERGENCY DIRECTOR, SUPPORT PERSONNEL INTERFACE DIRECTLY WITH THE MANAGER REQUESTING ASSISTANCE.

Revision 45 B-28

ARKANSAS NUCLEAR ONE EMERGENCY PLAN FIGURE B-10 WORKING LEVEL INTERFACES WITH FEDERAL, STATE, AND LOCAL AGENCIES TSC Manager Security

- Pope County Sheriffs Dept.

Emergency Plant Shift Manager/ - U.S. Coast Guard Manager OSC Manager*

Fire

- London Fire Dept.

Emergency Director Medical

- Monfee Medical Clinic

- St. Marys Regional Medical Center

- Pope County EMS

- UAMS NWS Radiological Assessment ADH Radiological Response Coordinator Team Leaders

• May assist the Shift Manager with the coordination of DOE Oak Ridge these groups, if requested. Operations Office Revision 45 B-29

ARKANSAS NUCLEAR ONE EMERGENCY PLAN FIGURE B-11 CONTROL ROOM SHIFT MANAGERS STAFF*

Shift Manager /

Emergency Director CR Communicator CR Log Keeper On-shift staffing Control Room Staff outside of Control Room

• The ANO Emergency Plan Table B-1 describes the on-shift staffing.

FIGURE B-12 JOINT INFORMATION CENTER (JIC) STAFF Company Spokesperson Technical Advisor Press Release JIC Manager Writer Information Logistics Media Liaison JIC Log Keeper Coordinator Coordinator Credentialing Inquiry Response Technical Assistant Media Monitoring Coordinator Inquiry Responders Revision 45 B-30

ARKANSAS NUCLEAR ONE EMERGENCY PLAN C EMERGENCY RESPONSE SUPPORT AND RESOURCES This section describes the arrangements for requesting and effectively using the resources of Federal, State, and local response organizations and offsite radiological analysis facilities. The mutual agreements in regard to the accommodation of State and local staffs and of ANO staff at the various response centers are also addressed.

1.0 PERSONNEL AUTHORIZED TO REQUEST AID Requests for assistance from Federal organizations are the responsibility of the individual with Emergency Direction and Control. This individual has the authority to request any assistance deemed necessary to respond to an incident at ANO.

Requests for assistance from State agencies, interfaces with State radiological field monitoring teams, and requests for assistance from offsite radiological laboratories shall be coordinated by the Radiological Assessment Coordinator. These requests are approved by the Emergency Director.

2.0 FEDERAL RESPONSE ORGANIZATIONS The Federal government maintains considerable resources that may be utilized in response to needs arising from an emergency situation at a fixed nuclear facility. Within the framework of the National Incident Management System (NIMS), the National Response Plan (NRP), and associated annexes govern the Federal Governments overall response to an incident. Interfaces between the Initial Response Staff, the Emergency Response Organization and the Federal government support organizations are shown in Figures B-3, B-8, and B-10.

The following description of Federal resources is not a complete inventory of assistance capabilities but represents those resources most likely to be involved should an incident occur at Arkansas Nuclear One.

2.1 NUCLEAR REGULATORY COMMISSION (NRC)

The role of the NRC during a radiological emergency is that of verifying that emergency plans and procedures have been implemented, assuring that the public health and safety are protected, and conducting investigative activities associated with the incident. The NRC assists in the coordination of federal response resources and provides to the licensee, state, and local agencies advisory assistance associated with assisting and mitigating hazards to the public. The NRCs actions are governed by NUREG-0728, NRC Incident Response Plan (IRP) and the NRPs Nuclear/Radiological Incident Annex, which supersedes the Federal Radiological Emergency Response Plan (FRERP). The NRC IRP uses a flexible system to tailor its response to the significance of an incident. In the different modes of the system, NRC responders activities change in order to best support the event. If necessary, personnel from the Region IV office in Texas can be at the ANO site within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> following the notification of a radiological emergency.

Notifications and continuing communications between ANO and the NRC are described in other sections of this Plan and are detailed in the Emergency Plan Implementing Procedures.

2.2 DEPARTMENT OF HOMELAND SECURITY (DHS) / FEDERAL EMERGENCY MANAGEMENT AGENCY (FEMA)

For incidents below the threshold of an Incident of National Significance, the NRC, as the Coordinating Agency, performs the federal-level functions and coordinates the overall federal response as provided in the NRPs Nuclear/Radiological Incident Annex. For incidents of National Significance, DHS is responsible for the overall coordination of federal response activities and the NRC, as the Coordinating Agency, performs the federal-level functions in concert with DHS.

DHS/FEMA, in consultation with the Coordinating Agency, coordinates the provision of the Revision 45 C-1

ARKANSAS NUCLEAR ONE EMERGENCY PLAN Resources and Assistance to affected state/local/tribal governments under the Stafford Act. In addition, DHS/FEMA maintains integrated and coordinated information regarding the status of all support activities.

2.3 DEPARTMENT OF ENERGY (DOE)

The responsibilities of other Federal departments/agencies such as DOE, Environmental Protection Agency (EPA), and U.S. Department of Agriculture (USDA), pertaining to nuclear/radiological incidents are delineated in the Nuclear/Radiological Incident Annex. For a nuclear/radiological incident in which the NRC is designated the Coordinating Agency, these departments/agencies serve as Cooperating Agencies and provide technical assistance and support to the NRC. During a radiological incident, DOE can provide trained personnel with expertise in onsite/offsite radiological monitoring.

2.3.1 Department of Energy, Oak Ridge Operations The Department of Energy (DOE) operates the Radiation Emergency Assistance Center/Training Site (REACTS) in Oak Ridge Tennessee. In conjunction with the Oak Ridge Institute for Science and Education (ORISE), REACTS maintains equipment and trained staff to evaluate and treat individuals who have excessive radioactive materials ingestion or significant overexposures to external radiation in conjunction with severe trauma. This assistance is usually only available to commercial nuclear facilities when the magnitude or uniqueness of the radiological emergency exceeds commercially available resources.

2.4 NATIONAL WEATHER SERVICE The National Weather Service operates on a twenty-four (24) hour per day basis. Upon request, this organization can provide Arkansas Nuclear One with meteorological conditions.

2.5 MEMPHIS UNIVERSITY EARTHQUAKE INFORMATION CENTER / NATIONAL EARTHQUAKE INFORMATION CENTER The Memphis University Earthquake Information Center and the National Earthquake Information Service provide, upon request, information concerning major seismic activity occurring near Arkansas Nuclear One.

2.6 U.S. COAST GUARD Upon notification, the U.S. Coast Guard controls traffic on the Arkansas River/Lake Dardanelle in the area of Arkansas Nuclear One. They provide waterborne patrols for extended periods if contamination levels persist.

2.7 U.S. ARMY CORPS OF ENGINEERS The U.S. Army Corps of Engineers assists the United States Coast Guard in controlling boat traffic on the Arkansas River should an evacuation of the area be required.

2.8 ENVIRONMENTAL PROTECTION AGENCY Upon request, the U.S. EPA provides trained manpower to assist in reviewing survey data, perform offsite evaluations and advise on protective actions for the public. They may also provide assistance in the collection and analysis of environmental samples.

Revision 45 C-2

ARKANSAS NUCLEAR ONE EMERGENCY PLAN 3.0 LIAISON WITH STATE, LOCAL AND FEDERAL RESPONSE ORGANIZATIONS During an emergency, utility, State, and Federal personnel operate from a common emergency response facility, the Emergency Operations Facility. Counterparts from ANO, the Arkansas Department of Health (ADH), the Arkansas Department of Emergency Management (ADEM), the Nuclear Regulatory Commission (NRC), the Department of Homeland Security (DHS), the Federal Emergency Management Agency (FEMA), and other agencies work side by side (collocate) in order to more efficiently respond to an emergency.

The process of collocation allows ANO's EOF Emergency Director to interface directly with ADH's Technical Operations Control Director, ADEM's Director, the NRC's Director of Site Operations and the Senior FEMA Official to more quickly formulate and issue protective action recommendations for the general public.

ANO also dispatches, upon request by the State or counties, an ANO representative to each of Pope, Yell, Logan, Johnson, and Conway County EOC's.

4.0 OFFSITE RADIOLOGICAL/ANALYTICAL ASSISTANCE Facilities for analysis of low-level offsite samples are presently available in at least one of the following locations:

Arkansas Nuclear One, Russellville, Arkansas

-Gamma Spectroscopy The Qualified Offsite Laboratory Facility

-Gamma Spectroscopy

-Low background beta counting

-Gross alpha/beta counting The Arkansas Department of Health Radiochemistry Laboratory, Little Rock, Arkansas

-Gamma Spectroscopy

-Alpha Spectroscopy

-Low background beta counting

-Gross alpha/beta counting These facilities are expected to be available during an emergency for analysis of offsite environmental samples.

5.0 EMERGENCY RESPONSE RESOURCES The following resources are either available in the local area or provided by ANO to support the response to an emergency at Arkansas Nuclear One:

a. Bill and Hillary Clinton National Airport / Adams Field located in Little Rock is the nearest airport with commercial flight service. The Russellville Airport can accommodate Falcon 10 jet traffic or its equivalent. The Russellville Airport is located approximately 8 miles from the site.

b. A laboratory for radioisotope analysis is available at Arkansas Nuclear One.

c. A boat is available to take river samples.

d. Electrical and communication access is available at the Emergency Operations Facility for the NRC's mobile analytical laboratory.

Revision 45 C-3

ARKANSAS NUCLEAR ONE EMERGENCY PLAN

e. In addition to the NRC Resident Inspector's office, the following command posts are available for NRC use:

Control Room (ENS and Commercial telephone service)

TSC (ENS, HPN, Reactor Safety Counterpart Link (RSCPL), Protective Measures Counterpart Link (PMCL), Management Counterpart Link (MCL), a LAN circuit and commercial service; additionally, offices adjacent to the TSC are available with commercial telephone service)

OSC (HPN and commercial service)

EOF (ENS, HPN, RSCPL, PMCPL, MCL, and commercial service available in the command room; additionally, an adjacent office is available with ENS, a LAN circuit and commercial service)

f. The Arkansas Department of Emergency Management located in North Little Rock, Arkansas (approximately 80 miles east of Russellville on I-40) operates a mobile communications van with a variety of communications capabilities.

Resources for FEMA have been provided by the State as indicated in Annex V of the Arkansas Comprehensive Emergency Management Plan (ARCEMP).

6.0 ADDITIONAL ASSISTANCE This section discusses the industrial support organizations that can be contacted for support services in the event of an emergency at Arkansas Nuclear One. These organizations will be kept informed of the incident as appropriate.

The initial ANO request for assistance and/or personnel from other utilities and industry is made by the EOF Admin & Logistics Coordinator. Once communications are established with these groups, their assistance is coordinated by the Emergency Plant Manager, Radiological Assessment Coordinator, or Admin & Logistics Coordinator, as appropriate.

The release of information regarding the incident to other utilities and to utility groups is coordinated via the Corporate Emergency Center (CEC). All requests for information from these groups are directed to the CEC. Releases are approved by the Emergency Director before being distributed.

The release of information regarding the incident within Entergy Operations and Entergy Arkansas, Inc. is coordinated by the JIC Manager. The JIC Manager or designee provides updates to Entergy Operations and Entergy Arkansas, Inc. employees through Inside Entergy and the Customer Services Department.

6.1 UTILITIES/INDUSTRY GROUPS 6.1.1 Entergy Corporation Entergy Operations notifies Entergy Corporation of emergencies at ANO. Periodic status updates are also provided throughout the emergency. Provisions have been established to notify Entergy Corporation on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day basis.

Assistance may be requested in accordance with the Corporate Emergency Response Plan.

Support is available from Entergy Corporation in the areas of communications, risk management, nuclear engineering, quality assurance, power engineering, system fuels, information systems, governmental affairs and finance.

Revision 45 C-4

ARKANSAS NUCLEAR ONE EMERGENCY PLAN 6.1.2 Institute of Nuclear Power Operations ANO participates in the activities of the Institute of Nuclear Power Operations (INPO) and is a beneficiary of INPO's emergency services. The support that INPO is prepared to provide includes: (1) assistance in locating technical expertise; (2) assistance in obtaining industry experience relating to plant components or systems; and (3) facilitation of the flow of technical information from the affected utility to the nuclear industry. ANO provides accommodations at the EOF for a representative from INPO who serves as a liaison to our Emergency Response Organization during a Site Area or General Emergency.

ANO notifies INPO of Alert or higher emergency declarations at ANO. Provisions have been established to notify INPO on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day basis. Periodic status updates are also provided throughout the emergency. INPO's estimated response time is within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Details on the specific support available from INPO and information on how to request support are described in the INPO Emergency Resources Manual.

6.1.3 Miscellaneous Industry Groups Information is made available to industry groups such as the Institute of Nuclear Power Operations (INPO), Electric Power Research Institute (EPRI), and the Nuclear Energy Institute (NEI). The JIC Manager is responsible for ensuring that information is provided to these groups.

6.2 CONTRACTORS Entergy Operations has various engineering service contracts with the nuclear steam supply system suppliers, architect-engineers, and several consultants for both routine and emergency services. The organizational structure and communications arrangements for such services presently exist to assure that these services can be obtained in a timely manner.

Requests for contractor assistance by the Emergency Plant Manager, the Radiological Assessment Coordinator or the JIC Manager are coordinated through the Admin & Logistics Coordinator or his designee. Coordination of contractor assistance is performed at the level in the Emergency Response Organization to which the support is provided. Personnel requests from contractors are coordinated with the Admin & Logistics Coordinator or his designee.

Revision 45 C-5

ARKANSAS NUCLEAR ONE EMERGENCY PLAN D EMERGENCY CLASSIFICATION SYSTEM 1.0 CLASSIFICATION SYSTEM BACKGROUND ANO maintains 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. Additionally, personnel are trained to promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level.

For the purposes of classifying emergencies, ANO and the State of Arkansas utilize a method outlined in NEI 99-01, in which emergencies are grouped into a four-level response scheme. This approach to classification has been expanded and detailed to encompass the entire spectrum of possible emergency situations that may arise at ANO. Each of the four classifications is associated with a particular set of immediate actions to be taken. The ANO Emergency Action Levels are reviewed with State and County authorities on an annual basis.

The spectrum of possible emergency situations at Arkansas Nuclear One is categorized into the following Emergency Classes:

a. Notification of Unusual Event

b. Alert

c. Site Area Emergency

d. General Emergency The severity of the Emergency Classes increases in the order as they are listed above from a Notification of Unusual Event to a General Emergency. Each classification is characterized by Initiating Conditions (ICs). ICs consist of plant conditions and specific plant parameters (i.e.,

instrument readings and system status indications, etc.) that are used to denote the emergency classification and require the implementation of emergency measures, such as notifications and mobilization of resources. Since the severity of the emergency situation may change with time, an emergency situation may be reclassified from one Emergency Class to another. After the initial declaration of an Emergency Class, the individual responsible for Emergency Direction and Control performs a continuing assessment of the situation to determine whether the Emergency Class must be upgraded. Emergency Class ICs and associated Emergency Action Levels (EALs) that apply to both Unit 1 and Unit 2, are listed in OP-1903.010, Emergency Action Level Classification.

The rationale for the Notification of Unusual Event and Alert classes is to provide early and prompt notification of minor events which could lead to more serious consequences given operator error or equipment failure or which might be indicative of more serious conditions which are not yet fully realized. The Site Area Emergency Class reflects conditions where some significant releases are likely or are occurring, but where a core melt situation is not indicated based on current information. In this situation full mobilization of emergency personnel in the near site environs is indicated as well as dispatch of monitoring teams and associated communications. The General Emergency class involves actual or imminent substantial core degradation or melting with the potential for loss of containment integrity.

Revision 45 D-1

ARKANSAS NUCLEAR ONE EMERGENCY PLAN 2.0 NOTIFICATION OF UNUSUAL EVENT Events are in progress 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 offsite response or monitoring are expected unless further degradation of safety systems occurs.

3.0 ALERT 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 EPA Protective Action Guideline (PAG) exposure levels.

4.0 SITE AREA EMERGENCY Events are in progress or have occurred which involve actual or likely major failures 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 PAG exposure levels beyond the site boundary.

5.0 GENERAL EMERGENCY Events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with 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 PAG exposure levels off-site for more than the immediate site area.

6.0 EMERGENCY CLASS CRITERIA Table D-1 provides a summary of EAL Categories used to determine the Emergency Class.

OP-1903.010 Emergency Action Level Classification provides details on initiating conditions. It is noted that most of the listed initiating conditions for the Notification of Unusual Event class are events that can be expected to be terminated quickly, and therefore, the notification process may occur after the event has already been corrected.

The examples of initiating conditions found under the various emergency classifications are intended as general guidelines. Examples represent the types of conditions that may be evaluated to determine the extent of emergency response initiated by the plant operating staff.

However, whether the event is a Notification of Unusual Event, an Alert, a Site Area Emergency, or a General Emergency; there are many variables involved in going from plant instrument readings of a pre-accident situation to significant exposures to the public. Such readings may usefully serve as conservative criteria for determining when to mobilize various emergency organizations, but final decisions to notify and alert the public by the early warning siren system are the decisions of governmental officials.

Revision 45 D-2

ARKANSAS NUCLEAR ONE EMERGENCY PLAN In utilizing the emergency class criteria as the basis for initiating emergency response activity there may be instances when the plant operating staff cannot determine quickly which of two emergency classes is appropriate for a particular occurrence. In those cases, the occurrence should be treated as the higher of the emergency classes and the appropriate response for that class should be initiated.

7.0 DESIGN BASIS ACCIDENT EMERGENCY CLASSES A broad range of possible off-normal and accident conditions has been postulated and taken into consideration in deriving response actions to occur at the ANO site. These include radiological and non-radiological events that range from minor occurrences, which may be anticipated during the life of the plant, to highly improbable events, which could affect members of the general public.

Chapter 14 and 15 of the Unit 1 and Unit 2 Safety Analysis Report (SAR) contains a summary of the events that have been postulated for the site.

7.1 CLASSIFICATION OF POSTULATED ACCIDENTS The events postulated in SAR may be categorized by one of the four emergency classifications.

In many cases, the classification assigned initially may undergo escalation to the next higher classification depending on the severity of the accident. A complete discussion of these events may be found in the SAR.

The operating shift personnel under the direction of the Manager, Shift Ops perform the initial assessment and classification of potential in-plant and offsite consequences. These assessment times should last no longer than 15 minutes. The shift personnel then activate the Onsite Emergency Organization in accordance with the level of emergency response required, thereby providing additional manpower as the emergency evolves.

A list of all radiological-related design basis accidents, addressed in Chapters 14 and 15, respectively, of the Unit 1 and Unit 2 Safety Analysis Reports is provided in Tables D-3 and D-4.

Revision 45 D-3

ARKANSAS NUCLEAR ONE EMERGENCY PLAN TABLE D-1

SUMMARY

OF EAL CATEGORIES OP-1903.010, Emergency Action Level Classification, is an Emergency Action Level Basis Document and is considered part of the Emergency Plan.

OP-1903.010, Emergency Action Level Classification, provides an explanation and rationale for each Emergency Action Level (EAL). OP-1903.010 contains EAL technical bases for each EAL according to EAL group (Any, Hot, Cold), EAL category (A, C, E, F, H and S) and EAL subcategory. For each EAL the following information is provided - Category Letter/Title; Subcategory Letter/Title; Initiating condition; EAL Identifier; Classification; EAL; Mode Applicability; Definitions; Basis and References.

Further detail on Emergency Action Levels and Initiating Conditions is found in OP-1903.010, Emergency Action Level Classification.

Category A - Abnormal Radiation Levels/Radiological Effluents EAL Group: ANY (EALS in this category are applicable to any plant condition)

Many EALs are based on actual or potential degradation of fission product barriers because of the elevated potential for offsite radioactivity release. Degradation of fission product barriers though is not always apparent via non-radiological symptoms. Therefore, direct indication of elevated radiological effluents or area radiation levels are appropriate symptoms for emergency classification.

At lower levels, abnormal radioactivity releases can be indicative of a failure of containment systems or precursors to more significant releases. At higher release rates, offsite radiological conditions can result which require offsite protective actions. Elevated area radiation levels in plant can also be indicative of the failure of containment systems or preclude access to plant vital equipment necessary to ensure plant safety.

Events of this category pertain to the following subcategories:

Radiological Effluent - Direct indication of effluent radiation monitoring systems provides a rapid assessment mechanism to determine releases in excess of classifiable limits.

Projected offsite doses, actual offsite field measurements or measured release rates via sampling indicate doses or dose rates above classifiable limits.

Irradiated Fuel Event - Conditions indicative of a loss of adequate shielding or damage to irradiated fuel can preclude access to vital plant areas or result in radiological releases that warrant emergency classification.

Area Radiation Levels - Sustained general area radiation levels which can preclude access to areas requiring continuous occupancy also warrant emergency classification.

Revision 45 D-4

ARKANSAS NUCLEAR ONE EMERGENCY PLAN TABLE D-1 (continued)

SUMMARY

OF EAL CATEGORIES CATEGORY C - Cold Shutdown/Refueling System Malfunction EAL Group: Cold Conditions (RCS temperature less than or equal to 200 °F); EALs in this category are applicable only in one or more cold operating modes Category C EALs are directly associated with cold shutdown or refueling system safety functions.

Given the variability of plant configurations (e.g., systems out-of-service for maintenance, containment open, reduced AC power redundancy, time since shutdown) during these periods, the consequences of any given initiating event can vary greatly. For example, a loss of decay heat removal capability that occurs at the end of an extended outage has less significance than a similar loss occurring during the first week after shutdown. Compounding these events is the likelihood that instrumentation necessary for assessment might also be inoperable. The cold shutdown and refueling system malfunction EALs are based on performance capability to the extent possible with consideration given to RCS integrity, CONTAINMENT CLOSURE and fuel clad integrity for the applicable operating modes (5 - Cold Shutdown, 6 - Refueling, DEF -

Defueled).

Events of this category pertain to the following subcategories:

RCS Level - RCS water level is directly related to the status of adequate core cooling and, therefore, fuel clad integrity.

Loss of Vital AC Power - Loss of vital plant electrical power can compromise plant SAFETY SYSTEM operability including decay heat removal and emergency core cooling systems which can be necessary to ensure fission product barrier integrity. This category includes loss of onsite and offsite power sources for 4.16 KV vital buses.

RCS Temperature - Uncontrolled or inadvertent temperature or pressure rises are indicative of a potential loss of safety functions.

Loss of Vital DC Power - Loss of emergency plant electrical power can compromise plant SAFETY SYSTEM operability including decay heat removal and emergency core cooling systems which can be necessary to ensure fission product barrier integrity. This category includes loss of power to or degraded voltage on the 125V DC vital buses.

Loss of Communications - Certain events that degrade plant operator ability to effectively communicate with essential personnel within or external to the plant warrant emergency classification.

Hazardous Event Affecting Safety Systems - Certain hazardous natural and technological events can result in VISIBLE DAMAGE to or degraded performance of safety systems warranting classification.

Revision 45 D-5

ARKANSAS NUCLEAR ONE EMERGENCY PLAN TABLE D-1 (continued)

SUMMARY

OF EAL CATEGORIES CATEGORY E - Independent Spent Fuel Storage installation (ISFSI) Malfunction EAL Group: ANY (EALS in this category are applicable to any plant condition)

An ISFSI is a complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage. A significant amount of the radioactive material contained within a canister must escape its packaging and enter the biosphere for there to be a significant environmental effect resulting from an accident involving the dry storage of spent nuclear fuel.

An Unusual Event is declared on the basis of the occurrence of an event of sufficient magnitude that a loaded cask CONFINEMENT BOUNDARY is damaged or violated.

The ANO ISFSI is located wholly within the plant PROTECTED AREA. Therefore, any security event related to the ISFSI is classified under Category H1 security event related EALs.

CATEGORY F - Fission Product Barrier Degradation EAL Group: Hot Conditions (RCS temperature > 200 °F); EALs in this category are applicable only in one or more hot operating modes EALs in this category represent threats to the defense in depth design concept that precludes the release of highly radioactive fission products to the environment. This concept relies on multiple physical barriers any one of which, if maintained intact, precludes the release of significant amounts of radioactive fission products to the environment. The primary fission product barriers are:

Fuel Clad Barrier (FCB): The Fuel Clad Barrier consists of the cladding material that contains the fuel pellets.

Reactor Coolant System Barrier (RCB): The RCS Barrier includes the RCS primary side and its connections up to and including the pressurizer safety and relief valves, and other connections up to and including the primary isolation valves.

Containment Barrier (CNB): The Containment Barrier includes the Reactor Building and connections up to and including the outermost containment isolation valves. This barrier also includes the main steam, feedwater, and blowdown line extensions outside the Reactor Building up to and including the outermost secondary side isolation valve.

Containment Barrier thresholds are used as criteria for escalation of the Emergency Classification Level (ECL) from an Alert to a Site Area Emergency or a General Emergency.

Revision 45 D-6

ARKANSAS NUCLEAR ONE EMERGENCY PLAN TABLE D-1 (continued)

SUMMARY

OF EAL CATEGORIES CATEGORY F - Fission Product Barrier Degradation (continued)

The EALs in this category require evaluation of the loss and potential loss thresholds listed in the fission product barrier matrix of Table F-1. Loss and Potential Loss signify the relative damage and threat of damage to the barrier. Loss means the barrier no longer assures containment of radioactive materials. Potential Loss means integrity of the barrier is threatened and could be lost if conditions continue to degrade. The number of barriers that are lost or potentially lost and the following criteria determine the appropriate emergency classification level:

Alert - Any loss or any potential loss of either Fuel Clad or RCS Barrier Site Area Emergency - Loss or potential loss of any two barriers General Emergency - Loss of any two barriers and loss or potential loss of third barrier The logic used for emergency classification based on fission product barrier monitoring should reflect the following considerations:

The Fuel Clad Barrier and the RCS Barrier are weighted more heavily than the Containment Barrier.

Unusual Event ICs associated with RCS and Fuel Clad Barriers are addressed under System Malfunction ICs.

For accident conditions involving a radiological release, evaluation of the FISSION PRODUCT BARRIER THRESHOLDS is performed in conjunction with dose assessments to ensure correct and timely escalation of the emergency classification. For example, an evaluation of the FISSION PRODUCT BARRIER THRESHOLDS might result in a Site Area Emergency classification while a dose assessment might indicate that an EAL for General Emergency IC AG1 has been exceeded.

The FISSION PRODUCT BARRIER THRESHOLDS specified within a scheme reflect plant-specific ANO design and operating characteristics.

As used in this category, the term RCS leakage encompasses not just those types defined in Technical Specifications but also includes the loss of RCS mass to any location--inside the containment, an interfacing system, or outside of the containment. The release of liquid or steam mass from the RCS due to the as-designed/expected operation of a relief valve is not considered to be RCS leakage.

At the Site Area Emergency level, maintaining cognizance of how far present conditions are from meeting a threshold that would require a General Emergency declaration is vital for EAL users. For example, if a loss of both Fuel Clad and RCS fission product barriers exists, frequent assessments of containment radioactive inventory and integrity are necessary. Alternatively, if a potential loss of both the Fuel Clad and RCS fission product barriers exists, the Emergency Director has more assurance that there was no immediate need to escalate to a General Emergency.

Revision 45 D-7

ARKANSAS NUCLEAR ONE EMERGENCY PLAN TABLE D-1 (continued)

SUMMARY

OF EAL CATEGORIES CATEGORY H - Hazards and Other Conditions Affecting Plant Safety EAL Group: ANY (EALs in this category are applicable to any plant condition, hot or cold)

Hazards are non-plant, system-related events that can directly or indirectly affect plant operation, reactor plant safety or personnel safety.

Security: Unauthorized entry attempts into the PROTECTED AREA, bomb threats, sabotage attempts, and actual security compromises threatening loss of physical control of the plant.

Seismic event: Natural events such as earthquakes have potential to cause plant structure or equipment damage of sufficient magnitude to threaten personnel or plant safety.

Natural or technological hazard: Other natural and non-naturally occurring events that can cause damage to plant facilities include tornados, FLOODING, hazardous material releases and events restricting site access warranting classification.

Fire: FIRES can pose significant hazards to personnel and reactor safety. Appropriate for classification are FIRES within the plant PROTECTED AREA or which can affect operability of equipment needed for safe shutdown.

Hazardous gas: Toxic, corrosive, asphyxiant or flammable gas leaks can affect normal plant operations or preclude access to plant areas required to safely shutdown the plant.

Control Room evacuation: If the Control Room is evacuated, additional support for monitoring and controlling plant functions is necessary through the emergency response facilities.

Emergency Director judgment: The EALs defined in other categories specify the pre-determined symptoms or events that are indicative of emergency or potential emergency conditions and thus warrant classification. While these EALs have been developed to address the full spectrum of possible emergency conditions which can warrant classification and subsequent implementation of the Emergency Plan, a provision for classification of emergencies based on operator/management experience and judgment is still necessary. The EALs of this category provide the Emergency Director the latitude to classify emergency conditions consistent with the established classification criteria based upon Emergency Director judgment.

Revision 45 D-8

ARKANSAS NUCLEAR ONE EMERGENCY PLAN TABLE D-1 (continued)

SUMMARY

OF EAL CATEGORIES CATEGORY S - System Malfunction EAL Group: Hot Conditions (RCS temperature greater than 200 °F); EALs in this category are applicable only in one or more hot operating modes Numerous system-related equipment failure events that warrant emergency classification have been identified in this category. They can pose actual or potential threats to plant safety.

Loss of Vital AC Power: Loss of vital electrical power can compromise plant safety system operability including decay heat removal and emergency core cooling systems which may be necessary to ensure fission product barrier integrity. This category includes loss of onsite and offsite sources for vital 4.16 KV buses.

Loss of Vital DC Power: Loss of emergency electrical power can compromise plant safety system operability including decay heat removal and emergency core cooling systems which may be necessary to ensure fission product barrier integrity. This category includes loss of vital plant 125V DC power sources.

Loss of Control Room Indications: Certain events that degrade plant operator ability to effectively assess plant conditions within the plant warrant emergency classification.

Losses of indicators are in this subcategory.

RCS Activity: During normal operation, reactor coolant fission product activity is very low.

Small concentrations of fission products in the coolant are primarily from the fission of tramp uranium in the fuel clad or minor perforations in the clad itself. Any significant rise from these base-line levels (2% - 5% clad failures) is indicative of fuel failures and is covered under the Fission Product Barrier Degradation category. However, lesser amounts of clad damage may result in coolant activity exceeding Technical Specification limits. These fission products will be circulated with the reactor coolant and can be detected by coolant sampling.

RCS Leakage: The reactor vessel provides a volume for the coolant that covers the reactor core. The reactor pressure vessel and associated pressure piping (reactor coolant system) together provide a barrier to limit the release of radioactive material should the reactor fuel clad integrity fail. Excessive RCS leakage greater than Technical Specification limits indicates potential pipe cracks that may propagate to an extent threatening fuel clad, RCS and containment integrity.

RPS Failure: This subcategory includes events related to failure of the Reactor Protection System (RPS) to initiate and complete reactor trips. In the plant licensing basis, postulated failures of the RPS to complete a reactor trip comprise a specific set of analyzed events referred to as Anticipated Transient Without Scram (ATWS) events. For EAL classification, however, ATWS is intended to mean any trip failure event that does not achieve reactor shutdown. If RPS actuation fails to assure reactor shutdown, positive control of reactivity is at risk and could cause a threat to fuel clad, RCS and containment integrity.

Loss of Communications: Certain events that degrade plant operator ability to effectively communicate with essential personnel within or external to the plant warrant emergency classification.

Revision 45 D-9

ARKANSAS NUCLEAR ONE EMERGENCY PLAN TABLE D-1 (continued)

SUMMARY

OF EAL CATEGORIES CATEGORY S - System Malfunction (continued)

Containment Failure: Failure of containment isolation capability (under conditions in which the containment is not currently challenged) warrants emergency classification. Failure of containment pressure control capability also warrants emergency classification.

Hazardous Event Affecting Safety Systems: Various natural and technological events that result in degraded plant safety system performance or significant VISIBLE DAMAGE warrant emergency classification under this subcategory.

Revision 45 D-10

ARKANSAS NUCLEAR ONE EMERGENCY PLAN TABLE D-3 CORRELATION OF DESIGN BASIS ACCIDENTS TO EMERGENCY CLASSES ARKANSAS NUCLEAR ONE UNIT 1 The following table lists the design basis accidents discussed in the Final Safety Analysis Reports.

DESIGN BASIS ACCIDENT Uncompensated operation reactivity changes Startup accident Rod withdrawal accident at rated power operation Moderator dilution accident Cold water accident Loss of coolant flow Stuck-out, stuck-in, or dropped control rod accident Loss of electric power (loss of load)

Complete loss of all Unit AC power Turbine overspeed Fuel loading errors Steam line failure Steam generator tube failure Fuel handling accident Rod ejection accident Loss of coolant accident Core flood line break Maximum hypothetical accident Waste gas tank rupture Uncontrolled CEA withdrawal from a subcritical condition Uncontrolled CEA withdrawal from critical conditions Revision 45 D-11

ARKANSAS NUCLEAR ONE EMERGENCY PLAN TABLE D-4 CORRELATION OF DESIGN BASIS ACCIDENTS TO EMERGENCY CLASSES ARKANSAS NUCLEAR ONE UNIT 2 The following table lists the design basis accidents discussed in the Final Safety Analysis Reports.

DESIGN BASIS ACCIDENT CEA misoperation Uncontrolled boron dilution incident Total and partial loss of reactor coolant forced flow Idle loop startup Loss of external load and/or turbine trip Loss of normal feedwater flow Loss of all normal preferred A-C power to the station auxiliaries Excess heat removal due to secondary system malfunction Failure of the regulating instrumentation Internal and external events including major and minor fire, floods, storms and earthquakes Major rupture of pipes containing reactor coolant up to and including double-ended rupture of largest pipe in the reactor coolant system (loss of coolant accident)

Major secondary system pipe breaks with or without a concurrent loss of A-C power Inadvertent loading of a fuel assembly into the improper position Waste gas decay tank leakage or rupture Failure of air ejector lines (BWR)

Steam generator tube rupture with or without a concurrent loss of A-C power Failure of charcoal or cryogenic system (BWR)

Control element assembly ejection The spectrum of rod drop accidents (BWR)

Break in instrument line or other lines from reactor coolant pressure boundary that penetrate containment Revision 45 D-12

ARKANSAS NUCLEAR ONE EMERGENCY PLAN TABLE D-4 (continued)

DESIGN BASIS ACCIDENT Fuel handling accident Small spills or leaks of radioactive material outside containment Fuel cladding failure combined with steam generator leak Control Room uninhabitability Failure or overpressurization of low-pressure residual heat removal system Loss of condenser vacuum Turbine trip with coincident failure of turbine bypass valves to open Loss of service water system Loss of one D-C system Turbine trip with failure of generator breaker to open Loss of instrument air system Malfunction of turbine gland sealing system Revision 45 D-13

ARKANSAS NUCLEAR ONE EMERGENCY PLAN E NOTIFICATION METHODS AND PROCEDURES This section describes those methods which have been established for notification, by Entergy Operations, of State and local response organizations and for notification of the emergency personnel of all response organizations. The content of initial and follow-up messages to response organizations and the public are discussed. The means to provide early notification and clear instruction to the public within the affected areas are outlined. More information on notification methods is provided by the Emergency Plan Implementing Procedures.

1.0 NOTIFICATION Entergy Operations has established communications links among the ANO emergency response centers and between the ANO centers and Federal, State, and local emergency response organizations. The notification of response organizations is based on the response criteria developed for each emergency class as discussed in Section D, subsection 6.0. Detailed information on the ERO personnel contacted for each Emergency Class is provided in Emergency Plan Implementing Procedures. Table F-1 shows the various communication links and the redundant communication equipment available to assure that communication channels are maintained. A description of the communications equipment is provided in Section H.2.

Initial notification is made to the State and local authorities within fifteen (15) minutes after declaring an emergency. Verification methods are used to authenticate messages to the State.

The NRC is notified immediately following notification of State and local authorities and within one (1) hour of the declared emergency.

The Shift Manager and the Operations staff monitor the Control Room instruments and alarms for any changes in the plant conditions. Upon noticing any unusual or abnormal change, the Shift Manager determines if the change or event corresponds to one of the Emergency Class categories as defined by Table D-1. If the event or change corresponds to one of the Emergency Classes he takes further actions as described below. Abnormal events or changes at the power plant are brought to the attention of the Shift Manager of the affected unit by the plant personnel.

Situations not unique to a specific unit are brought to the attention of either unit's Shift Manager.

1.1 NOTIFICATION OF UNUSUAL EVENT For a Notification of Unusual Event, the Shift Manager/ED initiates notifications in accordance with Emergency Plan Implementing Procedures. In general, notifications include the Emergency Plant Manager, EOF Emergency Director, NRC, ADH, ADEM, local authorities, and site support personnel, as needed. Additional emergency response personnel are then contacted, as needed. The purpose of this Emergency Class is to provide current information on abnormal events to State and Federal governmental agencies and to test the communications links with offsite groups.

If the incident involves a fire, security, a radiological or medical emergency, the Fire Brigade, appropriate emergency response teams/groups, and local support services are notified in accordance with Emergency Plan Implementing Procedures. These local support services may include the Local Fire Department, the Pope County Sheriff, the Pope County Emergency Medical Service, the Saint Marys Regional Medical Center, University of Arkansas for Medical Sciences Hospital, and Monfee Medical Clinic. These local support services activate other local services in their individual areas of support if additional support is required.

Revision 45 E-1

ARKANSAS NUCLEAR ONE EMERGENCY PLAN 1.2 ALERT For an Alert, the individual with Emergency Direction and Control immediately initiates notifications in accordance with Emergency Plan Implementing Procedures. In general, notifications include the Emergency Response Organization, NRC, ADH, ADEM, local authorities, and plant emergency response team/group leaders. Additional emergency response personnel are then contacted as needed and may be directed to remain in an alert status. Personnel are dispatched to make the emergency response centers ready should the situation become more serious.

The primary purpose of this Emergency Class is to provide early and prompt notification of minor events which could lead to more serious consequences given operator error or equipment failure or which might be indicative of more serious conditions which are not yet fully realized. If a fire, security, radiological, or medical emergency is involved; appropriate emergency response teams and local support services report to the plant as required.

The ADH may activate the State Emergency Operations Facility (located in the ANO EOF) and dispatch the State Radiological Response Team to the site to perform radiological monitoring.

1.3 SITE AREA EMERGENCY For a Site Area Emergency the individual with Emergency Direction and Control immediately initiates notifications in accordance with Emergency Plan Implementing Procedures. In general, notifications include the Emergency Response Organization, NRC, ADH, ADEM, local authorities, and plant emergency response team/group leaders. Personnel are dispatched to make the emergency response centers ready. This Emergency Class reflects conditions where full mobilization of emergency personnel in the near site environs is indicated as well as the dispatch of monitoring teams and associated communications. Members of the Emergency Response Organization report to Arkansas Nuclear One and other response centers to take appropriate corrective and recovery actions.

The ADH may activate the Early Warning System within the 10-mile Emergency Planning Zone.

The ADH activates State Emergency Operations Facility (located in the ANO EOF) and dispatches the Radiological Response Team to the site to perform radiological monitoring and environmental impact assessment. The ADEM also activates its Emergency Operations Center upon notification and provides a Mobile Support Unit to the State Emergency Operations Center at North Little Rock.

1.4 GENERAL EMERGENCY For a General Emergency the individual with Emergency Direction and Control immediately initiates notifications in accordance with Emergency Plan Implementing Procedures. In general, notifications include the Emergency Response Organization, NRC, ADH, ADEM, local authorities, and plant emergency response team/group leaders. The entire Emergency Response Organization is activated. Personnel are dispatched to make the emergency response centers ready. This Emergency Class reflects conditions requiring immediate implementation of appropriate predetermined protective actions. Members of the Emergency Response Organization report to Arkansas Nuclear One and other response centers.

Revision 45 E-2

ARKANSAS NUCLEAR ONE EMERGENCY PLAN The ADH also activates the Early Warning System within the 10-mile Emergency Planning Zone.

The ADH activates its State Emergency Operations Facility (located in the ANO EOF) and dispatches the Radiological Response Team to the site to perform radiological monitoring and environmental impact assessment. The ADEM also activates its Emergency Operations Center upon notification and provides a Mobile Support Unit to the State Emergency Operations Center at North Little Rock.

2.0 EMERGENCY MESSAGES The forms for messages sent from Arkansas Nuclear One to offsite agencies are included in ANO implementing procedures for the Arkansas Comprehensive Emergency Management Plan (ARCEMP), Annex V. These forms are utilized for both initial and follow-up messages. In general the message forms allow information pertinent to the Emergency Classes to be supplied to the off-site authorities in a consistent manner. Information provided to offsite response centers via these forms include: the class of the emergency; details of the onsite situation; radiological release data including meteorological parameters for making dose projections and determining affected populations; and recommendations of offsite protective actions.

3.0 EARLY WARNING SYSTEM The Early Warning System for the 10-mile radius Emergency Planning Zone (EPZ) around Arkansas Nuclear One consists of a mixture of sirens and National Oceanic and Atmospheric Administration (NOAA) Weather Radios. The system is essentially designed to notify the individuals in the 10-mile EPZ within 15 minutes of the issuance of recommendations by the State of Arkansas for radiological emergencies at Arkansas Nuclear One.

Sirens are used to alert the more densely populated areas shown on Figure E-1. The siren system is divided into five zones: Russellville, London, Dardanelle, Johnson County, and Logan County.

Each of these zones can be activated independently or in conjunction with each other. The locations of the sirens were determined by field studies conducted by the siren manufacturer taking into account ambient noise measurements, terrain and rural and suburban areas. This system was designed considering the Federal Emergency Management Agency's Outdoor Warning Systems Guide (CPG-17) and the Nuclear Regulatory Commission's guidance presented in NUREG-0654. Tests of the Early Warning System are conducted by the ADH.

The siren system is activated by radio signal. The primary activation point for the siren system is the ADH office in Little Rock, Arkansas. This office is manned 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day to accommodate day or night activation. The secondary activation points for the siren system are located in the State Emergency Operations Facility at the ANO EOF and the Nuclear Planning and Response Program office.

The public is instructed to tune to local radio stations for emergency instructions when the sirens are activated. Local radio stations have the capability to broadcast emergency messages on a 24-hour basis to the general public.

Revision 45 E-3

ARKANSAS NUCLEAR ONE EMERGENCY PLAN For those residents of the 10-mile EPZ who live outside the siren coverage area, NOAA Weather Radios are made available. Additionally, these receivers are made available to the rural population, large businesses, hospitals, schools, and other applicable groups, within the 10-mile EPZ.

The NOAA radio program is administered by the Arkansas Department of Health's Nuclear Planning and Response Program staff and operated by the National Weather Service. The NP&RP staff issues radios to new residents in the 10 mile EPZ. Recipients of NOAA radios are tracked on a master list by the NP&RP staff and needed repair and/or replacement of NOAA radios identified as defective is also carried out by the NP&RP staff.

The National Weather Service is a 300-watt station, with a 300-watt backup transmitter, which broadcasts 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day to the 10-mile EPZ. Entergy Operations has provided backup generator capability for the transmitter site. A summary of the NWS agreement with Entergy Operations to cooperate as a part of the Early Warning System can be found in Appendix 1 of this Plan.

The NWS is contacted by the ADH staff and informed of the intent to activate the Early Warning System. The NWS is notified in advance of the sirens being activated such that, in conjunction with the siren activation, the NWS activates the NOAA tone which automatically turns the receivers on. A loud tone is activated on the radio to alert the user. Following activation of the receivers, live or pre-recorded emergency messages are broadcast to instruct the public.

Supplemental notification to the EPZ population is provided by local fire departments in the EPZ.

Also, in the event of siren or NOAA radio system failures, route alerting is provided by local fire departments in the EPZ.

Special provisions have been developed by the Nuclear Planning and Response Program and Entergy Operations for the alerting of identified handicapped individuals. These individuals, depending upon their handicap, are notified appropriately.

Activation of the system for emergencies not related to an incident at Arkansas Nuclear One is upon local government request.

4.0 PUBLIC WARNING MESSAGES The State of Arkansas has formulated messages which instruct the public with regard to specific protective actions to be taken by occupants of affected areas in the event of an incident at Arkansas Nuclear One. The messages are provided in Appendix 6 of this Plan and in attachments to the Arkansas Emergency Operations Plan, Annex V. ANO has established notification methods and provides information as discussed in Section E, subsection 2.0, which allows officials of the State of Arkansas to make decisions on the appropriate public warning messages which are broadcast via the local broadcast stations. The ANO staff reviews revisions and provides comments on the formulation of emergency messages, as necessary, so that the ANO Emergency Plan and Implementing Procedures remain consistent with the needs of the State of Arkansas in regard to public warning messages.

Revision 45 E-4

ARKANSAS NUCLEAR ONE EMERGENCY PLAN FIGURE E-1 Predicted Siren Coverage N

10 Mile Radius W E S

JOHNSON CO Augsburg 359 27 333 2z16 60 40 POPE CO 60 Dover 4z2 5 Mile Radius 164 70 Knoxville 64 70 333 2z17 60 3z8 70 60 4z1 60 2z18 3z7 2z15 40 70 3z5 3z9 Lake Dardanelle 3z6 2z20 70 3z1 3z10 7 60 River 3z4 2z14 Mountain 3z2 London 124 2z21 2z22 5z2 3z3 2z12 2z13 2z23 60 Dover Mountain 2z11 64 70 5z3 5z1 2z9 2z25 Delaware Lake 2z10 2z1 Dardanelle 2z24 326 2z8 70 22 70 2z4 70 1z9 LOGAN CO RUSSELLVILLE 2z7 2z2 60 2z3 40 1z10 60 1z7 YELL CO 64 Mount Nebo 1z11 State Park 60 1z6 2z6 1z8 155 DARDANELLE 1z1 70 247 1z3 27 1z4 Sulpher Springs 70 7 60 1z5 1z2 28 70 60 Arkansas Nuclear One ANS 2011 Legend 10 Mile Radius Plant 0 1 2 4 6 8 10 Miles dBC Contours ATIHPSS32DR Kilometers 0 2 4 8 12 16 WS2800-7 Revision 45 E-5

ARKANSAS NUCLEAR ONE EMERGENCY PLAN F EMERGENCY COMMUNICATIONS 1.0 NOTIFICATION AND ACTIVATION OF STATE, LOCAL, AND SITE EMERGENCY RESPONSE NETWORKS Figure F-1 of this Plan illustrates the methods used to notify the State, local, and site emergency response organizations. This process is initiated by the Shift Manager who is responsible for making the calls as shown on Figure F-1 in accordance with Emergency Plan Implementing Procedures. The Shift Manager is required to be present for each shift, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day.

Therefore, notification of organizations can be accomplished at any given time as required.

The ADH maintains a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day communications center which is utilized to receive emergency notification from the site and activate State, local, and Federal response organizations, as necessary. The Arkansas Department of Emergency Management (ADEM) and the County Warning Points can also be contacted 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day. The ADH communications center and the Pope County Sheriff Department can be contacted by telephone or radio from the Control Room, TSC, and EOF. ADEM can also be contacted via radio using the Arkansas Wireless Information Network (AWIN) radio channel, as needed. The AWIN radio channel is available for use from the Control Rooms, the OSC, and the EOF. If normal communication systems are not accessible, use of the AWIN radio channel allows ANO to forward information to ADEM via AWIN, which can then be forwarded to ADH and the County Warning Points.

2.0 COMMUNICATIONS 2.1 COMMUNICATIONS WITH FEDERAL, STATE, AND LOCAL AGENCIES Table F-1 illustrates the communication interface between the EOF and State and local response centers and the communications equipment available. Section H of this Plan outlines the communications hardware that is available for communications from ANO emergency response centers to State and local agencies within the emergency planning zone. The Emergency Plan Implementing Procedures provide information on the periodic testing of the equipment. During an emergency, communication links are maintained on a 24-hour basis.

2.2 ONSITE COMMUNICATIONS Two-way radios are provided for communications between onsite facilities and the radiological monitoring teams.

2.3 COMMUNICATIONS BETWEEN THE SITE AND MEDICAL FACILITIES Communications with offsite medical facilities are made by telephone. If telephone service is not available, information may be relayed via radio communication with the Arkansas Department of Emergency Management. Radio communications between Pope County Emergency Medical Service and the Saint Marys Regional Medical Center are available via a private radio frequency.

This system uses a repeater on Mt. Nebo to provide a 30 to 40-mile radius coverage.

Revision 45 F-1

ARKANSAS NUCLEAR ONE EMERGENCY PLAN 2.4 COMMUNICATIONS BETWEEN ENTERGY OPERATIONS AND OTHER ORGANIZATIONS Figure F-2 indicates communications made to other organizations for information and/or requests for emergency response support.

3.0 ACTIVATION OF EMERGENCY PERSONNEL The Shift Manager/ED is responsible for initiation of the notification of emergency response personnel in accordance with Emergency Plan Implementing Procedures.

A computer-based, automated notification system referred to as the Emergency Response Organization Notification (ERON) system is used as the primary method for notification of Emergency Response Organization members. This system activates ERO pagers and begins telephone call-out of ERO personnel who do not carry pagers. The system uses several different types of communication pathways to contact ERO personnel and ERO support personnel (e.g.

pagers, cell phone, telephone and internet).

ERO Pagers and the Emergency Telephone Directory / Call Out lists are used as a backup method for ERO notification.

Revision 45 F-2

ARKANSAS NUCLEAR ONE EMERGENCY PLAN TABLE F-1 COMMUNICATION LINKS AVAILABLE FOR ONSITE/OFFSITE EMERGENCY RESPONSE FACILITIES ADH - State EOF (SEOF)

Technical Support Center Arkansas Dept. of Emerg. Yell County EOC Warning Joint Information Center Operational Support Emergency Operation Pope County EOC Johnson County EOC Logan County EOC Conway County EOC Saint Marys Regional NRC Headquarters US DOE Oak Ridge Legend and Communications Control Room (TSC) Alternate EOF Entergy CEC Mgmt. (ADEM) (24/7) Point (24/7) NRC Region IV Local Fire Dept.

= Location has indicated Facility (EOF) Warning Point (24/7) Warning Point (24/7) Medical Center service Center (OSC) Center (24/7) Warning Point (24/7) Warning Point (24/7)

Commercial Phone Entergy Network (Includes WebEOC)

Entergy/Plant Phone System Public Address System UHF Radio Console UHF Handheld Radios AWIN Radio Link NRC ENS Phone NRC HPN Phone Satellite Phone Telephone Conference Lines Ring-Down Facility Line Dedicated Emergency Offsite Notifications System WebEOC (External Viewing)

Facsimile Machine ERDS Virtual Private Network Note: EP Implementing Procedures define ANO ERO personnel associated with ANO Communication Links.

Revision 45 F-3

ARKANSAS NUCLEAR ONE EMERGENCY PLAN FIGURE F-1 SCHEDULE FOR EMERGENCY NOTIFICATIONS 1,3,5 1,2,3,5 IRS Team Leaders IRS Team Members Rad Resp Shift Teams Manager/ED Communicator ADH Staff 2,3 Duty HP TOCD Shift Engineer / 1,2,3 1,2,3,5 Shift Technical Plant Personnel Onsite Advisor 3, 4 ADH Comm 3,4 County NP&RP Center Warning Points Local Support Services (as required) ADEM Federal Comm Agencies Center SOEF London Fire Dept.

1,2,3,5 NRC County St. Marys Hospital EOCs 1,2,3,5 ERO UAMS 1,2,3,5 Emergency 2,3 Director Entergy Corp.

Pope County EMS 1,2,3,5 GM, Plant Ops 1 - PA System 2 - Pager Pope County Sheriff 3 - Telephone 1,2,3,5 4 - Radio Site VP 5 - ERO Notification (ERON) system Revision 45 F-4

ARKANSAS NUCLEAR ONE EMERGENCY PLAN FIGURE F-2 COMMUNCIATIONS WITH INFORMATION AND SUPPORT SERVICES ADMIN & LOGISTICS COORDINATOR --------------- Entergy Corp. Emergency Center (CEC)

Contractor Support & Other Utilities Areva NP Westinghouse Electric JOINT INFORMATION CENTER MANAGER Entergy Corp. Emer. Center (CEC) ------- Elec. Pwr. Rsrch Inst. (EPRI)

Nuclear Energy Institute (NEI)

INPO Other Utilities DOSE ASSESSOR ------------------------------------------ National Weather Service Revision 45 F-5

ARKANSAS NUCLEAR ONE EMERGENCY PLAN G PUBLIC EDUCATION AND INFORMATION 1.0 PUBLIC INFORMATION CONTENT AND DISSEMINATION 1.1 PUBLIC INFORMATION CONTENT Education of the public in the Russellville area on emergency planning for Arkansas Nuclear One and the proper response to an emergency is the responsibility of Entergy Operations and the Arkansas Department of Health. Annually, Entergy Operations and the Arkansas Department of Health disseminate information to the population within approximately 10 miles of the plant regarding the process by which they would be alerted in the event of an emergency and what their actions should be. This information is in the form of interactive electronic media. Public information can be found on the mobile application, Arkansas Nuclear One Public Information App and public information website at http://entergypublic.info/. Additionally, printed materials, in the form of a postcard are made available to each residence and business. This information may include, but is not necessarily limited to:

a. educational information on radiation,

b. respiratory protection,

c. sheltering,

d. evacuation routes, and

e. a point of contact for additional information, 1.2 PUBLIC INFORMATION DISSEMINATION Emergency Instructions are provided periodically to the permanent adult population within a 10-mile radius of ANO. A general distribution to reach the transient population is achieved by posting information in public areas and by providing emergency instructions in places that transients or new residents might visit.

In addition to providing information to the public through the media, Entergy Operations can provide information directly to the public through Entergy's extensive customer service organization. For events of significant public interest, the ANO Communications Specialist is responsible for activating the Customer Services Department of the Company. Customer Services is responsible for distributing the information releases prepared under the direction of the JIC Manager to each Entergy local office and directly to the public through mailings, as appropriate.

2.0 NEWS MEDIA COORDINATION AND FACILITIES The primary location of Entergy Operations' interface with the media is the JIC. As appropriate to the incident, the JIC Manager may also activate the Alternate JIC in the Little Rock offices of Entergy Arkansas, Inc. or other locations as appropriate.

Revision 45 G-1

ARKANSAS NUCLEAR ONE EMERGENCY PLAN 3.0 EMERGENCY CLASSIFICATION INFORMATION RELEASES It is the policy of Entergy Operations to provide prompt, accurate, and understandable information to the public for events that may affect, or simply concern, the nearby community and the public at large.

If, in the judgment of the Shift Manager/ED, conditions warrant the release of information to the public prior to the activation of the EOF Emergency Director, the Shift Manager/ED is authorized to release such information.

After the EOF is activated, all ANO press releases regarding an incident are prepared under the direction of the JIC Manager and/or Public Information Liaison and approved by the Emergency Director. Incident Commander / FBI approval may also be required in the event of a Hostile Action Based Event. These press releases are the basis for information provided to ANO employees, government groups, other utilities, and industry groups. Requests for information are directed to the JIC Manager. The JIC Manager, along with the Inquiry Response Coordinator is responsible for rumor control as described in Emergency Plan Implementing Procedures.

The JIC Manager establishes communications with the NRC and State public information officials to ensure mutual review and coordination of press releases. Each State and Federal agency directly involved with the emergency response is also invited to participate in joint news conferences. Prior to these news conferences, as appropriate, the information to be released is reviewed by representatives of ANO and each State and Federal agency directly involved with the information being released.

The Company Spokesperson is responsible for overall public information. As appropriate, the Emergency Director may approve other individuals to serve as a Company Spokesperson. The JIC Manager and Public Information Liaison are responsible for the consistency of the press releases.

4.0 NEWS MEDIA EXPOSURE TO EMERGENCY PLANNING INFORMATION At least annually, the news media are invited to participate in a program to acquaint them with emergency planning, information concerning radiation, and points of contact for release of information to the media in the event of an emergency. Additionally, Entergy Corporate Communications will respond to specific media requests for information regarding nuclear energy, Arkansas Nuclear One, and emergency planning.

Revision 45 G-2

ARKANSAS NUCLEAR ONE EMERGENCY PLAN H EMERGENCY FACILITIES AND EQUIPMENT This section of the Emergency Plan describes the location of equipment and facilities maintained by ANO for use in the event of an emergency at Arkansas Nuclear One. The design of Arkansas Nuclear One's emergency response facilities meets the intent of Supplement 1 to NUREG-0737.

Appendix 4 contains a list of general items contained within the Emergency Facilities at Arkansas Nuclear One.

1.0 EMERGENCY RESPONSE FACILITIES 1.1 CONTROL ROOMS The Shift Operations staff functions from the Control Room for each class of emergency at Arkansas Nuclear One. The Control Rooms are radiologically protected and seismically designed to withstand all credible events which could occur at the power plant. The functions of the Shift Manager, Shift Engineer / Shift Technical Advisor, and the Operations staff are performed under the direction of the Operations Manager.

1.2 TECHNICAL SUPPORT CENTER A Technical Support Center (TSC) is provided in the Arkansas Nuclear One Administration Building. This center is equipped with facilities to enable response personnel to monitor the course of an accident and plan corrective and recovery actions. It also serves as the primary location for coordinating the technical support activities in response to an incident. The radiation levels in and around the TSC are assessed using the following detection equipment or equivalent:

Type of Detector Type of Radiation Monitored GM Direct Radiation and Radioiodine Continuous Particulates and air monitor gases

• If it becomes necessary to evacuate the Technical Support Center due to radiation or other hazards, a Secondary Technical Support Center is provided in the Emergency Operations Facility. The Secondary Technical Support Center is also equipped with facilities for monitoring the course of an accident. The TSC is required to be operational within 60 - 90 minutes of the declaration of an Alert, or higher, emergency classification.

