Text

Southern Nuclear Operating Company Response to Third Request for Additional Information Regarding Standard Emergency Plan: Enclosure 11, Vogtle Units 1 and 2 Standard Emergency Plan Annex (Marked-Up Pages and Clean Copy)
	ML16167A416
Person / Time
Site:	Vogtle
Issue date:	06/09/2016
From:	; Southern Nuclear Operating Co
To:	; Office of New Reactors, Office of Nuclear Reactor Regulation
Shared Package
ML16167A468	List: NL-16-0169, Southern Nuclear Operating Company Response to Third Request for Additional Information Regarding Standard Emergency Plan: Enclosure 11, Vogtle Units 1 and 2 Standard Emergency Plan Annex (Marked-Up Pages and Clean Copy); NL-16-0628, Southern Nuclear Operating Company Response to Third Request for Additional Information Regarding Standard Emergency Plan: Cover Letter, Attachment 1 and Enclosures 1 - 10;
References
	NL-16-0169
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{{#Wiki_filter:Southern Nuclear Operating Company Joseph M. Farley Nuclear Plant Units 1 and 2; Edwin I. Hatch Nuclear Plant Units 1 and 2; Vogtle Electric Generating Plant Units 1 and 2; Vogtle Electric Generating Plant Units 3 and 4 Enclosure 11 Vogtle Units 1 and 2 Standard Emergency Plan Annex (Marked-Up Pages and Clean Copy) 1 to NL-16-0169 Vogtle (Units 1&2) Standard Emergency Plan Annex Section 4: Emergency Measures (SEP E) 4.1 Notification of Off-Site Agencies (SEP E.2.2) 4.1 .1 Notification Process (SEP E.2.2.1) State and local warning points are staffed 24 hours per day. State and local counties surround ing VEGP to be notified within 15 minutes of the declaration of an emergency condition are: State of Georg ia:

Georgia Emergency Management Agency (GEMA)

Georgia County Authorities:

Burke - Burke County Emergency Management Agency State of South Carolina :
Emergency Management Division (EMO)

South Carolina County Authorities:

Barnwell and Aiken County - Sheriffs Department
Allendale County - County Central Dispatch Department of Energy - Savannah River Site (DOR-SRS)
DOE-SRS Operations Center 4.2 Alert and Notification System (ANS) (SEP E.2.5) ( Comment [Ml): RAl-VEGP 1&2-3 Within the 10 mile Exposure Emergency Planning Zone (EPZ), there exist provisions for alerting and providing notification to the public. The state and/or local authorities are responsible for activation of this system .

Two totally independent public alerting systems are installed for use in the VEGP EPZ:

Network of fixed sirens and EAS ,
NOAA (National Oceanic and Atmospheric Administration) weather warning radio system .

Offsite agencies will activate both independent systems in the event of a plant condition requiring public awareness. Following any public alert, commercial radio and television stations , as well as NOAA weather radio (NWR) will be used to provide notification and follow-up emergency information to the population within the EPZ. Responsibility for alerting and notifying the public lies with the appropriate offsite civil authorities; specifically, GEMA for anywhere within the State of Georg ia; Burke County EMA for Burke County, Georgia; SCEMD for South Carolina ; The County Division of Emergency Preparedness in Aiken County , South Carolina; the County Disaster Preparedness Agencies in Allendale and Barnwell Counties , South Carolina ; and the SRS . Physical activation of the sirens in Burke County will be done by the Burke County EMA in accordance with the Burke County SOP, and in coordination with GEMA. Physical activation of the siren in Barnwell County will be done by that county , in consultation with SCEMD. Physical activation of the NWR system is by the NWS office in Columbia, SC for VEGP when requested to do so by GEMA. In general, SCEMD will rely upon GEMA to activate the NWR system, and to coordinate with Burke County on the activation of the EAS. E11 -16 1 to NL-16-0169 Vogtle (Units 1&2) Standard Emergency Plan Annex The South Carolina Governor's Office or SCEMD will activate the South Carolina EAS after coordination with Georgia authorities. The system maintenance requirements for the Tone Alert Radio System are contained in the FEMA approved System Design Report. Specifically , Vogtle maintains a database of those assigned tone alert radios and performs an annual telephone survey documenting the adequacy of distribution. Provisions for transient population notification are also included in state and county plans. T>No approved , independent, somplementary, alerting systems are installed in the EPZ to alert the plolblis, sonsisting of a network of fixed sirens or tone alert radios. Provisions for transient poplollation notifisation are also incllolded in state and cololnty plans. In the event of an emergency declaration at the VEGP, DOE-Savannah River Site has agreed to provide prompt notification of all persons on the SRS within VEGP's plume exposure pathway EPZ. The At>JS system inslloldes administrative and physical means for a basklolp method of plolblis alerting and notification capable of being loJSed in the event the primary method of alerting and notifisation is lolna'lailable dming an emergensy to alert or notify all or portions of the pllolme exposlolre pathway EPZ poplollation . The backlolp method has the capability to alert and notify the plolblis within the pllolme exposlolre pathway EPZ, blolt may not meet the 15 minlolte design objecti*1e for the primary prompt plolblic alert and notification system . The Alert and Notification System (ANS) description is provided in the FEMA approved Alert and Notification System Design Report located in the SNC document management system . 4.3 Protective Actions for Onsite Personnel (SEP J.4) Protective response fo r onsite personnel (including visitors and contractor personnel) includes alerting , assembly and accountability, site evacuation , monitoring , and decontamination . Protective actions may also be taken for onsite personnel for emergencies such as fires , security related events or natural disasters where personnel safety is threatened . 4.3 .1 Alerting (SEP E.2 .1, J.1)

                       .Section E of the Emergency Plan , Notification Methods and Procedures, describes the methods to be used to alert onsite personnel of emergency conditions.

4.3.2 Assembly (SEP J.4.1) Personnel assembly is mandatory at the Site Area Emergency or higher level classification. Upon activation of the plant emergency alarm , plant personnel assigned specific emergency responsibilities will proceed to their designated emergency response locations. Assembly of site personnel outside of the Protected Areas is accomplished by non-essential personnel reporting to designated assembly areas. Assembly may be initiated at any time site management deems it appropriate for personnel safety reasons . Nonessential plant personnel located within the Protected Area will exit the protected area upon hearing the Site Area or the General Emergency alarm and report to designated assembly areas. Visitors , contractors, and escorted personnel wi ll leave the protected area during an Alert or higher declaration. E11 -17 1 to NL-16-0169 Vogtle (Units 1&2) Standard Emergency Plan Annex TE~ICAL SUPl'Of!T CENTER AJR AIR LOCK I LOCK VESTIBULE COMPllTEJI OPERATION ROOM ROOll

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                                                                                   -        -                               LEV!'L 1 CONTROL ELECTRIC         BATTERY           Rf:STJlOOllS                  WOM A.REA               8UJLDtNG fQ.UJPMEHT         ROOM             & SHOWERS ROOM AJR LOCK c

Figure 5.1.A - Sample Technical Support Center E11 -23 1 to NL-16-0169 Vogtle (Units 1&2) Standard Emergency Plan Annex Activation of the time history accelerographs causes visual and audible annunciation in the control room to alert the plant operator that an earthquake has occurred . 5.7 Protective Facilities and Equipment (SEP J) Assembly Points (SEP J.4.1) In the event of a plant evacuation , the On-Site Assembly Areas located within the Administration Building (or Off-Site Assembly Areas , as appropriate) will be used. The function of the assembly area is to provide a center for personnel accountability and radiolog ical contamination screening along with any other immediately necessary actions. The assembly areas are located in various buildings throughout the site. Georgia Power Company facilities may be used as the off-site assembly area at the discretion of the Emergency Director. The assembly area location will be announced over the public address system when announcement of evacuation is made. Protective actions, including relocation of onsite personnel, in the event of an attack or threat of hostile action against the site have been developed for that specific situation. Specific protective actions in this case are identified in site procedures not readily available to the public. 5.8 Medical Support (SEP B.6, SEP L) 5.8.1 Hospital and Medical Support (SEP B.6.3, L.1) Agreements are in place with the University of Alabama at Birmingham (UAB) Hospital, Burke Medical Center, Doctors Hospital, and Burke County Emergency Management Agency to provide assistance for injured personnel, including cases involving radioactive contamination . This assistance will be requested whenever necessary in accordance with plant procedures . 5.8.2 Ambulance Service (SEP B.6.2, L.4) Injured/externally contaminated personnel who requ ire medical attention will normally be transported by ambulance to the cooperating hospitals. Ambulance crews are trained to handle external contamination cases, and an RP technician may accompany, as requested , any contaminated patients to the hospital. Ambulance service is provided by the Burke County Emergency Management Agency. E11-27 1 to NL-16-0169 Vogtle (Units 1&2) Standard Emergency Plan Annex Appendix C - Vogtle Electric Generating Plant 1&2 NUREG-0654 Cross Reference [able [ Comment [M2]: RAJ-GEN-2 NUREG 0654 Rev 1 VEGP1&2 SNC SEP Ref Section SEP Annex Criteria II.A

Assianment of Resoonsibility A.1.a A.1, A.2, A.3, A.4 1.3, 1.4, 1.5, 1.6 A.1 .b Introduction Section 1: Introduction A.1.c Figures 8 .2.1.A, 8 .2.2.A, 8 .3.1.A & --

8 .3.2.A A.1.d 8 .3.1 .1 -- A.1 .e 8 .1 Table 2.2.A A.2.a N/A N/A A.2.b N/A N/A A.3 A.5 1.7 A.4 8 .2, 8 .2.1.15, 8 .3.1.3 -- Criteria 11.B

Onsite Emeraenc1 Oraanization 8 .1 8 .2 --

8 .2 8 .1.1 Table 2.2.A 8.3 8 .1.2 -- 8.4 8 .1.1, Figure 8 .2.A -- 8 .5 Tables 1 - 4 Table 2.2.A 8.6 8 .2, 8 .3, Figures 8 .2.1.A, 8 .2.2.A, -- 8 .3.1.A & 8 .3.2.A 8 .7 Tables 1-4 -- Figures 8 .2.1.A, 8 .2.2.A, 8 .3.1.A & 8 .3.2.A 8 .7.a 8 .2.1.15, 8 .3.1.3 -- 8 .7.b 8 .3.1 .2, 8 .3.1.17 -- 8 .7.c 8 .3.1.1, 8 .3.1.2 -- 8 .7.d 8.3.2.1, 8 .3.2.2, 8 .3.2.8 -- 8 .8 8.4, C.4.2 2.3 8 .9 8.6, K.1 2.3 Criteria 11.C

Emergency Response Suooort and Resources C.1.a Section C --

C.1.b A.1 1.6 C.1.c A.1.1 , A.2, A.3 C.1-C.4, F.1 Section 1 C.2.a N/A N/A C.2.b A.1.1 , H.2.1 5.1.2 C.3 H.5.2 .3, H.6.3 -- C.4 Sections A & C, 8.4-8 .6, H.6.3, L.1- 1.3-1.7 , 2.3, 5.8 L.4 Criteria 11.D

Emergency Classification System D.1 Section D Appendix 8 D.2 Section D Appendix 8 D.3 N/A NIA D.4 N/A N/A Criteria 11.E
Notification Methods and Procedures E.1 E.1.1 Appendix D E.2 E.2.1 --

E.3 E.2.2.2 -- E.4 E.2.2.2 -- E.4.a E.2.2.2 -- E.4.b E.2.2.2 -- E.4.c E.2.2.2 -- NOTE: N/A =Not requ ired by Licensee in accordance with NUREG-0654 1 to NL- 16-0169 Vogtle (Units 1&2) Standard Emergency Plan Annex NUREG 0654 Rev 1 VEGP1&2 SNC SEP Ref Section SEP Annex Criteria 11.E - Notification Methods and Procedures (continued) E.4.d E.2.2.2 -- E.4.e E.2 .2.2 -- E.4.f E.2.2.2 -- E.4 .Q E.2.2.2 -- E.4.h E.2.2.2 -- E.4. i E.2.2.2 -- E.4.i E.2.2.2 -- E.4.k E.2.2.2 -- E.4.1 E.2.2.2 -- E.4.m E.2.2.2 -- E.4.n E.2.2.2 -- E.5 NIA NIA E.6 E.2.5 -- E.7 E.2.6 -- Criteria 11.F - Emeraencv Communications F.1 .a F.1.1 , F.1.2 4.1.1 F.1.b F.1.3 -- F.1.c F.1.4 -- F.1.d F.1.5 -- F.1.e F.1.6 -- F.1.f F.1.4 -- F.2 F.2 -- F.3 F.3 5.4 Criteria 11.G - Public Education and Information G.1 G.1 -- G.2 G.8 2.3.6 G.3.a B.3.2 .1, H.2.2, H.2.3 5.1.6 G.3.b NIA NIA G.4.a B.3.2.8 -- G.4.b G.2 -- G.4.c B.3.2.5, B.3.2.6 -- G.5 G.2 -- Criteria 11.H - Emeraencv Eauipment and Facilities H.1 H.1.2 5.1.2 H.2 H.2.1 5.1.5 H.3 H.2.2 , H.2.3 -- H.4 H.1 -- H.5 H.5 5.6 H.5.a H.5.1 5.6.1 H.5.b H.5.2 -- H.5.c H.5.3 -- H.5.d H.5.4 -- H.6.a H.5.1 5.6.1 H.6.b H.5.2 -- H.6.c H.5.2.3 H.6.3 -- H.7 H.6 -- H.8 H.7 5.6.1 H.9 H.1.3 5.1.3 H.10 H.8 -- H.11 H.9 -- H.12 H.10 -- NOTE: N/A =Not required by Licensee in accordance with NUREG-0654 1 to NL-16-0169 Vogtle (Units 1 &2) Standard Emergency Plan Annex NUREG 0654 Rev 1 VEGP 1&2 SNC SEP Ref Section SEP Annex Criteria II.I - Accident Assessment - 1.1 1.1 -- 1.2 1.2 --

1. 3.a 1.3 --

1.3.b 1.3 -- 1.4 1.4 -- 1.5 1.5 -- 1.6 1.6 -- 1.7 1.7 -- 1.8 1.8 -- 1.9 1.9 -- 1.10 1.7 -- 1.11 NIA NIA Criteria 11.J - Protective Response J.1.a J.1 -- J.1.b J.1 -- J.1 .c J.1 -- J.1.d J.1 -- J.2 J.4.3 -- J.3 J.2 -- J.4 J.3, J.4.3 -- J.5 J.4.2, 4.3.2 -- J.6.a J.4 -- J.6.b J.4 -- J.6.c J.4 -- J.7 J.5 -- J.8 J.6 Appendix A J.9 NIA NIA J.10.a J.7 -- J.10.b J.7 -- J.10.c E.2.5 4.2 J.10.d NIA NIA J.10.e NIA NIA J.10.f NIA NIA J.10.Cl NIA NIA J.10.h NIA NIA J.10.i NIA NIA J.10.i NIA NIA J.10.k NIA NIA J.1 0.1 NIA NIA J.10.m J.5 -- J.11 NIA NIA J.12 NIA NIA Criteria 11.K - Radioloaical Exposure Control K.1.a K.1 .1 -- K.1.b K.1 -- K.1.c K.1 -- K.1.d K.1.2.1 -- K.1.e K.1.2.1 , K.5 -- K.1.f K.1 .1.1 -- K.1.o K.1.3 -- K.2 K.1 - NOTE: N/A =Not requ ired by Licensee in accordance with NUREG-0654 1 to NL-16-0169 Vogtle (Units 1&2) Standard Emergency Plan Annex NUREG 0654 Rev 1 VEGP 1&2 SNCSEP Ref Section SEP Annex Criteria 11.K - Radiological Exposure Control (continue<tJ K.3.a K.3 -- K.3.b K.3 -- K.4 N/A N/A K.5.a K.5 -- K.5.b K.5 -- K.6.a K.6 -- K.6 .b K.6 -- K.6.c K.6 -- K.7 K.7 -- Criteria 11.L - Medical and Public Health Suooort L.1 L.1 -- L.2 L.2 -- L3 N/A N/A L.4 L.4 -- Criteria 11.M - Recovery and Reentry Plannina and Post-Accident Operations M.1 M.1 -- M.2 M.2 -- M.3 M.3 -- M.4 M.4 -- Criteria 11.N - Exercises and Drills N.1.a N.1 -- N.1 .b N.1 -- N.2.a F.3 -- N.2.b N.2.3 -- N.2.c N.2.4 -- N.2.d N.2.5 -- N.2.e(1) N.2.6 -- N.2.el2\ N.2.6 -- N.3.a N.3 -- N.3.b N.3 -- N.3.c N.3 -- N.3.d N.3 -- N.3.e N.3 -- N.3.f N.3 -- N.4 N.4 -- N.5 N.5 -- Criteria 11.0 - Radioloaical Emeraencv Response Trainina 0 .1 0 .1 -- 0 .1.a 0 .1.1 -- 0.1.b 0 .1.1 -- 0.2 0 .3 -- 0 .3 0.4 -- 0.4 .a 0.4 -- 0.4 .b 0.4 -- 0.4.c 0.4.3 -- 0.4.d 0.4.1, 0.4.4 -- 0 .4.e 0.4.5 -- 0.4.f 0.4.6 -- 0.4.a 0.1 .1 -- 0.4 .h 0 .1.1 -- 0.4.i 0 .4 -- NOTE: N/A = Not required by Licensee in accordance with NUREG-0654 1 to NL-16-0169 Vogtle (Units 1&2) Standard Emergency Plan Annex NUREG 0654 Rev 1 VEGP 1&2 SNCSEP Ref Section SEP Annex Criteria 11.0 - Radioloaical Emergencv Response Trainina !continued) - 0 .4.i 0.4 0.4.7 -- 0 .5 0.4 -- Criteria 11.P - Responsibility for the Planning Effort: Development, Periodic Review and Distribution of Emergency Plans P.1 0 .5 Section P -- P.2 Section P -- P.3 P.1 -- P.4 P.1 -- P.5 P.3 -- P.6 P.3 -- P.7 -- Appendix D P.8 Table of Contents -- P.9 P.3 -- P.10 F.1.4 -- NOTE: N/A =Not required by Licensee in accordance with NUREG-0654 1 to NL-16-0169 Vogtle (Units 1&2) Standard Emergency Plan Annex Appendix D - Supporting Plans & Implementing Procedures (SEP P.3) Supporting Plans

State of South Carolina Radiological Emergency Response Plan
State of Georg ia Radiological Emergency Response Plan.
Burke County Georgia Emergency Response Plan
Aiken, Allendale, Barnwell County Emergency Response Plan
VEGP Security Plan Administrative and Emergency Plan Implementing Procedures (EPIPl Plan Section Title EPIP EPIP Title Section A Assignment of Responsibility NMP-EP-300 SNC Emergency Preparedness (under Conduct of Operations development) 91801-C Coordination of Emergency Responses and Planning Between Southern Nuclear Operating Company-VEGP and US DOE-Savannah River Site B Emergency Response Organization NMP-EP-146 ERO Position Checklists 91 101 -C Emergency Response Organization c Emergency Response Support and NMP-EP-300 SNC Emergency Preparedness Resources (under Conduct of Operations development) 91703-C Emergency Support for Hatch Nuclear Plant D Emergency Classification System NMP-EP-141 Emergency Classification E Notification Methods and NMP-EP-142 Emergency Notification Procedures NMP-EP-308 SNC Emergency Alert Siren Operation , Testing And Maintenance Alert Notification System 91706-C F Emergency Communications NMP-EP-300 SNC Emergency Preparedness (under Conduct of Operations development) 91204-C Emergency Response Commun ications 1 to NL-16-0169 Vogtle (Units 1&2) Standard Emergency Plan Annex Plan Section Title EPIP EPIP Title Section G Public Education and Information NMP-EP-203 Corporate Media Center Operations NMP-EP-204 Emergency News Center/Joint Information Center Operations NMP-EP-205 Emergency Communications News NMP-EP-206 Releases NMP-EP-207 Emergency Communications News Briefings Emergency Communications Public

Response

H Emergency Facilities and Equipment NMP-EP-143 Facility Activation NMP-EP-305 Equipment Important to the EP Function 91702-C Emergency Equipment and Supplies 91705-C Inventory and Testing of Emergency Preparedness Material/Equipment Which Are Not Part of the Emergency Kits I Accident Assessment NMP-EP-140 Accident Assessment 91302-C In Plant Sampling and Surveys 91303-C Field Sampling and Surveys J Protective Response NMP-EP-144 Protective Actions 91704-C Actions for Security During a Radiological Emergency K Radiological Exposure Control NMP-EP-144 Protective Actions 91301 -C Emergency Exposure Guidelines 91306-C Contamination Monitoring and Decontamination L Medical and Public Health Support NMP-EP-300 SNC Emergency Preparedness (under Conduct of Operations development) 91309-C Mass Casualty Triage M Recovery and Re-entry Planning NMP-EP-145 Termination and Recovery and Post Accident Operations 91308-C Re-Entry N Exercises and Drills NMP-EP-303 Drill and Exercise Standards 0 Radiological Emergency Response NMP-EP-301 EOF Emergency Response Training Organization And EP Staff Training 91601-C Emergency Preparedness Training 1 to NL-16-0169 Vogtle (Units 1&2) Standard Emergency Plan Annex Plan Section Title EPIP EPIP Title Section p Responsibility for the Planning Effort NMP-EP-300 SNC Emergency Preparedness Conduct of Operations NMP-EP-310 Maintaining The Emergency Plan NMP-EP-312 Development Of Emergency Preparedness Technical Products 91701-C Preparation and Control of Emergency Preparedness Documents

Southern Nuclear Operating Company STANDARD EMERGENCY PLAN ANNEX for Vogtle Electric Generating Plant Units 1and2 Revision 0 1 to NL-16-0169 Vogtle (Units 1&2) Standard Emergency Plan Annex Table of Contents Section 1: Introduction (SEP) ............................................................................................................................ 3 1.1 Facility Description ...............................................................................................................................*........ 3 1.2 Emergency Planning Zones (SEP J.5) ....................................................................................................... 3 1.3 State of Georgia (SEP A.2.2) ...................................................................................................................... 3 1.4 State of South Carolina (SEP A.2.3) .......................................................................................................... 4 1.5 Local Organizations (SEP A.2.4, B.6.1) ..................................................................................................... 5 1.6 Department of Energy (DOE) - Savannah River Site (SRS) (SEP A.1.4) ........................................... 5 1.7 Hostile Action Based Events (SEP H.1.4) ................................................................................................. 5 Figure 1.1.A - Location and Vicinity Map ............................................................................................................ 7 Figure 1.1.B - Vogtle Electric Generating Plant Site Plan ................................................................................. 8 Figure 1.2.A - 10 Mile Emergency Planning Zone (EPZ) ................................................................................. 9 Figure 1.2.B - 50 Mile Ingestion Pathway IPZ ................................................................................................. IO Section 2: Organizational Control of Emergencies (SEP 8.1) ................................................................ 11 2.1 Normal Plant Organization (SEP B.1) ...................................................................................................... 11 2.2 Emergency Organization (SEP B.2, B.3) ............ ,.................................................................................... 11 Table 2.2.A - Vogtle Electric Generating Plant On-Shift Staffing ................................................................... 12 2.3 Non-SNC Support Groups (SEP B.4, B.5, B.6) ...................................................................................... 13 Section 3: Classification of Emergencies (SEP D.1) ................................................................:................ 15 3.1 Emergency Classifications: (SEP D.1) ..................................................................................................... 15 3.2 Determination of Levels: (SEP D.1.2) .......................................... :........................................................... 15 3.3 Operating Mode Applicability (SEP D.2.7) ............................................................................................... 15 Section 4: Emergency Measures (SEP E) ..................................................................................................... 16 4.1 Notification of Off-Site Agencies (SEP E.2.2) ......................................................................................... 16 4.2 Alert and Notification System (ANS) (SEP E.2.5) .................................................................................. 16 4.3 Protective Actions for Onsite Personnel (SEP J.4) ................................................................................ 17 4.4 Protective Actions for the Offsite Public (SEP J.5) ................................................................................. 18 Section 5: Emergency Facilities and Equipment (SEP H) ...................................................~ .................... 20 5.1 Emergency Response Facilities (SEP H.1, H.2) .................. ;................................................................. 20 Figure 5.1.A - Sample Technical Support Center ........................................................................................... 23 Figure 5.1.B - Sample Operations Support Center ......................................................................................... 24 5.2 On-Site Communications (SEP F.1) ......................................................................................................... 25 5.3 Offsite Communications (SEP F.1) ........................................................................................................... 25 5.4 Communications System Testing (SEP F.3) ........................................................................................... 25 5.5 Emergency Kits (SEP H.9) .......................................................................................................................... 25 5.6 Facilities and Equipment for On-site Monitoring (SEP H.5) .................................................................. 25

5. 7 Protective Facilities and Equipment (SEP J) ........................................................................................... 27 5.8 Medical Support (SEP B.6, SEP L) .....................:.. *********************************************************************************** 27 Appendix A - Evacuation Time Estimate Study and Map Reference (SEP J.6) ................................. 28 Appendix B - Emergency Action Level (EAL) Scheme (SEP D.1) .......................................................... 30 Appendix C - Vogtle Electric Generating Plant 1&2 NUREG-0654 Cross Reference Table ............ 31 Appendix D - Supporting Plans & Implementing Procedures (SEP P.3) .............................................. 36 E11-2 1 to NL-16-0169 Vogtle (Units 1&2) Standard Emergency Plan Annex Section 1: Introduction (SEP)

This document serves as the Vogtle Electric Generating Plant (VEGP) Units 1 and 2 Annex and contains information and guidance that is unique to VEGP Units 1 and 2. This includes Emergency Action Levels (EALs) and facility geography. In an emergency situation at VEGP, the initial response would be made by the site staff and, if needed, by local support agencies. This Annex addresses the actions and responsibilities of the VEGP plant staff and the offsite support agencies. 1.1 Facility Description The Vogtle Electric Generating Plant (VEGP) Units 1 and 2 are a two-unit pressurized water reactor. The plant site (Figure 1.1.B), to include VEGP Units 1-4, is on a 3, 169-acre site located in the eastern portion of Burke County, Georgia, approximately 23 river miles upstream from the intersection of the Savannah River with U.S. Highway 301 Figure 1.1.A). 1.2 Emergency Planning Zones (SEP J.5) 1.2.1 Plume Exposure Pathway (SEP J. 7) The 10-mile Emergency Planning Zone (EPZ) for VEGP approximates a 10-mile radius around the plant site and is depicted in Figure 1.2.A. Georgia and South Carolina, as well as the counties (Burke County in Georgia and Aiken, Barnwell, and Allendale Counties in South Carolina) are located within the plume exposure pathway EPZ. The major portion of the plume exposure pathway EPZ in South Carolina is within the Department of Energy's Savannah River Site (SRS). 1.2.2 Ingestion Pathway (SEP J.7) The area between the 10-mile and 50-mile radius is considered the Ingestion Pathway Zone (IPZ). The 50-mile IPZ is depicted in Figure 1.2.B. Planning for the ingestion exposure pathway is a responsibility of the states of Georgia and South Carolina. More information about the IPZ can be obtained from the states' Radiological Emergency Plans. 1.3

State of Georgia (SEP A.2.2)

Upon notification of an emergency condition, the Georgia Emergency Management Agency will implement the "State of Georgia Radiological Emergency Plan." The Georgia Emergency Management Agency has the authority and responsibility for coordinating the efforts of local and state agencies in Georgia to provide for the health and safety of the general public in the event of a radiological incident. An agreement is in place with the state of Georgia to provide available resources and equipment to support mitigation and response to an emergency at Plant Vogtle, including Hostile Action Based events. These resources include, but are not limited to, Local Law Enforcement Agency (LLEA) assets, fire fighting assets, medical support resources (including transportation), and coordination through an Incident Command Post. Requests for offsite resources and equipment will be communicated from the control room to the Burke County 911 center, the county EOC, or through the Incident Command Post, as applicable, based on the nature and timing of the event. E11-3 1 to NL-16-0169 Vogtle (Units 1&2) Standard Emergency Plan Annex 1.4 State of South Carolina (SEP A.2.3) The state of South Carolina has developed the South Carolina Radiological Emergency Response Plan (SCORERP), which provides guidance to state and local governments on procedures, organization, and responsibilities for preventing and mitigating the effects of a nuclear power plant incident or disaster. The SCORERP describes the South Carolina Radiological Emergency Response Organization which consists of the Office of the Adjutant General (Emergency Management Division) (EMO), the Department of Health and Environmental Control (Bureau of Solid and Hazardous Waste, Nuclear Emergency Planning (NEP) Section), and those state resources available to local government(s) during a fixed nuclear facility radiological accident. The response functions of involved agencies are described in the SCORERP and the South Carolina Technical Radiological Emergency Response Plan (SCTRERP). 1.4.1 Office of the Governor (SEP A.2.3.1) In the event of the declaration of a radiological emergency, the EMO, Department of Health and Environmental Control (DHEC), and other state agencies are activated. 1.4.2 Office of the Adjutant General - Emergency Management Division (EMO) (SEP A.2.3.1) The EMO is responsible for coordinating the emergency planning efforts of all state, county, and municipal agencies in developing a state emergency plan. Additional responsibilities include conducting a preparedness program to assure capability of the state government to execute the plan; establishing and maintaining a state EOC and providing support of the state emergency staff and work force; and establishing an effective system for reporting, analyzing, and disseminating emergency information. 1.4.3 Department of Health and Environmental Control (DHEC) (A.2.3.2) DHEC maintains a radiological hazard assessment capability and provides technical support, coordination, and guidance for the state and local governments. It will conduct and/or coordinate radiological surveillance and monitoring in coordination with DOE-Savannah River Site (SRS) and VEGP. 1.4.4 Other State Support Agencies (A.2.3.3) Other state agencies described in the South Carolina Emergency Operating Plan (SCEOP) and South Carolina Operational Radiological Emergency Response Plan (SCORERP) will provide related support pursuant to each plan. Those agencies include:

Department of Public Safety (Highway Patrol Division).
State Law Enforcement division (SLED).

E11-4 1 to NL-16-0169 Vogtle (Units 1&2) Standard Emergency Plan Annex

Forestry Commission.
Department of Natural Resources.
Department of Social Services.
Department of Agriculture.
Clemson University Cooperative Extension Service.

1.5 Local Organizations (SEP A.2.4, B.6.1) Principal activities of Local Emergency Management Agencies (LEMA) and Local Law Enforcement Agencies (LLEA) in Georgia and South Carolina are described in the respective County Emergency Operations Plans. 1.5.1 Burke County Georgia (SEP A.2.4) The area within the plume exposure pathway (EPZ) in the state of Georgia falls within Burke County. The responsibility for overall radiological emergency response planning rests with the Chairman, Burke County Board of Commissioners. It is the chairman's responsibility to initiate actions and provide direction and control at a level consistent with the specific incident. 1.5.2 Aiken, Barnwell, and Allendale Counties South Carolina (SEP A.2.4) Most of the plume exposure pathway EPZ within South Carolina falls within the site boundary of the Savannah River Site (SRS). The United States Department of Energy is responsible for the direction and control of all emergency response actions on the SRS. Limited portions of Aiken, Barnwell, and Allendale counties are outside of the SRS but within the plume exposure pathway EPZ of VEGP. These counties are similarly organized, with the responsibility for overall radiological emergency response planning resting with the Chairman of the County Council in each case. 1.6 Department of Energy (DOE) - Savannah River Site (SRS) (SEP A.1.4) The DOE-Savannah River Site (SRS) will provide the necessary response within the SRS reservation in accordance with the SRS Emergency Plan. The DOE will exercise overall responsibility, jurisdiction, and authority for conducting response operations on the Savannah River Site to protect the health and safety of SRS personnel. DOE will provide for emergency notification and, as needed, evacuation, monitoring, decontamination, and immediate lifesaving medical treatment of non-SRS personnel on the Savannah River Site. DOE will also provide access control for SRS areas.

1. 7 Hostile Action Based Events (SEP H.1.4)

Agreements are in place with the state of Georgia, Burke County, Georgia, Aiken, Allendale, and Barnwell Counties in South Carolina to provide available resources and equipment to support mitigation and response to an emergency at Plant Vogtle including Hostile Action Based events. These resources include, but are not limited to, Local Law Enforcement Agency (LLEA) assets, firefighting assets, medical support resources (including transportation), and coordination through an Incident Command Post. Requests for offsite resources and E11-5 1 to NL-16-0169 Vogtle (Units 1&2) Standard Emergency Plan Annex equipment will be communicated from the control room to Burke County 911 Center or through the Incident Command Post as applicable based on the nature of the event. Copies of these agreements are maintained in accordance with Emergency Plan procedures. E11-6 1 to NL-16-0169 Vogtle (Units 1&2) Standard Emergency Plan Annex 0 A10 20 30 Miles Figure 1.1.A - Location and Vicinity Map E11-7

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Figure 1.1.B - Vogtle Electric Generating Plant Site Plan E11 -8 1 to NL-16-0169 Vogtle (Units 1&2) Standard Emergency Plan Annex 1 '-

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Figure 1.2.A - 10 Mile Emergency Planning Zone (EPZ) E11-9 1 to NL-16-0169 Vogtle (Units 1&2) Standard Emergency Plan Annex Figure 1.2. B - 50 Mile Ingestion Pathway IPZ E11-10 1 to NL-16-0169 Vogtle (Units 1&2) Standard Emergency Plan Annex Section 2: Organizational Control of Emergencies (SEP B.1) 2.1 Normal Plant Organization (SEP B.1) The normal plant operating crew is staffed and qualified to perform actions that may be necessary to initiate immediate protective actions and to implement the emergency plan and is designated as the responsible group for such actions. The normal plant organization is described in Section B.1 of the SNC Standard Emergency Plan. 2.2 Emergency Organization (SEP B.2, B.3) 2.2.1 The VEGP On-Shift Emergency Response Organization is described in Table 2.2.A (SEP B.1) 2.2.2 The VEGP Augmented Emergency Response Organization is described in Figures B.2.1.A, B.2.2.A, B.3.1.A, and B.3.2.A in the Emergency Plan (SEP B.2, B.3) An On-Shift Staffing Analysis was completed in accordance with the requirements of 10 CFR 50 Appendix E IV.A.9. This analysis forms the basis for the on-shift staff as described in Table 2.2.A. A copy of the analysis is maintained in the SNC document management system. E11-11

Enclosure 11 to NL-16-0169 Vogtle (Units 1&2) Standard Emergency Plan Annex Table 2.2.A - Vogtle Electric Generating Plant On-Shift Staffing Vo~tle 1&2 Major Functional Area MaiorTasks Position On-Shift Emergency Direction and Shift Manager (SM)/ 1 Control Emeroency Director (ED) Plant Operations and Shift Supervisor (SRO) 2 Assessment of Operational Reactor Operator (RO) 4 Aspects Shift Support 1 Supervisor/Fire Bri~ade Leader (SRO/FBL) ote 1 System Operator (SO) Noie 1 7 Plant System Engineering, Technical Support Shift Technical Advisor Note 2 Repair and Corrective Actions Notification/ Communication Notify licensee, State local and Licensed Operator (RO or Note 2 Federal personnel & maintain SRO) communication Radiological Accident Offsite Dose Assessment Chemistry Technician or other 1 Assessment and Support of trained personnel Operational Accident In-plant surveys RP Technician or other 1 Assessment trained personnel Offsite Surveys Onsite (out-of-plant) RP Technician or other trained 1 personnel Protective Actions Radiation Protection: RP Technician 1

a. Access Control

b. RP Coverage for repair, corrective actions, search and rescue first-aid & firefighting

c. Personnel monitoring

d. Dosimetry Chemistry/Radio- chemistry Chemistry Technician 1 Plant System Engineering, Repair and Corrective Actions Maintenance Supervisor 1 Repair and Corrective Mechanic 1 Actions Electrician 1 l&C Technician 1 Total: 24 1

Fire Fighting Fire Brigade Note 5 Rescue Operations and First Rescue Operations/First Aid 2 Note 2 Aid Site Access Control and Security Security Personnel Accountability Plan Note 1 - Fire Brigade made up of FB Leader (SSS) and 4 System Operators not assigned safe shutdown responsibilities Note 2 - May be provided by shift personnel assigned other functions E11-12 1 to NL-16-0169 Vogtle (Units 1&2) Standard Emergency Plan Annex 2.3 Non-SNC Support Groups (SEP B.4, B.5, B.6) 2.3.1 Fire Fighting (SEP B.6.4) VEGP has established an agreement with the Burke County Emergency Management Agency to provide, upon request, offsite fire support to the VEGP Units 1 and 2 Fire Brigade. Fire support provided includes, but is not limited to, firefighters and firefighting equipment. Request for fire support will be made by the control room or site security to the Burke County Emergency Management Agency, Burke County EOC, or the Incident Command Post, as applicable, based on the nature and timing of the event. A copy of this agreement is maintained in the SNC document management system. 2.3.2 Hospital and Medical Support (SEP B.6.3, K.1.3, L.1) Agreements are in place with the University of Alabama at Birmingham (UAB) Hospital, Burke Medical Center, Doctors Hospital, and Burke County Emergency Management Agency, to provide assistance for injured personnel, including cases involving radioactive contamination. This assistance will be requested whenever necessary in accordance with plant procedures. Medical Specialists, Inc., a group of medical professionals, has agreed to provide treatment services through Burke Medical Center and Doctors Hospital. 2.3.3 Ambulance Service (SEP B.6.2, L.4) VEGP has established agreements with the Burke County Emergency Management Agency to provide ambulance service for the transportation of injured personnel, including people who may be radioactively contaminated, to hospital facilities for treatment. Support provided includes, but is not limited to, emergency medical services, ambulances, and emergency medical technicians. Requests for fire support will be made by the control room or site security to the Burke County Emergency

                    . Management Agency center, Burke County EOC, or the Incident Command Post, as applicable, based on the nature and timing of the event. A copy of this agreement is maintained in accordance with Emergency Plan procedures.

2.3.4 Emergency Broadcasts (SEP E.2.5.1) VEGP has established agreements with media agencies to broadcast emergency messages and information to the public during an emergency event. The messages will be coordinated with local or state Emergency Management Agencies and are available on a 24-hour basis as members of the Emergency Alert System (EAS). 2.3.5 Voluntary Assistance Group (SEP B.4.2) VEGP is a signatory to two comprehensive agreements among electric utility companies:

Nuclear Power Plant Emergency Response Voluntary Assistance Agreement.
Voluntary Assistance Agreement By and Among Electric Utilities Involved in Transportation of Nuclear Materials.

2.3.6 Information for Transients (SEP G.8) Several communications methods may be used to acquaint the public with plans for their protection during a Plant emergency. Effort will be concentrated on providing information to the public by written material E11-13 1 to NL-16-0169 Vogtle (Units 1&2) Standard Emergency Plan Annex that is likely to be available in local residences and in locations frequented by transients. The information will also provide instructions on which local media will be providing additional information in the event of an emergency. E11-14 1 to NL-16-0169 Vogtle (Units 1&2) Standard Emergency Plan Annex Section 3: Classification of Emergencies (SEP D.1) 3.1 Emergency Classifications: (SEP D.1) Emergencies are classified into four levels according to severity, taking into consideration potential, as well as actual, events in progress. They are, from the least to the most serious, Unusual Event, Alert, Site Area Emergency, and General Emergency. Initiating Conditions (ICs), which determine which level will be declared, are predetermined subsets of plant conditions where the potential exists for a radiological emergency, or such an emergency has occurred. Emergency Action Levels (EALs) are plant-specific indications, conditions, or instrument readings that are utilized to classify emergency conditions. 3.1.1 The described emergency classes and the emergency action levels that determine them are agreed on by SNC and state and local authorities. The emergency action levels will be reviewed by these (state and local) officials annually. 3.2 Determination of Levels: (SEP D.1.2) Appendix B to this Annex contains the matrix for Initiating Conditions used to determine an Emergency Action Level (EAL). They are part of the scheme established by NEI 99-01, Methodology for Development of Emergency Action Levels. 3.3 Operating Mode Applicability (SEP D.2.7) The plant operating mode that existed at the time that the event occurred, prior to any protective system or operator action initiated in response to the condition, is compared to the mode applicability of the EALs. If an event occurs, and a lower or higher plant operating mode is reached before the emergency classification level can be declared, the emergency classification level shall be based on the mode that existed at the time the event occurred. PWR Operating Modes at VEGP 1&2 Power Operations (1): Reactor Power> 5%, Kett~ 0.99 Startup (2): Reactor Power::;; 5%, Kett~ 0.99 Hot Standby (3): RCS ~ 350 °F, Kett< 0.99 Hot Shutdown (4): 200 °F < RCS< 350 °F, Kett< 0.99 Cold Shutdown (5): RCS:::; 200 °F, Kett< 0.99 Refueling (6): One or more vessel head closure bolts less than fully tensioned Defueled (None): All reactor fuel removed from reactor pressure vessel. (Full core off load during refueling or extended outage) E11-15 1 to NL-16-0169 Vogtle (Units 1&2) Standard Emergency Plan Annex Section 4: Emergency Measures (SEP E) 4.1 Notification of Off-Site Agencies (SEP E.2.2) 4.1.1 Notification Process (SEP E.2.2.1) State and local warning points are staffed 24 hours per day. State and* local counties surrounding VEGP to be notified within 15 minutes of the declaration of an emergency condition are: State of Georgia:

Georgia Emergency Management Agency (GEMA)

Georgia County Authorities:

Burke - Burke County Emergency Management Agency State of South Carolina:
Emergency Management Division (EMO)

South Carolina County Authorities:

Barnwell and Aiken County - Sheriff's Department

                      * . Allendale County - County Central Dispatch Department of Energy - Savannah River Site (DOR-SRS)

DOE-SRS Operations Center 4.2 Alert and Notification $ystem (ANS) (SEP E.2.5)

Within the 10 mile Exposure Emergency Planning Zone (EPZ), there exist provisions for alerting and providing notification to the public. The state and/or local authorities are responsible for activation of this system. Two totally independent public alerting systems are installed for use in the VEGP EPZ:

Network of fixed sirens and EAS,
NOAA (National Oceanic and Atmospheric Administration) weather warning radio system.

Offsite agencies will activate both independent systems in the event of a plant condition requiring public awareness. Following any public alert, commercial radio and television stations, as well as NOAA weather radio (NWR) will be used to provide notification and follow-up emergency information to the population within the EPZ. Responsibility for alerting and notifying the public lies with the appropriate offsite civil authorities; specifically, GEMA for anywhere within the State of Georgia; Burke County EMA for Burke County, Georgia; SCEMD for South Carolina; The County Division of Emergency Preparedness in Aiken County, South Carolina; the County Disaster Preparedness Agencies in Allendale and Barnwell Counties, South Carolina; and the SRS. Physical activation of the sirens in Burke County will be done by the Burke County EMA in accordance with the Burke County SOP, and in coordination with GEMA. Physical activation of the siren in Barnwell County will be done by that county, in consultation with SCEMD. Physical activation of the NWR system is by the NWS office in Columbia, SC for VEGP when requested to do so by GEMA. In general, SCEMD will rely upon GEMA to activate the NWR system, and to coordinate with Burke County on the activation of the EAS. E11-16 1 to NL-16-0169 Vogtle (Units 1&2) Standard Emergency Plan Annex The South Carolina Governor's Office or SCEMD will activate the South Carolina EAS after coordination with Georgia authorities. The system maintenance requirements for the Tone Alert Radio System are contained in the FEMA approved System Design Report. Specifically, Vogtle maintains a database of those assigned tone alert radios and performs an annual telephone survey documenting the adequacy of distribution. Provisions for transient population notification are also included in state anti county plans.* In the event of an emergency declaration at the VEGP, DOE-Savannah River Site has agreed to provide prompt notification of all persons on the SRS within VEGP's plume exposure pathway EPZ. The Alert and Notification System (ANS) description is provided in the FEMA approved Alert and Notification System Design Report located in the SNC document management system. 4.3 Protective Actions for Onsite Personnel (SEP J.4) Protective response for onsite personnel (including visitors and contractor personnel) includes alerting, assembly and accountability, site evacuation, monitoring, and decontamination. Protective actions may also be taken for onsite personnel for emergencies such as fires, security related events or natural disasters where personnel safety is threatened. 4.3.1 Alerting (SEP E.2.1, J.1) Section E of the Emergency Plan, Notification Methods and Procedures, describes the methods to be used to alert onsite personnel of emergency conditions. 4.3.2 Assembly (SEP J.4.1) Personnel assembly is mandatory at the Site Area Emergency or higher level classification. Upon activation of the plant emergency alarm, plant personnel assigned specific emergency responsibilities will proceed to their designated emergency response locations. Assembly of site personnel outside of the Protected Areas is accomplished by non-essential personnel reporting to designated assembly areas. Assembly may be initiated at any time site management deems it appropriate for personnel safety reasons. Nonessential plant personnel located within the Protected Area will exit the protected area upon hearing the Site Area or the General Emergency alarm and report to designated assembly areas. Visitors, contractors, and escorted personnel will leave the protected area during an Alert or higher declaration. 4.3.3 Security Events (SEP J.4) Onsite protection of employees during security events involves a combination of restricted movement, movement to safe locations, and site evacuation depending on the nature of the event and advance warning. Specific actions to be taken during such events are included in site procedures. 4.3.4 Monitoring and Decontamination (SEP K) When an Alert is declared but no site evacuation is anticipated, personnel who have left the protected area are monitored by portal monitors. If necessary, decontamination is completed using the plant E11-17 1 to NL-16-0169 Vogtle (Units 1&2) Standard Emergency Plan Annex decontamination facilities located in the Auxiliary building or other onsite locations. When site evacuation with monitoring is expected and release of radioactivity has occurred, monitoring is performed by Burke County emergency workers at an established reception center.

4.4 Protective Actions for the Offsite Public (SEP J.5)

The Emergency Director will recommend the necessary protective actions to offsite authorities based on predetermined protective actions for a General Emergency Classification or results of offsite dose assessment. Upon activation of the EOF, the EOF Manager will be responsible for recommending protective actions for the offsite population. Responsibility for carrying out the protective actions rests with offsite authorities. E11-18 1 to NL-16-0169 Vogtle (Units 1&2) Standard Emergency Plan Annex 4.4.1 Protective Action Recommendations (SEP J.5) A range of Protective Actions have been developed and agreed upon with state and local authorities. They may include the following:

Evacuation;
Shelter in Place;
Monitor and prepare;
Thyroid blocking agent (consider the use of Kl (Potassium iodide)) in accordance with state plans and policy.

E11-19 1 to NL-16-0169 Vogtle (Units 1&2) Standard Emergency Plan Annex Section 5: Emergency Facilities and Equipment (SEP H) 5.1 Emergency Response Facilities (SEP H.1, H.2) 5.1.1 Control Room (SEP H.1.1) The Control Room contains the necessary instrumentation, both process and radiological, to evaluate plant conditions, as detailed in the plant Final Safety Analysis Report. Habitability is maintained by shielding and the Emergency Filtration Train (EFT) ventilation system, which is capable of operating in a cleanup or recycle mode. Emergency equipment is supplied power from the emergency diesel generators with vital instrumentation powered from inverters connected to the storage batteries located in the battery rooms. 5.1.2 Technical Support*Center (SEP H.1.2) The TSC has been established consistent with NUREG 0696, as described below. The TSC is shared by both units and is located adjacent to the Unit 1 control room at el 220 ft. The layout of the TSC is shown in figure 5.1.A. It is an integral part of the Seismic Category I control building structure. The TSC provides plant management and technical support personnel with a facility from which they can assist plant operating personnel located in the control room during an emergency. The emergency director and NRC director will be co-located to ensure proper communications. The TSC is equipped with a computer system, which provides source term and meteorological data and technical data displays to allow TSC personnel to perform detailed analysis and diagnosis of abnormal plant conditions, including assessment of any significant release of radioactivity to the environment. In addition, the TSC has ready access to plant records, some of which are stored in the TSC and some in the control room. The TSC structure and ventilation system are designed to ensure that the TSC personnel are protected from radiological hazards. The TSC ventilation is a separate system and not a part of the control room ventilation system. The air supply is filtered by high efficiency particulate air (HEPA) and charcoal filters. During accident conditions, the filtration system provides filtered cooling air meeting the following exposure design criteria: 5 rem - Whole body; 30 rem - thyroid; and 75 rem - skin dose for a 30 day occupancy. The air filtration system will be placed in service when required by site procedures. The ventilation system can be manually controlled from the TSC. The air filtration system will also be placed in the filtration mode automatically whenever the control room HVAC is isolated. The continuous influx of outdoor air with no positive exhaust is designed to pressurize the area to 0.125 in. WG. When the TSC is activated, there will be a portable radiation monitor placed in the TSC to alert personnel of the presence of high radiation levels. In addition, portable radiation monitors are available for personnel in transit from the TSC to other areas. Portable air breathing apparatus and anticontamination clothing will also be available for the TSC. The TSC normal lighting is supplied from normal offsite power through a motor control center backed up by the security diesel generator. The TSC essential lighting is supplied from the essential lighting system. Self-contained, battery-E11-20 1 to NL-16-0169 Vogtle (Units 1&2) Standard Emergency Plan Annex operated emergency lighting is provided as a backup to the normal lighting for ingress and egress only and is located in the TSC hallway. Power for TSC vital equipment is provided from either the motor control center backed up by the security diesel generator or from a battery-backed uninterruptible power supply system. Power to the DC system is provided by battery chargers, one of which is powered from this same motor control center. The records storage is shared by the control room and the TSC. These records can be accessed on a digital records system. This system is supplied backup power from an uninterruptible power supply to allow retrieval of records in the event of a loss of power. These records include but are not limited to: Technical Specifications. Plant Operating Procedures. Final Safety Analysis Report. Emergency Plan. Emergency Plan Implementing Procedures. Plant operating records. System piping and instrumentation diagrams; heating, ventilation, and air-conditioning (HVAC) flow diagrams. Electrical one-line, elementary, and wiring diagrams. Control logic and loop diagrams. The above records are updated as necessary to ensure currency and completeness. 5.1.3 Operations Support Center (SEP H.1.3) The OSC has been established to be consistent with NU REG 0696 as described below. The OSC is located in the Maintenance Building. Figure 5.1.B illustrates a sample OSC layout and shows access stairwells. The OSC is where operational support personnel (such as instrument technicians, engineers, mechanics, electricians, chemical/radiation technicians, equipment operators, and incoming shift personnel) assemble to aid in the response to an emergency. Emergency kits containing radiation monitoring equipment, first aid supplies, decontamination supplies, breathing apparatus, portable lighting, and portable radios are stored in the OSC. In the event this facility becomes uninhabitable, the functions of the OSC will be conducted from the Outage Execution Center (OEC) located in the control building. Evacuation of the OSC will be conducted according to emergency plan implementing procedures .. Operations at this facility are directed by the OSC manager. E11-21 1 to NL-16-0169 Vogtle (Units 1&2) Standard Emergency Plan Annex 5.1.4 Alternative Facility (SEP H.1.4) During a security-related event or other event that precludes onsite access, the TSC and OSC ERO staff will be directed to an alternative facility. This facility is located in the near site media center in Waynesboro, Georgia. The alternative facility is equipped with the necessary communications and data links to support communications with the control room, site security, and the EOF. The available communications and data links also provide access to the SNC document management resources, work planning resources for performing engineering assessment activities including damage control team planning and preparation for return to the site. Guidance for use of the facility is contained in site procedures. 5.1.5 Emergency Operations Facility (SEP H.2.1) The EOF is the central location for management of the offsite emergency response, coordination of radiological assessment, and management of initial recovery operations. The EOF is a dedicated facility located in Birmingham, Alabama, and serves as the EOF for SNC sites (VEGP, FNP, and HNP). Additional details of the EOF are contained in section H.2.1 of the Emergency Plan. A near site location is maintained at the Vogtle Training Center for members of an NRC Site Team. 5.1.6 Joint Information Center (JIC) (SEP H.2.2) The VEGP JIC is located in Waynesboro, Georgia, adjacent to the Georgia Power Company operating headquarters. The JIC is the central location for the coordination and dissemination of information to news media, and responses to public and media inquiries. Details of the JIC for VEGP are in section H of the Emergency Plan. If the decision is made to activate the JIC the CMC in Atlanta, Georgia will maintain emergency communications response coordination until the JIC is ready to assume these responsibilities. E11-22 1 to NL-16-0169 Vogtle (Units 1&2) Standard Emergency Plan Annex TECHNICAL SUPPORT CENTER AIR* AIR LOCK I LOCK VESTIBULE COMPUTER O:?ERATION ROOM ROOM I

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LEVEL 1 COITTROL ELECTRIC BATTERY RESTROOMS WORK AREA BUlLDIPlG EQUIPMENT ROOM &SHOW:':RS ROOM AIR LOCK 84' c Figure 5.1.A - Sample Technical Support Center E11-23 1 to NL-16-0169 Vogtle (Units 1&2) Standard Emergency Plan Annex STA!RWB...l WOOEN'S RESTROOM f,WNTENANCE OFFICES KIT CHE OSC STAFF MAINTENANCE WAITING AREA ENGINEERING OFFICES OPERATIONS SUPPORT CENTER OSCSTAFF osc ~ l\'!ANAGER' OFFICE i~ CONFERENCE AREA r STMRWEll MAINTENANCE BUILDING I I SECOND FLOOR Figure 5.1.B - Sample Operations Support Center E11-24 1 to NL-16-0169 Vogtle (Units 1&2) Standard Emergency Plan Annex 5.2 On-Site Communications (SEP F.1) Normal on-site communications is provided by the plant telephone system (network and commercial). The plant public address (PA) system may also* be used for in-plant communications. The PA system is powered by normal plant power, backed up by uninterruptible power. Portable radios are used for communications between individuals and base stations located in the. Control Room, TSC, OSC EOF, and Security Building. There is also a plant intercom system. Intercom units are installed at selected plant locations primarily for specific task related activities. 5.3 Offsite Communications (SEP F.1) 5.3.1 Communications with States, Counties, and Savannah River (SEP F.1.2) The primary means of communication betwe~n VEGP, the states of Georgia and South Carolina, as well as Burke, Aiken, Allendale and Barnwell Counties and the Savannah River Site, is the Emergency Notification Network (ENN). The ENN is a dedicated communications system from the plant to the EOC at GEMA headquarters in Atlanta, Georgia, the South Carolina Warning Point in the SEOC, the Burke County EOG; and the Savannah River Operations Center. Extensions for this system are located in the Control Room, the TSC, and the EOF. 5.3.2 Alternate Offsite Communications (SEP F.1.1) Commercial telephones or land lines provide backup for the ENN. 5.4 Communications System Testing (SEP F.3) Communication channels with the state of Georgia, the state of South Carolina, the Savannah River Site, the plume exposure pathway EPZ counties, and the NRG (with the exception of EROS) are tested each calendar month, using the extensions in the Control Room, the TSC, and the EOF. EROS is tested each calendar quarter. Communications procedures and systems are also tested each calendar year. 5.5 Emergency Kits (SEP H.9) Emergency supplies and equipment are located in the TSC (also for the control room), the OSC, the radiation protection control point, and other plant locations. Procedures require an inspection and operational check of equipment in these kits on a quarterly basis and after each use. Equipment in these kits is calibrated in accordance with procedures. A set of spares of certain equipment is also maintained to replace inoperative or out-of-calibration equipment. 5.6 Facilities and Equipment for On-site Monitoring (SEP H.5) The plant instrumentation and monitors perform indicating, recording, and protective functions. The Reactor Protection System and associated plant instrumentation provide the ability to maintain plant safety from shutdown to *full power operations, and to monitor and maintain key variables such as reactor power, flow, temperature, and radioactivity levels within predetermined safe limits at both steady state conditions and during plant transients. Plant instrumentation and control systems also provide means to cope with abnormal operating conditions. The control and display of information of these various systems are centralized in the unit Control Room. This instrumentation provides the basis for initiation of protective actions. E11-25 1 to NL-16-0169 Vogtle (Units 1&2) Standard Emergency Plan Annex 5.6.1 Geophysical Phenomena Monitors (SEP H.5.1) Meteorological (SEP H.5.1) A meteorological monitoring program is in place at VEGP. Instruments are mounted on a 60-meter tower located to the south-southwest of the power block. Parameters measured and transmitted to the control room include:

Windspeed (10 m and 60 m).
Wind direction (10 m and 60 m).
Standard deviation of horizontal wind direction (10 m).
Vertical temperature difference (10 m and 60 m).
Ambient temperature (1 O m).
Dewpoint temperature (10 m).
Precipitation (base).

An equipment building housing the recording, calibration, and amplification equipment is located near the base of the tower. The system is powered by an uninterruptible power supply consisting of wet cell batteries, charger, and inverter for high availability. Additionally, meteorological information can be obtained from the National Weather Service to supplement ons.ite data and provide a backup to the plant meteorological monitoring program on an as-needed basis. The important parameters for characterizing the transport of airborne radioactivity are wind speed, wind direction, and atmospheric stability (derived from the standard deviation of the horizontal wind direction or vertical temperature difference). These meteorological parameters are used in a calculation methodology to assess the offsite radiological consequences of accidental releases of airborne radioactivity. Hydrologic (SEP H.5.1) The normal source of plant cooling water is the Savannah River, which provides makeup to the cooling towers. The probable maximum flood level has been determined to be about 140 ft mean sea level (MSL). However, since the access elevations to safety-related structures are at 220 ft MSL, high river level is not relevant to plant safety. The ultimate heat sink for VEGP is the nuclear service cooling water towers. Two 1OD-percent towers are provided for each unit, and the system will provide sufficient shutdown cooling for approximately 30 days with no makeup. Because of these design features, hydrologic monitors will not be required for initiation of emergency actions; therefore, there will be no emergency levels based on hydrologic monitors. Seismic (SEP H.5.1) Seismic monitoring instrumentation for VEGP consists of time-history accelerographs, central control unit, and free-field ETNA. A strong-motion accelerometer (SMA) is installed in the containment tendon gallery on the basemat. The second SMA is located on the containment operating floor at elevation 220 feet. E11-26 1 to NL-16-0169 Vogtle (Units 1&2) Standard Emergency Plan Annex Activation of the time history accelerographs causes visual and audible annunciation in the control room to alert the plant operator that an earthquake has occurred. 5.7 Protective Facilities and Equipment (SEP J) Assembly Points (SEP J.4.1) In the event of a plant evacuation, the On-Site Assembly Areas located within the Administration Building (or Off-Site Assembly Areas, as appropriate) will be used. The function of the assembly area is to provide a center for personnel accountability and radiological contamination screening along with any other immediately necessary actions. The assembly areas are located in various buildings throughout the site. Georgia Power Company facilities may be used as the off-site assembly area at the discretion of the Emergency Director. The assembly area location will be announced over the public address system when announcement of evacuation is made. Protective actions, including relocation of onsite personnel, in the event of an attack or threat of hostile action against the site have been developed for that specific situation. Specific protective actions in this case are identified in site procedures not readily available to the public. 5.8 Medical Support (SEP B.6, SEP L) 5.8.1 Hospital and Medical Support (SEP B.6.3, L.1) Agreements are in place with the University of Alabama at Birmingham (UAB) Hospital, Burke Medical Center, Doctors Hospital, and Burke County Emergency Management Agency to provide assistance for injured personnel, including cases involving radioactive contamination. This assistance will be requested whenever necessary in accordance with plant procedures. 5.8.2 Ambulance Service (SEP B.6.2, L.4) Injured/externally contaminated personnel who require medical attention will normally be transported by ambulance to the cooperating hospitals. Ambulance crews are trained to handle external contamination cases, and an RP technician may accompany, as requested, any contaminated patients to the hospital. Ambulance service is provided by the Burke County Emergency Management Agency.

E11-27

Enclosure 11 to NL-16-0169 Vogtle (Units 1&2) Standard Emergency Plan Annex *\ Appendix A - Evacuation Time Estimate Study and Map Reference (SEP J.6) In order to ensure the safety of the public living in the vicinity of nuclear power plants in the nation, the U.S. Nuclear Regulatory Commission (NRC) requires licensees to develop and update evacuation time estimates (ETEs) for areas within the emergency planning zone (EPZ). Population reviews will be conducted annually using the most recent US Census and local information. Updates are required following the availability of data from the decennial census (1 O years) or when the sensitivity factor for changes in population within the EPZ has been exceeded. This appendix implements the requirements of 10 CFR 50, Appendix E, Sections IV.3 and IV.4 and in accordance with NUREG/CR-7002, Criteria for l)evelopment of Evacuation Time Estimate Studies. Southern Nuclear Operating Company (SNC) contracted IEM to estimate evacuation times for the 2012 populations within the 10-mile plume exposure pathway emergency planning zone (EPZ) surrounding VEGP. The report provided a breakdown of population by geographic areas and protective actions zones (PAZ). Four categories of population are identified in the report:

Permanent residents
Transient population
Transit dependent permanent residents
Schools The permanent resident population is made up of individuals residing in the 10-mile EPZ. The total year 2012 permanent resident populations within the 10-mile EPZ for VEGP Units 1 and 2 are estimated to be 3,080. The transient population consists of workers employed within the area, recreational sportsmen and visitors. The total peak transient population within the 10-mile EPZ is estimated to be 2,915. Only one school, Lord's House of Praise Christian School, was identified in the VEGP Units 1 and 2 EPZ. The total peak population for the school in the EPZ is estimated to be 70. Transient dependent permanent residents in the EPZ are estimated to be 29. This study also considered shadow evacuees that reside within 10-15 miles from VEGP.

IEM utilized a computer traffic simulation model, PTV Vision VISUM, to perform the ETE analyses. For the analyses, the 10-mile plume exposure pathway EPZ was divided into 19 unique geographic areas based on two-mile, five-mile, and ten-mile* radius rings, the 16 22.5-degree PAZs, as well. as keyhole and staged evacuation logic. In order to represent the most realistic emergency scenarios, evacuations for the 19 geographic evacuation areas were modeled individually for the midweek daytime, midweek - weekend evening, and weekend daytime scenarios. Each of these scenarios was then considered under both normal and adverse weather conditions using the 2012 population estimations. A total of 114 evacuation scenarios were considered as part of this study to represent different wind, temporal, seasonal and weather conditions. Both 100% and 90% ETEs for each scenario were collected. The 100% ETEs for the evacuation areas ranged from 2 hours 10 minutes to 3 hours 25 minutes for the normal scenarios, and from 2 hours 15 minutes to 3 hours 25 minutes for those occurring in adverse weather. The 90% ETEs for the evacuation areas ranged from 1 hour 20 minutes to 2 hours 20 minutes for the normal scenarios, and from 1 hour 20' minutes to 2 hours 25 minutes for those occurring in adverse weather. The factors that contributed to the variations in ETEs between scenarios include differences in the number of evacuating vehicles, the capacity of the evacuation routes used, or the distance from the origin zones to the EPZ boundary. E11-28 1 to NL-16-0169 Vogtle (Units 1&2) Standard Emergency Plan Annex Based on the data gathered and the results of the evacuation simulations, the existing evacuation strategy was determined to be functional for the 2012 conditions, given the lack of severe congestion or very high ETEs. Recommendations were provided for enhancements to improve the evacuation time estimate. Assumptions utilized in the ETE will be reviewed when evaluating changes to roadways or evacuation networks to ensure the results of the ETE remain valid. Changes in population will be evaluated utilizing the sensitivity factor developed during the ETE analysis. The full Evacuation Time Estimate was submitted for NRC review in accordance with NRC regulations 10 CFR 50, Appendix E, Section IV.3. Following the NRC review, the results of the study and recommendations were reviewed with applicable offsite agencies. Modifications were incorporated as part of the ongoing emergency planning process. (

Reference:

Evacuation Time Estimates Update dated November 26, 2013 NL-13-2340; ETE Report ETE-VEGP-001; Annual ETE Review ETE-VEGP-002). E11-29 1 to NL-16-0169 Vogtle (Units 1&2) Standard Emergency Plan Annex Appendix B - Emergency Action Level (EAL) Scheme (SEP D.1) tiC>)~'."*o* FOR i:*~i;* $cffeme E11-30 1 to NL-16-0169 Vogtle (Units 1&2) Standard Emergency Plan Annex Appendix C - Vogtle Electric Generating Plant 1&2 NUREG-0654 Cross Reference Table NUREG 0654 Rev 1 VEGP1&2

SNC &EP Ref Section SEP Annex*

Criteria II.A - Assignment of Responsibility A.1.a A.1, A.2, A.3, A.4 1.3, 1.4, 1.5, 1.6 A.1.b Introduction Section 1: Introduction A.1.c Figures B.2.1.A, B.2.2.A, B.3.1.A & -- B.3.2.A A.1.d B.3.1.1 -- A.1.e B.1 Table2.2.A A.2.a NIA NIA A.2.b NIA 'NIA A.3 A.5 1.7 A.4 B.2, B.2.1.15, B.3.1.3 --

.*{

Criteria 11.8 -Onsite Emergencu Organization. B.1 B.2 -- B.2 B.1.1 Table 2.2.A B.3 B.1.2 -- B.4 B.1.1, Fiqure B.2.A -- B.5 Tables 1 - 4 Table 2.2.A B.6 B.2, B.3, Figures B.2.1.A, B.2.2.A, -- B.3.1.A & B.3.2.A B.7 Tables 1-4 -- Figures B.2.1.A, B.2.2.A, B.3.1.A & B.3.2.A B.7.a B.2.1.15, B.3.1.3 -- 8.7.b 8.3.1.2, 8.3.1.17 -- 8.7.c 8.3.1.1, B.3.1.2 -- 8.7.d B.3.2.1, 8.3.2.2, B.3.2.8 -- 8.8 8.4, C.4.2 2.3 B.9 B.6, K.1 2.3 Criteria 11.C - Emergency Response Suooort and Resources C.1.a Section C -- C.1.b A.1 1.6 C.1.c A.1.1, A.2, A.3, C.1-C.4, F.1 Section 1 C.2.a NIA NIA " C.2.b A.1.1, H.2.1 5.1.2 C.3 H.5.2.3, H.6.3 -- C.4 Sections A & C, B.4-8.6, H.6.3, L.1- 1.3-1.7, 2.3, 5.8 L.4 Criteria 11.D - Emeraencv Classification System D.1 Section D Appendix 8 D.2 Section D Appendix 8 D.3 *NIA NIA D.4 NIA NIA Criteria 11.E - Notification Methods and Procedures E.1 E.1.1 Aooendix D E.2 E.2.1 -- E.3 E.2.2.2 -- E.4 E.2.2.2 -- E.4.a E.2.2.2 -- E.4.b E.2.2.2 -- E.4.c E.2.2.2 -- NOTE: N/A =Not required by Licensee in accordance with NUREG-0654

Enclosure 11 to NL-16-0169 Vogtle (Units 1&2) Standard Emergency Plan Annex

 .      'NUREG o~.54 Rev 1        "

SNC.SEP .VEGP ~&2. . ;

l*;

Ref .Section, " *"'" ',

                                                                                                     ,,,'.        ','          SEP; .Annex
 'Criteria. II ;E :-.Notification Methods. and Proc'edures* (continued),                                          !             1'."

E.4.d E.2.2.2 -- E.4.e E.2.2.2 -- E.4.f E.2.2.2 -- E.4.Q E.2.2.2 -- E.4.h E.2.2.2 -- E.4.i E.2.2.2 -- E.4.i E.2.2.2 -- E.4.k E.2.2.2 -- E.4.1 E.2.2.2 -- E.4.m E.2.2.2 -- E.4.n E.2.2.2 -- E.5 >;' N/A. . ,*, "* ', N/A .

E.6 E.2.5 --

E.7 E.2.6 -- Criteria lf,F ~ Emeraehcv*commiinicaUoos* * ,*

                                                                                                            ,,               *\,    ,'"'*'                                 ,'

F.1.a F.1.1, F.1.2 4.1.1 F.1.b F.1.3 -- F.1.c F.1.4 -- F.1.d F.1.5 -- F.1.e F.1.6 -- F.1.f F.1.4 -- F.2 F.2 -- F.3 F.3 5.4 Criteria'ltG' ~.Public Educatiori'.and.lnform*ation ; * ' G.1 G.1 -- G.2 G.8 2.3.6 G.3.a G.3.b B.3.2.1, H.2.2, H.2.3

                                                              **NIA          .. ., -,,,, ~
                                                                                                        .1*   ",

5.1.6 NIA G.4.a B.3.2.8 -- G.4.b G.2 -- G.4.c B.3.2.5, B.3.2.6 -- G.5 G.2

Crit~l'iaJt.H :.::Emergency EqUioment and Faciliti~s .. .. . ,

H.1 H.1.2 5.1.2 H.2 H.2.1 5.1.5 H.3 H.2.2, H.2.3 -- H.4 H.1 -- H.5 H.5 5.6 H.5.a H.5.1 5.6.1 H.5.b H.5.2 -- H.5.c H.5.3 -- H.5.d H.5.4 -- H.6.a H.5.1 5.6.1 H.6.b H.5.2 -- H.6.c H.5.2.3, H.6.3 -- H.7 H.6 -- H.8 H.7 5.6.1 H.9 H.1.3 5.1.3 H.10 H.8 -- H.11 H.9 -- H.12 H.10 -- NOTE: N/A =Not required by Licensee in accordance with NUREG-0654 1 to NL-16-0169 Vogtle (Units 1&2) Standard Emergency Plan Annex NUREG 0654 Rev 1 VEGP 1&2 SNC SEP Ref Section. SEPA°nnex Criteria II.I - Accident Assessme~---------*--***----- ------ 1.1 1.1 -- 1.2 1.2 -- 1.3.a 1.3 -- 1.3.b 1.3 -- 1.4 1.4 -- 1.5 1.5 -- 1.6 1.6 -- 1.7 1.7 -- 1.8 1.8 -- 1.9 1.9 -- 1.10 1.7 -- 1.11 NIA NIA Criteria 11.J - Protective Response J.1.a J.1 -- J.1.b J.1 -- J.1.c J.1 -- J.1.d J.1 -- J.2 J.4.3 -- J.3 J.2 -- J.4 J.3, J.4.3 -- J.5 J.4.2, 4.3.2 -- J.6.a J.4 -- J.6.b J.4 -- J.6.c J.4 -- J.7 J.5 -- J.8 J.6 Appendix A J.9 NIA NIA J.10.a J.7 -- J.10.b J.7 -- J.10.c E.2.5 4.2 J.10.d NIA NIA J.10.e NIA NIA J.10.f NIA .. NIA J.10.g NIA NIA J.10.h NIA NIA J.10.i NIA NIA J.10.i NIA NIA J.10.k NIA NIA J.10.1 NIA ., . NIA J.10.m J.5 -- J.11 NIA NIA J.12 NIA NIA Criteria 11.K - Radiological Exposure Control K.1.a K.1.1 -- K.1.b K.1 -- K.1.c K.1 -- K.1.d K.1.2.1 -- K.1.e K.1.2.1, K.5 -- K.1.f K.1.1.1 -- K.1.q K.1.3 -- K.2 K.1 -- NOTE: N/A = Not required by Licensee in accordance with NUREG-0654

Enclosure 11 to NL-16-0169 Vogtle (Units 1&2) Standard Emergency Plan Annex NU REG 0654 Rev 1 :VEGP 1&2 *

                                                     $NC, SEP,
     ' * "R~f Settion"                                                                             .. SEP Annex

~-~~- *-* *--,...,...~-~--{~**- Criteria ll:K .'"'. R;:tdiological Exposure Control continued) * *

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

K.3.a K.3 -- K.3.b K.3 -- K.4 .. ... *.NIA NIA K.5.a K.5 -- K.5.b K.5 -- K.6.a K.6 -- K.6.b K.6 -- K.6.c K.6 -- K.7 K.7 -- .. Criteria 11.L' -Medical and Public Health Support ';* L.1 L.1 -- L.2 L.2 L.3 .* NIA ,*' NIA L.4 L.4 -- -Criteria*ll.M ~Recovery ant( Reeritry Planning and Post-Accident Operations.** M.1 M.1 -- M.2 M.2 -- M.3 M.3 -- M.4 "Criteria 11.N :._ Exercises* and"Orills

                                                   .       M.4
                                                              .: '          : .* . .<*<' ~L N.1.a                                   N.1                                                   --

N.1.b N.1 -- N.2.a F.3 -- N.2.b N.2.3 -- N.2.c N.2.4 -- N.2.d N.2.5 -- N.2.e(1) N.2.6 -- N.2.e(2) N.2.6 -- N.3.a N.3 -- N.3.b N.3 -- N.3.c N.3 -- N.3.d N.3 -- N.3.e N.3 -- N.3.f N.3 -- N.4 N.4 -- N.5 N.5 --

Criteria*ll.O*.- Rac(ioloaical Emeraencv Response :rrainina ... *' " .. '

0.1 0.1 -- 0.1.a 0.1.1 -- 0.1.b 0.1.1 -- 0.2 0.3 -- 0.3 0.4 -- 0.4.a 0.4 -- 0.4.b 0.4 -- 0.4.c 0.4.3 -- 0.4.d 0.4.1, 0.4.4 -- 0.4.e 0.4.5 -- 0.4.f 0.4.6 -- 0.4.g 0.1.1 -- 0.4.h 0.1.1 -- 0.4.i 0.4 -- NOTE: N/A =Not required by Licensee in accordance with NUREG-0654

Enclosure 11 to NL-16-0169 Vogtle (Units 1&2) Standard Emergency Plan Annex

     .NU REG 0654 Rev . 1                                                        VEGp1&2

Ref Section
SNC SEP SEP Annex Criteria 11.0 - Radiolqgical Emergency Response Training (continued) 0.4.j 0.4, 0.4.7 --

0.5 0.4 --

Criteria 11.P - Responsibility for the Planning Effprt: Development, P,eriodic Review: c;tnd Distribution of Emergency Plans * * ** * * . .'; .: *. ..

P.1 0.5, Section P -- P.2 Section P -- P.3 P.1 -- P.4 P.1 -- P.5 P.3 -- P.6 P.3 -- P.7 -- Appendix D P.8 Table of Contents -- P.9 P.3 -- P.10 F.1.4 -- NOTE: N/A = Not required by Licensee in accordance with NUREG-0654 1 to NL-16-0169 Vogtle (Units 1&2) Standard Emergency Plan Annex Appendix D - Supporting Plans & Implementing Procedures (SEP P.3) Supporting Plans

State of South Carolina Radiological Emergency Response Plan
State of Georgia Radiological Emergency Response Plan.
Burke County Georgia Emergency Response Plan
Aiken, Allendale, Barnwell County Emergency Response Plan
VEGP Security Plan Administrative and Emergency Plan Implementing Procedures (EPIP)

Plan Section

                        .. Title               EPIP                     EPIP Title      .*

Section A Assignment of Responsibility NMP-EP-300 SNC Emergency Preparedness (under Conduct of Operations development) 91801-C Coordination of Emergency Responses and Planning Between Southern Nuclear Operating Company-VEGP and US DOE-Savannah River Site B Emergency Response Organization NMP-EP-146 ERO Position Checklists 91101-C Emergency Response Organization c Emergency Response Support and NMP-EP-300 SNC Emergency Preparedness Resources (under Conduct of Operations development) 91703-C Emergency Support for Hatch Nuclear Plant D Emergency Classification System NMP-EP-141 Emergency Classification E Notification Methods and NMP-EP-142 Emergency Notification Procedures NMP-EP-308 SNC Emergency Alert Siren Operation, Testing And Maintenance Alert Notification System 91706-C F Emergency Communications NMP-EP-300 SNC Emergency Preparedness (under Conduct of Operations development) 91204-C Emergency Response Communications 1 to NL-16-0169 Vogtle (Units 1&2) Standard Emergency Plan Annex Plan , Se.ction Tit.I~ :EPIP. .£;.PIP Title Section G Public Education and Information NMP-EP-203 Corporate Media Center Operations NMP-EP-204 Emergency News Center/Joint Information Center Operations NMP-EP-205 Emergency Communications News NMP-EP-206 Releases NMP-EP-207 Emergency Communications News Briefings Emergency Communications Public

Response

H Emergency Facilities and Equipment NMP-EP-143 Facility Activation NMP-EP-305 Equipment Important to the EP Function 91702-C Emergency Equipment and Supplies 91705-C Inventory and Testing of Emergency Preparedness Material/Equipment Which Are Not Part of the Emergency Kits I Accident Assessment NMP-EP-140 Accident Assessment 91302-C In Plant Sampling and Surveys 91303-C Field Sampling and Surveys J Protective Response NMP-EP-144 Protective Actions 91704-C Actions for Security During a Radiological Emergency K Radiological Exposure Control NMP-EP-144 Protective Actions 91301-C Emergency Exposure Guidelines 91306-C Contamination Monitoring and Decontamination L Medical and Public Health Support NMP-EP-300 SNC Emergency Preparedness (under Conduct of Operations development) 91309-C Mass Casualty Triage M Recovery and Re-entry Planning NMP-EP-145 Termination and Recovery and Post Accident Operations 91308-C Re-Entry N Exercises and Drills NMP-EP-303 Drill and Exercise Standards 0 Radiological Emergency Response NMP-EP-301 EOF Emergency Response Training Organization And EP Staff Training 91601-C Emergency Preparedness Training 1 to NL-16-0169 Vogtle (Units 1&2) Standard Emergency Plan Annex Plan,: Section Title ' ; '.!;PIP , , .EPIP Title .. Section ~ p Responsibility for the Planning Effort NMP-EP-300 SNC Emergency Preparedness Conduct of Operations NMP-EP-310 Maintaining The Emergency Plan NMP-EP-312 Development Of Emergency Preparedness Technical Products 91701-C Preparation and Control of Emergency Preparedness Documents

Southern Nuclear Operating Company Joseph M. Farley Nuclear Plant Units 1 and 2; Edwin I. Hatch Nuclear Plant Units 1 and 2; Vogtle Electric Generating Plant Units 1 and 2; Vogtle Electric Generating Plant Units 3 and 4 Enclosure 12 Vogtle Units 1 and 2 Justification Matrix (Marked-Up Pages and Clean Copy) 2 to NL-16-0169 Vogtle (Units 1 & 2 ) Justifica tion Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section A.1 : The VEGP emergency EP B.1.1 : The Shift Manager (SM) is in direct The commitment wording was standardized and response is carried out under the charge of shift plant operations and is directly relocated to the SNC Standard Emergency Plan . control of the emergency director. responsible for the actions of the on-shift crew. In an emergency, the SM assumes the responsibility of the Emergency Director (ED) and takes necessary actions to identify and respond to the emergency until relieved by another qualified ED. A.2 .1 PRINCIPAL AGENCIES OF EP A.2.2.1 Georgia Emergency The commitment wording was standard ized and THE STATE OF GEORGIA Management Agency (GEMA) relocated to the SNC Standard Emergency Plan. The following State agencies are As the overall state coordinating agency assigned lead responsibility GEMA will coordinate with the Department of for radiation emergencies and for Natural Resources-Environmental Protection overall State preparedness, Division (DNR-EPD) on emergency response respectively: activities with state, county and municipal

1. GEORGIA EMERGENCY agencies and departments as stated in the MANAGEMENT AGENCY Georgia Emergency Operations Plan (GEOP).

a. GEMA is responsible for general GEMA provides for 24-hour notification and State emergency plann ing and staffing of the State Operations Center (SOC) exercises overall direction and and/or the Forward Emergency Operations control of emergency or disaster Center (FEOC), as required , throughout the operations as assigned by Executive event.

order. GEMA is responsible for general state

b. The director of emergency emergency planning and overall direction and management as the State disaster control of emergency or disaster operations as coordinator coordinates emergency assigned by executive order and in activities of DNR with overall State accordance with the Georgia Emergency response efforts. Operations Plan (GEOP) . GEMA has responsibilities for coordinating the state of Georgia response to emergencies at nuclear power plants .

E12-5 2 to NL-1 6-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63

2. DEPARTMENT OF NATURAL EP A.2.2.2 Department of Natural The wording was standard ized and relocated to the RESOURCES Resources Environmental Protection Division SNC Standard Emergency Plan and Site Annex .

a. DNR is assigned primary (DNR-EPD) responsibility by Executive Order for Department of Natural Resources-implementation and administration of Environmental Protection Division (DNR-EPD) the State radiological emergency is assigned as the coordinating and a primary response function . agency responsible by Executive Order for DNR will : implementation and administration of the state (1) Dispatch radiation emergency radiological and hazardous material function .

teams as needed. The DNR-EPD has primary responsibility for (2) Perform rad iation survey and implementation and adm inistration of the state monitoring . (3) Provide radiation safety training. radiological emergency response function . (4) Direct recovery/reentry operation and provide health physics control of Annex 1.3: Upon notification of an emergency contaminated areas. condition , the Georgia Emergency

b. A radiation emergency coordinator Management Agency will implement the "State (REC) in the Environmental Protection of Georgia Rad iological Emergency Plan ." The Division (EPD) interacts with Georgia Emergency Management Agency has appropriate State, local , and Federal the authority and responsibility for coordinating agencies and private organizations to the efforts of local and state agencies in direct all necessary radiation control Georgia to provide for the health and safety of actions. The REC is on call 24 h and the general public in the event of a radiological will be notified by the GEMA duty incident.

officer. An agreement is in place with the state of

c. In situations beyond local Georgia to provide available resources and government control , DNR provides equipment to support the mitigation and program assistance in the application response to an emergency at Plant Vogtle, of available personnel, equipment, and including Hostile Action Based events. These technical expertise as required .

resources include, but are not limited to , Local

d. DNR requests State support Law Enforcement Agency (LLEA) assets, fire agency(s) and Federal assistance pursuant to the GEOP as required . fighting assets, medical support resources

e. DNR will provide for health physics (including transportation) , and coordination escort of media and other personnel through an Incident Command Post. Requests within the plume exposure pathway for offsite resources and equipment will be emergency planning zone (EPZ) as communicated from the control room to the conditions allow if access controls Burke County 911 center, the county EOC, or have been established. through the Incident Command Post, as applicable, based on the nature and timing of the event.

E12-9 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section B.2: If the event is classified EP H.1 : SNC-operated nuclear power plants The commitment wording was standardized and as an Alert, the technical support have established a Technical Support Center relocated to the SNC Standard Emergency Plan . center (TSC), operations support (TSC) and an onsite Operations Support Center center (OSC), and Emergency (OSC), which are staffed and activated within Operations Facility (EOF) will be 75 minutes of the declaration of an Alert or activated . higher classification . EP H.2.1 : Staffing and activation of the EOF is mandatory upon declaration of an Alert or higher classification . Section B.2 : For a Site Area EP H.1: SNC-operated nuclear power plants The commitment wording was standardized and Emergency or General Emergency, have established a Technical Support Center relocated to the SNC Standard Emergency Plan . the emergency organization and (TSC) and an onsite Operations Support Center EOF will be fully activated. (Figure B- (OSC), which are staffed and activated within

3) 75 minutes of the declaration of an Alert or higher classification.

EP H.2.1 : Staffing and activation of the EOF is mandatory upon declaration of an Alert or higher classification. Appendix 7 G.1 .1: A training matrix EP 0.4: SNC ERO personnel who are The commitment wording was standardized and for corporate personnel assigned to responsible for implementing this plan receive relocated to the SNC Standard Emergency Plan . the ERO is shown in Table 2, and specialized training. training course summaries are EP 0.4.1: ERO members will receive presented in Table 3. Emergency Plan training on an annual basis. Section B.2.1: Following an Alert or EP Figures B.2.B, B.2.C, B.2.D and B.2.E The commitment wording was standardized and higher emergency declaration , the illustrate the standard Emergency Organization relocated to the SNC Standard Emergency Plan . positions shown on figures B-2 and at the three sites. B-3 will be filled by VEGP or SNC EP H.1: SNC-operated nuclear power plants personnel. have established a Technical Support Center (TSC) and an onsite Operations Support Center (OSC), which are staffed and activated within 75 minutes of the declaration of an Alert or higher classification . EP H.2.1: The EOF is procedurally required to be activated within 75 minutes following the declaration of an Alert or higher classification .SlaffiR9 aR9 aGtivalioR of ll:le EO~ is m~~9atory_ llf:lOR 9eGlaratioR of aR Alert or E12-33 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Table B-1: All EP B.1 : SNC plants maintain 24-hour The commitment word ing was standardized and Section L.1: Personnel to perform emergency response capability. The normal relocated to the SNC Standard Emergency Plan. first aid and decontamination will be on-shift complement provides the initial available 24-h a day as identified in response to an emergency. This group is Section B, Table B-1. trained to respond to emergency situations until the augmented Emergency Response Organization (ERO) arrives. Annex Table 2.2 .A Table B-2: All No Equivalent Plan Table The table was not carried forward to the SNC Standard Emergency Plan . Specific responsibilities are maintained as discussed throughout th is section of the Justification Matrix. Section B: Figure B-1 EP Figure P.1 The commitment wording was standardized and relocated to the SNC Standard Emergency Plan. C.1 STATE AND LOCAL EP A.2.2.1 Georgia Emergency The wording was standardized and relocated to the GOVERNMENTAL SUPPORT Management Agency (GEMA) SNC Standard Emergency Plan . The State of Georgia through the As the overall state coordinating agency Georgia Emergency Management GEMA will coordinate with Department of A more detailed description of state support is Agency (GEMA) has the lead agency Natural Resources-Environmental Protection provided in the references to the left. responsibility for responding to Division (DNR-EPD) on emergency response emergency situations throughout activities with state, county and municipal Georgia. Under the procedure agencies and departments as stated in the established by the Georgia Georgia Emergency Operations Plan (GEOP). Emergency Operations Plan (EOP), GEMA provides for 24-hour notification and which was developed pursua nt to the staffing of the State Operations Center (SOC) Governor's and/or the Forward Emergency Operations Executive Order, the Department of Center (FEOC), as required , throughout the Natural Resources (DNR) event. rad iolog ical emergency response GEMA is responsible for general state team in coordination with GEMA emergency planning and overall direction and assesses the radiological cond itions control of emergency or disaster operations as at the site of an incident and assigned by executive order and in determines whether a state of accordance with the Georg ia Emergency emergency should be declared. The Operations Plan (GEOP). GEMA has Governor of the State of Georgia or responsibilities for coordinating the state of GEMA can declare an emergency Georgia response to emergencies at nuclear based upon the assessment made power plants. by GEMA and/or DNR. E1 2-44 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 C2FEDERALGOVERNMENTAL SECTION A: ASSIGNMENT OF The commitment was standardized and relocated SUPPORT RESPONSIBILITY to the SNC Standard Emergency Plan and Site In addition to coordination with EP A.1 Primary Federal Organizations Annex . State/county governmental entities in EP A.1.1 Nuclear Regulatory Commission an emergency situation, VEGP may (NRC) require assistance from certain The NRG is the coordinating agency for Federal agencies in the areas of incidents at or caused by a facility or an activity communications, radiological that is licensed by the NRG or an Agreement monitoring and laboratory analysis, State, with the Chairman of the Commission as transportation , and disaster relief. the senior NRC authority for resgonse . The Requests for Federal assistance are Chairman can transfer control of emergency directed as needed by the resgonse activities when deemed aggrogriate. emergency director, and usually +l=le ~mG aGts as tl=le lea9 fetleFal ageAG'f foF these requests are channeled teGRAiGal matteFS 91:1FiAQ a Al:IGleaF iAGi9eAt, through GEMA. The exceptions to witl=I tl=le Gl=laiFmaA ef tl=le GemmissieA as tl=le this procedure are direct contacts seAi9F ~mG a1:1tR9Fity feF F9Sp9AS9. +l=le between the VEGP Emergency Gl=laiFmaA GaA tFaAsfeF G9Atrnl ef emeFQSAG'f Organization , the Nuclear Regulatory rnspeAse aGtivities wl=leA 9eeme9 apprnpFiate. Commission (NRC) , and Department Incident Response Centers have been of Energy, Savannah River (DOE- established at the four NRC regional offices SR). and NRC headquarters, to centralize and coordinate NRC's emergency response. Provision is made for NRC personnel at the plant's Technical Support Center and the Emergency Operations Facility. EP A.1.2 Department of Homeland Security (OHS) In accordance with the National Response Framework (NRF) , OHS is responsible for the overall coordination of a multi-agency federal response to a significant radiological incident. EP A.1.3 Federal Emergency Management Agency (FEMA) The primary role of FEMA is to support the states by coordinating the delivery of federal non-technical assistance. FEMA coordinates state requests for federal assistance, identifying which federal agency can best address specific needs. If deemed necessary, FEMA will establish a nearby Joint Field Office from which it will manage its assistance activities. E12-47 2 to NL- 16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section 0 .2.1.2: VEGP ACTIONS EP B.1 : SNC plants maintain 24-hour The commitment wording was standardized and (NUE) emergency response capability. The normal relocated to the SNC Standard Emergency Plan.

a. Inform State and local offsite on-shift complement provides the initial authorities of the nature of the response to an emergency. This group is The SNC Standard Emergency Plan was unusual event within 15 min. of trained to respond to emergency situations standardized to address overall response classifying the emergency. Notify until the augmented Emergency Response requirements rather than repeat listings by the Nuclear Regulatory Commission Organization (ERO) arrives. Classification Level. No change was made in the (NRC) as soon as possible (ASAP) EP E.1.1 : SNC-operated plants maintain the expectations/commitments for response.

but no later than 1 h following capability of notifying state and local agencies classification of the emergency. within 15 minutes of a declared emergency as

b. Augment on-shift resources , required by 10CFR50 Appendix E, section as needed. IV(D)(3). NRC will be notified , by the impacted

c. Assess and respond to the sitevia the HeaElt;j1,1arteFs Oi;ieFatieRs OffiseF, event. immediately following state and local

d. Escalate to a more severe notifications, but within an hour of an class, if appropriate, or close out with emergency classification using ENS.

a verbal summary to offsite EP E.2.2.1: State and local agencies listed in authorities followed by a written the site-specific Annexes shall be notified summary with in 24 h. within fifteen (15) minutes of:

The initial emergency classification .
Classification change .
The issuance of, or change to, a Protective Action Recommendation (PAR).

E12-52 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section D.2.2.2: VEGP ACTIONS EP B.1: SNC plants maintain 24-hour The commitment wording was standardized and (Alert) emergency response capability . The normal relocated to the SNC Standard Emergency Plan .

a. Within 15 min . of classification , on-shift complement provides the initial inform State and local offsite response to an emergency. This group is The SNC Standard Emergency Plan was authorities of Alert Emergency and trained to respond to emergency situations standardized to address overall response reasons for emergency. Notify the until the augmented Emergency Response requ irements rather than repeat listings by NRC ASAP but no later than 1 h Organization (ERO) arrives. Classification Level. No change was made in the following classification of the EP E.1 .1 : SNC-operated plants maintain the expectations/commitments for response.

emergency. capability of notifying state and local agencies

b. Augment resources and activate with in 15 minutes of a declared emergency as the emergency response facilities required by 10CFR50 Appendix E, section (e.g. Technical Support Center IV(D)(3) . NRC will be notified by the impacted (TSC), Operational Support Center site, via ll:ie Fleas~ ~arteFs 013eFatieRs OffiseF, (OSC) , and the emergency operating immediately following state and local facility (EOF) . These actions may be notifications, but within an hour of an delayed for security based events at emergency classification using ENS.

the discretion of the emerge ncy EP E.2.2.1: State and local agencies listed in director. the site-specific Annexes shall be notified

c. Assess and respond to the within fifteen (15) minutes of:

emergency.

The initial emergency classification .

d . Mobilize , and dispatch if

Classification change.

necessary, onsite survey teams .

The issuance of, or change to , a Protective

e. Provide periodic plant status Action Recommendation (PAR) .

updates to offsite authorities. EP E.2.3: The Emergency Response Data

f. Provide periodic meteorological System EROS will be initiated within one hour assessments to offsite authorities of the declaration of an Alert or higher and, if any emergency releases are classification .

occurring , field monitoring team readings or dose estimates for actual releases.

g. Activate the Emergency Response Data System for the affected unit within 1 h following declaration of the Alert .

h. Escalate to a more severe class , if appropriate , or close out emergency class by verbal summary to offsite authorities followed by written summarv within 8 h of closeout.

E12-53 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section D.2.2.3: VEGP ACTIONS EP B.1: SNC plants maintain 24-hour The commitment wording was standardized and (SAE) emergency response capability. The normal relocated to the SNC Standard Emergency Plan .

a. Within 15 min . of classification , on-shift complement provides the initial inform State and local offsite response to an emergency. This group is The SNC Standard Emergency Plan was authorities of Site Area Emergency trained to respond to emergency situations standardized to address overall response and reasons for emergency. Notify until the augmented Emergency Response requirements rather than repeat listings by the NRC ASAP but no later than 1 h Organization (ERO) arrives. Classification Level. No change was made in the following classification of the EP E.1.1 : SNC-operated plants maintain the expectations/commitments for response .

emergency. capability of notifying state and local agencies

b. If necessary, provide protective within 15 minutes of a declared emergency as action recommendations to State required by 10CFR50 Appendix E, section and local authorities. IV(D)(3). NRC will be notified by the impacted

c. Augment resources and activate site, via the Heae(111arters 0f')eratiens OlfiGer, the emergency response facilities immediately following state and local (e.g. Technical Support Center notifications, but within an hour of an (TSC) , Operational Support Center emergency classification using ENS.

(OSC) , and the Emergency EP E.2.2.1 : State and local agencies listed in Operating Facility (EOF. These the site-specific Annexes shall be notified actions may be delayed for security within fifteen (15) minutes of: based events at the discretion of the

The initial emergency classification .

emergency director.

Classification change .

d. Assess and respond to the

The issuance of, or change to, a Protective emergency. Action Recommendation (PAR).

e. Dispatch as necessary onsite and offsite survey teams.

f. Dedicate individuals for plant status updates to offsite authorities and periodic press briefings.

g. On a periodic basis, make senior technical and management staff available for consultation with the NRC and State officials.

E12-54

Enclosure 12 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section D.2.2.4: VEGP ACTIONS EP B.1 : SNC plants maintain 24-hour The commitment wording was standardized and (GE) emergency response capability. The normal relocated to the SNC Standard Emergency Plan.

a. Within 15 min . of classification , on-shift complement provides the initial inform State and local offsite response to an emergency. This group is The SNC Standard Emergency Plan was authorities of General Emergency trained to respond to emergency situations standardized to address overall response and reason for emergency. Notify until the augmented Emergency Response requirements rather than repeat listings by the NRC ASAP but no later than 1 h Organization (ERO) arrives . Classification Level. No change was made in the following classification of the EP E.1 .1: SNC-operated plants maintain the expectations/commitments for response .

emergency. capability of notifying state and local agencies

b. Provide protective action within 15 minutes of a declared emergency as recommendations to State and local required by 10CFR50 Appendix E, section authorities based upon plant IV(D)(3) . NRC will be notified by the impacted conditions and/or actual or projected site, via tt:ie l=leal'l~blarters Or:ieratieRs OlliGer, releases of radioactive material. immediately following state and local

c. Augment resources and activate notifications, but within an hour of an the emergency response facilities emergency classification using ENS.

(e.g. Technical Support Center EP E.2.2.1: State and local agencies listed in (TSC), Operational Support Center the site-specific Annexes shall be notified (OSC) , and the Emergency within fifteen (15) minutes of: Operating Facility (EOF)). These

The initial emergency classification.

actions may be delayed for security

Classification change .

based events at the discretion of the

The issuance of, or change to , a Protective emergency director. Action Recommendation (PAR).

d. Assess and respond to the EP E.2.3: The Emergency Response Data emergency. System EROS will be initiated within one hour

e. Dispatch onsite and offsite survey of the declaration of an Alert or higher teams . classification .

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

g. On a periodic basis, make senior technical and management staff available for consultation with the NRC and State officials.

El2-56

Enclosure 12 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section D.2.2.4: VEGP ACTIONS EP 8.1: SNC plants maintain 24-hour (GE) emergency response capability. The normal (Continued) on-shift complement provides the initial

h. Provide meteorological data and response to an emergency. This group is field monitoring team readings or trained to respond to emergency situations dose estimates to offsite authorities until the augmented Emergency Response for actual releases. Organization (ERO) arrives.

i. Provide release and dose EP E.1.1: SNC-operated plants maintain the projections based on plant condition capability of notifying state and local agencies and foreseeable contingencies . within 15 minutes of a declared emergency as

j. Activate the Emergency Response required by 10CFR50 Appendix E, section Data System for the affected unit IV(D)(3). NRC will be notified by the impacted within1 h following declaration of the site, 1.iia H:ie l=leaElE11:JaFteFs G~eFatieAs GHiGeF, General Emergency. immediately following state and local

k. Close out emergency class by notifications, but within an hour of an briefing of offsite authorities followed emergency classification using ENS.

by written summary within 8 h of EP E.2.2.1: State and local agencies listed in closeout or class reduction. the site-specific Annexes shall be notified within fifteen (15) minutes of:

The initial emergency classification .
Classification change.

The issuance of, or change to, a Protective Action Recommendation (PAR) .

EP E.2.3: The Emergency Response Data System EROS will be initiated within one hour of the declaration of an Alert or higher classification . Section D.3: The procedure by which Annex Appendix C Fleet functional EPIPs to be developed to support the plant operational staff classifies the SNC Standard Emergency Plan as part of the emergencies is EPIP 91001-C, approval process. Procedural direction for "Emergency Classification And Classification will be provided. The transition to Implementing Instructions." the revised EPIPs will be conducted in accordance with the approval of the Plan by the Commission and the provisions of 10 CFR 50.54(a). E12-57 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section D.3: The SNC policy is that EP D.2.5: The SNC policy is that once an The commitment wording was standardized and once an emergency classification is emergency classification is made, it cannot be relocated to the SNC Standard Emergency Plan. made, it cannot be downgraded to a downgraded to a lower classification . lower classification. Termination criteria contained in the Emergency Plan Implementing Procedures shall be completed for an event to be terminated. At termination , on an event specific basis, the site can either enter normal operating conditions or enter a recovery condition with a recovery organization established for turnover from the ERO. When the site determines that transition to termination or recovery is appropriate, the information will be transmitted to respective offsite aoencies. Section D.3: Termination criteria EP D.2.5: The SNC policy is that once an The commitment wording has been standardized contained in the Emergency Plan emergency classification is made, it cannot be and relocated to the SNC Standard Emergency Implementing Procedures shall be downgraded to a lower classification. Plan . completed for an event to be Termination criteria contained in the terminated. Emergency Plan Implementing Procedures shall be completed for an event to be term inated. At termination, on an event specific basis, the site can either enter normal operating conditions or enter a recovery condition with a recovery organization established for turnover from the ERO . When the site determines that transition to term ination or recovery is appropriate, the information will be transmitted to respective offsite agencies. E12-58 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 E. NOTIFICATION METHODS AND EP E.1 Notification Methodology The commitment wording has been standardized PROCEDURES EP E.1 .1 SNC, in cooperation with state and and relocated to the SNC Standard Emergency This section describes the plan for county authorities, has established methods Plan. notification of onsite and offsite and procedures for notification of offsite Vogtle Electric Generating Plant response organizations consistent with the (VEGP) response personnel and emergency classification and emergency State, local, and Nuclear Regulatory action level scheme. These notifications Commission (NRC) emergency include a means of verification or response centers . authentication. The methods used for authentication are developed and mutually agreed to by the utility and off-site authorities. The primary notification method will be by a dedicated communications svstem . E. NOTIFICATION METHODS AND EP E.1 .1: SNC-operated plants maintain the The commitment wording has been standardized PROCEDURES (cont) capability of notifying state and local agencies and relocated to the SNC Standard Emergency within 15 minutes of a declared emergency as Plan . required by 1 OCFR50 Appendix E, section IV(D)(3). The methods and forms used for notifying state and county authorities are site-specific, and detailed in plant specific Emergency Plan Implementing Procedures (EPIPsl . E. NOTIFICATION METHODS AND The commitment wording has been standardized EP E.1.1: NRC will be notified by the impacted PROCEDURES (cont) and relocated to the SNC Standard Emergency site immediately following state and local Plan . notifications, but within an hour of an emergency classification using ENS. N~G will Ile Relifiea ey ll:ie l=leaaEj~afteFs Gf'leFalieRs GffiGeF, immeaiately fellewiR9 stale aRa leGal RelifiGat~eRs : e~l will:iiR aR t:ie~F ef aR E12-59 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 E . NOTIFICATION METHODS AND EP E.1.1 : When multiple units of a multi-unit The commitment wording has been standardized PROCEDURES (cont) site are affected by an emergency, the and relocated to the SNC Standard Emergency classification shall be reported as applicable to Plan. all affected units. In situations where multiple units of a multi-unit site are affected by emergency events , but the events are not related and the classification for each unit is different, initial notification will be made for the highest classification . Additional classification information is provided in accordance with Section E.2.2.3 E. NOTIFICATION METHODS AND EP E.1.1: An accelerated call to the NRC The commitment wording has been standardized PROCEDURES (cont) Headquarters Operations Officer will be made and relocated to the SNC Standard Emergency following discovery of an imminent threat or Plan. attack against a plant. During a plant transient or an imminent threat situation requ iring physical security response , plant personnel are primarily responsible for stabilizing the plant and keeping it safe. An accelerated notification will not interfere with plant or personnel safety or physical security response. The accelerated notification will be completed after or concurrent w ith notification of local law enforcement agencies . The goal will be to initiate the notification within 15 minutes of discovery of an imminent threat or attack against a plant. The information provided in the accelerated notification will be limited to the following: Site name . Emergency classification if detenmined

                                           . prior to the accelerated notification.

Nature of the threat and the attack status . E12-60 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 E. NOTIFICATION METHODS AND EP E.2.2 Notification of State and Local The commitment wording has been standard ized PROCEDURES (cont) Authorities and relocated to the SNC Standard Emergency A dedicated ENN will normally be used to Plan. accomplish state and local notifications. Backup means of communication are described in Section F, Emergency Communication. of this olan . E. NOTIFICATION METHODS AND EP E.2.2.1: State and local agencies listed in The commitment wording has been standardized PROCEDURES (cont) the site-specific Annexes shall be notified and relocated to the SNC Standard Emergency within fifteen (15) minutes of: Plan.

The initial emergency classification .
Classification change.
The issuance of, or change to , a Protective Action Recommendation (PAR).

E. NOTIFICATION METHODS AND EP E.2.2.2 Initial Notification Message Form The commitment wording has been standardized PROCEDURES (cont) In conjunction with state and county and relocated to the SNC Standard Emergency authorities, SNC-operated plants have Plan. established the contents of the initial af\G s1o1eseei1o1eAt state notification message forms to be used during an emergency. These forms are described in EPIPs. The content of the forms has been reviewed and agreed on by the resoective Offsite Resoonse On:ianizations. E12-62 2 to NL-16-0169 Vogtle (Units 1 & 2 ) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 E. NOTIFICATION METHODS AND EP E.2.2.3 Follow-up Emergency Message The commitment wording has been standard ized PROCEDURES (cont) In conjunction with state and county and relocated to the SNC Standard Emergency authorities , SNC-operated plants have Plan . established the contents of the subsequent state notification message forms to be used during an emergency . The Emergency Director is responsible for the completion of a follow-up emergency message. The appropriate ERO personnel will ensure the emergency communicator(s) periodically provide follow-up messages to the appropriate offsite federal , state , and local authorities.

                                     +l:ie emeFQeRGY QiFeGleF is respeRsil:Jle feF ll:ie GempletieR ef a fellew 1,1p emeFjeRGY message.
                                     +l:ie apflF9pFiate eRG peFseRRel will eRs1,1Fe tl:ie emeFQeRGY Gemm1,1RiGaleF(s) peFieEliGally prn'1ile fellew 1,1p messages le tl:ie appFepFiate effsite feseral , stale , aREl leGal a1,1tl:ieFilies.

E. NOTIFICATION METHODS AND EP E.2.3 Notification of the Nuclear The commitment wording has been standardized PROCEDURES (cont) Regulatory Commission (NRC) and relocated to the SNC Standard Emergency The NRC is notified via the ENS. If the ENS is Plan . inoperative, the required notification will be made using alternate means in accordance with regulatory requirements. The Emergency Response Data System EROS w ill be initiated within one hour of the declaration of an Alert or higher classification . Specific information on the notifications to the NRC for emergency events is detailed in the reoortinQ requirements of 10CFR 50.72 . E. NOTIFICATION METHODS AND EP E.2.4 Notification of Other Federal The commitment word ing has been standardized PROCEDURES (cont) Agencies and relocated to the SNC Standard Emergency Notification of other federal agenc ies w ill be Plan . made in accordance with site-specific procedures . E12-63 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SN C Emergency Plan Justification Revision 63 Evacuation of the OSC w ill be Annex 5.1.3: Evacuation of the OSC will be New EPIPs will be developed to support the SNC conducted according to Procedure conducted according to emergency plan Standard Emergency Plan and Site Annex . These 91202-C , Activation and Operation of implementing procedures. procedures will be developed consistent with the the OSC . approval of the new Plan by the NRC and in accordance with the requirements of 10 CFR 50.43(al .

3. EMERGENCY OPERATIONS EP H.2 Offsite Emergency Facilities The wording was standardized and relocated to the FACILITY EP H.2.1 Emergency Operations Facility SNC Standard Emergency Plan .

The Emergency Operations Facility The EOF is the central location for management is described in Append ix 7. of the offsite emergency response, coordination See Justification Matrix for Appendix 7 below for of radiological assessment, and management of specific documentation . initial recovery operations. The EOF is a dedicated facility located in Birmingham , Alabama , and serves as the EOF for SNC sites (VEGP, FNP, and HNP). The EOF is procedurally required to be activated within 75 minutes following the declaration of an Alert or higher classificationStalfiRQ aRi::I aGtii.<ati{JR ef tt:le EO~ is fl'laRi::latery lJIJ9R i::teclaratieR of aR Alert E12-104 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section H.4.2 : The post-accident EP H.5.2.2: The process sampling system The commitment wording was standardized and radiation monitors provide radiation consists of the normal sampling system and relocated to the SNC Standard Emergency Plan. monitoring after an accident. additional sampling panels located throughout the plant. Pre-designated monitoring and sampling points are listed in site procedures. Sampling systems are installed or can be modified to permit reactor coolant and containment atmosphere sampling even under severe accident conditions . The system can provide information on post-accident plant conditions to allow operator actions to mitigate and control the course of an accident. Various chemical analyses and radiological measurements on these samples can be performed, including the determination of radionuclide concentrations. Section H.4.2: The monitors are EP H.5.2.1 : Radiation monitoring instruments The commitment wording was standardized and comprised of area, airborne, and air are located at selected areas within the plant relocated to the SNC Standard Emergency Plan. particulate monitors. to detect, measure, and record radiation levels. The monitors are comprised of area, airborne, and air particulate monitors. Section H.4.2 : Area monitors EP H.5.2.1: Radiation monitoring instruments The commitment wording was standardized and respond to gamma radiation photons are located at selected areas within the plant relocated to the SNC Standard Emergency Plan . within any energy range from 60 keV to detect, measure, and record radiation levels. to 3 MeV. The monitors are comprised of area, airborne and air particulate monitors.

Area monitors respond to gamma radiation.
Airborne monitors detect and measure radioactive gaseous effluent concentrations .
Air Particulate detectors capture and measure airborne particulate .

E12-112 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section H.4.3: The EOF is located in EP H.2.1 : The EOF is the central location for The commitment wording was standardized and Birmingham , Alabama . It contains management of the offsite emergency relocated to the SNC Standard Emergency Plan. workstations and computer network response, coordination of radiological equ ipment required for assessment, and management of initial communicating with the main IPC recovery operations. The EOF is a dedicated processors via the IPC gateway. facility located in Birmingham , Alabama . and serves as the EOF for SNC sites (VEGP, FNP, and HNP). The EOF is procedurally required to be activated within 75 minutes following the declaration of an Alert or higher classificationataffiRQ aRG aGtivatieR ef ttie i;;gi;: is rnaRGatery llJl9R eeGlaratieR ef aR Alert er tiigtier GlassifiGatieA. The EOF provides for:

Management of overall emergency response.
Coordination of radiological and environmental assessments.
Protective Action Recommendations .
Notification of Offsite Agencies .
Management of recovery operations .
Notification and update of the NRC via Emergency Notification System (ENS).
Notification and update of the NRG via Health Physics Network (HPN) .
Coordination of emergency response activities with federal, state, and local aaencies.

Section H.4.5 The SPDS is in EP H.5. 3.2: The SPDS parameters are The commitment wording was standardized and operation during normal and available during normal and abnormal relocated to the SNC Standard Emergency Plan. abnormal operating conditions. operating conditions in the Control Room , TSC, and EOF. E12-115

Enclosure 12 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section H.6: Emergency kits are EP H.9: Emergency kits are available at SNC- The commitment word ing was standardized and located in the TSC (for control room operated nuclear power plants. Designated site relocated to the SNC Standard Emergency Plan also), the OSC, the health physics or department procedures identify the and Site Annex. control point, the EOF and other equipment in the various emergency kits . plant locations. Details as to kit locations are found in the plant-Section H.6: An ambulance kit will be specific procedures. carried by the VEGP health physics Annex 5. 5: Emergency supplies and technician who accompanies the equ ipment are located in the TSC (also for the am bulance. control room) , the OSC, the radiation protection control point, and other plant locations. Procedures require an inspection and operational check of equipment in these kits on a quarterly basis and after each use. Equipment in these kits is calibrated in accordance with procedures. A set of spares of certain equ ipment is also maintained to replace inoperative or out-of-calibration eaui oment. Section H.6: Procedures requ ire an EP H.8: Emergency facilities and equipment are The commitment wording was standardized and inspection and operational check of inspected and inventoried using appropriate relocated to the SNC Standard Emergency Plan. equipment in these kits on a administrative or department procedures. quarterly basis and after each use . These inventories will include requirements that Section H.6: Equipment in these kits provisions are in place to inspect, inventory, and is cali brated in accordance with the operationally check emergency suppliers' recommendations. equipmenVinstruments at least once each calendar quarter and as needed. These procedures provide information on location and availability of emergency equipment and suppliesi.ffleFQeRGY faGililies aRd eqllif:Jffl9RI aFe iRSf:leGled aAd iA ...eAIEIFied llSiAij a1313rn13fiale adffliAiSIFalive Elf de13ai:lff19Ri f:JfeGEISllf96 .

                                     +Rese f:JfEIGEISllfEIS f:JfEl¥i9e iRfum:ialieA EIA leGatieA aRd availaeilily ef eff!eF!JeAGY Section H.6: A set of spares of       EP H.8: Sufficient reserves of instruments and         The commitment wording was standardized and certain equipment is also maintained  equipment are maintained lo replace those              relocated to the SNC Standard Emergency Plan .

to replace inoperative or out-of- removed from emergency kits or lockers for calibration eauioment. calibration or repair. E12-118 2 to NL- 16-0169 Vogtle (Units 1 & 2 ) J ustification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section 1.2: The containment high- EP H.5.2.1: Radiation monitoring instruments The commitment wording was standard ized and range radiation monitor and are located at selected areas within the plant to relocated to the SNC Standard Emergency Plan . conta inment hydrogen monitor are detect, measure, and record radiation levels. used to provide an early indication of The monitors are comprised of area, airborne, the quantity of radioactivity ava ilable and air particulate monitors. for release from the containment.

Area monitors respond to gamma radiation .
Airborne monitors are capable of detecting and measuring radioactive gaseous effluent concentrations.
Air Particulate detectors capture and measure airborne particulate.

Section 1.2: Emergency procedures EP H.5.2.1 : Emergency response procedures The commitment wording was standard ized and (Procedure 91502-C) include a provide methods for determining relationships relocated to the SNC Standard Emergency Plan. correlation between the monitor between monitor read ings and releases, reading and the extent of core material available for release and extent of damage. core damage. Section 1.2: A more detailed assessment of core damage is then performed using Procedures 91502-C and 91503-C , which are also based on the WOG methodoloav. Section 1.2: Samples can be EP H.5.2.2: Sampling systems are installed or The commitment wording was standardized and obtained for reactor coolant , can be modified to permit reactor coolant and relocated to the SNC Standa rd Emergency Plan. conta inment sump , and containment containment atmosphere sampling even under atmosphere and are used for all severe accident conditions . The system can radiochemical analyses. provide information on post-accident plant conditions to allow operator actions to be taken to mitigate and control the course of an accident. Section 1.2: Grab samples can be EP H.5.2.2: Sampling systems are installed or The commitment word ing was standardized and transported in a sh ielded cask. can be modified to permit reactor coolant and relocated to the SN C Standard Emergency Plan. containment atmosphere sampling even under severe accident conditions. The system can provide information on post-accident plant conditions to allow operator actions to be taken to mitigate and control the course of an accident. E12-121 2 to NL- 16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section H.5.2: The kits will include EP 1.9: Field monitoring equipment has the The commitment wording was standardized and dosimeters, a two-way radio , meters capability to detect and measure airborne relocated to the SNC Standard Emergency Plan. for measuring gamma and radioiodine in the presence of noble gases that beta/gamma dose rates, and air has the capability to detect and measure samplers for collecting particulates radioiodine concentrations in air in the plume and iodines. exposure EPZ as low as 10-7 uCi/cc Section 1.5: The emergency (microcuries per cubic centimeter) under field monitoring kits contain a portable air conditions . Interference from the presence of sampler, silver zeolite cartridges, noble gas and background radiation shall not and counters to provide the decrease the stated minimum detectable capability to detect and measure activity. radioiodine concentrations in the air j;:iel9 IJlGRitGRR!l 8EJ1jiJlR'l8RI Ras IRS GaJlability as low as 10-7 µCi/cc. te 9etesl aR9 1J1easljf8 aiFbeR'le Fa9ieie9iRe iR tile JlFeseRGe et Reble !jases. Section 1.5: Prior to leaving for the The SNC Standard Emergency Plan retains the field , the dose assessment commitment to dispatch Field Teams and use the supervisor, or designee, will normally environmental information for radiological direct and brief the teams on the assessment as previously described . The initial survey and sample locations, infonnation here is appropriate to procedural suggested travel routes , control of the teams. meteorological conditions, and team identification name or number for communication purposes. Section 1.5: The teams will obtain The SNC Standard Emergency Plan retains the their briefing from the health physics commitment to dispatch Field Teams and use the supervisor in the TSC or in the OSC environmental information for radiolog ical by the OSC manager. assessment as previously described. The infonnation here is appropriate to procedural control of the teams . Section 1.5: In-transit dose ra te The SNC Standard Emergency Plan retains the measurements will be made. commitment to dispatch Field Teams and use the environmental information for radiological assessment as previously described. The infonnation here is appropriate to procedural control of the teams . E12-129 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section J.2.2: Using available EP J.5: Plant conditions, projected dose and The commitment wording was standardized and information on plant conditions , dose rates , field monitoring data , and relocated to the SNC Standard Emergency Plan . projected dose estimates, and any evacuation lime estimates are evaluated to available monitoring data, the develop PARs for preventing or minimizing emergency director recommends exposure to the public. PARs are provided to whether the publ ic should be advised the offsite agencies responsible for to seek shelter or evacuate. implementing protective actions for the public within the 10-mile EPZ. The Emergency Director will approve PARs. The PAR decision making flowcharts are site-specific in nature, and are provided in the site-specific implementing procedures. SNC-operated plants have the capability to provide state and local agencies a PAR for beyond the 10-mile EPZ. Plant conditions , projected dose and dose rates and field monitoring data are communicated to offsite agencies responsible for dose assessment/PARs to assist them in developing parallel assessments There are various types of protective actions that can be recommended to the state and counties . They may include the following : Evacuation .

                                       .. Shelter in place .

Monitor and prepare . Thyroid blocking agent (consider the use of Kl (potassium iodide)) in accordance with state Plans and Policy. E12-146 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section L.2: Injured and Annex 5.8.1 : Agreements are in place with the The commitment wording was standardized and contaminated personnel requiring University of Alabama at Birmingham (UAB) relocated to the SNC Standard Emergency Plan. hospital medical attention will be Hospital , Burke Medical Center, Doctors transported to Doctors Hospital, Hospital , and Burke County Emergency Augusta, or Burke County Hospital, Management Agency to provide assistance for Waynesboro , by the Burke County injured personnel , including cases involving Ambulance Service. radioactive contamination. This assistance will Section L.3: Arrangements for be requested whenever necessary in treating externally contaminated accordance with plant procedures . ~ patients have been made with the 5.8.1: A9reeffieRls are iR i:ilase witt:i !Jt,Jrke Doctors Hospital in Augusta , Me6isal CeRler, Dostors Hesi:iital , aml Qt,Jrke Georgia, and Burke County Hospital COt,JRly Effier9eRGY MaRa9emeRt A@eRGy to in Waynesboro , Georgia, (appendix i:irovi6e assislaRGe fer iRjt,Jreg i:iersoRRel, 2). iRGlt,JSiR@ Gases iRV91ViR@ raeioastive GeRlaR'liRatioR . TRis assistaRse will be re~t,Jestee wt:ieRev~!_Resessary iR assoreaRse Section L.3: The medical staff of the EP L.1 : The hospitals are equipped and The commitment wording was standardized and hospital is trained to treat externally hospital personnel trained to address relocated to the SNC Standard Emergency Plan. contaminated patients or individuals contaminated injured individuals. Training of who have received high exposures. medical support personnel at the agreement hospitals includes basic training on the nature of radiological emergencies , diagnosis and treatment, and follow-up medical care . Section L.2 : The HPT will perform Annex 5.8.2 : Injured/externally contaminated The commitment wording was standardized and radiation surveys of the patient, personnel who require medical attention will relocated to the Site Annex . ambulance, and attending hospital normally be transported by ambulance to the staff and assist in maintaining cooperating hospitals. Ambulance crews are contamination control in the hospital. trained to handle external contamination Section L.3: Trained plant radiation cases , and an RP technician accompanies any protection personnel will assist contaminated patients to the hospital. hospital staff when plant personnel Ambulance service is provided by the Burke are beina evaluated . Countv Emeraencv Manaaement Aaency. E12-158 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section L.4: The VEGP training EP 0 .1.1 : Annually , training will be offered for The commitment wording was standardized and department conducts training hospital personnel, ambulance and rescue relocated to the SNC Standard Emergency Plan. sessions at least once per calendar personnel, police, and fire departments. The year (for onsite and offsite personnel training shall include the procedures for who have medical support notification , basic radiation protection , and resoonsibilitiesl . their oraanizations' exoected role . Section L.4: In addition, drills and EP N.2.34: A medical emergency drill, The commitment wording was standardized and exercises are an integral part of the involving a simulated contaminated individual, relocated to the SNC Standard Emergency Plan. training program and are conducted and containing provisions for participation by as specified in section N, Exercises local support services organizations including and Drills. ambulance response , are conducted annually at the nuclear plants. Local support service organizations that support more than one plant shall only be required to participate once each calendar year. Section M.1 : The emergency director EP M.1: Upon termination of the emergency The commitment wording was standardized and will determine when the recovery phase and at the discretion of the Emergency relocated to the SNC Standard Emergency Plan. phase begins . Director, following consultation with offsite authorities, the SNC Emergency Organization will shift to the Recovery Phase Organization . E12-160 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan J ustification Revision 63 Section N.1: The exercise program EP N.1.2: Full participation exercises will The commitment wording was standa rdized and for VEGP consists of an 8 year cycle include, as appropriate, offsite local and state relocated to the SNC Standard Emergency Plan. and incorporates the following authorities and SNC personnel actively The wording has been updated to reflect the features: participating in testing the integrated capability Enhanced Emergency Preparedness Rulemaking

1. A full participation exercise which to assess and respond to an accident at a (November 23 , 2011) tests as much of the Plant Vogtle , nuclear power plant. Additionally, full State, and local emergency plans as participation exercises will include, as is reasonable achievable without appropriate, testing the major observable mandatory public participation will be portions of the onsite and offsite emergency conducted on a biennial basis and plan s and mobilization of state, local , and SNC evaluated by NRC and FEMA. personnel and other resources in sufficient

2. Biennial exercise scenarios will be numbers to verify the capability to respond to submitted to the NRC under§ 50.4 the accident scenario.

at least 60 days before use in the EP N.2. 1: During these drills, activation of the biennial exercise. licensee's emergency response facilities TSC

3. Each biennial exercise scenario OSC, and the EOF would not be necessary, will provide the opportunity for the the ERO would have the opportunity to ERO to perform their key skills as consider accident management strategies, applicable to their emergency supervised instruction would be permitted ,

response duties in the CR, TSC, operating staff in participating facilities would OSC, EOF, and joint information have the opportun ity to resolve problems center to implement the EP principal (success paths) rather than have controllers functional areas. intervene, and the drills may focus on the onsite exercise training objectives. EP N.1.45: The Exercise planning cycle will consist of eight (8) successive calendar years . EP N.3: SNC sites subm it Biennial Exercise scenarios under 10 CFR 50 .4 for NRC review 60 days prior to the exercise. E12-178 2 to NL- 16-0169 Vogtle (Units 1 & 2 ) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section N.1 (Continued) EP N.3 : During the exercise planning cycle

4. Biennial evaluated exercises will described in Section N.1.54, SNC sites vary be varied such that the following the content of exercise scenarios to provide scenario elements are demonstrated ERO members the opportunity to demonstrate over the course of an 8 year exercise proficiency in key skills necessary to respond cycle:

Hostile action directed at the plant site.

to several specific scenario elements including : Hostile Action directed at the plant site .

No radiologica l release or unplanned
No rad iological release or an release that does not require public unplanned minimal radiolog ical release that does not require public protective actions.

                                       . protective actions.

An initial classification of or rapid escalation to a Site Area Emergency or

Initial classification of or rapid escalation to a Site Area Emergency or General Emergency.

                                       . General Emergency.

Implementation of strateg ies, procedures, and guidance developed in 50.54(hh), (i.e.,

Implementation of strategies , potential aircraft threat, explosion or large procedures, and guidance developed under 10 CFR 50.54(hh)(2).
Integration of offsite resources with

                                       . fire).

Integration of offsite resources with onsite response onsite response .

A drill initiated between the hours of 6 p.m .

                                       . and 4 a.m.

Drills using essentially 100 percent of Initiating Conditions in the 8-year cycle. EP N . 1 .4~ : Hostile Action Based (HAB) OOllsexercises involving an air, land, or water based attack scenario will be conducted at sites on a frequency of at least once every 8 years. EP N.2.6+: Accountability drills are conducted annually. EP N.2.89: At least one per drill cycle , a scenario resulting in an initial classification of, or rapid escalation to a Site Area or General Emergency, will be conducted . EP N.2.9.W: At least once per drill cycle , a scenario resulting in no rad iological release , or an unplanned minimal release resulting in a classification of a Site Area Emergency but not requiring declaration of a General Emergency, shall be conducted . E1 2-179 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section N.1 (Continued) EP N.1.3: States within an ingestion exposure The commitment wording was standardized and

5. An ingestion pathway exercise will pathway EPZ, are expected to exercise its relocated to the SNC Standard Emergency Plan be conducted on a frequency to plans and preparedness related to ingestion ensure the applicable States have exposure pathway measures at least once the opportunity to participate in an every 8 years. Gppefti,rnilies aFe pFeviaea le ingestion pathway exercise at least aRy stale eF leGal 9eveFRmeRI lesatea wilR iR once every exercise cycle. !Re plllme expeSlJFe palRway el2l le paflisipate iR aRRllal aFills aRa llieRRial exeFsises WReR Fe(jllestea lly IRal slate eF lesal E12-180 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section N.2 .1: The ERO (not EP N.3: During the exercise planning cycle The commitment wording was standardized and necessarily each ERO team) will be described in Section N..i.45, SNC sites vary relocated to the SNC Standard Emergency Plan.

provided the opportunity to the content of exercise scenarios to provide demonstrate key skills in response to ERO members the opportunity to demonstrate Section EP N .2.1 is directed to types of the following scenario elements in proficiency in key skills necessary to respond drills/exercises. The existing requirement to drills or exercises. to several specific scenario elements including: respond to essentially 100% of initiating conditions

All functions in each ERF (e.g. , all
Hostile Action directed at the plant site. is moved to Section N.3 of SNC Standard ERFs that are responsible for dose
No radiological release or unplanned release Emergency Plan.

assessment perform those duties in that does not require public protective response to a radiological release). actions.

Use of alternative facilities to stage
An initial classification of or rapid escalation the ERO for rapid activation during to a Site Area Emergency or General hostile action . Emergency.
Real-time staffing of facilities during
Implementation of strategies, procedures, off hours (i.e. , 6 :00 p.m. to 4:00 and guidance developed in 50.54(hh), (i.e. ,

a.m .). potential aircraft threat, explosion or large

Providing medical care for injured , fire) .

contaminated personnel (every 2

Integration of offsite resources with onsite years). response
Response to essentially 100
A drill initiated between the hours of 6 p.m .

percent of initiating conditions and 4 a.m . identified in the site emergency plan

Drills using essentially 100 percent of implementing procedure for Initiating Conditions in the 8-year cycle.

classification of emergencies. EP N.2.34: A medical emergency drill, involving a simulated contaminated individual, and containing provisions for participation by local support services organizations including ambulance response, are conducted annually at the nuclear plants EP N.3: . During the exercise planning cycle described in Section N.1.45, SNC sites vary the content of exercise scenarios to provide ERO members the opportunity to demonstrate proficiency in key skills necessary to respond to several specific scenario elements including:

A drill initiated between the hours of 6 p.m.

and 4 a.m . E12-182 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section N.2.1 (Continued) EP N .~1 .4 :Hostile Action Based (HAB)

Response to actual industry event Qi:illsExercises sequences appropriate for the Hostile Action Based (HAB) OOll&exercises nuclear plant technology (e.g ., involving an air, land , or water based attack BWR). scenario will be conducted at sites on a
Use of procedures developed in frequency of at least once every 8 years.

response to an aircraft threat and in EP N.3: During the exercise planning cycle compliance with 10 CFR described in Section N.441 .5, SNC sites vary 50.54(hh)(1). the content of exercise scenarios to provide

Use of the strategies associated ERO members the opportunity to demonstrate with 10 CFR 50.54(hh)(2) to mitigate proficiency in key skills necessary to respond to spent fuel pool damage scenarios several specific scenario elements including:

(all strategies, such as makeup,

Implementation of strategies, procedures, spray , and leakage control , but not and guidance developed in 50.54(hh), (i.e ..

every variation of a given strategy) . potential aircraft threat, explosion or large

Use of the strategies associated fire) .

with 10 CFR 50.54 9(hh)(2) to EP N.3: During the exercise planning cycle mitigate reactor accidents and described in Section N.1.45, SNC sites vary the maintain containment). content of exercise scenarios to provide ERO members the opportunity to demonstrate proficiency in key skills necessary to respond to several specific scenario elements including: Hostile Action directed at the plant site . No radiological release or unplanned release that does not require public

                                       . protective actions.

An initial classification of or rapid escalation to a Site Area Emergency or General

                                       . Emergency.

Implementation of strategies, procedures, and guidance developed in 50.54(hh), (i.e., potential aircraft threat, explosion or large

                                       . fire).

Integration of offsite resources with onsite response

A drill initiated between the hours of 6 p.m .

and 4a.m.

Drills using essentially 100 percent of lnitiatinQ Conditions in the 8-year cycle.

