ML20217H744

Forwards Proposed Rev 0 to AP 06-002, Radiological Emergency Response Plan (Rerp). Rev Is Rewrite of RERP & Conversion to Std WCNOC Procedure Format

ML20217H744
Person / Time
Site:	Wolf Creek
Issue date:	08/06/1997
From:	Warren C WOLF CREEK NUCLEAR OPERATING CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20217H751	List: ML20217H744
References
WO-97-0058, WO-97-58, NUDOCS 9708130210
Download: ML20217H744 (24)

Text

I l

4 Clay C. Warren W9LF CREEK NUCLEAR OPERATING CORPORATION l

Chief Operating Officer August 6, 1997 WO 97-0058 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station Pl-137 Washington, D. C. 20555

Subject:

Docket No. 50-482: Proposed Revision to Wolf Creek Generating Station Radiological Emergency Responso Plan Gentlement This letter transmits a proposed revision to the Wolf Creek Generating Station Radiological Emergency Response Plan (RERP). This revision is a comprehensive rewrite of the RERP and a conversion to the standard Wolf Creek Nuclear Operating Corporation (WCNOC) procedure format. WCNOC has evaluated the proposed change, pursuant to 10 CFR 50. 54 (q), and determined that certain items included in the proposed change may constitute a reduction in effectiveness of the plan. WCNOC requests NRC approval of this proposed change by December 19, 1997, to support our current implementation schedule.

Enclosure 1 identifies changes, based on our evaluation, that requ'i re NRC approval prior to implementation. Enclosure 2 provides an evaluation of the proposed changes in accordance with -10 CFR 50.54(q) and a summary of those j changes. Enclosure 3 provides the change summary for this revision.

! Enclosure 4 provides the full text of the proposed revision to the RERP.

If you have any questions regarding this proposed change please contact me at (316) 364-8831, extension 4485, or Mr. Richard D. Flannigan at extension 4500.

l Ver truly you rs, 4

')

4. n o t } ],

! ~

Cla C. Warren

, CCW/jad i

4 Enclosure 1: Changes for NRC Review

Enclosure 2

Evaluation and Disposition of Proposed Changes

Enclosure 3: Change Summary for RERP Change to AP 06-002, " Radiological Emergency Rtesponse Plan" 4 Enclosure 4: Proposed Radiological Emergency Response Plan /

k N cc: W. D. Johnson (NRC), w/e i

E. W. Merschoff (NRC), w/e lIl

., dl , i .,i4 .,Th },

J. F. Ringwald (NRC), w/e J. C. Stone (NRC), w/e I I l

4

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- Ndegfon. KS 66839 / Phone. (3161364-8831 9708130210 970006 2  % oi%,Necm ADOCK 0500

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ENCLOSURE 1 i

TO WCNOC LETTER WO 97-0058 CHANGES FOR NRC REVIEW 4

s

CHAMGES FOR HRC REVIEW Page 1 of 1 The Wolf Creek Generating Stat!on (WCGS) Radiological Emesgency Response Plan (RERP) has been upgraded to the new procedure format. The RERP will be an Administrative Procedure (AP) and will meet the format requirements of the WCGS procedure writer's guide." Redundant information located in two or more sections of the RERP has been entered in only one location in the new AP.

Some items were changed and should be reviewed by the NRC for approval. The following is a list of the items WCGS is requesting to t>e reviewed and approved by the NRC.

1. In section 1. 0, Normal Operating Organization, of the old plan, positions not required by NUREG-065 , Table B-1, have been removed from the plan. These support roles ate still used as needed to enhance facility performance. Thase positions, if not staffed, will not affect the activation of an emergency facility. The following is a list of the positions removed:

• Step 1.2.2.1, Operations Assessment Coordinator.

• Step 1.2.2.1.1, Operations Status board Recorder.

• Step 1.2.3.1.1, Field Team Conaunicator.

• Step 1.2.3.2.2, Radiological Status Board Recorder.

• Step 1.2.4.2, Accountability Clerk.

• Step 1.2.6, TSC Clerk.

• Step 1.2.9.4, Warehouse Support.

• Step 1.3.1.1, Technical Logkeeper.

• Step 1.3.3.1.1, EOF Field Team Communicator.

• Step EOF Operations Status Board Recorder.

• Step 1.3.5.2, EOF Administrative Assistant.

l

• Step 1.3.6.1.2, Media Center Registrar.

• Step 1.3.6.1.3, Audio / Visual Support.

• Step 1.3.6.2.1, Information Clearinghouse Administrative Assistant.

• Step 1.3.6.3.1, Phone Team.

• Step 1.3.6.4.1, Media Monitoring Team.

Positions required for Emergency facility activation, as suggested by NUREG-0654, Table B-1, are covered in the new AP in the following steps t

• Step 6.5, Control Room Organization.

• Step 6.6, Technical Support Center Organization.

• Step 6.7, Operations Support Center Organization.

• Step 6.8, Emergency Operations Facility Organization.

• Step 6.9, Public Information Organization.

2. In Section 2.0, the facility activation times have changed. The TSC has changed from activation in 30 minutes during normal working hours end 60 minutes during off normal working hours to a goal of 75 minutes fc all times to activate the TSC. The EOF has changed to a goal of 90 minutes.

These activation times were covered in the following:

• Old step 4.1.1.2 for the TSC to new step 6.6.1.

• Old step 4.1.1.3 for the EOF to new step 6.8.1,

3. Positions in RERP Table 1.1-1 were eliminated when to make required positions consistent with those recommended in NUREG-0654. The number of Health Physics personnel required at various times was also change to more accurately reflect requirements of NUREG-0654. The table was changed to Attachment D.

I I

ENCLOSURE 2 TO WCNOC LETTER WO 97-0058 EVALUATION AND DISPOSITION OF PROPOSED CHANGE 1

EVALt!ATION AND DISPOSITION OF PROPOSED CHANGE Page 1 of 2 The Radiological Emergency Response Plan (RERP) has been completely restructured, putting this document into the format of an Administ r ntive Procedure, which conforms to the format of the WCGS procedure writer's guide.

The major changes to the content of the RERP are as follows:

A. The positions required to activate the Technical Support Center (TSC)

, worm modified to allow activation when the TSC becomes capable of Ossuming the majot functions from the Control Room. The TSC becomea fully functional when all positions have been staffed. This will allow for a timely transition of major functions from the Control Room, allowing the Control Room to focus on plant conoitions requiring immediate attention.

