Text

Supplement to License Amendment Request (TSCR-182): Proposed Changes to the Emergency Plan for Permanently Defueled Condition
	ML20055D151
Person / Time
Site:	Duane Arnold
Issue date:	02/21/2020
From:	Dean Curtland; Nextera Energy
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NG-20-0011
	Download: ML20055D151 (256)
	v • d • e

{{#Wiki_filter:NEXTeraM ENERGY~ DUANE ARNOLD February 21 , 2020 NG-20-0011 10 CFR 50.90 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Duane Arnold Energy Center Docket No. 50-331 Renewed Op. License No. DPR-49

Subject:

Supplement to License Amendment Request (TSCR-182): Proposed Changes to the Emergency Plan for Permanently Defueled Condition References :

1. License Amendment Request (TSCR-182): Proposed Changes to the Emergency Plan for Permanently Defueled Condition, dated April 9, 2019 (ML19101A280)

2. FINAL - RAI Related to License Amendment Request (TSCR-182) for Proposed Changes to the Emergency Plan for Permanently Defueled Conditions at Duane Arnold Energy Center (DAEC) - L-2019-LLA-0075, dated October 4, 2019 (ML19280A035)

3. Response to Request for Additional Information Relating to Proposed Changes to the Emergency Plan for Permanently Defueled Condition, dated October 28, 2019(ML19301A529)

4. Supplement to Response to Request for Additional Information Relating to Proposed Changes to the Emergency Plan for Permanently Defueled Condition, dated December 9, 2019 (ML19343A225)

5. Revision to Duane Arnold Energy Center (DAEC) Emergency Plan Section B, dated May 16, 2019(ML19136A023)

6. Revision to Duane Arnold Energy Center (DAEC) Emergency Plan Section B and Appendix 6, dated June 4, 2019 (ML19155A112)

7. Revision to Duane Arnold Energy Center (DAEC) Emergency Plan Sections B, D & G, dated June 25, 2019(ML19178A134)

8. Revision to Duane Arnold Energy Center (DAEC) Emergency Plan Sections A, B, E, F, H, I and M, dated November 12, 2019(ML19316A331)

NextEra Energy Duane Arnold, LLC , 3277 DAEC Road, Palo, IA 52324

NG-20-0011 Page 2 of 2 NextEra Energy Duane Arnold, LLC (NEDA) submitted a License Amendment Request for the Duane Arnold Energy Center (DAEC) pursuant to 10 CFR 50.90 (Reference 1). Subsequently, the NRG Staff requested additional information regarding that application (Reference 2) and NEDA provided responses to the requested information (References 3 and 4). The RAI responses did not impact Attachments 2 and 3 of the License Amendment Request. The DAEC Emergency Plan has been revised since Reference 1 was submitted, as documented in References 5-8. Attachment 1 to this letter summarizes the post-submittal revisions and the correction of typographical errors. Attachments 2 and 3 to this letter incorporate the changes requested in Reference 1 into the current revisions of the applicable Emergency Plan Sections. Attachments 2 and 3 to this letter will supersede, in their entirety, the original Attachments 2 and 3 submitted with Reference 1 . The changes do not impact the Technical Evaluation or the 10 CFR 50.92 evaluation of "No Significant Hazards Consideration" previously provided in Reference 1. In accordance with 10 CFR 50.91, a copy of this letter is being forwarded to the State of Iowa designee. This letter contains no new commitments. If you have any questions regarding this matter, please contact Mike Davis, Licensing Manager at (319) 851-7032. 9:dz;270 I declare under penalty of perjury that the foregoing is true and correct. Dean Curtland Site Director, Duane Arnold Energy Center NextEra Energy Duane Arnold, LLC Attachments:

1. Summary of Changes

2. Marked-Up Copy Pages of Emergency Plan

3. Clean Copy Pages of Emergency Plan cc: Regional Administrator, USNRC, Region Ill Resident Inspector, USN RC, Duane Arnold Energy Center Project Manager, USNRC, Duane Arnold Energy Center State of Iowa

ATTACHMENT 1 NEXTERA ENERGY DUANE ARNOLD, LLC DUANE ARNOLD ENERGY CENTER NG-20-0011 SUPPLEMENT TO LICENSE AMENDMENT REQUEST (TSCR-182)

SUMMARY

OF CHANGES 2 pages follow

NG-20-0011 DAEC E-Plan Changes processed in accordance with 10 CFR 50.54(q) after TSCR-Section 182 was submitted and correction of typographical errors Section A Revision 26 eliminates the Radiological & EOF Manager Position and transfers the position tasks and responsibilities to the EOF Operations Liaison and the Radiological Assessment Coordinator. Previously, there was an overlap of tasks between the Radiological & EOF Manager and the Radiological Assessment Coordinator. Section B Revision 41 implemented a reorganization of the EOF and JIC. Due to the co-location of the EOF and JIC, the EOF and JIC will share Logistics, IT/AV, Administrative and Medical Support Services; the EOF Rad Data Plotter, JIC Technical Liaison, Logistics Coordinator, Logistics Support, PIO Support, AV Support and JIC Security Guards have been eliminated; the Spokesperson and JIC Manager coordinate with, and receive support from, Corporate Communications. Revision 42 eliminated the TSC Clerical and Rad Support Staff positions. Revision 43 implemented a new Joint Information System, which is a collaboration between the Site JIC and Corporate Communications; This initiative adds a Corporate JIC Manager and a Field Emergency Communications Team in the Site JIC, supported by a larger Emergency Communications Team based at Corporate Communications in Florida. It also eliminated the News Media Rumor Control position and one of two Assistant JIC Manager positions. FEMA Region 7 was briefed on this change in advance and feedback was incorporated. Revision 44 eliminates the Radiological & EOF Manager Position and transfers the position tasks and responsibilities to the EOF Operations Liaison and the Radiological Assessment Coordinator. Typographical error correction: The original LAR submittal had a typographical error in Table B-1. The EOF Ops Liaison was inadvertently shown as a 90-minute responder. It will remain a 60-minute responder. Since this is not a change, it is not shown in red. Section D Revision 29 upgraded the Emergency Action Level Scheme from NEI 99-01 Rev. 5 to Rev. 6, as approved by NRC Amendment 308 dated November 30, 2018. Section E Revision 26 eliminates the Radiological & EOF Manager Position and transfers the position tasks and responsibilities to the Radiological Assessment Coordinator. Previously, there was an overlap of tasks between the Radiological & EOF Manager and the Radiological Assessment Coordinator. Section F Revision 30 eliminates the Radiological & EOF Manager Position and transfers the position tasks and responsibilities to the Radiological Assessment Coordinator. Previously, there was an overlap of tasks between the Radiological & EOF Manager and the Radiological Assessment Coordinator.

NG-20-0011 Typographical error correction: The original LAR submittal had a typographical error in Table F-1. The Primary Responder for 1.d. should be the Operations Shift Manager only. This correction is shown in red in Attachment 2. Section H Revision 38 eliminates the Rad Support Staff position, as this position was underutilized. Section J No changes. Section K No changes.

ATTACHMENT 2 NEXTERA ENERGY DUANE ARNOLD, LLC DUANE ARNOLD ENERGY CENTER NG-20-0011 SUPPLEMENT TO LICENSE AMENDMENT REQUEST (TSCR-182) MARKED-UP COPY PAGES OF EMERGENCY PLAN 127 pages follow

DAECEMERGENCYPLAN SECTION 'A' ASSIGNMENT OF RESPONSIBILiTIES Rev. 2&-27 (ORGANIZATIONAL CONTROL) Page 1 of 13 Usage Level: INFORMATION Record the following: Date I Time: _ _ _ _ _ I _ _ _ _ Initials: _ __ NOTE: User shall perform and document a Temp Issue I Rev. Check to ensure revision is current, in accordance with procedure use and adherence requirements. Prepared By:

              -------~

I ----------~ Date: - - - - Print Signature APPROVAL BY EMERGENCY PREPAREDNESS MANAGER Approved By I Date: ----1 Print Signature APPROVAL BY ORG Approved By I Date:

                                                                                       -----t Print                         Signature APPROVAL BY DAEC SITE DIRECTOR Approved By                                 I Date:
                                                                                       - -- - - f Print                         Signature

DAECEMERG ENCYPLAN SECTION 'A' ASSIGNM ENT OF RESPONSIBILITI ES Rev. 2-6--27 (ORGANIZATIONAL CONTROL) Page 2of13 Table of Contents 1.0 PURPOSE .. ....... ..... ... .............. ... .. ...... ..... .... .. ......... ............ ...... ....... .... ....... ...... ............. ...... 3 2.0 REQUIREMENTS ........... ............ ...... ... ..... ..... .... ............. ..................................................... 3 2.1 RESPONSE ORGANIZATIONS AND RESPONSIBILITIES ... ... ...... .. ..... ...... .......... 3 2.2 CONCEPT OF OPERATIONS .... .... .... ........ ........ ........ ....... ..... .... .... ....... .. ..... ....... .. 4 2.3 RESPONSE ORGANIZATIONS INTERRELATIONSHIPS ... ...... .. ....... ..... ... ..... .. .... 5 2.4 ORGANIZATIONAL RESPONSIBILITY ... ..... .. ...... ..... ...... ..... ... ....... ........ ... ... ........ . 8 2.5 DIRECTION AND COORDINATION .... ...... ... .... ............. .... ......................... .. ... ... ... 8 2.6 EMERGENCY RESPONSE FUNCTIONS ... .... .. .... ................ ........ ............ .... ......... 9 2.7 AUTHORITY AND AGREEMENTS ... ..... ...... ... ............................... .... ... ... ... ....... .. 11 2.8 EXTENDED OPERATION .. .. ... .. ... ... ... ... ... ... ... .... ..... .... ..... ..... ..... .. ...... .. .... ....... ..... 11 TABLE A-1 EMERGENCY RESPONSE FUNCTION AND RESPONSIBILITIES .... .. .. ... ..... .. .. .. 12 FIGURE A-1 INTERRELATIONSHIPS BETWEEN EMERGENCY ORGANIZATIONS ... ..... ..... 13

DAECEMERGENCYPLAN SECTION 'A' ASSIGNMENT OF RESPONSIBILITIES Rev. 2&-27 (ORGANIZATIONAL CONTROL) Page 3 of 13 1.0 PURPOSE (1) This section describes the responsibilities of Duane Arnold as the principal response organizations for radiological events that may occur at the Duane Arnold Energy Center (DAEC). 2.0 REQUIREMENTS 2.1 RESPONSE ORGANIZATIONS AND RESPONSIBILITIES (1) The DAEC Emergency Response Organization (ERO) provides immediate response to an emergency condition at the DAEC and promptly informs local, state, and federal officials of the situation and potential ramifications . Provisions have been made to augment the overall organization with additional personnel who possess unique technical capabilities, as well as industry and governmental agency support groups which can provide assistance in engineering and radiological dose assessment activities. (2) The resources available from within Duane Arnold, coupled with those available from other utilities and industry service and support firms, will be sufficient to enable continuous response over the long term . These resources ensure a 24-hour per day operations capability for an extended period. (3) Local and State Agencies (a) County and state Radiological Emergency Response Plans, compatible with the DAEC Emergency Plan, have been developed to guide the emergency response actions of the officials and agencies of Linn County, Benton County, and the State of Iowa. These plans reflect the assignment of responsibilities for offsite protective actions and the methods of communicating among the involved local and state agencies. Offsite protective actions within the plume exposure pathway Emergency Planning Zone (EPZ) are implemented by Linn and Benton Counties.

DAEC EMERGENCY PLAN SECTION 'A' ASSIGNMENT OF RESPONSIBILITIES Rev. ~27 (ORGANIZATIONAL CONTROL) Page 4of13 2.2 CONCEPT OF OPERATIONS (1) The emergency classification system and levels of activation are discussed in Section 'D'. Section 'E' discusses notification methods and procedures. This section and the remainder of the plan discuss the specific responsibilities and interrelationships of the emergency response organizations. The following summarizes the order of actions. (a) NOTIFICATION OF UNUSUAL EVENT (i) Upon occurrence of an event that is classified as a NOTIFICATION OF UNUSUAL EVENT, the Operations Shift Manager/Supervisor will direct prompt corrective action to ensure the plant is placed in or maintained in a stable condition. Key Duane Arnold officials as well as individuals from the NRC, local and state emergency response organizations will be notified . Support agencies such as the local fire departments, hospitals, etc., will be alerted as indicated in county emergency response plans. Should the event be of such a nature that escalation to a higher emergency action level is probable, local and state officials and agencies will be notified to stand by for full activation. (b) ALERT, SITE AREA EMERGENCY, or GENERAL EMERGENCY (i) Upon occurrence of an event classified as an ALERT, SITE AREA EMERGENCY, or GENERAL EMERGENCY, the Operations Shift Manager/Supervisor will direct prompt corrective action to return the plant to a stable condition and to stop or mitigate radiological releases, if they are occurring. Key Duane Arnold officials as well as individuals from local and state emergency response organizations will be notified of the event and nature of the emergency, including its classification. (ii) Communications will be established and maintained with these local and state agencies as described in Sections B and F to assure the flow of information necessary to assess the situation and protect the population at risk. Assessment actions will be implemented based upon the type of event and plant status to determine the potential consequences to the population at risk. The results of the assessment will be reported to local and state officials and will form the basis for decisions associated with the proper course of protective action.

DAECEMERGENCYPLAN SECTION 'A' ASSIGNMENT OF RESPONSIBILITIES Rev. 2e-27 (ORGANIZATIONAL CONTROL) Page 5 of 13 2.3 RESPONSE ORGANIZATIONS INTERRELATIONSHIPS (1) The interrelationships between Duane Arnold, contractors and consultants, and local, state, and federal agencies are illustrated in Figure A-1 and are described below. (a) DAEC (i) Duane Arnold's relationship to the total effort includes the following: (a) Assessing the scope of the abnormal condition and determining the extent to which the situation is under control. (b) Ensuring that requisite safety-related systems and features are functioning properly, and implementing response actions that may be required to assist in regaining control of the situation. (c) Analyzing the potential or actual radiological impact within the plume exposure Emergency Planning Zone (EPZ) to determine the appropriate actions necessary to protect the populace within this EPZ. (d) Notifying appropriate local, state, and federal officials. (e) Defining the accident recovery functions to be performed by the Emergency Response Organization including providing assistance to the DAEC. (f) Assessing the existing corporate resources available and evaluating how best to apply these resources to the tasks previously defined. (g) Evaluation of the Emergency Response Organization and assignment of responsibilities based on this evaluation. (b) Linn and Benton Counties (i) The Linn and Benton County Emergency Operations Centers will coordinate their respective County's response, and will accept response requests for the DAEC. (c) Mercy Medical Center, University of Iowa Hospitals and Clinics, and Ambulance Services (i) Duane Arnold has made arrangements with Mercy Medical Center in Cedar Rapids, Center Point, Hiawatha, and Area Ambulance for ambulance service for the DAEC. Linn County Sheriff's Rescue will also provide medical assistance for the DAEC as needed. Both radiological and non-radiological injuries will normally be treated by medical personnel at Mercy Medical Center under the overall supervision of the DAEC Medical Consultant. As a backup, University of Iowa Hospitals and Clinics are available.

DAECEMERGENCYPLAN SECTION 'A' Rev. 26--27 ASSIGNMENT OF RESPONSIBILITIES

          .(ORGANIZATIONAL CONTROL)                                      Page 6 of 13 (d) Palo Fire Department (i) The Palo Fire Department provides first aid and backup fire-fighting support to the DAEC. Support efforts involving radiological incidents are directed and controlled by the Emergency Coordinator.

(e) Iowa Homeland Security and Emergency Management Division, Iowa Department of Public Defense (HS-EMO) (i) The HS-EMO provides assistance as outlined in the State of Iowa Radiological Emergency Response Plan. In summary, support includes the following: (a) Alerting State agencies. (b) Coordinating state radiological monitoring of areas, personnel, and equipment in support of local county authorities. (c) Evaluating offsite radiological conditions. (d) Operating the State Emergency Operations Center. (e) Informing federal organizations, adjacent counties, and adjacent states. (f) Ass isting local county authorities, through the State Highway Patrol, with establishing traffic and access control. (g) Establishing exposure criteria. (h) Preparing and coordinating state information releases to local and Federal agencies and to the news media. (i) Coordinating state mutual aid. (f) U.S. Nuclear Regulatory Commission (NRC) (i) The role of the NRC during a radiological emergency is to verify that emergency plans and procedures have been implemented, to assure that the public health and safety are protected, and to conduct investigative activities associated with the incident. The NRC will assist in coordinating federal response resources as specified in the NRC Incident Response Plan and will provide Duane Arnold, state, and local agencies advisory assistance associated with assessing and mitigating hazards to the public.

DAEC EMERGENCY PLAN SECTION 'A' ASSIGNMENT OF RESPONSIBILITIES Rev. ~27 (ORGANIZATIONAL CONTROL) Page 7 of 13 (g) U.S. Department of Energy (DOE) (i) The DOE has prepared a Federal Radiological Monitoring and Assessment Plan and an lnteragency Radiological Assistance Plan. Under the provisions of these plans, the DOE will, upon request from the state, dispatch radiological teams to assist local and state agencies in monitoring and provide technical guidance. For further details see Section C. (h) Federal Emergency Management Agency (FEMA) (i) The Federal Emergency Management Agency will provide federal emergency response as outlined in the National Response Plan and logistical support to the state and local governments involved in an emergency. (i) Contractors and Consultants (i) The Nuclear Steam Supply System (NSSS) at the DAEC was supplied by the General Electric Company, Nuclear Energy Systems Division, San Jose, California. General Electric has established 24-hour dedicated communications coverage which is monitored continuously by the Security Operations Center at General Electric Nuclear Energy, San Jose, California. This service will be used by the utility to request emergency assistance in the event of an emergency involving the NSSS. Actions will be taken in accordance with the latest Services Information Letter regarding the BWR Emergency Support Program. Contractual arrangements for these services are described in the GE Letter of Agreement. (ii) The Bechtel Power Corporation, Ann Arbor, Michigan, was the Architect-Engineer (AE) for the DAEC and may be requested to provide assistance. The Bechtel Emergency Response Manager will be the point of contact for the activation of Bechtel's Emergency Response Services (ERS). Upon notification from Duane Arnold of any emergency, the emergency response manager will activate Bechtel's ERS and contact the appropriate Bechtel management. Bechtel personnel will have the capability, under normal circumstances, of arriving at the DAEC within 24 hours after receipt of emergency notification. Bechtel can support many types of engineering activities. Bechtel's non-engineering departments include construction, cost and scheduling, quality assurance, procurement, and materials and quality services. Contractual arrangements for these services are described in the Bechtel Letter of Agreement. (iii) Other contractors and consultants will be used as their expertise, manpower, and facilities are required . Agreements and contracts are currently in place with each of these contractors which retain their services and define the commercial conditions of those services on a routine basis. In case of an emergency condition at DAEC, these private contractors could be contacted to augment the services they are currently providing. The Emergency Coordinator or Emergency Response and Recovery Director will coordinate the specific assistance requirements.

DAEC EMERGENCY PLAN SECTION 'A' ASSIGNMENT OF RESPONSIBILITIES Rev. 2-9--27 (ORGANIZATIONAL CONTROL) Page 8 of 13 U) Institute of Nuclear Power Operations (i) INPO has prepared an Emergency Resources Manual (ERM) from information provided by nuclear utilities, the major AE/NSSS organizations, and responding suppliers. In general, it contains the information necessary to locate and request staff, equipment and technical support in the event of a nuclear emergency. In addition, members of INPOs staff are available to assist in obtaining these resources. 2.4 ORGANIZATIONAL RESPONSIBILITY (1) Specific individuals within the Emergency Response Organization in charge of emergency response are as follows: (a) Emergency Response and Recovery Director (b) Emergency Coordinator 2.5 DIRECTION AND COORDINATION (1) The effectiveness of directing and coordinating the company's emergency response organization is influenced by the activation times, the organization and the severity of the emergency condition . The response time terminology listed below and the emergency conditions described in Section D should be utilized as mobilization and functional control criteria. (a) Short-Term Actions - Actions that can be taken within 1 hour of initial notification of an emergency condition. (b) Near-Term Actions -Actions that can be taken within 1 to 16 hours of initial notification of an emergency condition . (c) Long-Term Actions - All actions taken 16 hours or more after initial notification of the emergency condition. (2) Activation of Emergency Response Facilities occurs when the minimum staff for each facility, as noted in Figure B-1, has arrived, been briefed on the event, and is ready to perform command and control functions. Although the facility may be ready, turnover may be postponed in the interest of completing critical tasks. As an immediate action, the on-shift plant operations staff will initiate the callout process for augmented ERO members to ensure timely staffing of the onsite and offsite facilities. Augmenting the on-shift staff with additional off-shift personnel can occur within 60 minutes of initial declaration of the emergency condition.

DAEC EMERGENCY PLAN SECTION 'A' ASSIGNMENT OF RESPONSIBILITIES Rev. 2&-27 (ORGANIZATIONAL CONTROL) Page 9of13 (3) The Emergency Response and Recovery Director (ER&RD), Radiological Assessment Coordinator (or their alternates), and the Joint Information Center (JIC) Manager will be notified within the time frame specified in the Emergency Plan Implementing Procedures (EPIPs). Activation of the TSC and OSC will occur at an ALERT or higher classification. The TSC and OSC have an activation time of 60 minutes. The EOF has an activation time of 60 minutes from a Site Area Emergency or higher classification. Therefore, in the near-term, key Emergency Operations Facility staff members or their designees will be available to coordinate support activities from the Emergency Operations Facility on the 15th floor of the Alliant Tower in Cedar Rapids. During a SITE AREA EMERGENCY or GENERAL EMERGENCY condition, the EOF will be activated. When an ALERT condition is declared, personnel assigned to the EOF and JIC will leave from the DAEC and report to their respective facility, whether or not the EOF and JIC have yet been activated. Shift assignments and changes will occur within 16 hours of the initial mobilization of the Emergency Response Organization. 2.6 EMERGENCY RESPONSE FUNCTIONS (1) For DAEC, the functions and the person responsible for each function are addressed below and summarized in Table A-1. The functions are addressed in more detail throughout the remainder of the plan, primarily in Section B. (a) Command and Control (i) The ER&RD exercises overall control of DAEC emergency response activities. He ensures the overall direction of site and corporate activities is properly focused and the necessary resources are available for proper response. (b) Warning/Notification Communications (i) The Operations Shift Manager/Supervisor, acting as the Emergency Coordinator, is responsible for initially notifying ERO personnel and offsite agencies of an emergency situation and for providing support information to aid in initial response. (c) Public Information (i) The JIC Manager is responsible for ensuring that communications links are established with the news media and for coordinating information releases to the media related to plant conditions and offsite radiological consequences.

DAECEMERGENCYPLAN SECTION 'A' ASSIGNMENT OF RESPONSIBILITIES Rev. W-27 (ORGANIZATIONAL CONTROL) Page 10of13 (d) Accident Assessment (i) The Operations Shift Manager/Supervisor, acting as the Emergency Coordinator, is initially responsible for assessing the magnitude and potential consequences of an emergency condition and providing this information when notifying Duane Arnold, local, state, and federal officials and agencies. Subsequently, the Site Radiation Protection Coordinator assumes responsibility for dispatching appropriate personnel to monitor the environs. Upon activation of the EOF, the Radiological Assessment Coordinator assumes responsibility for directing field monitoring teams, assessing the results of monitoring activities, apprising appropriate personnel of the results of these efforts, and assisting in the development of appropriate recommendations for protective actions to be taken by the public. (e) Public Health and Protective Response (i) The Operations Shift Manager/Supervisor, acting as the Emergency Coordinator, is initially responsible for contact and coordination with public officials regarding protection of the general public. After activation of the Technical Support Center (TSC), the Emergency Coordinator, assisted by the Site Radiation Protection Coordinator, assumes the responsibility for contact with public offiCials. (ii) When the EOF is activated, the Radiological Assessment Coordinator is responsible for contact and coordination with public officials and provides recommendations associated with protective actions and alternatives that can be taken to protect the general public. He is responsible for keeping these officials apprised of changes in the condition of the plant and of releases, or planned releases, to the atmosphere. (f) Fire, Rescue/Emergency, and Medical Services (i) The Operations Shift Manager/Supervisor, acting as the Emergency Coordinator, is responsible for requesting and coordinating these services, if needed, during the initial stages of an accident. (g) Onsite Radiological Exposure Control (i) The Emergency Coordinator, assisted by the Site Radiation Protection Coordinator is responsible for controlling and minimizing radiological exposures to emergency response personnel and authorizing the performance of activities that may result in exposures in excess of normal limits. The Site Radiation Protection Coordinator is responsible for related onsite radiological monitoring activities, decontamination, and record keeping. (h) Access Control/Security/Accountability (i) The Security and Support Supervisor, assisted initially by the Operations Shift Manager/Supervisor, will assure personnel accountability is initiated and maintained, and will limit site and facility access to authorized personnel only.

DAECEMERGENCYPLAN SECTION 'A' ASSIGNM ENT OF RESPONSIBILITIES Rev . ~27 (ORGANIZATIONAL CONTROL) Page 11 of 13 2.7 AUTHORITY AND AGREEMENTS (1) The following identifies the legal state and federal instruments which establish authority for local and state agency support for an emergency. (a) Federal Civil Defense Act of 1950 as amended (Public Law 920, 81 st Congress) (b) Federal Civil Defense Guide, January 1965, as amended (c) Civil Preparedness Guide (d) Disaster Relief Act of 1974 as amended (Public Law 92-228) (e) 1993 Code of Iowa, Subtitle 12, Emergency Control and Chapter 29C, Emergency Management (f) Price Anderson/Stafford Act (2) Written agreements have been reached and are maintained with those support organizations that have an emergency response role within the Emergency Planning Zone. These agreements establish an understanding of assigned responsibilities and ensure proper coordination of activities in the event of an emergency. Included as Appendix 2 is a list of the support organizations with which agreements have been reached . These Letters of Agreement are kept on file with the Emergency Planning Department located onsite at the DAEC. 2.8 EXTENDED OPERATION (1) The Emergency Response Organization is capable of continuous operation from the time that emergency response actions are initiated until the recovery organization, discussed in Section M, is activated. The Emergency Response and Recovery Director is responsible for ensuring continuity of resources (technical, administrative, and material) . The Emergency Coordinator has been delegated authority to obtain necessary assistance from outside agencies, such as suppliers, contractors, and consultants as required to establish stable plant conditions .

DAECEMERGENCYPLAN SECTION 'A' ASSIGNMENT OF RESPONSIBILITIES Rev. ~27 (ORGANIZATIONAL CONTROL) Page 12of13 TABLE A-1 EMERGENCY RESPONSE FUNCTION AND RESPONSIBILITIES Responsible Individual

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(f) Command and Control L p I Alertinq and Notification L I Communications L p p I Public Information L Onsite Accident Assessment L p I Offsite Accident Assessment L p I Public Health and Protective Response L I Fire/Rescue, Emerqency, Medical L I Onsite Radioloqical Exposure Control L p I Access Control, Security, Accountability I L I =Initial Responsibility L = Lead Responsibility P =Primary Support

DAECEMERGENCYPLAN SECTION 'A' ASSIGNMENT OF RESPONSIBILITIES Rev . ~27 (ORGANIZATIONAL CONTROL) Page 13 of 13 FIGURE A-1 INTERRELATIONSHIPS BETWEEN EMERGENCY ORGANIZATIONS DAEC Contractors Nuclear Regulatory

                                                & Consulants                                       Commission INPO I

I I Homeland Security and Benton County Mercy Medical Palo Fire Emergency Management Division Linn County EOG Area Ambulance EOG Center Department Iowa Department of Public Defense I University of Iowa Center Point Linn County Ambulance Hospitals and Sheriffs Rescue Clinics I Hiawatha Ambulance Federal Emergency Management ... ..... ... .... Provides support to indicated agencies Agency Other Federal Agencies Other State State Department Agencies of Health

DAECEMERGENCYPLAN SECTION 'B' Rev. 44-45 EMERGENCY RESPONSE ORGANIZATION Page 1 of 36 Usage Level: INFORMATION Record the following: Date I Time: _ _ _ _ _ _ I _ _ _ _ Initials: _ __ NOTE: User shall perform and document a Temp Issue I Rev. Check to ensure revision is current, in accordance with procedure use and adherence requirements. Prepared By: I Date: Print Signature APPROVAL BY LICENSING MANAGER Approved By I Date: Print Signature APPROVAL BY ORG Approved By I Date: Print Signature APPROVAL BY DAEC SITE DIRECTOR Approved By I Date: Print Signature

DAECEMERGENCYPLAN SECTION 'B' Rev. 44-45 EMERGENCY RESPONSE ORGANIZATION Page 2 of 36 Table of Contents Section Numbers Section Titles Page 1.0 PURPOSE 3 2.0 REQUIREMENTS 3 2.1 RESPONSE POSITIONS 3 2.2 ONSITE RESPONSE ASSIGNMENTS 4 2.3 OFFSITE (EOF & JIG) RESPONSE ASSIGNMENTS 19 2.4 LONG-TERM ORGANIZATION 25 2.5 INTERFACES 25 2.6 LOCAL SUPPORT SERVICES 25 3.0 ATTACHMENTS 29 Table 8-1, "On-Shift Staffing & Staff Augmentation Attachment 1 30 Assignments" Attachment 2 Figure 8-1, "Emergency Response Organization" 33 Attachment 3 Figure 8-2, "Immediate Response Interface" 35 Attachment 4 Figure 8-3, "Long-Term Response Interface" 36

DAECEMERGENCYPLAN SECTION '8' Rev. 44-45 EMERGENCY RESPONSE ORGANIZATION Page 3 of 36 1.0 PURPOSE (1) This section describes the structure of the Emergency Response Organization and the specific responsibilities and authorities of key response personnel. Support services available with the DUANE ARNOLD (DAEC) to augment the Emergency Response Organization are identified as well as those services that may be provided by the DAEC, contractors , and local organizations. 2.0 REQUIREMENTS

2. 1 RESPONSE POSITIONS (1) The Emergency Response Organization is as illustrated in Figure B-1, and in the text of Section 'B' and Section 'H' of the DAEC Emergency Plan. Personnel qualified to fulfill the emergency response positions are identified in the Emergency Telephone Book, Learning Management System (LMS), and in the DAEC Emergency Preparedness Department's Training Records, which are considered to be the most up-to-date record available. The Emergency Response Organization (ERO) structure can be modified as required by the Emergency Coordinator or Emergency Response & Recovery Director (ER&RD).

DAECEMERGENCYPLAN SECTION '8' Rev. 44-45 EMERGENCY RESPONSE ORGANIZATION Page 4 of 36 2.2 ONSITE RESPONSE ASSIGNMENTS Immediate response organizational assignments, lines of succession, and responsibilities are as described below, for the Onsite organization. 2.2.1 EMERGENCY COORDINATOR (1) Assignment (a) The Emergency Coordinator functions onsite, coordinates the total site response effort, and normally operates from the Technical Support Center (TSC). The Emergency Coordinator reports to the ER&RD and has full authority and responsibility to initiate emergency actions and to recommend appropriate offsite protective measures to local and state authorities during the initial stages of the event as discussed in Section A. (2) Lines of Succession (a) The Operations Shift Manager/Control Room Supervisor (OSM,LGR.S) functions as the Emergency Coordinator until relieved . A qualified person will assume the responsibility of the Emergency Coordinator and receives turnover from the OSM,LGR.S. If necessary, the ER&RD will appoint the position of Emergency Coordinator and will inform the Operations Shift Manager/Control Room Supervisor of the appointment. (3) Responsibilities (a) The Emergency Coordinator exercises full responsibility and authority for all activities

        . at the site. This position is a 60-minute ERO response reporting position. He/she is assigned the following functional responsibilities:

(i) Ensure the activation of the onsite Emergency Response Organization as appropriate for the classification and circumstances of the emergency condition. (ii) Coordinate efforts to return the plant to and maintain it in a safe, stable condition . (iii) Coordinate accident assessment and analyses efforts to determine the full scope and impact of the emergency. (iv) Ensure appropriate initial notification of DAEC, local, state, and federal officials and agencies. This function will be assumed by the Emergency Operations Facility (EOF) when activated.

DAECEMERGENCYPLAN SECTION 'B' Rev. 44-45 EMERGENCY RESPONSE ORGANIZATION Page 5 of 36 (v) Provide initial Protective Action Recommendations, as appropriate, to local and state authorities who are responsible for offsite protective measures. This function will be assumed by the Emergency Operations Facility upon activation of that facility. (vi) Apprise DAEC, local, state, and federal officials and agencies of updated information pertaining to the emergency condition. (vii) Classify/reclassify the event as necessary. (viii) Approve extensions on exposure limits for emergency workers, if necessary. (ix) Select alternate location for the Offsite Relocation & Assembly Area if radiological release and meteorological conditions warrant a change. (x) Prepare the Emergency Response Organization for an orderly transfer of responsibilities to the recovery organization. (b) While the administrative aspects of most of these responsibilities may be delegated by the Emergency Coordinator, the responsibilities for items 2.2.1(3)(a)(v), 2.2.1(3)(a)(vii) , and 2.2.1(3)(a)(viii) may not be delegated except as indicated herein . Upon operation of the EOF, the ER&RD assumes responsibility for these non-delegable duties. 2.2.2 OPERATIONS SHIFT MANAGER AND CONTROL ROOM SUPERVISOR (OSMIGRS) (1) Assignment (a) The OSMIGRS, located in the Control Room, shall provide direction as required to return the plant to or assure that it is maintained in a safe, stable configuration .

DAECEMERGENCYPLAN SECTION 'B' Rev. 44-45 EMERGENCY RESPONSE ORGANIZATION Page 6 of 36 (2) Lines of Succession (a) Generally, the Operations Shift Manager, the senior individual, assumes the role of Emergency Coordinator. Hov1ever, the Control Room Supervisor will assume the role of Emergency Coordinator if the Operations Shift Manager is incapacitated . In the event that both the Operations Shift Manager and Control Room Supervisor are incapacitated, their responsibilities will immediately be assumed by a Licensed Senior Reactor Operator, if available, or by the ~Juclear Station Operating Engineer. Should this situation occur during normal work hours, the Operations Manager or Supervisor, upon his arrival in the Control Room, will assume the responsibilities and authorities normally assigned to the Operations Shift Manager/Control Room Supervisor. If this situation should occur during other than normal work hours, the first licensed Senior Reactor Operator who reports to the site will assume the functional responsibilities assigned to the Operations Shift Manager or Control Room Supervisor. Subsequent relief of this individual will be as directed by the Emergency Coordinator. (3) Responsibilities (a) The Operations Shift Manager/Control Room Supervisor evaluates the abnormal condition and implement emergency response actions as specified in the Emergency Plan Implementing Procedures (EPIPs) including:

Classifying the event
Recommending Protective Actions, if appropriate
Notifying county, state, and federal officials and offsite support agencies as necessary
Notifying the Emergency Response Organization

DAECEMERGENCYPLAN SECTION 'B' Rev. 44-45 EMERGENCY RESPONSE ORGANIZATION Page 7 of 36 2.2.3 TSC OPERATIONS SUPERVISOR (1) Assignment (a) The TSC Operations Supervisor will proceed to the TSC after receiving a plant status briefing , as needed, from the OSM/OSS and will assist the TSC in all matters pertaining to the Control Room and Operations Department activities. In the event that the TSC Operations Supervisor is needed to stay in the Control Room for an extended period of time, the Emergency Coordinator shall assume these duties, assign collateral responsibilities to another ERO position, or appoint an alternate. (2) Lines of Succession (a) The OSM/CRS functions as the TSC Operations Supervisor until relieved by a qualified individual. If necessary, the Emergency Coordinator .vill appoint the TSC 1 Operations Supervisor. (3) Responsibilities (a) This position is a 60 minute ERO response reporting time position . (b) The TSC Operations Supervisor is responsible for the follo .ving activities: 1

Assist the TSC in all matters pertaining to the Control Room and to Operations Department activities.
Providing direction and assistance, as necessary, to the OSM/CRS to achieve and maintain stable plant conditions .
Assisting the OSM/CRS in coordinating operational activities.
Monitoring operational activities to assure that the plant is operated and maintained in as safe a condition as possible.
Evaluating recommendations for corrective action provided by the technical staff and operating crew and recommending to the Emergency Coordinator a course of action to be taken to mitigate the situation.

DAECEMERGENCYPLAN SECTION 'B' Rev. 44-45 EMERGENCY RESPONSE ORGANIZATION Page 8 of 36

Recommending changes to the Emergency Classification based upon:

(i) Plant status changes, with or without radiological releases in progress. (ii)(i) Actual or potential radiological release parameters. (iii)(i) The progress of those activities undertaken to mitigate the situation and their probability for success. 2-.-2.42.2.3 SITE RADIATION PROTECTION COORDINATOR (1) Assignment (a) The Site Radiation Protection Coordinator will operate from the TSC and initiate those activities related to radiological assessment of the environs surrounding the plant during the initial stages of the event. Offsite monitoring will be assumed by the Radiological Assessment Coordinator upon activation of the EOF. (2) Lines of Succession (a) The Operations Shift Manager/Control Room Supervisor functions as the Site Radiation Protection Coordinator until officially relieved by the Emergency Coordinator. A qualified Site Radiation Protection Coordinator informs the Emergency Coordinator that he/she is ready to assume that position's responsibilities. If necessary, the Emergency Coordinator will appoint the Site Radiation Protection Coordinator. (3) Responsibilities (a) This position is a 60-minute ERO response reporting time position. (b) The Site Radiation Protection Coordinator is responsible for the following activities:

Ensuring that DAEC personnel are dispatched to monitor the environs in and around the plant for radiological consequences associated with the event.
Conducting an initial evaluation and assessment of the results of radiological monitoring activities. Upon activation of the EOF, evaluation and assessment of all offsite monitoring activities will be assumed by the Radiological Assessment Coordinator.

DAECEMERGENCYPLAN SECTION 'B' Rev. 44-45 EMERGENCY RESPONSE ORGANIZATION Page 9 of 36

Assessing the onsite radiological consequences and directing protective measures, including the need for partial or complete evacuation of the plant.
During the initial stages of the event, apprising local and state authorities, through the Emergency Coordinator, of the results of radiological monitoring activities and providing protective action recommendations based upon the projected radiological consequences to the population at risk. Upon activation of the EOF, this function will be assumed by the Radiological Assessment Coordinator.

2.2:.52.2.4 SECURITY AND SUPPORT SUPERVISOR (1) Assignment (a) The Security and Support Supervisor will exercise supervision and direction of the security staff and direction over the personnel assigned to the TSC support staff. (2) Lines of Succession (a) If necessary, the Emergency Coordinator will appoint the Security and Support Supervisor. (3) Responsibilities (a) This position is a 60-minute ERO response reporting time position. (b) Upon activation of the TSC, the Security and Support Supervisor is responsible for:

Assuring that an accountability check for all personnel within the protected area is conducted in a timely fashion and that requisite security posts are filled.
Ensuring that the Emergency Response Organization notification process as described in the Emergency Plan Implementing Procedures has been initiated and is successfully completed.
Assuring the TSC closed ventilation system is operational and activated.
Limiting access into the facility to only those personnel who are members of the Emergency Response Organization, or otherwise are authorized.
Establishing measures that will enable continuous accountability for all personnel within the protected area once the initial accountability check has been completed .

DAECEMERGENCYPLAN SECTION 'B' Rev. 44-45 EMERGENCY RESPONSE ORGANIZATION Page 10 of 36

Ensuring that no unauthorized personnel gain access to the site.
Assigning personnel for first aid duties, as required.
Providing overall management and direction to the support staff assembled in the TSC .

24.62.2.5 TECHNICAL AND ENGINEERING SUPERVISOR ( 1) Assignment (a) The Technical and Engineering Supervisor will exercise overall management and supervision of engineering, analysis and corrective action efforts undertaken by engineering and maintenance personnel at the DAEC from the TSC . In addition, he/she will coordinate with the Emergency Response Organization for engineering support efforts undertaken at the request of the Emergency Coordinator or TSC Operations Supervisor. (2) Lines of Succession (a) If necessary, the Emergency Coordinator will appoint the Technical and Engineering Supervisor. (3) Responsibilities (a) This position is a 60-minute ERO response reporting time position. (b) Upon activation of the site Emergency Response Organization and the Technical Support Center, the Technical and Engineering Supervisor is responsible for:

Verifying that the TSC is fully activated and staffed as described in the Emergency Plan Implementing Procedures.
Evaluating plant status and providing support to the operations staff as requested .
Assisting the Emergency Coordinator and the TSC Operations Supervisor in establishing the priority for repair activities to be undertaken.
Providing direction to the technical staff comprised of support personnel such as the Fire Marshal, Safety Supervisor, and consultant/contractor representatives to analyze plant conditions and define courses of action to mitigate the emergency situation .

DAECEMERGENCYPLAN SECTION 'B' Rev. 44-45 EMERGENCY RESPONSE ORGANIZATION Page 11 of 36

Providing direction to the engineering staff in TSC to aid in analysis of plant conditions and define courses of action to mitigate the emergency situation .
Coordinating corporate engineering activities with efforts being taken at the DAEC to mitigate the event and establish stable plant conditions .
Providing support to the Operations Support Center (OSC) Supervisor as necessary for coordinating all repair/corrective action efforts conducted at the DAEC.