E12-183 2 to NL- 16-0 169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section N.2.3: As discussed in the EP N.2.32: Fire drills will be conducted at The comm itment wording was standardized and FSAR , the program involves nuclear plants in accordance with Plant relocated to the SNC Standard Emergency Plan quarterly (fire) drills, at least one of Technical Specifications and Plant procedures. wh ich is unannounced . Section N.2.3: The quarterly drills EP N.2.32: Fire drills will be conducted at The commitment wording was standardized and are scheduled so that each member nuclear plants in accordance with Plant relocated to the SNC Standard Emergency Plan of the fire brigade participates in at Technical Specifications and Plant procedures. least two drills per vear. Section N.2.3: In add ition , an annual EP N.2.23: Fire drills will be conducted at The commitment word ing was standardized and practice is conducted which requires nuclear plants in accordance with Plant relocated to the SNC Standard Emergency Plan extinguishing a fire. Technical Specifications and Plant procedures. Section N.2.4 : A medical emergency EP N.2.34: A medical emergency drill, involving The commitment wording was standardized and drill involving a simulated a simulated contaminated individual, and relocated to the SNC Standard Emergency Plan contaminated person is conducted containing provisions for participation by local each calendar year. support services organizations including ambulance response, are conducted annually at the nuclear plants. Local support service organizations that support more than one plant shall only be required to participate once each calendar vear. Section N.2.5: Plant environs and EP N.2.M : Plant environs and radiological The commitment wording was standardized and radiological monitoring drills are monitoring drills are conducted annually. These relocated to the SNC Standard Emergency Plan conducted each calendar year per drills include collection and analysis of sample Procedure NMPEP-303, Drill and media and provisions for communications and Exercise Standards. record keeping . These drills also evaluate the response to , and analysis of, simulated airborne and direct radiation measurements in the environment. Section N.2.6: Semiannual health EP N.2.65: Radiation Protection Drills involving The commitment word ing was standardized and physics drills will be conducted per a response to, and analysis of, simulated relocated to the SNC Standard Emergency Plan Procedure NMP-EP-303, Drill and airborne and liquid samples and direct radiation Exercise Standards. measurements are conducted semi-annually. At least annually, these drills shall include a demonstration of the sampling system capabilities, as applicable. E12-185 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section N.2.6: Post accident Vogtle executed the PASS elimination as approved sampling under simulated accident by NRC SER in a letter dated November 12, 2001 conditions will be demonstrated each calendar year. The annual sampling requirement in the description of Radiation Protection drills in EP N.2.59 ensures accident sampling capabilities are maintained. Section N.3: Each drill and exercise EP N.3: When a major drill or exercise is The commitment wording was standardized and is conducted in accordance with a required , the Emergency Preparedness (EP) relocated to the SNC Standard Emergency Plan scenario. group will coordinate the preparation of a scenario. The EP group will also coordinate efforts with appropriate federal , state, and local emergency organizations and agencies, schedule a date to conduct the drill or exercise, and assign qualified controllers . Section N.3: The preparation of EP N.3 : When a major drill or exercise is The commitment wording was standardized and exercise scenarios is directed by the required , the Emergency Preparedness (EP) relocated to the SNC Standard Emergency Plan emergency preparedness supervisor group will coordinate the preparation of a who enlists the assistance of scenario. The EP group will also coordinate personnel from other departments, efforts with appropriate federal , state, and local as required , to assist in this task. emergency organizations and agencies, schedule a date to conduct the drill or exercise, and assign qualified controllers . E12-186 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section N.4 : All drills and exercises EP N.4: A formal critique will be performed for The commitment wording was standardized and are evaluated. exercises. drills. and training tabletops to relocated to the SNC Standard Emergency Plan Section N: For periodic drills. the develop, maintain . or demonstrate key skills in process consists of the following order to identify weak or deficient areas that steps: need correction .

1. Drills will be evaluated by A critique shall be conducted at the conclusion controllers/evaluators selected on of the exercise, to evaluate the organization's the basis of expertise and ability to respond as called for in the SNC ava ilability. Standard Emergency Plan . Qualified

2. Improper or incorrect performance personnel will observe and perform a critique during the drill may be corrected by of exercises and drills. Provisions will be made the controller/evaluator and the for federal. state. and local observers, as well proper method pointed out or as SNC personnel, to observe and critique demonstrated . required exercises.

3. The exercise or drill controllers Biennially, representatives from the NRC assemble the players at the observe and evaluate the licensee's ability to conclusion of activities for a critique . conduct an adequate self-critical critique. For Players are encouraged to identify partial and full offsite participation exercises.

areas where improvements are the NRC and Federal Emergency Management required . The drill controllers also Agency (FEMA). will observe. evaluate. and presents their observations to the critique. players. Drill and exercise performance objectives will

4. The site emergency preparedness be evaluated against measurable supervisor submits a list of corrective demonstration criteria . As soon as possible actions. responsibilities. and following the conclusion of the drill or exercise, schedule information to the site a critique is conducted to evaluate the ability of support manager for approval. the Emergency Response Organization (ERO)

5. The emergency preparedness to implement the emergency plan and supervisor assigns action items and procedures. and a formal evaluation will result monitors the status of completion of from the critique .

corrective actions. Significant A written critique report is prepared by the problems will be brought to the Emergency Preparedness group following a attention of appropriate plant drill or exercise involving the evaluation of management. designated objectives or following the final Exercise evaluation and corrective simulator set with ERO participation. The action are carried out in similar report will evaluate the ability of the ERO to fashion . respond to a simulated emergency situation. The report will also contain corrective actions and recommendations. E1 2-188 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Curre nt Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section 0 .2: Mandatory training for EP 0 .1 : To achieve and maintain an The commitment wording was standardized and emergency positions held: acceptable level of emergency preparedness, relocated to the SNC Standard Emergency Plan All ERO personnel shall be trained training will be conducted for members of the per table 0-2 within the last 15 Emergency Response Organization (ERO) and months, except for post accident those offsite organizations that may be called sampling and first aid training , which on to provide assistance in the event of an is to be with in 36 months. emergency. Training will be evaluated in accordance with the requirements of Systematic Approach to Training practices to ensure effectiveness and in order to identify weak or deficient areas that need correction . The ERO Training Program ensures the training , qualification, and requalification of individuals who may be called on for assistance during an emergency. Specific emergency response task training , prepared for response positions, is described in lesson clans and studv auides. Section P: The Executive Vice EP P: The PresidenVChief Executive Officer The commitment wording was standardized and PresidenVChief Nuclear Officer (CEO) Southern Nuclear Operating Company relocated to the SNC Standard Emergency Plan (CNO) Southern Nuclear Operating (SNC) has direct responsibility for the Company (SNC) has overall operation and maintenance of the SNC Plants. responsibility and authority for all nuclear activities, including emeraencv olannina IEPl oroarams. Section P: The vice president- EP P.1 : The Vice President - Regulatory The commitment wording was standardized and regulatory affairs is responsible for Affairs is responsible for the overall relocated to the SNC Standard Emergency Plan administration of the corrective coordination of the corporate emergency action program in the corporate preparedness programs and Emergency headquarters, the overall Plans. coordination of the corporate emergency preparedness programs (including the common Emergency Operations Facility) , Emergency Plans, and site emergency response communication. E12-193 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 EP E.2.5 : Prompt alerting and notification of the public within the plume Appendix 3: Initial alerting will be exposure pathway EPZ is the obligation of state and local govern ment or other The commitment wording was standardized and made primarily by both tone-alert responsi ble authority. Th e responsibility for ensuring the means exist to carry relocated to the SNC Standard Emergency Plan out this purpose rests with Southern Nuclear Operating Company. An radios and a system of fixed sirens. overview of these means excluding the Savannah River Site is listed in the and Site Annex site-specific Ann ex of this Plan. Appendix 3: In the event of a serious Annex 4.2: Two totally independent public alerting systems are installed for emergency at VEGP , the primary use in the VEGP EPZ: means for alerting and providing

Network of fixed sirens and EAS, initial instructions to the public will be by a combination of tone-alert radios
NOAA (National Oceanic and Atmospheric Administration) weather warning radio system.

and a system of fixed sirens. Offsite agencies will activate both independent systems in the event of a plant Appendix 3: The siren system condition requiring public awareness. Following any public alert, commercial consists of a network of 47 rotating radio and television stations, as well as NOAA weather radio (NWR) will be used to provide notification and follow-up emergency information to the electronic sirens mounted on poles population within the EPZ. strategically located throughout the Responsibility for alerting and notifying the public lies with the appropriate offsite civil authorities; specifically, GEMA for anywhere within the State of populated area of the plume Georgia; Burke County EMA for Burke County, Georgia: SCEMD for South exposure EPZ. Carolina; The County Division of Emergency Preparedness in Aiken County, South Carolina; the County Disaster Preparedness Agencies in Allendale and Barnwell Counties, South Carolina; and the SAS. Physical activation of the sirens in Burke County will be done by the Burke County EMA in accordance with the Burke County SOP, and in coordination with GEMA. Physical activation of the siren in Barnwell County will be done by that county, in consultation with SCEMD. Physical activation of the NWR system is by the NWS office in Columbia, SC for VEGP when requested to do so by GEMA. In general , SCEMD will rely upon GEMA to activate the NWR system, and to coordinate with Burke County on the activation of the EAS. The South Carolina Governor's Office or SCEMD will activate the South Carolina EAS after coordination with Georgia authorities. The system maintenance requirements for the Tone Alert Radio System are contained in the FEMA approved System Design Report. Specifically, Vogtle maintains a database of those assigned tone alert radios and performs an annual telephone survey documenting the adequacy of distribution. Provisions for transient population notification are also included in state and county plans. T"*e allllrG"es iASelleAseAt, sSF>lllleffieAtary alertiA§ systeffis are iAstalles iA tee ePZ ta alert tee ll" l31is, seAsistiA§ ef a Aetwerl< ef fixes sireAs er teAe alert rasies. Pre"isieAs fe r traAsieAt llGll"latieA AetifisatieA are alse iAsl"ses iA state aAs se"Aty lllaAs. Tee 0 1ert aAs NetifisatiaA Systeffi (,* NS) sessrilltiaA is llreuises iA tea ~e l! 0 allii*e"es

1ert aAs ~letifisatieA Systeffi Qesi§A l'lellert

_ *k ~ *-

E12 -196 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Append ix 3: Based upon Appendix 3 Annex 4.2: Two totally independent public alerting systems are The commitment word ing was standardized and of NUREG-0654 and FEMA REP-10, installed for use in the VEGP EPZ: relocated to the Site Annex. the system is designed to provide a

Network of fixed sirens and EAS, minimum of 60 dBC coverage to all residences within the plume
NOAA (National Oceanic and Atmospheric Administration) weather warning radio system .

exposure EPZ, plus adequate Offsite agencies will activate both independent systems in the coverage for people outdoors in all event of a plant condition requiring public awareness . Following other areas of the plume exposure any public alert, commercial radio and television stations, as well EPZ open to the public. as NOAA weather radio (NWR) will be used to provide notification and follow-up emergency information to the population within the EPZ. Responsibility for alerting and notifying the public lies with the appropriate offsite civil authorities ; specifically, GEMA for anywhere within the State of Georgia; Burke County EMA for Burke County, Georgia; SCEMD for South Carolina ; The County Division of Emergency Preparedness in Aiken County, South Carolina ; the County Disaster Preparedness Agencies in Allendale and Barnwell Counties, South Carolina ; and the SRS. Physical activation of the sirens in Burke County will be done by the Burke County EMA in accordance with the Burke County SOP, and in coordination with GEMA. Physical activation of the siren in Barnwell County will be done by that county, in consultation with SCEMD. Physical activation of the NWR system is by the NWS office in Columbia, SC for VEGP when requested to do so by GEMA. In general, SCEMD will rely upon GEMA to activate the NWR system , and to coordinate with Burke County on the activation of the EAS. The South Carolina Governor's Office or SCEMD will activate the South Carolina EAS after coordination with Georgia authorities. The system maintenance requirements for the Tone Alert Radio System are contained in the FEMA approved System Design Report. Specifically, Vogtle maintains a database of those assigned tone alert radios and performs an annual telephone survey documenting the adequacy of distribution. Provisions for transient population notification are also included in state and county plans. Two aJ:lJ:lf9*1es iRS8J:l8Rsent, G9fl1J:ll8fl18Rtary aleFliR!J systefl1s are installes iR IRS EPZ te aleFI IRS J:l~eliG , GORSisliR!j el a Ret .... afk el fiMes sirens or tono ale Fl rasies . Previsiens fer transient J:lOJ:l~latioR netifisatien are alse iRGl~sos in state ans sa~nty J:llans. Ttio /\~JS systefl1 insl~ses asfl1inistrati'le ans J:lRysisal F11oans fer a tiask~J:l fl1ottios el J:l~elis aloFliR!J ans notifisatien GaJ:lablo el boiR!J ~sos in tl:lo 8'18RI IRS J:lRfl1ary fl18IR8S el aloFliR!j ans RotifiGatioR is

                                     ~Ra"ailaele s~riR!J an ofl1of!JoRGY ta ale Fl er nelify all or J39Fliens el IRS J:ll~fl18 8MJ:l9S~F8 J:lalR"'ay EPZ J:lOJ:l~lalioR . TRo eaGk~J:l fl181R9S tias tl:lo GaJ:labi lily le aloFI ans Ratify ltio J:l~eliG witl:lin tl:lo J:ll~fl1o 8MJ:l9S~f8 J:lalR"'ay EPZ, 9~1 F11ay Rel fl188I tl:lo 1Ii fl1iR~l8 SOSi!JR oejesti"o for tl:lo J3Fifl1ary J:lf9fl1J:ll J:l~eliG aloFI ans netifisatien svstem, E12-197 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan                   Revised SNC Emergency Plan                                 Justification Revision 63 Appendix 9: All                       Annex Appendix C.                                   New Emergency Plan Implementing Procedures are to be developed following submittal of SNC Standard Emergency Plan and Annexes . The EPIPs will be developed consistent with the NRC approval of the Plan and the criteria of 10 CFR 50 .54(q)

Appendix 7 A .3: Upon notification of EP H.2.1 : The EOF is procedurally required to The commitment wording was standardized and an ALERT or higher classification or be activated within 75 minutes following the relocated to the SNC Standard Emergency Plan as directed by the ED, the EOF will declaration of an Alert or higher be activated as described in classification .Staffing ans aGti'lation of the EO~ emergency implementing is mansatory !,lj30n seGlaration ef an Alert er procedures . *- *r Appendix 7 A.3 : Offsite support EP B.2.1.16: The Support Coordinator reports The commitment wording was standardized and personnel and equipment will be to the TSC Manager and directs the clerical relocated to the SNC Standard Emergency Plan dispatched to the site Operations and logistic activities in the TSC and ensures Support Center (OSC) or Technical that support staff, including clerks , status board Support Center (TSC) upon request keepers, and communicators, are available in from the specific site Emergency sufficient numbers and that office supplies , Director. drawings, and other documents are available to TSC and OSC personnel. Appendix 7 A .3: The corporate The commitment wording was standardized and emergency organization will provide relocated to the SNC Standard Emergency Plan. offsite emergency response support and resources to SNC sites 24 hours The SNC Standard Emergency Plan integrates the per day until the emergency has Corporate response as part of the trained and been terminated . qualified ERO. A separate statement is not necessary. Appendix 7 A.3 : The EOF will be EP H.2.1: The EOF is procedurally required to The commitment wording was standard ized and activated for an ALERT , SITE AREA be activated within 75 minutes following the relocated to the SNC Standard Emergency Plan . or GENERAL emergency declaration of an Alert or higher classification . classifications . Staffing ans aGti'lation efthe EO~ is mansatory ll13on seGlaratien ef an Alert er I... ' .L.. . ... E12-207 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Appendix 7 B.1: The EOF Managers EP 0 .1 Training The commitment was modified to required qualified will typically have either previous To achieve and maintain an acceptable level of personnel. plant specific SRO background or emergency preparedness, training will be long-term supervisory/management conducted for members of the Emergency experience. Response Organization (ERO) and those offsite organizations that may be called on to provide assistance in the event of an emergency. Training will be evaluated in accordance with the requirements of Systematic Approach to Training practices to ensure effectiveness and in order to identify weak or deficient areas that need correction . The ERO Training Program ensures the training , qualification, and requalification of individuals who may be called on for assistance during an emergency. Specific emergency response task training, prepared for response positions, is described in lesson plans and study guides. The lesson plans, study guides, and written tests are contained in the ERO Training Program . Responsibilities for implementing the training program are contained in plant procedures. Offsite training is provided to support organizations that may be called upon to provide assistance in the event of an emergency. Appendix 7 B.1: The duties and EP B.3.1 .1 : The EOF ED has overall The commitment wording was standardized and responsibilities of the EOF Manager coordinating authority for Southern Nuclear relocated to the SNC Standard Emergency Plan . are as follows : (As listed in App . 7, Company resources . Upon EOF activation , 14 items listed) the EOF ED accepts responsibility for Notification and Protective Action Recommendation functions from the Control Room . The EOF ED is also responsible for keeping SNC corporate management informed regarding the emergency response and Classification upgrades. E12-211 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Appendix 7 C: Initial notifications or EP E.2.1: Emergency Response personnel The commitment wording was standardized and emergency response personnel will respond to their assigned Emergency relocated to the SNC Standard Emergency Plan. follow the guidelines specified in the Response Facilities upon notification of an site specific Emergency Plan and Alert or higher classification level. Emergency Plan Implementing Procedures. Appendix 7 C.1 : The On-call EOF EP E.2.1 : Emergency Response personnel The commitment wording was standardized and Manager will be notified of all respond to their assigned Emergency relocated to the SNC Standard Emergency Plan . emergencies classified at any SNC Response Facilities upon notification of an site . Alert or higher classification level. Appendix 7 D.1: The EOF is located EP H.2.1 : The EOF is a dedicated facility The commitment wording was standardized and in Birmingham, Alabama and serves located in Birmingham, Alabama , and serves as relocated to the SNC Standard Emergency Plan. as the EOF for all SNC sites (VEGP, the EOF for SNC sites (VEGP, FNP, and HNP). FNP, and HNP). Appendix 7 D.1: The EOF will be EP H.2.1: The EOF is procedurally required to The commitment wording was standardized and activated as prescribed in the site be activated within 75 minutes following the relocated to the SNC Standard Emergency Plan . specific Emergency Plan declaration of an Alert or higher implementing procedures. classification .SlafliRQ aRa aGli>JatieR ef 111e ~Qi:; is R'!aRaalePJ lli39R aeGlaralieR ef aR Alert eF Appendix 7 D.1: Plant systems EP H.5.1: A permanent meteorological The commitment wording was standardized and information, radiological data , and monitoring station is located near the plant for relocated to the SNC Standard Emergency Plan . meteorological data are provided via the acquisition and recording of wind speed, the SNC Integrated Data Display wind direction , ambient and differential System to EOF personnel. temperatures for use in making offsite dose projections. Meteorological information is displayed in the CR, TSC , and EOF. EP H.5.3.2: The SPDS parameters are available during normal and abnormal operating conditions in the Control Room , TSC, and EOF. Appendix 7 D.1 : Data displays are EP H.5.1: Meteorological information is The commitment wording was standardized and located in the main caucus area of displayed in the CR, TSC , and EOF by means relocated to the SNC Standard Emergency Plan . the EOF, dose assessment area, of the plant computer system. plant status area , and engineering EP H.5.3. 2: The SPDS parameters are area within the facility. available normal and abnormal operating conditions in the Control Room, TSC , and EOF. E12-214 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Appendix 7 0.1: Back-up power for EP H.2.1: Backup power for the EOF is The comm itment wording was standardized and the EOF is supplied by onsite diesel supplied by onsite diesel generation. Essential relocated to the SNC Standard Emergency Plan. generation . All essential equipment equipment is backed up by the diesel is backed up by the diesel generation system . aeneration system . Appendix 7 0.1 : The following EP H.2.1 : The EOF is located at SNC The commitment wording was standardized and records or information are available: Corporate Headquarters with the document relocated to the SNC Standard Emergency Plan . Technical Specifications. management section for SNC. The following Selected plant operating procedures. records or information are available : Emergency Plans.

Technical Specifications.

Emergency Plan Implementing

Selected plant operating procedures .

Procedures.

Emergency Plans.

FSARs.

Emergency Plan Implementing Procedures.

State and local emergency response

Final Safety Analysis Reports (FSARs).

plans.

System piping and instrumentation Savannah River Site Emergency diagrams and HVAC flow diagrams.

Plan .

Electrical one-line, elementary, and wiring Appendix 7 0 .2: In the unlikely event diagrams.

Egress of personnel from the EPZ fall under the that individuals shou ld need to provisions of the state Plan . A statement in the respond to the EOF from within the SNC Standard Emergency Plan is not required . 10 mile EPZ of any SNC plant, they would be surveyed prior to release by local emeraencv authorities. Appendix 7 0 .2: In the unlikely event The corporate EOF is located outside the that the EOF becomes reasonable expectation for damage based on a uninhabitable , resources and naturally occurring event beyond the design basis personnel will be transferred to the of the site. Should the EOF be so damaged the Corporate Headquarters of Alabama site can re-assume control of the event. Power Company. Appendix 7 E.1 : Provisions have EP F.1 .4: Communication with the Nuclear The commitment wording was standardized and been made to have direct NRC FTS Regulatory Commission (NRC) is on the relocated to the SNC Standard Emergency Plan. lines in the TSC and the EOF during Federal TeleJlRORe Telecommunications an emergency. System (FTS) telephone network that connects the SNC plant site and EOF with the NRC Operations Center. E12-217 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Appendix 7 G.1 .2: At least 1 N.2.1 0-t- The SNC Standard Emergency Plan incorporates activation every 5 years will require a At least once every five years , a drill involving the EOF multi-site drill requirement into the base concurrent EOF support response more than one SNC site will be conducted Plan response. for more than one SNC site. demonstrating the ability of the Common EOF to effectively implement the Emergency Plan for an event involvina more than one site. Appendix 7 G.1.2: Each drill/exercise EP N.1: Drills and exercises shall: The commitment wording was standardized and will test, as a minimum , the

Test the adequacy of timing and content of relocated to the SNC Standard Emergency Plan.

commun ication links and notification implementing procedures and methods. procedures.

Test emergency equipment and communications networks.
Test the public notification system.
Ensure that emergency organization personnel are familiar with their duties.

Appendix 7 G.1.2: Provisions are EP N.4: A formal critique will be performed for The commitment wording was standardized and made for critique of all exercises, drills, and training tabletops to relocated to the SNC Standard Emergency Plan . drills/exercises. develop, maintain, or demonstrate key skills in order to identify weak or deficient areas that need correction . A critique shall be conducted at the conclusion of the exercise, to evaluate the organization's ability to respond as called for in the SNC Standard Emeraencv Plan. Appendix 7 G.1.2 : Critique items will EP N.5: The Emergency Preparedness group The commitment wording was standardized and be forwarded to the site emergency is responsible for evaluating recommendations relocated to the SNC Standard Emergency Plan . preparedness coordinator for and comments, determining which items will be processing in the site specific incorporated into the program or require corrective action program. corrective actions, and for scheduling , tracking , and evaluating item resolution . Whenever exercises or drills indicate deficiencies in the SNC Standard Emergency Plan , site-specific Annexes , corresponding implementing procedures, or training lesson plans, such documents will be revised as necessary. E12-220

VOGTLE ELECTRIC GENERATING PLANT UNIT 1&2 JUSTIFICATION MATRIX Purpose The purpose of this attachment is to identify the commitments in the current Vogtle Electric Generating Plant Emergency Plan Revision 63, identify the equivalent or modified commitment in the integrated Fleet Emergency Plan and Vogtle Site Annex, and justified on a commitment-by-commitment basis the proposed License Amendment. 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix CHANGE MATRIX Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 PREFACE Annex 1.1 Facility Description The commitment wording was standardized and The Vogtle Electric Generating Plant The Vogtle Electric Generating Plant (VEGP) relocated to the Site Annex. (VEGP) is a two-unit pressurized Units 1 and 2 are a two-unit pressurized water water reactor operated by Southern reactor. The plant site, to include VEGP Units Nuclear 1-4, is on a 3, 169-acre site located in the Operating Company (SNC). The eastern portion of Burke County, Georgia, plant is on a 3169-acre site located approximately 23 river miles upstream from the in the eastern portion of Burke intersection of the Savannah River with U.S. County, Georgia, approximately 23 Highway 301. river mi upstream from the intersection of the Savannah River with U.S. Highway 301, as shown on figure i. Figure ii shows the site and the locations of the buildings on the site. The locations of the VEGP emergency facilities are shown on fig4.1.1 ure ii. This Emergency Plan is applicable to Annex 1.2 Emergency Planning Zones The commitment wording was standardized and VEGP, Units 1 and 2, and to its (SEP J.5) relocated to the Site Annex. environs as specified by the Annex 1.2.1 Plume Exposure Pathway (SEP emergency planning zones (EPZs): a J.7) plume exposure pathway EPZ, which The 10-mile Emergency Planning Zone (EPZ) nominally consists for VEGP approximates a 10-mile radius of the area within approximately 10 around the plant site and is depicted in Figure mi of the plant, and an ingestion 1.2.A. Georgia and South Carolina, as well as exposure pathway EPZ, which the counties (Burke County in Georgia and extends to 50 mi. These distances Aiken, Barnwell, and Allendale Counties in are reckoned from a point midway South Carolina) are located within the plume between the centers of the Unit 1 exposure pathway EPZ. The major portion of and Unit 2 containment buildings for the plume exposure pathway EPZ in South the 10 mile EPZ map. The two EPZs Carolina is within the Department of Energy's are shown in figures iii and iv. Savannah River Site (SRS). E12-2 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 The EPZ for ingestion exposure Annex 1.2.2 Ingestion Pathway (SEP J.7) The commitment wording was standardized and includes an area within 50 mi of The area between the 10-mile and 50-mile relocated to the Site Annex. VEGP. Planning for the ingestion radius is considered the Ingestion Pathway exposure pathway is a responsibility Zone (IPZ). The 50-mile IPZ is depicted in of the States of Georgia and South Figure 1.2.B. Planning for the ingestion Carolina. More information about exposure pathway is a responsibility of the the ingestion exposure pathway EPZ states of Georgia and South Carolina. More can be obtained from the States' information about the IPZ can be obtained Radiological Emergency Plans. from the states' Radiological Emergency Plans. Section A.1: Vogtle Electric EP

Introduction:

Detailed procedures The commitment wording was standardized and Generating Plant (VEGP) accepts concerning the implementation of the SNC EP relocated to the SNC Standard Emergency Plan. the responsibility of maintaining an are in the Emergency Plan Implementing effective Emergency Plan and Procedures (EPIPs). maintaining proper preparedness SNC has overall responsibility for maintaining a through the maintenance of formal state of readiness to implement this Plan for the procedures for implementing the protection of plant personnel, the general public Plan as identified in appendix 9, the and property from hazards associated with any training of personnel in accordance facility operated by the company. The authority with section 0, the maintenance of for planning, developing, and coordinating necessary equipment, and emergency control measures is derived from continuing relationships with various being the Nuclear Regulatory Commission governmental agencies and private (NRG) license holder for the nuclear power organizations as identified in this plants operated by SNC. section. E12-3 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section A.1: The following tasks are EP

Introduction:

SNC has overall responsibility The commitment wording was standardized and part of VEG P's responsibility: for maintaining a state of readiness to relocated to the SNC Standard Emergency Plan.

Recognize and declare the implement this Plan for the protection of plant existence of an emergency personnel, the general public, and property from condition. hazards associated with any facility operated by
Classify the event in accordance the company. The authority for planning, with the methodology described in developing, and coordinating emergency control section D of this Plan. measures is derived from being the Nuclear
Notify appropriate VEGP Regulatory Commission (NRC) license holder personnel and offsite authorities. for the nuclear power plants operated by SNC.
Take corrective actions to mitigate The SNC Emergency Plan describes the the severity of the accident. organization and facilities, training, and
Request additional support as maintenance of both onsite and off-site facilities deemed necessary. and equipment that will be used to address a
Establish and maintain effective wide spectrum of accidents ranging from minor communications within VEGP and onsite incidents to those that could affect the with offsite response groups as general public.

described in section F.

Continuously assess the status of the accident and periodically communicate the status information to the appropriate response groups. This includes the collection and evaluation of onsite and offsite radiological monitoring data.
Take protective measures onsite and recommend protective measures to offsite authorities.
Monitor and control radiation exposures of all personnel responding to the emergency and under the direction of VEGP.
Provide emergency information to the public through periodic press briefings in conjunction with State and local officials.

E12-4 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section A.1: The VEGP emergency EP 8.1.1: The Shift Manager (SM) is in direct The commitment wording was standardized and response is carried out under the charge of shift plant operations and is directly relocated to the SNC Standard Emergency Plan. control of the emergency director. responsible for the actions of the on-shift crew. In an emergency, the SM assumes the responsibility of the Emergency Director (ED) and takes necessary actions to identify and respond to the emergency until relieved by another qualified ED. A.2.1 PRINCIPAL AGENCIES OF EP A.2.2.1 Georgia Emergency The commitment wording was standardized and THE STATE OF GEORGIA Management Agency (GEMA) relocated to the SNC Standard Emergency Plan. The following State agencies are As the overall state coordinating agency assigned lead responsibility GEMA will coordinate with the Department of for radiation emergencies and for Natural Resources-Environmental Protection overall State preparedness, Division (DNR-EPD) on emergency response respectively: activities with state, county and municipal

1. GEORGIA EMERGENCY agencies and departments as stated in the MANAGEMENT AGENCY Georgia Emergency Operations Plan (GEOP).

a. GEMA is responsible for general GEMA provides for 24-hour notification and State emergency planning and staffing of the State Operations Center (SOC) exercises overall direction and and/or the Forward Emergency Operations control of emergency or disaster Center (FEOC), as required, throughout the operations as assigned by Executive event.

order. GEMA is responsible for general state

b. The director of emergency emergency planning and overall direction and management as the State disaster control of emergency or disaster operations as coordinator coordinates emergency assigned by executive order and in activities of DNR with overall State accordance with the Georgia Emergency response efforts. Operations Plan (GEOP). GEMA has responsibilities for coordinating the state of Georgia response to emergencies at nuclear power plants.

E12-5 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63

1. GEORGIA EMERGENCY Annex 1.3 The commitment wording was standardized and MANAGEMENT AGENCY (cont) Upon notification of an emergency condition, relocated to the Site Annex.

c. During an emergency, the State of the Georgia Emergency Management Agency Georgia, acting through GEMA, and will implement the "State of Georgia the State of South Carolina, acting Radiological Emergency Plan." The Georgia through the South Carolina Emergency Management Agency has the Emergency authority and responsibility for coordinating the Preparedness Division, will efforts of local and state agencies in Georgia coordinate their emergency to provide for the health and safety of the response efforts including such general public in the event of a radiological matters as radiological dose incident.

assessment, protective action An agreement is in place with the state of decisions, and activation of the Georgia to provide available resources and prompt notification system for equipment to support the mitigation and alerting the public. response to an emergency at Plant Vogtle,

d. On behalf of the Governor, including Hostile Action Based events. These activate all or portions of the GEOP resources include, but are not limited to, Local to provide the necessary overall Law Enforcement Agency (LLEA) assets, fire coordinated response. fighting assets, medical support resources

e. Provide communications for the (including transportation), and coordination State Operations Center (SOC), as through an Incident Command Post. Requests required, through 24-hour radio for offsite resources and equipment will be network, commercial telephone, communicated from the control room to the National Warning Burke County 911 center, the county EOG, or System (NAWAS), or other through the Incident Command Post, as communications systems. applicable, based on the nature and timing of Communication links will be the event.

established in accordance with existing procedures with the SOC in Atlanta as well as with additional State and local emergency response personnel within the plume exposure pathway and ingestion EPZs. These functions will initially be handled from the SOC and will then be transferred to the Forward Emergency Operations Center (FEOC) once activated. E12-6 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63

1. GEORGIA EMERGENCY MANAGEMENT AGENCY (cont)

f. Establish the FEOC if necessary.

The FEOC will be established at the Burke County Emergency Operations Center (EOC) Building, on the corner of Georgia Highway 24 and Perimeter Road in Waynesboro. Upon the decision of the GEMA director to activate the FEOC, the GEMA Mobile Communications Vehicle (MCV) may be dispatched to Burke County and arrive within driving time plus 30 min for mobilization. When dispatched, it may be used to transport certain State responders. The GEMA MCV will be located adjacent to the Burke County EOC and will provide support services to State agencies at the FEOC. The Burke County EOC has the necessary electrical hook-ups to provide long term electrical services to the vehicle. In addition to providing backup for the communications described in the preceding paragraph, the MCV provides backup communications for State agencies other than GEMA (Department of Transportation, the Georgia State Patrol, the Georgia Department of Natural Resources - Law Enforcement Section, and the Georgia Forestry Commission). In addition, the MCV has an onboard weather station that can provide wind speed and direction, barometric pressure and relative humidity. It also has micro down-link capabilities and a video camera svstem. E12-7 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63

1. GEORGIA EMERGENCY MANAGEMENT AGENCY (cont)

g. Maintain liaison with DNR radiation emergency coordinator (REC).

h. Activate public emergency warning and/or evacuation procedures, as needed, pursuant to the GEOP.

i. Assist radiological monitoring and provide instrumentation.

j. Provide radiological monitoring training assistance.

k. Assist in area security and control; request National Guard assistance if needed.

I. Provide for the coordination of land and air transportation for emergency personnel as requested.

m. Coordinate public information releases in cooperation with State and local agencies.

n. Communication links will be established with the state of South Carolina Emergency Preparedness Division and DOE-SRS to ensure efficient coordination of emergency response activities.

E12-8 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63

2. DEPARTMENT OF NATURAL EP A.2.2.2 Department of Natural The wording was standardized and relocated to the RESOURCES Resources Environmental Protection Division SNC Standard Emergency Plan and Site Annex.

a. DNR is assigned primary (DNR-EPD) responsibility by Executive Order for Department of Natural Resources-implementation and administration of Environmental Protection Division (DNR-EPD) the State radiological emergency is assigned as the coordinating and a primary response function. agency responsible by Executive Order for DNRwill: implementation and administration of the state (1) Dispatch radiation emergency radiological and hazardous material function.

teams as needed. The DNR-EPD has primary responsibility for (2) Perform radiation survey and implementation and administration of the state monitoring. (3) Provide radiation safety training. radiological emergency response function. (4) Direct recovery/reentry operation and provide health physics control of Annex 1.3: Upon notification of an emergency contaminated areas. condition, the Georgia Emergency

b. A radiation emergency coordinator Management Agency will implement the "State (REC) in the Environmental Protection of Georgia Radiological Emergency Plan." The Division (EPD) interacts with Georgia Emergency Management Agency has appropriate State, local, and Federal the authority and responsibility for coordinating agencies and private organizations to the efforts of local and state agencies in direct all necessary radiation control Georgia to provide for the health and safety of actions. The REC is on call 24 h and the general public in the event of a radiological will be notified by the GEMA duty incident.

officer. An agreement is in place with the state of

c. In situations beyond local Georgia to provide available resources and government control, DNR provides equipment to support the mitigation and program assistance in the application response to an emergency at Plant Vogtle, of available personnel, equipment, and including Hostile Action Based events. These technical expertise as required.

resources include, but are not limited to, Local

d. DNR requests State support agency(s) and Federal assistance Law Enforcement Agency (LLEA) assets, fire pursuant to the GEOP as required. fighting assets, medical support resources

e. DNR will provide for health physics (including transportation), and coordination escort of media and other personnel through an Incident Command Post. Requests within the plume exposure pathway for offsite resources and equipment will be emergency planning zone (EPZ) as communicated from the control room to the conditions allow if access controls Burke County 911 center, the county EOC, or have been established. through the Incident Command Post, as applicable, based on the nature and timing of the event.

E12-9 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC _Emergency Plan Justification Revision 63 A.2.2 State Support Agencies in Annex 1.3: Upon notification of an emergency The wording was standardized and relocated to Georgia condition, the Georgia Emergency SNC Standard Emergency Plan and Site Annex. The following State agencies are Management Agency will implement the "State prepared to provide related of Georgia Radiological Emergency Plan." The The specific agencies for the state of Georgia were support of this function as indicated Georgia Emergency Management Agency has not listed in the SNC Standard Emergency pursuant to the GEOP: the authority and responsibility for coordinating Plan/Annex due to frequent reorganization and

1. DEPARTMENT OF HUMAN the efforts of local and state agencies in name changes at the recommendation of state RESOURCES Georgia to provide for the health and safety of authorities. The overall responsibilities of the state Coordinate emergency health and the general public in the event of a radiological are unchanged by the SNC Standard Emergency social assistance pursuant to the incident. Plan.

GEOP. An agreement is in pl;:ice with the state of

2. DEPARTMENT OF PUBLIC Georgia to provide available resources and SAFETY equipment to support the mitigation and

a. As applicable, assume control response to an emergency at Plant Vogtle, over the onsite situation until the including Hostile Action Based events. These arrival of radiation safety personnel. resources include, but are not limited to, Local

b. Maintain liaison with DNR REC. Law Enforcement Agency (LLEA) assets, fire

c. Provide communication linkage as fighting assets, medical support resources required. (including transportation), and coordination

d. Provide land or air transportation through an Incident Command Post. Requests or escort as available for radiation for offsite re$ources and equipment will be safety personnel, other necessary communicated from the control room to the personnel, or equipment. Burke County 911 center, the county EOC, or

e. Assist in radiological monitoring as through the Incident Command Post, as required. applicable, based on the nature and timing of

f. Provide law enforcement the event.

assistance for area security or recovery of lost or stolen radioactive material.

g. Coordinate with DNR law enforcement and local police.

h. Assist in public warning or evacuation as required.

E12-10 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 A.2.2 State Support Agencies in Annex 1.3: Upon notification of an emergency The wording was standardized and relocated to Georgia condition, the Georgia Emergency SNC Standard Emergency Plan and Site Annex. (cont) Management Agency will implement the "State

3. DEPARTMENT OF of Georgia Radiological Emergency Plan." The The specific agencies for the state of Georgia were AGRICULTURE Georgia Emergency Management Agency has not listed in the SNC Standard Emergency

a. Collect samples of food products, the authority and responsibility for coordinating Plan/Annex due to frequent reorganization and livestock, produce, and dairy the efforts of local and state agencies in name changes at the recommendation of state products, as necessary. Georgia to provide for the health and safety of authorities. The overall responsibilities of the state

b. Restrict the sale, production, the general public .in the event of a radiological are unchanged by the SNC Standard Emergency distribution, and warehousing of incident. Plan.

livestock, produce, dairy, and An agreement is in place with the state of processed food products Georgia to provide available resources and contaminated beyond safe equipment to support the mitigation and consumption. response to an emergency at Plant Vogtle,

c. Assist in disposal of contaminated including Hostile Action Based events. These products. resources include, but are not limited to, Local

d. Coordinate these activities with Law Enforcement Agency (LLEA) assets, fire United States Department of fighting assets, medical support resources Agriculture (USDA) personnel. (including' t~ansportation), and coordination

e. Maintain liaison with DNR REC for through an Incident Command Post. Requests assessing degree of contamination. for offsite resources and equipment will be

4. DEPARTMENT OF communicated from the control room to the TRANSPORTATION Burke County 911 center, the county EOC, or

a. Assist in traffic control and routing, through the Incident Command Post, as accident assessment, and recovery applicable, based on the nature and timing of operations in transportation the event.

incidents.

b. As requested, provide land, air, or water transportation for radiation safety personnel, other necessary personnel, or equipment.

c. Provide communications linkage as required.

d. Assist State Patrol and DNR law enforcement in security and radioactive material escort as requested.

e. Provide heavy equipment and personnel as reouired.

E12-11 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 A.2.2 State Support Agencies in Georgia (cont)

5. FORESTRY COMMISSION

a. Provide land or air transportation as requested for radiation safety personnel, other necessary personnel, or equipment.

b. Provide personnel and heavy equipment as required to assist in recovery operations.

c. Provide communication linkage as necessary.

6. DEPARTMENT OF ADMINISTRATIVE SERVICES

a. Provide for expeditious approval and purchase of equipment and supplies essential to emergency operations.

b. Provide land transportation vehicles for emergency personnel.

c. Provide emergency communications equipment and repair.

E12-12 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 A.3 BURKE COUNTY, GEORGIA EP A.2.4 Emergency Planning Zone (EPZ) The wording was standardized and relocated to the All the area within the plume Counties SNC Standard Emergency Plan and Site Annex. exposure pathway EPZ in the State The Emergency Management Agencies of Georgia falls within Burke County. representing the counties of Aiken, Allendale, The responsibility for overall Appling, Barnwell, Burke, Early, Henry, radiological emergency response Houston, Jeff Davis, Tattnall, and Toombs planning rests with the chairman, have the responsibility for notification and Burke County Board of providing direction to residents in the event of Commissioners. It is the chairman's an emergency that affects their respective responsibility to initiate actions and jurisdiction. The 24-hour notification points provide direction and control at a have the responsibility to notify necessary local level consistent with the specific civil support groups in the event of an accident. incident. Agencies within Burke The County is responsible for protection of the County which have a primary role in public and can provide personnel and radiological emergency planning and equipment for evacuation, relocation and response include the Emergency isolation. Management Agency and the Sheriffs Department. A detailed discussion of the Burke County response is contained in Annex D to Annex 1.5.1 Burke County Georgia (SEP the Georgia Radiological Emergency A.2.4) Response Plan. The chairman, The area within the plume exposure pathway Burke County Board of (EPZ) in the state of Georgia falls within Burke Commissioners, or his County. The responsibility for overall predesignated alternate (the vice radiological emergency response planning chairman, any of three other rests with the Chairman, Burke County Board commissioners, the county of Commissioners. It is the chairman's administrator, or the EMA director), responsibility to initiate actions and provide may declare an emergency and direction and control at a level consistent with implement offsite protective actions. the specific incident. However, upon the declaration of an emergency situation or the decision to implement protective actions the emergency management agency director is authorized to represent the chairman, Burke County Board of Commissioners. E12-13 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 A.3 BURKE COUNTY, GEORGIA Annex 1.7 Hostile Action Based Events The wording was standardized and relocated to the (cont) Agreements are in place with the state of Site Annex. A.3.1 Emergency Management Georgia, Burke County, Georgia, Aiken, Agency Allendale, and Barnwell Counties in South Principal activities include the Carolina to provide available resources and following: equipment to support mitigation and response

1. Receive notification from VEGP to an emergency at Plant Vogtle to include and GEMA. Hostile Action Based events. These resources

2. Maintain communications with include, but are not limited to, Local Law VEGP on emergency situation Enforcement Agency (LLEA) assets, status. firefighting assets, medical support resources

3. Provide information to other Burke (including transportation), and coordination County response elements, to the through an Incident Command Post. Requests media, and to the public. for offsite resources and equipment will be

4. Activate the public notification communicated from the control room to Burke system, if required. County 911 Center or through the Incident

6. Coordinate Burke County Command Post as applicable based on the emergency response activities. nature of the event. Copies of these

7. Activate and direct operations at agreements are maintained in accordance with the designated reception and care Emergency Plan procedures.

facility.

8. Implement protective action recommendations as requested by GEMA or the chairman of the Burke County Board of Commissioners or his predesignated designee.

A.3.2 Sheriffs Department Principal activities include the following:

1. Provide backup public notification.

2. Control access to the plume exposure pathway EPZ.

3. Provide traffic control and law enforcement measures in the event of an evacuation.

E12-14 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 A.4 STATE OF SOUTH CAROLINA EP A.2.3 State of South Carolina The wording was standardized and relocated to the The State of South Carolina has EP A.2.3.1 Emergency Management Site Annex. developed the South Carolina Division (EMO) Radiological Emergency Response Plan The EMO is assigned the responsibility for (SCORERP) which provides guidance to coordinating the emergency planning efforts of state and local governments on procedures, organization, and state, county, and municipal agencies in responsibilities for preventing and accordance with the South Carolina mitigating the effects of a nuclear power Radiological Emergency Response Plan plant incident or disaster. The (SCORERP); conducting a preparedness SCORE RP provides for the radiological program to assure capability of the government emergency response in the event of a to execute the plan; establishing and radiological accident at a fixed nuclear maintaining a state EOC and providing support facility located in the state or in states of the state emergency staff and work force; contiguous to South Carolina. The and establishing an effective system for SCORERP describes the South Carolina Radiological Emergency Response reporting, analyzing, and disseminating Organization, which consists of the emergency information. Office of the Adjutant General EP A.2.3.2 Department of Health and (Emergency Management Division Environmental Control (DHEC), Nuclear (EMO), the Department of Health and Emergency Planning Section Environmental Control (Bureau of Solid The Department of Health and Environmental and Hazardous Waste, Nuclear Control (DHEC) maintains a radiological Emergency Planning (NEP) Section), hazard assessment capability and provides and those state resources available to technical support, coordination, and guidance local government(s) during a fixed nuclear facility radiological accident. for the state and local governments. It will State radiological emergency response conduct and/or coordinate radiological forces will be operational upon surveillance and monitoring in coordination notification of a radiological emergency. with DOE-Savannah River Site (SRS) and The response functions of involved nuclear power plants. DHEC will obtain and agencies are described in the SCORERP coordinate radiological assistance resources and the South Carolina Technical from the federal government, other states, and Radiological Emergency the nuclear industry as required. Response Plan (SCTRERP). A VEGP EP A.2.3.3 Other South Carolina State Site Specific Radiological Emergency Agencies Response Plan (Part 5 to SCORERP) addresses those matters that pertain Responsibilities of the other state agencies are directly to VEGP. described in the South Carolina Radiological Emergency Response Plan (SCORERP). E12-15 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 A.4 STATE OF SOUTH CAROLINA Annex 1.4 State of South Carolina (SEP The wording was standardized and relocated to the (cont) A.2.3) Site Annex. Upon being advised by EMD that a The state of South Carolina has developed the radiological emergency exists, the South Carolina Radiological Emergency Governor or his designated Response Plan (SCORERP), which provides representative declares an guidance to state and local governments on emergency condition. Under the procedures, organization, and responsibilities Governor's direction, the total and for preventing and mitigating the effects of a combined efforts of the state and nuclear power plant incident or disaster. local governments will be utilized to The SCORERP describes the South Carolina nullify or reduce the effects of offsite Radiological Emergency Response radiological hazards resulting from a Organization, which consists of the Office of nuclear plant accident. As deemed the Adjutant General (Emergency necessary, the Governor may Management Division) (EMD), the Department transfer the direction, personnel, or of Health and Environmental Control (Bureau functions of state agencies. All of Solid and Hazardous Waste, Nuclear radiological emergency response Emergency Planning (NEP) Section), and organizations are prepared to react those state resources available to local on a 24-h basis, and they are government(s) during a fixed nuclear facility capable of continuous operations for radiological accident. a protracted period. Directors of The response functions of involved agencies state agencies, departments, and are described in the SCORERP and the South commissions are responsible for Carolina Technical Radiological Emergency ensuring that their agencies' Response Plan (SCTRERP). radiological emergency response Annex 1.4.1 Office of the Governor (A.2.3.1) responsibilities are accomplished. In the event of the declaration of a radiological Designated county officials are emergency, the EMD, Department of Health responsible for emergency response and Environmental Control (DHEC), and other within their jurisdictions. state agencies are activated. The legal basis and authority for the emergency response of the State of South Carolina include:

1. South Carolina Constitution, Article IV, Annex 17, Appendix A

2. South Carolina Code of Laws ANN, 25-1-420 throuqh 25-1-460.

E12-16 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63

A.4 STATE OF SOUTH CAROLINA Annex 1.4.2 Office of the Adjutant General - The wording was standardized and relocated to the (cont) Emergency Management Division (EMO) (SEP Site Annex.

3. Regulation 58-1, Local A.2.3.1)

Government Preparedness The EMO is responsible for coordinating the Standards; and Regulation 58-101, emergency planning efforts of all state, county, State Emergency Preparedness and municipal agencies in developing a state Standards, South Carolina Code of emergency plan. Additional responsibilities Regulations. include conducting a preparedness program to assure capability of the state government to

4. The South Carolina Emergency execute the plan; establishing and maintaining a Operations Plan (SCEOP).

state EOC and providing support of the state

5. The South Carolina Operational emergency staff and work force; and establishing Radiological Emergency Response an effective system for reporting, analyzing, and Plan (SCORERP). disseminating emergency information.

6. The South Carolina Technical Annex 1.4.3 Department of Health and Radiological Emergency Response Environmental Control (DHEC) (A.2.3.2)

Plan (SCTRERP). DHEC maintains a radiological hazard The duties and responsibilities of the assessment capability and provides technical principal and support agencies of the support, coordination, and guidance for the state State of South Carolina are and local governments. It will conduct and/or summarized below. coordinate radiological surveillance and A.4.1 Principal Agencies of the State monitoring in coordination with DOE-Savannah of South Carolina The following state River Site (SRS) and VEGP. agencies are assigned primary Annex 1.4.4 Other State Support Agencies responsibilities for overall state (A.2.3.3) radiological emergency management Other state agencies described in the South and response operations. Carolina Emergency Operating Plan (SCEOP)

1. Office of the Governor and South Carolina Operational Radiological Emergency Response Plan (SCORERP) will

a. Upon being advised that a provide related support pursuant to each plan.

radiological emergency exists, the Those agencies include: Governor declares an emergency condition which results in the

Department of Public Safety (Highway Patrol Division).

activation of EMO, DHEC, and other state agencies to deal with the

State Law Enforcement division (SLED) .

situation, in accordance with their

Forestry Commission .

emergency response plans.

Department of Natural Resources .
Department of Social Services .
Department of Agriculture .
Clemson University Cooperative Extension Service.

E12-17 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 A.4 STATE OF SOUTH CAROLINA (cont)

b. The Governor's press secretary or authorized representative will direct and control public information service activities and serve as the Governor's official representative/spokesperson regarding the preparation and release of emergency information by state government.

2. Office of the Adjutant General Emergency Management Division

a. The EMO is assigned the responsibility for coordinating the emergency planning efforts of all state, county, and municipal agencies in developing a State emergency plan; conducting a preparedness program to assure capability of the government to execute the plan; establishing and maintaining a State EOC and providing support of the State emergency staff and work force; and establishing an effective system for reporting, analyzing, and disseminating emergency information.

b. The director of EMO is the principal advisor to the Governor for emergency response. He coordinates with DHEC the recommended protective measures based on DHEC evaluation and assessment of the radiological emergency at VEGP.

E12-18 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 A.4 STATE OF SOUTH CAROLINA (cont)

3. Department of Health and Environmental Control

a. The Department of Health and Environmental Control (DHEC) maintains a radiological hazard assessment capability and provides technical support, coordination, and guidance for the State and local governments. It will conduct and/or coordinate radiological surveillance and monitoring in coordination with DOE-SRS and VEGP. DHEC will obtain and coordinate radiological assistance resources from the Federal Government, other states, and the nuclear industry as required.

b. The Bureau of Solid and Hazardous Waste, Nuclear Emergency Planning (NEP) Section within DHEC has the direct responsibility to provide technical assistance and resources necessary to evaluate and assess the consequences of a radiological incident and to provide protective action guidance to State and local authorities. NEP is responsible for radiological surveying and monitoring of the environment, including the collection and analyses of samples of soil, air, water, milk, and crops.

c. The Manager, Nuclear Emergency Planning Section is the individual responsible for implementing the SCTRERP; providing EMO with recommended protective actions as well as recovery and reentry guidelines. NEP has 24-h accident response capability with EMO.

E12-19 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 A.4 STATE OF SOUTH CAROLINA (cont) A.4.2 State Support Agencies in South Carolina The following state agencies are prepared to provide related support pursuant to SCEOP and SCORERP.

1. Department of Public Safety (Highway Patrol Division)

a. Regulate and control traffic on the highways of the state.

b. Have its Highway Patrol warning point serve as the backup means of notification from the VEGP.

c. Provide for a 24-h communication system with VEGP, EMD, and DHEC.

d. Support the State Law Enforcement Division in security and other law enforcement activities.

e. Assist in transportation accident assessment and recovery operations.

f. As requested, provide transportation for radiation safety personnel, other emergency response personnel, or equipment.

g. Provide heavy equipment and personnel as requested.

2. State Law Enforcement Division (SLED)

a. Coordinate law enforcement activities, particularly during evacuation.

b. Assume control of areas suspected of contamination until the arrival of radiation safety personnel.

c. Assist in search and rescue.

d. Coordinate and assist in securing the SEOC, waterways and evacuated areas.

f. Augment communication system and warninQ points operation.

E12-20 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 A.4 STATE OF SOUTH CAROLINA (cont)

3. Forestry Commission

a. Provide land or air transportation as requested for emergency response personnel or equipment.

b. Provide fire control service.

c. Assist in decontamination, in coordination with DHEC.

d. Provide radio operators for the SEOC to operate permanently installed Forestry Commission radio equipment.

e. Maintain radio contact with all Forestry Commission elements in affected counties.

4. Department of Natural Resources

a. Coordinate search and rescue operations.

b. Provide air transportation in support of radiological monitoring operations.

c. Augment public warning operations and public information services.

d. Assist in law enforcement.

5. Department of Social Services

a. Coordinate shelter operations which includes registration of evacuees.

b. Coordinate all emergency welfare services to evacuees such as feeding, clothing, and information.

c. Administer and maintain individual and family assistance program.

d. Augment public information service to evacuees.

E12-21 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 A.4 STATE OF SOUTH CAROLINA (cont)

6. Clemson University Cooperative Extension Service

a. Maintain updated agricultural data required for radiological assessment in support of DHEC.

b. Assist in locating contaminated livestock, feed, milk, and other farm products for disposal or decontamination by DHEC.

7. Department of Agriculture

a. Restrict the sale, production, distribution, and warehousing of livestock, produce, dairy and processed food products contaminated beyond safe consumption.

b. Assist DHEC in disposal of contaminated products.

d. Coordinate these activities with the United States Department of Agriculture (USDA).

E12-22 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 A.5 AIKEN, BARNWELL, AND EP A.2.4 Emergency Planning Zone (EPZ) The wording was standardized and relocated to the ALLENDALE COUNTIES, SOUTH Counties SNC Standard Emergency Plan and Site Annex. CAROLINA The Emergency Management Agencies Most of the plume exposure pathway representing the counties of Aiken, Allendale, EPZ within South Carolina falls within the Appling, Barnwell, Burke, Early, Henry, site boundary of the Savannah River Site (SRS). The United States Department of Houston, Jeff Davis, Tattnall, and Toombs Energy is responsible for the direction have the responsibility for notification and and control of all emergency response providing direction to residents in the event of actions on the SRS. an emergency that affects their respective There are limited portions of Aiken, jurisdiction. The 24-hour notification points Barnwell, and Allendale counties which have the responsibility to notify necessary local are outside of the SRS but within the civil support groups in the event of an accident. plume exposure pathway EPZ of VEGP. The County is responsible for protection of the These counties are similarly organized, public and can provide personnel and with the responsibility for overall radiological emergency response equipment for evacuation, relocation, and planning resting with the chairman of the isolation. county council in each case. It is the

Annex 1.5.2 Aiken, Barnwell, and Allendale chairman's responsibility to initiate Counties South Carolina (SEP A.2.4) actions and provide direction and control Most of the plume exposure pathway EPZ at a level consistent with the specific within South Carolina falls within the site incident. boundary of the Savannah River Site (SRS).

Agencies within these counties which The United States Department of Energy is have a primary role in radiological emergency planning and response responsible for the direction and control of all include the Emergency (Disaster) emergency response actions on the SRS. Preparedness Agency (EPA) and the Limited portions of Aiken, Barnwell, and Sheriffs Department. A detailed Allendale counties are outside of the SRS but discussion of the county response is within the plume exposure pathway EPZ of contained in Annex Q2 to each county's VEGP. These counties are similarly emergency operations plan. organized, with the responsibility for overall The chairman of the county council, or radiological emergency response planning his predesignated alternate (the vice resting with the Chairman of the County chairman, county administrator, or EPA director) may declare an emergency Council in each case. within his respective county and implement offsite protective actions. The chairman or his designee is available 24 h per day. The locations of the county EOCs are indicated in Table C-2. Principal emergency response activities include the followinq: E12-23 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 A.5 AIKEN, BARNWELL, AND ALLENDALE COUNTIES, SOUTH CAROLINA (cont) A.5.1 Aiken County Emergency Preparedness Division, Allendale County Emergency Preparedness Agency, Barnwell County Emergency Management Agency.

a. Maintain communications with South Carolina EMO and VEGP on emergency situation status.

b. Provide information to other county response elements.

c. Activate the county EOC.

d. Activate public notification system if required.

e. Coordinate county emergency response activities.

f. Activate and direct operations at the designated reception facility.

g. Implement protective actions as requested by South Carolina EMD or the chairman, county council, or his predesignated designee.

A.5.2 Sheriffs Department

a. In Barnwell and Aiken*counties, receive notification from VEGP and South Carolina EMO, as primary warning points. This function is performed by the Allendale County Central Dispatch.

b. Provide backup public notification.

c. Provide traffic control and law enforcement in the event of an evacuation.

d. Coordinate access to the plume exposure pathway EPZ.

e. Provide security at EOC.

Other county resources, including Fire Department, Public Works Department, Emergency Medical Services, and Department of Social Services, may be mobilized as described in the county emergency operations plan. E12-24 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 A.5 AIKEN, BARNWELL, AND ALLENDALE COUNTIES, SOUTH CAROLINA (cont) other county resources, including Fire Department, Public Works Department, Emergency Medical Services, and Department of Social Services, may be mobilized as described in the county emergency operations plan. A.6 DEPARTMENT OF ENERGY - Annex 1.6 Department of Energy (DOE) - The wording was standardized and relocated to the SAVANNAH RIVER SITE Savannah River Site (SRS) (SEP A.1.4) Site Annex. A significant portion of the plume The DOE-Savannah River Site (SRS) will exposure pathway EPZ falls within provide the necessary response within the the site boundary of the Savannah SRS reservation in accordance with the SRS River Site (SRS). The United States Emergency Plan. The DOE will exercise Department of Energy - Savannah overall responsibility, jurisdiction, and authority River Operations consists of lands for conducting response operations on the owned or leased by the Federal Savannah River Site to protect the health and government. As such, DOE-SR is safety of SRS personnel. DOE will provide for responsible for the direction and emergency notification and, as needed, control of all emergency response evacuation, monitoring, decontamination, and actions on the SRS. See immediate lifesaving medical treatment of non-memorandum of agreement between SRS personnel on the Savannah River Site. DOE - Savannah River Operations DOE will also provide access control for SRS Office and Georgia Power Company, areas. as assiQned to SNC, (appendix 5). E12-25 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section A.7: VEGP has established EP B.6.2: Agreements with ambulance The commitment wording was standardized and agreements with the Burke County services are in place to transport injured relocated to the SNC Standard Emergency Plan, EMA to provide ambulance service personnel from the plants to the designated and details of services provided were moved to the for the transportation of injured medical facility. Training is provided for the Site Annex. personnel, including people who may transport of contaminated personnel, and be radioactively contaminated, to qualified utility personnel may accompany the hospital facilities for treatment. ambulance. Annex 2.3.3: VEGP has established agreements with the Burke County Emergency Management Agency to provide ambulance service for the transportation of injured personnel, including people who may be radioactively contaminated, to hospital facilities for treatment. Section A. 7: For radiological EP B.6.3: Prior arrangements have been made The commitment wording was standardized and medical emergency training, for medical treatment at a variety of facilities .. relocated to the SNC Standard Emergency Plan agreements have been established SNC-operated nuclear power plants are and details of services provided were moved to the with Tetra Tech. supported, and sites offer training to the Site Annex medical staff in dealing with contaminated injured personnel. Details on the services offered are in the SNC plant's site-specific Annex. Annex 2.3.2: Agreements are in place with the University of Alabama at Birmingham (UAB) Hospital, Burke Medical Center, Doctors Hospital, and Burke County Emergency Management Agency, to provide assistance for injured personnel, including cases involving radioactive contamination. This assistance will be requested whenever necessary in accordance with plant procedures. Medical Specialists, Inc., a group of medical professionals, has agreed to provide treatment services through Burke Medical Center and Doctors Hospital. E12-26 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section A.8.1: GPC/SNC has EP A.3.2: SNC has established an agreement The commitment wording was standardized and established an agreement with with Bechtel Power Corporation to obtain relocated to the SNC Standard Emergency Plan. Bechtel Power Corporation to obtain engineering and construction services which engineering and construction may be required following an accident. services. Section A.8.2: SNC has EP A.3.3: SNC has established an agreement The commitment wording was standardized and established an agreement with with Westinghouse to obtain general services relocated to the SNC Standard Emergency Plan. Westinghouse to obtain general related to nuclear steam supply system (NSSS) services related to nuclear steam operations during and following an accident supply system (NSSS) operations situation. Westinghouse provides the during and following an accident capability to respond on a 24-hour-a-day basis. situation. Westinghouse provides a capability to respond on a 24-hour-a-day basis. Section A.8.3: SNC is a signatory to EP A.4: The Institute of Nuclear Power The commitment wording was standardized and two comprehensive agreements Operations (INPO) aids nuclear utilities in relocated to the SNC Standard Emergency Plan. among electric utility companies: the obtaining resources beyond their usual Nuclear Power Plant Emergency capabilities during recovery from an Response Voluntary Assistance emergency. As one of its roles, INPO will Agreement and the Voluntary assist affected utilities by applying the Assistance Agreement By and resources of the nuclear industry to meet the Among Electric Utilities Involved in needs of an emergency. Transportation of Nuclear Materials. Section A.9: The emergency director EP B.1.1: The Emergency Director's non- The commitment wording was standardized and is specifically authorized to request delegable duties include: relocated to the SNC Standard Emergency Plan. Federal assistance on behalf of

Request federal assistance as needed.

VEGP under the provisions of the National Response Plan. Section C.2: Requests for Federal assistance are directed as needed bv the emerqency director. E12-27 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 A.10 CONCEPT OF OPERATIONS EP 8.1.1: The Emergency Director's non- The commitment wording was standardized and The emergency preparedness delegable duties include: relocated to the SNC Standard Emergency Plan. program for VEGP requires the

Notifications of offsite agencies and coordinated response of several approval of state, local, and NRC organizations. The emergency notifications.

organization for VEGP is described in detail in section B of this plan. The emergency director is the key individual in the VEGP emergency organization; one of his nondelegable responsibilities is the decision to notify the NRC and authorities responsible for offsite emergency measures. The interfaces among the emergency organizations are shown on figure A-1. Section A.10.1: The emergency EP 8.1.1: The ED has the responsibility and The commitment wording was standardized and director will initiate the activation of authority to immediately and unilaterally initiate relocated to the SNC Standard Emergency Plan. the emergency response emergency actions, including providing organization by contacting the states notification of Protective Action of Georgia and South Carolina, Recommendations (PAR) to state and local counties within the plume exposure government organizations responsible for pathway EPZ, the SRS, and the implementing off site emergency measures. NRC. The ED, at their discretion or when Section A.10.2.4: The State is procedurally required, activates the ERO. notified of an emergency at VEGP by the VEGP emergency director. Section A.10.3.3: The state and counties are notified of an emergency at VEGP by the VEGP emergency director. E12-28 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 A.10.1 Continuous Communication EP F.1.2 SNC-operated plants maintain the The wording was standardized and relocated to the Capability capability to make initial notifications to the SNC Standard Emergency Plan and Annex The emergency director will initiate designated offsite agencies 24 hours per day. the activation of the emergency Offsite notifications can be made to state and response organization by contacting county warning points and Emergency the states of Operations Centers from the Control Room, Georgia and South Carolina, Technical Support Center, and Emergency counties within the plume exposure Operations Facility using the ENN. Reliable pathway EPZ, the SRS, and the backup methods have been written into NRG. All these organizations can be procedures. State and county warning points contacted 24 h a day. The state and are continuously staffed. local agencies have continuously manned communication links for the purpose of receiving notification of a Annex 4.1.1 Notification Process (SEP radiological emergency. The SRS is E.2.2.1) a continuously operating facility and State and local warning points are staffed 24 can be contacted at all times. The hours per day. State and local counties Federal agencies which may be surrounding VEGP to be notified within 15 requested by VEGP to provide minutes of the declaration of an emergency assistance can be notified by condition are: contacting the NRC on a dedicated State of Georgia: communication link, the Emergency

Georgia Emergency Management Agency Notification System (ENS) line. (GEMA)

Georgia County Authorities:

Burke - Burke County Emergency Management Agency State of South Carolina:
Emergency Management Division (EMD)

South Carolina County Authorities:

Barnwell and Aiken County - Sheriff's Department
Allendale County - County Central Dispatch De12artment of Energy - Savannah River Site (DOR-SRS)
DOE-SRS Operations Center E12-29 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section B: Initial staffing of the onsite EP B.1: Normal Plant Organization The commitment wording was standardized and emergency organization will be The normal onsite organization of an SNC- relocated to the SNC Standard Emergency Plan.

provided from personnel normally operated nuclear power plant provides a staff The staffing table, documenting the results of the employed at the site. capable of providing the initial response to an On-Shift Staffing Assessment required by Part 50 emergency event. The On-Shift staff was Appendix E.IV.9, is in Section 2, Table 2.2.A of the validated by performing a detailed staffing Site Annex. analysis as required by Part 50 Appendix E.IV.9. Organizational structures for each of the sites and the On-Shift staffing tables are provided in the Site-Specific Annex. The number and ERO position titles of personnel available within 75 minutes following declaration of an Alert or higher classification is shown in Tables 2, 3and 5. SNC plants maintain 24-hour emergency response capability. The normal on-shift complement provides the initial response to an emergency. This group is trained to respond to emergency situations until the augmented Emergency Response Organization (ERO) arrives. The ERO is composed of personnel with specialties in operations, maintenance, engineering, radiochemistry, radiation protection, fire protection, and security. Annex 2.2: An On-Shift Staffing Analysis was completed in accordance with the requirements of 10 CFR 50 Appendix E IV.A.9. This analysis forms the basis for the on-shift staff as described in Table 2. A copy of the analysis is maintained in the SNC document management system. Annex Table 2.2.A E12-30 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Figure B-1 EP 8.1: The normal onsite organization of a The commitment wording was standardized and Section B.1: The normal operating SNC-operated nuclear power plant provides a relocated to the SNC Standard Emergency Plan. crew for two units includes a shift staff capable of providing the initial response to The staffing table, documenting the results of the supervisor, licensed plant operators, an emergency event. The On-Shift staff was On-Shift Staffing Assessment required by Part 50 and non-licensed plant operators. A validated by performing a detailed staffing Appendix E. IV.9, is in Section 2, Table 2 of the Site shift manager is also on shift during analysis as required by Part 50 Appendix Annex. operation (as defined in the E.IV.9. Organizational structures for each of Technical Specifications). the sites and the On-Shift staffing tables are provided in the Site-Specific Annex. Annex 2.2: An On-Shift Staffing Analysis was completed in accordance with the requirements of 10 CFR 50 Appendix E IV.A.9. This analysis forms the basis for the on-shift staff as described in Table 2. A copy of the analysis is maintained in the SNC document management system. Annex Table 2.2.A Section B.1: Personnel from the EP 8.1: The normal onsite organization of a The commitment wording was standardized and Chemistry and Health Physics, SNC-operated nuclear power plant provides a relocated to the SNC Standard Emergency Plan. Maintenance, and Security staff capable of providing the initial response to The staffing table, documenting the results of the Departments are also on site an emergency event. The On-Shift staff was On-Shift Staffing Assessment required by Part 50 continuously. validated by performing a detailed staffing Appendix E.IV.9, is in Section 2, Table 2.2.A of the analysis as required by Part 50 Appendix Site Annex. E.IV.9. Organizational structures for each of the sites and the On-Shift staffing tables are provided in the Site-Specific Annex. Annex 2.2: An On-Shift Staffing Analysis was completed in accordance with the requirements of 10 CFR 50 Appendix E IV.A.9. This analysis forms the basis for the on-shift staff as described in Table 2. A copy of the analysis is maintained in the SNC document management system. Annex Table 2.2.A Section B.2: The emergency EP 8.1.1: The Emergency Director's non- The commitment wording was standardized and director has the responsibility to delegable duties include: relocated to the SNC Standard Emergency Plan. classify an event in accordance with

Event classification in accordance with the the emergency classification system emergency classification system.

E12-31 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section 8.1: The organizational EP 8.1: The normal onsite organization of a The commitment wording was standardized and structure shown on figure 8-1 SNC-operated nuclear power plant provides a relocated to the SNC Standard Emergency Plan. represents the pool of personnel staff capable of providing the initial response to The staffing table, documenting the results of the available on site during normal an emergency event. The On-Shift staff was On-Shift Staffing Assessment required by Part 50 working hours. validated by performing a detailed staffing Appendix E.IV.9, is in Section 2, Table 2 of the Site analysis as required by Part 50 Appendix Annex. E.IV.9. Organizational structures for each of the sites and the On-Shift staffing tables are provided in the Site-Specific Annex. Annex 2.2: An On-Shift Staffing Analysis was completed in accordance with the requirements of 10 CFR 50 Appendix E IV.A.9. This analysis forms the basis for the on-shift staff as described in Table 2. A copy of the analysis is maintained in the SNC document management system. Annex Table 2 Section 8.2: For an NUE, the EP 8.1.1: The Shift Manager (SM) is in direct The commitment wording was standardized and emergency director assigns charge of shift plant operations and is directly relocated to the SNC Standard Emergency Plan. responsibility for making the responsible for the actions of the on-shift crew. appropriate notifications and In an emergency, the SM assumes the directing the proper response. responsibility of the Emergency Director (ED) and takes necessary actions to identify and respond to the emergency until relieved by another qualified ED. The ED has the responsibility and authority to immediately and unilaterally initiate emergency actions, including providing notification of Protective Action Recommendations (PAR) to state and local government organizations responsible for implementinQ off site emerQencv measures. E12-32 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section 8.2: If the event is classified EP H.1: SNC-operated nuclear power plants The commitment wording was standardized and as an Alert, the technical support have established a Technical Support Center relocated to the SNC Standard Emergency Plan. center (TSC), operations support (TSC) and an onsite Operations Support Center center (OSC), and Emergency (OSC), which are staffed and activated within Operations Facility (EOF) will be 75 minutes of the declaration of an Alert or activated. higher classification. EP H.2.1: Staffing and activation of the EOF is mandatory upon declaration of an Alert or higher classification. Section 8.2: For a Site Area EP H.1: SNC-operated nuclear power plants The commitment wording was standardized and Emergency or General Emergency, have established a Technical Support Center relocated to the SNC Standard Emergency Plan. the emergency organization and (TSC) and an onsite Operations Support Center EOF will be fully activated. (Figure 8- (OSC), which are staffed and activated within

3) 75 minutes of the declaration of an Alert or higher classification.

EP H.2.1: Staffing and activation of the EOF is mandatory upon declaration of an Alert or higher classification. Appendix 7 G.1.1: A training matrix EP 0.4: SNC ERO personnel who are The commitment wording was standardized and for corporate personnel assigned to responsible for implementing this plan receive relocated to the SNC Standard Emergency Plan. the ERO is shown in Table 2, and specialized training. training course summaries are EP 0.4.1: ERO members will receive presented in Table 3. Emeroencv Plan trainino on an annual basis. Section 8.2.1: Following an Alert or EP Figures 8.2.8, 8.2.C, 8.2.D and 8.2.E The commitment wording was standardized and higher emergency declaration, the illustrate the standard Emergency Organization relocated to the SNC Standard Emergency Plan. positions shown on figures 8-2 and at the three sites. 8-3 will be filled by VEGP or SNC EP H.1: SNC-operated nuclear power plants personnel. have established a Technical Support Center (TSC) and an onsite Operations Support Center (OSC), which are staffed and activated within 75 minutes of the declaration of an Alert or higher classification. EP H.2.1: The EOF is procedurally required to be activated within 75 minutes following the declaration of an Alert or higher classification. E12-33 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section 8.2.1.1: The emergency EP 8.1.1: In an emergency, the SM assumes The commitment wording was standardized and director has the authority, the responsibility of the Emergency Director relocated to the SNC Standard Emergency Plan. management ability, and knowledge (ED) and takes necessary actions to identify to assume the overall responsibility and respond to the emergency until relieved by for directing VEGP staff in an another qualified ED. The ED has the emergency situation. responsibility and authority to immediately and unilaterally initiate emergency actions, including providing notification of Protective Action Recommendations (PAR) to state and local government organizations responsible for imolementino off site emeroencv measures. Section 8.2.1.1: Initially this position EP 8.1.1: In an emergency, the SM assumes The commitment wording was standardized and (Emergency Director) will be filled by the responsibility of the Emergency Director relocated to the SNC Standard Emergency Plan. the shift manager or the shift (ED) and takes necessary actions to identify supervisor if the shift manager can and respond to the emergency until relieved by not be located expeditiously. another qualified ED. The ED has the responsibility and authority to immediately and unilaterally initiate emergency actions, including providing notification of Protective Action Recommendations (PAR) to state and local government organizations responsible for implementing off site emergency measures. Section 8.2.1.1: The responsibility EP 8.1.1: In an emergency, the SM assumes The commitment wording was standardized and for emergency direction will be the responsibility of the Emergency Director relocated to the SNC Standard Emergency Plan. transferred to the plant manager or (ED) and takes necessary actions to identify an alternate after receiving an and respond to the emergency until relieved by appropriate briefing and becoming another qualified ED. The ED has the familiar with the current status of responsibility and authority to immediately and events. unilaterally initiate emergency actions, including providing notification of Protective Action Recommendations (PAR) to state and local government organizations responsible for imolementino off site emeroencv measures. E12-34 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section B.2.1.1: Turnover with the EP B.1.1: In an emergency, the SM assumes The SNC Standard Emergency Plan maintains the accompanying briefing will include, the responsibility of the Emergency Director commitment to staff the position and defines the but is not limited to, the following: (ED) and takes necessary actions to identify responsibilities. Conduct of the turnover is Review of logs and status boards. and respond to the emergency until relieved by completed in accordance with site-specific EPIPs. Discussion with the incumbent another qualified ED. including emergency classification, summary of events, offsite notifications, plant status, equipment status, outstanding orders, any noted deficiencies and completed checklist items. Discussion with staff, as needed. Sec.tion B.2.2.2: Following relief (of EP B.1.1: In an emergency, the SM assumes No equivalent Plan Statement. The SNC Standard ED) announcement will be made to the responsibility of the Emergency Director Emergency Plan maintains the commitment to staff staff of the transfer of responsibility (ED) and takes necessary actions to identify the ED initially by the Shift Manager and perform and respond to the emergency until relieved by relief in accordance with Plan commitments. another qualified ED. Conduct of the turnover is procedural level information. Section B.2.1.1: They (Emergency EP 0.1: The ERO Training Program ensures The commitment wording was standardized and Directors) will receive training as the training, qualification, and requalification of relocated to the SNC Standard Emergency Plan. specified in table 0-2 of this plan individuals who may be called on for assistance prior to becoming qualified to fill this during an emergency. Specific emergency position. response task training, prepared for response positions, is described in lesson plans and study guides. The lesson plans, study guides, and written tests are contained in the ERO Training Program. E12-35 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section B.2.1.1: The emergency EP 8.1.1: The Shift Manager (SM) is in direct The commitment wording was standardized and director manages the following charge of shift plant operations and is directly relocated to the SNC Standard Emergency Plan. activities for the duration of the responsible for the actions of the on-shift crew. emergency: In an emergency, the SM assumes the Notification and communication: responsibility of the Emergency Director (ED) directs the notification of VEGP, SNC and takes necessary actions to identify and and GPC personnel and notifies and respond to the emergency until relieved by maintains open communications with another qualified ED. The ED has the offsite authorities regarding all aspects responsibility and authority to immediately and of emergency response. unilaterally initiate emergency actions, Emergency response facilities: including providing notification of Protective oversees the activation and staffing and requests additional assistance, as Action Recommendations (PAR) to state and needed. local government organizations responsible for Emergency operations: has authority implementing off site emergency measures. over those actions taken to mitigate The ED, at their discretion or when the emergency condition or reduce the procedurally required, activates the ERO. threat to the safety of plant personnel The Emergency Director's non-delegable or the public, including the duties include: recommendation of protective actions

Event classification in accordance with the to offsite authorities. emergency classification system.

Emergency services: provides overall

Perform the duties and responsibilities of direction for management of Protective Action Recommendation (PAR) procurement of site needed materials, determination.

equipment, and supplies;

Notifications of offsite agencies and documentation; accountability; and approval of state, local, and NRC security functions.

notifications. Emergency operations planning: provides overall direction for the

Authorization of emergency exposures in management of planning for excess of federal limits.

procedure, equipment, and system

Issuance of potassium iodide (Kl) to plant development to support emergency employees as a thyroid blocking agent.

operations.

Request federal assistance as needed.

Discretionary authority: can modify emergency implementing procedures; may tailor the emergency organization to fit the specific staffing needs on a case by case basis. E12-36 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section B.2.1.1: The emergency EP B.1.1: The Emergency Director's non- The commitment wording was standardized and director may not delegate the delegable duties include: relocated to the SNC Standard Emergency Plan. following responsibilities:

Event classification in accordance with the The decision to notify offsite emergency classification system.

emergency response agencies.

Perform the duties and responsibilities of The decision to recommend Protective Action Recommendation (PAR) protective actions to offsite determination.

authorities.

Notifications of offsite agencies and Declaration of emergency approval of state, local, and NRC classifications. notifications.

Authorization for plant personnel to

Authorization of emergency exposures in exceed 10 CFR 20 radiation excess of federal limits.

exposure limits.

Issuance of potassium-iodide (Kl) to plant The decision to terminate the employees as a thyroid blocking agent.

emergency.

Request federal assistance as needed.

Request for Federal assistance. The decision to order site dismissal of non-involved personnel from the site at an Alert classification level. The decision to order non-involved personnel to proceed to a reception center and receive radiological monitorino. E12-37 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section 8.2.1.2.a: The TSC EP 8.2.1.2: The TSC Manager reports to the The commitment wording was standardized and manager performs the following TSC ED and is responsible for coordinating relocated to the SNC Standard Emergency Plan. activities: activities between the TSC and other Coordination of inputs and emergency response facilities, directing the recommendations from technical and activities of the TSC staff, and ensuring corrective action advisors. communications are established with Direction of onsite emergency applicable offsite agencies. personnel involved in restoration of the plant to a safe condition. Technical assistance and operations guidance to control room personnel. Direction of TSC staff in analysis of problems, design and planning for temporary modifications, and development of temporary emergency operating procedures. Recommendation of protective actions to the emergency director based on plant conditions. Providing recommendations on emergency classifications to the emerQency director. Section 8.2.1.2.b: The TSC support EP 8.2.1.15: The Support Coordinator reports The commitment wording was standardized and coordinator directs the clerical and to the TSC Manager and directs the clerical* relocated to the SNC Standard Emergency Plan. logistic activities in the TSC. and logistic activities in the TSC, ensures support staff, including clerks, status board keepers, and communicators, are available in sufficient numbers, and ensures office supplies, drawings, and other documents are available to TSC and OSC personnel. Section 8.2.1.2.c: The engineering EP 8.2.1.7: The Engineering Supervisor The commitment wording was standardized and supervisor directs a staff of reports to the TSC Manager. The TSC relocated to the SNC Standard Emergency Plan. engineers with expertise in reactor Engineering Supervisor is responsible for the engineering, thermal and hydraulic overall direction of Engineering Group activities analysis, instrumentation and and assessment. The Engineering Supervisor control, and mechan!cal and also directs the analysis of plant problems and electrical systems. core damage, and provides recommendations for plant modifications to mitigate the effects of the accident. E12-38 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section 8.2.1.2.d: The maintenance EP 8.2.1.4: The Maintenance Supervisor The commitment wording was standardized and supervisor manages the planning reports to the TSC Manager and is responsible relocated to the SNC Standard Emergency Plan. and coordination of repair, damage for planning and coordination of repair, control, and plant modification damage control, and plant modification activities. activities. The Maintenance Supervisor works closely with the Engineering Supervisor in planning for plant modifications and repairs. Section 8.2.1.2.e: The operations EP 8.2.1.3: The Operations Supervisor reports The commitment wording was standardized and supervisor analyzes problems to the TSC Manager. Major position functions relocated to the SNC Standard Emergency Plan. associated with systems operations include evaluating plant conditions and and provides recommendations for initiating mitigation actions, coordinating TSC procedures for mitigating the efforts in determining the nature and extent of emergency situation. plant conditions affecting plant equipment, actions to limit or contain the emergency, invoking the provisions of 10 CFR 50.54(x) if appropriate, assisting the OSC Manager in determining the priority assigned to OSC activities, and timely completing offsite notifications. Section 8.2.1.2.h: The TSC security EP 8.2.1.14: The Security Supervisor reports The commitment wording was standardized and supervisor coordinates the security to the TSC Manager. The TSC Security relocated to the SNC Standard Emergency Plan. functions including accountability Supervisor is responsible for carrying out the and site access control. When plant security and Access Control program, directed by the emergency director, maintaining personnel accountability onsite, will request assistance from civil law and assisting in evacuation of onsite areas. enforcement authorities, as reauired. Section 8.2.1.3.a: The OSC EP 8.2.2.1: The OSC Manager reports to the The commitment wording was standardized and manager directs composition of the TSC Manager and directs a staff in providing relocated to the SNC Standard Emergency Plan. teams to ensure that appropriately labor, tools, protective equipment and parts qualified personnel are assigned. needed for emergency repair, damage control, He will also maintain firefighting, search and rescue, first aid, and communications with the teams that recovery. remain assigned to the OSC and monitor the status of their activities. E12-39 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section B.2.1.2.f: The health physics EP 8.2.1.5: The RP Supervisor reports to the The commitment wording was standardized and supervisor is responsible for onsite TSC Manager and supervises the activities of relocated to the SNC Standard Emergency Plan. and in-plant radiological controls. the radiation protection staff and Health Physics Network (HPN) Communicator. The RP Supervisor assists the Radiation Protection/Chemistry Group Lead in the OSC in determining the extent and nature of radiological or hazardous conditions and coordinates offsite dose assessment and offsite Field Monitoring Teams prior to EOF activation. Section B.2.1.2.g: The chemistry EP 8.2.1.10: The TSC Chemistry Support The Chem Supervisor was replaced with supervisor is responsible for reports to the RP Supervisor. The TSC Chemistry Support position reporting to the RP directing and evaluating in-plant Chemistry Support is responsible for directing Supervisor in the TSC. This change was to chemistry and analyses, directing and evaluating in-plant chemistry and facilitate the standardization of the ERO across the and evaluating post accident analyses, directing and evaluating post- Fleet. sampling, and assisting in core accident sampling, and assisting in core damage assessment. damage assessment. The duties of the equivalent Chemistry Support position will remain the same. Section B.2.1.3.b: The following EP 8.2.2.7: The following emergency teams The commitment wording was standardized and emergency teams will be formed as may be formed by OSC personnel, as relocated to the SNC Standard Emergency Plan. necessary: necessary: Backup fire brigade.

Search and rescue. The site provides a trained qualified fire brigade in Search and rescue.
Repair. accordance with the Fire Plan. The duties of the First aid.
Post-accident sampling. Fire Brigade are validated by staffing analyses Damage assessment.
Internal survey. performed in accordance with 10 CFR 50 Appendix Damage control.
Field monitoring. E.IV.A.9.

Repair and modification. Field monitoring. Back-up fire brigade support is provided by offsite fire companies as maintained by the Letters of Agreement. Section B.3.b: Depending on the EP 8.2.2.7: Selected personnel report to the The commitment wording was standardized and nature of the emergency, personnel OSC, as directed. Emergency personnel from relocated to the SNC Standard Emergency Plan. from the Maintenance, Operations, the Maintenance, Operations, and Chemistry and Health Physics RP/Chemistry Departments are directed to Departments will be directed to report to the OSC. report to the OSC. E12-40 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section B.2.1.3.b: Each team will be EP 8.2.2.7: OSC teams are headed by a The commitment wording was standardized and headed by a designated team designated team leader, who maintains relocated to the SNC Standard Emergency Plan. leader, who will maintain communication with the OSC. communications with the OSC, TSC, or EOF. Section B.2.2: Table B-2 identifies by EP Figures 8.2.8 through 8.2.E illustrate the The commitment wording was standardized and title the individuals who will fill the ERO organization relocated to the SNC Standard Emergency Plan. key emergency positions. Section B.2.2: A sufficient number of EP 8.1: SNC plants maintain 24-hour The commitment wording was standardized and people are identified to ensure that emergency response capability. The normal relocated to the SNC Standard Emergency Plan. all emergency positions on table B-2 on-shift complement provides the initial will be filled. response to an emergency. This group is trained to respond to emergency situations until the augmented Emergency Response Organization (ERO) arrives. The ERO is composed of personnel with specialties in operations, maintenance, engineering, radiochemistry, health physics, fire protection, and security. E12-41 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63

4. EOF STAFF EP 8.3 Offsite Emergency Response The commitment wording was standardized, the

The EOF staff is described in Organization (ERO) offsite ERO integrated into the Base Plan, and Appendix 7 The EOF and JIC Organizations consist of staff relocated to the SNC Standard Emergency Plan.

members from the SNC, Alabama Power Company and Georgia Power Company corporate offices. This organization is responsible for providing offsite emergency response support and resources as needed. The EOF and JIC Organizations are displayed in Figures B.1.D and B.1.E. EP 8.3.1 EOF Organization The EOF Organization consists of selected management and staff members located in the SNC Corporate Office. This organization is responsible for providing offsite emergency response support and resources, as needed. The EOF Organization is displayed on Figure B.1.D. When the EOF is activated, EOF staff electronic devices are activated, and EOF personnel are expected to report to the EOF. Personnel who are not needed to augment positions are briefed and dismissed with a standby status. E12-42 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section B.2.3.1: Arrangements have EP A.3.2. Bechtel Power Corporation The commitment wording was standardized and been made to obtain support SNC has established an agreement with relocated to the SNC Standard Emergency Plan. services from Bechtel Power Bechtel Power Corporation to obtain Corporation and Westinghouse. engineering and construction services which may be required following an accident. EP A.3.3 Westinghouse SNC has established an agreement with Westinghouse to obtain general services - related to nuclear steam supply system (NSSS) operations during and following an accident situation. Westinghouse provides the capability to respond on a 24-hour-a-day basis. EP C.4.2.3: Under established contracts, the following will supply available engineering expertise, specialized equipment, and other services identified as needed and deemed appropriate to provide in an emergency situation:

General Electric (GE) Nuclear Energy.
Westinqhouse Electric Comoanv.

Section B.2.3.2: Agreements are in Annex 2.3.2: Agreements are in place with the The commitment wording was standardized and place with Tetra Tech, Burke Medical University of Alabama at Birmingham (UAB) relocated to the Site Annex. Center, Doctors Hospital, and Burke Hospital, Burke Medical Center, Doctors County Emergency Management Hospital, and Burke County Emergency Agency to provide assistance and Management Agency to provide assistance for training for injured personnel, injured personnel, including cases involving including cases involving radioactive radioactive contamination. This assistance will contamination. be requested whenever necessary in accordance with plant procedures. Medical Specialists, Inc., a group of medical professionals, has agreed to provide treatment services through Burke Medical Center and Doctors Hospital. E12-43 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Table B-1: All EP 8.1: SNC plants maintain 24-hour The commitment wording was standardized and Section L.1: Personnel to perform emergency response capability. The normal relocated to the SNC Standard Emergency Plan. first aid and decontamination will be on-shift complement provides the initial available 24-h a day as identified in response to an emergency. This group is Section B, Table B-1. trained to respond to emergency situations until the augmented Emergency Response Organization (ERO) arrives. Annex Table 2.2.A Table B-2: All No Equivalent Plan Table The table was not carried forward to the SNC Standard Emergency Plan. Specific responsibilities are maintained as discussed throughout this section of the Justification Matrix. Section B: Figure B-1 EP Figure P.1 The commitment wording was standardized and relocated to the SNC Standard Emeraencv Plan. C.1 STATE AND LOCAL EP A.2.2.1 Georgia Emergency The wording was standardized and relocated to the GOVERNMENTAL SUPPORT Management Agency (GEMA) SNC Standard Emergency Plan. The State of Georgia through the As the overall state coordinating agency Georgia Emergency Management GEMA will coordinate with Department of A more detailed description of state support is Agency (GEMA) has the lead agency Natural Resources-Environmental Protection provided in the references to the left. responsibility for responding to Division (DNR-EPD) on emergency response emergency situations throughout activities with state, county and municipal Georgia. Under the procedure agencies and departments as stated in the established by the Georgia Georgia Emergency Operations Plan (GEOP). Emergency Operations Plan (EOP), GEMA provides for 24-hour notification and which was developed pursuant to the staffing of the State Operations Center (SOC) Governor's and/or the Forward Emergency Operations Executive Order, the Department of Center (FEOC), as required, throughout the Natural Resources (DNR) event. radiological emergency response GEMA is responsible for general state team in coordination with GEMA emergency planning and overall direction and assesses the radiological conditions control of emergency or disaster operations as at the site of an incident and assigned by executive order and in determines whether a state of accordance with the Georgia Emergency emergency should be declared. The Operations Plan (GEOP). GEMA has Governor of the State of Georgia or responsibilities for coordinating the state of GEMA can declare an emergency Georgia response to emergencies at nuclear based upon the assessment made power plants. by GEMA and/or DNR. E12-44 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 The South Carolina agencies EP A.2.3 State of South Carolina The wording was standardized and relocated to the responsible for responding to a EP A.2.3.1 Emergency Management SNC Standard Emergency Plan. radiological emergency are the Division (EMO) Office of the Adjutant The EMO is assigned the responsibility for A more detailed description of state support is General, Emergency Management coordinating the emergency planning efforts of provided in the references to the left. Division (EMO) and the Department state, county, and municipal agencies in of Health and Environmental Control accordance with the South Carolina (DHEC). The Nuclear Emergency Radiological Emergency Response Plan Planning Section within DHEC is (SCORERP); conducting a preparedness given the primary role in responding program to assure capability of the government to the technical aspects of a nuclear to execute the plan; establishing and accident: assessment of the maintaining a state EOC and providing support radiological consequences and of the state emergency staff and work force; provision of protective action and establishing an effective system for guidelines to state and local reporting, analyzing, and disseminating authorities, through the EMO. The emergency information. EMO is assigned primary responsibility for the planning effort and for coordinating the state response operations. Jointly with - DHEC, EMO determines whether a state of emergency should be declared. Upon EMD's advising the Governor of South Carolina that a radiological emergency exists, the Governor declares an emerQencv. E12-45 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Agreements are in place with the EP A.2.4 Emergency Planning Zone (EPZ) The wording was standardized and relocated to the State of Georgia, Burke County, Counties SNC Standard Emergency Plan and Site Annex. Georgia, and Aiken, Allendale, and The Emergency Management Agencies Barnwell Counties in South Carolina, representing the counties of Aiken, Allendale, to provide available resources and Appling, Barnwell, Burke, Early, Henry, Houston, equipment to support the mitigation Jeff Davis, Tattnall, and Toombs have the and response to an emergency at responsibility for notification and providing Plant Vogtle to include Hostile Action direction to residents in the event of an emergency that affects their respective Based events. These resources jurisdiction. The 24-hour notification points have include, but are not limited to, the responsibility to notify necessary local civil Local Law Enforcement Agency support groups in the event of an accident. The (LLEA) assets, Firefighting assets, County is responsible for protection of the public medical support resources (including and can provide personnel and equipment for transportation) and coordination evacuation, relocation, and isolation. through an Incident command Post. Annex 1.5.1 Burke County Georgia (SEP Requests for offsite resources and A.2.4) equipment will be communicated The area within the plume exposure pathway from the control room to the Burke (EPZ) in the state of Georgia falls within Burke County 911 Center or through the County. The responsibility for overall radiological Incident Command Post as emergency response planning rests with the applicable based on the nature and Chairman, Burke County Board of timing of the event. Copies of these Commissioners. It is the chairman's agreements are maintained in the responsibility to initiate actions and provide SNC document management system direction and control at a level consistent with the and are included by reference in specific incident. Appendix 2. Annex 1.5.2 Aiken, Barnwell, and Allendale Counties South Carolina (SEP A.2.4) Most of the plume exposure pathway EPZ within South Carolina falls within the site boundary of the Savannah River Site (SRS). The United States Department of Energy is responsible for the direction and control of all emergency response actions on the SRS. Limited portions of Aiken, Barnwell, and Allendale counties are outside of the SRS but within the plume exposure pathway EPZ ofVEGP. These counties are similarly organized, with the responsibility for overall radiological emergency response planning resting with the Chairman of the County Council in each case. E12-46 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 C.2 FEDERAL GOVERNMENTAL SECTION A: ASSIGNMENT OF The commitment was standardized and relocated SUPPORT RESPONSIBILITY to the SNC Standard Emergency Plan and Site In addition to coordination with EP A.1 Primary Federal Organizations Annex. State/county governmental entities in EP A.1.1 Nuclear Regulatory Commission an emergency situation, VEGP may (NRC) require assistance from certain The NRC is the coordinating agency for Federal agencies in the areas of incidents at or caused by a facility or an activity communications, radiological that is licensed by the NRC or an Agreement monitoring and laboratory analysis, State, with the Chairman of the Commission as transportation, and disaster relief. the senior NRC authority for response. The Requests for Federal assistance are Chairman can transfer control of emergency directed as needed by the response activities when deemed appropriate. emergency director, and usually Incident Response Centers have been these requests are channeled established at the four NRC regional offices through GEMA. The exceptions to and NRC headquarters, to centralize and this procedure are direct contacts coordinate NRC's emergency response. between the VEGP Emergency Provision is made for NRC personnel at the Organization, the Nuclear Regulatory plant's Technical Support Center and the Commission (NRC), and Department Emergency Operations Facility. of Energy, Savannah River (DOE- EP A.1.2 Department of Homeland Security SR). (OHS) In accordance with the National Response Framework (NRF), DHS is responsible for the overall coordination of a multi-agency federal response to a significant radiological incident. EP A.1.3 Federal Emergency Management Agency (FEMA) The primary role of FEMA is to support the states by coordinating the delivery of federal non-technical assistance. FEMA coordinates state requests for federal assistance, identifying which federal agency can best address specific needs. If deemed necessary, FEMA will establish a nearby Joint Field Office from which it will manage its assistance activities. E12-47 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 C.2 FEDERAL GOVERNMENTAL EP A.1.4 Department of Energy (DOE) SUPPORT (cont) The DOE provides radiological assistance on request, and has radiological monitoring equipment and personnel resources that it can assemble and dispatch to the scene of a radiological incident. Following a radiological incident, DOE operates as outlined in the Federal Radiological Monitoring and Assessment Plan (FRMAP). The Radiological Assistance Team can be expected to respond to SNC-operated sites as directed by the Savannah River Operations Office of DOE. EP A.1.5 Federal Bureau of Investigation (FBI) Support from the FBI is available through its statutory responsibility, based in public law and the US code, and through a memorandum of unde~standing for cooperation with the NRC. Notification to the FBI of emergencies in which they would have an interest will be through the provisions of a plant security plan, or by the NRC. EP A.1.6 National Weather Service (NWS) NWS provides meteorological information during emergency situations, if required. Data available will include existing and forecasted wind directions, wind speeds, and ambient air temperatures. EP A.1. 7 Environmental Protection Agency (EPA) The EPA cari assist with field radiological monitoring, sampling, and non-plant related recovery and reentry guidance. E12-48 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 C2FEDERALGOVERNMENTAL Annex 1.6 Department of Energy (DOE) - SUPPORT (cont) Savannah River Site (SRS) (SEP A.1.4) The DOE-Savannah River Site (SRS) will provide the necessary response within the SRS reseNation in accordance with the SRS Emergency Plan. The DOE will exercise overall responsibility, jurisdiction, and authority for conducting response operations on the Savannah River Site to protect the health ahd safety of SRS personnel. DOE will provide for emergency notification and, as needed, evacuation, monitoring, decontamination, and immediate lifesaving medical treatment of non-SRS personnel on the Savannah River Site. DOE will also provide access control for SRS areas. C.3 VEGP SUPPORT EP H.1.2: The TSG is sized to accommodate The commitment wording was standardized and VEGP provides space, telephone ERO responders and NRG Representatives. relocated to the SNG Standard Emergency Plan communications, and administrative EP H.2.1: The EOF is capable of and Site Annex. seNices for NRC and FEMA accommodating designated SNC personnel personnel at the TSC and EOF. Up and offsite local, state, and federal responders to five NRG representatives can be including NRG and FEMA. accommodated EP Figure H.2.A: EOF Layout at the TSC. In the EOF, space is Annex 5.1.2: The TSG provides plant provided for nine NRG personnel management and technical support personnel and one FEMA representative. NRG with a facility from which they can assist plant representatives may also be present operating personnel located in the control in the control room. room during an emergency. The emergency director and NRC director will be co-located to ensure proper communications. Annex Figure 5.1.A: TSC Layout EP Figure H.2.A: EOF Layout EP H.2.1: The EOF is capable of accommodating designated SNG personnel and offsite local, state, and federal responders including NRC and FEMA. E12-49 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix

 -current Vogtle Emergency Plan              Revised SNC Emergency Plan                                   Justification Revision 63 Section C.3 Emergency notification    EP F .1.4.1: This communications line provides   The commitment wording was standardized and system (ENS) telephones and           a communications link to the NRC Operations      relocated to the SNC Standard Emergency Plan.

commercial telephones are available Center in Rockville, Maryland, and is used for in the control room, TSC, and EOF. continuous communications in a classified The current design of the FTS system allows any emergency. EP F Table 5 phone with long distance capability be used as the specific phone as previously indicated. The specific locations of the phones are no longer needed. Section C.3: Health physics network EP F.1.4.2: This communications line provides The commitment wording was standardized and (HPN) telephones are available in a communications link with the NRC to provide relocated to the SNC Standard Emergency Plan. the TSC and the EOF. radiological information. EP F Table 5 The current design of the FTS system allows any phone with long distance capability be used as the specific phone as previously indicated. The specific locations of the phones are no longer needed. Section C.4: The onsite laboratory is EP C.3: The onsite laboratory/counting room at The commitment wording was standardized and equipped to analyze all normal in- SNC-operated nuclear power plants are the relocated to the SNC Standard Emergency Plan. plant samples. primary facility for radiation monitoring and Section C.4: The *equipment includes analysis effort. The onsite laboratory is the an ion chromatograph, gas central point for receipt and analysis of onsite chromatograph, gamma samples and includes equipment for chemical spectrometer, and other analytical and radiological analyses. The plant support equipment. laboratories have the capability of quantitative analysis of marine and air samples, and qualitative analysis of terrestrial samples. Section C.4: Field samples will be EP 1.7: The environmental monitoring The commitment wording was standardized and taken by VEGP field monitoring equipment includes portable survey, counting, relocated to the SNC Standard Emergency Plan. teams. and air sampling instrumentation and other Section C.4: These teams will take radiological monitoring equipment and supplies direct radiation readings and will to be used by the FMTs. collect air samples, soil samples, vegetation samples, and water samples as directed by the dose assessment manager. Section C.4: The samples will be EP H.10: SNC-operated nuclear power plants The commitment wording was standardized and scanned with field instrumentation have designated a point as the location for relocated to the SNC Standard Emergency Plan. and will then be taken to VEGP for receipt and analysis of field monitoring team laboratory analyses. environmental samples. E12-50 2 to NL-16-0169 Vogtfe (Units 1 & 2) Justification Matrix . Current Vogtle Emergency Plan Revise~ SNC Emergency Plan Justification Revision 63 Section C.4: Environmental samples EP H.6.2: SNC-operated nuclear power plants The commitment wording was standardized and will be collected by corporate have a Radiological Environmental Monitoring relocated to the SNC Standard Emergency Plan. personnel. These samples will be Program (REMP) consisting of locations with obtained from the current fixed dose recording devices and air sampling The specification that the sampling was conducted environmental program. equipment. by corporate personnel was eliminated. However, EP 1.7: The capability to take offsite soil, water, the commitment to maintain the program was and vegetation samples is provided by a maintained. minimum of two (2) Field Monitoring Teams (FMTs). Section C.4: In-plant samples such EP H.5.2.2: The process sampling system The commitment wording was standardized and as effluent and air samples will be consists of the normal sampling system and relocated to the SNC Standard Emergency Plan. analyzed using a gamma additional sampling panels located throughout spectrometer located in the counting the plant. Pre-designated monitoring and The specific wording to perform the .analysis by room. sampling points are listed in site procedures. gamma spectroscopy was eliminated to permit Sampling systems are installed or can be flexibility as new equipment is developed and modified to permit reactor coolant and processes revised .. The commitment to maintain containment atmosphere sampling even under the ability to perform the analysis is maintained in severe accident conditions. The system can the Plan. provide information on post-accident plant conditions to allow operator actions to mitigate and control the course of an accident. Various chemical analyses and radiological measurements on these samples can be performed, including the determination of radionuclide concentrations. Section D.1: The described EP D.1.1.1: The classification scheme is The commitment wording was standardized and emergency classes and the provided to and discussed by Southern relocated to the SNC Standard Emergency Plan emergency action levels which Nuclear Company, agreed upon by state and and Site Annex. determine them are agreed on by county governmental authorities and approved VEGP and State and local by the NRC. authorities. The emergency action levels will be reviewed by these Annex 3.1.1: The described emergency parties annually. classes and the emergency action levels that determine them are agreed on by SNC and state and local authorities. The emergency action levels will be reviewed by these (state and local) officials annually. E12-51 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section D.2.1.2: VEGP ACTIONS EP 8.1: SNC plants maintain 24-hour The commitment wording was standardized and (NUE) emergency response capability. The normal relocated to the SNC Standard Emergency Plan.

a. Inform State and local offsite on-shift complement provides the initial authorities of the nature of the response to an emergency. This group is The SNC Standard Emergency Plan was unusual event within 15 min. of trained to respond to emergency situations standardized to address overall response classifying the emergency. Notify until the augmented Emergency Response requirements rather than repeat listings by the Nuclear Regulatory Commission Organization (ERO) arrives. Classification Level. No change was made in the (NRC) as soon as possible (ASAP) EP E.1.1: SNC-operated plants maintain the expectations/commitments for response.

but no later than 1 h following capability of notifying state and local agencies classification of the emergency. within 15 minutes of a declared emergency as

b. Augment on-shift resources, required by 1 OCFR50 Appendix E, section as needed. IV(D)(3). NRC will be notified, by the impacted

c. Assess and respond to the site immediately following state and local event. notifications, but within an hour of an

d. Escalate to a more severe emergency classification using ENS.

class, if appropriate, or close out with EP E.2.2.1: State and local agencies listed in a verbal summary to offsite the site-specific Annexes shall be notified authorities followed by a written within fifteen (15) minutes of: summary within 24 h.

The initial emergency classification.
Classification change.
The issuance of, or change to, a Protective Action Recommendation (PAR).

E12-52 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section D.2.2.2: VEGP ACTIONS EP B.1: SNC plants maintain 24-hour The commitment wording was standardized and (Alert) emergency response capability. The normal relocated to the SNC Standard Emergency Plan.

a. Within 15 min. of classification, on-shift complement provides the initial inform State and local offsite response to an emergency. This group is The SNC Standard Emergency Plan was authorities of Alert Emergency and trained to respond to emergency situations standardized to address overall response reasons for emergency. Notify the until the augmented Emergency Response requirements rather than repeat listings by NRG ASAP but no later than 1 h Organization (ERO) arrives. Classification Level. No change was made in the following classification of the EP E.1.1: SNC-operated plants maintain the expectations/commitments for response.

emergency. capability of notifying state and local agencies

b. Augment resources and activate within 15 minutes of a declared emergency as the emergency response facilities required by 10CFR50 Appendix E, section (e.g. Technical Support Center IV(D)(3). NRG will be notified by the impacted (TSC), Operational Support Center site immediately following state and local (OSC), and the emergency operating notifications, but within an hour of an facility (EOF). These actions may be emergency classification using ENS.

delayed for security based events at EP E.2.2.1: State and local agencies listed in the discretion of the emergency the site-specific Annexes shall be notified director. within fifteen (15) minutes of:

c. Assess and respond to the

The initial emergency classification.

emergency.

Classification change.

d. Mobilize, and dispatch if

The issuance of, or change to, a Protective necessary, onsite survey teams. Action Recommendation (PAR).

e. Provide periodic plant status EP E.2.3: The Emergency Response Data updates to offsite authorities. System EROS will be initiated within one hour

f. Provide periodic meteorological of the declaration of an Alert or higher assessments to offsite authorities classification.

and, if any emergency releases are occurring, field monitoring team readings or dose estimates for actual releases.

g. Activate the Emergency Response Data System for the affected unit within 1 h following declaration of the Alert.

h. Escalate to a more severe class, if appropriate, or close out emergency class by verbal summary to offsite authorities followed by written summarv within 8 h of closeout.

E12-53 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section D.2.2.3: VEGP ACTIONS EP B.1: SNC plants maintain 24-hour The commitment wording was standardized and (SAE) emergency response capability. The normal relocated to the SNC Standard Emergency Plan.

a. Within 15 min. of classification, on-shift complement provides the initial inform State and local offsite responseto an.emergency. This group is The SNC Standard Emergency Plan was authorities of Site Area Emergency trained to respond to emergency situations standardized to address overall response and reasons for emergency. Notify until the augmented Emergency Response requirements rather than repeat listings by the NRG ASAP but no later than 1 h Organization (ERO) arrives. Classification Level. No change was made in the following classification of the EP E.1.1: SNC-operated plants maintain the expectations/commitments for response.

emergency. capability of notifying state and local agencies

b. If necessary, provide protective within 15 minutes of a declared emergency as action recommendations to State required by 10CFR50 Appendix E, section and local authorities. IV(D)(3). NRC will be notified by the impacted

c. Augment resources and activate site immediately following state and local the emergency response facilities no,tifications, but within an hour of an (e.g. Technical Support Center emergency classification using ENS.

(TSC), Operational Support Center EP E.2.2.1 : State and local agencies listed in (OSC), and the Emergency the site~specific Annexes shall be notified Operating Facility (EOF. These within fifteen (15) minutes of: actions may be delayed for security

The initial emergency classification.

based events at the discretion of the -. Classification change. emergency director.

The issuance of, or change to, a Protective

d. Assess and respond to the Action Recommendation (PAR).

emergency.

e. Dispatch as necessary onsite and .

offsite survey teams.

f. Dedicate individuals for plant status updates to offsite authorities and periodic press briefings.

g. On a periodic basis, make senior technical and management staff available for consultation with the NRG and State officials.

E12-54 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section D.2.2.3: VEGP ACTIONS EP E.2.2.1: State and local agencies listed in (SAE) (Continued) the site-specific Annexes shall be notified

h. Provide meteorological data and within fifteen (15) minutes of:

field monitoring team readings or

The initial emergency classification.

dose estimates to offsite authorities.

Classification change.

i. Provide release and dose

The issuance of, or change to, a Protective projections based on available plant Action Recommendation (PAR).

condition information and EP E.2.3: The Emergency Response Data foreseeable contingencies. System EROS will be initiated within one hour

j. Activate the Emergency Response of the declaration of an Alert or higher Data System for the affected unit classification.

within 1 h following declaration of the Site Area Emergency.

k. Escalate to General Emergency, if appropriate, or close out emergency class by briefing of offsite authorities followed by written summary within 8 h of closeout or class reduction.

E12-55 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section D.2.2.4: VEGP ACTIONS EP 8.1: SNC plants maintain 24-hour The commitment wording was standardized and (GE) emergency response capability. The normal relocated to the SNC Standard Emergency Plan.

a. Within 15 min. of classification, on-shift complement provides the initial inform State and local offsite response to an emergency. This group is The SNC Standard Emergency Plan was authorities of General Emergency trained to respond to emergency situations standardized to address overall response and reason for emergency. Notify until the augmented Emergency Response requirements rather than repeat listings by the NRC ASAP but no later than 1 h Organization (ERO) arrives. Classification Level. No change was made in the following classification of the EP E.1.1: SNC-operated plants maintain the expectations/commitments for response.

emergency. capability of notifying state and local agencies

b. Provide protective action within 15 minutes of a declared emergency as recommendations to State and local required by 10CFR50 Appendix E, section authorities based upon plant IV(D)(3). NRC will be notified by the impacted conditions and/or actual or projected site immediately following state and local releases of radioactive material. notifications, but within an hour of an

c. Augment resources and activate emergency classification using ENS.

the emergency response facilities EP E.2.2.1: State and local agencies listed in (e.g. Technical Support Center the site-specific Annexes shall be notified (TSC), Operational Support Center within fifteen (15) minutes of: (OSC), and the Emergency

The initial emergency classification.

Operating Facility (EOF)). These

Classification change.

actions may be delayed for security

The issuance of, or change to, a Protective based events at the discretion of the Action Recommendation (PAR).

emergency director. EP E.2.3: The Emergency Response Data

d. Assess and respond to the System EROS will be initiated within one hour emergency. of the declaration of an Alert or higher

e. Dispatch orisite and offsite survey classification.

teams.

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

g. On a periodic basis, make senior technical and management staff available for consultation with the NRC and State officials.

E12-56

Enclosure 12 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section D.2.2.4: VEGP ACTIONS EP 8.1: SNC plants maintain 24-hour (GE) emergency response capability. The normal (Continued) on-shift complement provides the initial

h. Provide meteorological data and response to an emergency. This group is field monitoring team readings or trained to respond to emergency situations dose estimates to offsite authorities until the augmented Emergency Response for actual releases. Organization (ERO) arrives.

i. Provide release and dose EP E.1.1: SNC-operated plants maintain the -

projections based on plant condition capability of notifying state and local agencies and foreseeable contingencies. within 15 minutes of a declared emergency as

j. Activate the Emergency Response required by 10CFR50 Appendix E, section Data System for the affected unit IV(D)(3). NRC will be notified by the impacted within1 h following declaration of the site immediately following state and local General Emergency. notifications, but within an hour of an

k. Close out emergency class by emergency classification using ENS.

briefing of offsite authorities followed EP E.2.2.1: State and local agencies listed in by written summary within 8 h of the site-specific Annexes shall be notified closeout or class reduction. within fifteen (15) minutes of:

The initial emergency classification.
Classification change.
The issuance of, or change to, a Protective Action Recommendation (PAR).

EP E.2.3: The Emergency Response Data System EROS will be initiated within one hour of the declaration of an Alert or higher classification. Section D.3: The procedure by which Annex Appendix C Fleet functional EPIPs to be developed to support the plant operational staff classifies the SNC Standard Emergency Plan as part of the emergencies is EPIP 91001-C, approval process. Procedural direction for "Emergency Classification And Classification will be provided. The transition to Implementing Instructions." the revised EPIPs will be conducted in accordance with the approval of the Plan by the Commission and the provisions of 10 CFR 50.54(q). E12-57 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section D.3: The SNC policy is that EP D.2.5: The SNC policy is that once an The commitment wording was standardized and once an emergency classification is emergency classification is made, it cannot be relocated to the SNC Standard Emergency Plan. made, it cannot be downgraded to a downgraded to a lower classification. lower classification. Termination criteria contained in the Emergency Plan Implementing Procedures shall be completed for an event to be terminated. At termination, on an event specific basis, the site can either enter normal operating conditions or enter a recovery condition with a recovery organization established for turnover from the ERO. When the site determines that transition to termination or recovery is appropriate, the information will be transmitted to respective offsite aQencies. Section D.3: Termination criteria EP D.2.5: The SNC policy is that once an The commitment wording has been standardized contained in the Emergency Plan emergency classification is made, it cannot be and relocated to the SNC Standard Emergency Implementing Procedures shall be downgraded to a lower classification. Plan. completed for an event to be Termination criteria contained in the terminated. Emergency Plan Implementing Procedures shall be completed for an event to be terminated. At termination, on an event specific basis, the site can either enter normal operating conditions or enter a recovery condition with a recovery organization established for turnover from the ERO. When the site determines that transition to termination or recovery is appropriate, the information will be transmitted to respective offsite agencies. E12-58

Enclosure 12 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 E. NOTIFICATION METHODS AND EP E.1 Notification Methodology The commitment wording has been standardized PROCEDURES EP E.1.1 SNC, in cooperation with state and and relocated to the SNC Standard Emergency This section describes the plan for county authorities, has established methods Plan. notification of onsite .and offsite and procedures for notification of offsite Vogtle Electric Generating Plant response organizations consistent with the

(VEGP) response personnel and emergency classification and emergency*

State, local, and Nuclear Regulatory action level scheme. These notifications Commission (NRC) emergency include a means of verification or response centers. authentication. The methods used for authentication are developed and mutually agreed to by the utility and off-site authorities. The primary notification method will be by a dedicated communications system. E. NOTIFICATION METHODS AND EP E.1.1: SNC-operated plants maintain the The commitment wording has been standardized PROCEDURES (cont) capability of notifying state and local agencies and relocated to the SNC Standard Emergency within 15 minutes of a declared emergency as Plan. required by 10CFRSO Appendix E, section IV(D)(3). The methods and forms. used for notifying state and county authorities are site-specific, and detailed in plant specific Emergency Plan Implementing Procedures (EPIPs). E. NOTIFICATION METHODS AND The commitment wording has been standardized EP E.1.1: NRC will be notified by the impacted PROCEDURES (cont) and relocated to the SNC Standard Emergency site immediately following state and local Plan. notifications, but within an hour of an emergency classification using ENS. E. NOTIFICATION METHODS AND EP E.1.1: When multiple units of a multi-unit The commitment wording has been standardized PROCEDURES (cont) site are affected by an emergency, the and relocated to the SNC Standard Emergency classification shall be reported as applicable to Plan. all affected .units. In situations where multiple units of a multi-unit site are affected by emergency events, but the events are not .. related and the classification for each unit is different, initial notification will' be made for the highest classification. Additional classification information is provided in accordance with Section E.2.2.3 E12-59 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 E. NOTIFICATION METHODS AND EP E.1.1: An accelerated call to the NRC The commitment wording has been standardized PROCEDURES (cont) Headquarters Operations Officer will be made and relocated to the SNC Standard Emergency following discovery of an imminent threat or Plan. attack against a plant. During a plant transient or an imminent threat situation requiring physical security response, plant personnel are primarily responsible for stabilizing the plant and keeping it safe. An accelerated notification will not interfere with plant or personnel safety or physical security response. The accelerated notification will be completed after or concurrent with notification of local law enforcement agencies. The goal will be to initiate the notification within 15 minutes of discovery of an imminent threat or attack against a plant. The information provided in the accelerated notification will be limited to the following:

Site name .
Emergency classification if determined prior to the accelerated notification.
Nature of the threat and the attack status.

E12-60 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 E. NOTIFICATION METHODS AND EP E.2 Notification of Personnel The commitment wording has been standardized PROCEDURES (cont) EP E.2.1 Notification of Onsite Personnel and relocated to the SNC Standard Emergency The Emergency Director is responsible for Plan. classifying an event into the appropriate emergency classification and then notifying on-site personnel of the emergency declaration in accordance with procedures. This notification may consist of the use of the plant emergency alarm signal, announcements over the plant public address system, or activation of the recall system. Emergency Response personnel respond to their assigned Emergency Response Facilities upon notification of an Alert or higher classification level. In the event of a Design Basis Threat, personnel may be directed to respond to alternative facilities. Notification of persons who are in the public access areas, on or passing through the site, or within the controlled area, will be performed by the Security Department. Such notifications will be in accordance with the Emergency Plan Implementing Procedures (EPIPs). Visitors within the protected area are escorted by a permanently badged individual. This individual is responsible for informing the visitors of emergencies when they occur and for taking action to evacuate the visitors from the site, as necessary. Notification procedures include notification of Emergency Response Organization Personnel (ERO) not on site or during backshift hours. ERO members will be notified by means of an automated callout system activated by on-shift personnel. E12-61 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 E. NOTIFICATION METHODS AND EP E.2.2 Notification of State and Local The commitment wording has been standardized PROCEDURES (cont) Authorities and relocated to the SNC Standard Emergency A dedicated ENN will normally be used to Plan. accomplish state and local *notifications. Backup means of communication are described in Section F, Emergency Communication, of this plan. E. NOTIFICATION METHODS AND EP E.2.2.1: State and local agencies listed in The commitment wording has been standardized PROCEDURES (cont) the site-specific Annexes shall be notified and relocated to the SNC Standard Emergency within fifteen (15) minutes of: Plan.

The initial emergency classification.
Classification change.
The issuance of, or change to, a Protective Action Recommendation (PAR).

E. NOTIFICATION METHODS AND EP E.2.2.2 Initial Notification Message Form The commitment wording has been standardized PROCEDURES (cont) In conjunction with state and county and relocated to the SNC Standard Emergency authorities, SNC-operated plants have Plan. established the contents of the initial state notification message forms to be used during an emergency. These forms are described in EPIPs. The content of the forms has been reviewed and agreed on by the respective Offsite Response Organizations. E. NOTIFICATION METHODS AND EP E.2.2.3 Follow-up Emergency Message The commitment wording has been standardized PROCEDURES (cont) In conjunction with state and county and relocated to the SNC Standard Emergency authorities, SNC-operated plants have Plan. established the contents of the subsequent state notification message forms to be used during an emergency. The Emergency Director is responsible for the completion of a follow-up emergency message. The appropriate ERO personnel will ensure the emergency communicator(s) periodically provide follow-up messages to the appropriate offsite federal, state, and local authorities. E12-62 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 E. NOTIFICATION METHODS AND EP E.2.3 Notification of the Nuclear The commitment wording has been standardized PROCEDURES (cont) Regulatory Commission (NRC) and relocated to the SNC Standard Emergency The NRC is notified via the ENS. If the ENS is Plan. inoperative, the required notification will be made using alternate means in accordance with regulatory requirements. The Emergency Response Data System EROS will be initiated within one hour of the declaration of an Alert or higher classification. Specific information on the notifications to the NRC for emergency events is detailed in the reporting requirements of 10 CFR 50. 72. E. NOTIFICATION METHODS AND EP E.2.4 Notification of Other Federal The commitment wording has been standardized PROCEDURES (cont) Agencies and relocated to the SNC Standard Emergency Notification of other federal agencies will be Plan. made in accordance with site-specific o raced u res. E12-63 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 E. NOTIFICATION METHODS AND EP E.2.5 Notification of the Public The commitment wording has been standardized PROCEDURES (cont) Prompt alerting and notification of the public and relocated to the SNC Standard Emergency within the plume exposure pathway EPZ is the Plan. obligation of state and local government or other responsible authority. The responsibility for ensuring the means exist to carry out this purpose rests with Southern Nuclear Operating Company. An overview of these means excluding the Savannah River Site is listed in the site-specific Annex of this Plan. Initial notification of the public will occur in a manner consistent with assuring the public health and safety. The design objective for the system is to meet the acceptance criteria provided in a subsequent section of the FEMA approved design report for each SNC-operated plant. The design objective does not constitute a guarantee that prompt notification can be provided for everyone with 100 percent assurance, or that the system when tested under actual field conditions will meet the design objectives. In the event of an emergency, the Emergency Director is responsible for notifying appropriate state and local response organizations, plant emergency response organization and plant personnel. E12-64 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification-Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Actual methods and sequencing of Annex Appendix C Fleet functional EPIPs to be developed to support notifications are covered in the SNC Standard Emergency Plan as part of the appropriate implementation approval process. Procedural direction for procedures (Procedure 91002-C, Notification will be provided. The transition to the Emergency Notifications, and __ revised EPIPs will be conducted in accordance Procedure 91204-C, Emergency with the approval of the Plan by the Commission Response Communications). and the provisions of 10 CFR 50.54(q). Section E: Tables E-1 and E-2 and EP F Table 5 The commitment wording has been standardized figure E-1 and relocated to the SNC Standard Emergency Plan. Section E.1: The emergency director EP 8.1.1: The Emergency Director's non- The commitment wording has been standardized is responsible for classifying an delegable duties include: and relocated to the SNC Standard Emergency event (section D) into the appropriate

Notifications of offsite agencies and approval Plan.

emergency class and then notifying onsite and offsite personnel E12-65 2 to NL-16-0169 (PA) system. Section E.1: Upon declaration an Alert, a Site Area Emergency, Section E.1: This notification will making appropriate announcements E, notification of onsite Section E.1: The supervisor nuclear visitors center, and recreation park E12-66 2 to NL-16-0169 evacuation order. EP E.2.1: Notification Section E.1: The Security nonessential personnel from the Plant Wilson, the training Section E.1: Visitors within the permanently badged individual. E12-67 2 to NL-16-0169 to be taken in an emergency prior to Section E.1: The training includes personnel notification and the Section E.1: Notification of the Section E.1: The notification Emergency Response Organization Section E.1: ERO members will be system activated by on-shift E12-68 2 to NL-16-0169 Maintenance, and Security Section E.2: The emergency director E-1 for a sam pie form) and for the of state, local, and NRG notifications. EP E.2.1: The Emergency Director is accordingly. responsible for classifying an event into the appropriate emergency classification and then notifying on-site personnel of the emergency declaration in accordance with site-specific procedures. Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section E.1: The primary means for EP E.2.1: This notification may consist of the The commitment wording has been standardized notification of personnel within the use of the plant emergency alarm, and relocated to the SNC Standard Emergency protected area is the public address announcements over the plant public address Plan. system, or activation of the recall system. of a Notification of Unusual Event (NUE), or a General Emergency, the emergency director will order an announcement of the emergency. EP E.2.1: The Emergency Director is The commitment wording has been standardized involve sounding the appropriate responsible for classifying an event into the and relocated to the SNC Standard Emergency plant emergency alarm signal, appropriate emergency classification and then Plan. notifying on-site personnel of the emergency over the plant public address declaration in accordance with site-specific system, activation of the recall procedures. This notification may consist of system and using appropriate plant the use of the plant emergency alarm, telephone system. announcements over the plant public address Section F.7: As described in section system, or activation of the recall system. personnel at VEGP will be completed through a combination of public address system announcements, tone signals, and proceduralized telephone calls. EP E.2.1: Notification of persons who are in the The commitment wording has been standardized security is responsible for notifying public access areas, on or passing through the and relocated to the SNC Standard Emergency Plant Wilson, the training center, the site, or within the controlled area, will be Plan. performed by the Security Department. Such staff. notifications will be in accordance with the Emergency Plan Implementing Procedures (EPIPs). Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section E.1: Security will activate the EP E.2.1: The Emergency Director is The commitment wording has been standardized site siren to notify personnel on site, responsible for classifying an event into the and relocated to the SNC Standard Emergency outside the protected area of an appropriate emergency classification and then Plan. notifying on-site personnel of the emergency declaration in accordance with site-specific procedures. This notification may consist of the use of the plant emergency alarm, announcements over the plant public address system, or activation of the recall system. of persons who are in the public access areas, on or passing through the site, or within the controlled area will be performed by the Security Department. Such notifications will be in accordance with the Emergency Plan Implementing Procedures (EPIPs). EP E.2.1: Notification of persons who are in The commitment wording has been standardized Department will also be responsible the public access areas, on or passing through and relocated to the SNC Standard Emergency for evacuating all visitors and the site, or within the controlled area, will be Plan. performed by the Security Department. Such Plant Vogtle Recreational Park and notifications will be in accordance with the for the verification of the evacuation Emergency Plan Implementing Procedures of all nonessential personnel from (EPIPs). center, and the remaining areas inside the owner controlled area. EP E.2.1: Visitors within the protected area The commitment wording was standardized and protected area are escorted by a are escorted by a permanently badged relocated to the SNC Standard.Emergency Plan. individual. Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section E.1: Plant and contractor EP 0.4.8: GET will include general training in The commitment wording was standardized and personnel will be trained on actions emergency preparedness for plant and other relocated to the SNC Standard Emergency Plan. site personnel. GET will include classification, their work assignment. Otherwise, individual response, signals, accountability, and The general training requirements include visitor they must be escorted by an site evacuation procedures. control. SNC provides emergency preparedness individual who has been trained in training appropriate to the individual's emergency procedures. responsibilities as required by Appendix E. General employee training and specialized training are provided as required. The visitor program is maintained as part of the approved Security Plan ensuring all non-badged individuals receive the appropriate traininQ. EP 0.4.8: GET will include general training in The commitment wording was standardized and instructions on the methods of emergency preparedness for plant and other relocated to the SNC Standard Emergency Plan. site personnel. GET will include classification, required personnel actions in the individual response, signals, accountability, and event of an emergency. site evacuation procedures. Annex Appendix C Fleet functional EPIPs are to be developed to corporate staff is performed in support the SNC Standard Emergency Plan as part accordance with NMP-EP-002 I of the approval process. Procedural direction for NMP-GM-036. Notification will be provided. The transition to the revised EPIPs will be conducted in accordance with the approval of the Plan by the Commission and the provisions of 10 CFR 50.54(q). EP E.2.1: Notification procedures include The commitment wording was standardized and procedure includes notification of notification of Emergency Response relocated to the SNC Standard Emergency Plan. Organization Personnel (ERO) not on site or Personnel (ERO) not on site. during backshift hours. ERO members will be notified by means of an automated callout system activated by on-shift personnel. EP E.2.1: Notification procedures include The commitment wording was standardized and notified by means of an autodialer notification of Emergency Response relocated to the SNC Standard Emergency Plan. Organization Personnel (ERO) not on site or personnel. during backshift hours. ERO members will be notified by means of an automated callout system activated by on-shift personnel. Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section E.1: In addition to those EP E.2.1: Notification procedures include The commitment wording was standardized and personnel recalled; Operations, notification of Emergency Response relocated to the SNC Standard Emergency Plan. Organization Personnel (ERO) not on site or personnel required to report shall be during backshift hours. ERO members will be contacted by on-shift personnel from notified by means of an automated callout their own respective department. system activated by on-shift personnel. EP E.2.2.1: State and local agencies listed in The commitment wording was standardized and is responsible for the completion of the site-specific Annexes shall be notified relocated to the SNC Standard Emergency Plan the Initial Message Form (see figure within fifteen (15) minutes of: and Site Annex.

The initial emergency classification.

notification of the following within 15

Classification change.

min of the declaration of an

The issuance of, or change to, a Protective emergency: Action Recommendation (PAR).
Georgia Emergency Annex 4.1.1 Notification Process Management Agency State of Georgia:

Emergency Operations Center

Georgia Emergency Management Agency (EOC) communicator. (GEMA)
Burke County Emergency Georgia County Authorities:

Operations Center (EOC)

Burke - Burke County EMA communicator. State of South Carolina:
South Carolina warning point.
Emergency Management Division (EMO)
Aiken County sheriff dispatcher. South Carolina County Authorities:
Barnwell County sheriff
Barnwell and Aiken County - Sheriffs dispatcher. Department
Allendale County central
Allendale County- County Central Dispatch dispatch. De~artment of Energy - Savannah River Site
Department of Energy-Savannah (DOR-SRS)

River (DOE SR) Operations Cente

DOE-SRS Operations Center communicator.

Section E.2: A dedicated telephone EP E.2.2: A dedicated ENN will normally be The commitment wording was standardized and system, known as the Emergency used to accomplish state and local relocated to the SNC Standard Emergency Plan. Notification Network (ENN), will notifications. normally be used to accomplish these notifications. E12-69 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section E.4: It is the responsibility of EP E.2.5: Prompt alerting and notification of The commitment wording was standardized and VEGP to provide adequate means the public within the plume exposure pathway relocated to the SNC Standard Emergency Plan for notifying the public, or to be EPZ is the obligation of state and local and Site Annex. assured that such means are government or other responsible authority. provided. The responsibility for ensuring means exist to carry out this purpose rests with Southern Nuclear Operating Company. Annex 4.2: Within the 10 mile Exposure Emergency Planning Zone (EPZ), there exist provisions for alerting and providing notification to the public. Section E.4. Administrative and Annex 4.2: Two approved, independent, The commitment wording was standardized and physical means have been complementary alerting systems are installed relocated to the Site Annex. established for providing early initial in the EPZ to alert the public, consisting of a warning and subsequent clear network of fixed sirens or tone-alert radios. instructions to the populace within Provisions for transient population notification the plume exposure pathway are also included in state and county plans. In emergency planning zone (EPZ). the event of an emergency declaration at the VEGP, DOE-Savannah River Site has agreed to provide prompt notification of all persons on the SRS within VEGP's plume exposure pathway EPZ. Section E.4: The alert notification EP E.2.5.2: Capability for both an alerting The commitment wording was standardized and system, except for the Savannah signal and an informational or instructional relocated to the SNC Standard Emergency Plan River Site (SRS), is described in message to the population on an area-wide and Site Annex. appendix 3; this system has the basis throughout the plume exposure pathway capability to complete the initial alert EPZ, within 15 minutes. notification of residents within the Annex 4.2: Within the 10 mile Exposure plume EPZ in about 15 min. Emergency Planning Zone (EPZ), there exist provisions for alerting and providing notification to the public. Section E.5: The emergency director EP E.2.2.3: The Emergency Director is The commitment wording was standardized and is responsible for the completion of a responsible for the completion of a follow-up relocated to the SNC Standard Emergency Plan. follow up emergency message. emergency message. E12-70 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section E.6: All notification EP E.2.7: The SNC emergency notification The commitment wording was standardized and messages must be verified. form is transmitted electronically to the relocated to the SNC Standard Emergency Plan. responsible state and local agencies using a secure data sharing system provided by SNC. Once transmitted to the OROs the receipt of this information is confirmed using a dedicated communications link. Section F.1.1: Commercial EP F.1.3: Provisions exist for continuous The commitment wording was standardized and telephones and a Southern communications with state and local relocated to the SNC Standard Emergency Plan Company Communications in Atlanta governments within the Emergency Planning and Site Annex. provide backup for the dedicated Zones, as detailed above. At least one onsite telephone circuits. and one offsite communications system is maintained, each with a backup power source to ensure continuous communications. Annex 5.3.2: Commercial telephones or land lines provide backup for the ENN. Section E.2: Figure E-1 presents the EP E.1.1: SNC, in cooperation with state and The commitment wording was standardized and sample initial message form for county authorities, has established methods relocated to the SNC Standard Emergency Plan. making notifications to these and procedures for notification of offsite response centers. This form has response organizations consistent with the been developed in conjunction with emergency classification and emergency aooropriate offsite aqencies. action level scheme. Section E.6: All notification EP E.1.1: These notifications include a means The commitment wording was standardized and messages must be verified. When of verification or authentication. relocated to the SNC Standard Emergency Plan. the ENN is used, verification is EP E.2.7: The SNC emergency notification form accomplished by roll call. is transmitted electronically to the responsible state and local agencies using a secure data sharing system provided by SNC. Once transmitted to the OROs, the receipt of this information is confirmed using a dedicated communications link. E12-71 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section E.3: The emergency director EP B.1.1: The Emergency Director's non- The commitment wording was standardized and is responsible for ordering delegable duties include: relocated to the SNC Standard Emergency Plan notification calls to the DOE-SR

Notifications of offsite agencies and approval and Site Annex.