1 B. The activation time for the TSC has been modified to a gosi of 75 minutes from the declaration of an ALERT.

C. The activation time for the Emergency Operations racility (EOF) has been modified to a goel of 90 minutes from the declaration of a Site Area Emergency or General Emergency.

i D. Moved the Emergency Action Levels (EALs) from a table within the body of the RERP to a form controlled by the RERP. This change also includes a connitment to ensure that a Unreviewed Safety Question Determination (USQD) is performed on the EALs, as is currently

, required.

The following areas of the RERP have been effected:

This change effects th . ..ary responsibilities described in the Emergency Plan in that positions which cover the functional areas of the emergency as listed in Table B-1 of NUREG-0654 are covered, However, those positions which have a minor support role and do not affect the activation of the emergency facilities have been removed. The plan will more accurately reflect the positions required to activate emergency facilities. Steps have been placed in the plan to allow for positions not recommended by Table B.1 to be used to enhance performance in the emergency facilities. This change should not reduce the overall ef fectiveness of the plan because it does not affect the key functions of the emergency facility and allows for changes within the Emergency Response _ Organization (ERO) as better methods and means are ava'lable for conducting these minor support roles without having to make a change. However, NRC approval should be received before implementation.

Positions in RERP Table 1.1-1 were eliminated to make required positions consistent with those recommended in NUREG-0654. The number of Health Physics personnel required at various times was also changed to more accurately reflect requirements of NUREG-0654. The table was changed to Attachment D.

This item should be reviewed by the NRC.

The Emergency Action Level (EAL) flow charts have not been changed. However, to be consistent with the format of the WCGS procedure writer's guide, they have been made into a form. A commitment was added to the RERP to ensure that a USQD is performed for all EAL changes. This is not a reduction in the effectiveness of the plan since the same review and approval process is retained and no changes were made to the EALs themselves.

The insediate notification form was not changed. A description of the general information which must be provided was moved and is described in the actions for the Shift Supervisor, Duty Emergoney Director, and Duty Emergency Manager.

This form can not be changed without concurrence of the State and County. This is not a reduction in the effectiveness of the plan.

EVALUATION AND DISPOSITION OF PROPOSED CHANGE Page 2 of 2 Several tables were removed from the supplements which describe Hotel and School locations and capacities and information describing how evacuation time estimates are calculated. This change does not affect protective action reconcendations. Coffey County is responsible for this information and it is contained in the county emergency plan. This is not a reduction in ie offectiveness of the plan The current revision of the RERP states that a Health Physics Technician (HP)

, will travel in the ambulance. It is also states that if a HP does not travel I

in the ambulance, personnel qualified in contamination control will accompany the victim and an HP will arrive at the hospital. To clarify this inconsistency, the initial statement indicating an HF would travel with the i

ambulance, is removed. This is not a reduction in the effectiveness of the plan.

The description of the exercise cycle was changed from 5 years to 6 years.

However, this change is being made to be consistent with the NRC inspection cycle and therefore this is not a reduction in the effectiveness of the plan.

Thia activation times for the TSC and EOF described in the RERP have changed.

The activation times for the TSC have been changed from 30 minutes during normal working hours and 60 minutos during of f normal hours to a goal of 75 minutes during all times, and the activation time for the Eor has been changed j to a goal of 90 minutes. The times have been changed to give personnel respending to an emergency a more realistic time to respond after normal working hours or if responding from the Learning Center to the site during

, normal working hours. The major population areas for people responding to emergency facilities include Emporia, Kansas and Ottawa, Kansas. The driving distance to the WCGS site from Emporia, Kansas is approximately 45 miles and

< the driving distance to the WCGS site from Ottawa, Kansas is approximately 50 4

miles. The establishment of the activation times as goals allows for the consideration of adverse weather or other conditions which may affect responso times. Present requirements may lead personnel to respond in an unsafe manner to meet the requirements for activation. Due to changing requirements for the

. time to activate an emergency facility, the requirement for having an offsite team deployed within one hour f rom ' the declaration of an ALERT has been

, modified. Under the responsibility of the Dose Assessment Coordinator (DAC) i and the Radiological Assessment Supervisor (RAS) a statement was added to have it be a priority in getting the of f-site monitoring teams dispatched. The changes in activation times are considered a reduction in the effectiveness of the plan. Therefore, NRC approval is necessary before implementation.

l The enclosed change summary provides a detailed description of all changes.

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4

l ENCLOSURE 3 l

TO WCNOC LETTER WO 97-0058 CHANGE

SUMMARY

FOR RERP CHANGE TO-AP 06-002

" RADIOLOGICAL EMERGENCY RESPONSE PLAN"

_.__.m__._._

CRANGE

SUMMARY

FOR RERP CHANGE TO Page 1 of 15 AP 06-002,

• RADIOLOGICAL E!CRGENCY RESPONSE PLAN" The RERP has been changed to an Administrative Procedure (AP) to be consistent

with procedures used at Wolf Creek Generating Station (WCGS). The format of

[

Y the AP makes the procedure easier to use because of the laycut of information.

During the change to the AP format the same information i being conveyed, but

>; - some of the wording was changed to make the directions re. 3asier and to meet WCGS writer's guide format. Information which was contained in several sections of the old plan war placed in one section of the new AP. This should eliminate contradicting statements due to making changes to information in one

{ section but not to other sections containing the same information. When information contained in several sections was placed in one location, some of the old RERP paragraphs containing the same information were deleted.

Information in the new AP is easier to find since it is better identified in the Table Of Contents. The table shown below is a cross-reference of the changes made from the RERP to the new AP. Some of the reasons for changes are listed as being editorial enhancement to make the section/ step easier to read and understand due to the above mentioned reasons. Several positions were removed from the text of the RERP, but not from the Emergency Plan Organization. This was done to make the PERP more closely aligned with statutory requirements and guidance.

Step Description Reason for Change ALL Changed RERP into new The new tormat is easier to use and Administrative Procedure (AP) Information should be in only one format. Made wording changes to location, thu3 decreasing the improve readability, chance to miss changing all the information during a revision.

Section 0.0 Deleted all of the section. This is a summary and the new AP does not have a summary section.

The information in this section is covered in the body of the new AP.