2.2.7 REACTOR ENGINEER (1) Assignment (a) The Reactor Engineer will provide support to the operations crew located in the Control Room, and to the Emergency Coordinator from the TSC . He/she 'Nill provide . recommendations for returning the reactor core to a safe and stable condition . (2) Lines of Succession (a) If necessary, the Emergency Coordinator 'Nill appoint the Reactor Engineer. (3) Responsibilities (a) This position is a 60 minute ERO response reporting position . (b) Upon activation of the Emergency Plan for conditions classified as an ALERT or greater, the Reactor Engineer is responsible for:

Supporting the operating crew in bringing the reactor core to desired condition and maintaining it there .
Determining and reporting the amount of failed fuel to the TSC Operations Supervisor
Obtaining vendor feedback on the amount of failed fuel.
Recommending fuels related priorities in recovery/re entry operations.

DAECEMERGENCYPLAN SECTION 'B' Rev. 44-45 EMERGENCY RESPONSE ORGANIZATION Page 12 of 36 24.-32.2.6 ADMINISTRATIVE SUPERVISOR (1) Assignment (a) The Administrative Supervisor will provide administrative and logistics support, as required, in the event that activation of the site Emergency Response Organization is required from the Technical Support Center. (2) Lines of Succession (a) If necessary, the Security and Support Supervisor will appoint someone to fill this position . (3) Responsibilities (a) This position is a 60-minute ERO response reporting time position. (b) Services to be provided under the direction of the Administrative Supervisor include, but are not limited to:

Clerical, typing, and copying services.
Document retrieval.
Food services, clothing and overnight accommodations.
Coordination of transportation services and any facilities or office space needs.
Determining existing and potential administrative support needs and providing recommendations to the Security & Support Supervisor, as required .
Providing updates of status and relevant log information.

DAECEMERGENCYPLAN SECTION 'B' Rev. 44-45 EMERGENCY RESPONSE ORGANIZATION Page 13 of 36 2.+.92.2. 7 TSC OPS LIAISON (1) Assignment (a) The TSC Operations Liaison will provide operations support, as required, in the event that activation of the site Emergency Response Organization is required from the Technical Support Center. (2) Lines of Succession (a) If necessary, the Emergency Coordinator will appoint the TSC Operations Liaison. (3) Responsibilities (a) This is a 60-minute ERO response reporting time position. (b) The TSC Ops Liaison is responsible for the following:

Advising the EC and TSC Ops Supervisor on EAL/PAR declarations
Generating paperwork required for EAL/PAR declarations
Ensuring the State, Counties, and NRC receive notification regarding EALs and PARs
Providing an operational insight and tracking plant status
Advising the EC and TSC Ops Supervisor on matters that pertain to the plant as part of the Severe Accident Management Team.
Assist the TSC in all matters pertaining to the Control Room and to Operations Department activities.
Providing direction and assistance. as necessary. to the OSM/CRS to achieve and maintain stable plant conditions.
Assisting the OSM/CRS in coordinating operational activities.
Monitoring operational activities to assure that the plant is operated and maintained in as safe a condition as possible.
Evaluating recommendations for corrective action provided by the technical staff and operating crew and recommending to the Emergency Coordinator a course of action to be taken to mitigate the situation.

DAECEMERGENCYPLAN SECTION '8' Rev. 44-45 EMERGENCY RESPONSE ORGANIZATION Page 14 of 36

Recommending changes to the Emergency Classification based upon :

(i) Plant status changes. with or without radiological releases in progress. (ii) Actual or potential radiological release parameters. (iii) The progress of those activities undertaken to mitigate the situation and their probability for success.

Ensure Control Room is kept informed of TSC and OSC activities and priorities.
Assist EC and Control Room on plant condition status and trends.
Planning work packages for repair activities with assistance of engineering personnel in the TSC .

2.2.102.2.8 OPERATIONAL SUPPORT CENTER (OSC) SUPERVISOR (1) Assignment (a) The OSC Supervisor will exercise supervision and direction over the personnel who report to the OSC. He/she will report to the Emergency Coordinator in the TSC and will coordinate repair/corrective action efforts conducted at DAEC. (2) Lines of Succession (a) If necessary, the Emergency Coordinator will appoint the OSC Supervisor. (3) Responsibilities (a) This position is a 60-minute ERO response reporting time position.

DAECEMERGENCYPLAN SECTION 'B' Rev. 4445 EMERGENCY RESPONSE ORGANIZATION Page 15 of 36 (b) Upon activation of the Emergency Response Organization the OSC Supervisor is responsible for:

Supervising the implementation of the tasks and staffing delineated by the Emergency Assignment Staffing Board.
Providing general supervision and direction to personnel who report to the OSC.
Coordinating evacuation from the site of all unnecessary personnel during events classified as a SITE AREA or GENERAL EMERGENCY, once such an evacuation has been authorized by the Emergency Coordinator.
Coordinating all repair/corrective action efforts conducted at the DAEC to achieve stable plant conditions and to terminate any uncontrolled or excessive radiological release.
Ensuring that personnel dispatched from the OSC are properly briefed and equipped for their assignment in regards to technical content, as well as ALARA, including existing and potential radiological hazards.

2.2.112.2.9 HEAL TH PHYSICS SUPERVISOR (1) Assignment (a) The Health Physics Supervisor will provide overall direction and supervision in regards to ALARA and radiological practices to personnel in the OSC. In addition, he/she will provide direction to personnel for habitability of assembly areas. (2) Lines of Succession (a) If necessary, the OSC Supervisor will appoint the Health Physics Supervisor. (3) Responsibilities (a) This position is a 60-minute ERO response reporting time position. (b) Upon activation of the Emergency Response Organization the Health Physics Supervisor is responsible for:

Ensuring that personnel dispatched from the OSC are properly outfitted with protective clothing and equipment, briefed regarding ALARA, and apprised of existing and potential radiological hazards.

DAECEMERGENCYPLAN SECTION 'B' Rev. 44-45 EMERGENCY RESPONSE ORGANIZATION Page 16 of 36

Coordinating with the Site Radiation Protection Coordinator to obtain information regarding plant status, problems, response options, significant radiological releases in progress, offsite dose rates, plume location, and meteorological conditions as necessary.
Ensuring the determination of habitability of assembly areas and ERO facilities.
Coordinating the dispatch of monitoring teams and Offsite Relocation and Assembly Area (ORAA) personnel.
Ensuring the ORAA is briefed periodically in terms of plant and radiological conditions .
Supervising efforts to prepare injured/contaminated personnel for transport to offsite medical facilities.

2.2.12 INSTRUMENTATION AND CONTROL/ELECTRICAL MAINTENANCE (IClEM) SUPERVISOR, AND MECHANICAL MAINTENANCE SUPERVISOR (1) Assignment (a) The IC/EM Supervisor and Mechanical Maintenance Supervisor will aid in the coordination of repair/corrective actions conducted at the DAEC to achieve stable plant conditions from the Operations Support Center. (2) Lines of Succession (a) If necessary, the OSC Supervisor will appoint the IC/EM Supervisor and Mechanical Maintenance Supervisor (3) Responsibilities (a) These positions are 60 minute ERO response time reporting positions. (b) Upon activation of the Emergency Response Organization, the IC/EM Supervisor and Mechanical Maintenance Supervisor are responsible for:

Planning *.vork packages for repair activities with assistance of engineering personnel in the TSC.
Selecting personnel for repair teams appropriate to the work being done.
Conducting briefing and debriefings to repair team personnel.

DAECEMERGENCYPLAN SECTION 'B' Rev. 44-45 EMERGENCY RESPONSE ORGANIZATION Page 17 of 36 2.2.132.2.10 MINIMUM STAFFING (1) On-sh ift staffing and staff augmentation assignments are identified in Table B-1. The staffing plan is consistent with the guidance contained in NUREG-0654. On-shift staffing as noted in Table B-1 has been validated by an On-shift Staffing Analysis completed in accordance with the requirements of 10 CFR 50 Appendix E, IV.A.9. Details regarding the assignments and associated responsibilities are addressed in the EPIPs. 2.2.142.2.11 OTHER DAEC ORGANIZATIONAL ASSIGNMENTS In addition to the key response personnel described in the preceding sections, other DAEC personnel will assume roles as necessary in supporting the overall emergency response. Assignments and responsibilities of these support groups follow: (1) Security (a) Upon activation of the plan , for events classified as an ALERT or greater, the DAEC Security Force is responsible for performing an accountability check for all personnel within the protected area and controlling access to the site property. If evacuation of the site is required, the Security Force will assist in the evacuation and conduct an accountability check of all personnel dispatched to the ORAA. (2) Administrative (a) The DAEC Administrative Support Staff will provide general logistical support functions to aid response organization activities. This includes long range planning for providing personnel, material, facilities and office and clerical services. Additionally, the administrative staff will coordinate warehouse and procurement activities and obtain life support services such as food , clothing, and overnight accommodations. (3) Technical/Engineering (a) The technical and maintenance support staffs will provide plant engineering, maintenance assistance and coordination of corrective actions taken to mitigate the emergency condition, or terminate a release . This includes analytical and engineering efforts of site and corporate engineers and supervision and technical direction of activities performed by engineering, maintenance, or construction crafts.

DAECEMERGENCYPLAN SECTION 'B' Rev. 44-45 EMERGENCY RESPONSE ORGANIZATION Page 18 of 36 (4) Quality Assurance (a) Quality Assurance can provide assistance to design, procurement, and construction activities that are required to establish cold shutdown conditions. Quality Assurance can define and track activities that are not conducted in accordance with normal established practices, and can ensure that post-accident evaluations are conducted to verify the acceptability of those activities for both short and long term service . (5) Materials Management (Warehouse) (a) The Warehouse Supervisor will provide warehouse and procurement support in the event that procurement of specialized parts/equipment not currently stored on-site, or available locally, is required . (i) The site staff has the ability to procure site stores, and locally available stores, (equipment, parts, etc.) without involving the Warehouse Supervisor. (6) Contracts and Agreements (a) Assistance to the emergency response effort will be available from the Nuclear Steam Supply System supplier (General Electric), Architect-Engineer (Bechtel) and other consultants. Agreements and contracts are currently in place with each of these organizations which retain their services and define the commercial conditions of those services on a routine basis. In case of an emergency condition at DAEC, these private contractors could be contacted to augment the services they are currently providing. Agreements have been negotiated for emergency services as necessary. Section A of the DAEC Emergency Plan provides further details on the availability of contractors and consultants. (7) Safety (a) The Safety Specialist can advise Corporate Management in the area of safety. When a personal injury accident occurs at DAEC, the Safety Specialist can provide investigative reports reflecting the events that led up to the accident. He/she can indicate whether safety rules and procedures were followed and recommend follow-up corrective/disciplinary actions . Additionally, the Safety Specialist is responsible for reporting all serious accidents to the Iowa Occupational Safety and Health Administration, a branch of the Iowa Bureau of Labor.

DAECEMERGENCYPLAN SECTION 'B' Rev. 44-45 EMERGENCY RESPONSE ORGANIZATION Page 19 of 36 2.3 OFFSITE (EOF & JIC) RESPONSE ASSIGNMENTS 2.3.1 The Emergency Operations Facility and Joint Information Center (JIC) provide the following principal functions in the overall response to an emergency at the DAEC once control is transferred from the Technical Support Center: (1) Establishes a single focal point for perform ing radiological dose assessment and Protective Action Recommendation decision-making, including coordination and interface with local , state, and federal support groups (2) Establishes a coordinated means to disseminate information related to the accident to public officials, the news media, and industry public relations forums. 2.3.2 Response positions are as follows: (1) Emergency Response and Recovery Director (ER&RD) (a) Assignment (i) The ER&RD is responsible for the overall direction and control of DAEC's integrated emergency response and recovery effort and providing the financial resources and contractual capabilities to ensure requisite actions can be taken to protect the health and safety of the public. (b) Responsibilities (i) This is a 60-minute ERO response time reporting position. (ii) Ensuring that the Emergency Response Organization is staffed by qualified personnel and coordinating with these personnel to ensure that sufficient support for various functions is available, either from within Duane Arnold or from outside organizations (i.e., other utilities, Architect Engineers, Nuclear Steam Supply System suppliers, INPO, consultants, etc.) . (iii) Authorizing the procurement of equipment, materials, and resources, as necessary, to effectively respond , control , and recover from an accident condition at DAEC. (iv) Implementing the Emergency Plan Implementing Procedures (EPIPs). (v) Reviewing and concurring with Protective Action Recommendations prior to their issuance once the Emergency Operations Facility (EOF) is operational.

DAECEMERGENCYPLAN SECTION 'B' Rev. 44-45 EMERGENCY RESPONSE ORGANIZATION Page 20 of 36 (2) Radiological Assessment Coordinator (a) Assignment (i) The Radiological Assessment Coordinator is responsible for coordinating and directing all offsite radiological monitoring and dose assessment programs and supervising activities within the EOF. He/she will be accountable to the ER&RD. (b) Responsibilities (i) Establishing communications with the TSC as necessary. Obtain ing information on the diagnosis and prognosis of the accident condition, the quantities of radioactive material releases, and the prevailing meteorological conditions . (ii) Coordinating the onsite and offsite radiological monitoring activities to provide anticipated release rates and projected dose rates. (iii) Interpreting radiological data for updating the ER&RD, county, state, federal and support agencies in terms of projected radiological exposures and actual dose measurements. This includes providing estimates of total population exposure when necessary. Providing radiation protection for those assembled at the EOF. (iv) Analyzing all information for significant trends while developing Protective Action Recommendations (PARs). Review the recommendations with the Emergency Response and Recovery Director and , when authorized, provide them to the state and county officials. (v) Providing assistance to county, state, and federal officials for. recovery activities. (vi) Advising the ER&RD to ensure compliance with legal and regulatory requirements. (vii) Directing and coordinating offsite monitoring teams. (viii) Performing dose projection calculations . (ix) Providing Protective Action Recommendations, as required, to the Emergency Response and Recovery Director. (x) Coordinating the necessary support to other Agencies and support groups in field assessment, data analysis, and environmental sample analysis. (xi) Coordinating with the State of Iowa in tracking the plume offsite.

DAECEMERGENCYPLAN SECTION 'B' Rev. 44-45 EMERGENCY RESPONSE ORGANIZATION Page 21 of 36 (3) Support Services Coordinator (a) The Support Services Coordinator will assure that necessary resources and activities are provided by staff personnel. Specific areas are available to support the overall emergency response and recovery effort conducted both at the Alliant Tower and at the site. This includes security, communications, personnel, transportation, purchasing , industrial relations, and safety. He/she will also coordinate, as necessary, the application of resources and equipment available within Duane Arnold departments. (i) Security

The Support Services Coordinator in cooperation with the Alliant Corporate Security Manager is responsible for providing security for the Alliant Tower and controlling access to the EOF, JIC, and backup facility to the JIC as well as appropriate Duane Arnold working areas in the building . Staff assistance for building security will be provided by the security force under contract, and, to the extent possible, the Cedar Rapids Police Department and the Linn County Sheriff's office. Further details and instructions for establishing and maintaining security are provided in the EPIPs.

(ii) Communications

The Local Telephone Companies can provide engineering support for commercial telephone installations that are permanent or temporary. He/she can respond to identified communication needs and problems and coordinate necessary engineering and maintenance support for restoration or rearrangement of Duane Arnold communications systems.

(iii) Corporate Services

The Corporate Services Department can provide required services and equipment such as record and document retrieval and reproduction, office supplies, office furniture, photography, facility and area maps, audio visual aids, graphics, printing, distribution services, and general housekeeping services.

DAECEMERGENCYPLAN SECTION 'B' Rev. 44-45 EMERGENCY RESPONSE ORGANIZATION Page 22 of 36 (iv) Personnel

Administrative personnel can be contacted to provide personnel to augment the administrative and clerical support functions associated with initial activation and continued operation of the EOF and JIC.

(v) Logistics and Transportation

Transportation personnel can respond to identified transportation needs and emergency air and land transportation necessary for materials and personnel. He/she can arrange for rental cars and hotel accommodations for those personnel temporarily assigned to the Cedar Rapids area in support of the response and recovery effort. They can also provide for repairing and maintaining a transportation fleet and implementing contracts with commercial carriers to obtain priority transportation .

(vi) Purchasing

Purchasing and Materials personnel can respond to identified needs related to procurement of materials and services and coordinate onsite and offsite procurement activities to assure rapid delivery of materials. They can augment Duane Arnold resources by activating contracts with outside agencies and requesting , through use of prepared lists, emergency equipment available in Cedar Rapids.

(vii) Industrial Relations

The Manager, Industrial Relations can assess and respond to contractual problems that may arise during the course of the event and apprise bargaining unit officials and trade counsels of existing or projected labor problems. He/she can also assist in the response to manpower needs through the use of established manning lists, a computerized skill inventory of DAEC employees, and the activation of established contracts/agreements with outside organizations.

DAECEMERGENCYPLAN SECTION 'B' Rev. 44-45 EMERGENCY RESPONSE ORGANIZATION Page 23 of 36 (viii) Supplemental Resources

The Operations and Production Departments of Duane Arnold can augment the DAEC staff during an emergency. Personnel and equipment are available to provide maintenance and construction services at the DAEC .

Materials, equipment, and machine shop services are also available. (4) EOF Ops Liaison (a) The EOF Ops Liaison is responsible for the following : (i) Advising the ER&RD on Emergency Action Levels (ii) Providing an operational insight and tracking plant status (iii) Communicating with county, state, federal and support agencies to relate accident information necessary for the offsite authorities to implement their county and state emergency plans and procedures . (iv) Ensuring the State, Counties, and NRC receive notification regarding EALs and PARs (v) Assisting in the recovery phase of the emergency (vi) Advising the ER&RD on matters that pertain to the plant (5) Joint Information Center (JIC) Manager (a) Assignment: (i) Working in coordination with Corporate Communications and in cooperation with the Corporate JIC Manager, the Site JIC Manager is responsible for the overall direction and control of the Site JIC so as to ensure that accurate and timely information is provided to the public, and that information releases and news media briefings with local, county, state and federal public relations officials are coordinated. (b) Responsibilities: (i) Coordinate with the ER&RD and the Corporate JIC Manager to determine the level of activation at an Unusual Event or Alert and to ensure the Site JIC is activated at a Site Area Emergency.

DAECEMERGENCYPLAN SECTION 'B' Rev. 44-45 EMERGENCY RESPONSE ORGANIZATION Page 24 of 36 (ii) Supervise all communication operations at the Site JIC and coordinate the distribution of all information releases and statements with the Corporate JIC Manager and offsite partners. (iii) Coordinate with Corporate Communications media conferences at the Site JIC as appropriate, with the goal of each participating organization to provide clear, consistent messages to the public. (iv) Work directly with the Corporate JIC Manager to ensure support for the following functions:

1. Coordinate and provide information to the Business Units such as legal, risk management, finance, and human resources as needed .

2. Media monitoring of local and national news outlets.

3. Information releases and coordination of information requests.

4. Interview coordination (6) Corporate JIC Manager (a) The Corporate JIC Manager leads the Emergency Communication Team (ECT) organization located at the Site JIC, informs and influences communication strategies and tactics and provides critical information to the ECT to develop messages.

(7) Emergency Communication Team (ECT) (a) The ECT is a corporate team that supports the operation of the Site JIC and execution of communication tasks during a declared nuclear emergency. The ECT will recommend and execute public information plans and strategies on behalf of the company and its executive leadership. The ECT is responsible for gathering information about an incident, developing and distributing messaging, monitoring media and social media and executing all other functions deemed necessary to accurately communicate during an emergency.

DAECEMERGENCYPLAN SECTION 'B' Rev. 44-45 EMERGENCY RESPONSE ORGANIZATION Page 25 of 36 2.4 LONG-TERM ORGANIZATION (1) Activation of the onsite Emergency Response Organization will, directly and indirectly, result in a response by essentially all personnel normally associated with the DAEC , particularly by management and key support personnel. Therefore, within several hours after the initiating event, decisions will be made to provide and prepare for a long term augmented emergency organization. The Emergency Response and Recovery Director will determine when the Recovery Organization is to be implemented. Prior to implementation of the Recovery Organization, the situation may require that the onsite Emergency Response Organization remain in place for a protracted period of time. As conditions allow, shift schedules will be developed by the supervisors in charge of the Control Room and several support centers various facilities. Prior to implementation, these schedules shall be reviewed and concurred with by the Emergency Coordinator facility leads. The Emergency Response Organization is set up on a team concept for 24-hour coverage. (2) Duane Arnold maintains the resources and capabilities to support response and recovery activities in the event of an emergency or accident condition at the DAEC. These include, but are not limited to, the following : (a) Management direction and control (b) Corporate and government affairs (c) Public information and public relations (d) Communications systems (e) Security and administration (f) Medical and first aid (g) Transportation and accommodations (h) Commissary and catering (i) Purchasing and stores U) Construction, maintenance, and mobile equipment and materials (k) Appropriate staff and work force augmentation

DAECEMERGENCYPLAN SECTION 'B' Rev. 4445 EMERGENCY RESPONSE ORGANIZATION Page 26 of 36 (I) Engineering activities (i) Nuclear fuel , core physics, and thermal hydraulics (ii) Design and construction (iii) Electrical, instrumentation, mechanical (iv) Chemistry and metallurgy (m) Planning and scheduling (n) Radiological analysis and protection (o) Accident analysis (p) Meteorological monitoring and analysis (q) Health physics and decontamination (r) Fire Protection (s) Procedure development (t) Operations and maintenance (u) Quality assurance and control (v) Contracts and agreements (w) Company records and files (x) Safety 2.5 INTERFACES 2.5.1 Figures 8-2 and 8-3 illustrate the immediate and long-term response interfaces, respectively, between the Emergency Response Organization and organizations of affected local, state and federal offices and agencies. The TSC, OSC, EOF, and JIC are described and discussed in Section H. (1) Public Information and Governmental Relations

DAECEMERGENCYPLAN SECTION 'B' Rev. 44-45 EMERGENCY RESPONSE ORGANIZATION Page 27 of 36 (a) During a nuclear incident, State and County officials will activate their local emergency operations centers and will send PIOs to the Site Joint Information Center (JIC). The Site JIC Manager is responsible for working with the state and county PIOs to ensure the timely and coordinated release of information to the public. The Corporate Emergency Communication Team (ECT) aligns with and supports the Site JIC Manager. (b) If the Cedar Rapids/Marion metropolitan area is evacuated , JIC spokespersons, state and county PIOs and appropriate support staff can be relocated to facilities on the main campus of Kirkwood Community College to continue media briefings and news conferences. (c) Press Briefings and Public Relations (i) The Site Joint Information Center will function as the principal focal point for coordination of information to the public regarding the emergency condition at the DAEC. Press briefings will be coordinated by the JIC Manager, who will ensure that appropriate emergency response and corporate individuals are available to provide technical information and respond to inquiries from the assembled media personnel. Information related to the plant as well as generic information related to the nuclear industry will be available to the media. Further details and instructions related to press briefings and public relations are provided in the EPIPs. (d) Apprising Public Officials and Agencies (i) The facilities in the JIC will be used, as appropriate, following the issuance of Protective Action Decision (PADs) made by offsite officials. The Corporate and Site JIC Managers will work in collaboration with offsite partners to establish a cohesive communication strategy, with the goal of effectively communicating with the public. (2) Corporate Assistance (a) Legal Counsel (i) Legal Counsel can provide the ER&RD with advice to prevent DAEC from taking actions that could increase corporate liability or jeopardize indemnification agreements when handling claims and litigation.

DAECEMERGENCYPLAN SECTION 'B' Rev. 44-45 EMERGENCY RESPONSE ORGANIZATION Page 28 of 36 (b) Insurance and Claims (i) Insurance and Risk personnel can advise the ER&RD in the area of insurance and claims, and provide them with regular status reports on the injured or contaminated individuals treated at nearby medical facilities. They interface with American Nuclear Insurers and can apprise them of the details, the sequence of events, the impact of the emergency, and the actions being taken to mitigate its consequences . They also interface with Nuclear Electric Insurance Limited and Nuclear Mutual Limited (NEIL/NML), a utility-owned captive insurance group, which covers the loss of generation and coordinates claims filed on behalf of DAEC. (ii) Insurance and Risk personnel will coordinate with nearby medical facilities and backup medical facilities at the University of Iowa Hospitals and Clinics, as required, in the treatment of radiological and non-radiological injuries. Insurance and Risk personnel can also complete all insurance forms and document all events affecting insurance and claims during the emergency.

DAECEMERGENCYPLAN SECTION 'B' Rev. 44-45 EMERGENCY RESPONSE ORGANIZATION Page 29 of 36 2.6 LOCAL SUPPORT SERVICES (1) Agreements have been reached with local agencies and private support facilities with regard to the type of support that will be furnished to the DAEC in the event of an emergency. These agreements in the form of letters of agreement (refer to Appendix 2 for list of letters) and agreements of responsibility as described in the Linn and Benton County Radiological Emergency Response Plans have been developed to ensure that there is a clear understanding of assigned responsibilities and that there will be proper coordination of activities in the event of an emergency. The Letters of Agreement will be updated as necessary and confirmed as acceptable at least every two years. Linn County, Benton County, and the State of Iowa are notified of classified events using the communication methods described in Section E "Notification Methods and Procedures. Through this formal process, and other informal communication processes, resources can be requested from the County and State Emergency Response Organizations. Existing agreements are in place to supply the site with resources requested. Examples are: (a) Emergency Medical Services (EMS) - Emergency medical services and ambulances as requested by DAEC and implemented using the Incident Command System (ICS). (b) Fire and Rescue - Fire response, fire apparatus , and volunteer firefighters as requested by DAEC and implemented using the ICS . Additionally, the Counties have mutual aid agreements to obtain additional resources from surrounding counties. Processes are also in place for Counties to request resources from the State. The site Security Plan contains information on how local law enforcement is contacted for a hostile action. 3.0 ATTACHMENTS (1) Table B-1, "On-Shift Staffing & Staff Augmentation Assignments" (2) Figure B-1, "Emergency Response Organization" (3) Figure B-2, "Immediate Response Interface" (4) Figure B-3, "Long-Term Response Interface"

DAEC EMERGENCY PLAN SECTION 'B' 4445 EMERGENCY RESPONSE ORGANIZATION Rev. Page 30 of 36 Table B-1 On-Shift Staffing & Staff Augmentation Assignments Major Functional Areas Major Tasks Position Title or Expertise On-Shift Capability for Response Comments (All positions are 24-hour staffing) *=see additions Location Comments 60min 90min Plant Operations and Respond to condition and Operations Shift Manager (SRGCertified 1! CR Provides early direction and control until assessment or mitigate operational event Fuel Handler) relieved by the Emergency Coordinator operational aspects consequences Control Room S1.113ervisorNon-Certified +2 CR One NCO is designated as the Fire Operator (SRGNCO) Brigade Leader Control Room 013erators ¢! GR Third ReaGtor 013erator is assigned as Fire Brigade Leader 1'.1.1xiliary 013erators 2 GR Shift Technical Advisor + GR Emergency Direction Site utility Emergency Operations Shift Manager (CFH) CR and Control Management Notification/ Notify licensee, state, Operations Shift Comm1.1nicatorManager .+* CR Assumed by the OSM until relieved Communications local & federal personnel (CFH) and maintain communications TSC Operations Liaison 21 TSC NRG ENS Communicator NRC ENS Communicator TSC EOF Ops Liaison EOF Radiological Accident Overall utility Emergency Emergency Coordinator TSC Assessment and Management and offsite Support of Operational agency interface Emergency Response and Recovery EOF Accident Assessment Director Offsite Dose Assessment Site Rad ProteGtion Coor:dinator 2 TSG and Protective Action MID/\S 013eratorNCO Recommendations Site Radiation Protection Coordinator TSC MIDAS Operator TSC Rad Assessment Coordinator EOF Rad Assessment Coordinator 21 EOF MIDAS Operator I Page 1 Subtotal ] 93 ] 9 ] O ] ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~- , ------ '

DAECEMERGENCYPLAN SECTION 'B' Rev. 4445 EMERGENCY RESPONSE ORGANIZATION Page 31 of 36 Table B-1 On-Shift Staffina & Staff Auamentation Assianments Major Functional Areas Major Tasks Position Title or Expertise On-Shift Capability for Response Comments (All positions are 24-hour staffing) *=see additions Location Comments 60min 90min Offsite Surveys HP Technician 1! 4.! osc May be staffed by Plant Personnel trained in the HP role for Field Teams. DAEC Staff Member + osc HP Technician osc May be staffed by Plant Personnel trained in the HP role for Field Teams. DAEC Staff Member osc Onsite and In-Plant HP Technician 1! + EGFOSC May ee staffeel ey Plant PeFSonnel tFaineel Surveys 11 EC in the HP role for Fielel Teams. 0 $>1aff Member (Out of plant) lnplant Surveys HP Testmisian + + + GSG Chemistry/Radio- Chemistry Technician .+* 1 osc Performed by HP Technician until relieved chemistry Plant System Technical Support COFe!TheFrnal HyelFaulissTech and TSC Engineering Repair and Engineering Supervisor Corrective Actions l::leotFisal EngineeF + +sG Meshanioal EngineeF + +sG Repair and corrective OSC Supervisor osc actions Mechanical Maintenance osc Electrical Maintenance + osc lnstFurnent anel Control (l&C) Technician osc Protective Actions (In- Radiation Protection" HP Technicians .+* 1 21 osc Performed by RP Technician responsible Plant) including Access control, for onsite and in-plant surveys RP coverage for repair and corrective action, search & rescue, first aid and firefighting. A) Assess Control

DAECEMERGENCYPLAN SECTION 'B' Rev. 4445 EMERGENCY RESPONSE ORGANIZATION Page 32 of 36 Table B-1 On-Shift Staffina & Staff Auamentation Assianments Major Functional Areas Major Tasks Position Title or Expertise On-Shift Capability for Response Comments (All positions are 24-hour staffing) *=see additions Location Comments 60 min 90 min B) HP Coverage for Re~air, Corrective Actions, Search & Rescue, First aiel , & Fire fighting C) Habitability D) Dosimetry I Page 2 Subtotal I 31 I 29 I 84 I Table B-1 On-Shift Staffing & Staff Augmentation Assignments Major Functional Areas Major Tasks Position Title or Expertise On-Shift Capability for Response Comments (All positions are 24-hour staffing) *=see additions Location Comments 60 90 min min Fire Fighting 4 Local Support Fire Brigade per FP-AB-100. Rescue Operations and Local Support May be provided by shift personnel First Aid assigned other functions. Site Access Control and Security, fire fighting, Security All per Security Plan. Personnel Communications, Accountability personnel accountability Page 1 Subtotal 93 9 0 Page 2 Subtotal 31 29 84 Page 3 Subtotal 4 0 0 GRAND TOTAL 468 2418 84

DAEC EMERGENCY PLAN SECTION 'B' 4445 EMERGENCY RESPONSE ORGANIZATION Rev. Page 33 of 36 Figure B-1 EMERGENCY RESPONSE ORGANIZATION (Page 1 of 2) I Onsite ERO I Emergency Coordinator

                                                           '"'sl-lAl:fecW'~ i;.                 Site Rad               Security &

osc NOS Engineering Protection Support Supervisor Supervisor Supervisor Supervisor Operations Shift MIDAS Security Force Manager Operator Electricians and Field Team l&C Techs Director Information Services Rep NRC HPN Communicator NRC ENS Admin Communicator Supervisor HP Tech's Minimum Staff Chem Tech's Positions included in this ORAA Staff diagram are 60 minute (RW) responders unless otherwise indicated in Table B-1 OSC Staff (RW)

DAEC EMERGENCY PLAN SECTION 'B'

                                                                                                                                       ~=~~ ~ 36 5

EMERGENCY RESPONSE ORGANIZATION Figure B-1 EMERGENCY RESPONSE ORGANIZATION I Corporate ERO J (Page 2 of 2) 1~------ Site JIC Manager Corporate JIC Manager ER&RD ~ --,__ and Emergency I I I Communication Team [ _________ I Spokesperson ._ - - I Coordination and Support {Technical Advisor) EOF Ops Liaison NRC HPN Communicator I Assistant JIC Manager State/County

                         ,____    Technical Liaisons                              I Media Host Ra di ologi ca I             Field Team Assessment                     Director Coordinator EOF/JIC Shared Support MIDAS Operator ! - - -                              Services                     ~

Notes: Logistics, IT/AV, {l)All dashed lines represent coordination and support Administrative, Medical t- (2) Title s underlined in boxes represent functions Consultants I - - - - - - JI _ - - - - - l [ 0

nimum StaffJ I I

I I I Communicator/ Support Services Information Messenger/ Coordinator Services Rep . Recorder L

DAECEMERGENCYPLAN SECTION 'B' Rev. 4445 EMERGENCY RESPONSE ORGANIZATION Page 35 of 36 Figure 8-2 IMMEDIATE RESPONSE INTERFACE DAEC Control Emergency ER&RD RoomOSM Coordinator I I Benton County EOC HSEMD Linn County EOC I Mercy Medical State Agencies Center Palo Fire Department I FEMA Area Ambulance (Lead) I Hiawatha Federal Agencies Ambulance I Center Point Ambulance NRC Sheriffs Rescue

DAEC EMERGENCYPLAN SECTION 'B' Rev. 4445 EMERG ENCY RESPONSE ORGANIZATION Page 36 of 36 Figure B-3 LONG-TERM RESPONSE INTERFACE EMERGENCY RESPONSE EMERGENCY RESPONSE ORGANIZATION !OFFSITEl ORGANIZATION !ONSITEl DAEC CONTRACTORS OPERATIONAL CORPORATE AND CONTROL ROOM SUPPORT SERVICES CONSULTANTS CENTER EMERGENCY TECHNICAL OPERATIONS SUPPORT FACILITY CENTER LINN & BENTON STATE COUNTIES UNIVERSITY OF HYGiENIC EMERGENCY IOWA LAB OPERATIONS CENTERS UNIVERSITY OF IOWA HOSPITALS f - - - - - - - - - - - - - - j STATE OF IOWA AND CLINICS EMERGENCY OPERATIONS f-------~ CENTER MERCY MEDICAL CENTER 0---- - - - - - - - - - - - - - - - - - - < PALO FIRE DEPARTMENT FEMA LINN COUNTY SHERIFF'S RESCUE AREA AMBULANCE HIAWATHA AMBULANCE CENTER POINT AMBULANCE

DAECEMERGENCYPLAN SECTION 'D' Rev. 2-9-30 EMERGENCY CLASSIFICATION SYSTEM Page 1 of 10 Usage Level: INFORMATION Record the following: Date I Time : _ _ _ _ _ _ I _ _ _ _ Initials: _ __ NOTE: User shall perform and document a Temp Issue I Rev. Check to ensure revision is current, in accordance with procedure use and adherence requirements. Prepared By: Date: - - - - Print Signature APPROVAL BY EMERGENCY PREPAREDNESS MANAGER Approved By I Date: Print Signature APPROVAL BY ORG Approved By I Date: Print Signature APPROVAL BY DAEC SITE DIRECTOR Approved By I Date: Print Signature APPROVAL BY CORPORATE DIRECTOR OF EMERGENCY PLANNING Approved By I Date: _ _ _ ___. Print Signature

DAECEMERGENCYPLAN SECTION 'D' Rev. 29--30 EMERGENCY CLASSIFICATION SYSTEM Page 2 of 10 Table of Contents Section Numbers Section Titles Page 1.0 PURPOSE 3 2.0 EMERGENCY CLASSIFICATION SYSTEM 3 2.1 NOTIFICATION OF UNUSUAL EVENT 3 2.2 ALERT 4 2.3 SITE AREA EMERGENCY 4 2.4 GENERAL EMERGENCY 4 EMERGENCY ACTION LEVEL (EAL) INITIATING 3.0 5 CONDITIONS TABLE D-1 Attachment 1 7 IMMEDIATE ACTION TABULATION

DAECEMERGENCYPLAN SECTION 'D' Rev. ~30 EMERGENCY CLASSIFICATION SYSTEM Page 3 of 10 1.0 PURPOSE (1) This section describes the system used to classify emergency conditions. This system is consistent with that set forth in Appendix 1 of NUREG-0654 and is the system used by state and local organizations. The Emergency Action Levels established for each emergency classification are reviewed annually with offsite authorities who are responsible for implementing protective measures for the population at risk. 2.0 EMERGENCY CLASSIFICATION SYSTEM (1) Each emergency classification is associated with a particular set of immediate actions that are identified in EPIP Manual Appendix 1, forms EAL-01 and EAL-02. Specific details regarding required actions to be taken at the DAEC for each class of emergency are specified in the EPIPs. The specific instruments, parameters, and status indicators used to establish the emergency classification are specified in the Emergency Plan Implementing Procedures. If an emergency condition changes in severity, it will be reclassified and the corresponding response actions will escalate or de-escalate accordingly. (2) The highest emergency classification for which an Emergency Action Level (EAL) is currently met should be DECLARED. If an action level for a higher classification is exceeded but the situation is resolved prior to offsite notification, the higher classification should be REPORTED to the offsite agencies and the NRC, but SHOULD NOT be declared. The notification must indicate the CURRENT classification, the period of time that the higher classification existed and the mitigating conditions that caused the reduction in the emergency classification. 2.1 NOTIFICATION OF UNUSUAL EVENT (1) This class of emergency conditions includes the least severe events requiring offsite notification. This classification will be declared whenever 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 release of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.

DAECEMERGENCYPLAN SECTION 'D' Rev. ~30 EMERGENCY CLASSIFICATION SYSTEM Page 4 of 10 2.2 ALERT (1) The ALERT emergency condition is the second class in increasing order of severity. This emergency classification will be declared whenever 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. Accidents analyzed in Chapter 15 of the Updated Final Safety Analysis Report that fit this classification include the Refueling Fuel Handling Accident. 2.3 SITE AREA EMERGENCY (1) The SITE AREA EMERGENCY condition is the third class in increasing order of severity and requires immediate notification of the public. This classification will be declared whenever 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) prevents 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. Accidents analyzed in Chapter 15 of the Updated Final Safety Analysis Report that fit this classification are Control Rod Drop, Loss of Coolant, and Main Steam Line Break. 2.4 GENERAL EMERGENCY (1) The GENERAL EMERGENCY condition is the most severe and requires immediate notification of the public. This emergency classification will be declared whenever events are in progress or have occurred which involve actual or imm inent substantial core degradation or melting with potential for loss of containment integrity or a HOSTILE ACTION that results in an actual loss of physical control of the facility, or .,....Rreleases that can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area.

DAECEMERGENCYPLAN SECTION 'D' Rev. ~30 EMERGENCY CLASSIFICATION SYSTEM Page 5 of 10 3.0 EMERGENCY ACTION LEVEL (EAL) INITIATING CONDITIONS (1) The EAL Tables, located in the EPIP Manual Appendix 1, forms EAL-01 and EAL-02, identify the specific conditions and associated limits that serve as the basis for initiating the appropriate monitoring, assessment, and response actions described in this plan. As the severity of each condition increases, the event is classified (or reclassified), based upon instruments, equipment status, and parameters identified in the EAL Tables to assure that appropriate emergency response actions are being taken. (2) The EALs are based upon one or more of the following criteria : (a) System design specifications (b) Technical Specification limits (c) FSAR accident analyses (d) 10CFR20 and 10CFR100 requirements (e) EPA 400-R-92-001 Manual of Protective Action Guides and Protective Actions for Nuclear Incidents (dated October 1991 with 2nd printing May 1992) (f) NUREG-0578, "TMl-2 Lessons Learned Task Force Status Report and Short-Term Recommendations." (g) NUREG-0654, FEMA-REP-1, Revision 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants." (h) NEI Development of Emergency Action Levels for Non-Passive Reactors, NEI 99-01, Revision 6, November 2012 (i) NRC Bulletin 2005-02, Emergency Preparedness and Response Actions for Security-Based Events, July 18, 2005 as clarified by NEI Industry White Paper Dated November 15, 2005

DAECEMERGENCYPLAN SECTION 'D' Rev. 29-30 EMERGENCY CLASSIFICATION SYSTEM Page 6 of 10 (3) The EALs to be initiated are not necessarily based upon actual radiological exposures to the population at risk, but rather are based upon the potential exposures or specific plant conditions that may pose a threat to the population at risk. (4) The release rates and release rate calculations established for the EALs are based upon an assumed isotopic mix at the time of the event and are calculated using the MIDAS computer model. Effluent release rate levels have been identified for both the SITE AREA EMERGENCY and GENERAL EMERGENCY classifications. The monitor readings established for the SITE AREA EMERGENCY are based upon adverse meteorology while those established for the GENERAL EMERGENCY are based upon normal meteorological conditions . The limiting case for releases from the Off-Gas Stack, an elevated release with the Standby Gas Treatment System (SBGT) in operation, is Deep Dose Equivalent (whole body dose) rates. All other release paths are assumed to be secured. The limiting case for release from the Turbine Building Ventilation Exhaust Stack, a mixed mode release without the benefit of treatment via SBGT, is Committed Dose Equivalent (thyroid dose) rates . Again, all other release paths are assumed to be secured . Since the projected site boundary dose rates are based upon assumed meteorological conditions, these levels will serve as a warning to calculate projected doses using actual meteorological conditions in order to properly classify the condition . (5) High range containment radiation monitor levels have been established for the SITE AREA and GENERAL EMERGENCY classifications. These levels are based on 10% and 20% gap release, respectively. The relationship between percentage gap release and containment monitor response values is delineated in NG-88-0966 and CAL-R17-001 . (6) EALs are conservatively established for the SITE AREA EMERGENCY, and ensure that offsite support agency actions are taken in a timely manner. The EALs for the GENERAL EMERGENCY are established to provide a more realistic basis for evacuation or sheltering decisions.