Operations Center by ENN and to of state, local, and NRG notifications. the NRG Operations Center by the EP E.2.3: The NRG is notified via the Emergency Notification System Emergency Notification System (ENS). (ENS). Annex 5.3.1: The primary means of communication between VEGP, the states of Georgia and South Carolina, as well as Burke, Aiken, Allendale and Barnwell Counties and the Savannah River Site, is the Emergency Notification Network (ENN). Section E.2: The emergency director EP B.1.1: The Emergency Director's non- The commitment wording was standardized and is responsible for the completion of delegable duties include: relocated to the SNC Standard Emergency Plan. the Initial Message Form (see figure

Notifications of offsite agencies and approval E-1 for a sample form) and for the of state, local, and NRG notifications.

(initial notification) within 15 min of the declaration of an emergency. Section E.4: VEGP will provide EP E.2.6: State and local authorities have The commitment wording was standardized and offsite authorities with supporting developed procedures and messages to be relocated to the SNC Standard Emergency Plan. information for their messages to the provided to the public in the event of an public. Such messages, consistent emergency at an SNC-operated nuclear power with the emergency classification plant. scheme, will provide the public with instructions in regard to specific protective actions to be taken by occupants of affected areas. Section E: Table E-1. EP F Table 5 The commitment wording was standardized and relocated to the SNC Standard Emergency Plan. Section E: Table E-2: All EP F Table 5 The commitment wording was standardized and relocated to the SNC Standard Emergency Plan. Section F.1.1: The primary means of Annex 5.3.1: The primary means of The commitment wording was standardized and communication between the VEGP communication between VEGP, the states of relocated to the Site Annex. and the State of Georgia is the Georgia and South Carolina, as well as Burke, Emergency Notification Network Aiken, Allendale and Barnwell Counties and (ENN). the Savannah River Site, is the Emergency Notification Network (ENN). E12-72 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section F.1.1: Extensions for this EP F .1.2: Offsite notifications can be made to The commitment wording was standardized and system are located in the control state and county warning points and relocated to the SNC Standard Emergency Plan. room, technical support center Emergency Operations Centers from the (TSC), emergency operations facility Control Room, Technical Support Center, and (EOF). Emergency Operations Facility using the ENN. EP F Table 5 Section F.1.1: The plant telephone EP F.1.1: Reliable primary and backup means The commitment wording was standardized and backup power is supplied by a of communication have been established. relocated to the SNC Standard Emergency Plan. battery system. Section F.1.1: An Administrative Decision Line (AOL) connects the EOF, SRS Operations Center, the GEMA FEOC, the SEOCs of both states and the three South Carolina counties. Section F.1.1: The ENN system is EP F .1.2: SNC-operated plants maintain the The commitment wording was standardized and available and manned 24 h per day. capability to make initial notifications to the relocated to the SNC Standard Emergency Plan. Section F.1.2: The ENN is available designated offsite agencies 24 hours per day. and manned 24 h per day. State and county warning points are Section F.3: The ENN system is continuously staffed. available and manned 24 h per dav. E12-73 2 to NL-16-0169 Vogtle (Units 1 _& 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section F.2. t: The primary means of Annex 4.1.1 Notification Process The commitment wording was standardized and communication between the VEGP State of Georgia: relocated to the Site Annex. and South Carolina is the ENN, a

Georgia Emergency Management Agency dedicated telephone system from the (GEMA) plant to South Carolina emergency Georgia County Authorities:

response agencies.

Burke County Emergency Management Section F.2.2: The primary means of Agency communication between VEGP and State of South Carolina:

the South Carolina counties is the

Emergency Management Division (EMO)

ENN, a dedicated telephone system South Carolina County Authorities: which includes the plant and Aiken,

Barnwell and Aiken County - Sheriff's Barnwell, and Allendale County Department emergency response agencies.
Allendale County - County Central Dispatch De12artment of Energy - Savannah River Site (DOE-SRS)
DOE-SRS Operations Center Annex 5.3.1: The primary means of communication between VEGP, the states of Georgia and South Carolina, as well as Burke, Aiken, Allendale and Barnwell Counties and the Savannah River Site, is the Emergency Notification Network (ENN). The ENN is a dedicated communications system from the plant to the EOG at GEMA heac;lquarters in Atlanta, Georgia, the South Carolina Warning Point in the SEOC, and the Burke County EOG; and the Savannah River Operations Center. Extensions for this system are located in the Control Room, the TSC, and the EOF.

2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section F .1.1: Commercial EP F .1.3: At least one on-site and one offsite The commitment wording was standardized and telephones and a Southern communications system is maintained, each relocated to the SNC Standard Emergency Plan Company Communications in Atlanta with a backup power source to ensure and Site Annex. provide backup for the dedicated continuous communications. telephone circuits. Annex 5.3.2: Commercial telephones or land Section F.1.2: Commercial lines provide backup for the ENN. telephones and the Burke County Emergency Management Agency (EMA) radio network provide backups for the ENN. Section F.2.1: Commercial telephones provide the backup for the ENN. Section F.2.2: Commercial telephone is the backup means of communication. Section F.3: Commercial telephones provide a backup for the ENN. Section F.1.2: The primary means of Annex 5.3.1: The primary means of The commitment wording was standardized and communication between VEGP and communication between VEGP, the states of relocated to the Site Annex. Burke County is the ENN. Georgia and South Carolina, as well as Burke, Aiken, Allendale and Barnwell Counties and the Savannah River Site, is the Emergency Notification Network (ENN). Section F.3: The primary means of Annex 5.3.1: The primary means of The commitment wording was standardized and communication between VEGP and communication between VEGP, the states of relocated to the Site Annex. the Savannah River Site (SRS) is the Georgia and South Carolina, as well as Burke, ENN. Aiken, Allendale and Barnwell Counties and the Savannah River Site, is the Emergency Notification Network (ENN). Section F.1.2: Commercial Annex 5.3.2: Commercial telephones or land The commitment wording was standardized and telephones and Southern Company lines provide backup for the ENN relocated to the Site Annex. Communications provide backups for the ENN .. El2-75 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section F.1.1: The ENN system is EP F.1.2: Offsite notifications can be made to The commitment wording was standardized and available and manned 24 h per day. state and county warning points and relocated to the SNC Standard Emergency Plan. Emergency Operations Centers from the Control Room, Technical Support Center, and Emergency Operations Facility using the ENN. Reliable backup methods have been written into procedures. State and county warning points are continuously staffed. Section F.1.2: At the plant, the EP B.1.1: The Emergency Director's non- The commitment wording was standardized and emergency director is in charge of delegable duties include: relocated to the SNC Standard Emergency Plan communications to the Burke County

Notifications of offsite agencies and approval and Site Annex.

EOC. of state, local, and NRC notifications. Annex 4.1.1: State and local warning points are staffed 24 hours per day. State and local counties surrounding VEGP to be notified within 15 minutes of the declaration of an emergency condition are: Georgia Count~ Authorities:

Burke - Burke County Emergency Manaqement Aqencv Section F.2.1: An AOL connects the No corresponding statement in the Plan or Communication line is utilized by offsite agencies EOF, the SRS Operations Center, Annex. and is listed in the Offsite Emergency Plan. As the the GEMA FEOC, the SEOCs of line is not utilized by SNC for official notification both states, and the three South purposes, it is not included in the SNC Standard Carolina counties. EmerQencv Plan or Annexes Section F.3: At VEGP, the EP B.1.1: The Emergency Director's non- The commitment wording was standardized and emergency director is in charge of delegable duties include: relocated to the SNC Standard Emergency Plan communications to the SRS
Notifications of offsite agencies and approval and Site Annex.

Operations Centers. of state, local, and NRC notifications. Annex 5.3.1: The primary means of communication between VEGP, the states of Georgia and South Carolina, as well as Burke, Aiken, Allendale and Barnwell Counties and the Savannah River Site, is the Emergency Notification Network (ENN). E12-76 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section F.4: The primary means of EP F .1.4.1: This communications line provides The commitment wording was standardized and communication between VEGP and a communications link to the NRC Operations relocated to the SNC Standard Emergency Plan. the Nuclear Regulatory Commission Center in Rockville, Maryland, and is used for (NRC) is the emergency notification continuous communications in a classified svstem (ENS). emeraencv. Section F.4: Emergency notification EP F.1.4.2: This communications line provides The commitment wording was standardized and system phones are located in the a communications link with the NRC to provide relocated to the SNC Standard Emergency Plan. control room, TSC, and EOF. radiological information. Section F.4: Health physics network The design of the current FTS system allows any phones are located in the TSC and EP F Table 5 phone with long distance capability to be linked to EOF. any FTS bridge. Specific phone locations are no longer needed. Section F.4: In the TSC, the HPN EP B.2.1.12: The HPN Communicator reports The commitment wording was standardized and telephone is located in the to the RP Supervisor and is responsible for relocated to the SNC Standard Emergency Plan. communications room and will be providing radiological and environmental attended by VEGP personnel until an information to the NRC on the HPN Line. The design of the current FTS system allows any NRC representative arrives. EP F.1.4.2: This communications line provides phone with long distance capability to be linked to a communications link with the NRC to provide any FTS bridge. Specific phone locations are no radiological information. lonQer needed. Section F.4: The Emergency EP E.2.3: The Emergency Response Data The commitment wording was standardized and Response Data System (EROS) is System EROS will be initiated within one hour relocated to the SNC Standard Emergency Plan. the primary means by which the of the declaration of an Alert or higher transmission of plant parameters classification. occurs. EP F.1.4.8: EROS is a dedicated network and Section H.4.4: In accordance with is a direct near real-time electronic data link the requirements of 10 CFR 50, between the plant's on-site computer system Appendix E, Section VI and NUREG and the NRC Operations Center. It provides for 1394, Revision 1, means are the automated transmission of a limited data provided to transmit critical plant set of selected parameters. variables from the onsite computer system to the Nuclear Regulatory Commission Operations Center via a dedicated communications link. Section F.4: Commercial telephone EP F .1.4: Commercial telephone lines serve as The commitment wording was standardized and lines and the Southern Company the backup to the ENS and other FTS lines. relocated to the SNC Standard Emergency Plan. Communications serve as backups to the ENS and HPN. E12-77 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section F.5: Communications among EP F.1.1: At SNC-operated nuclear power The commitment wording was standardized and the control room, TSC, OSC, and plants, several modes of reliable relocated to the SNC Standard Emergency Plan. EOF can be completed using communication are available, during both dedicated telephone circuits, normal normal and emergency conditions, to transmit plant telephones, and radio, using and receive information among the Control the plant network. Room, TSC, OSC, EOF, and other locations onsite and offsite including the Joint Information Center near the SNC site. Reliable primary and backup means of communication have been established. EP F Table 5 Section F.5: The radio system is also EP F .1.1: At SNC-operated nuclear power The commitment wording was standardized and used for communications with the plants, several modes of reliable relocated to the SNC Standard Emergency Plan. radiological monitoring teams. communication are available, during both normal and emergency conditions, to transmit and receive information among the Control Room, TSC, OSC, EOF, and other locations onsite and offsite including the Joint Information Center near the SNC site. Reliable primary and backup means of communication have been established. EP F Table 5 E12-78 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section F.5: Communications EP F .1.1: At SNC-operated nuclear power The commitment wording was standardized and available at each emergency plants, several modes of reliable relocated to the SNC Standard Emergency Plan. response facility are as follows: communication are available, during both CONTROL ROOM normal and emergency conditions, to transmit Dedicated telephone circuits to the and receive information among the Control TSC, EOF, and OSC (one for each Room, TSC, OSC, EOF, and other locations location). onsite and offsite including the Joint The ENN. Information Center near the SNC site. Reliable The NRC ENS. primary and backup means of communication Normal plant phones. have been established. In-plant radio console EP F Table 5 Sound-powered phones. Plant page system. Commercial dial. Southern Company Communications. Facsimile. Section F.5: TECHNICAL SUPPORT CENTER Dedicated telephone circuits to the control room, EOF, and OSC (one to each location). The ENN. The ENS. Two FTS EROS lines. The HPN. Facsimile. Normal plant phones. In-plant radio. Sound-powered phones. Plant page system. Field team radio remote. Additional FTS lines. Commercial dial. Burke County radio remote. South Carolina radio remote. Southern Company Communications. E12-79 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section F.5: OPERATIONS EP F.1.1: At SNC-operated nuclear power The commitment wording has been standardized SUPPORT CENTER plants, several modes of reliable and relocated to the SNC Standard Emergency Dedicated voice telephone circuits to communication are available, during both Plan. the EOF and TSC (one for each normal and emergency conditions, to transmit location). and receive information among the Control Normal plant phones. Room, TSC, OSC, EOF, and other locations In-plant radio transceiver. onsite and offsite including the Joint Plant page system. Information Center near the SNC site. Reliable Commercial dial. primary and backup means of communication have been established. EP F Table 5 Section F.5: EMERGENCY EP F.1.1: At SNC-operated nuclear power The commitment wording was standardized and OPERATIONS FACILITY plants, several modes of reliable relocated to the SNC Standard Emergency Plan. Dedicated telephone circuits to the communication are available, during both control room, OSC, and TSC (one normal and emergency conditions, to transmit each to the control room, OSC, and receive information among the Control TSC). Room, TSC, OSC, EOF, and other locations The ENN. onsite and offsite including the Joint The ENS. Information Center near the SNC site. Reliable The HPN. primary and backup means of communication Facsimile. have been established. Normal plant phones. EP F Table 5 Commercial dial. Additional FTS lines. Southern Company Communications. ENC hotline. Field team radio remote. AOL prearranged conference. E12-80 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section F.5: Joint Information Center EP F .1.1: At SNC-operated nuclear power The commitment wording was standardized and Southern Company plants, several modes of reliable relocated to the SNC Standard Emergency Plan. Communications. communication are available, during both GPC general office dial. normal and emergency conditions, to transmit Commercial dial. and receive information among the Control VEGP dial. Room, TSC, OSC, EOF, and other locations Facsimile. onsite and offsite including the Joint Information Center near the SNC site. Reliable primary and backup means of communication have been established. Section F.6: Communications with EP F.2 Medical Emergency Communications Columbia Doctors Hospital or the Communications have been established Burke County Hospital will be by between the primary and backup medical commercial telephone. Radio hospitals and transportation services with contact through the Burke County SNC-operated plants. EOC serves as a backup. E12-81 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section F.8: Communication EP F.3 Communications Tests The commitment wording was standardized and channels with the State of Georgia, Communications tests will be conducted on the relocated to the SNC Standard Emergency Plan. Burke County, the State of South frequency specified below. Each of these tests Carolina, Aiken County, Barnwell includes provisions to ensure participants in County, Allendale County, SRS, and the test are able to understand the content of the NRG will be tested monthly, the messages in the test. using the extensions in the control

Communications with state and local room, TSC, and EOF. governments within the plume exposure pathway will be tested monthly.
Communications with federal response organizations and state governments within the plume exposure pathway will be tested quarterly.
Communications between SNC-operated nuclear power plants, state Emergency Operating Centers and local Emergency Operations Centers, and radiation monitoring teams will be tested annually.
Communication from the Control Room, TSC, and EOF to the NRG Operations Center will be tested monthly.
The Emergency Response Data System (EROS) will be tested on a quarterly basis.
The fixed siren portion of the Alert and Notification System (ANS) will be tested and verified in accordance with existing FEMA aoorovals.

Section F.8: Emergency Response EP F.3: The Emergency Response Data The commitment wording was standardized and Data System computers are tested System (EROS) will be tested on a quarterly relocated to the SNC Standard Emergency Plan. once per quarter, or as dictated by basis. NUREG 1394. Section F.8: Communications No specific Plan Statement is provided. The Plan specifies tests for existing systems procedures and systems are also consistent with NUREG-0654 Revision 1. The tested biennially during a Plan commits to a drill program that will include communications drill. communications capabilities. Section F.8: The communication No specific Plan Statement is provided. The Drill programmed maintained will ensure system for communicating between specific testing of the Field Monitoring systems the TSC, EOF, and VEGP field without a specific communications test monitoring teams is tested quarterly. requirement. E12-82 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section F.8: Communications EP F.3: Communications with state and local The commitment wording was standardized and systems that link the control room, governments within the plume exposure relocated to the SNC Standard Emergency Plan. TSC, EOF, State EOC's and GEMA pathway will be tested monthly. FEOC, County EOC's and SRS EOC are tested quarterly. Section F.9: In-plant monitoring Specific communications frequencies between the teams will communicate with the - OSC and dispatched response teams are event Health Physics or OSC specific and determined on a case by case basis communicator at least every half for the event. A Plan commitment is not hour per Procedure 91302-C, In- appropriate and could actually hinder effective Plant SamplinQ and Surveys. response. Section F .9: Field monitoring teams Specific communications frequencies between the will communicate with the EOF or OSC and dispatched response teams are event TSC communicator at least every specific and determined on a case by case basis half hour per Procedure 91303-C, for the event. A Plan commitment is not Field Sampling and Surveys. appropriate and could actually hinder effective response. Section F.9: The field monitoring The capability to dispatch teams and for those team radio covers the entire plume teams to function is maintained in the SNC exposure pathway EPZ. Standard Emergency Plan. This statement of radio coverage is not required. The required drills and equipment tests ensure the capability to effectively communicate is maintained. Section F.9: Remote stations for EP F Table 5 The commitment wording was standardized and communicating with the field relocated to the SNC Standard Emergency Plan. monitoring teams are located in the TSC and the EOF. Table F-1: All EP F Table 5 The commitment wording was standardized and relocated to the SNC Standard Emergency Plan. E12-83

Enclosure 12 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section G: Georgia Power Company EP G.8: The goal of the public information The commitment wording was standardized and (GPC) and Southern Nuclear program is to acquaint the general public with relocated to the SNC Standard Emergency Plan. Operating Company (SNC) in the emergency plans for the operation of coordination with State and local APC/GPC nuclear plants, as appropriate, and

officials will provide information to actions they should in the event of a plant the public at least annually regarding emergency.

how they will be notified and what Emergency information is. disseminated each their actions should be in an calendar year for residents and transients in the emergency. plume exposure pathway Emergency Planning Zone. Section G: The means for EP G.8: Emergency information is The commitment wording was standardized and disseminating this information disseminated each calendar year for residents relocated to the SNC Standard Emergency Plan. include information on siren poles, and transients in the plume exposure pathway signs, notices in public areas, and Emergency Planning Zone. publications distributed at least annually. Section G: All materials will be EP G.8: The goal of the public information The commitment wording was standardized and updated as necessary and printed program is to acquaint the general public with relocated to the SNC Standard Emergency Plan. material distributed annually. the emergency plans for the operation of Based on experience, the most effective means of Section G: Information is distributed APC/GPC nuclear plants, as appropriate, and communicating with the EPZ citizens may no annually to residents in the plume actions they should in the event of a plant longer be the calendar. The SNC Standard exposure pathway emergency emergency. Emergency Plan maintains the commitment to planning zone (EPZ) through an Emergency information is disseminated each provide the required information and allows the emergency information calendar calendar year for residents and transients in the flexibility to provide other means of distributing the entitled, "The Plant Vogtle plume exposure pathway Emergency Planning information. Emergency Information Calendar". Zone. E12-84 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section G: The text of the calendar Annex 2.3.6: Several communications The commitment wording was standardized and addresses the following subjects: methods may be used to acquaint the public relocated to the Site Annex. Summary - What to do if you are with plans for their protection during a Plant warned of an emergency at Plant emergency. Effort will be concentrated on Vogtle. providing information to the public by written Emergency response plans. material that is likely to be available in local When an emergency will affect you. residences and in locations frequented by How you will be told about an transients. The information will also provide emergency. instructions on which local media will be What actions you might need to take. providing additional information in the event of What if you are told to shelter. an emergency. What if you are told to evacuate. Steps to be prepared for an emergency. Steps for using map and chart of evacuation area. Steps to take to get ready for the trip. Classes of accidents. Where to get more information or other help. What radiation is. Special needs card. A joint message from Southern Nuclear Operating Company, the states of Georgia and South Carolina, and Burke, Aiken, Allendale, and Barnwell counties explaining the contents of the calendar, asking that they read the emergency information, requesting that they keep it in a handy place, and giving contacts for further information. E12-85 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section G.1: Signs and notices Annex 2.3.6: Several communications The commitment wording was standardized and providing information to methods may be used to acquaint the public relocated to the Site Annex. transients are placed in public with plans for their protection during a Plant recreation areas as well as other emergency. Effort will be concentrated on providing information to the public by written public places in the plume EPZ material that is likely to be available in local such as siren poles, the Plant residences and in locations frequented by Vogtle Visitors Center, and in transients. The information will also provide commercial establishments; for instructions on which local media will be example, motels, restaurants, providing additional information in the event of and gas stations. an emergency. Section G.1: Finally, a Vogtle emergency information brochure will be made available within the EPZ to transients at commercial establishments, churches, motels, hunting clubs, Creek and Cawden Plantations, the Plant Vogtle Visitors Center, and through residents whose land is used by nonresidents Section G.1: Outside the EPZ, the brochure will be made available to timber company offices. Section G.1: (Outside the EPZ, the brochure will be made available) to the Waynesboro Office of the Agriculture Stabilization & Conservation Service for distribution to farmers who farm, but do not reside, in the EPZ. E12-86 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section G.1: This material will Annex 2.3.6: Several communications The commitment wording was standardized and include the following information: methods may be used to acquaint the public relocated to the Site Annex. How people will be warned of an with plans for their protection during a Plant emergency. emergency. Effort will be concentrated on What to do if warned of an providing information to the public by written emergency. material that is likely to be available in local A list of radio and television stations residences and in locations frequented by to tune to for further information. transients. The information will also provide instructions on which local media will be providing additional information in the event of an emergency. Section G: In addition, public EP G.8: The goal of the public information The commitment wording was standardized and information personnel provide public program is to acquaint the general public with relocated to the SNC Standard Emergency Plan. education programs to the the emergency plans for the operation of community. APC/GPC nuclear plants, as appropriate, and actions they should in the event of a plant emergency. Emergency information is disseminated each calendar year for residents and transients in the plume exposure pathway Emergency Planning Zone. Section G: All materials used to The SNC Standard Emergency Plan and Site provide emergency planning Annex retain the commitment to provide the information to the public (information information. The mechanics of performing the brochures, advertisements, signs commitment are best controlled by administrative and notices, etc.) will be reviewed by procedures. GPC and SNC on an annual basis. E12-87 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section G.2: The JIC will EP H.2.2: Corporate Media Center (CMC) The commitment wording has been standardized accommodate public information Upon notification of an Alert or higher and incorporated into the ERO Staffing as representatives from SNC, GPC, classification, the Public Information Director described in Section B, Facilities as described in State, local and Federal response and corporate staff assigned to JIC functions Section H and the Emergency Communications agencies. will assemble at the CMC. The CMC, located at portion of Section G of the SNC Standard the Atlanta/Birmingham corporate headquarters Emergency Plan. building of Georgia Power Company/Alabama Power Company, as appropriate, is the official location for coordination of emergency communications response until the site specific JIC has been activated. The Public Information Director will coordinate with the EOF Emergency Director and affected OROs and determine whether to activate the site specific JIC. When the decision is made to activate the JIC the CMC will maintain emergency communications response coordination until the site specific JIC is ready to assume these responsibilities. Once overall responsibility for emergency communications response transfers to the site specific JIC the remaining CMC staff will provide support for the JIC as needed. E12-88 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 The commitment wording has been standardized EP H.2.3 Joint Information Center (JIC) and incorporated into the ERO Staffing as After the initial notification of an emergency at described in Section B, Facilities as described in the Alert classification or higher, the Public Section Hand the Emergency Communications Information Director will coordinate with the portion of Section G of the SNC Standard EOF Emergency Director and affected OROs Emergency Plan. and determine whether to activate the JIC. Upon the decision to activate the JIC, the Public Information Director and J IC staff transfer from the CMC to the site specific JIC. Once the JIC is staffed the Public Information Director will nianage the emergency communications response from the JIC in coordination with ORO public information officers (PIOs). Site specific JIC is provided in the site specific Annexes. E12-89 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section G.2: GPC will utilize the EP H.2.2: Corporate Media Center (CMC) The commitment wording has been standardized Corporate Headquarters Building at Upon notification of an Alert or higher classification, and incorporated into the ERO Staffing as 241 Ralph McGill Boulevard, NE, the Public Information Director and corporate staff described in Section B, Facilities as described in Atlanta, Georgia, to serve as a assigned to JIC functions will assemble at the CMC. Section H, the Emergency Communications portion The CMC, located at the Atlanta/Birmingham temporary information center until of Section G of the SNC Standard Emergency Plan corporate headquarters building of Georgia Power the JIC in Waynesboro is activated. Company/Alabama Power Company, as and Section 5.1.6 of the Vogtle Annex. appropriate, is the official location for coordination of emergency communications response until the site specific JIC has been activated. The Public Information Director will coordinate with the EOF Emergency Director and affected OROs and determine whether to activate the site specific JIC. When the decision is made to activate the JIC the CMC will maintain emergency communications response coordination until the site specific JIC is ready to assume these responsibilities. Once overall responsibility for emergency communications response transfers to the site specific JIC the remaining CMC staff will provide support for the JIC as needed. Annex 5.1.6. Joint Information Center (JIC) The VEGP JIC is located in Waynesboro, Georgia, adjacent to the Georgia Power Company operating headquarters. The JIC is the central location for the

                               '     coordination and dissemination of information to news media, and responses to public and media inquiries. Details of the JIC for VEGP are in section H of the Emergency Plan. If the decision is made to activate the JIC the CMC in Atlanta, Georgia will maintain emergency communications response coordination until the JIC is ready to assume these responsibilities.

Annex 5.1.6: The JIC is the central location for the coordination and dissemination of information to news media, and responses to media inquiries. Details of the JIC for VEGP are in section H of the Emergency Plan. If the decision is made to move the JIC function forward to a near site location from the Atlanta location, the Atlanta facility will maintain media coordination until the JIC is operational at the near site location. The near site location is in Waynesboro, Georgia. E12-90 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 The commitment wording has been standardized EP H.2.3 Joint Information Center (JIC) and incorporated into the ERO Staffing as After the initial notification of an emergency at described in Section B, Facilities as described in the Alert classification or higher, the Public Section H and the Emergency Communications Information Director will coordinate with the portion of Section G of the SNC Standard EOF Emergency Director and affected OROs Emergency Plan. and determine whether to activate the JIC. Upon the decision to activate the JIC, the Public Information Director and JIC staff transfer from the CMC to the site specific JIC. Once the JIC is staffed the Public Information Director will manage the emergency communications response from the JIC in coordination with ORO public information officers (PIOs). Site specific JIC is provided in the site specific Annexes. Section G.2: The Company EP 8.3.2.8: The Nuclear Spokesperson The SNC Standard Emergency Plan provides an spokesperson position is filled by speaks on behalf of the company, providing updated structure and functional capability for individuals who, under normal plant status updates during news briefings. Information Management to the public in the event operations, hold supervisory The Spokesperson also may do one-on-one of a classified emergency. The new system is positions on the SNC Corporate or media interviews. The position works with the described and supported separately in the plant staff and are technically and Technical Assistant in keeping abreast of the technical analysis of this submittal. professionally qualified to perform event status and keeps the PIO posted on that this important function. status. Section G.2: The Company EP 8.3.2.8: The Nuclear Spokesperson The SNC Standard Emergency Plan provides an spokesperson has access to all speaks on behalf of the company, providing updated structure and functional capability for information and telephone contact plant status updates during news briefings. Information Management to the public in the event with the emergency director through The Spokesperson also may do one-on-one of a classified emergency. The new system is the EOF Manager. He briefs the media interviews. The position works with the described and supported separately in the media on plant status and Company Technical Assistant in keeping abreast of the technical analysis of this submittal. emergency activities. event status and keeps the PIO posted on that status. Section G.2: In addition, technical EP 8.3.2.9: The Technical Assistant reports to The SNC Standard Emergency Plan provides an briefers have been designated who the Nuclear Spokesperson and is responsible updated structure and functional capability for can provide general and background for gathering accurate and timely information Information Management to the public in the event information. about the event and the plant's status from of a classified emergency. The new system is displays, the ERF Communicator, ENN Forms, described and supported separately in the and direct contact with the EOF Manager. technical analysis of this submittal. E12-91 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section G.3: GPC and SNC will The SNC Standard Emergency Plan and Site provide timely and accurate Annex provide an updated structure and functional information to local, State and capability for Information Management to the public federal agencies. in the event of a classified emergency. The new system is described and supported separately in the technical analysis of this submittal. Section G.4: In an emergency, a EP B.3.2.6: The Public Response Staff reports The commitment wording was standardized and rumor control network will be to the Public Response Coordinator and is relocated to the SNC Standard Emergency Plan. activated. responsible for coordinating and developing responses to rumors and public inquiry. Section G.4: News media will be The SNC Standard Emergency Plan and Site monitored to detect and respond to Annex provide an updated structure and functional misinformation. capability for Information Management to the public in the event of a classified emergency. The new system is described and supported separately in the technical analysis of this submittal. Section G.5: GPC will offer an EP G.2: A program will be offered each The commitment wording was standardized and annual program to acquaint the news calendar year to acquaint the news media with relocated to the SNC Standard Emergency Plan. media with the methodology for the methodology for obtaining information obtaining information about overall during an emergency and with overall emergency preparedness at Vogtle. emergency preparedness at APC/GPC nuclear Training will include information plants, as appropriate. Training will include about the plant, radiation, and the information about the plant, emergency role of the emergency news center. response and the role of the JIC, as well as oooortunities to participate in drill activities. H.1 EMERGENCY FACILITIES EP H.1.2 Technical Support Center (TSC) The commitment wording was standardized and

1. TECHNICAL SUPPORT CENTER SNC-operated nuclear power plants have relocated to the SNC Standard Emergency Plan.

(TSC) established a TSC for use during emergency The TSC has been established situations by plant management, technical, and consistent with NU REG 0696, as engineering support personnel. The TSC is described below. The TSC is shared procedurally required to be activated within 75 by both minutes following the declaration of an Alert or units and is located adjacent to the higher classification. Activation for Unusual Unit 1 control room at el 220 ft. The Events or unclassified incidents is optional. layout of the TSC and location of key personnel are shown in figure H-1. E12-92 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 The TSC covers about 5900 ft 2 and EP H.1.2: The TSC is sized to accommodate The commitment wording was standardized and can accommodate 25 people. ERO responders and NRC Representatives. relocated to the SNC Standard Emergency Plan and Site Annex. Annex Figure 5.1.A The TSC has been established EP H.1.2 Technical Support Center (TSC) The commitment wording was standardized and consistent with NUREG 0696. SNC-operated nuclear power plants have relocated to the SNC Standard Emergency Plan. established a TSC for use during emergency situations by plant management, technical, and The wording was updated to provide more specific engineering support personnel. The TSC is capabilities for the facility. procedurally required to be activated within 75 minutes following the declaration of an Alert or higher classification. Activation for Unusual Events or unclassified incidents is optional. When activated, TSC functions include:

Support for the Control Room's emergency response efforts.
Performance of response management functions when in Command & Control.
Continued evaluation of event classification.
Assessment of the plant status and potential offsite impact.
Coordination of emergency response actions.
Notification of appropriate corporate and plant management.
Notification and update of the NRC via the Emergency Notification System (ENS).
Notification and update of the NRC via Health Physics Network (HPN).

E12-93 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 The TSC has been established EP H.1.2: The TSC is the onsite location used The commitment wording has been standardized consistent with NUREG 0696. (cont) to support the Control Room for assessment of and relocated to the SNC Standard Emergency plant status and for implementation of Plan. emergency actions. TSC personnel provide technical data and information to the EOF. Each TSC provides reliable voice and communications to the Control Room, the OSC, the EOF, the NRC, and state Emergency Operations Centers. The TSC is sized to accommodate ERO responders and NRC Representatives. State and county personnel are not expected to report to the TSC. Personnel in the TSC are protected from radiological hazards, including direct radiation and airborne contaminants under accident conditions, with similar radiological habitability standards as Control Room personnel. To ensure adequate radiological protection, radiation monitoring equipment has been installed in the TSC, or periodic radiation surveys are conducted. These systems indicate radiation dose rates and airborne radioactivity inside the TSC while in use. In addition, potassium iodide (Kl) is available for use. The TSC has access to a controlled set of drawings and other records, including general arrangement diagrams, piping and instrumentation diagrams (P&IDs), and electrical schematics. The TSC has the capability to display vital plant data, in real time, to be used by knowledgeable individuals responsible for engineering and management support of reactor operations, and for implementation of emergency procedures. Details of the TSC configuration and location are in the site-specific Annexes. E12-94 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Walking time from the TSC to the Based on drill/exercise evidence and the ongoing control room is less than 2 min. improvement in inter-facility communication capabilities since the requirement for walking time was developed the effectiveness of the facility is not impacted by walking proximity. While the statement is removed based on demonstration the walking time is no longer a needed commitment the physical location of the TSC has not been changed as a result of this submittal. The TSC provides plant EP H.1.2: The TSC is sized to accommodate The commitment wording was standardized and management and technical support ERO responders and NRC Representatives. relocated to the SNC Standard Emergency Plan personnel (including five Nuclear Annex 5.1.2: The TSC provides plant and Site Annex. Regulatory Commission (NRC) management and technical support personnel personnel) with a facility from which with a facility from which they can assist plant they can assist plant operating operating personnel located in the control personnel. room during an emergency. The emergency director and NRC director will be co-located to ensure proper communications. The emergency director and NRC Annex 5.1.2: The Emergency Director and The commitment wording was standardized and director will be located in close NRC director will be co-located to ensure relocated to the Site Annex. proximity to ensure proper proper communications. communications. The TSC is equipped with a Annex 5.1.2: The TSC is equipped with a The commitment wording was standardized and computer system, which provides computer system, which provides source term relocated to the Site Annex. source term and meteorological data and meteorological data and technical data and technical data displays to allow displays to allow TSC personnel to perform TSC personnel to perform detailed detailed analysis and diagnosis of abnormal analysis and diagnosis of abnormal plant conditions, including assessment of any plant conditions, including significant release of radioactivity to the assessment of any significant environment. In addition, the TSC has ready release of radioactivity to the access to plant records, some of which are environment. stored in the TSC and some in the control Section H.1.1: In addition, the TSC room. has ready access to plant records. E12-95 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency- Plan Revised SNC Emergency Plan Justification Revision 63 The TSC structure and ventilation EP H.1.2: Personnel in the TSC are protected The commitment wording was standardized and system are designed to ensure that from radiological hazards, including direct relocated to the SNC Standard Emergency Plan the TSC personnel are protected radiation and airborne contaminants under and Site Annex. _ from radiological hazards. ac~ident conditions, with similar radiological habitability standards as Control Room personnel. Annex 5.1.2: TSC structure and ventilation system are designed to ensure that the TSC personnel are protected from radiological . hazards. The TSC ventilation is a separate system and not a part of the control room ventilation system. The air supply is filtered by high Annex 5.1.2: The air supply is filtered by high The commitment wording was standardized and efficiency particulate air (HEPA) arid efficiency particulate air (HEPA) and charcoal relocated to the Site Annex. charcoal filters. filters. During accident conditions the Annex 5.1.2: During accident conditions the The commitment wording was standardized and filtration system provides tiltered filtration system provides filtered cooli_ng air relocated to the Site Annex. cooling air meeting the following meeting the following exposure design criteria: exposure design criteria: 5 rem - 5 rem - whole body; 30 rem -thyroid; and 75 whole body; 30 rem - thyroid; and 75 rem - skin dose for a 30 day occupancy. rem - skin dose for a 30 day occupancy. The air filtration system will be Annex 5.1.2: The air filtration system will be The commitment wording was standardized and placed in service when required by placed in service when required by site -relocated to the SNC Standard Emergency Plan Procedure 91110-C, Duties ofthe p raced u res. and Site Annex. Health Physics Supervisor (TSC). The procedure reference is deleted. The SNC Standard Emergency Plan retains the commitment to provide the appropriate radiological protection of TSC responders. The ventilation system can be Annex 5.1.2: The ventilation system can be The commitment wording was standardized and manually controlled from the TSC. manually controlled from the TSC. relocated to the SNC Standard Emergency Plan and Site Annex. The procedure reference is deleted. The SNC Standard Emergency Plan retains the commitment to provide the appropriate radiological protection of TSC responders. E12-96 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 The air filtration system will also be Annex 5.1.2: The air filtration system will also The commitment wording was standardized and placed in the filtration mode be placed in the filtration mode automatically relocated to the Site Annex. automatically whenever the control whenever the control room HVAC is isolated. The specific mechanical functioning of the room HVAC is isolated. ventilation system is not required in the Emergency Plan. The air filtration system, when Annex 5.1.2: The ventilation system will be The.commitment wording was standardized and activated, automatically processes designed to maintain exposures to occupants relocated to the Site Annex. all of the outdoor air together with at or below 5 rem total effective dose The specific mechanical functioning of the approximately 25 percent of the equivalent (TEDE) for the duration of the ventilation system is not required in the Emergency recirculated air through the filtration accident. Plan. unit. In the initial actuation of the air Annex 5.1.2: The continuous influx of outdoor The commitment wording was standardized and filtration system, a parallel signal is air with no positive exhaust is designed to relocated to the Site Annex. initiated to deenergize the onsite pressurize the area to 0.125 in. WG. The specific mechanical functioning of the technical support center battery ventilation system is not required in the Emergency room and toilet exhaust fans and Plan. dampers. The continuous influx of outdoor air Annex 5.1.2: The continuous influx of outdoor The commitment wording was standardized and with no positive exhaust is designed air with no positive exhaust is designed to relocated to the Site Annex. to pressurize the area to 0.125 in. pressurize the area to 0.125 in. WG. The specific mechanical functioning of the WG. ventilation system is not required in the Emergency Plan. When the TSC is activated, there will EP H.1.2: To ensure adequate radiological The commitment wording was standardized and be a portable radiation monitor protection, radiation monitoring equipment has relocated to the SNC Standard Emergency Plan. placed in the TSC to alert personnel been installed in the TSC, or periodic radiation of the presence of high radiation surveys are conducted. These systems levels. indicate radiation dose rates and airborne radioactivity inside the TSC while in use. In addition, potassium iodide (Kl) is available for use. In addition, portable radiation Annex 5.1.2: In addition, portable radiation The commitment wording was standardized and monitors are available for personnel monitors will be available for personnel in relocated to the Site Annex. in transit from the TSC to other transit from the TSC to other areas. areas. E12-97 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 The TSC normal lighting is supplied Annex 5.1.2: The TSC normal lighting is The commitment wording was standardized and from normal offsite power through a supplied from normal offsite power through a relocated to the Site Annex. motor control center backed up by motor control center backed up by the security the security diesel generator. diesel generator. Self-contained, battery-operated Annex 5.1.2: Self-contained, battery-operated The commitment wording was standardized and emergency lighting is provided as a emergency lighting is provided as a backup to relocated to the Site Annex. backup to the normal lighting for the normal lighting for ingress and egress only ingress and egress only. and is located in the TSC hallway. Power for TSC vital equipment is Annex 5.1.2: Power for TSC vital equipment is The commitment wording was standardized and provided from either the motor provided from either the motor control center relocated to the Site Annex. control center backed up by the backed up by the security diesel generator, or security diesel generator or from a from a battery-backed uninterruptible power battery-backed uninterruptible power supply system. suoolv system. Power to the de system is provided Annex 5.1.2: Power to the DC system is The commitment wording was standardized and via battery chargers, one of which is provided by battery chargers, one of which is relocated to the Site Annex. powered from this same motor powered from this same motor control center. control center. E12-98 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Separate copies of the following Annex 5.1.2: The records storage is shared by The commitment wording was standardized and documents will be stored in the the control room and the TSC. These records relocated to the Site Annex. control room complex and in the can be accessed on a digital records system. TSC: This system is supplied backup power from an Technical Specifications. uninterruptible power supply to allow retrieval Plant Operating Procedures. of records in the event of a loss of power. Final Safety Analysis Report. These records include but are not limited to: Emergency Plan.

Technical Specifications .

Emergency Plan Implementing

Plant Operating Procedures .

Procedures.

Final Safety Analysis Report .

The following documents are

Emergency Plan .

available in Vogtle Electric

Emergency Plan Implementing Procedures.

Generating Plant (VEGP) Document Control:

Plant operating records .

Plant operating records.

System piping and instrumentation diagrams; heating, ventilation, and air-
Plant Review Board records and conditioning (HVAC) flow diagrams.

reports.

System piping and instrumentation
Electrical one-line, elementary, and wiring diagrams.

diagrams and heating, ventilation, and air-conditioning (HVAC) flow

Control logic and loop diagrams .

The above records are updated as necessary diagrams. to ensure currency and completeness.

Piping area drawings.
Electrical one-line, elementary, and wiring diagrams.
Control logic and loop diagrams.
Technical Specifications.
Final Safety Analysis Report.
Emergency Plan.
Records needed to perform the functions of the emergency operating facility (EOF) when it is not operational.

E12-99 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63

2. OPERATIONS SUPPORT EP H.1.3 Operations Support Center (OSC) The commitment wording was standardized and CENTER (OSC) The OSC has been established to provide an relocated to the SNC Standard Emergency Plan The OSC has been established to be area for coordinating and planning activities and Site Annex.

consistent with NUREG 0696 as . and staging personnel and equipment. The described below. The OSC is located OSC responders include groups such as on the second floor of the Instrument and Control Technicians, maintenance building in the lunch Mechanics, Electricians, Nuclear Chemistry room. The lunch room is located in and RP Technicians, Operations personnel, the southeast corner of the second and oncoming shift personnel. Additional floor and is accessed via the south space is available to accommodate personnel stairwell or the east stairwell. Figure as required. If the OSC is deemed H-2 defines the OSC layout and uninhabitable, the OSC may be moved to other shows access stairwells. The OSC locations as deemed appropriate by the OSC is where operational support Manager. personnel (such as instrument Annex 5.1.3: Operations Support Center technicians, engineers, mechanics, The OSC is located in the Maintenance electricians, chemical/radiation Building. The OSC is where operational technicians, equipment operators, support personnel (such as instrument incoming shift personnel, etc.) technicians, engineers, mechanics, assemble to aid in the response to electricians, chemical/radiation technicians, an emergency. equipment operators and incoming shift personnel) assemble to aid in the response to an emerQencv. E12-100 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 The OSC has been established to be EP H.1.3: The OSC has been established to The commitment wording was standardized and consistent with NU REG 0696. provide an area for coordinating and planning relocated to the SNC Standard Emergency Plan. activities and staging personnel and equipment. The OSC responders include The wording was updated to provide more specific groups such as Instrument and Control capabilities for the facility. Technicians, Mechanics, Electricians, Nuclear Chemistry and RP Technicians, System Operators, and oncoming shift personnel. Additional space is available to accommodate personnel as required. If the OSC is deemed uninhabitable the OSC may be moved to other locations as deemed appropriate by the OSC Manager. Emergency supplies are maintained in the OSC. When an emergency condition exists at one SNC-operated nuclear power plant, additional supplies can be obtained from other unaffected plants and SNC resources upon request. Details of the OSC configuration and location are in the site-specific Annexes. Members of the team will be EP 8.2.2.7: OSC teams are headed by a The commitment wording was standardized and selected by the OSC manager based designated team leader, who maintains relocated to the SNC Standard Emergency Plan. on the type of work to be conducted. communication with the OSC. The following emergency teams may be formed by OSC personnel, as necessary:

Search and rescue.
Repair.
Post-accident sampling.
Internal survey.
Field monitoring.

E12-101 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Preparations for dispatching EP 8.2.2.1: The OSC Manager reports to the The commitment wording was standardized and maintenance teams to the plant will TSC Manager and directs a staff in providing relocated to the SNC Standard Emergency Plan. include the following steps as described labor, tools, protective equipment, and parts in Procedure 91104, Duties of the OSC needed for emergency repair, damage control, The commitment to perform OSC operations is Manager, and Procedure 91202, firefighting, search and rescue, first aid, and maintained unchanged by the SNC Standard Activation and Operation of the OSC. A. Members of the team will be selected recovery. Emergency Plan. The responsibility of conducting by the OSC manager based on the type EP H.1.3: The OSC has been established to OSC operations is included in Section B job of work to be conducted. provide an area for coordinating and planning descriptions of the various OSC leaders. The OSC B. The work will be preplanned by the activities and staging of personnel and Manager's job description contains the overall maintenance personnel. equipment. The OSC responders include unchanged intent of job operations. Specifics in C. Drawings, manuals, and other groups such as Instrument and Control each area (RP, Maint, Ops, etc.) are included in procedures will be obtained from the Technicians, Mechanics, Electricians, Nuclear the remainder of the job descriptions in B.2. document control room or maintenance Chemistry and RP Technicians, System building. If the equipment manuals are Operators, and oncoming shift personnel. not available in either facility, a complete set of manuals is available in the service Additional space is available to accommodate building. personnel as required. If the OSC is deemed D. Dosimetry will be obtained from the uninhabitable, the OSC may be moved to other OSC emergency kit or at the HP control locations as deemed appropriate by the OSC point. Manager. E. Protective clothing and equipment, radios, and other supplies will be obtained from the emergency kit stored in the OSC or the health physics control point. All equipment will be checked before leaving the OSC or health physics control point. F. A radiation work permit (RWP) will be completed in accordance with standard practices at the health physics control point, TSC, or OSC. Standard procedures include emergency RWPs. Procedure 91301-C, Emergency Exposure Guidelines, provides instruction for emergency exposures. G. The tools and equipment needed to conduct repairs and take corrective actions will be determined. This ... E12-102 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 G. (Continued) ... equipment may be Continued from above The commitment wording was standardized and available in the auxiliary building tool relocated to the SNC Standard Emergency Plan. crib or in the maintenance building. Arrangements for tools and The commitment to perform OSC operations is equipment not located onsite will be maintained unchanged by the SNC Standard made in coordination with the Emergency Plan. The responsibility of conducting support coordinator OSC operations is included in Section B job H. ALARA and job briefings will be descriptions of the various OSC leaders. The OSC held with each team in the OSC, the Manager's job description contains the overall TSC, or at the health physics control unchanged intent of job operations. Specifics in point, as appropriate. Work to be each area (RP, Maint, Ops, etc.) are included in performed, special precautions, plant the remainder of the job descriptions in B.2. conditions, and radiological information will be included in the briefings. I. Upon completion of the job, the team members will be debriefed and their exposures recorded. Status boards containing plant Specific reference to status boards was eliminated conditions and emergency from the SNC Standard Emergency Plan due to classification will be available in the the ongoing enhancements in communications OSC. display capabilities. Emergency kits containing radiation Annex 5.1.3: Emergency kits containing The commitment wording was standardized and monitoring equipment, first aid radiation monitoring equipment, first aid relocated to the Annex supplies, decontamination supplies, supplies, decontamination supplies, breathing breathing apparatus, portable apparatus, portable lighting, and portable lighting, and hand-held radios are radios are stored in the OSC. stored in the OSC. In the event that this facility becomes Annex 5.1.3: In the event this facility becomes The commitment wording was standardized and uninhabitable, the functions of the uninhabitable, the functions of the OSC will be relocated to the Site Annex. OSC will be conducted from the conducted from the Outage Execution Center Clearance and Tagging (C&T) (OEC) located in the control building. located in the control building. Evacuation of the OSC will be conducted according to emergency plan implementing procedures. E12-103 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Evacuation of the OSC will be Annex 5.1.3: Evacuation of the OSC will be New EPIPs will be developed to support the SNC conducted according to Procedure conducted according to emergency plan Standard Emergency Plan and Site Annex. These 91202-C, Activation and Operation of implementing procedures. procedures will be developed consistent with the the OSC. approval of the new Plan by the NRC and in accordance with the requirements of 10 CFR 50.43(q).

3. EMERGENCY OPERATIONS EP H.2 Offsite Emergency Facilities The wording was standardized and relocated to the FACILITY EP H.2.1 Emergency Operations Facility SNC Standard Emergency Plan.

The Emergency Operations Facility The EOF is the central location for management is described in Appendix 7. of the offsite emergency response, coordination See Justification Matrix for Appendix 7 below for of radiological assessment, and management of specific documentation. initial recovery operations. The EOF is a dedicated facility located in Birmingham, Alabama, and serves as the EOF for SNC sites (VEGP, FNP, and HNP). The EOF is procedurally required to be activated within 75 minutes following the declaration of an Alert or hiqher classification E12-104 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63

4. ALTERNATIVE FACILITY EP H.1.4: An Alternative Facility for staging of The wording was standardized and relocated to the During a security related event or ERO personnel has been designated at the SNC Standard Emergency Plan and Site Annex.

other event that precludes onsite sites. In the event of a Security or Hostile access, the TSC and OSC ERO staff Action threat or event, the designated will be directed to an alternative Alternative Facility may also serve as an facility. This facility is located in the evacuation location for TSC and OSC Plant Vogtle JIC building. The personnel. The Alternative Facility is designed alternative facility is located in the to be accessible in the event of an onsite HAB rear conference room of the JIC and event and has the capability to: is equipped with the necessary

Communicate with the Control Room, communications and data links to Security, and the EOF.

support communications with the

Conduct engineering assessment control room, site security, and the activities including damage control EOF. team planning and preparation.

The functions of Notification and PARs will be performed from the EOF should the Alternative Facility be activated. Details of Alternative Facilities can be found in the Site-Specific Annex. Annex 5.1.4: During a security-related event or other event that precludes onsite access, the TSC and OSC ERO staff will be directed to an

                   '                     alternative facility. This facility is located in the rear of the near site media center in Waynesboro, Georgia. The alternative facility is equipped with the necessary communications and data links to support communications with the control room, site securitv, and the EOF.

E12-105 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 H.2 NEWS CENTER FACILITIES EP H.2.2 Corporate Media Center (CMC) The commitment wording has been standardized The Joint Information Center is Upon notification of an Alert or higher and incorporated into the ERO Staffing as described in appendix 8. classification, the Public Information Director described in Section B, Facilities as described in and corporate staff assigned to JIC functions Section H and the Emergency Communications will assemble at the CMC. The CMC, located at portion of Section G of the SNC Standard the Atlanta/Birmingham corporate headquarters Emergency Plan. building of Georgia Power Company/Alabama Power Company, as appropriate, is the official location for coordination of emergency communications response until the site specific JIC has been activated. The Public Information Director will coordinate with the EOF Emergency Director and affected OROs and determine whether to activate the site specific JIC. When the decision is made to activate the JIC the CMC will maintain emergency communications response coordination until the site specific JIC is ready to assume these responsibilities. Once overall responsibility for emergency communications response transfers to the site specific JIC the remaining CMC staff will provide support for the JIC as needed. The commitment wording has been standardized EP H.2.3 Joint Information Center (JIC) and incorporated into the ERO Staffing as After the initial notification of an emergency at described in Section B, Facilities as described in the Alert classification or higher, the Public Section H and the Emergency Communications Information Director will coordinate with the portion of Section G of the SNC Standard EOF Emergency Director and affected OROs Emergency Plan. and determine whether to activate the JIC. Upon the decision to activate the JIC, the Public Information Director and JIC staff transfer from the CMC to the site specific JIC. Once the JIC is staffed the Public Information Director will manage the emergency communications response from the JIC in coordination with ORO public information officers (PIOs). Site specific JIC is provided in the site specific Annexes. E12-106 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 H.3 ACTIVATION AND STAFFING EP H.1: SNC-operated nuclear power plants The commitment wording was standardized and OF EMERGENCY FACILITIES have established a Technical Support Center relocated to the SNC Standard Emergency Plan. During the initial stages of an (TSC) and an onsite Operations Support Center emergency situation, emergency (OSC), which are staffed and activated within The SNC Standard Emergency Plan requests ERO activities at VEGP are directed from 75 minutes of the declaration of an Alert or augmentation be revised to 75 minutes as part of the control room. For a Notification of higher classification. this submittal. That justification is provided in the Unusual Event, no other facilities Technical Analysis Section of this submittal rather need be activated. than repeated in the table each place it is For security related events, the referenced. activation of emergency facilities may be delayed as described in section B. Section H.4.1.a: (Meteorological) Annex 5.6.1: A meteorological monitoring The commitment wording was standardized and Parameters measured and program is in place at VEGP. Instruments are relocated to the Site Annex. transmitted to the control room mounted on a 60-meter tower located to the include: south-southwest of the power block. Met Tower modified under DCP SNC143331 which Windspeed (10 m and 60 m). Parameters measured and transmitted to the was evaluated per 10 CFR 50.54 (q) VEGP Wind direction (10 m and 60 m). control room include: 003-02. This DCP provided to channels of Standard deviation of horizontal wind

Windspeed (10 m and 60 m). instrumentation on the primary tower and deleted direction (10 m).
Wind direction (10 m and 60 m). the back-up tower.

Vertical temperature difference (10

Standard deviation of horizontal wind m and 60 m). direction (10 m).

Ambient temperature (10 m).

Vertical temperature difference (10 m and 60 Dewpoint temperature (10 m). m).

Precipitation (base).

Ambient temperature (10 m).

Section 1.4: In the event the primary

Dewpoint temperature (10 m).

instruments are unavailable, the

Precipitation (base).

backup meteorological tower is Additionally, meteorological information can be equipped with instruments at the 10- obtained from the National Weather Service to m level to provide parameters supplement onsite data and provide a backup relevant to atmospheric dispersion to the plant meteorological monitoring program calculations (i.e., windspeed, wind on an as-needed basis. direction, and siqma theta). E12-107 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section H.4.1.a: (Meteorological) Annex 5.6.1: A meteorological monitoring The commitment wording was standardized and Parameters measured and program is in place at VEGP. Instruments are relocated to the Site Annex. transmitted to the control room mounted on a 60-meter tower located to the include: south-southwest of the power block. Windspeed (10 m and 60 m). Parameters measured and transmitted to the Wind direction (10 m and 60 m). control room include: Standard deviation of horizontal wind

Windspeed (10 m and 60 m).

direction (10 m).

Wind direction (10 m and 60 m).

Vertical temperature difference (10

Standard deviation of horizontal wind m and 60 m). direction (10 m).

Ambient temperature (10 m).

Vertical temperature difference (10 m and 60 Dewpoint temperature (10 m). m).

Precipitation (base).

Ambient temperature (10 m).
Dewpoint temperature (10 m).
Precipitation (base).

Section H.4.1.a: The system is Annex 5.6.1: The system is powered by an The commitment wording was standardized and powered by an uninterruptible power uninterruptible power supply consisting of wet relocated to the Site Annex. supply consisting of wet cell cell batteries, charger, and inverter for high batteries, charger, and inverter for availability. high availability. Section H.4.3: The meteorological system power is provided with a wet cell batterv backuo. E12-108 2 to NL-16.. 0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section H: Table H-1: All EP I. t: Some of the key plant parameters The commitment wording was standardized and monitored in the Control Room are assembled relocated to the SNC Standard Emergency Plan into a single display on the Safety Parameter and Site Annex. Display System (SPDS). The SPDS monitors such parameters as reactor coolant system pressure, reactor or pressurizer water level, containment pressure, suppression pool water level and temperature, reactor power, safety system status, containment radiation level, and effluent monitor readings. Annex Section 5.6: The plant instrumentation

              -                       and monitors perform indicating, recording, and protective functions. The Reactor Protection System and associated plant instrumentation provide the ability to maintain plant safety from shutdown to full power operations, and to monitor and maintain key variables such as reactor power, flow, temperature, and radioactivity levels within predetermined safe limits at both steady state conditions and during plant transients. Plant instrumentation and

control systems also provide means to cope with abnormal operating conditions. The control and display of information of these various syste111s are centralized in the unit Control Room. This instrumentation provides the basis for*initiation of protective actions.

E12-109 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section 1.4: In the event both the Annex 5.6.1: Additionally, meteorological The commitment wording was standardized and primary and backup meteorological information can be obtained from the National relocated to the Site Annex. systems are unavailable, Weather Service to supplement onsite data meteorological data will be obtained and provide a backup to the plant by commercial telephone directly meteorological monitoring program on an as-from the National Weather Service needed basis. located in Columbia, South Carolina. Section H.5.1: The National Weather Service (NWS) maintains an automated observation station at the airport (Augusta); and windspeed, wind direction, cloud cover, and ceiling height can be obtained. Information from this automated observation station as well as forecast information can be obtained from the NWS in Columbia, S. C. Section H.4.3: In the event the data transmission system fails, data will Procedural level steps to obtain tertiary sources be obtained by sending a person to are not needed in the SNC Standard Emergency the meteorological shack to collect Plan. the information and phone it back to the plant. Section H. 4.1.c: Seismic monitoring Annex 5.6.1: Seismic monitoring The commitment wording was standardized and instrumentation for VEGP consists of instrumentation for VEGP consists of relocated to the Site Annex. time-history accelerographs, central time-history accelerographs, central control unit, and free-field ETNA. control unit, and free-field ETNA. A strong-motion accelerometer A strong-motion accelerometer (SMA) (SMA) is installed in the containment is installed in the containment tendon tendon gallery on the basemat. gallery on the basemat. The second SMA is located on the containment operating floor at elevation 220 feet. Activation of the tinie history accelerographs causes visual and audible annunciation in the control room to alert the plant operator that an earthquake has occurred. E12-110 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section H.4.1.c: Activation of the Annex 5.6.1: Activation of the time history The commitment wording was standardized and time history accelerographs causes accelerographs causes visual and audible relocated to the Site Annex. visual and audible annunciation in annunciation in the control room to alert the the control room to alert the plant plant operator that an earthquake has operator that an earthquake has occurred. occurred Section H.4.1.d: The fire-detection EP H.5.4: The Fire Detection System is The commitment wording was standardized and system at VEGP includes smoke, designed to detect products of combustion or relocated to the SNC Standard Emergency Plan. flame, and temperature detectors heat in designated areas of the plant. The fire and manual fire alarms. alarm communication systems and subsystems are located at strategic points throughout the plant to warn personnel of a fire or other emergency conditions. Additional description of the fire system is provided in the FSAR. Section H.4.1.d: Fire-detection EP H.5.4: The Fire Detection System is The commitment wording was standardized and systems are provided in all areas designed to detect products of combustion or relocated to the SNC Standard Emergency Plan. with safe shutdown equipment. heat in designated areas of the plant. The fire alarm communication systems and subsystems are located at strategic points throughout the plant to warn personnel of a fire or other emergency conditions. Additional description of the fire system is provided in the FSAR. Section H.4.1.d: In addition to EP H.5.4: The Fire Detection System is The commitment wording was standardized and initiating fire-suppression systems, designed to detect products of combustion or relocated to the SNC Standard Emergency Plan. indications from the fire-detection heat in designated areas of the plant. The fire system are transmitted to the control alarm communication systems and subsystems room. are located at strategic points throughout the plant to warn personnel of a fire or other emergency conditions. Additional description of the fire system is provided in the FSAR. E12-111 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section H.4.2: The post-accident EP H.5.2.2: The process sampling system The commitment wording was standardized and radiation monitors provide radiation consists of the normal sampling system and relocated to the SNC Standard Emergency Plan. monitoring after an accident. additional sampling panels located throughout the plant. Pre-designated monitoring and sampling points are listed in site procedures. Sampling systems are installed or can be modified to permit reactor coolant and containment atmosphere sampling even under severe accident conditions. The system can provide information on post-accident plant conditions to allow operator actions to mitigate and control the course of an accident. Various chemical analyses and radiological measurements on these samples can be performed, including the determination of radionuclide concentrations. Section H.4.2: The monitors are EP H.5.2.1: Radiation monitoring instruments The commitment wording was standardized and comprised of area, airborne, and air are located at selected areas within the plant relocated to the SNC Standard Emergency Plan. particulate monitors. to detect, measure, and record radiation levels. The monitors are comprised of area, airborne, and air particulate monitors. Section H.4.2: Area monitors EP H.5.2.1: Radiation monitoring instruments The commitment wording was standardized and respond to gamma radiation photons are located at selected areas within the plant relocated to the SNC Standard Emergency Plan. within any energy range from 60 keV to detect, measure, and record radiation levels. to 3 MeV. The monitors are comprised of area, airborne and air particulate monitors.

Area monitors respond to gamma radiation.
Airborne monitors detect and measure radioactive gaseous effluent concentrations.
Air Particulate detectors capture and measure airborne particulate.

E12-112 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 -' Section H.4.2: Airborne monitors are EP H.5.2.1: Radiation monitoring instruments The commitment wording was standardized and capable of detecting and measuring are located at selected areas within the plant relocated to the SNC Standard Emergency Plan. radioactive gaseous effluent to detect, measure, and record radiation levels. concentrations with compositions The monitors are comprised of area, airborne, ranging from fresh equilibrium noble and air particulate monitors. gas fission product mixtures to 10-dav old mixtures. Section H.4.2: Power to post- The SNC Standard Emergency Plan and Site accident monitors is diesel generator Annex retain the commitment to provide sampling backed. capability. Section H.4.3: The IPC serves as the EP H.5.3: Process Monitors The commitment wording was standardized and primary data acquisition system for The Control Room and redundant backup relocated to the SNC Standard Emergency Plan. emergency response, acquiring, locations are equipped with extensive plant processing, and feeding data to the process monitors for use in both normal and TSC and SPDS. emergency conditions. These indications Section H.4.3: In addition, data links include reactor coolant system pressure and are provided to other locations temperatures, containment pressure and including the EOF. temperature, and various liquid levels, flow Section H.4.5: The SPDS provides a rates, status or lineup of equipment display of plant parameters from components. which the status of operation can be EP H.5.3.1: A plant monitoring/information assessed, in the control room and system provides the data acquisition and TSC. The EOF accesses SPDS via database capability for performing plant the IPC gateway. monitoring and functions. The system is Section H.4.5: Duplicate SPDS designed to scan, convert to engineering units, displays are located in the TSC and make sensor range and alarm limit checks, EOF. apply required transformations, store for recall and analysis, and display the reading of transformed data from plant instrumentation. The system scans flows, pressures, temperatures, fluid levels, r~diation levels, equipment, and valve status at required frequencies. EP H.5.3.2: Safety Parameter Display System (SPDS) The SPDS parameters are available during normal and abnormal operating conditions in the Control Room, TSC, and EOF. E12-113 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section H.4.3: The IPC has the EP H.5.3.1: A plant monitoring/information The commitment wording was standardized and required data storage capability to system provides the data acquisition and relocated to the SNC Standard Emergency Plan. meet the guidelines of NUREG- database capability for performing plant 0696, which specifies 2 hours of pre- monitoring and functions. The system is events data, 12 hours of post event designed to scan, convert to engineering units, data, and 2 weeks of additional post- make sensor range and alarm limit checks, event data within reduced-time apply required transformations, store for recall resolution. and analysis, and display the reading of transformed data from plant instrumentation. The system scans flows, pressures, temperatures, fluid levels, radiation levels, equipment, and valve status at required frequencies. Section H.4.3: The IPC hardware EP H.2 Offsite Emergency Facilities The commitment wording was standardized and and software are _protected against EP H.2.1 Emergency Operations Facility relocated to the SNC Standard Emergency Plan. unauthorized manipulation of, or Normal power to the EOF is from a reliable interference with, input signals, data offsite source. Emergency lighting is provided processing, data storage, and data by battery-operated lights. Backup power for output the EOF is supplied by onsite diesel generation. Essential equipment is backed up by the diesel generation system. Section H.4.3: The required IPC EP H.2 Offsite Emergency Facilities The commitment wording was standardized and equipment (processor, workstations, EP H.2.1 Emergency Operations Facility relocated to the SNC Standard Emergency Plan. printer, video copiers, and network Normal power to the EOF is from a reliable devices) are powered by a battery offsite source. Emergency lighting is provided system (uninterruptible power). by battery operated lights. Backup power for the EOF is supplied by onsite diesel generation. Essential equipment is backed up by the diesel generation system. E12-114 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision .63 Section H.4.3: The EOF is located in EP H.2.1: The EOF is the central location for The commitment wo~ding was standardized and Birmingham, Alabama. It contains management of the offsite emergency relocated to the SNC Standard Emergency Plan. workstations and. computer network response, coordination of radiological equipment required for assessment, and management of initial communicating with the main IPC recovery operations. The EOF is a dedicated processors via the IPC gateway. facility located in Birmingham, Alabama, and serves as th~ EOF for SNC sites (VEGP, FNP, and HNP). The EOF is procedurally required to be activated w.ithin 75 minutes following the declaration of an Alert or higher classification. The EOF provides for:

Management of overall emergency response.
Coordination of radiological and environmental assessments.
ProtectiveAction Recommendations.
Notification of Offsite Agencies.
Management of recovery operations.
Notification and update of the NRG via Emergency Notification System (ENS).
Notification and update of the NRG via Health Physics Network (HPN}.
Coordination of emergency response activities with federal, state, arid local agencies.

Section H.4.5 The SPDS is in EP H.5.3.2: The SPDS parameters are The commitment wording was standardized and operation during normal and available during normal and abnormal relocated to the SNC Standard Emergency Plan. abnormal operating conditions. operating conditions in the Control Room, TSC, and EOF. E12-115 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section H.4.6: Liquid samples from EP H.5.2.2: The process sampling system The commitment wording was standardized and the reactor coolant system and the consists of the normal sampling system and relocated to the SNC Standard Emergency Plan. containment sumps, and air samples additional sampling panels located throughout from the containment atmosphere the plant. Pre-designated monitoring and may be taken during accident sampling points are listed in site procedures. conditions. Sampling systems are installed or can be modified to permit reactor coolant and containment atmosphere sampling even under severe accident conditions. The system can provide information on post-accident plant conditions to allow operator actions to mitigate and control the course of an accident. Section H.5.3:VEGP has laboratory EP C.3.1: The onsite laboratory/counting room The commitment wording was standardized and facilities for analysis of radioactive at SNC-operated nuclear power plants are the relocated to the SNC Standard Emergency Plan. samples. The major pieces of primary facility for radiation monitoring and equipment include a solid-state analysis effort. The onsite laboratory is the gamma spectrometer and a central point for receipt and analysis of onsite beta/gamma gas proportional samples and includes equipment for chemical counter. and radiological analyses. The plant laboratories have the capability of quantitative analysis of marine and air samples, and qualitative analysis of terrestrial samples. Additional facilities for counting and analyzing samples are available at the other SNC-operated nuclear plants or state and federal laboratory services. These laboratories can act as backup facilities in the event that the affected nuclear power plant's counting room and laboratory become unusable or the capacity or capability of the plant's laboratory is exceeded. EP H.5.2.3: SNC sites have a laboratory facility for analysis of radioactive samples. E12-116 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section H.5.3: The GPC EP A.3.5: Radiological monitoring in the plant The commitment wording was standardized and environmental laboratory located in and in the environs, both onsite and offsite, will relocated to the SNC Standard Emergency Plan. Smyrna, GA has the capability to be augmented by outside vendors as perform isotopic analyses of drinking necessary. Initial radiological monitoring will be water, river water, milk, vegetation, performed by available Southern Company sediment, and biological samples, as resources (e.g., Georgia Power Company well as tritium and gross-beta (GPC) Central Laboratory). analysis. EP H.6.3: External facilities for counting and Section H.5.3: In addition, analyzing samples, and for dosimetry processing of environmental TLDs processing, can be provided by other SNC-will be handled by this laboratory. operated plants including the GPC Central Laboratory, state, federal, or contracted laboratories. Outside analytical assistance may be requested from state and federal agencies, or through contracted vendors. The DOE, through the Radiological Assistance Program (RAP) has access to any national laboratory. Section H.5.3: Backup laboratory EP H.6.3: External facilities for counting and The commitment wording was standardized and facilities are available at Plant Hatch. analyzing samples, and for dosimetry relocated to the SNC Standard Emergency Plan. processing, can be provided by other SNC-operated plants including the GPC Central Laboratory, state, federal, or contracted laboratories. Outside analytical assistance may be requested from state and federal agencies, or through contracted vendors. The DOE, through the Radiological Assistance Program (RAP) has access to any national laboratory. Section H.5.2: VEGP will have EP 1.7: The capability to take offsite soil, water, The commitment wording was standardized and sufficient portable equipment and and vegetation samples is provided by a relocated to the SNC Standard Emergency Plan. trained personnel to field three field minimum of two (2) Field Monitoring Teams monitoring teams. (FMTs). The modification of the commitment to provide two vs. three field teams aligns with industry standards. The bases for the original commitment to deploy three field teams cannot be determined at this point. E12-117 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section H.6: Emergency kits are EP H.9: Emergency kits are available at SNC- The commitment wording was standardized and located in the TSC (for control room operated nuclear power plants. Designated site relocated to the SNC Standard Emergency Plan also), the OSC, the health physics or department procedures identify the and Site Annex. control point, the EOF and other equipment in the various emergency kits. plant locations. Details as to kit locations are found in the plant-Section H.6: An ambulance kit will be specific procedures. carried by the VEGP health physics Annex 5.5: Emergency supplies and technician who accompanies the equipment are located in the TSC (also for the ambulance. control room), the OSC, the radiation protection control point, and other plant locations. Procedures require an inspection and operational check of equipment in these kits on a quarterly basis and after each use. Equipment in these kits is calibrated in accordance with procedures. A set of spares of certain equipment is also maintained to replace inoperative or out-of-calibration equipment. Section H.6: Procedures require an EP H.8: Emergency facilities and equipment are The commitment wording was standardized and inspection and operational check of inspected and inventoried using appropriate relocated to the SNC Standard Emergency Plan. equipment in these kits on a administrative or department procedures. quarterly basis and after each use. These inventories will include requirements that Section H.6: Equipment in these kits provisions are in place to inspect, inventory, and is calibrated in accordance with the operationally check emergency suppliers' recommendations. equipment/instruments at least once each calendar quarter and as needed. These procedures provide information on location and availability of emergency equipment and supplies Section H.6: A set of spares of EP H.8: Sufficient reserves of instruments and The commitment wording was standardized and certain equipment is also maintained equipment are maintained to replace those relocated to the SNC Standard Emergency Plan. to replace inoperative or out-of- removed from emergency kits or lockers for calibration equipment. calibration or repair. E12-118 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section I: Initial assessment actions EP B.1: The normal onsite organization of a The commitment wording was standardized and are the responsibility of the shift SNC-operated nuclear power plant provides a relocated to the SNC Standard Emergency Plan. superintendent and/or the shift staff capable of providing the initial response to The responsibility was relocated to Section 8 supervisor, using available shift an emergency event. The normal on-shift description of on-shift staff and ED responsibilities. personnel. complement provides the initial response to an emergency. The On-Shift staff was validated by performing a detailed staffing analysis as required by Part 50 Appendix E.IV.9. Organizational structures for each of the sites and the On-Shift staffing tables are provided in the Site-Specific Annex. EP B.1.1: The Shift Manager (SM) is in direct charge of shift plant operations and is directly responsible for the actions of the on-shift crew. In an emergency, the SM assumes the responsibility of the Emergency Director (ED) and takes necessary actions to identify and respond to the emergency until relieved by another qualified ED. The ED has the responsibility and authority to immediately and unilaterally initiate emergency actions, including providing notification of Protective Action Recommendations (PAR) to state and local government organizations responsible for implementing off site emergency measures. E12-119 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section I: Subsequent assessment EP B.1: The Shift Manager (SM) is in direct The commitment wording was standardized and actions are directed by the charge of shift plant operations and is directly relocated to the SNC Standard Emergency Plan. emergency director with assistance responsible for the actions of the on-shift crew. from the control room, technical In an emergency, the SM assumes the support center (TSC), emergency responsibility of the Emergency Director (ED) operations facility (EOF), and and takes necessary actions to identify and emergency teams, as necessary. respond to the emergency until relieved by another qualified ED. The ED has the responsibility and authority to immediately and unilaterally initiate emergency actions, including providing notification of Protective Action Recommendations (PAR) to state and local government organizations responsible for implementing off site emergency measures. The ED, at their discretion or when procedurally required, activates the ERO. The Emergency Director's non-delegable duties include:

Event classification in accordance with the emergency classification system.
Perform the duties and responsibilities of Protective Action Recommendation (PAR) determination.
Notifications of offsite agencies and approval of state, local, and NRC notifications.
Authorization of emergency exposures in excess of federal limits.
Issuance of potassium iodide (Kl) to plant employees as a thyroid blocking agent.
Request federal assistance as needed.

After being relieved as Emergency Director, the Shift Manager directs the activities of the operating crew and is responsible for the safe operation of the plant. E12-120 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section 1.2: The containment high- EP H.5.2.1: Radiation monitoring instruments The commitment wording was standardized and range radiation monitor and are located at selected areas within the plant to relocated to the SNC Standard Emergency Plan. containment hydrogen monitor are detect, measure, and record radiation levels. used to provide an early indication of The monitors are comprised of area, airborne, the quantity of radioactivity available and air particulate monitors. for release from the containment. *Area monitors respond to gamma radiation.

Airborne monitors are capable of detecting and measuring radioactive gaseous effluent concentrations.
Air Particulate detectors capture and measure airborne particulate.

Section 1.2: Emergency procedures EP H.5.2.1: Emergency response procedures The commitment wording was standardized and (Procedure 91502-C) include a provide methods for determining relationships relocated to the SNC Standard Emergency Plan. correlation between the monitor between monitor readings and releases, reading and the extent of core material available for release and extent of damage. core damage. Section 1.2: A more detailed assessment of core damage is then performed using Procedures 91502-C and 91503-C, which are also based on the WOG methodoloov. Section 1.2: Samples can be EP H.5.2.2: Sampling systems are installed or The commitment wording was standardized and obtained for reactor coolant, can be modified to permit reactor coolant and relocated to the SNC Standard Emergency Plan. containment sump, and containment containment atmosphere sampling even under atmosphere and are used for all severe accident conditions. The system can radiochemical analyses. provide information on post-accident plant conditions to allow operator actions to be taken to mitigate and control the course of an accident. Section 1.2: Grab samples can be EP H.5.2.2: Sampling systems are installed or The commitment wording was standardized and transported in a shielded cask. can be modified to permit reactor coolant and relocated to the SNC Standard Emergency Plan. containment atmosphere sampling even under severe accident conditions. The system can provide information on post-accident plant conditions to allow operator actions to be taken to mitigate and control the course of an accident. E12-121 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section 1.4: Computer dose EP 1.3: The dose calculation model is provided The commitment wording was standardized and calculation systems will be located in in the Control Room, TSC, and EOF for use in relocated to the SNC Standard Emergency Plan. both the TSC and EOF for offsite projecting potential offsite doses. dose assessment purposes. Section 1.4: Initial dose projections EP 1.3: SNC-operated nuclear power plants use The commitment wording was standardized and can be made within 15 min of a an offsite dose assessment program that relocated to the SNC Standard Emergency Plan. radiological release utilizing the estimates doses from radiological accidents for computer system. comparison with the EPA Protective Action Guidance and acute health effect thresholds. Section 1.4: Subsequent dose EP 1.3: SNC-operated nuclear power plants use The commitment wording was standardized and projections will be made an offsite dose assessment program that relocated to the SNC Standard Emergency Plan. approximately every 15-30 min estimates doses from radiological accidents for depending on the variability of comparison with the EPA Protective Action The commitment is to maintain the comparison meteorological conditions and/or Guidance and acute health effect thresholds. with EPA PAGs. The time reference is not radioactive releases. required to support the PAR process. E12-122 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section 1.4: Default release rates are EP 1.3: The program estimates reactor source The commitment wording was standardized and available for possible accidents in term, atmospheric transport, and doses relocated to the SNC Standard Emergency Plan. the event that measured source term resulting from radiological emergencies, and data are not available or the case can be used to assist in making protective where bounding calculations are action determinations The system desired. supplements assessments based on plant conditions and quick estimates based on hand-calculation methods. The model was developed to allow consideration of the dominant aspects of source term, transport, dose, and consequences. Because the program is designed to be used during a radiological emergency, it is assumed that the amount of activity being released and the meteorological conditions will not be precisely known. EP 1.6: Unmonitored Release Dose projections can be made during a release through use of sample data in situations where effluent monitors are either off-scale, inoperative, or the release occurs by an unmonitored flow path. In the absence of effluent sample data, a computerized offsite dose projection can be performed by specifyinQ the accident category as a default. Section 1.4: When precipitation is EP 1.3: The model was developed to allow The commitment wording was standardized and predicted or occurring in the area of consideration of the dominant aspects of relocated to the SNC Standard Emergency Plan. the plume, the potential for source term, transport, dose, and significantly increased rates of consequences. Because the program is Precipitation is part of the standard modeling radioactivity deposition will be designed to be used during a radiological techniques and a specific discussion in the Plan is considered by increasing the scope emergency, it is assumed that the amount of not required. of environmental sampling as activity being released and the meteorological required. conditions will not be precisely known. E12-123 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section 1.4: The VEGP staff will EP J.5 Offsite Protective Action The deposition doses will be calculated in the calculate the 50-mile ingestion Recommendations (PARs) intermediate phase under the direction of the pathway doses from the deposition Plant conditions, projected dose and dose Offsite Response Organization. The utility retains of specific radionuclides. rates, field monitoring data, and evacuation the commitments to make Ad Hoc Protective time estimates are evaluated to develop PARs Action Recommendations beyond the 10 mile EPZ for preventing or minimizing exposure to the in Section J of the SNC Standard Emergency Plan. public. PARs are provided to the offsite agencies responsible for implementing protective actions for the public within the 10-mile EPZ. The Emergency Director will approve PARs. The PAR decision making flowcharts are site-specific in nature, and are provided in the site-specific implementing procedures. SNC-operated plants have the capability to provide state and local agencies a PAR for bevond the 10-mile EPZ. Section 1.4: The VEGP field EP 1.7: In addition to the capabilities and The commitment wording was standardized and monitoring team will collect sufficient resources described in Section H, SNC- relocated to the SNC Standard Emergency Plan. environmental data to characterize operated nuclear power plants have the ability the initial deposition of activity, the to take offsite air samples and to directly peak activity in pasture grass and measure gamma dose rates from a radioactive milk, and total intake of 1-131, Cs- material release. The capability to take offsite 137, Sr-90, and Sr-89. soil, water, and vegetation samples is provided by a minimum of two (2) Field Monitoring Teams (FMTs). E12-124 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section 1.4: The dose assessment EP J.5 Offsite Protective Action The deposition doses will be calculated in the computer program will be used to Recommendations (PARs) intermediate phase under the direction of the calculate the projected deposition of Plant conditions, projected dose and dose Offsite Response Organization. The utility retains radionuclides and associated doses rates, field monitoring data, and evacuation the commitments to make Ad Hoc Protective in the ingestion pathway based on time estimates are evaluated to develop PARs Action Recommendations beyond the 10 mile EPZ release data and meteorological for preventing or minimizing exposure to the in Section J of the SNC Standard Emergency Plan. conditions. public. PARs are provided to the offsite agencies responsible for implementing protective actions for the public within the 10-mile EPZ. The Emergency Director will approve PARs. The PAR decision making flowcharts are site-specific in nature, and are provided in the site-specific implementing procedures. SNC-operated plants have the capability to provide state and local agencies a PAR for beyond the 10-mile EPZ. Section 1.4: The results of all EP B.3.1.4: The Dose Assessment Supervisor The commitment wording was standardized and analyses will be provided to the reports to the EOF Manager and provides relocated to the SNC Standard Emergency Plan. States of Georgia and South oversight of dose assessment, field team Carolina by the dose assessment control, and protective action recommendation supervisor. activities in the EOF; and coordinates communication of results with offsite aQencies. Section 1.4: Dat;:i from the primary EP 1.3: The dose calculation model is provided The commitment wording was standardized and meteorological monitoring system in the Control Room, TSC, and EOF for use in relocated to the SNC Standard Emergency Plan. can be accessed directly from the projecting potential offsite doses. control room, TSC, and EOF, and EP 1.5: SNC-operated nuclear power plants are also available to NRG personnel have a meteorological monitoring system and State representatives at the site. sufficient to acquire and evaluate meteorological information for accident assessment. This information can be accessed in the Control Room, TSC, and EOF, and is transmitted by the Emergency Response Data System (EROS) for NRG and offsite authorities use. E12-125 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section H.5.2: VEGP will have EP 1.7: In addition to the capabilities and The commitment wording was standardized and sufficient portable equipment and resources described in Section H, SNC- relocated to the SNC Standard Emergency Plan. trained personnel to field three field operated nuclear power plants have the ability monitoring teams. to take offsite air samples and to directly The modification of the commitment to provide two Section 1.5: The emergency director measure gamma dose rates from a radioactive vs. three field teams aligns with industry standards. or his designee can deploy up to material release. The capability to take offsite The bases for the original commitment to deploy three teams for field monitoring. soil, water, and vegetation samples is provided three field teams cannot be determined at this by a minimum of two (2) Field Monitoring point. Teams (FMTs). Section 1.5: Initially, the emergency EP 1.7: In addition to the capabilities and The commitment wording was standardized and director can activate at least one resources described in Section H, SNC- relocated to the SNC Standard Emergency Plan. team from on-shift personnel. operated nuclear power plants have the ability to take offsite air samples and to directly Table 2 designating the required minimum on-shift measure gamma dose rates from a radioactive staffing retains the commitment to support one material release. The capability to take offsite environmental team from on-shift personnel. soil, water, and vegetation samples is provided by a minimum of two (2) Field Monitoring Teams (FMTs). Table 2.2.A - Vogtle Electric Generating Plant On-Shift Staffing Section H.5.2: Results of the offsite EP B.2.1.5: The RP Supervisor reports to the The commitment wording was standardized and monitoring activities will be provided TSC Manager and supervises the activities of relocated to the SNC Standard Emergency Plan. to the TSC until the dose the radiation protection staff and Radiation assessment activities are transferred Protection Network (HPN) Communicator. The from the TSC to the EOF. RP Supervisor assists the Radiation Section 1.5: They will be controlled Protection/Chemistry Group Lead in the OSC by the TSC until the responsibility is in determining the extent and nature of transferred to the EOF. radiological or hazardous conditions and coordinates offsite dose assessment and offsite Field Monitoring Teams prior to EOF activation. E12-126 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section 1.2: In addition to the onsite EP C.3.1: Additional facilities for counting and The commitment wording was standardized and capabilities for radiological analyzing samples are available at the other relocated to the SNC Standard Emergency Plan. assessment, Framatome SNC-operated nuclear plants or state and Technologies has agreed to provide federal laboratory services. These backup analysis of high radioactivity laboratories can act as backup .facilities in the level samples per the agreement in event that the affected nuclear power plant's appendix 2. counting room and laboratory become Appendix 7 F.2.4: The GPC Central unusable or the capacity or capability of the Laboratory has personnel and plant's laboratory is exceeded. facilities available to provide offsite EP H.6.3:. External faGilities for counting and monitoring, sample analysis, and analyzing samples, and for dosimetry dosimetry processing for the affected processing, can be provided by other SNC-site. operated plants including the GPC Central Appendix 7 F.8 Contract Laboratory, state, federal, or contracted Laboratories laboratories. Outside analytical assistance may Teledyne Isotopes, Inc. for be requested from state and federal agencies, emergency analytical services. or through contracted vendors. The DOE, Framatome ANP for emergency through the Radiological Assistance Program analytical services (RAP) has access to any national laboratory. Section 1.2: The TSC manager will The statement of process was eliminated. approve and direct the transport of Procedural control for the release of material offsife the grab sample to Framatome. is maintained by existing site non-emergency procedures. Section H.5.2: Each team will include EP Table 3 The commitment wording was standardized and two people who will obtain an EP 1.7: The capability to take offsite soil, water, relocated to the SNC Standard Emergency Plan. emergency monitoring kit. and Vegetation samples is provided by a Section 1.5: Monitoring teams of at minimum of two (2) Field Monitoring Teams least two people are formed and (FMTs) dispatched at the OSC or TSC as appropriate. Section 1.5: Field monitoring kits are EP 1.7: The capability to take offsite*soil, water, The commitment wording was standardized and available to the teams in and vegetation samples is provided by a relocated to the SNC Standard Emergency Plan. predetermined locations as minimum of two (2) Field Monitoring Teams described in 91702-C. (FMTs). The environmental monitoring Section 1.5: The kits will include anti- equipment include portable survey, counting, contamination suits, respirators, a and air sampling instrumentation and other two-way radio, meters for measuring radiological monitoring equipment and supplies gamma and beta/gamma dose rates, to be used by the FMTs. and air samplers. E12-127 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section 1.5: Designated vehicles may EP 1.7: The capability to take offsite soil, water, The commitment wording was standardized and be used which are equipped with and vegetation samples is provided by a relocated to the SNC Standard Emergency Plan. two-way radios on plant-dedicated minimum of two (2) Field Monitoring Teams frequencies. (FMTs). The environmental monitoring Section 1.5: Hand held radios will also equipment include portable survey, counting, be available as a backup. and air sampling instrumentation and other Section 1.5: Vehicles will be available radiological monitoring equipment and supplies 24 h per day. to be used by the FMTs. Section H.5.2: VEGP monitoring The conduct of sampling operations is event teams will remain on the Georgia specific and Plan direction not considering the side of the Savannah River. environmental and release considerations are potentially inconsistent with appropriate deployment. Section 1.5: It is estimated that teams Table 2.2.A - Vogtle Electric Generating Table 2.2.A of the Site Annex directs the capability will be in the field and performing Plant On-Shift Staffing to be maintained for a single team with on-shift monitoring tasks within about 1 h of personnel. The submittal supports the response of the determination of the need for a second team at 75 minutes. field monitorinQ. Section 1.5: Monitoring teams are Procedural guidance for the conduct of sampling instructed to contact the monitoring will be relocated to EPIPs developed to support team communicator approximately implementation of the Plan. everv half hour. Section 1.5: The teams will inspect EP H.6.2: SNC-operated nuclear power plants The commitment wording was standardized and their field monitoring kits, perform maintain a sufficient supply of portable offsite relocated to the SNC Standard Emergency Plan. survey equipment operation checks, radiological monitoring equipment. These obtain dosimeters, and establish supplies are located at each staging point for Procedural guidance for the conduct of sampling radio communications with the Field Monitoring Teams. will be relocated to EPIPs developed to support monitorinq team communicator. implementation of the Plan. Section 1.6: Copies of the map EP 1.7: Samples are taken at predetermined The commitment wording was standardized and showing the locations will be in the locations as well as those locatioris specified relocated to the SNC Standard Emergency Plan. field monitoring kits, the TSC and during and after a release. EOF. E12-128 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section H.5.2: The kits will include EP 1.9: Field monitoring equipment has the The commitment wording was standardized and dosimeters, a two-way radio, meters capability to detect and measure airborne relocated to the SNC Standard Emergency Plan. for measuring gamma and radioiodine in the presence of noble gases that beta/gamma dose rates, and air has the capability to detect and measure samplers for collecting particulates radioiodine concentrations in air in the plume and iodines. exposure EPZ as low as 10-7 uCi/cc Section 1.5: The emergency (microcuries per cubic centimeter) under field monitoring kits contain a portable air conditions. Interference from the presence of sampler, silver zeolite cartridges, noble gas and background radiation shall not and counters to provide the decrease the stated minimum detectable capability to detect and measure activity. radioiodine concentrations in the air as low as 10-7 µCi/cc. Section 1.5: Prior to leaving for the The SNC Standard Emergency Plan retains the field, the dose assessment commitment to dispatch Field Teams and use the supervisor, or designee, will normally environmental information for radiological direct and brief the teams on the assessment as previously described. The initial survey and sample locations, information here is appropriate to procedural suggested travel routes, control of the teams. meteorological conditions, and team identification name or number for communication purposes. Section 1.5: The teams will obtain The SNC Standard Emergency Plan retains the their briefing from the health physics commitment to dispatch Field Teams and use the supervisor in the TSC or in the OSC environmental information for radiological by the OSC manager. assessment as previously described. The information here is appropriate to procedural control of the teams. Section 1.5: In-transit dose rate The SNC Standard Emergency Plan retains the measurements will be made. commitment to dispatch Field Teams and use the environmental information for radiological assessment as previously described. The information here is appropriate to procedural control of the teams. E12-129 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section 1.5: If the dose rate exceeds The SNC Standard Emergency Plan retains the 100 mrem/h, off-centerline commitment to dispatch Field Teams and use the measurements will be made. environmental information for radiological assessment as previously described. The information here is appropriate to procedural control of the teams. Section 1.5: The total sample volume The SNC Standard Emergency Plan retains the and the limiting background count commitment to dispatch Field Teams and use the rate allow for a LLD of at least 10-7 environmental information for radiological µCi/cc. assessment as previously described. The information here is appropriate to procedural control of the teams. Section 1.5: The Dose Assessment EP 1.7: The environmental monitoring The commitment wording was standardized and Team at the EOF will collate field equipment include portable survey, counting, relocated to the SNC Standard Emergency Plan. monitoring data for VEGP dose and air sampling instrumentation, and other projection purposes. radiological monitoring equipment and supplies to be used by the FMTs. Samples are taken at predetermined locations as well as those locations specified during and after a release. Environmental measurements are used as an aid in determining and assessing protective actions for the general public and recovery actions for the plant. Section 1.6: In addition to direct EP 1.7: In addition to the capabilities and The commitment wording was standardized and monitoring and air sampling, the resources described in Section H, SNC- relocated to the SNC Standard Emergency Plan. assessment program includes an operated nuclear power plants have the ability emergency environmental sampling to take offsite air samples and to directly program. measure gamma dose rates from a radioactive material release. The capability to take offsite soil, water, and vegetation samples is provided by a minimum of two (2) Field Monitoring Teams (FMTs). E12-130 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section 1.6: Direct radiation is EP H.6.2: SNC-operated nuclear power plants The commitment wording was standardized and measured by thermoluminescent maintain a sufficient supply of portable offsite relocated to the SNC Standard Emergency Plan. dosimeters (TLDs) which are radiological monitoring equipment. These exchanged and analyzed (read) for supplies are located at each staging point for gamma dose quarterly. Field Monitoring Teams. SNC-operated nuclear power plants have a Radiological Environmental Monitoring Program (REMP) consisting of locations with dose recording devices and air sampling equipment. Section 1.6: The (airborne radioiodine EP H.6.2: SNC-operated nuclear power plants The commitment wording was standardized and and particulates for environmental maintain a sufficient supply of portable offsite relocated to the SNC Standard Emergency Plan. sample) cartridge and filter are radiological monitoring equipment. These changed weekly. supplies are located at each staging point for The SNC Standard Emergency Plan retains the Field Monitoring Teams. commitment to maintain the capability for the fixed SNC-operated nuclear power plants have a environmental program. The procedural aspects of Radiological Environmental Monitoring maintenance of the program are not needed in the Program (REMP) consisting of locations with Plan. dose recording devices and air sampling equipment. Section 1.6: Filters are composited EP H.6.2: SNC-operated nuclear power plants The commitment wording was standardized and quarterly by location for gamma maintain a sufficient supply of portable offsite relocated to the SNC Standard Emergency Plan. isotopic analysis. radiological monitoring equipment. These supplies are located at each staging point for The SNC Standard Emergency Plan retains the Field Monitoring Teams. commitment to maintain the capability for the fixed SNC-operated nuclear power plants have a environmental program. The procedural aspects of Radiological Environmental Monitoring maintenance of the program are not needed in the Program (REMP) consisting of locations with Plan. dose recording devices and air sampling equipment. Section 1.6: Quarterly composites, EP H.6.2: SNC-operated nuclear power plants The commitment wording was standardized and which are obtained from the monthly maintain a sufficient supply of portable offsite relocated to the SNC Standard Emergency Plan. composites, are analyzed for tritium. radiological monitoring equipment. These supplies are located at each staging point for The SNC Standard Emergency Plan retains the Field Monitoring Teams. commitment to maintain the capability for the fixed SNC-operated nuclear power plants have a environmental program. The procedural aspects of Radiological Environmental Monitoring maintenance of the program are not needed in the Program (REMP) consisting of locations with Plan. dose recording devices and air sampling equipment. E12-131 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section 1.6: Composite samples (of EP H.6.2: SNC-operated nuclear power plants The commitment wording was standardized and drinking water) from each location maintain a sufficient supply of portable offsite relocated to the SNC Standard Emergency Plan. are collected monthly. radiological monitoring equipment. These supplies are located at each staging point for The SNC Standard Emergency Plan retains the Field Monitoring Teams. commitment to maintain the capability for the fixed SNC-operated nuclear power plants have a environmental program. The procedural aspects of Radiological Environmental Monitoring maintenance of the program are not needed in the Program (REMP) consisting of locations with Plan. dose recording devices and air sampling equipment. Section 1.6: Grab samples of finished EP H.6.2: SNC-operated nuclear power plants The commitment wording was standardized and drinking water are taken monthly. maintain a sufficient supply of portable offsite relocated to the SNC Standard Emergency Plan. radiological monitoring equipment. These supplies are located at each staging point for The SNC Standard Emergency Plan retains the Field Monitoring Teams. commitment to maintain the capability for the fixed SNC-operated nuclear power plants have a environmental program. The procedural aspects of Radiological Environmental Monitoring maintenance of the program are not needed in the Program (REMP) consisting of locations with Plan. dose recording devices and air sampling equipment. Section 1.6: Monthly samples are EP H.6.2: SNC-operated nuclear power plants The commitment wording was standardized and analyzed for gross beta and gamma maintain a sufficient supply of portable offsite relocated to the SNC Standard Emergency Plan. isotopics. radiological monitoring equipment. These supplies are located at each staging point for The SNC Standard Emergency Plan retains the Field Monitoring Teams. commitment to maintain the capability for the fixed SNC-operated nuclear power plants have a environmental program. The procedural aspects of Radiological Environmental Monitoring maintenance of the program are not needed in the Program (REMP) consisting of locations with Plan. dose recording devices and air sampling equipment. E12-132 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section 1.6: Quarterly composites, EP H.6.2: SNC-operated nuclear power plants The commitment wording was standardized and which are prepared from the monthly maintain a sufficient supply of portable offsite relocated to the SNC Standard Emergency Plan. samples, are analyzed for tritium. radiological monitoring equipment. These supplies are located at each staging point for The SNC Standard Emergency Plan retains the Field Monitoring Teams. commitment to maintain the capability for the fixed SNC-operated nuclear power plants have a environmental program. The procedural aspects of Radiological Environmental Monitoring maintenance of the program are not needed in the Program (REMP) consisting of locations with Plan. dose recording devices and air sampling equipment. Section 1.6: Sediment from the EP H.6.2: SNC-operated nuclear power plants The commitment wording was standardized and Savannah River is collected maintain a sufficient supply of portable offsite relocated to the SNC Standard Emergency Plan. semiannually from control and radiological monitoring equipment. These indicator locations using manual supplies are located at each staging point for The SNC Standard Emergency Plan retains the grab sampling techniques. Sediment Field Monitoring Teams. commitment to maintain the capability for the fixed samples are analyzed for gamma SNC-operated nuclear power plants have a environmental program. The procedural aspects of isotopics Radiological Environmental Monitoring maintenance of the program are not needed in the Program (REMP) consisting of locations with Plan. dose recording devices and air sampling equipment. Section 1.6: Milk samples are EP H.6.2: SNC-operated nuclear power plants The commitment wording was standardized and collected semimonthly by taking grab maintain a sufficient supply of portable offsite relocated to the SNC Standard Emergency Plan. samples from milk supplies at control radiological monitoring equipment. These and indicator stations. These supplies are located at each staging point for The SNC Standard Emergency Plan retains the samples are analyzed for gamma Field Monitoring Teams. commitment to maintain the capability for the fixed isotopics. SNC-operated nuclear power plants have a environmental program. The procedural aspects of Radiological Environmental Monitoring maintenance of the program are not needed in the Program (REMP) consisting of locations with PIC!:n. dose recording devices and air sampling equipment. E12-133 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section 1.6: Vegetation is sampled EP H.6.2: SNC-operated nuclear power plants The commitment wording was standardized and monthly during the growing season. maintain a sufficient supply of portable offsite relocated to the SNC Standard Emergency Plan. radiological monitoring equipment. These supplies are located at each staging point for The SNC Standard Emergency Plan retains the Field Monitoring Teams. commitment to maintain the capability for the fixed SNC-operated nuclear power plants have a environmental program. The procedural aspects of Radiological Environmental Monitoring maintenance of the program are not needed in the Program (REMP) consisting of locations with Plan. dose recording devices and air sampling equipment. Section 1.6: Vegetation samples are EP H.6.2: SNC-operated nuclear power plants The commitment wording was standardized and analyzed for gamma isotopics. maintain a sufficient supply of portable offsite relocated to the SNC Standard Emergency Plan. radiological monitoring equipment. These supplies are located at each staging point for The SNC Standard Emergency Plan retains the Field Monitoring Teams. commitment to maintain the capability for the fixed SNC-operated nuclear power plants have a environmental program. The procedural aspects of Radiological Environmental Monitoring maintenance of the program are not needed in the Program (REMP) consisting of locations with Plan. dose recording devices and air sampling equipment. Section 1.6: During and/or EP H.6.2: SNC-operated nuclear power plants The commitment wording was standardized and subsequent to emergency maintain a sufficient supply of portable offsite relocated to the SNC Standard Emergency Plan. conditions, the routine environmental radiological monitoring equipment. These monitoring program will be modified supplies are located at each staging point for to collect and analyze additional Field Monitoring Teams. samples from existing stations. SNC-operated nuclear power plants have a Radiological Environmental Monitoring Program (REMP) consisting of locations with dose recording devices and air sampling equipment. E12-134 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section 1.6: The GPC environmental EP H.6.3: External facilities for counting and The commitment wording was standardized and laboratory, located in Smyrna, analyzing samples, and for dosimetry relocated to the SNC Standard Emergency Plan. Georgia, has the capability to processing, can be provided by other SNC-perform isotopic analyses of drinking operated plants including the GPC Central water, river water, milk, vegetation, Laboratory, state, federal, or contracted sediment, and biological samples as laboratories. Outside analytical assistance well as tritium and gross beta may be requested from state and federal analysis. agencies, or through contracted vendors. The DOE, through the Radiological Assistance Program (RAP) has access to any national laboratory. Section J .1.2: Emergency response EP J.4.2: Accountability of personnel within the The commitment wording was standardized and personnel in the protected area Protected Area is accomplished within 30 relocated to the SNC Standard Emergency Plan. badge into their emergency minutes of the declaration of Site Area response facility (TSC, OSC, or Emergency or higher, and maintained control room) using their ACAD continuously thereafter, using Protected badge and also sign in on a Area(s) boundary access control as described personnel roster (TSC and OSC in the Security Plan. If there are station only). personnel who are unaccounted for, the public Section J.1.2: Thereafter, the address system or other suitable emergency response facility communication methods are used to locate the managers of the control room, TSC, personnel, or, in extreme cases such as fire, and operations support center shall toxic gas release, explosions, or structural be responsible for periodically damage, trained search and rescue personnel assuring that accountabilities in their are deployed to search for and assist the facilities are beinQ maintained. missinQ personnel. E12-135 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section J .1.2: The security computer EP J.4.2: Accountability of personnel within the The commitment wording was standardized and system performs an initial of all Protected Area is accomplished within 30 relocated to the SNC Standard Emergency Plan persons in the protected area. minutes of the declaration of Site Area and Site Annex. Section J.1.2: The Security Emergency or higher, and maintained Department accounts for each continuously thereafter, using Protected person inside the protected area at Area(s) boundary access control as described the start of an emergency by using in the Security Plan. If there are station the security computer system. personnel who are unaccounted for, the public address system or other suitable communication methods are used to locate the personnel, or, in extreme cases such as fire, toxic gas release, explosions, or structural damage, trained search and rescue personnel are deployed to search for and assist the missing personnel. Annex 4.3.2: Personnel assembly is mandatory at the Site Area Emergency or higher level classification. Upon activation of the plant emergency alarm, plant personnel assigned specific emergency responsibilities will proceed to their designated emergency response locations. Assembly of site personnel outside of the Protected Areas is accomplished by non-essential personnel reporting to designated assembly areas. Assembly may be initiated at any time site management deems it appropriate for personnel safety reasons. Nonessential plant personnel located within the Protected Area will exit the Protected Area upon hearing the Site Area or the General Emergency alarm and report to designated assembly areas. Visitors, contractors, and escorted personnel will leave the protected area during an Alert or higher declaration. E12-136 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section J.1.2: Accountability reports EP J.4.2: Accountability of personnel within The commitment wording was standardized and are made periodically to the the Protected Area is accomplished within 30 relocated to the SNC Standard Emergency Plan emergency director by the Security minutes of the declaration of Site Area and Site Annex. Department. Emergency or higher, and maintained continuously thereafter, using Protected The SNC Standard Emergency Plan retains the Area(s) boundary access control as described commitment to perform and maintain in the Security Plan. If there are station accountability. The procedural aspects of e of the personnel who are unaccounted for, the public process are not needed in the Plan. address system or other suitable communication methods are used to locate the personnel, or, in extreme cases such as fire, toxic gas release, explosions, or structural damage, trained search and rescue personnel are deployed to search for and assist the missinq personnel. Section J.1.2: Assignment logs and EP J.4.2: Accountability of personnel within the The commitment wording was standardized and required periodic communications Protected Area is accomplished within 30 relocated to the SNC Standard Emergency Plan. between emergency response teams minutes of the declaration of Site Area maintain accountability. Emergency or higher, and maintained The SNC Standard Emergency Plan retains the continuously thereafter, using Protected commitment to perform and maintain Area(s) boundary access control as described accountability. The procedural aspects of e of the in the Security Plan. If there are station process are not needed in the Plan. personnel who are unaccounted for, the public address system or other suitable communication methods are used to locate the personnel, or, in extreme cases such as fire, toxic gas release, explosions, or structural damage, trained search and rescue personnel are deployed to search for and assist the missinq personnel. E12-137 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergen~y Plan Revised SNC Emergency Plan Justification Revision63 Section J.1.2: This method provides EP J.4.2: Accountability of personnel within the The commitment wording was standardized and for accountability of all individuals Protected Area is accomplished within 30 relocated to the SNC Standard Emergency Plan inside the protected area within minutes of the declaration of Site Area about 30 min. of the emergency Emergency or higher, and maintained* declaration page announcement. continuously thereafter, using Protected Area(s) boundary access control as described in the Security Plan. If there are station personnel who are unaccounted for, the public address system or other suitable communication methods are used to locate the

personnel, or, in extreme cases such as fire, toxic gas release, explosions, or structural damage, trained search and rescue personnel are deployed to search for and assist the missino personnel.

Section J .1.3: If protected area EP J.4.2: Accountability of personnel within the The commitment wording was standardized and accountability reveals a missing Protected Area is accomplished within 30 relocated to the SNC Standard Emergency Plan. person, the emergency director minutes of the declaration of Site Area assembles a search and rescue Emergency or higher, and maintained team per emergency response continuously thereafter, using Protected procedures (Procedure 91401-C, Area(s) boundary access control as described Assembly and Accountability). in the Security Plan. If there are station personnel who are unaccounted for, the public address system or other suitable communication methods are used to locate he personnel, or, in extreme cases such as fire, toxic gas release, explosions, or structural damage, trained search and rescue personnel are deployed to search for and assist the missing personnel. E12-138 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section J.1.3: A search of likely EP J.4.2: Accountability of personnel within the The commitment wording was standardized and areas is conducted until the missing Protected Area is accomplished within 30 relocated to the Site Annex. individual is located. minutes of the declaration of Site Area Emergency or higher, and maintained continuously thereafter, using Protected Area(s) boundary access control as described in the Security Plan. If there are station personnel who are unaccounted for, the public address system or other suitable communication methods are used to locate the personnel, or, in extreme cases such as fire, toxic gas release, explosions, or structural damage, trained search and rescue personnel are deployed to search for and assist the missinQ personnel. Section J.1.4: Site dismissal, with or EP J.4.3: If a Site Evacuation is required, The commitment wording was standardized and without monitoring, of non-involved personnel are directed to either assemble within relocated to the SNC Standard Emergency Plan. personnel on-site (if feasible) is designated Assembly Areas or immediately ordered by the emergency director leave the site. Personnel will be directed to whenever a Site Area or General either proceed to their homes or reassemble at Emergency is declared. designated locations. Visitors to the plant will assemble with and follow the instructions of their escorts. Personal transportation will normally be used and established evacuation routes will be followed. Personnel without transportation will be identified and provided transportation as necessary. Evacuation of personnel is usually conducted immediately after accountability if a Site Area Emergency or General Emergency has been declared and no impediments exist. Evacuation shall commence as directed by the Emergency Director. E12-139 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section J.1.4: Personnel on site will EP J.4.3: If a Site Evacuation is required, The commitment wording was standardized and be notified by public address, site personnel are directed to either assemble within relocated to the SNC Standard Emergency Plan. siren, or other communication that designated Assembly Areas or immediately dismissal of non-involved personnel leave the site. Personnel will be directed to to the applicable reception center will either proceed to their homes or reassemble at take place and specify the route. designated locations. Visitors to the plant will assemble with and follow the instructions of their escorts. Personal transportation will normally be used and established evacuation routes will be followed. Personnel without transportation will be identified and provided transportation as necessary. Evacuation of personnel is usually conducted immediately after accountability if a Site Area Emergency or General Emergency has been declared and no impediments exist. Evacuation shall commence as directed by the Emergency Director. Section J.1.4: Security will dispatch EP E.2.1: Notification of persons who are in The commitment wording was standardized and security officers to work areas the public access areas, on or passing through relocated to the SNC Standard Emergency Plan. outside the protected area to ensure the site, or within the controlled area, will be all non- involved personnel have left performed by the Security Department. Such the owner-controlled area. notifications will be in accordance with the Emergency Plan Implementing Procedures (EPIPs). E12-140 2 to NL-16-0169 Vogtle (Units 1 & 2) .Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section J.1.5: Onsite protection of EP J.4: Onsite protection of employees during The commitment wording was standardized and employees during hostile action hostile action involves a combination of relocated to the SNC Standard Emergency Plan involves a combination of restricted restricted movement, movement to safe and Site Annex. movement, movement to safe locations, and site evacuation depending on locations, and site evacuation the nature of the hostile event and advance depending on the nature of the warning. Site-specific procedures provide hostile event and advance warning. specific actions to take during hostile action or severe weather events. During a hostile action or severe weather event, Assembly and Accountability actions may be delayed in favor of other onsite protective actions required to ensure the safety of the site and its personnel. In these cases, accountability will be completed once safe conditions have been established. Annex 4.3.3: Onsite protection of employees during security events involves a combination of restricted movement, movement to safe locations, and site evacuation depending on the nature of the event and advance warning. Specific actions to be taken during such events are included in site procedures. E12-141 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section J.1.5: These actions will be EP J.4: Onsite protection of employees during The commitment wording was standardized and communicated to onsite personnel hostile action involves a combination of relocated to the SNC Standard Emergency Plan via the plant PA system and other restricted movement, movement to safe and Site Annex. communications means as locations, and site evacuation depending on applicable. the nature of the hostile event and advance warning. Site-specific procedures provide specific actions to take during hostile action or severe weather events. During a hostile action or severe weather event, Assembly and Accountability actions may be delayed in favor of other onsite protective actions required to ensure the safety of the site and its personnel. In these cases, accountability will be completed once safe conditions have been established. Annex 4.3.3: Onsite protection of employees during security events involves a combination of restricted movement, movement to safe locations, and site evacuation depending on the nature of the event and advance warning. Specific actions to be taken during such events are included in site procedures. E12-142 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section J.1.6: When an Alert is EP J.4.3: If a Site Evacuation is required, The commitment wording was standardized and declared and site dismissal with no personnel are directed to either assemble within relocated to the SNC Standard Emergency Plan monitoring is anticipated, personnel designated Assembly Areas or immediately and Site Annex. who have left the protected area are leave the site. Personnel will be directed to monitored by portal monitors. either proceed to their homes or reassemble at designated locations. Visitors to the plant will assemble with and follow the instructions of their escorts. Personal transportation will normally be used and established evacuation routes will be followed. Personnel without transportation will be identified and provided transportation as necessary. Evacuation of personnel is usually conducted immediately after accountability if a Site Area Emergency or General Emergency has been declared and no impediments exist. Evacuation shall commence as directed by the Emergency Director. Annex 4.3.4: When an Alert is declared but no site evacuation is anticipated, personnel who have left the protected area are monitored by portal monitors. If necessary, decontamination is completed using the plant decontamination facilities located in the Control building or other onsite locations. When site evacuation with monitoring is expected and release of radioactivity has occurred, monitoring is performed by Burke County emergency workers at an established reception center. E12-143 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section J .1.6: A supply of potassium EP J.4: SNC-operated nuclear power plants The commitment wording was standardized and iodide is stored in the TSC for TSC are responsible for maintaining a supply of Kl relocated to the SNC Standard Emergency Plan. and control room use, OSC, main at their respective site. The Emergency control point, or health physics room. Director has the responsibility for approval of Section J.1.6: The health physics issuing Kl to site emergency workers. supervisor will direct the issuance of potassium iodide when the projected thyroid exposure is greater than 25 rem. Section J .1.6: The health physics supervisor will direct radiological survey personnel to distribute potassium iodide and record the name and social security number of those individuals who are issued potassium iodide. Section J.1.6: Potassium iodide will EP J.4: SNC-operated nuclear power plants The commitment wording was standardized and be issued in 130-mg doses daily for are responsible for maintaining a supply of Kl relocated to the SNC Standard Emergency Plan. at least 3 days, but not more than 10 at their respective site. The Emergency days. Director has the responsibility for approval of issuinQ Kl to site emergency workers. Section J .1.6: Issuance will be EP J.4: SNC-operated nuclear power plants The commitment wording was standardized and performed immediately prior to are responsible for maintaining a supply of Kl relocated to the SNC Standard Emergency Plan. exposure or not longer than 4 hours at their respective site. The Emergency after exposure. Director has the responsibility for approval of issuinQ Kl to site emerQency workers. Section J.1.6: At the time potassium EP J.4: SNC-operated nuclear power plants The commitment wording was standardized and iodide is distributed, an iodine are responsible for maintaining a supply of Kl relocated to the SNC Standard Emergency Plan. sensitivity check will be made by at their respective site. The Emergency querying each individual concerning Director has the responsibility for approval of known reactions to iodine. issuinQ Kl to site emergency workers. E12-144 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Table J-1: Emergency equipment EP H.9: Emergency kits are available at SNC- The commitment wording was standardized and locations. operated nuclear power plants. Designated site relocated to the SNC Standard Emergency Plan or department procedures identify the and Site Annex. equipment in the various emergency kits. Details as to kit locations are found in the plant-specific procedures. Annex 5.5: Emergency supplies and equipment are located in the TSC (also for the control room), the OSC, the health physics control point, and other plant locations. An ambulance kit will be carried by the VEGP Radiation Protection technician who accompanies the ambulance. Procedures require an inspection and operational check of equipment in these kits on a quarterly basis and after each use. Equipment in these kits is calibrated in accordance with the suppliers' recommendations. A set of spares of certain equipment is also maintained to replace inoperative or out-of-calibration equipment. Section J.2.2: The emergency EP B.1.1: The Emergency Director's non- The commitment wording was standardized and director is responsible for providing delegable duties include: relocated to the SNC Standard Emergency Plan. protective action recommendations

Event classification in accordance with the to State and local officials as part of emergency classification system.

initial notifications and follow-up

Perform the duties and responsibilities of communications. Protective Action Recommendation (PAR) determination.
Notifications of offsite agencies and approval of state, local, and NRC notifications.
Authorization of emergency exposures in excess of federal limits.
Issuance of potassium iodide (Kl) to plant employees as a thyroid blocking agent.
Request federal assistance as needed.

El2-145 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section J.2.2: Using available EP J.5: Plant conditions, projected dose and The commitment wording was standardized and information on plant conditions, dose rates, field monitoring data, and relocated to the SNC Standard Emergency Plan. projected dose estimates, and any evacuation time estimates are evaluated to available monitoring data, the develop PARs for preventing or minimizing emergency director recommends exposure to the public. PARs are provided to whether the public should be advised the offsite agencies responsible for to seek shelter or evacuate. implementing protective actions for the public within the 10-mile EPZ. The Emergency Director will approve PARs. The PAR decision making flowcharts are site-specific in nature, and are provided in the site-specific implementing procedures. SNC-operated plants have the capability to provide state and local agencies a PAR for beyond the 10-mile EPZ. Plant conditions, projected dose and dose rates and field monitoring data are communicated to offsite agencies responsible for dose assessment/PARs to assist them in developing parallel assessments There are various types of protective actions that can be recommended to the state and counties. They may include the following:

Evacuation .
Shelter in place .
Monitor and prepare . -
Thyroid blocking agent (consider the use of Kl (potassium iodide)) in accordance with state Plans and Policy.

E12-146 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section J.2.2: Site dismissal of non- EP J.4.3: Evacuation of personnel is usually The commitment wording was standardized and involved station personnel and conducted immediately after accountability if a relocated to the SNC Standard Emergency Plan. evacuation and/or sheltering the Site Area Emergency or General Emergency general public is recommended for a has been declared and no impediments exist. General Emergency even though Evacuation shall commence as directed by the there has not been a release of Emergency Director. radioactivity from the plant. EP J.5: There are various types of protective actions that can be recommended to the state and counties. They may include the following:

Evacuation .
Shelter in place .
Monitor and prepare .
Thyroid blocking agent (consider the use of Kl (potassium iodide)) in accordance with state Plans and Policy.

Section J.3: Determination of the EP J.5: Plant conditions, projected dose and The commitment wording was standardized and benefit of evacuation must take into dose rates, field monitoring data, and relocated to the SNC Standard Emergency Plan. account the time needed to complete evacuation time estimates are evaluated to the evacuation. develop PARs for preventing or minimizing exposure to the public. PARs are provided to the offsite agencies responsible for implementing protective actions for the public within the 10-mile EPZ. The Emergency Director will approve PARs. The PAR decision making flowcharts are site-specific in nature, and are provided in the site-specific implementing procedures. EP J.6: An independent ETE report has been performed for SNC-operated nuclear power plants, which provides estimates of the time required to evacuate resident and transient populations surrounding the plant for various times of the year under favorable and adverse conditions. ETEs for evacuation of the plume exposure EPZ surrounding SNC-operated nuclear power plants are summarized in the site-specific Annex and detailed in the ETE report. E12-147 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section K.1: Decisions as to EP B.1.1: The Emergency Director's non- The commitment wording was standardized and appropriate exposures, considering delegable duties include: relocated to the SNC Standard Emergency Plan. the action required and relative risks,

Authorization of emergency exposures in will be made by the emergency excess of federal limits.

director in consultation with health

Issuance of potassium iodide (Kl) to plant -

physics personnel. employees as a thyroid blocking agent. EP K.1: The Emergency Director has responsibility for authorizing personnel exposure levels under emergency conditions using the guidance in Environmental Protection Agency (EPA) 400-R-92-001, "Manual of Protective Action Guides and Protective Actions for Nuclear Incidents." Section K.1: When necessary, the EP B.1.1: The Emergency Director's non- The commitment wording was standardized and emergency director can authorize delegable duties include: relocated to the SNC Standard Emergency Plan. emergency exposures in excess of

Authorization of emergency exposures in 10 CFR 20 limits but within the limits excess of federal limits.

in table K-1. Section K.2: Where possible, the EP K.3.3: Where possible, the normal radiation The commitment wording was standardized and normal radiation work permit (RWP) work permit procedure will be used to control relocated to the SNC Standard Emergency Plan. procedure will be used to control exposures. exposures. Section K.2: If time and urgency do EP K.3.3. Based on conditions and urgency The commitment wording was standardized and not allow this procedure to be Radiation Protection supervision may approve relocated to the SNC Standard Emergency Plan. followed, the health physics emergency radiological work permit controls. supervisor may approve emergency RWP controls. Section K.2: In all cases, a briefing is EP K.2: SNC-operated plants have a Radiation The commitment wording was standardized and given to the emergency team by Protection Program. The Emergency Director relocated to the SNC Standard Emergency Plan. health physics staff, and each team may authorize emergency workers to receive is accompanied by a qualified health doses in excess of the administrative dose physics technician who meets the levels. In some situations, it is possible that qualifications of ANSI 18.1 criteria certain activities or duties for the protection of set out in the VEGP Technical persons or the substantial protection of Specifications. property may result in doses in excess of 10 CFR 20.1201 limits. E12-148 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section K.2: This briefing includes a EP K.2: SNC-operated plants have a Radiation The commitment wording was standardized and discussion of the hazards involved in Protection Program. The Emergency Director relocated to the SNC Standard Emergency Plan. the planned action, as well as may authorize emergency workers to receive protective actions to be taken. doses in excess of the administrative dose levels. In some situations, it is possible that certain activities or duties for the protection of persons or the substantial protection of property may result in doses in excess of 10 CFR 20.1201 limits. Section K.2: A record of individual EP K.3.1: Exposure records will be maintained The commitment wording was standardized and and collective exposure received for emergency response personnel who are relocated to the SNC Standard Emergency Plan. during the emergency will be issued dosimetry. maintained by the dosimetry team. Section K.2: An individual's dose EP K.2: SNC-operated plants have a Radiation The commitment wording was standardized and margin will be assessed by Protection Program. The Emergency Director relocated to the SNC Standard Emergency Plan. determining the difference between may authorize emergency workers to receive the updated exposure and current doses in excess of the administrative dose administrative limit; these margins levels. In some situations, it is possible that are used to determine emergency certain activities or duties for the protection of assignments. persons or the substantial protection of property may result in doses in excess of 10 CFR 20.1201 limits. Section K.2: In situations where EP K.2: SNC-operated plants have a Radiation The commitment wording was standardized and exposures in excess of 10 CFR 20 Protection Program. The Emergency Director relocated to the SNC Standard Emergency Plan. limits are authorized, the following may authorize emergency workers to receive considerations will be made prior to doses in excess of the administrative dose emergency team selection: levels. In some situations, it is possible that

1. Declared pregnant female certain activities or duties for the protection of employees shall not be allowed to persons or the substantial protection of participate. property may result in doses in excess of 10

2. For doses greater than 25 rem, CFR 20.1201 limits. Decisions to accept personnel shall be volunteers and be doses in excess of occupational limits will be fully aware of the risks involved. on a volunteer basis and prospective volunteers shall be made aware of the risks.

E12-149 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section K.: All emergency exposures EP K.3.1: In an emergency situation, onsite The commitment wording was standardized and will be included in personnel personnel, offsite support personnel and local relocated to the SNC Standard Emergency Plan. radiation exposure records. governmental emergency response personnel may be issued monitoring devices. Exposure records will be maintained for emergency response personnel who are issued dosimetry. Section K.2: Emergency dosimetry is EP K.3.1: In an emergency situation, onsite The commitment wording was standardized and provided to each member of the personnel, offsite support personnel and local relocated to the SNC Standard Emergency Plan. emergency response organization governmental emergency response personnel for both onsite and offsite may be issued monitoring devices. Exposure organizations as required by the records will be maintained for emergency radiological conditions existing at the response personnel who are issued dosimetry. time. Section K.2: Emergency response No direct statement is made for reading direct personnel will be made aware that reading dosimetry. The original Plan statement self reading dosimeters should be was intended for pocket dosimeters requiring checked every 15 to 30 min. during specific action of the ERO individual. Modern the emergency. dosimetry provides alarm functions to support awareness. Section K.2: Appendix 4 presents EP K.3.1: Plant Radiological Protection Groups The commitment wording was standardized and information on the types of dosimetry have the equipment and personnel to provide relocated to the SNC Standard Emergency Plan. available in each emergency 24-hour capability to determine and control response facility and other locations. radiation exposures of emergency organization personnel. Equipment to perform the following functions:

Radiation detection devices.
Personnel monitoring.
Record keeping equipment.

Section K.2: There is the capability EP K.3.1: Plant Radiological Protection Groups The commitment wording was standardized and to read TLDs within 24 h. have the equipment and personnel to provide relocated to the SNC Standard Emergency Plan. 24-hour capability to determine and control radiation exposures of emergency organization personnel. Equipment to perform the following functions:

Radiation detection devices.
Personnel monitoring.
Record keeping equipment.