Section 1.0, Paragraph 1 captured in step 2.5 of Step 2.5 is under the scope section step 1.1 AP. and covers the organization and its ,

functions.

Paragraph 2 captured in stop b.5.1- The Figure is now Figure 2 and

1. covered under the Control Room organization.

Paragraph 3 captured in step 2.5. Step 2.5 1s under the scope section Vice-President Plant Operations has and covers the organization and its to Plant Manager. functions. Changed VP Plant Ops due to title change, B:T+ ap.. t captured in step 6.5. Step 6.5 is Control Room g+

organization. Minor changes to wording to read better.

k Paragraph 3 captured in step 6.5.1- Wording tormat changed to read

1. better.

Paragraph 6 captured in step 6.5.1- Both steps together contain the 1 and 6.5.5. subject matter of this paragraph.

Paragraph 7 captured in step 6.6. Step o.6 is TSC organization.

Changed time to respond to "a goal Minor changes to wording to improve to retivate the TSC within 75 readability. Time changed to a mir ces of an Alert, goal to allow for a more realirtic time for personnel to respond from home. The major population areas, for people responding to this facility include Emporia and Ottawa. Increasing the amount of time to a goal of 75 minutes provides a more realistic amount of time for personnel to safely report from home.

-- - .. . - . . . . -~

CHANGE SUM 4ARY FOR RERP CHANGE TO Page 2 of 15 AP 06-002, *RADIGlf.% CAL EMERGENCY RESPONSE PIAN" Step Description l_,, Reason for Change 1.2 Paragraph I deleted. Th2s paragrrph was deleted since Sct.er e t ep: in*>elving the nenirstions covers it.

Paragraph 2 captured in step 6.6.5. St'e7").5 discusses the management Removed the VP Plant Operations. organizatien and step 6.6.5 covers the DED position.

Paragraph 3 captured in step 6.6.5- Step 6.6.5-2 covers the transfer of

2. duties form the SS to the DED.

1. 2.1 Paragraph I captured in steps 6.6, This paragraph is covered by

6. 5, 6.8, & 6.5.2. several steps under each position or subject.

Paragraph 2 captured in step 6.5.2 Step b.5.2 covers the position of and substeps. the SS.

Paragraph 3 captured in step 6.6.5 Step 6.6.5 covers the position of and substeps. the DED.

1.2.1 Paragraph 4 captured in step 6.6.5- Step 6.6.5-4 lists the non-

4. transferable duties of the DED.

1.2.2 Captured in step 6.6.6. Step 6.6.6 covers the position of the OEC.

1.2.2.1 The OAC title was deleted. This position is not addressed by NUREG-0654, Table B-1. Failure to staff this position will not prevent the activation of the facility. RFRP step 6.6.18 allows for additional personnel if needed, The responsibilities for this function are described in the EPPs.

1.2.2.1.1 The operations Status Board This position is not addressed by

, Recorded title was deleted. NUREG-0654, Table B-1. Failure to staff this position will not prevent the activation of the facility. RERP step 6.6.18 allows for additional personnel if needed.

The responsibilities for this function are described in the EPPs.

1.2.2.2 Captured in step 6.b.7 Step 6.b.7 covers this position.

1.2.2.2.1 Captured in step 6.6.8. Step b.6.8 covers this position.

1.2.2.3 Captured in step 6.6.9. Step 6.6.9 covers this position.

1.2.3 Captured in step 6.6.10. Step 6.6.10 covers this position.

1.2.3.1 Captured in step 6.6.15. Step 6.6.15 covers this position.

1.2.3.1.1 The Field Team Communicator title This position is not addressed by was deleted. NUREG-0654, Table B-1. Failure to staff this position will not prevent the activation of the facility. RERP step 6.6.18 allows for additional personnel if needed.

The responsibilities for this function are described in the EPPs.

1.2.3.2 Captured in step 6.6.11. Step 6.6.11 covers this position.

1.2.3.2.1 Captured in step 6.6.13. Step 6.6.13 covers this position.

1.2.3.2.2 The Radiological Gtatus Board This position is not addressed by Recorder title was deleted. NUREG-0654, Table B-1. Failure to staff this position will not prevent the activation of the facility. RERP step 6.6.18 allows for additional personnel if needed.

The responsibilities for this function are described in the EPPs.

1.2.3.3 Captured in step 6.6.12. Step 6.6.12 covers this position.

1.2.4 Captured in step 6.6.14. Step 6.6.14 covers this position.

1.2.4.1 Captured in step 6.6.16. Step 6.6.16 covers this position.

CHANGE StM4ARY FOR RERP CHANGE TO Page 3 et 15 AP 06-002, " RADIOLOGICAL EMERGENCY RESPONSE PLAN" Step Description Reason for Change 1.2.4.2 The Accountability Clerk title was This position is not addressed by deleted. NUREG-0654, Table B-1. Failure to staff this position will not prevent the activation of the

, facility. RERP step 6.6.18 allows for additional personnel if needed.

The responsibilities for this function are described in the EPPs.

1.2.5 Captured in step 6.6.17. Step 6.6.17 covers this position.

1.2.6 The TSC Clerk title was deleted. This position is not addressed by J

NUREG-0654, Table D-1. Failure to staff this position will not prevent the activation of the facility. RERP step 6.6.18 allows for additional personnel if needed.

The responsibilities for this function are described in the EPPs.

1.2.7 Captured in step 6.9.2. Step 6.9.2 covers this position.

1.2.8 Deleted step. This position has been deleted.

1.2.9 Captured in step 6.7.1. Step 6.7.1 covers this position.

1.2.9.1 Captured in step 6.7.2. Step 6.7.2 covers this position.

1.2.9.2 Captured in step 6.7.2. Step 6.7.2 covers this position.

1.2.9.3 Captured in step 6.7.2. Step 6.7.2 covers this position.

1.2.9.4 The Warehouse Support title was This position is not addressed by deleted. HUREG-0654, Table B-1. Failure to staff this position will not prevent the activation of the facility. RERP step 6.6.18 allows for additional personnel if needed.

The responsibilities for this function are described in the EPPs.

1.2.10 Deleted. Deleted due to the Table being d

deleted.