1.3 OPERATIONAL SUPPORT CENTER An Operational Support Center (OSC) is provided in the ANO Maintenance Facility from which ANO personnel function to assist the Operations staff in the Control Room. It is used for assembling the plant emergency response teams and other ANO personnel. If it becomes necessary to evacuate the Operational Support Center due to radiation or other hazards, a secondary OSC is provided in the Emergency Operations Facility.

The OSC is required to be operational within 60 - 90 minutes of the declaration of an Alert, or higher, emergency classification.

Revision 45 H-1

ARKANSAS NUCLEAR ONE EMERGENCY PLAN 1.4 EMERGENCY OPERATIONS FACILITY The Emergency Operations Facility is located approximately 0.65 miles northeast of the Reactor Buildings. It serves as the alternate location for the Technical Support Center and the Operational Support Center should these centers be evacuated. The location of the Emergency Operations Facility and evacuation routes from the plant to the Emergency Operations Facility are shown in Figure J-4.

The EOF is required to be operational within 60 - 90 minutes of the declaration of an Alert, or higher emergency classification.

The Emergency Operations Facility also serves as the primary location for the following functions:

1) Coordination between ANO and non-ANO groups, such as the Arkansas Department of Health;

2) A central point for coordinating all ANO offsite radiological monitoring activities at the time of an incident; and

3) The primary location for coordinating both technical and non-technical support activities of personnel brought in to assist ANO personnel.

The areas within the EOF designated as the Secondary TSC, Secondary OSC and Command Room are designed to the same radiological habitability as the Control Room. However, should the Emergency Operations Facility have to be evacuated, the Entergy Arkansas, Inc. Russellville Service Center serves as the Alternate EOF. The estimated time to transfer from the primary to the Alternate Emergency Operations Facility is approximately 1 - 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. A map showing the location of this facility is contained in Figure H-1. The layout of the alternate EOF is provided in an Emergency Plan Implementing Procedure.

The Alternate EOF has the capability to:

Communicate by contacting the EOF, the ANO Control Room, and site Security.

Serve as a staging area for augmented emergency response staff, if the site is not accessible or under threat of, or experiencing hostile action.

Perform offsite notifications.

Engineering assessment activities, including damage control team planning and preparation.

Begin planning mitigation actions in order to minimize the delay in overall site response.

Access up-to-date plant technical documentation, such as general plant drawings, system information, and plant procedures, to enable engineers and maintenance supervisors to do adequate response planning.

The Reeves E. Ritchie Training Center (RERTC) also serves as the location for the Joint Information Center for coordinating the release of information to the media.

Revision 45 H-2

ARKANSAS NUCLEAR ONE EMERGENCY PLAN 1.5 FEDERAL GOVERNMENT EMERGENCY OPERATIONS CENTER Depending on the severity of an incident at Arkansas Nuclear One, the Nuclear Regulatory Commission activates the NRC Operations Center in Rockville, Maryland and the Incident Response Center in Arlington, Texas. NRC personnel also arrive in the Russellville area.

Provisions have been made for NRC personnel to collocate with ANO personnel. NRC personnel may respond to the Control Room, the Technical Support Center, the Operational Support Center, and the Emergency Operations Facility.

1.6 STATE GOVERNMENT EMERGENCY OPERATIONS CENTERS State government emergency operations centers are established at the:

a. State Emergency Operations Center (EOC) located at the Arkansas Department of Emergency Management (ADEM) complex in North Little Rock, Arkansas.

b. Technical Operations Control Center (TOCC) at the ANO EOF. The State of Arkansas maintains a backup TOCC at the Entergy Arkansas, Inc. Russellville Service Center.

This facility is the primary staging area for ADH field monitoring teams although the remainder of the ADH staff is located at the EOF.

c. Arkansas Department of Health (ADH) offices in Little Rock 1.7 COUNTY EMERGENCY OPERATIONS CENTERS Local support services for ANO, such as fire, police, and ambulance services, are coordinated from the Pope County Emergency Operations Center. County Emergency Operations Centers are also established as necessary in Johnson, Yell, Logan, and Conway counties to coordinate any protective or response activities which may be required in their respective counties.

1.8 ENTERGY OPERATIONS/ENTERGY ARKANSAS, INC. CORPORATE OFFICES Entergy Operations - ANO Corporate Offices are located in Jackson, Mississippi. The corporate functional group which responds to an emergency at ANO operates from the Corporate Emergency Center (CEC) located in Jackson.

The Entergy Arkansas, Inc. Corporate Offices are located in Little Rock, approximately 80 highway miles southeast of ANO. The following Entergy Arkansas, Inc. response centers may be established as appropriate to the incident:

a. A media center for coordination with the Little Rock area news media that may be participating in the response to the incident (e.g. Little Rock Convention Center).

b. Alternate Joint Information Center (AJIC) at 9th and LA in Little Rock should the ANO site Joint Information Center be evacuated.

Revision 45 H-3

ARKANSAS NUCLEAR ONE EMERGENCY PLAN 1.9 ENTERGY ARKANSAS, INC. RUSSELLVILLE SERVICE CENTER The Entergy Arkansas, Inc. Russellville Service Center (305 South Knoxville) is located approximately 7 miles from Arkansas Nuclear One. If the Emergency Operations Facility must be evacuated, the Entergy Arkansas, Inc. Russellville Service Center is used as an Alternate Emergency Operations Facility. This facility may also be used to prepare for press briefings during a Hostile Action Based Event 2.0 COMMUNICATION SYSTEMS During an emergency, contact with offsite ANO personnel and with other agencies is made by any of several communication systems. Personnel on site are notified of the emergency by the public address system, the ERO Notification (ERON) system and evacuation alarm systems when applicable. In addition, the Control Room, the Technical Support Center, the Operational Support Center, and the Emergency Operations Facility have radio communications with each other as well as with certain offsite support groups. Table F-1 and Emergency Plan Implementing Procedures identify the locations, and types of communications equipment available. Testing requirements for emergency communications systems are provided in Emergency Plan Implementing Procedures.

The communication systems available to ANO for use during an emergency consist of separate in plant communication systems; the Entergy Corporate telephone system, GAI-Tronics paging system, multichannel ultra-high frequency (UHF) radio network, Pope County Sheriff radio network, ADEM radio (Arkansas Wireless Information Network System - AWINS), direct phone lines (ENS/HPN) to the NRC, hand-held two-way radios and pagers. Both the onsite and offsite (EOF) telephone systems are provided with backup power supplies from batteries and diesel generators.

Communication links are available between the various centers involved in the response to an incident are shown in matrix form in Table F-1 of this Plan. In addition to these links, the capability exists to communicate indirectly between response centers by relaying information through several response centers.

2.1 COMMUNICATIONS WITHIN ENTERGY The primary means of communications between ANO facilities is the ANO phone system which consists of a mixture of private lines, microwave lines, and commercial telephone system lines.

Entergy supplies and maintains its own telephone system for use by Entergy Operations at Arkansas Nuclear One. This system is independent from and does not require the support of commercial telephones for internal service. The GAI-Tronics paging system, a public address system, consists of four independent channels which connect with stations located throughout the plant and can be used to communicate with onsite plant personnel who cannot be reached by telephone.

The Entergy radio network is used by ANO personnel primarily for mobile communications and as a backup to the telephone system. Arkansas Nuclear One is equipped with a multichannel two-way radio system. Each station, unless otherwise indicated, allows for radio communications over independent communication channels. The following units are contained in the system:

1) radio consoles (Unit One Control Room, Unit Two Control Room, Operational Support Center, Emergency Operations Facility, Technical Support Center, Entergy Arkansas, Inc. Russellville Service Center); 2) mobile units (ANO vehicles); and 3) portable (hand-held) units.

Revision 45 H-4

ARKANSAS NUCLEAR ONE EMERGENCY PLAN 2.2 COMMUNICATIONS WITH GOVERNMENT AGENCIES The primary means of communication with the Federal government are the dedicated phone lines provided by the NRC (ENS, HPN, etc.) through the ANO phone system and supplemented with the commercial telephone system. The primary means of communication with State and local groups is the commercial telephone system with the ADEM and Sheriffs Department radios as backup.

Control Room ENS phones are checked daily by the Nuclear Regulatory Commission.

Communications with NRC, State government, and local governments within 10 miles of the power plant, are tested at least monthly. Communications between the plant, Federal, State, and local emergency operations centers and field assessment teams are tested annually. The Early Warning System for the 10-mile Emergency Planning Zone is tested by the Arkansas Department of Health and the National Weather Service (NWS) periodically to ensure its readiness.

2.3 COMMUNICATIONS WITH THE MEDIA Communications with the media are normally made from the Joint Information Center. In the event of a JIC evacuation, an Alternate Joint Information Center (AJIC) may be activated at the Entergy Arkansas, Inc. facilities in Little Rock. Information will be transmitted to the media by JIC Media Liaisons.

2.4 COMMUNICATIONS WITH THE PUBLIC The primary means of communications to the public is through the news media and State and local government. An early warning system is provided by ANO to alert the public surrounding Arkansas Nuclear One of offsite Protective Action Advisories. This system consists of a mixture of NOAA tone alert radios and sirens to alert the public to tune in to local radio stations for further instruction. The early warning system is activated by the Arkansas Department of Health in accordance with Annex V of the Arkansas Emergency Operations Plan.

3.0 ASSESSMENT FACILITIES 3.1 ONSITE SYSTEMS AND EQUIPMENT Systems and equipment which are available on site allow continuing assessment and monitoring of unusual or emergency situations. The following geophysical phenomena monitors are available at Arkansas Nuclear One:

a. A strong motion accelerometer for earthquake detection;

b. A meteorological tower equipped with thermometers, anemometers, wind vanes, etc.,

for assessment of weather conditions. Backup weather information is available in Russellville and Little Rock; and

c. Indicators for monitoring of hydrologic conditions.

In addition, Dardanelle Lake water level information can be obtained from the U. S. Army Corps of Engineers at the Dardanelle Dam.

Revision 45 H-5

ARKANSAS NUCLEAR ONE EMERGENCY PLAN Area, process, and effluent radiological monitors are provided in the plant for continuing assessment of radiological levels. These devices can be used to recognize emergency situations and perform continuing assessment. A more detailed description of this instrumentation is provided in Section I. These devices may be supplemented by portable radiological monitoring devices and periodic sampling and laboratory analysis.

Process instrumentation (e.g., reactor coolant system pressure and temperature, containment pressure, liquid levels, flow rates, and status or lineup of equipment) may be used to monitor the status of the plant and detect unusual conditions. Instruments providing useful information on vital systems are discussed in Section I.

3.2 FACILITIES AND EQUIPMENT FOR OFFSITE MONITORING The routine offsite environmental radiation monitoring program for Arkansas Nuclear One is described in the Environmental Report and in the Offsite Dose Calculation Manual (ODCM) for the station. Thermoluminescent dosimeters (TLD's) are distributed around the plant as shown on Figure J-5. These devices will provide a record of accumulated radiological exposures in the event of an accident.

For unusual or emergency situations, the routine offsite environmental radiation monitoring program may be supplemented by dispatching the Offsite Radiation Monitoring Section of the Emergency Radiation Team (see Section B.2) to perform additional offsite surveys, monitoring, and sampling. This effort may be supplemented by laboratory personnel from ANO and the designated laboratory. Offsite surveys, sampling, and analysis of water, vegetation, soil, and air are accomplished under the direction of the Offsite Team Coordinator and the OSC RAD/Chem Coordinator.

Each field monitoring team has the capability to:

a. Perform direct radiation readings, and

b. Collect and analyze air samples.

Field monitoring teams may be utilized for environmental sampling when the team composition is augmented by personnel trained in environmental monitoring techniques.

The equipment available for use by these personnel includes vehicles, field monitoring kits, and two-way radios. Survey maps of the 10-mile EPZ (with preselected monitoring points) are available in each field kit (see Figure J-2). The radios are used to allow the field monitoring team to communicate with the Offsite Team Coordinator.

Emergency kits maintained by Arkansas Nuclear One are described in Appendix 4. These emergency kits are inventoried at least quarterly or more frequently if they are found unsealed or have been used during the quarter. There are sufficient reserves of instruments and equipment to replace those which are removed from emergency kits for calibration or repair. Calibration of equipment is performed at intervals determined by the manufacturer and the Entergy, Inc.

Calibration & Repair Facility. Intervals are based on equipment performance history.

Facilities for analysis of low-level environmental samples are available via offsite contractors.

Analyses are performed in accordance with established procedures.

Revision 45 H-6

ARKANSAS NUCLEAR ONE EMERGENCY PLAN Field team data from State teams is coordinated through ADH personnel collocated at the ANO EOF. ANO and ADH field team data is compared and any differences resolved prior to its dissemination to the public.

4.0 PROTECTIVE FACILITIES AND EQUIPMENT The response locations at Arkansas Nuclear One which are designed to serve a protective function are the Control Rooms. Specific protective features of the Control Rooms are described in the Final Safety Analysis Report for each unit. All other areas are evacuated if radiological levels warrant.

5.0 FIRST AID AND MEDICAL FACILITIES A Nurse's Station is maintained on site. A description of the type of equipment available in the Nurse's Station is contained in Appendix 4. The Primary and Backup Medical Facilities are the Saint Marys Regional Medical Center in Russellville and the University of Arkansas for Medical Sciences Hospital located in Little Rock, respectively. A description of the type of equipment maintained by Arkansas Nuclear One at these medical facilities is contained in Appendix 4.

6.0 DAMAGE CONTROL EQUIPMENT AND SUPPLIES Fire-fighting equipment on site includes portable extinguishers, hose stations, sprinkler systems, deluge systems, and fire hydrants. The Fire Protection System is described in detail in the Arkansas Nuclear One Fire Hazards Analysis.

7.0 TRANSPORTATION The Admin & Logistics Coordinator is responsible for obtaining the necessary transportation to support the emergency response. The Admin & Logistics Coordinator may use available Entergy Corporation resources for assistance in obtaining transportation and the necessary Entergy vehicles to support the emergency response.

7.1 GROUND ANO vehicles are used to the maximum extent. If there is a shortage of vehicles during an incident; cars, vans, and trucks are rented or leased, as required.

7.2 AIR Planes and helicopters can be rented at the Little Rock Adams Field for flights to and from Little Rock and Russellville. Commercial air services are utilized for national flights to the extent available and in consideration of appropriate time factors. Helicopters are commercially available in Little Rock and can be used in aerial surveys, movement of personnel and supplies, and security.

Revision 45 H-7

ARKANSAS NUCLEAR ONE EMERGENCY PLAN FIGURE H-1 Entergy Arkansas, Inc. Russellville Service Center (Alternate EOF)

RUSSELLVILLE DISTRICT OFFICE 16 333 13 326 02 Ouita Area Prairie DARDANELLE STATE PARK Russellville (Russellville 10 Boat Dock GAP Area) 1.9 64 326 0.9 0.8 Eno RUSSELLVILLE INDETERMINATE* St. Hwy Pop. 13,909 4th NORRISTOWN (1975 Census)

Pop. 556 1978 Cens. 7 7T 05 ANO Dam N Site 7 SPUR East Port Bernice Eno St. Hwy Directions From ANO take Highway 333 northeast to Highway 64. Travel east on Highway 64 to Highway 7T (Knoxville Street) and turn south. Travel on 7T south for approximately three blocks. The Russellville District Office will be on the east side of the street. (305 South Knoxville Street)

Revision 45 H-8

ARKANSAS NUCLEAR ONE EMERGENCY PLAN I ACCIDENT ASSESSMENT 1.0 ACCIDENT ASSESSMENT

SUMMARY

Accident assessment consists of initial assessment activities and long-term assessment activities.

At the first indication of abnormal conditions, initial assessments are performed. Actions are taken by the onsite plant staff to declare the Emergency Class, mitigate the conditions, make dose projections, and initiate the appropriate emergency response. When notified that an abnormal condition exists, the Shift Manager is responsible for making the immediate assessments, classifying the event, and initiating notification. The initial dose assessments for onsite and offsite personnel are evaluated and the recommended protective actions are promptly implemented in accordance with Emergency Plan Implementing Procedures. Initial assessment and projected dose data and offsite Protective Action Recommendations are provided to Federal, State, and local agencies.

If the situation dictates, the Shift Manager may activate the Emergency Response Organization.

When activated, Emergency Response Organization personnel perform accident assessment activities and appropriate offsite Protective Action Recommendations are determined by the Emergency Director. This information is provided to the appropriate agencies by the Emergency Director.

The long-term or continuing accident assessment is performed by the ERO. The ERO formulates protective responses; implements long-term offsite monitoring (radiological data gathered from the plume exposure pathway is analyzed and communicated to the ERO for further projected actual and integrated dose assessment); and the Emergency Director approves recommendations of protective actions. Monitoring teams systematically monitor the onsite and offsite environs using the functional plant instrumentation and portable instruments, as necessary.

Assessment continues for the duration of the recovery. Federal, State, and local emergency organizations are notified for assistance as required. The radiological assessment procedures for use by the ERO are in the Emergency Plan Implementing Procedures.

The general criteria described in Section D are used to define the four Emergency Classes for emergency planning purposes. The Emergency Class categories are listed in Table D-1.

Emergency Class ICs and associated Emergency Action Levels (EALs) that apply to both Unit 1 and Unit 2, are in OP-1903.010, Emergency Action Level Classification, along with plant specific indicators, to assist the person responsible for Emergency Direction and Control in recognizing and declaring the appropriate Emergency Class. The instrumentation available to the Shift Manager to perform this assessment is described in this section and in the Safety Analysis Report for each unit.

Tables D-3 and D-4 categorize each design basis accident considered in the Safety Analysis Report for each unit into the four Emergency Classes based upon their postulated consequences.

It should be noted that, should any of these design basis accidents occur, the category they would be placed in at that time would depend on the actual consequences (OP-1903.010, Emergency Action Level Classification) rather than on the postulated consequences used to develop Tables D-3 and D-4.

Revision 45 I-1

ARKANSAS NUCLEAR ONE EMERGENCY PLAN 2.0 ASSESSMENT CAPABILITIES 2.1 RESOURCES FOR DETECTION/ASSESSMENT OF NON-RADIOLOGICAL EVENTS 2.1.1 Fire Detection The Fire Detection System is described in Sections 9.8 and Appendix 9D of the Unit 1 Safety Analysis Report (SAR) and Sections 9.5 and Appendix 9D of the Unit 2 SAR.

2.1.2 Seismic Monitoring Plant seismic instrumentation, described in ANO-1 and ANO-2 SAR Sections 2.7 and 3.7.4, respectively, is provided to determine the response of the containment and auxiliary building structures in the event of an earthquake so that such response can be compared with that used as the basis of design.

Should a seismic disturbance occur in the neighborhood of the plant, the accelerations recorded within the plant will be the basis for a decision as to continued plant operation. Information on seismic activity can also be obtained from the Memphis University Earthquake Information Center and the National Earthquake Information Center.

2.1.3 River Level Detection The Lake Dardanelle level indication is monitored at the Lake Dardanelle Dam by the U.S. Army Corps of Engineers. The Corps of Engineers has agreed to notify ANO of probable or actual level changes that will lower the lake below Elevation 335 ft. or raise the lake above Elevation 350 ft.

at the ANO site.

2.2 RESOURCES FOR DETECTION/ASSESSMENT OF RADIOLOGICAL RELEASES 2.2.1 Plant Process Instrumentation The plant process instrumentation consists of various pressure, temperature, and level indicators of the Reactor Protection System (RPS) and the Engineered Safeguards System (ESF). Some of the parameters these instruments measure are:

a. Containment Pressure

b. Emergency Core Cooling System (ECCS) Actuation

c. Pressurizer Pressure

d. Steam Generator Pressure

e. Reactor Coolant (RC) Temperature

f. Pressurizer Level

g. Steam Generator Level Instruments which provide information to the reactor operators for monitoring conditions in the reactor, reactor coolant system, and containment; and specific instrumentation designations and ranges are listed in each unit's Technical Specifications. The alarm and trip setpoints for the listed instruments or components are subject to change as the reactor core configuration changes.

Revision 45 I-2

ARKANSAS NUCLEAR ONE EMERGENCY PLAN These various instruments or components are used to detect problems within the system(s) prior to a release of radioactivity as well as monitor system status throughout an incident. Corrective actions to return or maintain the reactor in a safe condition are contained in the Emergency Operations Procedures maintained in the Control Room.

2.2.2 Radiation Monitor for Failed Fuel Detection A monitor in the letdown line of each unit is the designated process radiation monitor which continuously measures the activity of the reactor coolant and activates an alarm in the Control Room if a predetermined activity level is reached. The monitor is described in SAR Table 11-7 and Section 11.4.2.1.1 for Unit 1 and Unit 2, respectively.

2.2.3 Radiation Monitoring ANO has an extensive system for monitoring radioactivity throughout the plant, called the Radiation Monitoring System (RMS). This system consists of area and process/effluent radiological instrumentation. The Area Radiation Monitoring Systems are described in SAR Sections 11.2.5 and 12.1.4 for Unit 1 and Unit 2, respectively. The Process Radiation Monitoring Systems are described in SAR Sections 11.1.3.4 and 11.4 for Unit 1 and Unit 2, respectively. All channels of the radiation monitoring system indicate, record, and alarm in the Control Room.

The area radiation monitors, process/effluent radiation monitors and SPING monitors which are used to classify and assess radiological conditions are listed in Tables I-1, I-2, I-3, I-4, and I-5.

Different types of portable survey instruments have been selected to cover the entire spectrum of radiation measurement. Portable survey and monitoring instruments are described in SAR Sections 11.2.6.2.5 and 12.3.2.5 for Unit 1 and Unit 2, respectively. This includes instruments for detecting and measuring alpha, beta, gamma, and neutron radiation. Sufficient quantities have been obtained to allow for calibration, maintenance and repair. Laboratory counting equipment is described in SAR Sections 11.2.6.2.2 and 12.3.2.2 for Unit 1 and Unit 2, respectively.

a. Process Radiation Monitoring Systems (Units 1 and 2)

1. Design Bases All process systems which contribute to plant discharges are monitored prior to entering the various discharge systems. Each discharge system is also monitored providing redundancy of radiation detection for plant effluents. The Reactor Building air, waste gas, and the main condenser air discharge radiation monitoring systems are backed up by the stack gas monitoring system. The service water, radwaste liquid discharge, intermediate cooling, and decay heat radiation monitoring systems are backed up by the liquid discharge monitoring system.

2. System Description The process radiation monitoring systems are designed to assure that ionizing radiation levels are indicated, recorded, and alarmed so that action, either automatic or manual, can be taken to prevent radioactive releases from exceeding the limits of 10 CFR 20. Devices are located in the various process systems to monitor radiation levels and annunciate any abnormally high activity.

Revision 45 I-3

ARKANSAS NUCLEAR ONE EMERGENCY PLAN All electronic circuitry (except for photomultipliers and geiger tubes) is solid state and each circuit has its own D.C. power supply and provisions for instrument operational testing while in service.

Most monitors are supplied with check sources. The check source simulates a radioactive sample and serves as a check for both the readout and detection equipment. The Control Room inlet air monitor is provided with a pulsed LED which provides an identical detector response as an isotopic check source and is used for the detector, preamplifier and readout equipment for this system.

Radiation monitoring equipment panels are located inside each Control Room. These panels provide mounting for indicators, recorders, power supplies, and alarms for the radiation monitoring systems. The radiation monitoring panels are fed by the instrument AC bus which, in the event of a loss of normal power, is fed by the diesel generator bus.

3. Testing and Maintenance Process radiation monitoring system instruments are tested as required by procedures using built-in or portable calibration sources.

Testing and maintenance for all systems and circuit testing of readout equipment and power supplies can be performed from the panels located in the Control Room. The circuit being tested or repaired indicates and alarms this condition in the Control Room. Faulty or inoperative circuits during operation are also alarmed and indicated in this manner.

b. Area Radiation Monitoring Systems (Units 1 and 2)

1. Design Bases This system consists of monitors, instrumentation, and alarms that serve to warn plant personnel of set radiation levels in various plant areas. The area radiation monitoring systems serve as an early warning of a plant malfunction which may result in increasing radiation levels and in a health hazard. Area radiation monitoring system instruments and detectors (chosen for their proven reliability, spare parts and portability) are provided to permit operation during a long-term response.

2. System Description Continuous monitoring points are located in the Control Room and other normally nonradioactive areas and at the appropriate access control boundaries. The locations of area radiation monitors are provided in each unit's SAR.

Readout and display equipment for the area radiation monitoring system are located on a panel in the unit's Control Room. The area radiation monitoring panels receive power from the instrument AC bus, which is a vital bus.

Revision 45 I-4

ARKANSAS NUCLEAR ONE EMERGENCY PLAN High range detectors (Geiger-Muller tubes) are located in the Unit 1 and Unit 2 containments. The detectors provide an indication of containment radiation levels up to 1 x 108R/hr.

The low-range area radiation monitors are wall-mounted, coaxial ion chambers or wall-mounted gamma sensitive Geiger-Muller tubes. The associated meters are designed with range and sensitivity suitable for their location. High radiation levels and individual circuit failures are alarmed both visually and audibly on the area radiation monitoring panel.

3. Testing and Maintenance Area radiation monitoring system instruments are tested as required by procedures using built-in or portable calibration sources.

Circuit testing of readout equipment and the power source can be performed from the Control Room. The circuit being tested or repaired is inoperative during this time and acts as a tripped channel. Check sources are used to calibrate the detectors and circuits.

c. In-Plant Portable Survey and Monitoring Instruments Portable radiation survey instrumentation consists of different types of instruments, as described in the SAR, capable of detecting and measuring alpha, beta, gamma and neutron radiation. Continuous air monitors capable of monitoring particulate and iodine activity are available to identify airborne radioactivity. These monitors can be set to alarm on high particulate or iodine activity.

When continuous air monitors indicate airborne radioactivity, portable air samplers are used to obtain grab air samples for timely analysis of airborne conditions. These samplers can be equipped with filter cartridges for collecting gaseous and iodine airborne concentrations for analysis.

Gaseous activities of 1 x 10-7 Ci/cc can be detected in low background areas.

d. Laboratory Counting Equipment Laboratory counting equipment includes internal gas flow proportional counter scalers, thin window GM counter scalers, and gamma spectroscopy equipment.

2.2.4 Meteorological Instrumentation The plant has a permanent 60-meter high meteorological tower with redundant power supply, instrumentation and modes of data output. The tower instrumentation includes sensors to measure wind direction, wind speed, air temperature and differential temperatures. The wind and temperature sensors are located at the 10-meter and the 57-meter levels. Meteorological instrumentation is described in Section 2.3 of both the Unit 1 and Unit 2 SARs.

Forecasted wind speed and direction data may also be obtained from the National Weather Service by telephone as described in the Emergency Plan Implementing Procedures.

Revision 45 I-5

ARKANSAS NUCLEAR ONE EMERGENCY PLAN Real-time data is available by use of the RDACS computer. The offsite NRC Response Center may obtain these parameters by calling the Control Room or Emergency Operations Facility.

Other offsite transmittal of data will be by radio or telephone circuits. Meteorological data is made available to State and local agencies through their dedicated communications network.

2.2.5 Water Analyses Analyses of plant liquid systems may be performed to help ascertain the nature of problems detected by other instrumentation (prior to an emergency situation). The samples are collected and analyzed in accordance with ANO procedures. The analysis performed may include both standard chemistry (i.e., chlorides, boron, etc.) and radiochemistry.

2.2.6 Post Accident Sampling Post-accident sampling via the Normal Sample System (NSS) provides the capability to obtain Reactor Coolant System (RCS) samples for isotopic determinations up to 5% clad failure. These analyses are primarily used to determine EAL criteria. Sampling above 5% clad failure may be performed but conditions and precautions will be assessed by Radiation Protection prior to sampling. The NSS has the capability of sampling the RCS from several RCS sample points.

2.2.7 Unified Rascal Interface (URI)

The URI offsite dose projection software provides an initial estimate of the radiological conditions at the ANO Exclusion Area Boundary, provides information to determine the Emergency Action Level for subsequent classification into one of the four Emergency Classes, defines the offsite area(s) potentially affected by an airborne radiological release, provides an estimate of the Total Effective Dose Equivalent (TEDE) and Child Thyroid Committed Dose Equivalent (CDE) doses, displays zones exceeding protective action guidelines, and refines projections based on available field monitoring data. This system meets the intent of 10 CFR 20 and Appendix I to 10 CFR 50.

2.2.8 Safety Parameter Display System (SPDS)

The function of the Safety Parameter Display System (SPDS) is to continuously provide concise displays of critical plant parameters to the control room operators to aid them in rapidly and reliably determining the safety status of the plant. The system is especially useful during abnormal and emergency conditions to assess whether the conditions warrant corrective action by the operators to avoid a degraded core. SPDS data display systems are also located in the Technical Support Center and in the Emergency Operations Facility.

2.2.9 Emergency Response Data System (ERDS)

The Emergency Response Data System (ERDS) is a channel over which raw reactor parametric data, i.e., SPDS information, is transmitted 24/7 from the site to the NRC Operations Center, (NRCOC) via a Virtual Private Network (VPN). Transmission status review and/or activation of ERDS can be performed via designated computers in each Control Room, the TSC, EOF, and other designated offsite Entergy computers. ERDS transmission shall be verified and/or activated within one hour of an ALERT or higher emergency class declaration.

Revision 45 I-6

ARKANSAS NUCLEAR ONE EMERGENCY PLAN 2.3 RADIATION TEAM MONITORING 2.3.1 Operation of Monitoring Teams The primary objective of the onsite and offsite emergency monitoring teams is to rapidly survey areas in order to determine the extent and magnitude of any unplanned release of radioactive material following an incident. The initial onsite and offsite surveys are of great importance; decisions regarding the extent and the type(s) of protective action(s) required are based upon data reported by the survey teams.

If it is determined that unplanned airborne materials have been released following an accident, monitoring teams are dispatched downwind immediately to evaluate radioactivity levels.

The task of each monitoring team is to collect air samples and survey data and transmit information and results to the appropriate response center (i.e., Control Room, TSC, OSC or EOF). Meteorological overlays, area maps, and actual radiation survey data collected by onsite and offsite survey teams are available for use to rapidly define affected areas and assess the extent and significance of the release. Information is required with as little delay as possible.

Therefore, surveys consist of simple methods and approximate results. Information obtained by the Offsite Monitoring Section is transmitted to the Dose Assessor, Radiological Assessment Coordinator (RAC), or their designees, as appropriate to the phase of the response, via radio contact. After the initial urgency of the post-accident situation has relaxed, subsequent surveys are continued to obtain more accurate information.

2.3.2 Personnel

a. Onsite Monitoring Section The Onsite Monitoring Section consists of members of the Emergency Radiation Team.

Their activities are coordinated initially by the Shift Manager and then by the RAD/Chem Coordinator in the OSC. The Onsite Monitoring Team focuses their attention on obtaining onsite radiological data. Duties of the Onsite Monitoring Team are outlined in Section B.2.0.

b. Offsite Monitoring Section The Offsite Monitoring Section consists of members of the Emergency Radiation Team and Chemistry. The Offsite Monitoring Section performs air sampling and measures radiation levels in the outlying areas of the plant site. Their activities are directed by the Offsite Team Coordinator. Survey results are forwarded to the Dose Assessor and the RAC. Duties of the Offsite Monitoring Section are further detailed in Section B.2.

ANO Chemistry personnel, accompanied by Emergency Radiation Team personnel, collect samples of water, vegetation, soil, and air and the environmental TLD's for analysis in accordance with ANO procedures.

Revision 45 I-7

ARKANSAS NUCLEAR ONE EMERGENCY PLAN 2.3.3 Equipment Appendix 4 of this Plan lists the emergency kit contents and their locations.

Emergency Plan Implementing Procedures describe the equipment utilized by the monitoring teams in more detail. Portable equipment capable of measuring gaseous activities 1E-10 Ci/cc is included in field monitoring kits.

3.0 ASSESSMENT OF RADIOLOGICAL RELEASES 3.1 METHOD OF ASSESSMENT Systems, equipment, instruments, and personnel resources available to the Initial Response Staff, and Emergency Response Organization allow for continuous monitoring and assessment of abnormal radiological conditions. Assessment of radioactivity released to the environs provides the information necessary to determine which, if any, offsite protective actions should be recommended to the State authorities. These recommendations are made in accordance with Emergency Plan Implementing Procedures. The methods and calculations prepared for the assessment of radioactivity released to the environs are discussed in the Emergency Plan Implementing Procedures.

Revision 45 I-8

ARKANSAS NUCLEAR ONE EMERGENCY PLAN TABLE I-1 AREA RADIATION MONITORS (UNIT 1)

Monitor Number Location Range Sensitivity RE-8001 Main Control Room 0.1mrem/hr-10rem/hr 0.1mrem/hr RE-8002 Relay Room " "

RE-8003 Machine Shop " "

RE-8004 Outside Stairway at EL 317' - 0" " "

RE-8005 Sample Room Hall " "

RE-8006 Radio-Chem Laboratory " "

RE-8007 Outside Stairway at EL 372' - 0" " "

RE-8008 Decontamination Room at EL 386' - 0" " "

RE-8009 Spent Fuel Pool " "

RE-8010 Controlled Access Entry at EL 386' - 0" " "

RE-8011 Make Up Pump Area at EL 335' - 0" " "

RE-8012 Elevator at Feed Pump at EL 335' - 0" " "

RE-8013 Emergency Feed Pump at EL 335' - 0" " "

RE-8014 CZ Pump at EL 326' - 0" " "

RE-8015 Condensate Demineralizer " "

RE-8016 Spent Fuel Filter " "

RE-8017 Fuel Handling 10mrem/hr-1000rem/hr 10mrem/hr RE-8018 Personnel Access Hatch " "

RE-8019 Incore Instrument Tank " "

RE-8020 Equipment Hatch " "

Revision 45 I-9

ARKANSAS NUCLEAR ONE EMERGENCY PLAN TABLE I-2 PROCESS RADIATION MONITORING SYSTEM (UNIT 1)

Process Radiation Detection Equipment/

Monitoring Systems Sampling Equipment Readout Equipment Sensitivity Alarm and Control Liquid Service Water Scintillation detector/piping, valves, Log count rate meter, 1.9 x 10-6 Ci/cc Alarm on high radiation, sample pump, and detector housing; 0-108 cpm, recorded of Cs-137 circuit failure; high radiation water line to discharge structure, two prohibits service water systems. discharge.

Radwaste Liquid Scintillation detector/in well in radwaste Log count rate meter, 5 x 10-6 Ci/cc Alarm on high radiation, Discharge liquid line to discharge structure. 0-108 cpm, recorded of CS-137 circuit failure; high radiation prohibits radwaste discharge.

Intermediate Cooling Scintillation detector/piping, valves, Linear rate meter, 3.8 x 10-6 Ci/cc Alarm on high radiation, Water sample pump and detector housing; 0-108 cpm, recorded of CS-137 circuit failure.

inlet to coolers, two systems Flumes Liquid Scintillation detector/piping, valves, Linear rate meter, 1 x 10-6 Ci/cc Alarm on high radiation, sample pump and detector housing; 0-108 cpm, recorded of Cs-137 circuit failure.

circulating water to discharge structure.

Main Condenser Air Scintillation detector/well on line; main Spectrometer-Log 1 x 10-5 Ci/cc Alarm on high radiation and Discharge condenser vacuum pumps non- count, 0-108 cpm, of Xe-133 circuit failure.

condensibles recorded Waste Gas Radiation Scintillation detector/in well in line from Linear rate meter, 2 x 10-6 Ci/cc Alarm on high radiation and the waste gas surge tank and waste 0-108 cpm, recorded of Xe-133 circuit failure; isolates waste gas decay tanks to plant vent gas surge tank and decay tanks.

Decay Heat Scintillation detector/piping, valves, Linear rate meter, 2.6 x 10-6 Ci/cc Alarm on high radiation and sample pump and detector housing; 0-108 cpm, recorded of CS-137 circuit failure.

water line discharge structure two systems.

Revision 45 I-10

ARKANSAS NUCLEAR ONE EMERGENCY PLAN TABLE I-2 (continued)

Process Radiation Detection Equipment/

Monitoring Systems Sampling Equipment Readout Equipment Sensitivity Alarm and Control Failed Fuel Scintillation detector/external to Log and spectro- 4 x 109 dis/sec of Alarm on high radiation and letdown line. meter-Log rate I-131 1 x 1012 circuit failure.

meter, 0-108 cpm, Gammas/sec of recorded Gross Gamma Reactor coolant Leak Scintillation detector/piping, valves, Spectrometer-Log 5.5 x 10-5 Ci/cc of Alarm on high radiation and Detector sample pump, detector housing; 0-106 cpm, recorded Xe-133 circuit failure.

reactor building atmosphere.

Penetration Rooms Scintillation detector Linear rate meter, Xe-133 Alarm on high radiation and Ventilation 0-108 cpm, recorded circuit failure S/G Tube Leak Scintillation detector Linear rate meter, N-16 Alarm on high radiation and 0-108 cpm, recorded circuit failure.

High Range Main Geiger-Muller Tube Log rate meter 0.1 to 10,000 mr/hr No alarm or control functions Steam Monitor (Approx. 1,200 counts/min/ mr/hr)

High Range Reactor Ion Chambers Log rate meter 100 to 108 r/hr No alarm or control functions.

Building Area Monitor Control Room Inlet Air Beta-Gamma Sensitive scintillation Auto Ranging digital 1(-5) Ci/cc of Alarm on high radiation and Monitor ratemeter Cs-137 with no circuit failure. High alarm lead shield isolates Control Room.

Revision 45 I-11

ARKANSAS NUCLEAR ONE EMERGENCY PLAN TABLE I-3 AREA RADIATION MONITORS (UNIT 2)

Monitor Number Location Range Sensitivity 2RE-8900 Outside Stairway, EL 317' - 0" 10-4 -10 R/hr 10-4 R/hr 2RE-8901 Outside Stairway, EL 335' - 0" " "

2RE-8902 Piping Area EL 335' - 0" " "

2RE-8903 Controlled Area, EL 360' - 0" " "

2RE-8904 Radwaste Tanks (Access EL 360' - 0") " "

2RE-8905 Containment (Equipment Hatch), EL 357' - 0" 10-2 -103 R/hr 10-2 R/hr 2RE-8906 Outside Stairway, EL 369' - 0" 10-4 -10 R/hr 10-4 R/hr 2RE-8907 Controlled Access, EL 372' - 0" " "

2RE-8908 Solid Radwaste Shipping Area Elev. 338' " "

2RE-8909 Containment Personnel Access, EL 386' - 0" 10-2 -103 R/hr 10-2 R/hr 2RE-8910 Controlled Area, EL 386' - 0" 10-4 -10 R/hr 10-4 R/hr 2RE-8911 HP Area, EL 386' - 0" " "

2RE-8912 Containment, Incore Instrumentation Area, 10-2 -103 R/hr 10-2 R/hr EL 424' - 0" 2RE-8913 Outside Stairway, EL 404' - 0" 10-4 -10 R/hr 10-4 R/hr 2RE-8914 Cask Washdown Area, EL 404' - 0" " "

2RE-8915 New Fuel Storage Area, EL 404' - 0" " "

2RE-8916 Spent Fuel Area, EL 404' - 0" " "

2RE-8917 Sample Area, EL 354' - 0" " "

2RE-8918 Hot Machine Shop Hallway, EL 354' - 0" " "

2RE-8919 Solid Radwaste Shipping Area " "

2RE-8920 Solid Radwaste Shipping Area " "

2RE-8922 Hot Machine Shop, EL 354' - 0" 10-2 -10 R/hr 10-4 R/hr 2RE-8923 Spare 2RE-8924 Regen Waste Control Area 10-4 -10 R/hr 2RE-8925-1 Containment High Range 1 -108 R/hr 2RE-8925-2 Containment High Range 1 -108 R/hr 2RE-8960 PASS Bldg. .1 -104 Mr/hr 2RE-8962 PASS Bldg. .1 -104 Mr/hr 2RE-1007 "A" Steamline Monitor .1 -104 Mr/hr 2RE-1057 "B" Steamline Monitor .1 -104 Mr/hr Revision 45 I-12

ARKANSAS NUCLEAR ONE EMERGENCY PLAN TABLE I-4 PROCESS RADIATION MONITORS (UNIT 2)

Channel Monitor Type-Detector Readout MDL* Set-Point Alarm & Control 2RE-4806 CVCS Process Gamma Scintillation crystal Linear Rate- 1(-4) Ci/cc Variable normally Alarm on high Radiation Monitor with photomultiplier tube meter and of I-131 set slightly above radiation (Failed Fuel) and integral preamplifier logarithmic current readings ratemeter 2RE-5200 Component Cooling Gamma Scintillation crystal Logarithmic 5(-6) Ci/cc 1(-5) Ci/cc Alarm on high 2RE-5202 Water Monitor with photomultiplier tube ratemeters of Cs-137 in radiation and circuit and integral preamplifier 2.5 mr/hr failure background 2RE-1513-2 Service Water, " " " " Alarm on high 2RE-1519-1 Containment Cooling radiation and circuit Coils failure 2RE-1453 Service Water " " " < 2x background Alarm on high 2RE-1456 Shutdown Cooling or 100 cpm if radiation and circuit Heat Exchangers back-ground failure

< 100 cpm 2RE-1525 Service Water Fuel " " " 1(-5) Ci/cc Alarm on high Pool Heat Exchanger radiation and circuit failure.

2RE-4423 Regenerative Waste " Logarithmic 5(-6) Ci/cc Variable setpoint Alarm on high 2RE-4425 Processing System Ratemeters of Cs-137 in established after radiation and circuit 2.5 mr/hr isotopic analysis failure. High alarm background discharge.

2RE-5854 Steam Generator " Logarithmic 5(-6) Ci/cc Approximately Alarm on high 2RE-5864 Sample Coolers ratemeters of Cs-137 in 2x background, radiation and circuit 2.2 mr/hr but not to exceed failure background 6400 CPM Revision 45 I-13

ARKANSAS NUCLEAR ONE EMERGENCY PLAN TABLE I-4 (continued)

Channel Monitor Type-Detector Readout MDL* Set-Point Alarm & Control 2RE-0715 Startup/Blowdown " " 3(-7) Ci/cc Variable setpoint "

Demin. monitor established after isotopic analysis 2RE-2330 Waste Management " " " Variable setpoint Alarm on high System established after radiation and circuit isotopic analysis failure; high alarm terminates discharges 2RE-0645 Main Condenser Air Beta-Gamma Sensitive GM Log count 1(-5) Ci/cc of 2 x background Alarm on high Discharge Monitor ratemeters Xe-133 in 2.5 radiation and circuit mr/hr failure background 2RE-2429 Waste Gas Monitoring " " " Variable setpoint Alarm on high System established after radiation and circuit isotopic analysis failure terminated discharge 2RE-8845 Penetration Rooms " " " 1(-4) Ci/cc Alarm on high 2RE-8846 Monitoring System radiation and circuit failure.

2RE-8271-2 Hydrogen Purge/ Particulate Gamma " Particulate: Variable set Alarm on high 2RE-8231-1 Containment scintillation crystal Gas: 1.5(-10) Ci/cc slightly above radiation and circuit Atmosphere Monitor Beta-Gamma sensitive of Cs-137 Gas: equilibrium failure GM tube 1(-5) Ci/cc of background level Xe-133 in 2.5 mr/hr background 2RE-8540 Fuel Handling Area Beta-Gamma sensitive Log count 1(-5) Ci/cc of 1st alarm 1(-4) Alarm on high Ventilation Monitor GM tube ratemeters Xe-133 in Ci/cc 2nd alarm radiation and circuit 2.5 mr/hr 1(-3) Ci/cc failure background Revision 45 I-14

ARKANSAS NUCLEAR ONE EMERGENCY PLAN TABLE I-4 (continued)

Channel Monitor Type-Detector Readout MDL* Set-Point Alarm & Control 2RE-8542 Radwaste Area " " " " Alarm on high Ventilation Monitor radiation and circuit failure 2RE-8233 Containment Purge " " 1(-5) Ci/cc Variable dependent Alarm on high Monitor of Xe-133 in on meteorological radiation and circuit 2.5 mr/hr conditions and failure terminated background containment activity containment purge 2RE-7828 Aux. Bldg. extension " " " 1(-4) Ci/cc Alarm on high ventilation monitor radiation and circuit failure.

2RE-8750-1A Control Room inlet air Beta-Gamma Sensitive Auto-Ranging 1(-5) Ci/cc Variable set slightly Alarm on high 2RE-8750-1B monitor Scintillation Digital of Cs-137 above equilibrium radiation and circuit Ratemeter with no lead background level failure. High alarm shield. isolates control room.

• MDL = Minimum Detectable Level Revision 45 I-15

ARKANSAS NUCLEAR ONE EMERGENCY PLAN TABLE I-5 SPING MONITORS*

Monitor Monitor Name Location Unit 1 Auxiliary Building EL 404' Boric Acid RX-9820 U-1 Containment Purge Addition Tank Room Unit 1 Auxiliary Building EL 404' Boric Acid RX-9825 U-1 Radwaste Area Addition Tank Room Unit 1 Auxiliary Building EL 404' Boric Acid RX-9830 U-1 Fuel Handling Area Addition Tank Room Unit 1 Auxiliary Building EL 404' Boric acid RX-9835 U-1 Emergency Penetration Room Addition Tank Room Unit 2 Auxiliary Building EL 404' Boric Acid 2RX-9820 U-2 Containment Purge Addition Tank Room Unit 2 Auxiliary Building EL 404' Boric Acid 2RX-9825 U-2 Radwaste Area Addition Tank Room Unit 2 Auxiliary Building EL 404' Boric Acid 2RX-9830 U-2 Fuel Handling Area Addition Tank Room Unit 2 Auxiliary Building EL 404' Boric Acid 2RX-9835 U-2 Emergency Penetration Room Addition Tank Room

• SPING (Super Particulate Iodine and Noble Gas) Monitors Each SPING stack radmonitor detects beta and gamma radiation through continuous particulate, iodine, and noble gas sampling for pathways being released to the atmosphere.

Each SPING monitor consists of 11 separate channels as follows:

Channel # Type Unit 1 Cumulative Particulate Release Ci 3 Cumulative Iodine Release Ci 5 Compensated Noble Gas Volumetric Ci/cc Activity (Normal Range) 9 Compensated Noble Gas Volumetric Ci/cc Activity (High Range) 10 Stack Flow Rate SCFM 13 Particulate/Iodine Branch Flow Rate SCFM (Normal Range) 14 Sample Pressure (Normal Range) psia 15 Total Skid Flow Rate (Normal Range) SCFM 16 Pump Vac. (Accident Range) psia 17 Total Skid Flow Rate (Accident Range) SCFM 18 Sample Flow Rate (Accident Range) SCFM Typical ranges for channel 5 and 9 are 1E-7 to 1E-1, 1E-4 to 1E5, respectively, in units of Ci/cc.

Sensitivities, set points and alarm settings vary and are calculated during normal calibration verification checks. Note SPING 11 does not have channels associated with the Accident Range.

Revision 45 I-16

ARKANSAS NUCLEAR ONE EMERGENCY PLAN J PROTECTIVE RESPONSE 1.0 PROTECTIVE RESPONSE FOR ONSITE PERSONNEL 1.1 NOTIFICATION Onsite personnel are notified of a nuclear emergency via the ANO Public Address System. The Shift Manager/ED, or his designee, will announce the emergency classification and any other pertinent information. The announcements to be made are identified in the Emergency Plan Implementing Procedures and/or Operations procedures.

Persons within the protected area are notified of plant emergency status via the Public Address System. Notification to persons within the exclusion area is accomplished by Security.

Evacuation of non-essential personnel within the exclusion area may be initiated for a Site Area Emergency and will be initiated for a General Emergency in accordance with EPIPs. The sounding of the plant evacuation alarm occurs for both classifications.

1.2 LOCALIZED EVACUATION A Localized Evacuation is initiated if any condition exists that, in the opinion of the Shift Manager or Emergency Plant Manager (EPM), may pose a threat to the health and safety of plant workers.

The threat must be confined to a localized area (i.e., the area selected for evacuation should have well-defined boundaries and be easily controllable).

1.3 PLANT EVACUATION A Plant Evacuation is performed for non-essential personnel if a Site Area Emergency or General Emergency is declared. However, certain conditions may preclude or delay plant evacuation.

These conditions may include an ongoing security threat within the protected area, inclement weather, or a radiological or hazardous material condition. A plant evacuation may be considered if RP survey results indicate that the general area radiation levels outside of a Radiologically Controlled Area exceed 2.5 mR/hr, which is attributed to a loss of control of radioactive material and the hazard is not confined to a well-defined area. If air sample results indicate unevaluated airborne radioactivity exceeds 9 x 10-10 µCi/cc, which is attributed to a loss of control of radioactive material and the threat cannot be confined to a well-defined area. If certain security threats indicate the need to evacuate, or if an uncontrolled toxic gas leak occurs where the hazard is not confined to a local area. The decision to evacuate is based upon the action that presents the least risk to non-essential personnel.

Upon verification that conditions warrant a Plant Evacuation, the Shift Manager or EPM immediately notifies plant emergency teams to assemble. The Shift Manager or EPM alternates an evacuation announcement over the public address system and the sounding of the Plant Evacuation Alarm several times. The evacuation announcement includes instructions concerning the appropriate assembly area, the evacuation route(s), and any other special protective measures to be taken by plant evacuees. Appropriate actions are described in detail in the Emergency Plan Implementing Procedures. The following personnel actions are taken if a Plant Evacuation is declared:

Revision 45 J-1

ARKANSAS NUCLEAR ONE EMERGENCY PLAN 1.3.1 Visitors, Contractor and Construction Personnel, and Employees Not Assigned a Role in the Emergency Organization These personnel proceed to the Primary Access Point (PAP) by the most direct, safest route.

Personnel accountability and preliminary monitoring is accomplished as personnel pass through the PAP. These personnel then proceed as directed. As required, additional personnel monitoring, decontamination, and debriefing may be performed at the EOF, GSB (security threats only), or the Atkins Emergency Worker Center.

1.3.2 Personnel Assigned a Role in the Emergency Organization These personnel proceed to their assigned emergency response location unless directed otherwise (security threat). If conditions require that the Technical Support Center or Operational Support Center be evacuated, these personnel relocate to the EOF.

1.3.3 Shift Personnel Shift operations personnel on duty report to the Control Room. Other shift personnel proceed to the OSC assembly area unless otherwise directed.

1.4 EXCLUSION AREA EVACUATION An Exclusion Area Evacuation, which is the orderly withdrawal of all personnel from that portion of the exclusion area affected by the emergency, is initiated if it is determined that area radiation levels greater than 2.5 mR/hr exist outside the Protected Area and within the Exclusion Area boundary.

The following personnel actions are taken in the event of an Exclusion Area Evacuation:

a. When notified that an Exclusion Area Evacuation has been declared, Security personnel take action according to established procedures to verify that an orderly, safe withdrawal of personnel within the affected portion of the Exclusion Area takes place. Security personnel are responsible for personnel notification and accountability within the Exclusion Area. Under most conditions, the Exclusion Area can be evacuated/verified within one hour of the declaration of an evacuation. Thereafter, Security patrols the Exclusion Area every two hours to notify anyone found within the area to leave.

b. Personnel evacuating from the affected areas of the Exclusion Area follow designated evacuation routes under the supervision of Security personnel while on site. Once offsite, personnel proceed as directed by State and local authorities. Portable loudspeakers are used by Security, as required, to direct the evacuation of the Exclusion Area. Evacuees use any available means of transportation and proceed as directed by the evacuation announcement.

1.5 EOF EVACUATION An EOF Evacuation is initiated if any condition exists which, in the opinion of the Emergency Director, poses a threat to the health and safety of emergency response personnel at the EOF.

EOF emergency response personnel relocate to the Alternate EOF in the Entergy Arkansas, Inc.

Russellville Service Center, if conditions allow.

Revision 45 J-2

ARKANSAS NUCLEAR ONE EMERGENCY PLAN 1.6 SECURITY AND ACCOUNTABILITY 1.6.1 Security A range of protective actions to protect onsite personnel during hostile action is provided to ensure the continued ability to safely shut down the reactor and perform the functions of the Emergency Plan.

The Security program at ANO is designed to deter, delay, and detect an intruder. The Protected Area of the plant site is enclosed by a security fence. All gates to the fence are normally kept locked. The Protected Area is surrounded by a Security Owner Controlled Area (SOCA) created by vehicle barrier systems and detection equipment. Security procedures outline the emergency evacuation duties of security personnel. Support group personnel reporting to the plant during an emergency assemble as discussed in security procedures unless instructed otherwise. Personnel assigned by the Shift Manager, Emergency Plant Manager (EPM), or Emergency Director (ED) to enter the plant must pass through the SOCA and PAP, which are guarded, unless instructed otherwise by Security. It is extremely unlikely that any unauthorized person would be able to enter the site undetected even during an emergency condition.

1.6.2 Accountability A record of Arkansas Nuclear One personnel and visitors on site is available at the PAP for use in personnel accountability. Security procedures have been developed to ensure that on-site personnel are accounted for in the event of an emergency. If necessary, initial accountability may be performed at any time. It is ANO's goal to achieve initial accountability within 30 minutes of the declaration of a Site Area or General Emergency, or plant evacuation. In the event of an emergency requiring evacuation of the PAP, the personnel accountability records are transferred to the EOF and/or GSB (security threat).

Emergency Plan Implementing Procedures are used to account for personnel during an evacuation. Personnel exiting the site log out through the security card reader or as directed by site Security and/or the Shift Manager/EPM. Names of evacuating persons who do not have permanent security badges are obtained. Emergency Response Organization personnel remaining on-site scan in at designated card readers for accountability purposes, except for Control Room personnel who are accounted for each time they enter the Control Room. Security personnel then request a computer print-out of any personnel who failed to either log off-site or log on-site for accountability purposes. Search and rescue efforts are then initiated for these individuals.

Following a plant evacuation, continuous accountability is maintained for all persons remaining on-site.

Assembly/Accountability may be delayed in the event of a Hostile Action Based Event.

Reentry into the plant is made under an Emergency Plan Implementing Procedure related to personnel rescue or reentry to evacuated areas.

Revision 45 J-3

ARKANSAS NUCLEAR ONE EMERGENCY PLAN 1.7 PROTECTIVE MEASURES 1.7.1 Whole Body Exposure It is the policy at ANO to maintain personnel radiation exposure at levels which are as low as is reasonably achievable and in compliance with NRC regulations. Personnel entering the evacuated area(s) to conduct investigations are supplied with appropriate monitoring devices, and every effort is made to keep their doses within the limits of 10 CFR 20. Reentry is made in accordance with an Emergency Plan Implementing Procedure.

Individuals entering Radiologically Controlled Areas wear personnel monitoring devices capable of measuring the dose received from external sources of ionizing radiation. The official and permanent record of accumulated deep dose equivalent is normally obtained from a DLR badge.

The self-reading dosimeter provides a day to day indication of deep dose equivalent.

Additional personnel monitoring equipment is available in the emergency kits as identified in Appendix 4.

1.7.2 Clothing Protective clothing is a normal use item for work in a contaminated area at Arkansas Nuclear One. Both washable and disposable protective clothing are available. Sets of protective clothing are available in the following emergency kits as described in Appendix 4: Control Room Kit, Onsite Radiological Monitoring Kit, EOF Kit, TSC Kit, and Saint Marys Hospital Kit. Protective clothing is available in the Auxiliary Building. Waterproof protective clothing is also available.

1.7.3 Respiratory Protection Respiratory protection devices may be required in any situation arising from plant operations where an airborne radioactivity condition exists or potentially exists. In such cases, the air is monitored and the necessary protective devices specified according to the concentration and type of airborne contaminants present. During an emergency, monitoring is conducted in accordance with RP Procedures. Precautions are taken to keep airborne contamination to a minimum through the use of proper ventilation and prior decontamination of equipment or work areas.

Listed below are the types of respiratory protection equipment available:

a. Full face and demand type respirator

b. Pressure demand Self Contained Breathing Apparatus (SCBA)

Revision 45 J-4

ARKANSAS NUCLEAR ONE EMERGENCY PLAN Normally, SCBAs are issued at the Controlled Access entry. The following is a listing of the emergency kits containing SCBAs:

Emergency Kit Control Room Kit Onsite Radiological Monitoring Kit Alternate Fire Brigade Ready Room RCA Fire Locker Fire Brigade Ready Room Emergency Operations Facility 1.7.4 Radioprotective Drugs Radioprotective drugs in the form of potassium iodide (KI) tablets are available in the onsite Radiological Monitoring Kit, TSC Kit, EOF Kit and in the Field Monitoring Kits. The use of potassium iodide is in accordance with Emergency Plan Implementing Procedures.

1.7.5 Contamination Controls Section K of this Plan outlines the radiological exposure controls implemented at ANO.

Contamination control, personnel monitoring, and decontamination are detailed in Sections K.2.2 and K.3.1.

2.0 PROTECTIVE RESPONSE FOR INDIVIDUALS WITHIN THE PLUME EXPOSURE PATHWAY 2.1 PROTECTIVE ACTION RECOMMENDATIONS 2.1.1 ANO Guidelines Arkansas Nuclear One is designed and equipped with a series of safety systems engineered to meet 10 CFR 100 criteria for reactor safety. ANO management recognizes that in any accident situation, it would be prudent and logical to make every effort to further reduce and minimize dose to the public.

