Text

Enclosure 6: Farley Justification Matrix
	ML16060A333
Person / Time
Site:	Hatch, Vogtle, Farley
Issue date:	02/17/2016
From:	; Southern Nuclear Operating Co
To:	; Office of New Reactors, Office of Nuclear Reactor Regulation
Shared Package
ML16060A283	List: ML16060A328; ML16060A329; ML16060A330; ML16060A332; ML16060A333; ML16060A334; ML16060A335; ML16060A336; NL-16-0169, Enclosure 20: SNC Standard Emergency Plan LAR - Updated Clean Version of Enclosures 1-19; NL-16-0169, Enclosure 6: Farley Justification Matrix; NL-16-0169, Enclosure 8: Hatch Standard Emergency Plan Annex; NL-16-0169, Enclosures 10, 11, 12, 13 & 14: Vogtle (Units 1 & 2) Staffing - Detailed Description and Technical Evaluation, Standard Emergency Plan Annex, Justification Matrix, Staffing-Detailed Description and Technical Evaluation and Standard Emerge; NL-16-0169, Enclosures 13, 14, 15, 16, 17, 18, 19 Re Vogtle Units 3 & 4 Detailed Description & Technical Evaluation, Standard Emergency Plan Annex, Justification Matrix, Evaluation of Proposed Changes, Revision to Units 3 & 4 COL Appendix C & Off-Sit; NL-16-0169, Enclosures 15, 16, 17, 18 & 19: Vogtle (Units 3 & 4) - Justification Matrix, Evaluation of Proposed Changes LAR for Revision for Emergency Planning ITAAC, Rev to Units 3 & 4 COL Appendix C - Proposed Changes, and Off-Site Response Organiz; NL-16-0169, Enclosures 2 to 12: SNC Standard Emergency Plan (Marked-Up Pages), Farley Staffing - Detailed Description and Technical Evaluation (Marked-up Pages),Standard Emergency Plan Annex (Marked-up Pages), Farley Justification Matrix..; NL-16-0169, Southern Nuclear Operating Company Response to First Request for Additional Information Re Standard Emergency Plan. Attachment 1: SNC Response to NRC RAI-1 Fleet Standard Emergency Plan and Enclosure 1: Evaluation of Proposed Changes Encl;
References
	NL-16-0169
	Download: ML16060A333 (222)
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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 6 Farley Justification Matrix FARLEY NUCLEAR POWER PLANT JUSTIFICATION MATRIX Purpose The purpose of this attachment is to identify the commitments in the current Farley Nuclear Power Plant Emergency Plan Revision 64, identify the equivalent or modified commitment in the integrated Fleet Emergency Plan and Farley Site Annex, and justify on a commitment-by-commitment basis the proposed License Amendment.

Enclosure 6 to NL-1 6-0169 Farley Justification Matrix CHANGE MATRIX Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description The purpose of the Joseph M. Farley EP INTRODUCTION The wording was standardized and relocated to Nuclear Plant (FNP) Emergency Purpose the SNC Standard Emergency Plan.Plan is to protect the health and The Southern Nuclear Operating Company's safety of the general public, persons (SNC) Emergency Plan provides the means to temporarily visiting or assigned to the protect the health and safety of the general plant, and plant employees in public, persons temporarily visiting or assigned accordance with the requirements to nuclear power plants operated by SNO, and set forth in Appendix E, "Emergency plant employees.

SNO operates the Hatch Plans for Production and Utilization .Nuclear Plant (HNP), Farley Nuclear Plant Facilities", of 100FR50, "Licensing of (FNP), and Vogtle Electric Generating Plant Production and Utilization Facilities". (VEGP).Backcqrou nd The SNC Emergency Plan was developed with the guidance of NUREG-0654, FEMA-REP-1, Revision 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants." The SNC Emergency Plan meets the emergency planning standards of 10 CFR 50.47(b), the requirements of Appendix E, and the intent of 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.E6-2 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

==

Introduction:==

Detailed procedures EP

Introduction:

Detailed procedures The wording was standardized and relocated to concerning the implementation of the concerning the implementation of the EP are in the SNC Standard Emergency Plan.Emergency Plan are not included the Emergency Plan Implementing Procedures here but are included in the (EPIPs). SNC has overall responsibility for Additional detail has been added regarding Emergency Plan Implementing maintaining a state of readiness to implement governmental relationships.

Procedures.

emergency plans for the protection of plant Summary: Southern Nuclear personnel, the general public, and property from Operating Company corporate hazards associated with any facility operated by management has overall the company.responsibility for maintaining a state of readiness to implement The SNC EP describes the organization and emergency plans for the protection of facilities, training, and maintenance of both plant personnel, the general public onsite and off-site facilities and equipment, that and property from hazards will be used to address a wide spectrum of associated with ionizing radiation accidents ranging from minor onsite incidents to originating within a company facility, those that could affect the general public.Information submitted in this plan EP

Introduction:

The SNC Emergency Plan The wording was standardized and relocated to was developed in accordance with was developed with the guidance of NUREG- the SNC Standard Emergency Plan.the elements outlined in NUREG- 0654, FEMA-REP-1, Revision 1, "Criteria for 0654, FEMA-REP-1, Rev. 1 "Criteria Preparation and Evaluation of Radiological for Preparation and Evaluation of Emergency Response Plans and Radiological Emergency Response Preparedness in Support of Nuclear Power Plans and Preparedness in Support Plants." The SNC Emergency Plan meets the of Nuclear Power Plants". emergency planning standards of 10 CFR Information that describes the 50.47(b), the requirements of Appendix E, and Emergency Operations the intent of NUREG 0654 Revision 1. The Facility (OEO) for Southern Nuclear SNC Emergency Plan is organized using the is outlined in Appendix 7(G). structure of NUREG-0654 Revision 1, and that structure provides the cross-reference to the base document.E6-3 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan fRevised SNC Emergency Plan Equivalent

[Justification Revision 64 Description____________________

B.

SUMMARY

Southern Nuclear Operating Company corporate management has overall responsibility for maintaining a state of readiness to implement emergency plans for the protection of plant personnel, the general public and property from hazards associated with ionizing radiation originating within a company facility.

The authority for planning, developing, and coordinating emergency control measures is discussed in Appendix 9 (I), Responsibility For The Planning Effort.The Farley Plant Emergency Plan describes the organization and facilities both onsite and offsite that will be used to deal with a spectrum of accidents ranging from minor onsite incidents to those that could affect the general public.There are three phases of responsive action contained within the Farley Plant Emergency Plan. The first phase includes initial actions directed toward the protection of personnel and the elimination of the potential for further exposure to the hazard. The second phase includes immediate and planned action directed toward termination of the incident, containment of the effluent, establishment of incident boundaries, establishment of control, channeling of information, and protection of the facility and equipment.

The third phase is to restore the facility to its normal operating condition.

To respond effectively utilizing these phases, emergencies are classified according to increasing severity as Notification of Unusual Event, Alert, Site Area Emergency or General Emergency.

EP

Introduction:

SNC has overall responsibility for maintaining a state of readiness to implement this Plan for the protection of plant personnel, the general public, and property from hazards associated with any facility operated by the company, The authority for planning, developing, and coordinating emergency control measures is derived from being the Nuclear Regulatory Commission (NRC) license holder for the nuclear power plants operated by SNO.The SNC Emergency Plan describes the organization and facilities, training, and maintenance of both onsite and off-site facilities and equipment, that will be used to address a wide spectrum of accidents ranging from minor onsite incidents to those that could affect the general public.There are three phases of responsive action described in the SNC Emergency Plan. The first phase includes initial actions to protect personnel and eliminate the potential for further exposure to the hazard. The second phase includes immediate and planned action to terminate the condition, contain any effluent, establish incident boundaries, establish control, channel information, and protect the facility and equipment.

The third phase is to restore the facility to its normal operating condition.

To respond effectively using these phases, emergencies are classified according to increasing severity:

Unusual Event, Alert, Site Area Emergency, or General Emergency.

The wording was standardized and relocated to the SNC Standard Emergency Plan.E6-4 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description II. ORGANIZATION EP

Introduction:

There are supporting and The wording was standardized and relocated to The organization, responsibilities and complementing emergency plans, including the SNC Standard Emergency Plan.functions of Southern Nuclear those of federal agencies, the states of Operating Company onsite and Alabama, Georgia, South Carolina, and offsite resources are individually individual counties.discussed below. The onsite and SNC has overall responsibility for maintaining a offsite organizations provide state of readiness to implement this Plan for the emergency response during the protection of plant personnel, the general activation, emergency, and recovery public, and property from hazards associated phases of accident response.

with any facility operated by the company.Principal federal, state, local and There are three phases of responsive action private agencies are also discussed.

contained within the SNC Emergency Plan.Figures 12 and 13 illustrate the The first phase includes initial actions to protect interrelationships of these personnel and eliminate the potential for further organizations before and after exposure to the hazard. The second phase Emergency Operations Facility includes immediate and planned action to activation respectively, terminate the condition, contain any effluent, establish incident boundaries, establish control, channel information, and protect the facility and equipment.

The third phase is to restore the facility to its normal operating condition.

To respond effectively using these phases, emergencies are classified according to increasing severity as Unusual Event, Alert, Site Area Emergency, or General Emergency.

______________________

E6-5 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description A. ONSITE EP B.1 Normal Plant Organization The wording was standardized and relocated to The normal onsite organization for The normal onsite organization of an SNC- the SNO Standard Emergency Plan and Site Farley Nuclear Plant is shown on operated nuclear power plant provides a staff Annex.Figure 1. capable of providing the initial response to an emergency event. The On-Shift staff was validated by performing a detailed staffing analysis as required by Part 50 Appendix E, IV.A.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 are shown in Tables 1, 2 and 3.ANNEX Table 2.2.A Section lIA: Management positions EP 0.4 SNC ERO personnel who are The wording was standardized and relocated to in the onsite organization meet the responsible for implementing this plan receive the SNC Standard Emergency Plan.qualification requirements of ANSI specialized training.

The training program for N18.1-1 971. emergency response personnel is 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 SNO Emergency Plan overview training, personnel assigned to onsite emergency response positions will receive training specific to their position.E6-6 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Section Il.A: The qualifications for EP 0.4 SNC ERO personnel who are The wording was standardized and relocated to the professional-technical level responsible for implementing this plan receive the SNC Standard Emergency Plan.positions also meet the requirements specialized training.

The training program for of ANSI Ni18.1-1971.

emergency response personnel is developed based on the requirements of 10 CFR 50, Appendix E and position specific responsibilities.

Requalification training for onsite ERG members consists of an annual review of the Emergency Plan in the form of a general overview.