DAECEMERGENCYPLAN SECTION 'D' Rev. ~30 EMERGENCY CLASSIFICATION SYSTEM Page 7 of 10 TABLE D-1 IMMEDIATE ACTION TABULATION NOTIFICATION OF UNUSUAL EVENT NextEra Energy DAEC ACTIONS Class Description 1. Inform local and State authorities and the NRC of the condition, significant actions Events are in progress or have occurred which taken or under way, and any need for indicate a potential degradation of the level of assistance. safety of the plant or indicate a security threat to facility protection has been initiated. No release 2. Augment on-shift resources if required as a of radioactive material requiring offsite response precautionaiy measure. or monitoring are expected unless fmther degradation of safety systems occur. 3. Assess and respond. Purpose 4. Escalate to a more severe classification, if appropriate. The purpose of this classification is to (1) assure that the first step in any response later found to be 5. Notify key organizational personnel based necessary has been carried out, (2) bring the upon plant conditions and the character of the operating staff to a state of readiness, and (3) event, as appropriate. provide systematic

handling of unusual events information and decision making. 6. Establish discussions with NRC, as appropriate.

7. If the abnormal condition becomes more severe, fmther actions to be taken shall be as prescribed for the emergency classification assigned.

Following restoration from the abnormal conditions, the following actions will be taken:

1. Inform local and state public officials of significant actions taken or under way and any need for assistance, as appropriate.

2. Issue a news statement, as appropriate.

DAECEMERGENCYPLAN SECTION 'D' Rev. ~30 EMERGENCY CLASSIFICATION SYSTEM Page 8 of 10 TABLE D-1 IMMEDIATE ACTION TABULATION ALERT NextEra Energy DAEC ACTIONS

1. Promptly inform local and State authorities Class Description and the NRC of the condition, status, and reason for emergency as soon as discovered .

Events are in progress or have occurred which involve an actual or potential substantial 2. Augment resources and activate the degradation of the level of safety of the plant or responders for the Technical Support Center a security event that involves probable life and Operational Support Center. Bring the threatening risk to site personnel or damage to Emergency Operations Facility, Joint site equipment because of HOSTILE ACTION. Information Center, and other key personnel Any releases are expected to be limited to small to standby status or activation. fractions of the EPA Protective Action

3. Assess and respond.

Guideline exposure levels.

4. Determine need to dispatch onsite and offsite Purpose monitoring teams and associated communications.

The purpose of this classification is to (1) assure 5. Provide periodic plant status updates to that emergency personnel are ready, available to offsite authorities. respond if the situation becomes more serious, or to perform confirmato1y radiation monitoring if 6. Provide periodic meteorological assessments required, and (2) provide offsite authorities to offsite authorities and, if any releases are current information. occurring, dose estimates for actual releases.

7. Escalate to a more severe classification, if appropriate.

8. Establish follow up discussions with the NRC.

9. Issue news statements, as appropriate.

10. If the plant condition becomes more severe, further actions to be taken shall be as prescribed for the emergency classification assigned.

Following restoration of the plant to a stable, safe shutdown condition, the following actions will be taken:

1. Inform local and state authorities of close out or reduction of emergency class.

2. Issue a summaiy news statement, as appropriate.

DAECEMERGENCYPLAN SECTION 'D' Rev. 2:9--30 EMERGENCY CLASSIFICATION SYSTEM Page 9 of 10 TABLE D-1 IMMEDIATE ACTION TABULATION SITE AREA EMERGENCY NextEra Energy DAEC ACTIONS

1. Promptly inform local and state authorities Class Description and the NRC of the condition, status, and reason for emergency as soon as discovered.

Events are in progress or have occurred which involve actual or likely major failures of plant 2. Augment resources by activating the functions needed for protection of the public or responders for the Technical Support Center, HOSTILE ACTION that result in intentional Operational Suppo1t Center, Emergency damage or malicious acts; (1) toward site Operations Facility and the Joint Information personnel or equipment that could lead to the Center. likely failure of or; (2) prevents effective access 3. Assess and respond. to equipment needed for the protection of the public. Any releases are not expected to result in 4. Dispatch onsite and offsite monitoring teams exposure levels which exceed EPA Protective and associated communications. Action Guideline exposure levels beyond the 5. Dedicate an individual for plant status site boundaiy. updates to offsite authorities and periodic press briefings. Purpose

6. Make senior technical and management staff The purpose of this classification is to (1) assure onsite available for consultation with the that response centers are staffed, (2) assure that NRC and the State who will contact the DOE monitoring teams are dispatched, (3) assure that and FEMA on a periodic basis.

personnel required for evacuation of near-site 7. Provide meteorological information and dose areas are at duty stations if the situation becomes estimates to offsite authorities for actual more serious, (4) provide consultation with offsite releases. authorities, and (5) provide updates for the public through offsite authorities. 8. Provide release and dose projections based on available plant conditions and foreseeable contingencies.

9. Initiate communications with industry liaison groups (i.e., INPO) to apprise them of the emergency situation.

10. Prepare to conduct press briefings and issue news statements.

11 . Escalate to GENERAL EMERGENCY class, if appropriate.

12. Inform local and state authorities of the closeout or reduction of the emergency class.

DAECEMERGENCYPLAN SECTION 'D' Rev. ~30 EMERGENCY CLASSIFICATION SYSTEM Page 10 of 10 TABLE D-1 IMMEDIATE ACTION TABULATION GENERAL EMERGENCY 7. Provide meteorological information and dose Class Description estimates of actual releases to offsite authorities. Events are in progress or have occurred which involve aetual or imminent substantial eore 8. Provide release and dose projections based on degradation or melting with potential for loss of available plant conditions and foreseeable eontainment integrity or a HOSTILE ACTION contingencies. that results in an actual loss of physical control

9. Maintain communications with industry of the facility,~ or --Rreleases that can be liaison groups to ensure they are fully reasonably expected to exceed EPA Protective apprised of the status of the event and the Action Guideline exposure levels offsite-fef potential ramifications.

more than the immediate site area.

10. Conduct periodic press briefings and issue Purpose news statements to ensure the public is The purpose of this classification is to ( 1) initiate apprised of the status of the event and the predetermined protective actions for the public, actions being taken to minimize its effect (2) provide continuous assessment of plant upon the public and the environment.

information and radiological monitoring 11 . Evaluate the resources and capabilities of the measurements taken by licensee and offsite overall emergency response organizations organizations, (3) initiate additional measures as and restructuring, as appropriate, to assist in indicated by actual or potential releases, ( 4) determining, tracking, and assessing the provide consultation with offsite authorities and environmental consequences of the event. (5) provide updates for the public through offsite authorities. 12. Achieve stable plant conditions. NextEra Energy DAEC ACTIONS 13. Investigate the consequences of the accident.

1. Promptly inform local and state authorities As conditions warrant, the emergency and the NRC of the condition, status, and classification will be downgraded and actions reason for emergency as soon as discovered. specified for the appropriate classification will be continued. Following restoration of the plant to a

2. Augment resources by activating the stable and safe shutdown condition, the following responders for the Technical Supp011 Center, actions shall be taken:

Operational Supp011 Center, Emergency Operations Facility, and the Joint Information I . Inform local and state authorities of closeout Center. or downgrading of the emergency classification.

3. Assess and respond.

2. Issue summary news statement, as 4 . Dispatch onsite and offsite monitoring teams appropriate.

and associated communications.

5. Dedicate an individual for plant status updates to offsite authorities and periodic press briefings.

6. Maintain communications with the NRC.

Make senior technical and management staff onsite available for consultation with the NRC and the State on a periodic basis.

DAECEMERGENCYPLAN SECTION 'E' Rev. 26-27 NOTIFICATION METHODS AND PROCEDURES Page 1 of 7 Usage Level: INFORMATION Record the following: Date I Time: - - - - - - I - - - - Initials: - - - NOTE: User shall perform and document a Temp Issue I Rev. Check to ensure revision is current, in accordance with procedure use and adherence requirements. Prepared By:

             --------                     I - - - - - - - - - - - - Date: - - - -

Print Signature APPROVAL BY EMERGENCY PREPAREDNESS MANAGER Approved By I Date: Print Signature APPROVAL BY ORG Approved By I Date:

                                                                                       -----1 Print                         Signature APPROVAL BY DAEC SITE DIRECTOR Approved By                                 I                                     Date:

Print Signature

DAECEMERGENCYPLAN SECTION 'E' Rev. ~27 NOTIFICATION METHODS AND PROCEDURES Page 2 of 7 Table of Contents 1.0 PURPOSE .. ...... ............... ....... ......... .. ........................ .. ... .. .. ....... ... .............................. .... ...... 3 2.0 REQUIREMENTS .............. ....... ..... ..... .......... ........ ...... ...... ................... ................... .... .... ...... 3 2.1 INITIAL NOTIFICATION ...... ....... .. ... .. ............ .. ... ..... ..... ........................ .......... .. ...... 3 2.2 NOTIFICATION AND ACTIVIATION OF THE ER0 .... .... .. .... .... .... ...... .................... 4 2.3 INITIAL MESSAGES TO OFFSITE AUTHORITIES ............ .. ........... .. .................... 5 2.4 FOLLOW-UP MESSAGES TO OFFSITE AUTHORITIES ...................................... 6 2.5 METHODS OF PROVIDING PROMPT PUBLIC NOTIFICATION .. ......................... 7 2.6 METHODS OF PROVIDING PUBLIC INFORMATION CONCERNING PROTECTIVE MEASURES ................ .... .. .. .................. .. .............. .... ............ .. .. ..... 7

DAECEMERGENCYPLAN SECTION 'E' Rev . ~27 NOTIFICATION METHODS AND PROCEDURES Page 3 of 7 1.0 PURPOSE (1) This section describes the methods and procedures used by NEE Duane Arnold to transmit emergency information to the Emergency Response Organization, local and state authorities, and subsequently, from such authorities to the public. Details required in the initial and follow-up message are described, along with a description of the types of news statements that will be used to provide the public with information and protective actions. 2.0 REQUIREMENTS (1) Methods used to accomplish notification of the Emergency Response Organization include the use of call lists contained in the Emergency Telephone Book, pager and automated telephone callout process. (2) The Emergency Telephone Book includes phone numbers and pager numbers (where applicable) of emergency response personnel who may be required to respond to an emergency condition. It also includes the 24-hour telephone numbers of local, state, and federal support agencies including the NRC. The NRC would normally be notified using the NRC ENS Telephone (FTS-2001 System) from the Control Room. The state and counties would normally be notified by a dedicated telecommunications link. 2.1 INITIAL NOTIFICATION (1) After declaration of an emergency condition , the Operations Shift Manager/ Supervisor will ensure that the following personnel and agencies are notified:

Linn and Benton Counties
State of Iowa
NRC Operations Center
Emergency Coordinator
Emergency Response and Recovery Director
NRC Resident Inspectors (2) Verification of Notification (a) The authenticity of initial notifications provided to Linn and Benton Counties and the State of Iowa do not require verification if the notification is made by the dedicated phone system.

(b) Local and state agencies notified by commercial communication system (telephone or facsimile) may require verification of the identity and authenticity of the caller and the message received .

DAECEMERGENCYPLAN SECTION 'E' Rev. ~27 NOTIFICATION METHODS AND PROCEDURES Page 4 of 7 2.2 NOTIFICATION AND ACTIVATION OF THE ERO (1) NOTIFICATION OF UNUSUAL EVENT (a) Activation of emergency facilities (refer to Section H), such as the TSC, the OSC, the EOF, or the JIC will be as directed by the Emergency Coordinator, ER&RD, and JIC Manager, respectively. Normally, these emergency facilities will not be activated for a NOTIFICATION OF UNUSUAL EVENT, but may be, if escalation of the emergency class appears to be imminent. (2) ALERT, SITE AREA EMERGENCY, OR GENERAL EMERGENCY (a) The Operations Shift Manager/Control Room Supervisor, or another member of the shift operating crew, at the direction of the Operations Shift Manager/Control Room Supervisor, shall notify onsite personnel by activation of a distinctive tone alarm over the public address system, followed by an announcement over the public address system . Off-duty emergency response personnel will be notified in accordance with the EPIPs describing notification and call out of off-duty personnel. The Emergency Telephone Book contains the telephone numbers and, if applicable, pager numbers of emergency response personnel. (b) The on site Emergency Response Organization personnel shall initially report to the TSC and the OSC at an Alert or higher classification . As personnel arrive at the Operational Support Center, they should select their own nameplate and place it into their response position. The instructions are designated in Emergency Plan Implementing Procedures and cover radiological survey, monitoring, communication, record-keeping, rescue, and emergency repair efforts. (c) The Emergency Coordinator will initiate notification of the following emergency response officials and agencies and provide them with additional information, as appropriate, until relieved by the ER&RD:

Local , state and federal governmental officials and support agency management personnel, as warranted, based upon the severity and potential ramifications of the event,
INPO Emergency Response Center.
Further information and instructions are provided in the supporting implementing procedures.

(d) Onsite personnel who staff the EOF and the JIC will report to their facilities at an Alert classification . The ER&RD in conjunction with the JIC Manager will determine when the EOF and JIC will be activated as indicated in the EPIPs.

DAEC EMERGENCYPLAN SECTION 'E' Rev. ~27 NOTIFICATION METHODS AND PROCEDURES Page 5 of 7 2.3 INITIAL MESSAGES TO OFFSITE AUTHORITIES (1) The initial notification message relayed to offsite authorities will provide the following information:

Caller identification/location.
Event classification, EAL number, and time of declaration .
If radiological release is in progress, type of release and projected duration of release and if airborne release, state whether the release is filtered or unfiltered .
Wind direction and wind speed .
Recommended protective actions, if any.
Assistance, if any, which may be required .

I l DAEC EMERGENCY PLAN SECTION 'E' Rev. ~27 NOTIFICATION METHODS AND PROCEDURES Page 6 of 7 2.4 FOLLOW-UP MESSAGES TO OFFSITE AUTHORITIES (1) After initial notifications have been made from the DAEC to the various offsite organizations, responsibility for communications with offsite agencies will normally be assumed by the TSC until the EOF is staffed. (2) The following information will be provided if known and appropriate to the circumstances:

Location of incident and name of caller.
Date/time of incident.
Emergency classification.
Type of actual or projected release (airborne, waterborne, surface spill) and estimated duration/impact times, filtered or unfiltered if the release is an airborne release.
Estimate of quantity of radioactive material released or being released and the point of release.
Chemical and physical form of released material, including estimates of the relative quantities and concentrations of noble gases, iodines, and particulates.
Meteorological conditions (wind velocity, direction, temperature , atmospheric stability data, form of precipitation, if any).
Actual or projected dose rates and integrated doses at the site boundary; and at about 2, 5, and 10 miles.
Estimates of any surface radioactive contamination in the plant, onsite or offsite.
Emergency response actions under way.
Recommended emergency actions, including protective measures.
Requests for any needed onsite support by offsite organizations.
Prognosis of event based on plant information .

DAECEMERGENCYPLAN SECTION 'E' Rev. W--27 NOTIFICATION METHODS AND PROCEDURES Page 7 of 7 2.5 METHODS OF PROVIDING PROMPT PUBLIC NOTIFICATION (1) A fixed offsite siren warning system providing an audible alert has been installed within the DAEC Plume Exposure Emergency Planning Zone (EPZ) . The EPZ includes subareas and is defined in Section I of this plan, Figure 1-1 . The audible warning sirens will alert the populace to listen to radios or televisions for detailed information. (2) The offsite warning system is designed to alert essentially 100% of the population in the DAEC EPZ. Activation of the system can be accomplished within fifteen minutes of issuance of an advisory from the Linn County Emergency Management Agency, Linn County Sheriff's Office, Benton County Emergency Management Agency, or Benton County Sheriffs Department. Each county can act as a backup to the other. (3) In the unlikely event that one or more sirens would fail to activate, the State of Iowa and Linn and Benton Counties maintain a backup Alert and Notification System that will alert the public in affected areas. This system covering the EPZ is achieved through physical route alerting, which is contained in the State of Iowa Radiological Emergency Response Plan and in Linn and Benton County's Radiological Emergency Response Plans and procedures. These plans and procedures are approved by FEMA in accordance with 44CFR350.12 and 14. 2.6 METHODS OF PROVIDING PUBLIC INFORMATION CONCERNING PROTECTIVE MEASURES (1) Section 2.5 identifies the methods to be used to notify the public, specifically those in the plume exposure pathway EPZ, of the occurrence of an emergency event. Recommendations regarding protective measures to be implemented for the population at risk will be provided to both county and state officials by the Emergency Coordinator prior to EOF activation, then by the Radiological Assessment Coordinator (RAC). Initial information to expedite the taking of protective measures by the public will be provided by using the Emergency Alert System (EAS) . (2) Messages to the public generated by a computerized EAS message generation system, will include appropriate aspects of protection; e.g., sheltering, ad hoc respiratory protection or evacuation . Formatted messages are included in the county plans and are the responsibility of Linn and Benton County Emergency Management Agencies.

DAECEMERGENCYPLAN SECTION 'F' Rev. ~31 EMERGENCY COMMUNICATIONS Page 1 of 17 Usage Level: INFORMATION Record the following : Date I Time: ~~~~~- I - - - - Initials: - - - NOTE: User shall perform and document a Temp Issue I Rev. Check to ensure revision is current, in accordance with procedure use and adherence requirements. Prepared By: Date: - - - -

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DAECEMERGENCYPLAN SECTION 'F' Rev. JG-.-31 EMERGENCY COMMUNICATIONS Page 2 of 17 Table of Contents 1.0 PURPOSE ................................................................ .................. .......................................... 3 2.0 REQUIREMENTS ....... .. ............................................... ................................... .. .. ... ... .. .......... 3 2.1 GENERAL DESCRIPTION OF NEE DUANE ARNOLD COMMUNICATIONS SYSTEMS ......... ... ......... .... ........ .... .......... ...... .... ................... ............. ... ......... ......... 3 2.2 NOTIFICATION OF LOCAL/STATE EMERGENCY RESPONSE NETWORK .. ...... ? 2.3 COMMUNICATIONS WITH CONTIGUOUS LOCAL/STATE AUTHORITIES .. ....... 7 2.4 NEE DUANE ARNOLD COMMUNICATIONS WITH NRC ................ .... .. .. .. .. .......... 7 2.5 COMMUNICATIONS BETWEEN EOCs AND FIELD ASSESSMENT TEAMS ....... 7 2.6 ACTIVATING EMERGENCY RESPONSE PERSONNEL ............................... .. ..... 7

2. 7 MEDICAL COMMUNICATIONS ............... .............. .... ... .. ......... .. ... ... ...... ........... .. ... 8 2.8 PERIODIC TESTS OF COMMUNICATIONS SYSTEMS ...... .. .. ... .. ................ .... ..... 8 TABLE F-1 COMMUNICATIONS PRIMARY AND ALTERNATE CONTACTS ............................ 9 FIGURE F-1 DAEC RADIOLOGICAL SURVEY RADIO SYSTEM ..................... .. ..................... 11 FIGURE F-2 PLANT OPERATIONS RADIO SYSTEM ........ .. .. .. .. .. .. .. ...... .. .... .. ........ .... ...... ... .. ... 12 FIGURE F-3 POINT-TO-POINT RADIO SYSTEM ...... .. .............. .. ..... .. ................ .. ..... .. ... ......... 13 FIGURE F-4 MICROWAVE FACILITIES .. .. ... .................... ... .. ... ..... ............... .. ....................... ... 14 FIGURE F-5 DAEC TELEPHONE SYSTEMS .... ...... .. .... .. ............................. .. ...... .. ........ .. .. .. .... 15 FIGURE F-6 FEDERAL TELEPHONE SYSTEM {FTS-2001) ............... .. ........................... .. .. .. .. 16 FIGURE F-7 ALL-CALL TELEPHONE SYSTEM .... ................................................................... 17

DAECEMERGENCYPLAN SECTION 'F' Rev. W-31 EMERGENCY COMMUNICATIONS Page 3 of 17 1.0 PURPOSE (1) This section describes the DAEC emergency communications systems and communications links between the NEE Duane Arnold and other response organizations. 2.0 REQUIREMENTS 2.1 GENERAL DESCRIPTION OF NEE DUANE ARNOLD COMMUNICATIONS SYSTEMS (1) DAEC Radiological Survey Radio System (a) This radio system (Figure F-1) provides base-to-portable communications for conducting radiological surveys throughout the DAEC plume exposure EPZ. The base station is a mobile relay (repeater) type using two VHF frequencies for a single frequency simplex talk-around, or for monitoring short range portable-to-portable communications in the event the base station is inoperative for a short period of time. (b) The installation meets the following functional requirements and limitations: (i) Installation of the radio base station equipment in a secure area (ii) Wide area coverage for radiological survey communications (c) The base station is controlled from the Technical Support Center, and Emergency Operations Facility. (i) The portable radios used are the hand-held type. (ii) The base station radios provide the following channels:

DAEC "Field Team" Repeater
DAEC "Maintenance" Repeater
DAEC "Security Call" Simplex
DAEC "Operations" UHF repeater
Linn County Fire
Point to Point (iii) All channels transmit continuous tone-coded squelch.

(iv) The hand-held portables are primarily utilized on the VHF "field team" repeater channel and can be used for communication between personnel on foot, mobiles, and the TSC EOF base stations.

DAECEMERGENCYPLAN SECTION 'F' Rev. W--31 EMERGENCY COMMUNICATIONS Page 4of17 (v) In addition, the DAEC Radiological Survey teams have three vehicles equipped with a 50-watt radio transceiver for communications to the DAEC at distances greater than obtainable with the high power portables. (vi) In addition to the attributes listed above the DAEC Security department has the ability to cross patch the frequencies listed above to specific LLEA frequencies if the need should arise during an emergency event. The details surrounding the capabilities of the security radio system are sensitive in nature and are not included in this document. (2) DAEC (Backup Radiological Survey) Radio System (a) This radio system provides backup capability for the VHF radio listed in (1) and provides base-to-portable communications for conducting radiological surveys throughout the DAEC plume exposure EPZ. The backup system is an 800 MHz trunked repeater system. The 800 MHz tower infrastructure is located on a tower at 1000 27th Avenue SW, Cedar Rapids, IA 52404. Two RadioPro Console PC-based dispatch radios support this system . One is located in the DAEC Technical Support Center (TSC), and a second identical dispatch radio is located in the Emergency Operations Facility (EOF) at the Alliant Tower. (3) Plant Operations Radio (a) Figure F-2 illustrates the plant operations radio system which consists of a UHF base station connected to an omni-directional antenna. Seven remote control units are associated with this base station, located in the Control Room, Control Room Backpanel, Technical Support Center, Secondary Alarm Station , Security Control Point, and the Central Alarm Station. Hand-held transceivers are used in this system to provide simplex communications within the plant and onsite. (4) Point-to-Point Radio System (a) The DAEC also has a base station licensed for operation in the Police Radio Service on the law enforcement statewide, point-to-point VHF frequency, as illustrated in Figure F-3. The transmitter and one control console are located at the Secondary Alarm Station, the Central Alarm Station, and Security Control Point. This station is for communications with the Iowa Department of Public Safety radio station, Linn County Sheriff's office, Benton County Sheriff's office, and the Cedar Rapids Fire Department, and uses a two-tone sequential signal to alert the latter two public-safety stations. This point-to-point channel is also used by the Linn County Emergency Management and other public safety organizations throughout the state of Iowa.

DAEC EMERGENCY PLAN SECTION 'F' Rev. JG-31 EMERGENCY COMMUNICATIONS Page 5 of 17 (5) ERO Notificatic;in systems NEE Duane Arnold has multiple methods to contact designated ERO members in the event of an emergency. All ERO members will be contacted via a phone call to their home or cell phone as needed. All management personnel filling a key ERO duty position will also have one of the following two methods available. (a) A pocket-radio paging system, operated and maintained by a local contractor. The system is designed to enable simultaneous contact of such personnel in the event of an emergency. (b) Cell phones or other similar devices that are programmed to be automatically contacted in the event of an emergency. (6) Microwave Facilities (a) NEE Duane Arnold, with a group of Iowa utilities, participates in a shared microwave system, a portion of which is illustrated in Figure F-4. The hub of this system is located at the Alliant Tower in Cedar Rapids. A westerly path extends from Cedar Rapids to the DAEC and contains 24 channels used for outdial telephone , which connect the NEE Duane Arnold phone system in Cedar Rapids to the DAEC phone system . (b) Additional microwave facilities provide paths east and west from the DAEC through the Alliant Energy substations at Vinton, Dysart, Traer, Wellsburg, and Marshalltown to complete the microwave loop system from Cedar Rapids. This enables a greater degree of reliability since loop switching equipment is installed at all microwave repeaters in the loop. Thus, if one microwave path becomes inoperative, signals will be switched continuing to provide communications to all points around the loop. (7) Telephone Facilities (a) Figure F-5 illustrates the telephone system. The system is operated and maintained by the Local Telephone Company and the regional provider which serves the Alliant Tower. (b) The DAEC PBX is connected to the central office by 20 active Central Office (CO) trunk lines, 48 long distance trunks, 23 duplex dial trunks, and 24 direct dial trunk lines. The PBX also contains six direct-dial tie trunks to the microwave terminal at the DAEC Substation . The PBX currently handles approximately 1,500 telephone stations. (c) There are 4 emergency lines with unlisted numbers which connect directly to the Control Room and several offices but do not connect through the PBX. (d) There are 6 dedicated telecommunications circuits which bypass the local system switch in the EOF and directly connect to the public switched network provided by a regional communications provider. There are seven data lines used for computer operations which do not connect through the PBX.

DAEC EMERG ENCYPLAN SECTION 'F' Rev. W--31 EMERG ENCY COMMUNICATIONS Page 6 of 17 (e) A LAN/Internet system with satellite backup connects the Linn County EOC and Sheriff's office, the Benton County EOC and Sheriff's office, the State of Iowa EOC, the EOF, the TSC, the Simulator, and the Control Room into a private telephone network referred to as the DAEC All-Call . See Figure F-7. (f) Redundant fiber connects the DAEC to the central office. This fiber terminates at the DAC Computer Room . (g) A Fixed Cell Phone System connects the DAEC Control Room and TSC with the Shellsburg Cell tower via exterior antenna. This phone system has a UPS power supply in the event of a loss of power. (h) A Control Room Satellite Phone System connects the DAEC Control Room to a communications satellite. This phone system provides redundancy from the other DAEC phone systems. (i) The Emergency Operations Facility has available: (i) Dedicated circuits to the NRC on the Federal Telecommunications system FTS-2001 (ii) PBX connectivity to DAEC through dedicated circuitry provided by a local and regional provider (iii) External phone service , separate from DAEC, provided by a separate regional provider (iv) An All-Call System that provides a communication path between the Control Room , Technical Support Center, Simulator, Emergency Operations Facility, Iowa Homeland Security and Emergency Management Division , Benton County and Linn County Emergency Operations Centers, Benton County and Linn County Sheriff 911 Dispatch Centers via LAN/Internet with satellite backup capabilities U) The NRC ENS and NRC HPN telephones are both installed and functioning . Both telephones are connected to the Federal Telephone System (FTS-2001) . The NRC ENS telephones are located in the Control Room, TSC, and EOF which gives those facilities the capability to contact NRC Headquarters in Rockville, MD. The NRC HPN telephones are located in the TSC and EOF and can be used to call regional NRC offices, the NRC Headquarters, or other sites within the region . (8) Emergency Microwave Facilities (a) Personnel Contacts for Communications Links (i) Table F-1 lists the primary and alternate communication contacts between NEE Duane Arnold emergency facilities and supporting local, State, and Federal agencies. The communications links are those identified in Figures F-1 through F-4. Table F-1 also identifies, by title, the principal and alternate contacts at each end of each communications link.

DAECEMERGENCYPLAN SECTION 'F' Rev. ~31 EMERGENCY COMMUNICATIONS Page 7 of 17 2.2 NOTIFICATION OF LOCAL/STATE EMERGENCY RESPONSE NETWORK (1) As mentioned in Section A, both the Linn County and Benton County Sheriff's Communications Centers are staffed on a continuous basis and may be notified from the DAEC and the EOF by the "DAEC All-Call" telephone , conventional telephone, or facsimile transmission of a condition requiring a response. The State Emergency Operations Center may be notified from the DAEC and the EOF by telephone and facsimile through the Iowa Homeland Security and Emergency Management Division, Iowa Department of Public Defense, by radio through the Department of Public Safety Communications, or by use of the "DAEC All-Call" telephone. 2.3 COMMUNICATIONS WITH CONTIGUOUS LOCAL/STATE AUTHORITIES (1) After the initial notification of an emergency condition and once the Technical Support Center and Emergency Operations Facility are operational, the Technical Support Center will be the principal onsite communications interface while the Emergency Operations Facility will be the principal offsite communications interface. Communications between local and state agencies and NEE Duane Arnold emergency facilities may be by telephone (normal and dedicated lines), network, satellite, or radio as discussed in Section 2.2. 2.4 NEE DUANE ARNOLD COMMUNICATIONS WITH NRC (1) DAEC E-Plan Section E discusses notification methods and procedures. Paragraph 2.1 of this Section F and Figures F-2, F-3, F-4, and F-5 describe the provisions for communicating between NEE Duane Arnold emergency facilities . The NRC will be notified of an emergency condition through the use of the FTS-2001 System (Federal Telecommunications System) . The FTS-2001 network provides a separate government network for all essential communications functions to the NRC . Details of the use and operation of the FTS-2001 can be found in the DAEC Emergency Plan Implementing Procedures. (See diagram on Figure F-6) 2.5 COMMUNICATIONS BETWEEN EOCs AND FIELD ASSESSMENT TEAMS (1) Section 2.1 discusses, and Figures F-1 through F-4 illustrate, the provisions for communicating between each emergency center (NEE Duane Arnold, county and state) and with field assessment teams monitoring the offsite radiological impact of the emergency. 2.6 ACTIVATING EMERGENCY RESPONSE PERSONNEL (1) DAEC E-Plan Section E discusses notification methods and procedures for offsite authorities. DAEC E-Plan Section A discusses the interrelationships between response organizations and Figure A-1 illustrates activation and notification lines of responsibility. Figures F-1 through F-4 and Paragraph 2.1 of this section describe the systems for notifying response personnel from onsite and offsite Emergency Response Organizations.

DAECEMERGENCYPLAN SECTION 'F' Rev. JG..-31 EMERGENCY COMMUNICATIONS Page 8 of 17 2.7 MEDICAL COMMUNICATIONS (1) Communications with the primary and secondary medical facilities will be accomplished through the use of commercial telephone system. Communications with the ambulance will be accomplished through the use of the Linn County fire frequency radio network. 2.8 PERIODIC TESTS OF COMMUNICATIONS SYSTEMS (1) Periodic tests will be conducted to determine the operability of the communications systems discussed in this section. A test (preferably in conjunction with the exercise addressed in DAEC E-Plan Section N) will be performed to test all communications links and notification procedures and the system used to alert the public. The NRC ENS, NRC HPN, and the other telephone lines in the FTS-2001 network will be tested on a monthly basis. The Emergency Response Data System (EROS) will be tested quarterly by establishing a link with the NRC EROS system.

DAEC EMERGENCY PLAN SECTION 'F' Rev. ~3 1 EMERGENCY COMMUNICATIONS Page 9 of 17 TABLE F-1 COMMUNICATIONS PRIMARY AND ALTERNATE CONTACTS ORGANIZATION/FACILITY PRIMARY CONTACT ALTERNATE CONTACT

1. NEE Duane Arnold

a. Emergency Operations Emergency Response & Radiological Assessment Facility Recovery Director Coordinator

b. Technical Support Center Emergency Coordinator Technical and Engineering Supervisor

c. Operational Support Operational Support Center l&Gte:M, Mesl=laRisal Center Supervisor MaiRteRaRse Supervisors or HP Supervisor

d. Control Room and Alarm Operations Shift TSC Operations Stations ManagerJSupervisor Supervisorliaison

2. LOCAL AGENCIES

a. Linn County Sheriff's County Emergency Management Sheriff's Office Communications Office and Emergency Coordinator Center Operator Management

b. Benton County Sheriff's County Emergency Management Sheriff's Office Communications Office and Emergency Coordinator Center Operator Mgmt.

c. Palo Fire Department Sheriffs Office Communications Center

d. Mercy Medical Center Emergency Room Desk Sheriff's Office Communications Center Operator

e. University of Iowa Emergency Room Desk Hospitals and Clinics

f. Center Point Ambulance Sheriff's Office Communications Center Operator

g. Hiawatha Ambulance Sheriff's Office Communications Center Operator

h. Area Ambulance Sheriff's Office Communications Center Operator

i. Linn County Sheriff's Linn County Sheriffs Dispatcher Rescue

DAECEMERGENCYPLAN SECTION 'F' Rev. JG-31 EMERGENCY COMMUNICATIONS Page 10 of 17 TABLE F-1 COMMUNICATIONS PRIMARY AND ALTERNATE CONTACTS ORGANIZATION/FACILITY PRIMARY CONTACT AL TERNA TE CONTACT

3. STATE AGENCIES

a. Iowa Homeland Security Iowa Homeland Security and Department of Public Safety, and Emergency Emergency Management Communications Station Management Division, Division Administrator Iowa Dept of Public Defense

b. University of Iowa University Telephone Operator

3. FEDERAL AGENCIES

a. NRC Duty Officer NRC Region Ill Office in (Rockville, Maryland) Lisle, Illinois

b. Department of Energy Regional Office in Chicago, Illinois

c. Federal Emergency Contacted by State of Iowa, Federal Emergency Management Agency Iowa Homeland Security and Management Agency, Region Emergency Mgmt. Division , VII ,

Iowa Dept of Public Defense Kansas City, Missouri

DAEC EMERGENCY PLAN SECTION 'F' Rev. JG.-31 EMERGENCY COMMUNICATIONS Page 11 of 17 FIGURE F-1 DAEC RADIOLOGICAL SURVEY RADIO SYSTEM Radiological Radiological Survey Survey Mobil/Portable DAEC VHF Mobil/Portable

     #1                                        Maintenance                                                   #2 Repeater I
                                                                      '                                       I I

I ' I ' ', I I ' I I ' I I I I ' I I '

                                      ~~----~~

VHF Field Team ' Repeater TSC VHF DAEC EOFVHF Control Security Control

                                                                  -----------                          Station Station DAEC                                   ',    Point to Point to Operation                                       See Figure F4 UHF

DAECEMERGENCYPLAN SECTION 'F' Rev. W--31 EMERGENCY COMMUNICATIONS Page 12of17 FIGURE F-2 PLANT OPERATIONS RADIO SYSTEM HAND-HELD TRANSCIEVERS DISTRIBUTED TO APPROPRIATE PERSONNEL THROUGHOUT THE PLANT DAEC TRANSMITTER AND REC IEVER CONTROL ROOM SECURITY CONTROL BACKPANELS POINT SECONDARY ALARM STATION CENTRAL ALARM CONTROL ROOM STATION TRANSMITTER AND CONTROL CONSOLE EMERGENCY TECHNICAL OPERATIONS SUPPORT CENTER FACILITY

DAECEMERGENCYPLAN SECTION 'F' Rev. JG-.-31 EMERGENCY COMMUNICATIONS Page 13of17 FIGURE F-3 POINT-TO-POINT RADIO SYSTEM x x x x I I I I LINN CO. IOWADEPT. CEDAR RAPIDS BENTON CO . SHERIFF'S OF PUBLIC FIRE SHERIFF'S OFFICE SAFETY DEPARTMENT OFFICE x x I I LINN COUNTY OTHER STATE EMERGENCY MANAGEMENT PUBLIC SAFETY ORGANIZATIONS ORGANIZATIONS x

                                   -       I DAEC TRANSMITTER AND RECEIVER SECONDARY                                      CENTRAL                    SECURITY ALARM                                       ALARM                     CONTROL STATION                                     STATION                      POINT Transmitter and                              Transmitter and Control Console                              Control Console

DAECEMERGENCYPLAN SECTION 'F' Rev. JG.-31 EMERGENCY COMMUNICATIONS Page 14of17 FIGURE F-4 MICROWAVE FACILITIES VINTON NORTH MICROWAVE SYSTEM DYSART EAST DAEC MICROWAVE SYSTEM Digital Microwave TRAER Computer Link - - 1 CORNBEL T POWER COOPERATIVE SYSTEM WELLSBURG ALLIANT TOWER IOWA FALLS MARSHALL TOWN STONEY POINT WEST SOUTH MICROWAVE MICROWAVE TOLEDO BELLE PLAINE CONTINUED SYSTEM JUNCTION LOCAL FIBER OPTIC TO SUBSTATIONS & CR OPERATING PRAIRIE CREEK CENTER

DAECEMERGENCYPLAN SECTION 'F' Rev. 30 Rev. 31 EMERGENCY COMMUNICATIONS Page 15 of 17 FIGURE F-5 DAEC TELEPHONE SYSTEMS

                                                                              -------------1 Ir----,                                         1 I I                I                           I J..,__.,

Shellsburg I Satellite Communications Cell Tower

                                                                                     /
                                                                                 /
                                                                            /
                                                                         /
                                                                      /                                                            Offs lte
                                                                   /

DAEC Laboratory and PBX Decontamination Room Center 4 emergency Microwave unlisted llnes (Blue Phones) in to Alliant Control Room . TSC. CAS, SAS Joint Public Tower Information Center Local Telephone Company j Alliant Tower (1)-EOF Central Office Microwave to DAEC

FPLE Duane Arnold Corporate Offices

- County Sheriff's Oflices

Palo Fire Department
Mercy Hospital
State Highway Patrol Qwest Emergency Operations
State Emergency Management Division (Cedar Rapids} Facility
Univmlty of lowa "NRC
DOE Nonna I

'FEMA Telephone

Linn County Emergency Management (1) Denotes a Dedicated Services To Other BeU
Benton County Emergency Management Line Central Offices

DAEC EMERGENCY PLAN SECTION 'F' Rev. 30 Rev. 31 EMERGENCY COMMUNICATIONS Page 16of17 FIGURE F-6 FEDERAL TELEPHONE SYSTEM (FTS-2001) NRC EROS DAEC EOF Local !<J----{> Icomputer Room TSC (i) ENS HPN @ RSCL © PMCL MCL

DAEC EMERGENCY PLAN SECTION 'F' Rev. 30 Rev. 31 EMERG ENCY COMMUNICATIONS Page 17 of 17 FIGURE F-7 ALL-CALL TELEPHONE SYSTEM Internet EOC Sheriffs Office Backup f acility Ma in Facility 1 - -- ,..\FA. Satellite L--~~~~~~~~~~

DAECEMERGENCYPLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev. ~39 EQUIPMENT Page 1 of 26 Usage Level INFORMATION Record the following : Date I Time: _ _ _ _ _ _ I _ _ _ _ Initials: _ __ NOTE: User shall perform and document a Temp Issue I Rev. Check to ensure revision is current, in accordance with procedure use and adherence requirements. Prepared By: Date:

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             - - - - -- - - - -            I - -- - - - - - - - - - Date:              ----~

Print Signature APPROVAL BY ORG Approved By I Date: -------i Print Signature APPROVAL BY DAEC SITE DIRECTOR Approved By I Date: - - -----i Print Signature

DAECEMERGENCYPLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev. ~39 EQUIPMENT Page 2 of 26 Table of Contents Section Numbers Section Titles Page 1.0 PURPOSE 3 2.0 REQUIREMENTS 3 2.1 TECHNICAL SUPPORT CENTER {TSC) 3 2.2 OPERATIONAL SUPPORT CENTER (OSC) 4 2.3 EMERGENCY OPERATIONS FACILITY (EOF) 5 2.4 JOINT INFORMATION CENTER (JIC) 7 2.5 OFFSITE RELOCATION AND ASSEMBLY AREA (ORAA) 8 2.6 ALTERNATIVE FACILITIES 9 2.7 STATE HYGENIC LABORATORY (SHL) 9 2.8 ONSITE MONITORING SYSTEMS 10 2.9 METEOROLOGICAL INSTRUMENTATION AND PROCEDURES 13 2.10 SEISMIC AND HYDROLOGICAL INSTRUMENTATION 13 2.11 CONTROL OF EMERGENCY EQUIPMENT/INSTRUMENTS 14 2.12 COMMUNICATION CHECKS 14 2.13 EMERGENCY KITS 14 2.14 RECEIPT AND ANALYSIS OF FIELD MONITORING DATA 14 RADIOLOGICAL MONITORING SAMPLING STATION TABLE H-1 15 LOCATIONS TABLE H-2 RADIOLOGICAL MONITORING LOCATIONS 16 FIGURE H-1 TSC/OSC FLOOR PLAN (Typical) 17 FIGURE H-2 EOF FLOOR PLAN (Typical) 18 FIGURE H-3 19 (DELETED) FIGURE H-4 DIRECTIONS TO ORAA 20 FIGURE H-5 21 (DELETED) FIGURE H-6 22 (DELETED) FIGURE H-7 JIC 6TH FLOOR PLAN (Typical) 23 FIGURE H-8 JIC 15TH FLOOR PLAN {Typical) 24 FIGURE H-9 25 (DELETED) FIGURE H-10 DIRECTIONS TO THE STATE HYGENIC LAB (SHL) 26

DAECEMERGENCYPLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev. J&-39 EQUIPMENT Page 3 of 26 1.0 PURPOSE (1) This section describes the DAEC Emergency Response Organization (ERO) emergency facilities, staffing and activation, and equipment required for support of emergency events. 2.0 REQUIREMENTS (1) Emergency response facilities will be activated according to the notification and activation procedures described in the EPIPs. Personnel who are assigned to each facility either appear on call or notification lists used for notification purposes, or by procedure and training , will automatically report to a predesignated area upon declaration of the appropriate Emergency Classification . Each key emergency organization position is assigned a minimum of two qualified persons to ensure complete facility staffing. Whenever possible, three qualified persons will be assigned. (2) Support facilities and organizations will be activated as described regardless of the time of day or day of the week. However, it should be recognized that the normal plant staff is only at the site approximately 25% of the time . As a result, as many functions as possible will be assumed by the shift operating crew until support facilities are established and off-duty personnel arrive on site. Sufficient plant staff and corporate personnel will be trained and qualified to staff the appropriate facilities to ensure that they will be established and operational in a timely manner. The Emergency Response Organization is shown in Figure B-1 and also in the Emergency Telephone Book. 2.1 TECHNICAL SUPPORT CENTER (TSC) (1) General Description (a) The TSC is located in a facility adjacent to the DAEC Administration Building and is staffed by plant management and technical personnel to provide technical support for Control Room activities. The facility has the capability to transmit and record vital plant data in real time and provides access to as-built plant drawings and other records. Computerized dose projections can be performed from a computer terminal available in the TSC . The program (MIDAS) has real-time access to data from the plant effluent and meteorological monitoring systems. The Safety Parameter Display System (SPDS), which displays critical plant parameters monitored by the process computer, is available in the TSC. Additionally, plant parameters and status information of significance to the event can be transmitted using a VAX computer terminal as well as telephone and radio. Also available is the Emergency Response Data System (EROS) which displays live-time plant data. The TSC is the main communications link between the plant and the Emergency Operations Facility (EOF) . The location and floor plan are shown in Figures H-1 and H-2, respectively. The Control Room is designated as the alternate TSC. Communication links between the TSC, Operational Support Center (OSC), Control Room , EOF, and the Nuclear Regulatory Commission (NRC) are described in Section F.

DAECEMERGENCYPLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev. ~39 EQUIPMENT Page 4 of 26 (2) Activation Criteria (a) Declaration of an ALERT or higher emergency classification requires activation of the TSC. The Operations Shift Manager (OSM) will authorize initiation of the notification chain according to procedure. Members of the Emergency Response Organization assigned to the TSC will be notified by plant page, extension number, commercial phone, pager or automated telephone system. During off-hours, members of the Emergency Response Organization assigned to the TSC will be contacted by pager and/or commercial telephone. A call list is provided for this purpose. Upon receiving notification of an Emergency Classification which requires activation of the TSC, each individual contacted will immediately report to the TSC to begin activation tasks. (b) The TSC is activated at an ALERT, SITE AREA EMERGENCY or GENERAL EMERGENCY. Activation of the TSC for a NOTIFICATION OF UNUSUAL EVENT is at the discretion of the OSM or Emergency Coordinator. (3) Staffing (a) The Emergency Coordinator exercises supervision and direction over the personnel assigned to the TSC. Personnel assigned to the TSC will include: selected members of the plant staff who are knowledgeable in specific functional areas at the DAEC, selected engineering personnel who can assist in providing engineering evaluations, and representatives from the NRC. (4) Habitability (a) The TSC is designed and constructed to provide the shielding necessary to protect occupants from radiation effects from either the reactor core or the plume. An independent ventilation system can be placed in a recirculation mode of operation, enabling air to be continually filtered through both charcoal and HEPA filters. Radiation monitors are provided at the ventilation system intake and within the TSC proper. In the event of radiological releases, portable air sampling equipment is available that will enable periodic checks to be made of airborne radiological conditions. 2.2 OPERATIONAL SUPPORT CENTER (OSC) (1) General Description (a) The OSC is located in a facility adjacent to the DAEC Administration Building and its floor plan is illustrated in Figure H-1. This center will be used to assemble and dispatch onsite and offsite radiation monitoring teams, and to coordinate in-plant survey efforts, rescue and emergency teams, and personnel who support Control Room emergency activities. This center will be in communication with the TSC and Control Room. Portable environmental sampling and monitoring equipment is stored near this facility to support radiation monitoring teams. This facility provides ready access to evacuation routes.

DAECEMERGENCYPLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev. ~39 EQUIPMENT Page 5 of 26 (2) Activation Criteria (a) Activation of the OSC occurs in a similar fashion to the TSC. Upon declaration of an ALERT or higher emergency classification, the OSM will initiate the notification process. Individuals will either report to the OSC when notified, or will automatically report when an emergency classification is declared that requires OSC activation . Those assigned to the OSC will be notified by plant page, extension number, commercial phone, pager or automated telephone system . During off-hours, individuals assigned to the OSC will be contacted by pager, commercial telephone, or automated telephone system . (b) The OSC is activated at an ALERT, SITE AREA EMERGENCY, or GENERAL EMERGENCY is declared. Activation of the OSC for a NOTIFICATION OF UNUSUAL EVENT is at the discretion of the EC. (3) Staffing (a) The OSC Supervisor exercises overall supervision and direction for all emergency response personnel on site who are not members of the operations shift crew or assigned to other emergency response facilities. Onsite and offsite field radiological monitoring teams , rescue and repair teams , in-plant radiological survey assignments, and communicator assignments are established at the OSC using an Emergency Assignment Tag Board . This method is further described in the EPIPs. (4) Habitability (a) Sections I and K describe the systems and methods for monitoring radiological conditions in the OSC. Emergency kits at or near the OSC provide respiratory protection , protective clothing , decontamination capabilities, and portable sampling and monitoring devices. First-aid supplies are available from the first aid room . Decontamination is performed at the access control area. Radios, onsite and offsite telephones, and intraplant telephones are available in this center. 2.3 EMERGENCY OPERATIONS FACILITY (EOF) (1) General Description (a) The EOF depicted in Figure H-2 is a dedicated facility located on the 15th floor of the Alliant Tower in Cedar Rapids. This facility is operated by Duane Arnold for the continued evaluation and coordination of emergencies having actual or potential offsite consequences . The EOF staff disseminates information to federal , state, and local emergency response organizations and provides a centralized location for representatives from federal , state and local agencies.

DAECEMERGENCYPLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev. ~39 EQUIPMENT Page 6 of 26 (b) This location has adequate square footage to support the ERO and the EOF. This provides adequate working space for approximately 40 people during normal conditions and 150 people during an emergency. It includes various offices and conference rooms, and provides ready access to the DAEC records, procedures, drawings, etc., that are normally used and maintained in this area. (c) The facility is equipped with suitable communications data transmission systems for use during normal and emergency conditions. These systems and equipment provide the following : (i) Dedicated and prioritized communications interconnecting with the TSC, NRC, and local and state networks. (ii) Terminals that can access and display vital plant parameters and radiological and meteorological data. (iii) A fax machine system for transmitting information to the TSC and other offsite agencies, organizations, and companies, as required . (2) Activation Criteria (a) Activation of the EOF will be accomplished for any event classified as a SITE AREA or GENERAL EMERGENCY. Activation and staffing of the EOF at an ALERT or lesser classification will be at the direction of the Emergency Response & Recovery Director (ER&RD). The Emergency Coordinator will notify the ER&RD of an emergency situation at DAEC. The ER&RD is responsible for ensuring that personnel are contacted and assigned to fill key EOF functions . Members of the Emergency Response Organization assigned to the EOF will be notified by pager, plant page, or commercial telephone during normal work hours, and by pager and/or commercial telephone, using either call lists or automated telephone system, during non-normal work hours. Key EOF personnel will be directed to report to the EOF when an ALERT is declared and may be placed on standby as directed by the ER&RD. The Emergency Telephone Book identifies each position to be contacted and response times. (3) Alternate EOF (a) If the Alliant Tower becomes uninhabitable the Alternate EOF will be activated . The Alternate EOF will be located at the Linn County Emergency Management Agency (EMA) . Linn EMA is housed in the Kirkwood Community College Facilities and Security Building on the main campus of Kirkwood Community College in Cedar Rapids, IA.

DAECEMERGENCYPLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev. ~39 EQUIPMENT Page 7 of 26 (4) Staffing (a) Duane Arnold corporate managers familiar with operating, engineering, licensing, and public relations functions and activities are available to the EOF. Functions to be performed by these key personnel are described in Section B of this plan and in supporting implementing procedures. (b) The EOF will provide overall management of the emergency response (including coordination with federal, state and local officials) during Site Area and General Emergency classifications, and, if desired, during lower classifications of emergencies. (5) Habitability (a) The EOF is located at a distance greater than 10 miles from the DAEC; therefore no shielding or specialized ventilation filtration systems are necessary. 2.4 JOINT INFORMATION CENTER (JIC) (1) General Description (a) The JIC is located on the sixth and fifteenth floors of the Alliant Tower in Cedar Rapids with an auditorium and conference rooms. It has approximately 3,700 square feet and is capable of accommodating 200 news personnel for registration, inquiries, and mass briefings. The JIC functions as the single-point contact for disseminating information to the industry, news media, and public officials. The JIC Manager will use the JIC as his/her headquarters. He/she will ensure that the center is provided with adequate equipment and materials including those listed below: (i) A large briefing area with a public address system (ii) A working area for the press (iii) Federal, state, and local government agency work area (iv) Kitchenette and restrooms (v) DAEC media guide and visual aids (b) A more detailed description of the JIC, specific equipment capabilities, and media material is provided in Figures H-7 and H-8, "JIC 6th and 15th Floor Plans, typical". (c) Should the Cedar Rapids metropolitan area require evacuation, facilities on the main campus of Kirkwood Community College can be used for media briefings and news conferences. JIC spokespersons representing DAEC, Linn and Benton Counties, the State of Iowa, and any Federal agencies, with appropriate support staff will relocate to the College to provide the media with timely and accurate information.

DAECEMERGENCYPLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev. ~39 EQUIPMENT Page 8 of 26 (2) Activation Criteria (a) Activation of the JIC will be accomplished for any event classified as a SITE AREA or GENERAL EMERGENCY. Activation and staffing of the JIC at an ALERT or lesser classification will be at the direction of the JIC Manager. The ER&RD will notify the JIC Manager of an emergency situation at DAEC. The JIC Manager is responsible for ensuring that personnel are contacted and assigned to fill key JIC functions. Members of the Emergency Response Organization assigned to the JIC will be notified by pager, plant page, or commercial telephone during normal work hours, and by pager and/or commercial telephone, using either call lists or automated telephone system, during non-normal work hours. Key JIC personnel will be directed to report to the JIC when an ALERT is declared and may be placed on standby as directed by the JIC Manager. The Emergency Telephone Book identifies each position to be contacted and response times. 2.5 OFFSITE RELOCATION AND ASSEMBLY AREA (ORAA) (1) General Description (a) The Offsite Relocation and Assembly Area (ORAA) is located in Palo. The directions to the facility are described in Figure H-4. This facility will be staffed by the ORAA Supervisor, security force members, and health physics technicians (or HP trained equivalents). This facility has the capability of providing space in the event of a site evacuation of non-essential personnel from the DAEC. The ORAA provides full decontamination capabilities, and can also function as a staging area to support recovery and re-entry efforts at the DAEC. (2) Activation Criteria (a) Activation and staffing of the ORAA will be accomplished for any event classified as a SITE AREA or GENERAL EMERGENCY. Activation and staffing of the ORAA at an ALERT level will be based upon whether or not a site evacuation has been initiated at the direction of the Emergency Coordinator. The OSC Supervisor, when notified that an evacuation from the site is being conducted , shall contact the ORAA Supervisor and inform him that the ORAA is to be activated. The ORAA Supervisor will then coordinate with the OSC Supervisor to assign three Health Physics technicians (or HP trained equivalents) to assist in the activation of the ORAA. (3) Staffing (a) The ORAA Supervisor exercises supervision and direction over the personnel assigned to the ORAA. Personnel assigned to the ORAA include selected security force members and health physics trained personnel for monitoring and decontamination purposes. The ORAA Supervisor will coordinate with the HP Supervisor if more personnel are needed.

I i DAECEMERGENCYPLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev. ~39 EQUIPMENT Page 9 of 26 (4) Habitability (a) The ORAA does not provide shielding necessary to protect occupants from the plume. If the ORAA, located in Palo, Iowa, is not habitable due to plume effect, the alternate reassembly area will be the Benton County Emergency Worker Monitoring and Decontamination Station located at 701 East A Street in Vinton . It may be necessary for the Emergency Coordinator to select another location based upon input from the Site Radiation Protection Coordinator due to radiological release and meteorological conditions. 2.6 ALTERNATIVE FACILITIES (1) If the site is under threat or experiencing a hostile action, the onsite ERO members may be directed to Alternative Facilities. These facilities function as a staging area for augmentation of emergency response staff. Collectively, these facilities have the following characteristics : the capability for communication with the emergency operations facility, control room, and plant security; the capability to perform offsite notifications; and the capability for engineering assessment activities, including damage control team planning and preparation, for use when onsite emergency facilities cannot be safely accessed during hostile action. [Reference : 10CFR50 Appendix E Section IV.E.8.d] 2.7 STATE HYGIENIC LABORATORY (SHL) (1) General Description (a) The SHL is located at 2490 Crosspark Road , Coralville, Iowa 52241 . This facility provides for the analysis of contaminated or potentially contaminated samples such as water, vegetation, and soil. (2) Activation Criteria (a) The SHL is designated for activation at the discretion of the representative for the Iowa Homeland Security & Emergency Management Division (HSEMD). (3) Staffing (a) The SHL is staffed per the direction of the Iowa Homeland Security & Emergency Management Division (HSEMD). (4) Habitability (a) The SHL is located beyond the 10 mile Emergency Planning Zone (EPZ) from the DAEC. Habitability determinations will be conducted on an as needed basis when potentially contaminated samples or personnel are delivered to the SHL.

DAECEMERGENCYPLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev. J8--39 EQUIPMENT Page 10 of 26 2.8 ONSITE MONITORING SYSTEMS (1) Meteorological Monitors (a) Wind speed and direction (b) Temperature (2) Radiological Monitoring Systems (a) Area Radiation Monitoring System (b) Process Radiation Monitoring System (i) Main Steamline Radiation Monitoring System (ii) Offgas Radiation Monitoring System (a) Pre-treatment Offgas Monitor and Sampler (b) Post-treatment Offgas Monitor and Sampler (iii) Carbon Bed Vault Radiation Monitoring System (iv) Offgas Vent Pipe (Stack) Radiation Monitoring System (v) Refueling Pool Exhaust Radiation Monitoring System (vi) Reactor Bldg . Main Exhaust Radiation Monitoring System (vii) Control Building Air Intake Radiation Monitoring System (viii) Liquid Process Radiation Monitoring System (a) Radwaste Effluent (b) Service Water Effluent (c) Reactor Bldg Closed Cooling Water (d) RHR and Emergency Service Water Effluent (e) RHR and Emergency Service Water Rupture Disc Effluent (ix) KAMAN Extended Range Effluent Monitoring System (a) Offgas Vent Pipe (b) Reactor Building Stacks (c) Turbine Building Vents (c) Portable dose rate meters

DAECEMERGENCYPLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev. ~39 EQUIPMENT Page 11 of 26 (d) Counting Laboratory Equipment (i) Gamma Spectroscopy (ii) Proportional Counter (iii) Liquid Scintillation Counter (e) Whole Body Counter (3) Process Monitoring Systems (a) NSSS Instrumentation (i) Rx Vessel Level (ii) Rx Pressure (iii) Rx Temperature (iv) Nuclear Instrumentation (v) Associated Alarms, Annunciators (b) Containment Instrumentation (i) Drywell Temperature (ii) Drywell Pressure (iii) Containment Level (iv) Torus Temperature (v) Torus Pressure (vi) Drywell Sump Pump Timers (vii) Drywell to Torus DP (viii) Torus to Rx Building DP (c) ECCS Instrumentation (i) ECCS Pump Operation (ii) ECCS System Flow Indicators (iii) Isolation Valve Status (iv) HPCl/RCIC Turbine Speed/Minimum Flow (v) Emergency Diesel Generator Operation (vi) SBLC System Operation (vii) Associated Alarms, Annunciators

DAECEMERGENCYPLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev. J&-39 EQUIPMENT Page 12 of 26 (d) System Instrumentation (i) SBGT Operation and Flow (ii) Standby Filter Unit Operation and Flow (iii) Off-Gas System Operation and Flow (iv) Rx Building Ventilation Exhaust (v) Turbine Building Ventilation Exhaust (vi) Feedwater Flow (vii) Main Steam Flow (viii) Generator Load (ix) Valve Status Indicator Lights (x) Stack Fan Flow (xi) Associated Alarms, Annunciators (e) Electrical Instrumentation (i) RPS Failure Indication (ii) Battery Voltage (iii) Vital Bus Voltmeter (iv) Transformer Output (v) Breaker Position Indicators (vi) Sub-Station Breaker Positions (vii) Associated Alarms, Annunciators (4) Fire Monitoring Systems (a) Smoke (ionization) Detectors (b) Rate-of-rise heat Detectors (c) Heat Detectors (d) Associated Alarms, Annunciators

DAECEMERGENCYPLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev. ~39 EQUIPMENT Page 13 of 26 2.9 METEOROLOGICAL INSTRUMENTATION AND PROCEDURES (1) The DAEC Meteorological Instrumentation is used to acquire data for both on-site and off-site monitoring of weather conditions. (2) A complete description of the meteorology program is contained in the Updated Final Safety Analysis Report (UFSAR). A capsulated description of the system is given here. (a) The meteorological tower is located 1700 feet south-southeast of the Reactor Building. Both primary and backup instrumentation is provided to measure wind direction, wind speed , and ambient air temperature at 33 feet and 156 feet above the base of the tower. In addition, dewpoint is measured at the 33-foot level and precipitation is measured at the base of the tower. The accuracy's and ranges associated with this instrumentation are discussed in the UFSAR. Calibration of the instruments is performed semiannually. The onsite meteorological measurement program is documented in the UFSAR and the associated Onsite Meteorological Data Supplement. (b) The data gathered by the instrumentation is provided as instantaneous values at 10-second intervals to the Safety Parameter Display System (SPDS). The SPDS screens the data and selects either the primary or the backup instrumentation, as appropriate, under the existing meteorological conditions. The instantaneous values are then processed into one-minute averages and transmitted , along with radiological data, to the atmospheric dispersion and dose assessment model. This allows near real-time predictions of the atmospheric effluent transport and diffusion as well as remote interrogation of the atmospheric measurements and predictions by appropriate organizations. When the Emergency Response Data System (EROS) link is activated, this data is also picked up and transmitted to the NRC EROS. (c) The data gathered by the instrumentation is also provided to a hard copy recorder in the Control Room in the form of 30-minute averages as a backup to the data archived by the dose assessment model. For an expanded description of the effluent monitoring system and the dose assessment model, see DAEC Plan "I" section 2.2 "Accident Assessment Capabilities and Resources". 2.10 SEISMIC AND HYDROLOGICAL INSTRUMENTATION (1) Seismic instrumentation is installed at several locations to detect seismic disturbances. Accelerograph sensors are located in the basement of the Reactor Building, the Refueling Floor, the Intake Structure, Pump House, Recirculation System Piping, Reactor Vessel , and at various other Class I structures. An accelerograph is also installed at a "free field" location to measure soil structure interactions. The accelerograph sensors feed indicating lights and alarms located in the Control Room . The seismic indicators alert operators when predetermined Operating Basis Earthquake (OBE) and Design Basis Earthquake (DBE) values are exceeded . (2) The intake structure for plant cooling water employs a level sensing system for Cedar Rapids River level. A level recorder indicates increases or decreases in river level. Additionally, periodic checks of the total flow of the Cedar Rapids River are made at a gauge station in Cedar Rapids .

DAECEMERGENCYPLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev. ~39 EQUIPMENT Page 14 of 26 2.11 CONTROL OF EMERGENCY EQUIPMENT/INSTRUMENTS (1) The operational readiness of emergency equipment and supplies is ensured through a program of routine inventory, calibration , test, and maintenance. Once during each quarter, all emergency kits, emergency equipment, and supplies are inventoried. This inventory includes verification that procedures contained in the kits are the latest revision. Additionally, all portable instruments are verified to have been tested and calibrated as prescribed by DAEC procedures. The general condition of supplies such as batteries, respirators, and liquid containers are inspected for signs of leakage or deterioration. 2.12 COMMUNICATION CHECKS (1) The following communication checks will be performed at the specified frequencies: (a) Local and state governments - monthly (b) NRC Headquarters Operations Center - monthly (c) Emergency Response Data System - quarterly (d) Local and state Emergency Operations Centers - annually (2) These communication checks will be documented as specified in the EPIPs and in Emergency Preparedness Department Procedures. 2.13 EMERGENCY KITS (1) DAEC Emergency Plan Appendix 4 identifies the procedures which contain the location and type of emergency kits; i.e., protective equipment, communications equipment, radiological monitoring equipment, and emergency supplies. The Emergency Planning Department procedures establish the inventory quantities of the items listed in the kits. 2.14 RECEIPT AND ANALYSIS OF FIELD MONITORING DATA (1) Field monitoring data will be transmitted to the EOF for review and analysis. Prior to the EOF being operational, data will be transmitted to the TSC for review and analysis.

DAECEMERGENCYPLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev. ~39 EQUIPMENT Page 15 of 26 TABLE H-1 RADIOLOGICAL MONITORING SAMPLING STATION LOCATIONS Refer to ODAM Table 5-1

DAECEMERGENCYPLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev. ~39 EQUIPMENT Page 16 of 26 TABLE H-2 RADIOLOGICAL MONITORING LOCATIONS Refer to ODAM Table 5-1

DAECEMERGENCYPLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev. Jg_39 EQUIPMENT Page 17 of 26 FIGURE H-1 TSC/OSC FLOOR PLAN (Typical)

NRC = NRC TABLE NRC Office TSC
RAD PRO = SRPC, HPN COMM

                                                    *AMT= TSC OPS SUPV, AMT                      Rx ENG, OPS LIAISON, rn TECH &AN.ENG, D                NRC                                     TSCCOMM

ENG= TECH & ENG SUPV, EMER IGJEM ENG, MM ENG, COO RD ENS COMM RAD PRO
SUPPORT= ADMIN SUPV, SECURITY SLPV, INFO SERV, SUPPORT CLERICAL 0

I I osc r1 HP SUP\! D OSC SUP\f IC/EM, MVI SUPV 0 00 0 0

DAECEMERGENCYPLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev. ~39 EQUIPMENT Page 18 of 26 FIGURE H-2 EOF FLOOR PLAN (Typical) I. NRC HPN Communicator

2. NRC ENS Communicator

3. RAC

4. NRC DSO

5. ER&RD

6. EOF Communicator

7. Benton County

8. Linn County 0 9. Support Services Coordinator 0 IO. FEMA Vl 12. Stale Health Rep.

ro 13. Iowa H.*ID

Vl l.J . NRC ProtccliYe Measures

15. Tcdmical Recorder ro Vl 16. EOF Ops Liaison Vl

17. NRC Rx Safe~*

3 19. Field Team Director ro 20. MIDAS Operator

i

.-+                                                  21. Stale Radio Opcralor
)>                                                   22. State Comp Operator Cil                                                  23. State Dose Assessment Director DJ                                                   24. Infomliltion Smices E     ENS Phone 19-23 H     HPN Phone Figure H-2            R     RSCL Phone L

EOF Floor Plan P PMCLPhonc M MCLPhone (typical, not to scale and L LAN Phone seating/FTS locations may change)

DAECEMERGENCYPLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev. ~39 EQUIPMENT Page 19 of 26 FIGURE H-3 (DELETED)

DAECEMERGENCYPLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev. ~39 EQUIPMENT Page 20 of 26 FIGURE H-4 DIRECTIONS TO ORAA (2800 Hollenbeck Road, Palo, IA 52324) DAEC W36 N 1 BLAIRS _ _ _ _ _ , ' - - - - - - - - t - - - - - - - { FERRY RD. SHELLSBURG RD. VINTON ST. OFFSITE - - - . + - RELOCATION

&ASSEMBLY AREA(ORAA)            Cl a:::
                      ~

0 w a::i z w I 0 I

DAECEMERGENCYPLAN SECTION .'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev. ~39 EQUIPMENT Page 21 of 26 FIGURE H-5 (DELETED)

DAECEMERGENCYPLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev. Jg...39 EQUIPMENT Page 22 of 26 FIGURE H-6 (DELETED)

DAECEMERGENCYPLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev. ~39 EQUIPMENT Page 23 of 26 FIGURE H-7 JIC 6TH FLOOR PLAN (Typical) l.EDIA RUMOR CONTROL STORAGE AREA

                                                                    -*I ***

NEWl CONFERENCE AUDIO ROOM l.EDll\ VISUAL WO~ STORAGE AREA

DAECEMERGENCYPLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev. ~39 EQUIPMENT Page 24 of 26 FIGURE H-8 JIC 1STH FLOOR PLAN (Typical)

DAEC EMERGENCY PLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev. ~39 EQUIPMENT Page 25 of 26 FIGURE H-9 (DELETED)

DAECEMERGENCYPLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev. ~39 EQUIPMENT Page 26 of 26 FIGURE H-10 DIRECTIONS TO THE STATE HYGIENIC LAB (SHL) c,q-111r The Ra Ids Unlvernlt.y

of Iowa Research f,lrk lfJne~

                                                ~L ,crNa
                                             -1r~
                                              ~I'll Mite l

To N.Liberty I 1

. }

To 1-00 (1 mile) 1

DAEC EMERGENCY PLAN SECTION 'J' Rev. l-7--28 PROTECTIVE RESPONSE Page 1of12 Usage Level INFORMATION Record the following: Date/Time: I Initials: _ __ NOTE: User shall perform and document a Temp Issue/Rev. Check to ensure revision is current, in accordance with procedure use and adherence requirements. Prepared By : I Date: Print Signature APPROVAL BY EMERGENCY PREPAREDNESS MANAGER Approved By I Date: Print Signature APPROVAL BY ORG Approved By I Date: Print Signature APPROVAL BY DAEC SITE VICE PRESIDENT Approved By I Date: Print Signature APPROVAL BY CORPORATE DIRECTOR OF EMERGENCY PLANNING Approved By I Date: Print Signature

DAEC EMERGENCY PLAN SECTION 'J' Rev. µ28 PROTECTIVE RESPONSE Page 2of12 Table of Contents Section Numbers Section Titles Page 1.0 PURPOSE 3 2.0 REQUIREMENTS 3 2.1 NOTIFICATION OF ONSITE PERSONNEL 3 2.2 SITE EVACUATION 3 2.3 CONTAMINATION CONTROL OF SITE EVACUEES 4 2.4 ACCOUNTABILITY OF ONSITE PERSONNEL 4 2.5 RADIOLOGICAL PROTECTION OF ONSITE PERSONNEL 5 2.6 ONSITE PROTECTIVE ACTIONS 5 2.7 OFFSITE PROTECTIVE ACTION RECOMMENDATIONS 6 2.8 PLUME EPZ PROTECTIVE ACTIONS 7 2.9 PLUME EPZ EVACUATION TIME ESTIMATES 7 2.10 INGESTION PATHWAY PROTECTIVE ACTIONS 8 3.0 ATIACHMENTS 8

SUMMARY

OF POSSIBLE OFFSITE PROTECTIVE ACTIONS TO BE TABLE J-1 9 RECOMMENDED OR IMPLEMENTED DURING AN EMERGENCYt TABLE J-2 REPRESENTATIVE SHIELDING FACTORS FROM GAMMA CLOUD SOURCE* 10 FIGURE J-1 SITE EVACUATION ROUTES 11 FIGURE J-2 "DAEC EPZ EVACUATION ROUTES" 12

DAEC EMERGENCY PLAN SECTION 'J' Rev. ,2-7--28 PROTECTIVE RESPONSE Page 3of12 1.0 PURPOSE (1) This section describes the protective actions to be taken for emergency workers and the public based upon the event classification and resulting assessment of plant status and radiological conditions. Guidelines for the choice of protective actions to be implemented are presented, as well as the methods to be used to notify the population at risk of emergency conditions. 2.0 REQUIREMENTS 2.1 NOTIFICATION OF ONSITE PERSONNEL (1) Personnel on site within the Protected Area boundary, and personnel on site outside the Protected Area located in the Training Center and the Plant Support Center will be notified of an emergency condition by a distinctive tone-alarm over the public address system, followed by an announcement over the plant page system. (2) Security force personnel will be dispatched, as appropriate, to warn any individuals who may be on Duane Arnold property in the vicinity of the plant. 2.2 SITE EVACUATION (1) Non-essential personnel will be evacuated from the DAEC to an offsite reassembly area during a SITE AREA or GENERAL EMERGENCY. Evacuation from the site will be by the routes shown in Figure J-1, using personal transportation. The south route will normally be used, unless radiological conditions dictate use of the north route . Security personnel will provide traffic control on site. The detailed provisions for evacuation, relocation, radiological monitoring and decontamination of site personnel are provided in the EPIPs. (2) Evacuated personnel will proceed to the Palo Community Center, located in Palo, Iowa, and reassemble for an accountability check and personnel radiological monitoring, if not already accomplished at the DAEC. If the Palo Community Center is not habitable due to plume effects, the alternate reassembly area will be the Benton County Emergency Worker Monitoring and Decontamination Station located at 701 East A Street in Vinton, or at the Emergency Coordinator's discretion.

DAEC EMERGENCY PLAN SECTION 'J' Rev. µ2s PROTECTIVE RESPONSE Page 4of12 I 2.3 CONTAMINATION CONTROL OF SITE EVACUEES (1) Security force personnel will ensure that any individuals who may be on company property but outside of the fenced area are advised of the event and escorted off the property. Access will be permitted only to those individuals who are required at the site. If radiological releases have occurred or are in progress, individuals escorted offsite will be surveyed for any radiological contamination prior to being released from company property. In the event that evidence of contamination is found or suspected, the individual will be decontaminated onsite or taken to the Offsite Relocation and Assembly Area (ORAA) or Mercy Medical Center or University of Iowa Hospitals and Clinics for subsequent decontamination and release . (2) Where possible, plant employees will be decontaminated in onsite facilities . A full capability exists to conduct decontamination at the Palo Community Center. 2.4 ACCOUNTABILITY OF ONSITE PERSONNEL (1) For all events that result in activation of the Emergency Response Organization except those classified as NOTIFICATION OF UNUSUAL EVENT, personnel onsite will proceed to their pre-assigned assembly point. In those situations where the number of personnel at the site is significantly in excess ofthe normal plant staff, information will be disseminated to those additional personnel identifying alternate assembly and accountability locations. (2) An accountability check for all personnel who are within the Protected Area will be conducted . The methods used will enable accounting for all individuals onsite at the time of the emergency, ascertain the names of missing individuals within approximately thirty minutes of the start of an emergency, and continuously account for all onsite individuals thereafter.

DAEC EMERGENCY PLAN SECTION 'J' Rev. 2-7--28 PROTECTIVE RESPONSE Page 5of12 2.5 RADIOLOGICAL PROTECTION OF ONSITE PERSONNEL (1) Protective measures associated with the use of protective clothing and the use of respiratory protection equipment shall be taken in accordance with existing radiation protection requirements. (2) Respiratory protection devices may be required in any situation arising from plant operations where airborne radiological contamination exists. In such cases, the air will be monitored and the need for and type of protective devices will be specified according to the concentration and type of airborne contaminants present. This decision will be made to optimize the total effective dose equivalent. Periodic air samples are routinely taken in selected areas of operations or work activity during normal operations. Air samples will be taken in the OSC, Control Room and TSC, as appropriate, to ensure continued habitability ofthose areas and to alert the Emergency Coordinator to any changes in the airborne status. {3) Protective clothing and respiratory protection equipment are maintained at several locations within the plant. Personnel in the OSC will be dispatched to distribute additional equipment as necessary to the Control Room, TSC, or other plant areas where personnel may be stationed. In the event that sufficient equipment is not available, personnel will be relocated to plant areas where contamination hazards do not exist. (4) Where the potential exists for significant exposure to radioiodine, an initial dosage of potassium iodide will be administered. A sufficient quantity of potassium iodide will be kept onsite for this purpose. The use of potassium iodide will be in accordance with EPIPs. 2.6 ONSITE PROTECTIVE ACTIONS {1) A range of protective actions to protect onsite personnel during a hostile action have been developed to ensure the continued ability to safely shut down the reactor and perform the functions of the emergency plan. [

Reference:

10CFRSO Appendix E Section IV.I]

DAEC EMERGENCY PLAN SECTION 'J' Rev. µ23 PROTECTIVE RESPONSE Page 6of12 2.7 OFFSITE PROTECTIVE ACTION RECOMMENDATIONS (1) Upon identification and classification of the event, notifications will be made as delineated in Section E. Decisions with respect to sheltering or evacuation of the population at risk, as .well as the means of notification, are as prescribed in the Linn County and Benton County Radiological Emergency Response Plans and Emergency Plan Implementing Procedures. Recommendations for protective actions for the public are based upon ensuring that personnel exposures are maintained at or below those identified in the EPA Protective Action Guides, as described in Table K-1. (2) In addition to specific identification and classification of an event, other plant conditions rnay exist that rnal~e releases of large arnmmts of radioactivity in a short tirne possible. In this case, preca1::1tionary protective actions 'Nill be recornrnended and cornrn1::1nicated to the appropriate offsite agencies . The plant conditions which co1::1ld cornbine to create the potential for releases incl1::1de the following:

Core melt event seq1::1ences where releases from containment are not yet taking place, and large amo1::1nts of fission prod1::1cts are not yet in the containment atmosphere .
Core melt event seq1::1ences *.vhere large amo1::1nts of fission prod1::1cts are in the containment atmosphere.
Core melt event seq1::1ences where releases from containment are not yet taking place, b1::1t containment fail1::1re is likely with large amo1::1nts of fission prod1::1cts in addition to noble gases in the containment atmosphere.

fJ.1(2} Communication systems are available to ensure that the population at risk is notified of protective measures to be taken. These are discussed in Section E. {4}(3) Protective Action Recommendations have been developed using the guidance of NUREG-0654, Supplement 3 which provides an acceptable method to comply with 10 CFR 50, Append ix E, Section IV, paragraph 3 in the use of evacuation time estimates in the formulation of protective action recommendations (PARs} for the plume exposure emergency planning zone, and provides guidance for the provisions of 10 CFR 50.47(b}(10} in the development of a range of PARs. W(4} NUREG-0654, Supplement 3 also provides guidance to support the information in NUREG-0654/FEMA-REP-1 that the U.S. Nuclear Regulatory Commission finds to be an acceptable method of meeting the requirements in 10 CFR 50.47(b}(7} for the development of a public information program . te.}(5} The Protective Action Recommendations have been coordinated with the responsible Offsite Responsible Organizations.

DAEC EMERGENCY PLAN SECTION 'J' Rev. µ2g PROTECTIVE RESPONSE Page 7of12 2.8 PLUME EPZ PROTECTIVE ACTIONS (1) Offsite protective actions, including sheltering, evacuation and contamination control, will be taken in accordance with the action criteria established in the EPA Protective Action Guides (PAGs) described in Table K-1. The responsibilities associated with implementation of such protective actions are specified in the Linn County and Benton County Radiological Emergency Response Plans. In addition to Table K-1, the following factors will determine the basis for choosing between alternate recommended protective actions:

Potential for release based on plant conditions
Type of release, (i.e., constant or puff, elevated or ground), filtered or unfiltered
Length of release
Time required for the plume to reach the population at risk
Prevailing meteorological conditions
Evacuation time estimates for general and special population distributions are found in Appendix 3 (Evacuation - Time Estimates)
Radiological monitoring and environmental sampling results
Representative Shielding Factors for Gamma Cloud Sources (Table J-2)
Alternate local sheltering facilities (2) The Linn County and Benton County Radiological Emergency Response Plans and the State of Iowa Radiological Emergency Response Plan include maps identifying evacuation routes, evacuation subareas, and relocation centers in host counties.

2.9 PLUME EPZ EVACUATION TIME ESTIMATES (1) The DAEC Evacuation Time Estimate for Linn and Benton Counties identifies population distributions, evacuation time estimates, and evacuation routes and is included as Appendix 3. EPZ evacuation routes are as delineated in the Linn County and Benton County Radiological Emergency Response Plans and the State of Iowa Radiological Emergency Response Plan. The permanent population within the DAEC EPZ subareas and within the plume exposure EPZ of DAEC is reflected in Appendix 3. The county plans contain the EPZ evacuation plans.

DAEC EMERGENCY PLAN SECTION 'J' Rev. ~28 PROTECTIVE RESPONSE Page 8of12 2.10 INGESTION PATHWAY PROTECTIVE ACTIONS (1) Protective action recommendations provided to offsite authorities with regards to the ingestion exposure pathway {SO mile EPZ) will be based upon a number of factors including:

Type of release
Release source
Time frame (or accident phase)
The results of environmental monitoring and sampling efforts undertaken (2) Initial recommendations provided will typically be conservative and based primarily upon projected impacts as opposed to analytical results. Table J-1 provides a summary of the recommended protective actions that may be appropriate for an event at the DAEC. As is evident, these recommendations generally entail restriction of food stuffs and surface drinking water and placing milk animals on stored (non-contam inated) feed. The implementation of protective response options for the ingestion exposure pathway is the responsibility of the State of Iowa and is described in the Iowa Radiological Emergency Response Plan.

3.0 ATTACHMENTS (1) TABLE J-1, "

SUMMARY

OF POSSIBLE OFF-SITE PROTECTIVE ACTIONS TO BE RECOMMENDED OR IMPLEMENTED DURING AN EMERGENCY" (2) TABLE J-2, "REPRESENTATIVE SHIELDING FACTORS FROM GAMMA CLOUD SOURCE" (3) FIGURE J-1, "SITE EVACUATION ROUTES" (4) FIGURE J-2, "DAEC EPZ EVACUATION ROUTES"

DAEC EMERGENCY PLAN SECTION 'J' Rev. ~28 PROTECTIVE RESPONSE Page 9of12 TABLE J-1

SUMMARY

OF POSSIBLE OFFSITE PROTECTIVE ACTIONS TO BE RECOMMENDED OR IMPLEMENTED DURING AN EMERGENCYt ACCIDENT PHASE EXPOSUREPATH\NAY EXAMPLES OF ACTION TO BE RECOMMENDED 1 EARLY PHASE Inhalation of gases, radio iodines, Evacuation, shelter, access control, (0.5 TO 30 hours)

or particulates respi ratory protection, prophylaxis (thyroid protection)

Direct whole body exposure Evacuation, shelter, access control 2 INTERMEDIATE Ingestion of milk Take cows off pasture, prevent cows from PHASE drinking surface water, discard contaminated milk or divert it to stored {30 hours to 30 products such as cheese days)* Ingestion of fruits and vegetables \Nash all produce, or impound produce, delay harvest until approved, substitute uncontaminated produce Ingestion of water Cut off contaminated supplies, substitute from other sources, filter, demineralize

                         \Nhole body exposure and             Relocation, decontamination, access inhalation                          control 3

LATE PHASE Ingestion of food and water Decontamination, condemnation, or (over 30 days)

contaminated from the soil destruction of food; deep plowing either by resuspension or uptake condemnation, or alternate use of land through roots

                          \Nhole body exposure from           Relocation, access control, deposition of material or           decontamination, fixing of contamination, inhalation of resuspended           deep plowing material 1

Emergency Phase - Time period of major release and subsequent plume exposure. 2 Intermediate Phase - Time period of moderate continuous releases with plume exposure and contamination of the environment 3 Long Term Phase - Recovery period.

"Typical" Post-Accident time periods.

t

Reference:

USEPA "Manual of Protective Action Guides and Protective Actions for Nuclear Incidents," (EPA 400-R-92-001) dated October 1991 with 2nd printing May 1992.

DAEC EMERGENCY PLAN SECTION 'J' Rev. ~28 PROTECTIVE RESPONSE Page 10of12 TABLE J-2 REPRESENTATIVE SHIELDING FACTORS FROM GAMMA CLOUD SOURCE* Structure of Location Shielding Factor (a) Representative Range Outside 1.0 -- Vehicles 1.0 -- Wood-frame house (b) 0.9 -- (no basement) Basement of wood house 0.6 0.1to0.7 (c) Masonry house (no basement) 0.6 0.4 to 0.7 (c) Basement of masonry house 0.4 0.1 to o.s (c) Large office or industrial building 0.2 0.1 to 0.3 (c, d) (a) The ratio of the interior dose to the exterior dose (b) A wood frame house with brick or stone veneer is approximately equivalent to a masonry house for shielding purposes. (c) This range is due mainly to different wall materials and different geometrics. (d) The reduction factor depends on where the persons are located within the building (e.g., the basement or an inside room). (1) Consideration is limited to gamma radiation since beta and alpha particles cannot penetrate the walls of structures.

Manual of Protective Action Guides and Protective Actions for Nuclear Incidents (EPA 400-R-92-001) dated October 1991 with 2nd printing May 1992.