The protective action guides for the general population for thyroid dose due to inhalation from a passing plume and whole body exposure to airborne radioactive material, as recommended by the Environmental Protection Agency (EPA), are listed below:

Total Effective Dose Equivalent (TEDE) 1 Rem Child Thyroid Dose (CDE) 5 Rem 2.1.2 Initiation of Recommendation Recommendations originate from the Control Room or Emergency Operations Facility based upon data derived from implementing procedures relating to offsite dose assessment. The procedures establish methods for determining projected dose to the population at risk. Total population exposure is estimated in accordance with Emergency Plan Implementing Procedures.

Revision 45 J-5

ARKANSAS NUCLEAR ONE EMERGENCY PLAN Recommendations are made in accordance with agreements with the Arkansas Department of Health. Whenever possible, the message formats provided in procedures are utilized. The implementing procedures relating to Protective Action Guidelines assure that the recommendations are determined through an approved process. Offsite Protective Action Recommendations are approved by the individual responsible for Emergency Direction and Control.

2.1.3 Population Distribution This Emergency Plan is primarily applicable to the Arkansas Nuclear One Exclusion Area and the Emergency Planning Zones within a 10-mile and 50-mile radius of Arkansas Nuclear One as shown on Figures J-1, J-2, and J-3, respectively, although provisions exist for extending these areas in the unlikely event this coverage is necessary. Figure J-2 is divided into sixteen 221/2-degree sectors and ten lettered radial zones at one-mile radii from the center of the plant in order to identify the area surrounding the plant by sector and zone nomenclature. Figure J-4 depicts the location of the Arkansas Nuclear One Emergency Operations Facility and the site evacuation routes. The location of thermoluminescent dosimeters (TLDs) in the area surrounding the plant is provided in Figure J-5.

2.2 NOTIFICATION If public notification is required, both transient and resident populations within the plume exposure pathway are initially notified through the Early Warning System (reference Section E 3.0).

Additional notification and information is provided to the transient and resident population as well as the general public outside the 10-mile EPZ by local radio stations. Supplemental notification to the EPZ population is provided by local fire departments in the EPZ. Also, in the event of siren or NOAA radio system failures, route alerting is provided by local fire departments in the EPZ.

Emergency Instructions describing notification, protective actions, and general radiological education are provided to residents and public areas to transients within the 10-mile Emergency Planning Zone. State and local government officials issue messages describing the incident and recommended public protective actions. Examples of these messages are provided in Appendix 6.

2.3 EVACUATION The Arkansas Department of Health is responsible for the recommendation of protective actions for offsite areas and notification of State and local assistance agencies. State officials consider the potential risks of implementing protective actions against the reduction of radiological risk achieved by the protective action.

The State of Arkansas Department of Health determined in conjunction with local officials that, based on the existing local warning and notification systems, experience in actual evacuation situations, and ambulance response times, the offsite area within distances up to ten (10) miles of Arkansas Nuclear One could be evacuated within the estimated evacuation times indicated in Table J-1. Population distribution by evacuation zone is shown on Figure J-6.

Revision 45 J-6

ARKANSAS NUCLEAR ONE EMERGENCY PLAN An Evacuation Time Estimate is performed annually. The results of this study are available from Emergency Planning.

Under these estimates and other considerations involved in the protection of the public, the State of Arkansas has developed protective action guides for the public which are included in the State Emergency Operations Plan and are summarized below:

A variety of parameters, including plant conditions and actual offsite doses, may result in a recommendation to evacuate all or part of the EPZ. (Based upon an evaluation of the potential risks of evacuation versus the reduction of radiological risk achieved by the evacuation, some institutional groups may be recommended to shelter personnel and/or use radioprotective drugs.)

Further protective action is recommended based upon an evaluation of data received from field radiological assessment teams.

Offsite protective actions may be appropriate for emergency situations which fall in the Site Area Emergency or General Emergency Classes. In order that the public may be in a state of readiness for any necessary action, an Early Warning System has been installed and may be activated at any Emergency Class as determined appropriate by the State. The Early Warning System is described in Section E.

2.4 SHELTERING / STAY INDOORS Under certain conditions, sheltering may be the preferred recommended action. Sheltering involves remaining inside with windows and doors closed and sources of outside air turned off.

Limited radioactive releases may require this type of action.

Members of the public may also be requested to stay indoors. Staying indoors is similar to sheltering except there is no need to close windows and doors and secure sources of outside air.

Area radio stations advise the public on taking these actions and also give the "all clear" signal when appropriate.

2.5 RADIOLOGICAL ENVIRONMENTAL MONITORING In the event of an emergency, permanent air sampling stations are utilized for long-term evaluation concerning airborne releases. Environmental TLDs located at the background radiation stations, as shown on Figure J-5, provide exposure data and are periodically replaced.

Sampling efforts may be combined with emergency team activities.

Figures J-2 and J-7 show pre-selected radiological field monitoring points within the 10-mile EPZ.

Revision 45 J-7

ARKANSAS NUCLEAR ONE EMERGENCY PLAN TABLE J-1 ESTIMATED EVACUATION TIMES-ANO ENVIRONS (in hours)

Adverse Sub-zone Weekday Night Weekend Weekday G 2.8 2.5 2.8 3.3 H 4.2 3.7 5.6 5.0 I 3.7 3.3 3.3 4.5 J 2.5 2.5 2.5 2.8 K 2.3 2.3 2.7 2.8 L 2.5 2.5 2.5 2.8 M 2.3 2.0 2.0 2.5 N 2.5 2.5 3.7 2.8 O 2.3 2.0 2.3 2.7 P 2.2 2.0 3.0 2.5 Q 2.0 2.0 2.0 2.2 R 2.0 2.0 2.0 2.2 S 2.3 2.2 2.2 2.7 T 2.5 2.3 2.5 2.7 U 2.5 2.2 3.2 2.7 Full EPZ 5.8 4.3 7.5 7.8 Revision 45 J-8

ARKANSAS NUCLEAR ONE EMERGENCY PLAN FIGURE J-1 Z

Exclusion Area HWY 333 EMERGENCY OPERATIONS FACILITY SWITCHYARD UNIT 2 UNIT 1 0.65 MILE RADIUS COOLING TOWER Revision 45 J-9

ARKANSAS NUCLEAR ONE EMERGENCY PLAN FIGURE J-2 10-Mile EPZ Radiological Field Monitoring Points 10° 16 340° 1J1 1J3 20° 2 16J3 7 N Seminary St 359 1J2 2J1 2J2 Lamar Lee Mountain Rd 1I1 Riverpoint Rd Quarry St 16J2 Augsburg Rd Rushing Rd 2750 320° 3

16I1 15 16J1 16I2 2I1 2J3 3J1 40° J

Hetzel Ln Pless School Rd 1H2 Nelson Rd 359 Hickey Mt Loop 1H1 3I2 27 2740 16H2 3I1 I

2H1 333 15I3 2H2 Hickey Mt Loop Piney 2730 Pless Community Rd 1G1 16H1 3J2 Bay H S Elizabeth Dover 16G1 Mt Carmel Rd W Mt Carmel Rd W 15H2 16G2 1F2 St 1F3 Huckleberry Rd E 2G1 3H1 15I2 3J3 August Pl 435 2G2 15J2 2608 3G1 333 164 G

359 15J1 2F1 300° Knoxville 2606 15I1 2F2 3I3 60° 315 2700 15G2 Knoxville Rd 63 16F1 1F1 Ueliner Rd E Owen Wait Rd 14I3 15H1 3G2 7 14J2 16E2 Hurley Rd 1792 1794 3H2 F 4 1771 Pope County 1709 14 Johnson County Cabin Creek Rd 1790 1788 Singleton Rd 64 1E2 15G1 1780 1E1 Quail Hollow Rd 83 15F2 14H2 Mt Chapel 2F1 1651 School 16E1 Meimerstorf Ln 3F1 4H1 Morgan Rd 4I1 4I3 E

40 Storment Rd 15E2 Rd 1D1 S Pork Ln 3F2 3G3 Coffman 14I2 Rd Terra Villa 15F1 Rd Dr 4G1 1751 16D2 14J1 1660 14F2 1760 Will Baker Rd 15D1 2D1 Wake Robin Rd 15E1 16D1 4G2 Roy Taylor Rd 1660 14G1 4J1 Georgetown Rd 1C1 D

333 3E1 Round Rock Rd 14I1 2C2 Fairview Dr 1650 4I2 1631 3D1 Golden Pond Dr Davie Rd 1640 16C1 280° 14H1 15C1 2C1 C 4F2 4F1 Water Works Rd Randal 4H2 Hayden 80° 14D1 14C1 London School 2B2 3C1 4D1 Cir 4G3 Ln 5J1 B

Hays 64 St Ln N Laddy 15B2 5I1 16B1 40 Ln Alley Rd 4E1 McDonald Blvd 1B1 2B1 124 Price Blvd 15B1 3B1 4C1 5G1 Flatwood Rd A 4B1 5E1 Shiloh Rd 5F1 4B2 5H1 Cagle Rock Rd Panther Hollow Rd 64 5

13I2 14B1 333 13 13H1 13G1 13F1 River Mt Rd 13D1 Clear 5C1 5D1 5E2 E Aspen Ln Sparksford Dr 5H2 Crow Mountain 5I2 A Sparksford Dr 13E1 Lake Dr 5F2 Rd 6C1 Sunset Lake Front Dr 40 5J2 13I1 Dr TO 5G2 FORT 12D2 12C1 SMITH 6F1 5H3 B

Lake View Rd 7C1 393 12D1 Hob Nob Rd Spring Rd 13J1 Weir Rd 12E2 Hilltop 6E1 Brock Creek Rd 260° 12I1 12F2 7C2 Pl 6D1 5J3 Inglewood Ave 22 22 12E1 100° C

E Parkway Dr 12G1 11D1 6G1 12H2 Marina Way Lake Dardanelle 7D1 6H1 331 Nichols Ln Phoenix Ave Main St 6I1 Glenwood Ave 12J1 10C1 Elimira Ave Delaware Bay Rd 64 Knoxville Ave 12F1 11E1 Turrentine 324 Way 7E1 D

W 12th St Russellville E 6th St 6F2 6J1 E 16th St 7F1 12H1 Co 6G2 E 19th ST Rd 10D1 9D1 6H2 Sheppard Dr 746 8D1 10E1 Birdie St 9D2 E

Bogey St Bay 6J2 Elmira Ave 11F1 6

Ridge Rd 7G2 7G1 Jimmie Lile Rd 11G1 12 8E2 7F2 International Paper Rd Lock and Dam Rd 8E1 Sweeden Rd 11H1 22 F Co Rd 913 9E1 8F1 S Frankfort Ave 7H1 Pottsville Liberty Rd Co Rd 917 8F2 7G3 6J3 240° 9F1 Co Rd 915 120° G 10F1 8G1 Dardanelle 7H2 247 155 8G2 7H3 247 7I1 7J1 Robinson Ln H

7I2 9G2 8H1 9G1 Logan County Alexis Ln 7J2 Pfeifer Rd Yell County 27 I

8I1 8H3 8H2 9H1 11 J Robin Dr 28 8I2 7

140° 39 Pansons Ln 10J2 8J1 N 220° 9I3 Co Rd 46 9I1 8I3 Water Plant Rd Co Rd 427 10J1 9I2 Co Rd 39 Gum Springs Rd Co Rd 45 W E Co Rd 53 8J2 Alpha Rd Co Rd 41 Gum Springs Rd 9J1 8J3 Co Rd Co Rd 47 7 S 9J3 412 Scale 9J2 155 Miles 200° 160° 10 8 27 0 0.5 1 1.5 2 180° 28 9 NOTES

1. Map centered on Unit 1 Reactor Building

2. Sector 1 centered on map North

3. Coordinate System: UTM, NAD27, Zone 15N

4. Stations within a 1 mile radius are not shown Revision 45 J-10

ARKANSAS NUCLEAR ONE EMERGENCY PLAN FIGURE J-3 50-Mile EPZ Hindsville Huntsville Western Grove Pindall St. Joe Jasper Madison Gilbert Newton Searcy Marshall Leslie St. Paul Dennard Chester Shirley Mountainburg Crawford Fairfield Bay Van Buren Clinton Johnson Franklin Mulberry Hagarville Alma Dyer Ozark Wiederkehr Village Clarksville Hector Altus Lamar Coal Hill Hartman Denning Pope Dover Morrison Bluff Center Ridge Knoxville Scranton Damascus Lavaca London Twin Groves Guy Branch Ratcliff Caulksville ANO Charleston Subiaco Paris New Blaine Conway Russellville Pottsville Atkins Dardanelle Greenbrier Greenwood Sebastian Logon Wooster Holland Plumerville Magazine Morrilton Menifee Booneville Blue Mountain Faulkner Havana Oppelo Belleville Conway Corinth Danville Perry Adona Houston Ola Casa Yell Perryville Bigelow Plainview Fourche Perry Mayflower Waldron Roland Scott Natural Steps Maumelle Pulaski North Little Rock Cammack Villiage Little Rock Avilla Hot Springs Village Saline Salem Oden Shannon Hills Bryant Alexander Fountain Lake Landmark Garland Mountain Pine Benton Bauxite East End Mount Ida Montgomery Lonsdale Piney Haskell Hot Springs N Black SpringsNorman Rockwell Traskwood Lake Hamilton Legend ANO W E ANO 5 Mile Buffer ANO 2 Miles 10 Miles S 50 Miles Water Places Counties Revision 45 J-11

ARKANSAS NUCLEAR ONE EMERGENCY PLAN FIGURE J-4 ANO Emergency Operations Facility Location & Site Evacuation Routes Emergency Operations Facility Evacuation Route 2 HWY 333 Evacuation Route 1 0.65 mile radius Revision 45 J-12

ARKANSAS NUCLEAR ONE EMERGENCY PLAN FIGURE J-5 Distribution of Thermoluminescent Dosimeters (TLDs) 1 2

0° 16 340° 20° US HWY 7 TO HARRISON 15 320° 40° INTERSTATE 40 3

TO FORT SMITH SR 5 PINEY BAY USE AREA Dover 125 SR 333 300° 60° 164 EAST TO 153 U.S.

MORELAND HWY 14 64 4

14 SR 24 TO MORELAND 280° ARKANSAS RIVER 116 INTERSTATE 40 80° 16 LONDON 13 J I H G F E D C B A 5 DELAWARE STATE PARK 127 260° DARDANELLE STATE PARK 111 ARKANSAS TECH UNIVERSITY U.S. HWY 22 HWY 524 LAKE DARDANELLE DARDANELLE STATE PARK RUSSELLVILLE 6

12 DARDANELLE LOCK AND DAM DAM SITE EAST PARK HWY 7T 6 240° 120° HWY 7 SR 247 TO POTTSVILLE MT. NEBO HWY 27 137 STATE PARK DARDANELLE 11 220° HWY 28 140° 7

HWY 7 200° 160° 10 180° 8

HWY 7 TO HOT SPRINGS HWY 27 TO DANVILLE INSET DANVILLE (SEE INSET) 9 N W E HWY 154 S

HWY 27 55 HWY 10 Entergy Substation 7

Petit Jean River 57 HWY 10 Cowger Lake City of Danville TLDs are located at: Arkansas Nuclear One HWY 80 HWY 27 6, 111, 116, 125, 127, 137, 153 REMP Sample Locations (Far Field)

Revision 45 J-13

ARKANSAS NUCLEAR ONE EMERGENCY PLAN FIGURE J-6 Estimates of Population Relocating To Care Centers by Evacuation Area 10 Mile Radius TO CLARKSVILLE TO HECTOR Augsburg 7 TO CLARKSVILLE 333 Dover 40 POPE COUNTY 164 64 5 Mile Radius 359 TO HECTOR Knoxville 333 JOHNSON COUNTY 7 40 Lake Dardanelle TO MORRILTON London 331 333 ARKANSAS NUCLEAR ONE 64 331 TO PAIRS Delaware Lake Dardanelle 22 LOGAN 40 COUNTY 7 7T 22 7 64 SPUR RUSSELLVILLE TO MORRILTON DARDANELLE Mount Nebo 55 247 State Park YELL COUNTY 7 27 28 FIGURE J-20 TO DANVILLE ESTIMATES OF POPULATION RELOCATING TO CARE CENTERS BY EVACUATION AREA MORRILTION 17,000 DANVILLE 4,500 HECTOR 4,000 CLARKSVILLE 1,900 PARIS 700 Revision 45 J-14

ARKANSAS NUCLEAR ONE EMERGENCY PLAN FIGURE J-7 One Mile EPZ Environmental Sampling Stations Arkansas Nuclear One Environmental Sampling Stations 1-Mile Emergency Planning Zone AREA ENLARGED Old Hwy 64 Alley Rd 64 Pine St 40 Pine Hill Dr London Mill Creek Rd Hill Blvd Price Blvd Bennett Dr Bennett Rd 16A1 333 1A1 Exclusion Area Boundary Training Center 2A1 14A2 3A1 4A1 14A1 Round Mountain Rd Cooling Tower 5A1 West Access Rd 13A1 13A2 Galaxy Ln East Access Rd 6A1 12A1 Scott Ln 6A2 7A1 May Cemetery 8A1 Boat Ramp 10A1 9A1 Burl Ln Exclusion Area Boundary 7A1 Pope County N

Beach Rd W E Lake Dardanelle Russellville S

Scale 1. Map centered on Unit-1 Reactor Building NOTES 0 0.1 0.2 0.3 2. Sector 1 centered on map North

3. Coordinate System: UTM, NAD27, Zone 15N Miles 5 07/023/08 Project No. 6045-300 DMM JHJ Rev Date

Description:

Version 5 edits from Bob Fowler BY CHK Revision 45 J-15

ARKANSAS NUCLEAR ONE EMERGENCY PLAN K RADIOLOGICAL DOSE CONTROL 1.0 DOSE GUIDELINES Radiation dose control is of utmost importance at Arkansas Nuclear One. Therefore, it is deemed appropriate that detailed radiation protection measures be established and utilized. These measures are included in Emergency Plan Implementing Procedures and Radiation Protection Procedures, as appropriate. A description of applicable radiation control measures follows.

1.1 DOSE LIMITS ANO Radiation Protection Procedures provide the specific actions undertaken to determine and record individual occupational doses on a 24-hour per day basis. These procedures state that each emergency responder entering a radiologically controlled area shall be issued appropriate personnel monitoring devices consisting of one or more of the following types: dosimeter of legal record (DLR), self-reading pocket dosimeter, neutron badges and extremity dosimetry devices.

The TSC Radiological Coordinator is responsible for ensuring that all personnel (employees, vendors, contractors, and visitors) are appropriately monitored for exposure to ionizing radiation at ANO.

Allowable emergency doses and accidental doses to individuals have been established. Table K-1 outlines ANO's permissible emergency dose limits. Restrictions to further exposure are placed on exposed individuals, if necessary.

To determine accumulative doses, any DLRs of individuals exposed to radiation prior to the event are read and added to the emergency events doses promptly.

In all cases and events, administrative control and restriction of dose to radiation is monitored by the TSC Radiological Coordinator and the Radiation Protection staff.

EPA-400, "Manual of Protective Action Guides and Protective Actions for Nuclear Incidents,"

Table 2.2, is used to establish additional dose guidelines for life saving actions and protection of property. These guidelines are described in the Emergency Plan Implementing Procedures.

All requests for increasing radiation doses for emergency workers above administrative limits are directed to the Shift Manager, EPM or ED. These individuals have the authority in emergency situations to authorize emergency workers to receive doses in excess of 10 CFR 20 limits. After ERO activation, the EPM will typically assume the responsibility for approving on-site personnel doses exceeding 10 CFR 20 limits and the ED will typically assume the responsibility for approving off-site ERO personnel doses exceeding 10 CFR 20 limits.

1.2 PERSONNEL DOSIMETRY The capability to determine radiation dose to emergency response personnel is available twenty-four hours per day. Dosimetry personnel issue DLRs and dosimeters, maintain DLR and dosimeter logs, and keep the TSC Radiological Coordinator informed of personnel doses.

The self-reading dosimeters are read by the Radiation Protection staff upon entry and exit from radiologically controlled areas and recorded for each individual. The permanent DLR is read, as necessary, in order to establish dose trends and control individual dose.

Revision 45 K-1

ARKANSAS NUCLEAR ONE EMERGENCY PLAN 2.0 CONTAMINATION CONTROL 2.1 AREA ACCESS Controls have been established at ANO to ensure that there is no detectable fixed or removable contamination (beta-gamma or alpha) outside of the Controlled Access Area under normal and emergency conditions. All personnel and equipment leaving the Controlled Access Area are monitored to ensure that the limits for contamination levels are met.

Contamination control actions for off-site areas are planned for the Emergency Planning Zones with provisions to extend the actions to areas beyond this limit if necessary. These contamination control actions are described in the State Emergency Operations Plan.

2.2. PERSONNEL 2.2.1 Under Normal Conditions Personnel working practices within the Controlled Access Area are controlled by Radiation Protection personnel. Radiation Work Permits are required by all personnel working in the Controlled Access Area. Specific instructions, precautions, and limitations are listed on the work permits.

Individuals leaving radiologically controlled areas are monitored for contamination before entering the uncontrolled area of the plant. Personnel are again monitored as they pass through the portal monitor before leaving the Protected Area, thus making it unlikely that a contaminated person could leave the site undetected.

2.2.2 Under Emergency Conditions Under certain emergency conditions (e.g., security-related evacuations) personnel monitoring may be relaxed at the determined plant exit point(s) in order to reduce personal harm to plant personnel. However, these personnel will be monitored at external designated assembly areas in accordance with established procedures.

In the event of personnel contamination, Radiation Protection procedures are implemented.

These procedures detail methods for contamination removal from wounds, the whole body, hair, nostrils, and under fingernails. Wounds, eyes, ears, nose, and mouth are treated with utmost care to prevent internal deposition and infections. The procedures list supplies for decontamination; however, decontamination is accomplished by use of soap and water unless use of another agent is approved by the TSC Radiological Coordinator, or his designee.

All decontaminations are recorded and, if not effective or if sickness and/or wounds are involved, personnel are taken to the Saint Marys Regional Medical Center. Further decontamination is carried out at the Saint Marys Regional Medical Center. The types of supplies and detection instrumentation maintained by ANO at the hospital are listed in Appendix 4. Certain agents such as titanium dioxide, EDTA cream, surgical soap, and potassium permanganate solution are common hospital supplies and are not listed. Radiation Protection personnel assist hospital personnel in surveying the patient and in contamination control. Hospital radiological department facilities for waste disposal are used.

Revision 45 K-2

ARKANSAS NUCLEAR ONE EMERGENCY PLAN If an accident occurs in a radiologically controlled area, and the patient requires medical aid, he is checked for contamination. If contamination levels are found to be below the levels for personnel contamination, the patient is taken to the Nurse's Station for treatment. If additional treatment is necessary, the Shift Manager may call the Pope County Emergency Medical Service for transportation to the Saint Marys Regional Medical Center. If the patient is contaminated to unacceptable levels, reasonable efforts are made to decontaminate him. If this cannot be done due to the nature of the injury or hospitalization is immediately necessary, medical treatment and transportation to a hospital takes priority over decontamination activities. The injured individual is placed in clean protective clothing or wrapped, if time allows, to minimize the spread of contamination. A person trained in Radiation Protection accompanies the patient.

When the patient arrives at the hospital, the hospital staff follows their procedure to handle this type of patient. Radiation Protection personnel conduct surveys to ensure that contamination levels are kept to a minimum and control contamination until clean-up has been satisfactorily completed.

Contaminated personal items are confiscated if successful decontamination cannot be completed.

The Emergency Radiation Team performs radiological surveys and establishes Radiologically Controlled Area boundaries. The criteria for boundary placement are found in the Radiation Protection Implementing procedures. Controls normally include use of a personnel entry log, a frisking station, and air sampling. The establishment of such areas control and contain contamination.

Decontaminated items and areas must meet radiological release criteria before being released from Radiation Protection control.

2.3 WATER AND FOOD SUPPLY 2.3.1 Onsite Supplies Radiological surveys of the emergency response facilities and the designated assembly area are performed on a frequent basis. Potable water for ANO is obtained from the Russellville Water Supply. It is unlikely that any airborne release of radioactive material could affect this supply. A minimum storage of bottled water and MREs (meals ready to eat) are staged onsite for use by ERO and support personnel during extended emergency event staffing. Contaminated areas are posted as described in Section K.3.2. Drinking, eating, and smoking are prohibited in radiologically controlled areas.

2.3.2 Offsite Supplies Surface water samples from Lake Dardanelle upstream and downstream of the plant discharge and at the intake to the Russellville water supplies on the Illinois Bayou are analyzed for gross activity. Samples of vegetation and milk (if active dairies in the 10-mile EPZ - see ODCM) are also analyzed as part of the Environmental Radiological Monitoring Program. In the event of an airborne release of radioactive materials, samples are collected and analyzed. Results are provided to the Arkansas Department of Health for appropriate protective action.

Revision 45 K-3

ARKANSAS NUCLEAR ONE EMERGENCY PLAN 2.4 TOOLS AND EQUIPMENT All tools and equipment used in radiologically controlled areas are checked for contamination before being taken from these areas. If the item is found to be contaminated and decontamination is not practical, the item remains in the radiologically controlled area.

Equipment and tools are unconditionally released for use outside of the radiologically controlled areas only if they meet radiological release criteria.

2.4.1 Site Equipment Contamination Control Equipment, such as vehicles, normally stored outside the plant buildings are surveyed for contamination. Normal decontamination procedures of wiping, vacuuming or water spray are performed, dependent on the magnitude and type of the contaminant.

Vehicles leaving the site are monitored and decontaminated. Emergency vehicles on lifesaving missions are not delayed for decontamination when leaving the site.

Large equipment on site which is contaminated, but not required for emergency recovery, is normally covered with plastic film to contain loose contamination.

2.4.2 Plant Equipment Contamination Control Small contaminated tools and equipment are wrapped in plastic and stored in radiologically controlled areas of the plant until decontaminated.

Large equipment outside radiologically controlled areas is covered with plastic film and decontaminated by methods described in radiation control procedures.

Large equipment inside radiologically controlled areas of the plant is normally located within rooms. Access and ventilation to these rooms are individually controlled. Contaminated plant equipment is decontaminated and/or controlled by methods described in radiation control procedures.

3.0 DECONTAMINATION 3.1 PERSONNEL DECONTAMINATION 3.1.1 Decontamination Facilities Contaminated personnel are dressed in clean protective clothing to contain the contamination and transferred to the decontamination area to be decontaminated in accordance with Radiation Protection procedures. Normal personnel decontamination is accomplished in the Controlled Access Area exit Control Point decontamination area. All drains lead to the Radwaste System where the liquid is processed and monitored prior to discharge. The domestic fresh water system supplies water to all the restrooms and showers. During a plant evacuation, personnel decontamination can be performed at the Emergency Operations Facility. A decontamination shower and supplies for decontamination of personnel are maintained at the EOF.

Revision 45 K-4

ARKANSAS NUCLEAR ONE EMERGENCY PLAN 3.1.2 Decontamination Process Personnel decontamination is conducted by members of the Radiation Protection staff, under the direction of the TSC Radiological Coordinator. Decontamination is conducted in accordance with Radiation Protection procedures.

3.2 AREA DECONTAMINATION Area decontamination is performed in accordance with Radiation Protection procedures.

3.2.1 Clean Areas For areas outside of the radiologically controlled areas, surface contamination is kept below the following:

a. Removable and Fixed Contamination Beta-Gamma or Alpha In accordance with Radiation Protection Implementing Procedures.

3.2.2 Contamination Areas Contamination Areas are defined in Radiation Protection procedures. Contamination areas have been divided into categories where the degree of contamination control requires changes with the level of contamination present.

3.2.3 Priorities for Area Decontamination Priorities for area decontamination are determined by the Emergency Plant Manager or the Emergency Director.

4.0 WASTE DISPOSAL UNDER EMERGENCY CONDITIONS Liquid and gaseous wastes are processed using normal methods during emergency conditions.

Emergency conditions may, however, require that additional resources of processing and disposal of waste be obtained.

A Process Control Program (PCP) is used at Arkansas Nuclear One to ensure that radioactive waste management results in solid waste products meeting the criteria contained in the Code of Federal Regulations, state regulations, off-site processing facility criteria and radioactive waste burial site license criteria for solid radiological waste shipment, processing and disposal.

In order to minimize the possibility of an accident involving radioactive waste occurring in an uncontrolled area, radioactive wastes are packaged and stored in a facility designed to prevent radiological releases to the environment. The waste is prepared, loaded and shipped to an offsite processor or a federal or state licensed radioactive waste disposal facility (burial site) in accordance with Arkansas Nuclear One approved procedures and/or qualified vendor procedures which have been approved by Arkansas Nuclear One. These procedures provide specific instructions which ensure the shipments meet the processor or intended burial site license requirements as well as applicable federal and state regulations.

Revision 45 K-5

ARKANSAS NUCLEAR ONE EMERGENCY PLAN TABLE K-1 DOSE LIMITS Permissible dose limits for a NOTIFICATION OF UNUSUAL EVENT are established in accordance with Radiation Protection procedures.

ANO Emergency Permissible Dose Limits ALERT, Site Area Emergency, and General Emergency 5 Rem TEDE

• Protecting valuable property 10 Rem TEDE

• Life saving or protection of large populations 25 Rem TEDE

• • Life saving or protection of large populations > 25 Rem TEDE Note:

• These limits are allowed with proper authorization.

• • This limit is allowed with proper authorization and only on a voluntary basis to persons fully aware of the risks involved.

Revision 45 K-6

ARKANSAS NUCLEAR ONE EMERGENCY PLAN L MEDICAL AND PUBLIC HEALTH SUPPORT 1.0 ONSITE FIRST AID Arkansas Nuclear One maintains first aid kits for minor treatment of injured individuals, showers for decontaminating personnel, and a whole body counter. A decontamination shower and supplies for decontamination of personnel are also maintained at the Emergency Operations Facility.

2.0 MEDICAL TRANSPORTATION Pope County Emergency Medical Services provides ambulances as required. Radio communications between Pope County Emergency Medical Services and the Saint Marys Regional Medical Center are available via a private radio frequency. Members of the Emergency Radiation Team accompany contaminated personnel off site. Special effort is made to minimize radiological contamination of the ambulances.

3.0 OFFSITE MEDICAL FACILITIES 3.1 MEDICAL SERVICES PERSONNEL Local physicians have been retained to provide medical consultants for Arkansas Nuclear One.

These physicians have received training in the treatment of patients that are contaminated and/or overexposed to radiation. These physicians treat contaminated, injured personnel from Arkansas Nuclear One. These physicians practice at the Saint Marys Regional Medical Center.

3.2 SAINT MARYS REGIONAL MEDICAL CENTER The Saint Marys Regional Medical Center has facilities to treat individuals who are contaminated with radioactive material. Agreements are established between the Saint Marys Regional Medical Center, the consulting physicians, and Arkansas Nuclear One for the treatment of contaminated individuals at the Saint Marys Regional Medical Center. Individuals may be transferred to the University of Arkansas for Medical Sciences Hospital for further tests, examination, or treatment, as required, if they:

a. have received an overexposure to radiation sufficient to warrant special treatment or observation;

b. have, or are suspected of having, inhaled or ingested significant quantities of radioactive materials; and/or

c. cannot be readily decontaminated at the Saint Marys Regional Medical Center.

Appendix 4 lists types of emergency supplies that are maintained at the Saint Marys Regional Medical Center by Arkansas Nuclear One. These supplies are checked on a routine basis by Arkansas Nuclear One and/or medical facility personnel.

Revision 45 L-1

ARKANSAS NUCLEAR ONE EMERGENCY PLAN 3.3 UNIVERSITY OF ARKANSAS FOR MEDICAL SCIENCES HOSPITAL The University of Arkansas for Medical Sciences Hospital provides medical treatment for radiologically contaminated and/or overexposed patients.

3.4 OAK RIDGE ASSOCIATED UNIVERSITY MEDICAL DIVISION The Oak Ridge Associated University Medical Division assists in the treatment of radiologically overexposed patients, if required.

Revision 45 L-2

ARKANSAS NUCLEAR ONE EMERGENCY PLAN M RECOVERY AND REENTRY PLANNING AND POST ACCIDENT OPERATIONS 1.0 ORGANIZATIONAL BACKGROUND The Emergency Response Organization (ERO) is responsible for the overall coordination and management of the recovery effort and for the technical and administrative services, design work, scheduling, planning, quality control/assurance, construction, and vendor support necessary during the initial stages of the recovery phase. The individual responsible for Emergency Direction and Control has full authority to take immediate and decisive actions to mitigate the consequences of any nuclear emergency and for protection of the health and safety of the public.

The Emergency Response Organization's effort during emergencies is viewed as a long-term effort requiring the ERO to be present 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day. The Initial Response Staff (IRS), in contrast, functions as the immediate response organization for emergencies. The IRS provides required immediate response actions and radiological controls; and compiles technical data for its own use and for review by the ERO. From the point of initiation of an emergency classification until the ERO is fully operational, the IRS provides direction and assistance for all emergencies.

The ERO is composed of, or can incorporate as needed, all the necessary technical, administrative, managerial, and support personnel that may be required for an emergency as illustrated on Figures B-4 through B-12 of Section B. The organization is capable of 24-hour-a-day sustained operation. For each job title shown on Figures B-5, B-6, B-7 and B-12, there are at least three personnel assigned to fill that position, which facilitates the 24-hour-a-day operational capability.

The Emergency Director makes the decision to proceed from the emergency phase to the recovery phase. The Emergency Response Organization's responsibilities extend into the recovery phase until a decision is made by ERO managers that plant parameters and other pertinent criteria allow deactivation of the ERO and return to the normal plant and corporate organization.

The Emergency Director makes the decision to relax/curtail duties of the ERO personnel. This decision is based on input from ERO managers and advisors and includes, at a minimum, the following criteria:

a. Stable reactor shutdown with direction toward a cold shutdown condition.

b. Containment Building integrity.

c. Availability of an operational heat sink.

d. Operability of instrumentation and control equipment needed to maintain the reactor in a safe condition.

The duties of the ERO may be curtailed, as appropriate, by the Emergency Director to provide the recovery assistance necessary to support the normal plant staff or the ERO may be deactivated by the Emergency Director and responsibility for long-term recovery activities assumed by the normal corporate and plant staff. At the time the ERO is deactivated, ANO management or the Emergency Director may form special groups/ task forces to handle specialized recovery operations.

Revision 45 M-1

ARKANSAS NUCLEAR ONE EMERGENCY PLAN Decisions to relax protective actions for the public are made by the appropriate State and local officials. The Emergency Director advises the State Technical Operations Control Director (TOCD) and the NRC when the plant has returned to a safer mode and suggests that the response be downgraded or terminated and recovery actions initiated if necessary. Recovery actions and procedures are developed as required considering maximum protection for plant personnel and the public.

After ERO deactivation, the organization performing recovery activities follows the ANO normal corporate organization structure as shown in Figure M-1. The ANO corporate positions indicated in Figure M-1 have been assigned recovery responsibilities as described in the following sections.

2.0 ORGANIZATIONAL ARRANGEMENT, ASSIGNMENT, AND RESPONSIBILITIES 2.1 SITE VICE PRESIDENT The Site Vice President provides overall management and direction of the ANO resources utilized for recovery, provides corporate level guidance, provides licensing support, and provides coordination with other Entergy Operations Divisions. If the recovery phase is expected to be a long-term process, he may form a team to be responsible for continuous control of the recovery operation thus permitting other personnel to return to their normal duties. The organizational structure of such a team is contingent on the emergency situation and the procedures required for recovery.

2.2 GENERAL MANAGER, PLANT OPERATIONS The General Manager, Plant Operations is responsible for the site recovery effort and security support. He may request any needed offsite support through the Site Vice President and is responsible for developing required recovery procedures dictated by the type of incident.

The General Manager, Plant Operations also provides for Radiation Protection, Radwaste, and Chemistry support and ensures that area sampling programs are developed for continued sampling until radiation effects of the emergency have been analyzed and an agreement has been reached between Entergy Operations, the State of Arkansas, and local governments that continued special sampling is no longer required. Once the recovery phase is entered, the General Manager, Plant Operations updates estimates of the total population exposure received in the 10-mile EPZ as more current radiological data becomes available.

2.3 DIRECTOR, ENGINEERING The Director, Engineering is responsible for reactor, performance, and system design engineering activities required for the safe and efficient recovery of the plant. These activities include resolving all plant-related engineering issues that do not alter the design basis of the plant.

2.4 MANAGER, OPERATIONS The Sr. Manager, Operations provides assistance and technical services to the General Manager, Plant Operations in the area of plant operations and maintenance.

Revision 45 M-2

ARKANSAS NUCLEAR ONE EMERGENCY PLAN 2.5 OTHER ENTERGY OPERATIONS RESOURCES All other Entergy Operations resources plus other governmental and vendor support are available through the Entergy Operations Corporate Emergency Center to aid the Site Vice President in developing, evaluating, and implementing specific recovery and reentry operations.

2.6 POST ACCIDENT RECOVERY MEASURES Major post-accident recovery measures are performed in accordance with applicable Emergency Plan Implementing Procedures and Emergency Operating Procedures. Other procedures which may be developed following an incident include the following activities:

1. The first auxiliary building entry.

2. The first containment building entry.

3. Damage evaluation.

4. Facility Decontamination.

5. Disposal of radioactive material.

Recovery coordination is provided from the Emergency Operations Facility or normal staff offices according to the status of the ERO. A description of the EOF is provided in Section H and in the Emergency Plan Implementing Procedures. The communications equipment available in this facility is described in Section F and shown in Table F-1 of this Plan.

2.7 POST ACCIDENT REPORTING An Emergency Class is closed out with a verbal and written summary to offsite authorities in accordance with 10 CFR 50.72 and ANO EPIPs. A LER may serve as a written summary.

If a release of radioactive material occurred during the emergency, ANO personnel, in cooperation with ADH personnel, develop a report estimating the total radiation exposure to the population affected by the release.

3.0 REENTRY 3.1 PURPOSE The purpose of a reentry plan is to provide a means to regain access to an onsite or offsite area that was previously made inaccessible due to an emergency situation.

3.2 AUTHORITY The individual responsible for Emergency Direction and Control authorizes reentry into a previously evacuated onsite area. In the event the ERO is deactivated, the Site Vice President has the responsibility for authorizing reentry into a previously evacuated area.

Revision 45 M-3

ARKANSAS NUCLEAR ONE EMERGENCY PLAN 3.3 IMPLEMENTING ORGANIZATION The implementation of the reentry plan is carried out by the ERO depicted in Figure B-6 or the normal ANO organization shown in Figure M-1 and discussed in Section M.2. These organizations have access to all information, documents, equipment, and personnel required to support a reentry effort. Actual reentry is accomplished by recovery personnel under the control of the Emergency Plant Manager and/or the Emergency Director.

3.4 REENTRY - EMERGENCY RADIATION EXPOSURE DOSE JUSTIFICATION Although every effort is made to keep dose as low as is reasonably achievable (ALARA), it is understood that there are emergency situations which transcend the normal requirements for limiting dose. When such situations exist, the individual responsible for Emergency Direction and Control makes the determination as to the amount of radiation exposure that will be permitted based on the guidelines set forth below.

3.5 REENTRY GUIDELINES Reentry into an evacuated area may be required for one or more of the following reasons:

a. To ascertain that all personnel who were in the affected area have been evacuated and, if necessary, to search for unaccounted personnel;

b. To rescue any injured or trapped personnel from the affected area;

c. To perform operations which may decrease the effect of the emergency or hazardous condition; and/or

d. To determine the nature and extent of the emergency and/or radiological conditions.

Reentry operations take place only on the authority of the individual responsible for Emergency Direction and Control who selects individuals that are familiar with radiation protection, first aid, operation, or maintenance for specialized recovery groups. The initial entry of these groups, and all subsequent entries until radiation areas have been properly marked, are under the direction of the TSC Radiological Coordinator. Recovery personnel are briefed regarding their duties and the actions they are to perform while in the area. They are also briefed as to the expected dose rates, stay time, and other hazards. Information for these briefings is obtained from the applicable available sources including interviews with evacuated employees, current operating records, surveys conducted by the Emergency Radiation Team, and Company technical support personnel.

Even under emergency conditions, it is not desirable to exceed the limits of 10 CFR 20.

Guidelines in the Emergency Plan Implementing Procedures, however, permit the individual with Emergency Direction and Control to authorize exceeding those limits under conditions where the mission is to search for and remove injured personnel, prevent conditions that may endanger human life or safety, protect the facilities, eliminate further escape of effluents, or control fires.

Revision 45 M-4

ARKANSAS NUCLEAR ONE EMERGENCY PLAN Recovery personnel perform their duties in the most safe and efficient manner possible. Once their operations have been completed, the recovery personnel follow self-monitoring and personnel decontamination procedures as specified by the TSC Radiological Coordinator.

All questions which relate to exceeding occupational dose limits are directed to the individual responsible for Emergency Direction and Control.

FIGURE M-1 Corporate Positions Assigned Recovery Responsibilities Site Vice President General Manager, Plant Operations Sr. Manager, Operations Director, Engineering Revision 45 M-5

ARKANSAS NUCLEAR ONE EMERGENCY PLAN N EXERCISES AND DRILLS 1.0 EXERCISES Exercises shall test the adequacy of timing and content of implementing procedures and methods, test emergency equipment and communications networks, test the public Alert and Notification System, and ensure that emergency organizational personnel are familiar with their duties.

At least biennially, local, State, and Federal agencies are invited to participate in an exercise with the ANO ERO. Each exercise scenario is varied from year to year such that major elements of the Emergency Plan and Emergency Response Organization are tested within an eight-year period. The exercise attempts to include mobilization of State and local personnel and resources adequate to verify the capability to respond to the accident scenario requiring response. The State and Local Governments are required to participate in biennial exercises in accordance with 44 CFR 350. Provisions are made to start an exercise between 6 p.m. and 4 a.m. once every eight years. An ingestion pathway exercise is also conducted every eight years in which the State and local governments participate. Qualified observers from Federal, State, and local governments are invited to observe and critique these exercises.

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: Hostile action directed at the plant site involving the integration of offsite resources with onsite response; an initial classification of or rapid escalation to a Site Area Emergency or General Emergency; 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.

2.0 DRILLS At their request, state and/or local governments located within the plume exposure pathway EPZ are allowed to participate in scheduled ANO drills. Refusal by state and/or local governments located within the plume exposure pathway EPZ to participate in drills and/or exercises shall be documented by the Emergency Planning group. The types and frequency of drills conducted at ANO (in addition to the biennial exercise) are listed below. More than one type of drill may be initiated at a time and drills may be combined with exercises. The drill is evaluated and additional training or correction provided. Additional drills may be conducted as deemed necessary. The drill instructor makes on-the-spot corrections of erroneous performances.

2.1 COMMUNICATION DRILLS The utility verifies communications with the NRC, State of Arkansas, and local governments within the plume exposure pathway monthly. Communications between the nuclear facility, State and local emergency operations centers, and field assessment teams are tested annually.

Communication drills also include the aspect of understanding the content of messages.

Revision 45 N-1

ARKANSAS NUCLEAR ONE EMERGENCY PLAN 2.2 FIRE EMERGENCY These drills require the activation of the Fire Brigade in accordance with the Arkansas Nuclear One Fire Protection Plan. Fire drills are performed at least once per quarter. At least one drill per year is scheduled to be performed on a "back shift" for the Fire Brigade. At least one drill per year is unannounced. At least once per year a drill is conducted with invited participation of the Local Fire Department. These drills meet the requirements of the ANO Fire Protection Plan.

2.3 MEDICAL EMERGENCY This drill requires activation of emergency medical personnel and, if feasible, transportation by the Pope County Emergency Medical Service of a simulated injured person to an offsite medical treatment facility and activation of their response team. The Medical Emergency drill is conducted annually. This drill is alternated annually between University of Arkansas for Medical Sciences and Saint Marys Regional Medical Center. The offsite portions of the medical drill may be performed as part of the biennial exercise.

2.4 RADIOLOGICAL MONITORING Plant environs and radiological monitoring drills (onsite and offsite) are conducted annually.

These drills shall include collection and analysis of all sample media (e.g., water, vegetation, soil, and air) and provisions for communications and record keeping. Where appropriate, local organizations may participate in these drills.

2.5 HEALTH PHYSICS DRILLS Health Physics drills are conducted semi-annually which involve response to, and analysis of, simulated elevated airborne and liquid samples and direct radiation measurements in the environment.

Analysis of in-plant liquid samples with actual elevated radiation levels, including the use of the post-accident sampling method, is included annually at ANO in Health Physics drills.

2.5.1 Radiological Dose Assessment A radiological dose assessment drill utilizing simulated field monitoring data is conducted annually. The drill may be in conjunction with a Health Physics drill and address dose projection calculations and offsite Protective Action Recommendations.

2.6 OFF-HOURS ERO UNANNOUNCED DRILLS An Off-Hours Mobilization Unannounced Drill is required at least once every eight years to ensure that the capability exists to implement Table B-1, "Minimum Staffing Requirements", of the Emergency Plan and to ensure demonstration that adequate staffing is available to activate the Emergency Response Facilities. This Off-Hours Drill can be accomplished by using the ERO Notification (ERON) system. This type of drill may be performed more frequently.

Revision 45 N-2

ARKANSAS NUCLEAR ONE EMERGENCY PLAN An Off-Hours Augmentation Unannounced Drill is also conducted in accordance with EP Implementing Procedures to test the ERON system and to ensure that the ERO can activate and staff facilities in a timely manner. This drill is performed using the ERON system and requires a call-in response from ERO and ERO support personnel.

3.0 SCENARIOS Scenario development for drills and the biennial exercise is the responsibility of the Emergency Planning Manager. Input from major Federal, State and local agencies, as well as the ANO staff, is required in order to define the objectives to be accomplished in graded exercises. The scenario for drills and exercises is then prepared which may include but is not limited to:

a. the basic objective of the drill or exercise;

b. the participating organizations for the drill or exercise;

c. a chronology of the simulated unusual events;

d. a time schedule of real and simulated initiating events;

e. a narrative summary describing the simulated events and the appropriate responses and actions; and

f. arrangements for qualified controllers and evaluators.

Preparation of the scenario includes identifying Control Room alarms, sequence of alarms, and instrument readings required to initiate the essential components of the exercise.

Only officials of Federal, State, and local support agencies involved in scenario development or designated as scenario controllers/evaluators share scenario information in advance of the exercises. Limited distribution of scenario information allows effective participation by observers/controllers without losing confidentiality of exercise information.

4.0 CRITIQUES In addition to the ANO observers, offsite support agencies provide evaluators for the biennial exercise. Evaluators are given information on the accident scenario prior to the exercise so that they may judge participants effectively.

A critique is scheduled at the conclusion of the exercise to evaluate the ability of organizations to respond as called for in the Emergency Plan. The critique is conducted as soon as practical after the exercise, and a formal evaluation should result from the critique.

The Manager, Emergency Planning is responsible for reviewing the results from the final drill/exercise critique meeting and proposing corrective action to the General Manager, Plant Operations and the Site Vice President. The General Manager, Plant Operations and the Site Vice President are responsible for assuring that appropriate corrective action is taken to improve emergency preparedness.

Remedial exercises are required by the NRC if the emergency plan is not satisfactorily tested during the biennial exercise.

Revision 45 N-3

ARKANSAS NUCLEAR ONE EMERGENCY PLAN O RADIOLOGICAL EMERGENCY RESPONSE TRAINING This section of the Plan describes the methods used to ensure that the Emergency Plan remains effective throughout the lifetime of Arkansas Nuclear One. Responsibility for the administration of this Plan rests with the Site Vice President.

A training program for instructing and qualifying personnel who implement the radiological emergency response plan has been established. The specialized initial training and periodic retraining programs (including the scope, nature and frequency) are provided in the following categories for emergency personnel:

Directors or coordinators of the response organization Personnel responsible for accident assessment Radiological monitoring teams and radiological analysis personnel Fire brigade Repair and damage control teams First aid and rescue personnel Local Emergency Services personnel Medical support personnel Licensee's headquarters support personnel Personnel responsible for transmission of emergency information and instructions Security personnel Responsibility for the training of ANO onsite responders rests with the Site Vice President. The Arkansas Department of Health is responsible for the training of offsite response organizations.

1.0 EMERGENCY RESPONSE ORGANIZATION TRAINING The Emergency Response Organization (ERO) includes the following groups:

Directors or coordinators of the response organization Personnel responsible for accident assessment Radiological monitoring teams and radiological analysis personnel Licensee's headquarters support personnel Personnel responsible for transmission of emergency information and instructions (i.e.,

Communicators, Shift Engineers / Shift Technical Advisors)

It is the responsibility of the personnel assigned to the ERO to become familiar with their Emergency Plan assigned authority and responsibility so that planned actions are taken in the event of an emergency. Personnel who function in the ERO are provided initial training and periodic retraining.

Revision 45 O-1

ARKANSAS NUCLEAR ONE EMERGENCY PLAN The initial and annual retraining programs for ERO personnel are accomplished using various combinations of training settings which may include, but are not limited to, the following:

classroom instruction, computer-based training, written examinations, drill performance (with on-the-spot correction of erroneous performance),

completion of position specific workbooks, and/or self-study Initial training and annual retraining are given in a range of subjects defined by position in the Emergency Response Training procedure. Emergency Plan Implementing Procedures, the Emergency Response Training Procedure, and other documents address administration, scheduling, subject matter, qualification criteria and specific training requirements for the ERO.

Self-study by read and sign is used to make responsible emergency response personnel aware of critical changes to the plan and/or procedures. This method is most often used when such information cannot be delayed until other training can be provided.

Drills are used to provide practical experience to enhance information gained in training. During the year, as many emergency response personnel as possible participate in the scheduled drills and exercises to broaden the experience base of the emergency organization. The goal is to achieve maximum participation of ERO personnel in drills.

A written examination is used as a means for an individual to demonstrate knowledge in a given area. Written examinations are administered, as prescribed by procedure, to supplement portions of the initial training and annual retraining.

2.0 TRAINING FOR OTHER ANO EMERGENCY RESPONSE GROUPS Training for other ANO Emergency Response groups is described as follows:

2.1 FIRE BRIGADE The Fire Brigade consists of members of the Operations staff who are assigned to shift crews.

Fire Brigade members receive initial training and at least quarterly retraining on fire fighting techniques. The training program includes classroom training, field training, and drills. Training covers the chemistry of fire, basic fire fighting techniques, fire hazards, and methods of reporting fires. Detailed training is outlined in the ANO training procedures.

2.2 REPAIR AND DAMAGE CONTROL TEAM The Repair and Damage Control team typically consists of a combination of individuals from the following groups: Radiation Protection, Operations, Maintenance (Electrical, I&C, or Mechanical),

and First Aid and Rescue Personnel.

These individuals receive training concerning: (1) radiation protection; (2) the location of the assembly area following a plant evacuation announcement; and (3) their particular craft.

Revision 45 O-2

ARKANSAS NUCLEAR ONE EMERGENCY PLAN 2.3 SECURITY PERSONNEL Security personnel training is administered by the Security Training Program. The EOI Integrated Security Training and Qualification Plan describes the security personnel training requirements.

2.4 FIRST AID AND RESCUE PERSONNEL All plant personnel responsible for responding to an emergency situation involving personal injury receive rescue training and first aid training. The first aid training meets or exceeds the Red Cross Multi-Media course. Personnel with first aid responsibilities receive initial training and at least annual retraining.

3.0 LOCAL SERVICES PERSONNEL TRAINING Training for local services personnel, includes but is not necessarily limited to, procedures for notification and, where applicable, site access procedures and the identity of the individuals in the Emergency Response Organization who coordinate the local services groups' activities. Changes to the Emergency Plan are transmitted to all local groups.

Radiological orientation training is made available to the following local services personnel.

3.1 LOCAL EMERGENCY SERVICES PERSONNEL 3.1.1 Local Fire Department Initial and annual retraining is provided to Local Fire Department personnel concerning site specific emergency response. This training includes procedures for notification, basic radiation protection, site access procedures and emergency response functions.

3.1.2 Pope County Emergency Medical Service Initial training and annual retraining are provided to the Pope County Emergency Medical Service personnel concerning site specific emergency response. This training includes procedures for notification, basic radiation protection, site access procedures and emergency response functions.

3.1.3 Miscellaneous Personnel A radiological training program is made available by the State of Arkansas in support of offsite planning requirements to miscellaneous local emergency services personnel (i.e., ADEM, local law enforcement agencies, volunteers, etc.)

3.2 MEDICAL SUPPORT PERSONNEL 3.2.1 Saint Marys Regional Medical Center Personnel Saint Marys Regional Medical Center personnel who may be involved in response to an emergency at ANO receive initial training and periodic retraining by Arkansas Department of Health personnel on how to deal with radiation accident cases.

Revision 45 O-3

ARKANSAS NUCLEAR ONE EMERGENCY PLAN 3.2.2 Medical Services Personnel Local physicians supporting Arkansas Nuclear One have received training in the treatment of patients that are contaminated and/or over exposed to radiation. Refresher training for these physicians is made available periodically.

4.0 GENERAL EMPLOYEE TRAINING Personnel are given initial orientation in the basic principles of radiological safety including the effects of radiation and, as appropriate, the use of protective clothing, equipment, and devices.

Emergency training sufficient for proper evacuation is given to all individuals receiving training for unescorted access into the plant. The training includes the method of notification (plant evacuation alarm) and instructions on how to evacuate the site. Initial training and annual retraining is conducted in general employee training sessions.

5.0 TRAINING EVALUATION To assure the continued quality of emergency response training, training conducted for emergency response personnel is maintained and improved by monitoring various indicators of training effectiveness. Emergency response training is evaluated using the following indicators:

Trainee examination/workbook scores.

Emergency Planning inspection and audit reports.

Training Evaluation/Action Requests.

Trainee feedback through critiques of training.

Training Review Groups (TRG)

Revision 45 O-4

ARKANSAS NUCLEAR ONE EMERGENCY PLAN P RESPONSIBILITY FOR THE PLANNING EFFORT: DEVELOPMENT, PERIODIC REVIEW, AND DISTRIBUTION 1.0 RESPONSIBILITY FOR RADIOLOGICAL EMERGENCY RESPONSE PLANNING The Site Vice President has overall responsibility and authority for radiological emergency planning. Under the direction of the organization shown in Figure P-1, the Emergency Planners are responsible for the development and updating of the Emergency Plan and Implementing Procedures and coordination with other response organizations for the implementation of the Emergency Plan. Responsibilities and authorities of the Emergency Planners include, but are not limited to:

initiation of changes to the Emergency Plan and the Emergency Plan Implementing Procedures; ensuring implementation of changes to the Emergency Plan and the Emergency Plan Implementing Procedures; initiation of unannounced drills; ensuring scheduling of training, drills, and exercises; evaluation of effectiveness of exercises and recommends enhancements; interfacing with local, State, and Federal agencies regarding emergency preparedness; and providing ANO management with timely information regarding the status of emergency preparedness.

2.0 REVIEW AND UPDATE OF THE EMERGENCY PLAN AND IMPLEMENTING PROCEDURES The Emergency Plan and Implementing Procedure review, approval and distribution process is described in the Emergency Plan Implementing Procedures.

Notification lists, rosters, and emergency equipment lists are updated, as necessary. Revisions of the Emergency Plan and the Emergency Plan Implementing Procedures, including notification lists, are distributed to holders of these documents to ensure that their procedures are maintained current. Records are maintained as required in the Technical Specifications.

Whenever exercises or drills are conducted, the Emergency Plan and the Emergency Plan Implementing Procedures are evaluated against the results and revised, if necessary.

The Emergency Plan and the Emergency Plan Implementing Procedures shall be reviewed and audited on a frequency that complies with the requirements of 10 CFR 50.54(t)(1) by persons who have no direct responsibility for implementation of the emergency preparedness program to verify that emergency planning requirements and commitments are being met. Normally, this review is conducted by ANO Nuclear Independent Oversight personnel.

Revision 45 P-1

ARKANSAS NUCLEAR ONE EMERGENCY PLAN The results of the review and audit, along with recommendations for improvements, are documented and reported to both corporate and plant management; and the Safety Review Committee. These records are retained for a period of at least five years. Included in the audit is a program review of the elements of 10 CFR 50.54(t)(2). The part of the review and audit involving the adequacy of interface with State and local governments is available to the appropriate State and local governments.

Letters of agreement for support with local, State, and Federal agencies are reviewed annually and updated as appropriate at least every two years.

The emergency action levels listed in Section D of the ANO Emergency Plan are reviewed with the State and local governmental authorities on an annual basis.

3.0 UPDATE OF EMERGENCY TELEPHONE NUMBERS Emergency telephone numbers are verified on a quarterly basis in accordance with Emergency Plan Implementing Procedures. Any changes in phone numbers or organizations are documented, and a revision to the Emergency Telephone Directory (and, as appropriate, any Emergency Plan Implementing Procedures) are generated and distributed.

4.0 TRAINING OF PERSONNEL RESPONSIBLE FOR THE PLANNING EFFORT The Emergency Planning staff receives training in accordance with ANO training procedures.