In addition to SNO Emergency Plan overview training, personnel assigned to onsite emergency response positions will receive training specific to their position.1. Technical Support Center (TSC) EP Figure B.2.B -Technical Support Center Figure B.2.B is provided to address the TSC The emergency onsite organization organization organization proposed for the SNO Standard implemented for events requiring Emergency Plan. Individual positions are activation of the TSC is described in described below.FNP-0-EIP-0 and is shown in Figure 2.Responsibilities and authorities of personnel in the TSC emergency organization are as follows: E6-7 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Section lI.A.1l.a:

a. Emerqency EP B.1 .1: The Shift Manager (SM) is in direct The wording was standardized and relocated to Director (ED) charge of shift plant operations and is directly the SNC Standard Emergency Plan.The ED is charged with the responsible for the actions of the on-shift crew.responsibility of overall direction of In an emergency, the SM assumes the position onsite emergency activity including of the Emergency Director (ED) and takes near-site field monitoring team necessary actions to identify and respond to dispatch and control and interfacing the emergency until relieved by another with offsite organizations and qualified ED.agencies until the Emergency EP B.2.1 .1 TSC Emergency Director (ED)Operations Facility (EOF) is The TSC ED has the authority and activated.

After the EOF is responsibility to immediately initiate any functional, the ED is responsible for emergency actions. Once Command and overall direction of all in-plant Control has been completed, the TSC ED emergency activity.

The ED shall assumes the non-delegable duties of event supervise the TSC, and manage the Classification, on-site Emergency Exposure in plant recovery efforts and the in authorization, and on-site protective actions.plant recovery organization.

The ED EP B.3.1.1 EOF Emergency Director shall communicate directly with the The EOF ED has overall coordinating authority EOF Manager when the EOF is for Southern Nuclear Company resources.

activated and shall have full authority Upon EOF activation, the EOF ED accepts to direct the onsite recovery efforts responsibility for Notification and Protective without further consultation when the Action Recommendation functions from the situation demands such action. Control Room. The EOF ED is also Following EOF activation when time responsible for keeping SNC corporate permits the ED will consult with EOF management informed regarding the personnel prior to initiating major emergency response and Classification evolutions or changes in plant upgrades.configuration.

E6-8 Enclosure 6 to NL-1 6-01 69 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent IJustification Revision 64 Description_____________________

The ED's general responsibilities include: 1 ) Staffing the TSC. The TSC will be staffed by plant supervisory personnel supplemented by plant engineering, technical and administrative personnel as necessary to staff the TSC 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months a day and discharge the responsibilities discussed below.2) Evaluating the classification of the emergency and amending as appropriate.

Terminating an emergency level will not be delegated to other elements of the emergency organization and will be performned in accordance with approved procedures.

3) Verifying correct control room response to the emergency classification.

4) Determining radiological status and initiating notifications to state agencies (and local agencies for General Emergencies).

The decision to notify offsite government agencies may not be delegated to any other element of the emergency organization.

5) Initiating, on initial or upgrade emergency notifications, recommendations to state agencies on advisability of evacuations.

Recommendations to local agencies when state authorities cannot be contacted for immediate evacuation may not be delegated to any other element of the emergency organization.

6) Initiating rescue or emergency repair operations as appropriate.

7) Maintaining plant security.8) Establishing communications with and providing information to the EOF Manager.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 position of the Emergency Director (ED) and takes necessary actions to identify and respond to the emergency until relieved by another qualified ED.EP B.2.1 .1 TSC Emergency Director (ED)The TSC ED has the authority and responsibility to immediately initiate any emergency actions. Once Command and Control has been completed, the TSC ED assumes the non-delegable duties of event Classification, on-site Emergency Exposure authorization, and on-site protective actions.EP B.3.1.1 EQF Emergency Director The EOF ED has overall coordinating authority for Southern Nuclear Company resources.

Upon EOF activation, 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.The wording was standardized and relocated to the SNC Standard Emergency Plan.E6-9 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description_____________________

In fulfilling the above listed Annex Appendix C The specific procedural reference for the ED has responsibilities the Emergency been deleted.Director (ED) is guided by the.procedures listed below: Function-based EPIPs to direct overall ERO FNP-0-EIP-8.1 Emergency Phone response will be developed as part of the Directory approval process for this License Amendment FNP-0-EIP-8.3 Communication Request.Equipment Operating Procedures NMP-EP-104 Dose Assessment NMP-EP--110 Emergency Classification Determination and Initial Action NMP-EP-1 11 Emergency Notifications NMP-EP-1 12 Protective Action Recommendations E6-1 0 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description The ED position is initially filled by EP B.1 .1:* The Shift Manager (SM) is in direct The wording was standardized and relocated to the Shift Manager until relieved by charge of shift plant operations and is directly the SNC Standard Emergency Plan.the on-call ED. It is the intent of SNC responsible for the actions of the on-shift crew.that the ED will be transferred from In an emergency, the SM assumes the position the Control Room as soon as of the Emergency Director (ED) and takes practicable, necessary actions to identify and respond to the emergency until relieved by another qualified ED.EP B.2.1 .1 TSC Emergency Director (ED)The TSC ED has the authority and responsibility to immediately initiate any emergency actions. Once Command and Control has been completed, the TSC ED assumes the non-delegable duties of event Classification, on-site Emergency Exposure authorization, and on-site protective actions.EP B.3.1.1 EQF Emergency Director The EOF ED has overall coordinating authority for Southern Nuclear Company resources.-

Upon EQF activation, 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._____________________

E6-1 1 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description The line of succession of individuals No equivalent Plan/Annex statement No line of succession is provided in the SNC who may serve as the ED is Standard Emergency Plan. The Plan commits to as follows: providing 24-hour staffing coverage for the ERO, Vice President

-Nuclear Plant Site with qualified ERO personnel trained for the Plant Manager respective positions in accordance with the Site Support Manager approved Emergency Plan.Operations Director On-call Operations Supervisor Shift Manager Shift Supervisor Other Managers or staff designated by the Plant Manager The above line of succession does not preclude higher level management from assuming the role of Emergency Director (ED) in any circumstance which, in the judgment of the manager, is appropriate or necessary to protect the health and safety of the public. This designation also does not relieve higher level management from the responsibility to be aware of those circumstances that may initiate this action. These individuals will be trained as EDs. _____________________________________________

E6-12 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

b. TSC Manager EP B.2.1 .2 TSC Manager The wording was standardized and relocated to The on-call TSC Manager reports to The TSC Manager reports to the TSC ED and the SNC Standard Emergency Plan.the Technical Support Center (TSC) is responsible for coordinating activities and is responsible for implementing between the TSC and other emergency Specific references to procedure usage were FNP-O-EIP-6, "TSC Setup and response facilities, directing the activities of the deleted based on the conversion to function Activation", assisting the ED with TSC staff, and ensuring communications are based procedures.

classification assessment and established with applicable offsite agencies.emergency plan implementation per NMP-EP-1 10, "Emergency Classification Determination and Initial Action" and coordination of communications between the TSC and other locations per NMP-EP-111, "Emergency Notifications

" c. Operations Supervisor EP B.2.1 .3 TSC Operations Supervisor The wording was standardized and relocated to The on-call Operations Supervisor The Operations Supervisor reports to the TSC the SNO Standard Emergency Plan.reports to the Technical Support Manager. Major position functions include Center (TSC) and is responsible for evaluating plant conditions and initiating Specific references to procedure usage were coordinating the efforts of the mitigating actions, coordinating TSC efforts in deleted based on the conversion to function operating crew, advising the ED on determining the nature and extent of plant based procedures.

emergency operations and conditions affecting plant equipment, actions to facilitating communications between limit or contain the emergency, invoking the the ED and Shift Supervisor.

provisions of 10 CFR 50.54(x) if appropriate, Supervisory personnel designated by assisting the OSC Manager in determining the the Plant Manager and holding a priority assigned to 0S0 activities, and timely Senior Reactor Operator License completing off site notifications.

rotate as the on-call Operations Supervisor.

E6-1 3 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

d. Maintenance Supervisor EP B.2.1 .4 TSC Maintenance Supervisor The wording was standardized and relocated to The on-call Maintenance Supervisor The Maintenance Supervisor reports to the the SNC Standard Emergency Plan, reports to the TSC and is responsible TSC Manager and is responsible for planning for implementing FNP-O-EIP-5, and coordination of repair, damage control, Specific references to procedure usage were"Maintenance Support to the and plant modification activities.

The deleted based on the conversion to function Emergency Plan", including Maintenance Supervisor works closely with the based procedures.

coordination of the efforts of Engineering Supervisor in planning for plant Emergency Repair Parties and modifications and repairs.advising the ED on proposed modifications, alterations or repair to plant systems and on specifics of plant systems and equipment.

Supervisory I&C and Maintenance personnel designated by the Plant Manager rotate as the on-call MaintenanceSupervisor.

____________________

_____________________

E6-14 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

e. Health Physics Supervisor EP B.2.1 .5 TSC Radiation Protection (RP) The wording was standardized and relocated to The Health Physics Supervisor Supervisor the SNC Standard Emergency Plan.reports to the TSC and is responsible The RP Supervisor reports to the TSC for implementation of FNP-0-EIP-4, Manager and supervises the activities of the Specific references to procedure usage were'Health Physics Support to the radiation protection staff and Health Physics deleted based on the conversion to function Emergency Plan', including Network (HPN) Communicator.

The RP based procedures.

coordination of the efforts of in-plant Supervisor assists the Radiation Field Monitoring Teams, Protection/Chemistry Group Lead in the OSO The title was changed from Health Physics decontamination activities, Health in determining the extent and nature of Supervisor to Radiation Protection Supervisor, to Physics and ALARA support, and radiological or hazardous conditions, and better align with current plant terminology.

advising the ED on the status of coordinates offsite dose assessment and onsite and offsite radiation protection offsite Field Monitoring Teams prior to EOF activities.

This individual is also activation.

responsible for coordination of out-of-plant and SNC offsite Field Monitoring Teams until relieved by the Emergency Operations Facility (EOF) staff. The Health Physics Supervisor and other supervisory personnel designated by the Plant Manager and, to the maximum extent possible, meeting the requirements of Regulatory Guide 1 .8, September 1975, rotate as the on-call Health Physics Supervisor.

f. Security EP B.2.1.14 TSC Security Supervisor The wording was standardized and relocated to Security supervision is responsible The Security Supervisor reports to the TSC the SNC Standard Emergency Plan.for implementing FNP-0-EIP-7, Manager. The TSC Security Supervisor is"Security Support to the Emergency responsible for carrying out the plant security Specific references to procedure usage were Plan", maintaining site security, and and Access Control program, maintaining deleted based on the conversion to function advising the ED. personnel accountability onsite, and assisting based procedures.

in evacuation of onsite areas.E6-1 5 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revision 64 qi. Enciineerincq Supervisor The on-call Engineering Supervisor provides engineering expertise for advising the ED in the development of plans for modifications, alterations, or repairs to plant systems. The on-call Engineering Supervisor is responsible for assisting the on call Maintenance Supervisor with plant repair and mitigation activities by coordinating the necessary engineering resources.