1.3 Deleted. This step provided general

, information. Details of positions called for in the plan are covered in sections 6.5 through 6.9 1.3.1 Captured in step 6.8.1, 6.8.2-2, & Step 6.8.1 and 6.8.2 covers the DEM 6.8.2-3. Changed the activation position and duties. Time changed time to "a goal to be activated to a goal to allow for times when within 90 minutes of a declaration severe weather may not allow for of an SAE or GE*, normal response times, for

, personnel responding from home.

The major population areas, for people responding to this facility include Topeka and Olathe, Changing the response time to a goal of 90 minutes provides an allowance when conditions prevent personnel from reporting safely from home in ninety minutes.

1.3.1.1 The Technical Logkeeper title was This position is not addressed by deleted. NUREG-0654, Table B-1. Failure to staff this position will not prevent the activation of the facility. RERP step 6.8.14 allows for additional personnel if needed.

The responsibilities for this function are described in the EPPs.

1.3.2 Captured in step 6.9.3. Step 6.9.3 covers this position.

1.3.3 Captured in steps 6.8.3 & 6.8.3-1. Step 6.8.3 covers this position.

CHANGE

SUMMARY

FOR RERP CHANGE TO Page 4 of 15 AP 06-002, " RADIOLOGICAL EMERGENCY RESPONSE PLAN" Step Description Reason for Change ~~

1,3.3.1 Captured in step 6.8.4. Step 6.8.4 covers this position.

1.3.3.1.1 The EOF Field Team Communicator This position is not addressed by title was deleted. NUREG-0654, Table B-1. Failure to staff this position will not prevent the activation of the facility. RERP step 6.8.14 allows for additional personnel if needed.

The responsibilities for this function are described in the EPPs.

1.3.3.1.2 Captured in step 6.8.5. Step 6.8.$ covers this position.

1.3.3.2 Captured in step 6.8.6. Step 6.8.6 covers this position.

1.3.3.2.1 Captured in step 6.8.7 Step 6.8.7 covers this position.

1.3.3.3 Captured in step 6.8.8. Step 6.8.8 covers this position.

1.3.4 Captured in step 6.8.9. Step 6.8.9 covers this position.

1.3.4.1 The EOF Ops Status Recorder title This position is not addressed by was deleted. NUREG-0654, Table B-1. Failure to staff this position will not prevent the activation of the facility. RERP step 6.8.14 allows for additional personnel if needed.

The responsibilities for this function are described in the EPPs.

1.3.4.2 Captured in step 6.8.10. Step b.8.10 covers this position.

1.3.5 Captured in step 6.8.11. Step 6.8.11 covers this position.

1.3.5.1 Captured in step 6.8.13. Step 6.8.13 covers this position.

1.3.5.2 The EOF Administrative Assistant This position is not addressed by title was deleted. NUREG-0654, Table B-1. Failure to staff this position will not prevent the activation of the facility. RERP step 6.8.14 allows for additional personnel if needed, The responsibilities for this function are described in the EPPs.

1.3.5.3 Captured in step 6.8.12. Step 6.8.12 covers this position.

1.3.6 Captured in step 6.9.1. Step 6.5.1 covers this position.

1.3.6.1 Captured in step 6.9.4. Step 6.9.4 covers this position.

1.3.6.1.1 Captured in step 6.9.5. Step 6.9.5 covers this position.

1.3.6.1.2 The Media Center Registrar title This position is not addressed by was deleted. NUREG-0654, Table B-1. Failure to staff this position will not prevent the activation of the facility. RERP step 6.9.11 allows for additional personnel if needed.

The responsibilities for this function are described in the EPPs.

1.3.6.1.3 The Audio / Visual Support title was This position is not addressed by deleted. NUREG-0654, Table B-1. Failure to staff this position will not prevent the activaticn of the facility. RERP step 4.r.11 allows for additional persor..wd if needed.

The responsibilities tor this function are described in the EPPs.

1.3.6.2 Captured in step 6.9.6. Step 6.9.6 covers this position.

1.3.6.2.1 The Inf ormation Clearinghouse This position is not addressed by Administrative Assistant title was NUREG-0654, Table B-1. Failure to deleted. staff this position will not prevent the activation of the facility. RERP step 6.9.11 allows for additional persontal if needed, The responsibilities for this function are described in the EPPs.

CRANGE SUltiARY FOR RERP CHANGE TO Page 5 of 15 AP 06-002, "RADIOLCGICAL EMERGENCY RESPONSE PLAN" Step Description Reason for Change

-1.3.6.3 Captured in step 6.9.7 Step 6.9.7 covers t his position.

1.3.6.3.1 The Fhone Team title was deleted. This position is not addressed by NUREG-0654, Table B-1. Failure to staff this position will not prevent the activation of the facility. RERP step 6.9.11 allows for additional personnel if needed.

The responsibilities for this function are described in the EPPs.

1.3.6.4 Captured in step b.9.8. Step 6.9.8 covers this position.

1.3.6.4.1 The Media Monitoring Team title was This position is not addressed by deleted. NUREG-0654, Table B-1. Failure to staff this position will not prevent the activation of the facility. RERP step 6.9.11 allows for additional personnel if needed.

The responsibilities for this function are described in the EPPs.

1.3.6.5 Captured in step 6.9.9. Step 6.9.9 covers this position.

1.3.6.6 Captured in step b.9.10. Step 6.9.10 covers this position.

1.3.7 Captured in step 6.5.3-la. Step b.5.3-la covers this position.

1.4.1 Paragraph 1 captured in step 6.10.1 Paragraphs captured as stated with

& 6.10.2. minor word changes for better readability.

Paragraph 2 captured in step 6.11.1

& 6.4.7-2.

Paragraph 3 captured in step 6.3.3.

Paragraph 4 captured in step b.5.2, 6.6.5, & 6.8.2.

Paragraph 5 captured in step 6.5.2.

1.4.1.1 Paragraph I captured in step The County Plan is covered by this 6.10.1. step.

Paragraph 2 captured in step 4.19, Added immediate notification to 6.5.2, 6.6.5-3, & 6.8.2-2g. definition Section (4.19) and the covered the subject in the SS, DED,

& DEM position steps.

Paragraph 3 deleted. Paragraph does not fit the format of the AP and duties are covered in other steps of the AP.

1.4.1.1.1 Paragraph I captured in step Step 6.10.2 covers this position.

6.10.2.

Paragraph 2 captured in step 6.10.2 Steps 6.10.2 & 6.10.3 covers this

& 6.10.3. position.