Revision 45 P-2

ARKANSAS NUCLEAR ONE EMERGENCY PLAN FIGURE P-1 EMERGENCY PLANNING ORGANIZATION Site Vice President

- ANO Director, Regulatory

& Performance Improvement Manager, Emergency Planning Emergency Planners Revision 45 P-3

ARKANSAS NUCLEAR ONE EMERGENCY PLAN APPENDIX 1 LETTERS OF AGREEMENT WITH SUPPORTING ORGANIZATIONS

ARKANSAS NUCLEAR ONE EMERGENCY PLAN TABLE OF CONTENTS LETTERS OF AGREEMENT WITH SUPPORTING ORGANIZATIONS U.S. Department of Energy, Oak Ridge Operations .................................................................. 1-1 Arkansas Department of Emergency Management ................................................................... 1-1 Arkansas Department of Health ................................................................................................. 1-1 Johnson County, Arkansas ........................................................................................................ 1-1 Johnson County Sheriff's Office ................................................................................................. 1-1 Logan County, Arkansas............................................................................................................ 1-2 Logan County Sheriff's Office .................................................................................................... 1-2 Pope County, Arkansas ............................................................................................................. 1-2 Pope County Sheriff's Office ...................................................................................................... 1-2 Yell County, Arkansas ................................................................................................................ 1-3 Yell County Sheriff's Office ........................................................................................................ 1-3 Conway County, Arkansas ......................................................................................................... 1-3 University of Arkansas Medical Sciences - Hospital .................................................................. 1-3 Saint Mary's Regional Medical Center ....................................................................................... 1-3 Pope County Emergency Medical Service ................................................................................. 1-3 Local Fire Department ............................................................................................................... 1-4 Institute of Nuclear Power Operations (INPO) ........................................................................... 1-4 Monfee Medical Clinic ................................................................................................................ 1-4 ATU Radio Station KXRJ ........................................................................................................... 1-4 Arkansas Valley Electric Cooperative, Inc. ................................................................................ 1-4 National Weather Service. ......................................................................................................... 1-5 Revision 45 1-i

ARKANSAS NUCLEAR ONE EMERGENCY PLAN The Letters of Agreement describes the arrangements for requesting and effectively using the resources of Federal, State, Local response organizations and offsite radiological analysis facilities. The mutual agreements in regard to the accommodation of State and Local staffs are also addressed. Listed below are brief descriptions of these agreements.

1. U.S. Department of Energy - The U.S. Department of Energy, by Letter of Agreement, is responsible for coordination of all efforts by Federal agencies in offsite radiological monitoring, assessment, evaluation and reporting during the initial phases of a radiological incident.

2. Arkansas Department of Emergency Management - The Arkansas Department of Emergency Management, by Letter of Agreement, is responsible for the coordination of offsite emergency response and recovery efforts of state, county and municipal agencies and departments. They also assure mutual coordination with the Arkansas Department of Health concerning an incident at Arkansas Nuclear One. The potential nature of some emergencies may warrant the utilization of offsite individuals, organizations, and agencies. As a result, arrangements have been made with offsite groups to provide on-site aid in the event of an emergency situation, including those resulting from hostile actions at ANO. In relation to support provided for hostile actions, ANOs Letter of Agreement with the Arkansas Department of Emergency Management (ADEM) will encompass the necessary support that will be provided by State agencies through the EOC as deemed necessary. The Arkansas Comprehensive Emergency Management Plan, describes the support and the agencies that will respond to terroristic threats. This letter of agreement with ADEM encompasses law enforcement and logistical needs at ANO in response to a hostile action situation.

3. Arkansas Department of Health - The Arkansas Department of Health, by Letter of Agreement, provides 1) personnel and equipment to the Radiological Response Team,

2) coordinates with ANOs Radiological Assessment Coordinator or designee, for sharing information regarding monitoring, decontamination, 3) determination of magnitude of release and radiation levels, 4) dose assessment in the event of an incident at ANO. They also provide for the notification and warning of the Arkansas Department of Emergency Management (ADEM), local government and the general public in affected areas.

4. Johnson County, Arkansas - Johnson County, Arkansas, by Letter of Agreement, carries out protective actions as determined by the Arkansas Department of Health and provides the following emergency actions, through the Johnson County Office of Emergency Management: 1) activating the Johnson County Operations Center, 2) Notifying appropriate local agencies/organizations as specified in the Johnson County Radiological Emergency Response Plan, 3) Establish communications with the Technical Operations Control Center,

4) coordinating local and state support, 5) preparing and submitting required reports to include a detailed after action report, 6) conducting exercises at the frequency required by appropriate Federal guidelines to test adequacy of plans and updating plans at least yearly.

Revision 45 1-1

ARKANSAS NUCLEAR ONE EMERGENCY PLAN

5. Johnson County Sheriffs Office - Johnson County Sheriffs Office, by Letter of Agreement, agrees to the following: 1) authenticate the notification in accordance with standard procedures, 2) Notify appropriate local agencies/organizations as specified in the Johnson County Radiological Emergency Response Plan, 3) Assist in the warning of Johnson County citizens within the 10-mile EPZ, 4) provide traffic control outside of municipalities in Johnson County within the 10-mile EPZ, placing special emphasis on all critical points such as road junctions, channeled traffic areas and accident sites, 5) Coordinate with the Arkansas State Police in establishing road blocks within Johnson County on roadways at the outer boundary of the 10-mile EPZ, 6) coordinate with the Arkansas State Police and Transportation Department to establish detour routes around the Emergency Planning Zone within Johnson County, 7) provide security of affected areas outside of municipalities within Johnson County,

8) coordinate communication assets with other county agencies and provide backup communications.

6. Logan County, Arkansas - Logan County, Arkansas, by Letter of Agreement, carries out protective actions as determined by the Arkansas Department of Health and provides the following emergency actions, through the Logan County Office of Emergency Management:

1) activating the Logan County Operations Center, 2) Notifying appropriate local agencies/organizations as specified in the Logan County Radiological Emergency Response Plan, 3) Establish communications with the Technical Operations Control Center, 4) coordinating local and state support, 5) preparing and submitting required reports to include a detailed after action report, 6) conducting exercises at the frequency required by appropriate Federal guidelines to test adequacy of plans and updating plans at least yearly.

7. Logan County Sheriffs Office - The Logan County Sheriffs Office, by Letter of Agreement, agrees to the following: 1) authenticate the notification in accordance with standard procedures, 2) Notify appropriate local agencies/organizations as specified in the Logan County Radiological Emergency Response Plan, 3) Assist in the warning of Logan County citizens within the 10-mile EPZ, 4) provide traffic control outside of municipalities in Logan County within the 10-mile EPZ, placing special emphasis on all critical points such as road junctions, channeled traffic areas and accident sites, 5) Coordinate with the Arkansas State Police in establishing road blocks within Logan County on roadways at the outer boundary of the 10-mile EPZ, 6) coordinate with the Arkansas State Police and Transportation Department to establish detour routes around the Emergency Planning Zone within Logan County, 7) provide security of affected areas outside of municipalities within Logan County,

8) coordinate communication assets with other county agencies and provide backup communications.

8. Pope County, Arkansas - Pope County, Arkansas, by Letter of Agreement, carries out protective actions as determined by the Arkansas Department of Health and provides the following emergency actions, through the Pope County Office of Emergency Management:

1) activating the Pope County Operations Center, 2) Notifying appropriate local agencies/organizations as specified in the Pope County Radiological Emergency Response Plan, 3) Establish communications with the Technical Operations Control Center,

4) coordinating local and state support, 5) preparing and submitting required reports to include a detailed after action report, 6) conducting exercises at the frequency required by appropriate Federal guidelines to test adequacy of plans and updating plans at least yearly.

9. Pope County Sheriffs Office - The Pope County Sheriffs Office, by Letter of Agreement, agrees to the following: 1) authenticate the notification in accordance with standard Revision 45 1-2

ARKANSAS NUCLEAR ONE EMERGENCY PLAN procedures, 2) Notify appropriate local agencies/organizations as specified in the Pope County Radiological Emergency Response Plan, 3) Assist in the warning of Pope County citizens within the 10-mile EPZ, 4) provide traffic control outside of municipalities in Pope County within the 10-mile EPZ, placing special emphasis on all critical points such as road junctions, channeled traffic areas and accident sites, 5) Coordinate with the Arkansas State Police in establishing road blocks within Pope County on roadways at the outer boundary of the 10-mile EPZ, 6) coordinate with the Arkansas State Police and Transportation Department to establish detour routes around the Emergency Planning Zone within Pope County, 7) provide security of affected areas outside of municipalities within Pope County,

8) coordinate communication assets with other county agencies and provide backup communications.

10. Yell County, Arkansas - Yell County, Arkansas, by Letter of Agreement, carries out protective actions as determined by the Arkansas Department of Health and provides the following emergency actions, through the Yell County Office of Emergency Management: 1) activating the Yell County Operations Center, 2) Notifying appropriate local agencies/organizations as specified in the Yell County Radiological Emergency Response Plan, 3) Establish communications with the Technical Operations Control Center, 4) coordinating local and state support, 5) preparing and submitting required reports to include a detailed after action report, 6) conducting exercises at the frequency required by appropriate Federal guidelines to test adequacy of plans and updating plans at least yearly.

11. Yell County Sheriffs Office - The Yell County Sheriffs Office, by Letter of Agreement, agrees to the following: 1) authenticate the notification in accordance with standard procedures, 2)

Notify appropriate local agencies/organizations as specified in the Yell County Radiological Emergency Response Plan, 3) Assist in the warning of Yell County citizens within the 10-mile EPZ, 4) provide traffic control outside of municipalities in Yell County within the 10-mile EPZ, placing special emphasis on all critical points such as road junctions, channeled traffic areas and accident sites, 5) Coordinate with the Arkansas State Police in establishing road blocks within Yell County on roadways at the outer boundary of the 10-mile EPZ, 6) coordinate with the Arkansas State Police and Transportation Department to establish detour routes around the Emergency Planning Zone within Yell County, 7) provide security of affected areas outside of municipalities within Yell County, 8) coordinate communication assets with other county agencies and provide backup communications.

12. Conway County, Arkansas - Conway County, Arkansas, by Letter of Agreement, carries out protective actions as determined by the Arkansas Department of Health and provides the following emergency actions, through the Conway County Office of Emergency Management: 1) activating the Conway County Operations Center, 2) Notifying appropriate local agencies/organizations as specified in the Conway County Radiological Emergency Response Plan, 3) Establish communications with the Technical Operations Control Center,

4) coordinating local and state support, 5) preparing and submitting required reports to include a detailed after action report, 6) conducting exercises at the frequency required by appropriate Federal guidelines to test adequacy of plans and updating plans at least yearly.

13. University of Arkansas Medical Sciences Hospital - The University of Arkansas Medical Sciences Hospital, by Letter of Agreement, agrees to plan, respond and assist with respect to medical treatment of injured personnel who may be radiologically contaminated or overexposed as a result of an incident at the Arkansas Nuclear One facility.

Revision 45 1-3

ARKANSAS NUCLEAR ONE EMERGENCY PLAN

14. Saint Marys Regional Medical Center - Saint Marys Regional Medical Center, by Letter of Agreement, agrees to plan, respond and assist with respect to medical treatment of injured personnel who may be radiologically contaminated or overexposed as a result of an incident at the Arkansas Nuclear One facility.

15. Pope County Emergency Medical Service - The Pope County Emergency Medical Service, by Letter of Agreement, agrees to plan, respond and assist with respect to potential or actual radiological incidents at the Arkansas Nuclear One facility.

16. Local Fire Department - The Local Fire Department, by Letter of Agreement, agrees to provide personnel and equipment as required to assist the ANO Fire Brigade in extinguishing fires located at the ANO site, includes both inside and outside the protected area.

17. INPO - INPO, by Letter of Agreement, will provide assistance in acquiring the help of other organizations in the industry. This will include: 1) Facilitating technical information flow from the affected utility to the nuclear industry, 2) locate replacement equipment and personnel with technical expertise, 3) obtain technical information and industry experience regarding plant components and systems, 4) Provide an INPO liaison to facilitate interface.

18. Monfee Medical Clinic - Monfee Medical Clinic, by Letter of Agreement, agrees to furnish the following services at either Arkansas Nuclear One or at Monfee Medical Clinic: 1) Outage physical examinations, 2) other physical examinations, 3) ANO Emergency Plan coverage,

4) fitness-for-duty/Medical Review Officer support, and 5) other services as deemed necessary from time to time.

19. ATU Radio Station KXRJ - Arkansas Tech University (ATU), by Letter of Agreement, agrees to allow remote access of its transmitter for the purpose of transmitting emergency information and instructions to the public.

20. Arkansas Valley Electric Cooperative, Inc. - Arkansas Valley Electric Cooperative, Inc., by letter of agreement, agrees to provide a list of new customers within the ANO 10-mile EPZ.

21. National Weather Service - The National Weather Service, by Letter of Agreement, will operate the NOAA Weather Radio System for the Arkansas River Valley area and agrees to broadcast emergency messages related to Arkansas Nuclear One.

Revision 45 1-4

ARKANSAS NUCLEAR ONE EMERGENCY PLAN APPENDIX 2 EMERGENCY INSTRUCTIONS:

POPE, YELL, LOGAN AND JOHNSON COUNTIES THIS APPENDIX HAS BEEN DELETED

ARKANSAS NUCLEAR ONE EMERGENCY PLAN APPENDIX 3 EMERGENCY PLAN IMPLEMENTING PROCEDURES

ARKANSAS NUCLEAR ONE EMERGENCY PLAN APPENDIX 3 EMERGENCY PLAN IMPLEMENTING PROCEDURES*

1903.XXX Series 1903.001 Organization and Use of Emergency Plan Implementing Procedures 1903.004 Administration and Maintenance of the Emergency Plan and Implementing Procedures 1903.010 Emergency Action Level Classification 1903.011 Emergency Response/Notifications 1903.021 Natural Gas Line Rupture 1903.023 Personnel Emergency 1903.030 Evacuation 1903.033 Protective Action Guidelines for Rescue/Repair and Damage Control Teams 1903.042 Duties of the Emergency Medical Team 1903.043 Duties of the Emergency Radiation Team 1903.053 Logistical Support 1903.060 Emergency Supplies and Equipment 1903.062 Communications System Operating Procedure 1903.064 Emergency Response Facility - Control Room 1903.068 Emergency Response Facility - Joint Information Center (JIC) 1903.069 Equipment Important to Emergency Preparedness 1903.079 Incident Command Post (ICP) 1903.080 Emergency Operations Facility (EOF) Activation 1903.081 Technical Support Center (TSC) Activation 1903.082 Operational Support Center (OSC) Activation 1904.XXX Series 1904.002 Offsite Dose Projections 1905.XXX Series 1905.001 Emergency Radiological Controls 1905.002 Offsite Emergency Monitoring 1905.003 Radiological Protection Requirements for Post-Accident Sampling of Reactor Coolant 1905.004 EOF Radiological Controls 1905.031 Airborne I-131 Determination Using a Frisker Revision 45 3-1

ARKANSAS NUCLEAR ONE EMERGENCY PLAN EN-EP-XXX Series EN-EP-301 Emergency Planning Assessment of Offsite Emergency Response Capability Following a Natural Disaster EN-EP-305 Emergency Planning 10CFR50.54(Q) Review Program EN-EP-306 Drills and Exercises EN-EP-307 Hostile Action Based Drills & Exercises EN-EP-308 Emergency Planning Critiques EN-EP-310 Emergency Response Organization Notification System EN-EP-311 Emergency Response Data System (ERDS) Activation via the Virtual Private Network (VPN)

EN-EP-313 Offsite Dose Assessment using the Unified RASCAL Interface EN-EP-609 Emergency Operations Facility (EOF) Operations EN-EP-610 Technical Support Center (TSC) Operations EN-EP-611 Operational Support Center (OSC) Operations EN-EP-613 Recovery from a Declared Emergency EN-EP-801 Emergency Response Organization EN-EP-900 Emergency Preparedness Forms

• For a description of the contents of a procedure and a cross-reference to the Emergency Plan, refer to Procedure 1903.001, "Organization and Use of Emergency Plan Implementing Procedures."

Revision 45 3-2

ARKANSAS NUCLEAR ONE EMERGENCY PLAN APPENDIX 4 EMERGENCY SUPPLIES AND EQUIPMENT

ARKANSAS NUCLEAR ONE EMERGENCY PLAN TABLE OF CONTENTS Table No. Title 4A Control Room Kit 4B Onsite Radiological Monitoring Kit 4C Technical Support Center Kit 4D Primary Access Point Kit 4E Emergency Operations Facility Kit 4F Field Monitoring Kits 4G Hospital Kit 4H Nurse's Station 4I Joint Information Center Kit Revision 45 4-i

ARKANSAS NUCLEAR ONE EMERGENCY PLAN TABLE 4A CONTROL ROOM SURVEY INSTRUMENTS SAMPLING SUPPLIES PERSONNEL MONITORING EQUIPMENT RESPIRATORY PROTECTION EQUIPMENT PROTECTIVE CLOTHING POSTING MATERIALS BATTERIES EMERGENCY TELEPHONE DIRECTORY MISCELLANEOUS TABLE 4B ONSITE RADIOLOGICAL MONITORING KIT SURVEY INSTRUMENTS SAMPLING SUPPLIES PERSONNEL MONITORING EQUIPMENT RESPIRATORY PROTECTION EQUIPMENT PROTECTIVE CLOTHING POSTING MATERIALS BATTERIES KI TABLETS MISCELLANEOUS TABLE 4C ONSITE TECHNICAL SUPPORT CENTER KIT SURVEY INSTRUMENTS PERSONNEL MONITORING EQUIPMENT BATTERIES MISCELLANEOUS KI TABLETS Revision 45 4-1

ARKANSAS NUCLEAR ONE EMERGENCY PLAN TABLE 4D PRIMARY ACCESS POINT KIT EVACUATION EQUIPMENT MISCELLANEOUS TABLE 4E EMERGENCY OPERATIONS FACILITY KIT SURVEY INSTRUMENTS SAMPLING SUPPLIES PERSONNEL MONITORING EQUIPMENT RESPIRATORY PROTECTION EQUIPMENT PROTECTIVE CLOTHING POSTING MATERIALS PERSONNEL DECONTAMINATION SUPPLIES BATTERIES KI TABLETS MISCELLANEOUS TABLE 4F FIELD MONITORING KIT*

RADIOLOGICAL SURVEY INSTRUMENTS SAMPLING SUPPLIES PERSONNEL MONITORING EQUIPMENT PROTECTIVE CLOTHING BATTERIES SURVEY MAPS KI TABLETS MISCELLANEOUS

• A detailed listing of equipment contained within each kit and the number of kits is shown in Emergency Plan Implementing Procedures.

Revision 45 4-2

ARKANSAS NUCLEAR ONE EMERGENCY PLAN TABLE 4G HOSPITAL KIT SURVEY INSTRUMENTS SAMPLING SUPPLIES

• PERSONNEL MONITORING EQUIPMENT PROTECTIVE CLOTHING

• PERSONNEL DECONTAMINATION SUPPLIES POSTING MATERIALS BATTERIES MISCELLANEOUS TABLE 4H NURSES STATION FURNISHINGS MEDICAL SUPPLIES AND EQUIPMENT DRUGS TABLE 4I JOINT INFORMATION CENTER KIT MEDIA INFORMATION PACKETS NEWS CONFERENCE SUPPLIES CLERICAL SUPPLIES MISCELLANEOUS

• St. Marys kit only Revision 45 4-3

ARKANSAS NUCLEAR ONE EMERGENCY PLAN APPENDIX 5 EVACUATION TIME ESTIMATE FOR ARKANSAS NUCLEAR ONE The complete Evacuation Time Estimate Study can be obtained from Emergency Planning.

ARKANSAS NUCLEAR ONE EMERGENCY PLAN APPENDIX 6 EMERGENCY MESSAGES

ARKANSAS NUCLEAR ONE EMERGENCY PLAN TABLE OF CONTENTS

1. Public Notification Message Form - Message "E" - Evacuation ...................................... 6-1

2. Public Notification Message Form - Message "S-I" - Stay Indoors ................................. 6-4

3. Public Notification Message Form - Message "S" - Sheltering ........................................ 6-6

4. Public Notification Message Form - Message "PSA" - Public Situation Advisory ............ 6-8

5. Public Notification Message Form - Message "SSA" - School Situation Advisory ........... 6-9

6. Public Notification Message Form - Message AA Agricultural Advisory (10 Mile Emergency Planning Zone) ............................................................................. 6-10

7. Public Notification Message Form - Message AA Agricultural Advisory (50 Mile Emergency Planning Zone) ............................................................................. 6-12 Revision 45 6-1

ARKANSAS NUCLEAR ONE EMERGENCY PLAN Public Notification Message MESSAGE E - EVACUATION MESSAGE NUMBER: DATE: TIME:

• READ MESSAGE CAREFULLY*

An/A (1) has been declared at Arkansas Nuclear One by officials of Entergy Operations Incorporated. The Arkansas Department of Health, and local officials, have recommended the EVACUATION of the following zones:

(2) ZONE "G" - the area within approximately two miles of Arkansas Nuclear One.

This includes Lake Dardanelle, the ANO peninsula, Mill Creek, 40 Acre Rock and London Communities. Residents of this zone should proceed to the designated reception center at Hector High School.

(3) ZONE "H" - Russellville residents west of Arkansas Avenue and south of I-40.

This includes Norristown and the Dardanelle State Park area. Residents in this zone should proceed to the designated reception center at Morrilton Junior High School.

(4) ZONE "I" - Russellville residents south of I-40 and east of Arkansas Avenue.

This includes the South New Hope Community. Residents in this zone should proceed to the designated reception center at Morrilton Junior High School.

(5) ZONE "J" - Pope county residents north of I-40, south of Bakers Creek and east of the Illinois Bayou. Residents in this zone should proceed to the designated reception center at Morrilton Junior High School.

(6) ZONE "K" - Pope County residents north of Highway 64, west of the Illinois Bayou, east and south of Highway 333, and south of county road 79 (also known as Shinn Mountain Road) and county road 141 (also known as Lower Shinn Mountain Road). Residents in this zone should proceed to the designated reception center at Hector High School.

(7) ZONE "L" - Pope County residents east of the Illinois Bayou and north of Bakers Creek. This includes Dover and the Linker Mountain Community. Residents in this zone should proceed to the designated reception center at Hector High School.

Form 11003 (typical) 11/06 Revision 45 6-2

ARKANSAS NUCLEAR ONE EMERGENCY PLAN Public Notification Message MESSAGE E - EVACUATION (8) ZONE "M" - Pope County residents north of Hickeytown Road, east of Highway 333 and north of county road 79 (also known as Shinn Mountain Road) and county road 141 (also known as Lower Shinn Mountain Road). This includes the Augsburg, Rushing and North New Hope Communities. Residents in this zone should proceed to the designated reception center at Hector High School.

(9) ZONE "N" - Pope County residents south of Hickeytown Road, west of Highway 333 and north of Lake Dardanelle. Residents in this zone should proceed to the designated reception center at Hector High School.

(10) ZONE "O" - Johnson County residents east of Highway 359 and south of Flat Rock Creek. Residents in this zone should proceed to the designated reception center at Clarksville High School.

(11) ZONE "P" - Johnson County residents north of Flat Rock Creek and west of Highway 359. This includes the Piney, Piney Bay, Knoxville and Hickeytown Communities. Residents in this zone should proceed to the designated reception center at Clarksville High School.

(12) ZONE "Q" - Logan County residents residing between Delaware and New Blaine.

This includes the New Liberty, West River Mountain and Nichols Lane area.

Residents in this zone should proceed to the designated reception center at Paris High School.

(13) ZONE "R" - Logan County residents within an area approximately two miles west of the Logan - Yell county line. This includes Wildcat Hollow, Delaware, Delaware Use Area, River Mountain Road east of Flurry Road and Highway 22 east of Johnson Lane. Residents in this zone should proceed to the designated reception center at Paris High School.

(14) ZONE "S" - Yell County residents who reside south of Mt. Nebo Road and west of the Dardanelle city limits. This includes the Slo Fork and Sulphur Springs areas. Residents in this zone should proceed to the designated reception center at Danville High School.

(15) ZONE "T" - All residents of the city of Dardanelle. Residents in this zone should proceed to the designated reception center at Danville High School.

Form 11003 (typical) 11/06 Revision 45 6-3

ARKANSAS NUCLEAR ONE EMERGENCY PLAN Public Notification Message MESSAGE E - EVACUATION (16) ZONE "U" - Yell County residents who reside north of the Mt. Nebo Road and west of the Dardanelle City limits. This includes Mt. Nebo, Haney Hollow, Wildcat Hollow in Yell County and the Lake Dardanelle State Park area. Residents in this zone should proceed to the designated reception center at Danville High School.

If you live in an area currently being evacuated, consult your Emergency Instructions for evacuation routes and detailed instructions. Please avoid using your telephone at this time if possible. All telephone circuits in the area will be needed by emergency workers and overtaxing the facilities could add to the confusion and cause delays. However, if you have urgent concerns or questions you may call 968-7171. Emergency information you will need will be provided by this station. Please stay tuned.

MESSAGE RECEIVER: OPERATOR ON AIR:

TIME(S) TRANSMITTED:

Form 11003 (typical) 11/06 Revision 45 6-4

ARKANSAS NUCLEAR ONE EMERGENCY PLAN Public Notification Message MESSAGE S-I - STAY INDOORS MESSAGE NUMBER: DATE: TIME:

• READ MESSAGE CAREFULLY*

• READ MESSAGE CAREFULLY*An/A (1) has been declared at Arkansas Nuclear One by officials of Entergy Operations Incorporated. The Arkansas Department of Health and local officials have recommended that residents of the following zones stay indoors until further notice:

(2) ZONE "G" - the area within approximately two miles of Arkansas Nuclear One.

This includes Lake Dardanelle, the ANO peninsula, Mill Creek, 40 Acre Rock and London Communities.

(3) ZONE "H" - Russellville residents west of Arkansas Avenue and south of I-40.

This includes Norristown and the Dardanelle State Park area.

(4) ZONE "I" - Russellville residents south of I-40 and east of Arkansas Avenue.

This includes the South New Hope Community.

(5) ZONE "J" - Pope county residents north of I-40, south of Bakers Creek and east of the Illinois Bayou.

(6) ZONE "K" - Pope County residents north of Highway 64, west of the Illinois Bayou, east and south of Highway 333, and south of county road 79 (also known as Shinn Mountain Road) and county road 141 (also known as Lower Shinn Mountain Road).

(7) ZONE "L" - Pope County residents east of the Illinois Bayou and north of Bakers Creek. This includes Dover and the Linker Mountain Community.

(8) ZONE "M" - Pope County residents north of Hickeytown Road, east of Highway 333 and north of county road 79 (also known as Shinn Mountain Road) and county road 141 (also known as Lower Shinn Mountain Road). This includes the Augsburg, Rushing and North New Hope Communities.

(9) ZONE "N" - Pope County residents south of Hickeytown Road, west of Highway 333 and north of Lake Dardanelle.

Form 110010 (typical) 6/08 Revision 45 6-5

ARKANSAS NUCLEAR ONE EMERGENCY PLAN (10) ZONE "O" - Johnson County residents east of Highway 359 and south of Flat Rock Creek.

(11) ZONE "P" - Johnson County residents north of Flat Rock Creek and west of Highway 359. This includes the Piney, Piney Bay, Knoxville and Hickeytown Communities.

(12) ZONE "Q" - Logan County residents residing between Delaware and New Blaine.

This includes the New Liberty, West River Mountain and Nichols Lane area.

(13) ZONE "R" - Logan County residents within an area approximately two miles west of the Logan - Yell county line. This includes Wildcat Hollow, Delaware, Delaware Use Area, River Mountain Road east of Flurry Road and Highway 22 east of Johnson Lane.

(14) ZONE "S" - Yell County residents who reside south of Mt. Nebo Road and west of the Dardanelle city limits. This includes the Slo Fork and Sulphur Springs areas.

(15) ZONE "T" - All residents of the city of Dardanelle.

(16) ZONE "U" - Yell County residents who reside north of the Mt. Nebo Road and west of the Dardanelle City limits. This includes Mt. Nebo, Haney Hollow, Wildcat Hollow in Yell County and the Lake Dardanelle State Park area.

If you live in one of these affected zones, remain indoors with windows and doors closed.

Please refer to your Emergency Instructions for additional information. Emergency information you will need will be provided by this station. Please stay tuned. However, if you have urgent concerns or questions you may call 968-7171.

MESSAGE RECEIVER: OPERATOR ON AIR:

TIME(S) TRANSMITTED:

Form 110010 (typical) 6/08 Revision 45 6-6

ARKANSAS NUCLEAR ONE EMERGENCY PLAN Public Notification Message MESSAGE S - SHELTERING MESSAGE NUMBER: DATE: TIME:

• READ MESSAGE CAREFULLY*An/A (1) has been declared at Arkansas Nuclear One by officials of Entergy Operations Incorporated. The Arkansas Department of Health and local officials have recommended the SHELTERING of the following zones:

(2) ZONE "G" - the area within approximately two miles of Arkansas Nuclear One.

This includes Lake Dardanelle, the ANO peninsula, Mill Creek, 40 Acre Rock and London Communities.

(3) ZONE "H" - Russellville residents west of Arkansas Avenue and south of I-40.

This includes Norristown and the Dardanelle State Park area.

(4) ZONE "I" - Russellville residents south of I-40 and east of Arkansas Avenue.

This includes the South New Hope Community.

(5) ZONE "J" - Pope county residents north of I-40, south of Bakers Creek and east of the Illinois Bayou.

(6) ZONE "K" - Pope County residents north of Highway 64, west of the Illinois Bayou, east and south of Highway 333, and south of county road 79 (also known as Shinn Mountain Road) and county road 141 (also known as Lower Shinn Mountain Road).

(7) ZONE "L" - Pope County residents east of the Illinois Bayou and north of Bakers Creek. This includes Dover and the Linker Mountain Community.

(8) ZONE "M" - Pope County residents north of Hickeytown Road, east of Highway 333 and north of county road 79 (also known as Shinn Mountain Road) and county road 141 (also known as Lower Shinn Mountain Road). This includes the Augsburg, Rushing and North New Hope Communities.

(9) ZONE "N" - Pope County residents south of Hickeytown Road, west of Highway 333 and north of Lake Dardanelle.

Form 11009 (typical) 1/08 Revision 45 6-7

ARKANSAS NUCLEAR ONE EMERGENCY PLAN (10) ZONE "O" - Johnson County residents east of Highway 359 and south of Flat Rock Creek.

(11) ZONE "P" - Johnson County residents north of Flat Rock Creek and west of Highway 359. This includes the Piney, Piney Bay, Knoxville and Hickeytown Communities.

(12) ZONE "Q" - Logan County residents residing between Delaware and New Blaine.

This includes the New Liberty, West River Mountain and Nichols Lane area.

(13) ZONE "R" - Logan County residents within an area approximately two miles west of the Logan - Yell county line. This includes Wildcat Hollow, Delaware, Delaware Use Area, River Mountain Road east of Flurry Road and Highway 22 east of Johnson Lane.

(14) ZONE "S" - Yell County residents who reside south of Mt. Nebo Road and west of the Dardanelle city limits. This includes the Slo Fork and Sulphur Springs areas.

(15) ZONE "T" - All residents of the city of Dardanelle.

(16) ZONE "U" - Yell County residents who reside north of the Mt. Nebo Road and west of the Dardanelle City limits. This includes Mt. Nebo, Haney Hollow, Wildcat Hollow in Yell County and the Lake Dardanelle State Park area.

If you live in an area currently being sheltered, consult your Emergency Instructions. Remain indoors with windows and doors closed and ventilation turned off. When traveling, keep your automobile windows rolled up. If you have an auto air conditioner, turn it to the maximum setting during hot weather. Emergency information you will need will be provided by this station.

Please stay tuned. However, if you have urgent concerns or questions you may call 968-7171.

MESSAGE RECEIVER: OPERATOR ON AIR:

TIME(S) TRANSMITTED:

Form 11009 (typical) 1/08 Revision 45 6-8

ARKANSAS NUCLEAR ONE EMERGENCY PLAN Public Notification Message MESSAGE PSA PUBLIC SITUATION ADVISORY MESSAGE NUMBER: DATE: TIME:

• READ MESSAGE CAREFULLY*

An/A has been declared at Arkansas Nuclear One by officials of Entergy Operations Incorporated. This emergency measure has been taken because of abnormal operating conditions which are affecting the level of safety within the plant and which could affect the level of safety in the immediate vicinity of the plant. Arkansas Department of Health and local officials advise there has been no release of radioactivity off-site, and there is no immediate danger to the public. Persons within a ten mile radius of the plant should stay tuned to their local radio station for further information. At this time, you should review your Emergency Instructions and be prepared to take emergency measures if advised to do so.

Avoid using your telephone if possible. All telephone circuits in the area will be needed by emergency workers and overtaxing these facilities could cause confusion and delay emergency activities. However, if you have urgent concerns or questions you may call 479-968-7171.

Emergency information you will need will be provided by this station. Please stay tuned to this station for further updates.

MESSAGE RECEIVER: OPERATOR ON AIR:

TIME(S) TRANSMITTED:

Form 11007 (typical) 6/08 Revision 45 6-9

ARKANSAS NUCLEAR ONE EMERGENCY PLAN Public Notification Message MESSAGE SSA - SCHOOL SITUATION ADVISORY MESSAGE NUMBER: DATE: TIME:

A/An emergency has been declared at Arkansas Nuclear One by officials of Entergy Operations Incorporated. Because of this emergency condition the Arkansas Department of Health and local officials have recommended that children from some area schools be evacuated to their Designated Reception Centers. Area school administrators have implemented this recommendation. As a result, children from:

(1) have been taken to (2) have been taken to (3) have been taken to (4) have been taken to (5) have been taken to (6) have been taken to (7) have been taken to (8) have been taken to Parents should not attempt to pick up their children at school, but should proceed to their proper Designated Reception Center. However if you have urgent concerns or questions you may call 479-968-7171. Please stay tuned to this station for further updates, or other possible protective actions.

MESSAGE RECEIVER: OPERATOR ON AIR:

TIME(S) TRANSMITTED:

Form 11008 (typical) 6/08 Revision 45 6-10

ARKANSAS NUCLEAR ONE EMERGENCY PLAN Public Notification Message MESSAGE AA AGRICULTURAL ADVISORY (10 Mile Emergency Planning Zone)

MESSAGE NUMBER: DATE: TIME:

• READ MESSAGE CAREFULLY*

An/a has been declared at Arkansas Nuclear One by officials of Entergy Operations Incorporated. The Arkansas Department of Health, and local officials, have recommended the following agricultural protective actions:

(1) Place dairy cattle and milk producing livestock on stored feed and water.

(2) Place all livestock on stored feed and water.

(3) Wash and peel garden vegetables before eating.

(4) All agricultural products are impounded until further notice.

(5) Additional actions or comments:

These protective actions are effective immediately in the following zones within a ten mile radius of Arkansas Nuclear One:

(6) ZONE "G" - the area within approximately two miles of Arkansas Nuclear One.

This includes Lake Dardanelle, the ANO peninsula, Mill Creek, 40 Acre Rock and London Communities.

(7) ZONE "H" - Russellville residents west of Arkansas Avenue and south of I-40.

This includes Norristown and the Dardanelle State Park area.

(8) ZONE "I" - Russellville residents south of I-40 and east of Arkansas Avenue.

This includes the South New Hope Community.

(9) ZONE "J" - Pope county residents north of I-40, south of Bakers Creek and east of the Illinois Bayou.

Form 11004 (typical) 6/08 Revision 45 6-11

ARKANSAS NUCLEAR ONE EMERGENCY PLAN (10) ZONE "K" - Pope County residents north of Highway 64, west of the Illinois Bayou, east and south of Highway 333, and south of county road 79 (also known as Shinn Mountain Road) and county road 141 (also known as Lower Shinn Mountain Road).

(11) ZONE "L" - Pope County residents east of the Illinois Bayou and north of Bakers Creek. This includes Dover and the Linker Mountain Community.

(12) ZONE "M" - Pope County residents north of Hickeytown Road, east of Highway 333 and north of county road 79 (also known as Shinn Mountain Road) and county road 141 (also known as Lower Shinn Mountain Road). This includes the Augsburg, Rushing and North New Hope Communities.

(13) ZONE "N" - Pope County residents south of Hickeytown Road, west of Highway 333 and north of Lake Dardanelle.

(14) ZONE "O" - Johnson County residents east of Highway 359 and south of Flat Rock Creek.

(15) ZONE "P" - Johnson County residents north of Flat Rock Creek and west of Highway 359. This includes the Piney, Piney Bay, Knoxville and Hickeytown Communities.

(16) ZONE "Q" - Logan County residents residing between Delaware and New Blaine.

This includes the New Liberty, West River Mountain and Nichols Lane area.

(17) ZONE "R" - Logan County residents within an area approximately two miles west of the Logan - Yell county line. This includes Wildcat Hollow, Delaware, Delaware Use Area, River Mountain Road east of Flurry Road and Highway 22 east of Johnson Lane.

(18) ZONE "S" - Yell County residents who reside south of Mt. Nebo Road and west of the Dardanelle city limits. This includes the Slo Fork and Sulphur Springs areas.

(19) ZONE "T" - All residents of the city of Dardanelle.

(20) ZONE "U" - Yell County residents who reside north of the Mt. Nebo Road and west of the Dardanelle City limits. This includes Mt. Nebo, Haney Hollow, Wildcat Hollow in Yell County and the Lake Dardanelle State Park area.

Please stay tuned to this station for further information. However, if you have urgent concerns or questions, please refer to the Emergency Instructions or you may call 479-968-7171.

MESSAGE RECEIVER: OPERATOR ON AIR:

TIME(S) TRANSMITTED:

Form 11004 (typical) 6/08 Revision 45 6-12

ARKANSAS NUCLEAR ONE EMERGENCY PLAN Public Notification Message MESSAGE AA AGRICULTURAL ADVISORY (50 Mile Emergency Planning Zone)

MESSAGE NUMBER: DATE: TIME:

• READ MESSAGE CAREFULLY*

An/A has been declared at Arkansas Nuclear One by officials of Entergy Operations Incorporated. The Arkansas Department of Health has recommended the following agricultural protective actions (1) Place dairy cattle and milk producing livestock on stored feed and water.

(2) Place all livestock on stored feed and water.

(3) Wash and peel garden vegetables before eating.

(4) All agricultural products are impounded until further notice.

(5) Additional actions or comments:

These protective actions are effective immediately in an area lying (6) miles on either side of a line extending from (7) to (8)

For additional information, please consult your Emergency Instructions or you may call 479-968-7171.

MESSAGE RECEIVER: OPERATOR ON AIR:

TIME(S) TRANSMITTED:

Form 11005 (typical) 1/09 Revision 45 6-13

Attachment 3 to 0CAN012001 Summary of Changes to ANO Emergency Plan Implementing Document to 0CAN012001 Page 1 of 2

SUMMARY

OF CHANGES TO ANO EMERGENCY PLAN IMPLEMENTING DOCUMENT The following table provides a brief description or summary of changes made to an Arkansas Nuclear One (ANO) Emergency Plan implementing document included in Attachment 4 of this submittal. This summary includes changes completed in Revisions 58 and 59 of the subject procedure.

Each change is preceded by either "screen or "evaluation", indicating whether the change required a full evaluation in accordance with 10 CFR 50.54(q). Those not requiring a full evaluation are preceded by the term "screen". Note that editorial changes to the Table of Contents are made to support the changes described in the following summary table, where necessary. Table of Contents updates are not discussed further.

The following table lists changes incorporated in Revision 58 of the OP-1903.010. These changes are directly derived from changes made to the NRC-approved OP-1903.010, "Emergency Action Level Classification," basis document (ML18337A247) and, therefore, no 10 CFR 50.54(q) evaluation was required.

Procedure OP-1903.010, Revision 58, "Emergency Action Level Classification" Section Revised Description of Change (Screen) - The Emergency Action Level (EAL) Classification procedure is replaced in its entirety with that approved by the NRC in the update to Revision 6 of Nuclear Energy ALL Institute (NEI) 99-01, "Development of Emergency Action Levels for Non-Passive Reactors."

The following table includes the changes incorporated in Revision 59 of OP-1903.010.

Procedure OP-1903.010, Revision 59, "Emergency Action Level Classification" Section Revised Description of Change Change reference title on subject Radiological Effluent / Irradiated Fuel Event bases pages from "OP-1604.051, Eberline Radiation Monitor System" to "OP-1604.051, Ventilation Radiation Monitor System."

Pages 28, 33, 42, 49, 58 - This change corrected the title of procedure OP-1604.051 that was changed during the AU1.1, AA1.1, AS1.1, ANO Super Particulate Iodine and Noble Gas (SPING) modification. This does not AG1.1, AA2.2 change any equipment of the ANO EPlan and does not affect the activation and operation of the Emergency Response Facilities (ERFs) or the responsibility for classification, notification, dose assessment, or Protective Action Recommendations (PARs). The ability to maintain the EPlan is not affected by this change. No further evaluation is required for this change.

In loss of RCS Inventory related EALs, replaced "Reactor Drain Tank" with "Dirty Waste Drain Tank" and added tank identification (ID) reference (T-20A/B). Also added tank ID reference (T-11) to the Auxiliary Building Drain Tank listing and ID reference (T-42) to the Quench Tank listing.

Pages 71, 75, 79, 85 - This change provides a clarifying description by changing the Reactor Drain Tank to the Table 1C-1 Dirty Waste Drain Tank in ANO-1 and adds an identification number to each tank listed in the table. This does not change any equipment of the ANO EPlan and does not affect the activation and operation of the ERFs or the responsibility for classification, notification, dose assessment, or PARs. The ability to maintain the EPlan is not affected by this change. No further evaluation is required for this change.

to 0CAN012001 Page 2 of 2 Procedure OP-1903.010, Revision 59, "Emergency Action Level Classification" Section Revised Description of Change In loss of RCS Inventory related EALs, added tank ID reference (2T-56) to the Containment Sump listing, ID reference (2T-68) to the Reactor Drain Tank listing, and ID reference (2T-42) to the Quench Tank listing.

Pages 71, 75, 80, 86 - This change adds an identification number to each tank listed in the subject table. This Table 2C-1 does not change any equipment of the ANO EPlan and does not affect the activation and operation of the ERFs or the responsibility for classification, notification, dose assessment, or PARs. The ability to maintain the EPlan is not affected by this change.

No further evaluation is required for this change.

In the tables associated with AC power sources, changed "(backfed from main transformer)" to "(from 22 KV switchyard)".

Page 90 - Table 2C-3 This change provides a clarifying description to accurately reflect conditions that are Pages 202, 205 - monitored under these EALs. This does not change any equipment of the ANO EPlan Table 2S1 and does not affect the activation and operation of the ERFs or the responsibility for classification, notification, dose assessment, or PARs. The ability to maintain the EPlan is not affected by this change. No further evaluation is required for this change.

Added the word "required" to "Indicated voltage is < 105 VDC on required vital 125 VDC buses for 15 minutes".

This change adds a clarifying description (required) to accurately reflect what 125 VDC Page 100 - CU4.1 buses are monitored for this EAL. This does not change any equipment of the ANO EPlan and does not affect the activation and operation of the ERFs or the responsibility for classification, notification, dose assessment, or PARs. The ability to maintain the EPlan is not affected by this change. No further evaluation is required for this change.

Added reference" EP FAQ 2018-04" to the Hazardous Events CA6.1 and SA9.1 Bases.

The addition of this reference is considered an editorial change only. This does not Pages 106, 240 - CA6.1, change any equipment of the ANO EPlan and does not affect the activation and SA9.1 operation of the ERFs or the responsibility for classification, notification, dose assessment, or PARs. The ability to maintain the EPlan is not affected by this change.

No further evaluation is required for this change.

Attachment 4 to 0CAN012001 OP-1903.010, REVISION 59 Emergency Action Level Classification (243 pages)

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 1 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Table of Contents Section Page

1.0 INTRODUCTION

.................................................................................................................2 2.0 DISCUSSION ......................................................................................................................2 2.1 Background ................................................................................................................2 2.2 Fission Product Barriers .............................................................................................3 2.3 Fission Product Barrier Classification Criteria ............................................................3 2.4 EAL Organization .......................................................................................................4 2.5 Technical Basis Information .......................................................................................5 2.6 Operations Mode Applicability....................................................................................7 3.0 GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS ..........................................8 3.1 General Considerations .............................................................................................8 3.2 Classification Methodology ......................................................................................10

4.0 REFERENCES

..................................................................................................................13 4.1 Developmental .........................................................................................................13 4.2 Implementing............................................................................................................13 5.0 DEFINITIONS, ACRONYMS & ABBREVIATIONS ...........................................................13 5.1 Definitions (ref. 4.1.1 except as noted) ....................................................................13 5.2 Abbreviations/Acronyms ..........................................................................................18 6.0 ANO-TO-NEI 99-01 Rev. 6 EAL CROSS-REFERENCE ..................................................21 7.0 ATTACHMENTS ...............................................................................................................24 7.1 Attachment 1, Emergency Action Level Technical Bases ........................................24 Category A - Abnormal Rad Levels / Rad Effluents ................................................25 Category C - Cold Shutdown / Refueling System Malfunction ................................65 Category E - Independent Spent Fuel Storage Installation (ISFSI) .......................104 Category F - Fission Product Barrier Degradation ................................................107 Table 1[2]F-1, Fission Product Barrier Threshold Matrix & Bases ...114 Category H - Hazards and Other Conditions Affecting Plant Safety .....................158 Category S - System Malfunction ..........................................................................196 7.2 Attachment 2, Safe Operation & Shutdown Areas Tables 1[2]A-3 & 1[2]H-2 Bases .....................................................239

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 2 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059

1.0 INTRODUCTION

This document provides an explanation and rationale for each Emergency Action Level (EAL) included in the EAL Upgrade Project for Arkansas Nuclear One (ANO). It should be used to facilitate review of the ANO EALs and provide historical documentation for future reference.

Decision-makers responsible for implementation of 1903.010, Emergency Action Level Classification, may use this document as a technical reference in support of EAL interpretation.

This information may assist the Emergency Director in making classifications, particularly those involving judgment or multiple events. The basis information may also be useful in training and for explaining event classifications to off-site officials.

The expectation is that emergency classifications are to be made as soon as conditions are present and recognizable for the classification, but within 15 minutes or less in all cases when conditions are present and have been recognized. Use of this document for assistance is not intended to delay the emergency classification.

Because the information in a basis document can affect emergency classification decision-making (e.g., the Emergency Director refers to it during an event), the NRC staff expects that changes to the basis document will be evaluated in accordance with the provisions of 10 CFR 50.54(q).

2.0 DISCUSSION 2.1 Background EALs are the plant-specific indications, conditions or instrument readings that are utilized to classify emergency conditions defined in the ANO Emergency Plan.

In 1992, the NRC endorsed NUMARC/NESP-007 Methodology for Development of Emergency Action Levels as an alternative to NUREG-0654 EAL guidance.

NEI 99-01 (NUMARC/NESP-007) Revisions 4 and 5 were subsequently issued for industry implementation. Enhancements over earlier revisions included:

Consolidating the system malfunction initiating conditions and example emergency action levels which address conditions that may be postulated to occur during plant shutdown conditions.

Initiating conditions and example emergency action levels that fully address conditions that may be postulated to occur at permanently Defueled Stations and Independent Spent Fuel Storage Installations (ISFSIs).

Simplifying the fission product barrier EAL threshold for a Site Area Emergency.

Subsequently, Revision 6 of NEI 99-01 has been issued which incorporates resolutions to numerous implementation issues including the NRC EAL Frequently Asked Questions (FAQs).

Using NEI 99-01 Revision 6, "Methodology for the Development of Emergency Action Levels for Non-Passive Reactors, November 2012 (ref. 4.1.1), ANO conducted an EAL implementation upgrade project that produced the EALs discussed herein.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 3 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 2.2 Fission Product Barriers Fission product barrier thresholds represent threats to the defense in depth design concept that precludes the release of radioactive fission products to the environment. This concept relies on multiple physical barriers, any one of which, if maintained intact, precludes the release of significant amounts of radioactive fission products to the environment.

Many of the EALs derived from the NEI methodology are fission product barrier threshold based. That is, the conditions that define the EALs are based upon thresholds that represent the loss or potential loss of one or more of the three fission product barriers. Loss and Potential Loss signify the relative damage and threat of damage to the barrier. A Loss threshold means the barrier no longer assures containment of radioactive materials.

A Potential Loss threshold implies a greater probability of barrier loss and reduced certainty of maintaining the barrier.

The primary fission product barriers are:

A. Fuel Clad Barrier (FCB): The Fuel Clad Barrier consists of the cladding material that contains the fuel pellets.

B. Reactor Coolant System Barrier (RCB): The Reactor Coolant System Barrier includes the RCS primary side and its connections up to and including the pressurizer safety and relief valves, and other connections up to and including the primary isolation valves.

C. Containment Barrier (CNB): The Containment Barrier includes the Reactor Building and connections up to and including the outermost containment isolation valves. This barrier also includes the main steam, feedwater, and blowdown line extensions outside the Reactor Building up to and including the outermost secondary side isolation valve.

Containment Barrier thresholds are used as criteria for escalation of the Emergency Classification Level (ECL) from an Alert to a Site Area Emergency or a General Emergency.

2.3 Fission Product Barrier Classification Criteria The following criteria are the bases for event classification related to fission product barrier loss or potential loss:

Alert:

Any loss or any potential loss of either Fuel Clad or RCS Barrier Site Area Emergency:

Loss or potential loss of any two barriers General Emergency:

Loss of any two barriers and loss or potential loss of the third barrier

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 4 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 2.4 EAL Organization The ANO EAL scheme includes the following features:

Division of the EAL set into three broad groups:

o EALs applicable under any plant operating modes - This group would be reviewed by the EAL-user any time emergency classification is considered.

o EALs applicable only under hot operating modes - This group would only be reviewed by the EAL-user when the plant is in Hot Shutdown, Hot Standby, Startup, or Power Operation mode.

o EALs applicable only under cold operating modes - This group would only be reviewed by the EAL-user when the plant is in Cold Shutdown, Refueling or Defueled mode.

The purpose of the groups is to avoid review of hot condition EALs when the plant is in a cold condition and avoid review of cold condition EALs when the plant is in a hot condition. This approach significantly minimizes the total number of EALs that must be reviewed by the EAL-user for a given plant condition, reduces EAL-user reading burden and, thereby, speeds identification of the EAL that applies to the emergency.

Within each group, assignment of EALs to categories and subcategories:

Category and subcategory titles are selected to represent conditions that are operationally significant to the EAL-user. The ANO EAL categories are aligned to and represent the NEI 99-01, Recognition Categories. Subcategories are used in the ANO scheme as necessary to further divide the EALs of a category into logical sets of possible emergency classification thresholds. The ANO EAL categories and subcategories are listed below.

The primary tool for determining the emergency classification level is the EAL Classification Matrix. The user of the EAL Classification Matrix may (but is not required to) consult the EAL technical bases in order to obtain additional information concerning the EALs under classification consideration. The user should consult Section 3.0 and Attachment 1 of this document for such information.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 5 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 EAL Groups, Categories and Subcategories EAL Group/Category EAL Subcategory Any Operating Mode:

A - Abnormal Rad Levels / Rad Effluent 1 - Radiological Effluent 2 - Irradiated Fuel Event 3 - Area Radiation Levels H - Hazards and Other Conditions Affecting 1 - Security Plant Safety 2 - Seismic Event 3 - Natural or Technological Hazard 4 - Fire 5 - Hazardous Gas 6 - Control Room Evacuation 7 - Emergency Director Judgment E - Independent Spent Fuel Storage 1 - Confinement Boundary Installation (ISFSI)

Hot Conditions:

S - System Malfunction 1 - Loss of Essential AC Power 2 - Loss of Vital DC Power 3 - Loss of Control Room Indications 4 - RCS Activity 5 - RCS Leakage 6 - RPS Failure 7 - Loss of Communications 8 - Containment Failure 9 - Hazardous Event Affecting Safety Systems F - Fission Product Barrier Degradation None Cold Conditions:

C - Cold Shutdown / Refueling System 1 - RCS Level Malfunction 2 - Loss of Essential AC Power 3 - RCS Temperature 4 - Loss of Vital DC Power 5 - Loss of Communications 6 - Hazardous Event Affecting Safety Systems 2.5 Technical Bases Information EAL technical bases are provided in Attachment 1 for each EAL according to EAL group (Any, Hot, Cold), EAL category (A, C, E, F, H and S) and EAL subcategory. A summary explanation of each category and subcategory is given at the beginning of the technical bases discussions of the EALs included in the category. For each EAL, the following information is provided:

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 6 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Category Letter & Title Subcategory Number & Title Initiating Condition (IC)

Site-specific description of the generic IC given in NEI 99-01 Rev. 6.

EAL Identifier (enclosed in rectangle)

Each EAL is assigned a unique identifier to support accurate communication of the emergency classification to onsite and offsite personnel. Four characters define each EAL identifier:

1. First character (letter): Corresponds to the EAL category as described above (A, C, E, F, H or S)

2. Second character (letter): The emergency classification (G, S, A or U)

G = General Emergency S = Site Area Emergency A = Alert U = Unusual Event

3. Third character (number): Subcategory number within the given category. Subcategories are sequentially numbered beginning with the number one (1). If a category does not have a subcategory, this character is assigned the number one (1).

4. Fourth character (number): The numerical sequence of the EAL within the EAL subcategory. If the subcategory has only one EAL, it is given the number one (1).

Classification (enclosed in rectangle):

Unusual Event (U), Alert (A), Site Area Emergency (S) or General Emergency (G)

EAL (enclosed in rectangle)

Exact wording of the EAL as it appears in the EAL Classification Matrix. If an ANO Unit 2 EAL threshold value differs from Unit 1, the Unit 2 threshold is enclosed in brackets. For example, in the EAL threshold RVLMS Levels 1 through 8 indicate DRY [RVLMS Levels 1 through 5 indicate DRY], RVLMS Levels 1 through 5 indicate DRY apply only to Unit 2.

Mode Applicability One or more of the following plant operating conditions comprise the mode to which each EAL is applicable: 1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown, 5 - Cold Shutdown, 6 - Refueling, DEF - Defueled, or All. (See Section 2.6 for operating mode definitions).

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 7 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Definitions:

If the EAL wording contains a defined term, the definition of the term is included in this section. These definitions can also be found in Section 5.1.

Basis:

An EAL basis section that provides ANO-relevant information concerning the EAL as well as a description of the rationale for the EAL as provided in NEI 99-01 Rev. 6.

Reference(s):

Source documentation from which the EAL is derived.

2.6 Operating Mode Applicability Unit 1 (ref. 4.1.6):

1 Power Operation Keff 0.99, reactor power > 5%

2 Startup Keff 0.99, reactor power 5%

3 Hot Standby Keff < 0.99, reactor coolant temperature 280°F 4 Hot Shutdown Keff < 0.99, reactor coolant temperature 280°F > Tavg > 200°F and all reactor vessel head closure bolts fully tensioned 5 Cold Shutdown Keff < 0.99, reactor coolant temperature 200°F and all reactor vessel head closure bolts fully tensioned 6 Refueling One or more reactor vessel head closure bolts less than fully tensioned DEF Defueled All fuel assemblies have been removed from Containment and placed in the spent fuel pool.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 8 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Unit 2 (ref. 4.1.6):

1 Power Operation Keff 0.99, reactor power > 5%, average coolant temperature 300°F 2 Startup Keff 0.99, reactor power 5%, average coolant temperature 300°F 3 Hot Standby Keff < 0.99, average coolant temperature 300°F 4 Hot Shutdown Keff < 0.99, average coolant temperature 300°F > Tavg > 200°F 5 Cold Shutdown Keff < 0.99, average coolant temperature 200°F 6 Refueling Keff 0.95, average coolant temperature 140°F, reactor vessel head unbolted or removed, and fuel in the vessel.

DEF Defueled All fuel assemblies have been removed from Containment and placed in the spent fuel pool.

The plant operating mode that exists at the time that the event occurs (prior to any protective system or operator action being initiated in response to the condition) should be compared to the mode applicability of the EALs. If a lower or higher plant operating mode is reached before the emergency classification is made, the declaration shall be based on the mode that existed at the time the event occurred.

3.0 GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS 3.1 General Considerations When making an emergency classification, the Emergency Director must consider all information having a bearing on the proper assessment of an Initiating Condition (IC). This includes the Emergency Action Level (EAL) plus the associated Operating Mode Applicability, Notes, and the informing basis information. In the Recognition Category F matrices, EALs are based on loss or potential loss of Fission Product Barrier Thresholds.

EAL matrices should be read from left to right, from General Emergency to Unusual Event, and top to bottom. Declaration decisions should be independently verified before declaration is made except when gaining this verification would exceed the 15 minute declaration requirement. Place keeping should be used on all EAL matrices.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 9 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 3.1.1 Classification Timeliness NRC regulations require the licensee 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 to promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level. The NRC staff has provided guidance on implementing this requirement in NSIR/DPR-ISG-01, "Interim Staff Guidance, Emergency Planning for Nuclear Power Plants" (ref. 4.1.8).

3.1.2 Valid Indications All emergency classification assessments shall be based upon valid indications, reports or conditions. A valid indication, report, or condition, is one that has been verified through appropriate means such that there is no doubt regarding the indicators operability, the conditions existence, or the reports accuracy. For example, verification could be accomplished through an instrument channel check, response on related or redundant indicators, or direct observation by plant personnel.

An indication, report, or condition is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

3.1.3 Imminent Conditions For ICs and EALs that have a stipulated time duration (e.g., 15 minutes, 30 minutes, etc.), the Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time. If an ongoing radiological release is detected and the release start time is unknown, it should be assumed that the release duration specified in the IC/EAL has been exceeded, absent data to the contrary.

3.1.4 Planned vs. Unplanned Events A planned work activity that results in an expected event or condition which meets or exceeds an EAL does not warrant an emergency declaration provided that: 1) the activity proceeds as planned, and 2) the plant remains within the limits imposed by the operating license. Such activities include planned work to test, manipulate, repair, maintain or modify a system or component. In these cases, the controls associated with the planning, preparation and execution of the work will ensure that compliance is maintained with all aspects of the operating license provided that the activity proceeds and concludes as expected. Events or conditions of this type may be subject to the reporting requirements of 10 CFR 50.72 (ref. 4.1.4).