Revised SNC Emergency Plan Equivalent Description Justification EP B.2.1 .7 TSC Engineering Supervisor The Engineering Supervisor reports to the TSC Manager. The TSC Engineering Supervisor is responsible for the overall direction of Engineering Group activities and assessment.

The Engineering Supervisor also directs the analysis of plant problems and core damage, and provides recommendations for plant modifications to mitigate the effects of the accident.The wording was standardized and relocated to the SNC Standard Emergency Plan.+ t h. Chemistry Supervisor The on-call Chemistry Supervisor reports to the TSC and is responsible for implementation of FNP-O-EIP-20,"Chemistry and Environmental Support to the Emergency Plan" including coordination of offsite dose projections and in plant sampling.The on-call Chemistry Supervisor is responsible for coordinating offsite dose projections until relieved by the Emergency Operations Facility (EOF) staff.i. Emercqency Notification Network EP B.2.1.10 TSC Chemistry Support The TSC Chemistry Support reports to the RP Supervisor.

The TSC Chemistry Support is responsible for directing and evaluating in-plant chemistry and analyses, directing and evaluating post-accident sampling, and assisting in core damage assessment.

EP B.2.1 .6 TSC Dose Analyst The Dose Analyst reports to the RP Supervisor.

The Dose Analyst operates the dose assessment model to provide estimates of environmental dose in the event of a radiological release attributable to the event.Specific references to procedure usage were deleted based on the conversion to function based procedures.

The SNC Standard Emergency Plan uses on-shift Chemistry to perform the Dose Assessment function.-4 --f (ENN~) Communicator The on-call ENN Communicator reports to the TSC and is responsible for communications with the state and local government agencies using the guidance found in NMP-EP-1 11,"Emergency Notifications

" EP B.3.1.8 EOF Emergency Notification Network (ENN) Communicator The ENN Communicator in thea EOF reports to the Emergency Communication Coordinator and is responsible for providing offsite agency notifications and periodic updates.The revised Plan provides for simultaneous activation of the TSC and EOF. The Control Room will be relieved for the ENN function by the EOF ENN Communicator.

E6-16 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

i. Emernqency Notification System EP B.2.1.9 EOF Emergency Notification The wording was standardized and relocated to (ENS) Communicator System (ENS) Communicator the SNC Standard Emergency Plan.The on-call ENS Communicator The ENS Communicator reports to the reports to the TSC and is responsible Operations Supervisor and is responsible for Specific references to procedure usage were for communications with the Nuclear ensuring NRC notifications are completed in deleted based on the conversion to function Regulatory Commission (NRC) using accordance with the requirements of 10 CFR based procedures.

the guidance found in NMP-EP-1 11, 50.72 and 73."Emergency Notifications" E6-1 7 Enclosure 6 to NL-1 6-01 69 Farley Justification Matrix Current Farley Emergency Plan [Revised SNC Emergency Plan Equivalent IJustification Revision 64 Description_____________________

k. Shift Manaqer The Shift Manager is responsible for directing operational activities to classify and combat the emergency as delineated in NMP-EP-110,"Emergency Classification Determination and Initial Action". The Shift Manager acts as the Emergency Director (ED) until relieved by the on-call ED and until relieved has the authority and responsibility to immediately and unilaterally initiate any necessary emergency actions, including providing protective action recommendations to authorities responsible for implementing offsite emergency measures.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 offsite 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.

Notification of offsite agencies and approval of state, local, and NRC notifications.

Authorization of emergency exposures in excess of federal limits.* Issuance of potassium iodide (KI) 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. The Shift Manager, after relinquishing duties and responsibilities of the Emergency Director, functionally reports to the Operations Supervisor in the Technical Support Center (TSC).The wording was standardized and relocated to the SNC Standard Emergency Plan.E6-1 8 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description I. Emergency Repair Party B.2.2 Operations Support Center (OSC) Terminology in the SNC Standard Emergency The Emergency Repair Party, as B.2.2.1 0S0 Manager Plan was updated to describe the industry shown in Figure 2, is a group of B.2.2.20OSO Mechanical Maintenance Group standard 0S0 organization.

personnel competent in operations Lead and repair work who will be used B.2.2.3 0S0 Electrical Group Lead The contents of that organization are in Section during an emergency situation to B.2.2.4 0S0 RP / Chemistry Group Lead B.2.2 of the SNC Standard Emergency Plan.make temporary repairs to B.2.2.5 0S0 I&C Group Lead systems/components in order to B.2.2.60OSO Emergency Response Facility The positions by title, without the detailed mitigate the effects of the (ERF) Communicator description from B.2.2, are provided in column 2 emergency.

An Emergency Repair B.2.2.7 030 Personnel to the left.Party for initial re-entry and repair will

Search and rescue.consist of individuals as required

Repair.from the following personnel groups:

Post-accident sampling.Operations Personnel , Internal survey.Maintenance Personnel

Field monitoring.

Instrumentation and Control Personnel Health Physics Personnel Chemistry Personnel E6-19 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

m. Field Monitoring!

Team (FMT) EP Table 2 The wording was standardized and relocated to The Field Monitoring Teams, as EP B.3.1.6 EOF Field Team Coordinator the SNC Standard Emergency Plan.shown in Figure 2, consisting of The Field Team Coordinator reports to the permanent plant employees and/or Dose Assessment Supervisor.

The Field The Field Team Coordinator (EOF) was added as qualified vendor personnel, will Team Coordinator develops the environmental the focal point of direction of activities once the perform onsite and offsite monitoring, sampling strategy in response to potential EOF is activated.

They will provide radiation protection radiological releases and advises the Dose support at the Southeast Alabama Assessment Supervisor and Dose Analyst of Medical Center, during transport of measured radiological values in the potentially irradiated and/or environment.

contaminated casualties, and at the EP 1.7 The capability to take offsite soil, water, Assembly Areas, and at any other and vegetation samples is provided by a location onsite or offsite as instructed minimum of two (2) Field Monitoring Teams by the Emergency Director (ED) or (FMTs).EOF Manager. Field Monitoring Teams are dispatched by To perform these functions a number SNC-operated plants to perform a variety of of teams will be designated functions in situations potentially involving consisting of a Team Leader and an significant releases of radioactive materials Assistant.

from a plant.Team Leader -A Health Physics Technician or qualified vendor technician.

Assistant

-Any qualified plant employee or vendor personnel.

E6-20 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

n. Dose Assessment Staff Annex Table 2.2.A The wording was standardized and relocated to The Shift Supervisor is responsible EP B.2.1 .6 TSC Dose Analyst the SNC Standard Emergency Plan and Site for offsite dose projections until The Dose Analyst reports to the RP Annex.relieved by the Technical Support Supervisor.

The Dose Analyst operates the Center (TSC) staff. Personnel dose assessment model to provide estimates reporting to the Chemistry of environmental dose in the event of a Supervisor are responsible for radiological release attributable to the event.making dose projections until the EP B.3.1.4 EQF Dose Assessment Emergency Operations Facility Supervisor (EQF) is activated, at which time The Dose Assessment Supervisor reports to*EOF dose assessment personnel the EOF Manager and provides oversight of become responsible for making dose assessment, field team control, and off site dose projections.

These protective action recommendation activities in projections may initially be made the EOF; and coordinates communication of automatically by a computerized results with offsite agencies.dose projection program described in EP B.3.1.5 EOF Dose Analyst FNP-0-M-007, Emergency Dose The Dose Analyst reports to the Dose Calculation Manual, using guidance Assessment Supervisor.

The Dose Analyst found in FNP-0-.EIP-9.1, "Automated operates the dose assessment model to Dose Assessment Method". A provide estimates of environmental dose in the manual personal computer event of a radiological release attributable to methodology is provided in NMP-EP- the event.104, Dose Assessment, for long term dose assessment or in the event that the automatic computerized system is inoperable___________________________________________

E6-21 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Normally, dose projections are EP B.3.1 .4 EOF Dose Assessment The wording was standardized and relocated to transmitted to appropriate state Supervisor the SNC Standard Emergency Plan.authorities by telecopy, commercial The Dose Assessment Supervisor reports to telephone, the Emergency the EQF Manager and provides oversight of Notification Network (ENN), or by dose assessment, field team control, and posting dose projections on the SNC protective action recommendation activities in Integrated Data Display System. The the EQF; and coordinates communication of Emergency Notification System results with offsite agencies.(ENS), Health Physics Network EP B.3.1.13 EOF Health Physics Network (HPN), and commercial telephone (HPN) Communicator lines are available for transmission of The HPN Communicator reports to the Dose dose assessment data to the NRC. Assessment Supervisor and is responsible for Data will be provided as directed by providing radiological and environmental the NRC at the time of need. information to the NRC using the HPN Line.o. Additional Plant Staff Assiqnments EP B.2.2 Operations Support Center (OSC) The wording was standardized and relocated to 1) Operations Support Center (OSC) EP B.2.2.10OSC Manager the SNC Standard Emergency Plan.Managqer The OSC Manager reports to the TSC The OSC Manager will be Manager and directs a staff in providing labor, Specific references to procedure usage was considered to be the senior individual tools, protective equipment, and parts needed deleted based on the conversion to function in the OSC and will report to the for emergency repair, damage control, based procedures.

Maintenance Supervisor.

The OSC firefighting, search and rescue, first aid, and Manager will take the lead in recovery.coordinating the activities of the OSC or other location directed by the Emergency Director per FNP-0-EIP-5.0. The senior individual at each of the Assembly Areas will become the supervisor at that location.

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. ___________________________________________

E6-22 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

2) Radiological monitorinq EP B.2.2.40QSC RP/Chemistry Group Lead The wording was standardized and relocated to The Health Physics Group is The RP/Chemistry Group Lead reports to the the SNC Standard Emergency Plan.responsible for all aspects of applied OSO Manager and provides oversight for RP health physics. Emergency and Chemistry Technicians.

Their monitoring will be provided by a responsibilities include onsite radiological Health Physics Technician on shift, a surveys, access control, personnel monitoring qualified/trained vendor technician, and decontamination, dosimetry issuance and or qualified member of the plant staff. monitoring, and onsite habitability surveys.Health Physics supervision will be responsible for relocation of access control to both units as necessary, and for implementing procedures for handling highly radioactive samples.3) Fire Fighting and Rescue Annex Table 2.2.A The wording was standardized and relocated to The plant fire brigade and rescue EP B.6.4 Fire Fighting the SNC Standard Emergency Plan and Site team on all shifts will be composed To supplement the Fire Brigade onsite, Annex.of personnel described in NMP-ES- agreements are made with local fire 035-010. The fire brigade will be departments.

Details on the services offered directed by the Fire Brigade Chief may be found in the SNC plant's site-specific with the aid of FNP-0-EIP-13.