E12-150 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section K.2: A record of individual EP K.3.1: Exposure records will be maintained The commitment wording was standardized and and collective exposure received for all emergency response personnel who are relocated to the SNC Standard Emergency Plan. during the emergency will be issued dosimetry. maintained bv the dosimetrv team. Section K.3: The action levels for EP K.5: During normal conditions or an The commitment wording was standardized and determining the need for emergency, guidelines to follow for relocated to the SNC Standard Emergency Plan. decontamination of personnel, contamination limits are established by the site equipment, and areas are delineated radiation protection program. in plant admin. and health physics procedures. Section K.3: The facility EP K.5: Facilities and supplies for The commitment wording was standardized and (decontamination area) has vertical decontaminating personnel are available at relocated to the SNC Standard Emergency Plan. showering and normal wash sinks. various plant locations. Section K.3: Instrumentation to survey personnel during and after decontamination is located at the health physics station. Section K.3: Waste generated EP K.5: Facilities and supplies for The commitment wording was standardized and through the use of the decontaminating personnel are available at relocated to the SNC Standard Emergency Plan. decontamination facilities is collected various plant locations. and processed by the plant liquid Procedures and equipment for material radwaste system. decontamination are available at the plant, as specified in the site radiation protection program. E12-151 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section K.3: If decontamination EP K.5: The Radiation Protection Group will be The commitment wording was standardized and activities are required, a controlled responsible for controlling or minimizing direct relocated to the SNC Standard Emergency Plan. access area will be established by or subsequent internal exposure from roping off the area. radioactive materials deposited on the ground or other surfaces, and for determining the extent of contamination in controlled and normally uncontrolled areas. During normal conditions or an emergency, guidelines to follow for contamination limits are established by the site radiation protection program. Facilities and supplies for decontaminating personnel are available at various plant locations. Personnel leaving the Radiological Controlled Area (RCA) or leaving a contaminated area will be monitored for contamination. During emergencies, other onsite personnel will be checked for contamination as necessary. Designated personnel, under the direction of the Radiation Protection Group, are responsible for performing material decontamination. Procedures and equipment for material decontamination are available at the plant, as specified in the site radiation protection proqram. Section K.3: Supplies of clean EP K.5: Facilities and supplies for The commitment wording was standardized and clothing will be made available. decontaminating personnel are available at relocated to the SNC Standard Emergency Plan. various plant locations. Section K.3: Decontamination of EP K.5: Facilities and supplies for The commitment wording was standardized and personnel will be conducted in decontaminating personnel are available at relocated to the SNC Standard Emergency Plan. accordance with standard health various plant locations. physics practices. Section K3: Personnel decontamination will be accomplished using water washes or other methods for extreme cases as described in plant health physics procedures. E12-152 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section K.3: Decontamination of Annex 2.3.2: Agreements are in place with the The commitment wording was standardized and serious wounds will be accomplished University of Alabama at Birmingham (UAB) relocated to the Site Annex. at Doctors Hospital or the Burke Hospital, Burke Medical Center, Doctors Medical Center as described in Hospital, and Burke County Emergency section L of this Plan. Management Agency, to provide assistance for injured personnel, including cases involving radioactive contamination. This assistance will be requested whenever necessary in accordance with plant procedures. Medical Specialists, Inc., a group of medical professionals, has agreed to provide treatment services through Burke Medical Center and Doctors Hospital. Section K.3: It (equipment and area EP K.5: Designated personnel, under the The commitment wording was standardized and decon) is accomplished as described direction of the Radiation Protection Group, relocated to the SNC Standard Emergency Plan. in plant health physics procedures are responsible for performing material and ranges from vacuum cleaning to decontamination. Procedures and equipment wash downs with water and acid or for material decontamination are available at caustic solutions. the plant, as specified in the site radiation protection proqram. Section K.3: Personnel exiting the EP K.5: Personnel leaving the Radiological The commitment wording was standardized and radiation-controlled area will be Controlled Area (RCA) or leaving a relocated to the SNC Standard Emergency Plan. monitored for contamination by contaminated area will be monitored for stand-up monitoring booths or by a contamination. whole-body scan with a hand-held probe. Section K.4: Access control is B.2.1.14 Security Supervisor The commitment wording was standardized and provided by the Security Department The Security Supervisor reports to the TSC relocated to the SNC Standard Emergency Plan. during emergency conditions. Manager. The TSC Security Supervisor is responsible for carrying out the plant security and Access Control program, maintaining personnel accountability onsite, and assisting in evacuation of onsite areas. E12-153 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section K.3: Plant areas that require EP K.5: The Radiation Protection Group will be The commitment wording was standardized and access to facilitate recovery responsible for controlling or minimizing direct relocated to the SNC Standard Emergency Plan. operations will be surveyed with or subsequent internal exposure from portable instruments equipped with radioactive materials deposited on the ground Beta/Gamma detectors. or other surfaces, and for determining the Section K.4: Emergency monitoring extent of contamination in controlled and teams are responsible for normally uncontrolled areas. During normal determining the need for onsite conditions or an emergency, guidelines to access control and establishing the follow for contamination limits are established proper method through discussions by the site radiation protection program. with technical support center (TSC) Facilities and supplies for decontaminating personnel. personnel are available at various plant Section K.4: Plant procedures used locations. Personnel leaving the Radiological for determining contaminated areas Controlled Area (RCA) or leaving a will be used for determining the need contaminated area will be monitored for for access control. contamination. During emergencies, other onsite personnel will be checked for contamination as necessary. Designated personnel, under the direction of the Radiation Protection Group, are responsible for performing material decontamination. Procedures and equipment for material decontamination are available at the plant, as specified in the site radiation protection program. Section K.3: The standard health EP K.5: Facilities and supplies for The commitment wording was standardized and physics contamination limits will be decontaminating personnel are available at relocated to the SNC Standard Emergency Plan. used for release of personnel. various plant locations. Personnel leaving the Radiological Controlled Area (RCA) or leaving a contaminated area will be monitored for contamination. During emergencies, other onsite personnel will be checked for contamination as necessary. E12-154 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section K.4: The emergency health EP K.5: The Radiation Protection Group will be The commitment wording was standardized and physics supervisor is responsible for responsible for controlling or minimizing direct relocated to the SNC Standard Emergency Plan. permitting return of onsite areas and or subsequent internal exposure from equipment to normal use once radioactive materials deposited on the ground monitoring and decontamination are or other surfaces, and for determining the completed. extent of contamination in controlled and normally uncontrolled areas. During normal conditions or an emergency, guidelines to follow for contamination limits are established by the site radiation protection proqram. Section L.1: There are personnel on EP K.1.2.1: Selected plant workers at SNC- The commitment wording was standardized and shift and in the Emergency operated plants have received first aid and relocated to the SNC Standard Emergency Plan. Organization trained in first aid and decontamination training. decontamination procedures. EP 0.3: Individuals assigned as First Aid Table 2 of the Site Annex retains the commitment responders shall maintain qualifications for first for on-shift capability to perform the function. aid and Cardio-Pulmonary Resuscitation (CPR) traininq. Section L.1: The onsite personnel EP K.1.2.1: Selected plant workers at SNC-responsible for responding to a operated plants have received first aid and The commitment wording was standardized and medical emergency have had decontamination training. relocated to the SNC Standard Emergency Plan. training per the OSHA standard 29 EP 0.3: Individuals assigned as First Aid CFR 1910.151 and directive OSHA responders shall maintain qualifications for first Table 2 of the Site Annex retains the commitment 3317-06N, Fundamentals of a aid and Cardio-Pulmonary Resuscitation for on-shift capability to perform the function. Workplace First-Aid Proqram (CPR) traininq. Section L.1: Health physics EP K.1.2.1: Selected plant workers at SNC- The commitment wording was standardized and technicians will be assigned to first operated plants have received first aid and relocated to the SNC Standard Emergency Plan. aid teams in accordance with decontamination training. Procedure 70302-C, Reporting and EP 0.3: Individuals assigned as First Aid Table 2 of the Site Annex retains the commitment Documenting Occupational Injuries responders shall maintain qualifications for first for on-shift capability to perform the function. Or Illnesses. aid and Cardio-Pulmonary Resuscitation (CPR) traininq. Section L.1: Personnel found to be EP K.5: Facilities and supplies for The commitment wording was standardized and externally contaminated but not decontaminating personnel are available at relocated to the SNC Standard Emergency Plan. requiring immediate medical various plant locations. Personnel leaving the attention will undergo Radiological Controlled Area (RCA) or leaving decontamination in accordance with a contaminated area will be monitored for plant procedures. contamination. During emergencies, other onsite personnel will be checked for contamination as necessary. E12-155 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section L.2: Injured and EP L.1: In addition to the on-site first aid The commitment wording was standardized and contaminated personnel requiring response, arrangements have been made with relocated to the SNC Standard Emergency Plan hospital medical attention will be local hospitals for treatment and evaluation of and Site Annex. transported to Doctors Hospital, serious injuries or sicknesses. Augusta, or Burke County Hospital, SNC-operated nuclear power plants have Waynesboro, by the Burke County arranged for hospital and medical services Ambulance Service. Letters of having the capability to evaluate radiation agreement pertaining to these exposure and uptake, including assurance that services are located in Appendix 2. persons providing these services are adequately prepared to handle contaminated individuals. Annex 5.8.1: Agreements are in place with Burke Medical Center, Doctors Hospital, and Burke County Emergency Management Agency to provide assistance for injured personnel, including cases involving radioactive contamination. This assistance will be requested whenever necessary in accordance with plant procedures. Annex 5.8.2: Ambulance service is provided by the Burke County Emergency Management Agency. Section L.1: In addition, an onsite EP K.5: Facilities and supplies for The commitment wording was standardized and first aid and decontamination area decontaminating personnel are available at relocated to the SNC Standard Emergency Plan. equipped with decontamination various plant locations. supplies and other specialized EP L.2: SNC-operated nuclear power plants equipment is located near the health maintain onsite first aid supplies and physics station on the 220 ft equipment necessary for the treatment of elevation in the control buildinQ. contaminated and/or injured persons. E12-156 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section L.2: All contaminated EP L.4: Contaminated and injured persons are The commitment wording was standardized and materials will be properly packaged transported to a facility specified for SNC- relocated to the SNC Standard Emergency Plan. and returned to the site for disposal. operated nuclear power plants. Arrangements have been made by nuclear power plants for ambulance transport of persons with injuries involving radioactivity to designated hospitals. Such services are available on a 24-hour-per-day basis and are confirmed by letters of agreement. Radiation monitoring services are provided by SNC plant personnel whenever it becomes necessary to use an ambulance service for the transportation of contaminated persons. Section L.2: A health physics EP L.4: Radiation monitoring services are The commitment wording was standardized and technician (HPT) will accompany the provided by SNC plant personnel whenever it relocated to the SNC Standard Emergency Plan patient to the hospital. becomes necessary to use an ambulance and Site Annex. service for the transportation of contaminated persons. Section A.7: VEGP has established Annex 5.8.2: Injured/externally contaminated The commitment wording was standardized and agreements with the Burke County personnel who require medical attention will relocated to the Site Annex. EMA to provide ambulance service normally be transported by ambulance to the for the transportation of injured cooperating hospitals. Ambulance crews are personnel, including people who may trained to handle external contamination be radioactively contaminated, to cases, and an RP technician accompanies any hospital facilities for treatment. contaminated patients to the hospital. Ambulance service is provided by the Burke County Emergency Management Agency. E12-157 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section L.2: Injured and Annex 5.8.1: Agreements are in place with the The commitment wording was standardized and contaminated personnel requiring University of Alabama at Birmingham (UAB) relocated to the SNC Standard Emergency Plan. hospital medical attention will be Hospital, Burke Medical Center, Doctors transported to Doctors Hospital, Hospital, and Burke County Emergency Augusta, or Burke County Hospital, Management Agency to provide assistance for Waynesboro, by the Burke County injured personnel, including cases involving Ambulance Service. radioactive contamination. This assistance will Section L.3: Arrangements for be requested whenever necessary in treating externally contaminated accordance with plant procedures. patients have been made with the Doctors Hospital in Augusta, Georgia, and Burke County Hospital in Waynesboro, Georgia, (appendix 2). Section L.3: The medical staff of the EP L.1: The hospitals are equipped and The commitment wording was standardized and hospital is trained to treat externally hospital personnel trained to address relocated to the SNC Standard Emergency Plan. contaminated patients or individuals contaminated injured individuals. Training of who have received high exposures. medical support personnel at the agreement hospitals includes basic training on the nature of radiological emergencies, diagnosis and treatment, and follow-up medical care. Section L.2: The HPT will perform Annex 5.8.2: Injured/externally contaminated The commitment wording was standardized and radiation surveys of the patient, personnel who require medical attention will relocated to the Site Annex. ambulance, and attending hospital normally be transported by ambulance to the staff and assist in maintaining cooperating hospitals. Ambulance crews are contamination control in the hospital. trained to handle external contamination Section l.3: Trained plant radiation cases, and an RP technician accompanies any protection personnel will assist contaminated patients to the hospital. hospital staff when plant personnel Ambulance service is provided by the Burke are beinq evaluated. County Emerqencv Manaqement Aqencv. E12-158 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section L.2: The ambulance will also Annex 5.8.2: Injured/externally contaminated The commitment wording was standardized and be decontaminated at VEGP if personnel who require medical attention will relocated to the Site Annex. required. normally be transported by ambulance to the cooperating hospitals. Ambulance crews are trained to handle external contamination cases, and an RP technician accompanies any contaminated patients to the hospital. Ambulance service is provided by the Burke County Emerqencv Manaqement Aqencv. Section L.3: Following Annex 5.8.1: Agreements are in place with The SNC Standard Emergency Plan commits to decontamination, personnel Burke Medical Center, Doctors Hospital, and maintaining agreements supporting the treatment suspected to have ingested Burke County Emergency Management of contaminated and/or injured personnel. Medical radionuclides will undergo whole Agency to provide assistance for injured experts will determine the course of treatment and body counting at VEGP. personnel, including cases involving subsequent monitoring. A specific commitment for radioactive contamination. This assistance will internal monitoring at the site may or may not be be requested whenever necessary in included in this post event treatment. accordance with plant procedures. Section L.3: Arrangements have also EP L.3: The states of Alabama and Georgia The commitment wording was standardized and been made with local doctors to have developed lists of facilities that can relocated tb the SNC Standard Emergency Plan render medical assistance, both provide medical support for treating injured, and Site Annex. onsite and offsite, and to assume contaminated individuals. Details are found in responsibility for the medical the respective state emergency plan. supervision of the patient (appendix Annex 2.3.2: Agreements are in place with the 2, Letters of Agreement). University of Alabama at Birmingham (UAB) Hospital, Burke Medical Center, Doctors Hospital, and Burke County Emergency Management Agency to provide assistance for injured personnel, including cases involving radioactive contamination. This assistance will be requested whenever necessary in accordance with plant procedures. Medical Specialists, Inc., a group of medical professionals, has agreed to provide treatment services through Burke Medical Center and Doctors Hospital. E12-159

Enclosure 12 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section L.4: The VEGP training EP 0.1.1: Annually, training will be offered for The commitment wording was standardized and department conducts training hospital personnel, ambulance and rescue relocated to the SNC Standard Emergency Plan.

sessions at least once per calendar personnel, police, and fire departments. The year (for onsite and offsite personnel training shall include the procedures for who have medical support notification, basic radiation protection, and responsibilities). their orqanizations' expected role. Section L.4: In addition, drills and EP N.2.3: A medical emergency drill, involving The commitment wording was standardized and exercises are an integral part of the a simulated contaminated individual, and relocated to the SNC Standard Emergency Plan. training program and are conducted containing provisions for participation by local as specified in section N, Exercises support services organizations including and Drills. ambulance response, are conducted annually at the nuclear plants. Local support service organizations that support more than one plant shall only be required to participate once each calendar year. Section M.1: The emergency director EP M.1: Upon termination of the emergency The commitment wording was standardized and will determine when the recovery phase and at the discretion of the Emergency relocated to the SNC Standard Emergency Plan. phase begins. Director, following consultation with offsite authorities, the SNC Emergency Organization will shift to the Recovery Phase Organization. E12-160 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section M.1: The following EP M.1: The following guidelines, as The commitment wording was standardized and guidelines, as applicable to the applicable to the specific situation, will be relocated to the SNC Standard Emergency Plan. specific situation, will be observed addressed prior to terminating the emergency: prior to terminating the emergency:

The affected reactor is in a stable condition

1. The affected reactor is in a stable and can be maintained in that condition condition and can be maintained in indefinitely.

that condition indefinitely.

Plant radiation levels are stable or are

2. Plant radiation levels are stable or decreasing with time.

are decreasing with time.

Releases of radioactive material to the

3. Releases of radioactive material to environment have ceased or are being the environment have ceased or are controlled within permissible limits.

being controlled within permissible

Fire or similar emergency conditions no limits. longer constitute a hazard to safety-related

4. Fire or similar emergency systems or equipment or personnel.

conditions no longer constitute a hazard to safety-related systems or

For a site area emergency or general emergency, discussions with plant equipment or personnel. management, applicable members of the

5. For a site area emergency or SNC emergency organization, or offsite general emergency, discussions with authorities do not result in identification of plant management, applicable any valid reason for not terminating the members of the VEGP emergency emergency.

organization, offsite authorities including the Nuclear Regulatory Commission (NRC); Georgia Emergency Management Agency, Burke County Emergency Management Agency director; South Carolina Emergency Management Division director; and Savannah River Site (SRS) emergency staff do not result in identification of any valid reason for not terminating the emergency. E12-161 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section M.1: He (ED) will direct that EP M.3: Members of the ERO will be informed The commitment wording was standardized and all elements of the emergency when Recovery is initiated. The recovery relocated to the SNC Standard Emergency Plan response organization be advised of organization may be structured like the the change in status via the emergency response organization with Emergency Notification Network additional modifications depending on the (ENN), Emergency Notification nature of the accident, post-accident conditions, System (ENS), and other pertinent and other factors. communications systems. The state EOC will be advised when the plant deems it safe to begin the reentry phase of the offsite recovery operation. If the governor ordered an evacuation, the law requires the governor to officially rescind the order before any return can be made to evacuated areas. The states are responsible for coordinating reentry procedures for the offsite population. EP M.5: Following the completion of the Recovery Phase, the site will transition to an Outage Organization to complete necessary repairs. Section M.1: At this time, the EP M.1: The Emergency Director will designate The commitment wording was standardized and emergency director will designate a a recovery manager to constitute the recovery relocated to the SNC Standard Emergency Plan. recovery manager to constitute the organization. recoverv oroanization. E12-162 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section M.2: Individuals will be EP M.1: The Recovery Manager will structure The commitment wording was standardized and assigned to specific positions by the the recovery organization to accomplish the relocated to the SNC Standard Emergency Plan. recovery manager, depending on the following general objectives: nature and extent of damage to the

Maintain comprehensive radiation plant. surveillance of the site until levels return to normal.
Control access to the affected area of the plant and exposures to workers.
Decontaminate affected areas and equipment.
Conduct activities in radiation areas in accordance with the plant's standard radiation work practices.
Isolate and repair damaged systems.
Document proceedings of the accident and review the effectiveness of the emergency response organization in mitigating plant damage and reducing radiation exposures to the public.
Provide offsite authorities with plant status reports and information concerning the plant recovery organization.
Provide assistance with recovery activities undertaken by state and county authorities, if requested.
Provide public information on the status of recovery operations in releases to the media.

E12-163 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section M.2 : He (Recovery EP M.1: The Recovery Manager will structure The commitment wording was standardized and Manager) will structure the recovery the recovery organization to accomplish the relocated to the SNC Standard Emergency Plan. organization to accomplish the following general objectives: following general objectives:

Maintain comprehensive radiation

1. Maintain comprehensive radiation surveillance of the site until levels return to surveillance of the site until levels normal.

return to normal.

Control access to the affected area of the

2. Control access to the affected plant and exposures to workers.

area of the plant and exposures to

Decontaminate affected areas and workers. equipment.

3. Decontaminate affected areas and

Conduct activities in radiation areas in equipment. accordance with the plant's standard

4. Conduct activities in radiation radiation work practices.

areas in accordance with the plant's

Isolate and repair damaged systems.

standard radiation work practices.

Document proceedings of the accident and

5. Isolate and repair damaged review the effectiveness of the emergency systems. response organization in mitigating plant

6. Document proceedings of the damage and reducing radiation exposures to accident and review the the public.

effectiveness of the emergency

Provide offsite authorities with plant status response organization in mitigating reports and information concerning the plant plant damage and reducing radiation recovery organization.

exposures to the public.

Provide assistance with recovery activities

7. Provide offsite authorities with undertaken by state and county authorities, if plant status reports and information requested.

concerning the plant recovery

Provide public information on the status of organization.

recovery operations in releases to the media.

8. Provide assistance with recovery activities undertaken by State and county authorities, if requested.

9. Provide public information on the status of recovery operations via releases to the media.

E12-164 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section M.2: Recovery manager: EP M.1: Guidance for determining the transition The Statement on return to normal operations is has overall responsibility for from Emergency to Recovery Organization is not appropriate for the Plan. Normal operations, restoring the station to a normal provided in the plant Emergency Plan extended shutdown, or decommissioning are all operating configuration. Implementing Procedures. The composition of potential outcomes of events involving activation of the Recovery Organization will depend on the the Emergency Plan. The outcome will be nature of the accident and the conditions determined on a site-specific basis through following the accident. transition from the Emergency Phase. The SNC Emergency Plan addresses general principles that serve as guides for developing a Recovery Plan. It is the responsibility of the Emergency Director (ED) to determine that the facility and surroundings are safe for reentry. The Emergency Director will designate a recovery manager to constitute the recovery organization. The following guidelines, as applicable to the specific situation, will be addressed prior to terminating the emergency:

The affected reactor is in a stable condition and can be maintained in that condition indefinitely.
Plant radiation levels are stable or are decreasing with time.
Releases of radioactive material to the environment have ceased or are being controlled within permissible limits.
Fire or similar emergency conditions no longer constitute a hazard to safety-related systems or equipment or personnel.
For a site area emergency or general emergency, discussions with plant management, applicable members of the SNC emergency organization, or offsite authorities do not result in identification of any valid reason for not terminating the emergency.

EP M.5: Following the completion of the Recovery Phase, the site will transition to an Outage OrQanization to complete necessarv repairs. E12-165 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section M.2: Plant operations EP M.1: The Recovery Manager will structure The SNC Standard Emergency Plan provides a manager: manages day-to-day in- the recovery organization to accomplish the likely recovery organization and provides overall plant operations and during following general objectives: responsibility for the event under the Recovery recovery, is responsible for ensuring

Maintain comprehensive radiation Manager.

that repairs and modifications will surveillance of the site until levels return to optimize post recovery plant normal. The specific event will drive individual operational effectiveness and safety.

Control access to the affected area of the responsibilities.

plant and exposures to workers.

Decontaminate affected areas and equipment.
Conduct activities in radiation areas in accordance with the plant's standard radiation work practices.
Isolate and repair damaged systems.
Document proceedings of the accident and review the effectiveness of the emergency response organization in mitigating plant damage and reducing radiation exposures to the public.
Provide offsite authorities with plant status reports and information concerning the plant recovery organization.
Provide assistance with recovery activities undertaken by state and county authorities, if requested.
Provide public information on the status of recovery operations in releases to the media.

E12-166 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section M.2: Design and EP M.1: The Recovery Manager will structure The SNC Standard Emergency Plan provides a construction support manager: the recovery organization to accomplish the likely recovery organization and provides overall focuses necessary engineering, following general objectives: responsibility for the event under the Recovery design, and construction resources

Maintain comprehensive radiation Manager.

on those aspects of plant recovery surveillance of the site until levels return to requiring redesign, modifications, or normal. The specific event will drive individual new construction.

Control access to the affected area of the responsibilities.

plant and exposures to workers.

Decontaminate affected areas and equipment.
Conduct activities in radiation areas in accordance with the plant's standard radiation work practices.
Isolate and repair damaged systems.
Document proceedings of the accident and review the effectiveness of the emergency response organization in mitigating plant damage and reducing radiation exposures to the public.
Provide offsite authorities with plant status reports and information concerning the plant recovery organization.
Provide assistance with recovery activities undertaken by state and county authorities, if requested.
Provide public information on the status of recovery operations in releases to the media.

E12-167 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section M.2: Chemistry manager: EP M.1: The Recovery Manager will structure The SNC Standard Emergency Plan provides a develops plans and procedures to the recovery organization to accomplish the likely recovery organization and provides overall process and control liquid, gaseous, following general objectives: responsibility for the event under the Recovery and solid wastes to minimize

Maintain comprehensive radiation Manager.

adverse effects on the health and surveillance of the site until levels return to safety of the public and plant normal. The specific event will drive individual recovery personnel.

Control access to the affected area of the responsibilities.

plant and exposures to workers.

Decontaminate affected areas and equipment.
Conduct activities in radiation areas in accordance with the plant's standard radiation work practices.
Isolate and repair damaged systems.
Document proceedings of the accident and review the effectiveness of the emergency response organization in mitigating plant damage and reducing radiation exposures to the public.
Provide offsite authorities with plant status reports and information concerning the plant recovery organization.
Provide assistance with recovery activities undertaken by state and county authorities, if requested.
Provide public information on the status of recovery operations in releases to the media.

E12-168 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section M.2: Health physics EP M.1: The Recovery Manager will structure The SNC Standard Emergency Plan provides a manager: responsible for As Low As the recovery organization to accomplish the likely recovery organization and provides overall Reasonably Achievable (ALARA) following general objectives: responsibility for the event under the Recovery planning, execution, and monitoring;

Maintain comprehensive radiation Manager.

plans and manages decontamination surveillance of the site until levels return to of affected areas and equipment; normal. The specific event will drive individual supervises and directs all special

Control access to the affected area of the responsibilities.

radiological controls required to plant and exposures to workers. support the recovery operation.

Decontaminate affected areas and equipment.
Conduct activities in radiation areas in accordance with the plant's standard radiation work practices.
Isolate and repair damaged systems.
Document proceedings of the accident and review the effectiveness of the emergency response organization in mitigating plant damage and reducing radiation exposures to the public.
Provide offsite authorities with plant status reports and information concerning the plant recovery organization.
Provide assistance with recovery activities undertaken by state and county authorities, if requested.
Provide public information on the status of recovery operations in releases to the media.

E12-169 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section M.2: Technical support EP M.1: The Recovery Manager will structure The SNC Standard Emergency Plan provides a manager: provides analyses, plans, the recovery organization to accomplish the likely recovery organization and provides overall schedules, and procedures in direct following general objectives: responsibility for the event under the Recovery support of plant operations.

Maintain comprehensive radiation Manager.

surveillance of the site until levels return to normal. The specific event will drive individual

Control access to the affected area of the responsibilities.

plant and exposures to workers.

Decontaminate affected areas and equipment.
Conduct activities in radiation areas in accordance with the plant's standard radiation work practices.
Isolate and repair damaged systems.
Document proceedings of the accident and review the effectiveness of the emergency response organization in mitigating plant damage and reducing radiation exposures to the public.
Provide offsite authorities with plant status reports and information concerning the plant recovery organization.
Provide assistance with recovery activities undertaken by state and county authorities, if requested.
Provide public information on the status of recovery operations in releases to the media.

E12-170 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section M.2: Quality assurance EP M.1: The Recovery Manager will structure The SNC Standard Emergency Plan provides a manager: ensures that the overall the recovery organization to accomplish the likely recovery organization and provides overall conduct of recovery operations is following general objectives: responsibility for the event under the Recovery performed in accordance with

Maintain comprehensive radiation Manager.

corporate policy and rules and surveillance of the site until levels return to regulations governing activities normal. The specific event will drive individual which may affect public health and

Control access to the affected area of the responsibilities.

safety. plant and exposures to workers.

Decontaminate affected areas and equipment.
Conduct activities in radiation areas in accordance with the plant's standard radiation work practices.
Isolate and repair damaged systems.
Document proceedings of the accident and review the effectiveness of the emergency response organization in mitigating plant damage and reducing radiation exposures to the public.
Provide offsite authorities with plant status reports and information concerning the plant recovery organization.
Provide assistance with recovery activities undertaken by state and county authorities, if requested.
Provide public information on the status of recovery operations in releases to the media.

E12-171 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section M.2: Scheduling/planning EP M.1: The Recovery Manager will structure The SNC Standard Emergency Plan provides a manager: prepares plans and the recovery organization to accomplish t~e likely recovery organization and provides overall schedules and tracks/expedites following general objectives: responsibility for the event under the Recovery recovery operations.

Maintain comprehensive radiation Manager.

surveillance of the site until levels return to normal. The specific event will drive individual

Control access to the affected area of the responsibilities.

plant and exposures to workers.

Decontaminate affected areas and equipment.
Conduct activities in radiation areas in accordance with the plant's standard radiation work practices.
Isolate and repair damaged systems.
Document proceedings of the accident and review the effectiveness of the emergency response organization in mitigating plant damage and reducing radiation exposures to the public.
Provide offsite authorities with plant status reports and information concerning the plant recovery organization.
Provide assistance with recovery activities undertaken by state and county authorities, if requested.
Provide public information on the status of recovery operations in releases to the media.

E12-172 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section M.2: Administration/logistics EP M.1: The Recovery Manager will structure The SNC Standard Emergency Plan provides a manager: supplies administrative, the recovery organization to accomplish the likely recovery organization and provides overall logistic, communications, and following general objectives: responsibility for the event under the Recovery personnel support for the recovery

Maintain comprehensive radiation Manager.

operation. surveillance of the site until levels return to normal. The specific event will drive individual

Control access to the affected area of the responsibilities.

plant and exposures to workers.

Decontaminate affected areas and equipment.
Conduct activities in radiation areas in accordance with the plant's standard radiation work practices.
Isolate and repair damaged* systems.
Document proceedings of the accident and review the effectiveness of the emergency response organization in mitigating plant damage and reducing radiation exposures to the public.
Provide offsite authorities with plant status reports and information concerning the plant recovery organization.
Provide assistance with recovery activities undertaken by state and county authorities, if requested.
Provide public information on the status of recovery operations in releases to the media.

E12-173 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section M.2: Public information EP M.1: The Recovery Manager will structure The SNC Standard Emergency Plan provides a director: coordinates the flow of the recovery organization to accomplish the likely recovery organization and provides overall media information concerning following general objectives: responsibility for the event under the Recovery recovery operations.

Maintain comprehensive radiation Manager.

surveillance of the site until levels return to normal. The specific event will drive individual

Control access to the affected area of the responsibilities.

plant and exposures to workers.

Decontaminate affected areas and equipment.
Conduct activities in radiation areas in accordance with the plant's standard radiation work practices.
Isolate and repair damaged systems.
Document proceedings of the accident and review the effectiveness of the emergency response organization in mitigating plant damage and reducing radiation exposures to the public.
Provide offsite authorities with plant status reports and information concerning the plant recovery organization.
Provide assistance with recovery activities undertaken by state and county authorities, if requested.
Provide public information on the status of recovery operations in releases to the media.

Section M.3: If the accident situation EP M.1: Recovery operations will be The commitment wording was standardized and involved a release of radioactivity, conducted in compliance with normal relocated to the SNC Standard Emergency Plan appropriate areas of the plant and operational radiation exposure level limits as site will be monitored to determine specified in 10 CFR 20. When possible, any contamination and radiation levels. necessary releases of radioactive materials or effluent during recovery will be planned, controlled, evaluated in advance for radiological impact, and appropriate offsite organizations and agencies informed of the scheduled releases and estimated impact. E12-174 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section M.3: Identifying and EP M.1: Recovery operations will be The commitment wording was standardized and controlling access to these areas will conducted in compliance with normal relocated to the SNC Standard Emergency Plan be in accordance with normal plant operational radiation exposure level limits as procedures. specified in 10 CFR 20. When possible, any necessary releases of radioactive materials or effluent during recovery will be planned, controlled, evaluated in advance for radiological impact, and appropriate offsite organizations and agencies informed of the scheduled releases and estimated impact. Section M.3: When reentry to a EP M.1: Recovery operations will be The commitment wording was standardized and radiation area is required for conducted in compliance with normal relocated to the SNC Standard Emergency Plan inspection or work, the activity will be operational radiation exposure level limits as preplanned and plant radiation work specified in 10 CFR 20. When possible, any practices and As Low As necessary releases of radioactive materials or Reasonably Achievable (ALARA) effluent during recovery will be planned, program principles will be followed. controlled, evaluated in advance for radiological impact, and appropriate offsite organizations and agencies informed of the scheduled releases and estimated impact. Section M.4: All personnel who EP M.1: Recovery operations will be The commitment wording was standardized and require access to the plant or to conducted in compliance with normal relocated to the SNC Standard Emergency Plan radiation areas on site during the operational radiation exposure level limits as recovery phase will be issued specified in 10 CFR 20. When possible, any dosimetry, as appropriate. necessary releases of radioactive materials or effluent during recovery will be planned, controlled, evaluated in advance for radiological impact, and appropriate offsite organizations and agencies informed of the scheduled releases and estimated impact. E12-175 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section M.4: The criteria for reading EP M.1: Recovery operations will be The commitment wording was standardized and TLDs and assessing radiation dose conducted in compliance with normal relocated to the SNC Standard Emergency Plan will be in accordance with standard operational radiation exposure level limits as health physics practices. specified in 10 CFR 20. When possible, any necessary releases of radioactive materials or effluent during recovery will be planned, controlled, evaluated in advance for radiological impact, and appropriate offsite organizations and agencies informed of the scheduled releases and estimated impact. Section M.4: The results of the EP M.1: Recovery operations will be The commitment wording was standardized and dosimeter readings, including conducted in compliance with normal relocated to the SNC Standard Emergency Plan integrated exposures (i.e., man- operational radiation exposure level limits as rems) will be reported to the specified in 10 CFR 20. When possible, any recovery manager, the necessary releases of radioactive materials or radcon/radwaste manager, and effluent during recovery will be planned, others in the plant organization who controlled, evaluated in advance for normally receive such reports radiological impact, and appropriate offsite organizations and agencies informed of the scheduled releases and estimated impact. Section M.4: VEGP will provide EP M.4: It is anticipated that the Federal Section B of the Standard Emergency Plan retains radiological information including Radiological Monitoring andAssessment the commitment to provide environmental field estimated quantity of radioactivity Center (FRMAC) will make a total population teams. released, isotopic composition of exposure calculation, based on estimated dose The progression of the overall planning process released material, and rates and population representing exposed has shifted the long term responsibilities for offsite meteorological data to assist the areas. radiological assessment to the FRMAC. governmental authorities in their determinations. E12-176 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section N.1: Exercises are EP N.1: SNC-operated nuclear power plants will The commitment wording was standardized and conducted every two calendar years, conduct a biennial exercise and additional relocated to the SNC Standard Emergency Plan and are designed to include the periodic drills. An exercise is an event that tests demonstration of response to a integrated capability, and a major portion of the major portion of the basic elements basic elements of emergency preparedness of the emergency preparedness plans and organizations. Drills and exercises plans of the participating shall: organizations.

Test the adequacy of timing and content of implementing procedures and methods.
Test emergency equipment and communications networks.
Test the public notification system.
Ensure emergency organization personnel are familiar with their duties.

E12-177 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section N.1: The exercise program EP N.1.2: Full participation exercises will The commitment wording was standardized and for VEGP consists of an 8 year cycle include, as appropriate, offsite local and state relocated to the SNC Standard Emergency Plan. and incorporates the following authorities and SNC personnel actively The wording has been updated to reflect the features: participating in testing the integrated capability Enhanced Emergency Preparedness Rulemaking

1. A full participation exercise which to assess and respond to an accident at a (November 23, 2011) tests as much of the Plant Vogtle, nuclear power plant. Additionally, full State, and local emergency plans as participation exercises will include, as is reasonable achievable without appropriate, testing the major observable mandatory public participation will be portions of the onsite and offsite emergency conducted on a biennial basis and plans and mobilization of state, local, and SNC evaluated by NRC and FEMA. personnel and other resources in sufficient

2. Biennial exercise scenarios will be numbers to verify the capability to respond to submitted to the NRC under § 50.4 the accident scenario.

at least 60 days before use in the EP N.2.1: During these drills, activation of the biennial exercise. licensee's emergency response facilities TSC

3. Each biennial exercise scenario OSC, and the EOF would not be necessary, will provide the opportunity for the the ERO would have the opportunity to ERO to perform their key skills as consider accident management strategies, applicable to their emergency supervised instruction would be permitted, response duties in the CR, TSC, operating staff in participating facilities would OSC, EOF, and joint information have the opportunity to resolve problems center to implement the EP principal (success paths) rather than have controllers functional areas. intervene, and the drills may focus on the onsite exercise training objectives.

EP N.1.5: The Exercise planning cycle will consist of eight (8) successive calendar years. EP N.3: SNC sites submit Biennial Exercise scenarios under 10 CFR 50.4 for NRC review 60 days prior to the exercise. E12-178 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section N.1 (Continued) EP N.3: During the exercise planning cycle

4. Biennial evaluated exercises will described in Section N.1.5, SNC sites vary the be varied such that the following content of exercise scenarios to provide ERO scenario elements are demonstrated members the opportunity to demonstrate over the course of an 8 year exercise proficiency in key skills necessary to respond cycle: to several specific scenario elements including:

Hostile action directed at the plant
Hostile Action directed at the plant site .

site.

No radiological release or unplanned
No radiological release or an release that does not require public unplanned minimal radiological protective actions.

release that does not require public

An initial classification of or rapid protective actions. escalation to a Site Area Emergency or
Initial classification of or rapid General Emergency.

escalation to a Site Area Emergency

Implementation of strategies, procedures, or General Emergency. and guidance developed in 50.54(hh), (i.e.,
Implementation of strategies, potential aircraft threat, explosion or large procedures, and guidance developed fire).

under 10 CFR 50.54(hh)(2).

Integration of offsite resources with
Integration of offsite resources with onsite response onsite response.
A drill initiated between the hours of 6 p.m .

and 4 a.m.

Drills using essentially 100 percent of Initiating Conditions in the 8-year cycle.

EP N.1.4: Hostile Action Based (HAS) exercises involving an air, land, or water based attack scenario will be conducted at sites on a frequency of at least once every 8 years. EP N.2.6: Accountability drills are conducted annually. EP N.2.8: At least one per drill cycle, a scenario resulting in an initial classification of, or rapid escalation to a Site Area or General Emergency, will be conducted. EP N.2.9: At least once per drill cycle, a scenario resulting in no radiological release, or an unplanned minimal release resulting in a classification of a Site Area Emergency but not requiring declaration of a General Emergency, shall be conducted. E12-179 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section N.1 (Continued) EP N.1.3: States within an ingestion exposure The commitment wording was standardized and

5. An ingestion pathway exercise will pathway EPZ, are expected to exercise its relocated to the SNC Standard Emergency Plan be conducted on a frequency to plans and preparedness related to ingestion ensure the applicable States have exposure pathway measures at least once the opportunity to participate in an every 8 years.

ingestion pathway exercise at least once everv exercise cycle. Section N.2.1: At least one of these EP N.2.1: SNC-operated nuclear power plants The commitment wording was standardized and drills will be conducted during the shall ensure adequate emergency response relocated to the SNC Standard Emergency Plan calendar year when there is no capabilities are maintained during the interval biennial exercise and shall involve a between biennial exercises by conducting combination of some of the principal drills, including at least one drill involving a functional areas of the onsite combination of some of the principal functional emergency response capabilities. areas of the licensee's onsite emergency response capabilities. The principal functional areas of emergency response include:

Management and coordination of emergency response.
Accident assessment.
Event classification.
Notification of offsite authorities.
Assessment of the onsite and offsite impact of radiological releases.
Protective action recommendation development.
Protective action decision making.
Plant system repair and corrective actions.

During these drills, activation of the licensee's emergency response facilities (TSC, OSC, and the EOF) would not be necessary, the ERO would have the opportunity to consider accident management strategies, supervised instruction would be permitted, operating staff in participating facilities would have the opportunity to resolve problems (success paths) rather than have controllers intervene, and the drills may focus on the onsite exercise training objectives. E12-180 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section N.2.1: The ERO (not EP N.3: During the exercise planning cycle The commitment wording was standardized and necessarily each ERO team) will be described in Section N.5, SNC sites vary the relocated to the SNC Standard Emergency Plan. provided the opportunity to content of exercise scenarios to provide ERO demonstrate key skills in response to members the opportunity to demonstrate Section EP N.2.1 is directed to types of the following scenario elements in proficiency in key skills necessary to respond drills/exercises. The existing requirement to drills or exercises. to several specific scenario elements including: respond to essentially 100% of initiating conditions

All functions in each ERF (e.g., all
Hostile Action directed at the plant site. is moved to Section N.3 of SNC Standard ERFs that are responsible for dose
No radiological release or unplanned release Emergency Plan.

assessment perform those duties in that does not require public protective response to a radiological release). actions.

Use of alternative facilities to stage
An initial classification of or rapid escalation the ERO for rapid activation during to a Site Area Emergency or General hostile action. Emergency.
Real-time staffing of facilities during
Implementation of strategies, procedures, off hours (i.e., 6:00 p.m. to 4:00 and guidance developed in 50.54(hh), (i.e.,

a.m.). potential aircraft threat, explosion or large

Providing medical care for injured, fire).

contaminated personnel (every 2

Integration of offsite resources with onsite years). response
Response to essentially 100
A drill initiated between the hours of 6 p.m.

percent of initiating conditions and 4 a.m. identified in the site emergency plan

Drills using essentially 100 percent of implementing procedure for Initiating Conditions in the 8-year cycle.

classification of emergencies. EP N.2.3: A medical emergency drill, involving a ~ simulated contaminated individual, and containing provisions for participation by local support services organizations including ambulance response, are conducted annually at the nuclear plants EP N.3:. During the exercise planning cycle described in Section N.1.5, SNC sites vary the content of exercise scenarios to provide ERO members the opportunity to demonstrate proficiency in key skills necessary to respond to several specific scenario elements including:

A drill initiated between the hours of 6 p.m.

and 4 a.m. E12-181 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section N.2.1 (Continued) EP N.1.4:Hostile Action Based (HAB)

Response to actual industry event Exercises sequences appropriate for the Hostile Action Based (HAB) exercises involving nuclear plant technology (e.g., an air, land, or water based attack scenario will BWR). be conducted at sites on a frequency of at least
Use of procedures developed in once every 8 years.

response to an aircraft threat and in EP N.3: During the exercise planning cycle compliance with 10 CFR described in Section N.1.5, SNC sites vary the 50.54(hh)(1 ). content of exercise scenarios to provide ERO

Use of the strategies associated members the opportunity to demonstrate with 10 CFR 50.54(hh)(2) to mitigate proficiency in key skills necessary to respond to spent fuel pool damage scenarios several specific scenario elements including:

(all strategies, such as makeup,

Implementation of strategies, procedures, spray, and leakage control, but not and guidance developed in 50.54(hh), (i.e.,

every variation of a given strategy). potential aircraft threat, explosion or large

Use of the strategies associated fire).

with 10 CFR 50.54 9(hh)(2) to EP N.3: During the exercise planning cycle mitigate reactor accidents and described in Section N.1.5, SNC sites vary the maintain containment). content of exercise scenarios to provide ERO members the opportunity to demonstrate proficiency in key skills necessary to respond to several specific scenario elements including:

Hostile Action directed at the plant site .
No radiological release or unplanned release that does not require public protective actions.
An initial classification of or rapid escalation to a Site Area Emergency or General Emergency.
Implementation of strategies, procedures, and guidance developed in 50.54(hh), (i.e.,

potential aircraft threat, explosion or large fire).

Integration of offsite resources with onsite response
A drill initiated between the hours of 6 p.m .

and 4 a.m.

Drills using essentially 100 percent of Initiating Conditions in the 8-year cycle.

E12-182 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section N.2.2.b: Communication EP F.3: Communications tests will be The commitment wording was standardized and drills among the control room, conducted on the frequency specified below. relocated to the SNC Standard Emergency Plan technical support center (TSC}, Each of these tests includes provisions to operations support center (OSC}, ensure participants in the test are able to emergency operations facility (EOF), understand the content of the messages in the emergency news center, general test. office operations center, the States

Communications with state and local of Georgia and South Carolina, governments within the plume exposure Burke, Aiken, Barnwell, and pathway will be tested monthly.

Allendale Counties, SRS, and VEGP

Communications with federal response field monitoring teams are conducted organizations and state governments within every two years. the plume exposure pathway will be tested quarterly.
Communications between SNC-operated nuclear power plants, state Emergency Operating Centers and local Emergency Operations Centers, and radiation monitoring teams will be tested annually.
Communication from the Control Room, TSC, and EOF to the NRC Operations Center will be tested monthly.
The Emergency Response Data System (EROS) will be tested on a quarterly basis.
The fixed siren portion of the Alert and Notification System (ANS) will be tested and verified in accordance with existing FEMA aoorovals.

Section N.2.2: To ensure that EP F.3: Communications tests will be The commitment wording was standardized and emergency communication channels conducted on the frequency specified below. relocated to the SNC Standard Emergency Plan between VEGP and offsite Each of these tests includes provisions to authorities are operable, periodic ensure participants in the test are able to drills are conducted. understand the content of the messages in the test. Section N.2.2: For drills, the EP F.3: Communications tests will be The commitment wording was standardized and communication is initiated at VEGP conducted on the frequency specified below. relocated to the SNC Standard Emergency Plan using the actual message format in Each of these tests includes provisions to accordance with the applicable plan ensure participants in the test are able to and procedure. understand the content of the messages in the test. E12-183 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section N.2.3: As discussed in the EP N.2.2: Fire drills will be conducted at nuclear The commitment wording was standardized and FSAR, the program involves plants in accordance with Plant Technical relocated to the SNC Standard Emergency Plan quarterly (fire) drills, at least one of Specifications and Plant procedures. which is unannounced. Section N.2.3: The quarterly drills EP N.2.2: Fire drills will be conducted at nuclear The commitment wording was standardized and are scheduled so that each member plants in accordance with Plant Technical relocated to the SNC Standard Emergency Plan of the fire brigade participates in at Specifications and Plant procedures. least two drills per year. Section N.2.3: In addition, an annual EP N.2.2: Fire drills will be conducted at nuclear The commitment wording was standardized and practice is conducted which requires plants in accordance with Plant Technical relocated to the SNC Standard Emergency Plan extinguishing a fire. Specifications and Plant procedures. Section N.2.4: A medical emergency EP N.2.3: A medical emergency drill, involving a The commitment wording was standardized and drill involving a simulated simulated contaminated individual, and relocated to the SNC Standard Emergency Plan contaminated person is conducted containing provisions for participation by local each calendar year. support services organizations including ambulance response, are conducted annually at the nuclear plants. Local support service organizations that support more than one plant shall only be required to participate once each calendar year. Section N.2.5: Plant environs and EP N.2.4: Plant environs and radiological The commitment wording was standardized and radiological monitoring drills are monitoring drills are conducted annually. These relocated to the SNC Standard Emergency Plan conducted each calendar year per drills include collection and analysis of sample Procedure NMPEP-303, Drill and media and provisions for communications and Exercise Standards. record keeping. These drills also evaluate the response to, and analysis of, simulated airborne and direct radiation measurements in the environment. Section N.2.6: Semiannual health EP N.2.5: Radiation Protection Drills involving a The commitment wording was standardized and physics drills will be conducted per response to, and analysis of, simulated airborne relocated to the SNC Standard Emergency Plan Procedure NMP-EP-303, Drill and and liquid samples and direct radiation Exercise Standards. ) measurements are conducted semi-annually. At least annually, these drills shall include a demonstration of the sampling system capabilities, as aoolicable. E12-184 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section N.2.6: Post accident Vogtle executed the PASS elimination as approved sampling under simulated accident by NRC SER in a letter dated November 12, 2001 conditions will be demonstrated each calendar year. The annual sampling requirement in the description of Radiation Protection drills in EP N.2.5 ensures accident sampling capabilities are maintained. Section N.3: Each drill and exercise EP N.3: When a major drill or exercise is The commitment wording was standardized and is conducted in accordance with a required, the Emergency Preparedness (EP) relocated to the SNC Standard Emergency Plan scenario. group will coordinate the preparation of a scenario. The EP group will also coordinate efforts with appropriate federal, state, and local emergency organizations and agencies, schedule a date to conduct the drill or exercise, and assign qualified controllers. Section N.3: The preparation of EP N.3: When a major drill or exercise is The commitment wording was standardized and exercise scenarios is directed by the required, the Emergency Preparedness (EP) relocated to the SNC Standard Emergency Plan emergency preparedness supervisor group will coordinate the preparation of a who enlists the assistance of scenario. The EP group will also coordinate personnel from other departments, efforts with appropriate federal, state, and local as required, to assist in this task. emergency organizations and agencies, schedule a date to conduct the drill or exercise, and assign qualified controllers. E12-185 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section N.3: Scenarios include the EP N.3: A scenario, prepared in advance, will The commitment wording was standardized and following information: govern the conduct of exercises and drills. relocated to the SNC Standard Emergency Plan Objectives. Scenarios will include the following: Date, time period, place, and

Objectives of the drill or exercise; a participating organizations. measurable and observable objective must Controller/evaluator assignments. be specified for each major problem and Time schedules of real and solution.

simulated initiating events.

Dates, time period, places, personnel, and Messages describing equipment participating organizations.

malfunctions, personnel injuries, and

Simulated events.

other non plant events, as

Time schedule of real and simulated initiating appropriate. events.

Narrative summary describing the

Narrative summary describing the conduct of conduct of the drill or exercise. the exercise or drill, including simulated Radiological data for onsite facilities casualties, offsite fire department assistance, and offsite field monitoring teams. rescue of personnel, use of protective clothing and associated equipment, deployment of personnel and radiological teams, and public information activities.

E12-186 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section N.4: All drills and exercises EP N.4: A formal critique will be performed for The commitment wording was standardized and are evaluated. exercises, drills, and training tabletops to relocated to the SNC Standard Emergency Plan Section N: For periodic drills, the develop, maintain, or demonstrate key skills in process consists of the following order to identify weak or deficient areas that steps: need correction.

1. Drills will be evaluated by A critique shall be conducted at the conclusion controllers/evaluators selected on of the exercise, to evaluate the organization's the basis of expertise and ability to respond as called for in the SNC availability. Standard Emergency Plan. Qualified

2. Improper or incorrect performance personnel will observe and perform a critique during the drill may be corrected by of exercises and drills. Provisions will be made the controller/evaluator and the for federal, state, and local observers, as well proper method pointed out or as SNC personnel, to observe and critique demonstrated. required exercises.

3. The exercise or drill controllers Biennially, representatives from the NRC assemble the players at the observe and evaluate the licensee's ability to conclusion of activities for a critique. conduct an adequate self-critical critique. For Players are encouraged to identify partial and full offsite participation exercises, areas where improvements are the NRC and Federal Emergency Management required. The drill controllers also Agency (FEMA), will observe, evaluate, and presents their observations to the critique.

players. Drill and exercise performance objectives will

4. The site emergency preparedness be evaluated against measurable supervisor submits a list of corrective demonstration criteria. As soon as possible actions, responsibilities, and following the conclusion of the drill or exercise, schedule information to the site a critique is conducted to evaluate the ability of support manager for approval. the Emergency Response Organization (ERO)

5. The emergency preparedness to implement the emergency plan and supervisor assigns action items and procedures, and a formal evaluation will result monitors the status of completion of from the critique.

corrective actions. Significant A written critique report is prepared by the problems will be brought to the Emergency Preparedness group following a attention of appropriate plant drill or exercise involving the evaluation of management. designated objectives or following the final Exercise evaluation and corrective simulator set with ERO participation. The action are carried out in similar report will evaluate the ability of the ERO to fashion. respond to a simulated emergency situation. The report will also contain corrective actions and recommendations. E12-187 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section 0: All VEGP badged EP 0.4.8: GET will include general training in The commitment wording was standardized and personnel will receive General emergency preparedness for plant and other relocated to the SNC Standard Emergency Plan Employee Training at inception of site personnel. GET will include classification, onsite duties. individual response, signals, accountability, Section 0.3: All badged VEGP and site evacuation procedures. workers will receive general training in emen::iencv preparedness. Section 0: GET will include EP 0.4.8: GET will include general training in The commitment wording was standardized and emergency classification, individual emergency preparedness for plant and other relocated to the SNC Standard Emergency Plan response, signals, accountability, site personnel. GET will include classification, and site dismissal procedures. individual response, signals, accountability, and site evacuation procedures. Section 0: All VEGP emergency EP 0.4.1: ERO members will receive The commitment wording was standardized and response organization personnel will Emergency Plan training on an annual basis. relocated to the SNC Standard Emergency Plan receive specialized training per Personnel identified receive training Table 0-2. appropriate to their position in the areas of: Section 0.3: Selected individuals on

Accident assessment.

site and off site will annually receive

Accident mitigation.

specialized training.

Notifications.
Emergency Classifications.
Protective Action Recommendations.
Emergency Action Levels.
Emerqencv Exposure Control.

E12-188 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section 0: All VEGP emergency EP 0.4: SNC ERO personnel who are The commitment wording was standardized and response organization personnel will responsible for implementing this plan receive relocated to the SNC Standard Emergency Plan receive specialized training per specialized training. The training program for Table 0-2. emergency response personnel is developed Section 0.1: As a minimum, training based on the requirements of 10 CFR 50, will be provided in the subject areas Appendix E and position-specific shown in table 0-1 to various responsibilities. personnel according to their Requalification training for onsite ERO emergency response position as members consists of an annual review of the shown on table 0-2. Emergency Plan in the form of a general Section 0.1: Those designated to overview. In addition to SNC Emergency Plan receive training in each subject area overview training, personnel assigned to onsite are indicated in table 0-2. emergency response positions will receive training specific to their position. EP 0.4.1: Emergency Response Organization (ERO) EP 0.4.2: Active Senior Licensed Control Room Personnel EP 0.4.3: Radiological Field Monitoring Teams EP 0.4.4: Fire Brigade Training EP 0.4.5: Operations, Maintenance, Chemistry and Radiation Protection Training EP 0.4.6: Medical Support EP 0.4.7: News Media Training EP 0.4.8: General Employee Training (GET) Section 0.1: The training will be EP 0.1: The ERO Training Program ensures The commitment wording was standardized and conducted in accordance with lesson the training, qualification, and requalification of relocated to the SNC Standard Emergency Plan plans. individuals who may be called on for assistance during an emergency. Specific emergency response task training, prepared for response positions, is described in lesson plans and study guides. The lesson plans, study guides, and written tests are contained in the ERO Training Program. Section 0.1: Records of the EP 0.1: Responsibilities for implementing the The commitment wording was standardized and attendance and examination scores training program are contained in plant relocated to the SNC Standard Emergency Plan will be retained in the traininQ files. . procedures. E12-189 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section 0.1: Upon completion of EP 0.1: Responsibilities for implementing the The commitment wording was standardized and each training session or drill, the training program are contained in plant relocated to the SNC Standard Emergency Plan participants will be asked to critique procedures. the training in order to ensure continued improvement. Section 0.1: Radiological emergency EP 0.1: The ERO Training Program ensures The commitment wording was standardized and response training is offered the training, qualification, and requalification of relocated to the SNC Standard Emergency Plan throughout the year, with each individuals who may be called on for training course being covered at assistance during an emergency. Specific least once per calendar year. emergency response task training, prepared for response positions, is described in lesson plans and study quides. Section 0.1: Annual retraining EP 0.4: Requalification training for onsite ERO The commitment wording was standardized and consists of initial training material members consists of an annual review of the relocated to the SNC Standard Emergency Plan reinforcement and appropriate Emergency Plan in the form of a general lessons learned from the previous overview. In addition to SNC Emergency Plan year's operating experience. overview training, personnel assigned to onsite emergency response positions will receive traininq specific to their position. Section 0: All VEGP emergency EP 0.4: SNC ERO personnel who are The commitment wording was standardized and response organization personnel will responsible for implementing this plan receive relocated to the SNC Standard Emergency Plan receive specialized training per specialized training. The training program for Table 0-2. emergency response personnel is developed based on the requirements of 10 CFR 50, Appendix E and position-specific responsibilities. E12-190 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section 0: Offsite response groups EP 0.1: Personnel from nuclear power plants The commitment wording was standardized and who may support onsite situations, annually offer to train those non-SNC relocated to the SNC Standard Emergency Plan such as fire or personnel injury, will organizations referenced in the Plant Annexes be offered annual training in that may provide specialized services during a notification, expected roles, site nuclear plant emergency. The training offered orientation, security procedures, and will acquaint the participants with the special basic radiation protection. problems potentially encountered during a Section 0: Selected state and local nuclear plant emergency, notification emergency response management procedures, and their expected roles. personnel with offsite emergency Organizations that must enter the site shall response roles will be offered a also receive site-specific emergency response seminar/training course in specific training and be instructed as to the identity of areas; (1) the VEGP emergency those persons in the onsite organization who classification system; (2) the VEGP will control their support activities. protective action recommendation Training of state and local offsite emergency criteria and their relationship to plant response organizations is described in their conditions; and (3) the VEGP respective radiological emergency plans, with emergency response organization. support provided by SNC if requested. Section 0: These offsite EP 0.1.1: A training opportunity will be offered management personnel will be annually for offsite organizations and agencies offered initial training and annual as specified in respective agreements and retraining. understandings. In addition, those offsite organizations and agencies that may provide onsite emergency assistance will be encouraged to become familiar with the general layout of SNC plants, and will be invited to attend applicable Emergency Plan training and orientation courses. Annually, training will be offered for hospital personnel, ambulance and rescue personnel, police, and fire departments. The training shall include the procedures for notification, basic radiation protection, and their organizations' expected role. E12-191 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section 0.2: Mandatory training for EP 0.1: To achieve and maintain an The commitment wording was standardized and emergency positions held: acceptable level of emergency preparedness, relocated to the SNC Standard Emergency Plan All ERO personnel shall be trained training will be conducted for members of the per table 0-2 within the last 15 Emergency Response Organization (ERO) and months, except for post accident those offsite organizations that may be called sampling and first aid training, which on to provide assistance in the event of an is to be within 36 months. emergency. Training will be evaluated in accordance with the requirements of Systematic Approach to Training practices to ensure effectiveness and in order to identify weak or deficient areas that need correction. The ERO Training Program ensures the training, qualification, and requalification of individuals who may be called on for assistance during an emergency. Specific emergency response task training, prepared for response positions, is described in lesson plans and study guides. Section P: The Executive Vice EP P: The President/Chief Executive Officer The commitment wording was standardized and President/Chief Nuclear Officer (CEO) Southern Nuclear Operating Company relocated to the SNC Standard Emergency Plan (CNO) Southern Nuclear Operating (SNC) has direct responsibility for the Company (SNC) has overall operation and maintenance of the SNC Plants. responsibility and authority for all nuclear activities, including emergency planning (EP) programs. Section P: The vice president- EP P.1: The Vice President - Regulatory The commitment wording was standardized and regulatory affairs is responsible for Affairs is responsible for the overall relocated to the SNC Standard Emergency Plan administration of the corrective coordination of the corporate emergency action program in the corporate preparedness programs and Emergency headquarters, the overall Plans. coordination of the corporate emergency preparedness programs (including the common Emergency Operations Facility), Emergency Plans, and site emergency response communication. E12-192 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section P: The Fleet Emergency EP P.1: The Fleet Emergency Preparedness The commitment wording was standardized and Preparedness Manager is Director is responsible for the oversight of relocated to the SNC Standard Emergency Plan responsible for overseeing Emergency Preparedness activities and emergency planning activities offsite coordinating those activities with Licensee, and coordinating those activities with federal, state, and local response Licensee, Federal, State and local organizations. response organizations. Section P: Vice President - (Plant) is EP P.2: The Vice President-(Site) is The commitment wording was standardized and responsible for the site Emergency responsible for the site Emergency relocated to the SNC Standard Emergency Plan Preparedness aspects of the Preparedness aspects of the program at each proQram. site. Section P: The Emergency EP P.2: The Emergency Preparedness The commitment wording was standardized and Preparedness Supervisor is Supervisor is responsible for coordinating relocated to the SNC Standard Emergency Plan responsible for coordinating onsite emergency preparedness activities and emergency preparedness activities supports offsite emergency preparedness onsite and supports offsite activities in the plant vicinity. emergency preparedness activities in the vicinity of the plant. Section P: The Emergency EP P.3: EPIPs and administrative procedures The commitment wording was standardized and Preparedness for the Emergency Preparedness function are relocated to the SNC Standard Emergency Plan Supervisor is responsible for the maintained by the Fleet Emergency implementation of the Emergency Preparedness Director with a designated EP Plan and procedure development staff member as the principal contact. and maintenance. Section P: The Fleet Emergency EP P.3. The Emergency Plan, agreements, The commitment wording was standardized and Preparedness Manager performs a and the EPIPs are reviewed once per calendar relocated to the SNC Standard Emergency Plan review of the site specific emergency year and updated, as needed. plan annually and all onsite EPIPs biennially. The review includes the letters of agreement, which are updated as necessary. Section P: The Emergency plans EP P.3. The Emergency Plan, agreements, The commitment wording was standardized and and EPIPs are revised in accordance and the EPIPs are reviewed once per calendar relocated to the SNC Standard Emergency Plan with applicable site procedures. year and updated, as needed. E12-193 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Section P: As required by 10 CFR EP P .3: An independent review of the EP The commitment wording was standardized and 50.54(t), an annual independent program is conducted, as required by 10 CFR relocated to the SNC Standard Emergency Plan audit of the emergency 50.54(t). preparedness program is conducted by the SNC Fleet Oversight Department. Section P: The interval from the EP P.3: An independent review of the EP The commitment wording was standardized and previous audit may be shortened but program is conducted, as required by 10 CFR relocated to the SNC Standard Emergency Plan may not be extended beyond 15 50.54(t). months. Section P: Audits are performed in EP P.3: An independent review of the EP The commitment wording was standardized and accordance with SNC Fleet program is conducted, as required by 10 CFR relocated to the SNC Standard Emergency Plan OversiQht department procedures. 50.54(t). Section P: Records of these audits EP P.3: The results of the review, along with The commitment wording was standardized and and exercise findings are maintained recommendations for improvements, are relocated to the SNC Standard Emergency Plan in accordance with plant procedures. documented and reported to plant management and to appropriate offsite agencies. Section P: The Fleet Emergency EP P.3. The Emergency Plan, agreements, The commitment wording was standardized and Preparedness Manager performs a and the EPIPs are reviewed once per calendar relocated to the SNC Standard Emergency Plan review of the emergency plans for year and updated, as needed. Southern Nuclear once each calendar vear. Appendix 2: All Criteria added to body of SNC Standard Emergency Plan. Individual Annex no longer required. Appendix 3: In the event of an EP 8.1.1: The Emergency Director's non- The commitment wording was standardized and emergency the Emergency Director delegable duties include: relocated to the SNC Standard Emergency Plan at VEGP is responsible for notifying

Notifications of offsite agencies and approval appropriate State and local response of state, local, and NRC notifications.

organizations, plant emergency personnel, and DOE's Savannah River Site. E12-194 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 EP E.2.5: Prompt alerting and notification of the public within the plume Appendix 3: Initial alerting will be exposure pathway EPZ is the obligation of state and local government or other The commitment wording was standardized and made primarily by both tone-alert responsible authority. The responsibility for ensuring the means exist to carry relocated to the SNC Standard Emergency Plan out this purpose rests with Southern Nuclear Operating Company. An radios and a system of fixed sirens. overview of these means excluding the Savannah River Site is listed in the and Site Annex site-specific Annex of this Plan. Appendix 3: In the event of a serious emergency at VEGP, the primary Annex 4.2: Two totally independent public alerting systems are installed for use in the VEGP EPZ: means for alerting and providing initial instructions to the public will be

Network of fixed sirens and EAS, by a combination of tone-alert radios
NOAA (National Oceanic and Atmospheric Administration) weather warning radio system.

and a system of fixed sirens. Offsite agencies will activate both independent systems in the event of a plant Appendix 3: The siren system condition requiring public awareness. Following any public alert. commercial consists of a network of 47 rotating radio and television stations. as well as NOAA weather radio (NWR) will be used to provide notification and follow-up emergency information to the electronic sirens mounted on poles population within the EPZ. strategically located throughout the Responsibility for alerting and notifying the public lies with the appropriate populated area of the plume offsite civil authorities; specifically, GEMA for anywhere within the State of Georgia; Burke County EMA for Burke County, Georgia; SCEMD for South exposure EPZ. Carolina; The County Division of Emergency Preparedness in Aiken County, South Carolina; the County Disaster Preparedness Agencies in Allendale and Barnwell Counties, South Carolina; and the SRS. Physical activation of the sirens In Burke County will be done by the Burke County EMA in accordance with the Burke County SOP, and in coordination with GEMA. Physical activation of the siren in Barnwell County will be done by that county, in consultation with SCEMD. Physical activation of the NWR system is by the NWS office in Columbia, SC for VEGP when requested to do so by GEMA. In general, SCEMD will rely upon GEMA to activate the NWR system, and to coordinate with Burke County on the activation of the EAS. The South Carolina Governor's Office or SCEMD will activate the South Carolina EAS after coordination with Georgia authorities. The system maintenance requirements for the Tone Alert Radio System are contained in the FEMA approved System Design Report. Specifically, Vogtle maintains a database of those assigned tone alert radios and performs an annual telephone survey documenting the adequacy of distribution. Provisions for transient population notification are also included in state and county plans. E12-195 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Appendix 3: Based upon Appendix 3 Annex 4.2: Two totally independent public alerting systems are The commitment wording was standardized and of NUREG-0654 and FEMA REP-10, installed for use in the VEGP EPZ: relocated to the Site Annex. the system is designed to provide a

Network of fixed sirens and EAS, minimum of 60 dBC coverage to all residences within the plume
NOAA (National Oceanic and Atmospheric Administration) weather warning radio system.

exposure EPZ, plus adequate Offsite agencies will activate both independent systems in the coverage for people outdoors in all event of a plant condition requiring public awareness. Following other areas of the plume exposure any public alert, commercial radio and television stations, as well EPZ open to the public. as NOAA weather radio (NWR) will be used to provide notification and follow-up emergency information to the population within the EPZ. Responsibility for alerting and notifying the public lies with the appropriate offsite civil authorities; specifically, GEMA for anywhere within the State of Georgia; Burke County EMA for Burke County, Georgia; SCEMD for South Carolina; The County Division of Emergency Preparedness in Aiken County, South Carolina; the County Disaster Preparedness Agencies in Allendale and Barnwell Counties, South Carolina; and the SRS. Physical activation of the sirens in Burke County will be done by the Burke County EMA in accordance with the Burke County SOP, and in coordination with GEMA. Physical activation of the siren in Barnwell County will be done by that county, in consultation with SCEMD. Physical activation of the NWR system is by the NWS office in Columbia, SC for VEGP when requested to do so by GEMA. In general, SCEMD will rely upon GEMA to activate the NWR system, and to coordinate with Burke County on the activation of the EAS. The South Carolina Governor's Office or SCEMD will activate the South Carolina EAS after coordination with Georgia authorities. The system maintenance requirements for the Tone Alert Radio System are contained in the FEMA approved System Design Report. Specifically, VogUe maintains a database of those assigned tone alert radios and performs an annual telephone survey documenting the adequacy of distribution. Provisions for transient population notification are also included in state and county plans. Appendix 3: Assurance of continued EP E.2.5.2: The testing and maintenance of The commitment wording was standardized and notification capability will be verified the public alerting sirens are the responsibility relocated to the SNC Standard Emergency Plan. on a statistical basis similar to of SNC. The maintenance program will consist engineering calculation DOEJ- of both periodic routine checks and, as HX2008100234-M001. required, corrective maintenance. E12-196 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNG Emergency Plan Justification Revision 63 Appendix 3: Southern Nuclear EP E.2.5.2: The testing and maintenance of The commitment wording was standardized and Operating Company, and/or the the public alerting sirens are the responsibility relocated to the SNC Standard Emergency Plan. State and local governments will of SNC. The maintenance program will consist survey a sample of the residents in of both periodic routine checks and, as the plume exposure pathway EPZ. required, corrective maintenance. Appendix 3: The survey results shall be used to assess the public's ability to hear the alerting signal and their awareness of the meaning of the prompt notification message, as well as the availability of information on what to do in an emergency. Appendix 3: In response to the EP E.2.5.2: The testing and maintenance of The commitment wording was standardized and findings of these surveys, the public alerting sirens are the responsibility relocated to the SNC Standard Emergency Plan. appropriate corrective measures will of SNC. The maintenance program will consist be taken to provide reasonable of both periodic routine checks and, as assurance that the required required, corrective maintenance. coveraQe is maintained. Appendix 3: The communications Annex 1.6: Primary offsite authorities provide The commitment wording was standardized and system between the plant and the a 24-hour per day staffing of communications relocated to the Site Annex responsible authorities (Federal, links as follows: State and local) features the State of Georgia: following capabilities:

Georgia Emergency Management Agency Twenty-four hour coverage at VEGP (GEMA) and at the primary points to receive Georgia County Authorities:

and act upon notification.

Burke - Burke County EMA VEGP assumes primary State of South Carolina:

responsibility for net control since

Emergency Management Division (EMO) effectively all of the emergency South Carolina County Authorities:

information originates at VEGP.

Barnwell and Aiken County - Sheriff's Department
Allendale County - County Central Dispatch DeQartment of Energy - Savannah River Site (DOR-SRS)
DOE-SRS Operations Center E12-197 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Appendix 3: Within the plume Annex 4.2: Two totally independent public alerting systems are The commitment wording was standardized and exposure pathway EPZ, the prompt installed for use in the VEGP EPZ: relocated to the Site Annex alerting and notification system will
Network affixed sirens and EAS, provide an alerting signal and notification by NOAA radio and an
NOAA (National Oceanic and Atmospheric Administration) weather warning radio system.

alerting signal by fixed sirens. Offsite agencies will activate both independent systems in the Appendix 3: Southern Nuclear event of a plant condition requiring public awareness. Following Operating Company in conjunction any public alert. commercial radio and television stations. as well with Georgia Power Company as NOAA weather radio (NWR) will be used to provide notification and follow-up emergency information to the population within the provides NOAA radio receivers for all EPZ. known establishments (residence, Responsibility for alerting and notifying the public lies with the businesses, schools, etc.) within the appropriate offsite civil authorities; specifically. GEMA for plume exposure pathway EPZ who anywhere within the State of Georgia; Burke County EMA for Burke County, Georgia; SCEMD for South Carolina; The County choose to accept them. Division of Emergency Preparedness in Aiken County, South Carolina; the County Disaster Preparedness Agencies in Allendale and Barnwell Counties. South Carolina; and the SRS. Physical activation of the sirens in Burke County will be done by the Burke County EMA in accordance with the Burke County SOP. and in coordination with GEMA Physical activation of the siren in Barnwell County will be done by that county. in consultation with SCEMD. Physical activation of the NWR system is by the NWS office in Columbia, SC for VEGP when requested to do so by GEMA In general, SCEMD will rely upon GEMA to activate the NWR system, and to coordinate with Burke County on the activation of the EAS. The South Carolina Governor's Office or SCEMD will activate the South Carolina EAS after coordination with Georgia authorities. The system maintenance requirements for the Tone Alert Radio System are contained in the FEMA approved System Design Report. Specifically. Vogtle maintains a database of those assigned tone alert radios and performs an annual telephone survey documenting the adequacy of distribution. Provisions for transient population notification are also included in state and county plans. E12-198 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Appendix 3: During the distribution to EP G.8: The goal of the public information The commitment wording was standardized and those accepting the radios, a program is to acquaint the general public with relocated to the SNC Standard Emergency Plan brochure is handed out. the emergency plans for the operation of and Site Annex APC/GPC nuclear plants, as appropriate, and actions they should take in the event of a plant The combination of Sirens and Tone Alert Radios emergency. is conducted in accordance with the FEMA Emergency information is disseminated each approved Design Report. calendar year for residents and transients in the plume exposure pathway Emergency Planning Zone. Appendix 3: That brochure will be EP G.8: The goal of the public information The commitment wording was standardized and redistributed on an annual basis to program is to acquaint the general public with relocated to the SNC Standard Emergency Plan NOAA recipients. the emergency plans for the operation of and Site Annex APC/GPC nuclear plants, as appropriate, and actions they should take in the event of a plant The combination of Sirens and Tone Alert Radios emergency. is conducted in accordance with the FEMA Emergency information is disseminated each approved Design Report. calendar year for residents and transients in the plume exposure pathway Emergency Planninq Zone. Appendix 3: This brochure includes EP G.8: The goal of the public information The commitment wording was standardized and the following information: program is to acquaint the general public with relocated to the SNC Standard Emergency Plan What is NOAA. the emergency plans for the operation of and Site Annex Why NOAA radios are provided. APC/GPC nuclear plants, as appropriate, and Information they will receive on the actions they should take in the event of a plant The combination of Sirens and Tone Alert Radios NOAA radio. emergency. is conducted in accordance with the FEMA When the alert system will be Emergency information is disseminated each approved Design Report. activated. calendar year for residents and transients in Who makes NOAA broadcasts. the plume exposure pathway Emergency Where to place the radio. Planning Zone. Backup battery power for power failures. What to do if the NOAA radio doesn't work. How to replace radio batteries. E12-199 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Appendix 3: A public information Annex 2.3.6: Several communications The commitment wording was standardized and calendar entitled "The Plant Vogtle methods may be used to acquaint the public relocated to the Site Annex Emergency Information Calendar" with plans for their protection during a Plant will be distributed on an annual basis emergency. Effort will be concentrated on to the NOAA radio recipients. providing information to the public by written material that is likely to be available in local residences and in locations frequented by transients. The information will also provide instructions on which local media will be providing additional information in the event of an emergency. Appendix 3: SNC will replace any Annex 4.2 The Alert and Notification System The commitment wording was standardized and defective radios upon request or (ANS) description is provided in the FEMA relocated to the SNC Standard Emergency Plan discovery that the radios are approved Alert and Notification System Design and Site Annex defective. Report located in the SNC document management system. The combination of Sirens and Tone Alert Radios is conducted in accordance with the FEMA aooroved Desiqn Report. Appendix 3: SNC will also annually Annex 4.2 The Alert and Notification System The commitment wording was standardized and distribute replacement batteries to all (ANS) description is provided in the FEMA relocated to the SNC Standard Emergency Plan recipients of tone alert radios. approved Alert and Notification System Design and Site Annex Report located in the SNC document management system. The combination of Sirens and Tone Alert Radios is conducted in accordance with the FEMA approved Desiqn Report. Appendix 3: SNC will maintain a Annex 4.2 The Alert and Notification System The commitment wording was standardized and register of all radio recipients. (ANS) description is provided in the FEMA relocated to the SNC Standard Emergency Plan approved Alert and Notification System Design and Site Annex Report located in the SNC document management system. The combination of Sirens and Tone Alert Radios is conducted in accordance with the FEMA aooroved Design Report. E12-200 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Appendix 3: The Emergency Annex 4.2 The Alert and Notification System The commitment wording was standardized and Communications staff distributes (ANS) description is provided in the FEMA relocated to the SNC Standard Emergency Plan tone alert radios to any new approved Alert and Notification System Design and Site Annex residents and updates the register of Report located in the SNC document radio recipients periodically. management system. The combination of Sirens and Tone Alert Radios is conducted in accordance with the FEMA approved Design Report. Appendix 3: The Emergency Annex 4.2 The Alert and Notification System The commitment wording was standardized and Communications staff also (ANS) description is provided in the FEMA relocated to the SNC Standard Emergency Plan determines whether there are any approved Alert and Notification System Design and Site Annex permanent Burke County plume EPZ Report located in the SNC document residents without electricity. A list of management system. The combination of Sirens and Tone Alert Radios these residents is maintained. is conducted in accordance with the FEMA approved Design Report. Appendix 3: A survey of the Burke Annex 4.2 The Alert and Notification System The commitment wording was standardized and County portion of the plume EPZ will (ANS) description is provided in the FEMA relocated to the SNC Standard Emergency Plan be made annually by the Emergency approved Alert and Notification System Design and Site Annex Communications staff to assure that Report located in the SNC document the list of any such residents is management system. The combination of Sirens and Tone Alert Radios current. is conducted in accordance with the FEMA approved Desiqn Report. Appendix 3: Rather, annual surveys Annex 4.2 The Alert and Notification System The commitment wording was standardized and of the entire South Carolina portion (ANS) description is provided in the FEMA relocated to the SNC Standard Emergency Plan of the plume EPZ will be made approved Alert and Notification System Design and Site Annex directly by the Emergency Report located in the SNC document Communications Staff. management system. The combination of Sirens and Tone Alert Radios is conducted in accordance with the FEMA approved Desiqn Report. Appendix 3: The effectiveness of the Annex 4.2 The Alert and Notification System The commitment wording was standardized and tone alert radios will be tested and (ANS) description is provided in the FEMA relocated to the SNC Standard Emergency Plan evaluated at least once a year per approved Alert and Notification System Design and Site Annex procedure 91706-C, Alert Notification Report located in the SNC document System. management system. The combination of Sirens and Tone Alert Radios is conducted in accordance with the FEMA approved DesiQn Report. Appendix 3: The testing and EP E.2.5.2: The testing and maintenance of The commitment wording was standardized and maintenance of the public alerting the public alerting sirens are the responsibility relocated to the SNC Standard Emergency Plan sirens in the VEGP EPZ are the of SNC. responsibility ofVEGP. E12-201 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Appendix 3: The maintenance EP E.2.5.2: The maintenance program will The commitment wording was standardized and program will consist of both periodic consist of both periodic routine checks and, as relocated to the SNC Standard Emergency Plan routine checks and, as required, required, corrective maintenance. corrective maintenance. Appendix 3: This program will be EP P .1: Emergency Preparedness The commitment wording was standardized and under the direction of the VEGP Coordinator(s) coordinate functional elements relocated to the SNC Standard Emergency Plan emergency preparedness of the emergency preparedness program for coordinator. the SNC fleet under the direction of the Fleet Emergency Preparedness Director. Appendix 3: SNC will replace any EP E.2.5.2: Unsatisfactory conditions detected The commitment wording was standardized and defective radios upon request or by any means will be promptly repaired. relocated to the SNC Standard Emergency Plan. discovery that the radios are defective. The combination of Sirens and Tone Alert Radios is conducted in accordance with the FEMA approved Desiqn Report. Appendix 3: The periodic routine EP E.2.5.2: The periodic routine maintenance The commitment wording was standardized and maintenance program will be based and test program will be based on the relocated to the SNC Standard Emergency Plan on the manufacturers' manufacturers' recommendations and recommendations and experience experience gained with the installation. gained with the installation. Appendix 3: It will consist of quarterly EP E.2.5.2: The periodic routine maintenance The commitment wording was standardized and inspections to verify the proper and test program will be based on the relocated to the SNC Standard Emergency Plan physical condition of each siren manufacturers' recommendations and location and checks to verify the experience gained with the installation. proper operation of each location utilizing the built-in test and monitoring features of this system. Appendix 3: The periodic test EP E.2.5.2: Annually the system will be The commitment wording was standardized and program will consist of a weekly activated in the normal mode. Advance notice relocated to the SNC Standard Emergency Plan silent test, from the county activation of the test will be provided to the public. points, and an annual full scale Activation of sirens will be verified by the activation of the system. system. Reports of siren failures will be investigated and repaired by the respective SNC site. E12-202 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Appendix 3: The weekly silent test EP E.2.5.2: The periodic routine maintenance The commitment wording was standardized and will consist of activation of the siren and test program will be based on the relocated to the SNC Standard Emergency Plan from the County EOC. manufacturers' recommendations and and Site Annex experience gained with the installation. The testing will be conducted in accordance with the FEMA aooroved Desian Report. Appendix 3: Proper activation of EP E.2.5.2: Annually the system will be The commitment wording was standardized and each siren is confirmed utilizing a activated in the normal mode. Advance notice relocated to the SNC Standard Emergency Plan. monitoring system. of the test will be provided to the public. Activation of sirens will be verified by the The testing will be conducted in accordance with system. Reports of siren failures will be the FEMA approved Design Report. investigated and repaired by the respective SNC site. Appendix 3: Once each year the EP E.2.5.2: Annually, the system will be The commitment wording was standardized and system will be activated from the activated in the normal mode. Advance notice relocated to the SNC Standard Emergency Plan. associated county EOC in the of the test will be provided to the public. normal mode. Activation of sirens will be verified by the The testing will be conducted in accordance with system. Reports of siren failures will be the FEMA approved Design Report. investigated and repaired by the respective SNC site. Appendix 3: Advance notice of the EP E.2.5.2: Annually, the system will be The commitment wording was standardized and test will be provided to the public. activated in the normal mode. Advance notice relocated to the SNC Standard Emergency Plan of the test will be provided to the public. Activation of sirens will be verified by the The testing will be conducted in accordance with system. Reports of siren failures will be the FEMA approved Design Report. investigated and repaired by the respective SNC site. Appendix 3: Activation of each siren EP E.2.5.2: Annually, the system will be The commitment wording was standardized and will be verified by the WSMRFC. activated in the normal mode. Advance notice relocated to the SNC Standard Emergency Plan of the test will be provided to the public. Activation of sirens will be verified by the The testing will be conducted in accordance with system. Reports of siren failures will be the FEMA approved Design Report. investigated and repaired by the respective SNC site E12-203 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Appendix 3: Reports of siren failures EP E.2.5.2: Annually, the system will be The commitment wording was standardized and or inadequate coverage will be activated in the normal mode. Advance notice relocated to the SNC Standard Emergency Plan investigated by VEGP. of the test will be provided to the public. Activation of sirens will be verified by the The testing will be conducted in accordance with system. Reports of siren failures will be the FEMA approved Design Report. investigated and repaired by the respective SNC site. Appendix 3: Unsatisfactory EP E.2.5.2: Unsatisfactory conditions detected The commitment wording was standardized and conditions detected by any means by any means will be promptly repaired. relocated to the SNC Standard Emergency Plan will be promptly repaired by Southern Company Services The testing will be conducted in accordance with maintenance or contract personnel the FEMA approved Design Report. under the direction of the VEGP emergency preparedness coordinator. Appendix 4: All EP H.9: Emergency kits are available at SNC- The commitment wording was standardized and operated nuclear power plants. Designated relocated to the SNC Standard Emergency Plan site or department procedures identify the equipment in the various emergency kits. Details as to kit locations are found in the plant-specific procedures. Annex 5.5: Emergency supplies and equipment are located in the TSC (also for the control room), the OSC, the radiation protection control point, and other plant locations. Procedures require an inspection and operational check of equipment in these kits on a quarterly basis and after each use. Equipment in these kits is calibrated in accordance with procedures. A set of spares of certain equipment is also maintained to replace inoperative or out-of-calibration equipment. E12-204 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Appendix 9: All Annex Appendix C. New Emergency Plan Implementing Procedures are to be developed following submittal of SNC Standard Emergency Plan and Annexes. The EPIPs will be developed consistent with the NRC approval of the Plan and the criteria of 10 CFR 50.54(q) Appendix 7 A.3: Upon notification of EP H.2.1: The EOF is procedurally required to The commitment wording was standardized and an ALERT or higher classification or be activated within 75 minutes following the relocated to the SNC Standard Emergency Plan as directed by the ED, the EOF will declaration of an Alert or higher classification. be activated as described in emergency implementing procedures. Appendix 7 A.3: Offsite support EP 8.2.1.16: The Support Coordinator reports The commitment wording was standardized and personnel and equipment will be to the TSC Manager and directs the clerical relocated to the SNC Standard Emergency Plan dispatched to the site Operations and logistic activities in the TSC and ensures Support Center (OSC) or Technical that support staff, including clerks, status board Support Center (TSC) upon request keepers, and communicators, are available in from the specific site Emergency sufficient numbers and that office supplies, Director. drawings, and other documents are available to TSC and OSC personnel. Appendix 7 A.3: The corporate The commitment wording was standardized and emergency organization will provide relocated to the SNC Standard Emergency Plan. offsite emergency response support and resources to SNC sites 24 hours The SNC Standard Emergency Plan integrates the per day until the emergency has Corporate response as part of the trained and been terminated. qualified ERO. A separate statement is not necessarv. Appendix 7 A.3: The EOF will be EP H.2.1: The EOF is procedurally required to The commitment wording was standardized and activated for an ALERT, SITE AREA be activated within 75 minutes following the relocated to the SNC Standard Emergency Plan. or GENERAL emergency declaration of an Alert or higher classification. classifications. Appendix 7 A.3: This facility (EOF) EP 8.2: Augmentation of on-shift staffing will The commitment wording was standardized and will be operational within about an occur within 75 minutes of event classification relocated to the SNC Standard Emergency Plan. hour of the initial notification. by the Emergency Response Organization (ERO). ERO positions for the TSC, Operations The change in activation times will be justified Support Center (OSC), Emergency Operations separately in the Technical Analysis Section of this Facility (EOF), and JIC are detailed below. License Amendment Request. E12-205 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Appendix 7 A.3: SNC's goal is to The SNC Standard Emergency Plan moves to a begin notification of all required on- commitment to activate facilities within a timeframe call Emergency Response of 75 minutes. Notification of the responding ERO Organization (ERO) personnel as is a step in the overall process and not needed as soon as practicable, within 15 a separate commitment. minutes, following the declaration of an Alert emergency or higher The change in activation times will be justified emergency classification at any SNC separately in the Technical Analysis Section of this site. License Amendment Request. Appendix 7 A.3: Minimum EOF staff EP Figure 8.2.D The commitment wording was standardized and for facility activation will include the relocated to the SNC Standard Emergency Plan. EOF Manager, the Dose Assessment Supervisor, the Dose Analyst, the Field Team Coordinator, the ENN Communicator, and the Licensino Suooort Coordinator. Appendix 7 A.3: Access control for EP H.2.1: Access to the EOF is controlled The commitment wording was standardized and the EOF is established through the through the use of electronic card readers. relocated to the SNC Standard Emergency Plan. use of electronic card readers. Appendix 7 A.3: The emergency EP 8.1.1: The Emergency Director's non- The commitment wording was standardized and director is responsible for the delegable duties include: relocated to the SNC Standard Emergency Plan. management of the emergency

Event classification in accordance with the response. Specific duties and emergency classification system.

responsibilities are provided in the

Perform the duties and responsibilities of site specific Emergency Plan and Protective Action Recommendation (PAR)

Emergency Plan Implementing determination. Procedures.

Notifications of offsite agencies and approval of state, local, and NRG notifications.
Authorization of emergency exposures in excess of federal limits.
Issuance of potassium iodide (Kl) to plant employees*as a thyroid blocking agent.
Request federal assistance as needed.

E12-206 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Appendix 7 A.3: ... the EOF can be EP 8.2: Augmentation of on-shift staffing will The commitment wording was standardized and quickly accessed and made occur within 75 minutes of event classification relocated to the SNC Standard Emergency Plan. operational within about an hour of by the Emergency Response Organization the initial notification and is safe- (ERO). ERO positions for the TSC, OSC, The change in activation times will be justified guarded against unauthorized EOF, and JIC are detailed below. separately in the Technical Analysis Section of this personnel. EP H.2.1: Access to the EOF is controlled License Amendment Request. through the use of electronic card readers. Appendix 7 A.3: The building itself EP H.2.1: Access to the EOF is controlled The commitment wording was standardized and (EOF building) has posted security through the use of electronic card readers. relocated to the SNC Standard Emergency Plan. guards and video surveillance cameras. Appendix 7 A.3: Any outside doors EP H.2.1: Access to the EOF is controlled The commitment wording was standardized and that do not have security guards are through the use of electronic card readers. relocated to the SNC Standard Emergency Plan. accessible only by SNC ID badqes. Appendix 7 A.3: If an event were to EP H.2.1: Access to the EOF is controlled No equivalent Plan statement. occur during off-normal hours, a through the use of electronic card readers. guard will be posted at the main NRC has indicated Security concerns over entrance to Building 40 to allow buildings accessible to the general public and may access to offsite agency or other want a more positive statement of building control responders without pre-designated ID access. Appendix 7 B: The EOF EP Figure 8.2.D EOF Organization Chart The commitment wording was standardized and Organization is displayed in Figure 1 EP 8.3 Listing of typical duty assignments. relocated to the SNC Standard Emergency Plan. and typical duty assignments are shown on Table 1. Appendix 7 B: Each of the following EP 0.1: The ERO Training Program ensures The commitment wording was standardized and EOF positions has site-specific the training, qualification, and requalification of relocated to the SNC Standard Emergency Plan. personnel designated: individuals who may be called on for EOF Manager assistance during an emergency. Specific EOF Technical Supervisor emergency response task training, prepared for response positions, is described in lesson plans and study guides. Appendix 7 B: In order to augment EP 8.2: Augmentation of on-shift staffing will General statement on activation of the ERO is additional staff that may be needed occur within 75 minutes of event classification sufficient for staffing. in the unlikely event of a multi-site by the Emergency Response Organization accident, SNC will re-activate its (ERO). ERO positions for the TSC, Operations ERO notification system. Support Center (OSC), Emergency Operations Facility (EOF), and JIC are detailed below. E12-207 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Appendix 7 B: When the EOF is EP 8.2: Augmentation of on-shift staffing will The commitment wording was standardized and activated, all EOF staff pagers are occur within 75 minutes of event classification relocated to the SNC Standard Emergency Plan. activated, and all EOF personnel are by the Emergency Response Organization expected to report to the EOF. (ERO). ERO positions for the TSC, Operations Support Center (OSC), Emergency Operations Facility (EOF), and JIC are detailed below. Appendix 7 8.1: The EOF Managers EP 0.1 Training The commitment was modified to required qualified will typically have either previous To achieve and maintain an acceptable level of personnel. plant specific SRO background or emergency preparedness, training will be long-term supervisory/management conducted for members of the Emergency experience. Response Organization (ERO) and those offsite organizations that may be called on to provide assistance in the event of an emergency. Training will be evaluated in accordance with the requirements of Systematic Approach to Training practices to ensure effectiveness and in order to identify weak or deficient areas that need correction. The ERO Training Program ensures the training, qualification, and requalification of individuals who may be called on for assistance during an emergency. Specific emergency response task training, prepared for response positions, is described in lesson plans and study guides. The lesson plans, study guides, and written tests are contained in the ERO Training Program. Responsibilities for implementing the training program are contained in plant procedures. Offsite training is provided to support organizations that may be called upon to provide assistance in the event of an emerqencv. E12-208 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Appendix 7 B.1: The duties and EP 8.3.1.1: The EOF ED has overall The commitment wording was standardized and responsibilities of the EOF Manager coordinating authority for Southern Nuclear relocated to the SNC Standard Emergency Plan. are as follows: (As listed in App. 7, Company resources. Upon EOF activation, 14 items listed) the EOF ED accepts responsibility for Notification and Protective Action Recommendation functions from the Control Room. The EOF ED is also responsible for keeping SNC corporate management informed regarding the emergency response and Classification uoarades. Appendix 7 B.2: The EOF Technical The commitment was modified to required qualified Supervisor will typically have plant personnel. specific long-term enoineerino/desion experience. Appendix 7 B.2: The duties and EP 8.3.1.19: The Technical Supervisor reports The commitment wording was standardized and responsibilities of the EOF Technical to the EOF Manager and is responsible for relocated to the SNC Standard Emergency Plan. Supervisor are as follows: (As listed providing engineering expertise during an in App. 7, 7 items listed) emergency event at an SNC-operated plant. This may include interacting with non-SNC response groups, developing mitigation and recovery plans and coordinating work performed by SNC and non-SNC engineering Qroups .. Appendix 7 B.3: The duties and EP 8.3.1.3: The Support Coordinator reports to The commitment wording was standardized and responsibilities of the EOF Support the EOF Manager. The duties and relocated to the SNC Standard Emergency Plan. Coordinator are as follows: (As listed responsibilities of the Support Coordinator in in App. 7, 8 items listed). The the EOF include providing oversight of the individuals designated to assume the News Writer, providing assistance to the position will be indicated on a Support Coordinator in the Technical Support predetermined rotational schedule. Center (TSC) for ordering equipment and materials, and logistics arrangements for support personnel called in to assist in the emergency, including communications hardware, transportation, food, and lodging. E12-209 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Appendix 7 8.4: The TSC will initially EP 8.2.1.5: The RP Supervisor assists the The commitment wording was standardized and be responsible for dose projection Radiation Protection/Chemistry Group Lead in relocated to the SNC Standard Emergency Plan. and field team control activities. the OSC in determining the extent and nature of radiological or hazardous conditions and coordinates offsite dose assessment and offsite Field Monitoring Teams prior to EOF activation. Appendix 7 8.4: When the EOF is Figure 8.2.A Figure 8.2.A describes the transfer of non-activated and ready to assume delegable responsibilities between the ERFs. functions of dose projection/ EP 8.3 Offsite Emergency Response Section 8.3 provides the overall responsibility of assessment activities, then the EOF Organization (ERO) EOF responders. Dose Assessment Supervisor will coordinate transfer of dose The commitment wording was standardized and assessment, field team control, and relocated to the SNC Standard Emergency Plan. protective action determination from the TSC to the EOF. Appendix 7 8.4: The duties and EP 8.3.1.4: The Dose Assessment Supervisor The commitment wording was standardized and responsibilities of the EOF Dose reports to the EOF Manager and provides relocated to the SNC Standard Emergency Plan. Assessment Supervisor are as oversight of dose assessment, field team follows: (As listed in App. 7, 7 items control, and protective action recommendation listed). The individuals designated to activities in the EOF; and coordinates assume the position will be indicated communication of results with offsite agencies. on a predetermined rotational schedule. Appendix 7 8.5: The duties and EP 8.3.1.11: The Security Coordinator reports The commitment wording was standardized and responsibilities of the Security to the EOF Manager. The duties and relocated to the SNC Standard Emergency Plan. Coordinator are as follows: (As listed responsibilities of the Security Coordinator will in App. 7, 3 items listed}. The be assumed by SNC corporate security individuals designated to assume the personnel. Responsibilities include supporting position will be indicated on a the plant security manager, keeping the EOF predetermined rotational schedule. Manager informed of any security events or issues, communication of Security Related information to the NRG using the Security Bridge line, and establishing and maintaining access control for the EOF. E12-210 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Appendix 7 B.6: The duties and EP B.3.1.12: The Offsite Response The commitment wording was standardized and responsibilities of the Offsite Coordinator reports to the EOF Manager. The relocated to the SNC Standard Emergency Plan. Response Coordinator are as duties and responsibilities of the Offsite follows: (As listed in App. 7, 2 items Response Coordinator include coordination of listed). The individuals designated to activities for the dispatch and update of assume the position will be indicated technical liaisons to state and local authorities on a predetermined rotational and monitoring EOF functional areas to schedule. facilitate coordination between the licensee and state and local agencies. Appendix 7 C: Initial notifications or EP E.2.1: Emergency Response personnel The commitment wording was standardized and emergency response personnel will respond to their assigned Emergency relocated to the SNC Standard Emergency Plan. follow the guidelines specified in the Response Facilities upon notification of an site specific Emergency Plan and Alert or higher classification level. Emergency Plan Implementing Procedures. Appendix 7 C.1: The On-call EOF EP E.2.1: Emergency Response personnel The commitment wording was standardized and Manager will be notified of all respond to their assigned Emergency relocated to the SNC Standard Emergency Plan. emergencies classified at any SNC Response Facilities upon notification of an site. Alert or hiQher classification level. Appendix 7 D.1: The EOF is located EP H.2.1: The EOF is a dedicated facility The commitment wording was standardized and in Birmingham, Alabama and serves located in Birmingham, Alabama, and serves as relocated to the SNC Standard Emergency Plan. as the EOF for all SNC sites (VEGP, the EOF for SNC sites (VEGP, FNP, and HNP). FNP, and HNP). Appendix 7 D.1: The EOF will be EP H.2.1: The EOF is procedurally required to The commitment wording was standardized and activated as prescribed in the site be activated within 75 minutes following the relocated to the SNC Standard Emergency Plan. specific Emergency Plan declaration of an Alert or higher classification. imolementinQ procedures. Appendix 7 D.1: Plant systems EP H.5.1: A permanent meteorological The commitment wording was standardized and information, radiological data, and monitoring station is located near the plant for relocated to the SNC Standard Emergency Plan. meteorological data are provided via the acquisition and recording of wind speed, the SNC Integrated Data Display wind direction, ambient and differential System to EOF personnel. temperatures for use in making offsite dose projections. Meteorological information is displayed in the CR, TSC, and EOF. EP H.5.3.2: The SPDS parameters are available during normal and abnormal operating conditions in the Control Room, TSC, and EOF. E12-211 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Appendix 7 D.1: Data displays are EP H.5.1: Meteorological information is The commitment wording was standardized and located in the main caucus area of displayed in the CR, TSC, and EOF by means relocated to the SNC Standard Emergency Plan. the EOF, dose assessment area, of the plant computer system. plant status area, and engineering EP H.5.3.2: The SPDS parameters are area within the facility. available normal and abnormal operating conditions in the Control Room, TSC, and EOF. Appendix 7 D.1: Data is also EP H.2.1 Emergency Operations Facility The commitment wording was standardized and available to all state agencies The EOF is capable of accommodating relocated to the SNC Standard Emergency Plan. responding to the EOF. designated SNC personnel and offsite local, state, and federal responders including NRC and FEMA. It is anticipated that representatives from the state(s) of Georgia, South Carolina, Alabama, or Florida may be dispatched to the EOF for an event at specific SNC site(s). Responders from state and local agencies have access to plant parameters through the various data displays available in the EOF. See Figure H.2.A. Appendix 7 D.1: This data is SECTION I: ACCIDENT ASSESSMENT The commitment wording was standardized and available to state and local EP 1.1 Systems and Parameters Monitored relocated to the SNC Standard Emergency Plan. authorities via a secure network Select plant parameters are available to state dedicated to data distribution among and local authorities via a secure network the various offsite emergency dedicated to data distribution among the various response facilities. offsite emerqencv response facilities. Appendix 7 D.1: Data may also be EP F .1.1: At SNC-operated nuclear power The commitment wording was standardized and obtained manually via telephone plants, several modes of reliable relocated to the SNC Standard Emergency Plan. from the Control Room and the TSC communication are available, during both to the EOF. normal and emergency conditions, to transmit and receive information among the Control Room, TSC, OSC, EOF, and other locations onsite and offsite including the Joint Information Center near the SNC site. E12-212 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Appendix 7 D.1: Contained within the EP F .1.1: At SNC-operated nuclear power The commitment wording was standardized and facility will be the manpower and plants, several modes of reliable relocated to the SNC Standard Emergency Plan equipment necessary to provide communication are available, during both dedicated direct communication links normal and emergency conditions, to transmit to the plant site(s). and receive information among the Control Room, TSC, OSC, EOF, and other locations onsite and offsite including the Joint Information Center near the SNC site. EP Section B: ERF Communicators Appendix 7 D.1: In addition, there EP F.1.1: Reliable primary and backup means The commitment wording was standardized and are commercial and company wide of communication have been established. relocated to the SNC Standard Emergency Plan phone systems to and from the Annex 5.3.2: Commercial telephones or land and Site Annex site(s). lines provide backup for the ENN. Appendix 7 D.1: A communication EP F.1.1: At SNC-operated nuclear power The commitment wording was standardized and link will be established and plants, several modes of reliable relocated to the SNC Standard Emergency Plan. maintained between the Emergency communication are available, during both Operations Facility and the Technical normal and emergency conditions, to transmit Support Center (TSC) until the and receive information among the Control emergency director determines that Room, TSC, OSC, EOF, and other locations the communication link is no longer onsite and offsite including the Joint needed. Information Center near the SNC site. Appendix 7 D.1: Computer No equivalent Plan statement. workstations are dedicated for performing dose assessment for multiple sites. Appendix 7 D.1: The EOF is sized to EP H.2.1: The EOF is capable of The commitment wording was standardized and accommodate 35 persons, including accommodating designated SNC personnel relocated to the SNC Standard Emergency Plan. 25 pre-designated persons, 9 and offsite local, state, and federal responders persons from the NRC, and 1 person including NRC and FEMA. from the Federal Emergency Management Agency (FEMA). E12-213 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Appendix 7 D.1: Table 4 provides EP F Table 5 The SNC Standard Emergency Plan and Annex additional information concerning provide commitments to maintain the EOF communications capabilities. communications capabilities within the ERO, required offsite responders, and the public through the execution of the Joint Information System. The detailed physical description of equipment maintaining those commitments is subject to change and not necessary to ensure the effective implementation of the EmerQency Plan. Appendix 7 D.1: Upon activation of The SNC Standard Emergency Plan incorporates the EOF, Corporate personnel will the EOF as part of the general ERO supporting provide staffing 24 hours per day ongoing operations. The separate statement is not until directed otherwise by the required. Emergency Director. Appendix 7 D.1: The EOF is a EP H.2.1: The EOF is a dedicated facility The commitment wording was standardized and dedicated facility. located in Birmingham, Alabama, and serves relocated to the SNC Standard Emergency Plan. as the EOF for SNC sites (VEGP, FNP, and HNP). Appendix 7 D.1: Back-up power for EP H.2.1: Backup power for the EOF is The commitment wording was standardized and the EOF is supplied by onsite diesel supplied by onsite diesel generation. Essential relocated to the SNC Standard Emergency Plan. generation. All essential equipment equipment is backed up by the diesel is backed up by the diesel generation system. Qeneration system. Appendix 7 D.1: The following EP H.2.1: The EOF is located at SNC The commitment wording was standardized and records or information are available: Corporate Headquarters with the document relocated to the SNC Standard Emergency Plan. Technical Specifications. management section for SNC. The following Selected plant operating procedures. records or information are available: Emergency Plans.

Technical Specifications.

Emergency Plan Implementing

Selected plant operating procedures.

Procedures.

Emergency Plans.

FSARs.

Emergency Plan Implementing Procedures.

State and local emergency response

Final Safety Analysis Reports (FSARs).

plans.

System piping and instrumentation Savannah River Site Emergency diagrams and HVAC flow diagrams.

Plan.

Electrical one-line, elementary, and wiring diagrams.

E12-214 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Appendix 7 D.2: In the unlikely event Egress of personnel from the EPZ fall under the that individuals should need to provisions of the state Plan. A statement in the respond to the EOF from within the SNC Standard Emergency Plan is not required. 10 mile EPZ of any SNC plant, they would be surveyed prior to release by local emergency authorities. Appendix 7 0.2: In the unlikely event The corporate EOF is located outside the that the EOF becomes reasonable expectation for damage based on a uninhabitable, resources and naturally occurring event beyond the design basis personnel will be transferred-to the of the site. Should the EOF be so damaged the Corporate Headquarters of Alabama site can re-assume control of the event. Power Company. Appendix 7 E.1: Provisions have EP F.1.4: Communication with the Nuclear The commitment wording was standardized and been made to have direct NRC FTS Regulatory Commission (NRC) is on the relocated to the SNC Standard Emergency Plan. lines in the TSC and the EOF during Federal Telecommunications System (FTS) an emergency. telephone network that connects the SNC plant site and EOF with the NRC Operations Center. Appendix 7 F.2.4: The GPC Central EP H.6.3: External facilities for counting and The commitment wording was standardized and Laboratory has personnel and analyzing samples, and for dosimetry relocated to the SNC Standard Emergency Plan. facilities available to provide offsite processing, can be provided by other SNC-monitoring, sample analysis, and operated plants including the GPC Central dosimetry processing for the affected Laboratory, state, federal, or contracted site. laboratories. Outside analytical assistance may be requested from state and federal agencies, or through contracted vendors. The DOE, through the Radiological Assistance Program (RAP) has access to anv national laboratorv. Appendix 7 G.1.1: Corporate EP 0.4: SNC ERO personnel who are The commitment wording was standardized and personnel identified in the responsible for implementing this plan receive relocated to the SNC Standard Emergency Plan. Emergency Response Organization specialized training. The training program for receive training. emergency response personnel is developed based on the requirements of 10 CFR 50, Appendix E and position-specific responsibilities. E12-215 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Appendix 7 G.1.1: The training EP 0.4: SNC ERO personnel who are The commitment wording was standardized and consists of familiarization with the responsible for implementing this plan receive relocated to the SNC Standard Emergency Plan. Site Emergency Plans and specialized training. The training program for applicable emergency implementing emergency response personnel is developed procedures required to carry out their based on the requirements of 10 CFR 50, specific functions. Appendix E and position-specific responsibilities. Appendix 7 G.1.1: A training matrix EP 0.4: SNC ERO personnel who are The commitment wording was standardized and for corporate personnel assigned to responsible for implementing this plan receive relocated to the SNC Standard Emergency Plan. the ERO is shown in Table 2, and specialized training. The training program for training course summaries are emergency response personnel is developed presented in Table 3. Training will based on the requirements of 10 CFR 50, be documented in accordance with Appendix E and position-specific established practices. responsibilities. EP 0.4.1: ERO members will receive Emergency Plan training on an annual basis. Personnel identified receive training appropriate to their position in the areas of:

Accident assessment.
Accident mitigation .
Notifications .
Emergency Classifications .
Protective Action Recommendations .
Emergency Action Levels .
Emergency Exposure Control.

Appendix 7 G.1.1: The corporate The SNC Standard Emergency Plan maintains the emergency planning coordinator(s) commitment to conduct the training for corporate are responsible for assuring that personnel. Who conducts the training may depend training is conducted for corporate on specific areas of expertise and provides no emergency response personnel each purpose in the SNC Standard Emergency Plan. calendar year. Appendix 7 G.1.2: Drills/ exercises The SNC Standard Emergency Plan incorporates will be conducted each calendar year the EOF into the base Plan response. The Drill to test the performance of criteria of the Plan and Annex. Separate drill implementing procedures, personnel, criteria for the EOF are no longer required. and emergency equipment. These drills/exercises will be conducted with each SNC site. E12-216 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix Current Vogtle Emergency Plan Revised SNC Emergency Plan Justification Revision 63 Appendix 7 G.1.2: EOF activation is The SNC Standard Emergency Plan incorporates required at least 3 times annually (1 the EOF into the base Plan response. The Drill scenario per site per year). criteria of the Plan and Annex. Separate drill criteria for the EOF are no longer required. Appendix 7 G.1.2: At least 1 N.2.10 The SNC Standard Emergency Plan incorporates activation every 5 years will require a At least once every five years, a drill involving the EOF multi-site drill requirement into the base concurrent EOF support response more than one SNC site will be conducted Plan response. for more than one SNC site. demonstrating the ability of the Common EOF to effectively implement the Emergency Plan for an event involving more than one site. Appendix 7 G.1.2: Each drill/exercise EP N.1: Drills and exercises shall: The commitment wording was standardized and will test, as a minimum, the

Test the adequacy of timing and content of relocated to the SNC Standard Emergency Plan.

communication links and notification implementing procedures and methods. procedures.

Test emergency equipment and communications networks.
Test the public notification system.
Ensure that emergency organization personnel are familiar with their duties.

Appendix 7 G.1.2: Provisions are EP N.4: A formal critique will be performed for The commitment wording was standardized and made for critique of all exercises, drills, and training tabletops to relocated to the SNC Standard Emergency Plan. drills/exercises. develop, maintain, or demonstrate key skills in order to identify weak or deficient areas that need correction. A critique shall be conducted at the conclusion of the exercise, to evaluate the organization's ability to respond as called for in the SNC Standard Emergency Plan. Appendix 7 G.1.2: Critique items will EP N.5: The Emergency Preparedness group The commitment wording was standardized and be forwarded to the site emergency is responsible for evaluating recommendations relocated to the SNC Standard Emergency Plan. preparedness coordinator for and comments, determining which items will be processing in the site specific incorporated into the program or require corrective action program. corrective actions, and for scheduling, tracking, and evaluating item resolution. Whenever exercises or drills indicate deficiencies in the SNC Standard Emergency Plan, site-specific Annexes, corresponding implementing procedures, or training lesson plans, such documents will be revised as necessary. E12-217 2 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix E12-218

Enclosure 12 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix VEGP 1 & 2 Site On-Shift Table Comparison Major Functional Area Major Tasks Position Title I Expertise 0654 VEGP 1&2 VEGP 1&2 VEGP 1&2 Table B-1 Rev5 Rev63 Proposed on-shift* Plant Operation and Shift Supervisor (SRO) 1 1 1 1 Assessment of Operation Shift Foreman (SRO) 1 1 2 2 Aspects Control Room Operators 2 (per unit) 2 4 4 Auxiliary Operators 2 (per unit) 2 7 7 Shift Support Supervisor 1 1 Emergency Direction and Shift Technical Advisor, Shift 1** 1 1** 1** Control (Emergency Supervisor or designated facility Coordinator) *** manager Notification I Communication Notify state/local and federal 1**** 2 2** 1**

- - - personnel, maintain communication Radiological Accident In-Plant surveys HP Technicians 1 1 1 1 Assessment and Support of Chemistry I Radiochemistry Chem/HP Technicians 1 1 1 2 Operational Accident Offsite Surveys onsite (out of plant) Chemistry Technicians, System 5 2 1 Assessment Operator or other trained personnel FMT Communicator 1 Plant System Engineering Technical suooort Shift Technical Advisor 1 1 1** 1**

Repair and Corrective Repair and Corrective Actions Maintenance Supervisor 1 Actions Mechanical Maintenance 1** 1 1 1 Electrical Maintenance 1** 1 1 1 I & C Technician 1 1 1 Protective Actions (In-Plant) Radiation Protection: HP Technicians 2** 2 2 1

a. Access Control

b. HP Coverage for repair, corrective actions, search and rescue first-aid & firefighting

c. Personnel monitoring

d. Dosimetry Firefighting Fire Brigade per Tee Specs 5**

Rescue Operations and First- 2** 2** 2** 2** Aid Site Access Control and Security, firefighting communications, Security personnel per security plan Personnel Accountability personnel accountability Total On-Shift 10 22 25 24 E12-219

Enclosure 12 to NL-16-0169 Vogtle (Units 1 & 2) Justification Matrix VEGP 1 & 2 Site 60 Minute Augmented ERO Table Comparison Major Functional Area Major Tasks Position Title I Expertise Table B-1 VEGP VEGP 1&2 VEGP 1&2 Augment 1&2 Rev63 Proposed Revs (60 min) (75 min) Emergency Direction and 9 Control Notification I Notify state/local and federal 2 2 2 11 Communication personnel, maintain communication Radiological Accident EOF Director Senior ManaQer 1 1 1 (a) Assessment and Support of Dose Assessment HP Expertise 3 Operational Accident Offsite Surveys HP Technicians 2 4 3 6 Assessment On-Site Surveys HP Technicians 1 In-Plant surveys HP Technicians 1 Chemistry I Radiochemistry Chem/HP Technicians 1 1 1 2 Plant System Engineering Technical Support Electrical 1 1 1 1 Mechanical 1 1 1 1 Engineering Supervision 2 Core Thermal I Hydraulic 1 1 Repair and Corrective Repair and Corrective Actions Mechanical Maintenance 1 1 1 1 Actions Rad Waste Operator 1 1 1 Electrical Maintenance 1 1 1 1 l&C Technician 1 Maintenance Supervision 2 Protective Actions (In-Plant) Radiation Protection: HP Technicians 2 2 2 3

a. Access Control

b. HP Coverage for repair, corrective actions, search and rescue first-aid &

firefighting

c. Personnel monitoring

d. Dosimetrv Total Augmented ERO 15 15 14 44

 *For each unaffected unit, maintain at least 1 SF, 1 CRO, 1 AO.        ***Overall direction to be assumed by EOF Dire when ERFs are fully manned.
**May be provided by shift personnel assigned other functions.        ****May be performed by engineering aid to shift supervisor.

(a) EOF Emergency Director counted in Emergency Direction and Control. E12-220

Southern Nuclear Operating Company Joseph M. Farley Nuclear Plant Units 1 and 2; Edwin I. Hatch Nuclear Plant Units 1 and 2; Vogtle Electric Generating Plant Units 1 and 2; Vogtle Electric Generating Plant Units 3 and 4 Enclosure 14 Vogtle (Units 3 and 4) Standard Emergency Plan Annex (Marked-Up Pages and Clean Copy) 4 to NL-16-0169 Vogtle (Units 3 & 4) Standard Emergency Plan Annex Section 4: Emergency Measures (SEP El 4.1 Notification of Off-Site Agencies (SEP E.2.2) 4.1.1 Notification Process (SEP E.2 .2.2) State and local warning points are staffed 24 hours per day. State and local counties surrounding VEGP are to be notified within 15 minutes of the declaration of an emergency condition are: State of Georg ia:

Georgia Emergency Management Agency (GEMA)

Georgia County Authorities:

Burke - Burke County Emergency Management Agency State of South Carolina :
Emergency Management Division (EMO)

South Carolina County Authorities:

Barnwell and Aiken County - Sheriffs Department
Allendale County - County Central Dispatch Department of Energy - Savannah River Site (DOE-SRS)
DOE-SRS Operations Center 4.2 Alert and Notification System (ANS) (SEP E.2.'5) ( Comment [Ml]: RAl-VEGP3&4-3 Within the 10 mile Exposure Emergency Plann ing Zone (EPZ), there exist provisions for alerting and providing notification to the public. The state and/or local authorities are responsible for activation of this system.

Two totally independent public alerting systems are installed for use in the VEGP EPZ:

Network of fixed sirens and EAS ,
NOAA (National Oceanic and Atmospheric Administration) weather warning rad io system .

Offsite agencies will activate both independent systems in the event of a plant condition requ iring public awareness. Following any public alert, commercial radio and television stations, as well as NOAA weather rad io (NWR) will be used to provide notification and follow-up emergency information to the population with in the EPZ. Responsibility for alerting and notifying the public lies with the appropriate offsite civil authorities; specifically , GEMA for anywhere within the State of Georgia ; Burke County EMA for Burke County, Georgia; SCEMD for South Carolina ; The County Division of Emergency Preparedness in Aiken County, South Carolina ; the County Disaster Preparedness Agencies in Allendale and Barnwell Counties, South Carolina ; and the SRS . Physical activation of the sirens in Burke County will be done by the Burke County EMA in accordance with the Burke County SOP, and in coordination with GEMA Physical activation of the siren in Barnwell County will be done by that county, in consultation with SCEMD. Physical activation of the NWR system is by the NWS office in Columbia, SC for VEGP when requested to do so by GEMA In general , SCEMD will rely upon GEMA to activate the NWR system , and to coord inate with Burke County on the activation of the EAS. E1 4-16 4 to NL-16-0169 Vogtle (Units 3 & 4) Standard Emergency Plan Annex The South Carolina Governor's Office or SCEMD will activate the South Carolina EAS after coordination with Georgia authorities. Provisions for transient population notification are also included in state and county plans. The system maintenance requirements for the Tone Alert Radio System are contained in the FEMA approved System Design Report. Specifically , Vogtle maintains a database of those assigned tone alert radios and performs an annual telephone survey documenting the adequacy of distribution. In the event of an emergency declaration at the VEGP, DOE-Savannah River Site has agreed to provide prompt notification of all persons on the SRS within VEGP's plume exposure pathway EPZ. The Alert and Notification System (ANS) description is provided in the FEMA approved Alert and Notification System Design Report located in the SNC document management system . Within the Plume Exposure Emergency Planning Zone (EPZ) , there exist provisions for alerting and providing notification to the public. The state and/or local authorities are responsible for activation of this system . The Vogtle Electric Generating Plant (VEGP) has de*,reloped a Public Alert and

              ~Jotification system designed for coverage of the population within the EPZ . This is accomplished utilizing a combination of fixed sirens and tone alert radios. Sirens installed by \tEGP ha 1e been sited according to FEMA REP 10 criterion to ensure the 1

required co*1erage. Provisions for transient population notification are also included in state and county plans. In the e\*ent of an emergency declaration at the VEGP, DOE Savannah River Site has agreed to provide for the prompt notification of all persons on the SRS within VEGP's plume exposure pathway EPZ. A full Alert and Notification System (ANS) description is provided in the FEMA approved Alert and Notification System Design Report (ANS VEGP 001) located in the S~JC document management system . The AMS system includes administrative and physical means for a backup method of public alerting and notification capable of being used in the event the primary method of alerting and notification is una 1ailable during an emergency to alert or notify all or 1 portions of the plume exposure pathway EPZ population . The backup method has the capability to alert and notify the public within the plume exposure pathway EPZ, but may not meet the 15 minute design objecti'1e for the primary prompt public alert and notification system . 4.3 Protective Actions for Onsite Personnel (SEP J.4) Protective response for onsite personnel (including visitors and contractor personnel) includes alerting, assembly and accountability , site evacuation , monitoring , and decontamination . Protective actions may also be taken for onsite personnel for emergencies such as fi res, security related events or natural disasters where personnel safety is threatened . 4.3.1 Alerting (SEP E.2.1, J.1) Section E of the Emergency Plan (EP), Notification Methods and Procedures , describes the methods to be used to alert onsite personnel of emergency conditions*. 4.3.2 Assembly (SEP J.4. 1) E14-17 4 to NL-16-0169 Vogtle (Units 3 & 4) Standard Emergency Plan Annex Seismic (SEP H.5.1) Seismic monitoring instrumentation for VEGP Units 3 and 4 will include triaxi al acceleration sensors and a time-history analyzer. One of the four triaxial acceleration sensors will be located in the free fie ld, a second sensor will be located on the nuclear island basemat, a third sensor will be located on the shield building structure, and a fourth sensor will be located on the containment internal structure . The triaxial acceleration sensors will provide a signal to the time-history analyzer located in a room near the control room. The time-history analyzer includes a dedicated computer for data storage, playback , and analysis. Activation of the time-history analyzer causes visual and audible annunciation in the control room to alert the plant operator that an earthquake has occurred . 5.7 Protective Facilities and Equipment (SEP J) Assembly Points (SEP J.4.1) In the event of a plant evacuation , the On-Site Assembly Areas (or Off-Site Assembly Areas, as appropriate) will be utilized. The function of the assembly area is to provide a center for personnel accountability and radiological contamination screening along with any other immediately necessary actions. The assembly areas are located in various buildings throughout the site. Georgia Power Company facilities may be utilized as the off-site assembly area at the discretion of the Emergency Director. Its location will be announced over the public address system when announcement of evacuation is made. Protective actions including relocation of onsite personnel in the event of an attack or threat of hostile action against the site have been developed for that specific situation. Specific protective actions in this case are identified in site procedures not readily available to the public. 5.8 Medical Support (SEP B, SEP L) 5.8.1 Hospital and Medical Support (SEP B.6.3, L.1) Agreements are in place with the University of Alabama Birmingham (UAB) Hospital, Burke Medical Center, Doctors Hospital, and Burke County Emergency Management Agency to provide assistance for injured personnel, including cases involving radioactive contamination . This assistance will be requested whenever necessary in accordance with plant procedures. 5.8.2 Ambulance Service (SEP B.6.2, L.4) Injured/externally contaminated personnel who require medical attention will normally be transported by ambulance to the cooperating hospitals. Ambulance crews are trained to handle external contamination cases, and an RP technician may accompany, as requested , any contaminated patients to the hospital. Ambulance service is provided by the Burke County Emergency Management Agency. E14-26 4 to NL-16-0169 Vogtle (Units 3 & 4) Standard Emergency Plan Annex A ppend ix C - Vogt le Electric Generating Plant 3&4 NUREG-0654 Cross Reference Table [ Comment [M2]: RA l*GEN-2 NUREG 0654 Rev 1 VEGP3&4 SNC SEP Section Ref Section SEP Annex Criteria II.A - Assignment of Responsibilitv A. 1.a A. 1, A.2 , A.3, A.4 1.3, 1.4, 1.5, 1.6 A. 1.b Introduction Section 1: Introduction A.1 .c Figures 8 .2.1.A, 8 .2.2.A, 8 .3.1.A & -- 8 .3.2.A A.1.d 8 .3.1.1 -- A.1.e 8 .1 Table 2.2.A A.2 .a NIA NIA A.2 .b NIA NIA A.3 A.5 1.7 A.4 8 .2, 8 .2.1.15, 8 .3.1.3 -- Criteria 11.B - Onsite Emeraencv Oraanization 8 .1 8.2 -- 8 .2 8 .1.1 Table 2.2.A 8 .3 8 .1.2 -- 8.4 8 .1.1 , Fiaure 8 .2.A -- 8 .5 Tables 1 - 4 Table 2. 2.A 8 .6 8 .2, 8 .3, Figures 8 .2.1.A, 8 .2.2.A, -- 8 .3.1.A & 8 .3.2.A 8 .7 Tables 1-4 -- Figures 8 .2.1.A, 8 .2.2.A, 8 .3.1.A & 8 .3.2.A 8 .7.a 8 .2.1.15, 8 .3.1.3 -- 8 .7.b 8 .3.1.2, 8.3.1.17 -- 8 .7.c 8 .3.1.1 8 .3.1.2 -- 8 .7. d 8 .3.2.1 , 8 .3.2.2, 8 .3.2.8 -- 8 .8 8.4, C.4.2 2.3 8 .9 8 .6, K.1 2.3 Criteria 11.C - Emeraencv Response Sunnort and Resources C.1.a Section C -- C.1.b A.1 1.6 C.1.c A. 1.1 , A.2 , A.3 , C.1-C.4, F.1 Section 1 C.2.a NIA NIA C.2.b A.1.1 , H.2.1 5.1.2 C.3 H.5.2.3, H.6.3 -- C.4 Sections A & C, 8.4-8 .6, H.6.3, L.1 - 1.3-1 .7, 2.3, 5.8 L.4 Criteria 11.D - Emergency Classification Svstem D.1 Section D Append ix 8 D.2 Section D Appe ndix 8 D.3 NIA NIA D.4 NIA NIA Criteria 11.E - Notification Methods and Procedures E.1 E.1 .1 Append ix D E.2 E.2 .1 -- E.3 E.2.2.2 -- E.4 E.2.2.2 -- E.4.a E.2.2.2 -- E.4.b E.2.2.2 -- E.4.c E.2.2.2 -- NOTE: N/A =Not required by Licensee in accordance w ith NUREG-0654 E14-30 4 to NL-16-0169 Vogtle (Units 3 & 4) Standard Emergency Plan Annex NUREG 0654 Rev 1 VEGP3&4 SNC SEP Section Ref Section SEP Annex Criteria 11.E - Notification Methods and Procedures (continued) E.4.d E.2.2.2 -- E.4.e E.2.2.2 -- E.4.f E.2.2.2 -- E.4.g E.2.2.2 -- E.4.h E.2.2.2 -- E.4.i E.2.2.2 - E.4.i E.2.2.2 -- E.4.k E.2.2.2 -- E.41 E.2.2.2 -- E.4.m E.2.2.2 -- E.4.n E.2.2.2 -- E.5 N/A N/A E.6 E.2.5 -- E.7 E.2.6 -- Criteria 11.F - Emergency Communications F.1.a F.1.1, F.1.2 4.1.1 F.1.b F.1.3 -- F.1.c F.1.4 -- F.1.d F.1.5 -- F.1.e F.1.6 -- F.1.f F.1.4 -- F.2 F.2 -- F.3 F.3 5.4 Criteria 11.G - Public Education and Information G.1 G.1 -- G.2 G.8 2.3.6 G.3.a B.3.2 .1, H.2.2, H.2.3 5.1.6 G.3.b N/A N/A G.4.a B.3.2.8 -- G.4 .b G.2 -- G.4.c B.3.2.5, B.3.2.6 -- G.5 G.2 -- Criteria 11.H - Emergency Equipment and Facilities H.1 H.1.2 5.1.2 H.2 H.2.1 5.1.5 H.3 H.2.2, H.2.3 -- H.4 H.1 -- H.5 H.5 5.6 H.5.a H.5.1 5.6.1 H.5.b H.5.2 -- H.5.c H.5.3 -- H.5.d H.5.4 -- H.6.a H.5.1 5.6.1 H.6.b H.5.2 -- H.6.c H.5.2.3, H.6.3 -- H.7 H.6 -- H.8 H.7 5.6.1 H.9 H.1.3 5.1 .3 H.10 H.8 -- H.11 H.9 -- H.12 H.10 -- NOTE: NIA = Not required by Licensee in accordance w ith NUREG-0654 E14-31 4 to NL-16-0169 Vogtle (Units 3 & 4) Stan dard Emergency Plan Annex NUREG 0654Rev1 VEGP3&4 SNC SEP Section Ref Section SEP Annex Criteria II.I - Accident Assessment 1.1 1.1 -- 1.2 1.2 -- 1.3.a 1.3 -- 1.3.b 1.3 - 1.4 1.4 -- 1.5 1.5 -- 1.6 1.6 -- 1.7 1.7 -- 1.8 1.8 -- 1.9 1.9 -- 1.10 1.7 - 1.11 NIA NIA Criteria 11.J - Protective Response J.1.a J.1 -- J.1.b J.1 - J.1.c J.1 -- J.1.d J.1 -- J.2 J.4.3 -- J.3 J.2 -- J.4 J.3, J.4 .3 -- J.5 J.4.2 , 4.3.2 -- J.6.a J.4 -- J.6.b J.4 -- J.6.c J.4 -- J.7 J.5 -- J.8 J.6 Appendix A J.9 NIA NIA J.10.a J.7 -- J.10.b J.7 -- J.10.c E.2 .5 4.2 J.10.d NIA NIA J.10.e NIA NIA J.1O.f NIA NIA J.10.g NIA NIA J.10.h NIA NIA J.10.i NIA NIA J.10.i NIA NIA J.10.k NIA NIA J.10.1 NIA NIA J.10.m J.5 -- J.11 NIA NIA J.12 NIA NIA Criteria 11.K - Radioloaical Exoosure Control K.1.a K.1.1 -- K.1.b K.1 - K.1 .c K.1 -- K.1.d K.1 .2.1 -- K.1.e K.1.2. 1, K.5 -- K.1.f K.1.1 .1 -- K.1.a K.1.3 -- K.2 K.1 -- NOTE: N/A =Not required by Licensee in accordance with NUREG-0654 E14-32 4 to NL-16-0169 Vogtle (Units 3 & 4) Standard Emergency Plan Annex NUREG 0654 Rev 1 VEGP3&4 SNC SEP Section Ref Section SEP Annex Criteria 11.K - Radiological Exposure Control (continued) K.3.a K.3 -- K.3.b K.3 -- K.4 N/A N/A K.5.a K.5 -- K.5.b K.5 -- K.6.a K.6 -- K.6.b K.6 -- K.6.c K.6 -- K.7 K.7 -- Criteria 11.L - Medical and Public Health Suooort L.1 L.1 -- L.2 L.2 -- L.3 N/A NIA L.4 L.4 - Criteria 11.M - Recoverv and Reentrv Plannina and Post-Accident Operations M.1 M.1 -- M.2 M.2 -- M.3 M.3 -- M.4 M.4 -- Criteria 11.N - Exercises and Drills N.1.a N.1 -- N.1.b N.1 -- N.2.a F.3 -- N.2.b N.2.3 -- N.2.c N.2.4 -- N.2.d N.2.5 -- N.2.e(1) N.2.6 -- N.2.e(2) N.2.6 -- N.3.a N.3 -- N.3.b N.3 -- N.3.c N.3 -- N.3.d N.3 -- N.3.e N.3 -- N.3.f N.3 -- N.4 N.4 -- N.5 N.5 -- Criteria 11.0 - Radiological Emer~ency Response Training 0 .1 0.1 -- 0 .1.a 0 .1.1 -- 0 .1.b 0 .1.1 -- 0 .2 0 .3 -- 0.3 0 .4 -- 0.4.a 0.4 -- 0 .4.b 0 .4 -- 0.4.c 0.4.3 -- 0 .4.d 0 .4.1, 0.4.4 -- 0.4 .e 0.4.5 -- 0.4.f 0.4.6 * -- 0.4.g 0.1.1 -- 0.4.h 0 .1.1 -- 0.4.i 0.4 -- NOTE: NIA = Not required by Licensee in accordance with NUREG -0654 E14-33 4 to NL-16-0169 Vogtle (Units 3 & 4) Standard Emergency Plan Annex NUREG 0654 Rev 1 VEGP3&4 SNC SEP Section Ref Section SEP Annex Criteria 11.0 - Radiological Emergency Resoonse Trainina (continued 0.4.i 0.4, 0 .4.7 - 0 .5 0.4 -- Criteria 11.P - Responsibility for the Planning Effort: Development, Periodic Review and Distribution of Emergency Plans P.1 0 .5, Section P -- P.2 Section P -- P.3 P.1 -- P.4 P.1 -- P.5 P.3 -- P.6 P.3 -- P.7 -- Aooend ix D P.8 Table of Contents -- P.9 P.3 -- P.10 F.1.4 -- NOTE: NIA = Not requ ired by Licensee in accordance w ith NUREG-0654 E14-34 4 to NL-16-0169 Vogtle (Units 3 & 4) Standard Emergency Plan Annex Appendix D - Supporting Plans & Implementing Procedures (SEP P.3) Supporting Plans

State of South Carolina Radiological Emergency Response Plan
State of Georgia Rad iological Emergency Response Plan.
Burke County Georg ia Emergency Response Plan
Aiken , Allendale , Barnwell County Emergency Response Plan
VEGP Security Plan
VEGP Fire Protection Plan Adm inistrative and Emergency Plan Implementing Procedures (EPIP)

Plan Section Title EPIP EPIP Title Section A Assignment of Respons ibility NMP-EP-300 SNC Emergency Preparedness (under Conduct of Operations development) 91801-C Coordination of Emergency Responses and Planning Between Southern Nuclear Operating Company-VEGP and US DOE-Savannah River Site B Emergency Response Organization NMP-EP-146 ERO Position Checklists 91101-C Emergency Response Organization c Emergency Response Support and NMP-EP-300 SNC Emergency Preparedness Resources (under Conduct of Operations development) 91703-C Emergency Support for Hatch Nuclear Plant D Emergency Classification System NMP-EP-141 Emergency Classification E Notification Methods and Procedures NMP-EP-142 Emergency Notification NMP-EP-308 SNC Emergency Alert Siren Operation , Testing And Maintenance 91706-C Alert Notification System F Emergency Communications NMP-EP-300 SNC Emergency Preparedness (under Conduct of Operations development) 91204-C Emergency Response Communications E14-35 4 to NL-16-0169 Vogtle (Units 3 & 4) Standard Emergency Plan Annex Plan Section Title EPIP EPIPTitle Section G Public Education and Information NMP-EP-203 Corporate Media Center Operations NMP-EP-204 Emergency News Center/Joint Information Center Operations NMP-EP-205 Emergency Communications News Releases NMP-EP-206 Emergency Communications News Briefings NMP-EP-207 Emergency Communications Public

Response

H Emergency Facilities and Equipment NMP-EP-143 Facility Activation NMP-EP-305 Equ ipment Important to the EP Function 91702-C Emergency Equipment and Supplies 91705-C Inventory and Testing of Emergency Preparedness Material/Equ ipment Wh ich Are Not Part of the Emergency Kits I Accident Assessment NM P-EP-140 Accident Assessment 91302-C In Plant Sampling and Surveys 91303-C Field Sampling and Surveys J Protective Response NMP-EP-144 Protective Actions 91704-C Actions for Security During a Rad iological Emergency K Rad iolog ical Exposure Control 91301 -C Emergency Exposure Gu idelines 91306-C Contamination Monitoring and Decontamination L Medical and Public Health Support NMP-EP-300 SNC Emergency Preparedness (under Conduct of Operations development) 91309-C Mass Casualty Triage M Recovery and Re-entry Plan ning and NMP-EP-145 Te rmi nation and Recovery Post Accident Operations 91308-C Re-Entry N Exercises and Drills NMP-EP-303 Drill and Exercise Standards 0 Radiological Emergency Response NMP-EP-301 EOF Emergency Response Training Organ ization And EP Staff Training 91601-C Emergency Preparedness Training E14-36 4 to NL-16-0169 Vogtle (Units 3 & 4) Standard Emergency Plan Annex Plan Section Title EPlp EPIP Title Section '-' p Responsibility for the Planning Effort NMP-EP-300 SNC Emergency Preparedness Conduct of Operations NMP-EP-310 Maintaining The Emergency Plan NMP-EP-312 Development Of Emergency Preparedness Technical Products NMP-TR-104- SEPTOC 006 91701-C Preparation and Control of Emergency Preparedness Documents E14-37

Southern Nuclear Operating Company STANDARD EMERGENCY PLAN ANNEX for Vogtle Electric Generating Plant Units 3 and 4 Revision 0 4 to NL-16-0169 Vogtle (Units 3 & 4) Standard Emergency Plan Annex Table of Contents Section 1: Introduction (SEP) ............................................................................................................................ 3 1.1 Facility Description ........................................................................................................................................ 3 1.2 Emergency Planning Zones (SEP J.5) ....................................................................................................... 3 1.3 State of Georgia (SEP A.2.2) ...................................................................................................................... 3 1.4 State of South Carolina (SEP A.2.3) ...........................................................................................*.............. 4 1.5 Local Organizations (SEP A.2.4, B.6.1) ..................................................................................................... 5 1.6 Department of Energy (DOE) - Savannah River Site (SRS) (SEP A.1.4) ........................................... 5

1. 7 Hostile Action Based Events (SEP H.1.4) ................................................................................................. 5 Figure 1.1.A - Location and Vicinity Map .................*........................................................................................... 6 Figure 1.1.B - VEGP Site Layout ................,...................................................................................................'..... 7 Figure 1.2.A - 10 Mile Emergency Planning Zone (EPZ) ................................................................................. 8 Figure 1.2.B - 50 Mile Ingestion Pathway IPZ ................................................................................................... 9 Section 2: Organizational Control of Emergencies (SEP 8.1) .......................................................*........ 10 2.1 Normal Plant Organization (SEP B.1) ...................................................................................................... 10 2.2 Emergency Organization (SEP B.2, B.3) ..*.............................................*................................................ 10 Table 2.2.A - Vogtle Electric Generating Plant On-Shift Staffing.'.................................................................. 11 2.3 Non-SNC Support Groups (SEP B.4, B.5, 8.6) ...................................................................................... 13 Section 3: Classification of Emergencies (SEP D.1) ........................................................*........................ 15 3.1 Emergency Classifications: (SEP D.1) ...........................................................................................*......... 15 3.2 Determination of Levels: (SEP D.1.2) ............................................*......................................................... 15 3.3 Operating Mode Applicability (SEP D.2.7) ........................*...................................................................... 15 Section 4: Emergency Measures (SEP E) ..................................................................................................... 16 4.1 Notification of Off-Site Agencies (SEP E.2.2) ......................................................................................... 16 4.2 Alert and Notification System (ANS) (SEP E.2.5) .................................................................................. 16 4.3 Protective Actions for Onsite Personnel (SEP J.4) ................................................................................ 17 4.4 Protective Actions for the Offsite Public (SEP J.5) ................................................................................. 18 Section 5: Emergency Facilities and Equipment (SEP H) ........................................................................ 19 5.1 Emergency Response Facilities (SEP H.1, H.2) .................................................................................... 19 Figure 5.1.A - Sample Technical Support Center ........................................................................................... 22 Figure 5.1.B- Sample Operations Support Center .... ,.........................................................*.......................... 23 5.2 On-Site Communications (SEP F.1) ......................................................................................................... 24 5.3 Offsite Communications (SEP F.1) ........................................................................................................... 24 5.4 Communications System Testing (SEP F.3) ..................................................*........................................ 24 5.5 Emergency Kits (SEP H.9) ......................................................................................................................... 24 5.6 Facilities and Equipment for On-site Monitoring (SEP H.5) .................................................................. 24 5.7 Protective Facilities and Equipment (SEP J) ...............*....................................*...................................... 26 5.8 Medical Support (SEP B, SEP L) .........*.................. _. ...............................................................~*****************26 Appendix A - Evacuation.Time Estimate Study and Map Reference (SEP J.6) ................................. 27 Appendix B - Emergency Action Level (EAL) Scheme (SEP D. 1) .......................................................... 29 Appendix C - Vogtle Electric Generating Plant 3&4 NUREG-0654 Cross Reference Table....*........ 30 Appendix D - Supporting Plans & Implementing Procedures (SEP P.3) .............................................. 35 E14-2 4 to NL-16-0169 Vogtle (Units 3 & 4) Standard Emergency Plan Annex Section 1: Introduction (SEP)

This document serves as the Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Annex and contains information and guidance that is unique to VEGP Units 3 and 4. This includes Emergency Action Levels (EALs) and facility geography. In an emergency situation at VEGP, the initial response would be made by the site staff and, if needed, by local support agencies. This Annex addresses the actions and responsibilities of the VEGP plant staff and the offsite support agencies. 1.1 Facility Description The Vogtle Electric Generating Plant (VEGP) Units 3 and 4 are a two-unit pressurized water reactor, based upon the Westinghouse AP1000 passive reactor design. The plant site, to include VEGP Units 1-4, is on a 3, 169-acre site located in the eastern portion of Burke County, Georgia, approximately 23 river miles upstream from the intersection of the Savannah River with U.S. Highway 301. 1.2 Emergency Planning Zones (SEP J.5) 1.2.1 Plume Exposure Pathway (SEP J. 7) The 10-mile Emergency Planning Zone (EPZ) for VEGP approximates a 10-mile radius around the plant site and is depicted in Figure 1.2.A. Georgia and South Carolina, as well as the counties (Burke County in Georgia and Aiken, Barnwell, and Allendale Counties in South Carolina) are located within the plume exposure pathway EPZ. The major portion of the plume exposure pathway EPZ in South Carolina is within the Department of Energy's Savannah River Site (SRS). 1.2.2 Ingestion Pathway (SEP J. 7) The area between the 10-mile and 50-mile radius is considered the Ingestion Pathway Zone (IPZ). The 50 mile IPZ is depicted in Figure 1.2.B. Planning for the ingestion exposure pathway is a responsibility of the states of Georgia and South Carolina. More information about the IPZ can be obtained from the states' Radiological Emergency Plans. 1.3 State of Georgia (SEP A.2.2) Upon notification of an emergency condition, the Georgia Emergency Management Agency will implement the "State of Georgia Radiological Emergency Plan." The Georgia Emergency Management Agency has the authority and responsibility for coordinating the efforts of local and state agencies in Georgia to provide for the health and safety of the general public in the event of a radiological incident. An agreement is in place with the state of Georgia to provide available resources and equipment to support the mitigation and response to an emergency at Plant Vogtle to include Hostile Action Based events. These resources include, but are not limited to, Local Law Enforcement Agency (LLEA) assets, fire fighting assets, medical support resources (including transportation), and coordination through an Incident Command Post. Requests for offsite resources and equipment will be communicated from the control room to the Burke County 911 center, the county EOC, or through the Incident Command Post, as applicable, based on the nature and timing of the event. E14-3 4 to NL-16-0169 Vogtle (Units 3 & 4) Standard Emergency Plan Annex

   . 1.4    State of South Carolina (SEP A.2.3)

The state of South Carolina has developed the South Carolina Radiological Emergency Response Plan (SCORERP), which provides guidance to state and local governments on procedures, organization, and responsibilities for preventing and mitigating the effects of a nuclear power plant incident or disaster. The SCORERP describes the South Carolina Radiological Emergency Response Organization, which consists of the Office of the Adjutant General (Emergency Management Division) (EMO), the Department of Health and Environmental Control (Bureau of Solid and Hazardous Waste, Nuclear Emergency Planning (NEP) Section), and those state resources .available to local government(s) during a fixed nuclear facility radiological accident. The response functions of involved agencies. are described in the SCORERP and the South Carolina Technical Radiological Emergency Response Plan (SCTRERP). 1.4.1 Office of the Governor (SEP A.2.3.1) In the event of the declaration of a radiological emergency, the EMO, Department of Health and Environmental Control (DHEC) and other state agencies are activated. 1.4.2 Office of the Adjutant General - Emergency Management Division (EMO)_ (SEP A.2.3.1) . The EMO is responsible for coordinating the emergency planning efforts of all state, county, and municipal agencies in developing a state emergency plan. Additional responsibilities include conducting a preparedness program to assure capability of the state government to execute the plan; establishing and maintaining a state EOG and provide support of the state emergency staff and work force; and establishing an effective system for reporting, analyzing, and disseminating emergency information.