3.1.5 Classification Based on Analysis The assessment of some EALs is based on the results of analyses that are necessary to ascertain whether a specific EAL threshold has been exceeded (e.g., dose assessments,

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 10 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 chemistry sampling, RCS leak rate calculation, etc.). For these EALs, the EAL wording or the associated basis discussion will identify the necessary analysis. In these cases, the 15-minute declaration period starts with the availability of the analysis results that show the threshold to be exceeded (i.e., this is the time that the EAL information is first available). The NRC expects licensees to establish the capability to initiate and complete EAL-related analyses within a reasonable period of time (e.g., maintain the necessary expertise on-shift).

3.1.6 Emergency Director Judgment While the EALs have been developed to address a full spectrum of possible events and conditions which may warrant emergency classification, a provision for classification based on operator/management experience and judgment is still necessary. The NEI 99-01 EAL scheme provides the Emergency Director with the ability to classify events and conditions based upon judgment using EALs that are consistent with the Emergency Classification Level (ECL) definitions (refer to Category H). The Emergency Director will need to determine if the effects or consequences of the event or condition reasonably meet or exceed a particular ECL definition.

A similar provision is incorporated in the Fission Product Barrier Tables; judgment may be used to determine the status of a fission product barrier.

3.2 Classification Methodology To make an emergency classification, the user will compare an event or condition (i.e., the relevant plant indications and reports) to an EAL(s) and determine if the EAL has been met or exceeded. The evaluation of an EAL must be consistent with the related Operating Mode Applicability and Notes. If an EAL has been met or exceeded, the associated IC is likewise met, the emergency classification process clock starts, and the ECL must be declared in accordance with plant procedures no later than fifteen minutes after the process clock started.

When assessing an EAL that specifies a time duration for the off-normal condition, the clock for the EAL time duration runs concurrently with the emergency classification process clock.

For a full discussion of this timing requirement, refer to NSIR/DPR-ISG-01 (ref. 4.1.8).

3.2.1 Classification of Multiple Events and Conditions When multiple emergency events or conditions are present, the user will identify all met or exceeded EALs. The highest applicable ECL identified during this review is declared. For example:

If an Alert EAL and a Site Area Emergency EAL are met, whether at one unit or at two units, a Site Area Emergency should be declared.

There is no additive effect from multiple EALs meeting the same ECL. For example:

If two Alert EALs are met, whether at one unit or at two units, an Alert should be declared.

3.2.2 Consideration of Mode Changes During Classification The mode in effect at the time that an event or condition occurred, and prior to any plant or operator response, is the mode that determines whether or not an IC is applicable. If an event

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 11 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 or condition occurs, and results in a mode change before the emergency is declared, the emergency classification level is still based on the mode that existed at the time that the event or condition was initiated (and not when it was declared). Once a different mode is reached, any new event or condition, not related to the original event or condition, requiring emergency classification should be evaluated against the ICs and EALs applicable to the operating mode at the time of the new event or condition.

For events that occur in Cold Shutdown or Refueling, escalation is via EALs that are applicable in the Cold Shutdown or Refueling modes, even if Hot Shutdown (or a higher mode) is entered during the subsequent plant response. In particular, the fission product barrier EALs are applicable only to events that initiate in the Hot Shutdown mode or higher.

3.2.3 Classification of Imminent Conditions Although EALs provide specific thresholds, the Emergency Director must remain alert to events or conditions that could lead to meeting or exceeding an EAL within a relatively short period of time (i.e., a change in the ECL is IMMINENT). If, in the judgment of the Emergency Director, meeting an EAL is IMMINENT, the emergency classification should be made as if the EAL has been met. While applicable to all emergency classification levels, this approach is particularly important at the higher emergency classification levels since it provides additional time for implementation of protective measures.

3.2.4 Emergency Classification Level Upgrading and Termination An ECL may be terminated when the event or condition that meets the classified IC and EAL no longer exists, and other site-specific termination requirements are met.

3.2.5 Classification of Short-Lived Events Event-based ICs and EALs define a variety of specific occurrences that have potential or actual safety significance. By their nature, some of these events may be short-lived and, thus, over before the emergency classification assessment can be completed. If an event occurs that meets or exceeds an EAL, the associated ECL must be declared regardless of its continued presence at the time of declaration. Examples of such events include an earthquake or a failure of the reactor protection system to automatically trip the reactor followed by a successful manual trip.

3.2.6 Classification of Transient Conditions Many of the ICs and/or EALs employ time-based criteria. These criteria will require that the IC/EAL conditions be present for a defined period of time before an emergency declaration is warranted. In cases where no time-based criterion is specified, it is recognized that some transient conditions may cause an EAL to be met for a brief period of time (e.g., a few seconds to a few minutes). The following guidance should be applied to the classification of these conditions.

EAL momentarily met during expected plant response - In instances in which an EAL is briefly met during an expected (normal) plant response, an emergency declaration is not warranted provided that associated systems and components are operating as expected, and operator

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 12 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 actions are performed in accordance with procedures.

EAL momentarily met but the condition is corrected prior to an emergency declaration - If an operator takes prompt manual action to address a condition, and the action is successful in correcting the condition prior to the emergency declaration, then the applicable EAL is not considered met and the associated emergency declaration is not required. For illustrative purposes, consider the following example:

An ATWS occurs and the high pressure ECCS systems fail to automatically start. The plant enters an inadequate core cooling condition (a potential loss of both the Fuel Clad and RCS Barriers). If an operator manually starts a high pressure ECCS system in accordance with an EOP step and clears the inadequate core cooling condition prior to an emergency declaration, then the classification should be based on the ATWS only.

It is important to stress that the 15-minute emergency classification assessment period (process clock) is not a grace period during which a classification may be delayed to allow the performance of a corrective action that would obviate the need to classify the event. Emergency classification assessments must be deliberate and timely, with no undue delays. The provision discussed above addresses only those rapidly evolving situations when an operator is able to take a successful corrective action prior to the Emergency Director completing the review and steps necessary to make the emergency declaration. This provision is included to ensure that any public protective actions resulting from the emergency classification are truly warranted by the plant conditions.

3.2.7 After-the-Fact Discovery of an Emergency Event or Condition In some cases, an EAL may be met but the emergency classification was not made at the time of the event or condition. This situation can occur when personnel discover that an event or condition existed which met an EAL, but no emergency was declared, and the event or condition no longer exists at the time of discovery. This may be due to the event or condition not being recognized at the time or an error that was made in the emergency classification process.

In these cases, no emergency declaration is warranted; however, the guidance contained in NUREG-1022 (ref. 4.1.3) is applicable. Specifically, the event should be reported to the NRC in accordance with 10 CFR § 50.72 (ref. 4.1.4) within one hour of the discovery of the undeclared event or condition. The licensee should also notify appropriate State and local agencies in accordance with the agreed upon arrangements.

3.2.8 Retraction of an Emergency Declaration Guidance on the retraction of an emergency declaration reported to the NRC is discussed in NUREG-1022 (ref. 4.1.3).

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 13 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059

4.0 REFERENCES

4.1 Developmental 4.1.1 NEI 99-01 Revision 6, Methodology for the Development of Emergency Action Levels for Non-Passive Reactors, ADAMS Accession Number ML12326A805 4.1.2 RIS 2007-02 Clarification of NRC Guidance for Emergency Notifications During Quickly Changing Events, February 2, 2007.

4.1.3 NUREG-1022 Event Reporting Guidelines: 10CFR50.72 and 50.73 4.1.4 10 § CFR 50.72 Immediate Notification Requirements for Operating Nuclear Power Reactors 4.1.5 10 § CFR 50.73 License Event Report System 4.1.6 Unit 1[2] Technical Specifications Table 1.1-1[1.1], Modes[Operational Modes]

4.1.7 Arkansas Nuclear One Offsite Dose Calculation Manual (ODCM) 4.1.8 NSIR/DPR-ISG-01 Interim Staff Guidance, Emergency Planning for Nuclear Power Plants 4.1.9 Arkansas Nuclear One Emergency Plan 4.1.10 1015.008 Unit 2 SDC Control 4.2 Implementing 4.2.1 1903.010 Emergency Action Level Classification 4.2.2 NEI 99-01 Rev. 6 to ANO EAL Comparison Matrix 4.2.3 ANO EAL Matrix 5.0 DEFINITIONS, ACRONYMS & ABBREVIATIONS 5.1 Definitions (ref. 4.1.1 except as noted)

Selected terms used in Initiating Condition, Emergency Action Level statements and EAL bases are set in all capital letters (e.g., ALL CAPS). These words are defined terms that have specific meanings as used in this document. The definitions of these terms are provided below.

Alert 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 EPA Protective Action Guideline exposure levels.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 14 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Confinement Boundary The barrier(s) between spent fuel and the environment once the spent fuel is processed for dry storage. As related to the ANO ISFSI, the Confinement Boundary is comprised of either the Multi-assembly Sealed Basket (MSB) (SNC System) or Multi-Purpose Canister (MPC) (Holtec System).

Containment Closure The action to secure primary containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions (ref. 4.1.10).

As applied to ANO, Containment Closure must be capable of being set within 30 minutes.

Containment Closure is set when the penetrations are isolated by manual or automatic isolation valve, blind flange, or equivalent.

Emergency Action Level (EAL)

A pre-determined, site-specific, observable threshold for an INITIATING CONDITION that, when met or exceeded, places the plant in a given emergency classification level.

Emergency Classification Level (ECL)

One of a set of names or titles established by the US Nuclear Regulatory Commission (NRC) for grouping off-normal events or conditions according to (1) potential or actual effects or consequences, and (2) resulting onsite and offsite response actions. The emergency classification levels, in ascending order of severity, are:

Unusual Event (UE)

Alert Site Area Emergency (SAE)

General Emergency (GE)

Explosion A rapid, violent and catastrophic failure of a piece of equipment due to combustion, chemical reaction or overpressurization. A release of steam (from high energy lines or components) or an electrical component failure (caused by short circuits, grounding, arcing, etc.) should not automatically be considered an explosion. Such events require a post-event inspection to determine if the attributes of an explosion are present.

Faulted The term applied to a steam generator that has a steam leak on the secondary side of sufficient size to cause an uncontrolled drop in steam generator pressure or the steam generator to become completely depressurized.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 15 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Fire Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute fires. Observation of flame is preferred but is not required if large quantities of smoke and heat are observed.

Fission Product Barrier Threshold A pre-determined, site-specific, observable threshold indicating the loss or potential loss of a fission product barrier.

Flooding A condition where water is entering a room or area faster than installed equipment is capable of removal, resulting in a rise of water level within the room or area.

General Emergency Events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with 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 PAG exposure levels offsite for more than the immediate site area.

Hostage A person(s) held as leverage against the station to ensure that demands will be met by the station.

Hostile Action An act toward ANO or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate 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 ANO. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the SECURITY OWNER CONTROLLED AREA).

Hostile Force 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.

Imminent The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 16 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Impede(d)

Personnel access to a room or area is hindered to an extent that extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).

Independent Spent Fuel Storage Installation (ISFSI)

A complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage.

Initiating Condition (IC)

An event or condition that aligns with the definition of one of the four emergency classification levels by virtue of the potential or actual effects or consequences.

Projectile An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.

Protected Area An area clearly demarcated by a fence or building wall with an entrance portal that is regulated by Security Personnel to control access (ref. 4.1.9).

RCS Intact The RCS should be considered intact when the RCS pressure boundary is in its normal condition for the cold shutdown mode of operation (e.g., no freeze seals or nozzle dams).

Refueling Pathway All the cavities, tubes, canals and pools through which irradiated fuel may be moved, but not including the reactor vessel.

Ruptured The condition of a steam generator in which primary-to-secondary leakage is of sufficient magnitude to require a safety injection (automatic or manual).

Safety System A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related (as defined in 10 CFR 50.2):

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 17 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Security Condition Any security event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A Security Condition does not involve a HOSTILE ACTION.

Security Owner Controlled Area (SOCA)

The SOCA is the area demarcated as a Vehicle Barrier System (VBS) consisting of passive elements including a series of large concrete blocks on the inside of a delay fence with early warning capabilities. The SOCA is the area between the SOCA Fence and the PROTECTED AREA Boundary (ref. 4.1.9).

Site Area Emergency Events are in progress or have occurred which involve actual or likely major failures 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 PAG exposure levels beyond the SITE BOUNDARY.

Site Boundary That boundary defined by a 1046 meter (0.65 mile) radius around the plant (ref. 4.1.7).

Unisolable An open or breached system line that cannot be isolated, remotely or locally.

Unplanned A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 18 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Unusual Event Events are in progress or have occurred which indicate a potential degradation in the level of safety of the plant or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of SAFETY SYSTEMS occurs.

Valid An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

Visible Damage Damage to a SAFETY SYSTEM train that is readily observable without measurements, testing, or analysis. The visual impact of the damage is sufficient to cause concern regarding the operability or reliability of the affected SAFETY SYSTEM train.

5.2 Abbreviations/Acronyms

°F .................................................................................................................... Degrees Fahrenheit

°......................................................................................................................................... Degrees AC ..................................................................................................................... Alternating Current ANO ............................................................................................................ Arkansas Nuclear One AOP .............................................................................................. Abnormal Operating Procedure ATWS.................................................................................... Anticipated Transient Without Scram BMS ................................................................................................... Boron Management System BWST................................................................................................ Borated Water Storage Tank CDE ................................................................................................... Committed Dose Equivalent CET .......................................................................................................... Core Exit Thermocouple CFR................................................................................................... Code of Federal Regulations CIAS.................................................................................. Containment Isolation Actuation Signal CMT, CNTMT, CTMT ..................................................................................................Containment CNB ................................................................................................................ Containment Barrier DBA............................................................................................................. Design Basis Accident DBE......................................................................................................... Design Basis Earthquake DC .............................................................................................................................Direct Current DEF ...................................................................................................................................Defueled

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 19 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 D/G....................................................................................................................... Diesel Generator DHR .............................................................................................................. Decay Heat Removal DROPS ............................................................ Diverse Reactor Overpressure Protection System DSC ............................................................................................................. Dry Shielded Canister DSS............................................................................................................ Diverse Scram System EAL .......................................................................................................... Emergency Action Level ECCS ......................................................................................... Emergency Core Cooling System ECL ............................................................................................... Emergency Classification Level DEF ...................................................................................................................................Defueled ENS............................................................................................... Emergency Notification System EOF................................................................................................ Emergency Operations Facility EOP ........................................................................................... Emergency Operating Procedure EPA ............................................................................................ Environmental Protection Agency ERG ............................................................................................ Emergency Response Guideline EPIP ............................................................................. Emergency Plan Implementing Procedure ESAS ........................................................................... Engineered Safeguards Actuation System ESF ...................................................................................................... Engineered Safety Feature ESFAS .................................................................. Engineered Safety Features Actuation System FAA ............................................................................................... Federal Aviation Administration FBI ................................................................................................ Federal Bureau of Investigation FCB ...................................................................................................................... Fuel Clad Barrier FEMA ............................................................................ Federal Emergency Management Agency GE ................................................................................................................... General Emergency HPI ............................................................................................................. High Pressure Injection IC ...................................................................................................................... Initiating Condition IPEEE ............................. Individual Plant Examination of External Events (Generic Letter 88-20)

ISFSI ......................................................................... Independent Spent Fuel Storage Installation Keff ...................................................................................... Effective Neutron Multiplication Factor LCO................................................................................................Limiting Condition of Operation LER .............................................................................................................Licensee Event Report LOCA ...................................................................................................... Loss of Coolant Accident LRW ....................................................................................................................Liquid Rad Waste LTOP............................................................................................ Low Temperature Overpressure LWR ................................................................................................................ Light Water Reactor

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 20 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 MCC .............................................................................................................. Motor Control Center MPC ................................................ Maximum Permissible Concentration/Multi-Purpose Canister mR, mRem, mrem, mREM ............................................................ milli-Roentgen Equivalent Man MSL...................................................................................................................... Main Steam Line MTS ................................................................................................................ Margin to Saturation MW.................................................................................................................................. Megawatt NDTT ...................................................................................... Nil Ductility Transition Temperature NEI ............................................................................................................Nuclear Energy Institute NEIC ................................................................................ National Earthquake Information Center NESP ................................................................................ National Environmental Studies Project NORAD ................................................................ North American Aerospace Defense Command NOT .............................................................................................. Normal Operating Temperature (NO)UE ............................................................................................. Notification of Unusual Event NPP................................................................................................................ Nuclear Power Plant NRC ............................................................................................ Nuclear Regulatory Commission NSSS ............................................................................................. Nuclear Steam Supply System OBE ................................................................................................... Operating Basis Earthquake ODCM ........................................................................................ Off-site Dose Calculation Manual ORO ............................................................................................... Offsite Response Organization PA ........................................................................................................................... Protected Area PAG ..................................................................................................... Protective Action Guideline PRA/PSA .................................. Probabilistic Risk Assessment / Probabilistic Safety Assessment P-T .............................................................................................................. Pressure-Temperature PTS ..................................................................................................... Pressurized Thermal Shock PWR..................................................................................................... Pressurized Water Reactor PSIG ............................................................................................ Pounds per Square Inch Gauge R ..................................................................................................................................... Roentgen RB .........................................................................................................................Reactor Building RCC ......................................................................................................... Reactor Control Console RCB ............................................................................................. Reactor Coolant System Barrier RCP ............................................................................................................ Reactor Coolant Pump RCS ......................................................................................................... Reactor Coolant System Rem, rem, REM ..................................................................................... Roentgen Equivalent Man Rep CET ....................................................................... Representative Core Exit Thermocouples

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 21 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 RETS ...................................................................... Radiological Effluent Technical Specifications RPS...................................................................................................... Reactor Protection System RV ...........................................................................................................................Reactor Vessel RVLMS........................................................................... Reactor Vessel Level Monitoring System RWT ............................................................................................................. Refueling Water Tank SAR.............................................................................................................Safety Analysis Report SBO ...................................................................................................................... Station Blackout SCBA ................................................................................... Self-Contained Breathing Apparatus SDC ................................................................................................................... Shutdown Cooling SOCA ........................................................................................... Security Owner Controlled Area SG ....................................................................................................................... Steam Generator SI............................................................................................................................ Safety Injection SPDS ........................................................................................ Safety Parameter Display System SPING ..................................................................................... Super Particulate Iodine Noble Gas SRO ......................................................................................................... Senior Reactor Operator TEDE ............................................................................................ Total Effective Dose Equivalent TOAF ................................................................................................................. Top of Active Fuel TSC ........................................................................................................ Technical Support Center USGS .......................................................................................... United States Geological Survey VBS ............................................................................................................ Vehicle Barrier System

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 22 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 6.0 ANO-TO-NEI 99-01 REV. 6 EAL CROSS-REFERENCE This cross-reference is provided to facilitate association and location of an ANO EAL within the NEI 99-01 IC/EAL identification scheme. Further information regarding the development of the ANO EALs based on the NEI guidance can be found in the EAL Comparison Matrix.

ANO NEI 99-01 Rev. 6 EAL IC Example EAL AU1.1 AU1 1, 2 AU1.2 AU1 3 AU2.1 AU2 1 AA1.1 AA1 1 AA1.2 AA1 2 AA1.3 AA1 3 AA1.4 AA1 4 AA2.1 AA2 1 AA2.2 AA2 2 AA2.3 AA2 3 AA3.1 AA3 1 AA3.2 AA3 2 AS1.1 AS1 1 AS1.2 AS1 2 AS1.3 AS1 3 AS2.1 AS2 1 AG1.1 AG1 1 AG1.2 AG1 2 AG1.3 AG1 3 AG2.1 AG2 1 CU1.1 CU1 1 CU1.2 CU1 2 CU2.1 CU2 1 CU3.1 CU3 1 CU3.2 CU3 2 CU4.1 CU4 1

PROC./WORK PLAN N

O. PROCEDURE

/WORK PLAN TITLE: PAGE: 23 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 ANO NEI 99-01 Rev. 6 EAL IC Example EAL CU5.1 CU5 1, 2, 3 CA1.1 CA1 1 CA1.2 CA1 2 CA2.1 CA2 1 CA3.1 CA3 1, 2 CA6.1 CA6 1 CS1.1 CS1 1 CS1.2 CS1 2 CS1.3 CS1 3 CG1.1 CG1 1 CG1.2 CG1 2 EU1.1 EU1 1 FA1.1 FA1 1 FS1.1 FS1 1 FG1.1 FG1 1 HU1.1 HU1 1, 2, 3 HU2.1 HU2 1 HU3.1 HU3 1 HU3.2 HU3 2 HU3.3 HU3 3 HU3.4 HU3 4 HU4.1 HU4 1 HU4.2 HU4 2 HU4.3 HU4 3 HU4.4 HU4 4 HU7.1 HU7 1 HA1.1 HA1 1, 2 HA5.1 HA5 1 HA6.1 HA6 1 HA7.1 HA7 1

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 24 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 ANO NEI 99-01 Rev. 6 EAL IC Example EAL HS1.1 HS1 1 HS6.1 HS6 1 HS7.1 HS7 1 HG7.1 HG7 1 SU1.1 SU1 1 SU3.1 SU2 1 SU4.1 SU3 1 SU4.2 SU3 2 SU5.1 SU4 1, 2, 3 SU6.1 SU5 1 SU6.2 SU5 2 SU7.1 SU6 1, 2, 3 SU8.1 SU7 1, 2 SA1.1 SA1 1 SA3.1 SA2 1 SA6.1 SA5 1 SA9.1 SA9 1 SS1.1 SS1 1 SS2.1 SS8 1 SS6.1 SS5 1 SG1.1 SG1 1 SG1.2 SG8 1 7.0 ATTACHMENTS 7.1 Attachment 1, Emergency Action Level Technical Bases 7.2 Attachment 2, Safe Operation & Shutdown Areas Tables 1[2]A-3 & 1[2]H-2 Bases

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 25 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category A - Abnormal Rad Levels / Rad Effluent EAL Group: ANY (EALs in this category are applicable to any plant condition, hot or cold.)

Many EALs are based on actual or potential degradation of fission product barriers because of the elevated potential for offsite radioactivity release. Degradation of fission product barriers though is not always apparent via non-radiological symptoms. Therefore, direct indication of elevated radiological effluents or area radiation levels are appropriate symptoms for emergency classification.

At lower levels, abnormal radioactivity releases may be indicative of a failure of containment systems or precursors to more significant releases. At higher release rates, offsite radiological conditions may result which require offsite protective actions. Elevated area radiation levels in plant may also be indicative of the failure of containment systems or preclude access to plant vital equipment necessary to ensure plant safety.

Events of this category pertain to the following subcategories:

1. Radiological Effluent Direct indication of effluent radiation monitoring systems provides a rapid assessment mechanism to determine releases in excess of classifiable limits. Projected offsite doses, actual offsite field measurements or measured release rates via sampling indicate doses or dose rates above classifiable limits.

2. Irradiated Fuel Event Conditions indicative of a loss of adequate shielding or damage to irradiated fuel may preclude access to vital plant areas or result in radiological releases that warrant emergency classification.

3. Area Radiation Levels Sustained general area radiation levels which may preclude access to areas requiring continuous occupancy also warrant emergency classification.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 26 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for 60 minutes or longer EAL:

AU1.1 Unusual Event Reading on any Table 1[2]A-1 effluent radiation monitor > column "UE" for 60 min.

(Notes 1, 2, 3)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Note 3: If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer VALID for classification purposes.

Table 1A-1 Unit 1 Effluent Monitor Classification Thresholds (2 min. avg reading)

Release Point Monitor GE SAE Alert UE RX-9820 Containment Purge 4.15E+01 Ci/cc 4.15E+00 µCi/cc 4.15E-01 µCi/cc 1.21E-03 µCi/cc (SPING 1)

RX-9825 Radwaste Area 2.67E+01 Ci/cc 2.67E+00 µCi/cc 2.67E-01 µCi/cc 4.94E-04 µCi/cc Gaseous (SPING 2)

RX-9830 Fuel Handling Area 6.20E+02 Ci/cc 6.20E+01 µCi/cc 6.20E+00 µCi/cc 5.44E-04 µCi/cc (SPING 3)

Emergency RX-9835 6.55E+02 Ci/cc 6.55E+01 µCi/cc 6.55E+00 µCi/cc 1.21E-02 µCi/cc Penetration Room (SPING 4)

Liquid Liquid Radwaste RE-4642 ---- ---- ---- 2.46E+05 cpm

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 27 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Table 2A-1 Unit 2 Effluent Monitor Classification Thresholds (2 min. avg reading)

Release Point Monitor GE SAE Alert UE 2RX-9820 Containment Purge 1.88E+01 Ci/cc 1.88E+00 µCi/cc 1.88E-01 µCi/cc 5.48E-04 µCi/cc (SPING 5) 2RX-9825 Radwaste Area 2.35E+01 Ci/cc 2.35E+00 µCi/cc 2.35E-01 µCi/cc 4.35E-04 µCi/cc Gaseous (SPING 6) 2RX-9830 Fuel Handling Area 6.86E+02 Ci/cc 6.86E+01 µCi/cc 6.86E+00 µCi/cc 6.04E-04 µCi/cc (SPING 7)

Emergency 2RX-9835 5.88E+02 Ci/cc 5.88E+01 µCi/cc 5.88E+00 µCi/cc 1.09E-02 µCi/cc Penetration Room (SPING 8)

BMS Liquid 2RE-2330 ---- ---- ---- 2.45E+04 cpm Discharge Liquid Regenerative 2RE-4423 ---- ---- ---- 2.45E+05 cpm Waste Discharge Mode Applicability:

All Definition(s):

VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

Basis:

This IC addresses a potential reduction in the level of safety of the plant as indicated by a low-level radiological release that exceeds regulatory commitments for an extended period of time (e.g., an uncontrolled release). It includes any gaseous or liquid radiological release, monitored or un-monitored, including those for which a radioactivity discharge permit is normally prepared.

Nuclear power plants incorporate design features intended to control the release of radioactive effluents to the environment. Further, there are administrative controls established to prevent unintentional releases, and to control and monitor intentional releases. The occurrence of an extended, uncontrolled radioactive release to the environment is indicative of degradation in these features and/or controls.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 28 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer VALID for classification purposes.

Releases should not be prorated or averaged. For example, a release exceeding 4 times release limits for 30 minutes does not meet the EAL.

This EAL addresses normally occurring continuous radioactivity releases from monitored gaseous or liquid effluent pathways as well as radioactivity releases that cause effluent radiation monitor readings to exceed 2 times the limit established by a radioactivity discharge permit.

Such releases are typically associated with planned batch releases from non-continuous release pathways (e.g., radwaste, waste gas).

Escalation of the emergency classification level would be via IC AA1.

Reference(s):

1. OP-1604.051 Ventilation Radiation Monitor System

2. Offsite Dose Calculation Manual

3. EP-CALC-ANO-1701 Radiological Effluent EAL Values

4. NEI 99-01 AU1

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 29 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for 60 minutes or longer EAL:

AU1.2 Unusual Event Sample analysis for a gaseous or liquid release indicates a concentration or release rate 2 x ODCM limits for 60 min. (Notes 1, 2)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Mode Applicability:

All Definition(s):

None Basis:

This IC addresses a potential reduction in the level of safety of the plant as indicated by a low-level radiological release that exceeds regulatory commitments for an extended period of time (e.g., an uncontrolled release). It includes any gaseous or liquid radiological release, monitored or un-monitored, including those for which a radioactivity discharge permit is normally prepared.

Nuclear power plants incorporate design features intended to control the release of radioactive effluents to the environment. Further, there are administrative controls established to prevent unintentional releases, and to control and monitor intentional releases. The occurrence of an extended, uncontrolled radioactive release to the environment is indicative of degradation in these features and/or controls.

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 30 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Releases should not be prorated or averaged. For example, a release exceeding 4 times release limits for 30 minutes does not meet the EAL.

This EAL addresses uncontrolled gaseous or liquid releases that are detected by sample analyses or environmental surveys, particularly on unmonitored pathways (e.g., spills of radioactive liquids into storm drains, heat exchanger leakage in river water systems, etc.).

Escalation of the emergency classification level would be via IC AA1.

Reference(s):

1. Offsite Dose Calculation Manual

2. NEI 99-01 AU1

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 31 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE EAL:

AA1.1 Alert Reading on any Table 1[2]A-1 effluent radiation monitor > column "ALERT" for 15 min.

(Notes 1, 2, 3, 4)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Note 3: If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer VALID for classification purposes.

Note 4 The pre-calculated effluent monitor values presented in EALs AA1.1, AS1.1 and AG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

Table 1A-1 Unit 1 Effluent Monitor Classification Thresholds (2 min. avg reading)

Release Point Monitor GE SAE Alert UE RX-9820 Containment Purge 4.15E+01 Ci/cc 4.15E+00 µCi/cc 4.15E-01 µCi/cc 1.21E-03 µCi/cc (SPING 1)

RX-9825 Radwaste Area 2.67E+01 Ci/cc 2.67E+00 µCi/cc 2.67E-01 µCi/cc 4.94E-04 µCi/cc Gaseous (SPING 2)

RX-9830 Fuel Handling Area 6.20E+02 Ci/cc 6.20E+01 µCi/cc 6.20E+00 µCi/cc 5.44E-04 µCi/cc (SPING 3)

Emergency RX-9835 6.55E+02 Ci/cc 6.55E+01 µCi/cc 6.55E+00 µCi/cc 1.21E-02 µCi/cc Penetration Room (SPING 4)

Liquid Liquid Radwaste RE-4642 ---- ---- ---- 2.46E+05 cpm

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 32 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Table 2A-1 Unit 2 Effluent Monitor Classification Thresholds (2 min. avg reading)

Release Point Monitor GE SAE Alert UE 2RX-9820 Containment Purge 1.88E+01 Ci/cc 1.88E+00 µCi/cc 1.88E-01 µCi/cc 5.48E-04 µCi/cc (SPING 5) 2RX-9825 Radwaste Area 2.35E+01 Ci/cc 2.35E+00 µCi/cc 2.35E-01 µCi/cc 4.35E-04 µCi/cc Gaseous (SPING 6) 2RX-9830 Fuel Handling Area 6.86E+02 Ci/cc 6.86E+01 µCi/cc 6.86E+00 µCi/cc 6.04E-04 µCi/cc (SPING 7)

Emergency 2RX-9835 5.88E+02 Ci/cc 5.88E+01 µCi/cc 5.88E+00 µCi/cc 1.09E-02 µCi/cc Penetration Room (SPING 8)

BMS Liquid 2RE-2330 ---- ---- ---- 2.45E+04 cpm Discharge Liquid Regenerative 2RE-4423 ---- ---- ---- 2.45E+05 cpm Waste Discharge Mode Applicability:

All Definition(s):

VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

Basis:

This IC addresses a release of gaseous or liquid radioactivity that results in projected or actual offsite doses greater than or equal to 1% of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude represent an actual or potential substantial degradation of the level of safety of the plant as indicated by a radiological release that significantly exceeds regulatory limits (e.g., a significant uncontrolled release).

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 33 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

Escalation of the emergency classification level would be via IC AS1.

Reference(s):

1. OP-1604.051 Ventilation Radiation Monitor System

2. EP-CALC-ANO-1701 Radiological Effluent EAL Values

3. NEI 99-01 AA1

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 34 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE EAL:

AA1.2 Alert Dose assessment using actual meteorology indicates doses > 10 mrem TEDE or 50 mrem thyroid CDE at or beyond the SITE BOUNDARY (Note 4)

Note 4: The pre-calculated effluent monitor values presented in EALs AA1.1, AS1.1 and AG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

Mode Applicability:

All Definition(s):

SITE BOUNDARY - That boundary defined by a 1046 meter (0.65 mile) radius around the plant.

Basis:

This IC addresses a release of gaseous or liquid radioactivity that results in projected or actual offsite doses greater than or equal to 1% of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude represent an actual or potential substantial degradation of the level of safety of the plant as indicated by a radiological release that significantly exceeds regulatory limits (e.g., a significant uncontrolled release).

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

Escalation of the emergency classification level would be via IC AS1.

Reference(s):

1. OP-1904.002 Offsite Dose Projections

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 35 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases

2. NEI 99-01 AA1

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 36 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE EAL:

AA1.3 Alert Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses > 10 mrem TEDE or 50 mrem thyroid CDE at or beyond the SITE BOUNDARY for 60 min. of exposure (Notes 1, 2)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Mode Applicability:

All Definition(s):

SITE BOUNDARY - That boundary defined by a 1046 meter (0.65 mile) radius around the plant.

Basis:

This IC addresses a release of gaseous or liquid radioactivity that results in projected or actual offsite doses greater than or equal to 1% of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude represent an actual or potential substantial degradation of the level of safety of the plant as indicated by a radiological release that significantly exceeds regulatory limits (e.g., a significant uncontrolled release).

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

This EAL is assessed per the ODCM (ref. 2).

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 37 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Escalation of the emergency classification level would be via IC AS1.

Reference(s):

1. OP-1904.002 Offsite Dose Projections

2. Offsite Dose Calculation Manual

3. NEI 99-01 AA1

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 38 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE EAL:

AA1.4 Alert Field survey results indicate EITHER of the following at or beyond the SITE BOUNDARY:

Closed window dose rates > 10 mR/hr expected to continue for 60 min.

Analyses of field survey samples indicate thyroid CDE > 50 mrem for 60 min. of inhalation (Notes 1, 2)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Mode Applicability:

All Definition(s):

SITE BOUNDARY - That boundary defined by a 1046 meter (0.65 mile) radius around the plant.

Basis:

This IC addresses a release of gaseous or liquid radioactivity that results in projected or actual offsite doses greater than or equal to 1% of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude represent an actual or potential substantial degradation of the level of safety of the plant as indicated by a radiological release that significantly exceeds regulatory limits (e.g., a significant uncontrolled release).

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 39 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

Escalation of the emergency classification level would be via IC AS1.

Reference(s):

1. OP-1905.002 Offsite Emergency Monitoring

2. NEI 99-01 AA1

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 40 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 100 mrem TEDE or 500 mrem thyroid CDE EAL:

AS1.1 Site Area Emergency Reading on any Table 1[2]A-1 effluent radiation monitor > column "SAE" for 15 min.

(Notes 1, 2, 3, 4)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Note 3: If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer VALID for classification purposes.

Note 4: The pre-calculated effluent monitor values presented in EALs AA1.1, AS1.1 and AG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

Table 1A-1 Unit 1 Effluent Monitor Classification Thresholds (2 min. avg reading)

Release Point Monitor GE SAE Alert UE RX-9820 Containment Purge 4.15E+01 Ci/cc 4.15E+00 µCi/cc 4.15E-01 µCi/cc 1.21E-03 µCi/cc (SPING 1)

RX-9825 Radwaste Area 2.67E+01 Ci/cc 2.67E+00 µCi/cc 2.67E-01 µCi/cc 4.94E-04 µCi/cc Gaseous (SPING 2)

RX-9830 Fuel Handling Area 6.20E+02 Ci/cc 6.20E+01 µCi/cc 6.20E+00 µCi/cc 5.44E-04 µCi/cc (SPING 3)

Emergency RX-9835 6.55E+02 Ci/cc 6.55E+01 µCi/cc 6.55E+00 µCi/cc 1.21E-02 µCi/cc Penetration Room (SPING 4)

Liquid Liquid Radwaste RE-4642 ---- ---- ---- 2.46E+05 cpm

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 41 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Table 2A-1 Unit 2 Effluent Monitor Classification Thresholds (2 min. avg reading)

Release Point Monitor GE SAE Alert UE 2RX-9820 Containment Purge 1.88E+01 Ci/cc 1.88E+00 µCi/cc 1.88E-01 µCi/cc 5.48E-04 µCi/cc (SPING 5) 2RX-9825 Radwaste Area 2.35E+01 Ci/cc 2.35E+00 µCi/cc 2.35E-01 µCi/cc 4.35E-04 µCi/cc Gaseous (SPING 6) 2RX-9830 Fuel Handling Area 6.86E+02 Ci/cc 6.86E+01 µCi/cc 6.86E+00 µCi/cc 6.04E-04 µCi/cc (SPING 7)

Emergency 2RX-9835 5.88E+02 Ci/cc 5.88E+01 µCi/cc 5.88E+00 µCi/cc 1.09E-02 µCi/cc Penetration Room (SPING 8)

BMS Liquid 2RE-2330 ---- ---- ---- 2.45E+04 cpm Discharge Liquid Regenerative 2RE-4423 ---- ---- ---- 2.45E+05 cpm Waste Discharge Mode Applicability:

All Definition(s):

VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

Basis:

This IC addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to 10% of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public.

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 42 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases The TEDE dose is set at 10% of the EPA PAG of 1,000 mrem while the 500 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer VALID for classification purposes.

Escalation of the emergency classification level would be via IC AG1.

Reference(s):

1. OP-1604.051 Ventilation Radiation Monitor System

2. EP-CALC-ANO-1701 Radiological Effluent EAL Values

3. NEI 99-01 AS1

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 43 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 100 mrem TEDE or 500 mrem thyroid CDE EAL:

AS1.2 Site Area Emergency Dose assessment using actual meteorology indicates doses > 100 mrem TEDE or 500 mrem thyroid CDE at or beyond the SITE BOUNDARY (Note 4)

Note 4 The pre-calculated effluent monitor values presented in EALs AA1.1, AS1.1 and AG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

Mode Applicability:

All Definition(s):

SITE BOUNDARY - That boundary defined by a 1046 meter (0.65 mile) radius around the plant).

Basis:

This IC addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to 10% of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public.

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 10% of the EPA PAG of 1,000 mrem while the 500 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

Escalation of the emergency classification level would be via IC AG1.

Reference(s):

1. OP-1904.002 Offsite Dose Projections

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 44 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases

2. NEI 99-01 AS1

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 45 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 100 mrem TEDE or 500 mrem thyroid CDE EAL:

AS1.3 Site Area Emergency Field survey results indicate EITHER of the following at or beyond the SITE BOUNDARY:

Closed window dose rates > 100 mR/hr expected to continue for 60 min.

Analyses of field survey samples indicate thyroid CDE > 500 mrem for 60 min. of inhalation (Notes 1, 2)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Mode Applicability:

All Definition(s):

SITE BOUNDARY - That boundary defined by a 1046 meter (0.65 mile) radius around the plant.

Basis:

This IC addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to 10% of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public.

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 10% of the EPA PAG of 1,000 mrem while the 500 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 46 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Escalation of the emergency classification level would be via IC AG1.

Reference(s):

1. OP-1905.002 Offsite Emergency Monitoring

2. NEI 99-01 AS1

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 47 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mrem TEDE or 5,000 mrem thyroid CDE EAL:

AG1.1 General Emergency Reading on any Table 1[2]A-1 effluent radiation monitor > column "GE" for 15 min.

(Notes 1, 2, 3, 4)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Note 3: If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer VALID for classification purposes.

Note 4: The pre-calculated effluent monitor values presented in EALs AA1.1, AS1.1 and AG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

Table 1A-1 Unit 1 Effluent Monitor Classification Thresholds (2 min. avg reading)

Release Point Monitor GE SAE Alert UE RX-9820 Containment Purge 4.15E+01 Ci/cc 4.15E+00 µCi/cc 4.15E-01 µCi/cc 1.21E-03 µCi/cc (SPING 1)

RX-9825 Radwaste Area 2.67E+01 Ci/cc 2.67E+00 µCi/cc 2.67E-01 µCi/cc 4.94E-04 µCi/cc Gaseous (SPING 2)

RX-9830 Fuel Handling Area 6.20E+02 Ci/cc 6.20E+01 µCi/cc 6.20E+00 µCi/cc 5.44E-04 µCi/cc (SPING 3)

Emergency RX-9835 6.55E+02 Ci/cc 6.55E+01 µCi/cc 6.55E+00 µCi/cc 1.21E-02 µCi/cc Penetration Room (SPING 4)

Liquid Liquid Radwaste RE-4642 ---- ---- ---- 2.46E+05 cpm

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 48 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Table 2A-1 Unit 2 Effluent Monitor Classification Thresholds (2 min. avg reading)

Release Point Monitor GE SAE Alert UE 2RX-9820 Containment Purge 1.88E+01 Ci/cc 1.88E+00 µCi/cc 1.88E-01 µCi/cc 5.48E-04 µCi/cc (SPING 5) 2RX-9825 Radwaste Area 2.35E+01 Ci/cc 2.35E+00 µCi/cc 2.35E-01 µCi/cc 4.35E-04 µCi/cc Gaseous (SPING 6) 2RX-9830 Fuel Handling Area 6.86E+02 Ci/cc 6.86E+01 µCi/cc 6.86E+00 µCi/cc 6.04E-04 µCi/cc (SPING 7)

Emergency 2RX-9835 5.88E+02 Ci/cc 5.88E+01 µCi/cc 5.88E+00 µCi/cc 1.09E-02 µCi/cc Penetration Room (SPING 8)

BMS Liquid 2RE-2330 ---- ---- ---- 2.45E+04 cpm Discharge Liquid Regenerative 2RE-4423 ---- ---- ---- 2.45E+05 cpm Waste Discharge Mode Applicability:

All Definition(s):

VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

Basis:

This IC addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude will require implementation of protective actions for the public.

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 49 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases The TEDE dose is set at the EPA PAG of 1,000 mrem while the 5,000 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer VALID for classification purposes.

Reference(s):

1. OP-1604.051 Ventilation Radiation Monitor System

2. EP-CALC-ANO-1701 Radiological Effluent EAL Values

3. NEI 99-01 AG1

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 50 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mrem TEDE or 5,000 mrem thyroid CDE EAL:

AG1.2 General Emergency Dose assessment using actual meteorology indicates doses > 1,000 mrem TEDE or 5,000 mrem thyroid CDE at or beyond the SITE BOUNDARY (Note 4)

Note 4 The pre-calculated effluent monitor values presented in EALs AA1.1, AS1.1 and AG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

Mode Applicability:

All Definition(s):

SITE BOUNDARY - That boundary defined by a 1046 meter (0.65 mile) radius around the plant).

Basis:

This IC addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude will require implementation of protective actions for the public.

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at the EPA PAG of 1,000 mrem while the 5,000 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

Reference(s):

1. OP-1904.002 Offsite Dose Projections

2. NEI 99-01 AG1

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 51 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mrem TEDE or 5,000 mrem thyroid CDE EAL:

AG1.3 General Emergency Field survey results indicate EITHER of the following at or beyond the SITE BOUNDARY:

Closed window dose rates > 1,000 mR/hr expected to continue for 60 min.

Analyses of field survey samples indicate thyroid CDE > 5,000 mrem for 60 min. of inhalation (Notes 1, 2)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Mode Applicability:

All Definition(s):

SITE BOUNDARY - That boundary defined by a 1046 meter (0.65 mile) radius around the plant.

Basis:

This IC addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude will require implementation of protective actions for the public.

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at the EPA PAG of 1,000 mrem while the 5,000 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 52 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Reference(s):

1. OP-1905.002 Offsite Emergency Monitoring

2. NEI 99-01 AG1

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 53 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 2 - Irradiated Fuel Event Initiating Condition: UNPLANNED loss of water level above irradiated fuel EAL:

AU2.1 Unusual Event UNPLANNED water level drop in the REFUELING PATHWAY as indicated by low water level alarm, visual observation, or BWST[RWT] level drop due to makeup demands AND UNPLANNED rise in corresponding area radiation levels as indicated by any of the following radiation monitors:

Unit 1 o RE-8009 Spent Fuel Area o RE-8017 Fuel Handling Area Unit 2 o 2RE-8914 Spent Fuel Area o 2RE-8915 Spent Fuel Area o 2RE-8916 Spent Fuel Area o 2RE-8912 Containment Incore Instrumentation Mode Applicability:

All Definition(s):

UNPLANNED - A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

REFUELING PATHWAY - All the cavities, tubes, canals and pools through which irradiated fuel may be moved, but not including the reactor vessel.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 54 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Basis:

This IC addresses a drop in water level above irradiated fuel sufficient to cause elevated radiation levels. This condition could be a precursor to a more serious event and is also indicative of a minor loss in the ability to control radiation levels within the plant. It is therefore a potential degradation in the level of safety of the plant.

A water level drop will be primarily determined by indications from available level instrumentation. Other sources of level indications may include reports from plant personnel (e.g., from a refueling crew) or video camera observations (if available). A significant drop in the water level may also cause a rise in the radiation levels of adjacent areas that can be detected by monitors in those locations.

The effects of planned evolutions should be considered. For example, a refueling bridge area radiation monitor reading may rise due to planned evolutions such as lifting of the reactor vessel head or movement of a fuel assembly. Note that this EAL is applicable only in cases where the elevated reading is due to an UNPLANNED loss of water level.

A drop in water level above irradiated fuel within the reactor vessel may be classified in accordance Recognition Category C during the Cold Shutdown and Refueling modes.

Escalation of the emergency classification level would be via IC AA2.

Reference(s):

1. OP-1203.050 Unit 1 Spent Fuel Pool Emergencies

2. OP-2203.002 Spent Fuel Pool Emergencies

3. 1SAR 11.2.5 Area Radiation Monitoring Systems Table 11-15 Area Radiation Monitors

4. 2SAR 12.1.4 Area Radiation Monitoring System

5. NEI 99-01 AU2

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 55 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 2 - Irradiated Fuel Event Initiating Condition: Significant lowering of water level above, or damage to, irradiated fuel EAL:

AA2.1 Alert IMMINENT uncovery of irradiated fuel in the REFUELING PATHWAY.

Mode Applicability:

All Definition(s):

CONFINEMENT BOUNDARY - The barrier(s) between spent fuel and the environment once the spent fuel is processed for dry storage. As related to the ANO ISFSI, the Confinement Boundary is comprised of either the Multi-assembly Sealed Basket (MSB) (SNC System) or Multi-Purpose Canister (MPC) (Holtec System).

IMMINENT - The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.

REFUELING PATHWAY - All the cavities, tubes, canals and pools through which irradiated fuel may be moved, but not including the reactor vessel.

Basis:

This IC addresses events that have caused IMMINENT or actual damage to an irradiated fuel assembly, or a significant lowering of water level within the REFUELING PATHWAY. These events present radiological safety challenges to plant personnel and are precursors to a release of radioactivity to the environment. As such, they represent an actual or potential substantial degradation of the level of safety of the plant. This IC applies to irradiated fuel that is licensed for dry storage up to the point that the loaded storage cask is sealed. Once sealed, damage to a loaded cask causing loss of the CONFINEMENT BOUNDARY is classified in accordance with IC EU1.

This EAL escalates from AU2.1 in that the loss of level, in the affected portion of the REFUELING PATHWAY, is of sufficient magnitude to have resulted in uncovery of irradiated fuel. Indications of irradiated fuel uncovery may include direct or indirect visual observation (e.g., reports from personnel or camera images), as well as significant changes in water and radiation levels, or other plant parameters. Computational aids may also be used (e.g., a boil-off curve). Classification of an event using this EAL should be based on the totality of available indications, reports and observations.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 56 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases While an area radiation monitor could detect a rise in a dose rate due to a lowering of water level in some portion of the REFUELING PATHWAY, the reading may not be a reliable indication of whether or not the fuel is actually uncovered. To the degree possible, readings should be considered in combination with other available indications of inventory loss.

A drop in water level above irradiated fuel within the reactor vessel may be classified in accordance with Recognition Category C during the Cold Shutdown and Refueling modes.

Escalation of the emergency classification level would be via IC AS1.

Reference(s):

1. NEI 99-01 AA2

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 57 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 2 - Irradiated Fuel Event Initiating Condition: Significant lowering of water level above, or damage to, irradiated fuel EAL:

AA2.2 Alert Damage to irradiated fuel resulting in a release of radioactivity AND High alarm on any Table 1[2]A-2 radiation monitor.

Table 1A-2 Unit 1 Fuel Damage Radiation Monitors RE-8009 Spent Fuel Area RE-8017 Fuel Handling RE-8060 Containment High Range Radiation Monitor RE-8061 Containment High Range Radiation Monitor RX-9820 (SPING 1) Containment Purge RX-9825 (SPING 2) Radwaste Area RX-9830 (SPING 3) Fuel Handling Area

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 58 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Table 2A-2 Unit 2 Fuel Damage Radiation Monitors 2RE-8905 Containment Equipment Hatch Area 2RE-8909 Containment Personnel Access Area 2RE-8912 Containment Incore Inst.

2RE-8914 Spent Fuel Area 2RE-8915 Spent Fuel Area 2RE-8916 Spent Fuel Area 2RE-8925-1 Containment High Range Radiation Monitor 2RE-8925-2 Containment High Range Radiation Monitor 2RX-9820 (SPING 5) Containment Purge 2RX-9825 (SPING 6) Radwaste Area 2RX-9830 (SPING 7) Fuel Handling Area Mode Applicability:

All Definition(s):

CONFINEMENT BOUNDARY - The barrier(s) between spent fuel and the environment once the spent fuel is processed for dry storage. As related to the ANO ISFSI, the Confinement Boundary is comprised of either the Multi-assembly Sealed Basket (MSB) (SNC System) or Multi-Purpose Canister (MPC) (Holtec System).

VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

Basis:

This EAL addresses events that have caused actual damage to an irradiated fuel assembly.

These events present radiological safety challenges to plant personnel and are precursors to a release of radioactivity to the environment. As such, they represent an actual or potential substantial degradation of the level of safety of the plant.

This EAL applies to irradiated fuel that is licensed for dry storage up to the point that the loaded storage cask is sealed. Once sealed, damage to a loaded cask causing loss of the CONFINEMENT BOUNDARY is classified in accordance with IC EU1.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 59 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases This EAL addresses a release of radioactive material caused by mechanical damage to irradiated fuel. Damaging events may include the dropping, bumping or binding of an assembly, or dropping a heavy load onto an assembly. A rise in readings on radiation monitors should be considered in conjunction with in-plant reports or observations of a potential fuel damaging event (e.g., a fuel handling accident).

Escalation of the emergency classification level would be via IC AS1.

Reference(s):

1. OP-1203.050 Unit 1 Spent Fuel Pool Emergencies

2. OP-1305.001 Radiation Monitoring System Check and Test

3. OP-2203.002 Spent Fuel Pool Emergencies

4. OP-1604.051 Ventilation Radiation Monitoring System

5. OP-2304.133 Containment High Range Radiation Monitor Calibration

6. Offsite Dose Calculation Manual

7. NEI 99-01 AA2

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 60 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 2 - Irradiated Fuel Event Initiating Condition: Significant lowering of water level above, or damage to, irradiated fuel EAL:

AA2.3 Alert Lowering of spent fuel pool level to 387.0 ft.[389.5 ft.] (Alarm 2) on LIT-2020-3(4)

[2LIT-2020-1(2)]

Mode Applicability:

All Definition(s):

None Basis:

This EAL addresses events that have caused a significant lowering of water level within the spent fuel pool. These events present radiological safety challenges to plant personnel and are precursors to a release of radioactivity to the environment. As such, they represent an actual or potential substantial degradation of the level of safety of the plant.

Spent fuel pool water level at this value is within the lower end of the level range necessary to prevent significant dose consequences from direct gamma radiation to personnel performing operations in the vicinity of the spent fuel pool. This condition reflects a significant loss of spent fuel pool water inventory and thus it is also a precursor to a loss of the ability to adequately cool the irradiated fuel assembles stored in the pool.

Escalation of the emergency classification level would be via IC AS1 or AS2.

Post-Fukushima order EA-12-051 required the installation of reliable SFP level indication capable of identifying normal level (Level 1), SFP level 10 ft. above the top of the fuel racks (Level 2) and SFP level at the top of the fuel racks (Level 3) (ref. 1, 2).

Reference(s):

1. MOHR-ANO-1, ANO-1 SFPI (Level) Configuration, Sheet 1, Revision 0

2. MOHR-ANO-2, ANO-2 SFPI (Level) Configuration, Sheet 1, Revision 0

3. NEI 99-01 AA2

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 61 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 2 - Irradiated Fuel Event Initiating Condition: Spent fuel pool level at the top of the fuel racks EAL:

AS2.1 Site Area Emergency Lowering of spent fuel pool level to 377.0 ft.[379.5 ft.] (Alarm 3) on LIT-2020-3(4)

[2LIT-2020-1(2)]

Mode Applicability:

All Definition(s):

IMMINENT - The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.

Basis:

This EAL addresses a significant loss of spent fuel pool inventory control and makeup capability leading to IMMINENT fuel damage. This condition entails major failures of plant functions needed for protection of the public and thus warrant a Site Area Emergency declaration.

It is recognized that this IC would likely not be met until well after another Site Area Emergency IC was met; however, it is included to provide classification diversity.

Escalation of the emergency classification level would be via IC AG1 or AG2.

Post-Fukushima order EA-12-051 required the installation of reliable SFP level indication capable of identifying normal level (Level 1), SFP level 10 ft. above the top of the fuel racks (Level 2) and SFP level at the top of the fuel racks (Level 3) (ref. 1, 2).

Reference(s):

1. MOHR-ANO-1, ANO-1 SFPI (Level) Configuration, Sheet 1, Revision 0

2. MOHR-ANO-2, ANO-2 SFPI (Level) Configuration, Sheet 1, Revision 0

3. NEI 99-01 AS2

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 62 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 2 - Irradiated Fuel Event Initiating Condition: Spent fuel pool level cannot be restored to at least the top of the fuel racks for 60 minutes or longer EAL:

AG2.1 General Emergency Spent fuel pool level cannot be restored to at least 377.0 ft.[379.5 ft.] (Alarm 3) on LIT-2020-3(4)[2LIT-2020-1(2)] for 60 min. (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Mode Applicability:

All Definition(s):

None Basis:

This EAL addresses a significant loss of spent fuel pool inventory control and makeup capability leading to a prolonged uncovery of spent fuel. This condition will lead to fuel damage and a radiological release to the environment.

It is recognized that this IC would likely not be met until well after another General Emergency IC was met; however, it is included to provide classification diversity.

Post-Fukushima order EA-12-051 required the installation of reliable SFP level indication capable of identifying normal level (Level 1), SFP level 10 ft. above the top of the fuel racks (Level 2) and SFP level at the top of the fuel racks (Level 3) (ref. 1, 2).

Reference(s):

1. MOHR-ANO-1, ANO-1 SFPI (Level) Configuration, Sheet 1, Revision 0

2. MOHR-ANO-2, ANO-2 SFPI (Level) Configuration, Sheet 1, Revision 0

3. NEI 99-01 AG2

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 63 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 3 - Area Radiation Levels Initiating Condition: Radiation levels that IMPEDE access to equipment necessary for normal plant operations, cooldown or shutdown EAL:

AA3.1 Alert Dose rate > 15 mR/hr in EITHER of the following areas:

Control Room Central Alarm Station (by survey)

Mode Applicability:

All Definition(s):

IMPEDE(D) - Personnel access to a room or area is hindered to an extent that extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).

Basis:

Areas that meet this threshold include the Control Room (CR) and the Central Alarm Station (CAS). The Control Room envelope (Unit 1 and Unit 2) is monitored for excessive radiation by five detectors. These radiation detectors are RE-8001, 2RE-8001A, 2RE-8001B, 2RE-8750-1A, and 2RE-8750-1B (ref. 1). The CAS is included in this EAL because of its importance to permitting access to areas required to assure safe plant operations. There are no permanently installed area radiation monitors in CAS that may be used to assess this EAL threshold.

Therefore, this threshold is evaluated using local radiation survey for this area.

This IC addresses elevated radiation levels in certain plant rooms/areas sufficient to preclude or IMPEDE personnel from performing actions necessary to maintain normal plant operation, or to perform a normal plant cooldown and shutdown. As such, it represents an actual or potential substantial degradation of the level of safety of the plant. The Emergency Director should consider the cause of the rise in radiation levels and determine if another IC may be applicable.

Escalation of the emergency classification level would be via Recognition Category A, C or F ICs.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 64 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Reference(s):

1. STM 1-62 Radiation Monitoring

2. NEI 99-01 AA3

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 65 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 3 - Area Radiation Levels Initiating Condition: Radiation levels that IMPEDE access to equipment necessary for normal plant operations, cooldown or shutdown EAL:

AA3.2 Alert An UNPLANNED event results in radiation levels that prohibit or IMPEDE access to any Table 1[2]A-3 room or area (Note 5)

Note 5: If the equipment in the listed room or area was already inoperable or out-of-service before the event occurred, then no emergency classification is warranted.

Table 1A-3 Unit 1 Safe Operation & Shutdown Rooms/Areas Room/Area Mode A-4 Switchgear Room 3, 4 Upper North Electrical Penetration Room 3, 4 Lower South Electrical Equipment Room 3, 4 Table 2A-3 Unit 2 Safe Operation & Shutdown Rooms/Areas Room/Area Mode Aux Building 317 Emergency Core Cooling Rooms 3, 4 Aux Building 317 Tendon Gallery Access 3, 4 Aux Building 335 Charging Pumps / MCC 2B-52 3, 4 Aux Building 354 MCC 2B-62 Area 3, 4 Emergency Diesel Generator Corridor 3, 4 Lower South Piping Penetration Room 3, 4 Aux Building 386 Containment Hatch 3, 4

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 66 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Mode Applicability:

3 - Hot Standby, 4 - Hot Shutdown Definition(s):

IMPEDE(D) - Personnel access to a room or area is hindered to an extent that extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).

UNPLANNED - A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

Basis:

This IC addresses elevated radiation levels in certain plant rooms/areas sufficient to preclude or IMPEDE personnel from performing actions necessary to maintain normal plant operation, or to perform a normal plant cooldown and shutdown. As such, it represents an actual or potential substantial degradation of the level of safety of the plant. The Emergency Director should consider the cause of the rise in radiation levels and determine if another IC may be applicable.

For AA3.2, an Alert declaration is warranted if entry into the affected room/area is, or may be, procedurally required during the plant operating mode in effect at the time of the elevated radiation levels. The emergency classification is not contingent upon whether entry is actually necessary at the time of the higher radiation levels. Access should be considered as IMPEDED if extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., installing temporary shielding, requiring use of non-routine protective equipment, requesting an extension in dose limits beyond normal administrative limits).