DAEC EMERGENCY PLAN SECTION 'J' Rev. P-28 PROTECTIVE RESPONSE Page 11of12 FIGURE J-1 SITE EVACUATION ROUTES

NORMAL ROADBLOCK (SECURITY BARRIERS NORTH EVACUATION - MUST BE REMOVED ROUTE PRIOR TO USING THIS NORMAL ROADBLOCK ROUTE)

                                             '-I\  I    PARKING f    ~OTS SWITCHYARd   ~

I DAEC

                                                                     ~FENCE I_
                                                ' SOUTH EVACUATION ROUTE
                                         . _ _ SITE BOUNDARY
                           ~

r 5r---*6r 0 s r )> rn ::0 z (/) I OJ 5---t~

0 0

0

             !=J BLAIRSFERRY RD.
                                     ~        TOWN OF PALO SHELLSBURG RD I

0 OFFSITE r r RELOCATION rn z &ASSEMBLY OJ rn AREA(ORAA) 0

/;

0

!=J

DAEC EMERGENCY PLAN SECTION 'J' PROTECTIVE RESPONSE Rev. 27 Rev. Page 12of12 FIGURE J-2 DAEC EMERGENCY PLANNING ZONE EVACUATION ROUTES

Manchester Independence 13 Delhi Ryan t Coggon Marshalltown

        .,..__                     ;'1    ..      J\    ~  \:::: n.             -; - (us 3 0 ' ) - - -

t Newton

                                                                    -*---------                         ~

DAECEMERGENCYPLAN SECTION 'K' Rev. 2J4 RADIOLOGICAL EXPOSURE CONTROL Page 1 of 6 Usage Level INFORMATION Approved for 'Point-of-Use' printing IF NO Temporary Changes are in effect for this procedure. Record the following: Date I Time: _ _ _ _ _ _ I _ _ _ _ Initials: NOTE: A check to ensure current revision and no temporary changes shall be performed and documented every 24 hours if active document use exceeds a 24 hour period as determined from the date and time recorded above. Prepared By: I Date: - - - - -

             ~--------                          ~------------

Print Signature APPROVAL BY EMERGENCY PREPAREDNESS MANAGER Approved By I Date: --------< Print Signature APPROVAL BY ORG Approved By I Date: -----1 Print Signature APPROVAL BY DAEC SITE VICE PRESIDENT Approved By I Date: Print Signature APPROVAL BY CORPORATE DIRECTOR OF EMERGENCY PLANNING Approved By I Date: -----I Print Signature

DAECEMERGENCYPLAN SECTION 'K' Rev. 2J4 RADIOLOGICAL EXPOSURE CONTROL Page 2 of 6 Table of Contents Section Numbers Section Titles Page 1.0 PURPOSE 3 2.0 REQUIREMENTS 3 2.1 EXPOSURE GUIDELINES 3 2.2 ONSITE RADIATION PROTECTION PROGRAM 3 2.3 EXPOSURE CONTROL 4 2.4 CONTAMINATION CONTROL MEASURES 5 2.5 DECONTAMINATION OF RELOCATED PERSONNEL 5 3.0 ATTACHMENTS 5 TABLE K-1 EPA PROTECTIVE ACTION GUIDELINES* 6

DAECEMERGENCYPLAN SECTION 'K' Rev. 2J4 RADIOLOGICAL EXPOSURE CONTROL Page 3 of 6 1.0 PURPOSE (1) This section describes the measures to be taken to control radiological exposure to emergency workers and the affected offsite population. 2.0 REQUIREMENTS 2.1 EXPOSURE GUIDELINES (1) Conditions may arise wherein consideration will be given to authorizing radiological exposures beyond the normal occupational limit to emergency personnel. These decisions will be based upon the following categories of risk: Emergency Workers. (2) To provide the flexibility that may be necessary for emergencies , Duane Arnold will not consider any occupational dose received during the year and will apply the EPA dose limits stipulated in Table 2.2 of EPA 400-R-92-001 (Manual of Protective Action Guides and Protective Actions for Nuclear Incidents) dated October 1991 with 2nd printing May 1992. However, when determining if a worker may respond to an emergency, Duane Arnold will consider prior overexposures and/or planned special exposures when establishing a worker's available emergency dose. Time permitting; NRC Reg Guide 8.35 (Planned Special Exposures) guidelines will be used. (3) When emergency action is necessary such that emergency personnel would receive radiological exposures beyond the normal occupational limits, the guidelines as outlined in Table K-1 apply. (4) For emergency response actions which might include inhalation of gases or particulates, the emergency dose limit Committed Dose Equivalent to the thyroid is ten times the listed limit in Table K-1 . Although respirators and stable iodine should be used where effective to control doses to emergency team workers, Committed Dose Equivalent (thyroid dose) may not be a limiting factor for lifesaving missions. 2.2 ONSITE RADIATION PROTECTION PROGRAM (1) Protective measures associated with the use of protective clothing and the use of respiratory protection equipment are discussed in Section J.

DAECEMERGENCYPLAN SECTION 'K' Rev. 2J4 RADIOLOGICAL EXPOSURE CONTROL Page 4 of 6 2.3 EXPOSURE CONTROL (1) Exposure Monitoring (a) Duane Arnold will provide exposure monitoring services to determine the doses received by emergency personnel. A health physics technician will supplement each shift operating crew to provide health physics coverage during backshifts, weekends , and holidays when the normal plant staff is not present. In addition , the shift Radwaste operator is available to assist the health physics technician at all times. Added health physics coverage will be provided by trained personnel assigned to the Radiation Protection Department on an as needed basis. +Re-An on-shift chemist Non-Certified Operator has been designated to run the MIDAS Dose Projection System until relieved . (b) Electronic or self reading dosimeters and permanent record (thermoluminescent) dosimeters will be issued to onsite emergency personnel including those from Duane Arnold , NRG, state, county, and local agencies. (2) Exposure Records (a) Standard radiation protection practices will be followed in preparing and maintaining exposure records. These procedures ensure that dosimeters are read at appropriate frequencies . Separate records will be maintained for Duane Arnold , NRG, local, state, contractor and consultant personnel who arrive at the site. The Site Radiation Protection Coordinator will be responsible for ensuring that personnel are informed of permissible exposure limits and work time within a controlled zone . Following deactivation, each agency participating in onsite recovery activities will be sent the exposure records for its personnel.

DAECEMERGENCYPLAN SECTION 'K' Rev. 2.J4 RADIOLOGICAL EXPOSURE CONTROL Page 5 of 6 2.4 CONTAMINATION CONTROL MEASURES (1) Decontamination Action Levels (a) Standard radiation protection requirements associated with decontamination of areas, equipment, and tools, etc. will be followed. Any modifications to these standards will be as authorized by the Site Radiation Protection Coordinator. (2) Decontamination Facilities (a) Decontamination facilities are located at the Access Control Point in the Administration Building . These facilities provide for the decontamination of personnel, supplies, and equipment and for waste disposal. The Low Level Radwaste facility can also provide for the decontamination of supplies, equipment, and for waste disposal. (3) Area Access Control (a) Area access will be established .and controlled in accordance with standard practices. (4) Water and Food Supplies (a) Water and food supplies at the site shall be verified as acceptable for ingestion in those situations where the probability of contamination of food and water exists. (5) Area Return to Normal Use (a) The Site Radiation Protection Coordinator will determine when evacuated areas may be returned to normal use. Radiological monitoring of those areas will be accomplished in accordance with standard radiation protection practices. 2.5 DECONTAMINATION OF RELOCATED PERSONNEL (1) Personnel will be decontaminated when possible in the onsite decontamination center prior to relocation . Personnel will be taken to the Offsite Relocation and Assembly Area (ORAA) (located at 2800 Hollenbeck Road in Palo) as prescribed in Emergency Plan Implementing Procedures when onsite decontamination is not possible. All personnel will be decontaminated prior to release or reassignment to emergency duties. Necessary equipment and supplies will be available for use at the ORAA, including provisions for extra clothing, decontamination methods suitable for the type of contamination expected, and radioiodine contamination of the skin. Personnel who cannot be decontaminated will be taken to Mercy Medical Center or University of Iowa Hospitals and Clinics for further evaluation. 3.0 ATTACHMENTS (1) TABLE K-1, "EPA PROTECTIVE ACTION GUIDELINES"

DAECEMERGENCYPLAN SECTION 'K' Rev. 2~4 RADIOLOGICAL EXPOSURE CONTROL Page 6 of 6 TABLE K-1 EPA PROTECTIVE ACTION GUIDELINES* Protective Action PAG Comments (projected dose) Evacuation 1-5 remb Evacuation (or, for some situations, (or shelteringa) shelteringa) should normally be initiated at 1 rem. Administration of stable iodine 25 remc Requires approval of State medical officials. asheltering may be the preferred protective action when it will provide protection equal to or greater than evacuation, based on consideration of factors such as source term characteristics, and temporal or other site-specific conditions. bThe sum of the effective dose equivalent resulting from exposure to external sources and the committed effective dose equivalent incurred from all significant inhalation pathways during the early phase. Committed dose equivalents to the thyroid and to the skin may be 5 and 50 times larger, respectively. ccommitted dose equivalent to the thyroid from radioiodine. Guidance on Dose Limits for Workers Performing Emergency Services Dose Limita Activity Condition (rem) 5 all 10 protecting valuable lower dose not practicable property 25 life saving or protection of lower dose not practicable large populations

           >25            lifesaving or protection of  only on a voluntary basis to persons fully large populations            aware of the risks involved aSum of external effective dose equivalent and committed effective dose equivalent to nonpregnant adults from exposure and intake during an emergency situation. Workers performing services during emergencies should limit dose to the lens of the eye to three times the listed value and doses to any other organ (including skin and body extremities) to ten times the listed value.

These limits apply to all doses from an incident, except those received in unrestricted areas as members of the public during the intermediate phase of the incident.

EPA 400-R-92-001 - Manual of Protective Action Guides and Protective Actions for Nuclear Incidents, Dated 1991 with 2nd printing May 1992.

ATTACHMENT 3 NEXTERA ENERGY DUANE ARNOLD, LLC DUANE ARNOLD ENERGY CENTER NG-20-0011 SUPPLEMENT TO LICENSE AMENDMENT REQUEST (TSCR-182) CLEAN COPY PAGES OF EMERGENCY PLAN 122 pages follow

DAECEMERGENCYPLAN SECTION 'A' ASSIGNMENT OF RESPONSIBILITIES Rev. 27 (ORGANIZATIONAL CONTROL) Page 1of13 Usage Level: INFORMATION Record the following: Date I Time: _ _ _ _ _ I _ _ _ _ Initials: _ __ NOTE: User shall perform and document a Temp Issue I Rev. Check to ensure revision is current, in accordance with procedure use and adherence requirements. Prepared By:

             -------- I                                                          Date: - - - -

Print Signature APPROVAL BY EMERGENCY PREPAREDNESS MANAGER Approved By Print Signature APPROVAL BY ORG Approved By __________ / _ _ _ _ _ _ _ _ _ _ _ Date: _ _ ___, Print Signature APPROVAL BY DAEC SITE DIRECTOR Approved By I Date: -----I Print Signature

DAECEMERGENCYPLAN SECTION 'A' ASSIGNMENT OF RESPONSIBILITIES Rev. 27 (ORGANIZATIONAL CONTROL) Page 2 of 13 Table of Contents 1.0 PURPOSE ........................................................................................................................... 3 2.0 REQUIREMENTS ................................................................................................................ 3 2.1 RESPONSE ORGANIZATIONS AND RESPONSIBILITIES ................................... 3 2.2 CONCEPT OF OPERATIONS .............................................................................. .4 2.3 RESPONSE ORGANIZATIONS INTERRELATIONSHIPS ..................................... 5 2.4 ORGANIZATIONAL RESPONSIBILITY ................................................................. 8 2.5 DIRECTION AND COORDINATION ...................................................................... 8 2.6 EMERGENCY RESPONSE FUNCTIONS .............................................................. 9

2. 7 AUTHORITY AND AGREEMENTS ...................................................................... 11 2.8 EXTENDED OPERATION .................................................................................... 11 TABLE A-1 EMERGENCY RESPONSE FUNCTION AND RESPONSIBILITIES ...................... 12 FIGURE A-1 INTERRELATIONSHIPS BETWEEN EMERGENCY ORGANIZATIONS ............. 13

DAECEMERGENCYPLAN SECTION 'A' ASSIGNMENT OF RESPONSIBILITIES Rev. 27 (ORGANIZATIONAL CONTROL) Page 3 of 13 1.0 PURPOSE (1) This section describes the responsibilities of Duane Arnold as the principal response organizations for radiological events that may occur at the Duane Arnold Energy Center (DAEC). 2.0 REQUIREMENTS 2.1 RESPONSE ORGANIZATIONS AND RESPONSIBILITIES (1) The DAEC Emergency Response Organization (ERO) provides immediate response to an emergency condition at the DAEC and promptly informs local, state, and federal officials of the situation and potential ramifications. Provisions have been made to augment the overall organization with additional personnel who possess unique technical capabilities, as well as industry and governmental agency support groups which can provide assistance in engineering and radiological dose assessment activities. (2) The resources available from within Duane Arnold, coupled with those available from other utilities and industry service and support firms, will be sufficient to enable continuous response over the long term. These resources ensure a 24-hour per day operations capability for an extended period. (3) Local and State Agencies (a) County and state Radiological Emergency Response Plans, compatible with the DAEC Emergency Plan, have been developed to guide the emergency response actions of the officials and agencies of Linn County, Benton County, and the State of Iowa. These plans reflect the assignment of responsibilities for offsite protective actions and the methods of communicating among the involved local and state agencies. Offsite protective actions within the plume exposure pathway Emergency Planning Zone (EPZ) are implemented by Linn and Benton Counties.

DAECEMERGENCYPLAN SECTION 'A' ASSIGNMENT OF RESPONSIBILITIES Rev. 27 (ORGANIZATIONAL CONTROL) Page 4 of 13 2.2 CONCEPT OF OPERATIONS (1) The emergency classification system and levels of activation are discussed in Section 'D'. Section 'E' discusses notification methods and procedures. This section and the remainder of the plan discuss the specific responsibilities and interrelationships of the emergency response organizations. The following summarizes the order of actions. (a) NOTIFICATION OF UNUSUAL EVENT (i) Upon occurrence of an event that is classified as a NOTIFICATION OF UNUSUAL EVENT, the Operations Shift Manager will direct prompt corrective action to ensure the plant is placed in or maintained in a stable condition. Key Duane Arnold officials as well as individuals from the NRC, local and state emergency response organizations will be notified. Support agencies such as the local fire departments, hospitals, etc., will be alerted as indicated in county emergency response plans. Should the event be of such a nature that escalation to a higher emergency action level is probable, local and state officials and agencies will be notified to stand by for full activation. (b) ALERT, SITE AREA EMERGENCY, or GENERAL EMERGENCY (i) Upon occurrence of an event classified as an ALERT, SITE AREA EMERGENCY, or GENERAL EMERGENCY, the Operations Shift Manager will direct prompt corrective action to return the plant to a stable condition and to stop or mitigate radiological releases, if they are occurring. Key Duane Arnold officials as well as individuals from local and state emergency response organizations will be notified of the event and nature of the emergency, including its classification. (ii) Communications will be established and maintained with these local and state agencies as described in Sections B and F to assure the flow of information necessary to assess the situation and protect the population at risk. Assessment actions will be implemented based upon the type of event and plant status to determine the potential consequences to the population at risk. The results of the assessment will be reported to local and state officials and will form the basis for decisions associated with the proper course of protective action.

DAECEMERGENCYPLAN SECTION 'A' ASSIGNMENT OF RESPONSIBILITIES Rev. 27 (ORGANIZATIONAL CONTROL) Page 5 of 13 2.3 RESPONSE ORGANIZATIONS INTERRELATIONSHIPS (1) The interrelationships between Duane Arnold, contractors and consultants, and local, state, and federal agencies are illustrated in Figure A-1 and are described below. (a) DAEC (i) Duane Arnold's relationship to the total effort includes the following: (a) Assessing the scope of the abnormal condition and determining the extent to which the situation is under control. (b) Ensuring that requisite safety-related systems and features are functioning properly, and implementing response actions that may be required to assist in regaining control of the situation. (c) Analyzing the potential or actual radiological impact within the plume exposure Emergency Planning Zone (EPZ) to determine the appropriate actions necessary to protect the populace within this EPZ. (d) Notifying appropriate local, state, and federal officials. (e) Defining the accident recovery functions to be performed by the Emergency Response Organization including providing assistance to the DAEC. (f) Assessing the existing corporate resources available and evaluating how best to apply these resources to the tasks previously defined. (g) Evaluation of the Emergency Response Organization and assignment of responsibilities based on this evaluation. (b) Linn and Benton Counties (i) The Linn and Benton County Emergency Operations Centers will coordinate their respective County's response, and will accept response requests for the DAEC. (c) Mercy Medical Center, University of Iowa Hospitals and Clinics, and Ambulance Services (i) Duane Arnold has made arrangements with Mercy Medical Center in Cedar Rapids, Center Point, Hiawatha, and Area Ambulance for ambulance service for the DAEC. Linn County Sheriffs Rescue will also provide medical assistance for the DAEC as needed. Both radiological and non-radiological injuries will normally be treated by medical personnel at Mercy Medical Center under the overall supervision of the DAEC Medical Consultant. As a backup, University of Iowa Hospitals and Clinics are available.

DAECEMERGENCYPLAN SECTION 'A' ASSIGNMENT OF RESPONSIBILITIES Rev. 27 (ORGANIZATIONAL CONTROL) Page 6of13 (d) Palo Fire Department (i) The Palo Fire Department provides first aid and backup fire-fighting support to the DAEC. Support efforts involving radiological incidents are directed and controlled by the Emergency Coordinator. (e) Iowa Homeland Security and Emergency Management Division, Iowa Department of Public Defense (HS-EMO) (i) The HS-EMO provides assistance as outlined in the State of Iowa Radiological Emergency Response Plan. In summary, support includes the following: (a) Alerting State agencies. (b) Coordinating state radiological monitoring of areas, personnel, and equipment in support of local county authorities. (c) Evaluating offsite radiological conditions. (d) Operating the State Emergency Operations Center. (e) Informing federal organizations, adjacent counties, and adjacent states. (f) Assisting local county authorities, through the State Highway Patrol, with establishing traffic and access control. (g) Establishing exposure criteria. (h) Preparing and coordinating state information releases to local and Federal agencies and to the news media. (i) Coordinating state mutual aid. (f) U.S. Nuclear Regulatory Commission (NRC) (i) The role of the NRC during a radiological emergency is to verify that emergency plans and procedures have been implemented, to assure that the public health and safety are protected, and to conduct investigative activities associated with the incident. The NRC will assist in coordinating federal response resources as specified in the NRC Incident Response Plan and will provide Duane Arnold, state, and local agencies advisory assistance associated with assessing and mitigating hazards to the public.

DAECEMERGENCYPLAN SECTION 'A' ASSIGNMENT OF RESPONSIBILITIES Rev. 27 (ORGANIZATIONAL CONTROL) Page 7of13 (g) U.S. Department of Energy (DOE) (i) The DOE has prepared a Federal Radiological Monitoring and Assessment Plan and an lnteragency Radiological Assistance Plan. Under the provisions of these plans, the DOE will, upon request from the state, dispatch radiological teams to assist local and state agencies in monitoring and provide technical guidance. For further details see Section C. (h) Federal Emergency Management Agency (FEMA) (i) The Federal Emergency Management Agency will provide federal emergency response as outlined in the National Response Plan and logistical support to the state and local governments involved in an emergency. (i) Contractors and Consultants (i) The Nuclear Steam Supply System (NSSS) at the DAEC was supplied by the General Electric Company, Nuclear Energy Systems Division, San Jose, California. General Electric has established 24-hour dedicated communications coverage which is monitored continuously by the Security Operations Center at General Electric Nuclear Energy, San Jose, California. This service will be used by the utility to request emergency assistance in the event of an emergency involving the NSSS. Actions will be taken in accordance with the latest Services Information Letter regarding the BWR Emergency Support Program. Contractual arrangements for these services are described in the GE Letter of Agreement. (ii) The Bechtel Power Corporation, Ann Arbor, Michigan, was the Architect-Engineer (AE) for the DAEC and may be requested to provide assistance. The Bechtel Emergency Response Manager will be the point of contact for the activation of Bechtel's Emergency Response Services (ERS). Upon notification from Duane Arnold of any emergency, the emergency response manager will activate Bechtel's ERS and contact the appropriate Bechtel management. Bechtel personnel will have the capability, under normal circumstances, of arriving at the DAEC within 24 hours after receipt of emergency notification. Bechtel can support many types of engineering activities. Bechtel's non-engineering departments include construction, cost and scheduling, quality assurance, procurement, and materials and quality services. Contractual arrangements for these services are described in the Bechtel Letter of Agreement. (iii) Other contractors and consultants will be used as their expertise, manpower, and facilities are required. Agreements and contracts are currently in place with each of these contractors which retain their services and define the commercial conditions of those services on a routine basis. In case of an emergency condition at DAEC, these private contractors could be contacted to augment the services they are currently providing. The Emergency Coordinator or Emergency Response and Recovery Director will coordinate the specific assistance requirements.

DAECEMERGENCYPLAN SECTION 'A' ASSIGNMENT OF RESPONSIBILITIES Rev. 27 (ORGANIZATIONAL CONTROL) Page 8of13 U) Institute of Nuclear Power Operations (i) INPO has prepared an Emergency Resources Manual (ERM) from information provided by nuclear utilities, the major AE/NSSS organizations, and responding suppliers. In general, it contains the information necessary to locate and request staff, equipment and technical support in the event of a nuclear emergency. In addition, members of INPOs staff are available to assist in obtaining these resources. 2.4 ORGANIZATIONAL RESPONSIBILITY (1) Specific individuals within the Emergency Response Organization in charge of emergency response are as follows: (a) Emergency Response and Recovery Director (b) Emergency Coordinator 2.5 DIRECTION AND COORDINATION (1) The effectiveness of directing and coordinating the company's emergency response organization is influenced by the activation times, the organization and the severity of the emergency condition. The response time terminology listed below and the emergency conditions described in Section D should be utilized as mobilization and functional control criteria. (a) Short-Term Actions -Actions that can be taken within 1 hour of initial notification of an emergency condition. (b) Near-Term Actions - Actions that can be taken within 1 to 16 hours of initial notification of an emergency condition. (c) Long-Term Actions - All actions taken 16 hours or more after initial notification of the emergency condition. (2) Activation of Emergency Response Facilities occurs when the minimum staff for each facility, as noted in Figure B-1, has arrived, been briefed on the event, and is ready to perform command and control functions. Although the facility may be ready, turnover may be postponed in the interest of completing critical tasks. As an immediate action, the on-shift plant operations staff will initiate the callout process for augmented ERO members to ensure timely staffing of the onsite and offsite facilities. Augmenting the on-shift staff with additional off-shift personnel can occur within 60 minutes of initial declaration of the emergency condition.

DAECEMERGENCYPLAN SECTION 'A' ASSIGNMENT OF RESPONSIBILITIES Rev. 27 (ORGANIZATIONAL CONTROL) Page 9 of 13 (3) The Emergency Response and Recovery Director (ER&RD), Radiological Assessment Coordinator (or their alternates), and the Joint Information Center (JIC) Manager will be notified within the time frame specified in the Emergency Plan Implementing Procedures (EPIPs). Activation of the TSC and OSC will occur at an ALERT or higher classification. The TSC and OSC have an activation time of 60 minutes. The EOF has an activation time of 60 minutes from a Site Area Emergency or higher classification. Therefore, in the near-term, key Emergency Operations Facility staff members or their designees will be available to coordinate support activities from the Emergency Operations Facility on the 15th floor of the Alliant Tower in Cedar Rapids. During a SITE AREA EMERGENCY or GENERAL EMERGENCY condition, the EOF will be activated. When an ALERT condition is declared, personnel assigned to the EOF and JIC will leave from the DAEC and report to their respective facility, whether or not the EOF and JIC have yet been activated. Shift assignments and changes will occur within 16 hours of the initial mobilization of the Emergency Response Organization. 2.6 EMERGENCY RESPONSE FUNCTIONS (1) For DAEC, the functions and the person responsible for each function are addressed below and summarized in Table A-1. The functions are addressed in more detail throughout the remainder of the plan, primarily in Section B. (a) Command and Control (i) The ER&RD exercises overall control of DAEC emergency response activities. He ensures the overall direction of site and corporate activities is properly focused and the necessary resources are available for proper response. (b) Warning/Notification Communications (i) The Operations Shift Manager, acting as the Emergency Coordinator, is responsible for initially notifying ERO personnel and offsite agencies of an emergency situation and for providing support information to aid in initial response. (c) Public Information (i) The JIC Manager is responsible for ensuring that communications links are established with the news media and for coordinating information releases to the media related to plant conditions and offsite radiological consequences.

DAECEMERGENCYPLAN SECTION 'A' ASSIGNMENT OF RESPONSIBILITIES Rev. 27 (ORGANIZATIONAL CONTROL) Page 10of13 (d) Accident Assessment (i) The Operations Shift Manager, acting as the Emergency Coordinator, is initially responsible for assessing the magnitude and potential consequences of an emergency condition and providing this information when notifying Duane Arnold, local, state, and federal officials and agencies. Subsequently, the Site Radiation Protection Coordinator assumes responsibility for dispatching appropriate personnel to monitor the environs. Upon activation of the EOF, the Radiological Assessment Coordinator assumes responsibility for directing field monitoring teams, assessing the results of monitoring activities, apprising appropriate personnel of the results of these efforts, and assisting in the development of appropriate recommendations for protective actions to be taken by the public. (e) Public Health and Protective Response (i) The Operations Shift Manager, acting as the Emergency Coordinator, is initially responsible for contact and coordination with public officials regarding protection of the general public. After activation of the Technical Support Center {TSC), the Emergency Coordinator, assisted by the Site Radiation Protection Coordinator, assumes the responsibility for contact with public officials. (ii) When the EOF is activated, the Radiological Assessment Coordinator is responsible for contact and coordination with public officials and provides recommendations associated with protective actions and alternatives that can be taken to protect the general public. He is responsible for keeping these officials apprised of changes in the condition of the plant and of releases, or planned releases, to the atmosphere. (f) Fire, Rescue/Emergency, and Medical Services (i) The Operations Shift Manager, acting as the Emergency Coordinator, is responsible for requesting and coordinating these services, if needed, during the initial stages of an accident. (g) Onsite Radiological Exposure Control (i) The Emergency Coordinator, assisted by the Site Radiation Protection Coordinator is responsible for controlling and minimizing radiological exposures to emergency response personnel and authorizing the performance of activities that may result in exposures in excess of normal limits. The Site Radiation Protection Coordinator is responsible for related onsite radiological monitoring activities, decontamination, and record keeping. (h) Access Control/Security/Accountability (i) The Security and Support Supervisor, assisted initially by the Operations Shift Manager, will assure personnel accountability is initiated and maintained, and will limit site and facility access to authorized personnel only.

DAECEMERGENCYPLAN SECTION 'A' ASSIGNMENT OF RESPONSIBILITIES Rev. 27 (ORGANIZATIONAL CONTROL) Page 11 of 13 2.7 AUTHORITY AND AGREEMENTS (1) The following identifies the legal state and federal instruments which establish authority for local and state agency support for an emergency. (a) Federal Civil Defense Act of 1950 as amended (Public Law 920, 81 st Congress) (b) Federal Civil Defense Guide, January 1965, as amended (c) Civil Preparedness Guide (d) Disaster Relief Act of 1974 as amended (Public Law 92-228) (e) 1993 Code of Iowa, Subtitle 12, Emergency Control and Chapter 29C, Emergency Management (f) Price Anderson/Stafford Act (2) Written agreements have been reached and are maintained with those support organizations that have an emergency response role within the Emergency Planning Zone. These agreements establish an understanding of assigned responsibilities and ensure proper coordination of activities in the event of an emergency. Included as Appendix 2 is a list of the support organizations with which agreements have been reached. These Letters of Agreement are kept on file with the Emergency Planning Department located onsite at the DAEC. 2.8 EXTENDED OPERATION (1) The Emergency Response Organization is capable of continuous operation from the time that emergency response actions are initiated until the recovery organization, discussed in Section M, is activated. The Emergency Response and Recovery Director is responsible for ensuring continuity of resources (technical, administrative, and material). The Emergency Coordinator has been delegated authority to obtain necessary assistance from outside agencies, such as suppliers, contractors, and consultants as required to establish stable plant conditions.

DAECEMERGENCYPLAN SECTION 'A' ASSIGNMENT OF RESPONSIBILITIES Rev. 27 (ORGANIZATIONAL CONTROL) Page 12of13 TABLE A-1 EMERGENCY RESPONSE FUNCTION AND RESPONSIBILITIES Responsible Individual 0 Q.)

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DAECEMERGENCYPLAN SECTION 'A' ASSIGNMENT OF RESPONSIBILITIES Rev. 27 (ORGANIZATIONAL CONTROL) Page 13of13 FIGURE A-1 INTERRELATIONSHIPS BETWEEN EMERGENCY ORGANIZATIONS DAEC Contractors Nuclear Regulatory

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I I, Hom eland Security and Emergency Management Division Iowa Depa rtment of Public Defense Linn County EOC Benton County EOC Mercy Medical Center Palo Fire Department Area Ambulance I University of Iowa Center Point Linn County Ambulance Hospitals and Sheriffs Rescue Clinics I Hiawatha Ambulance Federal Emergency 1-------------; Management Provides support to Agency indicated agencies Other Federal Agencies Other State State Department Agencies of Health

DAEC EMERGENCY PLAN SECTION 'B' Rev. 45 EMERGENCY RESPONSE ORGANIZATION Page 1of32 Usage Level: INFORMATION Record the following: Date I Time: _ _ _ _ _ _ I _ _ _ _ Initials: _ __ NOTE: User shall perform and document a Temp Issue I Rev. Check to ensure revision is current, in accordance with procedure use and adherence requirements. Prepared By: Date: Print Signature APPROVAL BY LICENSING MANAGER Approved By I Date: Print Signature APPROVAL BY ORG Approved By I Date: Print Signature APPROVAL BY DAEC SITE DIRECTOR Approved By I Date: Print Signature

DAEC EMERGENCY PLAN SECTION 'B' Rev. 45 EMERGENCY RESPONSE ORGANIZATION Page 2 of 32 Table of Contents Section Numbers Section Titles Page 1.0 PURPOSE 3 2.0 REQUIREMENTS 3 2.1 RESPONSE POSITIONS 3 2.2 ONSITE RESPONSE ASSIGNMENTS 4 2.3 OFFSITE (EOF & JIC) RESPONSE ASSIGNMENTS 15 2.4 LONG-TERM ORGANIZATION 21 2.5 INTERFACES 23 2.6 LOCAL SUPPORT SERVICES 25 3.0 ATTACHMENTS 25 Table B-1, "On-Shift Staffing & Staff Augmentation Attachment 1 26 Assignments" Attachment 2 Figure B-1, "Emergency Response Organization" 29 Attachment 3 Figure B-2, "Immediate Response Interface" 31 Attachment 4 Figure B-3, "Long-Term Response Interface" 32

DAEC EMERGENCY PLAN SECTION 'B' Rev. 45 EMERGENCY RESPONSE ORGANIZATION Page 3 of 32 1.0 PURPOSE (1) This section describes the structure of the Emergency Response Organization and the specific responsibilities and authorities of key response personnel. Support services available with the DUANE ARNOLD (DAEC) to augment the Emergency Response Organization are identified as well as those services that may be provided by the DAEC, contractors, and local organizations. 2.0 REQUIREMENTS 2.1 RESPONSE POSITIONS ( 1) The Emergency Response Organization is as illustrated in Figure B-1, and in the text of Section 'B' and Section 'H' of the DAEC Emergency Plan. Personnel qualified to fulfill the emergency response positions are identified in the Emergency Telephone Book, Learning Management System (LMS), and in the DAEC Emergency Preparedness Department's Training Records, which are considered to be the most up-to-date record available. The Emergency Response Organization (ERO) structure can be modified as required by the Emergency Coordinator or Emergency Response & Recovery Director (ER&RD).

DAEC EMERGENCY PLAN SECTION 'B' Rev. 45 EMERGENCY RESPONSE ORGANIZATION Page 4 of 32 2.2 ONSITE RESPONSE ASSIGNMENTS Immediate response organizational assignments, lines of succession, and responsibilities are as described below, for the Onsite organization. 2.2.1 EMERGENCY COORDINATOR (1) Assignment (a) The Emergency Coordinator functions onsite, coordinates the total site response effort, and normally operates from the Technical Support Center (TSC). The Emergency Coordinator reports to the ER&RD and has full authority and responsibility to initiate emergency actions and to recommend appropriate offsite protective measures to local and state authorities during the initial stages of the event as discussed in Section A. (2) Lines of Succession (a) The Operations Shift Manager (OSM) functions as the Emergency Coordinator until relieved. A qualified person will assume the responsibility of the Emergency Coordinator and receives turnover from the OSM. If necessary, the ER&RD will appoint the position of Emergency Coordinator and will inform the Operations Shift Manager of the appointment. (3) Responsibilities (a) The Emergency Coordinator exercises full responsibility and authority for all activities at the site. This position is a 60-minute ERO response reporting position. He/she is assigned the following functional responsibilities: (i) Ensure the activation of the onsite Emergency Response Organization as appropriate for the classification and circumstances of the emergency condition. (ii) Coordinate efforts to return the plant to and maintain it in a safe, stable condition. (iii) Coordinate accident assessment and analyses efforts to determine the full scope and impact of the emergency. (iv) Ensure appropriate initial notification of DAEC, local, state, and federal officials and agencies. This function will be assumed by the Emergency Operations Facility (EOF) when activated.

DAEC EMERGENCY PLAN SECTION 'B' Rev. 45 EMERGENCY RESPONSE ORGANIZATION Page 5 of 32 (v) Provide initial Protective Action Recommendations, as appropriate, to local and state authorities who are responsible for offsite protective measures. This function will be assumed by the Emergency Operations Facility upon activation of that facility. (vi) Apprise DAEC, local, state, and federal officials and agencies of updated information pertaining to the emergency condition. (vii) Classify/reclassify the event as necessary. (viii) Approve extensions on exposure limits for emergency workers, if necessary. (ix) Select alternate location for the Offsite Relocation & Assembly Area if radiological release and meteorological conditions warrant a change. (x) Prepare the Emergency Response Organization for an orderly transfer of responsibilities to the recovery organization. (b) While the administrative aspects of most of these responsibilities may be delegated by the Emergency Coordinator, the responsibilities for items 2.2.1 (3)(a)(v), 2.2.1 (3)(a)(vii), and 2.2.1 (3)(a)(viii) may not be delegated except as indicated herein. Upon operation of the EOF, the ER&RD assumes responsibility for these non-delegable duties. 2.2.2 OPERATIONS SHIFT MANAGER (OSM) (1) Assignment (a) The OSM, located in the Control Room, shall provide direction as required to return the plant to or assure that it is maintained in a safe, stable configuration. (2) Lines of Succession (a) Generally, the Operations Shift Manager, the senior individual, assumes the role of Emergency Coordinator. (3) Responsibilities (a) The Operations Shift Manager evaluates the abnormal condition and implement emergency response actions as specified in the Emergency Plan Implementing Procedures (EPIPs) including:

Classifying the event

DAEC EMERGENCY PLAN SECTION 'B' Rev. 45 EMERGENCY RESPONSE ORGANIZATION Page 6 of 32

Recommending Protective Actions, if appropriate
Notifying county, state, and federal officials and offsite support agencies as necessary
Notifying the Emergency Response Organization 2.2.3 SITE RADIATION PROTECTION COORDINATOR (1) Assignment (a) The Site Radiation Protection Coordinator will operate from the TSC and initiate those activities related to radiological assessment of the environs surrounding the plant during the initial stages of the event. Offsite monitoring will be assumed by the Radiological Assessment Coordinator upon activation of the EOF.

(2) Lines of Succession (a) The Operations Shift Manager functions as the Site Radiation Protection Coordinator until officially relieved by the Emergency Coordinator. A qualified Site Radiation Protection Coordinator informs the Emergency Coordinator that he/she is ready to assume that position's responsibilities. If necessary, the Emergency Coordinator will appoint the Site Radiation Protection Coordinator. (3) Responsibilities (a) This position is a 60-minute ERO response reporting time position. (b) The Site Radiation Protection Coordinator is responsible for the following activities:

Ensuring that DAEC personnel are dispatched to monitor the environs in and around the plant for radiological consequences associated with the event.
Conducting an initial evaluation and assessment of the results of radiological monitoring activities. Upon activation of the EOF, evaluation and assessment of all offsite monitoring activities will be assumed by the Radiological Assessment Coordinator.

DAEC EMERGENCY PLAN SECTION 'B' Rev. 45 EMERGENCY RESPONSE ORGANIZATION Page 7 of 32

Assessing the onsite radiological consequences and directing protective measures, including the need for partial or complete evacuation of the plant.
During the initial stages of the event, apprising local and state authorities, through the Emergency Coordinator, of the results of radiological monitoring activities and providing protective action recommendations based upon the projected radiological consequences to the population at risk. Upon activation of the EOF, this function will be assumed by the Radiological Assessment Coordinator.

2.2.4 SECURITY AND SUPPORT SUPERVISOR (1) Assignment (a) The Security and Support Supervisor will exercise supervision and direction of the security staff and direction over the personnel assigned to the TSC support staff. (2) Lines of Succession (a) If necessary, the Emergency Coordinator will appoint the Security and Support Supervisor. (3) Responsibilities (a) This position is a 60-minute ERO response reporting time position. (b) Upon activation of the TSC, the Security and Support Supervisor is responsible for:

Assuring that an accountability check for all personnel within the protected area is conducted in a timely fashion and that requisite security posts are filled.
Ensuring that the Emergency Response Organization notification process as described in the Emergency Plan Implementing Procedures has been initiated and is successfully completed.
Assuring the TSC closed ventilation system is operational and activated.
Limiting access into the facility to only those personnel who are members of the Emergency Response Organization, or otherwise are authorized.
Establishing measures that will enable continuous accountability for all personnel within the protected area once the initial accountability check has been completed.

DAEC EMERGENCY PLAN SECTION 'B' Rev. 45 EMERGENCY RESPONSE ORGANIZATION Page 8 of 32

Ensuring that no unauthorized personnel gain access to the site.
Assigning personnel for first aid duties, as required.
Providing overall management and direction to the support staff assembled in the TSC.

2.2.5 TECHNICAL AND ENGINEERING SUPERVISOR (1) Assignment (a) The Technical and Engineering Supervisor will exercise overall management and supervision of engineering, analysis and corrective action efforts undertaken by engineering and maintenance personnel at the DAEC from the TSC. In addition, he/she will coordinate with the Emergency Response Organization for engineering support efforts undertaken at the request of the Emergency Coordinator. (2) Lines of Succession (a) If necessary, the Emergency Coordinator will appoint the Technical and Engineering Supervisor. (3) Responsibilities (a) This position is a 60-minute ERO response reporting time position. (b) Upon activation of the site Emergency Response Organization and the Technical Support Center, the Technical and Engineering Supervisor is responsible for:

Verifying that the TSC is fully activated and staffed as described in the Emergency Plan Implementing Procedures.
Evaluating plant status and providing support to the operations staff as requested.
Assisting the Emergency Coordinator in establishing the priority for repair activities to be undertaken.
Providing direction to the technical staff comprised of support personnel such as the Fire Marshal, Safety Supervisor, and consultant/contractor representatives to analyze plant conditions and define courses of action to mitigate the emergency situation.

DAEC EMERGENCY PLAN SECTION 'B' Rev. 45 EMERGENCY RESPONSE ORGANIZATION Page 9 of 32

Providing direction to the engineering staff in TSC to aid in analysis of plant conditions and define courses of action to mitigate the emergency situation.
Coordinating corporate engineering activities with efforts being taken at the DAEC to mitigate the event and establish stable plant conditions.
Providing support to the Operations Support Center (OSC) Supervisor as necessary for coordinating all repair/corrective action efforts conducted at the DAEC.

2.2.6 ADMINISTRATIVE SUPERVISOR (1) Assignment (a) The Administrative Supervisor will provide administrative and logistics support, as required, in the event that activation of the site Emergency Response Organization is required from the Technical Support Center. (2) Lines of Succession (a) If necessary, the Security and Support Supervisor will appoint someone to fill this position. (3) Responsibilities (a) This position is a 60-minute ERO response reporting time position. (b) Services to be provided under the direction of the Administrative Supervisor include, but are not limited to:

Clerical, typing, and copying services.
Document retrieval.
Food services, clothing and overnight accommodations.
Coordination of transportation services and any facilities or office space needs.
Determining existing and potential administrative support needs and providing recommendations to the Security & Support Supervisor, as required.
Providing updates of status and relevant log information.

DAEC EMERGENCY PLAN SECTION 'B' Rev. 45 EMERGENCY RESPONSE ORGANIZATION Page 10 of 32 2.2.7 TSC OPS LIAISON (1) Assignment (a) The TSC Operations Liaison will provide operations support, as required, in the event that activation of the site Emergency Response Organization is required from the Technical Support Center. (2) Lines of Succession (a) If necessary, the Emergency Coordinator will appoint the TSC Operations Liaison. (3) Responsibilities (a) This is a 60-minute ERO response reporting time position. (b) The TSC Ops Liaison is responsible for the following:

Advising the EC on EAL/PAR declarations
Generating paperwork required for EAL/PAR declarations
Ensuring the State, Counties, and NRC receive notification regarding EALs and PARs
Providing an operational insight and tracking plant status
Advising the EC on matters that pertain to the plant as part of the Severe Accident Management Team.
Assist the TSC in all matters pertaining to the Control Room and to Operations Department activities.
Providing direction and assistance, as necessary, to the OSM/CRS to achieve and maintain stable plant conditions.
Assisting the OSM/CRS in coordinating operational activities.
Monitoring operational activities to assure that the plant is operated and maintained in as safe a condition as possible.
Evaluating recommendations for corrective action provided by the technical staff and operating crew and recommending to the Emergency Coordinator a course of action to be taken to mitigate the situation.

DAEC EMERGENCY PLAN SECTION 'B' Rev. 45 EMERGENCY RESPONSE ORGANIZATION Page 11 of 32

Recommending changes to the Emergency Classification based upon:

(i) Plant status changes, with or without radiological releases in progress. (ii) Actual or potential radiological release parameters. (iii) The progress of those activities undertaken to mitigate the situation and their probability for success.