1.4.3 Department of Health and Environmental Control (DHEC) (A.2.3.2)

DHEC maintains a radiological hazard assessment capability and provides technical support, coordination, and guidance for the state and local governments. It will conduct and/or coordinate radiological surveillance and monitoring in coordination with DOE-Savannah River Site (SRS) and V_EGP. 1.4.4 Other State Support Agencies (A.2.3.3) Other state agencies described in the South Carolina Emergency Operating Plan (SCEOP) and South Carolina Operational Radiological Emergency Response Plan (SCORERP) will provide related support pursuant to each plan. Those agencies include:

Department of Public Safety (Highway Patrol Division)
State Law Enforcement division (SLED)
Forestry Commission
Department of Natural Resources E14-4 4 to NL-16-0169 Vogtle (Units 3 & 4) Standard Emergency Plan Annex
Department of Social Services
Department of Agriculture
Clemson University Cooperative Extension Service 1.5 Local Organizations (SEP A.2.4, B.6.1)

Principal activities of Local Emergency Management Agencies (LEMA) and Local Law Enforcement Agencies (LLEA) in Georgia and South Carolina are described in the respective county Emergency Operations Plans. 1.5.1 Burke County Georgia (SEP A.2.4) The area within the plume exposure pathway (EPZ) in the state of Georgia falls within Burke County. The responsibility for overall radiological emergency response planning rests with the Chairman, Burke County Board of Commissioners. It is the chairman's responsibility to initiate actions and provide direction and control at a level consistent with the specific incident. 1.5.2 Aiken, Barnwell, and Allendale Counties South Carolina (SEP A.2.4) Most of the plume exposure pathway EPZ within South Carolina falls within the site boundary of the Savannah River Site (SRS). The United States Department of Energy is responsible for the direction and control of all emergency response actions on the SRS. Limited portions of Aiken, Barnwell, and Allendale counties are outside of the SRS but within the plume exposure pathway EPZ of VEGP. These counties are similarly organized, with the responsibility for overall radiological' emergency response planning resting with the Chairman of the County Council in each case. 1.6 Department of Energy (DOE) - Savannah River Site (SRS) (SEP A.1.4) The DOE-Savannah River Site (SRS) will provide the necessary response within the SRS reservation in accordance with the SRS Emergency Plan. The DOE will exercise overall responsibility, jurisdiction, and authority for conducting response operations on the Savannah River Site to protect the health and safety of SRS personnel. DOE will provide for emergency notification and, as needed, evacuation, monitoring, decontamination, and immediate lifesaving medical treatment of non SRS personnel on the Savannah River Site. DOE will also provide access control for SRS areas.

1. 7 Hostile Action Based Events (SEP H.1.4)

Agreements are in place with the state of Georgia, Burke County, Georgia, Aiken, Allendale, and Barnwell Counties in South Carolina to provide available resources and equipment to support the mitigation and response to an emergency at Plant Vogtle to include Hostile Action Based events. These resources include, but are not limited to, Local Law Enforcement Agency (LLEA) assets, Firefighting assets, medical support resources (including transportation), and coordination through an Incident Command Post. Requests for offsite resources and equipment will be communicated from the control room to Burke County 911 Center or through the Incident Command Post as applicable based on the nature of the event. Copies of these agreements are maintained in accordance with Emergency Plan procedures. E14-5 4 to NL-16-01 69 Vogtle (Units 3 & 4) Standard Emergency Plan Annex

      /'.../ Platt Site    /V    Ra-Jro<tds                                         N
      ~ ltte!S'lates
      / ' . / Highways Q
                           ,.r, Utbal'I keias L __I Cou'lties                                        A
      / ' . / Ma jOt Roads       MajOt W<ltt!IS                         0          10 20 30 Mies Figure 1.1.A - Location and Vicinity Map E14-6

Figure 1.1.B - VEGP Site Layout E14-7 4 to NL-16-0169 Vogtle (Units 3 & 4) Standard Emergency Plan Annex

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Vogtle Ele tric Generating Pl ant ,....,,....

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10 ~*file Radius o. --- "'::* Figure 1.2.A - 10 Mile Emergency Planning Zone (EPZ) E14-8 4 to NL-16-0169 Vogtle (Units 3 & 4) Standard Emergency Plan Annex A Figure 1.2.B - 50 Mile Ingestion Pathway IPZ E14-9 4 to NL-16-0169 Vogtle (Units 3 & 4) Standard Emergency Plan Annex Section 2: Organizational Control of Emergencies (SEP B.1) 2.1 Normal Plant Organization (SEP B.1) The normal plant operating crew is staffed and qualified to perform actions that may be necessary to initiate immediate protective actions and to implement the emergency plan and is designated as the responsible group for such actions. The normal plant organization is described in Section B.1 of the Emergency Plan. 2.2 Emergency Organization (SEP B.2, B.3) 2.2.1 The VEGP On-Shift Emergency Response Organization is described in Table 2.2.A. (SEP B.1) 2.2.2 The VEGP Augmented Emergency Response Organization is described in Figures B.2.1.A, B.2.2.A, B.3.1.A, and B.3.2.A in the Emergency Plan (SEP B.2, B.3) An On-Shift Staffing Analysis was completed in accordance with the requirements of 10 CFR 50 Appendix E IV.A.9. This analysis forms the basis for the on-shift staff as described in Table 2.2.A. A copy of the analysis is maintained in the SNC document management system. E14-10

Enclosure 14 to NL-16-0169 Vogtle (Units 3 & 4) Standard Emergency Plan Annex Table 2.2.A - Vogtle Electric Generating Plant On-Shift Staffing Vogtle 3 &4 Major Functional Area Major Tasks Position On-Shift On-Shift Shared Unit3 Unit4 Resources with Unit 1&2 Note 3 Emergency Direction and Shift Manager (SM)/ 1 1 1 Control Emerqencv Director (ED) Shift Supervisor (SRO) 1 1 1 i.o.e ~ Plant Operations and !Assessment of Operational Aspects Shift Support Supervisor 1 11 Fire Briaade (SRO/FBL' Licensed Operator (SRO 1 or RO) Reactor Operators (RO) 2 2 System Operators (SO) 2 2 System Operators I Fire 4 Briaade <SO/FBM) Plant System Engineering, !Technical Support Shift Technical Advisor Note 1 Repair and Corrective !Actions Notification/ Notify licensee, state local and Licensed Operator (SRO Note 3 Note 1 1 Communication Federal personnel & maintain or RO) communication , Radiological Accident Offsite Dose Assessment Chemistry Technician 1 !Assessment and Support of Operational Accident In-plant surveys RP Technician 1 !Assessment Offsite Surveys Onsite (out-of-plant) RP Technician 1 Protective Actions Radiation Protection: RP Technician

a. Access Control

b. RP Coverage for repair, 1

corrective actions, search and rescue first- aid & firefighting

c. Personnel monitoring

d. Dosimetrv Chemistry/Radio- chemistry Chemistry Technician 1 Plant System Engineering, Repair and Corrective Actions Maintenance Supervisor 1 Repair and Corrective

!Actions Mechanic 1 Electrician 1 I & C Technician 1 Total: 21 9 2 Firefighting Fire Brigade Note 5 Rescue Operations and Rescue Operations/First 2 First Aid lAid Note 1 Site Access and Security Security Plan Personnel Accountability Note 1 - May be provided by shift personnel assigned other functions Note 2 - Fire Brigade made up of Fire Brigade Leader (SSS) and 4 System Operators E14-11

Enclosure 14 to NL-16-0169 Vogtle (Units 3 & 4) Standard Emergency Plan Annex Note 3 - Vogtle Unit 1&2 resource may be used for events impacting multiple units E14-12 4 to NL-16-0169 Vogtle (Units 3 & 4) Standard Emergency Plan Annex 2.3 Non-SNC Support Groups (SEP B.4, B.5, B.6) 2.3.1 Fire Fighting (SEP B.6.4) VEGP has established an agreement with the Burke County Emergency Management Agency to provide, upon request, offsite fire support to the VEGP Units 3 and 4 Fire Brigade. Fire support provided includes, but is not limited to, firefighters and firefighting equipment. Request for fire support will be made by the control room or site security to the Burke County Emergency Management Agency, Burke County EOG, or the Incident Command Post, as applicable, based on the nature and timing of the event. A copy of this agreement is maintained in the SNC document management system. 2.3.2 Hospital and Medical Support (SEP B.6.3, K.1.3, L.1) Agreements are in place with the University .of Alabama at Birmingham (UAB) Hospital, Burke Medical Center, Doctors Hospital, and Burke County Emergency Management Agency to provide assistance for injured personnel, including cases involving radioactive contamination. This assistance will be requested whenever necessary in accordance with plant procedures. Medical Specialists, Inc., a group of medical professionals, has agreed to provide treatment services through Burke Medical Center and Doctors Hospital. 2.3.3 Ambulance Service (SEP B.6.2, L.4) VEGP has established agreements with the Burke County EMA to provide ambulance service for the transportation of injured personnel, including people who may be radioactively contaminated, to hospital facilities for treatment. Support provided includes, but is not limited to, Emergency medical services, ambulances, and emergency medical technicians Request for fire support will be made by the control room or site security to the Burke County Emergency Management Agency, Burke County EOC, or the Incident Command Post, as applicable, based on the nature and timing of the event. A copy of this agreement is maintained in accordance with Emergency Plan procedures. 2.3.4 Emergency Broadcasts (SEP E.2.5.1) VEGP has established agreements with media agencies to broadcast emergency messages and information to the public during an emergency event. The messages will be coordinated with local or state Emergency Management Agencies and are available on a 24 hour basis as members of the Emergency Alert System (EAS). 2.3.5 Voluntary Assistance Group (SEP B.4.2) VEGP a signatory to two comprehensive agreements among electric utility companies:

Nuclear Power Plant Emergency Response Voluntary Assistance Agreement.
Voluntary Assistance Agreement By and Among Electric Utilities Involved in Transportation of Nuclear Materials.

2.3.6 Information for Transients (SEP G.8) Several communications methods may be used to acquaint the public with plans for their protection during a Plant emergency. Effort will be concentrated upon providing information to the public by written material that is likely to be available in local residences and in locations frequented by transients. The information will also provide instructions as to what E14-13 4 to NL-16~0169 Vogtle (Units 3 & 4) Standard Emergency Plan Annex local media will be providing additional information in the event of an emergency. E14-14 4 to NL-16-0169 Vogtle (Units 3 & 4) Standard Emergency Plan Annex Section 3: Classification of Emergencies (SEP D.1) 3.1 Emergency Classifications: (SEP D.1) Emergencies are classified into four levels according to severity, taking into consideration potential, as well as actual, events in progress. They are, from the least to the most serious, Unusual Event, Alert, Site Area Emergency, and General Emergency. Initiating Conditions (ICs), which determine which level will be declared, are predetermined subsets of plant conditions where the potential exists for a radiological emergency, or such an emergency has occurred. Emergency Action Levels (EALs) are plant-specific indications, conditions, or instrument readings that are utilized to classify emergency conditions. 3.1.1 The described emergency classes and the emergency action levels that determine them are agreed on by SNC and state and local authorities. The emergency action levels will be reviewed by these (state and local) officials annually. 3.2 Determination of Levels: (SEP D.1.2) Appendix B to this Annex contains the matrix for Initiating Conditions used to determine an Emergency Action Level (EAL). They are part of the scheme established by NEI 07-01, Methodology for Development of Emergency Action Levels for Advanced Passive Light Water Reactors. 3.3 Operating Mode Applicability (SEP D.2. 7) The plant operating mode that existed at the time that the event occurred, prior to any protective system or operator action initiated .in response to the condition, is compared to the mode applicability of the EALs. If an event occurs, and a lower or higher plant operating mode is reached before the emergency classification level can be declared, the emergency classification level shall be based on the mode that existed at the time the event occurred. PWR Operating Modes at VEGP 3&4 Power Operations (1): Reactor Power> 5%, Kett;::: 0.99 Startup (2): Reactor Powers 5%, Kett;::: 0.99 Hot Standby (3): RCS > 420 °F, Kett< 0.99 Safe Shutdown (4): 420 °F;::: Tavg > 200 °F, Kett< 0.99 Cold Shutdown (5): RCS s 200 °F, Kett < 0.99 Refueling (6): One or more vessel head closure bolts less than fully tensioned Defueled (None): All reactor fuel removed from reactor pressure vessel. (Full core off load during refueling or extended outage) E14-15 4 to NL-16-0169 Vogtle (Units 3 & 4) Standard Emergency Plan Annex Section 4: Emergency Measures (SEP E) 4.1 Notification of Off-Site Agencies (SEP E.2.2) 4.1.1 Notification Process (SEP E.2.2.2) State and local warning points are staffed 24 hours per day. State and local counties surrounding VEGP are to be notified within 15 minutes of the declaration of an emergency condition are: State of Georgia:

Georgia Emergency Management Agency (GEMA)

Georgia County Authorities:

Burke - Burke County Emergency Management Agency State of South Carolina:
Emergency Management Division (EMO)

South Carolina County Authorities:

Barnwell and Aiken County - Sheriff's Department
Allendale County - County Central Dispatch Department of Energy - Savannah River Site (DOE-SRS)
DOE-SRS Operations Center 4.2 Alert and Notification System (ANS) (SEP E.2.5)

Within the 10 mile Exposure Emergency Planning Zone (EPZ), there exist provisions for alerting and providing notification to the public. The state and/or local authorities are responsible for activation of this system. Two totally independent public alerting systems are installed for use in the VEGP EPZ:

Network of fixed sirens and EAS,
NOAA (National Oceanic and Atmospheric Administration) weather warning radio system.

Offsite agencies will activate both independent systems in the event of a plant condition requiring public awareness. Following any public alert, commercial radio and television stations, as well as NOAA weather radio (NWR) will be used to provide notification and follow-up emergency information to the population within the EPZ. Responsibility for alerting and notifying the public lies with the appropriate offsite civil authorities; specifically, GEMA for anywhere within the State of Georgia; Burke County EMA for Burke County, Georgia; SCEMD for South Carolina; The County Division of Emergency Preparedness in Aiken County, South Carolina; the County Disaster Preparedness Agencies in Allendale and Barnwell Counties, South Carolina; and the SRS.

Physical activation of the sirens in Burke County will be done by the Burke County EMA in accordance with the Burke County SOP, and in coordination with GEMA. Physical activation of the siren in Barnwell County will be done by that county, in consultation with SCEMD.

Physical activation of the NWR system is by the NWS office in Columbia, SC for VEGP when requested to do so by GEMA. In general, SCEMD will rely upon GEMA to activate the NWR system, and to coordinate with Burke County on the activation of the EAS. E14-16 4 to NL-16-0169 Vogtle (Units 3 & 4) Standard Emergency Plan Annex The South Carolina Governor's Office or SCEMD will activate the South Carolina EAS after coordination with Georgia authorities. Provisions for transient population notification are also included in state and county plans.

The system maintenance requirements for the Tone Alert Radio System are contained in the FEMA approved System Design Report. Specifically, Vogtle maintains a database of those assigned tone alert radios and performs an annual telephone survey documenting the adequacy of distribution.

In the event of an emergency declaration at the VEGP, DOE-Savannah River Site has agreed to provide prompt notification of all persons on the SRS within VEGP's plume exposure pathway EPZ. The Alert and Notification System (ANS) description is provided in the FEMA approved Alert and Notification System Design Report located in the SNC document management system. 4.3 Protective Actions for Onsite Personnel (SEP J.4) Protective response for onsite personnel (including visitors and contractor personnel) includes alerting, assembly and accountability, site evacuation, monitoring, and decontamination. Protective actions may also be taken for onsite personnel for emergencies such as fires, security related events or natural disasters where personnel safety is threatened. 4.3.1 Alerting (SEP E.2.1, J.1) Section E of the Emergency Plan (EP), Notification Methods and Procedures, describes the methods to be used to alert onsite personnel of emergency conditions.

             '4.3.2   Assembly (SEP J.4.1)

Personnel assembly is mandatory at the Site Area Emergency or higher level classification. Upon aGtivation of the plant emergency alarm, plant personnel assigned specific emergency responsibilities proceed to their designated emergency response locations reporting to designated assembly areas. Assembly may be initiated at any time site management deems it appropriate for personnel safety reasons. Nonessential plant personnel located within the Protected Area will exit the protected area upon hearing the Site Area or the General Emergency alarm and report to designated areas. Visitors, contractors, and escorted personnel will leave the protected area during an Alert or higher declaration. 4.3.3 Security Events (SEP J.4) Onsite protection of employees during security events involves a combination of restricted movement, movement to safe locations and site evacuation depending on the nature of the event and advance warning. Specific actions to be taken during such events are included in site procedures. 4.3.4 Monitoring and Decontamination (SEP K) When an Alert is declared but no site evacuation is anticipated, personnel who have left the protected area are monitored by portal monitors. If necessary, decontamination is completed using the plant decontamination facilities located in the Control building or other onsite locations. E14-17 4 to NL-16-0169 Vogtle (Units 3 & 4) Standard Emergency Plan Annex When site evacuation with monitoring is expected and release of radioactivity has occurred, monitoring is performed by Burke County emergency workers at an established reception center. 4.4 Protective Actions for the Offsite Public (SEP J.5) The Emergency Director will recommend the necessary protective actions to offsite authorities based on predetermined protective actions for a General Emergency Classification or results of offsite dose assessment. Upon activation of the EOF, the EOF Manager will be responsible for recommending protective actions for the offsite population. Responsibility for carrying out the protective actions rests with offsite authorities. 4.4.1 Protective Action Recommendations (SEP J.5) A range of Protective Actions have been developed and agreed upon with state and local authorities. They may include the following:

Evacuation.
Shelter in place.
Monitor and prepare.
Thyroid blocking agent (consider the use of Kl (potassium iodide)) in accordance with state plans and policy.

E14-18 4 to NL-16-0169 Vogtle (Units 3 & 4) Standard Emergency Plan Annex Section 5: Emergency Facilities and Equipment (SEP H) 5.1 Emergency Response Facilities (SEP H.1, H.2) 5.1.1 Control Room (SEP H.1.1) A main control room is provided that is able to control the plant during normal and anticipated transients and design basis accidents. The main control room includes indications and controls capable of monitoring and controlling the plant safety systems as well as the non-safety related control systems. The safety related power sources and passive cooling system are designed to provide a habitable environment for the operating staff assuming that no ac power is available. Installed equipment provides for at least 3 days of operation. After 3 days, it is possible to continue operation with the control room cooled and ventilated with circulation of outside air. 5.1.2 Technical Support Center (SEP H.1.2) The TSC will be located in the lower level of the Communication Support Center (CSC) sited between the Unit 2 and 3 power blocks within the VEGP Site protected area as shown on Figure 1.1.B. The TSC will be designed to withstand plant design basis earthquakes and high winds. The layout of the proposed TSC is shown in Figure 5.1.A. The TSC will accommodate the required personnel to support events on multiple Units. Technical and operational data and information will be available for Units within the TSC. Support facilities will be located within the TSC to support long term operation of the TSC. The TSC will provide plant management and technical support personnel (including Nuclear Regulatory Commission (NRC) personnel) with a facility from which they can assist plant operating personnel located in the control rooms during an emergency. The Emergency Director and NRC will be co-located to ensure proper communications. The TSC will be equipped with a computer system, which provides source term and meteorological data and technical data displays to allow TSC personnel to perform detailed analysis and diagnosis of abnormal plant conditions, including assessment of any significant release of radioactivity to the environment. In addition, the TSC will have ready access to plant records. The TSC structure and ventilation system will be designed to ensure that the TSC personnel are protected from radiological hazards. The ventilation system will include high efficiency particulate air (HEPA) and charcoal filters. The ventilation system will be designed to maintain exposures to occupants at or below 5 rem total effective dose equivalent (TEDE) for the duration of the accident. The ventilation system will be operated in accordance with emergency plan implementing procedures (EPIPs) and will be manually controlled from the TSC. The ventilation system will operate in the pressurization and filtering mode upon detection of high radiation in the TSC ventilation intake. In addition, portable radiation monitors will be available for personnel in transit from the TSC to other areas. Portable air breathing apparatus and anti-contamination clothing will also be available for the TSC. The TSC will be powered by reliable and redundant power supplies. Lighting will be powered by the normal and redundant electrical supply system. An E14-19 4 to NL-16-0169 Vogtle (Units 3 & 4) Standard Emergency Plan Annex emergency battery operated lighting system will be installed. Power for vital information systems will be provided by redundant power supplies including a battery backed uninterruptible power supply system. The records storage is shared by the control room and the TSC. These records can be accessed via a digital records system. This system is supplied backup power via an uninterruptible power supply to allow retrieval of records in the event of a loss of power. These records include but are not limited to:

Technical Specifications.
Plant Operating Procedures.
Final Safety Analysis Report.
Emergency Plan.
Emergency Plan Implementing Procedures.
Plant operating records.
System piping and instrumentation diagrams and heating, ventilation, and air-conditioning (HVAC) flow diagrams.
Electrical one-line, elementary, and wiring diagrams.
Control logic and loop diagrams.

The above records are updated as necessary to ensure currency and completeness. 5.1.3 Operations Support Center (SEP H.1.3) The OSC is located in the Maintenance Support Building located between Unit 2 and Unit 3. The OSC is where operational support personnel (such as instrument technicians, engineers, mechanics, electricians, chemical/radiation technicians, equipment operators, and incoming Shift personnel) assemble to aid in the response to an emergency. The layout of the proposed OSC is in Figure 5.1.A. Emergency kits containing radiation monitoring equipment, first aid supplies, decontamination supplies, breathing apparatus, portable lighting, and hand-held radios are stored in the OSC. In the event that this facility becomes uninhabitable, the functions of the OSC will be conducted from Outage Control Center (OCC) located in the Annex Building if Unit 3 or Unit 4 is affected unit and from Clearance and Tagging (C&T) located in the control building if Unit 1 or Unit 2 is the affected unit. These designated back-up OSC spaces will have the same capability as the OSC. Evacuation of the OSC will be conducted according to emergency implementing procedures. These procedures will describe the method by which the OSC is evacuated and the movement of personnel to other facilities The OSC will accommodate the staff support and technical staff to support an event on multiple Units. The OSC has the communications capability to communicate with control rooms, the Technical Support Center (TSC) and the Emergency Operations Facility (EOF). Operations at this facility will be directed by the OSC Manager. 5.1.4 Alternative Facility (SEP H.1.4) During a security related event or other event that precludes onsite access, the TSC and OSC ERO staff will be directed to an alternative facility. This facility is E14-20 4 to NL-16-0169 Vogtle (Units 3 & 4) Standard Emergency Plan Annex located in the near site media center in Waynesboro, GA. The alternative facility is equipped with the necessary communications and data links to support communications with the control room, site security and the EOF. The available communications and data links also provide access to the SNC document management resources, work planning resources for performing engineering assessment activities including damage control team planning and preparation for return to the site. Guidance for use of the facility is contained in site procedures. 5.1.5 Emergency Operations Facility (SEP H.2.1) The EOF is the central location for management of the offsite emergency response, coordination of radiological assessment, and management of initial recovery operations. The EOF is a dedicated facility located in Birmingham, Alabama, and serves as the EOF for SNC sites (VEGP, FNP, and HNP). Additional details of the EOF are contained in section H.2.1 of the Emergency Plan. The near site location is maintained at the Vogtle Training Center space for members of an NRC Site Team. 5.1.6 Joint Information Center (JIC) (SEP H.2.2) The VEGP JIC is located in Waynesboro, Georgia adjacent to the Georgia Power Company operating headquarters. The JIC is the central location for the coordination and dissemination of information to news media and responses to public and media inquiries. Details of the JIC for VEGP are in section H of the Emergency Plan. If the decision is made to activate the JIC the CMC in Atlanta, Georgia will maintain emergency communications response coordination *until the JIC is ready to assume these responsibilities. E14-21 4 to NL-16-0169 Vogtle (Units 3 & 4) Standard Emergency Plan Annex Work Electronics Room Room Dose Assessment NRG Technical Support C enter

                                             ~
                                         ~ u u J udoor;:66 1

Minimum 3750 sq ft (shaded area ) Commun-Work ications Room Work Room Work S talus Room Room Room S upport A rea Access , Restrooms. Showers , Kitchen , Videoconference Minim um 3750 sq fl Figure 5.1.A - Sample Technical Support Center E14-22 4 to NL-16-0169 Vogtle (Units 3 & 4) Standard Emergency Plan Annex Operations Support Center RP Briefing Room Briefing Room Figure 5.1. B - Sample Operations Support Center 4 to NL-16-0169 Vogtle (Units 3 & 4) Standard Emergency Plan Annex 5.2 On-Site Communications (SEP F.1) Normal on-site communications is provided by the plant telephone system (network and commercial). The plant Public Address (PA) system may also be used for in-plant communications. The PA system is powered by normal plant power, backed up by uninterruptible power. Portable radios are used for communications between individuals and base stations located in the Control Room, TSC, OSC, EOF, and Security Building. There is also a plant intercom system. Intercom units are installed at selected plant locations primarily for specific task related activities. 5.3 Offsite Communications (SEP F.1) 5.3.1 Communications with States, Counties, and Savannah River (SEP F.1.2) The primary means of communication between VEPG, the states of Georgia and South Carolina as well as Burke, Aiken, Allendale and Barnwell Counties and the Savannah River Site is the Emergency Notification Network (ENN). The ENN is a dedicated communications system from the plant to the EOC at GEMA headquarters in Atlanta, Georgia the South Carolina Warning Point in the SEOC, the Burke County EOC, and Savannah River Operations Center. Extensions for this system are located in the Control Room, the TSC, and the EOF. 5.3.2 Alternate Offsite Communications (SEP F.1.1) Commercial telephones, or land lines provide backup for the ENN. 5.4 Communications System Testing (SEP F.3) Communication channels with the state of Georgia, the state of South Carolina, the Savannah River Site, the plume exposure pathway EPZ counties, and the NRC (with the exception of EROS) are tested each calendar month, using the extensions in the Control Room, the TSC, and the EOF. EROS is tested each calendar quarter. Communications procedures and systems are also tested each calendar year. 5.5 Emergency Kits (SEP H.9) Emergency supplies and equipment are located in the Control Room, the TSC, the OSC, the radiation protection control points, and other plant locations. Procedures require an inspection and operational check of equipment in these kits on a quarterly basis and after each use. Equipment in these kits is calibrated in accordance with procedures. A set of spares of certain equipment is also maintained to replace inoperative or out-of-calibration equipment. 5.6 Facilities and Equipment for On-site Monitoring (SEP H.5) The plant instrumentation and monitors perform indicating, recording, and protective functions. The Reactor Protection System and associated plant instrumentation provide the ability to maintain plant safety from shutdown to full power operations and to monitor and maintain key variables such as reactor power, flow, temperature, and radioactivity levels within predetermined safe limits at both steady state conditions and during plant transients. Plant instrumentation and control systems also provide means to cope with abnormal operating conditions. The control and display of information of these various systems are centralized in the unit Control Room. This instrumentation would provide the basis for initiation of protective actions. 5.6.1 Geophysical Phenomena Monitors (SEP H.5.1) E14-24 4 to NL-16-0169 Vogtle (Units 3 & 4) Standard Emergency Plan Annex Meteorological (SEP H.5.1) A meteorological monitoring program is in place at VEGP. Instruments are mounted on a 60-meter tower located to the south-southwest of the power block. Parameters measured and transmitted to the control room include:

Windspeed (10 m and 60 m).
Wind direction (10 m and 60 m).
Standard deviation of horizontal wind direction (10 m).
Vertical temperature difference (10 m and 60 m).
Ambient temperature (1 O m).
Dewpoint temperature (10 m).
Precipitation (base).

An equipment building that houses the recording, calibration, and amplification equipment is located near the base of the tower. The system is powered by an uninterruptible power supply consisting of wet cell batteries, charger, and inverter for high availability. Additionally, meteorological information can be obtained from the National Weather Service to supplement onsite data and provide a backup to the plant meteorological monitoring program on an as needed basis. The important parameters for characterizing the transport of airborne radioactivity are wind speed, wind direction, and atmospheric stability (derived from the standard deviation of the horizontal wind direction or vertical temperature difference). These meteorological parameters are used in a calculation methodology to assess the offsite radiological consequences of accidental releases of airborne radioactivity. Hydrologic (SEP H.5.1) The normal source of plant makeup water to the secondary plant for Units 3 and 4 is the Savannah River, which provides makeup to the circulating water system cooling towers. The probable maximum flood level has been determined to be about 140 ft mean sea level (MSL). However, since the access elevations to safety- related structures are at 220 ft MSL, high river level is not relevant to plant safety. The ultimate heat sink for VEGP Units 3 and 4 is the atmosphere. Because of these design features, hydrologic monitors will not be required for initiation of emergency actions; therefore, there will be no emergency levels based on hydrologic monitors. E14-25 4 to NL-16-0169 Vogtle (Units 3 & 4) Standard Emergency Plan Annex Seismic (SEP H.5.1) Seismic monitoring instrumentation for VEGP Units 3 and 4 will include triaxial acceleration sensors and a time-history analyzer. One of the four triaxial acceleration sensors will be located in the free field, a second sensor will be located on the nuclear island basemat, a third sensor will be located on the shield building structure, and a fourth sensor will be located on the containment internal structure. The triaxial acceleration sensors will provide a signal to the time-history analyzer located in a room near the control room. The time-history analyzer includes a dedicated computer for data storage, playback, and analysis. Activation of the time-history analyzer causes visual and audible annunciation in the control room to alert the plant operator that an earthquake has occurred. 5.7 Protective Facilities and Equipment (SEP J) Assembly Points (SEP J.4.1) In the event of a plant evacuation, the On-Site Assembly Areas (or Off-Site Assembly Areas, as appropriate) will be utilized. The function of the assembly area is to provide a center for personnel accountability and radiological contamination screening along with any other immediately necessary actions.

The assembly areas are located in various buildings throughout the site. Georgia Power Company facilities may be utilized as the off-site assembly area at the discretion of the Emergency Director. Its location will be announced over the public address system when announcement of evacuation is made.

Protective actions including relocation of onsite personnel in the event of an attack or threat of hostile action against the site have been developed for that specific situation. Specific protective actions in this ca~e are identified in site procedures not readily available to the public. *

5.8 Medical Support (SEP B, SEP L) 5.8.1 Hospital and Medical Support (SEP B.6.3, L.1)

Agreements are in place with the University of Alabama Birmingham (UAB) Hospital, Burke Medical Center, Doctors Hospital, and Burke County Emergency Management Agency to provide assistance for injured personnel, including cases involving radioactive contamination. This assistance will be requested whenever necessary in accordance with plant procedures. 5.8.2 Ambulance Service (SEP B.6.2, L.4) Injured/externally contaminated personnel who require medical attention will normally be transported by ambulance to the cooperating hospitals. Ambulance crews are trained to handle external contamination cases, and an RP technician may accompany, as requested, any contaminated patients to the hospital. Ambulance service is provided by the Burke County Emergency Management Agency. E14-26

Enclosure 14 to NL-16-0169 Vogtle (Units 3 & 4) Standard Emergency Plan Annex Appendix A- Evacuation Time Estimate Study and Map Reference (SEP J.6) In order to ensure the safety of the public living in the vicinity of nuclear power plants in the nation, the U.S. Nuclear Regulatory Commission (NRC) requires licensees to develop and update evacuation time estimates (ETEs) for areas within the emergency planning zone (EPZ). Population reviews will be conducted annually using the most recent US Census and local information. Updates are required following the availability of data from the decennial census (10 years) or when the sensitivity factor for changes in population within the EPZ has been exceeded. This appendix implements the requirements of 10 CFR 50, Appendix E, Sections IV.3 and IV.4 and in accordance with NUREG/CR-7002, Criteria for Development of Evacuation Time Estimate Studies. Southern Nuclear Operating Company (SNC) contracted IEM to estimate evacuation times for the 2012 populations within the 10-mile plume exposure pathway emergency planning zone (EPZ) surrounding VEGP. The report provided a breakdown of population by geographic areas and protective actions zones (PAZ). Four categories of population are identified in the report:

Permanent residents
Transient population
Transit dependent permanent residents
Schools '

The permanent resident population is made up of individuals residing in the 10-mile EPZ. The total year 2012 permanent resident populations within the 10-mile EPZ for VEGP Units 3 and 4 are estimated to be 3.080. The transient population consists of workers employed within the area, recreational sportsmen, and visitors. The total peak transient population within the 10-mile EPZ is estimated to be 2,915. Only one school, Lord's House of Praise Christian School, was identified in the VEGP Units 3 and 4 EPZ. The total peak population for the school in the EPZ is estimated to be 70. Transient dependent permanent residents in the EPZ are estimated to be 29. This study also considered shadow evacuees that reside within 10-15 miles from VEGP. IEM utilized a computer traffic simulation model, PTV Vision VISUM, to perform the ETE analyses. For the analyses, the 10-mile plume exposure pathway EPZ was divided into 19 unique geographic areas based on two-mile, five-mile, and ten-mile radius rings, the 16 22.5-degree PAZs, as well as keyhole and staged evacuation logic. In order to represent the most realistic emergency scenarios, evacuations for the 19 geographic evacuation areas were modeled individually for the midweek daytime, midweek - weekend evening, and weekend daytime scenarios. Each of these scenarios was then considered under both normal and adverse weather conditions using the 2012 population estimations. A total of 114 evacuation scenarios were considered as part of this study to represent different wind, temporal, seasonal and weather conditions. Both 100% and 90% ETEs for each scenario were collected. The 100% ETEs for the evacuation areas ranged from 2 hours 1O minutes to 3 hours 25 minutes for the normal scenarios, and from 2 hours 15 minutes to 3 hours 25 minutes for those occurring in adverse weather. The 90% ETEs for the evacuation areas ranged from 1 hour 20 minutes to 2 hours 20 minutes for the normal scenarios, and from 1 hour 20 minutes to 2 hours 25 minutes for.those occurring in adverse weather. The factors that contributed to the variations in ETEs between scenarios include differences in the number of evacuating vehicles, the capacity of the evacuation routes used, or the distance from the origin zones to the EPZ boundary. E14-27 4 to NL-16-0169 Vogtle (Units 3 & 4) Standard Emergency Plan Annex Based on the data gathered and the results of the evacuation simulations, the existing evacuation strategy was determined to be functional for the 2012 conditions, given the lack of severe congestion or very high ETEs. Recommendations were provided for enhancements to improve the evacuation time estimate. Assumptions utilized in the ETE will be reviewed when evaluating changes to roadways or evacuation networks to ensure the results of the ETE remain valid. Changes in population will be evaluated utilizing the sensitivity factor developed during the ETE analysis. The full Evacuation Time Estimate was submitted for NRC review in accordance with NRC regulations 10 CFR 50, Appendix E, Section IV.3. Following the NRC review, the results of the study and recommendations were reviewed with applicable offsite agencies. The review focused on the utilization of the results of the evacuation simulations provided in the ETE for comparison to existing protective action strategies. Modifications were incorporated as part of the ongoing emergency planning process. (

Reference:

Annual ETE Review document ETE-VEG P-002, ETE document ETE-VEGP-001). E14-28 4 to NL-16-0169 Vogtle (Units 3 & 4) Standard Emergency Plan Annex Appendix B - Emergency Action Level (EAL) Scheme (SEP D.1) 1-!0LP FOR -EA!- Sche~e E14-29

Enclosure 14 to NL-16-0169 Vogtle (Units 3 & 4) Standard Emergency Plan Annex Appendix C - Vogtle Electric Generating Plant 3&4 NUREG-0654 Cross Reference Table NUREG 0654 Rev 1 Ref Section

                                               . . SNC SEP. S~ctio.n: ..

ii ' /

                                                                                    ..   .. ..                   VEC?P ~&4
                                                                                                      * , *si:P Annex                            ..

Criteria llA~Assignrrieht of Responsibility* ..

                                                                      .                         ..     'l      ..

A.1.a A. 1, A.2, A.3, A.4 1.3, 1.4, 1.5, 1.6 A.1.b Introduction Section 1: Introduction A.1.c Figures B.2. 1.A, B.2.2.A, B.3.1 .A & -- B.3.2.A A.1.d B.3.1.1 -- A.1.e B.1 Table 2.2.A A.2.a . *f\.llA :-NIA A.2.b .. . .. NIA N/A A.3 A.5 1.7 A.4 B.2, B.2. 1. 15, B.3. 1.3 --

Criteria 11.e:::.onsite;EmergencY"Organization . .. .* :- *.

                                                                                                            *'    ..     ~I' B.1                                          B.2                                                      --

B.2 B.1.1 Table2.2.A B.3 B.1.2 -- B.4 B. 1. 1, Figure B.2.A -- B.5 Tables 1 - 4 Table 2.2.A B.6 B.2, B.3, Figures B.2. 1.A, B.2.2.A, -- B.3. 1.A & B.3.2.A B.7 Tables 1-4 -- Figures B.2. 1.A, B.2.2.A, B.3. 1.A & B.3.2.A B.7.a B.2.1.15, 8.3.1.3 -- 8.7.b 8.3.1.2, 8.3.1.17 -- 8.7.c B.3.1.1, 8.3.1.2 -- 8.7.d B.3.2.1, 8.3.2.2, B.3.2.8 -- 8.8 8.4, C.4.2 2.3 8.9 B.6, K.1 2.3 CriteriCI 11.c -_ Emt:frgencv R~sponse *support ~nd *Re~ources *

                                                                                       .          *7
                                                                                                                      ..            ~'  *,.  '

C.1.a Section C -- C.1.b A.1 1.6 C.1.c A.1.1, A.2, A.3, C.1-C.4, F.1 Section 1 C.2.a .. NIA :N_IA

C.2.b A.1.1, H.2.1 5.1.2 C.3 H.5.2.3, H.6.3 --

C.4 Sections A & C, B.4-8.6, H.6.3, L.1- 1.3-1.7, 2.3, 5.8 L.4 Crite~ia 11.e ~:Erriergehcvciassification System*

                                                                                               .. '*                                   .....           ~

D.1 Section D Appendix 8 D.2 *Section D Appendix 8 D.3 NIA 'NIA D.4 NIA NIA

criteria_ n:_E .: Notification Methods and Procedures .. .. ... . .. *.

E.1 E.1.1 Aooendix D E.2 E.2.1 -- E.3 E.2.2.2 -- E.4 E.2.2.2 -- E.4.a E.2.2.2 -- E.4.b E.2.2.2 -- E.4.c E.2.2.2 -- NOTE: NIA = Not required by Licensee in accordance with NUREG-0654 E14-30 4 to NL-16-0169 Vogtle (Units 3 & 4) Standard Emergency Plan Annex NUREG 0654 Rev 1 VEGP3&4 SNC SEP Section Ref Section SEP Annex Criteria 11.E - Notification Methods and Procedures (continued) E.4.d E.2.2.2 -- E.4.e E.2.2.2 -- E.4.f E.2.2.2 -- E.4.g E.2.2.2 -- E.4.h E.2.2.2 -- E.4.i E.2.2.2 -- E.4.j E.2.2.2 -- E.4.k E.2.2.2 -- E.4.1 E.2.2.2 -- E.4.m E.2.2.2 -- E.4.n E.2.2.2 -- E.5 N/A N/A E.6 E.2.5 -- E.7 E.2.6 -- Criteria 11.F - Emer~encv Communications F.1.a F.1.1, F.1.2 4.1.1 F.1.b F.1.3 -- F.1.c F.1.4 -- F.1.d F.1.5 -- F.1.e F.1.6 -- F.1.f F.1.4 -- F.2 F.2 -- F.3 F.3 5.4 Criteria.11.G - Public Education and Information G.1 G.1 -- G.2 G.8 2.3.6 G.3.a B.3.2.1, H.2.2, H.2.3 5.1.6 G.3.b N/A N/A G.4.a B.3.2.8 -- G.4.b G.2 -- G.4.c B.3.2.5, B.3.2.6 -- G.5 G.2 -- Criteria 11.H - Emergency Equipment and Facilities H.1 H.1.2 5.1.2 H.2 H.2.1 5.1.5 H.3 H.2.2, H.2.3 -- H.4 H.1 -- H.5 H.5 5.6 H.5.a H.5.1 5.6.1 H.5.b H.5.2 -- H.5.c H.5.3 -- H.5.d H.5.4 -- H.6.a H.5.1 5.6.1 H.6.b H.5.2 -- H.6.c H.5.2.3, H.6.3 -- H.7 H.6 -- H.8 H.7 5.6.1 H.9 H.1.3 5.1.3 H.10 H.8 -- H.11 H.9 -- H.12 H.10 -- NOTE: N/A = Not required by Licensee in accordance with NUREG-0654 E14-31 4 to NL-16-0169 Vogtle (Units 3 & 4) Standard Emergency Plan Annex NUREG 0654 Rev 1 VEGf.'.3&4 SNC SEP Section _Ref Section SEP Annex Criteria II.I - Accident Assessment 1.1 1.1 -- 1.2 1.2 -- 1.3.a 1.3 -- 1.3.b 1.3 -- 1.4 1.4 -- 1.5 1.5 -- 1.6 1.6 -- 1.7 1.7 -- 1.8 1.8 -- 1.9 1.9 -- 1.10 1.7 -- 1.11 _NIA NIA Criteria 11.J - Protective Response er* J.1.a J.1 -- J.1.b J.1 -- J.1.c J.1 -- J.1.d J.1 -- J.2 J.4.3 --

                  ~.3                                J.2                 --

J.4 J.3, J.4.3 -- J.5 J.4.2, 4.3.2 -- J.6.a J.4 -- J.6.b J.4 -- J.6.c J.4 -- J.7 J.5 -- J.8 J.6 Appendix A J.9 NIA NIA J.10.a J.7 -- J.10.b J.7 -- J.10.c E.2.5 4.2 J.10.d NIA NIA* J.10.e NIA NIA J.10.f NIA NIA J.10.g NIA NIA J.10.h NIA NIA J.10.i NIA NIA J.10.i NIA NIA J.10.k NIA NIA J.10.1 NIA NIA J.10.m J.5 -- J.11 NIA NIA J.12 NIA NIA Criteria 11.K - Radiologi~al Exposure Control . ' K.1.a K.1.1 -- K.1.b K.1 -- K.1.c K.1 -- K.1.d K.1.2.1 -- K.1.e K.1.2.1, K.5 -- K.1.f K.1.1.1 -- K.1.g K.1.3 -- K.2 K.1 -- NOTE: N/A =Not required by Licensee in accordance with NUREG-0654 E14-32 4 to NL-16-0169 Vogtle (Units 3 & 4) Standard Emergency Plan Annex NUREG 0654 Rev 1 VEGP 3&4 SNC SEP,Section-Ref Section SEP Annex Criteria 11.K - Radiological Exposure Control (continued) K.3.a K.3 -- K.3.b K.3 -- K.4 N/A N/A K.5.a K.5 -- K.5.b K.5 -- K.6.a K.6 -- K.6.b K.6 -- K.6.c K.6 -- K.7 K.7 -- Criteria U.L - Medical and Public Health Support L.1 L.1 -- L.2 L.2 -- L.3 NIA N/A L.4 L.4 -- Criteria 11.M - Recovery and Reentry Planning and Post-Accident Operations M.1 M.1 -- M.2 M.2 -- M.3 M.3 -- M.4 M.4 -- Criteria 11.N - Exercises and Drills .. N.1.a N.1 -- N.1.b N.1 -- N.2.a F.3 -- N.2.b N.2.3 -- N.2.c N.2.4 -- N.2.d N.2.5 -- N.2.e(1) N.2.6 -- N.2.e(2) N.2.6 -- N.3.a N.3 -- N.3.b N.3 -- N.3.c N.3 -- N.3.d N.3 -- N.3.e N.3 -- N.3.f N.3 -- N.4 N.4 -- N.5 N.5 -- Criteria 11.0 ... Radiological Erner ency Response Training 0.1 0.1 -- 0.1.a 0.1.1 -- 0.1.b 0.1.1 -- 0.2 0.3 -- 0.3 0.4 -- 0.4.a 0.4 -- 0.4.b 0.4 -- 0.4.c 0.4.3 -- 0.4.d 0.4.1, 0.4.4 -- 0.4.e 0.4.5 -- 0.4.f 0.4.6 -- 0.4.a 0.1.1 -- 0.4.h 0.1.1 -- 0.4.i 0.4 -- NOTE: N/A = Not required by Licensee in accordance with NUREG-0654 E14-33 4 to NL-16-0169 Vogtle (Units 3 & 4) Standard Emergency Plan Annex NUREG 0654 Rev 1 ,.

VEGP 3&4 :,

SNC SEP Section Ref Section " SEP Annex Criteria 11.0 -~Radiological Emerqencv.Response Training (continued) 0.4.j 0.4, 0.4.7 -- 0.5 0.4 -- Criteria 11.P - R~sponsibility for the Planning Effort: Dev~lopment, Periodic .Review and:, .. Distributi<m of Emergency* Plans *, ., ' ~ < P.1 0.5, Section P -- P.2 Section P -- P.3 P.1 -- P.4 P.1 -- P.5 P.3 -- P.6 P.3 -- P.7 -- Appendix D P.8 Table of Contents -- P.9 P.3 -- P.10 F.1.4 -- NOTE: N/A =Not required by Licensee in accordance with NUREG-0654 E14-34 4 to NL-16-0169 Vogtle (Units 3 & 4) Standard Emergency Plan Annex Appendix D - Supporting Plans & Implementing Procedures (SEP P.3) Supporting Plans

State of South Carolina Radiological Emergency Response Plan
State of Georgia Radiological Emergency Response Plan.
Burke County Georgia Emergency Response Plan
Aiken, Allendale, Barnwell County Emergency Response Plan
VEGP Security Plan
VEGP Fire Protection Plan Administrative and Emergency Plan Implementing Procedures (EPIP)

Plan Section Title* EPIP EPIP Title Section. ' A Assignment of Responsibility NMP-EP-300 SNC Emergency Preparedness (under Conduct of Operations development) 91801-C Coordination of Emergency Responses and Planning Between Southern Nuclear Operating Company-VEGP and US DOE-Savannah River Site B Emergency Response Organization NMP-EP-146 ERO Position Checklists 91101-C Emergency Response Organization c Emergency Response Support and NMP-EP-300 SNC Emergency Preparedness Resources (under Conduct of Operations development) 91703-C Emergency Support for Hatch Nuclear Plant D Emergency Classification System NMP-EP-141 Emergency Classification E Notification Methods and Procedures NMP-EP-142 Emergency Notification NMP-EP-308 SNC Emergency Alert Siren Operation, Testing And Maintenance 91706-C Alert Notification System F Emergency Communications NMP-EP-300 SNC Emergency Preparedness (under Conduct of Operations development) 91204-C Emergency Response Communications E14-35 4 to NL-16-0169 Vogtle (Units 3 & 4) Standard Emergency Plan Annex Plan Section Title EPIP EPIP Title; Section ' G Public Education and Information NMP-EP-203 Corporate Media Center Operations NMP-EP-204 Emergency News Center/Joint Information Center Operations NMP-EP-205 Emergency Communications News Releases NMP-EP-206 Emergency Communications News Briefings NMP-EP-207 Emergency Communications Public

Response

H Emergency Facilities and Equipment NMP-EP-143 Facility Activation NMP-EP-305 Equipment Important to the EP Function 91702-C Emergency Equipment and Supplies 91705-C Inventory and Testing of Emergency Preparedness Material/Equipment Which Are Not Part of the Emergency Kits I Accident Assessment NMP-EP-140 Accident Assessment 91302-C In Plant Sampling and Surveys 91303-C Field Sampling and Surveys J Protective Response NMP-EP-144 Protective Actions 91704-C Actions for Security During a Radiological Emergency K Radiological Exposure Control 91301-C Emergency Exposure Guidelines 91306-C Contamination Monitoring and Decontamination L Medical and Public Health Support NMP-EP-300 SNC Emergency Preparedness (under Conduct of Operations development) 91309-C Mass Casualty Triage M Recovery and Re-entry Planning and NMP-EP-145 Termination and Recovery Post Accident Operations 91308-C Re-Entry N Exercises and Drills NMP-EP-303 Drill and Exercise Standards 0 Radiological Emergency Response NMP-EP-301 EOF Emergency Response Training Organization And EP Staff Training 91601-C Emergency Preparedness Training E14-36 4 to NL-16-0169 Vogtle (Units 3 & 4) Standard Emergency Plan Annex Plan Section* Title EPIP EPIPTitle. Section *. ~ ,, p Responsibility for the Planning Effort NMP-EP-300 SNC Emergency Preparedness Conduct of Operations NMP-EP-310 Maintaining The Emergency Plan NMP-EP-312 Development Of Emergency Preparedness Technical Products NMP-TR-104- SEPTOC 006 91701-C Preparation and Control of Emergency Preparedness Documents E14-37 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 A .9 Federal Government EP A.1 Prim ary Federal Organizatio ns The commitment wording was The resources of the Federal agencies EP A .1.1 Nuclear Regulatory Commission (NRC) standardized and relocated to appropriate to the emergency condition would be The NRG is the coordinating agency for incidents at or the SNC Standard Emergency made available in accordance with the National caused by a facility or an activity that is licensed by the Plan . Response Plan (NRP). The Emergency Director NRG or an Agreemenl State, with the Chairman of the will be specifically authorized to request Federal Commission as the senior NRG authority for response. assistance on behalf of the Site under the The Chairman can transfer control of emergency provisions of the NRP. In addition to the NRG , response activities when deemed appropriate. other agencies which may become involved are ne ~IRG asls as IRe leaa leaeFal a§eAsy Fe§aFaiA§ the Department of Homeland Security (OHS) , the leGRAisal malleFs a~FiA§ a A~sleaF iRGiaeAt, wi!A !Re Department of Energy (DOE), the GRaiFmaA el !Re GemmissieR as !Re seAieF ~IRG a~IReFily Federal Emergency Management Agency IBF FespeRse aspesls . +Re GRaiFmaR saA !FaAsleF seRIFBI (FEMA) , the Environmental Protection Agency el emeF§eAsy FBspeAse asli"ilies "'ReR aeemea (EPA, theDepartment of Health and Human appFBpFiale . Services (HHS) , the Department of Incident Response Centers have been established at the Transportation (DOT) , and the Department of four NRG Regional Offices and NRG Headquarters , to Agriculture (USDA). centralize and coordinate NRC's emergency response. Provision is made for NRG personnel at the plant's Technical Support Center and the Emergency Operations Facility. EP A.1 .2 Department of Homeland Security (OHS) In accordance with the National Response Framework (NRF). OHS is responsible for the overall coordination of a multi-agency Federal response to a significant rad iological incident. I EP A .1.3 Federal Emergency Management Agency (FEMA) The primary role of FEMA is to support the states by coordinating the delivery of federal non-technical assistance. FEMA coordinates state requests for federal assistance, identifying which federal agency can best address specific needs. If deemed necessary, FEMA will establish a nearby Joint Field Office from which it will manage its assistance activities. ElS-20 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 A.10.1 Continuous Communication EP E.1 .1 SNC in cooperation with state, and county The commitment wording was CapabilityConsistent with the Emergency authorities, has established methods and procedures for standardized and relocated to Classification System described in Section D, the notification of offsite response organizations consistent the SNC Standard Emergency Emergency Director will initiate the activation of with the emergency classification and emergency action Plan . the emergency response organization by level scheme . These notifications include a mean s of contacting the states of Georgia and South verification or authentication . The methods used for Carolina , the counties within the plume exposure authentication are developed and mutually agreed to by pathway EPZ, the SRS , and the NRC . These the utility and off-site authorities. The primary notification organizations can be contacted on a twenty-four method will be by a dedicated communications system . seven basis. The state and local agencies have SNC operated plants maintain the capability of notifying continuously manned communication links for the state and local agencies within 15 minutes of a declared purpose of receiving notification of a radiological emergency as required per 10CFR50 Appendix E, section emergency. The SRS is a continuously operating IV(D)(3) . The methods and forms used for notifying state facility and can be contacted at all times. The and county authorities are site-specific, and detailed in Federal agencies which may be requested by the plant specific Emergency Plan Implementing Procedures VEGPSite to provide assistance can be notified (EPIPs). by contacting the NRC on a dedicated NRC will be notified by the impacted site~ communication link, the Emergency Notification System (ENS) line . l-lea~~"aFlers OpeFatieAs Offiser, immediately following state and local notifications, but within an hour of an I emergency classification . EP E.2.3 The NRC is notified via the ENS . If the ENS is inoperative, the required notification will be made using alternate means in accordance with regulatory requirements . EP F.1.2 State and county warning points are continuously staffed . A .10.2 State of Georgia and Burke County EP H.3 State and local Emergency Operations Centers The commitment wording was Operations (EOC) standardized and relocated to The State of Georgia and Burke County EOCs operated by the state and local communities allow the SNC Standard Emergency responses are conducted in accordance with the direction and control of emergency response functions . Plan . Georgia Radiological Emergency Response Plan The states' EOCs are capable of continuous (24-hour) and its associated Annex D. operations for a protracted period . The county EOCs serve as Command and Control headquarters for local emergency response activities as well as a center for the coord ination of communications to field units and to the state EOCs . Additional details for state and county EOCs are found in the state and county emergency plans. ElS-22 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vog t le 3&4 Emergency Plan Revised SNC Emergency Plan J ustificatio n Revis ion 3 B.2: If the event is classified as an Alert, the EP H.1: SNC operated nuclear power plants have The commitment wording was Technical Support Center (TSC} , Operations established a TSC and an on site OSC , which are staffed standardized and relocated to Support Center (OSC} , and Emergency and activated within 75 minutes of the declaration of an the SNC Standard Emergency Operations Facility (EOF} will be activated . Alert or higher classification . Plan . For these classifications , the emergency EP H.2.1: The EOF is procedurally required to be response organization will be structured as activated within 75 minutes following the declaration of an shown on Figure B-2 . The corporate resources Alert or higher classificationStalfiRg aRG aG1i11alieR el lhe and operation is presented in Appendix 7, eOI" is maRGalery "P9R GeGlaFatieR gf aR Alert QF higheF Emergency Operations Facility. Corporate Glassi~GalieR . personnel who report to the plant site will be integrated into the Site emergency response organization . B.2: For a Site Area Emergency or General EP H.1: SNC operated nuclear power plants have The commitment wording was Emergency, the emergency response established a TSC and an on site OSC , which are staffed standardized and relocated to organization will be fully activated . The and activated within 75 minutes of the declaration of an the SNC Standard Emergency organization will be as shown in Figure B-3 . Alert or higher classification . Plan . EP H.2.1 : The EOF is procedurally required to be activated within 75 minutes following the declaration of an It is SNC policy to fu lly activate Alert or higher ciassificationSlafliRg a Rs aGli* *alieR el IAe the ERO at Alert or Higher. i;:oi; is maR<Jalery "P9R <JeGlaFalieR el aR l'lert eF higheF slassi~salieR. ElS-28 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 B.2.1 Emergency response organization EP H.1: SNC operated nuclear power plants have The commitment wording was ResponsibilitiesFollowing an Alert or higher established a TSC and an on site OSC , which are staffed standardized and relocated to emergency declaration , the positions shown on and activated within 75 minutes of the declaration of an the SNC Standard Emergency Figures B-2 and B-3 will be fill ed by Site or SNC Alert or higher classification . Plan . personnel as discussed below. EP H.2.1: The EOF is procedurally required to be activated within 75 minutes following the declaration of an Alert or higher classification SlaffiRg aRe aGli .. alieR el IAe eGF' is maReale>y "P9R eeGlaFalieR el aR A left QF RigReF GlassifiGalieR . EP Figure B.2.B , B.2.C, B.2.0 , and B.2.E: illustrates th e standard Emergency Organization . B.2.1.1 Emergency Director EP 0 .1 : The ERO Training Program assures the training , The commitment wording was Plant personnel that may be designated as qualification , and requalification of individuals who may be standardized and relocated to Emergency Directors are listed in Table B-2 . called on for assistance during an emergency. Specific the SNC Standard Emergency They will receive training as specified in Table 0 - emergency response task training , prepared for response Plan. 2 prior to becoming qualified to fill this position . positions, is described in lesson plans and study guides . Their non-emergency positions will provide them The lesson plans , study guides, and written tests are The commitment for qualified plant knowledge and supervisory skills necessary contained in the ERO Training Program . Responsibilities responders was maintained in a to fill the Emergency Director position . for implementing the training program are contained in generic statement applicable to plant procedures. any position . El S-30 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vog tle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revisio n 3 8 .2.1.1 The Emergency Director may operate EP B. 1.1 In an emergency, the SM assumes the The commitment wording was from the control room or TSC at his discretion. responsibility of the Emergency Director (ED) and takes standardized and relocated to He may act as the TSC manager during the early necessary actions to identify and respond to the the SNC Standard Emergency phases of emergency response until the TSC is emergency until relieved by another qualified ED. The ED Plan . activated . It is the intent of SNC that the ED has the responsibility and authority to immediately and function will be transferred from the Control unilaterally initiate emergency actions, including providing Room as soon as practicable. notification of Protective Action (PAR) Recommendations to State and Local government organizations responsible for implementing off site emergency measures. The ED , at their discretion or when procedurally required , activates the ERO . The Emergency Directo~s non-delegable duties include: Event classification in accordance with the

                                                 . emergency classification system ;

Perform the duties and responsibilities of Protective

                                                 . Action Recommendation (PAR) determination ;

Notifications of offsite agencies and approval of

                                                 . state , local , and NRC notifications.

Authorization of emergency exposures in excess of

                                                 . federal limits.

Issuance of potassium iodide (Kl) to plant 8 .2.1.1 The primary and alternates for the

                                                 . employees as a thyroid blocking agent.

Request Federal assistance as needed . EP 0 .1: The ERO Training Program assures the training, The commitment wording was position of Emergency Director are shown on qualification, and requalification of individuals who may standardized and relocated to Table 8-2 . the SNC Standard Emergency be called on for assistance during an emergency. Training Plan . will be evaluated in accordance with the requirements of Systematic Approach to Training practices to ensure The normal site staffing positions effectiveness and in order to identify weak or deficient and individuals assigned are areas that need correction . subject to change based on Specific emergency response task training , prepared for normal plant reassignment. The response positions . is described in lesson plans and study Integrated Plan maintains a guides. The lesson plans, study guides , and written tests commitment to staff any ERO are contained in the ERO Training Program . position with qualified personnel. Responsibilities for implementing the training program are contained in plant procedures. ElS-34 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 8 .2.1.1: Initially this position (Emergency EP B.1 .1: The Shift Manager (SM) is in direct charge of The commitment wording was Director) will be filled by the shift manager or the shift plant operations and is directly responsible for the standardized and relocated to shift supervisor if the shift manager cannot be actions of the on-shift crew. In an emergency, the SM the SNC Standard Emergency located expeditiously. assumes the responsibility of the Emergency Director Plan . (ED) and takes necessary actions to identify and respond to the emergency until relieved by another qualified ED. EP B.1.2 Shift Supervisors , who hold Senior Reactor Operator (SRO) licenses, supervise operation of the unit and may assume the duties of the ED in the absence of the Shift Manager. 8 .2.1.1: The responsibility for emergency EP B.1.1 In an emergency, the SM assumes the The commitment wording was direction will be transferred to the plant manager responsibility of the Emergency Director (ED) and takes standardized and relocated to or an alternate after receiving an appropriate necessary actions to identify and respond to the the SNC Standard Emergency briefing and becoming familiar with the current emergency until relieved by another qualified ED. The ED Plan . status of events. has the responsibility and authority to immediately and unilaterally initiate emergency actions, including providing notification of Protective Action (PAR) Recommendations to State and Local government organizations responsible for implementing off site emergency measures. The ED , at their discretion or when procedurally required , activa tes the ERO . ElS-35 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Table B-1: All EP B.1 SNC plants maintain 24-hour emergency The commitment wording was response capability. The normal on-shift complement standardized and relocated to provides the initial response to an emergency. This group the SNC Standard Emergency is trained to respond to emergency situations until the Plan . augmented Emergency Response Organization (ERO) arrives. Table B-2: All EP Figure B.2 .B The commitment wording was standardized and relocated to the SNC Standard Emergency Plan . ERO Augmentation response is justified separately in the Technical Evaluation section of the License Amendment Request. B: Figure B-1 EP Figure P.1 The commitment wording was standardized and relocated to the SNC Standard Emergency Plan . Section C Emergency Response Support and Rescue C.1 : The State of Georgia through the Office of EP A.2.2.1: As the overall state coordinating agency The commitment wording was Homeland Security - Georgia Emergency GEMA will coordinate with DNR-EPD on emergency standardized and relocated to Management Agency (OHS-GEMA) has the lead response activities with state, county and municipal the SNC Standard Emergency agency responsibility for responding to agencies and departments as stated in the Georgia Plan . emergency situations throughout Georgia . Emergency Operations Plan (GEOP) . GEMA provides for 24-hour notification and staffing of the State Operations Center (SOC) and/or the Forward Emergency Operations Center (FEOC), as required , throughout the event. GEMA is responsible for general State emergency planning and overall direction and control of emergency or disaster operations as assigned by Executive Order and in accordance with the Georgia Emergency Operations Plan (GEOP). GEMA has responsibilities for coordinating the State of Georgia response to emergencies at nuclear power plants. ElS-43 5 to NL-16-0169 Vogtl e (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 C.3: Emergency notification system (ENS) EP F.1.4 SNC has established communications systems Th e commitment wording was telephones and commercial telephones will be to provide reliable communications with Federal standardized and relocated to available in the control roo m, TSC , and EOF . emergency response organizations. Communications the SNC Standard Emergency with Federa l agencies is primarily by commercial Plan . telephon e, with alternate systems being used as needed . Communication with the Nuclear Regulatory Commission The current operation of the FTS (NRG) is via the Federal TelepRoAe Telecommunications system allows any phone with System (FTS) telephone network which connects the SNC long distance capability to call plant site and EOF with the NRG Operations Cen ter. Site into the Headquarters extensions are located in the Control Room , TSC , and Operations Center and be Site NRG Resident Inspector's Office. Site extensions patched into any bridge . The include ENS, HPN , ERDS , and other designated specific listing becomes counterpart links connecting to the NRG Operations redundant to the expanded Center. capability. EP F.1.4.1 NRC Emergency Notification System (ENS) This communications line provides a communications link to the NRG Operations Center in Rockville , MD and is used for continuous communications in a ciassified emergency. C.3: Health physics network (HPN) telephones EP F.1.4.2 NRC Health Physics Network (HPN) The commitment wording was are available in the TSC and the EOF . This communications line provides a communications link standardized and relocated to with the NRG to provide radiological information . the SNC Standard Emergency Plan . The current operation of the FTS system allows any phone with long distance capability to call into the Headquarters Operations Center and be patched into any bridge . The specific listing becomes redundant to the expanded capability. C.3: In the EOF , space is provided for nine NRG EP H.2.1: The EOF is capable of accommodating The commitment wording was personnel and one FEMA representative . designated SNC personnel and offsite Local , State and standardized and relocated to Federal responders including NRG and FEMA. the SNC Standard Emergency Plan . ElS-47 5 to NL-16-0169 Voglle (Units 3 & 4) Justification Matrix Cu rren t Vogtle 3&4 Emergency Plan Revised SNC Emerg enc y Plan Justification Revision 3 C.4: The onsite laboratory will be equipped to EP H.5.2.3: SNC sites have a laboratory facility for The commitment wording was analyze all normal in-plant samples. The analysis of radioactive samples . standardized and relocated to equipment will include an ion chromatograph , EP C.3: The onsite laboratory/counting room at SNC the SNC Standard Emergency gas chromatograph , gamma spectrometer, and operated nudear power plants are the primary facility for Plan. other analytical support equipment. radiation monitoring and analysis effort. The onsite laboratory is the central point for receipt and analysis of onsite samples and includes equipment for chemical and radiological analyses. The plant laboratories have the capability of quantitative analysis of marine and air samples , and qualitative analysis of terrestrial samples. C.4: The samples will be scanned with field EP H.10: SNC operated nuclear power plants have The commitment wording was instrumentation and will then be taken to the Site designated a point as the location for receipt and analysis standard ized and relocated to for laboratory analyses . of fiel d monitoring team environmental samples. the SNC Standard Emergency Sampling and analysis equipment is available for Plan . quantitative activity determination of marine and air samples , and qualitative acti vity determination of terrestrial samples. Table C-1 NA Location of EOCs is a function of the offsite Emergency Plans and not included in the Fleet Plan Sect io n D Emergency Class ific ation System D.1: All the actions associated with the EP D.2.5: The SNC policy is that once an emergency The commitment wording has emergency classification level must be classification is made, it cannot be downgraded to a lower been standardized and relocated completed and then a termination of the event classification . Termination criteria contained in the to the SNC Standard Emergency can be affected . Emergency Plan Implementing Procedures shall be Plan. completed for an event to be terminated. When the site determines that transition to termination or recovery is appropriate, the information will be transmitted to respective offsite agencies. D.1: Once an emergency classification is made, it EP D.2.5: The SNC policy is that once an emergency The commitmen t wording has cannot be downgraded to a lower classification . classification is made, it cannot be downgraded to a lower been standardized and relocated classification . to the SNC Standard Emergency Plan . ElS-49

Enclosure 15 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan J ustification Revision 3 D.1: The described emergency classes, and the Annex 3.1.1: The described emergency classes and the The commitment wording was emergency action levels which determine them, emergency action levels which determine them are standardized and relocated to are agreed on by SNC , and State and local agreed on by SNC and State and local authorities. The the SNC Standard Emergency authorities. The emergency action levels will be emergency action levels will be reviewed by these (state Plan . reviewed by these officials annually. and local) officials annually. D.1.1.2: VEGP ACTIONS (NUE) Inform State and local offsite authorities of the nature of the unusual event within 15 EP E.1.1: SNC operated plants maintain the capability of notifying state and local agencies within 15 minutes of a declared emergency as required per 10CFR50 Appendix The commitment wording was standardized and relocated to the SNC Standard Emergency minutes of classifying the emergency. Notify E, section IV(D)(3) . NRC will be notified by the impacted Plan.The SNC Standard the Nuclear Regulatory Commission (NRC) as soon as possible (ASAP), but no later site. "ia Ille Flea~~*aFleFs OpeFalieAs OffiGeF, immediately following state and local notifications , but within an hour of Emergency Plan incorporates the actions needed for each I than 1 hour following classification of the an emergency classification using the ENS system . individual Classification Level I emergency. into general responsibilities Augment on-shift resources, as needed . section .The wording has been . Assess and respond to the event. Escalate to a more severe class, if appropriate, or close out with a verbal standardized and relocated into the position descriptions for the ERO members and various summary to offsite authorities followed by a sections of the SNC Standard written summary within 24 hours. Emergency Plan and Site Ann ex (on-shift or augmented that maintain those functions . ElS-50

Enclosure 15 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergenc y Plan Revised SNC Emergency Plan Justification Revision 3 .D.1.2.2: VEGP ACTIONS (Alert) Within 15 minutes of classification , inform State and local offsite authori ties of Alert EP B .1 .1 The ED , at their discretion or when procedurally required , activates the ERO . EP B .2 Augmentation of on-shift staffing will occur within The commitment wording was standardized and relocated to the SNC Standard Emergency Emergency and reasons for emergency. 75 minutes of event classification by the Emergency Plan .The SNC Standard Notify the NRC ASAP, but no later than 1 Response Organization (ERO). ERO positions for the Emergency Plan incorporates hour following classification of the TSC , Operations Support Center (OSC), Emergency the actions needed for each

. emergency.

Augment resources and activate the emergency response facilities (e .g., Operations Facility (EOF) , and JIC are detailed below. EP E.1.1: SNC operated plants maintain the capability of notifying state and local agencies within 15 minutes of a individual Classification Level into general responsibilities section .The wording has been Technical Support Center (TSC), Operational declared emergency as required per 10CFR50 Appendix standardized and relocated into Support Center (OSC) and the Emergency E, section IV(D)(3) . NRC will be notified by the impacted the position descriptions for the Operations Facility [EOF]). These actions site, via tRe Heae~"arteFS OpeFatieAs OlliseF, immediately ERO members and various may be delayed for security based events at following state and local notifications , but within an hour of sections of the SNC Standard the discretion of the emergency director. an emergency classification . Emergency Plan and Site Annex Assess and respond to the emergency . (on-shift or augmented that Mobilize, and dispatch if necessary, on site maintain those functions . . survey teams . Provide periodic plant status updates to . offsite authorities. Provide periodic meteorological assessments to offsite authorities and , if any emergency releases are occurring , field monitoring team readings or dose estimates for actual . releases. Activate the Emergency Response Data System for the affected unit within 1 hour

. following declaration of the Alert.

Escalate to a more severe class, if appropriate, or close out the emergency class by verbal summary to offsite authorities followed by written summary within 8 hours of closeout. ElS-51 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergenc y Plan Revised SNC Emergency Plan Justif ica tion Revis ion 3 D.1.3.2: VEGP ACTIONS (SAE ) Within 15 minutes of classificat ion, inform State and local offsite authorrties of Srte EP B.1.1 The ED. at their discretion or when procedurally required , activates the ERO . EP B.2 Aug mentation of on-shift staffing will occur within The commitment wording was standardized and relocated to the SNC Standard Emergency AreaEmergency and reasons for emergency. 75 minutes of event classification by the Emergency Plan.The SNC Standard Notify the NRC ASAP, but no later than 1 hour Response Organization (ERO). ERO positions for the Emergency Plan incorporates

 . following classification of the emergency.

If necessary, provide protective action recommendations to State and local TSC , Operations Support Center (OSC), Emergency Operations Facility (EOF), and JIC are detailed below . EP E.1.1: SNC operated plants maintain the capability of the actions needed for each individual Classification Level into general responsibilities

 . authorities.

Augment resources and activate the emergency response facilities (e.g., Technical notifying state and local agencies within 15 minutes of a declared emergency as required per 1 OCFR50 Appendix section .The wording has been standardized and relocated into E, section IV(D)(3). NRC will be notified by the impacted the position descriptions for the Support Center (TSC), Operational Support Center (OSC), and the Emergency Operating site, **ia t~e '"ea~~~aFleFs GpeFatieAs GfliGeF, immediately following state and local notifications , but within an hour of ERO members and various sections of the SNC Standard I Facility [EOF]). These actions may be delayed an emergency classification . Emergency Plan and Site Annex for security based events at the discretion of

.. the emergency director.

Assess and respond to the emergency . Dispatch, as necessary, onsite and offsite (on-shift or augmented that maintain those functions .

 . survey teams.

Dedicate individuals for plant status updates to

 . offsite authorities and periodic press briefings.

On a periodic basis, make senior technical and management staff available for

 . consultation with the NRC and State officials.

Provide meteorological information and dose estimates to offsrte authorities for actual

 . releases via a dedicated individual.

Provide release and dose projections based on available plant condition information and

 . foreseeable contingencies.

Activate the Emergency Response Data System for the affected unit within 1 hour following declaration of the Site Area . Emergency

    .Escalate to General Emergency, if appropriate, or close out the emergency class by briefing of offsite authorities followed by written summary within 8 hours of closeout.

ElS-52

Enclosure 15 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Pla n Revised SNC Emergency Plan Justification Revision 3 D.1.4.2: VEGP ACTIONS (GE) Within 15 minutes of classification , inform State and local offsite authorities of the EP B.1.1 The ED, at their discretion or when procedurally required , activates the ERO . EP B.2 Augmentation of on-shift staffing will occur within The commitment wording was standardized and relocated to the SNC Standard Emergency General Emergency and reason for 75 minutes of event classification by the Emergency Plan .The SNC Standard emergency. Notify the NRC ASAP, but no Response Organization (ERO). ERO positions for the Emergency Plan incorporates later than 1 hour following classification of TSC , Operations Support Center (OSC) , Emergency the actions needed for each

. the emergency.

Provide protective action recommendations to State and local authorities based upon Operations Facility (EOF), and JIC are detailed below. EP E.1.1: SNC operated plants maintain the capability of notifying state and local agencies within 15 minutes of a individual Classification Level into general responsibilities section .The wording has been plant conditions and/or actual or projected declared emergency as required per 10CFR50 Appendix standardized and relocated into

. releases of radioactive material .

Augment resources and activate the emergency response facilities (e.g., E, section IV(D)(3) . NRC will be notified by the impacted site, via ti'le (.;eaa~"arters O~eratiaAs Offiser, immediately following state and local notifications , but within an hour of the position descriptions for the ERO members and various sections of the SNC Standard I Technical Support Center (TSC) , Operational an emergency classification . Emergency Plan and Site Annex Support Center (OSC), and the Emergency (on-shift or augmented that Operating Facility [EOF]). These actions may maintain those functions . be delayed for security based events at the .. discretion of the emergency director. Assess and respond to the emergency . . Dispatch onsite and offsite survey teams . Dedicate an individual for plant status updates to offsite authorities and periodic

. press briefings .

On a periodic basis, make senior technical and management staff available for

. consultation with the NRC and State officials.

Provide meteorological data and field monitoring team readings or dose estimates . to offsite authorities for actual releases. Provide release and dose projections based on plant condition and foreseeable . contingencies . Activate the Emergency Response Data System for the affected unit within 1 hour following declaration of the General Emergency. Close out the emergency class by briefing of offsite authorities followed by written summary within 8 hours of closeout. ElS-53 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revis ion 3 E.1: Notification of the corporate staff is EP E.2.1 Emergency Response personnel respond to The commitment wording was performed in accordance with EIPs . their assigned Emergency Response Facilities upon standardized and relocated to notification of an Alert or higher classification level. the SNC Standard Emergency Plan E.1 : The notification procedure includes EP E.2.1 Notification procedures include notification of The commitment wording was notification of Emergency Response Emergency Response Organization Personnel (ERO) not standardized and relocated to Organization Personnel (ERO) not on site. on site or during backshift hours. ERO members will be the SNC Standard Emergency notified by means of an automated callout system Plan . activated by on-shift personnel. E.1: ERO members will be notified by means of EP E.2.1 Notification procedures include notification of The commitment wording was an autodialer system activated by on-shift Emergency Response Organization Personnel (ERO) not standardized and relocated to personnel. on site or during backshift hours . ERO members will be the SNC Standard Emergency notified by means of an automated callout system Plan. activated by on-shift personnel. E.1: In addition to those personnel recalled ; EP B.3.1.3 EOF Support Coordinator The commitment wording was Operations, Maintenance, and Security The Support Coordinator reports to the EOF Manager. standardized and relocated to personnel required to report shall be contacted The duties and responsibilities of the Support Coordinator the SNC Standard Emergency by on-shift personnel from their own respective in the EOF include providing oversight of the News Writer, Plan. department. providing assistance to the Support Coordinator in the TSC for ordering equipment and materials needed and logistics arrangements for support personnel called in to assist in the emergency, including communications hardware, transportation , food , and lodging . E.2: A dedicated telephone system , known as the EP E.2.2: A dedicated ENN will normally be used to The commitment wording was Emergency Notification Network (ENN), will accomplish State and local notifications. standardized and relocated to normally be used to accomplish these the SNC Standard Emergency notifications.. Plan. E.2: Figure E-1 presents the sample initial EP E.2.2.2: In conjunction with state and county The commitment wording was message form for making notifications to these authorities, SNC operated plants have established the standardized and relocated to response centers. This form has been developed contents of the initial aAd s"bseq"eAI state notification the SNC Standard Emergency I in conjunction with appropriate oftsite agencies. message forms to be used during an emergency. These Plan . forms are described in site specific EPIPs. ElS-57 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vog tle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revisio n 3 E.2: The Emergency Director is responsible for EP E.2 .2.1: State and local agencies listed in the site The commitment wording was the completion of the Initial Message Form specific Annexes shall be notified within fifteen (15) standardized and relocated to (Figure E-1) and for the notification of the minutes EP E.2.2.2: In conjunction with state and county the SNC Standard Emergency following agencies within 15 minutes of the authorities , SNC operated plants have established the Plan and Site Annex. declaration of anemergency:Georgia Emergency contents of the initial aRd ""bseq"eRt state notification I Management Agency Emergency Operations message forms to be used during an emergency. These Center (EOC) com municatorBurke County forms are described in site specific EPIPs. Emergency Operations Center (EOC) A nnex 4.1.1 : Notificatio n Process (SEP E.2.2) communicatorSouth Carolina warning poin!Aiken State and local warn ing points are staffed 24 hours per County sheriff dispatcherBamwell County sheriff day. State and local counties surrounding VEGP are to dispatcherAllendale County central be notified within 15 minutes of the declaration of an dispatch Department of Energy-Savannah River emergency condition are: (DOE-SR) Operations Center communicator State of Georgia : Georgia Emergency Management Agency (GEMA) Georgia Countv Authorities: Burke County Emergency Management Agency State of South Carolina : Emergency Management Division (E MD) South Carolina Count~ Authorities: Barnwell and Aiken County - Sheriffs Department Allendale County - County Central Dispatch De~artment of Energ~ - Savannah River ~ite {DOE-SRSl DOE-SRS Operations Center ElS-58 5 to NL-1!>-0169 Vogtle (Units 3 & 4) Justification Matrix Cu rrent Vogtle 3&4 Emerg ency Plan Revised SNC Emergency Plan Justificatio n Revisio n 3 E.3: The Emergency Director is responsible for EP E.1.1: NRC will be notified by the impacted site;-llia The commitment wording was ordering notification calls to the DOE-SR l ~e Meadq~aFleFB GperatieR& GfliGer, immediately standardized and relocated to Operations Center by ENN and to the NRC following state and local notifications , but within an hour of the SNC Standard Emergency Operations Center by the Emergency Notification an emergency dassification . Plan. System (ENS) , or commercial telephone as EP E.2.2: A dedicated (ENN) will normally be used to backup , within prescribed time constraints from accomplish State and local notifications. Backup means the dedaration of an emergency of communication are described in Section F, Emergency Communication, of this plan . EP E.2.2.1: State and local agencies listed in the site specific Annexes shall be notified within fifteen (15) minules of: The initial emergency classification .

                                                      . Classification change .

The issuance of, or change to, a Protective Action Recommendation (PAR) . EP E.2.3: The NRC is notified via the ENS . ElS-59 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3& 4 Emergenc y Plan Revised SNC Emergency Plan Justification Revisio n 3 E.3: The emergency director is responsible for EP E.1.1: NRC will be notified by the impacted site;-Yia The commitment wording was ordering notification calls to the DOE-SR tl1e ~ead~"aFlers OperatieRs OfliGer. immediately standardized and relocated to Operations Center by ENN and to the NRC following state and local notifications, but within an hour of the SNC Standard Emergency Operations Center by the Emergency Notification an emergency dassification . Plan and Site Annex. System (ENS}. EP E.2.3: The NRC is notified via the ENS . Annex Section 4.1.1: Notification Process (S EP E.2.2) State and local warning points are staffed 24 hours per day. State and local counties surrounding VEGP are to be notified within 15 minutes of the declaration of an emergency condition are: State of Georgia: Georgia Emergency Management Agency (GEMA} Georgia County Authorities : Burke County Emergency Management Agency State of South Carolina : Emergency Management Division (EMD} South Carolina Coun!Y Authorities: Barnwell and Aiken County - Sheriffs Department Allendale County - County Central Dispatch De~artment of Energy- Savannah River Site (DOE-SR§) DOE-SRS Operations Center Ann ex 5.3.3 Communications with the Savannah River Site (SEP F.1 .2) The primary means of communication between VEGP and the Savannah River Site (SRS} is the ENN . SRS has two ENN drops, both located in their Operations Center. The ENN system is available and staffed 24 hours per day. Commercial telephones provide a backup for the ENN. E.4 . Administrative and physical means have EP E.2.5: Prompt alerting and notification of the public The commitment wording was been established for providing early initial within the plume exposure pathway EPZ is the obligation standardized and relocated to warning and subsequent clear instructions to the of State and local government or other responsible the SNC Standard Emergency populace within the plume exposure pathway authority. The responsib ility that means exist for this Plan . emergency planning zone (EPZ). purpose rests with Southern Nuclear Operating Company. ElS-60 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Cu rren t Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revis ion 3 E.4: It is the responsibility of SNC to provide EP E.2.5: Prompt alerting and notification of the public The commitment wording was adequate means for notifying the public, or to be within the plume exposure pathway EPZ is the obligation standardized and relocated to assured that such means are provided . of State and local government or other responsi ble the SNC Standard Emergency authority. The responsibility that means exi st for this Plan and Site Ann ex. purpose rests with Southern Nuclear Operating Company. Annex 4.2: Within the 10 mile Exposure Emergency Planning Zone (EPZ) ; there exist provisions for alerting and providing notification to the public. The state and /or local authorities are responsible for activation of this system . Two totally independent public alerting systems are installed for use in the VEGP EPZ: Network of fixed sirens and EAS . NOAA (National Oceanic and Atmospheric Administration) weather warning radio system witRiR the Pl*FRe E*pes*re EFRef9eRsy PlaAAiAg ZeAe (EPZ) . there el<ist preuisieAs fer alertiAg aA9 pre"i9iRg Ae@satieR le the p*blis. TRe state aAd 'Gr lesal a*IRerilies are respeAsible fer astiuatieA ef this systeFR . TRe llegUe ElestFis GeAeratiAg PlaAl ("EGP) Ras eeuelepee a P*blis *1ert aA9 ~letiHGatieR systeFR 9esigAe9 fer se**erage ef lRe pep*latieA wilRiA tRe EPZ. TRis is asseFRplisRe9 wtiliziAg a GeFRlliAatieA ef HKe9 sireAS aRd teAe alert raeies . SireR& iAstallee by VEGP Ra"e lleeA sitee asser9iAg le l"E,4 6 ~EP 1Q sFiteFieA le eAs*re IRe req*ired seuerage. PreuisieA& fer lraA&ieAl pep*lalieA A<ltiHGatieA are alse iR*l*9e9 iA State aA9 GewAly plaAs . ElS-61 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergenc y Plan Just ifica tion Revision 3 E.4: The alert notification system, except for the EP E.2.5.2: Capability for both an alerting signal and an The commitment wording was Savannah River Site (SRS), is described in informational or instructional message to the population standardized and relocated to Appendix 3. This system has the capability to on an area-wide basis throughout the plume exposure the SNC Standard Emergency complete the initial alert notification of residents pathway EPZ, within 15 minutes. Plan and Site Annex. within the plume EPZ in about 15 minutes. Annex 4.2 : Within the 10 mile Exposure Emergency Planning Zone (EPZ), there exist provisions for alerting and providing notification to the public The state and/or local authorities are responsible for activation of this system . Two totally independent public alerting systems are installed for use in the VEGP EPZ: Network of fixed sirens and EAS, NOAA (National Oceanic and Atmospheric Administration) weather warning radio system . will!iR 1~8 Pl~"'8 e*~9S~F8 '""'8Fij8R6Y PlaRRiRg Z9R8 (ePZ), 11!8F8 el<ist ~F9"iSi9RS feF aleFliRg aR~ ~F9"i~iRg Reli~GaljeR te Ille ~~bliG . E.4 : The Site will provide offsite authorities with EP E.2.5.1 : In the event of a serious emergency at any The commitment wording was supporting information for their messages to the SNC site , the primary means for alerting the public will be standardized and relocated to public. Such messages , consistent with the by the FEMA approved Alert and Notification System the SNC Standard Emergency emergency classification scheme , will provide the (ANS) referenced in the site specific Annex. Plan . public with instructions in regard to specific protective actions to be taken by occupants of affected areas. E.5 : The Emergency Director is responsible for EP E.2.2.3 Follow -up Emergency Message The commitment wording was the completion of a follow-up emergency Jn conjunction with sta_IE! and county authorities, SNC- standardized and relocated to { Formatted: Font: (Default} Arial, 10 pt message operated plants have established the contents of the the- SNC Standard Emergency subsequent state notification message forms to be used during an emergency. The Emergency Director is responsible for the completion of a follow-up emergency Plan . I message. ElS-62 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 E: Actual methods and sequencing of EP E.1 .1: SNC operated plants maintain the capability of The commitment wording has notifications will be covered in appropriate notifying state and local agencies within 15 minutes of a been standardized and relocated implementation procedures. declared emergency as required per 10CFR50 Appendix to the SNC Standard Emergency E, section IV(D)(3). The methods and forms used for Plan . notifying state and county authorities are site-specific, and detailed in plant specific Emergency Plan Implementing Procedures (EPIPs) . NRC will be notified by the impacted site , *'8 the f<ead~~aFteF& OperalieRs OffiGer, immediately following slate and local notifications , but within an hour of I an emergency dassification . EP E.2.1 The Emergency Director is responsible for classifying an event into the appropriate emergency classification and then notifying on site personnel of the emergency declaration in accordance with site specific procedures . E: Tables E-1 and E-2 and Figure E-1 present EP E.1.1: SNC in cooperation with state , and county The commitment wording has the initial notification concept. authorities , has established methods and procedures for been standardized and relocated notification of offsite response organizations consistent to the SNC Standard Emergency with the emergency classification and emergency action Plan and Site Annex. level scheme. Annex 4.1.1: Notification Process (SEP E.2.2) State and local warning points are staffed 24 hours per day. State and local counties surrounding VEGP are to be notified within 15 minutes of the declaration of an emergency condition are : State of Georaia: Georgia Emergency Management Agency (GEMA) Georgia County Authorities : Burke County Emergency Management Agency State of South Carolina : Emergency Management Division (EMO) South Carolina Coun!}'. Authorities: Barnwell and Aiken County - Sheriffs Department Allendale County - County Central Dispatch De11artment of Energ~ - Savannah River Site (DOE-SRS) DOE-SRS Operations Center ElS-64 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix C urre nt Vogtle 3&4 Emergency Plan Revised SNC Emergenc y Plan Justificatio n Revision 3 F.3: The primary means of communication Annex 5.3.1 : Commun ications w ith the States, Loc al The commitment wording was between V EGP and the Savannah River Site Count ies and Savannah River (SEP F.1.2) standardized and relocated to (SRS) is the ENN . The primary means of communication between V EPG. the the Site Annex. States of Georgia and South Carolina as well as Burke, Aiken , Allendale and Barnwell Counties and the Savannah River Site is the Emergency Notification Network (ENN). The ENN is a dedicated communications system from the plant to the EOC at GEMA headquarters in Manta , Georgia the South Carolina Warning Point in the SEOC . and the Burke Coun ty EOC and Savannah River Operations Center. Extensions for this system are located in the Control Room, the TSC, and the EOF. F.4 : Commercial telephone lines and the EP F .1.4: SNC has established communications systems The commitment wording was Southern Compan y Communications serve as to provide re liable communications with Federal standardized and relocated to backu ps to the ENS and HPN. emergency response organizations. the SNC Standard Emergency Commercial telephone lines serve as the backup to the Plan . ENS and other FTS lines. F.4 : Emergency notification system phones are EP F.1.4.1 This communications line provides a The commitment wording was located in the control room , TSC , and EOF . communications link to the NRC Operations Center in standardized and relocated to F .4 : Health physics network phones are located Rockville, MD and is used for continuous communications the SNC Standard Emergency in the TSC and EOF. in a classified emergency. Plan. EP F.1.4.2 This communications line provides a communications link with the NRC to provide radiological The current operation of the FTS information . . system allows any phone with long distance capability to call into the Headquarters Operations Center and be patched into any bridge . The specific listing becomes redundant to the expanded capability. ElS-71 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revisio n 3 H.1.3 & Appendix 7: The EOF is located in EP H.2.1 The EOF is the central location for management The commitment wording was Birmingham , Alabama and serves as the EOF for of the offsite emergency response , coordination of standardized and relocated to all SNC sites (VEGP ,FNP, and HNP) . radiological assessment, and management of initial the SNC Standard Emergency recovery operations. The EOF is a dedicated facility Plan . located in Birmingham , Alabama , and serves as the EOF for SNC sites (VEGP , FNP , and HNP). The EOF is procedurally required to be activated within 75 minutes following the dedaration of an Alert or higher classificationSlalliAQ aA<l aGtiualieA 01 IRe IOG~ 1s maA<lalePJ' "~eA <leGlaratieA el aA *1eF1 er Rigtler Glassi~GatieA . The EOF provides for: Management of overall emergency response Coordination of radiological and environmental

                                                        .. assessments.

Protective Action Recommendations .

                                                         .. Notification of Offsite Agencies .

Management of recovery operations .

                                                          . Notification and update of the NRG via ENS .

Notification and update of the NRG via Health

                                                        . Physics Network (HPN).

Coordination of emergency response activities with federal , state, and local agencies. H.3: Activation of the OSC will be initiated at an EP H.1: SNC operated nuclear power plants have The commitment wording was Alert or higher level dassification . established a TSC and an onsite OSC , which are staffed standardized and relocated to and activated within 75 minutes of the ded aration of an the SNC Standard Emergency Alert or higher dassification . Plan .The SNC Standard Emergency Plan requests ERO augmentation be revised to 75 minutes as part of this submittal. That justification is provided in the Technical Analysis Section of this submittal rather than repeated in the table each place it's referenced . ElS-95 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Curren t Vogtte 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 H.5.2: Each team will include two people who will EP B.2.2.7 The following emergency teams may be The commitment wording was obtain an emergency monitoring kit. Section 1.5: Monitoring teams of at least two .. formed by OSC personnel , as necessary. Search and rescue standardized and relocated to the SNC Standard Emergency people are formed and dispatched at the OSC or TSC as appropriate. .. Repair Post accident sampling Plan.

                                                           . Internal survey Field monitoring EP 1.7: In addition to the capabilities and resources described in Section H, SNC operated nuclear power plants have the ability to take offsite air samples and to directly measure gamma dose rates from a radioactive material release. The capability to take offsite soil , water, and vegetation samples is provided by a minimum of two (2) Field Monitoring Teams (FMTs).

H.5.2 : Results of the offsite monitoring activities EP 1.7: Field monitoring data is analyzed by personnel in The commitment wording was will be provided to the TSC until th e dose the TSC until relieved by the EOF staff. standardized and relocated to assessment activities are transferred from the the SNC Standard Emergency TSC to the EOF .Section 1.5: They will be Plan . controlled by the TSC until the responsibility is transferred to the EOF . H.5.2: The kits will include dosimeters, a two-way EP 1.9: Field monitoring equipment has the capability to The commitment wording was radio, meters for measuring gamma and detect and measure airborne radioiodine in the presence standardized and relocated to beta/gamma dose rates, and air samplers for of noble gases that has the capability to detect and the SNC Standard Emergency collecting particulates and iodines. measure radioiodine concentrations in air in the plume Plan. Section 1.5: The emergency monitoring kits exposure EPZ as low as 10-7 uCi/cc (microcuries per contain a portable air sampler, silver zeolite cubic centimeter) under field conditions Interference from The SNC Standard Emergency cartridges , and counters to provide the capability the presence of noble gas and background radiation shall Plan reta ins the commitment to to detect and measure radioiodine concentrations not decrease the stated minimum detectable activity perform the fu nction rather than in the air as low as 10-7 µCi/cc. l=ielEI meAiteFiAO eq"ipmeAI Ras IRe sapallility le Eletest the specifics on equipment. aAEI meas"Fe aiFlleme FaElieieEliAe iA lhe pFeseAse ef R8Bl9 oases. ElS-98 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 H.5.3: Backup laboratory facilities are available at EP H.6.3 Laboratory Facilities The commitment wording was Plant Hatch . External facilities for counting and analyzing samples, standardized and relocated to dosimetry processing , can be provided by the other SNC the SNC Standard Emergency operated plants including the GPC Central Laboratory, Plan. state, federal or contracted laboratories. Outside analytical assistance may be requested from state and federal agencies, or through contracted vendors . The DOE , through the Radiological Assistance Program (RAP) has access to any national laboratory. H.5.3 : The GPC environmental laboratory located EP H.6.3 Laboratory Facilities The commitment wording was in Smyrna , GA has the capability to perform External facilities for counting and analyzing samples, standardized and relocated to isotopic analyses of drinking water, river water, dosimetry processing , can be provided by the other SNC the SNC Standard Emergency milk, vegetation , sediment, and biological operated plants including the GPC Central Laboratory, Plan . samples, as well as tritium and gross-beta state, federal or contracted laboratories. Outside analysis . In addition, processing of environmental analytical assistance may be requested from state and thermos luminescent dosimeters (TLDs) will be federal agencies , or through contracted vendors . The handled by this laboratory. DOE, through the Radiological Assistance Program (RAP) has access to any national laboratory. H.5.3: VEGP has laboratory facilities for analysis EP H.5.2.3: SNC sites have a laboratory facility for The commitment wording was of radioactive samples. The major pieces of analysis of radioactive samples . standardized and relocated to equipment include a solid-state gamma EP H.6.3 Laboratory Facilities th e SNC Standard Emergency spectrometer and a beta/gamma gas proportional External facilities for counting and analyzing samples, Plan . counter. dosimetry processing , can be provided by the other SNC operated plants including the GPC Central Laboratory, state, federal or contracted laboratories. Outside analytical assistance may be requested from state and federal agencies, or through contracted vendors . The DOE , through the Radiological Assistance Program (RAP) has access to any national laboratory. H.6: A set of spares of certain equipment is also EP H.8: i;;..,e,~eRGY faGiliijes a Rs eq"ipmeRI aFe iRspeGles The commitment wording was maintained to replace inoperative or out-of- aR9 iR"8Rlefie9 "SiR~ apprnpfiale asmiRiSIFaQue eF standardized and relocated to calibration equipment. sepaft..,eRI pFG69G"f96 . lRese pF<l69G"F96 pf<luise the SNC Standard Emergency iRfeRffialieR eR leGalieR aRs a"ailallilily el emef§eRGY Plan . eq"iP"'8RI aRG ""PPlies. Sufficient reserves of instruments and equipment are maintained to replace those removed from emergency kits or lockers for calibration or repair. ElS-100 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matlix Curren t Vogtle 3&4 Emergency Plan Revi sed SNC Emergency Plan Justific atio n Revis ion 3 H.6: Emergency kits are located in the TSC (for EP H.9: Emergency kits are available at SNC operated The commitment wording was control room also) . the OSC, the health physics nuclear power plants. Designated site or department standardized and relocated to control point, the EOF and other plant procedures identify the equipment in the valious the SNC Standard Emergency locations.Section H.6: An ambulance kit will be emergency kits. Plan and Site Annex. carried by the VEGP health physics technician A nnex 5.5: Emergency supplies and equipment are wh o accompanies the ambulance . located in the Control Room , the TSC , the OSC, the health physics control points, and other plant locations. Procedures requ ire an inspection and operational check of equipment in these kits on a quarterly basis and after each use. Equipment in these kits is calibrated in accordance with procedures . A set of spares of certain equipment is also maintained to replace inoperative or out-of-calibration equipment. H.6: Procedures require an inspection and EP H.8 : Emergency facilities and equipment are inspected The commitment word ing was operational check of equipment in these kits on a and inventolied using appropliate administrative or standardized and relocated to quarterly basis and after each use. department procedu res . These inventolies will include the SNC Standard Emergency Section H .6: Equipment in these kits is calibrated requirements that provisions are in place to inspect, Plan . in accordance with the suppliers' inventory, and operationally check emergency recommendations. equipmenUinstruments at least once each calendar quarter and after each use. These procedures provide infonnation on location and availability of emergency equipment and supplies.

                                                   !;;meFg9RGV faGiliijes aA<l eq"ipmeAt 8FB iAspeste<l aA<l iA>>BAl9R9Q "6iAg appFepfialB admiAiSIFali*'B QF depaFlmBAI pFesee"Fes. +11ese pFasee"Fes pre>>iee iAleFmaijeA eA lesalieA aAd a>>ailabilily el emBFg9AGV eq"ipmeAI aAe
                                                   ~

S"ll<GieAI F868P*es el iASINmeAls aAd eq"ipmeAI aFe maiAlaiAed le FeplaGe IRese Feme¥ed fFem emeFgeAGV kils eF leskel'& feF salibFatieA eF FepaiF. Section I Accident Assessment ElS-101 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Voglle 3&4 Emergen c y Plan Revised SNC Emergency Plan Justification Revision 3 I: Initial assessment actions are the responsibility EP B.1 SNC plants maintain 24-hour emergency The commitment wording was of the shift superintendent and/or the shift response capability. The nonmal on-shift complement standardized and relocated to supervisor, using available shift personnel. provides the initial response to an emergency. This group the SNC Standard Emergency is trained to respond to emergency situations until the Plan . The responsibility was augmented Emergency Response Organization (ERO) relocated to Section B arrives . description of on-shift staff and ED responsibilities. I: Subsequent assessment actions are directed EP B.1.1 In an emergency, the SM assumes the The commitment wording was by the emergency director with assistance from responsibility of the Emergency Director (ED) and takes standardized and relocated to the control room, technical support center (TSC), necessary actions to identify and respond to the the SNC Standard Emergency emergency operations facility (EOF) , and emergency until relieved by another qualified ED. The ED Plan . emergency teams, as necessary. has the responsibility and authority to immediately and unilaterally initiate emergency actions , including providing notification of Protective Action (PAR) Recommendations to State and Local govern ment organizations responsible for implementing off site emergency measures. After being relieved as Emerg ency Director, the Shift Manager directs the activities of the operating crew and is responsible for the safe operation of the plant. 1.2: In-plant radiological measurements provide EP H.5.2.1 Radiation Monitoring System (RMS) The commitment wording was infonmation to help assess emergency conditions. Radiation monitoring instruments are located at selected standardized and relocated to The containment high-range radiation monitor areas within the plant to detect, measure, and record the SNC Standard Emergency and containment hydrogen monitor are used to radiation levels. The monitors are comprised of area, Plan . provide an early indication of the quantity of radioactivity available for release from the containment. Emergency procedures include a airborne and air particulate monitors. Area monitors respond to gamma radiation . Airborne monitors are capable of detecting and I correlation between the monitor reading and the measuring radioactive gaseous effluent exten t of core damage . These correlations are based on the Westinghouse Owners Group (y'JOG) Core Damage Assessment Guidance ,

                                                          . concentrations.

Air Particul ate detectors capture and measure airborne particulate. I WCAP-14696-A, Revision 1, November 1999. A Emergency response procedures provide methods for more detailed assessment of core damage is detenmining relationships between monitor readings and then perfonmed using emergency implementing releases , material available for release and extent of core procedures which are also based on the WOG damage. methodology. ElS-102 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergenc y Plan Revised SNC Emergency Plan J usti f icatio n Revision 3 1.4: Computer dose calculation systems will be EP H.5.2.1 Radiation Monitoring System (RMS) The commitment wording was located in both the TSC and EOF for offsite dose Radiation monitoring instruments are located at selected standardized and relocated to assessment purposes. These systems will areas within the plant to detect, measure, and record the SNC Standard Emergency support the MIDAS code, a VEGP-specific radiation levels. The monitors are comprised of area, Plan . version of a dose assessment computer code developed by Pickard , Lowe, and Garlick , Inc., (PLG). The airborne and air particulate monitors. Area monitors respond to gamma radiation . Airborne monitors are capable of detecting and I code is based on a PLG application entitled measuring radioactive gaseous effluent Calculation of Reactor Accident Consequences Including Trajectory (CRACIT), which is similar in concept to that in the CRAC program written for

                                                        . concentrations.

Air Particulate detectors capture and measure airborne particulate . I the Reactor Safety Study. The MIDAS version is Emergency response procedures provide methods for referred to as MID RAC . The basic functions of determining relationships between monitor readings and MIDRAC are the calculation of dispersion of the releases, material available for release and extent of core released material as it travels downwind and the damage. estimation of the resulting concentrations of this EP 1.3: The dose calculation model is provided in the material. Dispersion is modeled using the Control Room, TSC , and EOF for use in projecting straight-line Gaussian dispersion model and potential offsite doses. The commi tment is to maintain variable trajectory transport. Initial dose EP 1.3 : SNC operated nuclear power plants use an offsite the comparison with EPA PAGs. projections can be made within 15 minutes of a dose assessment program which estimates doses from The time reference is not radiological release utilizing the computer radiological accidents for comparison with the EPA required to support the PAR system. Protective Action Guidance and acute health effect process. Subsequent dose projections will be made thresholds. approximately every 15-30 minutes depending on the variability of meteorological conditions and/or radioactive releases . 1.4: MIDAS is a personal computer based EP 1.3 : The dose calculation model is provided in the The statement of process was program for rapidly assessing the radiological Control Room , TSC , and EOF for use in projecting eliminated. Procedural control impact of accidents at nuclear power plants. It potential offsite doses. for the release of material offsite calculates total effective dose equivalent (TEDE) , is maintained by existing site thyroid doses, and skin doses at various fixed non-emergency procedures. downwind distances . Source term information is derived from plant effluent monitors, RCS or containment samples , field monitoring teams, or default accident scenario . ElS-105 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 J.1.2: Emergency response personnel in the EP J.4.1 Assembly The commitment wording was protected area badge into their emergency Assembly is mandatory following the declaration of a Site standardized and relocated to response facility (TSC , OSC, or control room) . Area or General Emergency, or at the discretion of the the SNC Standard Emergency The security computer system performs an initial Emergency Director. When Accountability of onsite Plan. of all persons in the protected area. personnel is determined to be necessary by the J.1 .2: Thereafter, the emergency response Emergency Director, personnel within the Protected Area facility managers of the control room , TSC , and will be accounted for and the names of missing individuals operations support center shall be responsible for determined within 30 minutes of the emergency periodically assuring that accountabilities in their declaration . facilities are being maintained . The Assembly Area senior individual will take the lead in coordinating the activities of the Assembly Area in support of OSC operations as directed by the OSC Manager. Assel'Rbl*t is l'RaRElateFY lelleu1iR9 Ille EleslaralieR el a Site AFea BF GeReFal el'ReFgeRGy , BF at tRe EliSGFeijeR el tRe el'ReFQBRGy bliFeGtBF. IOIReR 0GGB*Rtabilily Bl BRSile peFSBRRel is EleteFl'RiReEI le be ResessaFY by Ille el'RBFgeRG~* bliFeGtBF, ~eFSBRRBI u;tRiR Ille PFetesteEI 0 F@a will be aG60ijRleEI laF aREI IRe Ral'ReS el l'RiSSiRg iAEli*;iEl*als EleteFl'RiAeEI "'ilRiA tRiFly l'RiA*les el tRe e!'ReFgeAGy EleslaFatieR . EP J .4.2 Accountability Personnel accountability is mandatory at the Site Area or General Emergency dassification. Accountability may be initiated at other times at the discretion of the Emergency Director to support worker safety. Accountability of personnel within the Protected Area is accomplished within 30 minutes of the declaration of Site Area Emergency or higher, and maintained continuously thereafter, using Protected Area(s) boundary access control as described in the Security Plan. If there are station personnel who are unaccounted for, the Public Address System or other suitable communication methods are used to locate them, or, in extreme cases such as fire , toxic gas release , explosions, or structural damage, trained search and rescue personnel are deployed to search for and assist the missing personnel. ElS-121 5 to NL-16-0 169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 J.1.6: At the time potassium iodide is distributed , EP J .4 : SNC operated nuclear power plants are The commitment wording was an iodine sensitivity check will be made by responsible for maintaining a supply of Kl at their standardized and relocated to querying each individual concerning known respective site . The Emergency Director has the the SNC Standard Emergency reactions to iodine. responsibility for approval of issuing Kl to site emergency Plan. workers. J.2.2: The emergency director is responsible for EP B.1.1 The Emergency Director's non-delegable duties The commitment wording was providing protective action recommendations to State and local officials as part of initial notifications and follow-up communications. include : Perform the duties and responsibilities of Protective Action Recommendation (PAR) standardized and relocated to the SNC Standard Emergency Plan . determination ; J.2.2: Using available information on plant EP J.5 Offsite Protective Action Recommendations The commitment wording was conditions, projected dose estimates. and any (PARs) standardized and relocated to available monitoring data , the emergency director Plant conditions , projected dose and dose rates, field th e SNC Standard Emergency recommends whether th e public should be monitoring data and evacuation time estimates are Plan . advised to seek shelter or evacuate. evaluated to develop PARs for preventing or minimizing exposure to the public. PARs are provided to the offsite agencies responsible for implementing protective actions for the public within the 10-mile EPZ. The Emergency Director will approve PARs. The PAR decision making flowcharts are site-specific in nature, and are provided in the site-specific implementing procedures. Plant conditions, projected dose and dose rates and field monitoring data are communicated to offsite agencies responsible for dose assessmenVPARs to assist them in developing parallel assessments There are various types of protective actions that can be recommended to the state and counties. They may include the following : Evacuation . Shelter in Place .

                                                     . Monitor and prepare .

Thyroid blocking agent (Consider the use of Kl (Potassium Iodide) in accordance with State Plans and Policy ElS-126 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan J ustification Revision 3 J.2.3: Determination of the benefit of evacuation EP J.5 Offsite Protective Actio n Recommendations The commitment wording was must take into account the time needed to (PA Rs) standardized and relocated to complete the evacuation . Plant conditions. projected dose and dose rates , field the SNC Standard Emergency monitoring data and evacuation time estimates are Plan . evaluated to develop PARs for preventing or minimizing exposure to the public. PARs are provided to the offsite agencies responsible for implementing protective actions for the public within the 10-mile EPZ. The Emergency Director will approve PARs. The PAR decision making flowcharts are site-specific in nature , and are provided in the site-specific implementing procedures. Plant conditions, projected dose and dose rates and field monitoring data are communicated to offsite agencies responsible for dose assessmenVPARs to assist them in developing parallel assessments There are various types of protective actions that can be recommended to the state and counties. They may include the following : Evacuation . Shelter in Place .

                                                   . Monitor and prepare .

Thyroid blocking agent (Consider the use of Kl (Potassium Iodide) in accordance with State Plans and Policy Table J-1: Emergency equipment locations . EP H.9: Emergency kits are available at SNC operated The commitment wording was nuclear power plants. Designated site or department standardized and relocated to procedures identify the equipment in the various the SNC Standard Emergency emergency kits . Plan and Site Annex. Ann ex 5.5: Emergency supplies and equipment are located in the Control Room , the TSC , the OSC , the health physics control points, and other plant locations. Procedures require an inspection and operational check of equipment in these kits on a quarterly basis and after each use . Equipment in these kits is calibrated in accordance with procedures . A set of spares of certain equipment is also maintained to replace inoperative or out-of-calibration equipment. ElS-127 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 J Figures J-1 and J-2 EP J .5 Offsite Protective Action Recommendations Figures were removed from the (PA Rs) SNC Standard Emergency Plan . Plant conditions , projected dose and dose rates , field monitoring data and evacuation time estimates are The PAR flowcharts are evaluated to develop PARs for preventing or minimizing contained in EPIPs. exposure to the public. PARs are provided to the offsite agencies responsible for implementing protective actions for the public within the 10-mile EPZ. The Emergency Director will approve PARs. The PAR decision making flowcharts are site-specific in nature , and are provided in the site-specific implementing procedures. Plant conditions, projected dose and dose rates and field monitoring data are communicated to offsite agencies responsible for dose assessment/PARs to assist them in developing parallel assessments There are various types of protecti ve actions that can be recommended to the state and counties. They may include the following : Evacuation .

                                          .. Shelter in Place .

Monitor and prepare . Thyroid blocking agent (Consider th e use of Kl (Potassium Iodide) in accordance with State Plans and Policy Table J-5, Reception Centers/Shelters The location of Reception Centers and Shelter information is a function of offsite agencies and included in offsite Plan and does not need to be addressed as part of the Standard Plan for SNC . Section K Radiolog ical Exposure Control ElS-128 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Pla n Revised SNC Emerg ency Plan Justific ation Revision 3 K.3: Decontamination of serious wounds will be Annex 5.8.1: Agreements are in place with the University The commitment wording was accomplished at Doctors Hospital or the Burke of Alabama at Birmingham (UAB) Hospital, Burke Medical standardized and relocated to Medical Center as described in Section L of this Center. Doctors Hospital , and Burke County Emergency the Site Annex. Plan . Management Agency to provide assistance for injured personnel, induding cases involving radioactive contamination . This assistance will be requested whenever necessary in accordance with plant procedures 0 RR ex 5 8 11-!Gspital aRd '4edisal S"ppGFI (S!OP 8 .li.:l, b.1) AgreemeRls aFe iR plase .. ;u~ 8"Fke '4edisal GeRleF, QQGIGFS 1-!Gspilal, aRd 8"Fke GG"Rly !OmeF§eRsy

                                                   '4aRa§emeRI l\geRsy le pre,.ide assislaRse feF iRj"Fed peF69RRel , iRGl"diR§ sases iRuel"iR§ Fadieasli"e seRlamiRalieR. ais assislaRse "'ill ~e Fe~"esled
                                                   "'R8R9H9F R96966aFy iR aGG9FdaRG8 "'ilR plaRI presed"F96.

K.3: If decontamination activities are required , a EP K.5 Decontamination The commitment wording was controlled access area will be established by The Radiation Protection Group will be responsible for standardized and relocated to roping off the area . controlling or minimizing direct or subsequent internal the SNC Standard Emergency exposure from radioactive materials deposited on the Plan . ground or other surfaces , and for determining the extent of contamination in controlled and normally uncontrolled areas. During normal conditions or an emergency, guidelines to follow for contamination limits are established by the site radiation protection program . Facilities and supplies for decontaminating personnel are available at various plant locations. Personnel leaving the Radiological Controlled Area (RCA) or leaving a con taminated area wi ll be monitored for contamination . During emergencies, other onsite personnel will be checked fo r contamination as necessary. K.3: It (equipment and area decon) is EP K.5: Designated personnel, under the direction of the The commitment wording was accomplished as described in plant health Radiation Protection Group , will perform material standardized and relocated to physics procedures and ranges from vacuum decontamination . Procedures and equipment for material the SNC Standard Emergency cleaning to wash downs with water and acid or decontamination are available at the plant, as specified in Plan . caustic solutions. the site radiation protection program . ElS-135 5 to NL-16-0169 Voglle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergenc y Plan Revised SNC Emerg ency Plan Justificatio n Revision 3 L.1 : Personnel foun d to be externally EP K.5 Decontam ination The commitment wording was contaminated but not requiring immediate The Radiation Protection Group will be responsible for standardized and relocated to medical attention will undergo decontamination in controlling or minimizing direct or subsequent internal the SNC Standard Emergency accordance with plant procedures. exposure from radioactive materials deposited on the Plan. ground or other surfaces, and for determining the extent of contamination in controlled and normally uncontrolled areas. During normal conditions or an emergency, guidelines to follow for contamination limits are established by the site radiation protection program . Facilities and supplies for decontaminating personnel are available at various plant locations. Personnel leaving the Radiological Controlled Area (RCA) or leaving a contamina ted area will be monitored for con tamination . During emergencies, other onsite personnel will be checked fo r contamination as necessary. L.2: Injured and contaminated personnel EP L.1: In addition to the onsite first aid response, The commitment wording was req uiring hospital medical attention will be arrangements have been made with local hospitals for standardized and relocated to transported to Doctors Hospital , Augusta , or treatment and evaluation of serious injuries or sicknesses . the SNC Standard Emergency Burke County Hospital , Waynesboro, by the Annex 5.8.1 : Agreements are in place with the University Plan and Site Annex. Burke County Ambulance Service. Letters of of Alabama at Birmingham (UAB) Hospital , Burke Medical agreement pertaining to these services are Center. Doctors Hospital , and Burke County Emergency located in Appendix 2. Management Agency to provide assistance for injured personnel , induding cases involving rad ioactive contamination . This assistance will be requested whenever necessary in accordance with plant procedures AAAe~ 5.8 ~

ogioeemeAI& aFe iA plase "'ilA B"A<e MeElisal GeAleF, Qe61eF& Maspilal , aAEI B"Fke Ge"AI~ !OmeFgeAG~ '4aAagemeAt ogeAG~ le pioe*;ae assislaAGe ler iAjijFeEI p8F68AAel , iAGlijEliAQ Gases iA"GIHiAQ FaElieasliue GeAtamiAalieA . +llis assislaAGe u;11 be req"esleEI wAeAeuer AeGessaF\' iA aGGeFElaAse "*ilA plaAI pFe6eElijF86 .

ElS-140 5 to NL-16-0169 Vogtle (Units 3 & 4 ) Justification Matrix Current Vogtle 3&4 Emergenc y Plan Revised SNC Emergency Plan Justifica t ion Revis ion 3 L.3: Arrangements for treating externally EP L.1 : In addition to the onsite first aid response, The commitment wording was contaminated patients have been made with the arrangements have been made with local hospitals for standardized and relocated to Doctors Hospital in Augusta , Georgia, and Burke treatment and evaluation of serious injuries or sicknesses . the SNC Standard Emergency County Hospital in Waynesboro, Georgia , Annex 5.8.1 : Agreements are in place with the University Plan and Site Annex. (appendix 2). of Alabama at Birmingham (UAB} Hospital , Burke Medical Center, Doctors Hospital , and Burke County Emergency Management Agency to provide assistance for injured personnel , induding cases involving radioactive contamination . This assistance will be requested whenever necessary in accordance with plant procedures Annu 5.8 l : AgFeemeAls a~ iA place "'ilR B*Fke '4eElical GeAleF, E:lesleFs Haspilal, aAEI B*Fke Ge*Al¥ em9F88AGy '4aAagemeAl AgeAGy le pFe ..iEle assislaAGe leF iAj"Fed peFseAAel , iAGl"EliAg cases iA"Sl" iAg FaElieacli"e seAlamiAalieA . +Ris assislaAGe u;11 Ile Feq*esled "'ReAe"eF Ae cessaf)' iA acseFdaAGe *vilR plaAl pFeGed"Fes . L.3: Trained plant radiation protection personnel Annex 5.8.2: Injured/externally contaminated personnel The commitment wording was will assist hospital staff when plant personnel are who require medical attention will normally be transported standardized and relocated to being evaluated . by ambulance to the cooperating hospitals. Am bulance the Site Annex. crews are trained to handle external contamination cases, and an HP technician accompanies any contaminated patients to the hospital. Ambulance service is provided by the Burke County Emergency Management Agency. ElS-142 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 L.3: Arrangements have also been made with EP L.3 State Emergency Medical Services The commitment wording was local doctors to render medical assistance, both The states of Alabama and Georgia have developed lists standardized and relocated to onsite and offsite , and to assume responsibility of facilities that can provide medical support for treating the SNC Standard Emergency for the medical supervision of the patient injured, contaminated individuals. Details are found in the Plan and Site Annex. (appendix 2, Letters of Agreement) . respective state emergency plan . Ann ex 5.8.1. Agreements are in place with the University of Alabama at Birmingham (UAB) Hospital , Burke Medical Center, Doctors Hospital , and Burke County Emergency Management Agency to provide assistance for injured personnel, induding cases involving radioactive contamination . This assistance will be requested whenever necessary in accordance with plant procedures l\RRS. 5 8,1 ' 4eElisal Spesialisls, IRG., a ijFe"p el meaisal pFelessieRals . Ras a9FeeEI le pFe**Ele IFealmeRI seP*ises IRFG*OR il*Flle '4eElisal GeRleF aREI QesleFs

L.3: Following decontamination , personnel Annex 5.8.1 : Agreements are in place with the University The SNC Standard Emergency suspected to have ingested radionud ides will of Alabama at Birmingham (UAB) Hospital , Burke Medical Plan commits to maintaining undergo whole body counting at VEGP. Center, Doctors Hospital , and Burke County Emergency agreements supporting the Management Agency to provide assistance for injured treatment of contaminated personnel , induding cases involving radioactive and/or injured personnel. contamination . This assistance will be requested Medical experts will determine whenever necessary in accordance with plant the course of treatment and procedures ORRu 5 8 l* AgFeemeRls aFe iR plase "'ilR !Re subsequent monitoring . A IJAiveF6ily el ,o,1aeama al iliFFRiR§ham {IJ.0,8) Hespital , specific commitment for internal il"Flle 14eElisal GeAleF, QesleFs Hespilal , aREI il"Flle monitoring at the site may or Ge*Aly !OmeF§eAsy MaAagemeAI AgeAsy le pFeviEle may not be included in this post assislaAGe leF iAj*FeEI peF6eAAel , iAGl"EliAij sases iA,.el,.iA§ event treatment. FaElieasijue ooAlamiAalieR . +Ris assislaRGe u;11 ee req"esteEI "'ReRe"eF Resessary iR assenJaRse wi!R plaRI pFeseEl*res L.3: The medical staff of the hospital is trained to EP 0 .1.1: Annually, training will be offered for hospital The commitment wording was treat externally contaminated patients or personnel , ambulance/rescue personnel, police , and fire standardized and relocated to individuals who have received high exposures . departments. The training shall include the procedures for the SNC Standard Emergency notification , basic radiation protection, and their Plan . organizations' expected role . ElS-143 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 L.4: In addition , drills and exercises are an EP N.2.43 Medical Emergency DrillsA medical emergency The commitment wording was integral part of the training prog ram and are drill , involving a simulated contaminated individual , and standardized and relocated to conducted as specified in section N, Exercises containing provisions for participation by local support the SNC Standard Emergency and Drills. services organizations including ambulance response are Plan . con ducted annually at the nuclear plants. Local support service organizations, which support more than one plant, shall only be required to participate once each calendar year. L.4: The VEGP training department conducts EP 0 .1.1: Annually, training will be offered for hospital Th e commitment wording was training sessions at least once per calendar year personnel , ambulance/rescue personnel , police, and fire standardized and reloca ted to (for on site and offsite personnel who have departments. The training shall include the procedures for the SNC Standard Emergency medical support responsibilities). notification , basic radiation protection , and their Plan. organizations' expected role . Section M Recovery and Reentry Planning and Post-Accident Operations M.1: The emergency director will detenmine when EP M.1: Upon tenmination of the emergency phase and at The commitment wording was the recovery phase begins . the discretion of the Emergency Director. following standardized and relocated to consultation with offsite authorities, the SNC Emergency the SNC Standard Emergency Organization will shift to the Recovery Phase Plan . Organization . ElS-144 5 to NL-16-0169 Vogue (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Figure M-1 EP Figu re M.2 The commitment wording was standardized and reloca ted to the SNC Standard Emergency Plan . Section N Exercises and Drills N.1: Exercises are conducted every two calendar EP N.1.2: Full participation exercises will include, as The commitment wording was years , and are designed to include the appropriate, offsite local and state authorities and SNC standardized and relocated to demonstration of response to a major portion of personnel actively participating in testing the integrated the SNC Standard Emergency the basic elements of the emergency capability to assess and respond to an accident at a Plan . preparedness plans of the participating nuclear power plant. Additionally, full participation organizations. exercises will include, as appropriate, testing the major observable portions of the onsi te and offsite emergency plans and mobilization of state, local, and SNC personnel and other resources in sufficient numbers to verify the capability to respond to the accident scenario. EP N.1.45: The Exercise planning cycle will consist of I eight (8) successive calendar years ElS-162 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 N.1: The exercise program for VEGP EP N.3: During the exercise planning cycle described in The commitment wording was incorporates the following features : Scenarios are varied from year to year so that all major elements of the VEGP Section N.1.45, SNC sites vary the content of exercise scenarios to provide ERO members the opportunity to demonstrate proficiency in key skills necessary to respond standardized and relocated to the SNC Standard Emergency Plan . The wording has been I emergency preparedness program are tested to several specific scenario elements including : updated to reflect the Enhanced within an eight year period , commencing in Hostile Action directed at the plant site . Emergency Preparedness the calendar year in which the VEGP 3 and 4 No radiological release or unplanned release that Rulemaking (November 23, . first exercise is conducted. VEGP starts an exercise between 6:00 p.m. . does not require public protective actions; An initial classification of or rapid escalation to a Site 2011 ). . and 4:00 a.m. once every 8 years. Since exercises are normally scheduled several months in advance, a variety of

                                                 . Area Emergency or General Emergency.

Implementation of strategies , procedures , and guidance developed in 50.54(hh) , (i.e., potential weather conditions is likely to occur. aircraft threat, explosion or large fire). Integration of offsite resources with on site response A drill initiated between the hours of 6 p.m. and 4

                                                . a.m.

Drills utilizing essentially 100 % of Initiating Conditions in the 8 year cycle. Drills and exercise scenarios will be varied from year to year so as to test major components of the plans and preparedness organizations. A record of Exercises conducted during the eight (8) year exercise planning cycle that documents the contents of scenarios used during that cycle shall be maintained in accordance with Drill and Exercise procedure guidance ElS-163 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revis ion 3 N.2.2: Communication drills among the control EP F.3: Communications tests will be conducted on the The commitment wording was room , technical support center (TSC), operations frequency specified below. Each of these tests includes standardized and relocated to support center (OSC), emergency operations provisions to ensure that all participants in the test are the SNC Standard Emergency facility (EOF) , emergency news center, general able to understand the content of the messages used in Plan . office operations center, the States of Georgia and South Carolina , Bur1<e, Aiken , Barnwell , and Allendale Counties , SRS , and VEGP field the test. Communications with state and local governments within the plume exposure pathway will be tested monitoring teams are conducted every two years .

                                                    . monthly.

Communications with federal response organizations and state governments within the plume exposure

                                                    . pathway will be tested quarterty.

Communications between SNC operated nuclear power plants, state Emergency Operating Centers and local Emergency Operations Centers, and

                                                    . rad iation monitoring teams will be tested annually; Communication from the Control Room , TSC , and EOF to the NRC Operations Center will be tested
                                                    . monthly.

The Emergency Response Data System (EROS) will

                                                    . be tested on a quarterty basis; The fixed siren portion of the Alert and Notification System (ANS) will be tested and verified in accordance with existing FEMA approvals.