An emergency declaration is not warranted if any of the following conditions apply:

The plant is in an operating mode different than the mode specified for the affected room/area (i.e., entry is not required during the operating mode in effect at the time of the elevated radiation levels). For example, the plant is in Mode 1 when the radiation rise occurs, and the procedures used for normal operation, cooldown and shutdown do not require entry into the affected room until Mode 3.

The higher radiation levels are a result of a planned activity that includes compensatory measures which address the temporary inaccessibility of a room or area (e.g.,

radiography, spent filter or resin transfer, etc.).

The access control measures are of a conservative or precautionary nature, and would not actually prevent or IMPEDE a required action.

Escalation of the emergency classification level would be via Recognition Category A, C or F ICs.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 67 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases If the equipment in the listed room or area was already inoperable, or out-of-service, before the event occurred, then no emergency should be declared since the event will have no adverse impact beyond that already allowed by Technical Specifications at the time of the event.

The list of plant rooms or areas with entry-related mode applicability identified specify those rooms or areas that contain equipment which require a manual/local action as specified in operating procedures used for normal plant operation, cooldown and shutdown. Rooms or areas in which actions of a contingent or emergency nature would be performed (e.g., an action to address an off-normal or emergency condition such as emergency repairs, corrective measures or emergency operations) are not included. In addition, the list specifies the plant mode(s) during which entry would be required for each room or area (ref. 1).

EAL AA3.2 mode applicability has been limited to the mode limitations of Table 1[2]A-3 (Modes 3 and 4 only).

Reference(s):

1. Attachment 2 Safe Operation & Shutdown Areas Tables 1[2]A-3 & 1[2]H-2 Bases

2. NEI 99-01 AA3

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 68 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category C - Cold Shutdown / Refueling System Malfunction EAL Group: Cold Conditions (RCS temperature 200°F); EALs in this category are applicable only in one or more cold operating modes.

Category C EALs are directly associated with cold shutdown or refueling system safety functions. Given the variability of plant configurations (e.g., systems out-of-service for maintenance, containment open, reduced AC power redundancy, time since shutdown) during these periods, the consequences of any given initiating event can vary greatly. For example, a loss of decay heat removal capability that occurs at the end of an extended outage has less significance than a similar loss occurring during the first week after shutdown. Compounding these events is the likelihood that instrumentation necessary for assessment may also be inoperable. The cold shutdown and refueling system malfunction EALs are based on performance capability to the extent possible with consideration given to RCS integrity, CONTAINMENT CLOSURE, and fuel clad integrity for the applicable operating modes (5 - Cold Shutdown, 6 - Refueling, DEF - Defueled).

The events of this category pertain to the following subcategories:

1. RCS Level RCS water level is directly related to the status of adequate core cooling and, therefore, fuel clad integrity.

2. Loss of Vital AC Power Loss of vital plant electrical power can compromise plant SAFETY SYSTEM operability including decay heat removal and emergency core cooling systems which may be necessary to ensure fission product barrier integrity. This category includes loss of onsite and offsite power sources for 4.16 KV vital buses.

3. RCS Temperature Uncontrolled or inadvertent temperature or pressure rises are indicative of a potential loss of safety functions.

4. Loss of Vital DC Power Loss of emergency plant electrical power can compromise plant SAFETY SYSTEM operability including decay heat removal and emergency core cooling systems which may be necessary to ensure fission product barrier integrity. This category includes loss of power to or degraded voltage on the 125V DC vital buses.

5. Loss of Communications Certain events that degrade plant operator ability to effectively communicate with essential personnel within or external to the plant warrant emergency classification.

6. Hazardous Event Affecting Safety Systems Certain hazardous natural and technological events may result in VISIBLE DAMAGE to or degraded performance of safety systems warranting classification.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 69 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: UNPLANNED loss of RCS inventory EAL:

CU1.1 Unusual Event UNPLANNED loss of reactor coolant results in RCS water level less than a required lower limit for 15 min. (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

UNPLANNED - A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

Basis:

This EAL addresses the inability to restore and maintain water level to a required minimum level (or the lower limit of a level band), or a loss of the ability to monitor RCS level concurrent with indications of coolant leakage. Either of these conditions is considered to be a potential degradation of the level of safety of the plant.

Refueling evolutions that lower RCS water inventory are carefully planned and controlled. An UNPLANNED event that results in water level lowering below a procedurally required limit warrants the declaration of an Unusual Event due to the reduced water inventory that is available to keep the core covered.

This EAL recognizes that the minimum required RCS level can change several times during the course of a refueling outage as different plant configurations and system lineups are implemented. This EAL is met if the minimum level, specified for the current plant conditions, cannot be maintained for 15 minutes or longer. The minimum level is typically specified in the applicable operating procedure but may be specified in another controlling document.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 70 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases The 15-minute threshold duration allows sufficient time for prompt operator actions to restore and maintain the expected water level. This criterion excludes transient conditions causing a brief lowering of water level.

Continued loss of RCS inventory may result in escalation to the Alert emergency classification level via either IC CA1 or CA3.

Reference(s):

1. OP-1015.002 Decay Heat Removal and LTOP System

2. OP-1015.008 Unit 2 SDC Control

3. NEI 99-01 CU1

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 71 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: UNPLANNED loss of RCS inventory EAL:

CU1.2 Unusual Event RCS level cannot be monitored AND EITHER:

UNPLANNED rise in any Table 1[2]C-1 sump/tank level due to loss of RCS inventory Visual observation of UNISOLABLE RCS leakage Table 1C-1 Unit 1 Sumps / Tanks Reactor Building Sump Dirty Waste Drain Tank T-20A/B Aux. Building Equipment Drain Tank T-11 Aux. Building Sump Quench Tank T-42 Table 2C-1 Unit 2 Sumps / Tanks CNTMT Sump 2T56 Reactor Drain Tank 2T-68 LRW Waste Tank (2T-20)

Holdup Tank Aux. Building Sump Quench Tank 2T-42 Mode Applicability:

5 - Cold Shutdown, 6 - Refueling

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 72 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Definition(s):

UNISOLABLE - An open or breached system line that cannot be isolated, remotely or locally.

UNPLANNED - A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

Basis:

This IC addresses the inability to restore and maintain water level to a required minimum level (or the lower limit of a level band), or a loss of the ability to monitor RCS level concurrent with indications of coolant leakage. Either of these conditions is considered to be a potential degradation of the level of safety of the plant.

Refueling evolutions that lower RCS water inventory are carefully planned and controlled. An UNPLANNED event that results in water level lowering below a procedurally required limit warrants the declaration of an Unusual Event due to the reduced water inventory that is available to keep the core covered.

This EAL addresses a condition where all means to determine RCS level have been lost. In this condition, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels (Table C-1). Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the RCS.

Continued loss of RCS inventory may result in escalation to the Alert emergency classification level via either IC CA1 or CA3.

Reference(s):

1. OP-1203.039 Excess RCS Leakage

2. OP-2203.016 Excess RCS Leakage

3. NEI 99-01 CU1

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 73 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: Significant Loss of RCS inventory EAL:

CA1.1 Alert Loss of RCS inventory as indicated by EITHER:

RVLMS Levels 1 through 8[1 through 5] indicate DRY Reactor vessel level < 370.2 ft. (LT-1195/LT-1196)[< 24 in. (L4791/L4792)] (minimum level for DHR operation @ 1000 gpm)[(minimum level for SDC operation)]

Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

None Basis:

This IC addresses conditions that are precursors to a loss of the ability to adequately cool irradiated fuel (i.e., a precursor to a challenge to the fuel clad barrier). This condition represents a potential substantial reduction in the level of plant safety.

For this EAL, a lowering of RPV water level below the specified level indicates that operator actions have not been successful in restoring and maintaining RCS water level. The heat-up rate of the coolant will rise as the available water inventory is reduced. A continuing drop in water level will lead to core uncovery.

Although related, this EAL is concerned with the loss of RPV inventory and not the potential concurrent effects on systems needed for decay heat removal (e.g., loss of a Decay Heat Removal suction point). A rise in RCS temperature caused by a loss of decay heat removal capability is evaluated under IC CA3.

If water level continues to lower, then escalation to Site Area Emergency would be via IC CS1.

A loss of DHR/SDC will occur at approximately RLVMS Level 8 (Unit 1) or RVLMS Level 5 (Unit 2). However, RVLMS may not be available in the cold shutdown modes. Redundant means of level indication is provided in these modes and included in this EAL. The point at which a loss of DHR/SDC is likely to occur is 370.2 ft. (Unit 1) or 24 in. (Unit 2) as indicated in the respective Control Rooms. The value selected for ANO-1 is based on 1000 gpm DHR flow

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 74 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases which is the flow rate at which the low flow alarm is received. The ANO-2 value is the proceduralized minimum value. Below these levels, a loss of suction to decay heat removal systems will occur (ref. 1, 2, 3). The inability to restore and maintain level after reaching this value would be indicative of a failure of the RCS barrier.

Reference(s):

1. OP-1104.004 Decay Heat Removal Operating Procedure

2. OP-1105.008 Inadequate Core Cooling Monitor and Display

3. OP-2105.003 Reactor Vessel Level Monitoring System Operations

4. OP-2203.029 Loss of Shutdown Cooling

5. Calculation No. 90-E-0116-01 ANO-2 EOP Setpoint Basis Document, Setpoints R.3 and R.9

6. NEI 99-01 CA1

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 75 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: Significant Loss of RCS inventory EAL:

CA1.2 Alert RCS level cannot be monitored for 15 min. (Note 1)

AND EITHER:

UNPLANNED rise in any Table 1[2]C-1 sump/tank level due to a loss of RCS inventory Visual observation of UNISOLABLE RCS leakage Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Table 1C-1 Unit 1 Sumps / Tanks Reactor Building Sump Dirty Waste Drain Tank T-20A/B Aux. Building Equipment Drain Tank T-11 Aux. Building Sump Quench Tank T-42 Table 2C-1 Unit 2 Sumps / Tanks CNTMT Sump 2T56 Reactor Drain Tank 2T-68 LRW Waste Tank (2T-20)

Holdup Tank Aux. Building Sump Quench Tank 2T-42

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 76 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

UNISOLABLE - An open or breached system line that cannot be isolated, remotely or locally.

UNPLANNED - A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

Basis:

This IC addresses conditions that are precursors to a loss of the ability to adequately cool irradiated fuel (i.e., a precursor to a challenge to the fuel clad barrier). This condition represents a potential substantial reduction in the level of plant safety.

For this EAL, the inability to monitor RCS level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation. If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the RCS.

The 15-minute duration for the loss of level indication was chosen because it is half of the EAL duration specified in IC CS1.

If the RCS inventory level continues to lower, then escalation to Site Area Emergency would be via IC CS1.

Reference(s):

1. OP-1203.039 Excess RCS Leakage

2. OP-2203.016 Excess RCS Leakage

3. NEI 99-01 CA1

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 77 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: Loss of RCS inventory affecting core decay heat removal capability EAL:

CS1.1 Site Area Emergency CONTAINMENT CLOSURE not established AND RVLMS Levels 1 through 9[1 through 6] indicate DRY Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

CONTAINMENT CLOSURE - The action to secure primary containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions.

As applied to ANO, CONTAINMENT CLOSURE must be capable of being set within 30 minutes. CONTAINMENT CLOSURE is set when the penetrations are isolated by manual or automatic isolation valve, blind flange, or equivalent.

IMMINENT - The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.

Basis:

This IC addresses a significant and prolonged loss of RCS inventory control and makeup capability leading to IMMINENT fuel damage. The lost inventory may be due to a RCS component failure, a loss of configuration control or prolonged boiling of reactor coolant. These conditions entail major failures of plant functions needed for protection of the public and thus warrant a Site Area Emergency declaration.

Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS/reactor vessel level cannot be restored, fuel damage is probable.

Outage/shutdown contingency plans typically provide for re-establishing or verifying CONTAINMENT CLOSURE following a loss of heat removal or RCS inventory control functions.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 78 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases This EAL addresses concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.

Escalation of the emergency classification level would be via IC CG1 or AG1.

Reference(s):

1. OP-1105.008 Inadequate Core Cooling Monitor and Display

2. OP-2105.003 Reactor Vessel Level Monitoring System Operations

3. NEI 99-01 CS1

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 79 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: Loss of RCS inventory affecting core decay heat removal capability EAL:

CS1.2 Site Area Emergency

[RVLMS Levels 1 through 7 indicate DRY OR]

RCS level cannot be monitored for 30 min. (Note 1)

AND Core uncovery is indicated by any of the following:

UNPLANNED rise in any Table 1[2]C-1 sump/tank level of sufficient magnitude to indicate core uncovery Containment high range radiation monitor RE-8060/8061[2RE-8925-1/8925-2] reading

> 10 R/hr Erratic Source Range Monitor indication Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Table 1C-1 Unit 1 Sumps / Tanks Reactor Building Sump Dirty Waste Drain Tank T-20A/B Aux. Building Equipment Drain Tank T-11 Aux. Building Sump Quench Tank T-42

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 80 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Table 2C-1 Unit 2 Sumps / Tanks CNTMT Sump 2T56 Reactor Drain Tank 2T-68 LRW Waste Tank (2T-20)

Holdup Tank Aux. Building Sump Quench Tank 2T-42 Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

CONTAINMENT CLOSURE - The action to secure primary containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions.

As applied to ANO, CONTAINMENT CLOSURE must be capable of being set within 30 minutes. CONTAINMENT CLOSURE is set when the penetrations are isolated by manual or automatic isolation valve, blind flange, or equivalent.

IMMINENT - The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.

UNPLANNED - A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

Basis:

When in service, the Unit 2 RVLMS can measure RCS level below the top of active fuel.

Level 7 DRY on this system is an indication of core uncovery.

This IC addresses a significant and prolonged loss of reactor vessel/RCS inventory control and makeup capability leading to IMMINENT fuel damage. The lost inventory may be due to a RCS component failure, a loss of configuration control or prolonged boiling of reactor coolant. These conditions entail major failures of plant functions needed for protection of the public and thus warrant a Site Area Emergency declaration.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 81 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS/reactor vessel level cannot be restored, fuel damage is probable.

Outage/shutdown contingency plans typically provide for re-establishing or verifying CONTAINMENT CLOSURE following a loss of heat removal or RCS inventory control functions.

The difference in the specified RCS levels of EALs CS1.1 and CS1.2 reflect the fact that with CONTAINMENT CLOSURE established, there is a lower probability of a fission product release to the environment.

The 30-minute criterion is tied to a readily recognizable event start time (i.e., the total loss of ability to monitor level), and allows sufficient time to monitor, assess and correlate reactor and plant conditions to determine if core uncovery has actually occurred (i.e., to account for various accident progression and instrumentation uncertainties). It also allows sufficient time for performance of actions to terminate leakage, recover inventory control/makeup equipment and/or restore level monitoring.

The inability to monitor RCS level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation. If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the RCS.

This EAL addresses concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.

Containment High Range Radiation Monitors RE-8060/8061 [2RE-8925-1/8925-2] are the site-specific radiation monitors that would be indicative of possible core uncovery in the Refueling mode. The dose rate due to core shine when the top of the core becomes uncovered should result in dose rates > 10 R/hr.

Escalation of the emergency classification level would be via IC CG1 or AG1.

Reference(s):

1. OP-1203.039 Excess RCS Leakage

2. OP-2203.016 Excess RCS Leakage

3. OP-2105.003 Reactor Vessel Level Monitoring System Operations

4. 1SAR Table 7-11

5. 2SAR 12.1.4.2

6. NEI 99-01 CS1

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 82 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: Loss of RCS inventory affecting fuel clad integrity with containment challenged EAL:

CG1.1 General Emergency - UNIT 2 ONLY RVLMS Levels 1 through 7 indicate DRY AND Any Containment Challenge indication, Table 1[2]C-2 Note 6: If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, declaration of a General Emergency is not required.

Table 1[2]C-2 Containment Challenge Indications CONTAINMENT CLOSURE not established (Note 6)

Containment hydrogen concentration > 4%

UNPLANNED rise in containment pressure Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

CONTAINMENT CLOSURE - The action to secure primary containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions.

As applied to ANO, CONTAINMENT CLOSURE must be capable of being set within 30 minutes. CONTAINMENT CLOSURE is set when the penetrations are isolated by manual or automatic isolation valve, blind flange, or equivalent.

IMMINENT - The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.

UNPLANNED - A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 83 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Basis:

When in service, the Unit 2 RVLMS can measure RCS level below the top of active fuel.

Level 7 DRY on this system is an indication of core uncovery.

This IC addresses the inability to restore and maintain reactor vessel level above the top of active fuel with containment challenged. This condition represents actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity. Releases can be reasonably expected to exceed EPA PAG exposure levels offsite for more than the immediate site area.

Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS level cannot be restored, fuel damage is probable.

With CONTAINMENT CLOSURE not established, there is a high potential for a direct and unmonitored release of radioactivity to the environment. If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, then declaration of a General Emergency is not required.

The existence of an explosive mixture means, at a minimum, that the containment atmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at the lower deflagration limit). A hydrogen burn will raise containment pressure and could result in collateral equipment damage leading to a loss of containment integrity. It therefore represents a challenge to Containment integrity.

In the early stages of a core uncovery event, it is unlikely that hydrogen buildup due to core uncovery could result in an explosive gas mixture in containment. If all installed hydrogen gas monitors are out-of-service during an event leading to fuel cladding damage, it may not be possible to obtain a containment hydrogen gas concentration reading as ambient conditions within the containment will preclude personnel access. During periods when installed containment hydrogen gas monitors are out-of-service, operators may use the other listed indications to assess whether or not containment is challenged.

This EAL addresses concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 84 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Reference(s):

1. OP-1203.039 Excess RCS Leakage

2. OP-2203.016 Excess RCS Leakage

3. OP-2105.003 Reactor Vessel Level Monitoring System Operations

4. 1SAR Table 7-11

5. 2SAR 12.1.4.2

6. Unit 1 SAMG Figure III-1B

7. Unit 2 SAMG Phase 1 Instructions, Containment Flowchart

8. NEI 99-01 CG1

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 85 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: Loss of RCS inventory affecting fuel clad integrity with containment challenged EAL:

CG1.2 General Emergency RCS level cannot be monitored for 30 min. (Note 1)

AND Core uncovery is indicated by any of the following:

UNPLANNED rise in any Table 1[2]C-1 sump/tank level of sufficient magnitude to indicate core uncovery Containment High Range Radiation Monitor RE-8060/8061[2RE-8925-1/8925-2]

reading > 10 R/hr Erratic Source Range Monitor indication AND Any Containment Challenge indication, Table 1[2]C-2 Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Note 6: If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, declaration of a General Emergency is not required.

Table 1C-1 Unit 1 Sumps / Tanks Reactor Building Sump Dirty Waste Drain Tank T-20A/B Aux. Building Equipment Drain Tank T-11 Aux. Building Sump Quench Tank T-42

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 86 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Table 2C-1 Unit 2 Sumps / Tanks CNTMT Sump 2T56 Reactor Drain Tank 2T-68 LRW Waste Tank (2T-20)

Holdup Tank Aux. Building Sump Quench Tank 2T-42 Table 1[2]C-2 Containment Challenge Indications CONTAINMENT CLOSURE not established (Note 6)

Containment hydrogen concentration > 4%

UNPLANNED rise in containment pressure Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

CONTAINMENT CLOSURE - The action to secure primary containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions.

As applied to ANO, CONTAINMENT CLOSURE must be capable of being set within 30 minutes. CONTAINMENT CLOSURE is set when the penetrations are isolated by manual or automatic isolation valve, blind flange, or equivalent.

IMMINENT - The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.

UNPLANNED - A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 87 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Basis:

When in service, the Unit 2 RVLMS can measure RCS level below the top of active fuel.

Level 7 DRY on this system is an indication of core uncovery.

This IC addresses the inability to restore and maintain reactor vessel level above the top of active fuel with containment challenged. This condition represents actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity. Releases can be reasonably expected to exceed EPA PAG exposure levels offsite for more than the immediate site area.

Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS level cannot be restored, fuel damage is probable.

With CONTAINMENT CLOSURE not established, there is a high potential for a direct and unmonitored release of radioactivity to the environment. If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, then declaration of a General Emergency is not required.

The existence of an explosive mixture means, at a minimum, that the containment atmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at the lower deflagration limit). A hydrogen burn will raise containment pressure and could result in collateral equipment damage leading to a loss of containment integrity. It therefore represents a challenge to Containment integrity.

In the early stages of a core uncovery event, it is unlikely that hydrogen buildup due to core uncovery could result in an explosive gas mixture in containment. If all installed hydrogen gas monitors are out-of-service during an event leading to fuel cladding damage, it may not be possible to obtain a containment hydrogen gas concentration reading as ambient conditions within the containment will preclude personnel access. During periods when installed containment hydrogen gas monitors are out-of-service, operators may use the other listed indications to assess whether or not containment is challenged.

The 30-minute criterion is tied to a readily recognizable event start time (i.e., the total loss of ability to monitor level), and allows sufficient time to monitor, assess and correlate reactor and plant conditions to determine if core uncovery has actually occurred (i.e., to account for various accident progression and instrumentation uncertainties). It also allows sufficient time for performance of actions to terminate leakage, recover inventory control/makeup equipment and/or restore level monitoring.

The inability to monitor RCS level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation. If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the RCS.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 88 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Containment High Range Radiation Monitor RE-8060/8061 [2RE-8925-1/8925-2] are the site-specific radiation monitors that would be indicative of possible core uncovery in the Refueling mode. The dose rate due to core shine when the top of the core becomes uncovered should result in dose rates > 10 R/hr.

This EAL addresses concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.

Reference(s):

1. OP-1203.039 Excess RCS Leakage

2. OP-2203.016 Excess RCS Leakage

3. OP-2105.003 Reactor Vessel Level Monitoring System Operations

4. 1SAR Table 7-11

5. 2SAR 12.1.4.2

6. Unit 1 SAMG Figure III-1B

7. Unit 2 SAMG Phase 1 Instructions, Containment Flowchart

8. NEI 99-01 CG1

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 89 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 2 - Loss of Vital AC Power Initiating Condition: Loss of all but one AC power source to vital buses for 15 minutes or longer EAL:

CU2.1 Unusual Event AC power capability, Table 1[2]C-3, to vital 4.16 KV buses A3[2A3] and A4[2A4] reduced to a single power source for 15 min. (Note 1)

AND Any additional single power source failure will result in loss of all AC power to SAFETY SYSTEMS Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Table 1C-3 Unit 1 AC Power Sources Offsite Startup Transformer No. 1 Startup Transformer No. 2 Unit Auxiliary Transformer (from 22 KV switchyard)

Onsite DG1 DG2 AAC Gen

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 90 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Table 2C-3 Unit 2 AC Power Sources Offsite Startup Transformer No. 3 Startup Transformer No. 2 Unit Auxiliary Transformer (from 22 KV switchyard)

Onsite 2DG1 2DG2 AAC Gen Mode Applicability:

5 - Cold Shutdown, 6 - Refueling, DEF - Defueled Definition(s):

SAFETY SYSTEM - A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related (as defined in 10 CFR 50.2):

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Basis:

This IC describes a significant degradation of offsite and onsite AC power sources such that any additional single failure would result in a loss of all AC power to SAFETY SYSTEMS. In this condition, the sole AC power source may be powering one, or more than one, train of safety-related equipment.

When in the cold shutdown, refueling, or defueled mode, this condition is not classified as an Alert because of the greater time available to restore another power source to service.

Additional time is available due to the reduced core decay heat load, and the lower temperatures and pressures in various plant systems. Thus, when in these modes, this condition is considered to be a potential degradation of the level of safety of the plant.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 91 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases An AC power source is a source recognized in AOPs and EOPs, and capable of supplying required power to a vital bus. Some examples of this condition are presented below.

A loss of all offsite power with a concurrent failure of all but one vital power source.

A loss of all offsite power and loss of all vital power sources with a single train of vital buses being back-fed from the unit main generator.

A loss of vital power sources (e.g., onsite diesel generators) with a single train of vital buses being back-fed from an offsite power source.

Fifteen minutes was selected as a threshold to exclude transient or momentary losses of power.

The subsequent loss of the remaining single power source would escalate the event to an Alert in accordance with IC CA2.

This EAL is the cold condition equivalent of the hot condition EAL SA1.1.

Reference(s):

1. 1SAR Figure 8-1 Station Single Line Diagram

2. OP-1202.007 Degraded Power

3. OP-1202.008 Blackout

4. OP-2104.037 Alternate AC Diesel Generator Operations

5. 2SAR Figure 8.3-1 Station Single Line Diagram

6. OP-2202.007 Loss of Off-Site Power

7. OP-2202.008 Station Blackout

8. OP-2107.006 Backfeed of Unit Auxiliary Transformer

9. NEI 99-01 CU2

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 92 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 2 - Loss of Vital AC Power Initiating Condition: Loss of all offsite and all onsite AC power to vital buses for 15 minutes or longer EAL:

CA2.1 Alert Loss of all offsite and all onsite AC power to vital 4.16 KV buses A3[2A3] and A4[2A4] for 15 min. (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Mode Applicability:

5 - Cold Shutdown, 6 - Refueling, DEF - Defueled Definition(s):

SAFETY SYSTEM - A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related (as defined in 10 CFR 50.2):

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Basis:

Although the AAC may be considered available, it will not prevent declaration of this EAL unless it is powering a vital bus within the 15-minute time period of the EAL.

This IC addresses a total loss of AC power that compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink.

Mitigative strategies using non-safety related power sources (FLEX generators, etc.) may be effective in supplying power to these buses. These power sources must be controlled in

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 93 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases accordance with abnormal or emergency operating procedures, or beyond design basis accident response guidelines (e.g., FLEX support guidelines) and must be capable (alone or in combination) of supplying power for long term decay heat removal systems.

When in the cold shutdown, refueling, or defueled mode, this condition is not classified as a Site Area Emergency because of the greater time available to restore a vital bus to service.

Additional time is available due to the reduced core decay heat load, and the lower temperatures and pressures in various plant systems. Thus, when in these modes, this condition represents an actual or potential substantial degradation of the level of safety of the plant.

Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

Escalation of the emergency classification level would be via IC CS1 or AS1.

This EAL is the cold condition equivalent of the hot condition EAL SS1.1.

Reference(s):

1. 1SAR Figure 8-1 Station Single Line Diagram

2. OP-1202.007 Degraded Power

3. OP-1202.008 Blackout

4. OP-2104.037 Alternate AC Diesel Generator Operations

5. 2SAR Figure 8.3-1 Station Single Line Diagram

6. OP-2202.007 Loss of Off-Site Power

7. OP-2202.008 Station Blackout

8. OP-2107.006 Backfeed of Unit Auxiliary Transformer

9. NEI 99-01 CU2

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 94 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 3 - RCS Temperature Initiating Condition: UNPLANNED rise in RCS temperature EAL:

CU3.1 Unusual Event UNPLANNED rise in RCS temperature to > 200°F Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

CONTAINMENT CLOSURE - The action to secure primary containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions.

As applied to ANO, CONTAINMENT CLOSURE must be capable of being set within 30 minutes. CONTAINMENT CLOSURE is set when the penetrations are isolated by manual or automatic isolation valve, blind flange, or equivalent.

UNPLANNED - A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

Basis:

This IC addresses an UNPLANNED rise in RCS temperature above the Technical Specification cold shutdown temperature limit and represents a potential degradation of the level of safety of the plant. If the RCS is not intact and CONTAINMENT CLOSURE is not established during this event, the Emergency Director should also refer to EAL CA3.1.

A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when the heat removal function is available does not warrant a classification.

This EAL involves a loss of decay heat removal capability, or an addition of heat to the RCS in excess of that which can currently be removed, such that reactor coolant temperature cannot be maintained below the cold shutdown temperature limit specified in Technical Specifications.

During this condition, there is no immediate threat of fuel damage because the core decay heat load has been reduced since the cessation of power operation.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 95 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases During an outage, the level in the reactor vessel will normally be maintained at or above the reactor vessel flange. Refueling evolutions that lower water level below the reactor vessel flange are carefully planned and controlled. A loss of forced decay heat removal at lowered inventory may result in a rapid rise in reactor coolant temperature depending on the time after shutdown.

Escalation to Alert would be via IC CA1 based on an inventory loss or IC CA3 based on exceeding plant configuration-specific time criteria.

Reference(s):

1. Unit 1 and Unit 2 Technical Specifications Table 1.1-1

2. NEI 99-01 CU3

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 96 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 3 - RCS Temperature Initiating Condition: UNPLANNED rise in RCS temperature EAL:

CU3.2 Unusual Event Loss of all RCS temperature and RCS level indication for 15 min. (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

CONTAINMENT CLOSURE - The action to secure primary containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions.

As applied to ANO, CONTAINMENT CLOSURE must be capable of being set within 30 minutes. CONTAINMENT CLOSURE is set when the penetrations are isolated by manual or automatic isolation valve, blind flange, or equivalent.

UNPLANNED - A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

Basis:

This EAL addresses the inability to determine RCS temperature and level, and represents a potential degradation of the level of safety of the plant. If the RCS is not intact and CONTAINMENT CLOSURE is not established during this event, the Emergency Director should also refer to EAL CA3.1.

This EAL reflects a condition where there has been a significant loss of instrumentation capability necessary to monitor RCS conditions and operators would be unable to monitor key parameters necessary to assure core decay heat removal. During this condition, there is no immediate threat of fuel damage because the core decay heat load has been reduced since the cessation of power operation.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 97 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Fifteen minutes was selected as a threshold to exclude transient or momentary losses of indication.

Escalation to Alert would be via IC CA1 based on an inventory loss or IC CA3 based on exceeding plant configuration-specific time criteria.

Reference(s):

1. NEI 99-01 CU3

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 98 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 3 - RCS Temperature Initiating Condition: Inability to maintain plant in cold shutdown EAL:

CA3.1 Alert UNPLANNED rise in RCS temperature to > 200°F for > Table 1[2]C-4 duration (Note 1)

OR UNPLANNED RCS pressure rise > 10 psig (this EAL does not apply during water-solid plant conditions)

Note 1: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Table 1[2]C-4 RCS Heat-up Duration Thresholds CONTAINMENT RCS Status Heat-up Duration CLOSURE Status Intact (but not lowered inventory) N/A 60 min.*

Not intact established 20 min.*

OR lowered inventory not established 0 min.

• If an RCS heat removal system is in operation within this time frame and RCS temperature is being reduced, the EAL is not applicable.

Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

CONTAINMENT CLOSURE - The action to secure primary containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 99 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases As applied to ANO, CONTAINMENT CLOSURE must be capable of being set within 30 minutes. CONTAINMENT CLOSURE is set when the penetrations are isolated by manual or automatic isolation valve, blind flange, or equivalent.

UNPLANNED - A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

Basis:

In the absence of reliable RCS temperature indication, classification should be based on the RCS pressure rise criteria when the RCS is intact in Mode 5 or based on time to boil data when in Mode 6 or the RCS is not intact in Mode 5.

This EAL addresses conditions involving a loss of decay heat removal capability or an addition of heat to the RCS in excess of that which can currently be removed. Either condition represents an actual or potential substantial degradation of the level of safety of the plant.

A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when the heat removal function is available does not warrant a classification.

The RCS Heat-up Duration Thresholds table addresses a rise in RCS temperature when CONTAINMENT CLOSURE is established but the RCS is not intact, or RCS inventory is reduced (e.g., lowered inventory operation). The 20-minute criterion was included to allow time for operator action to address the temperature rise.

The RCS Heat-up Duration Thresholds table also addresses a rise in RCS temperature with the RCS intact. The status of CONTAINMENT CLOSURE is not crucial in this condition since the intact RCS is providing a high pressure barrier to a fission product release. The 60-minute time frame should allow sufficient time to address the temperature rise without a substantial degradation in plant safety.

Finally, in the case where there is a rise in RCS temperature, the RCS is not intact or is at lowered inventory and CONTAINMENT CLOSURE is not established, no heat-up duration is allowed (i.e., 0 minutes). This is because 1) the evaporated reactor coolant may be released directly into the containment atmosphere and subsequently to the environment, and 2) there is reduced reactor coolant inventory above the top of irradiated fuel.

The RCS pressure rise threshold provides a pressure-based indication of RCS heat-up in the absence of RCS temperature monitoring capability.

Escalation of the emergency classification level would be via IC CS1 or AS1.

Reference(s):

1. Unit 1 and Unit 2 Technical Specifications Table 1.1-1

2. NEI 99-01 CA3

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 100 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 4 - Loss of Vital DC Power Initiating Condition: Loss of Vital DC power for 15 minutes or longer EAL:

CU4.1 Unusual Event Indicated voltage is < 105 VDC on required vital 125 VDC buses for 15 min. (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

SAFETY SYSTEM - A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related (as defined in 10 CFR 50.2).

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Basis:

Unit 1 batteries D06 and D07 and Unit 2 batteries 2D11 and 2D12 contain 58 cells each with a minimum cell voltage of 1.81 V or 105 VDC.

This IC addresses a loss of vital DC power which compromises the ability to monitor and control operable SAFETY SYSTEMS when the plant is in the cold shutdown or refueling mode. In these modes, the core decay heat load has been significantly reduced, and coolant system temperatures and pressures are lower; these conditions raise the time available to restore a vital DC bus to service. Thus, this condition is considered to be a potential degradation of the level of safety of the plant.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 101 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases As used in this EAL, required means the vital DC buses necessary to support operation of the in-service, or operable, train or trains of SAFETY SYSTEM equipment. For example, if Train A is out-of-service (inoperable) for scheduled outage maintenance work and Train B is in-service (operable), then a loss of Vital DC power affecting Train B would require the declaration of an Unusual Event. A loss of Vital DC power to Train A would not warrant an emergency classification.

Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

Depending upon the event, escalation of the emergency classification level would be via IC CA1 or CA3, or an IC in Recognition Category A.

This EAL is the cold condition equivalent of the hot condition EAL SS2.1.

Reference(s):

1. 1SAR 8.3.2.1.1 Batteries

2. 2SAR 8.3.2.1.1 Batteries

3. NEI 99-01 CU4

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 102 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 5 - Loss of Communications Initiating Condition: Loss of all onsite or offsite communications capabilities EAL:

CU5.1 Unusual Event Loss of all Table 1[2]C-5 onsite communication methods OR Loss of all Table 1[2]C-5 State and local agency communication methods OR Loss of all Table 1[2]C-5 NRC communication methods Table 1[2]C-5 Communication Methods System Onsite ORO NRC Station radio system X ANO plant phone system X Gaitronics X Telephone Systems:

Commercial Microwave X X Satellite VOIP Emergency Notification System (ENS) X Mode Applicability:

5 - Cold Shutdown, 6 - Refueling, DEF - Defueled Definition(s):

None

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 103 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Basis:

This IC addresses a significant loss of on-site or offsite communications capabilities. While not a direct challenge to plant or personnel safety, this event warrants prompt notifications to State and local agencies and the NRC.

This IC should be assessed only when extraordinary means are being utilized to make communications possible (e.g., use of non-plant, privately owned equipment, relaying of on-site information via individuals or multiple radio transmission points, individuals being sent to offsite locations, etc.).

The first EAL condition addresses a total loss of the communications methods used in support of routine plant operations.

The second EAL condition addresses a total loss of the communications methods used to notify all State and local agencies of an emergency declaration. The State and local agencies referred to here are the Arkansas Department of Health, Arkansas Department of Emergency Management, Pope, Yell, Johnson, and Logan County offsite agencies.

The third EAL addresses a total loss of the communications methods used to notify the NRC of an emergency declaration.

This EAL is the cold condition equivalent of the hot condition EAL SU7.1.

Reference(s):

1. OP-1903.062 Communications System Operating Procedure

2. NEI 99-01 CU5

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 104 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 6 - Hazardous Event Affecting Safety Systems Initiating Condition: Hazardous event affecting SAFETY SYSTEMS needed for the current operating mode EAL:

CA6.1 Alert The occurrence of any Table 1[2]C-6 hazardous event AND Event damage has caused indications of degraded performance on one train of a SAFETY SYSTEM needed for the current operating mode AND EITHER:

Event damage has caused indications of degraded performance to the second train of the SAFETY SYSTEM needed for the current operating mode Event damage has resulted in VISIBLE DAMAGE to the second train of the SAFETY SYSTEM needed for the current operating mode (Notes 10, 11)

Note 10: If the affected SAFETY SYSTEM train was already inoperable or out of service before the hazardous event occurred, then emergency classification is not warranted.

Note 11: If the hazardous event only resulted in VISIBLE DAMAGE, with no indications of degraded performance to at least one train of a SAFETY SYSTEM, then this emergency classification is not warranted.

Table 1[2]C-6 Hazardous Events Seismic event (earthquake)

Internal or external FLOODING event High winds or tornado strike FIRE EXPLOSION Other events with similar hazard characteristics as determined by the Shift Manager

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 105 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

EXPLOSION - A rapid, violent and catastrophic failure of a piece of equipment due to combustion, chemical reaction or overpressurization. A release of steam (from high energy lines or components) or an electrical component failure (caused by short circuits, grounding, arcing, etc.) should not automatically be considered an explosion. Such events require a post-event inspection to determine if the attributes of an explosion are present.

FIRE - Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute fires. Observation of flame is preferred but is not required if large quantities of smoke and heat are observed.

FLOODING - A condition where water is entering a room or area faster than installed equipment is capable of removal, resulting in a rise of water level within the room or area.

SAFETY SYSTEM - A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related (as defined in 10 CFR 50.2).

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

VISIBLE DAMAGE - Damage to a SAFETY SYSTEM train that is readily observable without measurements, testing, or analysis. The visual impact of the damage is sufficient to cause concern regarding the operability or reliability of the affected SAFETY SYSTEM train.

Basis:

This IC addresses a hazardous event that causes damage to SAFETY SYSTEMS needed for the current operating mode. In order to provide the appropriate context for consideration of an ALERT classification, the hazardous event must have caused indications of degraded SAFETY SYSTEM performance in one train, and there must be either indications of performance issues with the second SAFETY SYSTEM train or VISIBLE DAMAGE to the second train such that the potential exists for this second SAFETY SYSTEM train to have performance issues. In other words, in order for this EAL to be classified, the hazardous event must occur, at least one SAFETY SYSTEM train must have indications of degraded performance, and the second SAFETY SYSTEM train must have indications of degraded performance or VISIBLE DAMAGE

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 106 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases such that the potential exists for performance issues. Note that this second SAFETY SYSTEM train is from the same SAFETY SYSTEM that has indications of degraded performance; commercial nuclear power plants are designed to be able to support single system issues without compromising public health and safety from radiological events.

Indications of degraded performance addresses damage to a SAFETY SYSTEM train that is in service/operation since indications for it will be readily available. The indications of degraded performance should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.

VISIBLE DAMAGE addresses damage to a SAFETY SYSTEM train that is not in service/operation and that potentially could cause performance issues. Operators will make this determination based on the totality of available event and damage report information. This is intended to be a brief assessment not requiring lengthy analysis or quantification of the damage.

This VISIBLE DAMAGE should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.

Escalation of the emergency classification level would be via IC CS1 or AS1.

This EAL is the cold condition equivalent of the hot condition EAL SA9.1.

Reference(s):

1. EP FAQ 2016-002

2. NEI 99-01 CA6

3. EP FAQ 2018-04

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 107 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category E - Independent Spent Fuel Storage Installation (ISFSI)

EAL Group: ANY (EALs in this category are applicable to any plant condition, hot or cold.)

An independent spent fuel storage installation (ISFSI) is a complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage. A significant amount of the radioactive material contained within a canister must escape its packaging and enter the biosphere for there to be a significant environmental effect resulting from an accident involving the dry storage of spent nuclear fuel.

An Unusual Event is declared on the basis of the occurrence of an event of sufficient magnitude that a loaded cask CONFINEMENT BOUNDARY is damaged or violated.

The ANO ISFSI is located wholly within the plant PROTECTED AREA. Therefore any security event related to the ISFSI is classified under Category H1 security event related EALs.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 108 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: E - ISFSI Subcategory: Confinement Boundary Initiating Condition: Damage to a loaded cask CONFINEMENT BOUNDARY EAL:

EU1.1 Unusual Event Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading on the surface of a loaded spent fuel cask (VSC-24 VCC or HI-STORM overpack) > any Table 1[2]E-1 value Table 1[2]E-1 ISFSI Dose Rates VSC-24 VCC HI-STORM 200 mrem/hr on the sides 60 mrem/hr (gamma + neutron) on the top or outlet vent 400 mrem/hr on the top 600 mrem/hr (gamma + neutron) on 700 mrem/hr at the air inlet the side of the overpack (excluding 200 mrem/hr at the air outlet inlet and outlet ducts)

Mode Applicability:

All Definition(s):

CONFINEMENT BOUNDARY - The barrier(s) between spent fuel and the environment once the spent fuel is processed for dry storage. As related to the ANO ISFSI, the Confinement Boundary is comprised of either the Multi-assembly Sealed Basket (MSB) (SNC System) or Multi-Purpose Canister (MPC) (Holtec System).

INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) - A complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage.

Basis:

This IC addresses an event that results in damage to the CONFINEMENT BOUNDARY of a storage cask containing spent fuel. It applies to irradiated fuel that is licensed for dry storage

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 109 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases beginning at the point that the loaded storage cask is sealed. The issues of concern are the creation of a potential or actual release path to the environment, degradation of one or more fuel assemblies due to environmental factors, and configuration changes which could cause challenges in removing the cask or fuel from storage.

The existence of damage is determined by radiological survey. The specified EAL threshold values correspond to 2 times the cask technical specification values (ref. 1, 2). The technical specification (licensing bases document) multiple of 2 times, which is also used in Recognition Category A IC AU1, is used here to distinguish between non-emergency and emergency conditions. The emphasis for this classification is the degradation in the level of safety of the spent fuel cask and not the magnitude of the associated dose or dose rate. It is recognized that in the case of extreme damage to a loaded cask, the fact that the on-contact dose rate limit is exceeded may be determined based on measurement of a dose rate at some distance from the cask.

Security-related events for ISFSIs are covered under ICs HU1 and HA1.

Reference(s):

1. Certificate of Compliance Appendix A Technical Specifications for the HI-STORM 100 Cask System Section 5.7.4

2. VSC-24 Storage Cask Final Safety Analysis Report Section 1.2.4 Maximum External Surface Dose Rate

3. NEI 99-01 E-HU1

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 110 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category F - Fission Product Barrier Degradation EAL Group: Hot Conditions (RCS temperature > 200°F); EALs in this category are applicable only in one or more hot operating modes.

EALs in this category represent threats to the defense in depth design concept that precludes the release of highly radioactive fission products to the environment. This concept relies on multiple physical barriers any one of which, if maintained intact, precludes the release of significant amounts of radioactive fission products to the environment. The primary fission product barriers are:

A. Fuel Clad Barrier (FCB): The Fuel Clad Barrier consists of the cladding material that contains the fuel pellets.

B. Reactor Coolant System Barrier (RCB): The RCS Barrier includes the RCS primary side and its connections up to and including the pressurizer safety and relief valves, and other connections up to and including the primary isolation valves.

C. Containment Barrier (CNB): The Containment Barrier includes the Reactor Building and connections up to and including the outermost containment isolation valves. This barrier also includes the main steam, feedwater, and blowdown line extensions outside the Reactor Building up to and including the outermost secondary side isolation valve.

Containment Barrier thresholds are used as criteria for escalation of the Emergency Classification Level (ECL) from an Alert to a Site Area Emergency or a General Emergency.

The EALs in this category require evaluation of the loss and potential loss thresholds listed in the fission product barrier matrix of Table F-1. Loss and Potential Loss signify the relative damage and threat of damage to the barrier. Loss means the barrier no longer assures containment of radioactive materials. Potential Loss means integrity of the barrier is threatened and could be lost if conditions continue to degrade. The number of barriers that are lost or potentially lost and the following criteria determine the appropriate emergency classification level:

Alert:

Any loss or any potential loss of either Fuel Clad or RCS Barrier Site Area Emergency:

Loss or potential loss of any two barriers General Emergency:

Loss of any two barriers and loss or potential loss of third barrier

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 111 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases The logic used for emergency classification based on fission product barrier monitoring should reflect the following considerations:

The Fuel Clad Barrier and the RCS Barrier are weighted more heavily than the Containment Barrier.

Unusual Event ICs associated with RCS and Fuel Clad Barriers are addressed under System Malfunction ICs.

For accident conditions involving a radiological release, evaluation of the fission product barrier thresholds will need to be performed in conjunction with dose assessments to ensure correct and timely escalation of the emergency classification. For example, an evaluation of the fission product barrier thresholds may result in a Site Area Emergency classification while a dose assessment may indicate that an EAL for General Emergency IC AG1 has been exceeded.

The fission product barrier thresholds specified within a scheme reflect plant-specific ANO design and operating characteristics.

As used in this category, the term RCS leakage encompasses not just those types defined in Technical Specifications but also includes the loss of RCS mass to any location - inside the containment, an interfacing system, or outside of the containment.

The release of liquid or steam mass from the RCS due to the as-designed/expected operation of a relief valve is not considered to be RCS leakage.

At the Site Area Emergency level, EAL users should maintain cognizance of how far present conditions are from meeting a threshold that would require a General Emergency declaration. For example, if the Fuel Clad and RCS fission product barriers were both lost, then there should be frequent assessments of containment radioactive inventory and integrity. Alternatively, if both the Fuel Clad and RCS fission product barriers were potentially lost, the Emergency Director would have more assurance that there was no immediate need to escalate to a General Emergency.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 112 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: F - Fission Product Barrier Degradation Subcategory: N/A Initiating Condition: Any loss or any potential loss of either Fuel Clad or RCS EAL:

FA1.1 Alert Any loss or any potential loss of either Fuel Clad or RCS barrier (Table 1[2]F-1)

Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

None Basis:

Fuel Clad, RCS and Containment comprise the fission product barriers. Table 1[2]F-1 lists the fission product barrier thresholds, bases and references.

At the Alert classification level, Fuel Clad and RCS barriers are weighted more heavily than the Containment barrier. Unlike the Containment barrier, loss or potential loss of either the Fuel Clad or RCS barrier may result in the relocation of radioactive materials or degradation of core cooling capability. Note that the loss or potential loss of Containment barrier in combination with loss or potential loss of either Fuel Clad or RCS barrier results in declaration of a Site Area Emergency under EAL FS1.1.

Reference(s):

1. NEI 99-01 FA1

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 113 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: F - Fission Product Barrier Degradation Subcategory: N/A Initiating Condition: Loss or potential loss of any two barriers EAL:

FS1.1 Site Area Emergency Loss or potential loss of any two barriers (Table 1[2]F-1)

Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

IMMINENT - The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.

Basis:

Fuel Clad, RCS and Containment comprise the fission product barriers. Table 1[2]F-1 lists the fission product barrier thresholds, bases and references.

At the Site Area Emergency classification level, each barrier is weighted equally. A Site Area Emergency is therefore appropriate for any combination of the following conditions:

One barrier loss and a second barrier loss (i.e., loss - loss)

One barrier loss and a second barrier potential loss (i.e., loss - potential loss)

One barrier potential loss and a second barrier potential loss (i.e., potential loss -

potential loss)

At the Site Area Emergency classification level, the ability to dynamically assess the proximity of present conditions with respect to the threshold for a General Emergency is important. For example, the existence of Fuel Clad and RCS Barrier loss thresholds in addition to offsite dose assessments would require continual assessments of radioactive inventory and Containment integrity in anticipation of reaching a General Emergency classification. Alternatively, if both Fuel Clad and RCS potential loss thresholds existed, the Emergency Director would have greater assurance that escalation to a General Emergency is less IMMINENT.

Reference(s):

1. NEI 99-01 FS1

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 114 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: F - Fission Product Barrier Degradation Subcategory: N/A Initiating Condition: Loss of any two barriers and loss or potential loss of third barrier EAL:

FG1.1 General Emergency Loss of any two barriers AND Loss or potential loss of the third barrier (Table 1[2]F-1)

Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

None Basis:

Fuel Clad, RCS and Containment comprise the fission product barriers. Table 1[2]F-1 lists the fission product barrier thresholds, bases and references.

At the General Emergency classification level each barrier is weighted equally. A General Emergency is therefore appropriate for any combination of the following conditions:

Loss of Fuel Clad, RCS and Containment Barriers Loss of Fuel Clad and RCS Barriers with potential loss of Containment Barrier Loss of RCS and Containment Barriers with potential loss of Fuel Clad Barrier Loss of Fuel Clad and Containment Barriers with potential loss of RCS Barrier Reference(s):

1. NEI 99-01 FG1

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 115 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Table 1[2]F-1 Fission Product Barrier Threshold Matrix & Bases Table 1[2]F-1 lists the threshold conditions that define the Loss and Potential Loss of the three fission product barriers (Fuel Clad, Reactor Coolant System, and Containment). The table is structured so that each of the three barriers occupies adjacent columns. Each fission product barrier column is further divided into two columns; one for Loss thresholds and one for Potential Loss thresholds.

The first column of the table (to the left of the Fuel Clad Loss column) lists the categories (types) of fission product barrier thresholds. The fission product barrier categories are:

A. RCS or S/G Tube Leakage B. Inadequate Heat removal C. Containment Radiation / RCS Activity D. Containment Integrity or Bypass E. Emergency Director Judgment Each category occupies a row in Table 1[2]F-1 thus forming a matrix defined by the categories.

The intersection of each row with each Loss/Potential Loss column forms a cell in which one or more fission product barrier thresholds appear. If NEI 99-01 does not define a threshold for a barrier Loss/Potential Loss, the word None is entered in the cell.

Thresholds are assigned sequential numbers within each barrier column beginning with number one (ex., FCB1, FCB2FCB9).

If a cell in Table 1[2]F-1 contains more than one numbered threshold, each of the numbered thresholds, if exceeded, signifies a Loss or Potential Loss of the barrier. It is not necessary to exceed all of the thresholds in a category before declaring a barrier Loss/Potential Loss.

Subdivision of Table 1[2]F-1 by category facilitates association of plant conditions to the applicable fission product barrier Loss and Potential Loss thresholds. This structure promotes a systematic approach to assessing the classification status of the fission product barriers.

When equipped with knowledge of plant conditions related to the fission product barriers, the EAL-user first scans down the category column of Table 1[2]F-1, locates the likely category and then reads across the fission product barrier Loss and Potential Loss thresholds in that category to determine if a threshold has been exceeded. If a threshold has not been exceeded, the EAL-user proceeds to the next likely category and continues review of the thresholds in the new category.

If the EAL-user determines that any threshold has been exceeded, by definition, the barrier is lost or potentially lost - even if multiple thresholds in the same barrier column are exceeded, only that one barrier is lost or potentially lost. The EAL-user must examine each of the three fission product barriers to determine if other barrier thresholds in the category are lost or potentially lost. For example, if containment radiation is sufficiently high, a Loss of the Fuel

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 116 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Clad and RCS Barriers and a Potential Loss of the Containment Barrier can occur. Barrier Losses and Potential Losses are then applied to the algorithms given in EALs FG1.1, FS1.1, and FA1.1 to determine the appropriate emergency classification.

In the remainder of this Attachment, the Fuel Clad Barrier threshold bases appear first, followed by the RCS Barrier and finally the Containment Barrier threshold bases. In each barrier, the bases are given according category Loss followed by category Potential Loss beginning with Category A, then B,, E.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 117 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Table 1[2]F-1 Fission Product Barrier Threshold Matrix Fuel Clad Barrier (FCB) Reactor Coolant System Barrier (RCB) Containment Barrier (CNB)

Category Loss Potential Loss Loss Potential Loss Loss Potential Loss RCB2 UNISOLABLE RCS leakage or S/G tube leakage > 50[44] gpm excluding normal reductions in RCS inventory (e.g.,

letdown, RCP seal leakoff)

RCB3 RCB1 Unit 1: PTS limits apply (RT14) CNB1 A An automatic or manual AND A S/G that is leaking FCB1 ESAS [ESFAS] actuation > 50[44] gpm (excluding RCS or S/G required by EITHER: RCS pressure and temperature are left None RVLMS Levels 1 through 9 normal reductions in RCS None of the NDTT/LTOP limit lines on EOP Tube [1 through 7] indicate DRY UNISOLABLE RCS Figure 3 (Note 12) inventory) or that is Leakage leakage RUPTURED is also FAULTED Unit 2: Uncontrolled RCS cooldown (> 50 °F S/G tube RUPTURE outside of containment step change or > 100 °F change in less than a one-hour period)

AND RCS pressure and temperature are to the left of line B (200 degrees MTS),

Standard Attachment 1, P-T Limits (Note 12)

FCB3 CETs > 700°F FCB4 RCB4 B RCS heat removal cannot be RCS heat removal cannot be established using CNB2 established using steam steam generators CETs > 1200°F Inadequate FCB2 generators None AND None AND Heat CETs > 1200°F AND An on-shift SRO has determined that the Restoration procedures not effective Removal An on-shift SRO has procedure conditions are met to commence within 15 min. (Note 1) determined that the procedure initiation of HPI[Once Through] cooling conditions are met to commence initiation of HPI[Once Through] cooling FCB5 Containment High C Range Radiation RCB5 Monitor RE-8060/8061 CNB3 CTMT [2RE-8925-1/ 8925-2] Containment High Range None None None Containment High Range Radiation Radiation / > 750 [700] R/hr Radiation Monitor RE-Monitor RE-8060/8061 [2RE-8925-1/

8060/8061 [2RE-8925-1/

RCS FCB6 8925-2] > 40[50] R/hr 8925-2] > 10,000[12,000] R/hr Activity Coolant activity

> 300 Ci/gm dose equivalent I-131

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 118 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Table 1[2]F-1 Fission Product Barrier Threshold Matrix Fuel Clad Barrier (FCB) Reactor Coolant System Barrier (RCB) Containment Barrier (CNB)

Category Loss Potential Loss Loss Potential Loss Loss Potential Loss CNB4 Containment isolation is CNB6 required Containment pressure > 73.7 psia AND EITHER:

CNB7 Containment integrity D has been lost based on Containment hydrogen concentration Emergency Director > 4%

CTMT None None None None judgment CNB8 Integrity or UNISOLABLE pathway Containment pressure > 44.7 psia Bypass from Containment to the [23.3 psia] with < one full train of environment exists containment heat removal systems CNB5 (Note 9) operating per design for 15 min. (Note 1)

Indications of RCS leakage outside of Containment FCB7 E Any condition in the FCB8 RCB6 RCB7 CNB9 CNB10 Any condition in the opinion of Any condition in the opinion Any condition in the opinion of Any condition in the opinion of the Emergency opinion of the the Emergency Director that of the Emergency Director Any condition in the opinion of the Emergency the Emergency Director that Emergency Director that indicates Director Emergency Director Director that indicates potential loss of the RCS indicates potential loss of the that indicates loss of the RCS indicates loss of the potential loss of the Containment that indicates loss of barrier Judgment Fuel Clad barrier barrier Containment barrier barrier the Fuel Clad barrier

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 119 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Barrier: Fuel Clad Category: A - RCS or S/G Tube Leakage Degradation Threat: Loss Threshold:

None

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 120 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Barrier: Fuel Clad Category: A - RCS or S/G Tube Leakage Degradation Threat: Potential Loss Threshold:

FCB1 RVLMS Levels 1 through 9[1 through 7] indicate DRY Definition(s):

None Basis:

This reading indicates a reduction in reactor vessel water level sufficient to allow the onset of heat-induced cladding damage.

There is no Fuel Clad Barrier Loss threshold associated with RCS or S/G Tube Leakage.

Reference(s):

1. ULD-1-SYS-24 Unit 1 Inadequate Core Cooling System

2. Calculation 84-EQ-0080-02 Loop Error Analysis for Reactor Vessel Level Monitoring System

3. ULD-2-SYS-24 Unit 2 Inadequate Core Cooling Monitoring System

4. Calculation 90-E-0116-01 Unit 2 EOP Setpoint Document, Setpoint R.3

5. NEI 99-01 RCS or SG Tube Leakage Potential Loss 1.A

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 121 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Barrier: Fuel Clad Category: B - Inadequate Heat Removal Degradation Threat: Loss Threshold:

FCB2 CETs > 1200°F Definition(s):

None Basis:

This reading indicates temperatures within the core are sufficient to cause significant superheating of reactor coolant.

Reference(s):

1. NEI 99-01 Inadequate Heat Removal Loss 2.A

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 122 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Barrier: Fuel Clad Category: B - Inadequate Heat Removal Degradation Threat: Potential Loss Threshold:

FCB3 CETs > 700°F Definition(s):

None Basis:

This reading indicates a reduction in reactor vessel water level sufficient to allow the onset of heat-induced cladding damage.

Reference(s):

1. NEI 99-01 Inadequate Heat Removal Potential Loss 2.A

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 123 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Barrier: Fuel Clad Category: B - Inadequate Heat Removal Degradation Threat: Potential Loss Threshold:

FCB4 RCS heat removal cannot be established using steam generators AND An on-shift SRO has determined that the procedure conditions are met to commence initiation of HPI[Once Through] cooling Definition(s):

None Basis:

This condition indicates an extreme challenge to the ability to remove RCS heat using the steam generators (i.e., loss of an effective secondary-side heat sink). This condition represents a potential loss of the Fuel Clad Barrier. In accordance with EOPs, there may be unusual accident conditions during which operators intentionally reduce the heat removal capability of the steam generators; during these conditions, classification using this threshold is not warranted.

In combination with Potential Loss RCB4, meeting this threshold results in a Site Area Emergency.