Annex.Annex 2.3.1 Fire Fighting (SEP B.6.4)In the event an emergency is declared as a result of a fire at Farley Nuclear Plant, the City of Dothan Fire Department has agreed to provide support to help combat the fire.4) First Aid Annex Table 2.2.A The wording was standardized and relocated to At least one person on each shift will EP 0.3 First Aid Training the SNC Standard Emergency Plan and Site be qualified to perform first aid. Individuals assigned as First Aid responders Annex.shall maintain qualifications for first aid and Cardio-Pulmonary Resuscitation (CPR)training.E6-23 Enclosure 6 to NL-1 6-01 69 Farley Justification Matrix Current Farley Emergency Plan Revision 64 5') Decontamination Personnel decontamination is the responsibility of the Health Physics Group and during an emergency the responsibility of the Field Monitoring Team. Area and equipment decontamination onsite as the result of an accident will be a joint effort of personnel from the Operations, Maintenance, Chemistry and Health Physics Groups.Revised SNC Emergency Plan Equivalent Description Justification EP K.5 Decontamination The Radiation Protection Group will be responsible for controlling or minimizing direct or subsequent internal exposure from 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 program.EP K.70Offsite Decontamination Nonessential onsite personnel may be evacuated to an offsite reception center or assembly area, as discussed in Section J.Radiological controls personnel at that location will monitor evacuees and determine the need for decontamination.

In the event that decontamination of evacuees locally is not possible, personnel can be sent to designated locations for monitoring and decontamination.

The wording was standardized and relocated to the SNC Standard Emergency Plan.E6-24 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

6) Personnel Accountability EP J.4.2 Accountability The wording was standardized and relocated to Personnel accountability is the Personnel accountability is mandatory at the the SNC Standard Emergency Plan.responsibility of each plant Site Area or General Emergency classification.

supervisor or senior individual onsite Accountability may be initiated at other times in the group. That is, each supervisor at the discretion of the Emergency Director to is responsible for accounting for support worker safety.each person onsite in his group or Accountability of personnel within the visiting his group. Details for Protected Area is accomplished within 30 personnel accountability are minutes of the declaration of Site Area provided by FNP-0-EIP-10, Emergency or higher, and maintained"Evacuation, Personnel continuously thereafter, using Protected Accountability, and Site Dismissal".

Area(s) boundary access control as described Information pertinent to personnel in the Security Plan. If there are station accountability will be kept by security personnel who are unaccounted for, the public guards at each access control point. 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.

7) Record Keeping No equivalent Plan/Annex statement.

Record keeping is a procedural level function of A record 6f all significant events that each individual.

Plant Operations logbook/log occur will be kept by the operating keeping is controlled by Operations procedures.

crew in the Plant Operator's Logbook. A log will be kept by a designated plant staff member who will be responsible for maintaining communications with the corporate headquarters, and offsite authorities as directed by the Emergency Director.

Radiological information such as radiological survey data, personnel exposures, decontamination activities and information from onsite groups will be maintained by the Health Physics Supervisor.

E6-25 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

8) Communications EP B.1 .1 The Shift Manager (SM) is in direct The wording was standardized and relocated to Responsibility for initial offsite charge of shift plant operations and is directly the SNC Standard Emergency Plan.communications will be handled by responsible for the actions of the on-shift crew.the Shift Supervisor or Emergency In an emergency, the SM assumes the Director.

After the emergency responsibility of the Emergency Director (ED)organization is activated, designated and takes necessary actions to identify and plant staff member(s) may be respond to the emergency until relieved by assigned to maintain another qualified ED. The ED has the communications with the Emergency responsibility and authority to immediately and Operations Facility (EOF) and with unilaterally initiate emergency actions,_offsite authorities.

If the Emergency including providing notification of Protective Director is not located in the control Action Recommendations (PAR)to state and room he may maintain local government organizations responsible for communications with the control implementing offsite emergency measures.room through an assigned i~ndividual.

The ED, at their discretion or when When the Emergency Operations procedurally required, activates the ERO.Facility (EOF) is activated, the EOF The Emergency Director's non-delegable staff may handle communication with duties include: offsite authorities.

e Notifications of offsite agencies and Communications interfaces are approval of state, local, and NRC shown in Figure 3. notifications.

B. OFFSITE EP B.30Offsite Emergency Response The offsite organization is integrated into the SNC The normal Alabama Power Organization (ERO) Standard Emergency Plan in the proposed Company (APC) off site company The EOF and JIC Organizations consist of revision.organization is shown in Figure 5. staff members from the SNC, Alabama Power The normal Southern Nuclear Company, and Georgia Power Company For the detailed position by position comparison, Company Corporate organization corporate offices. This organization is see the justification section for the referenced and its relationship to the onsite responsible for providing offsite emergency current plan Appendices.

organization is shown in Figure 6. response support and resources as needed.The Emergency Communication The EOF and JIC Organizations are displayed Organization is shown and described in Figures B.2.D and B.2.E. The EOF and JIC in the Emergency Communications Organizations may also include state and local Plan in Appendix 10(J). personnel._____________________

E6-26 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

1. Emergency Operations Facility EP B.30Offsite Emergency Response The offsite organization is integrated into the SNC (EF)Organization (ERO) Standard Emergency Plan in the proposed The Emergency Operations Facility The EOF and JIC Organizations consist of revision.(EOF) Emergency Response staff members from the SNC, Alabama Power Organization (ERO) and its Company, and Georgia Power Company For the detailed position by position comparison, relationship to the Technical Support corporate offices. This organization is see the justification section for the referenced Center (TSC) emergency responsible for providing offsite emergency current plan Appendices.

organization is described in response support and resources as needed.Appendix 7(G). The EOF and JIC Organizations are displayed in Figures B.2.D and B.2.E. The EOF and JIC Organizations may also include state and local personnel.______________________

2. Corporate Orqanization EP H,2.1 Emergency Operations Facility The wording was standardized and relocated to In the event of an emergency The EOF is the central location for the SNC Standard Emergency Plan.condition at FNP that requires management of the offsite emergency activation of the Corporate response, coordination of radiological Emergency Response Organization assessment, and management of initial (ERO) the organization will be recovery operations.

The EOF is a dedicated activated to notify Emergency facility located in Birmingham, Alabama, and Organization personnel and to serves as the EOF for SNC sites (VEGP, FNP, provide corporate support from SNC. and HNP). Staffing and activation of the EOF is mandatory upon declaration of an Alert or higher classification.

E6-27 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

a. Corporate Duty Manacqer EP B.3.1 .1 EOF Emergency Director With the realignment of the EOF description in the The Duty Manager is responsible for The EOF ED has overall coordinating authority SNC Standard Emergency Plan, the EOF Director the overall management of for Southern Nuclear Company resources.

and Nuclear Spokesperson are now specifically emergency support at FNP. The Upon EOF activation, the EOF ED accepts identified as the individual in Command and Duty Manager is the primary contact responsibility for Notification and Protective Control of the respective facilities.

for support from off-site agencies, Action Recommendation functions from the and provides assistance, and advice Control Room. The EOF ED is also to the EOF Manager and Emergency responsible for keeping SNC corporate Director in decisions involving the management informed regarding the overall effect of the event. The Duty emergency response and Classification Manager will serve as the corporate upgrades.spokesperson until such time as an EP B.3.1.17 EOF Nuclear Spokesperson alternate Duty Manager or other The Nuclear Spokesperson speaks on behalf trained individual is available to of the company, providing plant status updates assume the role of spokesperson.

during news briefings.

The Spokesperson also This position will be filled by a may do one-on-one media interviews.

The qualified individual designated by the position works with the Technical Assistant in Executive Vice President.

keeping abreast of the event status and keeps the Public Information Director (PID) posted on that status.3. Emeroencv Communication EP B.30Offsite Emergency Response The offsite organization is integrated into the SNC Orglanization Organization (ERO) Standard Emergency Plan in the proposed The Emergency Communication The FOF and JIC Organizations consist of revision.Organization (ECO) is discussed in staff members from the SNC, Alabama Power Appendix 10(J). Company, and Georgia Power Company For the detailed position by position comparison, Corporate Offices. This organization is see the justification section for the referenced responsible for providing offsite emergency current plan Appendices.

response support and resources as needed.The EOF and JIC Organizations are displayed in Figures B.2.D and B.2.E. The EOF and JIC Organizations may also include state and local__________________________personnel.______________________

E6-28 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revision 64 Revised SNC Emergency Plan Equivalent Description Justification

4. Recovery Phase Orcianization Upon termination of the emergency condition and at the discretion of the Emergency Director, the SNC Emergency Organization will shift to the Recovery Phase Organization shown in Figure 10. The Recovery Manager has authority to modify the organization as deemed necessary.

EP M.1 Recovery Guidance for determining the transition from Emergency to Recovery Organization is provided in the plant Emergency Plan Implementing Procedures.

The composition of the Recovery Organization will depend on the nature of the accident and the conditions following the accident.The SNO 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.

Upon termination of the emergency phase and at the discretion of the Emergency Director, following consultation with offsite authorities, the SNO Emergency Organization will shift to the Recovery Phase Organization.

Figure M.2 provides a typical recovery operation organization.

The wording was standardized and relocated to the SNO Standard Emergency Plan.See SNC Standard Emergency Plan Section M1 for additional direction for determining when to enter the Recovery Phase and the purpose of recovery actions.The actual recovery organization below the recovery manager will be event-specific and determined on the transition to recovery.

Section M provides a generic organization and guidance for determination of the specific needs of the event.E6-29 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

a. Recovery Manaqier EP M.I: The Recovery Manager will The wording was standardized and relocated to The Recovery Manager shall direct structure the recovery organization to the SNC Standard Emergency Plan.the overall recovery effort. accomplish the following general objectives:

He has the full authority and

Maintain comprehensive radiation responsibility to make decisions surveillance of the site until levels regarding plant recovery and return return to normal.to operation.

This position will be

Control access to the affected area of filled by the Vice President-Nuclear the plant and exposures to workers.Plant Site or designee.

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.Figure M.2 provides a typical recovery___________________________operation organization.______________________

E6-30 Enclosure 6 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

b. Recovery Support Director EP M.1:* The Recovery Manager will structure The SNO Standard Emergency Plan outlines a The Recovery Support Director is the recovery organization to accomplish the general recovery organization and provides responsible for all administrative following general objectives:

overall responsibility for the event under the aspects of recovery activity.

The line

Maintain comprehensive radiation Recovery Manager.of succession for the Recovery surveillance of the site until levels return to Support Director shall be designated normal. The specific event will drive individual by the Vice President -Nuclear Plant

Control access to the affected area of the responsibilities.

Site, should the Recovery plant and exposures to workers.Organization be required.

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.Figure M.2 provides a typical recovery operation organization.

E6-31 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan 1Revised SNC Emergency Plan Equivalent

]Justification Revision 64 JDescription_____________________

c. Technical Support Director The Technical Support Director is responsible for managing all supplemental engineering, technical and licensing support resources needed in the recovery effort. The line of succession for the Technical Support Director shall be designated by the Vice President

-NUclear Plant Site, should the Recovery Organization be required.EP M.1 : The Recovery Manager will structure the recovery organization to accomplish the following general objectives:

Maintain comprehensive radiation 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.Figure M.2 provides a typical recovery operation organization.