N.2.3: As discussed in the FSAR. the program EP N.2.32 : Fire drills will be conducted at nuclear plants in The commitment wording was involves quarterty (fire) drills , at least one of accordance with Plant Technical Specifications and Plant standardized and relocated to which is unannounced . procedures. the SNC Standard Emergency Plan . N.2.3: The quarterty drills are scheduled so that EP N.2.32: Fire drills will be conducted at nuclear plants in The commitment wording was each member of the fire brigade participates in at accordance with Plant Technical Specifications and Plant standardized and relocated to least two drills per year. procedures . the SNC Standard Emergency Plan . N.2.3: In addition . an annual practice is EP N.2.32 : Fire drills will be conducted at nuclear plants in The commitment wording was conducted which requires extinguishing a fire . accordance with Plant Technical Specifications and Plant standardized and relocated to procedures. the SNC Standard Emergency Plan . ElS-165 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emerg ency Plan J ustifica tio n Revision 3 N.2.4 : A medical emergency drill involving a EP N.2.43: A medical emergency drill , involving a The commitment wording was simulated contaminated person is conducted simulated contaminated individual , and containing standardized and relocated to each calendar year. provisions for participation by local support services the SNC Standard Emergency organizations including ambulance response are Plan . conducted annually at the nuclear plan ts. N.2.5: Plant environs and radiological monitoring EP N.2.64: Plant environs and radiological monitoring The commitment wording was drills are conducted each calendar year per drills are conducted annually. These drills include standardized and relocated to administrative procedures collection and analysis of sample media and provisions for the SNC Standard Emergency communications and record keeping . These drills also Plan . evaluate the response to , and analysis of, simulated airborne and direct radiation measurements in the environment. N.2.6 : Semi-annual health physics drills will be EP N.2.65: Radiation Protection Drills involving a The commitment wording was conducted in accord ance with emergency response to, and analysis of, simulated airborne and liquid standardized and relocated to implementing procedures. samples and direct radiation measurements are the SNC Standard Emergency conducted semi-annually. At least annually, these drills Plan . shall include a demonstration of the sampling system capabilities, as applicable. N.2.6: Post accident sampling under simulated The annual sampling accident conditions will be demonstrated each requirement in the description of calendar year. Radiation Protection dri lls in EP N.2.65 ensures accident sampling capabilities are maintained . ElS-166 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revisio n 3 N.4: All drills and exercises are EP N.4 Exercise Evaluatio n and C ritique The commitment wording was evaluated .Section N: For periodic drills, the A formal critique will be performed for exercises, drills, standardized and relocated to process consists of the following steps : and training tabletops to develop , maintain , or the SNC Standard Emergency

1. Drills will be evaluated by controllers/evaluators selected on th e basis of expertise and availability.

demonstrate key skills in order to identify weak or deficient areas that need correction A critique shall be conducted at the condusion of the Plan . I

2. Improper or incorrect performance during the exercise , to evaluate the organization's ability to respond drill may be corrected by the controller/evaluator as called for in the SNC Standard Emergency Plan.

and the proper method pointed out or Qualified personnel will observe and perform a critique of demonstrated . exercises and drills. Provisions will be made for federal ,

3. The exercise or drill controllers assemble th e state, and local observers, as well as SNC personnel , to players at the conclusion of activities for a observe and critique requ ired exercises.Biennially, critique . Players are encouraged to identify representatives from the NRC observe and evaluate the areas where improvements are required . The licensee's ability to conduct an adequate self-critical drill controllers also presents their observations critique . For partial and full offsite participation exercises ,

to the players. the NRC and Federal Emergency Management Agency

4. The site emergency preparedness supervisor (FEMA), will observe, evaluate , and critique.

submits a list of corrective actions, Drill and exercise performance objectives will be responsibilities , and schedule information to th e evaluated against measurable demonstration criteria . As site support manager for approval. soon as possible following the condusion of the drill or

5. The emergency preparedness supervisor exercise, a critique is conducted to evaluate the ability of assigns action items and monitors the status of the Emergency Response Organization (ERO) to completion of corrective actions. Significant implement th e emergency plan and procedures and a problems will be brought to the attention of formal evaluation will result from the critique.

appropriate plant management.Exercise A written critique report is prepared by the Emergency evaluation and corrective action are carri ed out in Preparedness group following a drill or exercise involving similar fashion . the evaluation of designated objectives or following the final simulator set with ERO participation . The report will evaluate the ability of the ERO to respond to a simulated emergency situation . The report will also contain corrective actions and recommendations. Section 0 Radiological Emergency Response Training ElS-169 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergenc y Plan Revised SNC Emergency Plan Justification Revision 3 0 : All VEGP badged personnel will receive EP 0 .4.8: GET will include general training in emergency The commitment wording was General Employee Training at inception of onsite preparedness for plant and other site personnel. GET will standardized and relocated to duties. include classification , individual response, signals, the SNC Standard Emergency 0 .3: All badged VEGP workers will receive accountability, and site evacuation procedures. Plan. general training in emergency preparedness . The prerequisites for badging workers includes GET training . 0 : GET will include emergency classification , EP 0 .4.8: GET will include general training in emergency The commitment wording was individual response, signals , accountability, and preparedness for plant and other site personnel. GET will standardized and relocated to site dismissal procedures. include classification , individual response , signals, the SNC Standard Emergency accountability, and site evacuation procedures . Plan . 0 : All VEGP emergency response organization EP 0 .1 Training The commitment wording was personnel will receive specialized training per To achieve and maintain an acceptable level of standardized and relocated to Table 0 -2. emergency preparedness, training will be conducted for the SNC Standard Emergency members of the Emergency Response Organization Plan . (ERO) and those offsite organizations who may be called upon to provide assistance in the event of an emergency. Training will be evaluated in accordance with the requirements of Systematic Approach to Training practices to ensure effectiveness and in order to identify weak or deficient areas that need correction . The ERO Training Program assures the training , qualification , and requalification of individuals who may be called on for assistance during an emergency. Specific emergency response task training , prepared for response positions, is described in lesson plans and study guides. The lesson plans, study guides, and written tests are contained in the ERO Training Program . Responsibilities for implementing the training program are contained in plant procedures. Offsite training is provided to support organizations that may be called upon to provide assistance in the event of an emergency. ElS-170 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revis ion 3 0 .1: The training will be conducted in accordance EP 0 .1 Training The commitment wording was with lesson plans. To achieve and maintain an acceptable level of standardized and relocated to emergency preparedness, training will be conducted for the SNC Standard Emergency members of the Emergency Response Organization Plan . (ERO) and those offsite organizations who may be called upon to provide assistance in the event of an emergency. Training will be evaluated in accordance with the requirements of Systematic Approach to Training practices to ensure effectiveness and in order to identify weak or deficient areas that need correction. The ERO Training Program assures the training , I qualification , and requalification of individuals who may be called on for assistance during an emergency. Specific emergency response task training , prepared for response positions, is described in lesson plans and study guides. The lesson plans, study guides, and written tests are contained in the ERO Training Program . Responsibilities for implementing the training program are contained in plant procedures. ElS-173 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 0 .1: Records of the attendance and examination EP 0.1 Training The commitment wording was scores will be retained in the training files. To achieve and maintain an acceptable level of standardized and relocated to emergency preparedness, training will be conducted for the SNC Standard Emergency Plan. members of the Emergency Response Organization (ERO) and those offsite organizations who may be called upon to provide assistance in the event of an emergency. Training will be evaluated in accordance with the requirements of Systematic Approach to Training practices to ensure effectiveness and in order to identify weak or deficient areas that need correction . The ERO Training Program assures the training , qualification , and requalification of individuals who may be called on for assistance during an emergency. Specific emergency response task training, prepared for response positions, is described in lesson plans and study guides. The lesson plans , study guides, and written tests are contained in the ERO Training Program . Responsibilities for implementing the training program are contained in plant procedures. Offsite training is provided to support organizations that may be called upon to provide assistance in the event of an emergency. 0 .1: Radiological emergency response training is EP 0 .4 ERO Training The commitment wording was offered throughout the year, with each training SNC ERO personnel who are responsible for standardized and relocated to course being covered at least once per calendar implementing this plan receive specialized training . The the SNC Standard Emergency year. training program for emergency response personnel is Plan . developed based on the requirements of 10 CFR 50 , Appendix E and position specific responsibilities. Requalification training for onsite ERO members consists of an annual review of the Emergency Plan in the form of a general overview. In addition to SNC Emergency Plan overview training , personnel assigned on site emergency response positions will receive training specific to their position . ElS-174 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 0 .1: Annual retraining consists of initial training EP 0 .4 ERO Training The commitment wording was material reinforcement and appropriate lessons SNC ERO personnel who are responsible for standardized and relocated to learned from the previous year's operating implementing this plan receive specialized training. The the SNC Standard Emergency experience. training program for emergency response personnel is Plan . developed based on the requirements of 10 CFR 50, Appendix E and position specific responsibilities . Requalification training for onsite ERO members consists of an annual review of the Emergency Plan in the form of a general overview. In addition to SNC Emergency Plan overview training , personnel assigned onsite emergency response positions will receive training specific to their position . 0 .1: Upon completion of each training session or EP 0 .1 Training The commitment wording was drill , the participants will be asked to critique the To achieve and maintain an acceptable level of standardized and relocated to training in order to ensure continued the SNC Standard Emergency emergency preparedness, training will be conducted for improvement. Plan. members of the Emergency Response Organization (ERO) and those offsite organizations who may be called upon to provide assistance in the event of an emergency. Training will be evaluated in accordance with the requirements of Systematic Approach to Training practices to ensure effectiveness and in order to identify weak or deficient areas that need correction . The ERO Training Program assures the training , qualification , and requalification of individuals who may be called on for assistance during an emergency. Specific emergency response task training , prepared for response positions, is described in lesson plans and study guides. The lesson plans , study guides, and written tests are contained in the ERO Training Program . Responsibilities for implementing the training program are contained in plant procedures. Offsite training is provided to support organizations that may be called upon to provide assistance in the event of an emergency. ElS-175 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3& 4 Emergency Plan Revised SNC Emergency Plan Justification Revisio n 3 Table 0-1 EP 0 .1 Training The commitment wording was All ERO personnel shall be trained per table 0 -2 To achieve and maintain an acceptable level of standardized and relocated to within the last 15 months, except for post the SNC Standard Emergency emergency preparedness, training will be conducted for accident sampling and first aid training , which is Plan . to be within 36 months . members of the Emergency Response Organization (ERO) and those offsite organizations who may be called upon to provide assistance in the event of an emergency. Training will be evaluated in accordance with the requirements of Systematic Approach to Training practices to ensure effectiveness and in order to identify weak or deficient areas that need correction . The ERO Training Program assures the training , qualification , and requalification of individuals who may be called on for assistance during an emergency. Specific emergency response task training , prepared for response positions, is described in lesson plans and study guides. The lesson plans , study guides, and written tests are contained in the ERO Training Program. Responsibilities for implementing the training program are contained in plant procedures. Offsite training is provided to support organizations that may be called upon to provide assistance in the event of an emergency. ElS-176 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 0 .3: Selected individuals on site and off site will EP 0 .1 Training The commitment wording was annually receive specialized training . To achieve and maintain an acceptable level of standardized and relocated to emergency preparedness, training will be conducted for the SNC Standard Emergency members of the Emergency Response Organization Plan . (ERO) and those offsite organizations who may be called upon to provide assistance in the event of an emergency. Training will be evaluated in accordance with the requirements of Systematic Approach to Training practices to ensure effectiveness and in order to identify weak or deficient areas that need correction. The ERO Training Program assures the training , qualification , and requalification of individuals who may be called on for assistance during an emergency. Specific emergency response ta sk training , prepared for response positions, is described in lesson plans and study guides. The lesson plans, study guides, and written tests are contained in the ERO Training Program . Responsibilities for implementing the training program are contained in plant procedures. Offsite training is provided to support organizations that may be called upon to provide assistance in the event of an emergency. EP 0.4.1 ERO Training ERO members will receive Emergency Plan training on an annual basis. Personnel identified receive training appropriate to their position in the areas of: Accident assessment. Accident mitigation . Notifications . Emergency Classifications .

                                                     .. Protective Action Recommendations .

Emergency Action Levels . Emergency Exposure Control . Section P Responsibility for the Planning Effort ElS-177 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Annex V2 H.4 .1.4: The fire detection system will EP H.5.4: The Fire Detection System is designed to The commitment wording was provide audible and visual alarms in the main detect products of combustion or heat in designated areas standardized and relocated to control room . of the plant. The fire alarm communication systems and the SNC Standard Emergency subsystems are located at strategic points throughout the Plan. plant to warn personnel of a fire or other emergency conditions. Additional description of the fire system is provided in the FSAR. Annex V2 H.4 .2 : The radiation monitoring system EP H.5.2.1 Radiation Monitoring System (RMS) The commitment wording was is Radiation monitoring instruments are located at selected standardized and relocated to designed in accordance with ANSI N1 3.1- 1969, areas within the plant to detect, measure, and record the SNC Standard Emergency Sampling Airborne Radioactive Materials radiation levels. The monitors are comprised of area, Plan . airborne and air particulate monitors . Area monitors respond to gamma radiation . Airborne monitors are capable of detecting and I measuring radioactive gaseous effluent

                                                       . concentrations.

Air Particulate detectors capture and measure airborne particulate. I Emergency response procedures provide methods for determining relationships between monitor readings and releases, material available for release and extent of core damage . Annex V2 H.4.2: The radiation monitoring system EP H.5.2 .1 Radiation Monitoring System (RMS) The commitment wording was is divided functionally into two subsystems: Process , airborne, and effluent Radiation monitoring instruments are located at selected areas within the plant to detect, measure, and record standardized and relocated to the SNC Standard Emergency

    . radiological monitoring and sampling     radiation levels. The monitors are comprised of area ,       Plan.

Area radiation monitoring airborne and air particulate monitors. Area monitors respond to gamma radiation . Airborne monitors are capable of detecting and measuring radioactive gaseous effluent I

                                                       . concentrations.

Air Particulate detectors capture and measure airborne particulate I Emergency response procedures provide methods for determining relationships between monitor readings and releases , material available for release and extent of core damage . ElS-182 5 to NL-16-0169 Vogtle (Units 3 & 4} Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revis io n 3 Annex V2 H.4.2: Radiation monitoring data, EP H.5.2.1 Radiation Monitoring System (RMS} The commitment wording was induding alarm status , are provided to operators Radiation monitoring instruments are located at selected standardized and relocated to via the plant control system (and the protection areas within the plant to detect, measure, and record the SNC Standard Emergency and safety monitoring system for Class 1E radiation levels. The monitors are comprised of area, Plan . monitors}. The information is available in either counts per minute (count rate}, microCuries/cc (activity concentration }, or R/hr (radiation dose airborne and air particulate monitors . Area monitors respond to gamma radiation . Airborne monitors are capable of detecting and rate} . measuring radioactive gaseous effluent

                                                       . concentrations.

Air Particulate detectors capture and measure airborne particulate. Emergency response procedures provide methods for determining relationships between monitor readings and releases , material available for release and extent of core damage. Annex V2 H.4.2: Safety-related channels are EP H.5 .2.1 Radiation Monitoring System (RMS) The commitment wording was environmentally qualified and are powered from Radiation monitoring instruments are located at selected standardized and relocated to the Class 1E DC and uninterruptible power areas within the plant to detect, measure, and record the SNC Standard Emergency supply system . Non safety-related channels are radiation levels. The monitors are comprised of area, Plan. powered from the non-Class 1E DC and uninterruptible power supply (UPS} system . .. airborne and air particulate monitors. Area monitors respond to gamma radiation . Airborne monitors are capable of detecting and I measuring radioactive gaseous effluent

                                                       . concentrations.

Air Particulate detectors capture and measure airborne particulate. I Emergency response procedures provide methods for determining relationships between monitor readings and releases , material available for release and extent of core damage . ElS-183 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Appendix 3: Based upon Appendix 3 of NUREG- Annex 4.2 Alert and Notification System (ANS) (SEP The commitment wording was 0654 and FEMA REP-10, the system is designed E .2.5) standardized and relocated to to provide a minimum of 60 dBC coverage to all Within the 10 mile Exposure Emergency Planning Zone the Site Annex. residences within the plume exposure EPZ, plus (EPZ) , there exist provisions for alerting and providing adequate coverage for people outdoors in all notification to the public. The state and/or local authorities other are responsible for activation of this system. areas of the plume exposure EPZ open to the Two totally independent public alerting systems are public. installed for use in the VEGP EPZ: Network of fixed sirens and EAS , NOAA (National Oceanic and Atmospheric Administration) weather warning radio system . Offsite agencies will activate both independent systems in the event of a plant condition requiring public awareness . Following any public alert, commercial radio and television stations, as well as NOAA weather radio (NWR) will be used to provide notification and follow-up emergency information to the population within the EPZ.

                                              'NtRiR ttle Plwme expeswFe emergeRsy PlaRRiRg ZeRe (EPZ) tllere exist pm,,isieRs f<lr aleftiRg aR<l pre"i<liRg RetilisatieR te ttle pwblis. Ttle state aR<ller lesal awttlerities are respeRsible f<lr asti"alieR el ttlis system .

TRe Veg~e ElestFis GeReratiRg PlaRt (VEGP) tias eeuelepe<l a Pwblis A left aR<l ~letilisatieR system <lesigRell fer ooverage el tile pepwlatieR "'ittliR !Re EPZ. TRis is assemplisRe<l wtiliziRg a sembiRatieR el lixell sireRs aR<l teRe aleft rallies . SireRS iRstalle<l by "eGP Ra"e beeR sited asser<liRg te i=E,4° REP 1Q sriteFieR te eRswre tRe re~wirell se><erage. SireA besatieRs aFe sRewR iA l"igwre 4 .2.A, l"ixee SireR besatieR '4ap . Pre,,isieRs fer traAsieRt pepwlatieA RelilisatieA are alse iAslweell iR State aA<l CewRty plaRs. IA tRe e"eRt ef aR emergeRsy eeslaratieR at tRe HeGP, DOE Sa"aRRaR Ri"er Site Ras agreed te pre,,i<le fer tRe prempt RetilisatieR el all perseRs eR !Re SRS witRiR HEGP's plwme expeswre patRu*ay EPZ. A full Aleft aRe NetiliGatieA System ("i~IS) eesGFiptieA is pre"i<le<l iR tRe l"E,4° appre,,e<l 0 1eft aR<l NetilisatieR System DesigR Repeft ( 0 ~1S "!>GP 001) lesate<l iA tRe S~IC eeswmeRt maRagemeRI system . tn-.US/ 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Appendix 3: Within the plume exposure pathway Annex 4.2 Within the 10 mile Exposure Emergency The commitment wording was EPZ, the prompt alerting and notification system Planning Zone (EPZ), there exist provisions for alerting standardized and relocated to will provide an alerting signal and notification by and providing notification to the public. The state and/or the Site Annex. NOAA radio and an alerting signal by fixed local authorities are responsible for activation of this sirens . system . Two totally independent public alerting systems are installed for use in the VEGP EPZ: Network of fixed sirens and EAS, NOAA (National Oceanic and Atmospheric Administration) weather warning radio system . Offsite agencies will activate both independent systems in the event of a plant condition requiring public awareness . Following any public alert, commercial radio and lelevision stations, as well as NOAA weather radio (NWR) will be used to provide notification and follow-up emergency information to the population within the EPZ.

                                                   +tie Hegije EleGIFiG GeAeFaliAQ PlaAI ~ IEGP) Ras deueleped a P"blis ~ lefl aAd MelifisalieA syslem desigAed f<:lF seuerage el !Re pep"laijeA wilRiA IRe EP~ . +Ris is assemplisRed "lili*iAQ a sembiAalieA ern*ed siFeAs aAd leAe alefl Fadies . SiFeAs iAslalled by HEGP Ra"e beeA siled asseFdiAQ le l"E14A REP      rn  sFileFieA le eAs"Fe !Re Fe~"iFed se*,eFage . SiFeA besalieAs aFe SR<l'"" iA l"ig"Fe 4.:l .A , l"i*ed SiFeA besaijeA 14ap . PFS ..isieAs f<:lF IFaAsieAI pep"lalieA AelifisalieA aFe alse iAGl"ded iA Slale aAd Ge"AI;< plaAs .

Appendix 3: Assurance of continued notification EP E.2.5.2 The testing and maintenance of the public The commitment wording was capability will be verified on a statistical basis. alerting sirens are the responsibility of SNC . The standardized and relocated to maintenance program will consist of both periodic routine the SNC Standard Emergency checks and , as required , corrective maintenance . Plan . The periodic routine maintenance and test program will be based on the manufacturers' recommendations and experience gained with the installation . ElS-188 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Appendi x 3 : Southern Nuclear Operating F-!' _E,_2,_5_:_ i:>r.<?'!112.t i!l_Elrl_if!g_a_11cl_ f!O!iflc~tlO!J _<?f_tt}_e_p~l2_1if '?'.l' i!hl_n_tt}_e_ plume exposure pathway EPZ is the obligation of State and local

                                                                                                                                                              - Jl)_e_c;_o.rn_n:iit[lljl[]l_Vi_OJd.ilJ.!L'l{C!_S_ - - --i Formatted: Font: 9 pt Company, and/or the State and local                                                                                                                              standard ized and relocated to governments will survey a sample of the          government or other responsible authority. The responsibility                                                   the SNC Standard Emergency residents in the plume exposure pathway EPZ. that means exist for this purpose rests with Southern Nuclear Plan and Site Annex .

Operating Company. An overview of these means excl uding the Appendi x 3: The survey results shall be used to Savannah River Site is listed in the site specific Annex of this assess the public's ability to hear the alerting Plan. signal and their awareness of the meaning of the Initial notification of the public will occu r in a manner consistent prompt notification message, as well as the with assuring the public health and safety. The design objective availability of information on what to do in an for the system is to meet the acceptance criteria which are emergency. provided in a subsequent section of the FEMA approved design report for each SNC operated plant. The design objective does not constitute a guarantee that prompt notification can be provided for everyone with 100% assurance , or that the system when tested under actual field conditions will meet the design objectives. Annex 4.2 With in the 10 mile Ex12osure Emergencl'. Planni ng Zone (EPZ), the re exist 12rovisions for alerting and 12roviding notification to the 12ublic. The state and/or local authorities are res12onsible for activation of this system . Two totally inde12e ndent 12ublic alerting systems are installed for use in the VEGP EPZ: Network of fixed sirens and EAS NOAA (National Oceanic and Atmos12he ric Admin istration) weather warning radio system. Offsite agencies will activate both inde12endent systems in the event of a 12lant condition regu iring 12ublic awareness. Following any 12ublic alert, commercial radio and television stations, as well as NOAA weather radio (NWR) will be used to 12rovide notification and follow-u12 emergency information to the 12012ulation within the EPZ.

                                                +Re VeQtle e leGIFiG GeAeFaliAQ f21aAI (VeGf2) Ras 9e*; elef)e9 a PlJl:JliG ,O.left aAG ~l eliliGalieA sysleFR 9esiQA9G leF Ge ... eraQe el IRS flBfllllatieA witRi A Ifie ePi. +t:iis is asseFRfllisRe9 lllili2iAg a seml:JiAatieA el liMe9 siFeAs aA9 leAe aleft Faeies. SiFeAs iAstallee l:Jy HeGf2 Ra110 l:leeA sites asseF9iAg te fie~4 o. r::leP 1Q GFileFieA le 0ASlJF0 IRS f0llJiFe9 Ge ... aFage. SiFeA besatieAs aFe sRewR iA fiiglJFe 4 .2.A, FiMe9 SiFeR besalieA Mafl. Pm.,.isieAs leF traAsieAI flBfllJlatieA AelilisatieA aFe alse iAGllJElee iA State aR9 GelJAly fllaAs.

ElS-189 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Appendix 3: Southern Nuclear Operating Annex 4.2 Within the 10 mile Exposure Emergency The commitment wording was Company in conjunction with Georgia Power Planning Zone (EPZ), there exisl provisions for alerting standardized and relocated to Company provides NOAA radio receivers for all and providing notification to the public. The state and/or the Site Annex. known establishments (residence, businesses, local aulhorities are responsible for activation of this schools, etc.) within the plume exposure pathway system . EPZ who choose to accept them . Two totally independent public alerting systems are installed for use in the VEGP EPZ. Network of fixed sirens and EAS, NOAA (National Oceanic and Atmospheric Administration) weather warning radio system . Offsite agencies will activate both independent systems in the event of a plant condition requiring public awareness . Following any public alert, commercial radio and television stations, as well as NOAA weather radio (NWR) will be used to provide notification and follow-up emergency information to the population within the EPZ. ne llgg~e EleGtfiG GeReFaliRg PlaRI (l leGP) has 9euelepe9 a P"bliG AleFI aR9 ~leli~Gali9R system 9esigRe9 f<lf GeueFage e! Iha pep"latieR wilhiR Ille EP;i;. +his is aGGemplishe<l "lili~iRg a GembiRalieR ern*ee siFeRs aR9 leRe aleFI Faeies . SiFBRS iRslallee by HeGP haue beeR siled aGGeraiRg le Fe,4A REP 1g GFilefiaR le eRs"Fe Ille FBq"iFSQ 69U8Fage. SiFeR beGalieRs aFe she">A iR Fig"Fe 4.2.11 , Fi*ee SiFeR beGaliaR '4ap . PfeuisiaAs feF lFaAsieAl pep"latieR Reli~GalieR aFe alse iRGl"eee iR Slate aR9 Ge"Rly plaRs. ElS-191 5 to NL-16-0169 Vog tl e (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Appendix 3: During the distribu tion to those Annex 4.2 Within the 1O mile Exposure Emergency The commitment wording was accepting the radios, a brochu re is handed out. Planning Zone (EPZ). there exist provisions for alerting standardized and relocated to and providing notification to the public. The state and/or th e SNC Standard Emergency local authorities are responsible for activation of this Plan and Site Annex. system . Two totally independent public alerting systems are installed for use in the VEGP EPZ: Network of fixed sirens and EAS, NOAA (National Oceanic and Atmospheric Administration) weather warning radio system. Offsite agencies will activate both independent systems in the event of a plant condition requiring public awareness. Following any public alert, commercial radio and television stations. as well as NOAA weather radio (NWR) will be used to provide notification and follow-up emergency infonmation to the population within the EPZ. ns "egUs EIBGIRG GBABFaliAQ PlaAt !VEGP) Ras ds"sleped a P"lllis Alert aAd Ne@satieA system dssigAed feF 68"8f8Q8 el IRe pep"latieA "'itRiA the EPZ. This is assemplished "tili>iAQ a semlliAatieA el lixsd siFBAS aAd teAe alert Fadies . SiFeAs iAstalled lly \IEGP Ra"e lleeA sited asseraiAQ te FEMA REP 1Q Gfitefi8A te BAS"'" the

                                                '"~"iFed se 11 erage. SifBA besatieAs are SR8"'A iA Fig"'"

4.2.' , Fixee SifeA besatieA '~ap . PrevisieAs fer traAsieAI pep"latieA AetilisatieA afe alse iAGl"ded iA State aAd Ce"Aty plaAs. ElS-192 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Appendix 3: That brochure will be redistributed Annex 4.2 Within the 10 mile Exposure Emergency The commitment wording was on an annual basis to NOAA recipients. Planning Zone (EPZ) . there exist provisions for alerting standardized and relocated to and providing notification to the public. The state and/or the Site Annex. local authorities are responsible for activation of this system . Two totally independent public alerting systems are installed for use in the VEGP EPZ: Network of fixed sirens and EAS, NOAA (National Oceanic and Atmospheric Administration) weather warning radio system . Offsite agencies will activate both independent systems in the event of a plant condition requiring public awareness . Following any public alert, commercial radio and television stations, as well as NOAA weather radio (NWR) will be used to provide notification and follow-up emergency information to the population within the EPZ.

                                               +he llggtie !<leGIRG GBABFatiAO PlaAI {l ti.GP) has deuelgped a P"bliG o leFI aAd ~lgliliGali9A syslem desigAed l9F 69"BFBge el Ille pep"lalieA "'illliA Ille i.i:>.:. +his is aGGemplishe<l "lili*iAg a 69mbiASti9A el li*e<l SiFeA6 aA<l leAe aleFI Fa<lies . SiFeAs iAslalled by ll!;;GP ha"e beeA siled aGGQFQiAg le F!;;!4A R!;;P 1Q GFiteFi9A te BAS"FB Iha Fe~"iFeEI 69 .. eFage. SiFeA beGalieAs aFe she"'A iA Fig"'"

4.2.0, Fi*ee SiFBA b9Gali9A *lap . Prn~1isieAs feF h:aAsieAt pep"lali9A AeliliGalieA aFe alse iAGl"eee iA Slate aAe Ge"Aly plaAs . ElS-193

Enclosure 15 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Appendix 3: This brochure includes the following Annex 4.2 Within the 10 mile Exposure Emergency The commitment wording was

..information :

What is NOAA . Planning Zone (EPZ), there exist provisions for alerting and providing notification to the public. The state and/or standardized and relocated to the Site Ann ex.

 . Why NOAA radios are provided .

Information they will rece ive on the NOAA local authorities are responsible for activation of this system .

 .. radio                                         Two totally independent public alerting systems are When th e alert system will be activated . installed for use in the VEGP EPZ:

Who makes NOAA broadcasts Network of fixed sirens and EAS , Where to place the rad io NOAA (National Oceanic and Atmospheric Backup battery power for power failures . Administration) weather warning radio system . . What to do if the NOAA radio doesn't work . How to replace radio batteries . Offsite agencies will activate both independent systems in the event of a plant condition requiring public awareness . Following any public alert, commercial radio and television stations, as well as NOAA weather radio (NWR) will be used to provide notification and follow-up emergency information to the population within the EPZ.

                                                     +Re llagije EleGIFiG GeAeFaliAg PlaAI (l IEGP) Aas de,.elaped a P"bliG OleFl aAd ~latiliGatiaA system desigAed laF GaueFage al tAe pap"laijaA "'itAiA tAe EP<!:. +Ais is aGGamplisAed "lili*iRg a GambiAatiaR al li*ed siFBRS aRd taRe ale Fl radias . SiFeRs iAstalled by ><EGP Aaue beeR sited assamiAg ta l'EMll REP HJ sFiteFiaR ta eRs"'e IAe FB~"iFed sauefage. SiFeR basatiaRs aFe sAa*"R iR l'ig"Fe 4.:!. o, l'i*ed SiFeA basaliaR Map . Pm~iisiaAs fGF lraAsieAl pap"latiaR RatilisatiaR aFe alsa iRsl"ded iR State aRd Ga"Rty plaRs.

Appendix 3: Public information will be distributed EP G.8 The goal of the public information program is to The commitment wording was on an annual basis to the NOAA radio recipients. acquaint the general public with the emergency plans for standardized and relocated to the operation of APC/GPC nuclear plants, as appropriate , the SNC Standard Emergency and actions they should in the event of a plant emergency. Plan . Emerg ency Information is disseminated each calendar year for residents and transients in the plume exposure pathway Emergency Planning Zone . ElS-194 5 to NL-16-01 69 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Appendix 3: SNC will replace an y defective Annex 4.2 The system maintenance requirements for the The commitment wording was radios upon request or discovery that the radi os Tone Alert Radio System are contained in the FEMA standardized and re located to are defective. approved System Design Report. Specifically, Vogtle the Site Annex. maintains a database of those assigned tone alert radios and perfonms an annual telephone survey documenting the adequacy of distribution . Tl'le Veg~e i;;1estRG GeAeratiAg PlaAt (l 1i;;GP) l'las de¥eleped a P"blis "lert aAd ~le@satieA system desigAed f<lr se"erage er tl'le pep"latieA ";ll'liA tl'le i;;pz. Tl'lis is assemplisRed "tiliziAg a sembiAalieA er fi*ed sireAs aAd teAe alert radies . SireAs iAstalled by 11 i;;GP Ra"e beeA siled asserdiAg te l'i;;MA Ri;;P 1Q GRteReA te eAs"re tl'le req"ired Ge"erage . SireA besalieAs are sl'le"<A iA l"ig"re 4.2.* , l='i*ed SireA besatieA Map . Pre,,isieAs f<lr traAsieAl pep"latieA AelifisatieA are alse iAGl"ded iA State aAd Ce"Aly plaAs. Appendix 3: SNC will also annually distribute Annex 4.2 The system maintenance requirements for the The commitment wording was replacement batteries to all recipients of tone Tone Alert Radio System are contained in the FEMA standardized and relocated to alert radios . approved System Design Report. Specifically, Vogtle the Site Annex. maintains a database of those assigned tone alert radios and perfonms an annual telephone survey documenting the adequacy of distribution . TRe "eg~e i;;1eslRs GeAeratiA8 Pia Al (l 1 i;;GP) l'las de,,eleped a P"blis *1ert aAd ~letifisatieA system desigAed f<lr severage er tRe pep"latieA "'itlliA tRe i;;Pz. TRis is assemplisl'led "tiliziAg a sembiAatieA er fi*ed sireAs aAd leAe alert radies . SireAs iAslalled by 11i;;GP Ra"e beeA sited asserdiAg le ""'1A Ri;;P 11l GRteReA le eAs"re tRe req"ired seyerage. SireA besatieAs are sRe"*A iA l"ig"re 4.2.* , l"i*ed SireA besatieA '1ap . Pr<>>*isieAs f<lr traAsieAl pep"latieA AetifisatieA are alse iAGl"ded iA State aAd Ce"Aly plaAs . ElS-195 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Appendix 3: SNC will maintain a register of all Annex 4.2 The system maintenance requirements for the The commitment wording was radio recipients. Tone Alert Radio System are contained in the FEMA standardized and relocated to approved System Design Report. Specifically, Vogtle the Site Annex. maintains a database of those assigned tone alert radios and performs an annual telephone survey documenting the adequacy of distribution . ne 11egUe EleGIAG GeAeratiAg PlaAt p'EGP) has de" eleped a P"bliG *1ert aAd ~let1fisatieA system desigAed klr Ge"erage el the pep"latieA "*ithiA the EPZ. This is aGGemplishes "lili*iAg a GembiAatieA ernxes sireAs aAs teAe alert rasies . SireAs iAstalled by "EGP ha<<e beeA sites aGGereiAg le FEM,A, REP 1Q 6AleFieA le eA6"re the re~"ires Ge<<erage. SireA beGatieA6 are she""' iA Fig"re 4 .2 .** , Fixes SireA beGalieA '4ap . Pre**isieAs klr traAsieAI pepwlatieA AetifiGatieA are alse iAGlwded iA State aAd CewAty plaAs. Appendix 3: The Emergency Preparedness staff Annex 4.2 The system maintenance requirements for the The commitment wording was distributes tone alert radios to any new residents Tone Alert Radio System are contained in the FEMA standardized and relocated to and updates the register of radio recipients approved System Design Report. Specifically, Vogtle the Site Annex. periodically. maintains a database of those assigned tone alert rad ios and performs an annual telephone survey documenting the adequacy of distribution The "egUe Ele6IA6 GeAeratiAg PlaAt (HEGP) has de<<eleped a PwbliG *1ert aAd MetifiGatieA system sesigAes fer Ge*.. erage el the pepwlatieA '*AllliA the EPZ. This is assemplishes wtili*iAg a sembiAatieA ef fixed sireAs aAs teAe alert rasies. SireAs iAstalled by \IEGP ha"e beeA sites assereiAg te FEW' REP 1Q sFiteFieA te eAswre the re~wired Ge"erage. SireA besatieAs are shewA iA Figwre 4 .2. 11 , Fixes SireA beGalieA Map . PreuisieR6 klr traAsieAI pepwlatieA AelifisatieA are alse iAGlwsed iA State aAd CewAty plaAs . ElS-196 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Appendix 3: A survey of the Burl<e County portion Annex 4.2 Alert and Notification System (ANS) (SEP The commitment wording was of the plume EPZ will be made annually by the E.2.5) standardized and relocated to Emergency Preparedness staff to assure that the The system maintenance requirements for the Tone Alert the Site Annex. list of any such residents is current. Radio System are contained in the FEMA approved System Design Report. Specifically, Vogtle maintains a database of those assigned tone alert radios and performs an annual telephone survey documenting the adequacy of distribution . In the event of an emergency declaration at the VEGP, DOE-Savannah River Site has agreed to provide prompt notification of all persons on the SRS within VEGP's plume exposure pathway EPZ. The Alert and Notification System (ANS) description is provided in the FEMA approved Alert and Notification System Design Report located in the SNC document management system .

                                                 **~tRiR tRe PIYFRe EMp9SYFe EFReFgeRsy PlaRRiRg Z9Re (EPZ) lRBFB el<ist pFe"isi9RS leF aleFtiRg aR<l pFe"i<liRg RelinGatieR te tRe pYblis. TRe slate aR<l 'GF 19681 aYtReFities aFe FespeRsible leF astiuatieR el tRis systeFR.

TRe "egtle elestFis GeReFatiRg PlaRt (HeGP) Ras

                                                 <levelepe<l a PYblis AleFt aA<l ~letifiGatieA systeFR eesigAee feF 69"eFage el tRe pepylati9A witRiA tRe EPZ. This is asseFRplisRe<l wtiliziAg a seFRbiAatieA el fiMe<l siFeAs aR<l leAe aleFI rallies . SiFeAs iRslallee by "EGP Ra"e beeR sited asseF<liAg te 1"!0'4 ReP 1Q sFiteFieR kl eASWFe IRe Fe~wiFee se"eFage. SiFeA beGatieAs aFe SR9"'A iA l'igwFe 4.2. " , l'iKee SiFeA besatieA '4ap . Prn"isieA6 l9F lraAsieAI pepwlatieA Aetifisati9A aFe alse iAslYeee iA State aAe CewAty plaAs.

IA tt<e e"eAt el aA eFReFgeRsy eeslaFatieA at tRe "EGP, [)GE Sa"aAAaR Ri"eF Sile Ras agFeee 19 PF9"iee l9F tRe prnFRpt AetifisatieA el all peF&eAs 9A tile SRS *dtRiA "EGP's plYFRe eKp9SYF9 patRl'*ay EPZ. A lwll "left aAe ~letifisatieA SysteFR ("~IS) eessFiptieA is pFe*<ieee iA !Re l'EM" appFe11ee "left aAe NetifisatieA SysteFR [lesigR RepeFI (MIS VEGP QQ1) leGatee iA IRe S~IC eesYFReAt FRaAageFReRt systeFR . ElS-198 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Voglle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Appendix 3: Rather, annual surveys of the entire Annex 4.2 The system maintenance requirements for the The commitment wording was South Carolina portion of the plume EPZ will be Tone Alert Radio System are contained in the FEMA standardized and relocated to made directly by the Emergency Preparedness approved System Design Report. Specifically, Vogtle the Site Annex. Staff. maintains a database of those assigned tone alert radios and performs an annual telephone survey documenting the adequacy of distribution . In the event of an emergency declaration at the VEGP , DOE-Savannah River Site has agreed to provide prompt notification of all persons on the SRS within VEGP's plume exposure pathway EPZ. The Alert and Notification System (ANS) description is provided in the FEMA approved Alert and Notification System Design Report located in the SNC document management system .

                                                +Re Heg~e ele6IA6 GeAeFaliAQ PlaAI {l £!;GP) Ras ee .. elepee a P"blis Aleft aAe Msti~salieA system eesigAee feF se"eFage ef IRe pep"latieA uqlRiA IRe eP.:. +Ris is assemplisRee "lili*iA§ a sembiAalieA ef ~*ee siFeAs aAe leAe aleft Faeies . SiFeAs iAslallee by HEGP Ra"e beeA siled asseF<liAg le ~EMA REP 10 sFileFieA le 9AS"F9 IR9 F9~"iFee GeHeFage. SiFeA besalisAs aFe 6R8""' iA l"ig"FS 4.2 .*0., ~i*ee SiFeA besalisA Map . PFB"isieAs feF IFaAsieAI pep"lalisA Asti~salisA aFe alse iAsl"eee iA Stale aAe Gs"Aly plaAs .

El S-199 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Appendix 3: The effecUveness of the tone alert Annex 4.2 The system maintenance requirements for the The commitment wording was radios will be tested and evaluated at least once Tone Alert Radio System are contained in the FEMA standardized and relocated to a year in accordance with implementing approved System Design Report. Specifically. Vogtle the Site Annex. procedures . maintains a database of those assigned tone alert radios and performs an annual telephone survey documenting the adequacy of distribution .

                                                 +Re Heg~e !OleGIFiG GeAeFatiAg PlaAI (lleGP) Ras de.,eleped a P"blis AleFI aAd Neti~satieA system desigAed leF 69.,eFage el !Re pep"latieA witlliA tRe ePi:. +Ris is assemplisRed "tili~iAg a sembiAalieA efli*ed siFeAs aAd teAe aleFI Fadies . SiFeAS iAslalled by VeGP Ra"e beeA siled aGG9FdiAg te "'"'~A ReP     rn GFileFieA le 8R6"Fe !Re Feq"iFed GS"eFage . SiFeA besatieAs aFe SR9"'R iA >'ig"Fe 4.2.A, ~i*ed SiFeA besatieA Map . ~FQlli6iSR6 tGF lFaRsieFll pepwlalieA Aeli~GatieA aFe alse iAGlwded iA Stale aAd GewAly plaAs.

Appendix 3: The testing and maintenance of the EP E.2.5.2 Annually the system will be activated in the The commitment wording was public alerting sirens in the VEGP EPZ are the normal mode. Advance notice of the test will be provided standardized and relocated to responsibility of VEGP. to the public. Activation of sirens will be verified by the the SNC Standard Emergency system . Reports of siren failures will be investigated and Plan. repaired by the respective SNC site. Unsatisfactory conditions detected by any means will be promptly repaired . State and local emergency management Plans and procedures detail the Prompt Notification System (PNS) activation process in addition to the information provided in the Emergency PlanState aAd besal emeFgeAGY maAagemeAI detail PFempt ~leti~GalieA System (P~IS) aGlivalioo, Activation of the alert and notification system (ANS) is discussed in the offsite agencies specific emergency response plans. ElS-200 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Appendix 3: The maintenance program will EP E.2.5.2 Annually the system will be activated in the The commitment wording was consist of both periodic routine checks and , as normal mode. Advance notice of the test will be provided standardized and relocated to required , corrective maintenance. to the public. Activation of sirens will be verified by the the SNC Standard Emergency system . Reports of siren failures will be investigated and Plan . repaired by the respective SNC site . Unsatisfactory conditions detected by any means will be promptly repaired . State and local emergency management Plans and procedures detail the Prompt Notification System (PNS) activation process in addition to the information provided in the Emergency PlanState aRd besal eFReFgeRsy FRaRaQ9FR8RI eetail PF0FRpl MelifisatieA SysteFR (PMS)

Activation of the alert and notification system (ANS) is discussed in the offsite agencies specific emergency response plans. Appendix 3: This program will be under the EP E.2.5.2 Annually the system will be activated in the The commitment wording was direction of the VEGP emergency preparedness normal mode. Advance notice of the test will be provided standardized and relocated to coordinator. to the public. Activation of sirens will be verified by the the SNC Standard Emergency system . Reports of siren failures will be investigated and Plan . repaired by the respective SNC site . Unsatisfactory conditions detected by any means will be promptly repaired. State and local emergency management Plans and procedures detail the Prompt Notification System (PNS) activation process in addition to the information provided in the Emergency PlanStale aRd besal eFRefjjeAsy FRaRaQ9FR8AI eetail PFeFRpl ~lelifisaijeA SysleFR (PMS)

Activation of the alert and notification system (ANS) is discussed in the offsite agencies specific emergency response plans . ElS-201 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Appendix 3: The periodic routine maintenance EP E.2.5.2 Annually the system will be activated in the The commitment wording was program will be based on the manufacturers' normal mode. Advance notice of the test will be provided standardized and relocated to recommendations and experience gained with to the public. Activation of sirens will be verified by the the SNC Standard Emergency the installation . system . Reports of siren failures will be investigated and Plan . repaired by the respective SNC site . Unsatisfactory conditions detected by any means will be promptly repaired . State and local emergency management Plans and procedures detail the Prompt Notification System (PNS) activation process in addition to the information provided in the Emergency PlanState aRe besal 9Fll9FQ9RGy F!laAaQ9Fll9Al eetail PFeFllpl ~leti~satieA SysleF!l (PNS)

Activation of the alert and notification system (ANS) is discussed in the offsite agencies specific emergency response plans. Appendix 3: It will consist of quarterty inspections EP E.2.5.2 Annually the system will be activated in the The commitment wording was to verify the proper physical condition of each normal mode. Advance notice of the test will be provided standardized and relocated to siren location and checks to verify the proper to the public. Activation of sirens will be verified by the the SNC Standard Emergency operation of each location utilizing the built-in test system . Reports of siren failures will be investigated and Plan . and monitoring features of this system . repaired by the respective SNC site . Unsatisfactory conditions detected by any means will be promptly repaired . State and local emergency management Plans and procedures detail the Prompt Notification System (PNS) activation process in addition to the information provided in the Emergency PlanState aRe basal eF!leFQeAsy F!laRaQeF!leAt eetail Pr<lF!lpt ~leti~saijeR SysleF!l (PMS)

Activation of the alert and notification system (ANS) is discussed in the offsite agencies specific emergency response plans. ElS-202 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Appendix 3: The periodic test program will EP E.2.5.2 Annually the system will be activated in the The commitment wording was consist of a weekly silent test, from the county normal mode. Advance notice of the test will be provided standardized and relocated to activation points, and an annual full scale to the public. Activation of sirens will be verified by the the SNC Standard Emergency activation of the system . system . Reports of siren failures will be investigated and Plan . repaired by the respective SNC site. Unsatisfactory conditions detected by any means will be promptly repaired. State and local emergency management Plans and procedures detail the Prompt Notification System (PNS) activation process in addition to the information provided in the Emergency PlanSlale aRG beGal emeFg9R6\' maAagemeAI Gel ail Prnmpl ~ l elifiGalieA Syslem (P~IS) aGIWalioo, Activation of the alert and notification system (ANS) is discussed in lhe offsite agencies specific emergency response plans. Appendix 3: The weekly silent test will consist of EP E.2.5.2 Annually the system will be activated in the The commitment wording was activation of the siren from the County EOG. normal mode. Advance notice of the test will be provided standardized and relocated to to the public. Activation of sirens will be verified by the the SNC Standard Emergency system . Reports of siren failures will be investigated and Plan . repaired by the respective SNC site . Unsatisfactory conditions detected by any means will be promptly repaired . State and local emergency management Plans and procedures detail the Prompt Notification System (PNS) activation process in addition to the information provided in the Emergency PlanSlale aAG beGal eme"i19AGy maAagemeAI 9elail PF<lmpl MelifiGa~eA Syslem (P~IS) aGIWalioo, Activation of the alert and notification system (ANS) is discussed in the offsite agencies specific emergency response plans. ElS-203 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Appendix 3: Once each year the system will be EP E.2.5.2 Annually the system will be activated in the The commitment wording was activated from the associated county EOC in the nonmal mode. Advance notice of the test will be provided standardized and relocated to nonmal mode. to the public. Activation of sirens will be verified by the the SNC Standard Emergency system . Reports of siren failures will be investigated and Plan . repaired by the respective SNC site. Unsatisfactory conditions detected by any means will be promptly repaired . State and local emergency management Plans and procedures detail the Prompt Notification System (PNS) activation process in addition to the infonmation provided in the Emergency PlanSlate aRe basal emefgeRsy maRagemeRt eetail Prempt Neti~ salieR System (P~IS)

Activation of the alert and notification system (ANS) is discussed in the offsite agencies specific emergency response plans. Appendix 3: Advance notice of the test will be EP E.2.5.2 Annually the system will be activated in the The commitment wording was provided to the public. nonmal mode. Advance notice of the test will be provided standardized and relocated to to the public. Activation of sirens will be verified by the the SNC Standard Emergency system . Reports of siren failures will be investigated and Plan. repaired by the respective SNC site.Unsatisfactory conditions detected by any means will be promptly repaired. State and local emergency management Plans and procedures detail the Prompt Notification System (PNS) activation process in addition to the infonmation provided in the Emergency Plan Slate aRe besal emefll&Rsy maRagemeRt eelail Prempt ~leli~salieR System (PMS)

Activation of the alert and notification system (ANS) is discussed in the offsite agencies specific emergency response plans. ElS-204 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Appendix 3: Activation of each siren will be EP E.2.5.2 Annually the system will be activated in the The commitment wording was verified normal mode. Advance notice of the test will be provided standardized and relocated to by the WSMRFC . to the public. Activation of sirens will be verified by the the SNC Standard Emergency system . Reports of siren failures will be investigated and Plan. repaired by the respective SNC site . Unsatisfactory conditions detected by any means will be promptly repaired . State and local emergency management Plans and procedures detail the Prompt Notification System (PNS) activation process in addition to the information provided in the Emergency PlanSlale aA<J besal emeFgeAsy maAagemeAI detail Pmmpt MelilisalieA Syslem (PMS) aGIWatioo, Activation of th e alert and notification system (ANS) is discussed in the offsite agencies specific emergency response plans. Appendix 3: Reports of siren failures or EP E.2.5.2 Annually the system will be activated in the Th e commitment wording was inadequate coverage will be investigated by normal mode. Advance notice of the test will be provided standardized and relocated to VEGP. to the public. Activation of sirens will be verified by the the SNC Standard Emergency system . Reports of siren failures will be investigated and Plan. repaired by the respective SNC site. Unsatisfactory conditions detected by any means will be promptly repaired . State and local emergency management Plans and procedures detail the Prompt Notification System (PNS) activation process in addition to the information provided in the Emergency PlanSlale aA<J besal emeFgeAsy maAagemeAI <Jelail PFGmpt ~lelilisalieA Syslem (P~IS) aGIWatioo, Activation of the alert and notification system (ANS) is discussed in the offsite agencies specific emergency response plans. ElS-205 5 to NL-16-0 169 Vogtle (Units 3 & 4) Justification Matrix Cu rrent Vogtle 3&4 Emergency Pla n Revised SNC Emergenc y Plan Justification Revision 3 Appendix 3: Unsatisfactory conditions detected EP E.2.5.2 Annually the system will be activated in the The commitment wording was by any means will be promptly repaired by nonmal mode. Advance notice of the test will be provided standardized and relocated to Southern Company Services maintenance or to the public. Activation of sirens will be verified by the the SNC Standard Emergency contract personnel under the direction of the system. Reports of siren failures will be investigated and Plan. VEGP emergency preparedness coordinator. repaired by the respective SNC site. Unsatisfactory conditions detected by any means will be promptly repaired . State and local emergency management Plans and pri\cedures detail the Prompt Notification System (PNS) activation process in addition to the infonmation provided in the Emergency PlanState aAa b9Gal emefgeAGy maAagemeAt aetail Prnm~t ~19ti~Gati9A System (PNS) aGlivali<m, Activation of the alert and notification system (ANS) is discussed in the offsite agencies specific emergency response plans. Append ix 4: All The specific list of Emergency Equipment was deleted from the SNC Standard Emergency Plan and Annex. The Plan/Annex commit to the functions the equipment is needed to support. Specific equipment changes on a regular basis. The lack of needed equipment would affect the ability to perfonm the fu nction . The specific equipment needed to adequately perfonm the function is not appropriate at Plan level. ElS-206 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Curre nt Vogtle 3&4 Emergenc y Plan Revised SNC Emergency Plan Justification Revision 3 Appendix 5: Memorandum of Agreement with EP 1.7 Department of Energy (DOE) - Savannah River The commitment wording was Department of Energy - Savannah River Site (SRS) (SEP A.2.5) standardized and description of The DOE-Savannah River Site (SRS) will provide the expected response included as necessary response within the SRS reservation in required by 10 CFR 50 Appendix accordance with the SRS Emergency Plan . The DOE will E and relocated to the Site exercise overall responsibility, jurisdiction , and authority Annex. for conducting response operations on the Savannah River Site to protect the health and safety of SRS personnel. DOE will provide for emergency notification and. as needed, evacuation , monitoring , decontamination , and immediate lifesaving medical treatment of non SRS personnel on the Savannah River Site . DOE will also provi de access control for SRS areas . Append ix 6: All EP J .6 Evacuation Time Estimates (ETE)An independent Th e commitment wording was ETE report has been performed for SNC operated nudear standardized and relocated to power plants, which provides estimates of the time the SNC Standard Emergency required to evacuate resident and transient populations Plan. surrounding the plant for various times of the year under favorable and adverse conditions. ETEs for evacuation of the plume exposure EPZ surrounding SNC operated nuclear power plants are summarized in the site-specific Annex and detailed in the ETE report. Annex Append ix A Appendix 7: All The Emergency Operations Facility has been Removed specific statement established consistent with NUREG 0696 referencing NUREG -0696 as guidelines SER #SECY-04-0236 addresses the establishment and NRC approval of the EOF. Appendix 7 A.3: Upon notification of an ALERT EP H.2 .1 Emergency Operation s Facility The commitment wording was or higher classification or as directed by the ED , The EOF is procedurally required to be activated within 75 standardized and relocated to the EOF will be activated as described in minutes following the dedaration of an Alert or higher the SNC Standard Emergency emergency implementing procedures . classificationSlalliA@ aA9 aGtiualieA el ltle !;Qi;: is Plan . maA9alept *peA 9eGlaralieA el aA 0 1ert er Ri@tler GlassifiGalieA . ElS-207 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revis ion 3 Appendix 7 A .3 : Offsite support personnel and EP 8 .3.1.3 EOF Support Coordinator The commitment wording was equipment will be dispatched to the site The Support Coordinator reports to the EOF Manager. standardized and relocated to Operations Support Center (OSC) or Technical The duties and responsibilities of the Support Coordinator the SNC Standard Emergency Support Center (TSC) upon request from the in the EOF include providing oversight of the News Writer, Plan . specific site Emergency Director. providing assistance to the Support Coordinator in th e TSC for ordering equipment and materials needed and logistics arrangements for support personnel called in to assist in the emergency, including communications hardware , transportation , food , and lodging. Appendix 7 A .3: The corporate emergency The commitment wording was response organization will provide offsite standardized and relocated to emergency response support and resources to the SNC Standard Emergency SNC sites on a twenty-four seven basis until the Plan. emergency has been terminated. The SNC Standard Emergency Plan integrates the Corporate response as part of the trained and qualified ERO. A separate statement is not necessary. Appendix 7 A .3: The EOF will be activated for an EP H.2.1 Emergency Operations Facility The commitment wording was ALERT , SITE AREA or GENERAL emergency The EOF is procedurally required to be activated within 75 standardi zed and reloca ted to classifications. minutes following the declaration of an Alert or higher the SNC Standard Emergency classificationStalliAg aAa asij .. aijeA el Ille IOG~ is Plan . maAaalel)' ~peA aeslaratieA ef aA *1ert er lligller slassi~salieA . Appendix 7 A.3: This facility (EOF) will be EP H.4 : Although the response time will vary due lo The commitment wording was operational within abou t an hour of the initial factors such as weather and traffic conditions, a goal of 75 standardized and relocated to notification . minutes for minimum staffing, followi ng the declaration of the SNC Standard Emergency an Alert or higher emergency classification , has been Plan.The change in activation established for ERO personnel responding to plant times will be j ustified separately emergency facili ties including the TSC , OSC and EOF . in the Technical Analysis Section of this License Amendment Request. ElS-208 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Appendix 7 C.1: The On-call EOF Manager will EP E.2.1: The Emergency Director is responsible for The commitmen t wording was be notified of all emergencies classified at any classifying an event into the appropriate emergency standardized and relocated to SNC site. classification and then notifying on site personnel of the the SNC Standard Emergency emergency declaration in accordance with site specific Plan . procedures . This notification may consist of the use of the plant emergency alann , announcements over the plant public address system , or activation of the recall system. Emergency Response personnel respond to their assigned Emergency Response Facilities upon notification of an Alert or higher classification level. In the event of a Design Basis Threat, personnel may be directed to respond to alterna tive facilities . Appendix 7 D.1: Th e EOF is located in EP H.2 .1: The EOF is a dedicated facility located in The commitment wording was Binningham, Alabama and serves as the EOF for Binningham , Alabama , and serves as the EOF for SNC standardized and relocated to all SNC sites (VEGP , FNP , and HNP) . sites (VEGP . FNP , and HNP). the SNC Standard Emergency Plan. Appendix 7 D.1: The EOF will be activated as EP H.2.1 : The EOF is procedurally required to be activated The commitment wording was prescribed in the site specific Emergency Plan within 75 minutes following the declaration of an Alert or standardized and relocated to implementing procedures. higher classificationStaffiAg 8Ae aGtiHatieA el IA9 eGI" is the SNC Standard Emergency maAeat<JFy "~"" eeGlaralieA ef aA AleFt er tligtler Plan . Glassi~GatieA. Appendix 7 D.1: Plant systems infonnation , EP H.5.1: Meteorological infonnation is displayed in the The commitment wording was radiological data , and meteorological data are CR , TSC , and EOF. standardized and relocated to provided via the SNC Integrated Data Oisplay EP H.5.3.2: The SPDS parameters are available during the SNC Standard Emergency System to EOF personnel. nonnal and abnonnal operating conditions in the Control Plan . Room , TSC , and EOF . Appendix 7 D.1: Oata displays are located in the EP H.5.1: Meteorological infonnation is displayed in the The commitment wording was main caucus area of the EOF , dose assessment CR, TSC, and EOF. standardized and relocated to area, plant status area , and engineering area EP H.5.3 .2: The SPDS parameters are available during the SNC Standard Emergency within the facility. nonnal and abnonnal operating conditions in the Control Plan . Room , TSC , and EOF . ElS-215

Enclosure 15 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Appendix 7 D.1: Upon activation of the EOF , The SNC Standard Emergency Corporate personnel will provide staffing 24 Plan incorporates the EOF as hours per day until directed otherwise by the part of the general ERO Emergency Director. supporting ongoing operations. The separate statement is not required . Appendix 7 D.1: The EOF is a dedicated facility . EP H.2.1: The EOF is a dedicated facility located in The commitment wording was Birmingham , Alabama , and serves as the EOF for SNC standardized and relocated to sites (VEGP, FNP, and HNP). the SNC Standard Emergency Plan . Appendix 7 D.1: Back-up power for the EOF is EP H.2.1: .Backup power for the EOF is supplied by The commitment wording was supplied by onsite diesel generation . All on site diesel generation . Essential equipment is backed standardized and relocated to essential equipment is backed up by the diesel up by the diesel generation system . the SNC Standard Emergency generation system . Plan. Appendix 7 D.1: The following records or EP H.2.1: The EOF is located at SNC Corporate The commitment wording was .. information are available : Technical Specifications Headquarters with the document management section for SNC . The following records or information are available: standardized and relocated to the SNC Standard Emergency

.. Selected plant operating procedures Emergency Plans Technical Specifications.

Selected plant operating procedures. Plan.

 .. Emergency Plan Implementing Procedures FSARs.

Emergency Plans. Emergency Plan Implementing Procedures. . State and local emergency respon se plans . Savannah River Site Emergency Plan. Appendix 7 D.2: In the unlikely event that Final Safety Analysis Reports (FSARs). Egress of personnel from the

                                                                                                                                               .1 i Formatted : Indent: Lett: 0.3", No bullets or numberi~
                                                                                                                                                                                                  ]

individuals should need to respond to the EOF EPZ fall under the provisions of from within the 10 mile EPZ of any SNC plant, the State Plan . A statement in they would be surveyed prior to release by local the SNC Standard Emergency emergency authorities. Plan is not required . Appendix 7 D.2 : In the unlikely event that the The corporate EOF is located EOF becomes uninhabitable, resources and outside the reasonable personnel will be transferred to the Corporate expectation for damage based Headquarters of Alabama Power Company. on a naturally occurring event beyond the design basis of the site. Should the EOF be so damaged the site can re-assume control of the event. ElS-218

Enclosure 15 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Appendix 7 E.1: Provisions have been made to EP F.1.4: SNC has established communications systems The commitment wording was have direct NRC FTS lines in the TSC and the to provide reliable communications with Federal standardized and relocated to EOF during an emergency. emergency response organizations. Communications the SNC Standard Emergency with Federal agencies is primarily by commercial Plan . telephone , with alternate systems being used as needed . Communication with the Nuclear Regulatory Commission (NRC) is via the Federal Tele~RsRe Telecommunications I System (FTS) telephone network which connects the SNC plant site and EOF with the NRC Operations Center. Appendix 7 F.2: The GPC Central Laboratory has EP H.6.3 : External facilities for counting and analyzing The commitment wording was personnel and facilities available to provide samples , dosimetry processing , can be provided by the standardized and relocated to offsite monitoring , sample analysis, and other SNC operated plants including the GPC Central the SNC Standard Emergency dosimetry processing for the affected site. Laboratory, state , federal or contracted laboratories. Plan. Outside analytical assistance may be requested from state and federal agencies , or through contracted vendors . The DOE, through the Radiological Assistance Program (RAP) has access to any national laboratory. Appendix 7 G.1.1: Corporate personnel identified EP 0 .4.1: ERO members will receive Emergency Plan The commitment wording was in the Emergency Response Organization training on an annual basis. Personnel identified receive standardized and relocated to receive training . training appropriate to their position in the areas of: Accident assessment. the SNC Standard Emergency Plan .

                                                         . Accident mitigation .

Notifications . Emergency Classifications . Protective Action Recommendations . Appendix 7 G.1.1: The training consists of

                                                       . Emergency Action Levels .

Emergency Exposure Control. EP 0 .4: SNC ERO personnel who are responsible for The commitment wording was familiarization with the Site Emergency Plans and implementing this plan receive specialized training . The standardized and relocated to applicable emergency implementing procedures training program for emergency response personnel is the SNC Standard Emergency required to carry out their specific functions . developed based on the requirements of 10 CFR 50, Plan . Appendix E and position specific responsibilities . ElS-219 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Appendix 7 G.1.1: The corporate emergency EP 0 .1 Training The SNC Standard Emergency planning coordinator(s) are responsible for The ERO Training Program assures the training, Plan maintains the commitment assuring that training is conducted for corporate to conduct the training for qualification, and requalifi cation of individuals who may emergency response personnel each calendar corporate personnel. Who year. be called on for assistance during an emergency. Training conducts the training may will be evaluated in accordance with the requirements of depend on specific areas of Systematic Approach to Training practices to ensure expertise and provides no effectiveness and in order to identify weak or deficient purpose in th e SNC Standard areas that need correction . Emergency Plan . Specific emergency response task training , prepared for response positions. is described in lesson plans and study guides. The lesson plans, study guides, and written tests are contained in th e ERO Training Program . Responsibilities for implementing the training program are contained in plant procedures. ElS-220 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Appendix 7 G.1.1: A training matrix for corporate EP 0 .1 Training The commitment wording was personnel assigned to the ERO is shown in Table The ERO Training Program assures the training, standardized and relocated to A7-2 , and training course summaries are the SNC Standard Emergency qualification, and requalification of individuals who may presented in Table A7-3 . Plan. be called on for assistance during an emergency. Training will be evaluated in accordance with the requirements of Systematic Approach to Training practices to ensure effectiveness and in order to identify weak or deficient areas that need correction . Specific emergency response task training , prepared for response positions, is described in lesson plans and study guides. The lesson plans, study guides , and written tests are contained in the ERO Training Program . Responsibilities for implementing the training program are contained in plant procedures. EP 0 .4.1 : ERO members will receive Emergency Plan training on an annual basis. Personnel identified receive training appropriate to their position in the areas of: Accident assessment. Accident mitigation . Notifications .

                                                  .. Emergency Classifications .

Protective Action Recommendations . Appendix 7 G.1.2: Drills/ exercises will be

                                                    . Emergency Action Levels .

Emergency Exposure Control. The SNC Standard Emergency conducted each calendar year to test the Plan incorporates the EOF into performance of implementing procedures , the Site Plans. Separate personnel , and emergency equipment. These commitment statements for EOF drills/exercises will be conducted with each SNC activation are no longer required . site. Appendix 7 G.1.2: EOF activation is required at The SNC Standard Emergency least 3 times annually (1 scenario per site per Plan incorporates the EOF into year) . the Site Plans. Separate commitment statements for EOF activation are no longer required . ElS-221 5 to NL-16-0169 V ogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justificat ion Revision 3 Appendix 7 G.1.2: At least 1 activation every 5 ]'1.2.1-l-O Multi-S ite Drill The SNC Standard Emergency I { Formatted: Font: Bold years wi ll require a concurrent EOF support At least once in every five years , a drill involving more Plan incorporates the EOF multi-response for more than one SNC si te. than one SNC site will be conducted demonstrating the site drill requirement into the ability of the Common EOF to effectively implement the Common Plan . Emergency Plan for an event involving more than one site. Appendix 7 G.1.2: Each drill/exercise will test, as a minimum, the communication links and . EP N .1: Drills/Exercises shall: Test the adequacy of timing and content of The commitment wording was standardized and relocated to notification procedures.

                                                      . implementing procedures and methods.

Test emergency equipment and communications the SNC Standard Emergen cy Plan . networks. Test the public notification system , Ensure that emergency organization personnel are familiar with their duties Appendix 7 G.1.2: Provisi ons are made for EP N.4-l-: A formal critique will be performed for exercises, The commitment wording was critique of all drills/exercises . drills. and training tabletops to develop , maintain , or standardized and reloca ted to demonstrate key skills in order to identify weak or deficient the SNC Standard Emergency areas that need correction . Plan. I> leffl'al Glitiqwe sRall be GeRElwsteEl lelleu;Rg tRe Ellillle*eFsise te eualwate tRe ability el eFgaRi*atieRs te FespeREl as FeqwiFeEl iA tRe S~IG StaAElaFEl EmeFgBRGy l'laR aREl site speGi~G EmBFQBAGY l'laA lmplemeRliRQ l'FeGeElwFeS . Glitiqwe items will be eRteFeEl iRte tRe S~IG seFFBsliue astieR pr<igFam as appFepliate. Appendix 7 G.1.2: Critique items will be EP N.4-l-: A formal critique will be performed for exercises . The commitment wording was forwarded to the site emergency preparedness drills, and training tabletops to develop, maintain . or standardized and relocated to coordinator for processing in the site specific demonstrate key skills in order to identify weak or deficient the SNC Standard Emergency corrective action program . areas that need correction . Plan. A leffl'al GFitiqwe sRall be GeRElwsteEl lelle"OAQ tRe ElFilllB*BFGise te eualwate tRe ability el BFQaRi*alieRs te FespeREl as FeqwiFeEl iR tRe SMG StaRElaFEl i;;mergeAGY l'laR aREl site spesi~G EmeFgeRGy l'laR lmplemeRliRQ l'rnsedwFes . GFitiq"e items "'ill be eRteFeEl iRte tRe SNG GBA'estiue astieR pFegFam as appFepFiate . ElS-222

Southern Nuclear Operating Company Joseph M. Farley Nuclear Plant Units 1 and 2; Edwin I. Hatch Nuclear Plant Units 1 and 2; Vogtle Electric Generating Plant Units 1 and 2; Vogtle Electric Generating Plant Units 3 and 4 Enclosure 15 Vogtle Units 3 and 4 Justification Matrix (Marked-Up Pages and Clean Copy) J

                                "I VOGTLE ELECTRIC GENERATING PLANT UNITS 3 & 4 JUSTIFICATION MATRIX Purpose The purpose of this attachment is to identify the commitments in the current Vogtle Electric Generating Plant, Emergency Plan, Revision 3, and compare/identify the equivalent or modified commitment in the integrated Fleet Emergency Plan and Vogtle Unit 3 and 4 Site Annex. Justification for change will be addressed on a commitment by commitment basis for the proposed License Amendment.

5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Preface The Vogtle Electric Generating Plant (VEGP) is a Annex 1.1: The Vogtle Electric Generating Plant (VEGP) The information for Vogtle Units two-unit pressurized water reactor operated by Units 3 and 4 are a two unit pressurized water reactor, 3&4 was relocated to the Site Southern Nuclear Operating Company (SNC). In based upon the Westinghouse AP1000 passive reactor Annex. addition, SNC plans to submit an application for design. The plant site, to include VEGP Units 1-4, is on a a Combined Operating License (COL) for two 3169-acre site located in the eastern portion of Burke additional pressurized water reactor plants, County, Georgia, approximately 23 river miles upstream based from the intersection of the Savannah River with U.S. on the Westinghouse Electric Company, LLC Highway 301. (Westinghouse) AP1000 standard design, on the Annex Figure 1.1.A, 1.1.B VEGP site. The plant is on a 3169-acre site located in the eastern portion of Burke County, Georgia, approximately 23 river miles upstream from the intersection of the Savannah River with U.S. Highway 301, as shown on Figure i. Figure ii shows the site and the locations of existing and proposed buildings on the site. The locations of the VEGP emergency facilities are also shown on Figure ii. ElS-2

Enclosure 15 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 This Emergency Plan (EP) is applicable to Annex 1.1 - Facility Description The commitment wording was existing VEGP Units 1 and 2, as well as the The Vogtle Electric Generating Plant (VEGP) Units 3 and standardized and moved to the proposed 4 are a two unit pressurized water reactor, based upon the Site Annex. WestinghouseAP1000 (AP1000) units (i.e.,. new Westinghouse AP1000 passive reactor design. The plant VEGP Units 3 and 4), and to its environs as site, to include VEGP Units 1-4, is on a 3169-acre site specified by the emergency planning zones located in the eastern portion of Burke County, Georgia, (EPZs) as described below. The plume exposure approximately 23 river miles upstream from the pathway EPZ nominally consists of the area intersection of the Savannah River with U.S. Highway within approximately 10 miles of the plant, and 301. the ingestion exposure pathway EPZ extends to Annex 1.2 Emergency Planning Zones (SEP J.5) -50 miles from the plant. These distances are Annex 1.2.1 Plume Exposure Pathway (SEP J.7) centered on a point midway between the centers The 10-mile Emergency Planning Zone (EPZ) for VEGP of the VEGP Unit 1 and Unit 2 containment approximates a 10-mile radius around the plant site and is buildings for the 10 mile EPZ map. The two EPZs depicted in Figure 1.2.A. Georgia and South Carolina, as are shown in Figures iii and iv, respectively. well as the counties (Burke County in Georgia and Aiken, Barnwell, and Allendale Counties in South Carolina) are located within the plume exposure pathway EPZ. The major portion of the plume exposure pathway EPZ in South Carolina is within the Department of Energy's Savannah River Site (SRS). Annex 1.2.2 Ingestion Pathway (SEP J.7) The area between the 10-mile and 50-mile radius is considered the Ingestion Pathway Zone (IPZ). The 50 mile IPZ is depicted in Figure 1.2.B. Planning for the ingestion exposure pathway is a responsibility of the States of Georgia and South Carolina. More information about the IPZ can be obtained from the States' Radiological Emergency Plans. ElS-3 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Because of the location of VEGP site, the EP

Introduction:

There are also various supporting and The commitment wording was emergency planning and/or protective action complementing emergency plans, including those of standardized and moved to the responsibilities at the state level involves two federal agencies and those for the states of Alabama, SNC Standard Emergency Plan states, Georgia and South Carolina. Georgia, Georgia, South Carolina, and associated counties. and the Site Annex. South Carolina, and the respective counties Annex 1.2 Emergency Planning Zones (SEP J.5) (Burke County in Georgia and Aiken, Barnwell, Annex 1.2.1 Plume Exposure Pathway (SEP J.7) Agencies for which and Allendale Counties in South Carolina) have The 10-mile Emergency Planning Zone (EPZ) for VEGP Memorandum of Agreements are prepared plans for a response to an emergency approximates a 10-mile radius around the plant site and is maintained are now included in at VEGP. These plans describe their respective depicted in Figure 1.2.A. Georgia and South Carolina, as the SNC Standard Emergency responsibilities, authorities, capabilities, and well as the counties (Burke County in Georgia and Aiken, Plan and Site Annex with emergency functions. The major portion of the Barnwell, and Allendale Counties in South Carolina) are descriptions of services/support plume exposure pathway EPZ in South Carolina located within the plume exposure pathway EPZ. The expected in accordance with the is within the U. S. Department of Energy (DOE) major portion of the plume exposure pathway EPZ in requirements of 10 CFR 50 Savannah River Site (SRS). The Department of South Carolina is within the Department of Energy's Appendix E. Energy, Savannah River Operations Office Savannah River Site (SRS). (DOE-SR), pursuant to a memorandum of Annex 1.6 Department of Energy (DOE) - agreement between Georgia Power Company Savannah River Site (SRS) (SEP A.1.4) (GPC), as assigned to SNC, and DOE-SR, will The DOE-Savannah River Site (SRS) will provide the be responsible for all emergency response necessary response within the SRS reservation in actions on the SRS whenever an emergency accordance with the SRS Emergency Plan. The DOE will occurs at the VEGP. The memorandum of exercise overall responsibility, jurisdiction, and authority Agreement is shown in Appendix 4. for conducting response operations on the Savannah River Site to protect the health and safety of SRS personnel. DOE will provide for emergency notification and, as needed, evacuation, monitoring, decontamination, and immediate lifesaving medical treatment of non SRS personnel on the Savannah River Site. DOE will also provide access control for SRS areas. ElS-4 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Within the plume exposure pathway EPZ, Burke Annex 1.2.1 Plume Exposure Pathway (SEP J.7) The commitment wording was County in the State of Georgia has the largest The 10-mile Emergency Planning Zone (EPZ) for VEGP standardized and moved to the resident population. However, the population is approximates a 10-mile radius around the plant site and is Site Annex. small and dispersed. The areas in South Carolina depicted in Figure 1.2.A. Georgia and South Carolina, as that are not federally owned or controlled are well as the counties (Burke County in Georgia and Aiken, along the Savannah River lowlands in Aiken, Barnwell, and Allendale Counties in South Carolina) are Allendale, and Barnwell Counties. The segment located within the plume exposure pathway EPZ. The in Aiken County, approximately 8 to 10 miles major portion of the plume exposure pathway EPZ in north-northwest (NNW) from the VEGP, is part of South Carolina is within the Department of Energy's the Cowden Plantation and has no resident Savannah River Site (SRS). population. The segments to the east-southeast Annex 1.5.1: The area within the plume exposure (ESE), Barnwell and Allendale Counties pathway (EPZ) in the State of Georgia falls within Burke (approximately 9 to 10 miles from the VEGP), are County. The responsibility for overall radiological largely comprised of portions of the Creek emergency response planning rests with the Chairman, Plantation, a horse farm. Within the South Burke County Board of Commissioners. It is the Carolina portion of the plume exposure pathway chairman's responsibility to initiate actions and provide EPZ, the only housing occurs within the Creek direction and control at a level consistent with the specific Plantation in Barnwell County, where there are incident. only a limited number of permanent residences. Annex 1.5.2: Most of the plume exposure pathway EPZ Figure v presents the permanent population within South Carolina falls within the site boundary of the within the plume exposure pathway EPZ. Savannah River Site (SRS). The United States Department of Energy is responsible for the direction and control of all emergency response actions on the SRS.Limited portions of Aiken, Barnwell, and Allendale counties are outside of the SRS but within the plume exposure pathway EPZ ofVEGP. These counties are similarly organized, with the responsibility for overall radiological emergency response planning resting with the Chairman of the County Council in each case. ElS-5 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 The transient population within the plume EP G.8: The goal of the public information program is to The commitment wording was exposure pathway EPZ includes persons in the acquaint the general public with the emergency plans for standardized and moved to the work force at the VEGP and at recreational the operation of APC/GPC nuclear plants, as appropriate, SNC Standard Emergency Plan areas, mainly hunters and fishermen. This and actions they should in the event of a plant and the Site Annex. transient population is generally along the emergency.Emergency Information is disseminated each Savannah River; around the Cowden Plantation calendar year for residents and transients in the plume and Gray's Landing in Aiken County; around exposure pathway Emergency Planning Zone. Creek Plantation in Barnwell and Allendale Annex 2.3.6: Signs and notices providing information to Counties; and at St. Mary's Baptist Church in transients are placed in public recreation areas in the Barnwell County. Figure vi presents the transient plume EPZ such as siren.poles, churches, campgrounds, and special populations within the VEGP plume and the Plant Vogtle Visitors Center. This material will EPZ. include the following information:

How people will be warned of an emergency.
What to do if warned of an emergency.
A list of radio and television stations to tune to for further information.

A VEGP emergency information brochure will be made available within the EPZ to transients at commercial establishments, churches, motels, hunting clubs, Creek and Cawden Plantations, the Plant Vogtle Visitors Center, and through residents whose land is used by nonresidents (e.g., the occasional nonresident hunter). Outside the EPZ, the brochure will be made available to timber company offices for distribution to their employees who enter the EPZ on Company business, and to the Waynesboro Office of the Agriculture Stabilization & Conservation Service for distribution to farmers who farm, but do not reside, in the EPZ. ElS-6 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 The EPZ for ingestion exposure for the VEGP is Annex 1.2.2 Ingestion Pathway (SEP J.7) The commitment wording was shared with the Department of Energy's The area between the 10-mile and 50-mile radius is standardized and moved to the Savannah River Site. The ingestion pathway EPZ considered the Ingestion Pathway Zone (IPZ). The 50 Site Annex. includes an area within about 50 miles of the mile IPZ is depicted in Figure 1.2.B. Planning for the Savannah River Site and the VEGP site. The ingestion exposure pathway is a responsibility of the ingestion pathway EPZ for the VEGP is States of Georgia and South Carolina. More information contained within the States of Georgia and South about the IPZ can be obtained from the States' Carolina. It includes the Counties of Bullock, Radiological Emergency Plans. Burke, Candler, Columbia, Effingham, Emanuel, Glasscock, Jefferson, Jenkins, Johnson, Lincoln, McDuffie, Richmond, Screven, Warren, and Washington in Georgia, and the Counties of Aiken, Allendale, Bamberg, Barnwell, Colleton, Edgefield, Hampton, Jasper, Lexington, McCormick, Orangeburg, and Saluda, in South Carolina. Planning for the ingestion exposure pathway is a Annex 1.2.2 Ingestion Pathway (SEP J.7) The commitment wording was responsibility of the States of Georgia and South The area between the 10-mile and 50-mile radius is standardized and moved to the Carolina. Details of ingestion pathway considered the Ingestion Pathway Zone (IPZ). The 50 Site Annex. emergency planning are contained in the mile IPZ is depicted in Figure 1.2.B. Planning for the respective State emergency plans. ingestion exposure pathway is a responsibility of the States of Georgia and South Carolina. More information about the IPZ can be obtained from the States' Radiological Emergency Plans. ElS-7 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 The VEGP Emergency Plan is designed to be EP Intro: The SNC Emergency Plan was developed with The commitment wording was compliant with 10 CFR 50.47, Emergency plans, the guidance of NUREG-0654, FEMA-REP-1, Revision 1, standardized and disseminated and 10 CFR 50 Appendix E, Emergency "Criteria for Preparation and Evaluation of Radiological between the SNC Standard Planning and Preparedness for Production and Emergency Response Plans and Preparedness in Emergency Plan and the Site Utilization Facilities. It is based on meeting the Support of Nuclear Power Plants." The SNC Emergency Annex. intent of the guidance contained in NU REG 0654, Plan meets the emergency planning standards of 10 CFR Revision 1 with the exception of emergency 50.47(b), the requirements of Appendix E and the intent of EALs to be submitted separately action levels which are based on Nuclear Energy NUREG 0654 Revision 1. The SNC Emergency Plan is from SNC Standard Emergency Institute (NEI) 99-01, Revision 4, Methodology for organized using the structure of NUREG-0654 Revision 1 Plan and Annexes for SNC. Development of Emergency Action Levels (EAL), and that structure provides the cross-reference to the Currently, Appendix B to this for Units 1 and 2. EALs for Units 3 and 4 will be base document. annex is a placeholder for the based on the NRC endorsed version of NEI 07- EP D.1.1: Emergency classification is divided into four approved EAL's. 01, Revision 0, Methodology for Development of classification levels described in 10 CFR 50 Appendix E Emergency Action Levels Advanced Passive and NUREG 0654 and based on NEI 99-01 and 07-01 Light Water Reactors. methodologies. Annex 3.2: Appendix B to this Annex contains the matrix for Initiating Conditions used to determine an Emergency Action Level (EAL). They are part of the scheme established by NEI 07-01, Methodology for Development of Emergency Action Levels for Advanced Passive Light Water Reactors. Annex Appendix 8 In addition, for proposed Units 3 and 4, the EP Intro: The SNC Emergency Plan was developed with The commitment wording was VEGP Emergency Plan is designed to be the guidance of NUREG-0654, FEMA-REP-1, Revision 1, standardized and moved to the compliant with 10 CFR 52.17(b)(1), 10 CFR "Criteria for Preparation and Evaluation of Radiological SNC Standard Emergency Plan. 52.17(b)(2)(ii), and 10 CFR 52.17(b)(3). NUREG Emergency Response Plans and Preparedness in The wording was updated to 0654, Supplement 2 is also used as guidance for Support of Nuclear Power Plants." The SNC Emergency reflect operational conditions the development of the VEGP Emergency Plan Plan meets the emergency planning standards of 10 CFR under 10 CFR Part 50. pertaining to proposed Units 3 and 4 for the Early 50.47(b), the requirements of Appendix E and the intent of Site Permitting process. NUREG 0654 Revision 1. The SNC Emergency Plan is organized using the structure of NUREG-0654 Revision 1 and that structure provides the cross-reference to the base document. ElS-8 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 The VEGP Emergency Plan is designed to Annex 1: Introduction (SEP) This document serves as the The commitment wording was accommodate the unique features of the two unit Vogtle Electric Generating Plant (VEGP) Units 3 and 4 standardized and moved to the designs used at the Site. A common VEGP Annex and contains information and guidance that is SNC Standard Emergency Plan. Emergency Plan is supported by Annex V1 which unique to VEGP Units 3 and 4. This includes Emergency The wording was updated to contains the parts of the Emergency Plan that Action Levels (EALs) and facility geography. reflect operational conditions are unique to Units 1 and 2, and Annex V2 which under 10 CFR Part 50. contains the parts of the Emergency Plan that are unique to proposed Units 3 and 4. Each segment of the Emergency Plan is supported by Appendices that contain supporting information for each segment of the plan. The Appendices for Annex V2 contain a set of inspections, tests, analyses, and acceptance criteria (ITAAC) that contain those elements of the Emergency Plan pertaining to proposed Units 3 and 4 that cannot be completed or verified prior to approval of the Emergency Plan as part of the Early Site Permitting Process. Thus, these ITAACs will be incorporated into the Combined License (COL). After proposed Units 3 and 4 are operating, all references to ITAACs will be removed. ElS-9 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 A.1: The VEGP Site will be responsible for EP

Introduction:

SNC has overall responsibility for The commitment wording was maintaining an effective Emergency Plan and maintaining a state of readiness to implement this Plan for standardized and relocated to maintaining proper preparedness through the the protection of plant personnel, the general public, and the SNC Standard Emergency maintenance of formal procedures for property from hazards associated with any facility Plan. implementing the Plan, the training of personnel operated by the company. The authority for planning, in accordance with Section 0, the maintenance developing, and coordinating emergency control Responsibilities of SNC Sites of necessary equipment, and continuing measures is derived from being the Nuclear Regulatory and Personnel are listed in relationships with various governmental agencies Commission (NRC) license holder for the nuclear power Section B of the SNC Standard and private organizations as identified in this plants operated by SNC.The SNC Emergency Plan Emergency Plan. Section and in Appendix 2. The following tasks describes the organization and facilities, training, will be part of the VEGP Site's responsibility: maintenance of facilities and equipment, both onsite and

Recognize and declare the existence of an off-site, which will be used to address a wide spectrum of emergency condition. accidents ranging from minor onsite incidents to those that
Classify the event in accordance with the could affect the general public.

methodology described in Section D of this EP B.1.1: In an emergency, the SM assumes the Plan. responsibility of the Emergency Director (ED) and takes

Notify appropriate Site personnel and offsite necessary actions to identify and respond to the authorities. emergency until relieved by another qualified ED. The ED
Take corrective actions to mitigate the has the responsibility and authority to immediately and severity of the accident.Request additional unilaterally initiate emergency actions, including providing support as deemed necessary. notification of Protective Action Recommendations (PAR) to State and Local government organizations responsible
Establish and maintain effective for implementing off site emergency measures. The ED, communications within the Site and with offsite response groups as described in at their discretion or when procedurally required, activates Section F. the ERO.
Continuously assess the status of the accident and periodically communicate the status information to the appropriate response groups. This includes the collection and evaluation of onsite and offsite radiological monitoring data.

ElS-10 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 A.1 (cont) Continued from Above. See above

Take protective measures onsite and The Emergency Director's non-delegable duties include:

recommend protective actions to offsite

Event classification in accordance with the emergency authorities. classification system.
Monitor and control radiation exposures of all
Perform the duties and responsibilities of Protective personnel responding to the emergency and Action Recommendation (PAR) determination.

under the direction of the site.

Notifications of offsite agencies and approval of state,
Provide emergency information to the public local, and NRC notifications; through periodic press briefings in
Authorization of emergency exposures in excess of conjunction with Federal, State and local federal limits.

officials.

Issuance of potassium iodide (Kl) to plant employees The Site emergency response will be carried out as a thyroid blocking agent; under the control of the Emergency Director.
Request Federal assistance as needed .

The onsite organization to support these activities is described in Section B. ElS-11 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 A.2 State of GeorgiaThe Georgia Emergency EP A.2.2.1: Georgia Emergency Management Agency The commitment wording was Management Agency (GEMA) is assigned (GEMA)GEMA is responsible for general State emergency standardized and relocated to responsibility for overalldirection and coordination planning and overall direction and control of emergency or the SNC Standard Emergency of emergency and disaster planning and disaster operations as assigned by Executive Order and in Plan and Site Annex. operations in the State ofGeorgia. GEMA has accordance with the Georgia Emergency Operations Plan developed the Georgia Emergency Operations (GEOP). GEMA has responsibilities for coordinating the Plan (GEOP), which is an emergency operations State of Georgia response to emergencies at the Hatch plan for all natural disasters, accidents, and Nuclear Plant and the Vogtle Electric Generating Plant. incidents, including radiological emergencies at Annex 1.3 State of Georgia: fixed nuclear facilities. Integral to the GEOP is Upon notification of an emergency condition, the Georgia the Georgia Radiological Emergency Response Emergency Management Agency will implement the Base Plan (GA REP) which is used for planning "State of Georgia Radiological Emergency Plan." The for, responding to, and dealing with radiological Georgia Emergency Management Agency has the emergencies. Details concerning assignment of authority and responsibility for coordinating the efforts of responsibilities are contained in the GEOP and local and state agencies in Georgia to provide for the GA REP. health and safety of the general public in the event of a radiological incident. An agreement is in place with the State of Georgia to provide available resources and equipment to support the mitigation and response to an emergency at Plant Vogtle to include Hostile Action Based events. These resources include, but are not limited to, Local Law Enforcement Agency (LLEA) assets, fire fighting assets, medical support resources (including transportation), and coordination through an Incident Command Post. Requests for offsite resources and equipment will be communicated from the control room to the Burke County 911 center, the county EOC, or through the Incident Command Post, as applicable, based on the nature and timing of the event. ElS-12 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 A.3 Burke County, Georgia EP A.2.4: Emergency Planning Zone (EPZ) Counties The The commitment wording was All of the area within the VEGP plume exposure Emergency Management Agencies representing the standardized and relocated to pathway EPZ in the State of Georgia falls counties of Aiken, Allendale, Appling, Barnwell, Burke, the SNC Standard Emergency withinBurke County. The responsibility for overall Early, Henry, Houston, Jeff Davis, Tattnall, and Toombs Plan and Site Annex. radiological emergency response planning for have the responsibility for notification and providing BurkeCounty rests with the chairman, Burke direction to residents in the event of an emergency that County Board of Commissioners. It is the affects their respective jurisdiction. 24 hour notification chairman's responsibility to initiate actions and points have the responsibility to notify necessary local civil provide direction and control at a level consistent support groups in the event of an accident. The County is with the specific incident. Agencies within Burke responsible for protection of the public and can provide County which have a primary role in radiological personnel and equipment for evacuation, relocation, and emergency planning and response include the isolation. Emergency Management Agency (EMA) and the Annex 1.5.1: The area within the plume exposure Sheriff's Department. Details concerning pathway (EPZ) in the State of Georgia falls within Burke assignment of responsibilities for the Burke County. The responsibility for overall radiological Countyresponse are contained in Annex D to the emergency response planning rests with the Chairman, GA REP. Burke County Board of Commissioners. It is the chairman's responsibility to initiate actions and provide direction and control at a level consistent with the specific incident. ElS-13 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 - A.4 State of South Carolina EP A.2.3.1: Emergency Management Division (EMO) The commitment wording was The South Carolina Emergency Management The EMO is assigned the responsibility for coordinating standardized and relocated to Division (SCEMD) in the Office of the Adjutant the emergency planning efforts of state, county, and the SNC Standard Emergency General State of South Carolina is assigned municipal agencies in accordance with the South Carolina Plan and Site Annex. responsibility for South Carolina's emergency Radiological Emergency Response Plan (SCORERP); preparedness, response, recovery, and conducting a preparedness program to assure capability mitigation activities. SCEMD has developed the of the government to execute the plan; establishing and South maintaining a State EOC and providing support of the Carolina Emergency Operational Plan (SCEOP) State emergency staff and work force; arid establishing an which establishes the policies and procedures effectiye system for reporting, analyzing, and by which South Carolina will coordinate state and disseminating emergency information. federal response to disasters impacting South Annex 1.4: The State of South Carolina has developed Carolina. SCEOP Attachment A, Annex 25, the South Carolina Radiological Emergency Response Radiological Hazards, assigns responsibilities for Plan (SCORERP), which provides guidance to state and radiological hazards in South Carolina. Integral to local governments on procedures, organization, and the SCEOP is the South Carolina Operational responsibilities for preventing and mitigating the effects of Radiological Emergency Response Plan a nuclear power plant incident or disaster. (SCORERP) which prescribes planning The SCORERP describes the South Carolina Radiological objectives, tasks, and responsibilities to Emergency Response Organization, which consists of the departments and agencies of state and local Office of the Adjutant General (Emergency Management governments for radiological events at nuclear Division) (EMO), the Department of Health and facilities. Details concerning assignment of Environmental Control (Bureau of Solid and Hazardous responsibilities are contained in the SCEOP and Waste, Nuclear Emergency Planning (NEP) Section), and SCORERP. those state resources available to local government(s) during a fixed nuclear facility radiological accident. The response functions. of involved agencies are described in the SCORERP and the South Carolina Technical Radiological Emergency Response Plan (SCTRERP). E15-l4 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 A.5 Aiken, Barnwell, and Allendale Counties, EP A.2.4: Emergency Planning Zone (EPZ) Counties The commitment wording was South Carolina The Emergency Management Agencies representing the standardized and relocated to Most of the plume exposure pathway EPZ within counties of Aiken, Allendale, Appling, Barnwell, Burke, the SNC Standard Emergency South Carolina falls within the site boundary of Early, Henry, Houston, Jeff Davis, Tattnall, and Toombs Plan and Site Annex. the SRS. The DOE is responsible for the have the responsibility for notification and providing direction and control of all emergency response direction to residents in the event of an emergency which actions on the SRS.There are limited portions of affects their respective jurisdiction. 24 hour notification Aiken, Barnwell, and Allendale counties which points have the responsibility to notify necessary local civil are outside of the SRS but within the plume support groups in the event of an accident. The County is exposure pathway EPZ of the VEGP Site. These responsible for protection of the public and can provide counties are similarly organized, with the personnel and equipment for evacuation, relocation, and responsibility for overall radiological emergency isolation. response planning resting with the chairperson of Annex 1.6: DOE-Savannah River Site (SRS) the county council. It is the chairperson's The DOE-Savannah River Site (SRS) will provide the responsibility to initiate actions and provide necessary response within the SRS reservation in direction and control at a level consistent with the accordance with the SRS Emergency Plan. The DOE will specific incident. Agencies within these counties exercise overall responsibility, jurisdiction, and authority which have a primary role in radiological for conducting response operations on the Savannah emergency planning and response include the River Site to protect the health and safety of SRS Emergency Management Division (EMD) and the personnel. DOE will provide for emergency notification Sheriff's Department. Details concerning and, as needed, evacuation, monitoring, decontamination, assignment of responsibilities can be found in the and immediate lifesaving medical treatment of non SRS respective county's Emergency Operations Plan personnel on the Savannah River Site. DOE will also (EOP) and the respective Annex 02, Fixed provide access control for SRS areas. Nuclear Facility Radiological Emergency Response Plan (RERP). A.6 Department of Energy- Savannah River Site Annex 1.6: DOE-Savannah River Site (SRS) The commitment wording was A significant portion of the plume exposure The DOE-Savannah River Site (SRS) will provide the standardized and relocated to pathway EPZ falls within the site boundary of the necessary response within the SRS reservation in the Site Annex. SRS. The DOE-SR consists of lands owned or accordance with the SRS Emergency Plan. The DOE will leased by the Federal government. As such, exercise overall responsibility, jurisdiction, and authority DOE-SR is responsible for the direction and for conducting response operations on the Savannah control of all emergency response actions on the River Site to protect the health and safety of SRS SRS. See memorandum of agreement between personnel. DOE will provide for emergency notification DOE - Savannah River Operations Office and and, as needed, evacuation, monitoring, decontamination, Georgia Power Company, as assigned to SNC, and immediate lifesaving medical treatment of non SRS (Appendix 4 ). personnel on the Savannah River Site. DOE will also provide access control for SRS areas. ElS-15 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 A.7 Medical Support EP 8.6.2 Ambulance Services The commitment wording was The VEGP Site has establish agreements with Agreements with ambulance services are in place to standardized and relocated to the Burke County EMA to provide ambulance transport injured personnel from the plants to the the SNC Standard Emergency service for the transportation of injured designated medical facility. Training is provided for the Plan with details contained in the personnel, including people who may be transport of contaminated personnel, and qualified utility Site Annex. radioactively contaminated, to hospital facilities personnel may accompany the ambulance. Details on the for treatment. Agreements with Radiation services offered may be found in the SNC plant's site-Management Consultants, Burke County specific Annex. Hospital, which is located on Liberty Street EP 8.6.3 Medical Services between Fourth and Dogwood Streets in Prior arrangements have been made for medical Waynesboro, Georgia, and Doctors Hospital in treatment at a variety of facilities. SNC operated nuclear Augusta, Georgia, near the junction of Interstate power plants are supported, and sites offer training to the Highways 20 and 520, will also be established for medical staff in dealing with contaminated injured treatment of injured and contaminated personnel. Details on the services offered may be found individuals. Copies of these agreements are in the SNC plant's site-specific Annex. included in Appendix 2. Annex 2.3.2: Agreements are in place with the University of Alabama Birmingham Hospital, Burke Medical Center, Doctors Hospital, and Burke County Emergency Management Agency to provide assistance for injured personnel, including cases involving radioactive contamination. This assistance will be requested whenever necessary in accordance with plant procedures. Medical Specialists, Inc., a group of medical professionals, has agreed to provide treatment services through Burke Medical Center and Doctors Hospital. Annex 2.3.3: VEGP has established agreements with the Burke County EMA to provide ambulance service for the transportation of injured personnel, including people who may be radioactively contaminated, to hospital facilities for treatment.Support provided includes, but is not limited to, Emergency medical services, ambulances, and emergency medical technicians Request for fire support will be made by the control room or site security to the Burke County Emergency Management Agency, Burke County EOC, or the Incident Command Post, as applicable, based on the nature and timing of the event. A copy of this agreement is maintained in accordance with Emergency Plan procedures. ElS-16 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 A.7: VEGP has established agreements with the Annex 5.8.2: Injured/externally contaminated personnel The commitment wording was Burke County EMA to provide ambulance service who require medical attention will normally be transported standardized and relocated to for the transportation of injured personnel, by ambulance to the cooperating hospitals. Ambulance the Site Annex. including people who may be radioactively crews are trained to handle external contamination cases, contaminated, to hospital facilities for treatment. and an RP technician accompanies any contaminated patients to the hospital. Ambulance service is provided by the Burke County Emergency Management Agency. A.8 Private Sector Organizations EP A.3.2: Bechtel Power Corporation The commitment wording was A.8.1 Bechtel Power Corporation SNC has established an agreement with Bechtel Power standardized and relocated to GPC/SNC has established an agreement with Corporation to obtain engineering and construction the SNC Standard Emergency Bechtel Power Corporation to obtain engineering services which may be required following an accident. Plan. and construction services which may be required EP 8.4.1: Vendors and Contractors following an accident. Bechtel's assistance will Major equipment providers or Architect-Engineers include: not be required during the early stages of the Westinghouse Electric Corporation, General Electric emergency response, but is more likely to be Corporation, and Bechtel Power Corporation, which can requested during recovery activities as described provide the following assistance in an emergency: in Appendix 2.

Trained personnel;
Technical analysis;
Operational analysis;
Accident and transient analysis .

A.8.2 Westinghouse EP A.3.3: Westinghouse The commitment wording was SNC has established an agreement with SNC has established an agreement with Westinghouse to standardized and relocated to Westinghouse to obtain general services related obtain general services related to nuclear steam supply the SNC Standard Emergency to nuclear steam supply system (NSSS) system (NSSS) operations during and following an Plan. operations during and following an accident accident situation. Westinghouse provides a capability to situation as described in Appendix 2. respond on a 24-hour-a-day basis. Westinghouse will provide a capability to respond EP 8.4.1: Vendors and Contractors on a twenty-four seven basis. Major equipment providers or Architect-Engineers include: Westinghouse Electric Corporation, General Electric Corporation, and Bechtel Power Corporation, which can provide the following assistance in an emergency:

Trained personnel;
Technical analysis;
Operational analysis;
Accident and transient analysis .

ElS-17 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 A.8.3 Voluntary Assistance Group EP C.4.1: The nuclear industry provides a reservoir of The commitment wording was SNC is a signatory to two comprehensive personnel .with a wide range of technical expertise and standardized and relocated to agreements among electric utility companies: knowledge. A nuclear industry national inventory of the SNC Standard Emergency The Nuclear Power Plant Emergency Response personnel who may be called upon to supplement Plan and Site Annex. Voluntary Assistance Agreement and the company personnel has been developed through the Voluntary Assistance Agreement by and among Institute of Nuclear Power Operations (INPO). In addition, Electric Utilities Involved in Transportation of a number of utilities have entered into an INPO Nuclear Materials. coordinated Voluntary Assistance Agreement program. This provides a mechanism to draw upon industry resources during an emergency. Support may also be requested from neighboring utilities for the following: Personnel and equipment to assist with in-plant and emergency field monitoring; Engineering, design, and technical expertise to assist in determining the cause of the accident and to support recovery. Personnel and equipment to assist in maintenance and repairs to the facility. SNC operated plants are a signatory to two comprehensive agreements among electric utility companies: The Nuclear Power Plant Emergency Response Voluntary Assistance Agreement, and; The Voluntary Assistance Agreement By and Among Electric Utilities Involved in Transportation of Nuclear Materials. Annex 2.3.5 Voluntary Assistance Group (SEP 8.4.2) VEGP a signatory to two comprehensive agreements among electric utility companies:

The Nuclear Power Plant Emergency Response Voluntary Assistance Agreement, and.
The Voluntary Assistance Agreement By and Among Electric Utilities Involved in Transportation of Nuclear Materials.

ElS-18 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 A.9 Federal Government EP A.1.4 Department of Energy (DOE) The commitment wording was The resources of the Federal agencies The DOE provides radiological assistance upon request, standardized and relocated to appropriate to the emergency condition would be and has radiological monitoring equipment and personnel the SNC Standard Emergency made available in accordance with the National resources that it can assemble and dispatch to the scene Plan. Response Plan (NRP). The Emergency Director of a radiological incident. Following a radiological will be specifically authorized to request Federal incident, DOE operates as outlined in the Federal assistance on behalf of the Site under the Radiological Monitoring and Assessment Plan (FRMAP). provisions of the NRP. In addition to the NRC, The Radiological Assistance Team can be expected to other agencies which may become involved are respond to SNC operated sites as directed by the the Department of Homeland Security (OHS), the Savannah River Operations Office of DOE. Department of Energy (DOE), the Federal EP A.1.5 Federal Bureau of Investigation (FBI) Emergency Management Agency (FEMA), the Support from the FBI is available through its statutory Environmental Protection Agency (EPA, the responsibility, based in Public Law and the US code, and Department of Health and Human Services through a memorandum of understanding for cooperation (HHS), the Department of Transportation (DOT), with the NRC. Notification to the FBI of emergencies in and the Department of Agriculture (USDA). which they would have an interest will be through the provisions of a plant security plan, or by the NRC. EP A.1.6 National Weather Service (NWS) NWS provides meteorological information during emergency situations, if required. Data available will include existing and forecasted wind directions, wind speeds, and ambient air temperatures. EP A.1.7 Environmental Protection Agency (EPA) The EPA can assist with field radiological monitoring, sampling, and non-plant related recovery and reentry guidance. ElS-19 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 A.9 Federal Government EP A.1 Primary Federal Organizations The commitment wording was The resources of the Federal agencies EP A.1.1 Nuclear Regulatory Commission (NRC) standardized and relocated to appropriate to the emergency condition would be The NRC is the coordinating agency for incidents at or the SNC Standard Emergency made available in accordance with the National caused by a facility or an activity that is licensed by the Plan. Response Plan (NRP). The Emergency Director NRC or an Agreement State, with the Chairman of the will be specifically authorized to request Federal Commission as the senior NRC authority for response. assistance on behalf of the Site under the The Chairman can transfer control of emergency provisions of the NRP. In addition to the NRC, response activities when deemed appropriate. other agencies which may become involved are the Department of Homeland Security (OHS), the Incident Response Centers have been established at the Department of Energy (DOE), the four NRC Regional Offices and NRC Headquarters, to FederalEmergency Management Agency centralize and coordinate NRC's emergency response. (FEMA), the Environmental Protection Agency Provision is made for NRC personnel at the plant's (EPA, theDepartment of Health and Human Technical Support Center and the Emergency Operations Services (HHS), the Department of Facility. Transportation (DOT), and the Department of EP A.1.2 Department of Homeland Security (OHS) Agriculture (USDA). In accordance with the National Response Framework (NRF), OHS is responsible for the overall coordination of a multi-agency Federal response to a significant radiological incident. EP A.1.3 Federal Emergency Management Agency (FEMA) The primary role of FEMA is to support the states by coordinating the delivery of federal non-technical assistance. FEMA coordinates state requests for federal assistance, identifying which federal agency can best address specific needs. If deemed necessary, FEMA will establish a nearby Joint Field Office from which it will manage its assistance activities. ElS-20 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 A.10 Concept of Operations EP B.1.1 The ED has the responsibility and authority to The commitment wording was Consistent with the Emergency Classification immediately and unilaterally initiate emergency actions, standardized and relocated to System described in Section D, the emergency including providing notification of Protective Action (PAR) the SNC Standard Emergency preparedness program for the VEGP Site will Recommendations to State and Local government Plan. require the coordinated response of several organizations responsible for implementing off site organizations. The emergency response emergency measures. The ED, at their discretion or when organization for the VEGP Site is described in procedurally required, activates the ERO. detail in Section B. The Emergency Director will The Emergency Director's non-delegable duties include: be the key individual in the VEGP Site

Event classification in accordance with the emergency response organization; one of his emergency classification system.

non-delegable responsibilities will be the decision

Perform the duties and responsibilities of Protective to notify the NRC and authorities responsible for Action Recommendation (PAR) determination.

offsite emergency measures. The interfaces

Notifications of offsite agencies and approval of state, among the emergency response organizations local, and NRC notifications; are shown on Figure A-1.
Authorization of emergency exposures in excess of federal limits.
Issuance of potassium iodide (Kl) to plant employees as a thyroid blocking agent;
Request Federal assistance as needed .

ElS-21 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 A.10.1 Continuous Communication EP E.1.1 SNC in cooperation with state, and county The commitment wording was CapabilityConsistent with the Emergency authorities, has established methods and procedures for standardized and relocated to Classification System described in Section D, the notification of offsite response organizations consistent the SNC Standard Emergency Emergency Director will initiate the activation of with the emergency classification and emergency action Plan. the emergency response organization by level scheme. These notifications include a means of contacting the states of Georgia and South verification or authentication. The methods used for Carolina, the counties within the plume exposure authentication are developed and mutually agreed to by pathway EPZ, the SRS, and the NRC. These the utility and off-site authorities. The primary notification organizations can be contacted on a twenty-four method will be by a dedicated communications system. seven basis. The state and local agencies have SNC operated plants maintain the capability of notifying continuously manned communication links for the state and local agencies within 15 minutes of a declared purpose of receiving notification of a radiological emergency as required per 10CFR50 Appendix E, section emergency. The SRS is a continuously operating IV(D)(3). The methods and forms used for notifying state facility and can be contacted at all times. The and county authorities are site-specific, and detailed in Federal agencies which may be requested by the . plant specific Emergency Plan Implementing Procedures VEGPSite to provide assistance can be notified (EPIPs). by contacting the NRC on a dedicated NRC will be notified by the impacted site immediately communication link, the Emergency Notification following state and local notifications, but within an hour of System (ENS) line. an emergency classification. EP E.2.3 The NRC is notified via the ENS. If the ENS is inoperative, the required notification will be made using alternate means in accordance with regulatory requirements. EP F .1.2 State and county warning points are continuously staffed .. A.10.2 State of Georgia and Burke County EP H.3 State and local Emergency Operations Centers The commitment wording was Operations .(EOC) standardized and relocated to The State -of Georgia and Burke County - EOCs operated by the state and local communities allow the SNC Standard Emergency responses are conducted in accordance with the direction and control of emergency response functions. Plan. Georgia Radiological Emergency Response Plan The states' EOCs are capable of continuous (24-hour) and its associated Annex D. operations for a protracted period. The county EOCs serve as Command and Control

headquarters for local emergency response activities as well as a center for the coordination of communications to field units and to the state EOCs. Additional details for state and county EOCs are found in the state and county emergency plans.

ElS-22 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 A.10.3 State of South Carolina and County EP H.3 State and local Emergency Operations Centers The commitment wording was Operations (EOC) . standardized and relocated to The state of South Carolina and county response EOCs operated by the state and local communities allow the SNC Standard Emergency is conducted in accordance with the South direction and control of emergency response functions. Plan. Carolina Operational Radiological Emergency The states' EOCs are capable of continuous (24-hour) Response Plan, the respective county operations for a protracted period. Emergency Operations Plan and its associated The county EOCs serve as Command and Control Annex Q2. headquarters for local emergency response activities as well as a center for the coordination of communications to field units and to the state EOCs. Additional details for state and county EOCs are found in the state and county emergency plans. A.10.4 Savannah River Site EP A.1.4 Department of Energy (DOE)The DOE The commitment wording was The DOE-SR will provide the necessary provides radiological assistance upon request, and has standardized and relocated to response within the SRS reservation in radiological monitoring equipment and personnel the SNC Standard Emergency accordance with the SRS Emergency Plan. The resources that it can assemble and dispatch to the scene Plan and Site Annex. DOE will exercise overall responsibility, of a radiological incident. Following a radiological jurisdiction, and authority for conducting on-plant incident, DOE operates as outlined in the Federal response operations to protect the health and Radiological Monitoring and Assessment Plan (FRMAP). safety of SRS personnel.DOE will provide for The Radiological Assistance Team can be expected to emergency notification and, as needed, respond to SNC operated sites as directed by the evacuation, monitoring, decontamination, and Savannah River Operations Office of DOE. immediate life saving medical treatment of non Annex 1.6 DOE-Savannah River Site (SRS) SRS personnel on plant. DOE will also provide The DOE-Savannah River Site (SRS) will provide the access control for SRS areas.DOE will provide necessary response within the SRS reservation in initial radiological monitoring and assessment accordance with the SRS Emergency Plan. The DOE will support to the State of South Carolina under the exercise overall responsibility, jurisdiction, and authority DOE Radiological Assistance Program (RAP). for conducting response operations on the Savannah This includes projected release dispersion River Site to protect the health and safety of SRS information and offsite radiological monitoring personnel. DOE will provide for emergency notification and assessment assistance. SRS will also and, as needed, evacuation, monitoring, decontamination, coordinate public affairs activities with the State and immediate lifesaving medical treatment of non SRS of South Carolina, SNC and GPC.By personnel on the Savannah River Site. DOE will also memorandum of agreement between DOE-SR provide access control for SRS areas. and GPC, as assigned to SNC (see Appendix 4 ), DOE will provide radiological monitoring within about 1O miles of the VEGP Site in the State ofSouth Carolina. ElS-23 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Section 8 VEGP Emergency Response Organization 8 Initial staffing of the VEGP onsite emergency EP 8.1: SNC plants maintain 24-hour emergency The commitment wording was response organization (ERO) will be provided response capability. The normal on~shift complement standardized and relocated to from personnel normally employed at the Site. An provides the initial response to an emergency. This group the SNC Standard Emergency organizational chart for VEGP is shown in Figure is trained to respond to emergency situations until the Plan. Further justification for 8- 1. If the need arises, this staff will be augmented Emergency Response Organization (ERO) ERO Augmentation is provided augmented substantially by the addition of SNC arrives. The ERO is composed of personnel with in the Technical Evaluation personnel and by personnel from other specialties in operations, maintenance, engineering, section of the License organizations. This includes a description of the radiochemistry, radiation protection, fire protection, and Amendment Request. emergency duties of the normal shift security. complement; a discussion of the manner in which EP 8.2: Augmentation of on-shift staffing will occur within emergency assignments are to be made; a listing 75 minutes of event classification by the Emergency of additional support personnel on whom the Site Response Organization (ERO). ERO positions for the can rely; and a description of the relationships TSC, Operations Support. Center (OSC), Emergency between onsite and offsite response activities. Operations Facility (EOF), and JIG are detailed below. A sufficient number of personnel are qualified to ensure that positions listed in this section can be staffed on a 24 hour/day basis for an extended event. Figures 8.2.8 through 8.2.E illustrate the overall augmented emergency response organization. On-shift as well as Offsite state/ local government interfaces are detailed in the site-specific Annexes. ElS-24 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 8.1 Normal Plant Organization EP B.1 Normal Plant Organization The commitment wording was The organizational structure shown on Figure 8-1 The normal onsite organization of a SNC operated nuclear standardized and relocated to represents the pool of management personnel power plant provides a staff capable of providing the initial the SNC Standard Emergency available on site during normal working hours. response to an emergency event. The On-Shift staff was Plan and Site Annex. Approximately 700 people are stationed at Units validated by performing a detailed staffing analysis as 1 and 2 during the standard workday, and required by Part 50 Appendix E.IV.9. Organizational A Staffing Analysis supporting approximately 650 people will be stationed at structures for each of the sites and the on-shift staffing the on-shift staffing design and Units 3 and 4 during the standard workday. tables are provided in the Site Specific Annex. The compliant with 10 CFR 50 The normal operating crew for each unit includes number and ERO position titles of personnel available Appendix E.IV.A.9 was a shift supervisor, licensed plant operators, and within 75 minutes following declaration of an emergency is conducted to support the non-licensed plant operators. A Shift Manager is shown in Tables 1, 2 and 3. submittal. also on shift during operation (as defined in the SNC plants maintain 24-hour emergency response Technical Specifications). Personnel from the capability. The normal on-shift complement provides the Chemistry and Health Physics, Maintenance, and initial response to an emergency. This group is trained to Security Departments are also on site respond to emergency situations until the augmented continuously. Emergency Response Organization (ERO) arrives. The ERO is composed of personnel with specialties in operations, maintenance, engineering, radiochemistry, radiation protection, material control, fire protection, and security Annex Table 2.2.A Minimum Shift Staffing ElS-25 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 B.1: Refer to Table B-1 for minimum staffing Annex Table 2.2.A: Minimum Shift Staffing The commitment wording was requirements. The table is segmented into standardized and relocated to columns to identify the staffing requirements for the Site Annex.A Staffing the two reactor designs used at the site. The Analysis supporting the on-shift table also includes a column that lists site staffing staffing design was conducted to requirements. The fourth column lists the support the submittal. minimum staffing requirements for Units 1 and 2 operations; the fifth column lists the minimum staffing requirements for Unit 3 operations (prior to Unit 4 and independent of Units 1 and 2 staffing levels); the sixth column lists the minimum staffing requirements for Unit 3 and 4 operations; the seventh column lists the minimum staffing requirements for the VEGP site; and the eighth column lists staff augmentation that will occur within 60 minutes of notification. Augmentation of the site will occur at the indicated levels irrespective of the number of units located at the site. After Unit 4 is in operation, the fifth column (Unit 3 staffing) will not be used. ElS-26 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 B.2 Emergency Response Organization EP B.2 Augmentation of on-shift staffing will occur within The commitment wording was The Emergency Director has the responsibility to 75 minutes of event classification by the Emergency standardized and relocated to classify an event in accordance with the Response Organization (ERO). ERO positions for the the SNC Standard Emergency emergency classification system described in TSC, Operations Support Center (OSC), Emergency Plan. Section D. Classification of an event into one of Operations Facility (EOF), and JIC are detailed below. A the four emergency categories (Notification of sufficient number of personnel are qualified to ensure that Unusual Event [NUE]; Alert; Site Area positions listed in this section can be staffed on a 24 Emergency; or General Emergency) activates the hour/day basis for an extended event. Figures B.2.B Site emergency response organization. The through B.2.E illustrate the overall augmented emergency extent to which the emergency response response organization. On-shift as well as Offsite state/ organization is activated depends on the severity local government interfaces are detailed in the site-of the situation. Table B-1 provides a summary specific Annexes. of personnel available on shift and those who EP B.1.1 would be available within 60 minutes of The ED has the responsibility and authority to immediately notification. and unilaterally initiate emergency actions, including providing notification of Protective Action (PAR) Recommendations to State and Local government organizations responsible for implementing off site emergency measures. The ED, at their discretion or when procedurally required, activates the ERO. B.2: For an NUE, the Emergency Director will EP B.1.1 The ED, at their discretion or when procedurally The commitment wording was assign responsibility for making the appropriate required, activates the ERO. standardized and relocated to notifications and directing the proper response; The Emergency Director's non-delegable duties include: the SNC Standard Emergency but no further activation of the emergency

Event classification in accordance with the Plan.

response organization will be required. emergency classification system.

Perform the duties and responsibilities of Protective Action Recommendation (PAR) determination.
Notifications of offsite agencies and approval of state, local, and NRC notifications);
Authorization of emergency exposures in excess of federal limits.
Issuance of potassium iodide (Kl) to plant employees as a thyroid blocking agent;
Request Federal assistance as needed .

E15-27 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 8.2: If the event is classified as an Alert, the EP H.1: SNC operated nuclear power plants have The commitment wording was Technical Support Center (TSC), Operations established a TSC and an onsite OSC, which are staffed standardized and relocated to Support Center (OSC), and Emergency and activated within 75 minutes of the declaration of an the SNC Standard Emergency Operations Facility (EOF) will be activated. Alert or higher classification. Plan. For these classifications, the emergency EP H.2.1: The EOF is procedurally required to be response organization will be structured as activated within 75 minutes following the declaration of an shown on Figure 8-2. The corporate resources Alert or higher classification and operation is presented in Appendix 7, Emergency Operations Facility. Corporate personnel who report to the plant site will be integrated into the Site emergency response organization. 8.2: For a Site Area Emergency or General EP H.1: SNC operated nuclear power plants have The commitment wording was Emergency, the emergency response established a TSC and an onsite OSC, which are staffed standardized and relocated to organization will be fully activated. The and activated within 75 minutes of the declaration of an the SNC Standard Emergency organization will be as shown in Figure 8-3. Alert or higher classification. Plan. EP H.2.1: The EOF is procedurally required to be activated within 75 minutes following the declaration of an It is SNC policy to fully activate Alert or higher classification the ERO at Alert or Higher. ElS-28 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 8.2: During hostile action, ERO members would EP H.1.4 An Alternative Facility for staging of ERO The commitment wording was likely not have access to the onsite emergency personnel has been designated at the sites. In the event standardized and relocated to response facilities. A security related emergency of a Security or Hostile Action threat or event, the the SNC Standard Emergency may delay the ordering of facility activation in designated Alternative Facility may also serve as an Plan and Site Annex. order to protect plant personnel from the security evacuation location for TSC and OSC personnel. The threat. The decision to delay activation of the Alternative Facility is designed to be accessible in the The SNC Standard Emergency facilities will be made by the Emergency Director. event of an onsite HAB event and has the capability to: Plan and Annex provide However, these events will warrant timely ERO

Communicate with the Control Room, Security, commitments to maintain the augmentation. An alternative facility has been and the EOF. communications capabilities identified to ensure rapid access to the site by
Conduct engineering assessment activities within the ERO, required offsite augmented staff due to its close proximity. The including damage control team planning and responders and the public alternative facility is located in a designated area preparation through the execution of a Joint in the Joint Information Center (JIG) in The functions of Notification and PARs will be performed Information System. The Waynesboro, Georgia. This facility has been from the EOF should the Alternative Facility be activated. detailed physical description of established to minimize delays in overall site Details of Alternative Facilities can be found in the Site equipment maintaining those response by permitting ERO assembly without Specific Annex. commitments is subject to exposing responders to the danger of hostile Annex 5.1.4 During a security related event or other event change and not necessary to action. This facility functions as a staging area for that precludes onsite access, the TSC, and OSC ERO ensure effective implementation augmented ERO staff until the site is secured. staff will be directed to an alternative facility. This facility of the Emergency Plan.

is located in the near site media center in Waynesboro, Additional details on the JIC/JIS GA. The alternative facility is equipped with the are provided in a separate necessary communications and data links to support enclosure as a part of this LAR. communications with the control room, site security and the EOF. The available communications and data links also provide access to the SNC document management resources, work planning resources for performing engineering assessment activities including damage control team planning and preparation for return to the site. Guidance for use of the facility is contained in site procedures. ElS-29 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 8.2.1 Emergency response organization EP H.1: SNC operated nuclear power plants have The commitment wording was ResponsibilitiesFollowing an Alert or higher established a TSC and an onsite OSC, which are staffed standardized and relocated to emergency declaration, the positions shown on and activated within 75 minutes of the declaration of an the SNC Standard Emergency Figures 8-2 and 8-3 will be filled by Site or SNC Alert or higher classification. Plan. personnel as discussed below. EP H.2.1: The EOF is procedurally required to be activated within 75 minutes following the declaration of an Alert or higher classification EP Figure 8.2.8, 8.2.C, 8.2.D, and 8.2.E: illustrates the standard Emergency Organization. 8.2.1.1 Emergency Director EP 0.1: The ERO Training Program assures the training, The commitment wording was Plant personnel that may be designated as qualification, and requalification of individuals who may be standardized and relocated to Emergency Directors are listed in Table 8-2. called on for assistance during an emergency. Specific the SNC Standard Emergency They will receive training as specified in Table 0- emergency response task training, prepared for response Plan. 2 prior to becoming qualified to fill this position. positions, is described in lesson plans and study guides. Their non-emergency positions will provide them The lesson plans, study guides, and written tests are The commitment for qualified plant knowledge and supervisory skills necessary contained in the ERO Training Program. Responsibilities responders was maintained in a to fill the Emergency Director position. for implementing the training program are contained in generic statement applicable to plant procedures. any position. ElS-30 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 B.2.1.1 The Emergency Director has the EP B.1.1 In an emergency, the SM assumes the The commitment wording was authority, management ability, and knowledge to responsibility of the Emergency Director (ED) and takes standardized and relocated to assume the overall responsibility for directing necessary actions to identify and respond to the the SNC Standard Emergency Site staff in an emergency situation. Initially this emergency until relieved by another qualified ED. The ED Plan. position will be filled by the Shift Manager or the has the responsibility and authority to immediately and Shift Supervisor if the Shift Manager cannot be unilaterally initiate emergency actions, including providing located expeditiously. The responsibility for notification of Protective Action (PAR) Recommendations emergency direction will be transferred to the to State and Local government organizations responsible Nuclear Plant General Manager or an alternate for implementing off site emergency measures. The ED, after receiving an appropriate briefing and at their discretion or when procedurally required, activates becoming familiar with the current status of the ERO. events. The Emergency Director's non-delegable duties include:

Event classification in accordance with the emergency classification system.
Perform the duties and responsibilities of Protective Action Recommendation (PAR) determination.
Notifications of offsite agencies and approval of state, local, and NRC notifications.
Authorization of emergency exposures in excess of federal limits.
Issuance of potassium iodide (Kl) to plant employees as a thyroid blocking agent.
Request Federal assistance as needed .

ElS-31 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 B.2.1.1 The Emergency Director will manage the EP 8.1.1 In an emergency, the SM assumes the The commitment wording was following activities for the duration of the responsibility of the Emergency Director (ED) and takes standardized and relocated to emergency: necessary actior:is to identify and respond to the the SNC Standard Emergency

Directs the notification of Site, SNC and GPC emergency until relieved by another qualified ED. The ED Plan.

personnel and notifies and maintains open has the responsibility and authority to immediately and communications with offsite authorities* unilaterally initiate emergency actions, including providing regarding all aspects of emergency notification of Protective Action (PAR) Recommendations response. to State and Local government organizations responsible

Oversees the activation and staffing of for implementing off.site emergency measures. The ED, emergency response facilities and requests at their discretion or when procedurally required, activates additional assistance, as needed. the ERO.
Authorizes emergency operation actions The Emergency Director's non-delegable duties include:

taken to mitigate the emergency condition or

Event classification in accordance with the reduce the threat to the safety of plant emergency classification system; personnel or the public, including the
Perform the duties and responsibilities of Protective recommendation of protective actions to Action Recommendation (PAR) determination; offsite authorities.
Notifications of offsite agencies and approval of
Provides overall direction for management of state, local, and NRC notifications.

emergency services related to the

Authorization of emergency exposures in excess of procurement of materials, equipment, and federal limits.

supplies; documentation; accountability; and

Issuance of potassium iodide (Kl) to plant security functions. employees as a thyroid blocking agent.
Provides overall direction for the
Request Federal assistance as needed .

management of emergency operations planning for procedure, equipment, and system development to support emergency operations.

Use discretionary authority to modify emergency implementing procedures or tailor the emergency response organization to fit the specific staffing needs.

E15-32 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 B.2.1.1 The Emergency Director may not EP 8.1.1 The Emergency Director's non-delegable duties The commitment wording was delegate the following responsibilities: include: standardized and relocated to

Decision to notify offsite emergency
Event classification in accordance with the the SNC Standard Emergency response agencies. emergency classification system; Plan.
Decision to recommend protective actions to
Perform the duties and responsibilities of offsite authorities. Protective Action Recommendation (PAR)
Declaration of emergency classifications . determination;
Authorization for plant personnel to exceed
Notifications of offsite agencies and approval of 10 CFR 20 radiation exposure limits. state, local, and NRC notifications.
Decision to terminate the emergency.
Authorization of emergency exposures in excess
Requests for Federal assistance . of federal limits.
Decision to order site dismissal of non-
Issuance of potassium iodide (Kl) to plant involved personnel from the site at an Alert employees as a thyroid blocking agent.

classification level.

Request Federal assistance as needed.
Decision to order non-involved personnel to proceed to a reception center and receive radiological monitoring.

ElS-33 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 8.2.1.1 The Emergency Director may operate EP B.1.1 lri an emerge.ncy, the SM assumes the The commitment wording was from the control room or TSC at his discretion. responsibility of the Emergency Director (ED) and takes standardized and relocated to He may act as the TSC manager during the early necessary actions to identify and respond to the the SNC Standard Emergency phases of emergency response until the TSC is emergency until relieved by another qualified ED. The ED Plan. activated. It is the intent of SNC that the ED has the responsibility and authority to immediately and function will be transferred from the Control unilaterally initiate emergency actions, including providing Room as soon as practicable. notification of Protective Action (PAR) Recommendations to State and Local government organizations responsible for implementing off site emergency measures. The ED, at their.discretion or when procedurally required, activates the ERO. The Emergency Director's non-delegable dtities include:

Event classification in accordance with the emergency classification system;
Perform the duties and responsibilities of Protective

         ./                                           Action Recommendation (PAR) determination;

Notifications of .offsite agencies and approval of state, local, and NRC notifications.
Authorization of emergency exposures in excess of federal limits.
Issuance of potassium iodide (Kl) to plant employees as a thyroid blocking agent.
Request Federal assistance as needed .

8.2.1.1 The primary and alternates for the EP 0.1: The ERO Training Program assures the training, The commitment wording was position of Emergency Director are shown on qualification, and requalification of individuals who may standardized and relocated to Table 8-2. the SNC Standard Emergency be called on for assistance during an emergency. Training Plan. will be evaluated in accordance with the requirements of Systematic Approach to Training practices to ensure The normal site staffing positions effectiveness and in order to identify weak or deficient and individuals assigned are areas that need correction. subject to change based on Specific emergency response task training, prepared for normal plant reassignment. The response positions, is described in lesson plans and study Integrated Plan maintains a guides. The lesson plans, study guides, and written tests commitment to staff any ERO are contained in the ERO Training Program. position with qualified personnel. Responsibilities for implementing the training program are contained in plant procedures. ElS-34 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 B.2.1.1: Initially this position (Emergency EP 8.1.1: The Shift Manager (SM) is in direct charge of The commitment wording was Director) will be filled by the shift manager or the shift plant operations and is directly responsible for the standardized and relocated to shift supervisor if the shift manager cannot be actions of the on-shift crew. In an emergency, the SM the SNC Standard Emergency located expeditiously. assumes the responsibility of the Emergency Director Plan. (ED) and takes necessary actions to identify and respond to the emergency until relieved by another qualified ED. EP 8.1.2 Shift Supervisors, who hold Senior Reactor Operator (SRO) licenses, supervise operation of the unit and may assume the duties of the ED in the absence of the Shift Manager. B.2.1.1: The responsibility for emergency EP 8.1.1 In an emergency, the SM assumes the The commitment wording was direction will be transferred to the plant manager responsibility of the Emergency Director (ED) and takes standardized and relocated to or an alternate after receiving an appropriate necessary actions to identify and respond to the the SNC Standard Emergency briefing and becoming familiar with the current emergency until relieved by another qualified ED. The ED Plan. status of events. has the responsibility and authority to immediately and unilaterally initiate emergency actions, including providing notification of Protective Action (PAR) Recommendations to State and Local government organizations responsible for implementing off site emergency measures. The ED, at their discretion or when procedurally required, activafes the ERO. ElS-35 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 8.2.1.2 TSC Staff EP B.2.1 Technical Support Center (TSC) B.2.1.2.1 TSC Manager EP B.2.1.2 TSC Manager The commitment wording was

Coordination of inputs and The TSC Manager reports to the TSC ED and is standardized and relocated to recommendations from technical and responsible for coordination of activities between the TSC the SNC Standard Emergency corrective action advisors. and other emergency response facilities, directs the Plan.
Direction of onsite emergency personnel activities of the TSC staff and ensures communications involved in restoration of the plant to a safe are established with applicable offsite agencies.

condition.

Technical assistance and operations guidance to control room personnel.
Direction of TSC staff in analysis of problems, design and planning for temporary modifications, and development of temporary emergency operating procedures.
Recommendation of protective actions to the emergency director based on plant conditions.
Providing recommendations on emergency classifications to the Emergency Director.

B.2.1.2.2: The TSC Support Coordinator will EP B.2.1.15 TSC Support Coordinator The commitment wording was direct the clerical and logistic activities in the The Support Coordinator reports to the TSC Manager and standardized and relocated to TSC. The TSC Support Coordinator ensures that directs the clerical and logistic activities in the TSC and the SNC Standard Emergency support staff, including clerks, status board ensures that support staff, including clerks, status board Plan. keepers, and communicators, are available in keepers, and communicators, are available in sufficient sufficient numbers and that office supplies, numbers and that office supplies, drawings, and other drawings, and other documents are available to documents are available to TSC and OSC personnel. TSC and OSC personnel. The TSC Support Coordinator is responsible for timely completion of offsite notification. The TSC Support Coordinator ensures that transportation and communication needs are satisfied. The TSC Support Coordinator arranges for additional offsite support personnel and equipment working in conjunction with the EOF Support Coordinator. ElS-36 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 B.2.1.2.3: The Engineering Supervisor will direct EP B.2.1.7 TSC Engineering Supervisor The commitment wording was a staff of engineers with expertise in reactor The Engineering Supervisor reports to the TSC Manager. standardized and relocated to engineering, thermal and hydraulic analysis, The TSC Engineering Supervisor is responsible for the the SNC Standard Emergency instrumentation and control, .and mechanical and overall direction of Engineering Group activities and Plan. electrical systems. The Engineering Supervisor assessment. The Engineering Supervisor also directs, the will direct the analysis of plant problems, core analysis of plant problems, core damage, and provides damage assessment, and provide recommendations for plant modifications to mitigate the recommendations for plant modifications to effects of the accident. mitigate the effects of the accident. B.2.1.2.4: The Maintenance Supervisor will EP B.2.1.4 TSC Maintenance Supervisor The commitment wording was manage the planning and coordination of repair, The Maintenance Supervisor reports to the TSC Manager standardized and relocated to damage control, and plant modification activities. and is responsible for planning and coordination of repair, the SNC Standard Emergency The Maintenance Supervisor will work closely damage control, and plant modification activities. The Plan. with the Engineering Supervisor in planning for Maintenance Supervisor works closely with the plant modifications and repairs. Engineering Supervisor in planning for plant modifications and repairs. B.2.1.2.5: The Operations Supervisor will analyze EP B.2.1.3 TSC Operations Supervisor The commitment wording was problems associated with systems operations The Operations Supervisor reports to the TSC Manager. standardized and relocated to and provides recommendations for procedures Major position functions include evaluating plant the SNC Standard Emergency for mitigating the emergency situation. conditions and initiating mitigation actions, coordinating Plan. TSC efforts in determining the nature and extent of plant conditions affecting plant equipment, actions to limit or contain the emergency, invoking the provisions of 10 CFR 50.54(x) if appropriate, assist the OSC Manager in determining the priority assigned to OSC activities and timely completion of offsite notifications. ElS-37 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 B.2.1.2.6: The Health Physics Supervisor will be EP B.2.1.5 TSC Radiation Protection (RP) Supervisor The commitment wording was responsible for onsite and in-plant radiological The RP Supervisor reports to the TSC Manager and standardized and relocated to controls. The Health Physics Supervisor will supervises the activities of the radiation protection staff the SNC Standard Emergency provide guidance to the Maintenance Supervisor and Health Physics Network (HPN) Communicator. The Plan. related to radiological considerations associated RP Supervisor assists the Radiation Protection/Chemistry with plant modification and repair, and will Group Lead in the OSC in determining the extent and provide direction to the OSC Manager related to nature of radiological or hazardous conditions and the health physics controls for emergency teams. coordinates offsite dose assessment and offsite Field The Health Physics Supervisor will perform Monitoring Teams prior to EOF activation. offsite dose assessment prior to EOF activation and will keep the Dose Assessment Supervisor in the EOF informed of the radiological status of the plant. B.2.1.2.7: The Chemistry Supervisor will be EP B.2.1.10 Chemistry Support The commitment wording was responsible for directing and evaluating in-plant The TSC Chemistry Support reports to the RP Supervisor. standardized and relocated to chemistry and analyses, directing and evaluating The TSC Chemistry Support is responsible for directing the SNC Standard Emergency post accident sampling, and assisting in core and evaluating in-plant chemistry and analyses, directing Plan. damage assessment. and evaluating post-accident sampling, and assisting in core damage assessment. B.2.1.2.8: The TSC Security Supervisor will EP B.2.1.14 Security Supervisor The commitment wording was coordinate the security functions including The Security Supervisor reports to the TSC Manager. standardized and relocated to accountability and site access control. The TSC The TSC Security Supervisor is responsible for carrying the SNC Standard Emergency Security Supervisor coordinates the processing out the plant security and Access Control program, Plan. of offsite personnel who require authorization to maintaining personnel accountability onsite, assisting in enter the site. When directed by the Emergency evacuation of onsite areas. Director, the TSC Security Supervisor will request assistance from civil law enforcement authorities, as required. ElS-38 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 B.2.1.3.1: The OSC Manager will receive EP B.2.2.1 OSC Manager The commitment wording was direction from TSC personnel to dispatch The OSC Manager reports to the TSC Manager and standardized and relocated to emergency teams (e.g., firefighting, search and directs a staff in providing labor, tools, protective the SNC Standard Emergency rescue, first aid, repair, etc.) to prescribed areas equipment, and parts needed for emergency repair, Plan. of the plant or site. The damage control, firefighting, search and rescue, first aid, OSC Manager will direct the composition of the and recovery. teams to ensure that appropriately qualified personnel are assigned. In particular, the OSC Manager will ensure that proper health physics coverage is provided. The OSC Manager will provide specific instructions to the team leaders. The OSC Manager will also maintain communications with the teams that remain assigned to the OSC and monitor the status of their activities. B.2.1.3.2: Depending on the nature of the EP B.2.2.7: Selected personnel report to the OSC, as The commitment wording was emergency, personnel from the Maintenance, directed. Emergency personnel from the Maintenance, standardized and relocated to Operations, Chemistry and Health Physics the Operations, and the RP/Chemistry Departments are the SNC Standard Emergency Departments will be directed to report to the directed to report to the OSC. OSC teams are headed by Plan. OSC. a designated team leader, who maintains communication with the OSC. EP Figure B.2.C: OSC Organization B.2.1.3.2: The following emergency teams will be EP 2.2.7 OSC Personnel The commitment wording was formed as necessary: The following emergency teams may be formed by OSC standardized and relocated to

Backup fire brigade. personnel, as necessary. the SNC Standard Emergency
Search and rescue.
Search and rescue Plan.
First aid.
Repair
Damage assessment.
Post accident sampling The SNC Standard Emergency
Damage control.
Internal survey Plan and Site Annex provide for
Repair and modification.
Field monitoring on-shift fire response supported by offsite response.
Field monitoring.