Reference(s):

1. OP-1202.004 Overheating

2. OP-1202.013 Figure 4, Core Exit Thermocouple for Inadequate Core Cooling

3. OP-2202.006 Loss of Feedwater

4. OP-2202.009 Functional Recovery, Safety Function Status Check 5

5. NEI 99-01 Inadequate Heat Removal Potential Loss 2.B

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 124 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Barrier: Fuel Clad Category: C - CTMT Radiation / RCS Activity Degradation Threat: Loss Threshold:

FCB5 Containment High Range Radiation Monitor RE-8060/8061[2RE-8925-1/8925-2]

> 750[700] R/hr Definition(s):

None Basis:

The containment radiation monitor reading (768[682] R/hr rounded to 750[700] R/hr for readability) corresponds to an instantaneous release of all reactor coolant mass into the containment, assuming that reactor coolant activity equals 300 µCi/gm dose equivalent I-131.

Reactor coolant activity above this level is greater than that expected for iodine spikes and corresponds to 1.49[1.13]% fuel clad damage. Since this condition indicates that a significant amount of fuel clad damage has occurred, it represents a loss of the Fuel Clad Barrier.

The radiation monitor reading in this threshold is higher than that specified for RCS Barrier Loss threshold RCB5 since it indicates a loss of both the Fuel Clad Barrier and the RCS Barrier.

Note that a combination of the two monitor readings appropriately escalates the ECL to a Site Area Emergency.

There is no Potential Loss threshold associated with CTMT Radiation/RCS Activity.

Reference(s):

1. EP-CALC-ANO-1702 Containment High Range Radiation Monitor EAL Values

2. NEI 99-01 RCS Activity/Containment Radiation FC Loss 3.A

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 125 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Barrier: Fuel Clad Category: C - CTMT Radiation / RCS Activity Degradation Threat: Loss Threshold:

FCB6 Coolant activity > 300 µCi/gm dose equivalent I-131 Definition(s):

None Basis:

This threshold indicates that RCS radioactivity concentration is greater than 300 µCi/gm dose equivalent I-131. Reactor coolant activity above this level is greater than that expected for iodine spikes and corresponds to an approximate range of 2% to 5% fuel clad damage. Since this condition indicates that a significant amount of fuel clad damage has occurred, it represents a loss of the Fuel Clad Barrier.

It is recognized that sample collection and analysis of reactor coolant with highly elevated activity levels could require several hours to complete. Nonetheless, a sample-related threshold is included as a backup to other indications.

There is no Potential Loss threshold associated with CTMT Radiation/RCS Activity.

Reference(s):

1. NEI 99-01 RCS Activity/Containment Radiation Fuel Clad Loss 3.B

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 126 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Barrier: Fuel Clad Category: C - CTMT Radiation / RCS Activity Degradation Threat: Potential Loss Threshold:

None

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 127 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Barrier: Fuel Clad Category: D - CTMT Integrity or Bypass Degradation Threat: Loss Threshold:

None

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 128 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Barrier: Fuel Clad Category: D - CTMT Integrity or Bypass Degradation Threat: Potential Loss Threshold:

None

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 129 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Barrier: Fuel Clad Category: E - Emergency Director Judgment Degradation Threat: Loss Threshold:

FCB7 Any condition in the opinion of the Emergency Director that indicates loss of the Fuel Clad barrier Definition(s):

None Basis:

This threshold addresses any other factors that are to be used by the Emergency Director in determining whether the Fuel Clad barrier is lost.

Reference(s):

1. NEI 99-01 Emergency Director Judgment Fuel Clad Loss 6.A

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 130 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Barrier: Fuel Clad Category: E - Emergency Director Judgment Degradation Threat: Potential Loss Threshold:

FCB8 Any condition in the opinion of the Emergency Director that indicates potential loss of the Fuel Clad barrier Definition(s):

None Basis:

This threshold addresses any other factors that are to be used by the Emergency Director in determining whether the Fuel Clad barrier is potentially lost. The Emergency Director should also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored.

Reference(s):

1. NEI 99-01 Emergency Director Judgment Potential Fuel Clad Loss 6.A

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 131 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Barrier: Reactor Coolant System Category: A - RCS or S/G Tube Leakage Degradation Threat: Loss Threshold:

RCB1 An automatic or manual ESAS[ESFAS] actuation required by EITHER:

UNISOLABLE RCS leakage S/G tube RUPTURE Definition(s):

FAULTED - The term applied to a steam generator that has a steam leak on the secondary side of sufficient size to cause an uncontrolled drop in steam generator pressure or the steam generator to become completely depressurized.

RUPTURED - The condition of a steam generator in which primary-to-secondary leakage is of sufficient magnitude to require a safety injection (automatic or manual).

UNISOLABLE - An open or breached system line that cannot be isolated, remotely or locally.

Basis:

Failure to isolate the leak (from the Control Room or locally), within 15 minutes or if known that the leak cannot be isolated within 15 minutes, from the start of the leak requires immediate classification.

This threshold is based on an UNISOLABLE RCS leak of sufficient size to require an automatic or manual actuation of the Emergency Core Cooling System (ECCS). This condition clearly represents a loss of the RCS Barrier.

This threshold is applicable to unidentified and pressure boundary leakage, as well as identified leakage. It is also applicable to UNISOLABLE RCS leakage through an interfacing system.

The mass loss may be into any location - inside containment, to the secondary-side (i.e., steam generator tube leakage) or outside of containment.

A steam generator with primary-to-secondary leakage of sufficient magnitude to require a safety injection is considered to be RUPTURED. If a RUPTURED steam generator is also FAULTED outside of containment, the declaration escalates to a Site Area Emergency since the Containment Barrier Loss threshold CNB1 will also be met.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 132 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Reference(s):

1. OP-1202.010 ESAS

2. OP-2202.003 Loss of Coolant Accident

3. NEI 99-01 RCS or SG Tube Leakage Reactor Coolant System Loss 1.A

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 133 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Barrier: Reactor Coolant System Category: A - RCS or S/G Tube Leakage Degradation Threat: Potential Loss Threshold:

RCB2 UNISOLABLE RCS leakage or S/G tube leakage > 50[44] gpm excluding normal reductions in RCS inventory (e.g., letdown, RCP seal leakoff)

Definition(s):

FAULTED - The term applied to a steam generator that has a steam leak on the secondary side of sufficient size to cause an uncontrolled drop in steam generator pressure or the steam generator to become completely depressurized.

UNISOLABLE - An open or breached system line that cannot be isolated, remotely or locally.

Basis:

Failure to isolate the leak (from the Control Room or locally), within 15 minutes or if known that the leak cannot be isolated within 15 minutes, from the start of the leak requires immediate classification.

This threshold is based on an UNISOLABLE RCS leak that results in the inability to maintain pressurizer level within specified limits by operation of a normally used makeup [charging]

pump, but an ESAS [ESFAS] actuation has not occurred.

This threshold is applicable to unidentified and pressure boundary leakage, as well as identified leakage. It is also applicable to UNISOLABLE RCS leakage through an interfacing system.

The mass loss may be into any location - inside containment, to the secondary-side (i.e., steam generator tube leakage) or outside of containment.

If a leaking steam generator is also FAULTED outside of containment, the declaration escalates to a Site Area Emergency since the Containment Barrier Loss threshold CNB1 will also be met.

Reference(s):

1. 1SAR 9.1 Makeup and Purification System

2. 2SAR 9.3.4 Chemical and Volume Control System

3. NEI 99-01 RCS or SG Tube Leakage Reactor Coolant System Potential Loss 1.A

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 134 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Barrier: Reactor Coolant System Category: A - RCS or S/G Tube Leakage Degradation Threat: Potential Loss Threshold:

RCB3 Unit 1:

PTS limits apply (RT14)

AND RCS pressure and temperature are left of the NDTT/LTOP limit lines, on EOP Figure 3 (Note 12)

Unit 2:

Uncontrolled RCS cooldown (> 50 °F step change or > 100 °F change in less than a one-hour period)

AND RCS pressure and temperature are to the left of line B (200 degrees MTS), Standard Attachment 1, P-T Limits (Note 12)

Note 12: Once PTS limits are first invoked, if RCS temperature and pressure are not brought within the limits within 15 minutes, this threshold is met and an immediate declaration is warranted. This threshold is met immediately upon exceeding the limits after this initial 15 minute period until PTS limits no longer apply.

Definition(s):

None Basis:

This condition indicates an extreme challenge to the integrity of the RCS pressure boundary due to pressurized thermal shock - a transient that causes rapid RCS cooldown while the RCS is in Mode 3 or higher (i.e., hot and pressurized).

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 135 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Reference(s):

1. OP-1202.012 Repetitive Task 14 Control RCS Pressure

2. OP-1202.013 EOP Figures, Figure 3 RCS Pressure vs Temperature Limits

3. OP-1202.011 HPI Cooldown

4. Calculation No: 90-E-0116-01 ANO- EOP Setpoint Basis Document OP Setpoint P.2, RCS Pressure-Temperature

5. OP-2202.010 Standard Attachments, Attachment 1, P-T Limits

6. NEI 99-01 RCS or SG Tube Leakage Reactor Coolant System Potential Loss 1.B

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 136 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Barrier: Reactor Coolant System Category: B - Inadequate Heat Removal Degradation Threat: Loss Threshold:

None

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 137 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Barrier: Reactor Coolant System Category: B - Inadequate Heat Removal Degradation Threat: Potential Loss Threshold:

RCB4 RCS heat removal cannot be established using steam generators AND An on-shift SRO has determined that the procedure conditions are met to commence initiation of HPI[Once Through] cooling Definition(s):

None Basis:

This condition indicates an extreme challenge to the ability to remove RCS heat using the steam generators (i.e., loss of an effective secondary-side heat sink). This condition represents a potential loss of the RCS Barrier. In accordance with EOPs, there may be unusual accident conditions during which operators intentionally reduce the heat removal capability of the steam generators; during these conditions, classification using this threshold is not warranted.

In combination with Potential Loss FCB4, meeting this threshold results in a Site Area Emergency.

This condition warrants a Site Area Emergency declaration because inadequate RCS heat removal may result in fuel heat-up sufficient to damage the cladding and raise RCS pressure to the point where mass will be lost from the system.

There is no RCS barrier Loss threshold associated with Inadequate Heat Removal.

Reference(s):

1. OP-1202.004 Overheating

2. OP-1202.013 Figure 4, Core Exit Thermocouple for Inadequate Core Cooling

3. OP-2202.006 Loss of Feedwater

4. OP-2202.009 Functional Recovery, Safety Function Status Check 5

5. NEI 99-01 Inadequate Heat Removal RCS Potential Loss 2.B

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 138 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Barrier: Reactor Coolant System Category: C - CTMT Radiation/ RCS Activity Degradation Threat: Loss Threshold:

RCB5 Containment High Range Radiation Monitor RE-8060/8061[2RE-8925-1/8925-2] > 40[50] R/hr Definition(s):

None Basis:

NRC Information Notice 97-045, Supplement 1, identifies the potential for erratic indications from the high range radiation monitors (HRRMs) as a result of thermally induced currents (TIC) which may cause the HRRM to read falsely high (for approximately 15 minutes) on a rapid temperature rise, and fail low intermittently on a rapid temperature fall. Because of this phenomenon, any trends or alarms on the HRRMs should be validated by comparison to the containment low range/area radiation monitors and Air Monitoring Systems trends before actions are taken.

The containment radiation monitor reading (42.8[50.4] R/hr rounded to 40[50] R/hr for readability) corresponds to an instantaneous release of all reactor coolant mass into the containment, assuming that reactor coolant activity equals Technical Specification allowable limits. This value is lower than that specified for Fuel Clad Barrier Loss threshold FCB5 since it indicates a loss of the RCS Barrier only.

There is no Potential Loss threshold associated with CTMT Radiation/RCS Activity.

Reference(s):

1. EP-CALC-ANO-1702 Containment High Range Radiation Monitor EAL Values

2. NEI 99-01 CMT Radiation / RCS Activity RCS Loss 3.A

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 139 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Barrier: Reactor Coolant System Category: B - CTMT Radiation/ RCS Activity Degradation Threat: Potential Loss Threshold:

None

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 140 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Barrier: Reactor Coolant System Category: D - CTMT Integrity or Bypass Degradation Threat: Loss Threshold:

None

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 141 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Barrier: Reactor Coolant System Category: D - CTMT Integrity or Bypass Degradation Threat: Potential Loss Threshold:

None

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 142 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Barrier: Reactor Coolant System Category: E - Emergency Director Judgment Degradation Threat: Loss Threshold:

RCB6 Any condition in the opinion of the Emergency Director that indicates loss of the RCS barrier Definition(s):

None Basis:

This threshold addresses any other factors that may be used by the Emergency Director in determining whether the RCS Barrier is lost.

Reference(s):

1. NEI 99-01 Emergency Director Judgment RCS Loss 6.A

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 143 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Barrier: Reactor Coolant System Category: E - Emergency Director Judgment Degradation Threat: Potential Loss Threshold:

RCB7 Any condition in the opinion of the Emergency Director that indicates potential loss of the RCS barrier Definition(s):

None Basis:

This threshold addresses any other factors that may be used by the Emergency Director in determining whether the RCS Barrier is potentially lost. The Emergency Director should also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored.

Reference(s):

1. NEI 99-01 Emergency Director Judgment RCS Potential Loss 6.A

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 144 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Barrier: Containment Category: A - RCS or S/G Tube Leakage Degradation Threat: Loss Threshold:

CNB1 A S/G that is leaking > 50[44] gpm (excluding normal reductions in RCS inventory) or that is RUPTURED is also FAULTED outside of containment Definition(s):

FAULTED - The term applied to a steam generator that has a steam leak on the secondary side of sufficient size to cause an uncontrolled drop in steam generator pressure or the steam generator to become completely depressurized.

RUPTURED - The condition of a steam generator in which primary-to-secondary leakage is of sufficient magnitude to require a safety injection (automatic or manual).

Basis:

This threshold addresses a leaking or RUPTURED Steam Generator (SG) that is also FAULTED outside of containment. The condition of the SG, whether leaking or RUPTURED, is determined in accordance with the thresholds for RCS Barrier Potential Loss RCB2 and Loss RCB1, respectively. This condition represents a bypass of the containment barrier.

FAULTED is a defined term within the NEI 99-01 methodology; this determination is not necessarily dependent upon entry into, or diagnostic steps within, an EOP. For example, if the pressure in a steam generator is dropping uncontrollably (part of the FAULTED definition) and the FAULTED steam generator isolation procedure is not entered because EOP user rules are dictating implementation of another procedure to address a higher priority condition, the steam generator is still considered FAULTED for emergency classification purposes.

The FAULTED criterion establishes an appropriate lower bound on the size of a steam release that may require an emergency classification. Steam releases of this size are readily observable with normal Control Room indications. The lower bound for this aspect of the containment barrier is analogous to the lower bound criteria specified in IC SU4 for the fuel clad barrier (i.e., RCS activity values) and IC SU5 for the RCS barrier (i.e., RCS leak rate values).

This threshold also applies to prolonged steam releases necessitated by operational considerations such as the forced steaming of a leaking or RUPTURED steam generator directly to atmosphere to cooldown the plant. These types of conditions will result in a significant and sustained release of radioactive steam to the environment (and are thus similar to a FAULTED condition). The inability to isolate the steam flow without an adverse effect on plant cooldown meets the intent of a loss of containment.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 145 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Steam releases associated with the expected operation of a SG power operated relief valve or safety relief valve do not meet the intent of this threshold. Such releases may occur intermittently for a short period of time following a reactor trip as operators process through emergency operating procedures to bring the plant to a stable condition and prepare to initiate a plant cooldown. Steam releases associated with the unexpected operation of a valve (e.g., a stuck-open safety valve) do meet this threshold.

Following a SG tube leak or rupture, there may be minor radiological releases through a secondary-side system component (e.g., air ejectors, glad seal exhausters, valve packing, etc.).

These types of releases do not constitute a loss or potential loss of containment but should be evaluated using the Recognition Category A ICs.

The ECLs resulting from primary-to-secondary leakage, with or without a steam release from the FAULTED SG, are summarized below.

Affected SG is FAULTED Outside of Containment?

P-to-S Leak Rate Yes No Less than or equal to 25 gpm No classification No classification Greater than 25 gpm Unusual Event per SU5.1 Unusual Event per SU5.1 Greater than 50[44] gpm (RCS Site Area Emergency per Alert per FA1.1 Barrier Potential Loss) FS1.1 Requires an automatic or manual Site Area Emergency per ESAS[ESFAS] actuation (RCS Alert per FA1.1 FS1.1 Barrier Loss)

There is no Potential Loss threshold associated with RCS or S/G Tube Leakage.

Reference(s):

1. NEI 99-01 RCS or SG Tube Leakage Containment Loss 1.A

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 146 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Barrier: Containment Category: A - RCS or S/G Tube Leakage Degradation Threat: Potential Loss Threshold:

None

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 147 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Barrier: Containment Category: B - Inadequate Heat Removal Degradation Threat: Loss Threshold:

None

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 148 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Barrier: Containment Category: B - Inadequate Heat Removal Degradation Threat: Potential Loss Threshold:

CNB2 CETs > 1200°F AND Restoration procedures not effective within 15 min. (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Definition(s):

IMMINENT - The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.

Basis:

The restoration procedure is considered effective if core exit thermocouple readings are dropping and/or if reactor vessel level is rising. Whether or not the procedure(s) will be effective should be apparent within 15 minutes. The Emergency Director should escalate the emergency classification level as soon as it is determined that the procedure(s) will not be effective.

This condition represents an IMMINENT core melt sequence which, if not corrected, could lead to vessel failure and an increased potential for containment failure. For this condition to occur, there must already have been a loss of the RCS Barrier and the Fuel Clad Barrier. If implementation of a procedure(s) to restore adequate core cooling is not effective (successful) within 15 minutes, it is assumed that the event trajectory will likely lead to core melting and a subsequent challenge of the Containment Barrier.

Severe accident analyses (e.g., NUREG-1150) have concluded that function restoration procedures can arrest core degradation in a significant fraction of core damage scenarios, and that the likelihood of containment failure is very small in these events. Given this, it is appropriate to provide 15 minutes beyond the required entry point to determine if procedural actions can reverse the core melt sequence.

Reference(s):

1. NEI 99-01 Inadequate Heat Removal Containment Potential Loss 2.A

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 149 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Barrier: Containment Category: C - CTMT Radiation/RCS Activity Degradation Threat: Loss Threshold:

None

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 150 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Barrier: Containment Category: C - CTMT Radiation/RCS Activity Degradation Threat: Potential Loss Threshold:

CNB3 Containment High Range Radiation Monitor RE-8060/8061[2RE-8925-1/8925-2]

> 10,000[12,000] R/hr Definition(s):

None Basis:

The containment radiation monitor reading (10,300[12,100] R/hr rounded to 10,000[12,000] R/hr for readability) corresponds to an instantaneous release of all reactor coolant mass into the containment, assuming that 20% of the fuel cladding has failed. This level of fuel clad failure is well above that used to determine the analogous Fuel Clad Barrier Loss and RCS Barrier Loss thresholds.

NUREG-1228, Source Estimations During Incident Response to Severe Nuclear Power Plant Accidents, indicates the fuel clad failure must be greater than approximately 20% in order for there to be a major release of radioactivity requiring offsite protective actions. For this condition to exist, there must already have been a loss of the RCS Barrier and the Fuel Clad Barrier. It is therefore prudent to treat this condition as a potential loss of containment which would then escalate the ECL to a General Emergency.

There is no Loss threshold associated with CTMT Radiation/RCS Activity.

Reference(s):

1. EP-CALC-ANO-1702 Containment High Range Radiation Monitor EAL Values

2. NEI 99-01 CTMT Radiation / RCS Activity Containment Potential Loss 3.A

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 151 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Barrier: Containment Category: D - CTMT Integrity or Bypass Degradation Threat: Loss Threshold:

CNB4 Containment isolation is required AND EITHER:

Containment integrity has been lost based on Emergency Director judgment UNISOLABLE pathway from Containment to the environment exists Definition(s):

UNISOLABLE - An open or breached system line that cannot be isolated, remotely or locally.

Basis:

Failure to isolate the leak (from the Control Room or locally), within 15 minutes or if known that the leak cannot be isolated within 15 minutes, from the start of the leak requires immediate classification.

The status of the containment barrier during an event involving steam generator tube leakage is assessed using Loss Threshold CNB1.

These thresholds address a situation where containment isolation is required and one of two conditions exists as discussed below. Users are reminded that there may be accident and release conditions that simultaneously meet both bulleted thresholds.

First Threshold - Containment integrity has been lost, i.e., the actual containment atmospheric leak rate likely exceeds that associated with allowable leakage (or sometimes referred to as design leakage). Following the release of RCS mass into containment, containment pressure will fluctuate based on a variety of factors; a loss of containment integrity condition may (or may not) be accompanied by a noticeable drop in containment pressure. Recognizing the inherent difficulties in determining a containment leak rate during accident conditions, it is expected that the Emergency Director will assess this threshold using judgment, and with due consideration given to current plant conditions, and available operational and radiological data (e.g.,

containment pressure, readings on radiation monitors outside containment, operating status of containment pressure control equipment, etc.).

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 152 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Refer to the middle piping run of Figure 1. Two simplified examples are provided. One is leakage from a penetration and the other is leakage from an in-service system valve.

Depending upon radiation monitor locations and sensitivities, the leakage could be detected by any of the four monitors depicted in the figure.

Another example would be a loss or potential loss of the RCS barrier, and the simultaneous occurrence of two FAULTED locations on a steam generator where one fault is located inside containment (e.g., on a steam or feedwater line) and the other outside of containment. In this case, the associated steam line provides a pathway for the containment atmosphere to escape to an area outside the containment.

Following the leakage of RCS mass into containment and a rise in containment pressure, there may be minor radiological releases associated with allowable (design) containment leakage through various penetrations or system components. These releases do not constitute a loss or potential loss of containment but should be evaluated using the Recognition Category A ICs.

Second Threshold - Conditions are such that there is an UNISOLABLE pathway for the migration of radioactive material from the containment atmosphere to the environment. As used here, the term environment includes the atmosphere of a room or area, outside the containment, that may, in turn, communicate with the outside-the-plant atmosphere (e.g.,

through discharge of a ventilation system or atmospheric leakage). Depending upon a variety of factors, this condition may or may not be accompanied by a noticeable drop in containment pressure.

Refer to the top piping run of Figure 1. In this simplified example, the inboard and outboard isolation valves remained open after a containment isolation was required (i.e., containment isolation was not successful). There is now an UNISOLABLE pathway from the containment to the environment.

The existence of a filter is not considered in the threshold assessment. Filters do not remove fission product noble gases. In addition, a filter could become ineffective due to iodine and/or particulate loading beyond design limits (i.e., retention ability has been exceeded) or water saturation from steam/high humidity in the release stream.

Leakage between two interfacing liquid systems, by itself, does not meet this threshold.

Refer to the bottom piping run of Figure 1. In this simplified example, leakage in an RCP seal cooler is allowing radioactive material to enter the Auxiliary Building. The radioactivity would be detected by the Process Monitor. If there is no leakage from the closed water cooling system to the Auxiliary Building, then no threshold has been met. If the pump developed a leak that allowed steam/water to enter the Auxiliary Building, then second threshold would be met.

Depending upon radiation monitor locations and sensitivities, this leakage could be detected by any of the four monitors depicted in the figure and cause the first threshold to be met as well.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 153 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Following the leakage of RCS mass into containment and a rise in containment pressure, there may be minor radiological releases associated with allowable containment leakage through various penetrations or system components. Minor releases may also occur if a containment isolation valve(s) fails to close but the containment atmosphere escapes to an enclosed system.

These releases do not constitute a loss or potential loss of containment but should be evaluated using the Recognition Category A ICs.

Reference(s):

1. NEI 99-01 CTMT Integrity or Bypass Containment Loss 4.A

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 154 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Barrier: Containment Category: D - CTMT Integrity or Bypass Degradation Threat: Loss Threshold:

CNB5 Indications of RCS leakage outside of Containment Definition(s):

None Basis:

To ensure proper escalation of the emergency classification, the RCS leakage outside of containment must be related to the mass loss that is causing the RCS Loss RCB1 and/or Potential Loss RCB2 threshold to be met.

The status of the containment barrier during an event involving steam generator tube leakage is assessed using Containment Loss Threshold CNB1.

Containment sump, temperature, pressure and/or radiation levels will rise if reactor coolant mass is leaking into the containment. If these parameters have not risen, then the reactor coolant mass may be leaking outside of containment (i.e., a containment bypass sequence).

Rises in sump, temperature, pressure, flow and/or radiation level readings outside of the containment may indicate that the RCS mass is being lost outside of containment.

Unexpected elevated readings and alarms on radiation monitors with detectors outside containment should be corroborated with other available indications to confirm that the source is a loss of RCS mass outside of containment. If the fuel clad barrier has not been lost, radiation monitor readings outside of containment may not rise significantly; however, other unexpected changes in sump levels, area temperatures or pressures, flow rates, etc. should be sufficient to determine if RCS mass is being lost outside of the containment.

Refer to the middle piping run of Figure 1. In this simplified example, a leak has occurred at a reducer on a pipe carrying reactor coolant in the Auxiliary Building. Depending upon radiation monitor locations and sensitivities, the leakage could be detected by any of the four monitors depicted in the figure and cause threshold CNB4 to be met as well.

Reference(s):

1. NEI 99-01 CTMT Integrity or Bypass Containment Loss 4.B

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 155 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Figure 1: Containment Integrity or Bypass Examples nd 2 Threshold - Airborne release from pathway Effluent Inside Auxiliary Monitor Reactor Building Building Damper Area Monitor Open valve Open valve Damper st Penetration 1 Threshold -

Airborne Airborne Monitor nd Open valve Open valve 2 Threshold -

RCS leakage st Interface 1 Threshold - Airborne outside AB leakage release from penetration Process Monitor Closed Cooling Open valve Open valve Pump RCP Seal Cooling

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 156 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Barrier: Containment Category: D - CTMT Integrity or Bypass Degradation Threat: Potential Loss Threshold:

CNB6 Containment pressure > 73.7 psia Definition(s):

None Basis:

If containment pressure exceeds the design pressure, there exists a potential to lose the Containment Barrier. To reach this level, there must be an inadequate core cooling condition for an extended period of time; therefore, the RCS and Fuel Clad barriers would already be lost.

Thus, this threshold is a discriminator between a Site Area Emergency and General Emergency since there is now a potential to lose the third barrier.

Reference(s):

1. 1SAR 1.4.43 Criterion 50 - Containment Design Basis

2. 2SAR Table 6.2-7 Principle Containment Design Parameters

3. NEI 99-01 CTMT Integrity or Bypass Containment Potential Loss 4.A

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 157 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Barrier: Containment Category: D - CTMT Integrity or Bypass Degradation Threat: Potential Loss Threshold:

CNB7 Containment hydrogen concentration > 4%

Definition(s):

None Basis:

The existence of an explosive mixture means, at a minimum, that the containment atmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at the lower deflagration limit). The 4% hydrogen concentration is generally considered the lower limit for hydrogen deflagrations. A hydrogen burn will raise containment pressure and could result in collateral equipment damage leading to a loss of containment integrity. It therefore represents a potential loss of the Containment Barrier.

Reference(s):

1. Unit 1 SAMG Figure III-1B

2. Unit 2 SAMG Phase 1 Instructions, Containment Flowchart

3. NEI 99-01 CTMT Integrity or Bypass Containment Potential Loss 4.B

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 158 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Barrier: Containment Category: D - CTMT Integrity or Bypass Degradation Threat: Potential Loss Threshold:

CNB8 Containment pressure > 44.7 psia[23.3 psia] with < one full train of containment heat removal systems (Note 9) operating per design for 15 min. (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Note 9: One full train of containment heat removal systems consists of one train of RB [Containment]

Spray and one train of RB [Containment] Cooling System.

Definition(s):

None Basis:

This threshold describes a condition where containment pressure is greater than the setpoint at which containment energy (heat) removal systems are designed to automatically actuate, and less than one full train of equipment is capable of operating per design. The 15-minute criterion is included to allow operators time to manually start equipment that may not have automatically started, if possible. This threshold represents a potential loss of containment in that containment heat removal/depressurization systems (e.g., containment sprays but not including containment venting strategies) are either lost or performing in a degraded manner.

Reference(s):

1. 1SAR 6.2 Reactor Building Spray System

2. 1SAR 6.3 Reactor Building Cooling System

3. OP-2202.003 Loss of Coolant Accident

4. OP-2202.010 Standard Attachments, Attachment 22

5. 2SAR 6.2.2 Containment Heat Removal Systems

6. 2SAR 7.3.1.1.11.2 Containment Spray System

7. NEI 99-01 CTMT Integrity or Bypass Containment Potential Loss 4.C

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 159 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Barrier: Containment Category: E - Emergency Director Judgment Degradation Threat: Loss Threshold:

CNB9 Any condition in the opinion of the Emergency Director that indicates loss of the Containment barrier Definition(s):

None Basis:

This threshold addresses any other factors that may be used by the Emergency Director in determining whether the Containment Barrier is lost.

Reference(s):

1. NEI 99-01 Emergency Director Judgment Containment Loss 6.A

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 160 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Barrier: Containment Category: E - Emergency Director Judgment Degradation Threat: Potential Loss Threshold:

CNB10 Any condition in the opinion of the Emergency Director that indicates potential loss of the Containment barrier Definition(s):

None Basis:

This threshold addresses any other factors that may be used by the Emergency Director in determining whether the Containment Barrier is potentially lost. The Emergency Director should also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored.

Reference(s):

1. NEI 99-01 Emergency Director Judgment Containment Potential Loss 6.A

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 161 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category H - Hazards and Other Conditions Affecting Plant Safety EAL Group: ANY (EALs in this category are applicable to any plant condition, hot or cold.)

Hazards are non-plant, system-related events that can directly or indirectly affect plant operation, reactor plant safety or personnel safety.

1. Security Unauthorized entry attempts into the PROTECTED AREA, bomb threats, sabotage attempts, and actual security compromises threatening loss of physical control of the plant.

2. Seismic Event Natural events such as earthquakes have potential to cause plant structure or equipment damage of sufficient magnitude to threaten personnel or plant safety.

3. Natural or Technological Hazard Other natural and non-naturally occurring events that can cause damage to plant facilities include tornados, FLOODING, hazardous material releases and events restricting site access warranting classification.

4. Fire FIRES can pose significant hazards to personnel and reactor safety. Appropriate for classification are FIRES within the plant PROTECTED AREA or which may affect operability of equipment needed for safe shutdown.

5. Hazardous Gas Toxic, corrosive, asphyxiant or flammable gas leaks can affect normal plant operations or preclude access to plant areas required to safely shutdown the plant.

6. Control Room Evacuation Events that are indicative of loss of Control Room habitability. If the Control Room must be evacuated, additional support for monitoring and controlling plant functions is necessary through the emergency response facilities.

7. Emergency Director Judgment The EALs defined in other categories specify the predetermined symptoms or events that are indicative of emergency or potential emergency conditions and thus warrant classification.

While these EALs have been developed to address the full spectrum of possible emergency conditions which may warrant classification and subsequent implementation of the Emergency Plan, a provision for classification of emergencies based on operator/management experience and judgment is still necessary. The EALs of this category provide the Emergency Director the latitude to classify emergency conditions consistent with the established classification criteria based upon Emergency Director judgment.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 162 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards Subcategory: 1 - Security Initiating Condition: Confirmed SECURITY CONDITION or threat EAL:

HU1.1 Unusual Event A SECURITY CONDITION that does not involve a HOSTILE ACTION as reported by ANO Security Shift Supervision OR Notification of a credible security threat directed at the site OR A validated notification from the NRC providing information of an aircraft threat Mode Applicability:

All Definition(s):

HOSTAGE - A person(s) held as leverage against the station to ensure that demands will be met by the station.

HOSTILE ACTION - An act toward ANO or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate 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 ANO. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the SECURITY OWNER CONTROLLED AREA).

PROJECTILE - An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.

PROTECTED AREA - An area clearly demarcated by a fence or building wall with an entrance portal that is regulated by Security Personnel to control access.

SAFETY SYSTEM - A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related (as defined in 10 CFR 50.2).

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 163 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

SECURITY CONDITION - Any security event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A security condition does not involve a HOSTILE ACTION.

SECURITY OWNER CONTROLLED AREA - The SOCA is the area demarcated as a Vehicle Barrier System (VBS) consisting of passive elements including a series of large concrete blocks on the inside of a delay fence with early warning capabilities. The SOCA is the area between the SOCA Fence and the PROTECTED AREA Boundary.

Basis:

This IC addresses events that pose a threat to plant personnel or SAFETY SYSTEM equipment, and thus represent a potential degradation in the level of plant safety. Security events which do not meet one of these EALs are adequately addressed by the requirements of 10 CFR 73.71 or 10 CFR 50.72. Security events assessed as HOSTILE ACTIONS are classifiable under ICs HA1 and HS1.

Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event. Classification of these events will initiate appropriate threat-related notifications to plant personnel and Offsite Response Organizations.

Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].

The first threshold references the Security Shift Supervision because these are the individuals trained to confirm that a security event is occurring or has occurred. Training on security event confirmation and classification is controlled due to the nature of Safeguards and 10 CFR 2.39 information.

The second threshold addresses the receipt of a credible security threat. The credibility of the threat is assessed in accordance with OP-1203.048 Security Event .

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 164 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases The third threshold addresses the threat from the impact of an aircraft on the plant. The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft. The status and size of the plane may also be provided by NORAD through the NRC.

Validation of the threat is performed in accordance with 11-S-82-1 Security Contingency Events (ref. 2).

Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information. This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location. Security-sensitive information should be contained in non-public documents such as the Security Plan for ANO (ref. 1).

Escalation of the emergency classification level would be via IC HA1.

Reference(s):

1. ANO Security Plan

2. OP-1203.048 Security Event

3. NEI 99-01 HU1

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 165 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards Subcategory: 1 - Security Initiating Condition: HOSTILE ACTION within the SECURITY OWNER CONTROLLED AREA or airborne attack threat within 30 minutes EAL:

HA1.1 Alert A HOSTILE ACTION is occurring or has occurred within the SECURITY OWNER CONTROLLED AREA as reported by ANO Security Shift Supervision OR A validated notification from NRC of an aircraft attack threat within 30 min. of the site Mode Applicability:

All Definition(s):

HOSTAGE - A person(s) held as leverage against the station to ensure that demands will be met by the station.

HOSTILE ACTION - An act toward ANO or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate 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 ANO. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the SECURITY OWNER CONTROLLED AREA).

HOSTILE FORCE - 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.

PROJECTILE - An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.

PROTECTED AREA - An area clearly demarcated by a fence or building wall with an entrance portal that is regulated by Security Personnel to control access.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 166 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases SECURITY OWNER CONTROLLED AREA - The SOCA is the area demarcated as a Vehicle Barrier System (VBS) consisting of passive elements including a series of large concrete blocks on the inside of a delay fence with early warning capabilities. The SOCA is the area between the SOCA Fence and the PROTECTED AREA Boundary.

Basis:

This IC addresses the occurrence of a HOSTILE ACTION within the SECURITY OWNER CONTROLLED AREA or notification of an aircraft attack threat. This event will require rapid response and assistance due to the possibility of the attack progressing to the PROTECTED AREA, or the need to prepare the plant and staff for a potential aircraft impact.

Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event.

Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].

As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering). The Alert declaration will also heighten the awareness of Offsite Response Organizations (OROs), allowing them to be better prepared should it be necessary to consider further actions.

This EAL does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc.

Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR 73.71 or 10 CFR 50.72.

The first threshold is applicable for any HOSTILE ACTION occurring, or that has occurred, in the SECURITY OWNER CONTROLLED AREA.

The second threshold addresses the threat from the impact of an aircraft on the plant, and the anticipated arrival time is within 30 minutes. The intent of this EAL is to ensure that threat-related notifications are made in a timely manner so that plant personnel and OROs are in a heightened state of readiness. This EAL is met when the threat-related information has been validated in accordance with OP-1203.048 Security Event (ref. 2).

The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft. The status and size of the plane may be provided by NORAD through the NRC.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 167 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases In some cases, it may not be readily apparent if an aircraft impact within the SECURITY OWNER CONTROLLED AREA was intentional (i.e., a HOSTILE ACTION). It is expected, although not certain, that notification by an appropriate Federal agency to the site would clarify this point. In this case, the appropriate federal agency is intended to be NORAD, FBI, FAA or NRC. The emergency declaration, including one based on other ICs/EALs, should not be unduly delayed while awaiting notification by a Federal agency.

Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information. This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location. Security-sensitive information should be contained in non-public documents such as the Security Plan for ANO (ref. 1).

Escalation of the emergency classification level would be via IC HS1.

Reference(s):

1. ANO Security Plan

2. OP-1203.048 Security Event

3. NEI 99-01 HA1

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 168 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards Subcategory: 1 - Security Initiating Condition: HOSTILE ACTION within the PROTECTED AREA EAL:

HS1.1 Site Area Emergency A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA as reported by ANO Security Shift Supervision Mode Applicability:

All Definition(s):

HOSTAGE - A person(s) held as leverage against the station to ensure that demands will be met by the station.

HOSTILE ACTION - An act toward ANO or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate 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 ANO. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the SECURITY OWNER CONTROLLED AREA).

HOSTILE FORCE - 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.

PROJECTILE - An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.

PROTECTED AREA - An area clearly demarcated by a fence or building wall with an entrance portal that is regulated by Security Personnel to control access.

SECURITY OWNER CONTROLLED AREA - The SOCA is the area demarcated as a Vehicle Barrier System (VBS) consisting of passive elements including a series of large concrete blocks on the inside of a delay fence with early warning capabilities. The SOCA is the area between the SOCA Fence and the PROTECTED AREA Boundary.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 169 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Basis:

This IC addresses the occurrence of a HOSTILE ACTION within the PROTECTED AREA. This event will require rapid response and assistance due to the possibility for damage to plant equipment.

Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event (ref. 1, 2).

Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].

As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering). The Site Area Emergency declaration will mobilize Offsite Response Organization (ORO) resources and have them available to develop and implement public protective actions in the unlikely event that the attack is successful in impairing multiple safety functions.

This EAL does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc.

Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR 73.71 or 10 CFR 50.72.

Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information. This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location. Security-sensitive information should be contained in non-public documents such as the Security Plan for ANO (ref. 1).

Reference(s):

1. ANO Security Plan

2. OP-1203.048 Security Event

3. NEI 99-01 HS1

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 170 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 2 - Seismic Event Initiating Condition: Seismic event greater than OBE levels EAL:

HU2.1 Unusual Event Seismic event > OBE as indicated by annunciation of the 0.10 g acceleration alarm Mode Applicability:

All Definition(s):

None Basis:

This IC addresses a seismic event that results in accelerations at the plant site greater than those specified for an Operating Basis Earthquake (OBE). An earthquake greater than an OBE but less than a Design Basis Earthquake (DBE) should have no significant impact on safety-related systems, structures and components; however, some time may be required for the plant staff to ascertain the actual post-event condition of the plant (e.g., performs walk-downs and post-event inspections). Given the time necessary to perform walk-downs and inspections, and fully understand any impacts, this event represents a potential degradation of the level of safety of the plant.

Event verification with external sources should not be necessary during or following an OBE.

Earthquakes of this magnitude should be readily felt by on-site personnel and recognized as a seismic event (e.g., lateral accelerations in excess of 0.1g). The Shift Manager or Emergency Director may seek external verification if deemed appropriate (e.g., a call to the USGS, check internet news sources, etc.); however, the verification action must not preclude a timely emergency declaration.

Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via IC CA6 or SA9.

Two strong motion triaxial accelerometers, ACS-8001 and ACS-8003, located at the base slab provide alarms to the Unit 1 control room via the seismic network control center, C529-NCC.

One alarm from C529-NCC is triggered when a setpoint of 0.01g has been exceeded. This alarm indicates that an earthquake has occurred and the seismic monitoring system is recording seismic data. Another alarm from C529-NCC is triggered when the pre-determined value of 0.1g, indicating the OBE has been exceeded (ref. 2, 3).

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 171 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases To avoid inappropriate emergency classification resulting from spurious actuation of the seismic instrumentation or felt motion not attributable to seismic activity, an offsite agency (USGS, National Earthquake Information Center (NEIC)) can confirm that an earthquake has occurred in the area of the plant. Such confirmation should not, however, preclude a timely emergency declaration based on receipt of the OBE alarm. If requested, provide the analyst with the following ANO coordinates: 35º 18' 36" north latitude, 93º 13' 53" west longitude (ref. 4).

Alternatively, near real-time seismic activity can be accessed via the NEIC website:

Reference(s):

1. 1SAR 2.2.1 Location

2. 1SAR 2.7.2 Site Seismic Evaluation

3. 1SAR 2.7.6 Time-History Accelerograph

4. OP-1203.025 Natural Emergencies

5. OP-2203.008 Natural Emergencies

6. NEI 99-01 HU2

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 172 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 3 - Natural or Technological Hazard Initiating Condition: Hazardous event EAL:

HU3.1 Unusual Event A tornado strike within the PROTECTED AREA Mode Applicability:

All Definition(s):

PROTECTED AREA - An area clearly demarcated by a fence or building wall with an entrance portal that is regulated by Security Personnel to control access.

Basis:

This IC addresses hazardous events that are considered to represent a potential degradation of the level of safety of the plant.

This EAL addresses a tornado striking (touching down) within the PROTECTED AREA.

Escalation of the emergency classification level would be based on ICs in Recognition Categories A, F, S or C.

If damage is confirmed visually or by other in-plant indications, the event may be escalated to an Alert under EAL CA6.1 or SA9.1.

A tornado striking (touching down) within the PROTECTED AREA warrants declaration of an Unusual Event regardless of the measured wind speed at the meteorological tower. A tornado is defined as a violently rotating column of air in contact with the ground and extending from the base of a thunderstorm.

Reference(s):

1. OP-1203.025 Natural Emergencies

2. OP-2203.008 Natural Emergencies

3. NEI 99-01 HU3

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 173 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 3 - Natural or Technological Hazard Initiating Condition: Hazardous event EAL:

HU3.2 Unusual Event Internal room or area FLOODING of a magnitude sufficient to require manual or automatic electrical isolation of a SAFETY SYSTEM component required by Technical Specifications for the current operating mode Mode Applicability:

All Definition(s):

FLOODING - A condition where water is entering a room or area faster than installed equipment is capable of removal, resulting in a rise of water level within the room or area.

SAFETY SYSTEM - A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related (as defined in 10 CFR 50.2).

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Basis:

This IC addresses hazardous events that are considered to represent a potential degradation of the level of safety of the plant.

This EAL addresses FLOODING of a building room or area that results in operators isolating power to a SAFETY SYSTEM component due to water level or other wetting concerns.

Classification is also required if the water level or related wetting causes an automatic isolation of a SAFETY SYSTEM component from its power source (e.g., a breaker or relay trip). To warrant classification, operability of the affected component must be required by Technical Specifications for the current operating mode.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 174 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Escalation of the emergency classification level would be based on ICs in Recognition Categories A, F, S or C.

Refer to EAL CA6.1 or SA9.1 for internal FLOODING affecting more than one SAFETY SYSTEM train.

Reference(s):

1. OP-1203.025 Natural Emergencies

2. OP-2203.008 Natural Emergencies

3. NEI 99-01 HU3

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 175 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 3 - Natural or Technological Hazard Initiating Condition: Hazardous event EAL:

HU3.3 Unusual Event Movement of personnel within the PROTECTED AREA is IMPEDED due to an event external to the PROTECTED AREA involving hazardous materials (e.g., an offsite chemical spill or toxic gas release)

Mode Applicability:

All Definition(s):

IMPEDE(D) - Personnel access to a room or area is hindered to an extent that extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).

PROTECTED AREA - An area clearly demarcated by a fence or building wall with an entrance portal that is regulated by Security Personnel to control access.

Basis:

This IC addresses hazardous events that are considered to represent a potential degradation of the level of safety of the plant.

This EAL addresses a hazardous materials event originating at a location outside the PROTECTED AREA and of sufficient magnitude to IMPEDE the movement of personnel within the PROTECTED AREA.

Escalation of the emergency classification level would be based on ICs in Recognition Categories A, F, S or C.

Reference(s):

1. NEI 99-01 HU3

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 176 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 3 - Natural or Technological Hazard Initiating Condition: Hazardous event EAL:

HU3.4 Unusual Event A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles (Note 7)

Note 7: This EAL does not apply to routine traffic impediments such as fog, snow, ice, or vehicle breakdowns or accidents.

Mode Applicability:

All Definition(s):

FLOODING - A condition where water is entering a room or area faster than installed equipment is capable of removal, resulting in a rise of water level within the room or area.

Basis:

This IC addresses hazardous events that are considered to represent a potential degradation of the level of safety of the plant.

This EAL addresses a hazardous event that causes an on-site impediment to vehicle movement and significant enough to prohibit the plant staff from accessing the site using personal vehicles.

Examples of such an event include site FLOODING caused by a hurricane, heavy rains, up-river water releases, dam failure, etc., or an on-site train derailment blocking the access road.

This EAL is not intended to apply to routine impediments such as fog, snow, ice, or vehicle breakdowns or accidents, but rather to more significant conditions such as the Hurricane Andrew strike on Turkey Point in 1992, the FLOODING around the Cooper Station during the Midwest floods of 1993, or the FLOODING around Ft. Calhoun Station in 2011.

Escalation of the emergency classification level would be based on ICs in Recognition Categories A, F, S or C.

Reference(s):

1. NEI 99-01 HU3

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 177 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 4 - Fire Initiating Condition: FIRE potentially degrading the level of safety of the plant EAL:

HU4.1 Unusual Event A FIRE is not extinguished within 15 min. of any of the following FIRE detection indications (Note 1):

Report from the field (i.e., visual observation)

Receipt of multiple (more than 1) fire alarms or indications (Note 13)

Field verification of a single fire alarm AND The FIRE is located within any Table 1[2]H-1 area Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Note 13 Bullet 2 of this EAL (multiple fire alarm indications) is not applicable for LOCAs or MSL breaks in containment.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 178 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Table 1H-1 Unit 1 Fire Areas Reactor Building All elevations Auxiliary Building All elevations including: Penthouse/MSIV Room Exceptions:

Boric Acid Mix Tank Room (Chem Add Area), 404 (157-B), EDG Exhaust Fan area on 386 (1-E and 2-E)

Turbine Building All elevations on the west side of Turbine Building and including: Pipechase under ICW Coolers, CRD Pump Pit/T-28 Room/Area under ICW Pumps 372 Elevation from non-vital switchgear area to Auxiliary Building wall at DR 56 Outside Areas Manholes adjacent to Startup #2 XFMR (MH-03/MH-04)

Manholes adjacent to Intake Structure (MH-05/MH-06)

Intake Structure (354 and 366)

Diesel Fuel Vault Diesel Fuel Vault Pump Manholes (MH-09 and MH-10)

Table 2H-1 Unit 2 Fire Areas Reactor Building All elevations Auxiliary Building All elevations including: MG Set Room, UNEPR, LNEPR, 2B-53 Room Auxiliary Building Extension MSIV Room Turbine Building All elevations on the west side of Turbine Building and 372 Elevation from non-vital switchgear area to Auxiliary Building wall at DR 340 Outside Areas Intake Structure (354 and 366)

Concrete Manhole East, NE of intake (2MH-01)

Concrete Manhole East of Turbine Building next to train bay (2MH-03)

Diesel Fuel Vault Diesel Fuel Vault Pump Manholes (MH-09 and MH-10)

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 179 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Mode Applicability:

All Definition(s):

FIRE - Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute fires. Observation of flame is preferred but is not required if large quantities of smoke and heat are observed.

VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

Basis:

This IC addresses the magnitude and extent of FIRES that may be indicative of a potential degradation of the level of safety of the plant.

The intent of the 15-minute duration is to size the FIRE and to discriminate against small FIRES that are readily extinguished (e.g., smoldering waste paper basket). In addition to alarms, other indications of a FIRE could be a drop in fire main pressure, automatic activation of a suppression system, etc.

Upon receipt, operators will take prompt actions to confirm the validity of an initial fire alarm, indication, or report. For EAL assessment purposes, the emergency declaration clock starts at the time that the initial alarm, indication, or report was received, and not the time that a subsequent verification action was performed. Similarly, the fire duration clock also starts at the time of receipt of the initial alarm, indication or report.

Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via EAL CA6.1 or SA9.1.

The 15 minute requirement begins with a credible notification that a FIRE is occurring, or receipt of multiple VALID fire detection system alarms or field validation of a single fire alarm. The alarm is to be validated using available Control Room indications or alarms to prove that it is not spurious, or by reports from the field.

Table 1[2]H-1 Fire Areas are those areas that contain equipment necessary for safe operation and shutdown of the plant (ref. 1, 2).

Reference(s):

1. OP-1203.049 Fires in Areas Affecting Safe Shutdown

2. OP- 2203.049 Fires in Areas Affecting Safe Shutdown

3. NEI 99-01 HU4

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 180 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 4 - Fire Initiating Condition: FIRE potentially degrading the level of safety of the plant EAL:

HU4.2 Unusual Event Receipt of a single fire alarm (i.e., no other indications of a FIRE) (Note 14)

AND The fire alarm is indicating a FIRE within any Table 1[2]H-1 area AND The existence of a FIRE is not verified (i.e., proved or disproved) within 30 min. of alarm receipt (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Note 14: During Modes 1 and 2, HU4.2 is not applicable to a single fire alarm in the Reactor Building.

Table 1H-1 Unit 1 Fire Areas Reactor Building All elevations Auxiliary Building All elevations including: Penthouse/MSIV Room Exceptions:

Boric Acid Mix Tank Room (Chem Add Area), 404 (157-B), EDG Exhaust Fan area on 386 (1-E and 2-E)

Turbine Building All elevations on the west side of Turbine Building and including: Pipechase under ICW Coolers, CRD Pump Pit/T-28 Room/Area under ICW Pumps 372 Elevation from non-vital switchgear area to Auxiliary Building wall at DR 56 Outside Areas Manholes adjacent to Startup #2 XFMR (MH-03/MH-04)

Manholes adjacent to Intake Structure (MH-05/MH-06)

Intake Structure (354 and 366)

Diesel Fuel Vault Diesel Fuel Vault Pump Manholes (MH-09 and MH-10)

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 181 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Table 2H-1 Unit 2 Fire Areas Reactor Building All elevations Auxiliary Building All elevations including: MG Set Room, UNEPR, LNEPR, 2B-53 Room Auxiliary Building Extension MSIV Room Turbine Building All elevations on the west side of Turbine Building and 372 Elevation from non-vital switchgear area to Auxiliary Building wall at DR 340 Outside Areas Intake Structure (354 and 366)

Concrete Manhole East, NE of intake (2MH-01)

Concrete Manhole East of Turbine Building next to train bay (2MH-03)

Diesel Fuel Vault Diesel Fuel Vault Pump Manholes (MH-09 and MH-10)

Mode Applicability:

All Definition(s):

FIRE - Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute fires. Observation of flame is preferred but is not required if large quantities of smoke and heat are observed.

VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

Basis:

This IC addresses the magnitude and extent of FIRES that may be indicative of a potential degradation of the level of safety of the plant.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 182 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases This EAL addresses receipt of a single fire alarm, and the existence of a FIRE is not verified (i.e., proved or disproved) within 30-minutes of the alarm. Upon receipt, operators will take prompt actions to confirm the validity of a single fire alarm. For EAL assessment purposes, the 30-minute clock starts at the time that the initial alarm was received, and not the time that a subsequent verification action was performed.

A single fire alarm, absent other indication(s) of a FIRE, may be indicative of equipment failure or a spurious activation, and not an actual FIRE. For this reason, additional time is allowed to verify the validity of the alarm. The 30-minute period is a reasonable amount of time to determine if an actual FIRE exists; however, after that time, and absent information to the contrary, it is assumed that an actual FIRE is in progress.

This EAL is not applicable for the Reactor Building in Modes 1 and 2. The Reactor Building air flow design and Technical Specification requirements for operation of Reactor Building Fan Coolers are such that multiple smoke detectors would be expected to alarm for a fire in the Reactor Building. A fire in the Reactor Building in these modes would therefore be classified under EAL HU4.1.

If an actual FIRE is verified by a report from the field, then HU4.1 is immediately applicable, and the emergency must be declared if the FIRE is not extinguished within 15-minutes of the report.

If the alarm is verified to be due to an equipment failure or a spurious activation, and this verification occurs within 30-minutes of the receipt of the alarm, then this EAL is not applicable and no emergency declaration is warranted.

Basis-Related Fire Protection Requirements Criterion 3 of 10 CFR 50, Appendix A, states, in part:

Structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions.

In this respect, noncombustible and heat resistant materials are used wherever practical throughout the unit, particularly in locations such as the containment and Control Room. Fire detection and fighting systems of appropriate capacity and capability are provided and designed to minimize the adverse effects of fires on SSCs important to safety. Firefighting systems are designed to assure that the rupture or inadvertent operation of a fire system does not significantly impair the safety capability of these structures, systems, and components.

In addition, the use of 1-hour fire barriers for the enclosure of cable and equipment and associated non-safety circuits of one redundant train is employed. As used in HU4.2, the 30-minutes to verify a single alarm is well within this worst-case 1-hour time period.

Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via EAL CA6.1 or SA9.1.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 183 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases The 30-minute requirement begins upon receipt of a single VALID fire detection system alarm.

The alarm is to be validated using available Control Room indications or alarms to prove that it is not spurious, or by reports from the field. Actual field reports must be made within the 30-minute time limit or a classification must be made. If a fire is verified to be occurring by field report, classification shall be made based on EAL HU4.1, with the 15-minute requirement beginning with the verification of the fire by field report.

Table 1[2]H-1 Fire Areas are those areas that contain equipment necessary for safe operation and shutdown of the plant (ref. 1, 2).

Reference(s):

1. OP-1203.049 Fires in Areas Affecting Safe Shutdown

2. OP- 2203.049 Fires in Areas Affecting Safe Shutdown

3. NEI 99-01 HU4

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 184 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 4 - Fire Initiating Condition: FIRE potentially degrading the level of safety of the plant EAL:

HU4.3 Unusual Event A FIRE within the PROTECTED AREA not extinguished within 60 min. of the initial report, alarm or indication (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Mode Applicability:

All Definition(s):

FIRE - Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute fires. Observation of flame is preferred but is not required if large quantities of smoke and heat are observed.

PROTECTED AREA - An area clearly demarcated by a fence or building wall with an entrance portal that is regulated by Security Personnel to control access.

Basis:

This IC addresses the magnitude and extent of FIRES that may be indicative of a potential degradation of the level of safety of the plant.

In addition to a FIRE addressed by EAL HU4.1 or HU4.2, a FIRE within the plant PROTECTED AREA not extinguished within 60-minutes may also potentially degrade the level of plant safety.

Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via EAL CA6.1 or SA8.1.

Reference(s):

1. NEI 99-01 HU4

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 185 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 4 - Fire Initiating Condition: FIRE potentially degrading the level of safety of the plant EAL:

HU4.4 Unusual Event A FIRE within the PROTECTED AREA that requires firefighting support by an offsite fire response agency to extinguish Mode Applicability:

All Definition(s):

FIRE - Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute fires. Observation of flame is preferred but is not required if large quantities of smoke and heat are observed.

PROTECTED AREA - An area clearly demarcated by a fence or building wall with an entrance portal that is regulated by Security Personnel to control access.

Basis:

This IC addresses the magnitude and extent of FIRES that may be indicative of a potential degradation of the level of safety of the plant.

If a FIRE within the plant PROTECTED AREA is of sufficient size to require a response by an offsite firefighting agency (e.g., a local town Fire Department), then the level of plant safety is potentially degraded. The dispatch of an offsite firefighting agency to the site requires an emergency declaration only if it is needed to actively support firefighting efforts because the fire is beyond the capability of the Fire Brigade to extinguish. Declaration is not necessary if the agency resources are placed on stand-by, or supporting post-extinguishment recovery or investigation actions.

Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via EAL CA6.1 or SA9.1.

Reference(s):

1. NEI 99-01 HU4

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 186 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 5 - Hazardous Gas Initiating Condition: Gaseous release IMPEDING access to equipment necessary for normal plant operations, cooldown or shutdown EAL:

HA5.1 Alert Release of a toxic, corrosive, asphyxiant or flammable gas into any Table 1[2]H-2 room or area AND Entry into the room or area is prohibited or IMPEDED (Note 5)

Note 5: If the equipment in the listed room or area was already inoperable or out-of-service before the event occurred, then no emergency classification is warranted.

Table 1H-2 Unit 1 Safe Operation & Shutdown Rooms/Areas Room/Area Mode A-4 Switchgear Room 3, 4 Upper North Electrical Penetration Room 3, 4 Lower South Electrical Equipment Room 3, 4 Table 2H-2 Unit 2 Safe Operation & Shutdown Rooms/Areas Room/Area Mode Aux Building 317 Emergency Core Cooling Rooms 3, 4 Aux Building 317 Tendon Gallery Access 3, 4 Aux Building 335 Charging Pumps / MCC 2B-52 3, 4 Aux Building 354 MCC 2B-62 Area 3, 4 Emergency Diesel Generator Corridor 3, 4 Lower South Piping Penetration Room 3, 4 Aux Building 386 Containment Hatch 3, 4

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 187 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Mode Applicability:

3 - Hot Standby, 4 - Hot Shutdown Definition(s):

IMPEDE(D) - Personnel access to a room or area is hindered to an extent that extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).

Basis:

This IC addresses an event involving a release of a hazardous gas that precludes or IMPEDES access to equipment necessary to maintain normal plant operation, or required for a normal plant cooldown and shutdown. This condition represents an actual or potential substantial degradation of the level of safety of the plant.