The SNC Standard Emergency Plan outlines a general recovery organization and provides overall responsibility for the event under the Recovery Manager.The specific event will drive individual responsibilities.

__________________________________

I ___________________________________________

I E6-32 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan TRevised SNC Emergency Plan Equivalent TJustification Revision 64 Description t____________________

d. Recovery Support Supervisor The Recovery Support Supervisor is responsible for coordinating or monitoring operational support recovery activities as directed by the Recovery Support Director.

This position will be filled by a qualified individual designated by the Recovery Support Director.EP M.1 : The Recovery Manager will structure the recovery organization to accomplish the following general objectives:

Maintain comprehensive radiation 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.Figure M.2 provides a typical recovery operation organization.

The SNC Standard Emergency Plan outlines a general recovery organization and provides overall responsibility for the event under the Recovery Manager.The specific event will drive individual responsibilities.

E6-33 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan ]Revised SNC Emergency Plan Equivalent 1Justification Revision 64 JDescription_____________________

e. Administrative Suooort Suoervisor The Administrative Support Supervisor is responsible for supervising EOF recovery phase administrative activities including:

1) Special communications needs 2) Manpower augmentation

3) Personnel Affairs for temporarily assigned personnel 4) Special Budget Activities

5) Clerical Support 6) Other activities as assigned by the Recovery Support Director This position will be filled by a qualified individual designated by the Recovery Support Director.EP M.1 : The Recovery Manager will structure the recovery organization to accomplish the following general objectives:

Maintain comprehensive radiation 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.Figure M.2 provides a typical recovery operation organization.

The SNC Standard Emergency Plan outlines a general recovery organization and provides overall responsibility for the event under the Recovery Manager.The specific event will driVe individual responsibilities.

E6-34 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

f. Engqineering Supervisor EP M.1 : The Recovery Manager will structure The SNC Standard Emergency Plan outlines a The Engineering Supervisor is the recovery organization to accomplish the general recovery organization and provides responsible for offsite engineering following general objectives:

overall responsibility for the event under the resources directed toward design

Maintain comprehensive radiation Recovery Manager.modification, major repair and surveillance of the site until levels return to engineering evaluations associated normal. The specific event will drive individual with recovery and return to

Control access to the affected area of the responsibilities.

operation.

Responsibilities include: plant and exposures to workers.1) Coordination of offsite engineering

° Decontaminate affected areas and and technical support for design equipment.

changes and repairs ° Conduct activities in radiation areas in 2) Interfacing with accordance with the plant's standard Architect/Engineering firms for radiation work practices.

detailed technical support

Isolate and repair damaged systems.3) Interfacing with NSSS supplier for

Document proceedings of the accident and detailed analyses and technical review the effectiveness of the emergency support ..response organization in mitigating plant 4) Coordinating and expediting damage and reducing radiation exposures to procurement activities, the public.Thisposiion ill e filed y°aProvide offsite authorities with plant status qualified individual designated by the reports and information concerning the plant Technical Support Director.

rcvr raiain* 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.Figure Mv.2 provides a typical recovery operation organization.

E6-35 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description.q. Licensingq Supervisor EP M.1 : The Recovery Manager will structure The SNC Standard Emergency Plan outlines a The Licensing Supervisor is the recovery organization to accomplish the general recovery organization and provides responsible for all recovery phase following general objectives:

overall responsibility for the event under the licensing activities.

Maintain comprehensive radiation Recovery Manager.His responsibilities include: surveillance of the site until levels return to 1) Interfacing with the NRC to normal. The specific event will drive individual resolve license issues

Control access to the affected area of the responsibilities.

2) Interfacing with Architect/Engineer plant and exposures to workers.firms or NSSS supplier to obtain

Decontaminate affected areas and technical and engineering analyses equipment.

as necessary to resolve licensing

Conduct activities in radiation areas in issues accordance with the plant's standard 3) Coordinating with the Engineering radiation work practices.

Supervisor on design changes

Isolate and repair damaged systems.resutingfro licnsig isue* Document proceedings of the accident and resolution review the effectiveness of the emergency 4) Preparation of NRC required, response organization in mitigating plant reports associated with the accident damage and reducing radiation exposures to or recovery effort. the public.This position will be filled by a *Provide offsite authorities with plant status qualified individual designated by the reports and information concerning the plant Technical Support Director.

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.C. OUTSIDE ORGANIZATIONS See the Appendix 7 section of the Justification Coordination with Governmental Matrix for the detailed descriptions.

agencies is discussed in Appendix 7(G), section E. The following Section A. Assignment of Responsibility contains provides additional site specific the description of the major organizations.

details to the Appendix 7(G)discussion.

E6-36 Enclosure 6 to NL-1 6-01 69 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

1. Government Aclencies EP A.1.1 Nuclear Regulatory Commission The wording was standardized and relocated to The Nuclear Regulatory Commission (NRC) the SNC Standard Emergency Plan.has published its incident response The NRC acts as the lead federal agency for plan in NUREG-0728, specifying technical matters during a nuclear incident, NRC actions, responsibilities, with the Chairman of the Commission as the functions and authorities during an senior NRC authority for response.

The emergency.

Chairman can transfer control of emergency response activities when deemed appropriate.

Incident Response Centers have been established at the four NRC regional offices 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.______________________

Written agreements have been EP B.5 Letters of Agreement (LOAs) The SNC Standard Emergency Plan contains the reached with the other offsite The respective nuclear power plants have commitment for the Letter of Agreement in the agencies listed below with regard to obtained LOAs with private contractors and description of services from the various support the type of support that will be others who provide emergency support agencies.furnished to the Joseph M. Farley services.

LOAs, as a minimum, state that the Nuclear Plant in the event of an cooperating organization will provide its normal The general statement that LOAs exist is not emergency.

These agreements services in support of an emergency at the needed in the Plan.have been developed to ensure that affected plant. LOAs are referenced in the there is a clear understanding of site-specific plant Annex and the actual letters assigned responsibilities and that are maintained in accordance with Emergency there will be proper coordination of Plan procedures.

activities in the event of an emergency.

Letters of Agreement on File with offsite support groups are given in Part I, Appendix 2(B).E6-37 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Corporate and/or plant personnel will EP B.3.1.15 EOF Liaisons The wording was standardized and relocated to be dispatched to principal Liaisons report to the Offsite Response the SNC Standard Emergency Plan.government agencies on an as Coordinator and respond to the applicable needed basis. state Emergency Operations Centers (EOCs)as required by the type and source of the event. Liaisons are assigned to Georgia, Alabama and/or South Carolina state EOCs depending on which SNC site declared the initiating event.Anticipated offsite federal assistance See Section A.1. The SNC Standard Emergency Plan in Section is discussed in the individual state A.1 describes the federal agencies providing plans. direct support to the Emergency Plan. Additional support addressed in the existing statement is specific support to the offsite responders.

The federal agencies described in the Plan include: A.1 .1 Nuclear Regulatory Commission (NRC)A.1 .2 Department of Homeland Security (DHS)A.1 .3 Federal Emergency Management Agency (FEMA)A.1 .4 Department of Energy (DOE)A.1 .5 Federal Bureau of Investigation (FBI)A.1 .6 National Weather Service (NWS)A.1 .7 Environmental Protection Agency (EPA)a. Department of Enermy Savannah EP A.1 .4 Department of Energy (DOE) The wording was standardized and relocated to River Operations Office The DOE provides radiological assistance on the SNC Standard Emergency Plan.In the event of a General request, and has radiological monitoring Emergency, the DOE Savannah equipment and personnel resources that it can River Operations Office has agreed assemble and dispatch to the scene of a to provide a DOE Radiological radiological incident.

Following a radiological Assistance Team. This assistance incident, DOE operates as outlined in the team will be limited to advisory Federal Radiological Monitoring and assistance in handling radiological Assessment Plan (ERMAP). The Radiological emergencies.

The Emergency Assistance Team can be expected to respond Director is authorized to request this to SNC operated sites as directed by the assistance.

Savannah River Operations Office of DOE.E6-38 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

b. Nuclear Regiulatory Commission EP A.1 .1 Nuclear Regulatory Commission The wording was relocated and transferred to the Upon notification of an emergency (NRC) SNC Standard Emergency Plan.condition, the NRC will implement The NRC acts as the lead federal agency for the incident response plan described technical mailers during a nuclear incident, in NUREG-0728.

In addition to with the Chairman of the Commission as the fulfilling its regulatory responsibilities, senior N RC authority for response.

The it is expected that the NRC will Chairman can transfer control of emergency provide technical assistance and response activities when deemed appropriate.

recommendations.

For Site Area and Incident Response Centers have been General Emergencies, dispatch to established at the four NRC Regional Offices SNC facilities of a NRC Region II site and NRC Headquarters, to centralize and team is anticipated with arrival coordinate NRC's emergency response.expected 2 to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months following Provision is made for NRC personnel at the notification.

As described in Section plant's Technical Support Center and the 111, office space, telephones, etc. Emergency Operations Facility.have been provided for NRC personnel at the Technical Support Center and Emergency Operations Facility._______________________________________________

E6-39 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revision 64 c. State of Alabama The Alabama Radiation Control Division of the State of Alabama Department of Public Health is responsible for initiating the"Alabama Radiological Response Plan for Nuclear Power Plants" in support of an emergency at the Farley Nuclear Plant. This plan provides a detailed description of the notification procedures and responsibilities and duties of the local and state agencies involved.Since the primary concern of the Alabama Radiation Control Division is for the welfare and safety of the general public, they will have primary responsibility and authority for handling the offsite aspects of the emergency in Alabama.Revised SNC Emergency Plan Equivalent Description Justification-I- +EP A.2.1 State of Alabama EP A.2.1.1 Alabama Emergency Management Agency (AEMA)The Alabama Emergency Management Agency coordinates the Radiological Emergency Plans and offsite operations of affected state agencies and local governments, including notification of state and local agencies of a nuclear incident at a nuclear power plant impacting the state of Alabama, direction of activities at the state Emergency Operations Center, coordination of non-radiological operations with utility and federal authorities, and coordination of news information.

EP A.2.1 .2 Alabama Department of Public Health, Office of Radiation Control Through the Alabama Department of Public Health, the Alabama Office of Radiation Control is responsible for initiating the"Alabama Radiological Response Plan for Nuclear Power Plants" in support of an emergency at the Farley Nuclear Plant. The state plan provides a detailed description of the notification procedures and the responsibilities and duties of the local and state agencies involved.