Paragraph 3 captured in step 6.10.2 Steps 6.10.2 & 6.10.3-3 covers this

& 6.10.3-3. position.

1.4.1.1.2 Captured in step 6.10.3. Step 6.10.3 covers this position.

1.4.1.1.3 Captured in 6.10.4, deleted Step 6.10.4 covers this position, substeps.

1.4.1.2 Captured in stop 6.11.2. Step 6.11.2 covers this position.

1.4.1.2.1 Captured in step 6.11.3. Step 6.11.3 covers this position.

1.4.1.2.2 Captured in step 6.11.4. Step 6.11.4 covers this position.

1.4.1.2.3 Captured in step b.11.5. Step 6.11.5 covers this position.

1 4.1.2.4 Captured in step 6.11.6. Step 6.11.6 covers this position.

1.4.1.2.5 Captured in step 6.11.7. Step b.11.7 covers this position.

1.4.1.3 Paragraph I captured in step Step 6.12.1 covers this position.

6.12.1.

Paragraph 2 captured in step Step b.12.2 covers tais position.

6.12.2.

Paragraph 3 captured in step Step 6.12.5 covers this position.

6.12.5.

1.4.1.3.1 Captured in step 6.12.3. Step 6.12.3 covers this position.

1.4.1.3.2 Captured in step 6.12.4. Step 6.12.4 covers this position.

1.4.2.1 Captured in step 6.10.5-2. Step 6.10.5-2 covers this position.

CHANGE SUt*4ARY FOR RERP CHANGE TO Page 6 of 15 AP 06-002, "RADIOLOGZCAL EMERGENCY RESPONSE PLAN" Step Description Reason for Change 1.4.2.2 Captured in step 6.10.5-3. Step 6.10. 5-3 covers t his position.

1.4.2.3 Captured in step 6.10.5-7. Step 6.10.5-7 covera this position.

1.4.2.4 Captured in step 6.10.5-6. Step 6.10.5-b covers this position.

1.4.3.1 Paragraph I captured in step Step 6.13.1 covers this position.

6.13.1.

Paragraph 2 deleted. Step '.b.2-2 covers this subject.

Paragraph 3 captured in step b.8.2- Step 6.8.2-2 covers this position.

2.

1.4.3.2 Captured in step b.13.2. Step 6.13.2 covers this position. >

1.4.3.3 Captured in step 6.13.3. Step 6.13.3 : overs this position.

1.4.3.4 Captured in step 6.13.4. Step 6.13.4 covers this position.

Table 1.1-1 Captured in Attachment D Table change to an Attachment in the AP.

Table 1.2-1 Deleted kesponsibilities are covered in the steps for each position.

Table 1.2-2 Deleted Besponsibilities are covered in the steps for each position.

Table 1.2-3 Deleted kesponsibilities are covered in the steps for each position.

Table 1.4-1 Captured in Attachment H Table change to an Attachment in j the AP.

l Figure 1 1-2 Captured in Figure 2 Table change to a Figure in the AP.

Figure 1.2-2 Captured in Figure 3 Table change to a Figure in the AP.

Figure 1,2-4 Captured in Figure 4 Table change to a Figure in the AP.

Figure 1.2-5 Captured in Figure 5 Table change to a Figure in the AP.

Figure 1.3-2 Captured in Figure 6 Table change to a Figure in the AP.

Section 2.0, Captured in steps 6,2.2 & 6.2.3. Steps cover the subject. Extra step 2.1 wording deleted as an editorial enhancement to make the section/ step easier to read and understand.

2.2 Paragraph I captured in step 6.2.4. Step 6.2.4 covers the subject. The Substeps and rest deleted, substeps were deleted as an editorial enhancement to make the section/ step easier to read and understand.

2.2.1 Title and paragraph I captured in This step was moved to the step 4.23 & 4.23.1. definition section. The Explanations / Bases for the EALs Paragraph 2 deleted, contain the reasons and methods for declaring an emergency, so the last paragraph was deleted.

2.2.2 Title and paragraph I captured in This step was moved to the step 4.3 & 4.3.1. definition section. The Explanations / Bases for the EALs Paragraph 2 deleted, contain the reasons and methods for declaring an emergency, so the last paragraph was deleted.

2.2.3 Title and paragraph I captured in This step was moved to the step 4.31 & 4.31.1. definition section. The Explanations / Bases for the EALs Paragraph 2 deleted. contain the reasons and methods for ueclaring an emergency, so the last paragraph was deleted.

2.2.4 Title and paragraph 1 captured in This step was moved to the step 4.18 & 4.10.1. definition section. The Explanations / Bases for the EALs Paragraph 2 deleted. contain the reasons and methods for declaring an emergency, so the last paragraph was deleted.

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CHANGE SUtt4ARY FOR RERP CHANGE TO Page 7 of 15 AP 06-002, " RADIOLOGICAL EMERGENCY RESPONSE PIAN" Step Description Reason for Change 2.3 Captured in step 2.6. Stop 2.6 covers the subject. Made minor changes to wording for better readability.

2.4.1 Captured in step 6.2.1. Step 6.2.1 covers the subject.

Made minor changes to wording for better readability.

2.4.2 Deleted. Discussion of the Symptom, Event And Barrier Based Event ..

Classification is covered in NUMARC/NESP 007 and is not needed in the plan.

2.4.3 Deleted. Deleted due to being a Summary of the section which does not fit the Writer's Guide format.

Table 2.2-1 Captured in Attachment F. Table was changed to an Attachment.

Table 2.2-2 Captured in APF 06-002-01 Table was placed in a torm covered EMERGENCY ACTION LEVELS by the new AP.

Section 3.0 Paragraph I captured in step 6.3.1. Subject covered in indicated step with wording changed for better readability.

Paragraph 2 captured in steps b.3.2

& 6.3.3-1.

3.1.1 Deleted. Deleted as an editorial enhancement to make the section/ step easier to read and understand.

3.1.2 Paragraph 1, major points captured Subject covered in indicated step in step 6.3.6. with wording changed for better readability.

I Paragraph 2 captured in step 6.3.7.

f Paragraph 3 captured in step 6.3.5.

Paragraph 4 captured in step NPIS covered by step 6.14.

6.14.1-4.

Paragraph 5 captured in step b.3.b. Subject covered in indicated step with wording Paragraph 6 captured in step 6.3.7 changed for better rescability.