An Alert declaration is warranted if entry into the affected room/area is, or may be, procedurally required during the plant operating mode in effect at the time of the gaseous release. The emergency classification is not contingent upon whether entry is actually necessary at the time of the release.

Evaluation of the IC and EAL do not require atmospheric sampling; it only requires the Emergency Directors judgment that the gas concentration in the affected room/area is sufficient to preclude or significantly IMPEDE procedurally required access. This judgment may be based on a variety of factors including an existing job hazard analysis, report of ill effects on personnel, advice from a subject matter expert or operating experience with the same or similar hazards.

Access should be considered as IMPEDED if extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).

An emergency declaration is not warranted if any of the following conditions apply:

The plant is in an operating mode different than the mode specified for the affected room/area (i.e., entry is not required during the operating mode in effect at the time of the gaseous release). For example, the plant is in Mode 1 when the gaseous release occurs, and the procedures used for normal operation, cooldown and shutdown do not require entry into the affected room until Mode 4.

The gas release is a planned activity that includes compensatory measures which address the temporary inaccessibility of a room or area (e.g., fire suppression system testing).

The access control measures are of a conservative or precautionary nature, and would not actually prevent or IMPEDE a required action.

If the equipment in the listed room or area was already inoperable, or out-of-service, before the event occurred, then no emergency should be declared since the event will

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 188 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases have no adverse impact beyond that already allowed by Technical Specifications at the time of the event.

An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerous levels.

Most commonly, asphyxiants work by merely displacing air in an enclosed environment. This reduces the concentration of oxygen below the normal level of around 19%, which can lead to breathing difficulties, unconsciousness or even death.

This EAL does not apply to firefighting activities that generate smoke and that automatically or manually activate a fire suppression system in an area.

The list of plant rooms or areas with entry-related mode applicability identified specify those rooms or areas that contain equipment which require a manual/local action as specified in operating procedures used for normal plant operation, cooldown and shutdown. Rooms or areas in which actions of a contingent or emergency nature would be performed (e.g., an action to address an off-normal or emergency condition such as emergency repairs, corrective measures or emergency operations) are not included. In addition, the list specifies the plant mode(s) during which entry would be required for each room or area (ref. 1).

Escalation of the emergency classification level would be via Recognition Category A, C or F ICs.

EAL HA5.1 mode applicability has been limited to the mode limitations of Table 1[2]H-2 (Modes 3 and 4 only).

Reference(s):

1. Attachment 2 Safe Operation & Shutdown Areas Tables 1[2]A-3 & 1[2]H-2 Bases

2. NEI 99-01 HA5

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 189 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 6 - Control Room Evacuation Initiating Condition: Control Room evacuation resulting in transfer of plant control to alternate locations EAL:

HA6.1 Alert An event has resulted in plant control being transferred from the Control Room to alternate locations Mode Applicability:

All Definition(s):

None Basis:

This IC addresses an evacuation of the Control Room that results in transfer of plant control to alternate locations outside the Control Room. The loss of the ability to control the plant from the Control Room is considered to be a potential substantial degradation in the level of plant safety.

Following a Control Room evacuation, control of the plant will be transferred to alternate shutdown locations. The necessity to control a plant shutdown from outside the Control Room, in addition to responding to the event that required the evacuation of the Control Room, will present challenges to plant operators and other on-shift personnel. Activation of the ERO and emergency response facilities will assist in responding to these challenges.

Transfer of plant control begins when the last licensed operator leaves the Control Room.

Escalation of the emergency classification level would be via IC HS6.

Reference(s):

1. OP-1203.002 Alternate Shutdown

2. OP-2203.014 Alternate Shutdown

3. NEI 99-01 HA6

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 190 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 6 - Control Room Evacuation Initiating Condition: Inability to control a key safety function from outside the Control Room EAL:

HS6.1 Site Area Emergency An event has resulted in plant control being transferred from the Control Room to alternate locations AND Control of any of the following key safety functions is not re-established within 15 min. (Note 1):

Reactivity (Modes 1, 2 and 3 only)

Core cooling RCS heat removal Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown, 5 - Cold Shutdown, 6 - Refueling Definition(s):

None Basis:

This IC addresses an evacuation of the Control Room that results in transfer of plant control to alternate locations, and the control of a key safety function cannot be reestablished in a timely manner. The failure to gain control of a key safety function following a transfer of plant control to alternate locations is a precursor to a challenge to one or more fission product barriers within a relatively short period of time.

The determination of whether or not control is established at the remote safe shutdown location(s) is based on Emergency Director judgment. The Emergency Director is expected to make a reasonable, informed judgment within 15 minutes whether or not the operating staff has control of key safety functions from the remote safe shutdown location(s).

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 191 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Transfer of plant control and the time period to establish control begins when the last licensed operator leaves the Control Room.

Escalation of the emergency classification level would be via IC FG1 or CG1 Reference(s):

1. OP-1203.002 Alternate Shutdown

2. OP-2203.014 Alternate Shutdown

3. NEI 99-01 HS6

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 192 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 7 - Emergency Director Judgment Initiating Condition: Other conditions exist that in the judgment of the Emergency Director warrant declaration of a UE EAL:

HU7.1 Unusual Event Other conditions exist which, in the judgment of the Emergency Director, indicate that events are in progress 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 offsite response or monitoring are expected unless further degradation of SAFETY SYSTEMS occurs.

Mode Applicability:

All Definition(s):

SAFETY SYSTEM - A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related (as defined in 10 CFR 50.2).

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Basis:

This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for an UNUSUAL EVENT.

Reference(s):

1. NEI 99-01 HU7

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 193 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 7 - Emergency Director Judgment Initiating Condition: Other conditions exist that in the judgment of the Emergency Director warrant declaration of an ALERT EAL:

HA7.1 Alert Other conditions exist which, in the judgment of the Emergency Director, indicate that 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 EPA Protective Action Guideline exposure levels.

Mode Applicability:

All Definition(s):

HOSTAGE - A person(s) held as leverage against the station to ensure that demands will be met by the station.

HOSTILE ACTION - An act toward ANO or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate 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 ANO. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the SECURITY OWNER CONTROLLED AREA).

PROJECTILE - An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.

PROTECTED AREA - An area clearly demarcated by a fence or building wall with an entrance portal that is regulated by Security Personnel to control access.

SECURITY OWNER CONTROLLED AREA - The SOCA is the area demarcated as a Vehicle Barrier System (VBS) consisting of passive elements including a series of large concrete blocks on the inside of a delay fence with early warning capabilities. The SOCA is the area between the SOCA Fence and the PROTECTED AREA Boundary.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 194 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Basis:

This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for an ALERT.

Reference(s):

1. NEI 99-01 HA7

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 195 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 7 - Emergency Director Judgment Initiating Condition: Other conditions exist that in the judgment of the Emergency Director warrant declaration of a SITE AREA EMERGENCY EAL:

HS7.1 Site Area Emergency Other conditions exist which, in the judgment of the Emergency Director, indicate that events are in progress or have occurred which involve actual or likely major failures 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.

Mode Applicability:

All Definition(s):

HOSTAGE - A person(s) held as leverage against the station to ensure that demands will be met by the station.

HOSTILE ACTION - An act toward ANO or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate 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 ANO. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the SECURITY OWNER CONTROLLED AREA).

PROJECTILE - An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.

PROTECTED AREA - An area clearly demarcated by a fence or building wall with an entrance portal that is regulated by Security Personnel to control access.

SITE BOUNDARY - That boundary defined by a 1046 meter (0.65 mile) radius around the plant.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 196 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases SECURITY OWNER CONTROLLED AREA - The SOCA is the area demarcated as a Vehicle Barrier System (VBS) consisting of passive elements including a series of large concrete blocks on the inside of a delay fence with early warning capabilities. The SOCA is the area between the SOCA Fence and the PROTECTED AREA Boundary.

Basis:

This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for a SITE AREA EMERGENCY.

Reference(s):

1. NEI 99-01 HS7

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 197 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 7 - Emergency Director Judgment Initiating Condition: Other conditions exist that in the judgment of the Emergency Director warrant declaration of a GENERAL EMERGENCY EAL:

HG7.1 General Emergency Other conditions exist which, in the judgment of the Emergency Director, indicate that events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with 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 offsite for more than the immediate site area.

Mode Applicability:

All Definition(s):

HOSTAGE - A person(s) held as leverage against the station to ensure that demands will be met by the station.

HOSTILE ACTION - An act toward ANO or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate 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 ANO. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the SECURITY OWNER CONTROLLED AREA).

IMMINENT - The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.

PROJECTILE - An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.

PROTECTED AREA - An area clearly demarcated by a fence or building wall with an entrance portal that is regulated by Security Personnel to control access.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 198 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases SECURITY OWNER CONTROLLED AREA - The SOCA is the area demarcated as a Vehicle Barrier System (VBS) consisting of passive elements including a series of large concrete blocks on the inside of a delay fence with early warning capabilities. The SOCA is the area between the SOCA Fence and the PROTECTED AREA Boundary.

Basis:

This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for a GENERAL EMERGENCY.

Reference(s):

1. NEI 99-01 HG7

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 199 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category S - System Malfunction EAL Group: Hot Conditions (RCS temperature > 200°F); EALs in this category are applicable only in one or more hot operating modes.

Numerous system-related equipment failure events that warrant emergency classification have been identified in this category. They may pose actual or potential threats to plant safety.

The events of this category pertain to the following subcategories:

1. Loss of Vital AC Power Loss of vital electrical power can compromise plant SAFETY SYSTEM operability including decay heat removal and emergency core cooling systems which may be necessary to ensure fission product barrier integrity. This category includes loss of onsite and offsite sources for vital 4.16 KV buses.

2. Loss of Vital DC Power Loss of emergency electrical power can compromise plant SAFETY SYSTEM operability including decay heat removal and emergency core cooling systems which may be necessary to ensure fission product barrier integrity. This category includes loss of vital plant 125V DC power sources.

3. Loss of Control Room Indications Certain events that degrade plant operator ability to effectively assess plant conditions within the plant warrant emergency classification. Losses of indicators are in this subcategory.

4. RCS Activity During normal operation, reactor coolant fission product activity is very low. Small concentrations of fission products in the coolant are primarily from the fission of tramp uranium in the fuel clad or minor perforations in the clad itself. Any significant rise from these base-line levels (2% - 5% clad failures) is indicative of fuel failures and is covered under the Fission Product Barrier Degradation category. However, lesser amounts of clad damage may result in coolant activity exceeding Technical Specification limits. These fission products will be circulated with the reactor coolant and can be detected by coolant sampling.

5. RCS Leakage The reactor vessel provides a volume for the coolant that covers the reactor core. The reactor pressure vessel and associated pressure piping (reactor coolant system) together provide a barrier to limit the release of radioactive material should the reactor fuel clad integrity fail. Excessive RCS leakage greater than Technical Specification limits indicates potential pipe cracks that may propagate to an extent threatening fuel clad, RCS and containment integrity.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 200 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases

6. RPS Failure This subcategory includes events related to failure of the Reactor Protection System (RPS) to initiate and complete reactor trips. In the plant licensing basis, postulated failures of the RPS to complete a reactor trip comprise a specific set of analyzed events referred to as Anticipated Transient Without Scram (ATWS) events. For EAL classification, however, ATWS is intended to mean any trip failure event that does not achieve reactor shutdown. If RPS actuation fails to assure reactor shutdown, positive control of reactivity is at risk and could cause a threat to fuel clad, RCS and containment integrity.

7. Loss of Communications Certain events that degrade plant operator ability to effectively communicate with essential personnel within or external to the plant warrant emergency classification.

8. Containment Failure Failure of containment isolation capability (under conditions in which the containment is not currently challenged) warrants emergency classification. Failure of containment pressure control capability also warrants emergency classification.

9. Hazardous Event Affecting Safety Systems Various natural and technological events that result in degraded plant safety system performance or significant VISIBLE DAMAGE warrant emergency classification under this subcategory.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 201 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 1 - Loss of Vital AC Power Initiating Condition: Loss of all offsite AC power capability to vital buses for 15 minutes or longer EAL:

SU1.1 Unusual Event Loss of all offsite AC power capability, Table 1[2]S-1, to vital 4.16 KV buses A3[2A3] and A4[2A4] for 15 min. (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Table 1S-1 Unit 1 AC Power Sources Offsite Startup Transformer No. 1 Startup Transformer No. 2 Unit Auxiliary Transformer (from 22 KV switchyard)

Onsite Unit Auxiliary Transformer (main generator via main transformer)

DG1 DG2 AAC Gen

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 202 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Table 2S-1 Unit 2 AC Power Sources Offsite Startup Transformer No. 3 Startup Transformer No. 2 Unit Auxiliary Transformer (from 22 KV switchyard)

Onsite Unit Auxiliary Transformer (main generator via main transformer) 2DG1 2DG2 AAC Gen Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

None Basis:

This IC addresses a prolonged loss of offsite power. The loss of offsite power sources renders the plant more vulnerable to a complete loss of power to AC vital buses. This condition represents a potential reduction in the level of safety of the plant.

For emergency classification purposes, capability means that an offsite AC power source(s) is available to the vital buses, whether or not the buses are powered from it.

Fifteen minutes was selected as a threshold to exclude transient or momentary losses of offsite power.

Escalation of the emergency classification level would be via IC SA1.

Reference(s):

1. 1SAR Figure 8-1 Station Single Line Diagram

2. OP-1202.007 Degraded Power

3. OP-1202.008 Blackout

4. OP-2104.037 Alternate AC Diesel Generator Operations

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 203 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases

5. 2SAR Figure 8.3-1 Station Single Line Diagram

6. OP-2202.007 Loss of Off-Site Power

7. OP-2202.008 Station Blackout

8. OP-2107.006 Backfeed of Unit Auxiliary Transformer

9. NEI 99-01 SU1

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 204 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 1 - Loss of Vital AC Power Initiating Condition: Loss of all but one AC power source to vital buses for 15 minutes or longer EAL:

SA1.1 Alert AC power capability, Table 1[2]S-1, to vital 4.16 KV buses A3[2A3] and A4[2A4] reduced to a single power source for 15 min. (Note 1)

AND Any additional single power source failure will result in loss of all AC power to SAFETY SYSTEMS Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Table 1S-1 Unit 1 AC Power Sources Offsite Startup Transformer No. 1 Startup Transformer No. 2 Unit Auxiliary Transformer (from 22 KV switchyard)

Onsite Unit Auxiliary Transformer (main generator via main transformer)

DG1 DG2 AAC Gen

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 205 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Table 2S-1 Unit 2 AC Power Sources Offsite Startup Transformer No. 3 Startup Transformer No. 2 Unit Auxiliary Transformer (from 22 KV switchyard)

Onsite Unit Auxiliary Transformer (main generator via main transformer) 2DG1 2DG2 AAC Gen Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

SAFETY SYSTEM - A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related (as defined in 10 CFR 50.2).

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Basis:

This IC describes a significant degradation of offsite and onsite AC power sources such that any additional single failure would result in a loss of all AC power to SAFETY SYSTEMS. In this condition, the sole AC power source may be powering one, or more than one, train of safety-related equipment. This IC provides an escalation path from IC SU1.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 206 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases An AC power source is a source recognized in AOPs and EOPs, and capable of supplying required power to a vital bus. Some examples of this condition are presented below.

A loss of all offsite power with a concurrent failure of all but one emergency power source (e.g., an onsite diesel generator).

A loss of all offsite power and loss of all vital power sources (e.g., onsite diesel generators) with a single train of vital buses being back-fed from the unit main generator.

A loss of vital power sources (e.g., onsite diesel generators) with a single train of vital buses being back-fed from an offsite power source.

Fifteen minutes was selected as a threshold to exclude transient or momentary losses of power.

Escalation of the emergency classification level would be via IC SS1.

This EAL is the hot condition equivalent of the cold condition EAL CU2.1.

Reference(s):

1. 1SAR Figure 8-1 Station Single Line Diagram

2. OP-1202.007 Degraded Power

3. OP-1202.008 Blackout

4. OP-2104.037 Alternate AC Diesel Generator Operations

5. 2SAR Figure 8.3-1 Station Single Line Diagram

6. OP-2202.007 Loss of Off-Site Power

7. OP-2202.008 Station Blackout

8. OP-2107.006 Backfeed of Unit Auxiliary Transformer

9. NEI 99-01 SA1

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 207 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 1 - Loss of Vital AC Power Initiating Condition: Loss of all offsite power and all onsite AC power to vital buses for 15 minutes or longer EAL:

SS1.1 Site Area Emergency Loss of all offsite and all onsite AC power to vital 4.16 KV buses A3[2A3] and A4[2A4] for 15 min. (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

SAFETY SYSTEM - A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related (as defined in 10 CFR 50.2).

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Basis:

Although the AAC may be considered available, it will not prevent declaration of this EAL unless it is powering a vital bus within the 15 minute time period of the EAL.

This IC addresses a total loss of AC power that compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink.

Mitigative strategies using non-safety related power sources (FLEX generators, etc.) may be effective in supplying power to these buses. These power sources must be controlled in accordance with abnormal or emergency operating procedures, or beyond design basis

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 208 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases accident response guidelines (e.g., FLEX support guidelines) and must be capable (alone or in combination) of supplying power for long term decay heat removal systems. In addition, fission product barrier monitoring capabilities may be degraded under these conditions. This IC represents a condition that involves actual or likely major failures of plant functions needed for the protection of the public.

Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

Escalation of the emergency classification level would be via IC AG1, FG1 or SG1.

This EAL is the hot condition equivalent of the cold condition EAL CA2.1.

Reference(s):

1. 1SAR Figure 8-1 Station Single Line Diagram

2. OP-1202.007 Degraded Power

3. OP-1202.008 Blackout

4. OP-2104.037 Alternate AC Diesel Generator Operations

5. 2SAR Figure 8.3-1 Station Single Line Diagram

6. OP-2202.007 Loss of Off-Site Power

7. OP-2202.008 Station Blackout

8. OP-2107.006 Backfeed of Unit Auxiliary Transformer

9. NEI 99-01 SS1

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 209 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 1 - Loss of Vital AC Power Initiating Condition: Prolonged loss of all offsite and all onsite AC power to vital buses EAL:

SG1.1 General Emergency Loss of all offsite and all onsite AC power to vital 4.16 KV buses A3[2A3] and A4[2A4]

AND EITHER:

Restoration of at least one vital 4.16 KV bus in < 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is not likely (Note 1)

CETs > 1200°F Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

SAFETY SYSTEM - A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related (as defined in 10 CFR 50.2).

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Basis:

This IC addresses a prolonged loss of all power sources to AC vital buses. A loss of all AC power compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink. Mitigative strategies using non-safety related power sources (FLEX generators, etc.) may be effective in supplying power to these buses. These power sources must be controlled in accordance with abnormal or emergency operating procedures, or beyond design basis accident response guidelines (e.g.,

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 210 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases FLEX support guidelines) and must be capable (alone or in combination) of supplying power for long term decay heat removal systems. A prolonged loss of these buses will lead to a loss of one or more fission product barriers. In addition, fission product barrier monitoring capabilities may be degraded under these conditions.

The EAL should require declaration of a General Emergency prior to meeting the thresholds for IC FG1. This will allow additional time for implementation of offsite protective actions.

Escalation of the emergency classification from Site Area Emergency will occur if it is projected that power cannot be restored to at least one AC vital bus by the end of the analyzed station blackout coping period. Beyond this time, plant responses and event trajectory are subject to greater uncertainty, and there is a greater likelihood of challenges to multiple fission product barriers. 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is the site-specific SBO coping analysis time (ref. 4, 5).

The estimate for restoring at least one vital bus should be based on a realistic appraisal of the situation. Mitigation actions with a low probability of success should not be used as a basis for delaying a classification upgrade. The goal is to maximize the time available to prepare for, and implement, protective actions for the public.

The EAL will also require a General Emergency declaration if the loss of AC power results in parameters that indicate an inability to adequately remove decay heat from the core.

Reference(s):

1. OP-1202.005 Inadequate Core Cooling

2. OP-2202.009 Functional Recovery

3. OP-2202.011 Lower Mode Functional Recovery

4. Unit 1 Calculation 85-E-0072-02 Time from Loss of All AC Power to Loss of Subcooling

5. Unit 2 Calculation 85-E-0072-01 Time from Loss of All AC Power to Loss of Subcooling

6. 1SAR Figure 8-1 Station Single Line Diagram

7. OP-1202.007 Degraded Power

8. OP-1202.008 Blackout

9. OP-2104.037 Alternate AC Diesel Generator Operations

10. 2SAR Figure 8.3-1 Station Single Line Diagram

11. OP-2202.007 Loss of Off-Site Power

12. OP-2202.008 Station Blackout

13. OP-2107.006 Backfeed of Unit Auxiliary Transformer

14. NEI 99-01 SG1

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 211 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 1 - Loss of Vital AC Power Initiating Condition: Loss of all vital AC and vital DC power sources for 15 minutes or longer EAL:

SG1.2 General Emergency Loss of all offsite and all onsite AC power to vital 4.16 KV buses A3[2A3] and A4[2A4] for 15 min. (Note 1)

AND Indicated voltage is < 105 VDC on D01[2D01] and D02[2D02] vital 125 VDC buses for 15 min. (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

SAFETY SYSTEM - A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related (as defined in 10 CFR 50.2).

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Basis:

Unit 1 batteries D06 and D07 and Unit 2 batteries 2D11 and 2D12 contain 58 cells each with a minimum cell voltage of 1.81 V or 105 VDC (ref. 9, 10).

This IC addresses a concurrent and prolonged loss of both vital AC and Vital DC power. A loss of all vital AC power compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 212 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases removal/pressure control, spent fuel heat removal and the ultimate heat sink. Mitigative strategies using non-safety related power sources (FLEX generators, etc.) may be effective in supplying power to these buses. These power sources must be controlled in accordance with abnormal or emergency operating procedures, or beyond design basis accident response guidelines (e.g., FLEX support guidelines) and must be capable (alone or in combination) of supplying power for long term decay heat removal systems. A loss of vital DC power compromises the ability to monitor and control SAFETY SYSTEMS. A sustained loss of both vital AC and vital DC power will lead to multiple challenges to fission product barriers.

Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

The 15-minute emergency declaration clock begins at the point when both EAL thresholds are met.

Reference(s):

1. 1SAR Figure 8-1 Station Single Line Diagram

2. OP-1202.007 Degraded Power

3. OP-1202.008 Blackout

4. OP-2104.037 Alternate AC Diesel Generator Operations

5. 2SAR Figure 8.3-1 Station Single Line Diagram

6. OP-2202.007 Loss of Off-Site Power

7. OP-2202.008 Station Blackout

8. OP-2107.006 Backfeed of Unit Auxiliary Transformer

9. 1SAR 8.3.2.1.1 Batteries

10. 2SAR 8.3.2.1.1 Batteries

11. OP-1203.036 Loss of 125V DC

12. OP-2203.037 Loss of 125V DC

13. 2SAR Figure 8.3-6 Low Voltage Safety System Power Supplies

14. NEI 99-01 SG8

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 213 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 2 - Loss of Vital DC Power Initiating Condition: Loss of all vital DC power for 15 minutes or longer EAL:

SS2.1 Site Area Emergency Indicated voltage is < 105 VDC on D01[2D01] and D02[2D02] vital 125 VDC buses for 15 min. (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

SAFETY SYSTEM - A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related (as defined in 10 CFR 50.2).

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Basis:

Unit 1 batteries D06 and D07 and Unit 2 batteries 2D11 and 2D12 contain 58 cells each with a minimum cell voltage of 1.81 V or 105 VDC (ref. 2, 3).

This IC addresses a loss of vital DC power which compromises the ability to monitor and control SAFETY SYSTEMS. In modes above Cold Shutdown, this condition involves a major failure of plant functions needed for the protection of the public.

Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

Escalation of the emergency classification level would be via IC AG1, FG1 or SG1.

This EAL is the hot condition equivalent of the cold condition EAL CU4.1.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 214 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Reference(s):

1. 1SAR Figure 8-1 Station Single Line Diagram

2. 1SAR 8.3.2.1.1 Batteries

3. 2SAR 8.3.2.1.1 Batteries

4. OP-1203.036 Loss of 125V DC

5. OP-2203.037 Loss of 125V DC

6. 2SAR Figure 8.3-6 Low Voltage Safety System Power Supplies

7. NEI 99-01 SS8

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 215 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 3 - Loss of Control Room Indications Initiating Condition: UNPLANNED loss of Control Room indications for 15 minutes or longer EAL:

SU3.1 Unusual Event An UNPLANNED event results in the inability to monitor one or more Table 1[2]S-2 parameters from within the Control Room for 15 min. (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Table 1[2]S-2 Safety System Parameters Reactor power RCS level RCS pressure CET temperature Level in at least one S/G EFW flow to at least one S/G Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

SAFETY SYSTEM - A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related (as defined in 10 CFR 50.2).

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 216 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases UNPLANNED - A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

Basis:

This IC addresses the difficulty associated with monitoring normal plant conditions without the ability to obtain SAFETY SYSTEM parameters from within the Control Room. This condition is a precursor to a more significant event and represents a potential degradation in the level of safety of the plant.

As used in this EAL, an inability to monitor means that values for one or more of the listed parameters cannot be determined from within the Control Room. This situation would require a loss of all of the Control Room sources for the given parameter(s). For example, the reactor power level cannot be determined from any analog, digital and recorder source within the Control Room.

An event involving a loss of plant indications, annunciators and/or display systems is evaluated in accordance with 10 CFR 50.72 (and associated guidance in NUREG-1022) to determine if an NRC event report is required. The event would be reported if it significantly impaired the capability to perform emergency assessments. In particular, emergency assessments necessary to implement abnormal operating procedures, emergency operating procedures, and emergency plan implementing procedures addressing emergency classification, accident assessment, or protective action decision-making.

This EAL is focused on a selected subset of plant parameters associated with the key safety functions of reactivity control, core cooling and RCS heat removal. The loss of the ability to determine one or more of these parameters from within the Control Room is considered to be more significant than simply a reportable condition. In addition, if all indication sources for one or more of the listed parameters are lost, then the ability to determine the values of other SAFETY SYSTEM parameters may be impacted as well. For example, if the value for reactor vessel level cannot be determined from the indications and recorders on a main control board, the SPDS or the plant computer, the availability of other parameter values may be compromised as well.

Fifteen minutes was selected as a threshold to exclude transient or momentary losses of indication.

Escalation of the emergency classification level would be via EAL SA3.1.

Reference(s):

1. 1SAR 7.5 Safety-Related Display Instrumentation

2. 2SAR 7.5 Safety-Related Display Instrumentation

3. NEI 99-01 SU2

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 217 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 3 - Loss of Control Room Indications Initiating Condition: UNPLANNED loss of Control Room indications for 15 minutes or longer with a significant transient in progress EAL:

SA3.1 Alert An UNPLANNED event results in the inability to monitor one or more Table 1[2]S-2 parameters from within the Control Room for 15 min. (Note 1)

AND Any significant transient is in progress, Table 1[2]S-3 Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Table 1[2]S-2 Safety System Parameters Reactor power RCS level RCS pressure CET temperature Level in at least one S/G EFW flow to at least one S/G Table 1[2]S-3 Significant Transients Reactor trip Runback > 25% thermal power Electrical load rejection > 25% electrical load Safety injection actuation

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 218 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

SAFETY SYSTEM - A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related (as defined in 10 CFR 50.2):

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

UNPLANNED - A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

Basis:

This IC addresses the difficulty associated with monitoring rapidly changing plant conditions during a transient without the ability to obtain SAFETY SYSTEM parameters from within the Control Room. During this condition, the margin to a potential fission product barrier challenge is reduced. It thus represents a potential substantial degradation in the level of safety of the plant.

As used in this EAL, an inability to monitor means that values for one or more of the listed parameters cannot be determined from within the Control Room. This situation would require a loss of all of the Control Room sources for the given parameter(s). For example, the reactor power level cannot be determined from any analog, digital and recorder source within the Control Room.

An event involving a loss of plant indications, annunciators and/or display systems is evaluated in accordance with 10 CFR 50.72 (and associated guidance in NUREG-1022) to determine if an NRC event report is required. The event would be reported if it significantly impaired the capability to perform emergency assessments. In particular, emergency assessments necessary to implement abnormal operating procedures, emergency operating procedures, and emergency plan implementing procedures addressing emergency classification, accident assessment, or protective action decision-making.

This EAL is focused on a selected subset of plant parameters associated with the key safety functions of reactivity control, core cooling and RCS heat removal. The loss of the ability to determine one or more of these parameters from within the Control Room is considered to be

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 219 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases more significant than simply a reportable condition. In addition, if all indication sources for one or more of the listed parameters are lost, then the ability to determine the values of other SAFETY SYSTEM parameters may be impacted as well. For example, if the value for reactor vessel level cannot be determined from the indications and recorders on a main control board, the SPDS or the plant computer, the availability of other parameter values may be compromised as well.

Fifteen minutes was selected as a threshold to exclude transient or momentary losses of indication.

Escalation of the emergency classification level would be via IC FS1 or AS1.

Reference(s):

1. 1SAR 7.1.3 Engineered Safeguards Actuation System

2. 2SAR 7.3 Engineered Safety Features Systems

3. NEI 99-01 SA2

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 220 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 4 - RCS Activity Initiating Condition: RCS activity greater than Technical Specification allowable limits EAL:

SU4.1 Unusual Event Failed Fuel Iodine radiation monitor RI-1237S[2RITS-4806B] > 9.0 E5 cpm Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

None Basis:

This IC addresses a reactor coolant activity value that exceeds an allowable limit specified in Technical Specifications. This condition is a precursor to a more significant event and represents a potential degradation of the level of safety of the plant.

Escalation of the emergency classification level would be via IC FA1 or the Recognition Category A ICs.

Unit 1 RE-1237S, Failed Fuel Monitor, is in the letdown system to monitor the letdown line for evidence of fuel damage.

Unit 2 specific activity monitor 2RITS-4806B monitors the Letdown fluid for the presence of Iodine-131.

A monitor reading corresponding to the instantaneous dose equivalent I-131 value of 60 uCi/gm is determined by multiplying by 30 the monitor reading listed in the table in OP-1203.019[OP-2203.020] that represents a projected 2.0 uCi/gm I-131 RCS activity(ref. 2, 5).

This yields values of 3.1E6 cpm for Unit 1 and 3.9E6 cpm for Unit 2. The top of scale of the monitor is 1E6. The EAL value is set at 9.0 E5 cpm for both units which is 90% of the top of the scale.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 221 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Reference(s):

1. 1SAR Table 11-7

2. OP-1203-019 High Activity in Reactor Coolant

3. Unit 1 Technical Specifications LCO 3.4.12 RCS Specific Activity

4. 2SAR 9.3.5 Failed Fuel Detection System

5. OP-2203.020 High Activity in RCS

6. OP- 2203.012L ANNUNCIATOR 2K12 CORRECTIVE ACTION, A-1

7. Unit 2 Technical Specifications LCO 3.4.8 Reactor Coolant System Specific Activity

8. NEI 99-01 SU3

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 222 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 4 - RCS Activity Initiating Condition: RCS activity greater than Technical Specification allowable limits EAL:

SU4.2 Unusual Event RCS sample activity > 1.0 µCi/gm dose equivalent I-131 for > 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> (Note 1)

OR RCS sample activity > 60 µCi/gm dose equivalent I-131 OR RCS sample activity > 2200[3100] µCi/gm dose equivalent Xe-133 for > 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

None Basis:

This IC addresses a reactor coolant activity value that exceeds an allowable limit specified in Technical Specifications. This condition is a precursor to a more significant event and represents a potential degradation of the level of safety of the plant.

Escalation of the emergency classification level would be via IC FA1 or the Recognition Category A ICs.

Reference(s):

1. Unit 1 Technical Specifications LCO 3.4.12 RCS Specific Activity

2. Unit 2 Technical Specifications LCO 3.4.8 Reactor Coolant System Specific Activity

3. NEI 99-01 SU3

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 223 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 5 - RCS Leakage Initiating Condition: RCS leakage for 15 minutes or longer EAL:

SU5.1 Unusual Event RCS unidentified or pressure boundary leakage > 10 gpm for 15 min. (Note 1)

OR RCS identified leakage > 25 gpm for 15 min. (Note 1)

OR Reactor coolant leakage to a location outside containment > 25 gpm for 15 min. (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

UNISOLABLE - An open or breached system line that cannot be isolated, remotely or locally.

Basis:

Failure to isolate the leak (from the Control Room or locally) within 15 minutes, or if known that the leak cannot be isolated within 15 minutes, from the start of the leak requires immediate classification.

Steam generator tube leakage is identified RCS leakage.

This IC addresses RCS leakage which may be a precursor to a more significant event. In this case, RCS leakage has been detected and operators, following applicable procedures, have been unable to promptly isolate the leak. This condition is considered to be a potential degradation of the level of safety of the plant.

The first and second EAL conditions are focused on a loss of mass from the RCS due to unidentified leakage", "pressure boundary leakage" or "identified leakage (as these leakage types are defined in the plant Technical Specifications). The third condition addresses an RCS mass loss caused by an UNISOLABLE leak through an interfacing system. These conditions thus apply to leakage into the containment, a secondary-side system (e.g., steam generator tube leakage) or a location outside of containment.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 224 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases The leak rate values for each condition were selected because they are usually observable with normal Control Room indications. Lesser values typically require time-consuming calculations to determine (e.g., a mass balance calculation). The first condition uses a lower value that reflects the greater significance of unidentified or pressure boundary leakage.

The release of mass from the RCS due to the as-designed/expected operation of a relief valve does not warrant an emergency classification. An emergency classification would be required if a mass loss is caused by a relief valve that is not functioning as designed/expected (e.g., a relief valve sticks open and the line flow cannot be isolated).

The 15-minute threshold duration allows sufficient time for prompt operator actions to isolate the leakage, if possible.

Escalation of the emergency classification level would be via ICs of Recognition Category A or F.

Reference(s):

1. Unit 1 and Unit 2 Technical Specifications Section 1.1 Definitions

2. NEI 99-01 SU4

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 225 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 6 - RPS Failure Initiating Condition: Automatic or manual trip fails to shut down the reactor EAL:

SU6.1 Unusual Event An automatic trip did not shut down the reactor as indicated by reactor power > 5% after any RPS setpoint is exceeded AND A subsequent automatic trip or manual trip action taken at the reactor control console (C03

[2C03/2C14]) (manual reactor trip pushbuttons or DROPS[DSS]) is successful in shutting down the reactor as indicated by reactor power 5% (Note 8)

Note 8: A manual action is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core, and does not include manually driving in control rods or implementation of boron injection strategies.

Mode Applicability:

1 - Power Operation Definition(s):

IMMINENT - The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.

Basis:

This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor trip that results in a reactor shutdown, and either a subsequent operator manual action taken at the reactor control consoles or an automatic trip is successful in shutting down the reactor. This event is a precursor to a more significant condition and thus represents a potential degradation of the level of safety of the plant.

In the event that the operator identifies a reactor trip is IMMINENT and initiates a successful manual reactor trip before the automatic trip setpoint is reached, no declaration is required. The successful manual trip of the reactor before it reaches its automatic trip setpoint or reactor trip signals caused by instrumentation channel failures do not lead to a potential fission product barrier loss.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 226 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Following the failure of an automatic reactor trip, operators will promptly initiate manual actions at the reactor control consoles to shutdown the reactor (e.g., initiate a manual reactor trip). If these manual actions are successful in shutting down the reactor, core heat generation will quickly fall to a level within the capabilities of the plants decay heat removal systems.

If an initial manual reactor trip is unsuccessful, operators will promptly take manual action at another location(s) on the reactor control consoles to shutdown the reactor (e.g., initiate a manual reactor trip using a different switch). Depending upon several factors, the initial or subsequent effort to manually trip the reactor, or a concurrent plant condition, may lead to the generation of an automatic reactor trip signal. If a subsequent manual or automatic trip is successful in shutting down the reactor, core heat generation will quickly fall to a level within the capabilities of the plants decay heat removal systems.

A manual action at the reactor control consoles is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core (e.g., initiating a manual reactor trip).

This action does not include manually driving in control rods or implementation of boron injection strategies. Actions taken at back-panels or other locations within the Control Room, or any location outside the Control Room, are not considered to be at the reactor control consoles.

The plant response to the failure of an automatic or manual reactor trip will vary based upon several factors including the reactor power level prior to the event, availability of the condenser, performance of mitigation equipment and actions, other concurrent plant conditions, etc. If subsequent operator manual actions taken at the reactor control consoles are also unsuccessful in shutting down the reactor, then the emergency classification level will escalate to an Alert via IC SA6. Depending upon the plant response, escalation is also possible via IC FA1. Absent the plant conditions needed to meet either IC SA6 or FA1, an Unusual Event declaration is appropriate for this event.

Should a reactor trip signal be generated as a result of plant work (e.g., RPS setpoint testing),

the following classification guidance should be applied.

If the signal generated as a result of plant work causes a plant transient that results in a condition that should have included an automatic reactor trip and the RPS fails to automatically shutdown the reactor, then this IC and associated EALs are applicable, and should be evaluated.

If the signal generated as a result of plant work does not cause a plant transient and the trip failure is determined through other means (e.g., assessment of test results), then this IC and associated EALs are not applicable and no classification is warranted.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 227 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Reference(s):

1. Unit 1 Technical Specifications Table 3.3.1-1 Reactor Protection System Instrumentation

2. Unit 2 Technical Specifications Table 3.3-1 Reactor Protective Instrumentation

3. Unit 1 and Unit 2 Technical Specifications Table 1.1-1 Modes

4. OP-1202.001 Reactor Trip

5. OP-2202.001 Standard Post Trip Actions

6. NEI 99-01 SU5

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 228 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 6 - RPS Failure Initiating Condition: Automatic or manual trip fails to shut down the reactor EAL:

SU6.2 Unusual Event A manual trip did not shut down the reactor as indicated by reactor power > 5% after any manual trip action was initiated AND A subsequent automatic trip or manual trip action taken at the reactor control console (C03

[2C03/2C14]) (manual reactor trip pushbuttons or DROPS[DSS]) is successful in shutting down the reactor as indicated by reactor power 5% (Note 8)

Note 8: A manual scram action is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core, and does not include manually driving in control rods or implementation of boron injection strategies.

Mode Applicability:

1 - Power Operation Definition(s):

None Basis:

This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor trip that results in a reactor shutdown, and either a subsequent operator manual action taken at the reactor control consoles or an automatic trip is successful in shutting down the reactor. This event is a precursor to a more significant condition and thus represents a potential degradation of the level of safety of the plant.

This EAL addresses a failure of a manually initiated trip in the absence of having exceeded an automatic RPS trip setpoint and a subsequent automatic or manual trip is successful in shutting down the reactor.

Following the failure on an automatic reactor trip, operators will promptly initiate manual actions at the reactor control consoles to shutdown the reactor (e.g., initiate a manual reactor trip). If these manual actions are successful in shutting down the reactor, core heat generation will quickly fall to a level within the capabilities of the plants decay heat removal systems.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 229 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases If an initial manual reactor trip is unsuccessful, operators will promptly take manual action at another location(s) on the reactor control consoles to shutdown the reactor (e.g., initiate a manual reactor trip using a different switch). Depending upon several factors, the initial or subsequent effort to manually the reactor, or a concurrent plant condition, may lead to the generation of an automatic reactor trip signal. If a subsequent manual or automatic trip is successful in shutting down the reactor, core heat generation will quickly fall to a level within the capabilities of the plants decay heat removal systems.

A manual action at the reactor control consoles is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core (e.g., initiating a manual reactor trip).

This action does not include manually driving in control rods or implementation of boron injection strategies. Actions taken at back-panels or other locations within the Control Room, or any location outside the Control Room, are not considered to be at the reactor control consoles.

The plant response to the failure of an automatic or manual reactor trip will vary based upon several factors including the reactor power level prior to the event, availability of the condenser, performance of mitigation equipment and actions, other concurrent plant conditions, etc. If subsequent operator manual actions taken at the reactor control consoles are also unsuccessful in shutting down the reactor, then the emergency classification level will escalate to an Alert via IC SA6. Depending upon the plant response, escalation is also possible via IC FA1. Absent the plant conditions needed to meet either IC SA6 or FA1, an Unusual Event declaration is appropriate for this event.

Should a reactor trip signal be generated as a result of plant work (e.g., RPS setpoint testing),

the following classification guidance should be applied.

If the signal generated as a result of plant work causes a plant transient that results in a condition that should have included an automatic reactor trip and the RPS fails to automatically shutdown the reactor, then this IC and associated EALs are applicable, and should be evaluated.

If the signal generated as a result of plant work does not cause a plant transient and the trip failure is determined through other means (e.g., assessment of test results), then this IC and associated EALs are not applicable and no classification is warranted.

Reference(s):

1. Unit 1 Technical Specifications Table 3.3.1-1 Reactor Protection System Instrumentation

2. Unit 2 Technical Specifications Table 3.3-1 Reactor Protective Instrumentation

3. Unit 1 and Unit 2 Technical Specifications Table 1.1-1 Modes

4. OP-1202.001 Reactor Trip

5. OP-2202.001 Standard Post Trip Actions

6. NEI 99-01 SU5

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 230 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 6 - RPS Failure Initiating Condition: Automatic or manual trip fails to shut down the reactor and subsequent manual actions taken at the reactor control consoles are not successful in shutting down the reactor EAL:

SA6.1 Alert An automatic or manual trip fails to shut down the reactor as indicated by reactor power > 5%

AND Manual trip actions taken at the reactor control console (C03[2C03/2C14]) (manual reactor trip pushbuttons or DROPS[DSS]) are not successful in shutting down the reactor as indicated by reactor power > 5% (Note 8)

Note 8: A manual action is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core, and does not include manually driving in control rods or implementation of boron injection strategies.

Mode Applicability:

1 - Power Operation Definition(s):

None Basis:

This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor trip that results in a reactor shutdown, and subsequent operator manual actions taken at the reactor control consoles to shutdown the reactor are also unsuccessful. This condition represents an actual or potential substantial degradation of the level of safety of the plant. An emergency declaration is required even if the reactor is subsequently shutdown by an action taken away from the reactor control consoles since this event entails a significant failure of the RPS.

A manual action at the reactor control console is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core (e.g., initiating a manual reactor trip).

This action does not include manually driving in control rods or implementation of boron injection strategies. If this action(s) is unsuccessful, operators would immediately pursue additional manual actions at locations away from the reactor control console (e.g., locally opening breakers). Actions taken at back panels or other locations within the Control Room, or any location outside the Control Room, are not considered to be at the reactor control console.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 231 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases The plant response to the failure of an automatic or manual reactor trip will vary based upon several factors including the reactor power level prior to the event, availability of the condenser, performance of mitigation equipment and actions, other concurrent plant conditions, etc. If the failure to shut down the reactor is prolonged enough to cause a challenge to the core cooling or RCS heat removal safety functions, the emergency classification level will escalate to a Site Area Emergency via IC SS6. Depending upon plant responses and symptoms, escalation is also possible via IC FS1. Absent the plant conditions needed to meet either IC SS6 or FS1, an Alert declaration is appropriate for this event.

It is recognized that plant responses or symptoms may also require an Alert declaration in accordance with the Recognition Category F ICs; however, this IC and EAL are included to ensure a timely emergency declaration.

Reference(s):

1. Unit 1 Technical Specifications Table 3.3.1-1 Reactor Protection System Instrumentation

2. Unit 2 Technical Specifications Table 3.3-1 Reactor Protective Instrumentation

3. Unit 1 and Unit 2 Technical Specifications Table 1.1-1 Modes

4. OP-1202.001 Reactor Trip

5. OP-2202.001 Standard Post Trip Actions

6. NEI 99-01 SA5

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 232 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 6 - RPS Failure Initiating Condition: Inability to shut down the reactor causing a challenge to core cooling or RCS heat removal EAL:

SS6.1 Site Area Emergency An automatic or manual trip fails to shut down the reactor as indicated by reactor power > 5%

AND All actions to shut down the reactor are not successful as indicated by reactor power > 5%

AND EITHER:

CETs > 1200°F RCS heat removal cannot be established using steam generators and an on-shift SRO has determined that the procedure conditions are met to commence initiation of HPI[Once Through] cooling.

Mode Applicability:

1 - Power Operation Definition(s):

None Basis:

This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor trip that results in a reactor shutdown, all subsequent operator actions to manually shutdown the reactor are unsuccessful, and continued power generation is challenging the capability to adequately remove heat from the core and/or the RCS. This condition will lead to fuel damage if additional mitigation actions are unsuccessful and thus warrants the declaration of a Site Area Emergency.

In some instances, the emergency classification resulting from this IC/EAL may be higher than that resulting from an assessment of the plant responses and symptoms against the Recognition Category F ICs/EALs. This is appropriate in that the Recognition Category F ICs/EALs do not address the additional threat posed by a failure to shutdown the reactor. The inclusion of this IC and EAL ensures the timely declaration of a Site Area Emergency in response to prolonged failure to shutdown the reactor.

Escalation of the emergency classification level would be via IC AG1 or FG1.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 233 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Reference(s):

1. Unit 1 Technical Specifications Table 3.3.1-1 Reactor Protection System Instrumentation

2. Unit 2 Technical Specifications Table 3.3-1 Reactor Protective Instrumentation

3. Unit 1 and Unit 2 Technical Specifications Table 1.1-1 Modes

4. OP-1202.001 Reactor Trip

5. OP-2202.001 Standard Post Trip Actions

6. OP-1202.004 Overheating

7. OP-2202.006 Loss of Feedwater

8. OP-1202.013 Figure 1, Saturation and Adequate SCM

9. Calculation 90-E-0116-07 Unit 1 EOP Setpoint Document, Setpoint B.19

10. OP-2202.009 Functional Recovery

11. Calculation 90-E-0116-01 Unit 2 EOP Setpoint Document

12. NEI 99-01 SS5

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 234 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 7 - Loss of Communications Initiating Condition: Loss of all onsite or offsite communications capabilities EAL:

SU7.1 Unusual Event Loss of all Table 1[2]S-4 onsite communication methods OR Loss of all Table 1[2]S-4 State and local agency communication methods OR Loss of all Table 1[2]S-4 NRC communication methods Table 1[2]S-4 Communication Methods System Onsite State / Local NRC Station radio system X ANO plant phone system X Gaitronics X Telephone Systems:

Commercial Microwave X X Satellite VOIP Emergency Notification System (ENS) X Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

None

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 235 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Basis:

This IC addresses a significant loss of on-site or offsite communications capabilities. While not a direct challenge to plant or personnel safety, this event warrants prompt notifications to State and local agencies and the NRC.

This IC should be assessed only when extraordinary means are being utilized to make communications possible (e.g., use of non-plant, privately owned equipment, relaying of on-site information via individuals or multiple radio transmission points, individuals being sent to offsite locations, etc.).

The first EAL condition addresses a total loss of the communications methods used in support of routine plant operations.

The second EAL condition addresses a total loss of the communications methods used to notify all State and local agencies of an emergency declaration. The State and local agencies referred to here are the Arkansas Department of Health, Arkansas Department of Emergency Management, Pope, Yell, Johnson, and Logan County agencies.

The third EAL addresses a total loss of the communications methods used to notify the NRC of an emergency declaration.

This EAL is the hot condition equivalent of the cold condition EAL CU5.1.

Reference(s):

1. OP-1903.062 Communications System Operating Procedure

2. NEI 99-01 SU6

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 236 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 8 - Containment Failure Initiating Condition: Failure to isolate containment or loss of containment pressure control EAL:

SU8.1 Unusual Event Any penetration is not closed within 15 min. of an ESAS[CIAS] actuation signal OR Containment pressure > 44.7 psia[23.3 psia] with < one full train of containment heat removal systems (Note 9) operating per design for 15 min. (Note 1)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Note 9: One full train of containment heat removal systems consists of one train of RB [Containment]

Spray and one train of RB [Containment] Cooling System.

Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

None Basis:

A penetration is closed for this EAL if either side of the penetration has a closed valve or a check valve is intact (for penetrations that only have one automatic valve and a check valve).

This EAL addresses a failure of one or more containment penetrations to automatically isolate (close) when required by an actuation signal. It also addresses an event that results in high containment pressure with a concurrent failure of containment pressure control systems.

Absent challenges to another fission product barrier, either condition represents potential degradation of the level of safety of the plant.

For the first condition, the containment isolation signal must be generated as the result on an off-normal/accident condition (e.g., a safety injection or high containment pressure); a failure resulting from testing or maintenance does not warrant classification. The determination of containment and penetration status - isolated or not isolated - should be made in accordance with the appropriate criteria contained in the plant AOPs and EOPs. The 15-minute criterion is included to allow operators time to manually isolate the required penetrations, if possible.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 237 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases The second condition addresses a condition where containment pressure is greater than the setpoint at which containment energy (heat) removal systems are designed to automatically actuate, and less than one full train of equipment is capable of operating per design. The 15-minute criterion is included to allow operators time to manually start equipment that may not have automatically started, if possible. The inability to start the required equipment indicates that containment heat removal/depressurization systems (e.g., containment sprays) are either lost or performing in a degraded manner.

This event would escalate to a Site Area Emergency in accordance with IC FS1 if there were a concurrent loss or potential loss of either the Fuel Clad or RCS fission product barriers.

Reference(s):

1. OP-1202.010 ESAS

2. 1SAR 6.2 Reactor Building Spray System

3. 1SAR 6.3 Reactor Building Cooling System

4. OP-2202.003 Loss of Coolant Accident

5. OP-2202.010 Standard Attachments, Attachment 22

6. 2SAR 6.2.2 Containment Heat Removal Systems

7. 2SAR 7.3.1.1.11.2 Containment Spray System

8. NEI 99-01 SU7

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 238 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 9 - Hazardous Event Affecting Safety Systems Initiating Condition: Hazardous event affecting SAFETY SYSTEMS needed for the current operating mode EAL:

SA9.1 Alert The occurrence of any Table 1[2]S-5 hazardous event AND Event damage has caused indications of degraded performance on one train of a SAFETY SYSTEM needed for the current operating mode AND EITHER:

Event damage has caused indications of degraded performance to the second train of the SAFETY SYSTEM needed for the current operating mode Event damage has resulted in VISIBLE DAMAGE to the second train of the SAFETY SYSTEM needed for the current operating mode (Notes 10, 11)

Note 10: If the affected SAFETY SYSTEM train was already inoperable or out of service before the hazardous event occurred, then emergency classification is not warranted.

Note 11: If the hazardous event only resulted in VISIBLE DAMAGE, with no indications of degraded performance to at least one train of a SAFETY SYSTEM, then this emergency classification is not warranted.

Table 1[2]S-5 Hazardous Events Seismic event (earthquake)

Internal or external FLOODING event High winds or tornado strike FIRE EXPLOSION Other events with similar hazard characteristics as determined by the Shift Manager

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 239 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

EXPLOSION - A rapid, violent and catastrophic failure of a piece of equipment due to combustion, chemical reaction or overpressurization. A release of steam (from high energy lines or components) or an electrical component failure (caused by short circuits, grounding, arcing, etc.) should not automatically be considered an explosion. Such events require a post-event inspection to determine if the attributes of an explosion are present.

FIRE - Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute fires. Observation of flame is preferred but is not required if large quantities of smoke and heat are observed.

FLOODING - A condition where water is entering a room or area faster than installed equipment is capable of removal, resulting in a rise of water level within the room or area.

SAFETY SYSTEM - A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related (as defined in 10 CFR 50.2).

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

VISIBLE DAMAGE - Damage to a SAFETY SYSTEM train that is readily observable without measurements, testing, or analysis. The visual impact of the damage is sufficient to cause concern regarding the operability or reliability of the affected SAFETY SYSTEM train.

Basis:

This IC addresses a hazardous event that causes damage to SAFETY SYSTEMS needed for the current operating mode. In order to provide the appropriate context for consideration of an ALERT classification, the hazardous event must have caused indications of degraded SAFETY SYSTEM performance in one train, and there must be either indications of performance issues with the second SAFETY SYSTEM train or VISIBLE DAMAGE to the second train such that the potential exists for this second SAFETY SYSTEM train to have performance issues. In other words, in order for this EAL to be classified, the hazardous event must occur, at least one SAFETY SYSTEM train must have indications of degraded performance, and the second SAFETY SYSTEM train must have indications of degraded performance or VISIBLE DAMAGE such that the potential exists for performance issues.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 240 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 1 - Emergency Action Level Technical Bases Note that this second SAFETY SYSTEM train is from the same SAFETY SYSTEM that has indications of degraded performance; commercial nuclear power plants are designed to be able to support single system issues without compromising public health and safety from radiological events.

Indications of degraded performance addresses damage to a SAFETY SYSTEM train that is in service/operation since indications for it will be readily available. The indications of degraded performance should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.

VISIBLE DAMAGE addresses damage to a SAFETY SYSTEM train that is not in service/operation and that potentially could cause performance issues. Operators will make a determination of VISIBLE DAMAGE based on the totality of available event and damage report information. This is intended to be a brief assessment not requiring lengthy analysis or quantification of the damage. This VISIBLE DAMAGE should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.

Escalation of the emergency classification level would be via IC FS1 or AS1.

This EAL is the hot condition equivalent of the cold condition EAL CA6.1.

Reference(s):

1. EP FAQ 2016-002

2. NEI 99-01 SA9

3. EP FAQ 2018-04

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 241 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 2 - Safe Operation & Shutdown Areas Tables 1[2]A-3 & 1[2]H-2 Bases

Background

NEI 99-01 Revision 6 ICs AA3 and HA5 prescribe declaration of an Alert based on impeded access to rooms or areas (due to either area radiation levels or hazardous gas concentrations) where equipment necessary for normal plant operations, cooldown or shutdown is located. These areas are intended to be plant operating mode dependent.

Specifically the Developers Notes for AA3 and HA5 states:

The site-specific list of plant rooms or areas with entry-related mode applicability identified should specify those rooms or areas that contain equipment which require a manual/local action as specified in operating procedures used for normal plant operation, cooldown and shutdown. Do not include rooms or areas in which actions of a contingent or emergency nature would be performed (e.g., an action to address an off-normal or emergency condition such as emergency repairs, corrective measures or emergency operations). In addition, the list should specify the plant mode(s) during which entry would be required for each room or area.

The list should not include rooms or areas for which entry is required solely to perform actions of an administrative or record keeping nature (e.g., normal rounds or routine inspections).

Further, as specified in IC HA5:

The list need not include the Control Room if adequate engineered safety/design features are in place to preclude a Control Room evacuation due to the release of a hazardous gas. Such features may include, but are not limited to, capability to draw air from multiple air intakes at different and separate locations, inner and outer atmospheric boundaries, or the capability to acquire and maintain positive pressure within the Control Room envelope.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 242 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 2 - Safe Operation & Shutdown Areas Tables 1[2]A-3 & 1[2]H-2 Bases ANO Table 1[2]A-3 and 1[2]H-2 Bases A review of station operating procedures identified the following mode dependent in-plant actions and associated areas that are required for normal plant operation, cooldown or shutdown:

Unit 1 AREA MODES PURPOSE REFERENCE Core flood tank valves, OP-1102.010 A-4 Switchgear Room 3, 4 decay heat removal (DHR) OP-1104.004 Upper North Electrical 3, 4 DHR alignment OP-1104.004 Penetration Room Lower South Electrical 3, 4 DHR alignment OP-1104.004 Equipment Room Unit 2 AREA MODES PURPOSE REFERENCE Aux Building 317 Emergency Shutdown Cooling (SDC) 3, 4 OP-2104.004 Core Cooling Rooms venting and alignment Aux Building 317 Tendon 3, 4 SDC alignment OP-2104.004 Gallery Access Charging low pressure Aux Building 335 Charging OP-2102.010 operation, T-Hot injection Pumps / Motor Control Center 3, 4 valves, and SDC OP-2104.004 (MCC) 2B-52 alignment SDC alignment and T-Hot OP-2102.010 Auxiliary Building 354 3, 4 injection valves at MCC 2B-62 Area OP-2104.004 MCC 2B-62 Close Safety Injection Tank (SIT) valves and Emergency Diesel Generator SDC / Low Temperature 3, 4 OP-2102.010 Corridor Overpressure (LTOP) valve alignment at MCC 2B-51 Lower South Piping 3, 4 SDC alignment OP-2104.004 Penetration Room Aux Building 386 Close SIT valves at 3, 4 OP-2102.010 Containment Hatch MCC 2B-61 Mode 3 is included above for DHR- and SDC-related activities because the procedures begin alignment in Mode 3; however, these actions could be delayed until

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 243 of 243 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 059 Attachment 2 - Safe Operation & Shutdown Areas Tables 1[2]A-3 & 1[2]H-2 Bases Mode 4, if necessary. In order to ensure adequate guidance to emergency response personnel, the above areas are added to the EAL in order to provide prompt operator guidance for EAL declaration.

Both ANO-1 and ANO-2 Control Room ventilation systems have adequate engineered safety/design features in place to preclude a Control Room evacuation due to the release of a hazardous gas. Therefore the Control Room is not included in this assessment or in Tables 1[2]H-2.

Table 1[2]A-3 & 1[2]H-2 Results Table 1[2]A-3 & 1[2]H-2 Safe Operation & Shutdown Rooms/Areas Unit 1 Room/Area Mode Applicability A-4 Switchgear Room 3, 4 Upper North Electrical Penetration Room 3, 4 Lower South Electrical Equipment Room 3, 4 Unit 2 Room/Area Mode Applicability Aux Building 317 Emergency Core Cooling Rooms 3, 4 Aux Building 317 Tendon Gallery Access 3, 4 Aux Building 335 Charging Pumps / MCC 2B-52 3, 4 Auxiliary Building 354 MCC 2B-62 Area 3, 4 Emergency Diesel Generator Corridor 3, 4 Lower South Piping Penetration Room 3, 4 Aux Building 386 Containment Hatch 3, 4