ElS-39 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 B.2.2 Emergency response organization EP Figures 8.2.8, 8.2.C, 8.2.D, and 8.2.E The commitment wording was Assignments standardized and relocated to Table B-2 identifies by title the individuals who the SNC Standard Emergency will fill the key emergency positions. Plan. A sufficient number of people will be identified to ensure that all emergency positions on Table B-2 will be filled. B.2.2: A sufficient number of people are identified EP 8.2: A sufficient number of personnel are qualified to The commitment wording was to ensure that all emergency positions on table ensure that positions listed in this section can be staffed standardized and relocated to B-2 will be filled. on a 24 hour/day basis for an extended event. the SNC Standard Emergency Plan. B.2.2: Table B-2 identifies by title the individuals Annex Table 2.2.A - Minimum On-Shift Staffing The commitment wording was who will fill the key emergency positions. EP Figures 8.2.B through B.2.E- ERO Organizations standardized and relocated to the SNC Standard Emergency Plan and Site Annex. B.2.3 Other Support Services EP A.3.2: SNC has established an agreement with The commitment wording was B.2.3.1 Contractor Support Bechtel Power Corporation to obtain engineering and standardized and relocated to Arrangements have been made to obtain support construction services which may be required following an the SNC Standard Emergency services from Bechtel Power Corporation and accident. Plan. Westinghouse, if required. These organizations EP A.3.3: SNC has established an agreement with will initially be contacted by the EOF Support Westinghouse to obtain general services related to Coordinator to arrange for the required nuclear steam supply system (NSSS) operations during assistance. and following an accident situation. Westinghouse provides a capability to respond on a 24-hour-a-day basis. B.2.3.1: Arrangements have been made to obtain EP A.3.2. Bechtel Power Corporation The commitment wording was support services from Bechtel Power Corporation SNC has established an agreement with Bechtel Power standardized and relocated to and Westinghouse, if required. Corporation to obtain engineering and construction the SNC Standard Emergency services which may be required following an accident. Plan. EP A.3.3 Westinghouse SNC has established an agreement with Westinghouse to obtain general services related to nuclear steam supply system (NSSS) operations during and following an accident situation. Westinghouse provides a capability to respond on a 24-hour-a-day basis. ElS-40 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 B.2.3.2 Medical Assistance EP 8.6.2: Agreements with ambulance services are in The commitment wording was Agreements are in place with Radiation place to transport injured personnel from the plants to the standardized and relocated to Management Consultants, Burke County designated medical facility. the SNC Standard Emergency Hospital, Doctors Hospital, and Burke County EP 8.6.3: Prior arrangements have been made for Plan and Site Annex. Emergency Management Agency (see Appendix medical treatment at a variety of facilities.

2) to provide assistance for injured personnel, Annex 2.3.2 Hospital and Medical Support (SEP including cases involving radioactive 8.6.3, K.1.3, L.1) contamination. This assistance will be requested, Agreements are in place with the University of Alabama whenever necessary, in accordance with plant Birmingham Hospital, Burke Medical Center, Doctors procedures. Hospital, and Burke County Emergency Management Agency to provide assistance for injured personnel, including cases involving radioactive contamination. This assistance will be requested whenever necessary in accordance with plant procedures. Medical Specialists, Inc., a group of medical professionals, has agreed to provide treatment services through Burke Medical Center and Doctors Hospital.

Annex 2.3.3 Ambulance Service (SEP 8.6.2, L.4) VEGP has established agreements with the Burke County EMA to provide ambulance service for the transportation of injured personnel, including people who may be radioactively contaminated, to hospital facilities for treatment. Support provided includes, but is not limited to, Emergency medical services, ambulances, and emergency medical technicians Request for fire support will be made by the control room or site security to the Burke County Emergency Management Agency, Burke County EOC, or the Incident Command Post, as applicable, based on the nature and timing of the event. A copy of this agreement is maintained in accordance with Emergency Plan procedures. ElS-41 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 B.2.3.2: Agreements are in place with Radiation EP 8.6.2: Agreements with ambulance services are in The commitment wording was Management Consultants, Burke County place to transport injured personnel from the plants to the standardized and relocated to Hospital, Doctors Hospital, and Burke County designated medical facility. the SNC Standard Emergency Emergency Management Agency (see Appendix Annex 2.3.2 Hospital and Medical Support (SEP Plan and Site Annex.

2) to provide assistance for injured personnel, 8.6.3, K.1.3, L.1) including cases involving radioactive Agreements are in place with the University of Alabama contamination. Birmingham Hospital, Burke Medical Center, Doctors Hospital, and Burke County Emergency Management Agency to provide assistance for injured personnel, including cases involving radioactive contamination. This assistance will be requested whenever necessary in accordance with plant procedures. Medical Specialists, Inc., a group of medical professionals, has agreed to provide treatment services through Burke Medical Center and Doctors Hospital.

B.2.3.3 Government Agency Support EP 8.1.1 The Emergency Director's non-delegable duties The commitment wording was Assistance may be requested from Burke include: standardized and relocated to County, the State of Georgia, or Federal

Request Federal assistance as needed. the SNC Standard Emergency agencies. Section A describes the assistance Annex 1.3 State of Georgia (SEP A.2.2) Plan and Site Annex.

that may be requested. Requests for aid will be Annex 1.5.1 Burke County Georgia (SEP A.2.4) made by the Emergency Director. B.2.4 Interfaces among Response Groups The figure was deleted. Figure A-1 illustrates the integrated organization Interactions are described in the for response to an emergency at the Site. respective facility descriptions and Communications table. B.2: Table B-1 provides a summary of personnel EP Tables 2, 3, 4 & 5 The commitment wording was available on shift and those who would be Annex Table 2.2.A standardized and relocated to available within 60 minutes of notification. the SNC Standard Emergency Plan and Site Annex. A Staffing Analysis supporting the on-shift staffing design and compliant with 10 CFR 50 Appendix E.IV.A.9 was conducted to support the submittal. ElS-42 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Table B-1: All EP B.1 SNC plants maintain 24-hour emergency The commitment wording was response capability. The normal on-shift complement standardized and relocated to provides the initial response to an emergency. This group the SNC Standard Emergency is trained to respond to emergency situations until the Plan. augmented Emergency Response Organization (ERO) arrives. Table B-2: All EP Figure B.2.B The commitment wording was standardized and relocated to the SNC Standard Emergency Plan. ERO Augmentation respo"nse is justified separately in the Technical Evaluation section of the License Amendment Request. B: Figure B-1 EP Figure P.1 The commitment wording was standardized and relocated to the SNC Standard Emergency Plan. Section C Emergency Response Support and Rescue C.1: The State of Georgia through the Office of EP A.2.2.1: As the overall state coordinating agency The commitment wording was Homeland Security - Georgia Emergency GEMA will coordinate with DNR-EPD on emergency standardized and relocated to Management Agency (OHS-GEMA) has the lead response activities with state, county and municipal the SNC Standard Emergency agency responsibility for responding to agencies and departments as stated in the Georgia Plan. emergency situations throughout Georgia. Emergency Operations Plan (GEOP). GEMA provides for 24-hour notification and staffing of the State Operations Center (SOC) and/or the Forward Emergency Operations Center (FEOC), as required, throughout the event. GEMA is responsible for general State emergency planning and overall direction and control of emergency or disaster operations as assigned by Executive Order and in accordance with the Georgia Emergency Operations Plan (GEOP). GEMA has responsibilities for coordinating the State of Georgia response to emergencies at nuclear power plants. ElS-43 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 C.1: The South Carolina agencies responsible for EP A.2.3.1 Emergency Management Division (EMO) The commitment wording was responding to a radiological emergency are The EMO is assigned the responsibility for coordinating standardized and relocated to theOffice of the Adjutant General, Emergency the emergency planning efforts of state, county, and the SNC Standard Emergency Management Division (EMD) and the Department municipal agencies in accordance with the South Carolina Plan. ofHealth and Environmental Control (DHEC). Radiological Emergency Response Plan (SCORERP); conducting a preparedness program to assure capability of the government to execute the plan; establishing and maintaining a State EOC and providing support of the State emergency staff and work force; and establishing an effective system for reporting, analyzing, and disseminating emergency information. EP A.2.3.2 Department of Health and Environmental Control (DHEC), Nuclear Emergency Planning Section The Department of Health and Environmental Control (DHEC) maintains a radiological hazard assessment capability and provides technical support, coordination, and guidance for the State and local governments. It will conduct and/or coordinate radiological surveillance and monitoring in coordination with DOE-Savannah River Site (SRS) and nuclear power plants. DHEC will obtain and coordinate radiological assistance resources from the Federal Government, other states, and the nuclear industry as required. ElS-44 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 C.1: Representatives from the states of Georgia EP H.2.1: It is anticipated that representatives from the The commitment wording was and South Carolina will be dispatched to the State(s) of Georgia, South Carolina, Alabama, or Florida standardized and relocated to emergency operations facility (EOF) and the may be dispatched to the EOF for an event at specific the SNC Standard Emergency emergency news center (ENC). SNC site(s). Plan. EP H.2.2Corporate Media Center (CMC) Upon notification of an Alert or higher classification, the The SNC Standard Emergency Public Information Director and corporate staff assigned to Plan and Annex provide JIC functions will assemble at the CMC. The CMG, commitments to maintain the located at the Atlanta/Birmingham corporate headquarters communications capabilities building of Georgia Power Company/Alabama Power within the ERO, required offsite Company, as appropriate, is the official location for responders and the public coordination of emergency communications response until through the execution of a Joint the site specific JIG has been activated. The Public Information System. The Information Director will coordinate with the EOF detailed physical description of Emergency Director and affected OROs and determine equipment maintaining those whether to activate the site' specific JIG. When the commitments is subject to decision is made to activate the JIG the CMG will maintain change and not necessary to emergency communications response coordination until ensure effective implementation the site specific JIG is ready to assume these of the Emergency Plan. responsibilities. Once overall responsibility for emergency communications response transfers to the site specific JIG the remaining CMC staff will provide support for the JIG as needed. H.2.3. Joint Information Center (JIC) The commitment wording was After the initial notification of an emergency at the Alert standardized and relocated to classification or higher, the Public Information Director will the SNC Standard Emergency coordinate with the EOF Emergency Director and affected Plan. OROs and determine whether to activate the JIC. Upon the decision to activate the JIG, the Public Information Director and JIG staff transfer from the CMG to the site specific JIG. Once the JIG is staffed the Public Information Director will m13nage the emergency communications response from the JIG in coordination with ORO public information officers (PIOs). Site specific JIG is provided in the site specific Annexes. ElS-45 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 C.2: Requests for Federal assistance will be directed, EP 8.1.1: The Emergency Director's non-delegable duties The commitment wording was as needed, by the emergency director, and usually include: standardized and relocated to these requests will be channeled through the GEMA. The exceptions to this procedure are direct contacts

Request Federal assistance as needed . the SNC Standard Emergency Plan. Removed excess content.

between the Site Emergency Response Organization, the Nuclear Regulatory Commission (NRG), and Department of Energy, Savannah River (DOE-SR). In the event of an incident in which Federal assistance is needed to supplement county and State emergency response capabilities, principal points of contact for State government are as follows:

The Federal Emergency Management Agency (FEMA), Regional Headquarters in Atlanta, Georgia.
The Department of Energy (DOE), Region Operations Office in Aiken, South Carolina.
The Environmental Protection Agency (EPA),

Regional Headquarters in Atlanta, Georgia. The Department of Homeland Security (OHS) and its subordinate agency FEMA are assigned lead responsibility for Federal offsite nuclear emergency planning and response (per Title 44 CFR 351 and the Homeland Security Act of 2002). OHS is also delegated responsibility for development and promulgation of the Federal Radiological Emergency Response Plan (FRERP). The FRERP assumes that states will be responsible for overall management of offsite emergency response. The Federal government's role consists of providing technical and/or logistical resource support at the request of State emergency management. Federal emergency response consists of technical and non-technical components. The NRG and FEMA jointly coordinate federal emergency response actions. The NRG coordinates technical aspects, and FEMA coordinates non-technical aspects of Federal response. The NRG and FEMA are expected to have representatives at the Site within about three hours after receiving notification. DOE can give assistance within about two h.ours. ElS-46 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 C.3: Emergency notification system (ENS) EP F.1.4 SNC has established communications systems The commitment wording was telephones and commercial telephones will be to provide reliable communications with Federal standardized and relocated to available in the control room, TSC, and EOF. emergency response organizations. Communications the SNC Standard Emergency with Federal agencies is primarily by commercial Plan. telephone, with alternate systems being used as needed. Communication with the Nuclear Regulatory Commission The current operation of the FTS (NRG) is via the Federal Telecommunications System system allows any phone with (FTS) telephone network which connects the SNC plant long distance capability to call site and EOF with the NRC Operations Center. Site into the Headquarters extensions are located in the Control Room, TSC, and Operations Center and be Site NRG Resident Inspector's Office. Site extensions patched into any bridge. The include ENS, HPN, EROS, and other designated specific listing becomes counterpart links connecting to the NRG Operations redundant to the expanded Center. capability. EP F .1.4.1 NRC Emergency Notification System (ENS) This communications line provides a communications link to the NRG Operations Center in Rockville, MD and is used for continuous communications in a classified emergency. C.3: Health physics network (HPN) telephones EP F.1.4.2 NRC Health Physics Network (HPN) The commitment wording was are available in the TSC and the EOF. This communications line provides a communications link standardized and relocated to with the NRC to provide radiological information. the SNC Standard Emergency Plan. The current operation of the FTS system allows any phone with long distance capability to call into the Headquarters Operations Center and be patched into any bridge. The specific listing becomes redundant to the expanded capability. C.3: In the EOF, space is provided for nine NRC EP H.2.1: The EOF is capable of accommodating The commitment wording was personnel and one FEMA representative. designated SNC personnel and offsite Local, State and standardized and relocated to Federal responders including NRC and FEMA. the SNC Standard Emergency Plan. ElS-47 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 C.3: The Site will provide space, telephone EP H.1.2 The TSC is sized to accommodate ERO The commitment wording was communications, and administrative services for responders and NRC Representatives. standardized and relocated to NRC and FEMA personnel at the TSC and EOF. Annex 5.1.2 The TSC will provide plant management and the SNC Standard Emergency Up to five NRC representatives can be technical support personnel (including Nuclear Regulatory Plan and Site Annex. accommodated at the TSC. Commission (NRC) personnel) with a facility from which they can assist plant operating personnel located in the control rooms during an emergency. C.4: Environmental samples will be collected by EP 1.7 The environmental monitoring equipment includes There is no equivalent SNC GPC corporate personnel. These samples will be portable survey, counting, and air sampling Standard Emergency Plan obtained from the current fixed environmental instrumentation and other radiological monitoring statement. The SNC Standard program which is described in Section I. equipment and supplies to be used by the FMTs. Emergency Plan maintains the Samples are taken at predetermined locations as well as commitment to perform the those locations specified during and after a release. sampling. C.4: Field samples will be taken by Site field EP 1.7: The environmental monitoring equipment includes The commitment wording was monitoring teams. These teams will take direct portable survey, counting, and air sampling standardized and relocated to radiation readings and will collect air samples, instrumentation and other radiological monitoring the SNC Standard Emergency soil samples, vegetation samples, and water equipment and supplies to be used by the FMTs. Plan. samples as directed by the dose assessment manager. C.4: In-plant samples such as effluent and air EP 1.2: The resources available to provide initial and The commitment wording was samples will be analyzed using a gamma continuing information for accident assessment standardized and relocated to spectrometer located in the counting room. throughout the course of an event include plant parameter the SNC Standard Emergency display systems, liquid and gaseous sampling system, Plan. Area and Process Radiation Monitoring Systems, and Accident Radiation Monitoring Systems. Descriptions of these systems are given in Section H. Details as to how post-accident sampling will be performed are in the plant-specific procedures. ElS-48 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 C.4: The onsite laboratory will be equipped to EP H.5.2.3: SNC sites have a laboratory facility for The commitment wording was analyze all normal in-plant samples. The analysis of radioactive samples. standardized and relocated to equipment will include an ion chromatograph, EP C.3: The onsite laboratory/counting room at SNC the SNC Standard Emergency gas chromatograph, gamma spectrometer, and operated nuclear power plants are the primary facility for Plan. other analytical support equipment. radiation monitoring and analysis effort. The onsite laboratory is the central point for receipt and analysis of onsite samples and includes equipment for chemical and radiological analyses. The plant laboratories have the capability of quantitative analysis of marine and air samples, and qualitative analysis of terrestrial samples. C.4: The* samples will be scanned with field EP H.10: SNC operated nuclear power plants have The commitment wording was instrumentation and will then be taken to the Site designated a point as the location for receipt and analysis standardized and relocated to for laboratory analyses. of field monitoring team environmental samples. the SNC Standard Emergency Sampling and analysis equipment is available for Plan. quantitative activity determination of marine and air samples, and qualitative activity determination of terrestrial samples. Table C-1 NA Location of EOCs is a function of the offsite Emergency Plans and not included in the fleet Plan Section D Emergency Classification System D.1: All the actions associated with the EP D.2.5: The SNC policy is that once an emergency The commitment wording has emergency classification level must be classification is made, it cannot be downgraded to a lower been standardized and relocated completed and then a termination of the event classification. Termination criteria contained in the to the SNC Standard Emergency can be affected. Emergency Plan Implementing Procedures shall be Plan. completed for an event to be terminated. When the site determines that transition to termination or recovery is appropriate, the information will be transmitted to respective offsite agencies. D.1: Once an emergency classification is made, it EP D.2.5: The SNC policy is that once an emergency The commitment wording has cannot be downgraded to a lower classification. classification is made, it cannot be downgraded to a lower been standardized and relocated classification. to the SNC Standard Emergency Plan. E15-49 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 D.1: The described emergency classes, and the Annex 3.1.1: The described emergency classes and the The commitment wording was emergency action levels which determine them, emergency action levels which determine them are standardized and relocated to are agreed on by SNC, and State and local agreed on by SNC and State and local authorities. The the SNC Standard Emergency authorities. The emergency action levels will be emergency action levels will be reviewed by these (state Plan. reviewed by these officials annually. and local) officials annually. D.1.1.2: VEGP ACTIONS (NUE) EP E.1.1: SNC operated plants maintain the capability of The commitment wording was

Inform State and local offsite authorities of notifying state and local agencies within 15 minutes of a standardized and relocated to the nature of the unusual event within 15 declared emergency as required per 10CFR50 Appendix the SNC Standard Emergency minutes of classifying the emergency. Notify E, section IV(D)(3). NRC will be notified by the impacted Plan.The SNC Standard the Nuclear Regulatory Commission (NRC) site immediately following state and local notifications, but Emergency Plan incorporates as soon as possible (ASAP), but no later within an hour of an emergency classification using the the actions needed for each than 1 hour following classification of the ENS system. individual Classification Level emergency. into general responsibilities
Augment on-shift resources, as needed . section.The wording has been
Assess and respond to the event. standardized and relocated into
Escalate to a more severe class, if the position descriptions for the appropriate, or close out with a verbal ERO members and various summary to offsite authorities followed by a sections of the SNC Standard written summary within 24 hours. Emergency Plan and Site Annex (on-shift or augmented that maintain those functions.

ElS-50 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 D.1.2.2: VEGP ACTIONS (Alert) EP 8.1.1 The ED, at their discretion or when procedurally The commitment wording was

Within 15 minutes of classification, inform required, activates the ERO. standardized and relocated to State and local offsite authorities of Alert EP 8.2 Augmentation of on-shift staffing will occur within the SNC Standard Emergency Emergency and reasons for emergency. 75 minutes of event classification by the Emergency Plan.The SNC Standard Notify the NRC ASAP, but no later than 1 Response Organization (ERO). ERO positions for the Emergency Plan incorporates hour following classification of the TSC, Operations Support Center (OSC), Emergency the actions needed for each emergency. Operations Facility (EOF), and JIC are detailed below. individual Classification Level
Augment resources and activate the EP E.1.1: SNC operated plants maintain the capability of into general responsibilities emergency response facilities (e.g., notifying state and local agencies within 15 minutes of a section.The wording has been Technical Support Center (TSC), Operational declared emergency as required per 10CFR50 Appendix standardized and relocated into Support Center (OSC) and the Emergency E, section IV(D)(3). NRC will be notified by the impacted the position descriptions for the Operations Facility [EOF]). These actions site immediately following state and local notifications, but ERO members and various may be delayed for security based events at within an hour of an emergency classification. sections of the SNC Standard the discretion of the emergency director. Emergency Plan and Site Annex
Assess and respond to the emergency. (on-shift or augmented that maintain those functions.
Mobilize, and dispatch if necessary, onsite survey teams.
Provide periodic plant status updates to offsite authorities.
Provide periodic meteorological assessments to offsite authorities and, if any emergency releases are occurring, field monitoring team readings or dose estimates for actual releases.
Activate the Emergency Response Data System for the affected unit within 1 hour following declaration of the Alert.
Escalate to a more severe class, if appropriate, or close out the emergency class by verbal summary to offsite authorities followed by written summary within 8 hours of closeout.

ElS-51 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 D.1.3.2: VEGP ACTIONS (SAE) EP B.1.1 The ED, at their discretion or when procedurally The commitment wording was

Within 15 minutes of classification, inform required, activates the ERO. standardized and relocated to State and local offsite authorities of Site EP 8.2 Augmentation of on-shift staffing will occur within the SNC Standard Emergency AreaEmergency and reasons for emergency. 75 minutes of event classification by the Emergency Plan.The SNC Standard Notify the NRC ASAP, but no later than 1 hour Response Organization (ERO). ERO positions for the Emergency Plan incorporates following classification of the emergency. TSC, Operations Support Center (OSC), Emergency the actions needed for each
If necessary, provide protective action Operations Facility (EOF), and JIC are detailed below. individual Classification Level recommendations to State and local EP E.1.1: SNC operated plants maintain the capability of into general responsibilities authorities. notifying state and local agencies within 15 minutes of a section.The wording has been
Augment resources and activate the declared emergency as required per 10CFR50 Appendix standardized and relocated into emergency response facilities (e.g., Technical E, section IV(D)(3). NRC will be notified by the impacted the position descriptions for the Support Center (TSC), Operational Support site immediately following state and local notifications, but ERO members and various Center (OSC), and the Emergency Operating within an hour of an emergency classification. sections of the SNC Standard Facility [EOF]). These actions may be delayed Emergency Plan and Site Annex for security based events at the discretion of (on-shift or augmented that the emergency director.

maintain those functions.

Assess and respond to the emergency .
Dispatch, as necessary, onsite and offsite survey teams.
Dedicate individuals for plant status updates to offsite authorities and periodic press briefings.
On a periodic basis, make senior technical and management staff available for consultation with the NRC and State officials.
Provide meteorological information and dose estimates to offsite authorities for actual releases via a dedicated individual.
Provide release and dose projections based on available plant condition information and foreseeable contingencies.
Activate the Emergency Response Data System for the affected unit within 1 hour following declaration of the Site Area Emergency

* .Escalate to General Emergency, if appropriate, or close out the emergency class by briefing of offsite authorities followed by written summary within 8 hours of closeout.

ElS-52 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 D.1.4.2: VEGP ACTIONS (GE) EP B.1.1 The ED, at their discretion or when procedurally The commitment wording was

Within 15 minutes of classification, inform required, activates the ERO. standardized and relocated to State and local offsite authorities of the EP B.2 Augmentation of on-shift staffing will occur within the SNC Standard Emergency General Emergency and reason for 75 minutes of event classification by the Emergency Plan.The SNC Standard emergency. Notify the NRC ASAP, but no Response Organization (ERO). ERO positions for the Emergency Plan incorporates later than 1 hour following classification of TSC, Operations Support Center (OSC), Emergency the actions needed for each the emergency. Operations Facility (EOF), and JIC are detailed below. individual Classification Level
Provide protective action recommendations EP E.1.1: SNC operated plants maintain the capability of into general responsibilities to State and local authorities based upon notifying state and local agencies within 15 minutes of a section.The wording has been plant conditions and/or actual or projected declared emergency as required per 10CFR50 Appendix standardized and relocated into releases of radioactive material. E, section IV(D)(3). NRC will be notified by the impacted the position descriptions for the
Augment resources and activate the site immediately following state and local notifications, but ERO members and various emergency response facilities (e.g., within an hour of an emergency classification. sections of the SNC Standard Technical Support Center (TSC), Operational Emergency Plan and Site Annex Support Center (OSC), and the Emergency (on-shift or augmented that Operating Facility [EOF]). These actions may maintain those functions.

be delayed for security based events at the discretion of the emergency director.

Assess and respond to the emergency.
Dispatch onsite and offsite survey teams .
Dedicate an individual for plant status updates to offsite authorities and periodic press briefings.
On a periodic basis, make senior technical and management staff available for consultation with the NRC and State officials.
Provide meteorological data and field monitoring team readings or dose estimates to offsite authorities for actual releases.
Provide release and dose projections based on plant condition and foreseeable contingencies.
Activate the Emergency Response Data System for the affected unit within 1 hour following declaration of the General Emergency. Close out the emergency class by briefing of offsite authorities followed by written summary within 8 hours of closeout.

ElS-53 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 D.2: The Classification Emergency Implementing EP D.1.1.1: SNC has and maintains the capability to The commitment wording was Procedure is used to classify the emergency assess, classify, and declare an emergency condition standardized and relocated to condition upon recognition of an off-normal within 15 minutes after the availability of indications to the SNC Standard Emergency condition relative to an Initiating Condition. plant operators that an EAL threshold has been met or Plan. exceeded. Upon identification of the appropriate emergency classification level, the emergency condition The need to list the specific will be promptly declared. procedure to be used is not necessary for the Plan. Section E Notification Methods and Procedures E.1: The Emergency Director is responsible for EP 8.1.1 The ED, at their discretion or when procedurally The commitment wording has classifying an event (Section D) into the required, activates the ERO. been standardized and relocated appropriate emergency class and then notifying The Emergency Director's non-delegable duties include: to the SNC Standard Emergency onsite and off-site personnel accordingly using

Event classification in accordance with the Plan.

the means described below. emergency classification system;

Notifications of offsite agencies and approval of state, local, and NRC notifications.

EP E.2.1 The Emergency Director is responsible for classifying an event into the appropriate emergency classification and then notifying on site personnel of the emergency declaration in accordance with site specific procedures. E.1: The primary means for notification of EP E.2.1: The Emergency Director is responsible for The commitment wording has personnel within the protected area is the Public classifying an event into the appropriate emergency been standardized and relocated Address (PA) system. classification and then notifying on site personnel of the to the SNC Standard Emergency Section E.1: Upon declaration of a Notification of emergency declaration in accordance with site specific Plan. Unusual Event (NUE), an Alert, a Site Area procedures. This notification may consist of the use of the Emergency, or a General Emergency, the plant emergency alarm, announcements over the plant emergency director will order an announcement public address system, or activation of the recall system. of the emergency. ElS-54 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 E.1: The tone signals for each of these classes of EP E.2.1: The Emergency Director is responsible for The commitment wording was emergency conditions, as well as for a fire, will classifying an event into the appropriate emergency standardized and relocated to beas follows: classification and then notifying on site personnel of the the SNC Standard Emergency

NUE: announcement only, no tone signal emergency declaration in accordance with site specific Plan.
Alert: warble tone procedures. This notification may consist of the use of the
Site Area Emergency: warble tone plant emergency alarm, announcements over the plant
General Emergency: warble tone public address system, or activation of the recall system.

Emergency Response personnel respond to their

Fire: siren tone assigned Emergency Response Facilities upon notification Section F.7: As described in Section E, notification of onsite personnel at the Site will be of an Alert or higher classification level. In the event of a completed through a combination of public Design Basis Threat, personnel may be directed to address system announcements, tone signals, respond to alternative facilities.

and proceduralized telephone calls. E.1: The Supervisor Nuclear Security will be EP E.2.1: Notification of persons who are in the public The commitment wording was responsible for notifying the unaffected Site units, access areas, on or passing through the site or within the standardized and relocated to Plant Wilson, the training center, the visitor's controlled area will be performed by the Security the SNC Standard Emergency center, and recreation park staff. Department. Such notifications would be accomplished in Plan. accordance with the Emergency Plan Implementing Procedures (EPIPs). E.1: Security will activate the site siren to notify EP E.2.1: Notification of Onsite Personnel The commitment wording was personnel on site, but outside the protected area, The Emergency Director is responsible for classifying an standardized and relocated to of an evacuation order. event into the appropriate emergency classification and the SNC Standard Emergency then notifying on site personnel of the emergency Plan. declaration in accordance with site specific procedures. This notification may consist of the use of the plant emergency alarm announcements over the plant public address system, or activation of the recall system. Notification of persons who are in the public access areas, on or passing through the site or within the controlled area will be performed by the Security Department. Such notifications would be accomplished in accordance with the Emergency Plan Implementing Procedures (EPIPs). E15-55 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 E.1: The Security Department will also be EP E.2.1: Notification of persons who are in the public The commitment wording was responsible for evacuating all visitors and access areas, on or passing through the site or within the standardized and relocated to nonessential personnel from the Plant Vogtle controlled area will be performed by the Security the SNC Standard Emergency Recreational Park and for the verification of the Department. Such notifications would be accomplished in Plan. evacuation of all nonessential personnel from the accordance with the Emergency Plan Implementing unaffected Site Units, Plant Vogtle, Plant Wilson, Procedures (EPIPs). the training center, and the remaining areas inside the owner controlled area. E.1: Visitors within the protected area are EP E.2.1 Visitors within the protected area are escorted The commitment wording was escorted by a permanently badged individual. by a permanently badged individual. standardized and relocated to the SNC Standard Emergency Plan E.1: Plant and contractor personnel will be 0.4.8 General Employee Training (GET) The commitment wording was trained on actions to be taken in an emergency GET will include general training in emergency standardized and relocated to prior to their work assignment. preparedness for plant and other site personnel. GET will the SNC Standard Emergency include classification, individual response, signals, Plan accountability, and site evacuation procedures. The general training requirements include visitor control. SNC provides Emergency Preparedness Training appropriate to the individual's responsibilities as required by Appendix E in general employee training and specialized training as required. The visitor program is maintained as part of the approved Security Plan assuring all non-badged individuals receive the appropriate training. E.1: The training will include instructions on the 0.4.8 General Employee Training (GET) The commitment wording was methods of personnel notification and the GET will include general training in emergency standardized and relocated to required personnel actions in the event of an preparedness for plant and other site personnel. GET will the SNC Standard Emergency emergency. include classification, individual response, signals, Plan. accountability, and site evacuation procedures. ElS-56 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 E.1: Notification of the corporate staff is EP E.2.1 Emergency Response personnel respond to The commitment wording was performed in accordance with EIPs. their assigned Emergency Response Facilities upon standardized and relocated to notification of an Alert or higher classification level. the SNC Standard Emergency Plan E.1: The notification procedure includes EP E.2.1 Notification procedures include notification of The commitment wording was notification of Emergency Response Emergency Response Organization Personnel (ERO) not standardized and relocated to Organization Personnel (ERO) not on site. on site or during backshift hours. ERO members will be the SNC Standard Emergency notified by means of an automated callout system Plan. activated by on-shift personnel. E.1: ERO members will be notified by means of EP E.2.1 Notification procedures include notification of The commitment wording was an autodialer system activated by on-shift Emergency Response Organization Personnel (ERO) not standardized and relocated to personnel. on site or during backshift hours. ERO members will be the SNC Standard Emergency notified by means of an automated callout system Plan. activated by on-shift personnel. E.1: In addition to those personnel recalled; EP 8.3.1.3 EOF Support Coordinator The commitment wording was Operations, Maintenance, and Security The Support Coordinator reports to the EOF Manager. standardized and relocated to personnel required to report shall be contacted The duties and responsibilities of the Support Coordinator the SNC Standard Emergency by on-shift personnel from their own respective in the EOF include providing oversight of the News Writer, Plan. department. providing assistance to the Support Coordinator in the TSC for ordering equipment and materials needed and logistics arrangements for support personnel called in to assist in the emergency, including communications hardware, transportation, food, and lodging. E.2: A dedicated telephone system, known as the EP E.2.2: A dedicated ENN will normally be used to The commitment wording was Emergency Notification Network (ENN), will accomplish State and local notifications. standardized and relocated to normally be used to accomplish these the SNC Standard Emergency notifications .. Plan. E.2: Figure E-1 presents the sample initial EP E.2.2.2: In conjunction with state and county The commitment wording was message form for making notifications to these authorities, SNC operated plants have established the standardized and relocated to response centers. This form has been developed contents of the initial state notification message forms to the SNC Standard Emergency in conjunction with appropriate offsite agencies. be used during an emergency. These forms are Plan. described in site specific EPIPs. ElS-57 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 E.2: The Emergency Director is responsible for EP E.2.2.1: State and local agencies listed in the site The commitment wording was the completion of the Initial Message Form specific Annexes shall be notified within fifteen (15) standardized and relocated to (Figure E-1) and for the notification of the minutes EP E.2.2.2: In conjunction with state and county the SNC Standard Emergency following agencies within 15 minutes of the authorities, SNC operated plants have established the Plan and Site Annex. declaration of anemergency:Georgia Emergency contents of the initial state notification message forms to Management Agency Emergency Operations be used during an emergency. These forms are Center (EOC) communicatorBurke County described in site specific EPIPs. Emergency Operations Center (EOC) Annex 4.1.1: Notification Process (SEP E.2.2) communicatorSouth Carolina warning pointAiken State and local warning points are staffed 24 hours per County sheriff dispatcherBarnwell County sheriff day. State and local counties surrounding VEGP are to dispatcherAllendale County central be notified within 15 minutes of the declaration of an dispatchDepartment of Energy-Savannah River emergency condition are: (DOE-SR) Operations Center communicator State of Georgia:

Georgia Emergency Management Agency (GEMA)

Georgia County Authorities:

Burke County Emergency Management Agency State of South Carolina:
Emergency Management Division (EMO)

South Carolina County Authorities:

Barnwell and Aiken County - Sheriff's Department
Allendale County - County Central Dispatch Degartment of Energy - Savannah River Site (DOE-SRS)
DOE-SRS Operations Center ElS-58 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 E.3: The Emergency Director is responsible for EP E.1.1: NRC will be notified by the impacted site The commitment wording was ordering notification calls to the DOE-SR immediately following state and local notifications, but standardized and relocated to Operations Center by ENN and to the NRC , within an hour of an emergency classification. the SNC Standard Emergency Operations Center by the Emergency Notification EP E.2.2: A dedicated (ENN) will normally be used to Plan.

System (ENS), or commercial telephone as accomplish State and local notifications. Backup means backup, within prescribed time constraints from of communication are described in Section F, Emergency the declaration of an emergency Communication, of this plan. EP E.2.2.1: State and local agencies listed in the site specific Annexes shall be notified within fifteen (15) minutes of:

The initial emergency classification .
Classification change .
The issuance of, or change to, a Protective Action Recommendation (PAR).

EP E.2.3: The NRC is notified via the ENS. ElS-59 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 E.3: The emergency director is responsible for EP E.1.1: NRC will be notified by the impacted site The commitment wording was ordering notification calls to the DOE-SR immediately following state and local notifications, but standardized and relocated to Operations Center by ENN and to the NRC within an hour of an emergency classification. the SNC Standard Emergency Operations Center by the Emergency Notification EP E.2.3: The NRC is notified via the ENS. Plan and Site Annex. System (ENS). Annex Section 4.1.1: Notification Process (SEP E.2.2) State and local warning points are staffed 24 hours per day. State and local counties surrounding VEGP are to be notified within 15 minutes of the declaration of an emergency condition are: State of Georgia:

Georgia Emergency Management Agency (GEMA)

Georgia County Authorities:

Burke County Emergency Management Agency State of South Carolina:
Emergency Management Division (EMD)

South Carolina County Authorities:

Barnwell and Aiken County - Sheriff's Department
Allendale County - County Central Dispatch Department of Energy - Savannah River Site (DOE-SRS)

DOE-SRS Operations Center Annex 5.3.3 Communications with the Savannah River Site (SEP F.1.2) The primary means of communication between VEGP and the Savannah River Site (SRS) is the ENN. SRS has two ENN drops, both located in their Operations Center. The ENN system is available and staffed 24 hours per day. Commercial telephones provide a backup for the ENN. E.4. Administrative and physical means have EP E.2.5: Prompt alerting and notification of the public The commitment wording was been established for providing early initial within the plume exposure pathway EPZ is the obligation standardized and relocated to warning and subsequent clear instructions to the of State and local government or other responsible the SNC Standard Emergency populace within the plume exposure pathway authority. The responsibility that means exist for this Plan. emergency planning zone (EPZ). purpose rests with Southern Nuclear Operating Company. ElS-60 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 E.4: It is the responsibility of SNC to provide EP E.2.5: Prompt alerting and notification of the public The commitment wording was adequate means for notifying the public, or to be within the plume exposure pathway EPZ is the obligation standardized and relocated to assured that such means are provided. of State and local government or other responsible the SNC Standard Emergency authority. The responsibility that means exist for this Plan and Site Annex. purpose rests with Southern Nuclear Operating Company. Annex 4.2: Within the 10 mile Exposure Emergency Planning Zone (EPZ), there exist provisions for alerting and providing notification to the public. The state and/or local authorities are responsible for activation of this system. Two totally independent public alerting systems are installed for use in the VEGP EPZ:

Network of fixed sirens and EAS,
NOAA (National Oceanic and Atmospheric Administration) weather warning radio system.

E.4: The alert notification system, except for the EP E.2.5.2: Capability for both an alerting signal and an The commitment wording was Savannah River Site (SRS), is described in informational or instructional message to the population standardized and relocated to Appendix 3. This system has the capability to on an area-wide basis throughout the plume exposure the SNC Standard Emergency complete the initial alert notification of residents pathway EPZ, within 15 minutes. Plan and Site Annex. within the plume EPZ in about 15 minutes. Annex 4.2: Within the 10 mile Exposure Emergency Planning Zone (EPZ), there exist provisions for alerting and providing notification to the public. The state and/or local authorities are responsible for activation of this system. Two totally independent public alerting systems are installed for use in the VEGP EPZ:

Network of fixed sirens and EAS,
NOAA (National Oceanic and Atmospheric Administration) weather warning radio system.

ElS-61 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 E.4: The Site will provide offsite authorities with EP E.2.5.1: In the event of a serious emergency at any The commitment wording was supporting information for their messages to the SNC site, the primary means for alerting the public will be standardized and relocated to public. Such messages, consistent with the by the FEMA approved Alert and Notification System the SNC Standard Emergency emergency classification scheme, will provide the (ANS) referenced in the site specific Annex. Plan. public with instructions in regard to specific protective actions to be taken by occupants of affected areas. E.5: The Emergency Director is responsible for EP E.2.2.3 Follow-up Emergency Message The commitment wording was the completion of a follow-up emergency In conjunction with state and county authorities, SNC- standardized and relocated to message operated plants have established the contents of the the SNC Standard Emergency subsequent state notification message forms to be used Plan. during an emergency. The Emergency Director is responsible for the completion of a follow-up emergency message. E.6: All notification messages must be verified. EP E.2.7: The SNC emergency notification form is The commitment wording was This is a suitable mechanism, since the ENN is a transmitted electronically to the responsible state and standardized and relocated to multiparty, dedicated telephone line. When local agencies using a secure data sharing system the SNC Standard Emergency commercial telephone or radio is used for provided by SNC. Once transmitted to the OROs the Plan. notification, the called party will contact the Site receipt of this information is confirmed using a dedicated to verify the validity of the message or use the communications link. In the event an agency is unable to authentication system provided by the State of obtain the emergency notification form electronically the South Carolina EMO. affected agency will be contacted using a dedicated communication link and the content of the form will be communicated verbally to the agency. As these systems are dedicated systems, no additional verification of the authenticity of the message is required for verification of messages with state and local agencies within the states of Alabama and Georgia. Communications with agencies within the state of South Carolina will be authenticated using the authentication system provided by the South Carolina Emergency Management Division. In the unlikely event the electronic notification transmittal capability and dedicated communications links are lost, then the emergency notification form will be communicated verbally using commercial telephone lines and the receiving agency may verify authenticity of the message by calling the licensee back. ElS-62 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 E.6: All notification messages must be verified. EP E.2.7: The SNC emergency notification form is The commitment wording was When the ENN is used, verification is transmitted electronically to the responsible state and standardized and relocated to accomplished by roll call. local agencies using a secure data sharing system the SNC Standard Emergency provided by SNC. Once transmitted to the OROs the Plan. receipt of this information is confirmed using a dedicated communications link. E: Actual methods and sequencing of EP E.1.1: SNC operated plants maintain the capability of The commitment wording has notifications will be covered in appropriate notifying state and local agencies within 15 minutes of a been standardized and relocated implementation procedures. declared emergency as required per 10CFR50 Appendix to the SNC Standard Emergency E, section IV(D)(3). The methods and forms used for Plan. notifying state and county authorities are site-specific, and detailed in plant specific Emergency Plan Implementing Procedures (EPIPs). NRC will be notified by the impacted site immediately following state and local notifications, but within an hour of an emergency classification. EP E.2.1 The Emergency Director is responsible for classifying an event into the appropriate emergency classification and then notifying on site personnel of the emergency declaration in accordance with site specific procedures. ElS-63 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 E: Tables E-1 and E-2 and Figure E-1 present EP E.1.1: SNC in cooperation with state, and county The commitment wording has the initial notification concept. authorities, has established methods and procedures for been standardized and relocated notification of offsite response organizations consistent to the SNC Standard Emergency with the emergency classification and emergency action Plan and Site Annex. level scheme. Annex 4.1.1: Notification Process (SEP E.2.2) State and local warning points are staffed 24 hours per day. State and local counties surrounding VEGP are to be notified within 15 minutes of the declaration of an emergency condition are: State of Georgia:

Georgia Emergency Management Agency (GEMA)

Georgia County Authorities:

Burke County Emergency Management Agency State of South Carolina:
Emergency Management Division (EMD)

South Carolina County Authorities:

Barnwell and Aiken County - Sheriff's Department
Allendale County - County Central Dispatch De1;1artment of Energy - Savannah River Site (DOE-SRS}
DOE-SRS Operations Center ElS-64 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 E: Table E-1. EP E.2.1: Notification of Onsite PersonnelThe Emergency The commitment wording was Director is responsible for classifying an event into the standardized and relocated to appropriate emergency classification and then notifying on the SNC Standard Emergency site personnel of the emergency declaration in Plan and Site Annex.

accordance with site specific procedures. This notification may consist of the use of the plant emergency alarm, announcements over the plant public address system, or activation of the recall system. Notification of persons who are in the public access areas, on or passing through the site or within the controlled area will be performed by the Security Department. Such notifications would be accomplished in accordance with the Emergency Plan Implementing Procedures (EPIPs). EP E.2.3: The NRC is notified via the ENS. Annex 4.1.1: Notification Process (SEP E.2.2) State and local warning points are staffed 24 hours per day. State and local counties surrounding VEGP are to be notified within 15 minutes of the declaration of an emergency condition are: State of Georgia:

Georgia Emergency Management Agency (GEMA)

Georgia County Authorities:

Burke County Emergency Management Agency State of South Carolina:
Emergency Management Division (EMO)

South Carolina County Authorities:

Barnwell and Aiken County - Sheriff's Department
Allendale County - County Central Dispatch De12artment of Energy - Savannah River Site (DOE-SRS}

DOE-SRS Operations Center Annex 5.3.3 The primary means of communication between VEGP and the Savannah River Site (SRS) is the ENN. ElS-65 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 E: Table E-2: All EP E.2.1: Notification of Onsite PersonnelThe Emergency The commitment wording was Director is responsible for classifying an event into the standardized and relocated to appropriate emergency classification and then notifying on the SNC Standard Emergency site personnel of the emergency declaration in Plan and Site Annex. accordance with site specific procedures. This notification may consist of the use of the plant emergency alarm announcements over the plant public address system, or activation of the recall system. Notification of persons who are in the public access areas, on or passing through the site or within the controlled area will be performed by the Security Department. Such notifications would be accomplished in accordance with the Emergency Plan Implementing Procedures (EPIPs). EP E.2.3: The NRC is notified via the ENS. Annex 4.1.1: Notification Process (SEP E.2.2) State and local warning points are staffed 24 hours per day. State and local counties surrounding VEGP are to be notified within 15 minutes of the declaration of an emergency condition are: State of Georgia:

Georgia Emergency Management Agency (GEMA)

Georgia County Authorities:

Burke County Emergency Management Agency State of South Carolina:
Emergency Management Division (EMO)

South Carolina County Authorities:

Barnwell and Aiken County - Sheriff's Department
Allendale County - County Central Dispatch Degartment of Energy - Savannah River Site (DOE-SRS)

DOE-SRS Operations Center Section F Emergency Communications ElS-66 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 F.1.1: The primary means of communication Annex 5.3.1: Communications with the States, Local The commitment wording was between the VEGP and the State of Georgia is Counties and Savannah River (SEP F.1.2) standardized and relocated to the Emergency Notification Network (ENN). The primary means of communication between VEPG, the the Site Annex. States of Georgia and South Carolina as well as Burke, Aiken, Allendale and Barnwell Counties and the Savannah River Site is the Emergency Notification Network (ENN). The ENN is a dedicated communications system from the plant to the EOC at GEMA headquarters in Atlanta, Georgia the South Carolina Warning Point in the SEOC, and the Burke County EOC and Savannah River Operations Center. Extensions for this system are located in the Control Room, the TSC, and the EOF. F.1.1: Commercial telephones and a Southern EP F.1.1: Reliable primary and backup means of The commitment wording was Company Communications in Atlanta provide communication have been established. standardized and relocated to backup for the dedicated telephone circuits. Annex Section: 5.3.2: Commercial telephones, or land the SNC Standard Emergency lines provide backup for the ENN. Plan and Site Annex. F .1.1: Commercial telephones and a Southern EP F .1.3 At least one onsite and one offsite The commitment wording was Company Communications in Atlanta provide communications system is maintained, each with a standardized and relocated to backup for the dedicated telephone circuits. backup power source to ensure continuous the SNC Standard Emergency F.1.2: Commercial telephones and the Burke communications. Plan and Site Annex. County Emergency Management Agency (EMA) Annex 5.3.2 Commercial telephones, or land lines provide radio network provide backups for the ENN. backup for the ENN. F.2.1: Commercial telephones provide the backup for the ENN. F.2.2: Commercial telephone is the backup means of communication.F.3: Commercial telephones provide a backup for the ENN. F.1.1: Extensions for this system are located in EP F .1.2: Offsite notifications can be made to State and The commitment wording was the control room, technical support center (TSC), county warning points and Emergency Operations standardized and relocated to emergency operations facility (EOF). Centers from the Control Room, Technical Support the SNC Standard Emergency Center, and Emergency Operations Facility via the ENN. Plan. ElS-67 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 F.1.1: The ENN system is available on a twenty- EP F.1.2: SNC operated plants maintain the capability to The commitment wording was four seven basis. make initial notifications to the designated offsite agencies standardized and relocated to F.1.2: The ENN is available and manned on a 24-hours per day. Offsite notifications can be made to the SNC Standard Emergency twenty-four seven basis State and county warning points and Emergency Plan and Site Annex. F.3: The ENN system is available and manned Operations Centers from the Control Room, Technical on a twenty-four seven basis. Support Center, and Emergency Operations Facility via the ENN. Annex 5.3.1: Communications with the States, Local Counties and Savannah River (SEP F.1.2) The primary means of communication between VEPG, the States of Georgia and South Carolina as well as Burke, Aiken, Allendale and Barnwell Counties and the Savannah River Site is the Emergency Notification Network (ENN). The ENN is a dedicated communications system from the plant to the EOC at GEMA headquarters in Atlanta, Georgia the South Carolina Warning Point in the SEOC, and the Burke County EOC and Savannah River Operations Center. Extensions for this system are located in the Control Room, the TSC, and the EOF. F.1.1: The plant telephone backup power is EP F.1.3 At least one on site and one offsite The commitment wording was supplied by a battery system. communications system is maintained, each with a standardized and relocated to backup power source to ensure continuous the SNC Standard Emergency communications. Plan ElS-68 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 F.1.2: At the plant, the emergency director is in Annex 4.1.1: Notification Process (SEP E.2.2) The commitment wording was charge of communications to the Burke County State and local warning points are staffed 24 hours per standardized and relocated to EOC. day. State and local counties surrounding VEGP are to the Site Annex. be notified within 15 minutes of the declaration of an emergency condition are: State of Georgia:

Georgia Emergency Management Agency (GEMA)

Georgia County Authorities:

Burke County Emergency Management Agency State of South Carolina:
Emergency Management Division (EMO)

South Carolina County Authorities:

Barnwell and Aiken County - Sheriff's Department
Allendale County - County Central Dispatch DeQartment of Energy - Savannah River Site (DOE-SRS)
DOE-SRS Operations Center F.1.2: Commercial telephones and the Burke Annex 5.3.2 Commercial telephones or land lines provide The commitment wording was County Emergency Management Agency (EMA) backup for the ENN. standardized and relocated to radio network provide backups for the ENN. the SNC Standard Emergency Plan.

F.1.2: The primary means of communication Annex 5.3.1: Communications with the States, Local The commitment wording was between VEGP and Burke County is the ENN. Counties and Savannah River (SEP F.1.2) standardized and relocated to The primary means of communication between VEPG, the the Site Annex. States of Georgia and South Carolina as well as Burke, Aiken, Allendale and Barnwell Counties and the Savannah River Site is the Emergency Notification Network (ENN). The ENN is a dedicated communications system from the plant to the EOC at GEMA headquarters in Atlanta, Georgia the South Carolina Warning Point in the SEOC, and the Burke County EOC and Savannah River Operations Center. Extensions for this system are located in the Control Room, the TSC, and the EOF. ElS-69 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 F.2.1: An Administrative Decision Line (AOL) No equivalent Plan/Annex statement The Administrative Decision line connects the EOF, SRS Operations Center, the is used by offsite agencies and GEMA FEOC, the SEOCs of both states and the listed in the Offsite Emergency three South Carolina counties. This prearranged Plan. This line is not used by conference call over commercial lines may be SNC and so is not included in used for discussions other than emergency the Plan or Annexes. notifications. F.2.1: The primary means of communication Annex 5.3.1 Communications with the States, Local The commitment wording was between the Site and South Carolina is the ENN, Counties and Savannah River (SEP F.1.2) standardized and relocated to a The primary means of communication between VEPG, the the Site Annex. dedicated telephone system from the Site to States of Georgia and South Carolina as well as Burke, South Carolina emergency response agencies. Aiken, Allendale and Barnwell Counties and the Savannah F.2.2: The primary means of communication River Site is the Emergency Notification Network (ENN). between the Site and the South Carolina The ENN is a dedicated communications system from the counties will be the ENN, a dedicated telephone plant to the EOC at GEMA headquarters in Atlanta, system which includes the Site and Aiken, Georgia the South Carolina Warning Point in the SEOC, Barnwell, and and the Burke County EOC and Savannah River Allendale Counties' emergency response Operations Center. Extensions for this system are located agencies. in the Control Room, the TSC, and the EOF. F.3: Actual communications may be completed Annex 4.1.1: Notification Process (SEP E.2.2) The commitment wording was by others as designated by the Emergency State and local warning points are staffed 24 hours per standardized and relocated to Director. day. State and local counties surrounding VEGP are to the Site Annex. be notified within 15 minutes of the declaration of an emergency condition are: State of Georgia:

Georgia Emergency Management Agency (GEMA)

Georgia County Authorities:

Burke County Emergency Management Agency State of South Carolina:
Emergency Management Division (EMO)

South Carolina County Authorities:

Barnwell and Aiken County - Sheriff's Department
Allendale County - County Central Dispatch Department of Energy - Savannah River Site CDOE-SRS)
DOE-SRS Operations Center ElS-70 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 F.3: The primary means of communication Annex 5.3.1: Communications with the States, Local The commitment wording was between VEGP and the Savannah River Site Counties and Savannah River (SEP F.1.2) standardized and relocated to (SRS) is the ENN. The primary means of communication between VEPG, the the Site Annex.

States of Georgia and South Carolina as well as Burke, Aiken, Allendale and Barnwell Counties and the Savannah River Site is the Emergency Notification Network (ENN). The ENN is a dedicated communications system from the plant to the EOC at GEMA headquarters in Atlanta, Georgia the South Carolina Warning Point in the SEOC, and the Burke County EOC and Savannah River Operations Center. Extensions for this system are located in the Control Room, the TSC, and the EOF. F.4: Commercial telephone lines and the EP F.1.4: SNC has established communications systems The commitment wording was Southern Company Communications serve as to provide reliable communications with Federal standardized and relocated to backups to the ENS and HPN. emergency response organizations. the SNC Standard Emergency Commercial telephone lines serve as the backup to the Plan. ENS and other FTS lines. F.4: Emergency notification system phones are EP F.1.4.1 This communications line provides a The commitment wording was located in the control room, TSC, and EOF. communications link to the NRC Operations Center in standardized and relocated to F.4: Health physics network phones are located Rockville, MD and is used for continuous communications the SNC Standard Emergency in the TSC and EOF. in a classified emergency. Plan. EP F.1.4.2 This communications line provides a communications link with the NRC to provide radiological The current operation of the FTS information. . system allows any phone with long distance capability to call into the Headquarters Operations Center and be patched into any bridge. The specific listing becomes redundant to the expanded capability. ElS-71 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 F.4: In the TSC, the HPN telephone is located in EP F.1.4.2 This communications line provides a The commitment wording was the communications room and will be attended communications link with the NRC to provide radiological standardized and relocated to by VEGP personnel until an NRC representative information. the SNC Standard Emergency arrives. Plan. The current operation of the FTS system allows any phone with long distance capability to call into the Headquarters Operations Center and be patched into any bridge. The specific listing becomes redundant to the expanded capability. F.4: The Emergency Response Data System F .1.4.8 Emergency Response Data System (EROS) is a The commitment wording was (EROS) is the primary means by which the dedicated network and is a direct near real-time electronic standardized and relocated to transmission of plant parameters occurs.Annex data link between the plant's on-site computer system and the SNC Standard Emergency V2 H.4.4: In accordance with the requirements of the NRC Operations Center that provides for the Plan. 10 CFR 50, Appendix E, Section VI and NUREG automated transmission of a limited data set of selected 1394, Revision 1, Emergency Response Data parameters. The current operation of the FTS System (EROS) Implementation, means will be system allows any phone with providedto transmit critical plant variables from long distance capability to call the onsite computer system to the Nuclear into the Headquarters RegulatoryCommission Operations Center via a Operations Center and be dedicated communications link. patched into any bridge. The specific listing becomes redundant to the expanded capability. F.4: The primary means of communication EP E.2.3: The NRC is notified via the Emergency The commitment wording was between VEGP and the Nuclear Regulatory Notification System (ENS). standardized and relocated to Commission (NRG) is the emergency notification the SNC Standard Emergency system (ENS). Plan. ElS-72 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 F.5: Communications among the Control Room, EP F .1.1: At SNC operated nuclear power plants, several The commitment wording was TSC, OSC, and EOF will be completed modes of reliable communication are available, during standardized and relocated to usingdedicated telephone circuits, normal plant both normal and emergency conditions, to transmit and the SNC Standard Emergency telephones, and radio, using the plant network. receive information among the Control Room, TSC, OSC, Plan. EOF, and at other locations onsite and offsite including the Joint Information Center near the SNC site. Reliable primary and backup means of communication have been established. EP F Table 5 ElS-73 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 F.5: Communications available at each EP F .1.1: At SNC operated nuclear power plants, several The commitment wording was emergency resRonse facility are as follows: modes of reliable communication are available, during standardized and relocated to Section F.5.1: CONTROL ROOM both normal and emergency conditions, to transmit and the SNC Standard Emergency

Dedicated telephone circuits to the TSC, receive information among the Control Room, TSC, OSC, Plan and Site Annex.

EOF, and OSC (one for each location). EOF, and at other locations onsite and offsite including

ENN . the Joint Information Center near the SNC site. Reliable
NRC ENS . primary and backup means of communication have been
Normal plant phones . established.

Annex 5.3.1: Communications with the States, Local

In-plant radio console Counties and Savannah River (SEP F.1.2)
Sound-powered phones . The primary means of communication between VEPG, the
Plant page system . States of Georgia and South Carolina as well as Burke,
Commercial dial. Aiken, Allendale and Barnwell Counties and the Savannah
Southern Company Communications . River Site is the Emergency Notification Network (ENN).
Facsimile. The ENN is a dedicated communications system from the Section F.5.2: TECHNICAL SUPPORT CENTER plant to the EOC at GEMA headquarters in Atlanta,
Dedicated telephone circuits to the control Georgia the South Carolina Warning Point in the SEOC, room, EOF, and OSC (one to each location). and the Burke County EOC and Savannah River
ENN . Operations Center. Extensions for this system are located
ENS. in the Control Room, the TSC, and the EOF .
Two FTS EROS lines. EP F Table 5
HPN .
Facsimile.
Normal plant phones .
In-plant radio .
Sound-powered phones .
Plant page system .
Field team radio remote .
Additional FTS lines .
Commercial dial.
Burke County radio remote .
South Carolina radio remote . -
Southern Company Communications .

ElS-74 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 - F.5.3: OPERATIONS SUPPORT CENTER EP F.1.1: At SNC operated nuclear power plants, several The commitment wording was

Dedicated voice telephone circuits to the modes of reliable communication are available, during standardized and relocated to EOF and TSC (one for each location). both normal and emergency conditions, to transmit and the SNC Standard Emergency
Normal plant phones . receive information among the Control Room, TSC, OSC, Plan.
In-plant radio transceiver. EOF, and at other locations onsite and offsite including
Commercial dial. the Joint Information Center near the SNC site. Reliable primary and backup means of communication have been established.

F.5.4: EMERGENCY OPERATIONS FACILITY EP F .1.1: At SNC operated nuclear power plants, several The commitment wording was

Dedicated telephone circuits to the control modes of reliable communication are available, during standardized and relocated to room, OSC, and TSC (one each to the both normal and emergency conditions, to transmit and the SNC Standard Emergency control room, OSC, TSC). receive information among the Control Room, TSC, OSC, Plan and Site Annex.
ENN EOF, and at other locations onsite and offsite including
ENS the Joint Information Center near the SNC site. Reliable
HPN . primary and backup means of communication have been established.
Facsimile . Annex 5.3.1: Communications with the States, Local
Normal plant phones . Counties and Savannah River (SEP F .1.2)
Commercial dial. The primary means of communication between VEPG, the
Additional FTS lines . States of Georgia and South Carolina as well as Burke,
Southern Company Communications . Aiken, Allendale and Barnwell Counties and the Savannah
ENC hotline . River Site is the Emergency Notification Network (ENN).
Field team radio remote . The ENN is a dedicated communications system from the
AOL prearranged conference . plant to the EOC at GEMA headquarters in Atlanta, Georgia the South Carolina Warning Point in the SEOC, and the Burke County EOC and Savannah River Operations Center. Extensions for this system are located in the Control Room, the TSC, and the EOF.

EP F Table 5 F.5.5: EMERGENCY NEWS CENTER EP F.1.1: At SNC operated nuclear power plants, several The commitment wording was

Southern Company Communications . modes of reliable communication are available, during standardized and relocated to
GPC general office dial. both normal and emergency conditions, to transmit and the SNC Standard Emergency
Commercial dial. receive information among the Control Room, TSC, OSC, Plan.
VEGP dial. EOF, and at other locations onsite and offsite including the Joint Information Center near the SNC site. Reliable
Facsimile . primary and backup means of communication have been established.

ElS-75 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 F.5: The radio system is also used for EP F .1.1: At SNC operated nuclear power plants, several The commitment wording was communications with the radiological monitoring modes of reliable communication are available, during standardized and relocated to teams. both normal and emergency conditions, to transmit and the SNC Standard Emergency receive information among the Control Room, TSC, OSC, Plan. EOF, and at other locations onsite and offsite including the Joint Information Center near the SNC site. Reliable primary and backup means of communication have been established. EP F Table 5 F.6: Communications with Columbia Doctors EP F.2 Medical Emergency Communications The commitment wording was Hospital or the Burke County Hospital is by Communications have been established between the standardized and relocated to commercial telephone. Radio contact through the primary and backup medical hospitals and transportation the Site Annex. Burke County EOC serves as a backup. services with SNC operated plants. F.7: As described in Section E, notification of EP E.2.1 Notification of Onsite Personnel The commitment wording was onsite personnel at the Site will be completed The Emergency Director is responsible for classifying an standardized and relocated to through a combination of public address system event into the appropriate emergency classification and the SNC Standard Emergency announcements, tone signals, and then notifying on site personnel of the emergency Plan. proceduralized telephone calls. After normal declaration in accordance with procedures. This working hours, Site personnel not on site at the notification may consist of the use of the plant emergency time of the emergency will be notified by beeper alarm, announcements over the plant public address (for plant management) or by telephone call system, or activation of the recall system. using an autodialer system. Notification procedures include notification of Emergency Response Organization Personnel (ERO) not on site or during backshift hours. ERO members will be notified by means of an automated callout system activated by on-shift personnel. ElS-76 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 F.8: Communication channels with the State of EP F.3.: Communications tests will be conducted on the The commitment wording was Georgia, Burke County, the State of South frequency specified below. Each of these tests includes standardized and relocated to Carolina, Aiken County, Barnwell County, provisions to ensure that participants in the test are able the SNC Standard Emergency Allendale County, SRS, and the NRC are tested to understand the content of the messages used in the Plan. monthly, usingthe extensions in the Control test. Room, TSC, and EOF

Communications with state and local governments within the plume exposure pathway will be tested monthly;
Communication from the Control Room, TSC and EOF to the NRC Operations Center will be tested monthly; F.8: Communications systems that link the EP F.3 Communications tests will be conducted on the The commitment wording was Control Room, TSC, EOF, State EOC's and frequency specified below. Each of these tests includes standardized and relocated to GEMA FEOC, County EOC's, and SRS EOC are provisions to ensure that participants in the test are able the SNC Standard Emergency tested quarterly. to understand the content of the messages used in the Plan.

test.

Communications between SNC operated nuclear power plants, state Emergency Operating Centers and local Emergency Operations Centers, and radiation monitoring teams will be tested annually; F.8: The communication system for Separate testing for the Field communicating between the TSC, EOF, and the monitoring communication Site field monitoring teams is tested quarterly. system is performed as part of the routine drill and training programs. Any non-conforming conditions are addressed via the site corrective action program.

ElS-77 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 F.8: Communications procedures and systems EP F.3 Communications Tests The commitment wording was are also tested biennially during a Communications tests will be conducted on the frequency standardized and relocated to communications drill. specified below. Each of these tests includes provisions the SNC Standard Emergency to ensure that participants in the test are able to Plan. understand the content of the messages used in the test.

Communications with state and local governments within the plume exposure pathway will be tested monthly.
Communications with federal response organizations and state governments within the plume exposure pathway will be tested quarterly.
Communications between SNC operated nuclear power plants, state Emergency Operating Centers and local Emergency Operations Centers, and radiation monitoring teams will be tested annually.
Communication from the Control Room, TSC, and EOF to the NRC Operations Center will be tested monthly.
The Emergency Response Data System (EROS) will be tested on a quarterly basis.
The fixed siren portion of the Alert and Notification System (ANS) will be tested and verified in accordance with existing FEMA approvals.

F.8: Emergency Response Data System EP F.3 Communications tests will be conducted on the The commitment wording was computers are tested once per quarter, or as frequency specified below. Each of these tests includes standardized and relocated to dictated by NUREG 1394. provisions to ensure that participants in the test are able the SNC Standard Emergency to understand the content of the messages used in the Plan. test.

The Emergency Response Data System (EROS) will be tested on a quarterly basis; ElS-78 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 F.9: In-plant monitoring teams will communicate Specific communications with the Health Physics or OSC communicator at frequencies between the OSC least every half hour. and dispatched response teams are event specific and determined on a case by case basis for the event. A Plan commitment is not appropriate and could actually hinder effective response.

F.9: The field monitoring team radio covers the EP F Table 5 The capability to dispatch teams entire plume exposure pathway EPZ. and for those teams to function is maintained in the SNC Standard Emergency Plan. This statement of radio coverage is not required. F.9: Remote stations for communicating with the EP F.1.1: At SNC operated nuclear power plants, several The commitment wording was field monitoring teams are located in the TSC modes of reliable communication are available, during standardized and relocated to and the EOF. both normal and emergency conditions, to transmit and the SNC Standard Emergency receive information among the Control Room, TSC, OSC, Plan and Site Annex. EOF, and at other locations onsite and offsite. EP F Table 5 Table F-1: All EP F Table 5 The commitment wording was standardized and relocated to the SNC Standard Emergency Plan. Section G Public Education and Information G: Georgia Power Company (GPC) and EP G.8: The goal of the public information program is to The commitment wording was Southern Nuclear Operating Company (SNC) in acquaint the general public with the emergency plans for standardized and relocated to coordination with State and local officials will the operation of APC/GPC nuclear plants, as appropriate, the SNC Standard Emergency provide information to the public at least annually and actions they should in the event of a plant emergency. Plan. regarding how they will be notified and what their Emergency Information is disseminated each calendar actions should be in an emergency. year for residents and transients in the plume exposure pathway Emergency Planning Zone. ElS-79 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 G: All materials used to provide emergency EP G.8: The goal of the public information program is to The SNC Standard Emergency planning information to the public (information acquaint the general public with the emergency plans for Plan and Annex retains the brochures, advertisements, signs and notices, the operation of APC/GPC nuclear plants, as appropriate, commitment to provide the etc.) will be reviewed by GPC and SNC on an and actions they should in the event of a plant emergency. information. The mechanics of annual basis. Emergency Information is disseminated each calendar performing the commitment are year for residents and transients in the plume exposure best controlled by administrative pathway Emergency Planning Zone. procedures. G: The means for disseminating this information EP G.8: The goal of the public information program is to The commitment wording was include information on siren poles, signs, notices acquaint the general public with the emergency plans for standardized and relocated to in public areas, and publications distributed at the operation of APC/GPC nuclear plants, as appropriate, the SNC Standard Emergency least annually. and actions they should in the event of a plant emergency. Plan Emergency Information is disseminated each calendar year for residents and transients in the plume exposure pathway Emergency Planning Zone. G: Information is distributed annually to residents EP G.8: The goal of the public information program is to The commitment wording was in the plume exposure pathway emergency acquaint the general public with the emergency plans for standardized and relocated to planning zone (EPZ) through use of emergency the operation of APC/GPC nuclear plants, as appropriate, the SNC Standard Emergency information communication publications. The text and actions they should in the event of a plant emergency. Plan of the communication addresses the following Emergency Information is disseminated each calendar subjects: year for residents and transients in the plume exposure Summary- pathway Emergency Planning Zone.

What to do if you are warned of an emergency at the VEGPEmergency response plans
When an emergency will affect you
How you will be told about an emergency
What actions you might need to take
What if you are told to shelter
What if you are told to evacuate
Steps to be prepared for an emergency
Steps for using map and chart of evacuation area
Steps to take to get ready for the trip
Classes of accidents
Where to get more information or other help
What radiation is
Special needs card ElS-80 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 G: In addition, public information personnel EP G.8: The goal of the public information program is to The commitment wording was provide public education programs to the 9cquaint the general public with the emergency plans for standardized and relocated to community. the operation of APC/GPC nuclear plants, as appropriate, the SNC Standard Emergency and actions they should in the event of a plant emergency. Plan.

Emergency Information is disseminated each calendar year for residents and transients in the plume exposure pathway Emergency Planning Zone. G.1: Signs and notices providing information to Annex 2.3.6 Several communications methods may be The commitment wording was transients are placed in public recreation areas used to acquaint the public with plans for their protection standardized and relocated to as well as other public places in the plume EPZ during a Plant emergency. Effort will be concentrated the Site Annex. such as siren poles, the Plant Vogtle Visitors upon providing information to the public by written material Center, and in commercial establishments. that is likely to be available in local residences and in

How people will be warned of an emergency. locations frequented by transients. The information will
What to do if warned of an emergency. also provide instructions as to what local media will be
A list of radio and television stations to tune providing additional information in the event of an to for further information emergency.

G.1: Finally, a Vogtle emergency information brochure will be made available within the EPZ to transients at commercial establishments, churches, motels, hunting clubs, Creek and Cawden Plantations, the Plant Vogtle Visitors Center, and through residents whose land is used by nonresidents G.1: Outside the EPZ, the brochure will be made available to timber company offices. G.1: (Outside the EPZ, the brochure will be made available) to the Waynesboro Office of the Agriculture Stabilization & Conservation Service for distribution to farmers who farm, but do not reside, in the EPZ. ElS-81 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 G.1: This material will include the following Annex 2.3.6 Several communications methods may be The commitment wording was information: used to acquaint the public with plans for their protection standardized and relocated to

How people will be warned of an emergency. during a Plant emergency. Effort will be concentrated the Site Annex .
What to do if warned of an emergency. upon providing information to the public by written material
A list of radio and television stations to tune that is likely to be available in local residences and in to for further information. locations frequented by transients. The information will also provide instructions as to what local media will be providing additional information in the event of an emergency.

E15-82 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 G.2: The emergency news center (ENC) will be EP H.2.2: Corporate Media Center (CMC) The commitment wording was the principal point of contact with the news media Upon notification of an Alert or higher classification, the standardized and incorporated during an emergency. The ENC will Public Information Director and corporate staff assigned to into the ERO Staffing as accommodate public information representatives JIC functions will assemble at the CMC. The CMC, described in Section B, Facilities from SNC, GPC, State, local and Federal located at the Atlanta/Birmingham corporate headquarters as described in Section H, the response agencies. building of Georgia Power Company/Alabama Power Emergency Communications Company, as appropriate, is the official location for portion of Section G of the SNC coordination of emergency communications response until Standard Emergency Plan and the site specific JIC has been activated. The Public Section 5.1.6 of the Vogtle 3-4 Information Director will coordinate with the EOF Annex. Emergency Director and affected OROs and determine whether to activate the site specific JIC. When the decision is made to activate the JIC the CMC will maintain emergency communications response coordination until the site specific JIC is ready to assume these responsibilities. Once overall responsibility for emergency communications response transfers to the site specific JIC the remaining CMG staff will provide support for the JIG as needed. Annex 5.1.6. The VEGP JIC is located in Waynesboro, Georgia, adjacent to the Georgia Power Company operating headquarters. The JIC is the central location for the coordination and dissemination of information to news media, and responses to public and media inquiries. Details of the JIG for VEGP are in section H of the Emergency Plan. If the decision is made to activate the JIG the CMG in Atlanta, Georgia will maintain emergency communications response coordination until the JIG is ready to assume these responsibilities. ElS-83 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 H.2.3. Joint Information Center (JIC) The commitment wording was After the initial notification of an emergency at the Alert standardized and incorporated classification or higher, the Public Information Director will into the ERO Staffing as coordinate with the EOF Emergency Director and affected described in Section B, Facilities OROs and determine whether to activate the JIC. Upon as described in Section H, the the decision to activate the JIC, the Public Information Emergency Communications Director and JIC staff transfer from the CMC to the site portion of Section G of the SNC specific JIC. Once the JIC is staffed the Public Information Standard Emergency Plan and Director will manage the emergency communications Section 5.1.6 of the Vogtle 3-4 response from the JIC in coordination with ORO public Annex. information officers (PIOs). Site specific JIC is provided in the site specific Annexes. G.2: GPC will utilize the Corporate Headquarters EP H.2.2: Corporate Media Center (CMC) The commitment wording was Building at 241 Ralph McGill Boulevard, NE, Upon notification of an Alert or higher classification, the standardized and incorporated Atlanta, Georgia, to serve as a temporary Public Information Director and corporate staff assigned to into the ERO Staffing as information center until the ENC in Waynesboro JIC functions will assemble at the CMC. The CMC, (Burke County Office Park) is activated. described in Section B, Facilities located at the Atlanta/Birmingham corporate headquarters as described in Section H, the building of Georgia Power Company/Alabama Power Company, as appropriate, is the official location for Emergency Communications coordination of emergency communications response until portion of Section G of the SNC the site specific JIC has been activated. The Public Standard Emergency Plan and Information Director will coordinate with the EOF Section 5.1.6 of the Vogtle 3-4 Emergency Director and affected OROs and determine Annex. whether to activate the site specific JIC. When the decision is made to activate the JIC the CMC will maintain emergency communications response coordination until the site specific JIC is ready to assume these responsibilities. Once overall responsibility for emergency communications response transfers to the site specific JIC the remaining CMC staff will provide support for the JIC as needed. ElS-84 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 H.2.3 Joint Information Center (JIC) The commitment wording was standardized and incorporated After the initial notification of an emergency at the Alert into the ERO Staffing as classification or higher, the Public Information Director will described in Section B, Facilities coordinate with the EOF Emergency Director and affected as described in Section H, the OROs and determine whether to activate the JIC. Upon Emergency Communications the decision to activate the JIC, the Public Information portion of Section G of the SNC Director and JIC staff transfer from the CMC to the site Standard Emergency Plan and specific JIC. Once the JIC is staffed the Public Information Section 5.1.6 of the Vogtle 3-4 Director will manage the emergency communications Annex. response from the JIC in coordination with ORO public information officers (PIOs). Site specific JIC is provided in the site specific Annexes. G.2: In addition, technical briefers have been EP 8.3.2.9 Technical Assistant The commitment wording was designated who can provide general and The Technical Assistant reports to the Nuclear standardized and incorporated background information. Spokesperson and is responsible for gathering accurate into the ERO Staffing as and timely information about the event and the plant's described in Section B, Facilities status via displays, ENN Forms, and direct contact with as described in Section H, the the EOF Manager. Emergency Communications portion of Section G of the SNC Standard Emergency Plan and Section 5.1.6 of the Vogtle 3-4 Annex. G.2: The Company spokesperson has access to EP 8.3.2.8 Nuclear Spokesperson The commitment wording was all information and telephone contact with the The Nuclear Spokesperson speaks on behalf of the standardized and incorporated emergency director through the EOF Manager. company, providing plant status updates during news into the ERO Staffing as He briefs the media on plant status and briefings. The Spokesperson also may do one-on-one described in Section B, Facilities Company emergency activities. media interviews. The position works with the Technical as described in Section H, the Assistant in keeping abreast of the event status and keeps Emergency Communications the PIO posted on that status. portion of Section G of the SNC Standard Emergency Plan and Section 5.1.6 of the Vogtle 3-4 Annex. ElS-85 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 G.2: The Company spokesperson position is EP 8.3.2.8 Nuclear Spokesperson The commitment wording was filled by individuals who, under normal The Nuclear Spokesperson speaks on behalf of the standardized and incorporated operations, hold supervisory positions on the company, providing plant status updates during news into the ERO Staffing as SNC Corporate or plant staff and are technically briefings. The Spokesperson also may do one-on-one described in Section B, Facilities and professionally qualified to perform this media interviews. The position works with the Technical as described in Section H, the important function. Assistant in keeping abreast of the event status and keeps Emergency Communications the PIO posted on that status. portion of Section G of the SNC Standard Emergency Plan and Section 5.1.6 of the Vogtle 3-4 Annex. G.3: GPC and SNC will provide timely and EP 8.3.2.1 Public Information Director (PIO) The commitment wording was accurate information to local, State and federal The PIO is responsible for coordination of emergency standardized and incorporated agencies, and will seek reciprocal information information between the utility and responding offsite into the ERO Staffing as from these agencies. organizations participating in the Corporate Media Center described in Section B, Facilities (CMC) or Joint Information Center (JIC). Additional duties as described in Section H, the include managing approval and dissemination of utility Emergency Communications news bulletins, facilitating news briefings, overseeing portion of Section G of the SNC public response, serving as liaison to the media and Standard Emergency Plan and coordinating off-site agencies. The PIO may delegate Section 5.1.6 of the Vogtle 3-4 emergency communications approval authority to other Annex. staff members. G.4: Rumors will be controlled by providing EP G.5: Public Response The commitment wording was timely, accurate, and consistent information to All appropriate information will be released as clearly, standardized and incorporated the public and by having a single source of concisely and quickly as possible. Public announcements into the ERO Staffing as information. will be made on a frequent and regular basis. described in Section B, Facilities as described in Section H, the Emergency Comm~nications portion of Section G of the SNC Standard Emergency Plan and Section 5.1.6 of the Vogtle 3-4 Annex. ElS-86 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 G.4: To dispel rumors in an emergency, a rumor EP G.4 Press Briefings The commitment wording was control network will be activated. News media Press briefings will be conducted to keep the media standardized and incorporated will be monitored to detect and respond to informed of events and activities relating to the into the ERO Staffing as misinformation. emergency. Briefings will provide the most current, up-to- described in Section B, Facilities date information about events and response to the as described in Section H, the incident. Public Information Officers (PIOs) from all offsite Emergency Communications agencies responding to the emergency will be encouraged portion of Section G of the SNC to participate in the briefings to discuss their particular Standard Emergency Plan and activities. Section 5.1.6 of the Vogtle 3-4 Annex. G.5: GPC will offer an annual program to EP G.2: A program will be offered each calendar year to The commitment wording was acquaint the news media with the methodology acquaint the news media with the methodology for standardized and relocated to for obtaining information about overall obtaining information during an emergency and with the SNC Standard Emergency emergency preparedness at the VEGP. Training overall emergency preparedness at APC/GPC nuclear Plan. will include information about the plant, radiation, plants, as appropriate. Training will include information and the role of the emergency news center. about the plant, emergency response and the role of the JIC as well as opportunities to participate in drill activities. Section H Emergency Facilities and Equipment H.1.1: In addition, portable radiation monitors will Annex 5.1.2 The ventilation system will be operated in The commitment wording was be available for personnel in transit from the TSC accordance with emergency plan implementing standardized and relocated to to other areas. procedures (EPIPs) and will be manually controlled from the SNC Standard Emergency the TSC. The ventilation system will operate in the Plan and Site Annex.The pressurization and filtering mode upon detection of high procedure reference is deleted. radiation in the TSC ventilation intake. In addition, The SNC Standard Emergency portable radiation monitors will be available for personnel Plan retains the commitment to in transit from the TSC to other areas. Portable air provide the appropriate breathing apparatus and anti-contamination clothing will radiological protection of TSC also be available for the TSC. responders. Procedures will be developed consistent with the License Amendment Request and in accordance with the requirements of 10 CFR 50.54(q). ElS-87 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 H.1.1: Lighting will be powered by the normal and Annex 5.1.2: Lighting will be powered by the normal and The commitment wording was redundant electrical supply system. An redundant electrical supply system. An emergency battery standardized and relocated to emergency battery operated lighting system will operated lighting system will be installed. the Site Annex. be installed. H.1.1: Motorized vehicles are provided to The history of drills and facilitate the movement of personnel between the exercises supplemented by TSC and the Site's Control Rooms limited actual events has determined that personnel transit between the Control Room and the TSC is not effective in the overall command and control process. The enhancements in data transmission and phone/radio voice communication have effectively eliminated the need for transit between facilities. H.1.1: Portable air breathing apparatus and anti- Annex 5.1.2: Portable air breathing apparatus and anti- The commitment wording was contamination clothing will also be provided in contamination clothing will also be available for the TSC standardized and relocated to the TSC. the Site Annex. H.1.1: Power for vital information systems will be Annex 5.1.2: Power for vital information systems will be The commitment wording was provided by redundant power supplies including provided by redundant power supplies including a battery standardized and relocated to a battery backed uninterruptible power supply backed uninterruptible power supply system. the Site Annex. system H.1.1: The air supply is filtered by high efficiency Annex 5.1.2: The ventilation system will include high The commitment wording was particulate air (HEPA) and charcoal filters. efficiency particulate air (HEPA) and charcoal filters. standardized and relocated to the Site Annex. ElS-88 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 H.1.1: The documents that will be maintained in Annex 5.1.2: The records storage is shared by the control The commitment wording was the TSC include:Technical Specifications.Plant room and the TSC. These records can be accessed via a standardized and relocated to Operating Procedures.Final Safety Analysis digital records system. This system is supplied backup the Site Annex. Reports. Emergency Plan. Emergency power via an uninterruptible power supply to allow Implementing Procedures.System piping and retrieval of records in the event of a loss of power. These instrumentation diagrams and heating, records include but are not limited to. ventilation, and air-conditioning (HVAC) flow

Technical Specifications .

diagrams.Piping area drawings.Electrical one-

Plant Operating Procedures .

line, elementary, and wiring diagrams.Control

Final Safety Analysis Report.

logic and loop diagrams.Records needed to

Emergency Plan.Emergency Plan Implementing perform the functions of the emergency operating Procedures.

facility (EOF) when it is not operational.In addition, copies of the above-listed documents

Plant operating records .

and the following documents are available

System piping and instrumentation diagrams and heating, ventilation, and air-conditioning (HVAC) inVEGP Document Control: Plant operating flow diagrams.

records.Plant Review Board records and reports.

Electrical one-line, elementary, and wiring diagrams.
Control logic and loop diagrams .

H.1.1: The emergency director and NRC director Annex 5.1.2 The Emergency Director and NRC director The commitment wording was will be located in close proximity to ensure proper will be co-located to ensure proper communications standardized and relocated to communications. the Site Annex. Note that the SNC Standard Emergency Plan provides space in both the TSC and EOF. The responding NRC team will have the option of positioning personnel in either location. ElS-89 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 H.1.1: The TSC is equipped with a computer Annex 5.1.2 The TSC will be equipped with a computer The commitment wording was system, which provides source term and system, which provides source term and meteorological standardized and relocated to meteorological data and technical data displays data and technical data displays to allow TSC personnel the SNC Standard Emergency to allow TSC personnel to perform detailed to perform detailed analysis and diagnosis of abnormal Plan. analysis and diagnosis of abnormal plant plant conditions, including assessment of any significant conditions, including assessment of any release of radioactivity to the environment. In addition, the significant release of radioactivity to the TSC will have ready access to plant records. environment. Section H.1.1: In addition, the TSC has ready access to plant records. H.1.1: The TSC structure and ventilation system Annex 5.1.2: The TSC structure and ventilation system The commitment wording was are designed to ensure that the TSC personnel will be designed to ensure that the TSC personnel are standardized and relocated to are protected from radiological hazards. protected from radiological hazards. the Site Annex. ElS-90 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 H.1.1: The TSC will be established consistent Annex 5.1.2: The TSC structure and ventilation system The commitment wording was with NUREG 0696. will be designed to ensure that the TSC personnel are standardized and relocated to protected from radiological hazards. the SNC Standard Emergency EP H.1.2 Technical Support Center (TSC) Plan and Site Annex. SNC operated nuclear power plants have established a TSC for use during emergency situations by plant The wording was updated to management, technical, and engineering support provide more specific capabilities personnel. The TSC is procedurally required to be for the facility. activated within 75 minutes following the declaration of an Alert or higher classification. Activation for Unusual Events or unclassified incidents is optional. When activated, TSC functions include:

Support for the Control Room's emergency response efforts.
Performance of response management functions when in Command & Control.
Continued evaluation of event classification .
Assessment of the plant status and potential offsite impact.
Coordination of emergency response actions
Notification of appropriate corporate and plant management.
Notification and update of the NRC via the Emergency Notification System (ENS)
Notification and update of the NRC via Health Physics Network (HPN).

H.1.1: The TSC will provide plant management Annex 5.1.2 The TSC will provide plant management and The commitment wording was and technical support personnel (including five technical support personnel (including Nuclear Regulatory standardized and relocated to Nuclear Regulatory Commission (NRC) Commission (NRC) personnel) with a facility from which the Site Annex. personnel) with a facility from which they can they can assist plant operating personnel located in the assist plant operating personnel located in the control rooms during an emergency. control rooms during an emergency. H.1.1: The ventilation system will be designed to Annex 5.1.2: The ventilation system will be designed to The commitment wording was maintain exposures to occupants at or below 5 maintain exposures to occupants at or below 5 rem total standardized and relocated to rem total effective dose equivalent (TEDE) for the effective dose equivalent (TEDE) for the duration of the the Site Annex. duration of the accident. accident. ElS-91 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 H.1.1: The ventilation system will be operated in Annex 5.1.2 The ventilation system will be operated in The commitment wording was accordance with emergency implementing accordance with emergency plan implementing standardized and relocated to procedures (EIPs) and will be manually procedures (EPIPs) and will be manually controlled from the Site Annex. controlled from the TSC. the TSC. The procedure reference is deleted. The SNC Standard Emergency Plan retains the commitment to provide the appropriate radiological protection of TSC responders. Procedures will be developed consistent with the License Amendment Request and in accordance with the requirements of 10 CFR 50.54(q). Procedures will be submitted to the NRG no later than 180 days prior to fuel load ion each unit. H.1.1: The ventilation system will operate in the Annex 5.1.2 The ventilation system will operate in the The commitment wording was pressurization and filtering mode upon detection pressurization and filtering mode upon detection of high standardized and relocated to of high radiation in the TSC ventilation intake. radiation in the TSC ventilation intake. the SNC Standard Emergency Plan and Site Annex.The procedure reference is deleted. The SNC Standard Emergency Plan retains the commitment to provide the appropriate radiological protection of TSC responders.Procedures will be developed consistent with the License Amendment Request and in accordance with the requirements of 10 CFR 50.54(q). E15-92 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 H.1.1: The TSC will be powered by reliable and Annex 5.1.2: The TSC will be powered by reliable and The commitment wording was redundant power supplies. Lighting will be redundant power supplies. Lighting will be powered by the standardized and relocated to powered by the normal and redundant electrical normal and redundant electrical supply system. An the Site Annex. supply system. An emergency battery operated emergency battery operated lighting system will be lighting system will be installed. Power for vital installed. Power for vital information systems will be information systems will be provided by provided by redundant power supplies including a battery redundant power supplies including a battery backed uninterruptible power supply system. backed uninterruptible power supply system H.1.2: Emergency kits containing radiation Annex 5.1.3 Emergency kits containing radiation The commitment wording was monitoring equipment, first aid supplies, monitoring equipment, first aid supplies, decontamination standardized and relocated to decontamination supplies, breathing apparatus, supplies, breathing apparatus, portable lighting, and hand- the Site Annex. portable lighting, and hand-held radios are stored held radios are stored in the OSC. in the OSC. The commitment to perform OSC operations is maintained unchanged by the SNC Standard Emergency Plan. The responsibility of conducting OSC operations is included in Section B job descriptions of the various OSC leaders. The OSC Manager's job description contains the overall unchanged intent of job operations. Specifics in each area (RP, Maint, Ops, etc.) are included in the remainder of the job descriptions in 8.2. H.1.2: Evacuation of the OSC will be conducted Annex 5.1.3 Evacuation of the OSC will be conducted The commitment wording was according to emergency implementing according to emergency implementing procedures. standardized and relocated to procedures the SNC Standard Emergency Plan. ElS-93 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 H.1.2: In the event that this facility becomes Annex 5.1.3: In the event that this facility becomes The commitment wording was uninhabitable, the functions of the OSC will be uninhabitable, the functions of the OSC will be conducted standardized and relocated to conducted from the designated back-up OSC from Outage Control Center (OCC) located in the Annex the Site Annex. space in the Outage Control Center (OCC) Building if Unit 3 or Unit 4 is affected unit and from located in theAnnex Building if Unit 3 or Unit 4 is Clearance and Tagging (C&T) located in the control the affected unit and from Clearance and building if Unit 1 or Unit 2 is the affected unit. These Tagging (C&T) located in the control building if designated back-up OSC spaces will have the same Unit 1 or Unit 2 is the affected unit. capability as the OSC. Evacuation of the OSC will be conducted according to emergency implementing procedures. These procedures will describe the method by which the OSC is evacuated and the movement of personnel to other facilities H.1.2: Status boards containing plant conditions Due to the ongoing evolution of and emergency classification will be available in electronic capabilities for display the and dissemination of information OSC. the specific reference to status boards was eliminated from the SNC Standard Emergency Plan. Facility Operating Procedures will direct information dissemination. H.1.2: The OSC has been established to be EP H.1.3: The OSC has been established to provide an The commitment wording was consistent with NUREG 0696 guidelines as area for coordinating and planning of activities and the standardized and relocated to described below. staging of personnel and equipment. the SNC Standard Emergency Plan. H.1.2: The OSC is where operational support Annex 5.1.3 The OSC is where operational support The commitment wording was personnel (such as instrument technicians, personnel (such as instrument technicians, engineers, standardized and relocated to engineers, mechanics, electricians, chemical/radiation technicians, the Site Annex. mechanics, electricians, chemical/radiation equipment operators, and incoming shift personnel) technicians, equipment operators, and incoming assemble to aid in the response to an emergency. shift personnel) assemble to aid in the response to an emergency. ElS-94 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 H.1.3 & Appendix 7: The EOF is located in EP H.2.1 The EOF is the central location for management The commitment wording was Birmingham, Alabama and serves as the EOF for of the offsite emergency response, coordination of standardized and relocated to all SNC sites (VEGP,FNP, and HNP). radiological assessment, and management of initial the SNC Standard Emergency recovery operations. The EOF is a dedicated facility Plan. located in Birmingham, Alabama, and serves as the EOF for SNC sites (VEGP, FNP, and HNP). The EOF is procedurally required to be activated within 75 minutes following the declaration of an Alert or higher classification The EOF provides for:

Management of overall emergency response
Coordination of radiological and environmental assessments.
Protective Action Recommendations .
Notification of Offsite Agencies .
Management of recovery operations .
Notification and update of the NRC via ENS .
Notification and update of the NRC via Health Physics Network (HPN).
Coordination of emergency response activities with federal, state, and local agencies.

H.3: Activation of the OSC will be initiated at an EP H.1: SNC operated nuclear power plants have The commitment wording was Alert or higher level classification. established a TSC and an onsite OSC, which are staffed standardized and relocated to and activated within 75 minutes of the declaration of an the SNC Standard Emergency Alert or higher classification. Plan.The SNC Standard Emergency Plan requests ERO augmentation be revised to 75 minutes as part of this submittal. That justification is provided in the Technical Analysis Section of this submittal rather than repeated in the table each place it's referenced. ElS-95 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 H.3: The OSC will be operational within about an EP H.1: SNC operated nuclear power plants have The commitment wording was hour of initial notification. established a TSC and an onsite OSC, which are staffed standardized and relocated to and activated within 75 minutes of the declaration of an the SNC Standard Emergency Alert or higher classification. Plan. The SNC Standard Emergency Plan requests ERO augmentation be revised to 75 minutes as part of this submittal. That justification is provided in the Technical Analysis Section of this submittal rather than repeated in the table each place it's referenced. H.3: Upon declaration of an Alert or higher level EP H.1: SNC operated nuclear power plants have The commitment wording was classification, the TSC will be activated and will established a TSC and an onsite OSC, which are staffed standardized and relocated to be operational within about an hour of the initial and activated within 75 minutes of the declaration of an the SNC Standard Emergency notification. Overall Alert or higher classification. Plan. The SNC Standard Emergency Plan requests ERO augmentation be revised to 75 minutes as part of this submittal. That justification is provided in the Technical Analysis Section of this submittal rather than repeated in the table each place it's referenced. ElS-96 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 H.4.5: As described in UFSAR Subsection EP H.5.3 Process Monitors The commitment wording was 18.8.2, Safety Parameter Display System The Control Room and redundant backup locations are standardized and relocated to (SPDS), the SPDS is integrated into the design equipped with extensive plant process monitors for use in the SNC Standard Emergency of the AP1000 human system interface both normal and emergency conditions. These indications Plan. resources. include reactor coolant system pressure and temperatures, containment pressure and temperature, and various liquid levels, flow rates, status or lineup of equipment components. EP H.5.3.1 Plant Monitoring/Information System A plant monitoring/information system provides the data acquisition and database capability for performing plant monitoring and functions. The system is designed to scan, convert to engineering units, make sensor range and alarm limit checks, apply required transformations, store for recall and analysis, and display the reading of transformed data from plant instrumentation. The system scans flows, pressures, temperatures, fluid levels, radiation levels, equipment, and valve status at required frequencies. EP H.5.3.2 Safety Parameter Display System (SPDS) The SPDS parameters are available during normal and abnormal operating conditions in the Control Room, TSC, and EOF. H.4.6: Liquid samples from the reactor coolant EP H.5.2.2: The process sampling system consists of the The commitment wording was system and the containment sumps, and air normal sampling system and additional sampling panels standardized and relocated to samples from the containment atmosphere may located throughout the plant. Pre-designated monitoring the SNC Standard Emergency be taken during accident conditions. and sampling points are listed in site procedures. Plan. Sampling systems are installed or can be modified to permit reactor coolant and containment atmosphere sampling even under severe accident conditions. It is capable of providing information relative to post-accident plant conditions to allow operator actions to be taken to mitigate and control the course of an accident. ElS-97 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 H.5.2: Each team will include two people who will EP 8.2.2.7 The following emergency teams may be The commitment wording was obtain an emergency monitoring kit. formed by OSC personnel, as necessary. standardized and relocated to Section 1.5: Monitoring teams of at least two

Search and rescue the SNC Standard Emergency people are formed and dispatched at the OSC or
Repair Plan.

TSC as appropriate.

Post accident sampling
Internal survey
Field monitoring EP 1.7: In addition to the capabilities and resources described in Section H, SNC operated nuclear power plants have the ability to take offsite air samples and to directly measure gamma dose rates from a radioactive material release. The capability to take offsite soil, water, and vegetation samples is provided by a minimum of two (2) Field Monitoring Teams (FMTs).

H.5.2: Results of the offsite monitoring activities EP I. 7: Field monitoring data is analyzed by personnel in The commitment wording was will be provided to the TSC until the dose the TSC until relieved by the EOF staff. standardized and relocated to assessment activities are transferred from the the SNC Standard Emergency TSC to the EDF.Section 1.5: They will be Plan. controlled by the TSC until the responsibility is transferred to the EOF. H.5.2: The kits will include dosimeters, a two-way EP 1.9: Field monitoring equipment has the capability to The commitment wording was radio, meters for measuring gamma and detect and measure airborne radioiodine in the presence standardized and relocated to beta/gamma dose rates, and air samplers for of noble gases that has the capability to detect and the SNC Standard Emergency collecting particulates and iodines. measure radioiodine concentrations in air in the plume Plan. Section 1.5: The emergency monitoring kits exposure EPZ as low as 10-7 uCi/cc (microcuries per contain a portable air sampler, silver zeolite cubic centimeter) under field conditions. Interference from The SNC Standard Emergency cartridges, and counters to provide the capability the presence of noble gas and background radiation shall Plan retains the commitment to to detect and measure radioiodine concentrations not decrease the stated minimum detectable activity. perform the function rather than in the air as low as 10-7 µCi/cc. the specifics on equipment. ElS-98 5 to NL-16-0169 Vogtle (Units* 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 H.5.2: VEGP monitoring teams will remain on the EP 1.7: In addition to the capabilities and resources The commitment wording was Georgia side of the Savannah River. described in Section H, SNC operated nuclear power standardized and relocated to plants have the ability to take offsite air samples and to the SNC Standard Emergency directly measure gamma dose rates from a radioactive Plan. material release. The capability to take offsite soil, water, and vegetation samples is provided by a minimum of two The most effective positioning of (2) Field Monitoring Teams (FMTs). the monitoring teams is event specific. The existing Plan statement limiting the locations of the SNC teams is not needed. H.5.2: VEGP will have sufficient portable EP 1.7: The capability to take offsite soil, water, and The commitment wording was equipment and trained personnel to field three vegetation samples is provided by a minimum of two (2) standardized and relocated to field monitoring teams. Field Monitoring Teams (FMTs). the SNC Standard Emergency Plan. The modification of the commitment to provide two vs. three field teams aligns with industry standards. The bases for the original commitment to deploy three field teams cannot be determined at this point. H.5.2: VEGP will have sufficient portable EP 1.7: The capability to take offsite soil, water, and The commitment wording was equipment and trained personnel to field three vegetation samples is provided by a minimum of two (2) standardized and relocated to field monitoring teams. Field Monitoring Teams (FMTs). the SNC Standard Emergency Section 1.5: The emergency director or his Plan. designee can deploy up to three teams for field monitoring. The modification of the commitment to provide two vs. three field teams aligns with industry standards. The bases for the original commitment to deploy three field teams cannot be determined at this point. ElS-99 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 I H.5.3: Backup laboratory facilities are available at EP H.6.3 Laboratory Facilities The commitment wording was Plant Hatch. External facilities for counting and analyzing samples, standardized and relocated to I dosimetry processing, can be provided by the other SNC the SNC Standard Emergency operated plants including the GPC Central Laboratory, Plan. state, federal or contracted laboratories. Outside analytical assistance may be requested from state and federal agencies, or through contracted vendors. The DOE, through the Radiological Assistance Program (RAP) has access to any national laboratory. H.5.3: The GPC environmental laboratory located EP H.6.3 Laboratory Facilities The commitment wording was in Smyrna, GA has the capability to perform External facilities for counting and analyzing samples, standardized and relocated to isotopic analyses of drinking water, river water, dosimetry processing, can be provided by the other SNC the SNC Standard Emergency milk, vegetation, sediment, and biological operated plants including the GPC Central Laboratory, Plan. samples, as well as tritium and gross-beta state, federal or contracted laboratories. Outside analysis. In addition, processing of environmental analytical assistance may be requested from state and thermos luminescent dosimeters (TLDs) will be federal agencies, or through contracted vendors. The handled by this laboratory. DOE, through the Radiological Assistance Program (RAP) has access to any national laboratory. H.5.3: VEGP has laboratory facilities for analysis EP H.5.2.3: SNC sites have a laboratory facility for The commitment wording was of radioactive samples. The major pieces of analysis of radioactive samples. standardized and relocated to equipment include a solid-state gamma EP H.6.3 Laboratory Facilities the SNC Standard Emergency spectrometer and a beta/gamma gas proportional External facilities for counting and analyzing samples, Plan. counter. dosimetry processing, can be provided by the other SNC operated plants including the GPC Central Laboratory, state, federal or contracted laboratories. Outside analytical assistance may be requested from state and federal agencies, or through contracted vendors. The DOE, through the Radiological Assistance Program (RAP) has access to any national laboratory. H.6: A set of spares of certain equipment is also EP H.8:. The commitment wording was maintained to replace inoperative or out-of- Sufficient reserves of instruments and equipment are standardized and relocated to calibration equipment. maintained to replace those removed from emergency kits the SNC Standard Emergency or lockers for calibration or repair. Plan. ElS-100 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 H.6: Emergency kits are located in the TSC (for EP H.9: Emergency kits are available at SNC operated The commitment wording was control room also), the OSC, the health physics nuclear power plants. Designated site or department standardized and relocated to control point, the EOF and other plant procedures identify the equipment in the various the SNC Standard Emergency locations.Section H.6: An ambulance kit will be emergency kits. Plan and Site Annex. carried by the VEGP health physics technician Annex 5.5: Emergency supplies and equipment are who accompanies the ambulance. located in the Control Room, the TSC, the OSC, the health physics control points, and other plant locations. Procedures require an inspection and operational check of equipment in these kits on a quarterly basis and after each use. Equipment in these kits is calibrated in accordance with procedures. A set of spares of certain equipment is also maintained to replace inoperative or out-of-calibration equipment. H.6: Procedures require an inspection and EP H.8: Emergency facilities and equipment are inspected The commitment wording was operational check of equipment in these kits on a and inventoried using appropriate administrative or standardized and relocated to quarterly basis and after each use. department procedures. These inventories will include the SNC Standard Emergency Section H.6: Equipment in these kits is calibrated requirements that provisions are in place to inspect, Plan. in accordance with the suppliers' inventory, and operationally check emergency recommendations. equipment/instruments at least once each calendar quarter and after each use. These procedures provide information on location and availability of emergency equipment and supplies. Section I Accident Assessment I: Initial assessment actions are the responsibility EP 8.1 SNC plants maintain 24-hour emergency The commitment wording was of the shift superintendent and/or the shift response capability. The normal on-shift complement standardized and relocated to supervisor, using available shift personnel. provides the initial response to an emergency. This group the SNC Standard Emergency is trained to respond to emergency situations until the Plan. The responsibility was augmented Emergency Response Organization (ERO) relocated to Section B arrives. description of on-shift staff and ED responsibilities. ElS-101 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 I: Subsequent assessment actions are directed EP B.1.1 In an emergency, the SM assumes the The commitment wording was by the emergency director with assistance from responsibility of the Emergency Director (ED) and takes standardized and relocated to the control room, technical support center (TSC), necessary actions to identify and respond to the the SNC Standard Emergency emergency operations facility (EOF), and emergency until relieved by another qualified ED. The ED Plan. emergency teams, as necessary. has the responsibility and authority to immediately and unilaterally initiate emergency actions, including providing notification of Protective Action (PAR) Recommendations to State and Local government organizations responsible for implementing off site emergency measures. After being relieved as Emergency Director, the Shift Manager directs the activities of the operating crew and is responsible for the safe operation of the plant. 1.2: In-plant radiological measurements provide EP H.5.2.1 Radiation Monitoring System (RMS) The commitment wording was information to help assess emergency conditions. Radiation monitoring instruments are located at selected standardized and relocated to The containment high-range radiation monitor areas within the plant to detect, measure, and record the SNC Standard Emergency and containment hydrogen monitor are used to radiation levels. The monitors are comprised of area, Plan. provide an early indication of the quantity of airborne and air particulate monitors. radioactivity available for release from the

Area monitors respond to gamma radiation.

containment. Emergency procedures include a

Airborne monitors are capable of detecting and correlation between the monitor reading and the measuring radioactive gaseous effluent extent of core damage. These correlations are concentrations.

based on the Westinghouse Owners Group

Air Particulate detectors capture and measure (WOG) Core Damage Assessment Guidance, airborne particulate.

WCAP-14696-A, Revision 1, November 1999. A Emergency response procedures provide methods for more detailed assessment of core damage is determining relationships between monitor readings and then performed using emergency implementing releases, material available for release and extent of core procedures which are also based on the WOG damage. methodology. 1.2 Samples can be obtained from the reactor EP H.5.2.2: Sampling systems are installed or can be The commitment wording was coolant system (RCS), the containment sump, modified to permit reactor coolant and containment standardized and relocated to and the containment atmosphere, and are used atmosphere sampling even under severe accident the SNC Standard Emergency for all radiochemical analyses. conditions. It is capable of providing information relative Plan. to post-accident plant conditions to allow operator actions to be taken to mitigate and control the course of an accident. Various chemical analyses and radiological measurements on these samples can be performed, including the determination of radionuclide concentrations. ElS-102 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 1.2 Grab samples can be transported in a EP H.5.2.2: Sampling systems are installed or can be The commitment wording was shielded cask. modified to permit reactor coolant and containment standardized and relocated to atmosphere sampling even under severe accident the conditions. It is capable of providing information relative to SNC Standard Emergency Plan. post-accident plant conditions to allow operator actions to be taken to mitigate and control the course of an accident. Various chemical analyses and radiological measurements on these samples can be performed, including the determination of radionuclide concentrations. 1.2: Reactor coolant grab samples can be either EP B.4.3.1 Contract laboratories can provide assistance The commitment wording was diluted or undiluted. Grab samples can be in environmental monitoring and sampling. standardized and relocated to transported in a shielded cask. Analysis EP C.3.2: Additional outside analytical assistance may be the SNC Standard Emergency capability meets all Final Safety Analysis Report requested from contracted vendors. These laboratories Plan. (FSAR) commitments to Regulatory Guide 0737, provide bioassay analysis and radiochemical analysis 11.8.3. In addition to the onsite capabilities for services. radiological assessment, AREVA ANP has EP H.6.3: External facilities for counting and analyzing agreed to provide backup analysis of high samples, dosimetry processing, can be provided by the radioactivity level samples per the purchase other SNC operated plants including the GPC Central order listed in Appendix 2. Laboratory, state, federal or contracted laboratories. Outside analytical assistance may be requested from state and federal agencies, or through contracted vendors. The DOE, through the Radiological Assistance Program (RAP) has access to any national laboratory. 1.2 In addition to the onsite capabilities for EP B.4.3.1 Contract laboratories can provide assistance The commitment wording was radiological assessment, AREVA ANP has in environmental monitoring and sampling. standardized and relocated to agreed to provide backup analysis of high EP C.3.2: Additional outside analytical assistance may be the SNC Standard Emergency radioactivity level samples per the purchase requested from contracted vendors. These laboratories Plan. order listed in provide bioassay analysis and radiochemical analysis Appendix 2. services. EP H.6.3: External facilities for counting and analyzing samples, dosimetry processing, can be provided by the other SNC operated plants including the GPC Central Laboratory, state, federal or contracted laboratories. Outside analytical assistance may be requested from state and federal agencies, or through contracted vendors. The DOE, through the Radiological Assistance Program (RAP) has access to any national laboratory. ElS-103 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 1.2 The TSC Manager will approve and direct the The statement of process was transport of the grab sample to AREVA ANP. eliminated. Procedural control for the release of material offsite is maintained by existing site non-emergency procedures. 1.3: The source term or release rate is EP H.5.2.2: Sampling systems are installed or can be The commitment wording was determined using the process and effluent modified to permit reactor coolant and containment standardized and relocated to radiation monitoring systems, and measured or atmosphere sampling even under severe accident the SNC Standard Emergency estimated flow rates for releases via monitored conditions. It is capable of providing information relative Plan. effluent release paths. to post-accident plant conditions to allow operator actions In the event that instrumentation is off-scale or to be taken to mitigate and control the course of an inoperable, direct measurements with portable accident. Various chemical analyses and radiological survey instruments will be used for determination measurements on these samples can be performed, and verified by field monitoring team samples. including the determination of radionuclide concentrations. ElS-104 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 1.4: Computer dose calculation systems will be EP H.5.2.1 Radiation Monitoring System (RMS) The commitment wording was located in both the TSC and EOF for offsite dose Radiation monitoring instruments are located at selected standardized and relocated to assessment purposes. These systems will areas within the plant to detect, measure, and record the SNC Standard Emergency support the MIDAS code, a VEGP-specific radiation levels. The monitors are comprised of area, Plan. version of airborne and air particulate monitors. a dose assessment computer code developed by

Area monitors respond to gamma radiation .

Pickard, Lowe, and Garrick, Inc., (PLG). The

Airborne monitors are capable of detecting and code is based on a PLG application entitled measuring radioactive gaseous effluent Calculation of Reactor Accident Consequences concentrations.

Including Trajectory (CRACIT), which is similar in

Air Particulate detectors capture and measure concept to that in the CRAG program written for airborne particulate.

the Reactor Safety Study. The MIDAS version is Emergency response procedures provide methods for referred to as MIDRAC. The basic functions of determining relationships between monitor readings and MIDRAC are the calculation of dispersion of the releases, material available for release and extent of core released material as it travels downwind and the damage. estimation of the resulting concentrations of this EP 1.3: The dose calculation model is provided in the material. Dispersion is modeled using the Control Room, TSC, and EOFfor use in projecting straight-line Gaussian dispersion model and potential offsite doses. The commitment is to maintain variable trajectory transport. Initial dose EP 1.3: SNC operated nuclear power plants use an offsite the comparison with EPA PAGs. projections can be made within 15 minutes of a dose assessment program which estimates doses from The time reference is not radiological release utilizing the computer radiological accidents for comparison with the EPA required to support the PAR system. Protective Action Guidance and acute health effect process. Subsequent dose projections will be made thresholds. approximately every 15-30 minutes depending on the variability of meteorological conditions and/or radioactive releases. 1.4: MIDAS is a persona! ,computer based EP 1.3: The dose calculation model is provided in the The statement of process was program for rapidly assessing the radiological Control Room, TSC, and EOF for use in projecting eliminated. Procedural control impact of accidents at nuclear power plants. It potential offsite doses. for the release of material offsite calculates total effective dose equivalent (TEDE), is maintained by existing site thyroid doses, and skin doses at various fixed non-emergency procedures. downwind distances. Source term information is derived from plant effluent monitors, RCS or containment samples, field monitoring teams, or default accident scenario. ElS-105 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 1.4: Actual meteorological data and release rate EP 1.1: Plant system and effluent parameter values are The commitment wording was data are obtained from the plant computer and used in the determination of accident severity and standardized and relocated to information systems, and entered into the dose subsequent emergency classification. Environmental and the SNC Standard Emergency projection computer. Minimum meteorological meteorological events are also determining factors in Plan. data to be obtained include wind speed, wind emergency classification. An emergency condition can be direction, and a stability indicator (either vertical the result of just one parameter or condition change, or temperature difference or standard deviation of the combination of several. The specific symptoms, the horizontal wind direction). Plant-specific parameter values, or events for emergency classification default values are part of the program for use levels are detailed in the plant's site-specific Annex.To when meteorological or release rate data are not adequately assess the emergency condition, applicable available. The computer will calculate dispersion, emergency facilities have the equipment and dose, and plume arrival times. Dose calculations instrumentation necessary to monitor essential plant are based on dose conversion factors (DCF) information except where local monitoring is required. from EPA 400. Evaluation of plant conditions is accomplished by monitoring plant parameters from both the Control Room and within the plant. 1.4: Default release rates are available for EP 1.3: The program estimates reactor source term, The commitment wording was possible accidents in the event that measured atmospheric transport, and doses resulting from standardized and relocated to source term data are not available or the case radiological emergencies and can be used to assist in the SNC Standard Emergency where bounding calculations are desired. making protective action determinations The system Plan. supplements assessments based on plant conditions and quick estimates based on hand-calculation methods. The model was developed to allow consideration of the dominant aspects of source term, transport, dose, and consequences. Because the program is designed to be used during a radiological emergency, it is assumed that the amount of activity being released and the meteorological conditions will not be precisely known. EP 1.6 Unmonitored Release Dose projections can be made during a release through use of sample data in situations where effluent monitors are either off-scale, inoperative, or the release occurs by an unmonitored flow path. In the absence of effluent sample data, a computerized offsite dose projection can be performed by specifying the accident category as a default. ElS-106 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 1.4: In the event both the primary and backup EP H.5.1: The National Weather Service (NWS) maintains The commitment wording was meteorological systems are unavailable, an automated observation station at the airport; and wind standardized and relocated to meteorological data will be obtained by speed, wind direction, cloud cover, and ceiling height can the SNC Standard Emergency commercial telephone directly from the National be obtained. Plan and Site Annex. Weather Service located in Columbia, South Annex 5.6.1: Additionally, meteorological information can Carolina. be obtained from the National Weather Service to supplement onsite data and provide a backup to the plant meteorological monitoring program on an as needed basis. 1.4: The VEGP field monitoring team will collect EP 1.7 Environs Surveys and Monitoring In addition to the The commitment wording was sufficient environmental data to characterize the capabilities and resources described in Section H, SNC standardized and relocated to initial deposition of activity, the peak activity in operated nuclear power plants have the ability to take the SNC Standard Emergency pasture grass and milk, and total intake of 1-131, offsite air samples and to directly measure gamma dose Plan.The modification of the Cs-137, Sr-90, and Sr-89. rates from a radioactive material release. The capability commitment to provide two vs. to take offsite soil, water, and vegetation samples is three field teams aligns with provided by a minimum of two (2) Field Monitoring Teams industry standards. The bases (FMTs). for the original commitment to The environmental monitoring equipment includes deploy three field teams cannot portable survey, counting, and air sampling be determined at this point. instrumentation and other radiological monitoring equipment and supplies to be used by the FMTs. Samples are taken at predetermined locations as well as those locations specified during and after a release. Environmental measurements are used as an aid in the determination and assessment of protective actions for the general public and recovery actions for the plant. ElS-107 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 1.4: When precipitation is predicted or occurring EP 1.3: The program estimates reactor source term, The commitment wording was in the area of the plume, the potential for atmospheric transport, and doses resulting from standardized and relocated to significantly increased rates of radioactivity radiological emergencies and can be used to assist in the SNC Standard Emergency deposition will be considered by increasing the making protective action determinations The system Plan. scope of environmental sampling as required. supplements assessments based on plant conditions and quick estimates based on hand-calculation methods. Precipitation is part of the The model was developed to allow consideration of the standard modeling techniques dominant aspects of source term, transport, dose, and and a specific discussion in the consequences. Because the program is designed to be Plan is not required. used during a radiological emergency, it is assumed that the amount of activity being released and the meteorological conditions will not be precisely known. 1.4: The VEGP staff will calculate the 50-mile The deposition doses will be ingestion pathway doses from the deposition of calculated in the intermediate specific radionuclides. phase under the direction of the Offsite Response Organization. The utility retains the commitments to make Ad Hoc Protective Action Recommendations beyond the 10 mile EPZ in Section J of the Standard Plan. 1.4: The dose assessment computer program will The deposition doses will be be used to calculate the projected deposition of calculated in the intermediate radionuclides and associated doses in the phase under the direction of the ingestion pathway based on release data and Offsite Response Organization. meteorological conditions. The utility retains the commitments to make Ad Hoc Protective Action Recommendations beyond the 10 mile EPZ in Section J of the Standard Plan. 1.4: The results of all analyses will be provided to EP 8.3.1.4: The Dose Assessment Supervisor reports to The commitment wording was the States of Georgia and South Carolina by the the EOF Manager and provides oversight of dose standardized and relocated to dose assessment supervisor. assessment, field team control, and protective action the SNC Standard Emergency recommendation activities in the EOF and coordinates Plan. communication of results with offsite agencies. ElS-108 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 1.5: Initially, the emergency director can activate EP 1.7: The capability to take offsite soil, water, and The commitment wording was at least one team from on-shift personnel. vegetation samples is provided by a minimum of two (2) standardized and relocated to Field Monitoring Teams (FMTs). the SNC Standard Emergency Plan. 1.5 Monitoring teams of at least two people are EP 1.7: In addition to the capabilities and resources The commitment wording was formed at the OSC, TSC, or the EOF, as described in Section H, SNC operated nuclear power standardized and relocated to appropriate. plants have the ability to take offsite air samples and to the SNC Standard Emergency directly measure gamma dose rates from a radioactive Plan. material release. The capability to take offsite soil, water, and vegetation samples is provided by a minimum of two (2) Field Monitoring Teams (FMTs). 1.5: Field monitoring kits are available to the EP 1.7: In addition to the capabilities and resources The commitment wording was teams in the EOF or plant entry security building. described in Section H, SNC operated nuclear power standardized and relocated to 1.5: The emergency monitoring kits contain a plants have the ability to take offsite air samples and to the SNC Standard Emergency portable air sampler, silver zeolite cartridges, directly measure gamma dose rates from a radioactive Plan. andcounters to provide the capability to detect material release. The capability to take offsite soil, water, and measure radioiodine concentrations in the air and vegetation samples is provided by a minimum of two aslow as 10-7 µCi/cc. (2) Field Monitoring Teams (FMTs). 1.5: Designated vehicles may be used which are EP 1.7: In addition to the capabilities and resources The commitment wording was equipped with two-way radios on plant-dedicated described in Section H, SNC operated nuclear power standardized and relocated to frequencies. plants have the ability to take offsite air samples and to the SNC Standard Emergency 1.5: Handheld radios will also be available as a directly measure gamma dose rates from a radioactive Plan. backup. material release. The capability to take offsite soil, water, and vegetation samples is provided by a minimum of two (2) Field Monitoring Teams (FMTs). ElS-109 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 1.5: If the dose rate exceeds 100 mrem/h, off- No equivalent Plan Statement. centerline measurements will be made. The SNC Standard Emergency Plan retains the commitment to dispatch Field Teams and use the environmental information for radiological assessment as previously described. The information here is appropriate to procedural control of the teams. Environmental Team Procedures (Part of the EPIP series) will be developed consistent with the approval of this License Amendment Request and in accordance with the requirements of 10 CFR 50.54(q). 1.5: In-transit dose rate measurements will be No equivalent Plan Statement. made. The SNC Standard Emergency Plan retains the commitment to dispatch Field Teams and use the environmental information for radiological assessment as previously described. The information here is appropriate to procedural control of the teams. Environmental Team Procedures (Part of the EPIP series) will be developed consistent with the approval of this License Amendment Request and in accordance with the requirements of 10 CFR 50.54(q). ElS-110 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 1.5: It is estimated that teams will be in the field EP 1.7: In addition to the capabilities and resources The commitment wording was and performing monitoring tasks within about 1 h described in Section H, SNC operated nuclear power standardized and relocated to of the determination of the need for field plants have the ability to take offsite air samples and to the SNC Standard Emergency monitoring. directly measure gamma dose rates from a radioactive Plan.As previously stated the material release. The capability to take offsite soil, water, dispatch of teams at 75 minutes and vegetation samples is provided by a minimum of two vice the previous 1 hour (2) Field Monitoring Teams (FMTs). commitment is justified separately in the Technical Analysis Section of this submittal. 1.5: Monitoring teams are instructed to contact EP 8.2.1.5 TSC Radiation Protection (RP) Supervisor The commitment wording was the monitoring team communicator approximately The RP Supervisor reports to the TSC Manager and standardized and relocated to every half hour. supervises the activities of the radiation protection staff the SNC Standard Emergency and Health Physics Network (HPN) Communicator. The Plan. RP Supervisor assists the Radiation Protection/Chemistry Group Lead in the OSC in determining the extent and nature of radiological or hazardous conditions and coordinates offsite dose assessment and offsite Field Monitoring Teams prior to EOF activation. EP 8.3.2.8 EOF Dose Assessment Supervisor The Dose Assessment Supervisor reports to the EOF Manager and provides oversight of dose assessment, field team control, and protective action recommendation activities in the EOF and coordinates communication of results with offsite agencies. ElS-111 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 1.5: Prior to leaving for the field, the dose No equivalent Plan Statement. assessment supervisor, or designee, will The SNC Standard Emergency normally direct and brief the teams on the initial Plan retains the commitment to survey and sample locations, suggested travel dispatch Field Teams and use routes, meteorological conditions, and team the environmental information for identification name or number for communication radiological assessment as purposes. previously described. The information here is appropriate to procedural control of the teams. Environmental Team Procedures (Part of the EPIP series) will be developed consistent with the approval of this License Amendment Request and in accordance with the requirements of 10 CFR 50.54(q). ElS-112 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 1.5: The Dose Assessment Team at the EOF will EP 1.7 Environs Surveys and Monitoring The commitment wording was collate field monitoring data for VEGP dose In addition to the capabilities and resources described in standardized and relocated to projection purposes. Section H, SNC operated nuclear power plants have the the SNC Standard Emergency ability to take offsite air samples and to directly measure Plan. gamma dose rates from a radioactive material release. The capability to take offsite soil, water, and vegetation samples is provided by a minimum of two (2) Field Monitoring Teams (FMTs). The environmental monitoring equipment includes portable survey, counting, and air sampling instrumentation and other radiological monitoring equipment and supplies to be used by the FMTs. Samples are taken at predetermined locations as well as those locations specified during and after a release. Environmental measurements are used as an aid in the determination and assessment of protective actions for the general public and recovery actions for the plant. Field Monitoring Teams are dispatched by SNC operated plants to perform a variety of functions during conditions that may involve significant releases of radioactive materials from a plant. Radiological survey and sample data is used to define affected area boundaries, verify or modify dose projections and protective action recommendations, and assess the actual magnitude, extent, and significance of a liquid or gaseous radioactive material release. Field monitoring data is analyzed by personnel in the TSC until relieved by the EOF staff. 1.5: The teams will inspect their field monitoring EP 1.7: In addition to the capabilities and resources The commitment wording was kits, perform survey equipment operation checks, described in Section H, SNC operated nuclear power standardized and relocated to obtain dosimeters, and establish radio plants have the ability to take offsite air samples and to the SNC Standard Emergency communications with the monitoring team directly measure gamma dose rates from a radioactive Plan. communicator. material release. The capability to take offsite soil, water, and vegetation samples is provided by a minimum of two (2) Field Monitoring Teams (FMTs). ElS-113 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 1.5: The teams will obtain their briefing from the No equivalent Plan Statement. health physics supervisor in the TSC or in the The SNC Standard Emergency OSC by the OSC manager. Plan retains the commitment to dispatch Field Teams and use the environmental information for radiological assessment as previously described. The information here is appropriate to procedural control of the teams.Environmental Team Procedures (Part of the EPIP series) will be developed consistent with the approval of this License Amendment Request and in accordance with the requirements of 10 CFR 50.54(q). 1.5: The total sample volume and the limiting No equivalent Plan Statement. background count rate allow for a LLD of at least The SNC Standard Emergency 10-7 µCi/cc. Plan retains the commitment to dispatch Field Teams and use the environmental information for radiological assessment as previously described. The information here is appropriate to procedural control of the teams. Environmental Team Procedures (Part of the EPIP series) will be developed consistent with the approval of this License Amendment Request and in accordance with the requirements of 10 CFR 50.54(q). ElS-114 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 1.6: Composite samples (of drinking water) from The SNC Standard Emergency each location are collected monthly. Plan retains the commitment to maintain the capability for the fixed environmental program. The procedural aspects of maintenance of the program are not needed in the Plan. 1.6: Copies of the map showing the locations will EP l.7:*samples are taken at predetermined locations as The commitment wording was be in the field monitoring kits, the TSC and EOF. well as those locations specified during and after a standardized and relocated to release. the SNC Standard Emergency Plan. 1.6: Direct radiation is measured by EP H.6.2 Radiological Env.ironmental Monitors, The commitment wording was thermoluminescent dosimeters (TLDs) which are Sampling, and Monitoring Equipment standardized and relocated to exchanged and analyzed (read) for gamma dose SNC operated nuclear power plants maintain a sufficient the SNC Standard Emergency quarterly. supply of portable offsite radiological monitoring Plan. equipment. These supplies are located at each staging point for Field Monitoring Teams. SNC operated nuclear power plants. have a Radiological Environmental Monitoring Program (REMP) consisting of locations with dose recording devices and air sampling equipment. 1.6: During and/or subsequent to emergency EP H.6.2 Radiological Environmental Monitors, The commitment wording was conditions, the routine environmental monitoring Sampling, and Monitoring Equipment standardized and relocated to program will be modified to collect and analyze SNC operated .nuclear power plants maintain a sufficient the SNC Standard Emergency additional samples from existing stations. supply of portable offsite radiological monitoring Plan. equipment. These supplies are located at each staging point for Field Monitoring Teams. Section H of the SNC Standard SNC operated nuclear power plants have a Radiological Emergency Plan maintains the Environmental Monitoring Program (REMP) consisting of commitment to have the program locations with dose recording devices and air sampling as part of the Emergency Plan. equipment.. ElS-115 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 1.6: Filters are composited quarterly by location The commitment wording was for gamma isotopic analysis. standardized and relocated to the SNC Standard Emergency Plan.

The SNC Standard Emergency Plan retains the commitment to maintain the capability for the fixed environmental program.