Ensure Control Room is kept informed of TSC and OSC activities and priorities.
Assist EC and Control Room on plant condition status and trends.
Planning work packages for repair activities with assistance of engineering personnel in the TSC.

2.2.8 OPERATIONAL SUPPORT CENTER (OSC) SUPERVISOR (1) Assignment (a) The OSC Supervisor will exercise supervision and direction over the personnel who report to the OSC. He/she will report to the Emergency Coordinator in the TSC and will coordinate repair/corrective action efforts conducted at DAEC. (2) Lines of Succession (a) If necessary, the Emergency Coordinator will appoint the OSC Supervisor. (3) Responsibilities (a) This position is a 60-minute ERO response reporting time position.

DAEC EMERGENCY PLAN SECTION 'B' Rev. 45 EMERGENCY RESPONSE ORGANIZATION Page 12 of 32 (b) Upon activation of the Emergency Response Organization the OSC Supervisor is responsible for:

Supervising the implementation of the tasks and staffing delineated by the Emergency Assignment Staffing Board.
Providing general supervision and direction to personnel who report to the OSC.
Coordinating evacuation from the site of all unnecessary personnel during events classified as a SITE AREA or GENERAL EMERGENCY, once such an evacuation has been authorized by the Emergency Coordinator.
Coordinating all repair/corrective action efforts conducted at the DAEC to achieve stable plant conditions and to terminate any uncontrolled or excessive radiological release.
Ensuring that personnel dispatched from the OSC are properly briefed and equipped for their assignment in regards to technical content, as well as ALARA, including existing and potential radiological hazards.

2.2.9 HEALTH PHYSICS SUPERVISOR (1) Assignment (a) The Health Physics Supervisor will provide overall direction and supervision in regards to ALARA and radiological practices to personnel in the OSC. In addition, he/she will provide direction to personnel for habitability of assembly areas. (2) Lines of Succession (a) If necessary, the OSC Supervisor will appoint the Health Physics Supervisor. (3) Responsibilities (a) This position is a 60-minute ERO response reporting time position. (b) Upon activation of the Emergency Response Organization the Health Physics Supervisor is responsible for:

Ensuring that personnel dispatched from the OSC are properly outfitted with protective clothing and equipment, briefed regarding ALARA, and apprised of existing and potential radiological hazards.

DAEC EMERGENCY PLAN SECTION 'B' Rev. 45 EMERGENCY RESPONSE ORGANIZATION Page 13 of 32

Coordinating with the Site Radiation Protection Coordinator to obtain information regarding plant status, problems, response options, significant radiological releases in progress, offsite dose rates, plume location, and meteorological conditions as necessary.
Ensuring the determination of habitability of assembly areas and ERO facilities.
Coordinating the dispatch of monitoring teams and Offsite Relocation and Assembly Area (ORAA) personnel.
Ensuring the ORAA is briefed periodically in terms of plant and radiological conditions.
Supervising efforts to prepare injured/contaminated personnel for transport to offsite medical facilities.

2.2.10 MINIMUM STAFFING (1) On-shift staffing and staff augmentation assignments are identified in Table B-1. The staffing plan is consistent with the guidance contained in NUREG-0654. On-shift staffing as noted in Table B-1 has been validated by an On-shift Staffing Analysis completed in accordance with the requirements of 10 CFR 50 Appendix E, IV.A.9. Details regarding the assignments and associated responsibilities are addressed in the EPIPs. 2.2.11 OTHER DAEC ORGANIZATIONAL ASSIGNMENTS In addition to the key response personnel described in the preceding sections, other DAEC personnel will assume roles as necessary in supporting the overall emergency response. Assignments and responsibilities of these support groups follow: (1) Security (a) Upon activation of the plan, for events classified as an ALERT or greater, the DAEC Security Force is responsible for performing an accountability check for all personnel within the protected area and controlling access to the site property. If evacuation of the site is required, the Security Force will assist in the evacuation and conduct an accountability check of all personnel dispatched to the ORAA. (2) Administrative (a) The DAEC Administrative Support Staff will provide general logistical support functions to aid response organization activities. This includes long range planning

DAEC EMERGENCY PLAN SECTION 'B' Rev. 45 EMERGENCY RESPONSE ORGANIZATION Page 14 of 32 for providing personnel, material, facilities and office and clerical services. Additionally, the administrative staff will coordinate warehouse and procurement activities and obtain life support services such as food, clothing, and overnight accommodations. (3) Technical/Engineering (a) The technical and maintenance support staffs will provide plant engineering, maintenance assistance and coordination of corrective actions taken to mitigate the emergency condition, or terminate a release. This includes analytical and engineering efforts of site and corporate engineers and supervision and technical direction of activities performed by engineering, maintenance, or construction crafts. (4) Quality Assurance (a) Quality Assurance can provide assistance to design, procurement, and construction activities that are required to establish cold shutdown conditions. Quality Assurance can define and track activities that are not conducted in accordance with normal established practices, and can ensure that post-accident evaluations are conducted to verify the acceptability of those activities for both short and long term service. (5) Materials Management (Warehouse) (a) The Warehouse Supervisor will provide warehouse and procurement support in the event that procurement of specialized parts/equipment not currently stored on-site, or available locally, is required. (i) The site staff has the ability to procure site stores, and locally available stores, (equipment, parts, etc.) without involving the Warehouse Supervisor. (6) Contracts and Agreements (a) Assistance to the emergency response effort will be available from the Nuclear Steam Supply System supplier (General Electric), Architect-Engineer (Bechtel) and other consultants. Agreements and contracts are currently in place with each of these organizations which retain their services and define the commercial conditions of those services on a routine basis. In case of an emergency condition at DAEC, these private contractors could be contacted to augment the services they are currently providing. Agreements have been negotiated for emergency services as necessary.

DAEC EMERGENCY PLAN SECTION 'B' Rev. 45 EMERGENCY RESPONSE ORGANIZATION Page 15 of 32 Section A of the DAEC Emergency Plan provides further details on the availability of contractors and consultants. (7) Safety (a) The Safety Specialist can advise Corporate Management in the area of safety. When a personal injury accident occurs at DAEC, the Safety Specialist can provide investigative reports reflecting the events that led up to the accident. He/she can indicate whether safety rules and procedures were followed and recommend follow-up corrective/disciplinary actions. Additionally, the Safety Specialist is responsible for reporting all serious accidents to the Iowa Occupational Safety and Health Administration, a branch of the Iowa Bureau of Labor. 2.3 OFFSITE (EOF & JIC) RESPONSE ASSIGNMENTS 2.3.1 The Emergency Operations Facility and Joint Information Center (JIC) provide the following principal functions in the overall response to an emergency at the DAEC once control is transferred from the Technical Support Center: (1) Establishes a single focal point for performing radiological dose assessment and Protective Action Recommendation decision-making, including coordination and interface with local, state, and federal support groups (2) Establishes a coordinated means to disseminate information related to the accident to public officials, the news media, and industry public relations forums. 2.3.2 Response positions are as follows: (1) Emergency Response and Recovery Director (ER&RD) (a) Assignment (i) The ER&RD is responsible for the overall direction and control of DAEC's integrated emergency response and recovery effort and providing the financial resources and contractual capabilities to ensure requisite actions can be taken to protect the health and safety of the public.

DAEC EMERGENCY PLAN SECTION 'B' Rev. 45 EMERGENCY RESPONSE ORGANIZATION Page 16 of 32 (b) Responsibilities (i) This is a 60-minute ERO response time reporting position. (ii) Ensuring that the Emergency Response Organization is staffed by qualified personnel and coordinating with these personnel to ensure that sufficient support for various functions is available, either from within Duane Arnold or from outside organizations (i.e., other utilities, Architect Engineers, Nuclear Steam Supply System suppliers, INPO, consultants, etc.). (iii) Authorizing the procurement of equipment, materials, and resources, as necessary, to effectively respond, control, and recover from an accident condition at DAEC. (iv) Implementing the Emergency Plan Implementing Procedures (EPIPs). (v) Reviewing and concurring with Protective Action Recommendations prior to their issuance once the Emergency Operations Facility (EOF) is operational. (2) Radiological Assessment Coordinator (a) Assignment (i) The Radiological Assessment Coordinator is responsible for coordinating and directing all offsite radiological monitoring and dose assessment programs and supervising activities within the EOF. He/she will be accountable to the ER&RD. (b) Responsibilities (i) Establishing communications with the TSC as necessary. Obtaining information on the diagnosis and prognosis of the accident condition, the quantities of radioactive material releases, and the prevailing meteorological conditions. (ii) Coordinating the onsite and offsite radiological monitoring activities to provide anticipated release rates and projected dose rates. (iii) Interpreting radiological data for updating the ER&RD, county, state, federal and support agencies in terms of projected radiological exposures and actual dose measurements. This includes providing estimates of total population exposure when necessary. Providing radiation protection for those assembled at the EOF. (iv) Analyzing all information for significant trends while developing Protective Action Recommendations (PARs). Review the recommendations with the Emergency

DAEC EMERGENCY PLAN SECTION 'B' Rev. 45 EMERGENCY RESPONSE ORGANIZATION Page 17 of 32 Response and Recovery Director and, when authorized, provide them to the state and county officials. (v) Providing assistance to county, state, and federal officials for recovery activities. (vi) Advising the ER&RD to ensure compliance with legal and regulatory requirements. (vii) Directing and coordinating offsite monitoring teams. (viii) Performing dose projection calculations. (ix) Providing Protective Action Recommendations, as required, to the Emergency Response and Recovery Director. (x) Coordinating the necessary support to other Agencies and support groups in field assessment, data analysis, and environmental sample analysis. (xi) Coordinating with the State of Iowa in tracking the plume offsite. (3) Support Services Coordinator (a) The Support Services Coordinator will assure that necessary resources and activities are provided by staff personnel. Specific areas are available to support the overall emergency response and recovery effort conducted both at the Alliant Tower and at the site. This includes security, communications, personnel, transportation, purchasing, industrial relations, and safety. He/she will also coordinate, as necessary, the application of resources and equipment available within Duane Arnold departments. (i) Security

The Support Services Coordinator in cooperation with the Alliant Corporate Security Manager is responsible for providing security for the Alliant Tower and controlling access to the EOF, JIC, and backup facility to the JIC as well as appropriate Duane Arnold working areas in the building. Staff assistance for building security will be provided by the security force under contract, and, to the extent possible, the Cedar Rapids Police Department and the Linn County Sheriffs office. Further details and instructions for establishing and maintaining security are provided in the EPIPs.

DAECEMERGENCYPLAN SECTION 'B' Rev. 45 EMERGENCY RESPONSE ORGANIZATION Page 18 of 32 (ii) Communications

The Local Telephone Companies can provide engineering support for commercial telephone installations that are permanent or temporary. He/she can respond to identified communication needs and problems and coordinate necessary engineering and maintenance support for restoration or rearrangement of Duane Arnold communications systems.

(iii) Corporate Services

The Corporate Services Department can provide required services and equipment such as record and document retrieval and reproduction, office supplies, office furniture, photography, facility and area maps, audio visual aids, graphics, printing, distribution services, and general housekeeping services.

(iv) Personnel

Administrative personnel can be contacted to provide personnel to augment the administrative and clerical support functions associated with initial activation and continued operation of the EOF and JIC.

(v) Logistics and Transportation

Transportation personnel can respond to identified transportation needs and emergency air and land transportation necessary for materials and personnel. He/she can arrange for rental cars and hotel accommodations for those personnel temporarily assigned to the Cedar Rapids area in support of the response and recovery effort. They can also provide for repairing and maintaining a transportation fleet and implementing contracts with commercial carriers to obtain priority transportation.

(vi) Purchasing

Purchasing and Materials personnel can respond to identified needs related to procurement of materials and services and coordinate onsite and offsite procurement activities to assure rapid delivery of materials. They can augment Duane Arnold resources by activating contracts with outside agencies and requesting, through use of prepared lists, emergency equipment available in Cedar Rapids.

DAEC EMERGENCY PLAN SECTION 'B' Rev. 45 EMERGENCY RESPONSE ORGANIZATION Page 19 of 32 (vii) Industrial Relations

The Manager, Industrial Relations can assess and respond to contractual problems that may arise during the course of the event and apprise bargaining unit officials and trade counsels of existing or projected labor problems. He/she can also assist in the response to manpower needs through the use of established manning lists, a computerized skill inventory of DAEC employees, and the activation of established contracts/agreements with outside organizations.

(viii) Supplemental Resources

The Operations and Production Departments of Duane Arnold can augment the DAEC staff during an emergency. Personnel and equipment are available to provide maintenance and construction services at the DAEC.

Materials, equipment, and machine shop services are also available. (4) EOF Ops Liaison (a) The EOF Ops Liaison is responsible for the following: (i) Advising the ER&RD on Emergency Action Levels (ii) Providing an operational insight and tracking plant status (iii) Communicating with county, state, federal and support agencies to relate accident information necessary for the offsite authorities to implement their county and state emergency plans and procedures. (iv) Ensuring the State, Counties, and NRC receive notification regarding EALs and PARs (v) Assisting in the recovery phase of the emergency (vi) Advising the ER&RD on matters that pertain to the plant (5) Joint Information Center (JIC) Manager (a) Assignment: (i) Working in coordination with Corporate Communications and in cooperation with the Corporate JIC Manager, the Site JIC Manager is responsible for the overall direction and control of the Site JIC so as to ensure that accurate and timely

DAECEMERGENCYPLAN SECTION 'B' Rev. 45 EMERGENCY RESPONSE ORGANIZATION Page 20 of 32 information is provided to the public, and that information releases and news media briefings with local, county, state and federal public relations officials are coordinated. (b) Responsibilities: (i) Coordinate with the ER&RD and the Corporate JIC Manager to determine the level of activation at an Unusual Event or Alert and to ensure the Site JIC is activated at a Site Area Emergency. (ii) Supervise all communication operations at the Site JIC and coordinate the distribution of all information releases and statements with the Corporate JIC Manager and offsite partners. (iii) Coordinate with Corporate Communications media conferences at the Site JIC as appropriate, with the goal of each participating organization to provide clear, consistent messages to the public. (iv) Work directly with the Corporate JIC Manager to ensure support for the following functions:

1. Coordinate and provide information to the Business Units such as legal, risk management, finance, and human resources as needed.

2. Media monitoring of local and national news outlets.

3. Information releases and coordination of information requests.

4. Interview coordination (6) Corporate JIC Manager (a) The Corporate JIC Manager leads the Emergency Communication Team (ECT) organization located at the Site JIC, informs and influences communication strategies and tactics and provides critical information to the ECT to develop messages.

DAECEMERGENCYPLAN SECTION 'B' Rev. 45 EMERGENCY RESPONSE ORGANIZATION Page 21 of 32 (7) Emergency Communication Team (ECT) (a) The ECT is a corporate team that supports the operation of the Site JIC and execution of communication tasks during a declared nuclear emergency. The ECT will recommend and execute public information plans and strategies on behalf of the company and its executive leadership. The ECT is responsible for gathering information about an incident, developing and distributing messaging, monitoring media and social media and executing all other functions deemed necessary to accurately communicate during an emergency. 2.4 LONG-TERM ORGANIZATION (1) Activation of the onsite Emergency Response Organization will, directly and indirectly, result in a response by essentially all personnel normally associated with the DAEC, particularly by management and key support personnel. Therefore, within several hours after the initiating event, decisions will be made to provide and prepare for a long term augmented emergency organization. The Emergency Response and Recovery Director will determine when the Recovery Organization is to be implemented. Prior to implementation of the Recovery Organization, the situation may require that the onsite Emergency Response Organization remain in place for a protracted period of time. As conditions allow, shift schedules will be developed by the various facilities. Prior to implementation, these schedules shall be reviewed and concurred with by the facility leads. The Emergency Response Organization is set up on a team concept for 24-hour coverage. (2) Duane Arnold maintains the resources and capabilities to support response and recovery activities in the event of an emergency or accident condition at the DAEC. These include, but are not limited to, the following: (a) Management direction and control (b) Corporate and government affairs (c) Public information and public relations (d) Communications systems (e) Security and administration (f) Medical and first aid

DAECEMERGENCYPLAN SECTION 'B' Rev. 45 EMERGENCY RESPONSE ORGANIZATION Page 22 of 32 (g) Transportation and accommodations (h) Commissary and catering (i) Purchasing and stores U) Construction, maintenance, and mobile equipment and materials (k) Appropriate staff and work force augmentation (I) Engineering activities (i) Nuclear fuel (ii) Design and construction (iii) Electrical, instrumentation, mechanical (iv) Chemistry and metallurgy (m) Planning and scheduling (n) Radiological analysis and protection (o) Accident analysis (p) Meteorological monitoring and analysis (q) Health physics and decontamination (r) Fire Protection (s) Procedure development (t) Operations and maintenance (u) Quality assurance and control (v) Contracts and agreements (w) Company records and files (x) Safety

DAEC EMERGENCY PLAN SECTION 'B' Rev. 45 EMERGENCY RESPONSE ORGANIZATION Page 23 of 32 2.5 INTERFACES 2.5.1 Figures B-2 and B-3 illustrate the immediate and long-term response interfaces, respectively, between the Emergency Response Organization and organizations of affected local, state and federal offices and agencies. The TSC, OSC, EOF, and JIC are described and discussed in Section H. (1) Public Information and Governmental Relations (a) During a nuclear incident, State and County officials will activate their local emergency operations centers and will send PIOs to the Site Joint Information Center (JIC). The Site JIC Manager is responsible for working with the state and county PIOs to ensure the timely and coordinated release of information to the public. The Corporate Emergency Communication Team (ECT) aligns with and supports the Site JIC Manager. (b) If the Cedar Rapids/Marion metropolitan area is evacuated, JIC spokespersons, state and county PIOs and appropriate support staff can be relocated to facilities on the main campus of Kirkwood Community College to continue media briefings and news conferences. (c) Press Briefings and Public Relations (i) The Site Joint Information Center will function as the principal focal point for coordination of information to the public regarding the emergency condition at the DAEC. Press briefings will be coordinated by the JIC Manager, who will ensure that appropriate emergency response and corporate individuals are available to provide technical information and respond to inquiries from the assembled media personnel. Information related to the plant as well as generic information related to the nuclear industry will be available to the media. Further details and instructions related to press briefings and public relations are provided in the EPIPs.

DAEC EMERGENCY PLAN SECTION 'B' Rev. 45 EMERGENCY RESPONSE ORGANIZATION Page 24 of 32 (d) Apprising Public Officials and Agencies (i) The facilities in the JIC will be used, as appropriate, following the issuance of Protective Action Decision (PADs) made by offsite officials. The Corporate and Site JIC Managers will work in collaboration with offsite partners to establish a cohesive communication strategy, with the goal of effectively communicating with the public. (2) Corporate Assistance (a) Legal Counsel (i) Legal Counsel can provide the ER&RD with advice to prevent DAEC from taking actions that could increase corporate liability or jeopardize indemnification agreements when handling claims and litigation. (b) Insurance and Claims (i) Insurance and Risk personnel can advise the ER&RD in the area of insurance and claims, and provide them with regular status reports on the injured or contaminated individuals treated at nearby medical facilities. They interface with American Nuclear Insurers and can apprise them of the details, the sequence of events, the impact of the emergency, and the actions being taken to mitigate its consequences. They also interface with Nuclear Electric Insurance Limited and Nuclear Mutual Limited (NEIL/NML), a utility-owned captive insurance group, which covers the loss of generation and coordinates claims filed on behalf of DAEC. (ii) Insurance and Risk personnel will coordinate with nearby medical facilities and backup medical facilities at the University of Iowa Hospitals and Clinics, as required, in the treatment of radiological and non-radiological injuries. Insurance and Risk personnel can also complete all insurance forms and document all events affecting insurance and claims during the emergency.

DAEC EMERGENCY PLAN SECTION 'B' Rev. 45 EMERGENCY RESPONSE ORGANIZATION Page 25 of 32 2.6 LOCAL SUPPORT SERVICES (1) Agreements have been reached with local agencies and private support facilities with regard to the type of support that will be furnished to the DAEC in the event of an emergency. These agreements in the form of letters of agreement (refer to Appendix 2 for list of letters) and agreements of responsibility as described in the Linn and Benton County Radiological Emergency Response Plans have been developed to ensure that there is a clear understanding of assigned responsibilities and that there will be proper coordination of activities in the event of an emergency. The Letters of Agreement will be updated as necessary and confirmed as acceptable at least every two years. Linn County, Benton County, and the State of Iowa are notified of classified events using the communication methods described in Section E "Notification Methods and Procedures". Through this formal process, and other informal communication processes, resources can be requested from the County and State Emergency Response Organizations. Existing agreements are in place to supply the site with resources requested. Examples are: (a) Emergency Medical Services (EMS) - Emergency medical services and ambulances as requested by DAEC and implemented using the Incident Command System (ICS). (b) Fire and Rescue - Fire response, fire apparatus, and volunteer firefighters as requested by DAEC and implemented using the ICS. Additionally, the Counties have mutual aid agreements to obtain additional resources from surrounding counties. Processes are also in place for Counties to request resources from the State. The site Security Plan contains information on how local law enforcement is contacted for a hostile action. 3.0 ATTACHMENTS (1) Table B-1, "On-Shift Staffing & Staff Augmentation Assignments" (2) Figure B-1, "Emergency Response Organization" (3) Figure B-2, "Immediate Response Interface" (4) Figure B-3, "Long-Term Response Interface"

DAEC EMERGENCY PLAN SECTION '8' Rev. 45 EMERGENCY RESPONSE ORGANIZATION Page of 26 32 Table B-1 On-Shift Staffina & Staff Auamentation Assianments Major Functional Areas Major Tasks Position Title or Expertise On-Shift Capability for Response Comments (All positions are 24-hour staffing) *=see additions Location Comments 60min 90min Plant Operations and Respond to condition and Operations Shift Manager (Certified Fuel 1 CR Provides early direction and control until assessment or mitigate operational event Handler) relieved by the Emergency Coordinator operational aspects consequences Non-Certified Operator (NCO) 2 CR One NCO is designated as the Fire Brigade Leader Emergency Direction Site utility Emergency Operations Shift Manager (CFH) CR Assumed by the OSM until relieved and Control Management Notification/ Notify licensee, state, Operations Shift Manager (CFH) CR Assumed by the OSM until relieved Communications local & federal personnel and maintain TSC Operations Liaison TSC communications NRC ENS Communicator TSC EOF Ops Liaison EOF Radiological Accident Overall utility Emergency Emergency Coordinator TSC Assessment and Management and offsite Support of Operational agency interface Emergency Response and Recovery EOF Accident Assessment Director Offsite Dose Assessment NCO and Protective Action Recommendations Site Radiation Protection Coordinator TSC MIDAS Operator TSC Rad Assessment Coordinator EOF EOF MIDAS Operator [ Page 1 Subtotal I 3 I 9 . I O I

DAEC EMERGENCY PLAN SECTION 'B' 45 EMERGENCY RESPONSE ORGANIZATION Rev. Page 27 of 32 Table B-1 On-Shift Staffinq & Staff Auomentation Assionments Major Functional Areas Major Tasks Position Title or Expertise On-Shift Capability for Response Comments (All positions are 24-hour staffing) *=see additions Location Comments 60min 90min Offsite Surveys HP Technician osc May be staffed by Plant Personnel trained in the HP role for Field Teams. DAEC Staff Member osc HP Technician osc May be staffed by Plant Personnel trained in the HP role for Field Teams. DAEC Staff Member osc Onsite and In-Plant HP Technician osc Surveys Chemistry/Radio- Chemistry Technician osc Performed by HP Technician until relieved chemistry Plant System Technical Support Tech and Engineering Supervisor TSC Engineering Repair and Corrective Actions Repair and corrective OSC Supervisor osc actions Mechanical Maintenance osc Electrical Maintenance osc l&C Technician osc Protective Actions (ln- Radiation Protection HP Technicians osc Performed by RP Technician responsible Plant) including Access control, for onsite and in-plant surveys RP coverage for repair and corrective action, search & rescue, first aid and firefighting. I Page 2 Subtotal I 1 I 9 I 4 j

DAEC EMERGENCY PLAN SECTION 'B'

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EMERGENCY RESPONSE ORGANIZATION Table B-1 On-Shift Staffina & Staff Auamentation Assianments Major Functional Areas Major Tasks Position Title or Expertise On-Shift Capability for Response Comments (All positions are 24-hour staffing) *=see additions Location Comments 60 min 90 min Table B-1 On-Shift Staffing & Staff Augmentation Assignments Major Functional Areas Major Tasks Position Title or Expertise On-Shift Capability for Response Comments (All positions are 24-hour staffing) *=see additions Location Comments 60 90 min min Fire Fighting 4 Local Support Fire Brigade per FP-AB-100. Rescue Operations and Local Support May be provided by shift personnel First Aid assigned other functions. Site Access Control and Security, fire fighting, Security All per Security Plan. Personnel Communications, Accountability personnel accountability Page 1 Subtotal 3 9 0 Page2 Subtotal 1 9 4 Page3 Subtotal 4 0 0 GRAND TOTAL 8 18 4

DAEC EMERGENCY PLAN SECTION 'B' 45 EMERGENCY RESPONSE ORGANIZATION Rev. I Page 29 of 32 Figure B-1 EMERGENCY RESPONSE ORGANIZATION (Page 1 of 2) I Onsite ERO I Emergency Coordinator Tech an osc NOS Supervisor TSC Operations Engineering Site Rad Protection Security & Support Supervisor Liaison Coordinator Supervisor Electricians/l&C Operations Shift NRC ENS MIDAS Operator Security Force Technicians Manager Communicator NC Os Information Field Team Director Mechanics Services Rep TSC Communicator NRC HPN Admin Supervisor Communicator HP Supervisor HPTech's ChemTech's I Minimum Staff J ORAAStaff Positions indicated in this (RW) diagram are 60 minute responders unless otherwise OSC Staff (RW) indicated in Table B-1

DAEC EMERGENCY PLAN SECTION 'B'

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EMERGENCY RESPONSE ORGANIZATION Figure B-1 EMERGENCY RESPONSE ORGANIZATION I Corporate ERO I (Page 2 of 2) I ER&RD 1------- [ Site JIC Manager I I I I Corporate JIC Manager and Emergency Communication Team Coordination and Spokesperson -- Support (Technical Advisor) EOF Ops Liaison NRC HPN Com muni cater I Assistant JIC Manager State/County

                         -     Technical Liaisons                              I Radi ologi ca I                                              Media Host Field Team Assessment                  Director Coordinator EOF/JIC Shared Support MIDAS Operator ;------                           Services                     -

Notes: Logistics, IT/AV, (1) All d ashed lines represent coordination and support Administrative, Medical - (2) Title s underlined in boxes represent functions

Consultants r- - - - - _JI_ - - - - -l IMinimum Staff ~ I I I I I Communicator/ Support Services Information Messenger/ Coordinator Services Rep. Recorder

DAEC EMERGENCY PLAN SECTION 'B' Rev. 45 EMERGENCY RESPONSE ORGANIZATION Page 31 of 32 Figure B-2 IMMEDIATE RESPONSE INTERFACE DAEC Control Emergency ER&RD RoomOSM Coordinator I I Benton County EOG HSEMD Linn County EOC I Mercy Medical State Agencies Center Palo Fire Department I FEMA Area Ambulance (Lead) I Hiawatha Federal Agencies Ambulance I Center Point Ambulance NRC Sheriffs Rescue

DAECEMERGENCYPLAN SECTION 'B' Rev. 45 EMERGENCY RESPONSE ORGANIZATION Page 32 of 32 Figure B-3 LONG-TERM RESPONSE INTERFACE EMERGENCY RESPONSE EMERGENCY RESPONSE ORGANIZATION IOFFSITE) ORGANIZATION IONSITE) DAEC CONTRACTORS OPERATIONAL CORPORATE AND CONTROL ROOM SUPPORT SERVICES CONSULTANTS CENTER EMERGENCY TECHNICAL OPERATIONS 1 - - - - - - - - - - - - - - - - - - - - - - - - - 1 SUPPORT FACILITY CENTER LINN &BENTON STATE COUNTIES UNIVERSITY OF HYGIENIC EMERGENCY IOWA LAB OPERATIONS CENTERS UNIVERSITY OF IOWAHOSPITALS 1 - - - - - - - - - - - - - - - 1 STATEOFIOWA AND CLINICS EMERGENCY OPERATIONS !-------~ CENTER MERCY MEDICAL CENTER 1-----------------------j PALO FIRE DEPARTMENT FEMA LINN COUNTY SHERIFF'S RESCUE AREA AMBULANCE HIAWATHA AMBULANCE CENTER POINT AMBULANCE

DAEC EMERGENCY PLAN SECTION 'D' Rev. 30 EMERGENCY CLASSIFICATION SYSTEM Page 1 of 10 Usage Level: INFORMATION Record the following: Date I Time: ~~~~~- I -~~~ Initials: ~~- NOTE: User shall perform and document a Temp Issue I Rev. Check to ensure revision is current, in accordance with procedure use and adherence requirements. Prepared By: -~~~~~~~ Print Signature APPROVAL BY EMERGENCY PREPAREDNESS MANAGER Approved By I Date: Print Signature APPROVAL BY ORG Approved By I Date: Print Signature APPROVAL BY DAEC SITE DIRECTOR Approved By I Date: Print Signature APPROVAL BY CORPORATE DIRECTOR OF EMERGENCY PLANNING Approved By I Date: -----I Print Signature

DAEC EMERGENCY PLAN SECTION 'D' Rev. 30 EMERGENCY CLASSIFICATION SYSTEM Page 2 of 10 Table of Contents Section Numbers Section Titles Page 1.0 PURPOSE 3 2.0 EMERGENCY CLASSIFICATION SYSTEM 3 2.1 NOTIFICATION OF UNUSUAL EVENT 3 2.2 ALERT 4 2.3 SITE AREA EMERGENCY 4 2.4 GENERAL EMERGENCY 4 EMERGENCY ACTION LEVEL (EAL) INITIATING 3.0 5 CONDITIONS TABLE D-1 Attachment 1 7 IMMEDIATE ACTION TABULATION

DAECEMERGENCYPLAN SECTION 'D' Rev. 30 EMERGENCY CLASSIFICATION SYSTEM Page 3 of 10 1.0 PURPOSE (1) This section describes the system used to classify emergency conditions. This system is consistent with that set forth in Appendix 1 of NUREG-0654 and is the system used by state and local organizations. The Emergency Action Levels established for each emergency classification are reviewed annually with offsite authorities who are responsible for implementing protective measures for the population at risk. 2.0 EMERGENCY CLASSIFICATION SYSTEM (1) Each emergency classification is associated with a particular set of immediate actions that are identified in EPIP Manual Appendix 1, forms EAL-01 and EAL-02. Specific details regarding required actions to be taken at the DAEC for each class of emergency are specified in the EPIPs. The specific instruments, parameters, and status indicators used to establish the emergency classification are specified in the Emergency Plan Implementing Procedures. If an emergency condition changes in severity, it will be reclassified and the corresponding response actions will escalate or de-escalate accordingly. (2) The highest emergency classification for which an Emergency Action Level (EAL) is currently met should be DECLARED. If an action level for a higher classification is exceeded but the situation is resolved prior to offsite notification, the higher classification should be REPORTED to the offsite agencies and the NRC, but SHOULD NOT be declared. The notification must indicate the CURRENT classification, the period of time that the higher classification existed and the mitigating conditions that caused the reduction in the emergency classification. 2.1 NOTIFICATION OF UNUSUAL EVENT (1) This class of emergency conditions includes the least severe events requiring offsite notification. This classification will be declared whenever 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 release of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.

DAEC EMERGENCY PLAN SECTION 'D' Rev. 30 EMERGENCY CLASSIFICATION SYSTEM Page 4 of 10 2.2 ALERT (1) The ALERT emergency condition is the second class in increasing order of severity. This emergency classification will be declared whenever 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. Accidents analyzed in Chapter 15 of the Updated Final Safety Analysis Report that fit this classification include the Fuel Handling Accident. 2.3 SITE AREA EMERGENCY (1) The SITE AREA EMERGENCY condition is the third class in increasing order of severity and requires immediate notification of the public. This classification will be declared whenever 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) prevents 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. 2.4 GENERAL EMERGENCY (1) The GENERAL EMERGENCY condition is the most severe and requires immediate notification of the public. This emergency classification will be declared whenever events are in progress or have occurred which involve a HOSTILE ACTION that results in an actual loss of physical control of the facility, or releases that can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite.

DAEC EMERGENCY PLAN SECTION 'D' Rev. 30 EMERGENCY CLASSIFICATION SYSTEM Page 5 of 10 3.0 EMERGENCY ACTION LEVEL (EAL) INITIATING CONDITIONS (1) The EAL Tables, located in the EPIP Manual Appendix 1, forms EAL-01 and EAL-02, identify the specific conditions and associated limits that serve as the basis for initiating the appropriate monitoring, assessment, and response actions described in this plan. As the severity of each condition increases, the event is classified (or reclassified), based upon instruments, equipment status, and parameters identified in the EAL Tables to assure that appropriate emergency response actions are being taken. (2) The EALs are based upon one or more of the following criteria: (a) System design specifications (b) Technical Specification limits (c) FSAR accident analyses (d) 10CFR20 and 10CFR100 requirements (e) EPA 400-R-92-001 Manual of Protective Action Guides and Protective Actions for Nuclear Incidents (dated October 1991 with 2nd printing May 1992) (f) NUREG-0578, "TMl-2 Lessons Learned Task Force Status Report and Short-Term Recommendations." (g) NUREG-0654, FEMA-REP-1, Revision 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants." (h) NEI Development of Emergency Action Levels for Non-Passive Reactors, NEI 99-01, Revision 6, November 2012 (i) NRC Bulletin 2005-02, Emergency Preparedness and Response Actions for Security-Based Events, July 18, 2005 as clarified by NEI Industry White Paper Dated November 15, 2005

DAEC EMERGENCY PLAN SECTION 'D' Rev. 30 EMERGENCY CLASSIFICATION SYSTEM Page 6 of 10 (3) The EALs to be initiated are not necessarily based upon actual radiological exposures to the population at risk, but rather are based upon the potential exposures or specific plant conditions that may pose a threat to the population at risk. (4) The release rates and release rate calculations established for the EALs are based upon an assumed isotopic mix at the time of the event and are calculated using the MIDAS computer model. Effluent release rate levels have been identified for both the SITE AREA EMERGENCY and GENERAL EMERGENCY classifications. The monitor readings established for the SITE AREA EMERGENCY are based upon adverse meteorology while those established for the GENERAL EMERGENCY are based upon normal meteorological conditions. The limiting case for releases from the Off-Gas Stack, an elevated release with the Standby Gas Treatment System (SBGT) in operation, is Deep Dose Equivalent (whole body dose) rates. All other release paths are assumed to be secured. The limiting case for release from the Turbine Building Ventilation Exhaust Stack, a mixed mode release without the benefit of treatment via SBGT, is Committed Dose Equivalent (thyroid dose) rates. Again, all other release paths are assumed to be secured. Since the projected site boundary dose rates are based upon assumed meteorological conditions, these levels will serve as a warning to calculate projected doses using actual meteorological conditions in order to properly classify the condition. (5) High range containment radiation monitor levels have been established for the SITE AREA and GENERAL EMERGENCY classifications. These levels are based on 10% and 20% gap release, respectively. The relationship between percentage gap release and containment monitor response values is delineated in NG-88-0966 and CAL-R17-001. (6) EALs are conservatively established for the SITE AREA EMERGENCY, and ensure that offsite support agency actions are taken in a timely manner. The EALs for the GENERAL EMERGENCY are established to provide a more realistic basis for evacuation or sheltering decisions.

DAECEMERGENCYPLAN SECTION 'D' Rev. 30 EMERGENCY CLASSIFICATION SYSTEM Page 7 of 10 TABLE D-1 IMMEDIATE ACTION TABULATION NOTIFICATION OF UNUSUAL EVENT NextEra Energy DAEC ACTIONS Class Description 1. Inform local and State authorities and the NRC of the condition, significant actions Events are in progress or have occurred which taken or under way, and any need for indicate a potential degradation of the level of assistance. safety of the plant or indicate a security threat to facility protection has been initiated. No release 2. Augment on-shift resources if required as a of radioactive material requiring offsite response precautionaty measure. or monitoring are expected unless further degradation of safety systems occur. 3. Assess and respond. Purpose 4. Escalate to a more severe classification, if appropriate. The purpose of this classification is to (I) assure that the first step in any response later found to be 5. Notify key organizational personnel based necessaty has been carried out, (2) bring the upon plant conditions and the character of the operating staff to a state of readiness, and (3) event, as appropriate. provide systematic handling of unusual events information and decision making. 6. Establish discussions with NRC, as appropriate.

7. If the abnormal condition becomes more severe, futiher actions to be taken shall be as prescribed for the emergency classification assigned.

Following restoration from the abnormal conditions, the following actions will be taken:

1. Inform local and state public officials of significant actions taken or under way and any need for assistance, as appropriate.

2. Issue a news statement, as appropriate.

DAECEMERGENCYPLAN SECTION 'D' Rev. 30 EMERGENCY CLASSIFICATION SYSTEM Page 8 of 10 TABLE D-1 IMMEDIATE ACTION TABULATION ALERT NextEra Energy DAEC ACTIONS

1. Promptly inform local and State authorities Class Description and the NRC of the condition, status, and reason for emergency as soon as discovered.

Events are in progress or have occurred which involve an actual or potential substantial 2. Augment resources and activate the degradation of the level of safety of the plant or responders for the Technical Support Center a security event that involves probable life and Operational Supp01t Center. Bring the threatening risk to site personnel or damage to Emergency Operations Facility, Joint site equipment because of HOSTILE ACTION. Information Center, and other key personnel Any releases are expected to be limited to small to standby status or activation. fractions of the EPA Protective Action

3. Assess and respond.

Guideline exposure levels.

4. Determine need to dispatch onsite and offsite Purpose monitoring teams and associated communications.

The purpose of this classification is to ( 1) assure 5. Provide periodic plant status updates to that emergency personnel are ready, available to offsite authorities. respond if the situation becomes more serious, or to perform confirmatory radiation monitoring if 6. Provide periodic meteorological assessments required, and (2) provide offsite authorities to offsite authorities and, if any releases are current information. occurring, dose estimates for actual releases.

7. Escalate to a more severe classification, if appropriate.

8. Establish follow up discussions with the NRC.

9. Issue news statements, as appropriate.

10. If the plant condition becomes more severe, further actions to be taken shall be as prescribed for the emergency classification assigned.

Following restoration of the plant to a stable, safe shutdown condition, the following actions will be taken:

1. Inform local and state authorities of close out or reduction of emergency class.

2. Issue a summary news statement, as appropriate.

DAECEMERGENCYPLAN SECTION 'D' Rev. 30 EMERGENCY CLASSIFICATION SYSTEM Page 9 of 10 TABLE D-1 IMMEDIATE ACTION TABULATION SITE AREA EMERGENCY NextEra Energy DAEC ACTIONS

1. Promptly inform local and state authorities Class Description and the NRC of the condition, status, and reason for emergency as soon as discovered.

Events are in progress or have occurred which involve actual or likely major failures of plant 2. Augment resources by activating the functions needed for protection of the public or responders for the Technical Support Center, HOSTILE ACTION that result in intentional Operational Suppoti Center, Emergency damage or malicious acts; (I) toward site Operations Facility and the Joint Information personnel or equipment that could lead to the Center. likely failure of or; (2) prevents effective access 3. Assess and respond. to equipment needed for the protection of the public. Any releases are not expected to result in 4. Dispatch onsite and offsite monitoring teams exposure levels which exceed EPA Protective and associated communications. Action Guideline exposure levels beyond the 5. Dedicate an individual for plant status site boundary. updates to offsite authorities and periodic press briefings. Purpose

6. Make senior technical and management staff The purpose of this classification is to (I) assure onsite available for consultation with the that response centers are staffed, (2) assure that NRC and the State who will contact the DOE monitoring teams are dispatched, (3) assure that and FEMA on a periodic basis.

personnel required for evacuation of near-site 7. Provide meteorological information and dose areas are at duty stations if the situation becomes estimates to offsite authorities for actual more serious, (4) provide consultation with offsite releases. authorities, and (5) provide updates for the public through offsite authorities. 8. Provide release and dose projections based on available plant conditions and foreseeable contingencies.

9. Initiate communications with industry liaison groups (i.e., INPO) to apprise them of the emergency situation.

10. Prepare to conduct press briefings and issue news statements.

11. Escalate to GENERAL EMERGENCY class, if appropriate.

12. Inform local and state authorities of the closeout or reduction of the emergency class.

DAECEMERGENCYPLAN SECTION 'D' Rev. 30 EMERGENCY CLASSIFICATION SYSTEM Page 10of10 TABLE D-1 IMMEDIATE ACTION TABULATION GENERAL EMERGENCY 8. Provide release and dose projections based on Class Description available plant conditions and foreseeable contingencies. Events are in progress or have occurred which involve a HOSTILE ACTION that results in an 9. Maintain communications with indust1y actual loss of physical control of the facility, or liaison groups to ensure they are fully releases that can be reasonably expected to apprised of the status of the event and the exceed EPA Protective Action Guideline potential ramifications. exposure levels offsite.

10. Conduct periodic press briefings and issue Purpose news statements to ensure the public is apprised of the status of the event and the The purpose of this classification is to ( 1) initiate actions being taken to minimize its effect predete1mined protective actions for the public, upon the public and the environment.

(2) provide continuous assessment of plant information and radiological monitoring 11. Evaluate the resources and capabilities of the measurements taken by licensee and offsite overall emergency response organizations organizations, (3) initiate additional measures as and restructuring, as appropriate, to assist in indicated by actual or potential releases, (4) detennining, tracking, and assessing the provide consultation with offsite authorities and environmental consequences of the event. (5) provide updates for the public through offsite

12. Achieve stable plant conditions.

authorities.