Paragraph 7 captured in step d.3.1, 3.1.3 Paragraph I captured in steps 6.3.7 Subject covered in Indicated steps

& 6.14.1. with wording changed for better teadability.

Paragraph 2 captured in step 6.3.7.

Paragraph 3 captured in step 6.14.2.

Paragraph 4 captured in steps 6.1.7, 6.3.11, & 6.3.21.

Paragraph 5 covered in step 6.3.8.

3.1.4 Paragraph I captured in step Subject covered in indicated step 6.3.19. with wording changed for better readability.

Paragraph 2 captured in step 6.3.19.

3.2 Captured in section 2.0. Subject covered in section 2.0 with wording changed for better readability.

3.3 Captured in step 6.3.1. Subject covered in step b.3.1 with wording changed for better readability.

3.3.1 Captured in step 6.3.1, b.3.10 & Subject covered in steps indicated 6.3.11, with wording changed for better readability.

= .

1 CRANGE SUt44ARY FOR REkP CHANGE TO Page 8 of 15 AP 06-002, " RADIOLOGICAL EMERCENCY RESPONSE PLAN" Step Description Reason for Change 3.3.1.1 Captured in step 6.3.9, 6.3.10 & Sub3ect covered in steps indicated 6.3.11 with wording changed for better readability.

3.3.1.2 Captured in steps 6.3.12 & 6.3.13. Subject covered in steps indicated with wording changed for better readability.

3.3.1.3 Captured in steps t.3.14, 6.3.15, subject covered in steps indicated 6.3.16, 6.3.17, 6.3.10, & 6.3.19. with wording changed for better readability.

3.3.1.4 Captured in steps 6.3.20, b.3.21, Subject covered in steps indicated 6.3.22, & 6.6.10. with wording changed for better readability.

3.3.1.5 Captured in step b.4.6. Subject covered in step indicated with wording changed for better readability.

3.3.1.$.1 Captured in step 6.4.6. Subject covered in step indicated with wording changed for better readability.

3.3.1.5.2 Captured in step 6.4.6-4 6 6.4.6-b. Subject covered in steps indicated with wording changed for better readability.

3.3.1.5.3 Captured in step 6.10.6. Subject covered in step indicated with wording changed for better readability.

3.3.1.5.4 Captured in step b.10.5. Subject covered in step indicated with wording changed for better readability. Deleted non-essential wording as an editorial enhancement to make the section/ step easier to read and understand to make the section/ step easier to ree- nd understand.

3.3.2 Captured in steps d.3.3 & 6.16.2-4. Subject covered in steps indicated with wording changed for tatter readability. Deleted non-essential wording as an editorial enhancement to make the section/ step easier to read and understand to make the section/ step easier to read and understand.

Table 3.0-1 Captured in Attachment E, page 1 Table changed to an Attachn ent.

Table 3.0-2 Captured in Attachment E, page 2 Table changed to an Attachment.

Table 3.0-3 Captured in Attachment E, page 2 Table changed to an Attachment.

Table 3.0-4 Captured in Attachment E, page 3 Table changed to an Attachment.

Table 3.0-5 Captured in Attachment E, pace 4 Table changed to an Attachment.

Secti'n 4.0, Deleted. These items are covered in steps step 4.1.1 6.4.

4.1.1.1 Captured in step 6.4.1. Covered by step 6.4.

4.1.1.2 Captured in steps 6.4.2, 6.4.3, Items covered by indicated steps 6.6.1, 6.6.3, & 6.16. with wording changed for better readability.

4.1.1.3 Captured in steps b.4.4, b.4.5, items covered by indicated steps 6.8.1, 6.8.2, & 6.16, with wording changed for better readability.

4.1.2 Deleted. Items covered by other steps under facilities.

4.1.2.1 Captured in step b.4.5-1. Item covered by indicated step with wording changed for better readability.

CHANGE SUt+1ARY FOR RERP CHANGE TO page 9 of 15 AP 06-003, " RADIOLOGICAL EMERGENCY RESPONSE PIAN" Step Description Reason for Change 4.1.2.2 Captured in step t.4.5-3. Item covered by indicated step with wording changed for better readability.

4.1.2.3 Captured in step 6.4.5-4. Item covered by indicated step with wording changed for better readability.

4.1.3.1 Captured in step 6.4.7. Item covered by indicated step with wording changed for better readability.

4.1.3.2 Captured in step 6.4.7 Item covered by indicated step with wording changed for better readability.

4.2 Captured in step b.Jb. Items covered by Indicated steps with wording changed for better 4.2.1.1 Captured in step 6.16.1. readability. Deleted non- essential wording as an editorial enhancement 4.2.1.2 D( le t e d . to make the section/ step easier to read and understand. Exact number 4.2.1.3 Captured in step b.16.2. of PBX circuits is not necessary information.

4.2.1.3.2 Captured in step 6.16.1.

l 4.2.1.3.3 Captured in step 6.16.1. Covered by step 6.16.1.

4.2.1.3.4 Captured in step 6.16.1. Covered by step 6.16.1.

4.2.2 1st paragraph deleted. Figure was deleted from earlier revision.

2nd paragraph captured in etep Covered by step 4.19, 4.19.

4.2.J Deleted. Does not meet writer's guide format.

4.3 Captured in step b.4.1. Item covered by indicated step with wording changed for better readability.

4.3.1 Paragraph I captured in step Items covered by indicated steps 6.14.1. with wording changed for better readability.

Paragraph 2 captured in step 6.14.1.

Paragraph 3 captured in step 6.14.1-4.

Paragraph 4 captured in step 6.14.1-5.

Paragraph 5 captured in step 6.14.1-4.

4.3.2.1 Deleted. Subject covered by step 2.6.

4.3.2.1.1 Captured in step 6.14.2. Item covered by indicated step with wording changed for better readability.

4.3.2.1.2 Captured in step b.14.2. Item covered by indicated step with wording changed for better readability.

4,3.2.1.3 Captured in steps 6.14.2-3 & 6.3.6. Item covered by indicated step with" wording changed for better readability.

4.3.2.1.4 Captured in step 6.3.7. Item covered by indicated step with wording changed for better readability.

CHANGE SUH RRY FOR RERP CHANGE TO Page 10 of 15 AP 06-002, " RADIOLOGICAL EMERGENCY RESPONSE PLAN" Stop Description Reasota for Change 4.3.2.2 Paragraph I captured in step 6.0.3. Item covered by and2cated step with wording changed for better Paragraph 2 changed due to change readability.

in notAfication time of TSC.