The Alabama Office of Radiation Control has primary responsibility and authority for handling the offsite aspects of an emergency in Alabama with primary focus on the welfare and safety of the general public.EP A.2.1 .3 Other Alabama State Agencies Responsibilities of other state agencies are described in the Alabama Radiological Response Plan for Nuclear Power Plants.The wording was relocated and transferred to the SNC Standard Emergency Plan.E6-40 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan IRevised SNC Emergency Plan Equivalent IJustification Revision 64 Description I____________________

An agreement is in place with the State of Alabama to provide available resources and equipment to support the mitigation and response to an emergency at Plant Farley 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 Houston County 911 center, the county EQOC, or through the Incident Command Post, as applicable, based on the nature and timing of the event.EP A.2.1 State of Alabama EP A.2.1 .1 Alabama Emergency Management Agency (AEMA)The Alabama Emergency Management Agency coordinates the Radiological Emergency Plans and offsite operations of affected state agencies and local governments, including notification of state and local agencies of a nuclear incident at a nuclear power plant impacting the state of Alabama, direction of activities at the state Emergency Operations Center, coordination of non-radiological operations with utility and federal authorities, and coordination of news information.

EP A.2.1 .2 Alabama Department of Public Health, Radiation Control Division Through the Alabama Department of Public Health, the Alabama Radiation Control Division is responsible for initiating the "Alabama Radiological Response Plan for Nuclear Power Plants" in support of an emergency at the Farley Nuclear Plant. The state plan provides a detailed description of the notification procedures and the responsibilities and duties of the local and state agencies involved.

The Alabama Radiation Control Division has primary responsibility and authority for handling the offsite aspects of an emergency in Alabama with primary focus on the welfare and safety of the general public.EP A,2.1.3 Other Alabama State Agencies Responsibilities of other state agencies are described in the Alabama Radiological Response Plan for Nuclear Power Plants.The wording was relocated and transferred to the SNC Standard Emergency Plan.E6-41 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

d. State of Georqia EP A.2.2 State of Georgia The wording was relocated and transferred to the Upon notification of an emergency EP A.2.2.1 Georgia Emergency SNO Standard Emergency Plan.condition, the Georgia Emergency Management Agency (GEMA)Management Agency will implement-GEMA is responsible for general state the "State of Georgia Radiological emergency planning and overall direction, and Emergency Plan". The Georgia control of emergency or disaster operations as Emergency Management Agency assigned by executive order and in has the authority and responsibility accordance with the Georgia Emergency for coordinating the efforts of local Operations Plan (GEOP). GEMA has and state agencies in Georgia to responsibilities for coordinating the state of provide for the health and safety of Georgia response to emergencies at nuclear the general public in the event of a power plants.radiological incident.

EP A.2.2.2 Department of Natural Resources-Environ mental Protection Division (DNR-EPD)The DNR-EPD has primary responsibility for implementation and administration of the state radiological emergency response function.EP A.2.2.3 Other Georgia State Agencies Responsibilities of other state agencies are described in the Georgia Emergency Operations Plan (GEOP).____________________

E6-42 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description An agreement is in place with the EP A.2.2 State of Georgia The wording was relocated and transferred to the State of Georgia to provide available EP A.2.2.1 Georgia Emergency SNC Standard Emergency Plan.resources and equipment to support Management Agency (GEMA)the mitigation and response to an GEMA is responsible for general state emergency at Plant Farley to include emergency planning and overall direc~tion, and Hostile Action Based events. These control of emergency or disaster operations as resources include, but are not limited assigned by executive order and in to, Local Law Enforcement Agency accordance with the Georgia Emergency (LLEA) assets, Fire Fighting assets, Operations Plan (GEOP). GEMA has medical support resources (including responsibilities for coordinating the state of transportation), and coordination Georgia response to emergencies at nuclear through an Incident Command Post. power plants.Requests for offsite resources and EP A.2.2,2 Department of Natural equipment will be communicated Resources-Environmental Protection from the control room to the Early Division (DNR-EPD)County 911 center, the county EOC, The DNR-EPD has primary responsibility for or through the Incident Command implementation and administration of the state Post, as applicable, based on the radiological emergency response function.nature and timing of the event. EP A.2.2.3 Other Georgia State Agencies Responsibilities of other state agencies are described in the Georgia Emergency_________________________Operations Plan (GEOP).____________________

E6-43 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

e. State of Florida Annex 1.6 State of Florida The wording was relocated and transferred to the Upon notification of an emergency Upon notification of an emergency condition by Site Annex.condition by SNC or the Alabama SNC or the Alabama Emergency Management Emergency Management Agency, Agency, the Florida Department of Community the Florida Department of Affairs, Division of Emergency Management, Community Affairs, Division of State Warning Point will implement the "State Emergency Management, State of Florida Radiological Emergency Warning Point will implement the Management Plan for Nuclear Power Plants."'State of Florida Radiological The Department 6)f Community Affairs, Division Emergency Management Plan for of Emergency Management has the authority Nuclear Power Plants". The and responsibility for coordinating the efforts of Department of Community Affairs, local and state agencies in Florida to provide Division of Emergency Management for the health and safety of the general public has the authority and responsibility in the event of a radiological incident.

The for coordinating the efforts of local Department of Health-Bureau of Radiation and state agencies in Florida to Control will provide support to the Company in provide for the health and safety of matters related to the Florida ingestion the general public in the event of a pathway radiological emergency response.radiological incident.

The Department of Health-Bureau of Radiation Control will provide support to the Company in matters related to the Florida ingestion pathway radiological emergency response._____________________________________________

E6-44 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revision 64 f. Houston County. Alabama The Chairman of the Houston County Commission has the overall responsibility for emergency preparedness and local response in Houston County. Houston County has also accepted responsibility for evacuations in Henry County out to the 10 mile EPZ. The Houston County Emergency Management Agency coordinates planning and operations of all local agencies in support of an incident at Farley Nuclear Plant. A detailed emergency plan is maintained in case of an emergency at the Farley Nuclear Plant. This plan is Part I of the"Alabama Radiological Response Plan for Nuclear Power Plants'.Revised SNC Emergency Plan Equivalent Description J ustification Annex 1.7.1 Houston County, Alabama (SEP A.2.4)The Chairman of the Houston County Commission has the overall responsibility for emergency preparedness and local response in Houston County. Houston County also has accepted responsibility for evacuations in Henry County out to the 10 mile EPZ. The Houston County Emergency Management Agency coordinates planning and operations of all local agencies in support of an incident at Farley Nuclear Plant. A detailed emergency plan is maintained in case of an emergency at the Farley Nuclear Plant.An agreement is in place with Houston County, Alabama to provide available resources and equipment to support mitigation and response to an emergency at Plant Farley 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 off site resources and equipment will be communicated from the control room to the Houston County 911 center, the county EOC, or through the Incident Command Post, as applicable, based on the nature and timing of the event.The wording was relocated and transferred to the Site Annex.E6-45 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description An agreement is in place with Annex 1.7.1 Houston County, Alabama The wording was relocated and transferred to the Houston County, Alabama to provide (SEP A.2.4) Site Annex.available resources and equipment The Chairman of the Houston County to support the mitigation and Commission has the overall responsibility for response to an emergency at Plant emergency preparedness and local response Farley to include Hostile Action in Houston County. Houston County also has Based events. These resources accepted responsibility for evacuations in include, but are not limited to, Local Henry County out to the 10 mile EPZ. The Law Enforcement Agency (LLEA) Houston County Emergency Management assets, Fire Fighting assets, medical Agency coordinates planning and operations support resources (including of all local agencies in support of an incident at transportation), and coordination Farley Nuclear Plant. A detailed emergency through an Incident Command Post. plan is maintained in case of an emergency at Requests for offsite resources and the Farley Nuclear Plant.equipment will be communicated An agreement is in place with Houston County, from the control room to the Houston Alabama to provide available resources and County 911 center, the county EOC, equipment to support mitigation and response or through the Incident Command to an emergency at Plant Farley to include Post, as applicable, based on the Hostile Action Based events. These resources nature and timing of the event, 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 the Houston County 911 center, the county EOC, or through the Incident Command Post, as applicable, based on the nature and timing of the event.E6-46 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

g. Early County. Georcqia Annex 1.7.2 Early County, Georgia (SEP The wording was relocated and transferred to the The Chairman, Early County Board A.2.4) Site Annex.of Commissioners, has responsibility The Chairman, Early County Board of for overall radiological emergency Commissioners, has responsibility for overall response planning.

The actual plan radiological emergency response planning.development and coordination of The actual plan development and coordination emergency actions is carried out by of emergency actions is carried out by the the Blakely-Early County Emergency Blakely-Early County Emergency Management Management Agency. The "Blakely-Agency. The "Blakely-Early County Early County Emergency Emergency Management Agency Radiological Management Agency Radiological Emergency Plan for Nuclear Emergency Plan for Nuclear Incidents/Accidents Involving Joseph M. Farley Incidents/Accidents Involving Joseph Nuclear Power Plant" is given as part of the M. Farley Nuclear Power Plant"' is "State of Georgia Radiological Emergency given as part of the "State of Georgia Plan." Radiological Emergency Plan". An agreement is in place with Early County, Georgia, to provide available resources and equipment to support mitigation and response to an emergency at Plant Farley 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 the Early County 911 center, the county EOC, or through the Incident Command Post, as applicable, based on the nature and timing of the event.E6-47 Enclosure 6 to NL-1 6-01 69 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 jDescription_____________________

h. City of Dothan. Alabama -Fire Department In the event an emergency (Section IV) is declared as a result of a fire at Farley Nuclear Plant, the Dothan Fire Department has agreed to provide support to help combat the fire. The Dothan Fire Department resources are listed in FNP-0-EIP-13, "Fire Emergencies".

The estimated response time to Farley Nuclear Plant is 30 minutes. The Emergency Director is authorized to request this assistance.

Request for fire support will be made by the control room or site security to the Houston County 911 center, Houston County EOC, or the Incident Command Post, as applicable, based on the nature and timing of the event.2. Contractor and Private Offsite Orgqanizations

a. Southern Nuclear/Southern Company Services Southern Company Services, Incorporated (SCS), an affiliated service company, served as the original architect-engineer.

As a result of the consolidation of SCS and SNC nuclear expertise, and in addition to being the licensee, SNC also serves as its own architect-engineer and performs functions previously performed by SCS to include design, licensing, and fuel management support during normal operation.

Annex 1.7.3 City of Dothan, Alabama (SEP B.6.4)In the event an emergency is declared as a result of a fire at Farley Nuclear Plant, the Dothan Fire Department has agreed to provide support to help combat the fire. The estimated response time to Farley Nuclear Plant is 30 minutes. The Emergency Director is authorized to request this assistance.

Request for fire support will be made by the control room or site security to the Houston County 911 center, Houston County EOC, or the Incident Command Post, as applicable, based on the nature and timing of the event.The wording was relocated and transferred to the Site Annex.EP A.3.1 Southern Nuclear Operating Company (SN C)Southern Nuclear Operating Company (SNC)serves as the architect-engineer.

The wording was relocated and transferred to the SNC Standard Emergency Plan.E6-48 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

b. Bechtel Power Corporation EP A.3.2. Bechtel Power Corporation The wording was relocated and transferred to the Bechtel is the architect/engineer for SNC has established an agreement with SNC Standard Emergency Plan.portions of Unit 1 and for Unit 2. Bechtel Power Corporation to obtain Bechtel provides support in the areas engineering and construction services which of new concept design (including may be required following an accident.drawings, specifications, safety reviews, etc.); modification design;engineering support for licensing issues; and as advisor on component and system operation.