13. Investigate the consequences of the accident.

NextEra Energy DAEC ACTIONS As conditions warrant, the emergency

1. Promptly inform local and state authorities classification will be downgraded and actions and the NRC of the condition, status, and specified for the appropriate classification will be reason for emergency as soon as discovered.

continued. Following restoration of the plant to a

2. Augment resources by activating the stable and safe shutdown condition, the following responders for the Technical Suppott Center, actions shall be taken:

Operational Suppott Center, Emergency

1. Inform local and state authorities of closeout Operations Facility, and the Joint Information or downgrading of the emergency Center.

classification.

3. Assess and respond.

2. Issue summary news statement, as

4. Dispatch onsite and offsite monitoring teams appropriate.

and associated communications.

5. Dedicate an individual for plant status updates to offsite authorities and periodic press briefings.

6. Maintain communications with the NRC.

Make senior technical and management staff onsite available for consultation with the NRC and the State on a periodic basis.

7. Provide meteorological information and dose estimates of actual releases to offsite authorities.

DAEC EMERGENCY PLAN SECTION 'E' Rev.27 NOTIFICATION METHODS AND PROCEDURES Page 1of7 Usage Level: INFORMATION Record the following: Date I Time: _ _ _ _ _ _ I _ _ _ _ Initials: _ __ NOTE: User shall perform and document a Temp Issue I Rev. Check to ensure revision is current, in accordance with procedure use and adherence requirements.

             -------- I Prepared By:                                                                     Date: - - - -

Print Signature APPROVAL BY EMERGENCY PREPAREDNESS MANAGER Approved By I Date: ----< Print Signature APPROVAL BY ORG Approved By I Date: -----1 Print Signature APPROVAL BY DAEC SITE DIRECTOR Approved By I Date: -----1 Print Signature

DAECEMERGENCYPLAN SECTION 'E' Rev. 27 NOTIFICATION METHODS AND PROCEDURES Page 2 of 7 Table of Contents 1.0 PURPOSE ............................................................................................................................3 2.0 REQUIREMENTS .................................................................................................................3 2.1 INITIAL NOTIFICATION ......................................................................................... 3 2.2 NOTIFICATION AND ACTIVIATION OF THE ER0 ............................................... .4 2.3 INITIAL MESSAGES TO OFFSITE AUTHORITIES ................................................ 5 2.4 FOLLOW-UP MESSAGES TO OFFSITE AUTHORITIES ...................................... 6 2.5 METHODS OF PROVIDING PROMPT PUBLIC NOTIFICATION ........................... 7 2.6 METHODS OF PROVIDING PUBLIC INFORMATION CONCERNING PROTECTIVE MEASURES ...................................................................................7

DAEC EMERGENCY PLAN SECTION 'E' Rev.27 NOTIFICATION METHODS AND PROCEDURES Page 3 of 7 1.0 PURPOSE (I) This section describes the methods and procedures used by NEE Duane Arnold to transmit emergency information to the Emergency Response Organization, local and state authorities, and subsequently, from such authorities to the public. Details required in the initial and follow-up message are described, along with a description of the types of news statements that will be used to provide the public with information and protective actions. 2.0 REQUIREMENTS (1) Methods used to accomplish notification of the Emergency Response Organization include the use of call lists contained in the Emergency Telephone Book, pager and automated telephone callout process. (2) The Emergency Telephone Book includes phone numbers and pager numbers (where applicable) of emergency response personnel who may be required to respond to an emergency condition. It also includes the 24-hour telephone numbers of local, state, and federal support agencies including the NRC. The NRC would normally be notified using the NRC ENS Telephone (FTS-2001 System) from the Control Room. The state and counties would normally be notified by a dedicated telecommunications link. 2.1 INITIAL NOTIFICATION (1) After declaration of an emergency condition, the Operations Shift Manager will ensure that the following personnel and agencies are notified:

Linn and Benton Counties
State of Iowa
NRC Operations Center
Emergency Coordinator
Emergency Response and Recovery Director
NRC Resident Inspectors (2) Verification of Notification (a) The authenticity of initial notifications provided to Linn and Benton Counties and the State of Iowa do not require verification if the notification is made by the dedicated phone system.

(b) Local and state agencies notified by commercial communication system (telephone or facsimile) may require verification of the identity and authenticity of the caller and the message received.

DAEC EMERGENCY PLAN SECTION 'E' Rev.27 NOTIFICATION METHODS AND PROCEDURES Page 4 of 7 2.2 NOTIFICATION AND ACTIVATION OF THE ERO (1) NOTIFICATION OF UNUSUAL EVENT (a) Activation of emergency facilities (refer to Section H), such as the TSC, the OSC, the EOF, or the JIC will be as directed by the Emergency Coordinator, ER&RD, and JIC Manager, respectively. Normally, these emergency facilities will not be activated for a NOTIFICATION OF UNUSUAL EVENT, but may be, if escalation of the emergency class appears to be imminent. (2) ALERT, SITE AREA EMERGENCY, OR GENERAL EMERGENCY (a) The Operations Shift Manager, or another member of the shift operating crew, at the direction of the Operations Shift Manager, shall notify onsite personnel by activation of a distinctive tone alarm over the public address system, followed by an announcement over the public address system. Off-duty emergency response personnel will be notified in accordance with the EPIPs describing notification and call out of off-duty personnel. The Emergency Telephone Book contains the telephone numbers and, if applicable, pager numbers of emergency response personnel. (b) The onsite Emergency Response Organization personnel shall initially report to the TSC and the OSC at an Alert or higher classification. As personnel arrive at the Operational Support Center, they should select their own nameplate and place it into their response position. The instructions are designated in Emergency Plan Implementing Procedures and cover radiological survey, monitoring, communication, record-keeping, rescue, and emergency repair efforts. (c) The Emergency Coordinator will initiate notification of the following emergency response officials and agencies and provide them with additional information, as appropriate, until relieved by the ER&RD:

Local, state and federal governmental officials and support agency management personnel, as warranted, based upon the severity and potential ramifications of the event,
INPO Emergency Response Center.
Further information and instructions are provided in the supporting implementing procedures.

(d) Onsite personnel who staff the EOF and the JIC will report to their facilities at an Alert classification. The ER&RD in conjunction with the JIC Manager will determine when the EOF and JIC will be activated as indicated in the EPIPs.

DAECEMERGENCYPLAN SECTION 'E' Rev. 27 NOTIFICATION METHODS AND PROCEDURES Page 5 o~ 7. 2.3 INITIAL MESSAGES TO OFFSITE AUTHORITIES (1) The initial notification message relayed to offsite authorities will provide the following information:

Caller identification/location.
Event classification, EAL number, and time of declaration.
If radiological release is in progress, type of release and projected duration of release and if airborne release, state whether the release is filtered or unfiltered.
Wind direction and wind speed.
Recommended protective actions, if any.
Assistance, if any, which may be required.

DAECEMERGENCYPLAN SECTION 'E' Rev.27 NOTIFICATION METHODS AND PROCEDURES Page 6 of 7 2.4 FOLLOW-UP MESSAGES TO OFFSITE AUTHORITIES (1) After initial notifications have been made from the DAEC to the various offsite organizations, responsibility for communications with offsite agencies will normally be assumed by the TSC until the EOF is staffed. (2) The following information will be provided if known and appropriate to the circumstances:

Location of incident and name of caller.
Date/time of incident.
Emergency classification.
Type of actual or projected release (airborne, waterborne, surface spill) and estimated duration/impact times, filtered or unfiltered if the release is an airborne release.
Estimate of quantity of radioactive material released or being released and the point of release.
Chemical and physical form of released material, including estimates of the relative quantities and concentrations of noble gases, iodines, and particulates.
Meteorological conditions (wind velocity, direction, temperature, atmospheric stability data, form of precipitation, if any).
Actual or projected dose rates and integrated doses at the site boundary; and at about 2, 5, and 10 miles.
Estimates of any surface radioactive contamination in the plant, onsite or offsite.
Emergency response actions under way.
Recommended emergency actions, including protective measures.
Requests for any needed onsite support by offsite organizations.
Prognosis of event based on plant information.

DAECEMERGENCYPLAN SECTION 'E' Rev.27 NOTIFICATION METHODS AND PROCEDURES Page 7 of 7 2.5 METHODS OF PROVIDING PROMPT PUBLIC NOTIFICATION (1) A fixed offsite siren,warning system providing an audible alert has been installed within the DAEC Plume Exposure Emergency Planning Zone (EPZ). The EPZ includes subareas and is defined in Section I of this plan, Figure 1-1. The audible warning sirens will alert the populace to listen to radios or televisions for detailed information. (2) The offsite warning system is designed to alert essentially 100% of the population in the DAEC EPZ. Activation of the system can be accomplished within fifteen minutes of issuance of an advisory from the Linn County Emergency Management Agency, Linn County Sheriffs Office, Benton County Emergency Management Agency, or Benton County Sheriffs Department. Each county can act as a backup to the other. (3) In the unlikely event that one or more sirens would fail to activate, the State of Iowa and Linn and Benton Counties maintain a backup Alert and Notification System that will alert the public in affected areas. This system covering the EPZ is achieved through physical route alerting, which is contained in the State of Iowa Radiological Emergency Response Plan and in Linn and Benton County's Radiological Emergency Response Plans and procedures. These plans and procedures are approved by FEMA in accordance with 44CFR350.12 and 14. 2.6 METHODS OF PROVIDING PUBLIC INFORMATION CONCERNING PROTECTIVE MEASURES (1) Section 2.5 identifies the methods to be used to notify the public, specifically those in the plume exposure pathway EPZ, of the occurrence of an emergency event. Recommendations regarding protective measures to be implemented for the population at risk will be provided to both county and state officials by the Emergency Coordinator prior to EOF activation, then by the Radiological Assessment Coordinator (RAC). Initial information to expedite the taking of protective measures by the public will be provided by using the Emergency Alert System (EAS). (2) Messages to the public generated by a computerized EAS message generation system, will include appropriate aspects of protection; e.g., sheltering, ad hoc respiratory protection or evacuation. Formatted messages are included in the county plans and are the responsibility of Linn and Benton County Emergency Management Agencies.

DAECEMERGENCYPLAN SECTION 'F' Rev. 31 EMERGENCY COMMUNICATIONS Page 1 of 17 Usage Level: INFORMATION Record the following: Date I Time: _ _ _ _ _ _ I _ _ _ _ Initials: _ __ NOTE: User shall perform and document a Temp Issue I Rev. Check to ensure revision is current, in accordance with procedure use and adherence requirements. Prepared By:

             -------- I                      -----------~

Date: Print Signature APPROVAL BY EMERGENCY PREPAREDNESS MANAGER Approved By I Date:

             --------------------~                                                     -----1 Print                         Signature APPROVAL BY ORG Approved By                                 I                                     Date:

Print Signature APPROVAL BY DAEC SITE DIRECTOR Approved By I Date:

             --------------------~                                                     -------<

Print Signature

DAECEMERGENCYPLAN SECTION 'F' Rev. 31 EMERGENCY COMMUNICATIONS Page 2of17 Table of Contents 1.0 PURPOSE ............................................................................................................................3 2.0 REQUIREMENTS .................................................................................................................3 2.1 GENERAL DESCRIPTION OF NEE DUANE ARNOLD COMMUNICATIONS SYSTEMS ..............................................................................................................3 2.2 NOTIFICATION OF LOCAL/STATE EMERGENCY RESPONSE NETWORK ........ ? 2.3 COMMUNICATIONS WITH CONTIGUOUS LOCAL/STATE AUTHORITIES ......... 7 2.4 NEE DUANE ARNOLD COMMUNICATIONS WITH NRC ...................................... 7 2.5 COMMUNICATIONS BETWEEN EOCs AND FIELD ASSESSMENT TEAMS ....... 7 2.6 ACTIVATING EMERGENCY RESPONSE PERSONNEL ...................................... ? 2.7 MEDICAL COMMUNICATIONS ............................................................................. 8 2.8 PERIODIC TESTS OF COMMUNICATIONS SYSTEMS ........................................ 8 TABLE F-1 COMMUNICATIONS PRIMARY AND ALTERNATE CONTACTS ............................. 9 FIGURE F-1 DAEC RADIOLOGICAL SURVEY RADIO SYSTEM ............................................. 11 FIGURE F-2 PLANT OPERATIONS RADIO SYSTEM .............................................................. 12 FIGURE F-3 POINT-TO-POINT RADIO SYSTEM .................................................................... 13 FIGURE F-4 MICROWAVE FACILITIES ................................................................................... 14 FIGURE F-5 DAEC TELEPHONE SYSTEMS ........................................................................... 15 FIGURE F-6 FEDERAL TELEPHONE SYSTEM (FTS-2001) .................................................... 16 FIGURE F-7 ALL-CALL TELEPHONE SYSTEM ....................................................................... 17 J

DAECEMERGENCYPLAN SECTION 'F' Rev. 31 EMERGENCY COMMUNICATIONS Page 3of17 1.0 PURPOSE (1) This section describes the DAEC emergency communications systems and communications links between the NEE Duane Arnold and other response organizations. 2.0 REQUIREMENTS 2.1 GENERAL DESCRIPTION OF NEE DUANE ARNOLD COMMUNICATIONS SYSTEMS (1) DAEC Radiological Survey Radio System (a) This radio system (Figure F-1) provides base-to-portable communications for conducting radiological surveys throughout the DAEC plume exposure EPZ. The base station is a mobile relay (repeater) type using two VHF frequencies for a single frequency simplex talk-around, or for monitoring short range portable-to-portable communications in the event the base station is inoperative for a short period of time. (b) The installation meets the following functional requirements and limitations: (i) Installation of the radio base station equipment in a secure area (ii) Wide area coverage for radiological survey communications (c) The base station is controlled from the Technical Support Center, and Emergency Operations Facility. (i) The portable radios used are the hand-held type. (ii) The base station radios provide the following channels:

DAEC "Field Team" Repeater
DAEC "Maintenance" Repeater
DAEC "Security Call" Simplex
DAEC "Operations" UHF repeater
Linn County Fire
Point to Point (iii) All channels transmit continuous tone-coded squelch.

(iv) The hand-held portables are primarily utilized on the VHF "field team" repeater channel and can be used for communication between personnel on foot, mobiles, and the TSC EOF base stations.

DAEC EMERGENCY PLAN SECTION 'F' Rev. 31 EMERGENCY COMMUNICATIONS Page 4of17 (v) In addition, the DAEC Radiological Survey teams have three vehicles equipped with a 50-watt radio transceiver for communications to the DAEC at distances greater than obtainable with the high power portables. (vi) In addition to the attributes listed above the DAEC Security department has the ability to cross patch the frequencies listed above to specific LLEA frequencies if the need should arise during an emergency event. The details surrounding the capabilities of the security radio system are sensitive in nature and are not included in this document. (2) DAEC (Backup Radiological Survey) Radio System (a) This radio system provides backup capability for the VHF radio listed in (1) and provides base-to-portable communications for conducting radiological surveys throughout the DAEC plume exposure EPZ. The backup system is an 800 MHz trunked repeater system. The 800 MHz tower infrastructure is located on a tower at 1000 27th Avenue SW, Cedar Rapids, IA 52404. Two Radio Pro Console PC-based dispatch radios support this system. One is located in the DAEC Technical Support Center (TSC), and a second identical dispatch radio is located in the Emergency Operations Facility (EOF) at the Alliant Tower. (3) Plant Operations Radio (a) Figure F-2 illustrates the plant operations radio system which consists of a UHF base station connected to an omni-directional antenna. Seven remote control units are associated with this base station, located in the Control Room, Control Room Backpanel, Technical Support Center, Secondary Alarm Station, Security Control Point, and the Central Alarm Station. Hand-held transceivers are used in this system to provide simplex communications within the plant and onsite. (4) Point-to-Point Radio System (a) The DAEC also has a base station licensed for operation in the Police Radio Service on the law enforcement statewide, point-to-point VHF frequency, as illustrated in Figure F-3. The transmitter and one control console are located at the Secondary Alarm Station, the Central Alarm Station, and Security Control Point. This station is for communications with the Iowa Department of Public Safety radio station, Linn County Sheriff's office, Benton County Sheriff's office, and the Cedar Rapids Fire Department, and uses a two-tone sequential signal to alert the latter two public-safety stations. This point-to-point channel is also used by the Linn County Emergency Management and other public safety organizations throughout the state of Iowa.

DAECEMERGENCYPLAN SECTION 'F' Rev. 31 EMERGENCY COMMUNICATIONS Page 5of17 (5) ERO Notification systems NEE Duane Arnold has multiple methods to contact designated ERO members in the event of an emergency. All ERO members will be contacted via a phone call to their home or cell phone as needed. All management personnel filling a key ERO duty position will also have one of the following two methods available. (a) A pocket-radio paging system, operated and maintained by a local contractor. The system is designed to enable simultaneous contact of such personnel in the event of an emergency. (b) Cell phones or other similar devices that are programmed to be automatically contacted in the event of an emergency. (6) Microwave Facilities (a) NEE Duane Arnold, with a group of Iowa utilities, participates in a shared microwave system, a portion of which is illustrated in Figure F-4. The hub of this system is located at the Alliant Tower in Cedar Rapids. A westerly path extends from Cedar Rapids to the DAEC and contains 24 channels used for outdial telephone, which connect the NEE Duane Arnold phone system in Cedar Rapids to the DAEC phone system. (b) Additional microwave facilities provide paths east and west from the DAEC through the Alliant Energy substations at Vinton, Dysart, Traer, Wellsburg, and Marshalltown to complete the microwave loop system from Cedar Rapids. This enables a greater degree of reliability since loop switching equipment is installed at all microwave repeaters in the loop. Thus, if one microwave path becomes inoperative, signals will be switched continuing to provide communications to all points around the loop. (7) Telephone Facilities (a) Figure F-5 illustrates the telephone system. The system is operated and maintained by the Local Telephone Company and the regional provider which serves the Alliant Tower. (b) The DAEC PBX is connected to the central office by 20 active Central Office (CO) trunk lines, 48 long distance trunks, 23 duplex dial trunks, and 24 direct dial trunk lines. The PBX also contains six direct-dial tie trunks to the microwave terminal at the DAEC Substation. The PBX currently handles approximately 1,500 telephone stations. (c) There are 4 emergency lines with unlisted numbers which connect directly to the Control Room and several offices but do not connect through the PBX. (d) There are 6 dedicated telecommunications circuits which bypass the local system switch in the EOF and directly connect to the public switched network provided by a regional communications provider. There are seven data lines used for computer operations which do not connect through the PBX.

DAECEMERGENCYPLAN SECTION 'F' Rev. 31 EMERGENCY COMMUNICATIONS Page 6of17 (e) A LAN/Internet system with satellite backup connects the Linn County EOC and Sheriffs office, the Benton County EOC and Sheriffs office, the State of Iowa EOC, the EOF, the TSC, the Simulator, and the Control Room into a private telephone network referred to as the DAEC All-Call. See Figure F-7. (f) Redundant fiber connects the DAEC to the central office. This fiber terminates at the DAC Computer Room. (g) A Fixed Cell Phone System connects the DAEC Control Room and TSC with the Shellsburg Cell tower via exterior antenna. This phone system has a UPS power supply in the event of a loss of power. * (h) A Control Room Satellite Phone System connects the DAEC Control Room to a communications satellite. This phone system provides redundancy from the other DAEC phone systems. (i) The Emergency Operations Facility has available: (i) Dedicated circuits to the NRC on the Federal Telecommunications system FTS-2001 (ii) PBX connectivity to DAEC through dedicated circuitry provided by a local and regional provider (iii) External phone service, separate from DAEC, provided by a separate regional provider (iv) An All-Call System that provides a communication path between the Control Room, Technical Support Center, Simulator, Emergency Operations Facility, Iowa Homeland Security and Emergency Management Division, Benton County and Linn County Emergency Operations Centers, Benton County and Linn County Sheriff 911 Dispatch Centers via LAN/Internet with satellite backup capabilities U) The NRC ENS and NRC HPN telephones are both installed and functioning. Both telephones are connected to the Federal Telephone System (FTS-2001). The NRC ENS telephones are located in the Control Room, TSC, and EOF which gives those facilities the capability to contact NRC Headquarters in Rockville, MD. The NRC HPN telephones are located in the TSC and EOF and can be used to call regional NRC offices, the NRC Headquarters, or other sites within the region. (8) Emergency Microwave Facilities (a) Personnel Contacts for Communications Links (i) Table F-1 lists the primary and alternate communication contacts between NEE Duane Arnold emergency facilities and supporting local, State, and Federal agencies. The communications links are those identified in Figures F-1 through F-4. Table F-1 also identifies, by title, the principal and alternate contacts at each end of each communications link.

DAECEMERGENCYPLAN SECTION 'F' Rev. 31 EMERGENCY COMMUNICATIONS Page 7of17 2.2 NOTIFICATION OF LOCAL/STATE EMERGENCY RESPONSE NETWORK (1) As mentioned in Section A, both the Linn County and Benton County Sheriff's Communications Centers are staffed on a continuous basis and may be notified from the DAEC and the EOF by the "DAEC All-Call" telephone, conventional telephone, or facsimile transmission of a condition requiring a response. The State Emergency Operations Center may be notified from the DAEC and the EOF by telephone and facsimile through the Iowa Homeland Security and Emergency Management Division, Iowa Department of Public Defense, by radio through the Department of Public Safety Communications, or by use of the "DAEC All-Call" telephone. 2.3 COMMUNICATIONS WITH CONTIGUOUS LOCAL/ST ATE AUTHORITIES (1) After the initial notification of an emergency condition and once the Technical Support Center and Emergency Operations Facility are operational, the Technical Support Center will be the principal onsite communications interface while the Emergency Operations Facility will be the principal offsite communications interface. Communications between local and state agencies and NEE Duane Arnold emergency facilities may be by telephone (normal and dedicated lines), network, satellite, or radio as discussed in Section 2.2. 2.4 NEE DUANE ARNOLD COMMUNICATIONS WITH NRC (1) DAEC E-Plan Section E discusses notification methods and procedures. Paragraph 2.1 of this Section F and Figures F-2, F-3, F-4, and F-5 describe the provisions for communicating between NEE Duane Arnold emergency facilities. The NRC will be notified of an emergency condition through the use of the FTS-2001 System (Federal Telecommunications System). The FTS-2001 network provides a separate government network for all essential communications functions to the NRC. Details of the use and operation of the FTS-2001 can be found in the DAEC Emergency Plan Implementing Procedures. (See diagram on Figure F-6) 2.5 COMMUNICATIONS BETWEEN EOCs AND FIELD ASSESSMENT TEAMS (1) Section 2.1 discusses, and Figures F-1 through F-4 illustrate, the provisions for communicating between each emergency center (NEE Duane Arnold, county and state) and with field assessment teams monitoring the offsite radiological impact of the emergency. 2.6 ACTIVATING EMERGENCY RESPONSE PERSONNEL (1) DAEC E-Plan Section E discusses notification methods and procedures for offsite authorities. DAEC E-Plan Section A discusses the interrelationships between response organizations and Figure A-1 illustrates activation and notification lines of responsibility. Figures F-1 through F-4 and Paragraph 2.1 of this section describe the systems for notifying response personnel from onsite and offsite Emergency Response Organizations.

DAECEMERGENCYPLAN SECTION 'F' Rev. 31 EMERGENCY COMMUNICATIONS Page 8 of 17 2.7 MEDICAL COMMUNICATIONS (1) Communications with the primary and secondary medical facilities will be accomplished through the use of commercial telephone system. Communications with the ambulance will be accomplished through the use of the Linn County fire frequency radio network. 2.8 PERIODIC TESTS OF COMMUNICATIONS SYSTEMS (1) Periodic tests will be conducted to determine the operability of the communications systems discussed in this section. A test (preferably in conjunction with the exercise addressed in DAEC E-Plan Section N) will be performed to test all communications links and notification procedures and the system used to alert the public. The NRC ENS, NRC HPN, and the other telephone lines in the FTS-2001 network will be tested on a monthly basis. The Emergency Response Data System (EROS) will be tested quarterly by establishing a link with the NRC EROS system.

DAECEMERGENCYPLAN SECTION 'F' Rev.31 EMERGENCY COMMUNICATIONS Page 9of17 TABLE F-1 COMMUNICATIONS PRIMARY AND ALTERNATE CONTACTS ORGANIZATION/FACILITY PRIMARY CONTACT ALTERNATE CONTACT

1. NEE Duane Arnold

a. Emergency Operations Emergency Response & Radiological Assessment Facility Recovery Director Coordinator

b. Technical Support Center Emergency Coordinator Technical and Engineering Supervisor

c. Operational Support Operational Support Center HP Supervisor Center Supervisor

d. Control Room and Alarm Operations Shift Manager TSC Operations Liaison Stations

2. LOCAL AGENCIES

a. Linn County Sheriff's County Emergency Management Sheriff's Office Communications Office and Emergency Coordinator Center Operator Management

b. Benton County Sheriff's County Emergency Management Sheriff's Office Communications Office and Emergency Coordinator Center Operator Mgmt.

c. Palo Fire Department Sheriff's Office Communications Center

d. Mercy Medical Center Emergency Room Desk Sheriff's Office Communications Center Operator

e. University of Iowa Emergency Room Desk Hospitals and Clinics

f. Center Point Ambulance Sheriff's Office Communications Center Operator

g. Hiawatha Ambulance Sheriff's Office Communications Center Operator

h. Area Ambulance Sheriff's Office Communications Center Operator

i. Linn County Sheriff's Linn County Sheriff's Dispatcher Rescue

DAECEMERGENCYPLAN SECTION 'F' Rev.31 EMERGENCY COMMUNICATIONS Page 10of17 TABLE F-1 COMMUNICATIONS PRIMARY AND ALTERNATE CONTACTS ORGANIZATION/FACILITY PRIMARY CONTACT ALTERNATE CONTACT

3. STATE AGENCIES

a. Iowa Homeland Security Iowa Homeland Security and Department of Public Safety, and Emergency Emergency Management Communications Station Management Division, Division Administrator Iowa Dept of Public Defense

b. University of Iowa University Telephone Operator

3. FEDERAL AGENCIES

a. NRC Duty Officer NRC Region Ill Office in (Rockville, Maryland) Lisle, Illinois

b. Department of Energy Regional Office in Chicago, Illinois

c. Federal Emergency Contacted by State of Iowa, Federal Emergency Management Agency Iowa Homeland Security and Management Agency, Region Emergency Mgmt. Division, VII, Iowa Dept of Public Defense Kansas City, Missouri

DAECEMERGENCYPLAN SECTION 'F' Rev. 31 EMERGENCY COMMUNICATIONS Page 11 of 17 FIGURE F-1 DAEC RADIOLOGICAL SURVEY RADIO SYSTEM Radiological Radiological Survey Survey Mobil/Portable DAEC VHF Mobil/Portable

     #1                           Maintenance                                                     #2 Repeater I                                                                                        I I                                     ',                                                 I I
                                                  '                                               I I                                            '                                           I I                                              ',                                        I I

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I I ', I I ' I I ' I I ', I I ' I I '

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VHF Field Team Repeater TSC VHF DAEC EOFVHF Control Security Control

                                                        -----------                         Station Station DAEC                            Point to Point to Operation                          See Figure F4 UHF

DAECEMERGENCYPLAN SECTION 'F' Rev. 31 EMERGENCY COMMUNICATIONS Page 12of17 FIGURE F-2 PLANT OPERATIONS RADIO SYSTEM HAND-HELD TRANSCIEVERS DISTRIBUTED TO APPROPRIATE PERSONNEL THROUGHOUT THE PLANT DAEC TRANSMITTER AND RECIEVER CONTROL ROOM SECURITY CONTROL BACKPANELS POINT SECONDARY ALARM STATION CENTRAL ALARM CONTROL ROOM STATION TRANSMITIER AND CONTROL CONSOLE EMERGENCY TECHNICAL OPERATIONS SUPPORT CENTER FACILITY

DAECEMERGENCYPLAN SECTION 'F' Rev. 31 EMERGENCY COMMUNICATIONS Page 13of17 FIGURE F-3 POINT-TO-POINT RADIO SYSTEM x x x x I I I LINN CO. IOWADEPT. CEDAR RAPID BENTON CO. SHERIFF'S OF PUBLIC FIRE SHERIFF'S OFFICE SAFETY DEPARTMENT OFFICE x x I I LINNCOUNlY OTHER STATE EMERGENCY MANAGEMENl PUBLIC SAFETY ORGANIZATIONS ORGANIZATIONS x I DAEC TRANSMITIER AND RECEIVER SECONDARY CENTRAL SECURITY ALARM ALARM CONTROL STATION STATION POINT Transmitter and Transmitter and Control Console Control Console

DAECEMERGENCYPLAN SECTION 'F' Rev. 31 EMERGENCY COMMUNICATIONS Page 14of17 FIGURE F-4 MICROWAVE FACILITIES VINTON NORTH MICROWAVE SYSTEM DYSART EAST DAEC MICROWAVE SYSTEM Digital Microwave TRAER Computer Link - - l CORNBELT POWER COOPERATIVE SYSTEM WELLSBURG ALLIANT TOWER IOWA FALLS MARSHALLTOWN STONEY POINT WEST SOUTH MICROWAVE MICROWAVE TOLEDO BELLE PLAINE CONTINUED SYSTEM JUNCTION LOCAL FIBER OPTIC TO SUBSTATIONS & CR OPERATING PRAIRIE CREEK CENTER

DAEC EMERGENCY PLAN SECTION 'F' Rev. 31 EMERGENCY COMMUNICATIONS Page 15 of 17 FIGURE F-5 DAEC TELEPHONE SYSTEMS 1-r=--=--=--=-~- - - - - ---, I I I I Operational Shellsburg Satellite Support Center Cell Tower Communications (Access Control)

                                                                                                /   /                                    ........
                                                                                       //                         .,,,....,,,...,,.,,,..

(1) r-~~~~~~ Offsite Laboratory and DAEC PBX Decontamination Room Room Center DAEC 4 emergency Microwave unlisted lines (Blue Phones) in to Alliant Control Room, TSC. CAS. SAS Joint Public Tower Information Center (1)-EOF Local Telephone Company Central Office I Alliant Tower Microwave to DAEC

FPLE Duane Arnold Corporate Offices
County Sherill's Offices
Palo Fire Department
Mercy Hospital
State Highway Patrol Qwest Emergency Operations
state Emergency Management Division (Cedar Rapids) EOF Facility
University of Iowa "NRC
ooE Normal
FEMA Telephone
Linn County Emergency Management (1) Denotes a Dedicated Services To Other Bell
Benton County Emergency Management Line Central Offices

DAEC EMERGENCY PLAN SECTION 'F' Rev. 31 EMERGENCY COMMUNICATIONS Page 16of17 FIGURE F-6 FEDERAL TELEPHONE SYSTEM (FTS-2001) NRC EROS DAEC EOF Local <::)---C> IComputer Room TSC <D ENS HPN @ RSCL © PMCL MCL

DAECEMERGENCYPLAN SECTION 'F' Rev. 31 EMERGENCY COMMUNICATIONS Page 17of17 FIGURE F-7 ALL-CALL TELEPHONE SYSTEM Internet EOC Sheriff's Office BackupFadlity Main Facility

DAEC EMERGENCY PLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev. 39 EQUIPMENT Page 1 of 26 Usage Level INFORMATION Record the following: Date I Time: _ _ _ _ _ _ I _ _ _ _ Initials: _ __ NOTE: User shall perform and document a Temp Issue I Rev. Check to ensure revision is current, in accordance with procedure use and adherence requirements. Prepared By: ~~~~~~~- I Date: Print Signature APPROVAL BY EMERGENCY PREPAREDNESS MANAGER Approved By Print Signature APPROVAL BY ORG Approved By Print Signature APPROVAL BY DAEC SITE DIRECTOR Approved By Print Signature

DAEC EMERGENCY PLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev.39 EQUIPMENT Page 2 of 26 Table of Contents Section Numbers Section Titles Page 1.0 PURPOSE 3 2.0 REQUIREMENTS 3 2.1 TECHNICAL SUPPORT CENTER (TSC) 3 2.2 OPERATIONAL SUPPORT CENTER (OSC) 4 2.3 EMERGENCY OPERATIONS FACILITY (EOF) 5 2.4 JOINT INFORMATION CENTER (JIC) 7 2.5 OFFSITE RELOCATION AND ASSEMBLY AREA (ORAA) 8 2.6 ALTERNATIVE FACILITIES 9 2.7 STATE HYGIENIC LABORATORY (SHL) 9 2.8 ONSITE MONITORING SYSTEMS 10 2.9 METEOROLOGICAL INSTRUMENTATION AND PROCEDURES 13 2.10 SEISMIC AND HYDROLOGICAL INSTRUMENTATION 13 2.11 CONTROL OF EMERGENCY EQUIPMENT/INSTRUMENTS 14 2.12 COMMUNICATION CHECKS 14 2.13 EMERGENCY KITS 14 2.14 RECEIPT AND ANALYSIS OF FIELD MONITORING DATA 14 RADIOLOGICAL MONITORING SAMPLING STATION TABLE H-1 15 LOCATIONS TABLE H-2 RADIOLOGICAL MONITORING LOCATIONS 16 FIGURE H-1 TSC/OSC FLOOR PLAN (Typical) 17 FIGURE H-2 EOF FLOOR PLAN (Typical) 18 FIGURE H-3 19 (DELETED) FIGURE H-4 DIRECTIONS TO ORAA 20 FIGURE H-5 21 (DELETED) FIGURE H-6 22 (DELETED) FIGURE H-7 JIC 6TH FLOOR PLAN (Typical) 23 FIGURE H-8 JIC 15TH FLOOR PLAN (Typical) 24 FIGURE H-9 25 (DELETED) FIGURE H-10 DIRECTIONS TO THE STATE HYGIENIC LAB (SHL) 26

DAEC EMERGENCY PLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev. 39 EQUIPMENT Page 3 of 26 1.0 PURPOSE (1) This section describes the DAEC Emergency Response Organization (ERO) emergency facilities, staffing and activation, and equipment required for support of emergency events. 2.0 REQUIREMENTS (1) Emergency response facilities will be activated according to the notification and activation procedures described in the EPIPs. Personnel who are assigned to each facility either appear on call or notification lists used for notification purposes, or by procedure and training, will automatically report to a predesignated area upon declaration of the appropriate Emergency Classification. Each key emergency organization position is assigned a minimum of two qualified persons to ensure complete facility staffing. Whenever possible, three qualified persons will be assigned. (2) Support facilities and organizations will be activated as described regardless of the time of day or day of the week. However, it should be recognized that the normal plant staff is only at the site approximately 25% of the time. As a result, as many functions as possible will be assumed by the shift operating crew until support facilities are established and off-duty personnel arrive on site. Sufficient plant staff and corporate personnel will be trained and qualified to staff the appropriate facilities to ensure that they will be established and operational in a timely manner. The Emergency Response Organization is shown in Figure B-1 and also in the Emergency Telephone Book. 2.1 TECHNICAL SUPPORT CENTER (TSC) (1) General Description (a) The TSC is located in a facility adjacent to the DAEC Administration Building and is staffed by plant management and technical personnel to provide technical support for Control Room activities. The facility has the capability to transmit and record vital plant data in real time and provides access to as-built plant drawings and other records. Computerized dose projections can be performed from a computer terminal available in the TSC. The program (MIDAS) has real-time access to data from the plant effluent and meteorological monitoring systems. The Safety Parameter Display System (SPDS), which displays critical plant parameters monitored by the process computer, is available in the TSC. Additionally, plant parameters and status information of significance to the event can be transmitted using a VAX computer terminal as well as telephone and radio. Also available is the Emergency Response Data System (EROS) which displays live-time plant data. The TSC is the main communications link between the plant and the Emergency Operations Facility (EOF). The location and floor plan are shown in Figures H-1 and H-2, respectively. The Control Room is designated as the alternate TSC. Communication links between the TSC, Operational Support Center (OSC), Control Room, EOF, and the Nuclear Regulatory Commission (NRC) are described in Section F.

DAECEMERGENCYPLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev.39 EQUIPMENT Page 4 of 26 (2) Activation Criteria (a) Declaration of an ALERT or higher emergency classification requires activation of the TSC. The Operations Shift Manager (OSM) will authorize initiation of the notification chain according to procedure. Members of the Emergency Response Organization assigned to the TSC will be notified by plant page, extension number, commercial phone, pager or automated telephone system. During off-hours, members of the Emergency Response Organization assigned to the TSC will be contacted by pager and/or commercial telephone. A call list is provided for this purpose. Upon receiving notification of an Emergency Classification which requires activation of the TSC, each individual contacted will immediately report to the TSC to begin activation tasks. (b) The TSC is activated at an ALERT, SITE AREA EMERGENCY or GENERAL EMERGENCY. Activation of the TSC for a NOTIFICATION OF UNUSUAL EVENT is at the discretion of the OSM or Emergency Coordinator. (3) Staffing (a) The Emergency Coordinator exercises supervision and direction over the personnel assigned to the TSC. Personnel assigned to the TSC will include: selected members of the plant staff who are knowledgeable in specific functional areas at the DAEC, selected engineering personnel who can assist in providing engineering evaluations, and representatives from the NRC. (4) Habitability (a) The TSC is designed and constructed to provide the shielding necessary to protect occupants from radiation effects from either the reactor core or the plume. An independent ventilation system can be placed in a recirculation mode of operation, enabling air to be continually filtered through both charcoal and HEPA filters. Radiation monitors are provided at the ventilation system intake and within the TSC proper. In the event of radiological releases, portable air sampling equipment is available that will enable periodic checks to be made of airborne radiological conditions. 2.2 OPERATIONAL SUPPORT CENTER (OSC) (1) General Description (a) The OSC is located in a facility adjacent to the DAEC Administration Building and its floor plan is illustrated in Figure H-1. This center will be used to assemble and dispatch onsite and offsite radiation monitoring teams, and to coordinate in-plant survey efforts, rescue and emergency teams, and personnel who support Control Room emergency activities. This center will be in communication with the TSC and Control Room. Portable environmental sampling and monitoring equipment is stored near this facility to support radiation monitoring teams. This facility provides ready access to evacuation routes.

DAEC EMERGENCY PLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev. 39 EQUIPMENT Page 5 of 26 (2) Activation Criteria (a) Activation of the OSC occurs in a similar fashion to the TSC. Upon declaration of an ALERT or higher emergency classification, the OSM will initiate the notification process. Individuals will either report to the OSC when notified, or will automatically report when an emergency classification is declared that requires OSC activation. Those assigned to the OSC will be notified by plant page, extension number, commercial phone, pager or automated telephone system. During off-hours, individuals assigned to the OSC will be contacted by pager, commercial telephone, or automated telephone system. (b) The OSC is activated at an ALERT, SITE AREA EMERGENCY, or GENERAL EMERGENCY is declared. Activation of the OSC for a NOTIFICATION OF UNUSUAL EVENT is at the discretion of the EC. (3) Staffing (a) The OSC Supervisor exercises overall supervision and direction for all emergency response personnel on site who are not members of the operations shift crew or assigned to other emergency response facilities. Onsite and offsite field radiological monitoring teams, rescue and repair teams, in-plant radiological survey assignments, and communicator assignments are established at the OSC using an Emergency Assignment Tag Board. This method is further described in the EPIPs. (4) Habitability (a) Sections I and K describe the systems and methods for monitoring radiological conditions in the OSC. Emergency kits at or near the OSC provide respiratory protection, protective clothing, decontamination capabilities, and portable sampling and monitoring devices. First-aid supplies are available from the first aid room. Decontamination is performed at the access control area. Radios, onsite and offsite telephones, and intraplant telephones are available in this center. 2.3 EMERGENCY OPERATIONS FACILITY (EOF) (1) General Description (a) The EOF depicted in Figure H-2 is a dedicated facility located on the 15th floor of the Alliant Tower in Cedar Rapids. This facility is operated by Duane Arnold for the continued evaluation and coordination of emergencies having actual or potential offsite consequences. The EOF staff disseminates information to federal, state, and local emergency response organizations and provides a centralized location for representatives from federal, state and local agencies.

DAEC EMERGENCY PLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev.39 EQUIPMENT Page 6 of 26 (b) This location has adequate square footage to support the ERO and the EOF. This provides adequate working space for approximately 40 people during normal conditions and 150 people during an emergency. It includes various offices and conference rooms, and provides ready access to the DAEC records, procedures, drawings, etc., that are normally used and maintained in this area. (c) The facility is equipped with suitable communications data transmission systems for use during normal and emergency conditions. These systems and equipment provide the following: (i) Dedicated and prioritized communications interconnecting with the TSC, NRC, and local and state networks. (ii) Terminals that can access and display vital plant parameters and radiological and meteorological data. (iii) A fax machine system for transmitting information to the TSC and other offsite agencies, organizations, and companies, as required. (2) Activation Criteria (a) Activation of the EOF will be accomplished for any event classified as a SITE AREA or GENERAL EMERGENCY. Activation and staffing of the EOF at an ALERT or lesser classification will be at the direction of the Emergency Response & Recovery Director (ER&RD). The Emergency Coordinator will notify the ER&RD of an emergency situation at DAEC. The ER&RD is responsible for ensuring that personnel are contacted and assigned to fill key EOF functions. Members of the Emergency Response Organization assigned to the EOF will be notified by pager, plant page, or commercial telephone during normal work hours, and by pager and/or commercial telephone, using either call lists or automated telephone system, during non-normal work hours. Key EOF personnel will be directed to report to the EOF when an ALERT is declared and may be placed on standby as directed by the ER&RD. The Emergency Telephone Book identifies each position to be contacted and response times. (3) Alternate EOF (a) If the Alliant Tower becomes uninhabitable the Alternate EOF will be activated. The Alternate EOF will be located at the Linn County Emergency Management Agency (EMA). Linn EMA is housed in the Kirkwood Community College Facilities and Security Building on the main campus of Kirkwood Community College in Cedar Rapids, IA.