Covered in step 6.6.11.

Paragraph 3 major elements covered in steps 6.3.6. 6.3.7, & 6.3.8.

Paragraph 4 captured in step 6.3.9.

4.3.3.1 Paragraph I captured in step Items covered by indicated steps 6.14.3-1. with wording changed for better readability.

Paragraph 2 captured in step 6.14.3-2.

Paragraph 3 captured in step 6.14.3-3.

Paragraph 4 captured in step 6.14.3-4.

Paragraph $ captured in step 6.14.3-5.

4.3.3.2 Paragraph I covered in step 2.6. Items covered by indicated step with wording changed for better Paragraph 2 covered in step 2.6. readability. Deleted non-Paragraph 3 covered in step 2.6. essential wording as an editorial enhancement to make the section/

Paragraph 4 captured in step step easier to read and understand.

6.14.4.

Paragraph S covered in step 2.6.

Paragrapn 6 covered in step 2.6.

4.3.3.3 Captured in step 6.14.5. Item covered by indicated step with wording changed for better readability.

4.3.4 Paragraph I captured in step Items covered by indicated step 6.14.6-1. with wording changed for better readability. Deleted non-Paragraph 2 covered in step 2.b. essential an wording as editorial enhancement to make the section/

Paragraph 3 covered in step 2.t. Step easier to read and understand.

Paragraph 4 captured in step 6.14.6-2.

4.3.5 Paragraph I captured in step Items covered by indicated step 6.14.7-1. with wording changed for better readability. Deleted non-Paragraph 2 covered in step 2.b. essential wording as an editorial enhancement to make the section/

Paragraph 3 covered in step 2.6. step easier to read and understand.

Paragraph 4 covered in step 2.6.

Paragraph $ captured in step 6.14.7-2.

Paragraph 6 captured in step 6.14.7-3.

4.3.6 Paragraph 1 captured in step 6.4.b- Items covered by indicated steps 1, 6.4.6-2, & 6.4.6-3. with wording changed for better readability.

Paragraph 2 captured in step 6.4.6-4.

CHANGE

SUMMARY

FOR RERP CHANGE TO Page 11 of 15 AP 06-003, " RADIOLOGICAL EMERGENCY RESPONSE PLAN"

, Step Description Reason for Change 4.3.7 Paragraph I captured in step Items covered by indicated steps 6.15.1. with wording changed for better readability.

Paragraph 2 captured in step 6.15.2.

Paragraph 3 captured in step 6.15.3.

Table 4.1-1 Deleted. Facilities are discussed in Section 6.4.

Table 4.2-2 Deleted. Person in command in each facility is discussed in Organization Sections.

Table 4.3-1 Deleted. Deleted non-essential wording as an 3.

editorial enhancement to make the section/ step easier to read and understand. Inventory is controlled in EPPs.

Figure 4.1-1 Captured in Figure 1 & 7. Figures placed in new AP as Figures 14 7 Figure 4.1-2 Captured in Figure 7 Figures placed in new AP as Figure 7

Figure 4.1-3 Captured in Figure B. Figures placed in new AP as Figure B

Figure 4.1-4 Captured in Figure 9. Figures placed in new AP as Figure 9.

Figure 4.1-b Deleted. kesponse facilities are discussed in Section 6.4 and the o.d figure does not show a good location for these facilities.

Section b.0, Paragraph 1 captured in step Items covered by indicated steps step 5.1 6.17.1. with wording changed for better readability.

] Paragraph 2 captured in step 6.17.2.

Paragraph 3 captured in step 6.17.6.

Paragraph 4 captured in step 6.17.3.

Paragraph 5 captuted in step 6.17.4

& 6.17.5.

Paragraph b captured in step 6.17.4.

Paragraph 7 captured in step 6.17.2.

5.2 Paragraph I capturea in step Items covered by indicated step 6.19.1. with wording changed for better readability. Deleted non-Paragraph 2 deleted, essential wording as an editorial enhancement to make the section/ step easier to read and Paragraph 3 deleted. understand.

Paragraph 4 captured in step 5 6.19.3.

Paragraph 5 captured in step 6.19.3.

Paragraph 6 captured in step 6.17.6.

CHANGE SUt44ARY FOR RERP CHANGE TO Page 12 of 15 AP 06-002, " RADIOLOGICAL EMERGENCY RESPONSE PLAN" Step Description Reason for Change 5.2.1.1 Captured in step b.18.1. Items covered by indicated steps with wording changed for better readability.

b.2.1.2 Captured in step 6.18.1. Items covered by indicated steps with wording changed for better readability.

5.2.1.3 Captured in step 6.18.1. Items covered by indicated steps with wording changed for better readability.

5.2.1.4 Deleted. Deleted as an editorial enhancement to make the section/ step easier to read and understand.

5.2.2 Captured in step b.18.4. Items covered by indicated steps with wording changed for better readability.

5.2.3 Captured in step b.18.3. Items covered by indicated steps with wording chanced for better readability.

5.2.4 Captured in step 6.18.4 & b.18.5. Item covered by indicated steps with wording changed for better

__ readability.

5.2.5 Captured in step 6.18.b. Items covereo by indicated steps with wording changed for better readability.

5.2.6 Captured in step 6.19.5. Item covered by indicated step with wording changed for better readability.

5.2.7 Captured in step 6.19.4. Item covered.by indicated step with wording changed for better

! readability.

5.3 Paragraph 1 captured in step Items covered by indicated step 6.20.1. with wording changed for better readability. Deleted non-Paragraph 2 captured in step essential wording as an editorial 6.20.2. enhancement to make the section/ step easier to read and Paragraph 3 deleted. understand 5.4.1 Paragraph I captured in step Items covered by indicated steps 6.16.2-2. with wording changed for better readability.

Paragraph 2 captured in step 6.16.2-3.

b.4.2 Paragraph I captured in step Items covered by indicated steps 6.16.2-5. with wording changed for better readability.

Paragraph 2 captured in step 6.16.2-6.

Paragrapn 3 captured in step 6.16.2-4.

Paragraph 4 captured in step b.3.4.