The Engineering Support Manager (Emergency Support Phase) and the Technical Support Director (Recovery Phase) interface directly with Bechtel.________________________

c. Westinqhouse EP A.3.3 Westinghouse The wording was relocated and transferred to the Westinghouse is the NSSS supplier SNC has established an agreement with SNC Standard Emergency Plan.for both Farley units. Their support Westinghouse to obtain general services activities associated with the NSSS related to nuclear steam supply system include installation, testing, and (NSSS) operations during and following an corrective action assistance in their accident situation.

Westinghouse provides the scope of supply; engineering support capability to respond on a 24-hour-a-day for licensing issues; new concepts basis.design and modification design;advisor on components and systems;and engineering support related to operation, maintenance, and corrective action. The Engineering Support Manager (Emergency Support Phase) and the Technical Support Director (Recovery Phase)provide interface with Westinghouse either directly or through SCSI. _____________________________________________

E6-49 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

d. Institute of Nuclear Power EP A.4 Other Utilities The wording was relocated and transferred to the Operations (IN PO), Nuclear Energqy The Institute of Nuclear Power Operations SNC Standard Emergency Plan.Institute (NEI) and Electric Power (INPO) aids nuclear utilities in obtaining Research Institute (EPRI). resources beyond their usual capabilities Southern Nuclear Operating during recovery from an emergency.

As one of Company is a participating member its roles, INPO will assist affected utilities by of INPO and as such will have applying the resources of the nuclear industry available technical expertise from to meet the needs of an emergency.

this organization in areas of nuclear power plant operation in accordance with established agreements (Letter of Agreement

-Appendix 2(B)). Also, INPO and EPRI have a plan describing their combined emergency information response capabilities.

Their assistance is available to Southern Nuclear Operating Company (Letter of Agreement

-Appendix 2(B)). ___________________

_______________

e. Maintenance Assistance No equivalent Plan/Annex statement The non-specific statement in the current Plan is Assistance in the area of incorporated into the more detailed description of maintenance and repair is made Support provided in the SNC Standard available by contractor organizations.

______________________Emergency Plan and Site Annex.f. Radiological Monitoring EP A.3.5 Radiological Monitoring The wording was relocated and transferred to the Assistance.

Assistance SNC Standard Emergency Plan.Radiological monitoring in the plant Radiological monitoring in the plant and in the and in the environs both onsite and environs, both onsite and offsite, will be offsite will be augmented by outside augmented by outside vendors as necessary.

vendors as necessary.

Initial Initial radiological monitoring will be performed radiological monitoring will be by available Southern Company resources performed by available Southern (e.g., Georgia Power Company (GPO) Central Company resources, (e.g., Georgia Laboratory).

Power Company (G PC) Central Laboratory).___________________________________________

E6-50 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description_____________________

g. Other Utilities EP A.4 Other Utilities The wording was relocated and transferred to the Southern Nuclear Operating The Institute of Nuclear Power Operations SNC Standard Emergency Plan.Company is a signatory to the (IN P0) aids nuclear utilities in obtaining"Voluntary Assistance Agreement By resources beyond their usual capabilities and Among Electric Utilities Involved during recovery from an emergency.

As one of in Transportation of Nuclear its roles, INPO will assist affected utilities by Materials" and a signatory to the applying the resources of the nuclear industry"Nuclear Power Plant Emergency to meet the needs of an emergency.

Response Voluntary Assistance Agreement" (see Appendix 2(B)).Although these agreements do not impose an obligation on any signatory to provide assistance, they establish the contractual framework by which assistance may be requested and provided expeditiously.______________________

Ill. FACILITIES AND EQUIPMENT A. CONTROL CENTERS__________________________

________E6-51 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan ]Revised SNC Emergency Plan Equivalent 1Justification Revision 64 Description_____________________

1. Technical Support Center (TSC)During any emergency condition the center for coordinating all in-plant activities will be the TSC.Located immediately north of the Unit 2 control room area, the TSC is designed to accommodate up to 25 people for the evaluation of plant-status, coordination of damage assessment and emergency actions, and interface with the NRC, Emergency Operations Facility (EOF) and Operations Support Center (OSC).Provision is also made for control anid coordination of communications with offsite agencies and of out-of-plant radiation monitoring activities until the EOF is activated and assumes these functions.

The TSC when activated will normally maintain the function of offsite communications for initial and upgrade notifications to federal, state, and local authorities.

An overall space of 22 feet x 65 feet, with a 9-foot ceiling height, has been provided.

Room layout is as follows: a. Monitoring Area b. Planning and Coordination Area c. Document Room d. Conference Area Figure 14 shows the above layout.Annex 5.1.2 Technical Support Center (SEP H.1.2)Located immediately north of the Unit 2 control" room area, the TSC (Figure 5.1 .A) is designed for the evaluation of plant status, coordination of damage assessment and emergency actions, and interface with the NRC, Emergency Operations Facility (EOF), and Operations Support Center (OSC). Provision is also made for control and coordination of communications with offsite agencies and of out-of-plant radiation monitoring activities until the EOF is activated and assumes these functions.

The TSC is designed to be habitable to the same extent as the control room for postulated radiological accidents.

Its ventilation system includes a deep-bed charcoal filter to remove air-borne contamination, and it has the capability of pressurizing the TSC area and recirculating the room air through the charcoal filter. A permanent radiation monitor is provided to continuously indicate radiation dose rates and airborne activity.

A radiation alarm in the main control room make-up air supply duct automatically initiates room pressurization and recirculation.

Electrical power sources are designed so the HVAC, wall outlets, and lighting can be powered from the diesel generators if offsite power is lost.The TSC maintains access to drawings and records necessary for the response to an emergency event at FNP. 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.Annex Figure 5.1 .A The wording was relocated and transferred to the Site Annex.E6-52 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description The TSC is designed to be habitable Annex 5.1.2 Technical Support Center The wording was relocated and transferred to the to the same extent as the control (SEP H.1 .2) Site Annex.room for postulated radiological The TSC is designed to be habitable to the accidents.

Its ventilation system same extent as the control room for postulated includes a deep-bed charcoal filter to radiological accidents.

Its ventilation system remove air-borne contamination, and includes a deep-bed charcoal filter to remove it has the capability of pressurizing air-borne contamination, and it has the the TSC area and recirculating the capability of pressurizing the TSC area and room air through the charcoal filter. A recirculating the room air through the charcoal permanent radiation monitor is filter. A permanent radiation monitor is provided to continuously indicate provided to continuously indicate radiation radiation dose rates and airborne dose rates and airborne activity.

A radiation activity.

A radiation alarm in the main alarm in the main control room make-up air control room make-up air supply duct supply duct automatically initiates room automatically initiates room pressurization and recirculation.

Electrical pressurization and recirculation.

power sources are designed so the HVAC, Electrical power sources are such wall outlets, and lighting can be powered from that the HVAC, wall outlets and the diesel generators if offsite power is lost.lighting can be powered from the diesel generators if offsite power is lost.E6-53 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description The TSC contains a set of piping and Annex 5.1,2 Technical Support Center (SEP The wording was relocated and transferred to the instrumentation drawings for each H.1 .2) Site Annex.unit and technical manuals on The TSC maintains access to drawings and selected major equipment.

Other records necessary for the response to an technical data are readily available emergency event at FNP. These records can from the document control facility in be accessed on a digital records system. This the plant Service Building which may system is supplied backup power from an be reached by intra-plant phone from uninterruptible power supply to allow retrieval the TSC. Also available in the TSC of records in the event of a loss of power.are the Emergency Plan, Emergency These records include: Plan Implementing Procedures,

Technical specifications.

Abnormal Operating Procedures,

Plant operating procedures.

Emergency

Final safety analysis report.Response Procedures, Severe

Emergency Plan.Accident Management Guidelines,

Emergency Plan Implementing and Unit Operating Procedures along Procedures.

with other general reference

Patoeaigrcrs materal.*

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.Should the emergency situation so No equivalent Plan/Annex statement The ability to relocate the facility is provided at dictate, the Emergency Director may procedural level. The non-specific statement in shift the staff to other locations as the current Plan provides no additional value.designated by the Emergency Director.2. Emergency Operations Facility EP H.20Offsite Emergency Facilities The description was standardized and (EOF) EP H.2.1 Emergency Operations Facility incorporated in the SNC Standard Emergency The EOF facilities and equipment are The EOF is the central location for management Plan.described in Appendix 7(G). of the offsite emergency response, coordination of radiological assessment, and management of See Appendix 7(g) section for the detailed initial recovery operations.

The EOF is a comparative description.

dedicated facility located in Birmingham, Alabama, and serves as the EOF for SNC sites (VEGP, FNP, and HNP).E6-54 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revision 64 Revised SNC Emergency Plan Equivalent Description Justification

3. NRC Support Facilities Annex 5.1.5 A near site location is maintained The wording was relocated and transferred to the Support facilities for the NRC have at the FNP Training Center with space for Site Annex.been provided at the Site Training members of an NRC Site Team.Facility.

Adequate functional working space and telecommunication capability for up to 10 people (approximately 750 ft 2) has been provided in this near-site facility.4. Operations Center (OSC) Annex 5.1.3 Operations Support Center The wording was relocated and transferred to the The Breakroom (outside the (SEP H.1.3) Site Annex.Technical Support Center) will serve The break room (outside the Technical as the Operations Support Center Support Center) will serve as the Operations (Figure 19), from which emergency Support Center (Figure 5.1 .B), from which operations support will be provided, emergency operations support will be In the event that the Operations provided.

The OSC is where operational Support Center becomes untenable, support personnel such as instrument*

it will be relocated onsite or to offsite technicians, mechanics, electricians, company facilities in Headland, chemical/radiation technicians, equipment Alabama (Figure 17) at the discretion operators, and incoming shift personnel of the Emergency Director.

assemble to aid in the response to an emergency.

The OSC will accommodate the support and technical staff to respond to an event on one or both Units. The OSC has the capability to communicate with the control room, the Technical Support Center (TSC), and the Emergency Operations Facility (EOF).Operations at this facility will be directed by the________________________OSC Manager.____________________

E6-55 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 -Description

5. Alternative Facility Annex 5.1.=4 Alternative Facility (SEP H.1.4) The wording was relocated and transferred to the During a security related event or During a security-related event or other event Site Annex.other event that precludes onsite that precludes onsite access, the TSC and access, the TSC and 0S0 ERO staff OSC ERO staff will be directed to an will be directed to an alternative alternative facility.

This facility is located in the facility.