The procedural aspects of maintenance of the program are not needed in the Plan. 1.6: Grab samples of finished drinking water are The commitment wording was taken monthly. standardized and relocated to the SNC Standard Emergency Plan. The SNC Standard Emergency Plan retains the commitment to maintain the capability for the fixed environmental program. The procedural aspects of maintenance of the program are not needed in the Plan. 1.6: In addition to direct monitoring and air EP 1.7: In addition to the capabilities and resources The commitment wording was sampling, the assessment program includes an described in Section H, SNC operated nuclear power standardized and relocated to emergency environmental sampling program. plants have the ability to take offsite air samples and to the SNC Standard Emergency directly measure gamma dose rates from a radioactive Plan. material release. The capability to take offsite soil, water, and vegetation samples is provided by a minimum of two (2) Field Monitoring Teams (FMTs). ElS-116 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 1.6: Milk samples are collected semimonthly by The SNC Standard Emergency taking grab samples from milk supplies at control Plan retains the commitment to and indicator stations. These samples are maintain the capability for the analyzed for gamma isotopics. fixed environmental program. The procedural aspects of maintenance of the program are not needed in the Plan. 1.6: Monthly samples are analyzed for gross. beta The SNC Standard Emergency and gamma isotopics. Plan retains the commitment to maintain the capability for the fixed environmental program. The procedural aspects of maintenance of the program are not needed in the Plan. 1.6: Quarterly composites, which are obtained The SNC Standard Emergency from the monthly composites, are analyzed for Plan retains the commitment to tritium. maintain the capability for the fixed environmental program. The procedural aspects of maintenance of the program are not needed in the Plan. 1.6: Sediment from the Savannah River is The SNC Standard Emergency collected semiannually from control and indicator Plan retains the commitment to locations using manual grab sampling maintain the capability for the techniques. Sediment samples are analyzed for fixed environmental program. gamma isotopics The procedural aspects of maintenance of the program are not needed in the Plan. 1.6: The (airborne radioiodine and particulates for The SNC Standard Emergency environmental sample) cartridge and filter are Plan retains the commitment to changed weekly. maintain the capability for the fixed environmental program. The procedural aspects of maintenance of the program are not needed in the Plan. ElS-117 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 1.6: The GPC environmental laboratory, located EP H.6.3 Laboratory Facilities The commitment wording was in Smyrna, Georgia, has the capability to perform External facilities for counting and analyzing samples, standardized and relocated to isotopic analyses of drinking water, river water, dosimetry processing, can be provided by the other SNC the SNC Standard Emergency milk, vegetation, sediment, and biological operated plants including the GPC Central Laboratory, Plan. samples as well as tritium and gross beta state, federal or contracted laboratories. Outside analysis. analytical assistance may be requested from state and federal agencies, or through contracted vendors. The DOE, through the Radiological Assistance Program (RAP) has access to any national laboratory. 1.6: Vegetation is sampled monthly during the The SNC Standard Emergency growing season. Plan retains the commitment to maintain the capability for the fixed environmental program. The procedural aspects of maintenance of the program are not needed in the Plan. 1.6: Vegetation samples are analyzed for gamma The SNC Standard Emergency isotopics. Plan retains the commitment to maintain the capability for the fixed environmental *program. The procedural aspects of maintenance of the program are not needed in the Plan. ElS-118 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 1.7 Field monitoring measurements are important in Wording duplicates Standard determining the actual radiation levels in the Plan content in other sections. environment. The dose assessment computer code provides only a rough approximation of radiation levels and location of the plume. The uncertainties in the source term and meteorological conditions in the affected areas are the chief contributors to the inaccuracies of projected dose and dose rate. Once field monitoring information becomes available, the dose assessment computer code becomes less important in providing data on which to base protective action recommendations. There is no widely accepted formula to use field monitoring data to reduce the uncertainties and inaccuracies in the dose assessment computer code. The Dose Assessment Manager or HP Supervisor must exercise professional judgment in determining the proper correction factors. Field monitoring teams should not unnecessarily be exposed to high levels of radiation from a radioactive plume. ALARA (as-low-as-reasonably-achievable) principles should be applied to all field monitoring activities. Once the decision to evacuate the general public has been made, field monitoring activities should be restricted to such activities as determining the source term for an unmonitored release or confirming the presence of a radioactive plume. Plume centerline tracking is of relatively minor importance in protecting the health and safety of the public, and should not be attempted for highly radioactive plumes unless the information derived has some value in assisting in the evacuation of the public. Field monitoring team activities that contribute to the expeditious evacuation and consequent reduction in radiation dose of the public should continue within the EPA emergency exposure guidelines, if necessary Section J Protective Response ElS-119 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 J.1.2: Accountability reports are made EP J.4.2 Accountability The SNC Standard Emergency periodically to the emergency director by the Personnel accountability is mandatory at the Site Area or Plan retains the commitment to Security Department. General Emergency classification. Accountability may be perform and maintain initiated at other times at the discretion of the Emergency accountability. The procedural Director to support worker safety. aspects of the process are not Accountability of personnel within the Protected Area is needed in the Plan. accomplished within 30 minutes of the declaration of Site Area Emergency or higher, and maintained continuously Environmental Team Procedures thereafter, using Protected Area(s) boundary access (Part of the EPIP series) will be control as described in the Security Plan. If there are developed consistent with the station personnel who are unaccounted for, the Public approval of this License Address System or other suitable communication methods Amendment Request and in are used to locate them, or, in extreme cases such as fire, accordance with the toxic gas release, explosions, or structural damage, requirements of 10 CFR trained search and rescue personnel are deployed to 50.54(q). search for and assist the missing personnel. J.1.2: Assignment logs and required periodic The SNC Standard Emergency communications between emergency response Plan retains the commitment to teams maintain accountability. perform and maintain accountability. The procedural aspects of e of the process are not needed in the Plan. ElS-120 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 J.1.2: Emergency response personnel in the EP J.4.1 Assembly The commitment wording was protected area badge into their emergency Assembly is mandatory following the declaration of a Site standardized and relocated to response facility (TSC, OSC, or control room). Area or General Emergency, or at the discretion of the the SNC Standard Emergency The security computer system performs an initial Emergency Director. When Accountability of onsite Plan. of all persons in the protected area. personnel is determined to be necessary by the J.1.2: Thereafter, the emergency response Emergency Director, personnel within the Protected Area facility managers of the control room, TSC, and will be accounted for and the names of missing individuals operations support center shall be responsible for determined within 30 minutes of the emergency periodically assuring that accountabilities in their declaration. facilities are being maintained. The Assembly Area senior individual will take the lead in coordinating the activities of the Assembly Area in support of OSC operations as directed by the OSC Manager. EP J.4.2 Accountability Personnel accountability is mandatory at the Site Area or General Emergency classification. Accountability may be initiated at other times at the discretion of the Emergency Director to support worker safety. Accountability of personnel within the Protected Area is accomplished within 30 minutes of the declaration of Site Area Emergency or higher, and maintained continuously thereafter, using Protected Area(s) boundary access control as described in the Security Plan. If there are station personnel who are unaccounted for, the Public Address System or other suitable communication methods are used to locate them, or, in extreme cases such as fire, toxic gas release, explosions, or structural damage, trained search and rescue personnel are deployed to search for and assist the missing personnel. ElS-121 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 J.1.2: The Security Department accounts for EP J.4.2 Accountability The commitment wording was each person inside the protected area at the start Personnel accountability is mandatory at the Site Area or standardized and relocated to of an emergency by using the security computer General Emergency classification. Accountability may be the SNC Standard Emergency system. initiated at other times at the discretion of the Emergency Plan. Director to support worker safety. Accountability of personnel within the Protected Area is accomplished within 30 minutes of the declaration of Site Area Emergency or higher, and maintained continuously thereafter, using Protected Area(s) boundary access control as described in the Security Plan. If there are station personnel who are unaccounted for, the Public Address Systern or other suitable communication methods are used to locate them, or, in extreme cases such as fire, toxic gas release, explosions, or structural damage, trained search and rescue personnel are deployed to search for and assist the missing personnel. J.1.2: This method provides for accountability of EP J.4.2 Accountability The commitment wording was all individuals inside the protected area within Personnel accountability is mandatory at the Site Area or standardized and relocated to about 30 min. of the emergency declaration page General Emergency classification. Accountability may be the SNC Standard Emergency announcement. initiated at other times at the discretion of the Emergency Plan Director to support worker safety. Accountability of personnel within the Protected Area is accomplished within 30 minutes of the declaration of Site Area Emergency or higher, and maintained continuously thereafter, using Protected Area(s) boundary access control as described in the Security Plan. If there are station personnel who are unaccounted for, the Public Address System or other suitable communication methods are used to locate them, or, in extreme cases such as fire, toxic gas release, explosions, or structural damage, trained search and rescue personnel are deployed to search for and assist the missing personnel. ElS-122 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 J.1.3: If protected area accountability reveals a EP J.4.2 Accountability The commitment wording was missing person, the emergency director Personnel accountability is mandatory at the Site Area or standardized and relocated to assembles a search and rescue team per General Emergency classification. Accountability may be the SNC Standard Emergency emergency response procedures initiated at other times at the discretion of the Emergency Plan Director to support worker safety. Accountability of personnel within the Protected Area is accomplished within 30 minutes of the declaration of Site Area Emergency or higher, and maintained continuously thereafter, using Protected Area(s) boundary access control as described in the Security Plan. If there are station personnel who are unaccounted for, the Public Address System or other suitable communication methods are used to locate them, or, in extreme cases such as fire, toxic gas release, explosions, or structural damage, trained search and rescue personnel are deployed to search for and assist the missing personnel. J.1.3: A search of likely areas is conducted until EP J.4.2 Accountability The commitment wording was the missing individual is located. Personnel accountability is mandatory at the Site Area or standardized and relocated to General Emergency classification. Accountability may be the SNC Standard Emergency initiated at other times at the discretion of the Emergency Plan. Director to support worker safety. Accountability of personnel within the Protected Area is accomplished within 30 minutes of the declaration of Site Area Emergency or higher, and maintained continuously thereafter, using Protected Area(s) boundary access control as described in the Security Plan. If there are station personnel who are unaccounted for, the Public Address System or other suitable communication methods are used to locate them, or, in extreme cases such as fire, toxic gas release, explosions, or structural damage, trained search and rescue personnel are deployed to search for and assist the missing personnel. ElS-123 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 J.1.4: Site dismissal, with or without monitoring, J.4.3 Site Evacuation The commitment wording was of non-involved personnel on-site (if feasible) is If a Site Evacuation is required, personnel are directed to standardized and relocated to ordered by the emergency director whenever a either assemble within designated Assembly Areas or to the SNC Standard Emergency Site Area or General Emergency is declared. immediately leave the site. Personnel will be directed to Plan. either proceed to their homes or to reassemble at designated locations. Visitors to the plant will assemble with and follow the instructions of their escorts. Personal transportation will normally be used and established evacuation routes will be followed. Personnel without transportation will be identified and provided transportation as necessary. J.1.4: Personnel on site will be notified by public J.4.3 Site Evacuation The commitment wording was address, site siren, or other communication that If a Site Evacuation is required, personnel are directed to standardized and relocated to dismissal of non-involved personnel to the either assemble within designated Assembly Areas or to the SNC Standard Emergency applicable reception center will take place and immediately leave the site. Personnel will be directed to Plan. specify the route. either proceed to their homes or to reassemble at designated locations. Visitors to the plant will assemble with and follow the instructions of their escorts. Personal transportation will normally be used and established evacuation routes will be followed. Personnel without transportation will be identified and provided transportation as necessary. J.1.4: Security will dispatch security officers to J.4.3 Site Evacuation The commitment wording was work areas outside the protected area to ensure If a Site Evacuation is required, personnel are directed to standardized and relocated to all non- involved personnel have left the owner- either assemble within designated Assembly Areas or to the SNC Standard Emergency controlled area. immediately leave the site. Personnel will be directed to Plan. either proceed to their homes or to reassemble at designated locations. Visitors to the plant will assemble with and follow the instructions of their escorts. Personal transportation will normally be used and established evacuation routes will be followed. Personnel without transportation will be identified and provided transportation as necessary. ElS-124 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 J.1.5: When an Alert is declared and site J.4.3 Site Evacuation The commitment wording was dismissal with no monitoring is anticipated, If a Site Evacuation is required, personnel are directed to standardized and relocated to personnel who have left the protected area are either assemble within designated Assembly Areas or to the SNC Standard Emergency monitored by portal monitors. immediately leave the site. Personnel will be directed to Plan. either proceed to their homes or to reassemble at designated locations. Visitors to the plant will assemble with and follow the instructions of their escorts. Personal transportation will normally be used and established evacuation routes will be followed. Personnel without transportation will be identified and provided transportation as necessary. Evacuation of personnel is usually conducted immediately after accountability if a Site Area Emergency or General Emergency has been declared and no impediments exist. Evacuation shall commence as directed by the Emergency Director. J.1.6: A supply of potassium iodide is stored in EP J.4: SNC operated nuclear power plants are The commitment wording was the TSC for TSC and control room use, OSC, responsible for maintaining a supply of Kl at their standardized and relocated to main control point, or health physics room. respective site. The Emergency Director has the the SNC Standard Emergency J.1.6: The health physics supervisor will direct responsibility for approval of issuing Kl to site emergency Plan. the issuance of potassium iodide when the workers. projected thyroid exposure is greater than 25 rem. J.1.6: The health physics supervisor will direct radiological survey personnel to distribute potassium iodide and record the name and social security number of those individuals who are issued potassium iodide. J.1.6: Potassium iodide will be issued in 130-mg EP J.4: SNC operated nuclear power plants maintain an The commitment wording was doses daily for at least 3 days, but not more than inventory of respiratory protection equipment, anti- standardized and relocated to 10 days. contamination clothing, and potassium iodide (Kl) that is the SNC Standard Emergency available to emergency workers remaining onsite Plan. J.1.6: Issuance will be performed immediately EP J.4: SNC operated nuclear power plants are The commitment wording was prior to exposure or not longer than 4 hours after responsible for maintaining a supply of Kl at their standardized and relocated to exposure. respective site. The Emergency Director has the the SNC Standard Emergency responsibility for approval of issuing Kl to site emergency Plan. workers. ElS-125 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 J.1.6: At the time potassium iodide is distributed, EP J.4: SNC operated nuclear power plants are The commitment wording was an iodine sensitivity check will be made by responsible for maintaining a supply of Kl at their standardized and relocated to querying each individual concerning known respective site. The Emergency Director has the the SNC Standard Emergency reactions to iodine. responsibility for approval of issuing Kl to site emergency Plan. workers. J.2.2: The emergency director is responsible for EP B.1.1 The Emergency Director's non-delegable duties The commitment wording was providing protective action recommendations to include: standardized and relocated to State and local officials as part of initial

Perform the duties and responsibilities of the SNC Standard Emergency notifications and follow-up communications. Protective Action Recommendation (PAR) Plan.

determination; J.-2.2: Using available information on plant EP J.5 Offsite Protective Action Recommendations The commitment wording was conditions, projected dose estimates, and any (PARs) standardized and relocated to available monitoring data, the emergency director Plant conditions, projected dose and dose rates, field the SNC Standard Emergency recommends whether the public should be monitoring data and evacuation time estimates are Plan. advised to seek shelter or evacuate. evaluated to develop PARs for preventing or minimizing exposure to the public. PARs are provided to the offsite agencies responsible for implementing protective actions for the public within the 10-mile EPZ. The Emergency Director will approve PARs. The PAR decision making flowcharts are site-specific in nature, and are provided in the site-specific implementing procedures. Plant conditions, projected dose and. dose rates and field monitoring data are communicated to offsite agencies responsible for dose assessment/PARs to assist them in developing parallel assessments There are various types of protective actions that can be recommended to the state and counties. They may include the following:

Evacuation.
Shelter in Place.
Monitor and prepare.
Thyroid blocking agent (Consider the use of Kl (Potassium Iodide) in accordance with State Plans and Policy ElS-126 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergen_cy Plan Revised SNC Emergency Plan Justification Revision 3 J.2.3: Determination of the benefit of evacuation EP J.5 Offsite Protective Action Recommendations The commitment wording was must take into account the time needed to (PARs) standardized and relocated to complete the evacuation. Plant conditions, projected dose and dose rates, field the SNC Standard Emergency monitoring data and evacuation time estimates are Plan.

evaluated to develop PARs for preventing or minimizing exposure to the public. PARs are provided to the offsite agencies responsible for implementing protective actions for the public within the 10-mile EPZ. The Emergency Director will approve PARs. The PAR decision making flowcharts are site-specific in nature, and are provided in the site-specific implementing procedures. Plant conditions, projected dose and dose rates and field monitoring data are communicated to offsite agencies responsible for dose assessmenUPARs to assist them in developing parallel assessments There are various types of protective actions that can be recommended to the state and counties. They may include the following:

Evacuation.
Shelter in Place.
Monitor and prepare.
Thyroid blocking agent (Consider the use of Kl (Potassium Iodide) in accordance with State Plans and Policy Table J-1: Emergency equipment locations. EP H.9: Emergency kits are available at SNC operated The commitment wording was nuclear power plants. Designated site or department standardized and relocated to procedures identify the equipment in the various the SNC Standard Emergency emergency kits. Plan and Site Annex.

Annex 5.5: Emergency supplies and equipment are located in the Control Room, the TSC, the OSC, the health physics control points, and other plant locations. Procedures require an inspection and operational check of equipment in these kits on a quarterly basis and after each use. Equipment in these kits is calibrated in accordance with procedures. A set of spares of certain equipment is also maintained to replace inoperative or out-of-calibration equipment. ElS-127 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 J Figures J-1 and J-2 EP J.5 Offsite Protective Action Recommendations Figures were removed from the (PARs) SNC Standard Emergency Plan. Plant conditions, projected dose and dose rates, field monitoring data and evacuation time estimates are The PAR flowcharts are evaluated to develop PARs for preventing or minimizing contained in EPIPs. exposure to the public. PARs are provided to the offsite agencies responsible for implementing protective actions for the public within the 10-mile EPZ. The Emergency Director will approve PARs. The PAR decision making flowcharts are site-specific in nature, and are provided in the site-specific implementing procedures. Plant conditions, projected dose and dose rates and field monitoring data are communicated to offsite agencies responsible for dose assessment/PARs to assist them in developing parallel assessments There are various types of protective actions that can be recommended to the state and counties. They may include the following:

Evacuation .
Shelter in Place .
Monitor and prepare .
Thyroid blocking agent (Consider the use of Kl (Potassium Iodide) in accordance with State Plans and Policy Table J-5, Reception Centers/Shelters The location of Reception Centers and Shelter information is a function of offsite agencies and included in offsite Plan and does not need to be addressed as part of the Standard Plan for SNC.

Section K Radiological Exposure Control ElS-128 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 K.1: Decisions as to appropriate exposures, EP B.1.1 The Emergency Director's non-delegable duties The commitment wording was considering the action required and relative risks, include: standardized and relocated to will be made by the emergency director in

Authorization of emergency exposures in excess the SNC Standard Emergency consultation with health physics personnel. of federal limits. Plan.
Issuance of potassium iodide (Kl) to plant employees as a thyroid blocking agent; K.2: A record of individual and collective EP K.3.1 Exposure records will be maintained for The commitment wording was exposure received during the emergency will be emergency response personnel issued dosimetry. standardized and relocated to maintained by the dosimetry team. the SNC Standard Emergency Plan.

K.2: A record of individual and collective EP K.3.1: 24 Hour Capabilities The commitment wording was exposure received during the emergency will be Plant Radiological Protection Groups have the equipment standardized and relocated to maintained by the dosimetry team. and personnel to provide 24-hour capability to determine the SNC Standard Emergency and control radiation exposures of emergency Plan. organization personnel. Equipment to perform the following functions:

Radiation detection devices .
Personnel monitoring;
Record keeping equipment.

Contractor and vendor representatives may also be present to assist in exposure control and augment the Radiation Protection Group capabilities. In an emergency situation, onsite personnel, offsite support personnel and local governmental emergency response personnel may be issued monitoring devices. Exposure records will be maintained for emergency response personnel issued dosimetry. ElS-129 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 K.2: All emergency exposures will be included in EP K.3.1: 24 Hour Capabilities The commitment wording was personnel radiation exposure records. Plant Radiological Protection Groups have the equipment standardized and relocated to and personnel to provide 24-hour capability to determine the SNC Standard Emergency and control radiation exposures of emergency Plan. organization personnel. Equipment to perform the following functions:

Radiation detection devices.
Personnel monitoring;
Record keeping equipment.

Contractor and vendor representatives may also be present to assist in exposure control and augment the Radiation Protection Group capabilities. In an emergency situation, onsite personnel, offsite support personnel and local governmental emergency response personnel may be issued monitoring devices. Exposure records will be maintained for emergency response personnel issued dosimetry. K.2: An individual's dose margin will be assessed EP K.2 Emergency Exposure Authorization The commitment wording was by determining the difference between the SNC operated plants have a Radiation Protection standardized and relocated to updated exposure and current administrative Program. The Emergency Director may authorize the SNC Standard Emergency limit; these margins are used to determine emergency workers to receive doses in excess of the Plan. emergency assignments. administrative dose levels. In some situations, it is possible that certain activities or duties for the protection of persons or the substantial protection of property may result in doses in excess of 10 CFR 20.1201 limits. Decisions to accept doses in excess of occupational limits will be on a volunteer basis and prospective volunteers shall be made aware of the risks. ElS-130 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 K.2: Appendix 4 presents information on the EP K.3.1: 24 Hour Capabilities The commitment wording was types of dosimetry available in each emergency Plant Radiological Protection Groups have the equipment standardized and relocated to response facility and other locations. and personnel to provide 24-hour capability to determine the SNC Standard Emergency and control radiation exposures of emergency Plan. organization personnel. Equipment to perform the following functions:

Radiation detection devices.
Personnel monitoring;
Record keeping equipment.

Contractor and vendor representatives may also be present to assist in exposure control and augment the Radiation Protection Group capabilities. In an emergency situation, onsite personnel, offsite support personnel and local governmental emergency response personnel may be issued monitoring devices. Exposure records will be maintained for emergency response personnel issued dosimetry. K.2: Emergency dosimetry is provided to each EP K.3.1: 24 Hour Capabilities The commitment wording was member of the emergency response organization Plant Radiological Protection Groups have the equipment standardized and relocated to for both onsite and offsite organizations as and personnel to provide 24-hour capability to determine the SNC Standard Emergency required by the radiological conditions existing at and control radiation exposures of emergency Plan. the time. organization personnel. Equipment to perform the following functions:

Radiation detection devices.
Personnel monitoring;
Record keeping equipment.

Contractor and vendor representatives may also be present to assist in exposure control and augment the Radiation Protection Group capabilities. In an emergency situation, onsite personnel, offsite support personnel and local governmental emergency response personnel may be issued monitoring devices. Exposure records will be maintained for emergency response personnel issued dosimetry. ElS-131 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 K.2: Emergency response personnel will be No direct statement is made for made aware that self reading dosimeters should reading direct reading dosimetry. be checked every 15 to 30 min. during the The original Plan statement was emergency. intended for pocket dosimeters requiring specific action of the ERO individual. Modern dosimetry provides alarm functions to support awareness. K.2: If time and urgency do not allow this EP K.3.3 Radiation Work Permit Procedures The commitment wording was procedure to be followed, the health physics Where possible, the normal radiation work permit standardized and relocated to supervisor may approve emergency RWP procedure will be used to control exposures. Based on the SNC Standard Emergency controls. conditions and urgency Radiation Protection supervision Plan. may approve emergency radiological work permit controls. K.2: In all cases, a briefing is given to the EP K.2 Emergency Exposure Authorization The commitment wording was emergency team by health physics staff, and SNC operated plants have a Radiation Protection standardized and relocated to each team is accompanied by a qualified health Program. The Emergency Director may authorize the SNC Standard Emergency physics technician who meets the qualifications emergency workers to receive doses in excess of the Plan. of ANSI 18.1 criteria set out in the VEGP administrative dose levels. In some situations, it is Technical Specifications. possible that certain activities or duties for the protection of persons or the substantial protection of property may result in doses in excess of 10 CFR 20.1201 limits. Decisions to accept doses in excess of occupational limits will be on a volunteer basis and prospective volunteers shall be made aware of the risks. K.2: In situations where exposures in excess of EP K.2 Emergency Exposure Authorization The commitment wording was 10 CFR 20 limits are authorized, the SNC operated plants have a Radiation Protection standardized and relocated to followingconsiderations will be made prior to Program. The Emergency Director may authorize the SNC Standard Emergency emergency team selection: emergency workers to receive doses in excess of the Plan.

Declared pregnant female employees administrative dose levels. In some situations, it is shall not be allowed to participate possible that certain activities or duties for the protection
For doses greater than 25 rem, of persons or the substantial protection of property may personnel shall be volunteers and be result in doses in excess of 10 CFR 20.1201 limits.

fully aware of the risks involved Decisions to accept doses in excess of occupational limits will be on a volunteer basis and prospective volunteers shall be made aware of the risks. ElS-132 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 K.2: There is the capability to read TLDs EP K.3.1: 24 Hour Capabilities The commitment wording was within 24 hours. Plant Radiological Protection Groups have the equipment standardized and relocated to and personnel to provide 24-hour capability to determine the SNC Standard Emergency and control radiation exposures of emergency Plan. organization personnel. Equipment to perform the following functions:

Radiation detection devices.
Personnel monitoring;
Record keeping equipment.

Contractor and vendor representatives may also be present to assist in exposure control and augment the Radiation Protection Group capabilities. In an emergency situation, onsite personnel, offsite support personnel and local governmental emergency response personnel may be issued monitoring devices. Exposure records will be maintained for emergency response personnel issued dosimetry. K.2: This briefing includes a discussion of the EP K.2 Emergency Exposure Authorization The commitment wording was hazards involved in the planned action, as well SNC operated plants have a Radiation Protection standardized and relocated to as protective actions to be taken. Program. The Emergency Director may authorize the SNC Standard Emergency emergency workers to receive doses in excess of the Plan. administrative dose levels. In some situations, it is possible that certain activities or duties for the protection of persons or the substantial protection of property may result in doses in excess of 10 CFR 20.1201 limits. Decisions to accept doses in excess of occupational limits will be on a volunteer basis and prospective volunteers shall be made aware of the risks. K.2: When necessary, the emergency director EP 8.1.1 The Emergency Director's non-delegable duties The commitment wording was can authorize emergency exposures in excess of include: standardized and relocated to 10 CFR 20 limits but within the limits in table K-1.

Authorization of emergency exposures in excess the SNC Standard Emergency of federal limits. Plan.
Issuance of potassium iodide (Kl) to plant employees as a thyroid blocking agent; ElS-133 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 K.2: Where possible, the normal radiation work EP K.1: Under normal operating conditions, SNC The commitment wording was permit (RWP) procedure will be used to control operated plants maintain personnel exposure control standardized and relocated to exposures. programs in accordance with 10 CFR 20. the SNC Standard Emergency EP K.3.3 Radiation Work Permit Procedures Plan.

Where possible, the normal radiation work permit procedure will be used to control exposures. Based on conditions and urgency Radiation Protection supervision may approve emergency radiological work permit controls. K.3: Decontamination of personnel will be EP K.5 Decontamination The commitment wording was conducted in accordance with standard health The Radiation Protection Group will be responsible for standardized and relocated to physics practices. controlling or minimizing direct or subsequent internal the SNC Standard Emergency K.3: Personnel decontamination will be exposure from radioactive materials deposited on the Plan. accomplished using water washes or other ground or other surfaces, and for determining the extent of methods for extreme cases as described in plant contamination in controlled and normally uncontrolled health physics procedures. areas. During normal conditions or an emergency, guidelines to follow for contamination limits are established by the site radiation protection program. Facilities and supplies for decontaminating personnel are available at various plant locations. Personnel leaving the Radiological Controlled Area (RCA) or leaving a contaminated area will be monitored for contamination. During emergencies, other onsite personnel will be checked for contamination as necessary. K.3: Decontamination of serious wounds will be Annex 5.8.1: Agreements are in place with the University The commitment wording was accomplished at Doctors Hospital or the Burke of Alabama at Birmingham (UAB) Hospital, Burke Medical standardized and relocated to Medical Center as described in Section L of this Center, Doctors Hospital, and Burke County Emergency the Site Annex. Plan. Management Agency to provide assistance for injured personnel, including cases involving radioactive contamination. This assistance will be requested whenever necessary in accordance with plant procedures ElS-134 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 K.3: If decontamination activities are required, a EP K.5 Decontamination The commitment wording was controlled access area will be established by The Radiation Protection Group will be responsible for standardized and relocated to roping off the area. controlling or minimizing direct or subsequent internal the SNC Standard Emergency exposure from radioactive materials deposited on the Plan. ground or other surfaces, and for determining the extent of contamination in controlled and normally uncontrolled areas. During normal conditions or an emergency, guidelines to* follow for contamination limits are

established by the site radiation protection program.

Facilities and supplies for decontaminating personnel are available at various plant locations. Personnel. leaving the Radiological Controlled Area (RCA) or leaving a contaminated area will be monitored for contamination. During emergencies, other onsite personnel will be checked for contamination as necessary. K.3: It (equipment and area decon) is EP K.5: Designated personnel, under the direction of the The commitment wording was accomplished as described in plant health Radiation Protection Group, will perform material standardized and relocat~d to physics procedures and ranges from vacuum decontamination. Procedures and equipment for material the SNC Standard Emergency cleaning to wash downs with water and acid or decontamination are available at the plant, as specified in Plan. caustic solutions. the site radiation protection program. K.3: Personnel exiting the radiation-controlled EP K.5 Decontamination The commitment wording was area will be monitored for contamination by The Radiation Protection Group will be responsible for standardized and relocated to stand-up monitoring booths or by a whole-body controlling or minimizing direct or subsequent internal the SNC Standard Emergency scan with a hand-held probe. exposure from radioactive materials deposited on the Plan. ground or other surfaces, and for determining the extent of contamination in controlled and normally uncontrolled areas. During normal conditions or an emergency, guidelines to follow for contamination limits are established by the site radiation protection program. Facilities and supplies for decontaminating personnel are available at various plant locations. Personnel leaving the Radiological Controlled Area (RCA) or leaving a contaminated area will be monitored for contamination. During emergencies, other onsite personnel will be checked for contamination as necessary. ElS-135 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 K.3: Plant areas that require access to facilitate EP K.6 Contamination Controls The commitment wording was recovery operations will be surveyed with Contaminated areas are isolated as restricted areas with standardized and relocated to portable instruments equipped with Beta/Gamma appropriate radiological protection and access control. the SNC Standard Emergency detectors. Measures will be taken to control onsite access to Plan. potentially contaminated potable water and food supplies. K.3: Supplies of clean clothing will be made EP K.7: Nonessential onsite personnel may be evacuated The commitment wording was available. to an offsite reception center or assembly area, as standardized and relocated to discussed in Section J. Radiological controls personnel at the SNC Standard Emergency that location monitor evacuees and determine the need for Plan. decontamination. In the event that decontamination of evacuees locally is not possible, personnel can be sent to designated locations for monitoring and decontamination. K.3: The action levels for determining the need EP K.5: During normal conditions or an emergency, The commitment wording was for decontamination of personnel, equipment, guidelines to follow for contamination limits are standardized and relocated to and areas are delineated in plant admin. and established by the site radiation protection program. the SNC Standard Emergency health physics procedures. Plan. K.3: The facility (decontamination area) has EP K.5: Facilities and supplies for decontaminating The commitment wording was vertical showering and normal wash personnel are available at various plant locations. standardized and relocated to sinks.Section K.3: Instrumentation to survey the SNC Standard Emergency personnel during and after decontamination is Plan. located at the health physics station. K.3: The standard health physics contamination EP K.5 Decontamination The commitment wording was limits will be used for release of personnel. The Radiation Protection Group will be responsible for standardized and relocated to controlling or minimizing direct or subsequent internal the SNC Standard Emergency exposure from radioactive materials deposited on the Plan. ground or other surfaces, and for determining the extent of contamination in controlled and normally uncontrolled areas. During normal conditions or an emergency, guidelines to follow for contamination limits are established by the site radiation protection program. Facilities and supplies for decontaminating personnel are available at various plant locations. Personnel leaving the Radiological Controlled Area (RCA) or leaving a contaminated area will be monitored for contamination. During emergencies, other onsite personnel will be checked for contamination as necessary. ElS-136 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 K.3: Waste generated through the use of the EP K.5: Facilities and supplies for decontaminating The commitment wording was decontamination facilities is collected and personnel are available at various plant locations. standardized and relocated to processed by the plant liquid radwaste system. the SNC Standard Emergency Plan. K.4: Access control is provided by the Security EP 8.2.1.14 TSC Security Supervisor The commitment wording was Department during emergency conditions. The Security Supervisor reports to the TSC Manager. standardized and relocated to The TSC Security Supervisor is responsible for carrying the SNC Standard Emergency out the plant security and Access Control program, Plan. maintaining personnel accountability onsite, assisting in evacuation of onsite areas. K.4: Emergency monitoring teams are EP K.6 Contamination Controls The commitment wording was responsible for determining the need for onsite Contaminated areas are isolated as restricted areas with standardized and relocated to access control and establishing the proper appropriate radiological protection and access control. the SNC Standard Emergency method through discussions with technical Measures will be taken to control onsite access to Plan. support center (TSC) personnel. potentially contaminated potable water and food supplies. K.4: Plant procedures used for determining EP K.6 Contamination Controls The commitment wording was contaminated areas will be used for determining Contaminated areas are isolated as restricted areas with standardized and relocated to the need for access control. appropriate radiological protection and access control. the SNC Standard Emergency Measures will be taken to control onsite access to Plan. potentially contaminated potable water and food supplies. K.4: The emergency health physics supervisor is EP K.5 Decontamination The commitment wording was responsible for permitting return of onsite areas The Radiation Protection Group will be responsible for standardized and relocated to and equipment to normal use once monitoring controlling or minimizing direct or subsequent internal the SNC Standard Emergency and decontamination are completed. exposure from radioactive materials deposited on the Plan. ground or other surfaces, and for determining the extent of contamination in controlled and normally uncontrolled areas. During normal conditions or an emergency, guidelines to follow for contamination limits are established by the site radiation protection program. Facilities and supplies for decontaminating personnel are available at various plant locations. Personnel leaving the Radiological Controlled Area (RCA) or leaving a contaminated area will be monitored for contamination. During emergencies, other onsite personnel will be checked for contamination as necessary. ElS-137 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Table K-1, Emergency Worker Limits for Workers Table K.1.A Emergency Worker Dose Limits The commitment wording was Performing Emergency Services standardized and relocated to the SNC Standard Emergency Plan. Section L Medical and Public Health Support L.1: There are personnel on shift and in the EP L.2 First Aid The commitment wording was Emergency Organization trained in first aid and SNC operated nuclear power plants maintain onsite first standardized and relocated to decontamination procedures. aid supplies and equipment necessary for the treatment of the SNC Standard Emergency contaminated and/or injured persons. Plan and Site Annex. EP 0.3 First Aid Training Individuals assigned as First Aid responders shall Table 2.2.A of the site annex maintain qualifications for first aid and Cardio-Pulmonary retains First Aid as a required Resuscitation (CPR) training. on-shift capability. Site Annex Table 2.2.A - Vogtle Electric Generating Plant On-Shift Staffing SNC operated nuclear power plants maintain qualified first responders capable of providing initial first aid response in accordance with the Staffing requirements of Section B. L.1: The onsite personnel responsible for EP L.2 First Aid The commitment wording was responding to a medical emergency have had SNC operated nuclear power plants maintain onsite first standardized and relocated to training per the OSHA standard 29 CFR aid supplies and equipment necessary for the treatment of the SNC Standard Emergency 1910.151 and directive CPL 02-02-053, contaminated and/or injured persons. Plan and Site Annex. Guidelines for First Aid Training Programs. EP 0.3 First Aid Training Individuals assigned as First Aid responders shall Table 2.2.A of the site annex maintain qualifications for first aid and Cardio-Pulmonary retains First Aid as a required Resuscitation (CPR) training. on-shift capability. Site Annex Table 2.2.A - Vogtle Electric Generating Plant On-Shift Staffing SNC operated nuclear power plants maintain qualified first responders capable of providing initial first aid response in accordance with the Staffing requirements of Section B. ElS-138 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 L.1: Health physics technicians will be assigned EP L.2 First Aid The commitment wording was to first aid teams in accordance with Procedure SNC operated nuclear power plants maintain onsite first standardized and relocated to 70302-C, Reporting and Documenting aid supplies and equipment necessary for the treatment of the SNC Standard Emergency Occupational Injuries Or Illnesses. contaminated and/or injured persons. Plan. EP 0.3 First Aid Training Individuals assigned as First Aid responders shall Table 2.2.A of the site annex maintain qualifications for first aid and Cardio-Pulmonary retains First Aid as a required Resuscitation (CPR) training. on-shift capability. SNC operated nuclear power plants maintain qualified first responders capable of providing initial first aid response in accordance with the Staffing requirements of Section B. L.1: In addition, an on-site first aid and EP L.1 Plant personnel are available to assist medical The commitment wording was decontamination area equipped with personnel with decontamination, radiation exposure and standardized and relocated to decontamination supplies and other specialized contamination control. the SNC Standard Emergency equipment is located near the health physics EP L.2 First Aid Plan. stations. SNC operated nuclear power plants maintain onsite first aid supplies and equipment necessary for the treatment of contaminated and/or injured persons. L.1: Personnel found to be externally EP K.5 Decontamination The commitment wording was contaminated but not requiring immediate The Radiation Protection Group will be responsible for standardized and relocated to medical attention will undergo decontamination in controlling or minimizing direct or subsequent internal the SNC Standard Emergency accordance with plant procedures. exposure from radioactive materials deposited on the Plan. ground or other surfaces, and for determining the extent of contamination in controlled and normally uncontrolled areas. During normal conditions or an emergency, guidelines to follow for contamination limits are established by the site radiation protection program. Facilities and supplies for decontaminating personnel are available at various plant locations. Personnel leaving the Radiological Controlled Area (RCA) or leaving a contaminated area will be monitored for contamination. During emergencies, other onsite personnel will be checked for contamination as necessary. ElS-139 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Ma.trix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 L.2: Injured and contaminated personnel EP L.1: In addition to the onsite first aid response, The commitment wording was requiring hospital medical attention will be arrangements have been made with local hospitals for standardized and relocated to transported to Doctors Hospital, Augusta, or treatment and evaluation of serious injuries or sicknesses. the SNC Standard Emergency Burke County Hospital, Waynesboro, by the Annex 5.8.1: Agreements are in placewifh the University Plan and Site Annex. Burke County Ambulance Service. Letters of of Alabama at Birmingham (UAB) Hospital, Burke Medical agreement pertaining to these services are Center, Doctors Hospital, and Burke County Emergency located in Appendix 2. Management Agency to provide assistance for injured personnel, including cases involving radioactive contamination. This assistance will be requested whenever necessary in .accordance with plant procedures L.2: A health physics technician (HPT) will Annex 5.8.2: Ambulance Service (SEP 8.6.2, L.4) The commitment wording was accompany the patient to the hospital. .Injured/externally contaminated personnel who require standardized and relocated to medical attention will normally be transported by the Site Annex. ambulance to the cooperating hospitals. Ambulance crews are trained to handle external contamination cases, and an RP technician accompanies any contaminated patients to the hospital. Ambulance service is provided by the Burke County Emergency Management Agency. L.2: The HPT will perform radiation surveys of Annex 5.8.2: Injured/externally contaminated personnel The commitment wording was the patient, ambulance, and attending hospital who require medical attention will normally be transported standardized and relocated to staff and assist in maintaining contamination by ambulance to the cooperating hospitals. Ambulance the Site Annex. control in the hospital. crews are trained to handle external contamination cases, and an HP technician accompanies any contaminated patients to the hospital. Ambulance service is provided by the Burke County Emergency Management Agency. L.2: All contaminated materials will be properly EP L.4 Medical Transport The commitment wording was packaged and returned to the site for disposal. Contaminated and injured persons are transported to a standardized and relocated to facility specified for SNC operated nuclear power plants. the SNC Standard Emergency Arrangements have been made by nuclear power plants Plan. for ambulance transport of persons with injuries involving radioactivity to designated hospitals. Such services are available on a 24-hour per day basis and are confirmed by letters of agreement. Radiation monitoring services are provided by $NC plant personnel whenever it becomes necessary to use an ambulance service for the transportation of contaminated persons. ElS-140 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 L.2: The ambulance will also be decontaminated Annex 5.8.2: Injured/externally contaminated personnel The commitment wording was at VEGP if required. who require medical attention will normally be transported standardized and relocated to by ambulance to the cooperating hospitals. Ambulance the Site Annex. crews are trained to handle external contamination cases, and an HP technician accompanies any contaminated patients to the hospital. Ambulance service is provided by the Burke County Emergency Management Agency. L.3: Arrangements for treating externally EP L.1: In addition to the onsite first aid response, The commitment wording was contaminated patients have been made with the arrangements have been made with local hospitals for standardized and relocated to Doctors Hospital in Augusta, Georgia, and Burke treatment and evaluation of serious injuries or sicknesses. the SNC Standard Emergency County Hospital in Waynesboro, Georgia, Annex 5.8.1: Agreements are in place. with the University Plan and Site Annex. (appendix 2). of Alabama at Birmingham (UAB) Hospital, Burke Medical Center, Doctors Hospital, and Burke County Emergency Management Agency to provide assistance for injured personnel, including cases involving radioactive contamination. This assistance will be requested whenever necessary in accordance with plant procedures L.3: Trained plant radiation protection personnel Annex 5.8.2: Injured/externally contaminated personnel The commitment wording was will assist hospital staff when plant personnel are who require medical attention will normally be transported standardized and relocated to being evaluated. by ambulance to the cooperating hospitals. Ambulance the Site Annex. crews are trained to handle external contamination cases, and an HP technician accompanies any contaminated patients to the hospital. Ambulance service is provided by the Burke County Emergency Management Agency. L.3: Arrangements have also been made with EP L.3 State Emergency Medical Services The commitment wording was local doctors to render medical assistance, both The states of Alabama and Georgia have developed lists standardized and relocated to onsite and offsite, and to assume responsibility of facilities that can provide medical support for treating the SNC Standard Emergency for the medical supervision of the patient injured, contaminated individuals. Details are found in the Plan and Site Annex. (appendix 2, Letters of Agreement). respective state emergency plan. Annex 5.8.1: Agreements are in place with the University of Alabama at Birmingham (UAB) Hospital, Burke Medical Center, Doctors Hospital, and Burke County Emergency Management Agency to provide assistance for injured personnel, including cases involving radioactive contamination. This assistance will be requested whenever necessary in accordance with plant procedures ElS-141 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 L.3: Following decontamination, personnel Annex 5.8.1: Agreements are in place with the University The SNC Standard Emergency suspected to have ingested radionuclides will of Alabama at Birmingham (UAB) Hospital, Burke Medical Plan commits to maintaining undergo whole body counting at VEGP. Center, Doctors Hospital, and Burke County Emergency agreements supporting the Management Agency to provide assistance for injured treatment of contaminated personnel, including cases involving radioactive and/or injured personnel. contamination. This assistance will be requested Medical experts will determine whenever necessary in accordance with plant procedures the course of treatment and subsequent monitoring. A specific.commitment for internal monitoring at the site may or may not be included in this post event treatment. L.3: The medical staff of the hospital is trained to EP 0.1.1: Annually, training will be offered for hospital The commitment wording was treat externally contaminated patients or personnel, ambulance/rescue personnel, police, and fire standardized and relocated to individuals who have received high exposures. departments. The training shall include the procedures for the SNC Standard Emergency notification, basic radiation protection, and their Plan. organizations' expected role. L.4: In addition, drills and exercises are an EP N.2.3 Medical Emergency DrillsA medical emergency The commitment wording was integral part of the training program and are drill, involving a simulated contaminated individual, and standardized and relocated to conducted as specified in section N, Exercises containing provisions for participation by local support the SNC Standard Emergency and Drills. services organizations including ambulance response are Plan. conducted annually at the nuclear plants. Local support service organizations, which support more than one plant, shall only be required to participate once each calendar year. L.4: The VEGP training department conducts EP 0.1.1: Annually, training will be offered for hospital The commitment wording was training sessions at least once per calendar year personnel, ambulance/rescue personnel, police, and fire standardized and relocated to (for onsite and offsite personnel who have departments. The training shall include the procedures for the SNC Standard Emergency medical support responsibilities). notification, basic radiation protection, and their Plan. organizations' expected role. Section M Recovery and Reentry Planning and Post-Accident Operations ElS-142 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 M.1: The emergency director will determine when EP M.1: Upon termination of the emergency phase and at The commitment wording was the recovery phase begins. the discretion of the Emergency Director, following standardized and relocated to consultation with offsite authorities, the SNC Emergency the SNC Standard Emergency Organization will shift to the Recovery Phase Plan. Organization. M.1: The following guidelines, as applicable to EP M.1: The following guidelines, as applicable to the The commitment wording was the specific situation, will be observed prior to specific situation, will be addressed prior to terminating standardized and relocated to terminating the emergency: the emergency: the SNC Standard Emergency

The affected reactor is in a stable condition
The affected reactor is in a stable condition and can Plan.

and can be maintained in that condition be maintained in that condition indefinitely. indefinitely.

Plant radiation levels are stable or are decreasing
Plant radiation levels are stable or are with time. Releases of radioactive material to the decreasing with time. environment have ceased or are being controlled
Releases of radioactive material to the within permissible limits.

environment have ceased or are being

Fire or similar emergency conditions no longer controlled within permissible limits. constitute a hazard to safety-related systems or
Fire or similar emergency conditions no equipment or personnel.

longer constitute a hazard to safety-related

For a site area emergency or general emergency, systems or equipment or personnel. discussions with plant management, applicable
For a site area emergency or general members of the SNC emergency organization, offsite emergency, discussions with plant authorities do not result in identification of any valid management, applicable members of the reason for not terminating the emergency.

VEGP emergency organization, offsite authorities including the Nuclear Regulatory Commission (NRC); Georgia Emergency Management Agency, Burke County Emergency Management Agency director; South Carolina Emergency Management Division director; and Savannah River Site (SRS) emergency staff do not result in identification of any valid reason for not terminating the emergency. ElS-143 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 M.1: He (the ED) will direct that all elements of EP M.1 Upon termination of the emergency phase and at The commitment wording was the emergency response organization be advised the discretion of the Emergency Director, following standardized and relocated to of the change in status via the Emergency consultation with offsite authorities, the SNC Emergency the SNC Standard Emergency Notification Network (ENN), Emergency Organization will shift to the Recovery Phase Plan. Notification System (ENS), and other pertinent 0 rgan ization. communications systems. EP M.3 Recovery Notification Members of the ERO will be informed when Recovery is initiated. The recovery organizational structure may be much the same as the emergency response organization with additional modifications depending upon the nature of the accident, post-accident conditions, and other factors to be determined. The State EOC will be advised when the plant deems it safe to begin the reentry phase of the offsite recovery operation. If the governor has ordered an evacuation, it is legally required for the governor to officially rescind the order prior to return to evacuated areas. The states are responsible for coordinating reentry procedures for the offsite population. M.1: At this time, the emergency director will EP M.1: It is the responsibility of the Emergency Director The commitment wording was designate a recovery manager to constitute the (ED) to determine that the facility and surroundings are standardized and relocated to recovery organization. safe for reentry. The Emergency Director will designate a the SNC Standard Emergency recovery manager to constitute the recovery organization. Plan. ElS-144 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 M.2: Individuals will be assigned to specific EP M.1: The Recovery Manager will structure the The commitment wording was positions by the recovery manager, depending on recovery organization to accomplish the following general standardized and relocated to the nature and extent of damage to the plant. objectives: the SNC Standard Emergency

Maintain comprehensive radiation surveillance of the Plan.

site until levels return to normal.

Control access to the affected area of the plant and exposures to workers.
Decontaminate affected areas and equipment.
Conduct activities in radiation areas in accordance with the plant's standard radiation work practices.
Isolate and repair damaged systems .
Document proceedings of the accident and review the effectiveness of the emergency response organization in mitigating plant damage and reducing radiation exposures to the public.
Provide offsite authorities with plant status reports and information concerning the plant recovery organization.
Provide assistance with recovery activities undertaken by State and county authorities, if requested.
Provide public information on the status of recovery operations via releases to the media.

EP Figure M.2 ElS-145 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 M.2 : He (the Recovery Mgr.)will structure the EP M.1: The Recovery Manager will structure the . The commitment wording was recovery organization to accomplish the following recovery organization to accomplish the following general standardized and relocated to generalobjectives: objectives: the SNC Standard Emergency

Maintain comprehensive radiation
Maintain comprehensive radiation surveillance of the Plan.

surveillance of the site until levels return to site until levels return to normal. normal

Control access to the affected area of the plant and
Control access to the affected area of the exposures to workers .

plant and exposures to workers

Decontaminate affected areas and equipment.
Decontaminate affected areas and
Conduct activities in radiation areas in accordance equipment with the plant's standard radiation work practices.
Conduct activities in radiation areas in
Isolate and repair damaged systems .

accordance with the plant's standard

Document proceedings of the accident and review radiation work practices the effectiveness of the emergency response
Isolate and repair damaged systems organization in mitigating plant damage and reducing
Document proceedings of the accident and radiation exposures to the public.

review the effectiveness of the emergency

Provide offsite authorities with plant status reports response organization in mitigating plant and information concerning the plant recovery damage and reducing radiation exposures to organization.

the public

Provide assistance with recovery activities
Provide offsite authorities with plant status undertaken by State anc:I county authorities, if reports and information concerning the plant requested.

recovery organization

Provide public information on the status of recovery
Provide assistance with recovery activities operations via releases to the media .

undertaken by State and county authorities, if EP Figure M.2 requested

Provide public information on the status of recovery operations via releases to the media ElS-146 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 M.2: Recovery Manager: has overall EP M.1 Recovery The Statement on return to responsibility for restoring the station to a normal Guidance for determining the transition from Emergency normal operations is not operating configuration. to Recovery Organization is provided in the plant appropriate for the Plan. Normal Emergency Plan Implementing Procedures. The operations, extended shutdown, composition of the Recovery Organization will depend or decommissioning are all upon the nature of the accident and the conditions potential outcomes of events following the accident. involving activation of the SNC Emergency Plan addresses general principles that Emergency Plan. The outcome serve as guides for developing a Recovery Plan. will be determined on a site It is the responsibility of the Emergency Director (ED) to specific basis through transition determine that the facility and surroundings are safe for from the Emergency Phase.

reentry. The Emergency Director will designate a recovery manager to constitute the recovery organization. EP M.5 Termination of Recovery Phase Following the completion of the Recovery Phase, the site will transition to an Outage Organization to complete necessary repairs. ElS-147 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 M.2: Plant Operations Manager: manages day- EP M.1: The Recovery Manager will structure the The SNC Standard Emergency to-day in-plant operations and during recovery, is recovery organization to accomplish the following general Plan provides a likely recovery responsible for ensuring that repairs and objectives: organization and provides overall modifications will optimize post recovery plant

Maintain comprehensive radiation surveillance of the responsibility tor the event under operational effectiveness and safety. site until levels return to normal. the Recovery Manager.
Control access to the affected area of the plant and exposures to workers. The specific event will drive
Decontaminate affected areas and equipment. individual responsibilities.
Conduct activities in radiation areas in accordance with the plant's standard radiation work practices.
Isolate and repair damaged systems .
Document proceedings of the accident and review the effectiveness of the emergency response organization in mitigating plant damage and reducing radiation exposures to the public.
Provide offsite authorities with plant status reports and information concerning the plant recovery organization.
Provide assistance with recovery activities undertaken by State and county authorities, if requested.
Provide public information on the status of recovery operations via releases to the media.

EP Figure M.2 ElS-148 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 M.2: Design and Construction Support Manager: EP M .1 : The Recovery Manager will structure the The SNC Standard Emergency focuses necessary engineering, design, and recovery organization to accomplish the following general Plan provides a likely recovery construction resources on those aspects of plant objectives: organization and provides overall recovery requiring redesign, modifications, or

Maintain comprehensive radiation surveillance of the responsibility for the event under new construction. site until levels return to normal. the Recovery Manager. The
Control access to the affected area of the plant and specific event will drive individual exposures to workers. responsibilities.
Decontaminate affected areas and equipment.
Conduct activities in radiation areas in accordance with the plant's standard radiation work practices.
Isolate and repair damaged systems .
Document proceedings of the accident and review the effectiveness of the emergency response organization in mitigating plant damage and reducing radiation exposures to the public.
Provide offsite authorities with plant status reports and information concerning the plant recovery organization.
Provide assistance with recovery activities undertaken by State and county authorities, if requested.
Provide public information on the status of recovery operations via releases to the media.

EP Figure M.2 ElS-149 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 M.2: Health Physics Manager: responsible for As EP M.1: The Recovery Manager will structure the The SNC Standard Emergency Low As Reasonably Achievable (ALARA) recovery organization to accomplish the following general Plan provides a likely recovery planning, execution, and monitoring; plans and objectives: organization and provides overall manages decontamination of affected areas and

Maintain comprehensive radiation surveillance of the responsibility for the event under equipment; supervises and directs all special site until levels return to normal. the Recovery Manager.

radiological controls required to support the

Control access to the affected area of the plant and recovery operation. exposures to workers. The specific event will drive
Decontaminate affected areas and equipment. individual responsibilities.
Conduct activities in radiation areas in accordance with the plant's standard radiation work practices.
Isolate and repair damaged systems .
Document proceedings of the accident and review the effectiveness of the emergency response organization in mitigating plant damage and reducing radiation exposures to the public.
Provide offsite authorities with plant status reports and information concerning the plant recovery organization.
Provide assistance with recovery activities undertaken by State and county authorities, if requested.
Provide public information on the status of recovery operations via releases to the media.

EP Figure M.2 ElS-150 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 M.2: Technical Support Manager: provides EP M .1: The Recovery Manager will structure the The SNC Standard Emergency analyses, plans, schedules, and procedures in recovery organization to accomplish the following general Plan provides a likely recovery direct support of plant operations. objectives: organization and provides overall

Maintain comprehensive radiation surveillance of the responsibility for the event under site until levels return to normal. the Recovery Manager. The
Control access to the affected area of the plant and specific event will drive individual exposures to workers. responsibilities.
Decontaminate affected areas and equipment.
Conduct activities in radiation areas in accordance with the plant's standard radiation work practices.
Isolate and repair damaged systems .
Document proceedings of the accident and review the effectiveness of the emergency response organization in mitigating plant damage and reducing radiation exposures to the public.
Provide offsite authorities with plant status reports and information concerning the plant recovery organization.
Provide assistance with recovery activities undertaken by State and county authorities, if requested.
Provide public information on the status of recovery operations via releases to the media.

EP Figure M.2 ElS-151 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 M.2: Quality Assurance Manager: ensures that EP M.1: The Recovery Manager will structure the The SNC Standard Emergency the overall conduct of recovery operations is recovery organization to accomplish the following general Plan provides a likely recovery performed in accordance with corporate policy objectives: organization and provides overall and rules and regulations governing activities

Maintain comprehensive radiation surveillance of the responsibility for the event under which may affect public health and safety. site until levels return to normal. the Recovery Manager.
Control access to the affected area of the plant and exposures to workers. The specific event will drive
Decontaminate affected areas and equipment. individual responsibilities.
Conduct activities in radiation areas in accordance with the plant's standard radiation work practices.
Isolate and repair damaged systems .
Document proceedings of the accident and review the effectiveness of the emergency response organization in mitigating plant damage and reducing radiation exposures to the public.
Provide offsite authorities with plant status reports and information concerning the plant recovery organization.
Provide assistance with recovery activities undertaken by State and county authorities, if requested.
Provide public information on the status of recovery operations via releases to the media.

EP Figure M.2 ElS-152 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 M.2: Scheduling/Planning Manager: prepares EP M.1: The Recovery Manager will structure the The SNC Standard Emergency plans and schedules and tracks/expedites recovery organization to accomplish the following general Plan provides a likely recovery recovery operations. objectives: organization and provides overall

Maintain comprehensive radiation surveillance of the responsibility for the event under site until levels return to normal. the Recovery Manager.
Control access to the affected area of the plant and exposures to workers. The specific event will drive
Decontaminate affected areas and equipment. individual responsibilities.
Conduct activities in radiation areas in accordance with the plant's standard radiation work practices.
Isolate and repair damaged systems .
Document proceedings of the accident and review the effectiveness of the emergency response organization in mitigating plant damage and reducing radiation exposures to the public.
Provide offsite authorities with plant status reports and information concerning the plant recovery organization.
Provide assistance with recovery activities undertaken by State and county authorities, if requested.
Provide public information on the status of recovery operations via releases to the media.

EP Figure M.2 ElS-153 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 M.2: Administration/Logistics Manager: supplies EP M.1: The Recovery Manager will structure the The SNC Standard Emergency administrative, logistic, communications, and recovery organization to accomplish the following general Plan provides a likely recovery personnel support for ,the recovery operation. objectives: organization and provides overall

Maintain comprehensive radiation surveillance of the responsibility for the event under site until levels return to normal. the Recovery Manager. The

                                                **  Control  access to the affected area of the plant and   specific event will drive individuai exposures to workers.                                   responsibilities.

Decontaminate affected areas and equipment.
Conduct activities in radiation areas in accordance with the plant's standard radiation work practices.
Isolate and repair damaged systems .
Document proceedings of the accident and review the effectiveness of the emergency response organization in mitigating plant damage and reducing radiation exposures to the public.
Provide offsite authorities with plant status reports and information concerning the plant recovery organization. *
Provide assistance with recovery activities undertaken by State and county authorities, if requested.
Provide public information on the status of recovery operations via releases to the media.

EP Figure M.2 ElS-154 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 M.2: Public Information Director: coordinates the EP M.1: The Recovery Manager will structure the The SNC Standard Emergency flow of media information concerning recovery recovery organization to accomplish the following general Plan provides a likely recovery operations. objectives: organization and provides overall

Maintain comprehensive radiation surveillance of the responsibility for the event under site until levels return to normal. the Recovery Manager.The
Control access to the affected area of the plant and specific event will drive individual exposures to workers. responsibilities.
Decontaminate affected areas and equipment.
Conduct activities in radiation areas in accordance with the plant's standard radiation work practices.
Isolate and repair damaged systems .
Document proceedings of the accident and review the effectiveness of the emergency response organization in mitigating plant damage and reducing radiation exposures to the public.
Provide offsite authorities with plant status reports and information concerning the plant recovery organization.
Provide assistance with recovery activities undertaken by State and county authorities, if requested.
Provide public information on the status of recovery operations via releases to the media.

EP Figure M.2 E15-155 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 M.2: Chemistry Manager: develops plans and EP M.1: The Recovery Manager will structure the The SNC Standard Emergency procedures to process and control liquid, recovery organization to accomplish the following general Plan provides a likely recovery gaseous, and solid wastes to minimize adverse objectives: organization and provides overall effects on the health and safety of the public and

Maintain comprehensive radiation surveillance of the responsibility for the event under plant recovery personnel. site until levels return to normal. the Recovery Manager.
Control access to the affected area of the plant and exposures to workers. The specific event will drive
Decontaminate affected areas and equipment. individual responsibilities.
Conduct activities in radiation areas in accordance with the plant's standard radiation work practices.
Isolate and repair damaged systems .
Document proceedings of the accident and review the effectiveness of the emergency response organization in mitigating plant damage and reducing radiation exposures to the public.
Provide offsite authorities with plant status reports and information concerning the plant recovery organization.
Provide assistance with recovery activities undertaken by State and county authorities, if requested.
Provide public information on the status of recovery operations via releases to the media.

EP Figure M.2 ElS-156 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 M.3: Identifying and controlling access to these EP M.1: The Recovery Manager will structure th~ The commitment wording was areas will be in accordance with normal plant recovery organization to accomplish the following general standardized and relocated to procedures. objectives: the SNC Standard Emergency

Maintain comprehensive radiation surveillance of the Plan.

site until levels return to normal.

Control access to the affected area of the plant .and exposures to workers.
Decontaminate affected areas and equipment.
Conduct activities in radiation areas in accordance with the plant's standard radiation work practices.
Isolate and repair damaged systems .

I

Document proceedings of the accident and review the effectiveness of the emergency response organization in mitigating plant damage and reducing radi~tion exposures to the public.
Provide offsite authorities with plant status reports and information concerning the plant recovery organization.
Provide assistance with recovery activities undertaken by State and county authorities, if requested.
Provide public information on the status of recovery operations via releases to the media.

EP Figure M.2 ElS-157 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 M.3: If the accident situation involved a release of EP M.1: The Recovery Manager will structure the The commitment wording was radioactivity, appropriate areas of the plant and recovery organization to accomplish the following general standardized and relocated to site will be monitored to determine contamination objectives: the SNC Standard Emergency and radiation levels.

Maintain comprehensive radiation surveillance of the Plan.

site until levels return to normal.

Control access to the affected area of the plant and exposures to workers.
Decontaminate affected areas and equipment.
Conduct activities in radiation areas in accordance with the plant's standard radiation work practices.
Isolate and repair damaged systems .
Document proceedings of the accident and review the effectiveness of the emergency response organization in mitigating plant damage and reducing radiation exposures to the public.
Provide offsite authorities with plant status reports and information concerning the plant recovery organization.
Provide assistance with recovery activities undertaken by State and county authorities, if requested.
Provide public information on the status of recovery operations via releases to the media.

EP Figure M.2 M.3: When reentry to a radiation area is required EP M .1 Recovery The commitment wording was for inspection or work, the activity will be Recovery operations will be conducted in compliance with standardized and relocated to preplanned and plant radiation work practices normal operational radiation exposure level limits as the SNC Standard Emergency and As Low As Reasonably Achievable (ALARA) specified in 10 CFR 20. When possible, any necessary Plan. program principles will be followed. releases of radioactive materials or effluent during recovery will be planned, controlled, evaluated in advance for radiological impact and appropriate offsite organizations and agencies informed of the scheduled releases and estimated impact. ElS-158 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 M.4: All personnel who require access to the EP M.1 Recovery The commitment wording was plant or to radiation areas on site during the Recovery operations will be conducted in compliance with standardized and relocated to recovery phase will be issued dosimetry, as normal operational radiation exposure level limits as the SNC Standard Emergency appropriate. specified in 10 CFR 20. When possible, any necessary Plan. releases of radioactive materials or effluent during recovery will be planned, controlled, evaluated in advance for radiological impact and appropriate offsite organizations and agencies informed of the scheduled releases and estimated impact. M.4: The criteria for reading TLDs and assessing EP M.1 Recovery The commitment wording was radiation dose will be in accordance with Recovery operations will be conducted in compliance with standardized and relocated to standard health physics practices. normal operational radiation exposure level limits as the SNC Standard Emergency specified in 10 CFR 20. When possible, any necessary Plan. releases of radioactive materials or effluent during recovery will be planned, controlled, evaluated in advance for radiological impact and appropriate offsite organizations and agencies informed of the scheduled releases and estimated impact. M.4: The results of the dosimeter readings, EP M.1 Recovery The commitment wording was including integrated exposures (i.e., man-rems) Recovery operations will be conducted in compliance with standardized and relocated to will be reported to the recovery manager, the normal operational radiation exposure level limits as the SNC Standard Emergency radcon/radwaste manager, and others in the specified in 10 CFR 20. When possible, any necessary Plan. plant organization who normally receive such releases of radioactive materials or effluent during reports. recovery will be planned, controlled, evaluated in advance for radiological impact and appropriate offsite organizations and agencies informed of the scheduled releases and estimated impact. M.4: VEGP will provide radiological information EP M.4 Population Exposure Estimates Section B of the Plan retains the including estimated quantity of radioactivity It is anticipated that the Federal Radiological Monitoring commitment to provide released, isotopic composition of released and Assessment Center (FRMAC) will make a total environmental field teams. material, and meteorological data to assist the population exposure calculation, based on estimated dose The progression of the overall governmental authorities in their determinations. rates and population representing exposed areas. planning process has shifted the long term responsibilities for offsite radiological assessment to the FRMAC. ElS-159 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Figure M-1 EP Figure M.2 The commitment wording was standardized and relocated to the SNC Standard Emergency Plan. Section N Exercises and Drills N.1: Exercises are conducted every two calendar EP N.1.2: Full participation exercises will include, as The commitment wording was years, and are designed to include the appropriate, offsite local and state authorities and SNC standardized and relocated to demonstration of response to a major portion of personnel actively participating in testing the integrated the SNC Standard Emergency the basic elements of the emergency capability to assess and respond to an accident at a Plan. preparedness plans of the participating nuclear power plant. Additionally, full participation organizations. exercises will include, as appropriate, testing the major observable portions of the onsite and offsite emergency plans and mobilization of state, local, and SNC personnel and other resources in sufficient numbers to verify the capability to respond to the accident scenario. EP N.1.5: The Exercise planning cycle will consist of eight (8) successive calendar years ElS-160 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 N.1: The exercise program for VEGP EP N.3: During the exercise planning cycle described in The commitment wording was incorporates the following features: Section N.1.5, SNC sites vary the content of exercise standardized and relocated to

Scenarios are varied from year to year so scenarios to provide ERO members the opportunity to the SNC Standard Emergency that all major elements of the VEGP demonstrate proficiency in key skills necessary to respond Plan. The wording has been emergency preparedness program are tested to several specific scenario elements including: updated to reflect the Enhanced within an eight year period, commencing in
Hostile Action directed at the plant site . Emergency Preparedness the calendar year in which the VEGP 3 and 4
No radiological release or unplanned release that Rulemaking (November 23, first exercise is conducted. does not require public protective actions; 2011).
VEGP starts an exercise between 6:00 p.m.
An initial classification of or rapid escalation to a Site and 4:00 a.m. once every 8 years. Area Emergency or General Emergency.
Since exercises are normally scheduled
Implementation of strategies, procedures, and several months in advance, a variety of guidance developed in 50.54(hh), (i.e., potential weather conditions is likely to occur. aircraft threat, explosion or large fire).
Integration of offsite resources with onsite response
A drill initiated between the hours of 6 p.m. and 4 a.m.
Drills utilizing essentially 100 % of Initiating Conditions in the 8 year cycle.

Drills and exercise scenarios will be varied from year to year so as to test major components of the plans and preparedness organizations. A record of Exercises conducted during the eight (8) year exercise planning cycle that documents the contents of scenarios used during that cycle shall be maintained in accordance with Drill and Exercise procedure guidance ElS-161 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 N.2.1: At least one of these drills will be EP N.2.1: SNC operated nuclear power plants shall take The commitment wording was conducted during the calendar year when there is actions necessary to ensure that adequate emergency standardized and relocated to no biennial exercise and shall involve a response capabilities are maintained during the interval the SNC Standard Emergency combination of some of the principal functional between biennial exercises by conducting drills, including Plan. areas of the onsite emergency response at least one drill involving a combination of some of the capabilities. principal functional areas of the licensee's onsite emergency response capabilities. The principal functional areas of emergency response include activities such as:

Management and coordination of emergency response.
Accident assessment.
Event classification.
Notification of offsite authorities.
Assessment of the onsite and offsite impact of radiological releases.
Protective action recommendation development.
protective action decision making; and
Plant system repair and corrective actions.

N.2.2: To ensure that emergency communication EP F.3: Communications tests will be conducted on the The commitment wording was channels between VEGP and offsite authorities frequency specified below. Each of these tests includes standardized and relocated to are operable, periodic drills are conducted. provisions to ensure that all participants in the test are the SNC Standard Emergency able to understand the content of the messages used in Plan. the test. N.2.2: For drills, the communication is initiated at EP F.3: Communications tests will be conducted on the The commitment wording was VEGP using the actual message format in frequency specified below. Each of these tests includes standardized and relocated to accordance with the applicable plan and provisions to ensure that all participants in the test are the SNC Standard Emergency procedure. able to understand the content of the messages used in Plan. 1 the test. ElS-162 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 N.2.2: Communication drills among the control EP F.3: Communications tests will be conducted on the The commitment wording was room, technical support center (TSC), operations frequency specifie,d below. Each of these tests includes standardized and relocated to support center (OSC), emergency operations provisions to ensure that all participants in the test are the SNC Standard Emergency facility (EOF), emergency news center, general able to understand the content of the messages used in Plan. office operations center, the States of Georgia the test. ahd South Carolina, Burke, Aiken, Barnwell, and

Communications with state and local governments Allendale Counties, SRS, and VEGP field within the plume exposure pathway will be tested monitoring teams are conducted every two years. monthly.
Communications with federal response organizations and state governments Within the plume exposure pathway will be tested quarterly.
Communications between SNC operated nuclear power plants, state Emergency Operating Centers and local Emergency Operations Centers, and radiation monitoring teams will be tested annually;
Communication from the Control Room, TSC, and EOF to the NRC Operations Center will be tested monthly.
The Emergency Response Data System (EROS) will be tested on a quarterly basis;
The fixed siren portion of the Alert and Notification System (ANS) will be tested and verified in accordance with existing FEMA approvals.

N.2.3: As discussed in the FSAR, the program EP N.2.2: Fire drills will be conducted at nuclear plants in The commitment wording was involves quarterly (fire) drills, at least one of accordance with Plant Technical Specifications and Plant standardized and relocated to which is unannounced. procedures. the SNC Standard Emergency Plan. N.2.3: The quarterly drills are scheduled so that EP N.2.2: Fire drills will be conducted at nuclear plants in The commitment wording was each member of the fire brigade participates in at accordance with Plant Technical Specifications and Plant standardized and relocated to least two drills per year. procedures. the SNC Standard Emergency Plan. N.2.3: In addition, an annual practice is EP N.2.2: Fire drills will be conducted at nuclear plants in The commitment wording was conducted which requires extinguishing a fire. accordance with Plant Technical Specifications and Plant standardized and relocated to procedures. the SNC Standard Emergency Plan. ElS-163 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 N.2.4: A medical emergency drill involving a EP N.2.3: A medical emergency drill, involving a The commitment wording was simulated contaminated person is conducted simulated contaminated individual, and containing standardized and relocated to each calendar year. provisions for participation by local support services the SNC Standard Emergency organizations including ambulance response are Plan. conducted annually at the nuclear plants. N.2.5: Plant environs and radiological monitoring EP N.2.4: Plant environs and radiological monitoring drills The commitment wording was drills are conducted each calendar year per are conducted annually. These drills include collection standardized and relocated to administrative procedures and analysis of sample media and provisions for the SNC Standard Emergency communications and record keeping. These drills also Plan. evaluate the response to, and analysis of, simulated airborne and direct radiation measurements in the environment. N.2.6: Semi-annual health physics drills will be EP N.2.5: Radiation Protection Drills involving a response The commitment wording was conducted in accordance with emergency to, and analysis of, simulated airborne and liquid samples standardized and relocated to implementing procedures. and direct radiation measurements are conducted semi- the SNC Standard Emergency annually. At least annually, these drills shall include a Plan. demonstration of the sampling system capabilities, as applicable. N.2.6: Post accident sampling under simulated The annual sampling accident conditions will be demonstrated each requirement in the description of calendar year. Radiation Protection drills in EP N.2.5 ensures accident sampling capabilities are maintained. ElS-164 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 N.3: Each drill and exercise is conducted in EP N.3 Scenarios The commitment wording was accordance with a scenario. When a major drill or exercise is required, the Emergency standardized and relocated to Preparedness (EP) group will coordinate the preparation the SNC Standard Emergency of a scenario. The EP group will also coordinate efforts Plan. with appropriate federal, state, and local emergency organizations and agencies, schedule a date to conduct the drill or exercise, and assign qualified controllers. The Emergency Preparedness group retains critique results for review prior to future drills or exercise and for guidance in properly modifying the site-specific Annexes, Emergency Plan Implementing Procedures (EPIPs), or other procedures as appropriate. A scenario, prepared in advance, will govern the conduct of exercises and drills. Scenarios will include the following:

Objectives of the drill or exercise; a measurable and observable objective.must be specified for each major problem and solution.
Dates, time period, places, personnel, and participating organizations.
Simulated events .
Time schedule of real and simulated initiating events .
Narrative summary describing the conduct of the exercise or drill, including simulated casualties, offsite fire department assistance, rescue of personnel, use of protective clothing and associated equipment, deployment of personnel and radiological teams, and public information activities.

N.3: The preparation of exercise scenarios is EP N.3 Scenarios The commitment wording was directed by the Manager-Training and When a major drill or exercise is required, the Emergency standardized and relocated to Emergency Preparedness or EPC who enlists Preparedness (EP) group will coordinate the preparation the SNC Standard Emergency the assistance of personnel from other of a scenario. Plan. departments, as required, to assist in this task. ElS-165 5 to NL~16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 N.3: Scenarios include the following information: EP N.3 Scenarios The commitment wording was

Objectives. When a major drill or exercise is required, the Emergency standardized and relocated to
Date, time period, place, and participating Preparedness (EP) group will coordinate the preparation the SNC Standard Emergency organizations. of a scenario. The EP group will also coordinate efforts Plan.
Controller/evaluator assignments . with appropriate federal, state, and local emergency
Time schedules of real and simulated organizations ahd agencies, schedule a date to conduct initiating events. the drill or exercise, and assign qualified controllers.

The Emergency Preparedness group retains critique

Messages describing equipment results for review prior to future drills or exercise and for malfunctions, personnel injuries, and other non plant events, as appropriate. guidance in properly modifying the site-specific Annexes, Emergency Plan Implementing Procedures (EPIPs), or
Narrative summary describing the conduct of other procedures as .appropriate.

the drill or exercise. A scenario, prepared in advance, will govern the conduct

Radiological data for onsite facilities and of exercises and drills. Scenarios will include the offsite field monitoring teams.

following:

Objectives of the drill or exercise; a measurable and observable objective must be specified for each major problem and solution.
Dates, time period, places, personnel, and participating organizations.
Simulated events .
Time schedule of real and simulated initiating events .
Narrative summary describing the conduct of the exercise or drill, including simulated casualties, offsite fire department assistance, rescue of personnel, use of protective clothing and associated equipment, deployment of personnel and radiological teams, and public information activities.

ElS-166 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 N.4: All drills and exercises are EP N.4 Exercise Evaluation and Critique The commitment wording was evaluated.Section N: For periodic drills, the A formal critique will be performed for exercises, drills, standardized and relocated to process consists of the following steps: and training tabletops to develop, maintain, or the SNC Standard Emergency

1. Drills will be evaluated by demonstrate key skills in order to identify weak or deficient Plan.

controllers/evaluators selected on the basis of areas that need correction. expertise and availability. A critique shall be conducted at the conclusion of the

2. Improper or incorrect performance during the exercise, to evaluate the organization's ability to respond drill may be corrected by the controller/evaluator as called for in the SNC Standard Emergency Plan.

and the proper method pointed out or Qualified personnel will observe and perform a critique of demonstrated. exercises and drills. Provisions will be made for federal,

3. The exercise or drill controllers assemble the state, and local observers, as well as SNC personnel, to players at the conclusion of activities for a observe and critique required exercises. Biennially, critique. Players are encouraged to identify representatives from the NRC observe and evaluate the areas where improvements are required. The licensee's ability to conduct an adequate self-critical drill controllers also presents their observations critique. For partial and full offsite participation exercises, to the players. the NRC and Federal Emergency Management Agency

4. The site emergency preparedness supervisor (FEMA), will observe, evaluate, and critique.

submits a list of corrective actions, Drill and exercise performance objectives will be responsibilities, and schedule information to the evaluated against measurable demonstration criteria. As site support manager for approval. soon as possible following the conclusion of the drill or

5. The emergency preparedness supervisor exercise, a critique is conducted to evaluate the ability of assigns action items and monitors the status of the Emergency Response Organization (ERO) to completion of corrective actions. Significant implement the emergency plan and procedures and a problems will be brought to the attention of formal evaluation will result from the critique.

appropriate plant management.Exercise A written critique report is prepared by the Emergency evaluation and corrective action are carried out in Preparedness group following a drill or exercise involving similar fashion. the evaluation of designated objectives or following the final simulator set with ERO participation. The report will evaluate the ability of the ERO to respond to a simulated emergency situation. The report will also contain corrective actions and recommendations. Section 0 Radiological Emergency Response Training ElS-167 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 0: All VEGP badged personnel will receive EP 0.4.8: GET will include general training in emergency The commitment wording was General Employee Training at inception of onsite preparedness for plant and other site personnel. GET will standardized and relocated to duties. include classification, individual response, signals, the SNC Standard Emergency 0.3: All badged VEGP workers will receive accountability, and site evacuation procedures. Plan. general training in emergency preparedness. The prerequisites for badging workers includes GET training. 0: GET will include emergency classification, EP 0.4.8: GET will include general training in emergency The commitment wording was individual response, signals, accountability, and preparedness for plant and other site personnel. GET will standardized and relocated to site dismissal procedures. include classification, individual response, signals, the SNC Standard Emergency accountability, and site evacuation procedures. Plan. 0: All VEGP emergency response organization EP 0.1 Training The commitment wording was personnel will receive specialized training per To achieve and maintain an acceptable level of standardized and relocated to Table 0-2. emergency preparedness, training will be conducted for the SNC Standard Emergency members of the Emergency Response Organization Plan. (ERO) and those offsite organizations who may be called upon to provide assistance in the event of an emergency. Training will be evaluated in accordance with the requirements of Systematic Approach to Training practices to ensure effectiveness and in order to identify weak or deficient areas that need correction. The ERO Training Program assures the training, qualification, and requalification of individuals who may be called on for assistance during an emergency. Specific emergency response task training, prepared for response positions, is described in lesson plans and study guides. The lesson plans, study guides, and written tests are contained in the ERO Training Program. Responsibilities for implementing the training program are contained in plant procedures. Offsite training is provided to support organizations that may be called upon to provide assistance in the event of an emergency. ElS-168 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 0: Offsite response groups who may support EP 0.1: Personnel from nuclear power plants annually The commitment wording was onsite situations, such as fire or personnel injury, offer to train those non-SNC organizations referenced in standardized and relocated to will be offered annual training in notification, the Plant Annexes that may provide specialized services the SNC Standard Emergency expected roles, site orientation, security during a nuclear plant emergency. The training offered Plan. procedures, and basic radiation protection. will acquaint the participants with the special problems 0: Selected state and local emergency response potentially encountered during a nuclear plant emergency, management personnel with offsite emergency notification procedures, and their expected roles. response roles will be offered a seminar/training Organizations that must enter the site shall also receive course in specific areas; site-specific emergency response training and be

VEGP emergency classification system . instructed as to the identity of those persons in the onsite
VEGP protective action recommendation organization who will control their support activities.

criteria and their relationship to plant Training of state and local offsite emergency response conditions organizations is described in their respective radiological

VEGP emergency response emergency plans, with support provided by SNC if organization. requested.

0: These offsite management personnel will be EP 0.1.1: A training opportunity will be offered annually offered initial training and annual retraining. for offsite organizations and agencies as specified in respective agreements and understandings. In addition, those offsite organizations and agencies that may provide onsite emergency assistance will be encouraged to become familiar with the general layout of SNC plants, and will be invited to attend applicable Emergency Plan training and orientation courses.Annually, training will be offered for hospital personnel, ambulance/rescue personnel, police, and fire departments. The training shall include the procedures for notification, basic radiation protection, and their organizations' expected role. ElS-169 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 0.1: As a minimum, training will be provided in EP 0.4 ERO Training The commitment wording was the subject areas shown in table 0-1 to various SNC ERO personnel who are responsible for standardized and relocated to personnel according to their emergency implementing this plan receive specialized training. The the SNC Standard Emergency response position as shown on table 0-2.0.1: training program for emergency response personnel is Plan. Those designated to receive training in each developed based on the requirements of 10 CFR 50, subject area are indicated in table 0-2. Appendix E and position specific responsibilities. Requalification training for onsite ERO members consists of an annual review of the Emergency Plan in the form of a general overview. In addition to SNC Emergency Plan overview training, personnel assigned onsite emergency response positions will receive training specific to their position. EP 0.4.1 Emergency Response Organization (ERO) EP 0.4.2 Active Senior Licensed Control Room Personnel EP 0.4.3 Radiological Field Monitoring Teams EP 0.4.4 Fire Brigade Training EP 0.4.5 Operations, Maintenance, Chemistry and Radiation Protection Training EP 0.4.6 Medical Support EP 0.4.7 News Media Training EP 0.4.8 General Employee Training (GET) ElS-170 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 0.1: The training will be conducted in accordance EP 0.1 Training The commitment wording was with lesson plans. To achieve and maintain an acceptable level of standardized and relocated to emergency preparedness, training will be conducted for the SNC Standard Emergency members of the Emergency Response Organization Plan. (ERO) and those offsite organizations who may be called upon to provide assistance in the event of an emergency. Training will be evaluated in accordance with the requirements of Systematic Approach to Training practices to ensure effectiveness and in order to identify weak or deficient areas that need correction. The ERO Training Program assures the training, qualification, and requalification of individuals who may be called on for assistance during an emergency. Specific emergency response task training, prepared for response positions, is described in lesson plans and study guides. The lesson plans, study guides, and written tests are contained in the ERO Training Program. Responsibilities for implementing the training program are contained in plant procedures. ElS-171 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 0.1: Records of the attendance and examination EP 0.1 Training The commitment wording was scores will be retained in the training files. To achieve and maintain an acceptable level of standardized and relocated to emergency preparedness, training will be conducted for the SNC Standard Emergency Plan. members of the Emergency Response Organization (ERO) and those offsite organizations who may be called upon to provide assistance in the event of an emergency. Training will be evaluated in accordance with the requirements of Systematic Approach to Training practices to ensure effectiveness and in order to identify weak or deficient areas that need correction. The ERO Training Program assures the training, qualification, and requalification of individuals who may be called on for assistance during an emergency. Specific emergency response task training, prepared for response positions, is described in lesson plans and study guides. The lesson plans, study guides, and written tests are contained in the ERO Training Program. Responsibilities for implementing the training program are contained in plant procedures. Offsite training is provided to support organizations that may be called upon to provide assistance in the event of an emergency. 0.1: Radiological emergency response training is EP 0.4 ERO Training The commitment wording was offered throughout the year, with each training SNC ERO personnel who are responsible for standardized and relocated to course being covered at least once per calendar implementing this plan receive specialized training. The the SNC Standard Emergency year. training program for emergency response personnel is Plan. developed based on the requirements of 10 CFR 50, Appendix E and position specific responsibilities. Requalification training for onsite ERO members consists of an annual review of the Emergency Plan in the form of a general overview. In addition to SN'C Emergency Plan overview training, personnel assigned onsite emergency response positions will receive training specific to their position. ElS-172 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 0.1: Annual retraining consists of initial training EP 0.4 ERO Training The commitment wording was material reinforcement and appropriate lessons SNC ERO personnel who are responsible for standardized and relocated to learned from the previous year's operating implementing this plan receive specialized training. The the SNC Standard Emergency experience. training program for emergency response personnel is Plan. developed based on the requirements of 10 CFR 50, Appendix E and position specific responsibilities. Requalification training for onsite ERO members consists of an annual review of the Emergency Plan in the form of a general overview. In addition to SNC Emergency Plan overview training, personnel assigned onsite emergency response positions will receive training specific to their position. 0.1: Upon completion of each training session or EP 0.1 Training The commitment wording was drill, the participants will be asked to critique the To achieve and mail'ltain an acceptable level of standardized and relocated to training in order to ensure continued the SNC Standard Emergency emergency preparedness, training will be conducted for improvement. Plan. members of the Emergency Response Organization (ERO) and .those offsite organizations who may be called upon to provide assistance in the event of an emergency. Training will be evaluated in accordance with the requirements of Systematic Approach to Training practices to ensure effectiveness and in order to identify weak or deficient areas that need correction. The ERO Training Program assures the training, qualification, and requalification of individuals who may be called on for assistance during an emergency. Specific emergency response task training, prepared for response positions, is described in lesson plans and study guides. The le~son plans, study guides, and written tests are contained in the ERO Training Program. Responsibilities for implementing the training program are contained in plant procedures. Offsite training is provided to support organizations that may be called upon to provide assistance in the everit of an emergency. ElS-173 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Table 0-1 EP 0.1 Training The commitment wording was All ERO personnel shall be trained per table 0-2 To achieve and maintain an acceptable level of standardized and relocated to within the last 15 months, except for post the SNC Standard Emergency emergency preparedness, training will be conducted for accident sampling and first aid training, which is Plan. members of the Emergency Response Organization (ERO) to be within 36 months. and those offsite organizations who may be called upon to provide assistance in the event of an emergency. Training will be evaluated in accordance with the requirements of Systematic Approach to Training practices to ensure effectiveness and in order to identify weak or deficient areas that need correction. The ERO Training Program assures the training, qualification, and requalification of individuals who may be called on for assistance during an emergency. Specific emergency response task training, prepared for response positions, is described in lesson plans and study guides. The lesson plans, study guides, and written tests are contained in the ERO Training Program. Responsibilities for implementing the training program are contained in plant procedures. Offsite training is provided to support organizations that may be called upon to provide assistance in the event of an emergency. ElS-174 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 0.3: Selected individuals on site and off site will EP 0.1 Training The commitment wording was annually receive specialized training. To achieve and maintain an acceptable level of standardized and relocated to emergency preparedness, training will be conducted for the SNC Standard Emergency members of the Emergency Response Organization Plan. (ERO) and those offsite organizations who may be called upon to provide assistance in the event of an emergency. Training will be evaluated in accordance with the requirements of Systematic Approach to Training practices to ensure effectiveness and in order to identify weak or deficient areas that need correction. The ERO Training Program assures the training, qualification, and requalification of individuals who may be called on for assistance during an emergency. Specific emergency response task training, prepared for response positions, is described in lesson plans and study guides. The lesson plans, study guides, and written tests are contained in the ERO Training Program. Responsibilities for implementing the training program are contained in plant procedures. Offsite training is provided to support organizations that may be called upon to provide assistance in the event of an emergency. EP 0.4.1 ERO Training ERO members will receive Emergency Plan training on an annual basis. Personnel identified receive training appropriate to their position in the areas of:

Accident assessment.
Accident mitigation .
Notifications .
Emergency Classifications .
Protective Action Recommendations .
Emergency Action Levels .
Emergency Exposure Control.

Section P Responsibility for the Planning Effort ElS-175 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 P: The Executive Vice President/Chief Nuclear EP P: The President/Chief Executive Officer (CEO) The commitment wording was Officer (CNO) Southern Nuclear Operating Southern Nuclear Operating Company (SNC) has direct standardized and relocated to Company (SNC) has overall responsibility and responsibility for the operation and maintenance of the the SNC Standard Emergency authority for all nuclear activities, including SNC Plants. Plan. emergency planning (EP) programs. P: Vice President Fleet Operations Support has EP P.1: The Vice President - Regulatory Affairs is The commitment wording was Fleet responsibility for emergency planning. responsible for the overall coordination of the corporate standardized and relocated to emergency preparedness programs and Emergency the SNC Standard Emergency Plans. Plan. P: The Nuclear Fleet Security and Emergency EP P.1: The Fleet Emergency Preparedness Director is The commitment wording was Preparedness Manager has overview responsible for the oversight of Emergency Preparedness standardized and relocated to management responsibility for the Fleet SNC activities and coordinating those activities with Licensee, the SNC Standard Emergency Emergency Planning program effort. Federal, State, and local response organizations. Plan. P: The Emergency Planning (EP) Supervisor, EP P.2: The Emergency Preparedness Supervisor is The commitment wording was reporting to the Nuclear Fleet Security and responsible for coordinating onsite emergency standardized and relocated to Emergency Preparedness Manager is preparedness activities and supports offsite emergency the SNC Standard Emergency responsible for overseeing emergency planning preparedness activities in the plant vicinity. Plan. activities offsite and coordinating those activities with Licensee, Federal, State and local response organizations. P: Vice President - (Plant) is responsible for the EP P.2: The Vice President-(Site) is responsible for the The commitment wording was site Emergency Preparedness aspects of the site Emergency Preparedness aspects of the program at standardized and relocated to program. each site the SNC Standard Emergency Plan. P: The EP Supervisor, Emergency Planning EP 0.5: Training for the Emergency Preparedness Staff at The commitment wording was Coordinator, Emergency Preparedness an SNC operated plant consists of initial and continuing standardized and relocated to Supervisor, and other individuals with emergency training process. Details can be found in site specific the SNC Standard Emergency planning responsibilities are trained by self-study procedures and processes. Plan. and by attending industry seminars, short courses, workshops, etc. P: The Emergency Planning Supervisor performs EP P.3: The Emergency Plan, agreements, and the The commitment wording was a review of the emergency plans for Southern Emergency Implementing Procedures are reviewed once standardized and relocated to Nuclear once each calendar year. per calendar year and updated, as needed. the SNC Standard Emergency Plan. ElS-176 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 P: The Emergency Preparedness Supervisor EP P.3. EPIPs and administrative procedures for the The commitment wording was performs a review of the site specific emergency Emergency Preparedness function are maintained by the standardized and relocated to plan annually and all onsite EPIPs biennially. Fleet Emergency Preparedness Director with a the SNC Standard Emergency P: The review includes the letters of agreement, designated EP staff member being the principle contact. Plan. which are updated as necessary. Approved changes to the Emergency Plan are forwarded to key organizations and appropriate individuals who are responsible for implementing the Plan. The Emergency Plan, agreements, and the EPIPs are reviewed once per calendar year and updated, as needed. These updates take into account changes identified by drills and exercises, and the independent review described below. P: As required by 10 CFR 50.54(t), an annual EP P.3: An independent review of the EP program is The commitment wording was independent audit of the emergency conducted, as required by 10 CFR 50.54(t). standardized and relocated to preparedness program is conducted by the SNC the SNC Standard Emergency Quality Assurance (QA) Department. Plan: P: Audits are performed in accordance QA EP P.3: An independent review of the EP program is The commitment wording was department procedures. conducted, as required by 10 CFR 50.54(t). standardized and relocated to the SNC Standard Emergency Plan. P: The interval from the previous audit may be EP P.3: An independent review of the EP program is The commitment wording was shortened but may not be extended beyond 15 conducted, as required by 10 CFR 50.54(t). standardized and relocated to months. the SNC Standard Emergency Plan. P: Records of these audits and exercise findings EP P.3: The results of the review, along with The commitment wording was are maintained in accordance with plant recommendations for improvements, are documented and standardized and relocated to procedures. reported to plant management and to appropriate offsite the SNC Standard Emergency agencies. Plan. ElS-177 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 P: The Emergency plans and EPIPs are revised EP P.3. EPIPs and administrative procedures for the The commitment wording was in accordance with applicable site procedures. Emergency Preparedness function are maintained by the standardized and relocated to Fleet Emergency Preparedness Director with a the SNC Standard Emergency designated EP staff member being the principle contact. Plan. Approved changes to the Emergency Plan are forwarded to key organizations and appropriate individuals who are responsible for implementing the Plan. The Emergency Plan, agreements, and the EPIPs are reviewed once per calendar year and updated, as needed. These updates take into account changes identified by drills and exercises, and the independent review described below. Appendices and Annexes AnnexV2 Annex V2 H.4.1.1: (Meteorological) Parameters EP H.5.1: Meteorological Instrumentation: Meteorological The commitment wording was measured and transmitted to the control room Instrumentation: A permanent meteorological monitoring standardized and relocated to include: station is located near the plant for the acquisition and the SNC Standard Emergency

Windspeed (at 10 m and 60 m) recording of wind speed, wind direction, ambient and Plan and Site Annex.
Wind direction (at 10 m and 60 m) differential temperatures for use in making offsite dose
Standard deviation of horizontal wind projections. Meteorological information is displayed in the direction (at 10 m) CR, TSC, and EOF.
Vertical temperature difference (between 10 Annex 5.6.1: A meteorological monitoring program is in m and 60 m) place at VEGP. Instruments are mounted on a 60-meter tower located to the south-southwest of the power block.
Ambient temperature (at 10 m) Parameters measured and transmitted to the control room
Dewpoint temperature (at 10 m) include:
Precipitation (at the tower base) 1.4: In the event the primary instruments are
Windspeed (10 m and 60 m) .

unavailable, the backup meteorological tower is

Wind direction (10 m and 60 m) .

equipped with instruments at the 10-m level to

Standard deviation of horizontal wind direction (10 provide parameters relevant to atmospheric m).

dispersion calculations (i.e., windspeed, wind

Vertical temperature difference (10 m and 60 m).

direction, and sigma theta).

Ambient temperature (10 m).
Dewpoint temperature (10 m) .
Precipitation (base) .

ElS-178 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Annex V2 H.4.1.1: The system is powered by an Annex 5.6.1: The system is powered by an uninterruptible The commitment wording was uninterruptible power supply consisting of wet power supply consisting of wet cell batteries, charger, and standardized and relocated to cell batteries, charger, and inverter for high inverter for high availability. the Site Annex. availability. Annex V2 H.4.1.3: Seismic monitoring EP H.5.1: Seismic Monitoring: The seismic monitoring The commitment wording was instrumentation for VEGP Units 3 and 4 will system measures and records the acceleration of the standardized and relocated to include triaxial acceleration sensors and a time- structure if activated by an earthquake of sufficient the SNC Standard Emergency history analyzer. magnitude. It also provides signals for immediate remote Plan and Site Annex. indication that specific preset response accelerations have been exceeded. Annex 5.6.1: Seismic monitoring instrumentation for VEGP Units 3 and 4 will include triaxial acceleration sensors and a time-history analyzer. Annex V2 H.4.1.3: Activation of the time-history Annex 5.6.1: Activation of the time-history analyzer The commitment wording was analyzer causes visual and audible annunciation causes visual and audible annunciation in the control standardized and relocated to in the control room to alert the plant operator that room to alert the plant operator that an earthquake has the Site Annex. an earthquake has occurred. occurred. Annex V2 H.4.1.4: The fire-detection system at EP H.5.4: The Fire Detection System is designed to The commitment wording was VEGP Units 3 and 4 will include smoke, flame, detect products of combustion or heat in designated areas standardized and relocated to heat, and products of combustion detectors and of the plant. The fire alarm communication systems and the SNC Standard Emergency manually activated fire alarms. subsystems are located at strategic points throughout the Plan. plant to warn personnel of a fire or other emergency conditions. Additional description of the fire system is provided in the FSAR. Annex V2 H.4.1.4: Fire-detection systems are EP H.5.4: The Fire Detection System is designed to The commitment wording was provided in all areas where required by the fire detect products of combustion or heat in designated areas standardized and relocated to protection analysis. of the plant. The fire alarm communication systems and the SNC Standard Emergency subsystems are located at strategic points throughout the Plan. plant to warn personnel of a fire or other emergency conditions. Additional description of the fire system is provided in the FSAR. ElS-179 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Annex V2 H.4.1.4: The fire detection system will EP H.5.4: The Fire Detection System is designed to The commitment wording was provide audible and visual alarms in the main detect products of combustion or heat in designated areas standardized and relocated to control room. of the plant. The fire alarm communication systems and the SNC Standard Emergency subsystems are located at strategic points throughout the Plan. plant to warn personnel of a fire or other emergency conditions. Additional description of the fire system is provided in the FSAR. Annex V2 H.4.2: The radiation monitoring system EP H.5.2.1 Radiation Monitoring System (RMS) The commitment wording was is Radiation monitoring instruments are located at selected standardized and relocated to designed in accordance with ANSI N13.1-1969, areas within the plant to detect, measure, and record the SNC Standard Emergency Sampling Airborne Radioactive Materials radiation levels. The monitors are comprised of area, Plan. airborne and air particulate monitors.

Area monitors respond to gamma radiation .
Airborne monitors are capable of detecting and measuring radioactive gaseous effluent concentrations.
Air Particulate detectors capture and measure airborne particulate.

Emergency response procedures provide methods for determining relationships between monitor readings and releases, material available for release and extent of core damage. Annex V2 H.4.2: The radiation monitoring system EP H.5.2.1 Radiation Monitoring System (RMS) The commitment wording was is divided functionally into two subsystems: Radiation monitoring instruments are located at selected standardized and relocated to

Process, airborne, and effluent areas within the plant to detect, measure, and record the SNC Standard Emergency radiological monitoring and sampling radiation levels. The monitors are comprised of area, Plan.
Area radiation monitoring airborne and air particulate monitors.
Area monitors respond to gamma radiation .
Airborne monitors are capable of detecting and measuring radioactive gaseous effluent concentrations.
Air Particulate detectors capture and measure airborne particulate.

Emergency response procedures provide methods for determining relationships between monitor readings and releases, material available for release and extent of core damage. ElS-180 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Annex V2 H.4.2: Radiation monitoring data, EP H.5.2.1 Radiation Monitoring System (RMS) The commitment wording was including alarm status, are provided to operators Radiation monitoring instruments are located at selected standardized and relocated to via the plant control system (and the protection areas within the plant to detect, measure, and record the SNC Standard Emergency and safety monitoring system for Class 1E radiation levels. The monitors are comprised of area, Plan. monitors). The information is available in either airborne .and air particulate monitors. counts per minute (count rate), microCuries/cc

Area monitors respond to gamma radiation~

(activity concentration), or R/hr (radiation dose

Airborne monitors are capable of detecting and rate). measuring radioactive gaseous effluent concentrations.
Air Particulate detectors capture and measure airborne particulate.

Emergency response procedures provide methods for determining relationships between monitor readings and releases, material available for release and extent of core damage. Annex V2 H.4.2:. Safety-related channels are EP H.5.2.1 Radiation Monitoring System (RMS) The commitment wording was environmentally qualified and are powered from Radiation monitoring instruments are located at selected standardized and relocated to the Class 1E DC and uninterruptible power areas within the plant to detect, measure, and record the SNC Standard Emergency supply system. Nonsafety-related channels are radiation levels. The monitors are comprised of area, Plan. powered from the non-Class 1E DC and airborne and air particulate monitors. uninterruptible power supply (UPS) system.

Area monitors respond to gamma radiation .
Airborne monitors are capable of detecting and measuring radioactive gaseous effluent concentrations.
Air Particulate detectors capture and measure airborne particulate.

Emergency response procedures provide methods for determining relationships between monitor readings and releases, material a'1ailable for release and extent of core damage. ElS-181 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Annex V2 H.4.3: The processing monitoring EP H.5.2.2: The process sampling system consists of the The commitment wording was function is performed by equipment which is part normal sampling system and additional sampling panels standardized and relocated to of the Protection and Safety Monitoring System located throughout the plant. Pre-designated monitoring the SNC Standard Emergency (PMS), Special Monitoring System (SMS), Plant and sampling points are listed in site procedures. Plan. Control System (PLS), Diverse Actuation System Sampling systems are installed or can be modified to (DAS), Operation and Control Centers System permit reactor coolant and containment atmosphere (OCS), Data . sampling even under severe accident conditions. It is Display and Processing System (DDS), and the capable of providing information relative to post-accident lncore Instrumentation System (llS). A plant conditions to allow operator actions to be taken to description of each of these systems is provided mitigate and control the course of an accident. Various in UFSAR Section 7.1. chemical analyses and radiological measurements on these samples can be performed, including the determination of radionuclide concentrations. Annex V2 H.4.4 Emergency Response Data F.1.4.8 Emergency Response Data System (ERDS) The commitment wording was System (ERDS) ERDS is a dedicated network and is a direct near real- standardized and relocated to time electronic data link between the plant's on-site the SNC Standard Emergency computer system and the NRC Operations Center that Plan. provides for the automated transmission of a limited data set of selected parameters. The ERDS supplements the existing voice transmission over the FTS-ENS. Annex V2 H.4.5 Safety Parameter Display SECTION I: ACCIDENT ASSESSMENT The commitment wording was System EP 1.1 Systems and Parameters Monitored standardized and relocated to The instrumentation and equipment capabilities available the SNC Standard Emergency for emergency facilities are described in Section H. For Plan. Vogtle Unit 3 and Unit 3 the Safety Parameter Display System (SPDS) is integrated into the overall human interface design such that the SPDS parameters are available to operators via workstation visual display units. ElS-182 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Annex V2 H.4.6 Post Accident Sampling SECTION I: ACCIDENT ASSESSMENT The commitment wording was EP 1.2 Continuing and Post Accident Assessment standardized and relocated to The resources available to provide initial and continuing the SNC Standard Emergency information for accident assessment throughout the Plan. course of an event include plant parameter display systems, liquid and gaseous sampling system, area and process radiation monitoring systems, and Accident Radiation Monitoring Systems. Descriptions of these systems are given in Section H. Details as to how post-accident sampling will be performed are in the plant-specific procedures. Annex V2, Appendix 1, Table A2-1 FSAR No equivalent listing of FSAR Postulated Events in Plan or The Table of FSAR postulated Postulated Events: All Annexes. events is not required in the Emergency Plan. These events are a design basis concern and

not applicable to implementation of the Emergency Plan on an ongoing basis.

Appendix 2: All LOA descriptions were added to the Plan/Annex per the requirements of Appendix E,

                                                                                               -    eliminating the need for a separate appendix with a list of LOA's.

Appendix3 ElS-183 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Appendix 3: Initial alerting will be made primarily EP B.1.1 The Emergency Director's non-delegable duties The commitment wording was by both tone-alert radios and a system of fixed include: standardized and relocated to sirens.

Event classification in accordance with the the SNC Standard Emergency Appendix 3: In the event of a serious emergency emergency classification system. Plan.

at VEGP, the primary means for alerting and

Perform the duties and responsibilities of providing initial instructions to the public will be Protective Action Recommendation (PAR) by a combination of tone-alert radios and a determination.

system of fixed sirens.

Notifications of offsite agencies and approval of Appendix 3: The siren system consists of a state, local, and NRC notifications.

network of 47 rotating electronic sirens mounted on poles strategically located throughout the

Authorization of emergency exposures in excess of federal limits.

populated area of the plume exposure EPZ.

Issuance of potassium iodide (Kl) to plant employees as a thyroid blocking agent.
Request Federal assistance as needed .

Appendix 3: Based upon Appendix 3 of NUREG- Annex 4.2 Alert and Notification System (ANS) (SEP E.2.5) The commitment wording was 0654 and FEMA REP-10, the system is designed Within the 10 mile Exposure Emergency Planning Zone (EPZ), standardized and relocated to to provide a minimum of 60 dBC coverage to all there exist provisions for alerting and providing notification to the the Site Annex. residences within the plume exposure EPZ, plus public. The state and/or local authorities are responsible for activation of this system. adequate coverage for people outdoors in all Two totally independent public alerting systems are installed for other use in the VEGP EPZ: areas of the plume exposure EPZ open to the

Network of fixed sirens and EAS, public.
NOAA (National Oceanic and Atmospheric Administration) weather warning radio system.

Offsite agencies will activate both independent systems in the event of a plant condition requiring public awareness. Following any public alert, commercial radio and television stations, as well as NOAA weather radio (NWR) will be used to provide notification and follow-up emergency information to the population within the EPZ. ElS-184 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Appendix 3: Within the plume exposure pathway Annex 4.2 Within the 10 mile Exposure Emergency The commitment wording was EPZ, the prompt alerting and notification system Planning Zone (EPZ), there exist provisions for alerting standardized and relocated to will provide an alerting signal and notification by and providing notification to the public. The state and/or the Site Annex. NOAA radio and an alerting signal by fixed local authorities are responsible for activation of this sirens. system. Two totally independent public alerting systems are installed for use in the VEGP EPZ:

Network of fixed sirens and EAS,
NOAA (National Oceanic and Atmospheric Administration) weather warning radio system.

Offsite agencies will activate both independent systems in the event of a plant condition requiring public awareness. Following any public alert, commercial radio and television stations, as well as NOAA weather radio (NWR) will be used to provide notification and follow-up emergency information to the population within the EPZ. Appendix 3: Assurance of continued notification EP E.2.5.2 The testing and maintenance of the public The commitment wording was capability will be verified on a statistical basis. alerting sirens are the responsibility of SNC. The standardized and relocated to maintenance program will consist of both periodic routine the SNC Standard Emergency checks and, as required, corrective maintenance. Plan. The periodic routine maintenance and test program will be based on the manufacturers' recommendations and experience gained with the installation. ElS-185 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Appendix 3: Southern Nuclear Operating EP E.2.5: Prompt alerting and notification of the public within the The commitment wording was Company, and/or the State and local plume exposure pathway EPZ is the obligation of State and local standardized and relocated to governments will survey a sample of the government or other responsible authority. The responsibility the SNC Standard Emergency residents in the plume exposure pathway EPZ. that means exist for this purpose rests with Southern Nuclear Plan and Site Annex. Operating Company. An overview of these means excluding the Appendix 3: The survey results shall be used to Savannah River Site is listed in the site specific Annex of this assess the public's ability to hear the alerting Plan. signal and their awareness of the meaning of the Initial notification of the public will occur in a manner consistent prompt notification message, as well as the with assuring the public health and safety. The design objective availability of information on what to do in an for the system is to meet the acceptance criteria which are emergency. provided in a subsequent section of the FEMA approved design report for each SNC operated plant. The design objective does not constitute a guarantee that prompt notification can be provided for everyone with 100% assurance, or that the system when tested under actual field conditions will meet the design objectives. Annex 4.2 Within the 10 mile Exposure Emergency Planning Zone (EPZ), there exist provisions for alerting and providing notification to the public. The state and/or local authorities are responsible for activation of this system. Two totally independent public alerting systems are installed for use in the VEGP EPZ:

Network of fixed sirens and EAS,
NOAA (National Oceanic and Atmospheric Administration) weather warning radio system.

Offsite agencies will activate both independent systems in the event of a plant condition requiring public awareness. Following any public alert, commercial radio and television stations, as well as NOAA weather radio (NWR) will be used to provide notification and follow-up emergency information to the population within the EPZ. Appendix 3: In response to the findings of these EP E.2.5.2 The testing and maintenance of the public The commitment wording was surveys, appropriate corrective measures will be alerting sirens are the responsibility of SNC. The standardized and relocated to taken to provide reasonable assurance that the maintenance program will consist of both periodic routine the SNC Standard Emergency required coverage is maintained. checks and, as required, corrective maintenance. Plan and Site Annex. The periodic routine maintenance and test program will be based on the manufacturers' recommendations and experience gained with the installation. ElS-186 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Appendix 3: The communications system EP F.1.2 SNC operated plants maintain the capability to The commitment wording was between the plant and the responsible authorities make initial notifications to the designated offsite agencies standardized and relocated to (Federal, State and local) features the following 24-hours per day. Offsite notifications can be made to the SNC Standard Emergency capabilities: State and county warning points and Emergency Plan.

a. Twenty-four seven coverage at VEGP and at Operations Centers from the Control Room, Technical the primary points to receive and act upon Support Center, and Emergency Operations Facility via notification. the Emergency Notification Network (ENN).

c. VEGP assumes primary responsibility for net control since effectively all of the emergency information originates at VEGP.

Appendix 3: Southern Nuclear Operating Annex 4.2 Within the 10 mile Exposure Emergency The commitment wording was Company in conjunction with Georgia Power Planning Zone (EPZ), there exist provisions for alerting standardized and relocated to Company provides NOAA radio receivers for all and providing notification to the public. The state and/or the Site Annex. known establishments (residence, businesses, local authorities are responsible for activation of this schools, etc.) within the plume exposure pathway system. EPZ who choose to accept them. Two totally independent public alerting systems are installed for use in the VEGP EPZ:

Network of fixed sirens and EAS,
NOAA (National Oceanic and Atmospheric Administration) weather warning radio system.

Offsite agencies will activate both independent systems in the event of a plant condition requiring public awareness. Following any public alert, commercial radio and television stations, as well as NOAA weather radio (NWR) will be used to provide notification and follow-up emergency information to the population within the EPZ. ElS-187 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Appendix 3: During the distribution to those Annex 4.2 Within the 10 mile Exposure Emergency The commitment wording was accepting the radios, a brochure is handed out. Planning Zone (EPZ), there exist provisions for alerting standardized and relocated to and providing notification to the public. The state and/or the SNC Standard Emergency local authorities are responsible for activation of this Plan and Site Annex. system. Two totally independent public alerting systems are installed for use in the VEGP EPZ:

Network of fixed sirens and EAS,
NOAA (National Oceanic and Atmospheric Administration) weather warning radio system.

Offsite agencies will activate both independent systems in the event of a plant condition requiring public awareness. Following any public alert, commercial radio and television stations, as well as NOAA weather radio (NWR) will be used to provide notification and follow-up emergency information to the population within the EPZ. Appendix 3: That brochure will be redistributed Annex 4.2 Within the 10 mile Exposure Emergency The commitment wording was on an annual basis to NOAA recipients. Planning Zone (EPZ), there exist provisions for alerting standardized and relocated to and providing notification to the public. The state and/or the Site Annex. local authorities are responsible for activation of this system. Two totally independent public alerting systems are installed for use in the VEGP EPZ:

Network of fixed sirens and EAS,
NOAA (National Oceanic and Atmospheric Administration) weather warning radio system.

Offsite agencies will activate both independent systems in the event of a plant condition requiring public awareness. Following any public alert, commercial radio and television stations, as well as NOAA weather radio (NWR) will be used to provide notification and follow-up emergency information to the population within the EPZ. ElS-188 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Appendix 3: This brochure includes the following Annex 4.2 Within the 10 mile Exposure Emergency The commitment wording was information: Planning Zone (EPZ), there exist provisions for alerting standardized and relocated to

What is NOAA. and providing notification to the public. The state and/or the Site Annex.
Why NOAA radios are provided . local authorities are responsible for activation of this
Information they will receive on the NOAA system.

radio Two totally independent public alerting systems are

When the alert system will be activated . installed for use in the VEGP EPZ:
Who makes NOAA broadcasts
Network of fixed sirens and EAS,
Where to place the rad.io
NOAA (National Oceanic and Atmospheric Administratior;i) weather warning radio system.
Backup battery power for power failures . Offsite agencies will activate .both independent systems in
What to do if the NOAA radio doesn't work . the event of a plant condition requiring public awareness.
How to replace radio batteries . Following any public alert, commercial radio and television stations, as well as NOAA weather radio (NWR) will be used to provide notification and follow-up emergency information to the population within the EPZ.

Appendix 3: Public information will be distributed EP G.8 The goal of the public information program is to The commitment wording was on an annual basis to the NOAA radio recipients. acquaint the general public with the emergency plans for standardized and relocated to the operation of APC/GPG nuclear plants, as appropriate, the SNC Standard Emergency and actions they should in the event of a plant emergency. Plan. Emergency Information is disseminated each calendar year for residents and transients in the plume exposure pathway Emergency Planning Zone. Appendix 3: SNC will replace any defective Annex 4.2 The system maintenance requirements for the The commitment wording was radios upon request or discovery that the radios Tone Alert Radio System are contained in the FEMA standardized and relocated to are defective. approved System Design Report. Specifically, Vogtle the Site Annex .

                                                  . maintains a database of those assigned tone alert radios and performs an annual telephone survey documenting the adequacy of distribution.

ElS-189 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Appendix 3: SNC will also annually distribute Annex 4.2 The system maintenance requirements for the The commitment wording was replacement batteries to all recipients of tone Tone Alert Radio System are contained in the FEMA standardized and relocated to alert radios. approved System Design Report. Specifically, Vogtle the Site Annex. maintains a database of those assigned tone alert radios and performs an annual telephone survey documenting the adequacy of distribution. Appendix 3: SNC will maintain a register of all Annex 4.2 The system maintenance requirements for the The commitment wording was radio recipients. Tone Alert Radio System are contained in the FEMA standardized and relocated to approved System Design Report. Specifically, Vogtle the Site Annex. maintains a database of those assigned tone alert radios and performs an annual telephone survey documenting the adequacy of distribution. Appendix 3: The Emergency Preparedness staff Annex 4.2 The system maintenance requirements for the The commitment wording was distributes tone alert radios to any new residents Tone Alert Radio System are contained in the FEMA standardized and relocated to and updates the register of radio recipients approved System Design Report. Specifically, Vogtle the Site Annex. periodically. maintains a database of those assigned tone alert radios and performs an annual telephone survey documenting the adequacy of distribution. Appendix 3: The Emergency Preparedness staff Annex 4.2 The Vogtle Electric Generating Plant (VEGP) The commitment wording was also determines whether there are any has developed a Public Alert and Notification system standardized and relocated to permanent Burke County plume EPZ residents designed for coverage of the population within the EPZ. the Site Annex. without electricity. A list of these residents is This is accomplished utilizing a combination of fixed sirens maintained. and tone-alert radios. Sirens installed by VEGP have been sited according to FEMA-REP-10 criterion to ensure the required coverage. Siren Locations are shown in Figure 4.2.A, Fixed Siren Location Map. Provisions for transient population notification are also included in State and County plans. ElS-190 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Appendix 3: A survey of the Burke County portion Annex 4.2 Alert and Notification System (ANS) (SEP The commitment wording was of the plume EPZ will be made annually by the E.2.5) standardized and relocated to Emergency Preparedness staff to assure that the The system maintenance requirements for the Tone Alert the Site Annex. list of any such residents is current. Radio System are contained in the FEMA approved System Design Report. Specifically, Vogtle maintains a database of those assigned tone alert radios and performs an annual telephone survey documenting the adequacy of distribution. In the event of an emergency declaration at the VEGP, DOE-Savannah River Site has agreed to provide prompt notification of all persons on the SRS within VEGP's plume exposure pathway EPZ. The Alert and Notification System (ANS) description is provided in the FEMA approved Alert and Notification System Design Report located in the SNC document management system. Appendix 3: Rather, annual surveys of the entire Annex 4.2 The system maintenance requirements for the The commitment wording was South Carolina portion of the plume EPZ will be Tone Alert Radio System are contained in the FEMA standardized and relocated to made directly by the Emergency Preparedness approved System Design Report. Specifically, Vogtle the Site Annex. Staff. maintains a database of those assigned tone alert radios and performs an annual telephone survey documenting the adequacy of distribution. In the event of an emergency declaration at the VEGP, DOE-Savannah River Site has agreed to provide prompt notification of all persons on the SRS within VEG P's plume exposure pathway EPZ. The Alert and Notification System (ANS) description is provided in the FEMA approved Alert and Notification System Design Report located in the SNC document management system. ElS-191 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Appendix 3: The effectiveness of the tone alert Annex 4.2 The system maintenance requirements for the The commitment wording was radios will be tested and evaluated at least once Tone Alert Radio System are contained in the FEMA standardized and relocated to a year in accordance with implementing approved System Design Report. Specifically, Vogtle the Site Annex. procedures. maintains a database of those assigned tone alert radios and performs an annual telephone survey documenting the adequacy of distribution. Appendix 3: The testing and maintenance of the EP E.2.5.2 Annually the system will be activated in the The commitment wording was public alerting sirens in the VEGP EPZ are the normal mode. Advance notice of the test will be provided standardized and relocated to responsibility of VEGP. to the public. Activation of sirens will be verified by the the SNC Standard Emergency system. Reports of siren failures will be investigated and Plan. repaired by the respective SNC site. Unsatisfactory conditions detected by any means will be promptly repaired. State and local emergency management Plans and procedures detail the Prompt Notification System (PNS) activation process in addition to the information provided in the Emergency PlanActivation of the alert and notification system (ANS) is discussed in the offsite agencies specific emergency response plans. Appendix 3: The maintenance program will EP E.2.5.2 Annually the system will be activated in the The commitment wording was consist of both periodic routine checks and, as normal mode. Advance notice of the test will be provided standardized and relocated to required, corrective maintenance. to the public. Activation of sirens will be verified by the the SNC Standard Emergency system. Reports of siren failures will be investigated and Plan. repaired by the respective SNC site. Unsatisfactory conditions detected by any means will be promptly repaired. State and local emergency management Plans and procedures detail the Prompt Notification System (PNS) activation process in addition to the information provided in the Emergency PlanActivation of the alert and notification system (ANS) is discussed in the offsite agencies specific emergency response plans. ElS-192 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Appendix 3: This program will be under the EP E.2.5.2 Annually the system will be activated in the The commitment wording was direction of the VEGP emergency preparedness normal mode. Advance notice of the test will be provided standardized and relocated to coordinator. to the public. Activation of sirens will be verified by the the SNC Standard Emergency system. Reports of siren failures will be investigated and Plan. repaired by the respective SNC site. Unsatisfactory conditions detected by any means will be promptly repaired. State and local emergency management Plans and procedures detail the Prompt Notification System (PNS) activation process in addition to the information provided in the Emergency PlanActivation of the alert and notification system (ANS) is discussed in the offsite agencies specific emergency response plans. Appendix 3: The periodic routine maintenance EP E.2.5.2 Annually the system will be activated in the The commitment wording was program will be based on the manufacturers' normal mode. Advance notice of the test will be provided standardized and relocated to recommendations and experience gained with to the public. Activation of sirens will be verified by the the SNC Standard Emergency the installation. system. Reports of siren failures will be investigated and Plan. repaired by the respective SNC site. Unsatisfactory conditions detected by any means will be promptly repaired. State and local emergency management Plans and procedures detail the Prompt Notification System (PNS) activation process in addition to the information provided in the Emergency PlanActivation of the alert and notification system (ANS) is discussed in the offsite agencies specific emergency response plans. ElS-193 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Appendix 3: It will consist of quarterly inspections EP E.2.5.2 Annually the system will be activated in the The commitment wording was to verify the proper physical condition of each normal mode. Advance notice of the test will be provided standardized and relocated to siren location and checks to verify the proper to the public. Activation of sirens will be verified by the the SNC Standard Emergency operation of each location utilizing the built-in test system. Reports of siren failures will be investigated and Plan. and monitoring features of this system. repaired by the respective SNC site. Unsatisfactory conditions detected by any means will be promptly repaired. State and local emergency management Plans and procedures detail the Prompt Notification System (PNS) activation process in addition to the information provided in the Emergency PlanActivation of the alert and notification system (ANS) is discussed in the offsite agencies specific emergency response plans. Appendix 3: The periodic test program will EP E.2.5.2 Annually the system will be activated in the The commitment wording was consist of a weekly silent test, from the county normal mode. Advance notice of the test will be provided standardized and relocated to activation points, and an annual full scale to the public. Activation of sirens will be verified by the the SNC Standard Emergency activation of the system. system. Reports of siren failures will be investigated and Plan. repaired by the respective SNC site. Unsatisfactory conditions detected by any means will be promptly repaired. State and local emergency management Plans and procedures detail the Prompt Notification System (PNS) activation process in addition to the information provided in the Emergency PlanActivation of the alert and notification system (ANS) is discussed in the offsite agencies specific emergency response plans. ElS-194 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Appendix 3: The weekly silent test will consist of EP E.2.5.2 Annually the system will be activated in the The commitment wording was activation of the siren from the County EOC. normal mode. Advance notice of the test will be provided standardized and relocated to to the public. Activation of sirens will be verified by the the SNC Standard Emergency system. Reports of siren failures will be investigated and Plan. repaired by the respective SNC site. Unsatisfactory conditions detected by any means will be promptly repaired. State and local emergency management Plans and procedures detail the Prompt Notification System (PNS) activation process in addition to the information provided in the Emergency PlanActivation of the alert and notification system (ANS) is discussed in the offsite agencies specific emergency response plans. Appendix 3: Once each year the system will be EP E.2.5.2 Annually the system will be activated in the The commitment wording was activated from the associated county EOC in the normal mode. Advance notice of the test will be provided standardized and relocated to normal mode. to the public. Activation of sirens will be verified by the the SNC Standard Emergency system. Reports of siren failures will be investigated and Plan. repaired by the respective SNC site. Unsatisfactory conditions detected by any means will be promptly repaired. State and local emergency management Plans and procedures detail the Prompt Notification System (PNS) activation process in addition to the information provided in the Emergency PlanActivation of the alert and notification system (ANS) is discussed in the offsite agencies specific emergency response plans. ElS-195 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Appendix 3: Advance notice of the test will be EP E.2.5.2 Annually the system will be activated in the The commitment wording was provided to the public. normal mode. Advance notice of the test will be provided standardized and relocated to to the public. Activation of sirens will be verified by the the SNC Standard Emergency system. Reports of siren failures will be investigated and Plan. repaired by the respective SNC site.Unsatisfactory conditions detected by any means will be promptly repaired. State and local emergency management Plans and procedures detail the Prompt Notification System (PNS) activation process in addition to the information provided in the Emergency PlanActivation of the alert and notification system (ANS) is discussed in the offsite agencies specific emergency response plans. Appendix 3: Activation of each siren will be EP E.2.5.2 Annually the system will be activated in the The commitment wording was verified normal mode. Advance notice of the test will be provided standardized and relocated to by the WSMRFC. to the public. Activation of sirens will be verified by the the SNC Standard Emergency system. Reports of siren failures will be investigated and Plan. repaired by the respective SNC site. Unsatisfactory conditions detected by any means will be promptly repaired. State and local emergency management Plans and procedures detail the Prompt Notification System (PNS) activation process in addition to the information provided in the Emergency PlanActivation of the alert and notification system (ANS) is discussed in the offsite agencies specific emergency response plans. ElS-196 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Appendix 3: Reports of siren failures or EP E.2.5.2 Annually the system will be activated in the The commitment wording was inadequate coverage will be investigated by normal mode. Advance notice of the test will be provided standardized and relocated to VEGP. to the public. Activation of sirens will be verified by the the SNC Standard Emergency system. Reports of siren failures will be investigated and Plan. repaired by the respective SNC site. Unsatisfactory conditions detected by any means will be promptly repaired. State and local emergency management Plans and procedures detail the Prompt Notification System (PNS) activation process in addition to the information provided in the Emergency PlanActivation of the alert and notification system (ANS) is discussed in the offsite agencies specific emergency response plans. Appendix 3: Unsatisfactory conditions detected EP E.2.5.2 Annually the system will be activated in the The commitment wording was by any means will be promptly repaired by normal mode. Advance notice of the test will be provided standardized and relocated to Southern Company Services maintenance or to the public. Activation of sirens will be verified by the the SNC Standard Emergency contract personnel under the direction of the system. Reports of siren failures will be investigated and Plan. VEGP emergency preparedness coordinator. repaired by the respective SNC site. Unsatisfactory conditions detected by any means will be promptly repaired. State and local emergency management Plans and procedures detail the Prompt Notification System (PNS) activation process in addition to the information provided in the Emergency PlanActivation of the alert and notification system (ANS) is discussed in the offsite agencies specific emergency response plans. ElS-197 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Appendix 4: All The specific list of Emergency Equipment was deleted from the SNC Standard Emergency Plan and Annex. The Plan/Annex commit to the functions the equipment is needed to support. Specific equipment changes on a regular basis. The lack of needed equipment would affect the ability to perform the function. The specific equipment needed to adequately perform the function is not appropriate at Plan level. Appendix 5: Memorandum of Agreement with EP 1.7 Department of Energy (DOE) - Savannah River The commitment wording was Department of Energy - Savannah River Site (SRS) (SEP A.2.5) standardized and description of The DOE-Savannah River Site (SRS) will provide the expected response included as necessary response within the SRS reservation in required by 10 CFR 50 Appendix accordance with the SRS Emergency Plan. The DOE will E and relocated to the Site exercise overall responsibility, jurisdiction, and authority Annex. for conducting response operations on the Savannah River Site to protect the health and safety of SRS personnel. DOE will provide for emergency notification and, as needed, evacuation, monitoring, decontamination, and immediate lifesaving medical treatment of non SRS personnel on the Savannah River Site. DOE will also provide access control for SRS areas. Appendix 6: All EP J.6 Evacuation Time Estimates (ETE)An independent The commitment wording )Nas ETE report has been performed for SNC operated nuclear standardized and relocated to power plants, which provides estimates of the time the SNC Standard Emergency required to evacuate resident and transient populations Plan. surrounding the plant for various times of the year under favorable and adverse conditions. ETEs for evacuation of the plume exposure EPZ surrounding SNC operated nuclear power plants are summarized in the site-specific Annex and detailed in the ETE report. Annex Appendix A ElS-198 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Appendix 7: All The Emergency Operations Facility has been Removed specific statement established consistent with NUREG 0696 referencing NUREG-0696 as guidelines SER #SECY-04-0236 addresses the establishment and NRC approval of the EOF. Appendix 7 A.3: Upon notification of an ALERT EP H.2.1 Emergency Operations Facility The commitment wording was or higher classification or as directed by the ED, The EOF is procedurally required to be activated within 75 standardized and relocated to the EOF will be activated as described in minutes following the declaration of an Alert or higher the SNC Standard Emergency emergency implementing procedures. classification Plan. Appendix 7 A.3: Offsite support personnel and EP 8.3.1.3 EOF Support Coordinator The commitment wording was equipment will be dispatched to the site The Support Coordinator reports to the EOF Manager. standardized and relocated to Operations Support Center (OSC) or Technical The duties and responsibilities of the Support Coordinator the SNC Standard Emergency Support Center (TSC) upon request from the in the EOF include providing oversight of the News Writer, Plan. specific site Emergency Director. providing assistance to the Support Coordinator in the TSC for ordering equipment and materials needed and logistics arrangements for support personnel called in to assist in the emergency, including communications hardware, transportation, food, and lodging. Appendix 7 A.3: The corporate emergency The commitment wording was response organization will provide offsite standardized and relocated to emergency response support and resources to the SNC Standard Emergency SNC sites on a twenty-four seven basis until the Plan. emergency has been terminated. The SNC Standard Emergency Plan integrates the Corporate response as part of the trained and qualified ERO. A separate statement is not necessary. Appendix 7 A.3: The EOF will be activated for an EP H.2.1 Emergency Operations Facility The commitment wording was ALERT, SITE AREA or GENERAL emergency The EOF is procedurally required to be activated within 75 standardized and relocated to classifications. minutes following the declaration of an Alert or higher the SNC Standard Emergency classification. Plan. ElS-199 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Appendix 7 A.3: This facility (EOF) will be EP H.4: Although the response time will vary due to The commitment wording was operational within about an hour of the initial factors such as weather and traffic conditions, a goal of 75 standardized and relocated to notification. minutes for minimum staffing, following the declaration of the SNC Standard Emergency an Alert or higher emergency classification, has been Plan.The change in activation established for ERO personnel responding to plant times will be justified separately emergency facilities including the TSC, OSC and EOF. in the Technical Analysis Section of this License Amendment Request. Appendix 7 A.3: SN C's goal is to begin The SNC Standard Emergency notification of all required on-call Emergency Plan moves to a commitment to Response Organization (ERO) personnel as activate facilities within a soon as practicable, within 15 minutes, following timeframe of 75 minutes. the declaration of an Alert emergency or higher Notification of the responding emergency classification at any SNC site. ERO is a step in the overall process and not needed as a separate commitment.The change in activation times will be justified separately in the Technical Analysis Section of this License Amendment Request. Appendix 7 A.3: Minimum EOF staff for facility EP Figure 8.2.D The commitment wording was activation will include the EOF Manager, the standardized and relocated to Dose Assessment Supervisor, the Dose Analyst, the SNC Standard Emergency the Field Team Coordinator, the ENN Plan. Communicator, and the Licensing Support Coordinator. Appendix 7 A.3: Access control for the EOF is EP H.2.1: Access control for the EOF is established The commitment wording was established through the use of electronic card through the use of electronic card readers. standardized and relocated to readers. the SNC Standard Emergency Plan. ElS-200 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Appendix 7 A.3: The emergency director is EP 8.1.1 The ED has the responsibility and authority to The commitment wording was responsible for the management of the immediately and unilaterally initiate emergency actions, standardized and relocated to emergency response. Specific duties and including providing notification of Protective Action (PAR) the SNC Standard Emergency responsibilities are provided in the site specific Recommendations to State and Local government Plan. Emergency Plan and Emergency Plan organizations responsible for implementing off site Implementing Procedures. emergency measures. The ED, at their discretion or when procedurally required, activates the ERO. The Emergency Director's non-delegable duties include:

Event classification in accordance with the emergency classification system.
Perform the duties and responsibilities of Protective Action Recommendation (PAR) determination.
Notifications of offsite agencies and approval of state, local, and NRC notifications.
Authorization of emergency exposures in excess of federal limits.
Issuance of potassium iodide (Kl) to plant employees as a thyroid blocking agent.
Request Federal assistance as needed .

Appendix 7 A.3: ... the EOF can be quickly EP H.2.1: Access to the EOF is controlled through the use The commitment wording was accessed and made operational within about an of electronic card readers. standardized and relocated to hour of the initial notification and is safe-guarded the SNC Standard Emergency against unauthorized personnel. Plan. Appendix 7 A.3: Any outside doors that do not EP H.2.1: Access control for the EOF is established The commitment wording was have security guards are accessible only by SNC through the use of electronic card readers. standardized and relocated to ID badges. the SNC Standard Emergency Plan. Appendix 7 A.3: The building itself (EOF building) EP H.2.1: Access control for the EOF is established The commitment wording was has posted security guards and video through the use of electronic card readers. standardized and relocated to surveillance cameras. the SNC Standard Emergency Plan. Appendix 7 A.3: If an event were to occur during EP H.2.1: Access control for the EOF is established The commitment wording was off-normal hours, a guard will be posted at the through the use of electronic card readers. standardized and relocated to main entrance to Building 40 to allow access to the SNC Standard Emergency offsite agency or other responders without pre- Plan. designated ID access. ElS-201 5 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Appendix 7 B: The EOF Organization is EP Figure 8.2.D EOF Organization Chart The commitment wording was displayed in Figure A7-1 and typical duty EP Table 4 Listing of typical duty assignments. standardized and relocated to assignments are shown on Table A7-1. the SNC Standard Emergency Plan. Appendix 7 B: Each of the following EOF EP 8.3.1.2 EOF Manager The commitment wording was positions has site-specific personnel designated: The EOF Manager reports to the EOF ED and is standardized and relocated to

EOF Manager responsible for managing and directing EOF activities, the SNC Standard Emergency
EOF Technical Supervisor developing recovery plans, procure outside services and Plan.

equipment, as necessary, coordination with offsite agencies and approving news releases. EP 8.3.1.19 EOF Technical Supervisor The Technical Supervisor reports to the EOF Manager and is responsible for providing engineering expertise during an emergency event at an SNC operated plant. This may include interacting with non-SNC response groups, developing mitigation and recovery plans and coordinating work performed by SNC and non-SNC engineering groups. Appendix 7 B: In order to augment additional EP 8.2: A sufficient number of personnel are qualified to The commitment wording was staff that may be needed in the unlikely event of ensure that positions listed in this section can be staffed standardized and relocated to a multi-site accident, SNC will re-activate its ERO on a 24 hour/day basis for an extended event. Figures the SNC Standard Emergency notification system. B.2.B through B.2.E illustrate the overall augmented Plan. emergency response organization. Appendix 7 B: When the EOF is activated, all EP 8.2: A sufficient number of personnel are qualified to The commitment wording was EOF staff pagers are activated, and all EOF ensure that positions listed in this section can be staffed standardized and relocated to personnel are expected to report to the EOF. on a 24 hour/day basis for an extended event. Figures the SNC Standard Emergency B.2.B through B.2.E illustrate the overall augmented Plan. emergency response organization. Appendix 7 B.1: The designated individual will be EP 8.3.1.2 EOF Manager The commitment wording was assigned according to a predetermined rotation The EOF Manager reports to the EOF ED and is standardized and relocated to schedule and will typically have either previous responsible for managing and directing EOF activities, the SNC Standard Emergency plant specific SRO background or long term developing recovery plans, procure outside services and Plan. supervisory/management experience. equipment, as necessary, coordination with offsite agencies and approving news releases. ElS-202 5 to NL-1}}

NL-16-0169, Southern Nuclear Operating Company Response to Third Request for Additional Information Regarding Standard Emergency Plan: Enclosure 11, Vogtle Units 1 and 2 Standard Emergency Plan Annex (Marked-Up Pages and Clean Copy)

Text

Response

Reference:

Response

Introduction:

Introduction:

Response

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