5.4.3 Captured in step b.16.2-1. Item covered by indicated step with wording changed for better readability.

Table 5.4-1 Deleted. Information covered by the State and County Plans.

6.1 Captured in step 4.30. Step 4.30 is in the definition section.

6.2 Paragraph 1 captured in steps Items covered by indicated steps 6.21.1, 6.21.2, & 6.21.3. with wording changed for better readability.

Paragraph 2 captured in step 6.21.3-3.

Paragraph 3 captured in steps 6.21.5 & 6.21.4.

CHANGE SUl*RRY FOR RERP CHANGE TO Page 13 of 15 AP 06-002, "RADIOLOG3 CAL EMERGENCY RESPONSE PLAN" Step Description Raasan for Change 6.3 Captured in stop 6.21.1. Item covered by indicated step with wording changed for better readability.

6.3.1 Captured in step 6.8.2 & 6.21. Item covered by indicated step with wording changed for better

__ readability.

6.3.2 Captured in step 6.b.5 & 6.21. Item covered by indicated step with wording changed for better readability.

6.3.3 Captured in step 6.6.7 6 6.21. Item covered by indicated step with wording changed for better 4 readability.

, 6.3.4 Captured in step 6.8.3 & b.21. Item covered by indicated step with wording changed for better readability.

6.3.5 Captured in step 6.9.1 & b.21, item covered by indicated step with wording changed for better readability.

6.3.6 Captured in step b.U 11 & 6.21. Item covered by indicated step with wording changed for better 4 readability.

6.3.7 Captured in step b.13.1 & 6.21. Item covered by indicated step with wording changed for better readability.

6.3.8 Captured in step 6.13.2 & 6.21. Item covered by indicated step with wording changed for better readability.

6.4 Captured in step 6.4.4. Item covered by indicated step with wording changed for better readability.

6.4.1 Captured in step b.4.2 Item covered by indicated step with wording changed for better readability.

Figure 6.3-1 Deleted. Organization is determined by the DED or DEM for the emergency in progress.

Supplement Captured in section 4.0. The new AP has a definitions AA section. Deleted unnecessary definitions and added new ones.

Supplement Captured in Attachment C. Supplement changed to an BB Attachment.

Supplement Captured in Attachment G. Supplement changed to an CC Attachment.

Supplement Deleted. Deleted as an editorial enhancement DD, 1.1 to make the section/ step easier to read and understand.

1.2 Captured in step b.1.2. Item covered by indicsted step with wording changed for better readability.

1.3 Paragraph 1 captured in steps 6.1.3 Items covered by indicated steps

& 6.1.6. with wording changed for better readability.

Paragraph 2 captured in step b.1.b.

1.4 Paragraph I captured in step 6.1.7. Items covered by indicated steps with wording changed for better Paragraph 2 captured in Figure 1. readability.

2.0 Captured in steps 6.1.7 & 6.3.3-1. Itema covered by indicated steps with wording changed for better 3.0 Captured in step 6.3.3-1. readability and is covered by the 4.0 Captured in step 6.3.3-1. County Plan.

CHANGE SthMARY FOR RERP CHANGE TO Page 14 of 15 AP 06-002, *RADIOLOG2 CAL EMERGENCY RESPONSE PLAN" Step Description Reason for Cnar.ge Table DD-1 Captured in Attachment b, page 1. Tables changed to Attachm3nts.

Some tables were deleted as an editorial enhancement to make the Table DD-2 Deleted, section/ step easier to read and Table DD-3 Captured in Attachment B, page 2. understand since the items ate Table DD-4 Deleted, covered in the County Plan.

Table DD-5 Deleted.

Table DD-6 Captured in Attachment B, pages 3

&4.

Table DD-7 Captured in Attachment B, page 5.

Figure DD-1 Captured in Figure 1 Figures placed in new AP as indicated due to requirement in Writer's Guide.

Figure DD-3 Captured in Figure 1 Figures placed in new AP as indicated due to requirement in Writer's Guide.

Supplement Dcleted. Deleted as an editorial enhancement EE, to make the sectionistep easier to step 1.1 read and understand.

1.2 Captured in step 6.1.2. Item covered by indicated step with wording changed for better readability.

1.3 Captured in step b.1. Item covered by indicated step with wording changed for better readability.

J.4 Captured in step 6.1. Item covered by indicated step with wording changed for be*ter readability.

1.5 Captured in step 6.1. Item covered by indicated step with wording changed for better readability.

1.6 Captured in step 6.1.8. Item covered by indicated step with wording changed for better readability.

1.7 Captured in step 6.1.6. Item covered by indicated step with wording changed for better readability.

2.0 Captured in step 6.12.2. Item covered by 10dicated step with wording changed for better readability.

2.1 Captured in step 6.12.2. Item covered by indicated step with wording changed for better readability.

2.2 Captured in step b.1 & Figure 10. Item covered by indicated step and Figure with wording changed for better readability.

2.3 Captured in step e.l. Items covered by indicated steps with wording changed for better readability.

3.0 Captured in step 6.1. Items covered by indicated steps with wording changed for better readability.

4.0 Captured in step b.10.3. Items covered by indicated steps with wording changed for better readability.

4.1 Deleted. Deleted t.s an editorial enhancement to make the section/ step easier to read and understand.

4.2 Captured in step 6.10.3. Items covered by indicated steps with wording changed for better readability.

5.0 Deleted. Deleted as an editorial enhancement to make the section/ step easier to read and understand.

CRANGE StM4ARY FOR RERP CHANGE TO Page 15 of 15 AP 06-003, " RADIOLOGICAL EMERGENCY RESPONSE PLAN" Step Description Reason for Change Figure EE-1 Captured in Figure 1. Figures placed in new AP as indicated due to requirement in Writer's Guide.

Figure EE-2 Captured in Figure 10. Figures placed in new AP as indicated due to requirement in Writer's Guide.

Supplement Captured in Attachment C. Supplement changed to an FF Attachment.

Supplement Captured in Attachment C. Supplement changed to an CG Attachment.

Supplement Deleted. Supplement contained no information HH of use.

s

ENCLOSURE 4 TO WCNOC LETTER WO 97-0058 PROPOSED RADIOLOGICAL EMERGENCY RESPONSE PLAN

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i ENCLOSURE 4 TO WCNOC LETTER WO 97-0058 PROPOSED RADIOLOGICAL EMERGENCY RESPONSE PLAN

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