DAEC EMERGENCY PLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev. 39 EQUIPMENT Page 7 of 26 (4) Staffing (a) Duane Arnold corporate managers familiar with operating, engineering, licensing, and public relations functions and activities are available to the EOF. Functions to be performed by these key personnel are described in Section B of this plan and in supporting implementing procedures. (b) The EOF will provide overall management of the emergency response (including coordination with federal, state and local officials) during Site Area and General Emergency classifications, and, if desired, during lower classifications of emergencies. (5) Habitability (a) The EOF is located at a distance greater than 10 miles from the DAEC; therefore no shielding or specialized ventilation filtration systems are necessary. 2.4 JOINT INFORMATION CENTER (JIC) (1) General Description (a) The JIC is located on the sixth and fifteenth floors of the Alliant Tower in Cedar Rapids with an auditorium and conference rooms. It has approximately 3,700 square feet and is capable of accommodating 200 news personnel for registration, inquiries, and mass briefings. The JIC functions as the single-point contact for disseminating information to the industry, news media, and public officials. The JIC Manager will use the JIC as his/her headquarters. He/she will ensure that the center is provided with adequate equipment and materials including those listed below: (i) A large briefing area with a public address system (ii) A working area for the press (iii) Federal, state, and local government agency work area (iv) Kitchenette and restrooms (v) DAEC media guide and visual aids (b) A more detailed description of the JIC, specific equipment capabilities, and media material is provided in Figures H-7 and H-8, "JIC 6th and 15th Floor Plans, typical". (c) Should the Cedar Rapids metropolitan area require evacuation, facilities on the main campus of Kirkwood Community College can be used for media briefings and news conferences. JIC spokespersons representing DAEC, Linn and Benton Counties, the State of Iowa, and any Federal agencies, with appropriate support staff will relocate to the College to provide the media with timely and accurate information.

DAECEMERGENCYPLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev. 39 EQUIPMENT Page 8 of 26 (2) Activation Criteria (a) Activation of the JIC will be accomplished for any event classified as a SITE AREA or GENERAL EMERGENCY. Activation and staffing of the JIC at an ALERT or lesser classification will be at the direction of the JIC Manager. The ER&RD will notify the JIC Manager of an emergency situation at DAEC. The JIC Manager is responsible for ensuring that personnel are contacted and assigned to fill key JIC functions. Members of the Emergency Response Organization assigned to the JIC will be notified by pager, plant page, or commercial telephone during normal work hours, and by pager and/or commercial telephone, using either call lists or automated telephone system, during non-normal work hours. Key JIC personnel will be directed to report to the JIC when an ALERT is declared and may be placed on standby as directed by the JIC Manager. The Emergency Telephone Book identifies each position to be contacted and response times. 2.5 OFFSITE RELOCATION AND ASSEMBLY AREA (ORAA) (1) General Description (a) The Offsite Relocation and Assembly Area (ORAA) is located in Palo. The directions to the facility are described in Figure H-4. This facility will be staffed by the ORAA Supervisor, security force members, and health physics technicians (or HP trained equivalents). This facility has the capability of providing space in the event of a site evacuation of non-essential personnel from the DAEC. The ORAA provides full decontamination capabilities, and can also function as a staging area to support recovery and re-entry efforts at the DAEC. (2) Activation Criteria (a) Activation and staffing of the ORAA will be accomplished for any event classified as a SITE AREA or GENERAL EMERGENCY. Activation and staffing of the ORAA at an ALERT level will be based upon whether or not a site evacuation has been initiated at the direction of the Emergency Coordinator. The OSC Supervisor, when notified that an evacuation from the site is being conducted, shall contact the ORAA Supervisor and inform him that the ORAA is to be activated. The ORAA Supervisor will then coordinate with the OSC Supervisor to assign three Health Physics technicians (or HP trained equivalents) to assist in the activation of the ORAA. (3) Staffing (a) The ORAA Supervisor exercises supervision and direction over the personnel assigned to the ORAA. Personnel assigned to the ORAA include selected security force members and health physics trained personnel for monitoring and decontamination purposes. The ORAA Supervisor will coordinate with the HP Supervisor if more personnel are needed.

DAEC EMERGENCY PLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev. 39 EQUIPMENT Page 9 of 26 (4) Habitability (a) The ORAA does not provide shielding necessary to protect occupants from the plume. If the ORAA, located in Palo, Iowa, is not habitable due to plume effect, the alternate reassembly area will be the Benton County Emergency Worker Monitoring and Decontamination Station located at 701 East A Street in Vinton. It may be necessary for the Emergency Coordinator to select another location based upon input from the Site Radiation Protection Coordinator due to radiological release and meteorological conditions. 2.6 ALTERNATIVE FACILITIES (1) If the site is under threat or experiencing a hostile action, the onsite ERO members may be directed to Alternative Facilities. These facilities function as a staging area for augmentation of emergency response staff. Collectively, these facilities have the following characteristics: the capability for communication with the emergency operations facility, control room, and plant security; the capability to perform offsite notifications; and the capability for engineering assessment activities, including damage control team planning and preparation, for use when onsite emergency facilities cannot be safely accessed during hostile action. [

Reference:

10CFR50 Appendix E Section IV.E.8.d]

2. 7 STATE HYGIENIC LABORATORY (SHL)

(1) General Description (a) The SHL is located at 2490 Crosspark Road, Coralville, Iowa 52241. This facility provides for the analysis of contaminated or potentially contaminated samples such as water, vegetation, and soil. (2) Activation Criteria (a) The SHL is designated for activation at the discretion of the representative for the Iowa Homeland Security & Emergency Management Division (HSEMD). (3) Staffing (a) The SHL is staffed per the direction of the Iowa Homeland Security & Emergency Management Division (HSEMD). (4) Habitability (a) The SHL is located beyond the 1O mile Emergency Planning Zone (EPZ) from the DAEC. Habitability determinations will be conducted on an as needed basis when potentially contaminated samples or personnel are delivered to the SHL.

DAEC EMERGENCY PLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev. 39 EQUIPMENT Page 10 of 26 2.8 ONSITE MONITORING SYSTEMS (1) Meteorological Monitors (a) Wind speed and direction (b) Temperature (2) Radiological Monitoring Systems (a) Area Radiation Monitoring System (b) Process Radiation Monitoring System (i) Main Steamline Radiation Monitoring System (ii) Offgas Radiation Monitoring System (a) Pre-treatment Offgas Monitor and Sampler (b) Post-treatment Offgas Monitor and Sampler (iii) Carbon Bed Vault Radiation Monitoring System (iv) Offgas Vent Pipe (Stack) Radiation Monitoring System (v) Refueling Pool Exhaust Radiation Monitoring System (vi) Reactor Bldg. Main Exhaust Radiation Monitoring System (vii) Control Building Air Intake Radiation Monitoring System (viii) Liquid Process Radiation Monitoring System (a) Radwaste Effluent (b) Service Water Effluent (c) Reactor Bldg Closed Cooling Water (d) RHR and Emergency Service Water Effluent (e) RHR and Emergency Service Water Rupture Disc Effluent (ix) KAMAN Extended Range Effluent Monitoring System (a) Offgas Vent Pipe (b) Reactor Building Stacks (c) Turbine Building Vents (c) Portable dose rate meters

DAECEMERGENCYPLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev.39 EQUIPMENT Page 11 of 26 (d) Counting Laboratory Equipment (i) Gamma Spectroscopy (ii) Proportional Counter (iii) Liquid Scintillation Counter (e) Whole Body Counter (3) Process Monitoring Systems (a) NSSS Instrumentation (i) Rx Vessel Level (ii) Rx Pressure (iii) Rx Temperature (iv) Nuclear Instrumentation (v) Associated Alarms, Annunciators (b) Containment Instrumentation (i) Drywell Temperature (ii) Drywell Pressure (iii) Containment Level (iv) Torus Temperature (v) Torus Pressure (vi) Drywell Sump Pump Timers (vii) Drywell to Torus DP (viii) Torus to Rx Building DP (c) ECCS Instrumentation (i) ECCS Pump Operation (ii) ECCS System Flow Indicators (iii) Isolation Valve Status (iv) HPCl/RCIC Turbine Speed/Minimum Flow (v) Emergency Diesel Generator Operation (vi) SBLC System Operation (vii) Associated Alarms, Annunciators

DAEC EMERGENCY PLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev. 39 EQUIPMENT Page 12 of 26 (d) System Instrumentation (i) SBGT Operation and Flow (ii) Standby Filter Unit Operation and Flow (iii) Off-Gas System Operation and Flow (iv) Rx Building Ventilation Exhaust (v) Turbine Building Ventilation Exhaust (vi) Feedwater Flow (vii) Main Steam Flow (viii) Generator Load (ix) Valve Status Indicator Lights (x) Stack Fan Flow (xi) Associated Alarms, Annunciators (e) Electrical Instrumentation (i) RPS Failure Indication (ii) Battery Voltage (iii) Vital Bus Voltmeter (iv) Transformer Output (v) Breaker Position Indicators (vi) Sub-Station Breaker Positions (vii) Associated Alarms, Annunciators (4) Fire Monitoring Systems (a) Smoke (ionization) Detectors (b) Rate-of-rise heat Detectors (c) Heat Detectors (d) Associated Alarms, Annunciators

DAECEMERGENCYPLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev. 39 EQUIPMENT Page 13 of 26 2.9 METEOROLOGICAL INSTRUMENTATION AND PROCEDURES (1) The DAEC Meteorological Instrumentation is used to acquire data for both on-site and off-site monitoring of weather conditions. (2) A complete description of the meteorology program is contained in the Updated Final Safety Analysis Report (UFSAR). A capsulated description of the system is given here. (a) The meteorological tower is located 1700 feet south-southeast of the Reactor Building. Both primary and backup instrumentation is provided to measure wind direction, wind speed, and ambient air temperature at 33 feet and 156 feet above the base of the tower. In addition, dewpoint is measured at the 33-foot level and precipitation is measured at the base of the tower. The accuracy's and ranges associated with this instrumentation are discussed in the UFSAR. Calibration of the instruments is performed semiannually. The onsite meteorological measurement program is documented in the UFSAR and the associated Onsite Meteorological Data Supplement. (b) The data gathered by the instrumentation is provided as instantaneous values at 10-second intervals to the Safety Parameter Display System (SPDS). The SPDS screens the data and selects either the primary or the backup instrumentation, as appropriate, under the existing meteorological conditions. The instantaneous values are then processed into one-minute averages and transmitted, along with radiological data, to the atmospheric dispersion and dose assessment model. This allows near real-time predictions of the atmospheric effluent transport and diffusion as well as remote interrogation of the atmospheric measurements and predictions by appropriate organizations. When the Emergency Response Data System (EROS) link is activated, this data is also picked up and transmitted to the NRC EROS. (c) The data gathered by the instrumentation is also provided to a hard copy recorder in the Control Room in the form of 30-minute averages as a backup to the data archived by the dose assessment model. For an expanded description of the effluent monitoring system and the dose assessment model, see DAEC Plan "I" section 2.2 "Accident Assessment Capabilities and Resources". 2.10 SEISMIC AND HYDROLOGICAL INSTRUMENTATION (1) Seismic instrumentation is installed at several locations to detect seismic disturbances. Accelerograph sensors are located in the basement of the Reactor Building, the Refueling Floor, the Intake Structure, Pump House, Recirculation System Piping, Reactor Vessel, and at various other Class I structures. An accelerograph is also installed at a "free field" location to measure soil structure interactions. The accelerograph sensors feed indicating lights and alarms located in the Control Room. The seismic indicators alert operators when predetermined Operating Basis Earthquake (OBE) and Design Basis Earthquake (DBE) values are exceeded. (2) The intake structure for plant cooling water employs a level sensing system for Cedar Rapids River level. A level recorder indicates increases or decreases in river level. Additionally, periodic checks of the total flow of the Cedar Rapids River are made at a gauge station in Cedar Rapids.

DAECEMERGENCYPLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev.39 EQUIPMENT Page 14 of 26 2.11 CONTROL OF EMERGENCY EQUIPMENT/INSTRUMENTS (1) The operational readiness of emergency equipment and supplies is ensured through a program of routine inventory, calibration, test, and maintenance. Once during each quarter, all emergency kits, emergency equipment, and supplies are inventoried. This inventory includes verification that procedures contained in the kits are the latest revision. Additionally, all portable instruments are verified to have been tested and calibrated as prescribed by DAEC procedures. The general condition of supplies such as batteries, respirators, and liquid containers are inspected for signs of leakage or deterioration. 2.12 COMMUNICATION CHECKS (1) The following communication checks will be performed at the specified frequencies: (a) Local and state governments - monthly (b) NRC Headquarters Operations Center - monthly (c) Emergency Response Data System - quarterly (d) Local and state Emergency Operations Centers - annually (2) These communication checks will be documented as specified in the EPIPs and in Emergency Preparedness Department Procedures. 2.13 EMERGENCY KITS (1) DAEC Emergency Plan Appendix 4 identifies the procedures which contain the location and type of emergency kits; i.e., protective equipment, communications equipment, radiological monitoring equipment, and emergency supplies. The Emergency Planning Department procedures establish the inventory quantities of the items listed in the kits. 2.14 RECEIPT AND ANALYSIS OF FIELD MONITORING DATA (1) Field monitoring data will be transmitted to the EOF for review and analysis. Prior to the EOF being operational, data will be transmitted to the TSC for review and analysis.

DAEC EMERGENCY PLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev. 39 EQUIPMENT Page 15 of 26 TABLE H-1 RADIOLOGICAL MONITORING SAMPLING STATION LOCATIONS Refer to ODAM Table 5-1

DAEC EMERGENCY PLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev. 39 EQUIPMENT Page 16 of 26 TABLE H-2 RADIOLOGICAL MONITORING LOCATIONS Refer to ODAM Table 5-1

DAECEMERGENCYPLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev. 39 EQUIPMENT Page 17 of 26 FIGURE H-1 TSC/OSC FLOOR PLAN (Typical)

                                                  ' NRC = NRC TABLE NRCOffice TSC

RAO l'RO"' SRPG, HPN COMM, RAD SUPP STAFF
AMr"' OPS LIAISON, AMT TSCCOMM NRC DJ COOf!D RAD PRO ENG

                                                  .. ENG= TECH & ENG SUPV, ENS COMM

SUPPORT a AOM!N SUPV, SECURITY SUPV, INFO S~RV, CLERICAL SUPPORT osc HP SUPV D

OSCSUPV TSC/OSC FLOOR PLAN

DAEC EMERGENCY PLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev.39 EQUIPMENT Page 18 of 26 FIGURE H-2 EOF FLOOR PLAN (Typical) I. NRC HPN Ccxmulicator 2 NRC ENS Comminicator

3. RAC 4 NRC!llO

5. ER&RD

6. EOF Coommicator

7. Benton County

                ~~~~~~~~~~~~~~~~~~~                   & LimCounty Cl                                                    9. Suwirt SeMre; Coordinatcr

10. FBvlA Sl m 12 StateHealthRep.

13. 10\\llEMD t;' 14. NRC Protecti'e lvi'aswe; Vl 15. Tochnical Rocord<r m

Vl 16. EOFOpsLiaism Vl

17. NRCRxSafrty 3 19. FieldTeamDirector m Xl. lvllDAS Operator

i

..+                                                  21. StateRadioOpemtor
)>                                                   22  State Carp ()><rator i1l                                                  23. State Dose Ass<ss""'11 Director QJ                                                   24. lnfcmntion Service:;

E ENSPhore 19-23 H HPNPhme Figure H-2 R RSCLPhme L EOF Floor Plan P PMCLPhooe M MCLPhore (typical, not to scale and L LANPhone seating/FTS locations may change)

DAEC EMERGENCY PLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev.39 EQUIPMENT Page 19 of 26 FIGURE H-3 (DELETED)

DAECEMERGENCYPLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev.39 EQUIPMENT Page 20 of 26 FIGURE H-4 DIRECTIONS TO ORAA (2800 Hollenbeck Road, Palo, IA 52324) DAEC N I SHELLSBURG RD. VINION SI OFFSITE-~ RELOCATION

&ASSEMBLY AREA(ORAA)          ci 0::

() UJ co z UJ

                    ....I
                    ....I 0

I

DAEC EMERGENCY PLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev.39 EQUIPMENT Page 21 of 26 FIGURE H-5 (DELETED)

DAEC EMERGENCY PLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev. 39 EQUIPMENT Page 22 of 26 FIGURE H-6 (DELETED)

DAECEMERGENCYPLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev. 39 EQUIPMENT Page 23 of 26 FIGURE H-7 JIC 6TH FLOOR PLAN (Typical) MEaA RUMffi CCNTRa.. STORAGE AREA NE\l\S cal FERENCE AUllO ROCM MEDIA

                                  \llSUAL                             V\ORK STORAGE                              AREA

DAEC EMERGENCY PLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev. 39 EQUIPMENT Page 24 of 26 FIGURE H-8 JIC 15TH FLOOR PLAN (Typical) ti]

 +~~~

r "'

DAEC EMERGENCY PLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev. 39 EQUIPMENT Page 25 of 26 FIGURE H-9 (DELETED)

t DAECEMERGENCYPLAN SECTION 'H' EMERGENCY FACILITIES STAFFING, ACTIVATION AND Rev. 39 EQUIPMENT Page 26 of 26 FIGURE H-10 DIRECTIONS TO THE STATE HYGIENIC LAB (SHL) Cedar 1he Rapid& Unlver6lty h of Iowa 00 Re~earotl

         ~~                                        P.lrk
     @fl~
   ~-                      ~p~
                                              .l'.JL      lei'Nll 1fc~

Cot11Mlle l To N.Lib@rty To I-SO (1 mile) 1

DAEC EMERGENCY PLAN SECTION 'J' Rev.28 PROTECTIVE RESPONSE Page 1of11 Usage Level INFORMATION Record the following: Date/Time: / Initials: _ __ NOTE: User shall perform and document a Temp Issue/Rev. Check to ensure revision is current, in accordance with procedure use and adherence requirements. Prepared By: I Date: Print Signature APPROVAL BY EMERGENCY PREPAREDNESS MANAGER Approved By I Date: Print Signature APPROVAL BY ORG Approved By I Date: Print Signature APPROVAL BY DAEC SITE VICE PRESIDENT Approved By I Date: Print Signature APPROVAL BY CORPORATE DIRECTOR OF EMERGENCY PLANNING Approved By I Date: Print Signature

DAEC EMERGENCY PLAN SECTION 'J' Rev.28 PROTECTIVE RESPONSE Page 2of11 Table of Contents Section Numbers Section Titles Page 1.0 PURPOSE 3 2.0 REQUIREMENTS 3 2.1 NOTIFICATION OF ONSITE PERSONNEL 3 2.2 SITE EVACUATION 3 2.3 CONTAMINATION CONTROL OF SITE EVACUEES 4 2.4 ACCOUNTABILITY OF ONSITE PERSONNEL 4 2.5 RADIOLOGICAL PROTECTION OF ONSITE PERSONNEL 5 2.6 ONSITE PROTECTIVE ACTIONS 5 2.7 OFFSITE PROTECTIVE ACTION RECOMMENDATIONS 5 2.8 PLUME EPZ PROTECTIVE ACTIONS 6 2.9 PLUME EPZ EVACUATION TIME ESTIMATES 7 2.10 INGESTION PATHWAY PROTECTIVE ACTIONS 7 3.0 ATIACHMENTS 7

SUMMARY

OF POSSIBLE OFFSITE PROTECTIVE ACTIONS TO BE TABLE J-1 8 RECOMMENDED OR IMPLEMENTED DURING AN EMERGENCYt TABLE J-2 REPRESENTATIVE SHIELDING FACTORS FROM GAMMA CLOUD SOURCE* 9 FIGURE J-1 SITE EVACUATION ROUTES 10 FIGURE J-2 "DAEC EPZ EVACUATION ROUTES" 11

DAEC EMERGENCY PLAN SECTION 'J' Rev.28 PROTECTIVE RESPONSE Page 3of11 1.0 PURPOSE (1) This section describes the protective actions to be taken for emergency workers and the public based upon the event classification and resulting assessment of plant status and radiological conditions. Guidelines for the choice of protective actions to be implemented are presented, as well as the methods to be used to notify the population at risk of emergency conditions. 2.0 REQUIREMENTS 2.1 NOTIFICATION OF ONSITE PERSONNEL (1) Personnel on site within the Protected Area boundary, and personnel on site outside the Protected Area located in the Training Center and the Plant Support Center will be notified of an emergency condition by a distinctive tone-alarm over the public address system, followed by an announcement over the plant page system. (2) Security force personnel will be dispatched, as appropriate, to warn any individuals who may be on Duane Arnold property in the vicinity of the plant. 2.2 SITE EVACUATION (1) Non-essential personnel will be evacuated from the DAEC to an offsite reassembly area during a SITE AREA or GENERAL EMERGENCY. Evacuation from the site will be by the routes shown in Figure J-1, using personal transportation. The south route will normally be used, unless radiological conditions dictate use of the north route. Security personnel will provide traffic control on site. The detailed provisions for evacuation, relocation, radiological monitoring and decontamination of site personnel are provided in the EPIPs. (2) Evacuated personnel will proceed to the Palo Community Center, located in Palo, Iowa, and reassemble for an accountability check and personnel radiological monitoring, if not already accomplished at the DAEC. If the Palo Community Center is not habitable due to plume effects, the alternate reassembly area will be the Benton County Emergency Worker Monitoring and Decontamination Station located at 701 East A Street in Vinton, or at the Emergency Coordinator's discretion.

DAEC EMERGENCY PLAN SECTION 'J' Rev.28 PROTECTIVE RESPONSE Page 4of11 2.3 CONTAMINATION CONTROL OF SITE EVACUEES (1) Security force personnel will ensure that any individuals who may be on company property but outside of the fenced area are advised of the event and escorted off the property. Access will be permitted only to those individuals who are required at the site. If radiological releases have occurred or are in progress, individuals escorted offsite will be surveyed for any radiological contamination prior to being released from company property. In the event that evidence of contamination is found or suspected, the individual will be decontaminated onsite or taken to the Offsite Relocation and Assembly Area (ORAA) or Mercy Medical Center or University of Iowa Hospitals and Clinics for subsequent decontamination and release. (2) Where possible, plant employees will be decontaminated in onsite facilities. A full capability exists to conduct decontamination at the Palo Community Center. 2.4 ACCOUNTABILITY OF ONSITE PERSONNEL (1) For all events that result in activation of the Emergency Response Organization except those classified as NOTIFICATION OF UNUSUAL EVENT, personnel onsite will proceed to their pre-assigned assembly point. In those situations where the number of personnel at the site is significantly in excess of the normal plant staff, information will be disseminated to those additional personnel identifying alternate assembly and accountability locations. (2) An accountability check for all personnel who are within the Protected Area will be conducted. The methods used will enable accounting for all individuals onsite at the time of the emergency, ascertain the names of missing individuals within approximately thirty minutes of the start of an emergency, and continuously account for all onsite individuals thereafter.

DAEC EMERGENCY PLAN SECTION 'J' Rev.28 PROTECTIVE RESPONSE Page 5of11 2.5 RADIOLOGICAL PROTECTION OF ONSITE PERSONNEL (1) Protective measures associated with the use of protective clothing and the use of respiratory protection equipment shall be taken in accordance with existing radiation protection requirements. (2) Respiratory protection devices may be required in any situation arising from plant operations where airborne radiological contamination exists. In such cases, the air will be monitored and the need for and type of protective devices will be specified according to the concentration and type of airborne contaminants present. This decision will be made to optimize the total effective dose equivalent. Periodic air samples are routinely taken in selected areas of operations or work activity during normal operations. Air samples will be taken in the OSC, Control Room and TSC, as appropriate, to ensure continued habitability of those areas and to alert the Emergency Coordinator to any changes in the airborne status. (3) Protective clothing and respiratory protection equipment are maintained at several locations within the plant. Personnel in the OSC will be dispatched to distribute additional equipment as necessary to the Control Room, TSC, or other plant areas where personnel may be stationed. In the event that sufficient equipment is not available, personnel will be relocated to plant areas where contamination hazards do not exist. (4) Where the potential exists for significant exposure to radioiodine, an initial dosage of potassium iodide will be administered. A sufficient quantity of potassium iodide will be kept onsite for this purpose. The use of potassium iodide will be in accordance with EPIPs. 2.6 ONSITE PROTECTIVE ACTIONS (1) A range of protective actions to protect onsite personnel during a hostile action have been developed to ensure the continued ability to safely shut down the reactor and perform the functions of the emergency plan. [

Reference:

10CFRSO Appendix E Section IV.I] 2.7 OFFSITE PROTECTIVE ACTION RECOMMENDATIONS (1) Upon identification and classification of the event, notifications will be made as delineated in Section E. Decisions with respect to sheltering or evacuation of the population at risk, as well as the means of notification, are as prescribed in the Linn County and Benton County Radiological Emergency Response Plans and Emergency Plan Implementing Procedures. Recommendations for protective actions for the public are based upon ensuring that personnel exposures are maintained at or below those identified in the EPA Protective Action Guides, as described in Table K-1. (2) Communication systems are available to ensure that the population at risk is notified of protective measures to be taken. These are discussed in Section E.

DAEC EMERGENCY PLAN SECTION 'J' Rev. 28 PROTECTIVE RESPONSE Page 6of11 (3) Protective Action Recommendations have been developed using the guidance of NUREG-0654, Supplement 3 which provides an acceptable method to comply with 10 CFR 50, Appendix E, Section IV, paragraph 3 in the use of evacuation time estimates in the formulation of protective action recommendations (PARs) for the plume exposure emergency planning zone, and provides guidance for the provisions of 10 CFR 50.47(b)(10) in the development of a range of PARs. (4) NUREG-0654, Supplement 3 also provides guidance to support the information in NUREG-0654/FEMA-REP-1 that the U.S. Nuclear Regulatory Commission finds to be an acceptable method of meeting the requirements in 10 CFR 50.47(b)(7) for the development of a public information program. (5) The Protective Action Recommendations have been coordinated with the responsible Offsite Responsible Organizations. 2.8 PLUME EPZ PROTECTIVE ACTIONS (1) Offsite protective actions, including sheltering, evacuation and contamination control, will be taken in accordance with the action criteria established in the EPA Protective Action Guides (PAGs) described in Table K-1. The responsibilities associated with implementation of such protective actions are specified in the Linn County and Benton County Radiological Emergency Response Plans. In addition to Table K-1, the following factors will determine the basis for choosing between alternate recommended protective actions:

Potential for release based on plant conditions
Type of release, (i.e., constant or puff, elevated or ground), filtered or unfiltered
Length of release
Time required for the plume to reach the population at risk
Prevailing meteorological conditions
Evacuation time estimates for general and special population distributions are found in Appendix 3 (Evacuation - Time Estimates)
Radiological monitoring and environmental sampling results
Representative Shielding Factors for Gamma Cloud Sources (Table J-2)
Alternate local sheltering facilities (2) The Linn County and Benton County Radiological Emergency Response Plans and the State of Iowa Radiological Emergency Response Plan include maps identifying evacuation routes, evacuation subareas, and relocation centers in host counties.

DAEC EMERGENCY PLAN SECTION 'J' Rev.28 PROTECTIVE RESPONSE Page 7of11 2.9 PLUME EPZ EVACUATION TIME ESTIMATES (1) The DAEC Evacuation Time Estimate for Linn and Benton Counties identifies population distributions, evacuation time estimates, and evacuation routes and is included as Appendix 3. EPZ evacuation routes are as delineated in the Linn County and Benton County Radiological Emergency Response Plans and the State of Iowa Radiological Emergency Response Plan. The permanent population within the DAEC EPZ subareas and within the plume exposure EPZ of DAEC is reflected in Appendix 3. The county plans contain the EPZ evacuation plans. 2.10 INGESTION PATHWAY PROTECTIVE ACTIONS (1) Protective action recommendations provided to offsite authorities with regards to the ingestion exposure pathway (SO mile EPZ) will be based upon a number of factors including:

Type of release
Release source
Time frame (or accident phase)
The results of environmental monitoring and sampling efforts undertaken (2) Initial recommendations provided will typically be conservative and based primarily upon projected impacts as opposed to analytical results. Table J-1 provides a summary of the recommended protective actions that may be appropriate for an event at the DAEC. As is evident, these recommendations generally entail restriction of food stuffs and surface drinking water and placing milk animals on stored (non-contaminated) feed. The implementation of protective response options for the ingestion exposure pathway is the responsibility of the State of Iowa and is described in the Iowa Radiological Emergency Response Plan.

3.0 ATTACHMENTS (1) TABLE J-1, "

SUMMARY

OF POSSIBLE OFF-SITE PROTECTIVE ACTIONS TO BE RECOMMENDED OR IMPLEMENTED DURING AN EMERGENCY" (2) TABLE J-2, "REPRESENTATIVE SHIELDING FACTORS FROM GAMMA CLOUD SOURCE" (3) FIGURE J-1, "SITE EVACUATION ROUTES" (4) FIGURE J-2, "DAEC EPZ EVACUATION ROUTES"

DAEC EMERGENCY PLAN SECTION 'J' Rev.28 PROTECTIVE RESPONSE Page 8of11 TABLE J-1

SUMMARY

OF POSSIBLE OFFSITE PROTECTIVE ACTIONS TO BE RECOMMENDED OR IMPLEMENTED DURING AN EMERGENCYt ACCIDENT PHASE EXPOSURE PATHWAY EXAMPLES OF ACTION TO BE RECOMMENDED 1 EARLY PHASE Inhalation of gases, radioiodines, Evacuation, shelter, access control, (0.5 TO 30 hours)* or particulates respiratory protection, prophylaxis (thyroid protection) Direct whole body exposure Evacuation, shelter, access control 2 INTERMEDIATE Ingestion of milk Take cows off pasture, prevent cows from PHASE drinking surface water, discard contaminated milk or divert it to stored (30 hours to 30 products such as cheese days)* Ingestion of fruits and vegetables Wash all produce, or impound produce, delay harvest until approved, substitute uncontaminated produce Ingestion of water Cut off contaminated supplies, substitute from other sources, filter, demineralize Whole body exposure and Relocation, decontamination, access inhalation control 3 LATE PHASE Ingestion of food and water Decontamination, condemnation, or (over 30 days)* contaminated from the soil destruction of food; deep plowing either by resuspension or uptake condemnation, or alternate use of land through roots Whole body exposure from Relocation, access control, deposition of material or decontamination, fixing of contamination, inhalation of resuspended deep plowing material 1 Emergency Phase - Time period of major release and subsequent plume exposure. 2 Intermediate Phase - Time period of moderate continuous releases with plume exposure and contamination of the environment 3 Long Term Phase - Recovery period.

"Typical" Post-Accident time periods.

t

Reference:

USEPA "Manual of Protective Action Guides and Protective Actions for Nuclear Incidents," (EPA 400-R-92-001) dated October 1991 with 2nd printing May 1992.

DAEC EMERGENCY PLAN SECTION 'J' Rev.28 PROTECTIVE RESPONSE Page 9of11 TABLE J-2 REPRESENTATIVE SHIELDING FACTORS FROM GAMMA CLOUD SOURCE* Structure of Location Shielding Factor (a) Representative Range Outside 1.0 -- Vehicles 1.0 -- Wood-frame house (b) 0.9 -- (no basement) Basement of wood house 0.6 0.1 to 0.7 (c) Masonry house (no basement) 0.6 0.4 to 0.7 (c) Basement of masonry house 0.4 0.1to0.5 (c) Large office or industrial building 0.2 0.1to0.3 (c, d) (a) The ratio of the interior dose to the exterior dose (b) A wood frame house with brick or stone veneer is approximately equivalent to a masonry house for shielding purposes. (c) This range is due mainly to different wall materials and different geometrics. (d) The reduction factor depends on where the persons are located within the building (e.g., the basement or an inside room). (1) Consideration is limited to gamma radiation since beta and alpha particles cannot penetrate the walls of structures.

Manual of Protective Action Guides and Protective Actions for Nuclear Incidents (EPA 400-R-92-001) dated October 1991 with 2nd printing May 1992.

DAEC EMERGENCY PLAN SECTION 'J' Rev.28 PROTECTIVE RESPONSE Page 10of11 FIGURE J-1 SITE EVACUATION ROUTES

NORMAL ROADBLOCK (SECURITY BARRIERS NORTH EVACUATION - MUST BE REMOVED ROUTE PRIOR TO USING THIS NORMAL ROADBLOCK ROUTE)

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DAEC EMERGENCY PLAN SECTION 'J' Rev. PROTECTIVE RESPONSE Page 11of11 FIGURE J-2 DAEC EMERGENCY PLANNING ZONE EVACUATION ROUTES

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DAECEMERGENCYPLAN SECTION 'K' Rev. 24 RADIOLOGICAL EXPOSURE CONTROL Page 1 of 6 Usage Level INFORMATION Approved for 'Point-of-Use' printing IF NO Temporary Changes are in effect for this procedure. Record the following: Date I Time: _ _ _ _ _ _ / _ _ _ _ Initials: NOTE: A check to ensure current revision and no temporary changes shall be performed and documented every 24 hours if active document use exceeds a 24 hour period as determined from the date and time recorded above. Prepared By:

             --------~

Print Signature APPROVAL BY EMERGENCY PREPAREDNESS MANAGER Approved By Print Signature APPROVAL BY ORG Approved By I Date: - - - - - - " " " Print Signature APPROVAL BY DAEC SITE VICE PRESIDENT Approved By __________ / _ _ _ _ _ _ _ _ _ _ _~ Date: _ _ _ __. Print Signature APPROVAL BY CORPORATE DIRECTOR OF EMERGENCY PLANNING Approved By I Date: - - - - - < Print Signature

DAEC EMERGENCY PLAN SECTION 'K' Rev. 24 RADIOLOGICAL EXPOSURE CONTROL Page 2 of 6 Table of Contents Section Numbers Section Titles Page 1.0 PURPOSE 3 2.0 REQUIREMENTS 3 2.1 EXPOSURE GUIDELINES 3 2.2 ONSITE RADIATION PROTECTION PROGRAM 3 2.3 EXPOSURE CONTROL 4 2.4 CONTAMINATION CONTROL MEASURES 5 2.5 DECONTAMINATION OF RELOCATED PERSONNEL 5 3.0 ATTACHMENTS 5 TABLE K-1 EPA PROTECTIVE ACTION GUIDELINES* 6

DAECEMERGENCYPLAN SECTION 'K' Rev. 24 RADIOLOGICAL EXPOSURE CONTROL Page 3 of 6 1.0 PURPOSE (1) This section describes the measures to be taken to control radiological exposure to emergency workers and the affected offsite population. 2.0 REQUIREMENTS 2.1 EXPOSURE GUIDELINES (1) Conditions may arise wherein consideration will be given to authorizing radiological exposures beyond the normal occupational limit to emergency personnel. These decisions will be based upon the following categories of risk: Emergency Workers. (2) To provide the flexibility that may be necessary for emergencies, Duane Arnold will not consider any occupational dose received during the year and will apply the EPA dose limits stipulated in Table 2.2 of EPA 400-R-92-001 (Manual of Protective Action Guides and Protective Actions for Nuclear Incidents) dated October 1991 with 2nd printing May 1992. However, when determining if a worker may respond to an emergency, Duane Arnold will consider prior overexposures and/or planned special exposures when establishing a worker's available emergency dose. Time permitting; NRC Reg Guide 8.35 (Planned Special Exposures) guidelines will be used. (3) When emergency action is necessary such that emergency personnel would receive radiological exposures beyond the normal occupational limits, the guidelines as outlined in Table K-1 apply. (4) For emergency response actions which might include inhalation of gases or particulates, the emergency dose limit Committed Dose Equivalent to the thyroid is ten times the listed limit in Table K-1. Although respirators and stable iodine should be used where effective to control doses to emergency team workers, Committed Dose Equivalent (thyroid dose) may not be a limiting factor for lifesaving missions. 2.2 ONSITE RADIATION PROTECTION PROGRAM (1) Protective measures associated with the use of protective clothing and the use of respiratory protection equipment are discussed in Section J.

DAECEMERGENCYPLAN SECTION 'K' Rev. 24 RADIOLOGICAL EXPOSURE CONTROL Page 4 of 6 2.3 EXPOSURE CONTROL (1) Exposure Monitoring (a) Duane Arnold will provide exposure monitoring services to determine the doses received by emergency personnel. A health physics technician will supplement each shift operating crew to provide health physics coverage during backshifts, weekends, and holidays when the normal plant staff is not present. In addition, the shift Radwaste operator is available to assist the health physics technician at all times. Added health physics coverage will be provided by trained personnel assigned to the Radiation Protection Department on an as needed basis. An on-shift Non-Certified Operator has been designated to run the MIDAS Dose Projection System until relieved. (b) Electronic or self reading dosimeters and permanent record (thermoluminescent) dosimeters will be issued to onsite emergency personnel including those from Duane Arnold, NRC, state, county, and local agencies. (2) Exposure Records (a) Standard radiation protection practices will be followed in preparing and maintaining exposure records. These procedures ensure that dosimeters are read at appropriate frequencies. Separate records will be maintained for Duane Arnold, NRC, local, state, contractor and consultant personnel who arrive at the site. The Site Radiation Protection Coordinator will be responsible for ensuring that personnel are informed of permissible exposure limits and work time within a controlled zone. Following deactivation, each agency participating in onsite recovery activities will be sent the exposure records for its personnel.

DAECEMERGENCYPLAN SECTION 'K' Rev. 24 RADIOLOGICAL EXPOSURE CONTROL Page 5 of 6 2.4 CONTAMINATION CONTROL MEASURES (1) Decontamination Action Levels (a) Standard radiation protection requirements associated with decontamination of areas, equipment, and tools, etc. will be followed. Any modifications to these standards will be as authorized by the Site Radiation Protection Coordinator. (2) Decontamination Facilities (a) Decontamination facilities are located at the Access Control Point in the Administration Building. These facilities provide for the decontamination of personnel, supplies, and equipment and for waste disposal. The Low Level Radwaste facility can also provide for the decontamination of supplies, equipment, and for waste disposal. (3) Area Access Control (a) Area access will be established and controlled in accordance with standard practices. (4) Water and Food Supplies (a) Water and food supplies at the site shall be verified as acceptable for ingestion in those situations where the probability of contamination of food and water exists. (5) Area Return to Normal Use (a) The Site Radiation Protection Coordinator will determine when evacuated areas may be returned to normal use. Radiological monitoring of those areas will be accomplished in accordance with standard radiation protection practices. 2.5 DECONTAMINATION OF RELOCATED PERSONNEL (1) Personnel will be decontaminated when possible in the onsite decontamination center prior to relocation. Personnel will be taken to the Offsite Relocation and Assembly Area (ORAA) (located at 2800 Hollenbeck Road in Palo) as prescribed in Emergency Plan Implementing Procedures when onsite decontamination is not possible. All personnel will be decontaminated prior to release or reassignment to emergency duties. Necessary equipment and supplies will be available for use at the ORAA, including provisions for extra clothing, decontamination methods suitable for the type of contamination expected, and radioiodine contamination of the skin. Personnel who cannot be decontaminated will be taken to Mercy Medical Center or University of Iowa Hospitals and Clinics for further evaluation. 3.0 ATTACHMENTS (1) TABLE K-1, "EPA PROTECTIVE ACTION GUIDELINES"

DAECEMERGENCYPLAN SECTION 'K' Rev. 24 RADIOLOGICAL EXPOSURE CONTROL Page 6 of 6 TABLE K-1 EPA PROTECTIVE ACTION GUIDELINES* Protective Action PAG Comments (projected dose) Evacuation 1-5 remb Evacuation (or, for some situations, (or shelteringa) shelteringa) should normally be initiated at 1 rem. Administration of stable iodine 25 remc Requires approval of State medical officials. asheltering may be the preferred protective action when it will provide protection equal to or greater than evacuation, based on consideration of factors such as source term characteristics, and temporal or other site-specific conditions. bThe sum of the effective dose equivalent resulting from exposure to external sources and the committed effective dose equivalent incurred from all significant inhalation pathways during the early phase. Committed dose equivalents to the thyroid and to the skin may be 5 and 50 times larger, respectively. ccommitted dose equivalent to the thyroid from radioiodine. Guidance on Dose Limits for Workers Performing Emergency Services Dose Limita Activity Condition (rem) 5 all 10 protecting valuable lower dose not practicable property 25 life saving or protection of lower dose not practicable large populations

           >25            lifesaving or protection of  only on a voluntary basis to persons fully large populations            aware of the risks involved aSum of external effective dose equivalent and committed effective dose equivalent to nonpregnant adults from exposure and intake during an emergency situation. Workers performing services during emergencies should limit dose to the lens of the eye to three times the listed value and doses to any other organ (including skin and body extremities) to ten times the listed value.

These limits apply to all doses from an incident, except those received in unrestricted areas as members of the public during the intermediate phase of the incident.

EPA 400-R-92-001 - Manual of Protective Action Guides and Protective Actions for Nuclear Incidents, Dated 1991 with 2nd printing May 1992.}}

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NG-20-0011, Supplement to License Amendment Request (TSCR-182): Proposed Changes to the Emergency Plan for Permanently Defueled Condition

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