This facility is located in the Alabama Power Company (APC) Old Crew Alabama Power Company (APC) Old Headquarters Building in Headland, Alabama.Crew Headquarters Building in The alternative facility is equipped with the Headland, Alabama. The alternative necessary communications and data links to facility is equipped with the support communications with the control room, necessary communications and data site security, and the EOF.links to support communications with The available communications and data links the control room, site security, and also provide access to SNC document the EOF. The available management resources, work planning communications and data links also resources, plant technical data displays, and provide access to SNC document other SNC-specific resources for performing management resources, work engineering assessment activities, including planning resources, plant technical damage control team planning and preparation data displays, and other SNC for return to the site. Guidance for the specific resources for performing alternative facility activation and operation is engineering assessment activities, provided in implementing procedures.

including damage control team planning and preparation for return to the site. Procedural guidance for the alternative facility is provided in N MP- EP- 135, Alternative Facility Setup and Operation.___________________________________________

E6-56 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

5. Joint Information Center Annex 5.1.6 Joint Information Center (JIC) The wording was relocated and transferred to the The Houston County Juvenile Court (SEP H.2.2) Site Annex.Services Building (Figure 17) will The FNP JIC is located in Dothan, Alabama at serve as a working and briefing the Houston County Juvenile Court Services center for local, state and national Building.

The JIG is the central location for the news media (Lease Agreement

-coordination and dissemination of information Appendix 2(B)). All official to news media and responses to public and information released by SNC and media inquiries.

Details of the JIC for FNP are APC regarding the emergency will be in section H of the Emergency Plan. If the released from the Joint Information decision is made to activate the JIC, the CMC Center once it has been activated, in Birmingham, Alabama will maintain emergency communications response coordination until the JIC is ready to assume these responsibilities.

E6-57 Enclosure 6 to NL-1 6-01 69 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description_____________________

EP H.2.3. Joint Information Center (JIC) The wording was relocated and transferred to the After the initial notification of an emergency at SNC Standard Emergency Plan.the Alert classification or higher, the Public Information Director will coordinate with the EOF Emergency Director and affected OROs and determine whether to activate the JIC.Upon the decision to activate the JIG, the Public Information Director and JIC staff transfer from the CMC to the site specific JIG.Once the JIG is staffed the Public Information Director will manage 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.B. GOMMUNIGATIONS SYSTEMS EP F.1.1 At SNC operated nuclear power The wording was relocated and transferred to the Several modes of communication are plants, several modes of reliable SNC Standard Emergency Plan.available, during both normal and communication are available, during both emergency conditions, to transmit normal and emergency conditions, to transmit and receive information within the and receive information among the Gontrol plant and at locations onsite and Room, TSC, OSC, EOE, and at other locations offsite. onsite and offsite including the Joint Information Genter near the SNC site.Reliable primary and backup means of communication have been established.

The use of the communications systems during normal and emergency conditions has been integrated into plans, procedures, and___________________________the training program.E6-58 Enclosure 6 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description EP H.2.3. Joint Information Center (JIC) The wording was relocated and transferred to the After the initial notification of an emergency at SNC Standard Emergency Plan.the Alert classification or higher, the Public Information Director will coordinate with the EOF Emergency Director and affected OROs and determine whether to activate the JIC.Upon the decision to activate the JIC, the Public Information Director and JIC staff transfer from the 0MG to the site specific JIC.Once the JIG is staffed the Public Information Director will manage the emergency communications response from the JIG in coordination with ORO public information officers (Pigs).Site specific JIG is provided in the site specific Annexes.B. COMMUNICATIONS SYSTEMS EP F.1 .1 At SNC operated nuclear power The wording was relocated and transferred to the Several modes of communication are plants, several modes of reliable SNC Standard Emergency Plan.available, during both normal and communication are available, during both emergency conditions, to transmit normal and emergency conditions, to transmit and receive information within the and receive information among the Control plant and at locations onsite and Room, TSC, OSC, EOF, and at other locations offsite. onsite and offsite including the Joint Information Center near the SNC site.Reliable primary and backup means of communication have been established.

The use of the communications systems during normal and emergency conditions has been integrated into plans, procedures, and the training program.E6-59 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

1. Commercial Telephones EP F,1 .1 At SNC-operated nuclear power The wording was relocated and transferred to the The commercial telephone lines plants, several modes of reliable SNC Standard Emergency Plan.consist of several lines connected communication are available, during both through local exchanges to the Bell normal and emergency conditions, to transmit Telephone system. Access to these and receive information among the Control lines is available through selected Room, TSC, 0S0, EOF, and at other locations private automatic exchange (PAX) onsite and offsite including the Joint telephones located throughout the Information Center near the SNC site.plant, including the control room, Reliable primary and backup means of TSC, and Joint Information Center. communication have been established.

Commercial telephone lines The use of the communications systems servicing the Corporate Office may during normal and emergency conditions has be accessed through off-premises been integrated into plans, procedures, and extensions (OPX) of the Corporate the training program.Office PAX which are located in selected plant locations, including the TSC, and in the EOF. Availability of OPX and PAX telephones capable of accessing commercial telephone lines is tabulated in Table 1.Commercial telephone lines are also available at the Birmingham EOF and the Birmingham Corporate Communication Offices. A facility minimum of thirty (30) commercial telephone lines are available at the Joint Information Center.E6-60 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

2. Private Automatic Exchange Annex 5.2 On-Site Communications (SEP' The wording was relocated and transferred to the The plant private automatic F.1) Site Annex.exchange (PAX) consists of a Normal on-site communications is provided by network of telephones located the plant telephone system (network and strategically throughout the plant, at commercial).

The plant public address (PA)various stations on the site (including system also may be used for in-plant the Control Room, TSC and OSO) communications.

The PA system is powered and at selected offsite locations Joint by normal plant power, backed up by Information Center, the State of uninterruptible power.Alabama Forward Emergency Portable radios are used for communications Operations Center in Houston between individuals and base stations located County, the State of Georgia in the Control Room, TSC, OSC EOF, and Forward Emergency Operations Security.

There is also a plant intercom Center in Early County, the AEMA system. Intercom units are installed at EOC in Clanton, Alabama, the ARCD selected plant locations primarily for specific FOC in Montgomery, Alabama, and task related activities.

the GEMA EOC in Atlanta, Georgia. EP F Table 5 Selected PAX phones are capable of communication with similar private automatic exchanges at the Corporate Office, other APC/SNC facilities, and facilities of Southern Company affiliates (e.g. Southern Company Services and Georgia Power Company).____________________

E6-61 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revision 64 Revised SNC Emergency Plan Equivalent Description Justification In addition to the PAX network, selected phones operate as off-premises extensions (OPX) of the APC Corporate Headquarters private automatic exchange and operate independently of the plant PAX system. These phones may be used for calling APC/SNC facilities and offices connected to the APC Corporate Headquarters PAX system or for accessing Bell Telephone System commercial lines in Birmingham.

OPX and PAX phone availability is tabulated in Table 1.Annex 5.2 On-Site Communications (SEP The wording was relocated and transferred to the F. 1) Site Annex.Normal on-site communications is provided by the plant telephone system (network and commercial).

The plant public address (PA)system also may 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.

There is also a plant intercom system. Intercom units are installed at selected plant locations primarily for specific task related activities.

EP F Table 5 3. Microwave No equivalent Plan/Annex statement The SNC Standard Emergency Plan and Annex APC's microwave system provides provides detailed descriptions of the primary and telephone circuits to all of the back-up communications capabilities.

company's power plants and major offices including the Alabama Power Office in Headland, Alabama. All primary microwave routes are provided with standby RF equipment with automatic switchover.

The microwave telephone circuits available may be used by dialing through the PAX system._______________________

E6-62 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

4. Alabama Control Center (ACC) No equivalent Plan/Annex statement The load dispatch link provides no capability for Link implementation of the Site Emergency Plan.A computer link to the Alabama Control Center network is located in the Switchhouse.

The link provides for communications with the ACC for purposes of load dispatch and coordination with the Southern Company Power Control Center and other APC plants.5. Two-Way Radio Annex 5.2 On-Site Communications (SEP The wording was relocated and transferred to the Two-way radios and base stations F.1) Site Annex.are available at the site as follows: Portable radios are used for communications between individuals and base stations located in the Control Room, TSC, OSC EOF, and Security.

There is also a plant intercom system. Intercom units are installed at selected plant locations primarily for specific task related activities._______________________

a. Plant operations frequency

-EP F Table 5 The wording was relocated and transferred to the This radio frequency provides SNC Standard Emergency Plan.communication between the Control Room, TSC, EOF, and personnel in the plant equipped with operations frequency radios. This frequency may be used as a backup frequency for communicating with offsite/onsite field monitoring teams.b. Plant security frequency

-This EP F Table 5 The wording was relocated and transferred to the radio frequency provides SNC Standard Emergency Plan.communication between the Control Room, TSC, EOF, Security Offices, mobile units in security vehicles and other selected company owned vehicles and personnel equipped with security frequency walkie-talkies._______________________________________________

E6-63 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

c. Plant field monitorinq frequency

-EP F Table 5 The wording was relocated and transferred to the This radio frequency provides SNO Standard Emergency Plan.communication between the TSC, EOF, and personnel in the plant equipped with FMT frequency radios.This frequency may be used as a backup for communicating with offsite/onsite field monitoring teams._d. Digital radio system (multi EP F Table 5 The wording was relocated and transferred to the f reauency)

-This radio system SNO Standard Emergency Plan.provides both onsite/offsite group and private radio communication.

This radio system will be the normal communication system for the field monitoring teams.6. Public Address and Party Lines Annex 5.2 On-Site Communications (SEP The wording was relocated and transferred to the A plant wide public address system F.1) Site Annex.consisting of six separate and Normal on-site communications is provided by independent communications lines the plant telephone system (network and (one page and five party lines) exists commercial).

The plant public address (PA)to provide quick communications system also may be used for in-plant between two or more locations, even communications.

The PA system is powered in high noise level areas. The page by normal plant power, backed up by channel is used to call personnel uninterruptible power.over the speakers, issue plant-wide instructions or to communicate between two or more hand-sets.

The party lines are used to carry on communication after the paged party has answered.

One of the party lines will be dedicated as an emergency communications channel during emergency conditions.______________________

E6-64 Enclosure 6 to NL-1 6-01 69 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

7. Sound Powered Telephone EP F Table 5 The wording was relocated and transferred to the Sound powered telephone lines are SNC Standard Emergency Plan.located between critical points in the plant and are normally used primarily for communications during maintenance and refueling.

8. Plant Emergency Alarm EP E.2.1 Notification of Onsite Personnel The wording was relocated and transferred to the The Plant Emergency Alarm is a The Emergency Director is responsible for SNO Standard Emergency Plan.variable tone alarm. The warble tone classifying an event into the appropriate may be used to alert plant personnel, emergency classification and then notifying on-contractors, and visitors onsite in the site personnel of the emergency declaration in event of a Site Area Emergency or accordance with procedures.

This notification General Emergency or other may consist of the use of the plant emergency condition requiring all personnel to alarm, announcements over the plant public report to their emergency Assembly address system, or activation of the recall Areas. The siren tone may be used system.to muster the fire brigade or at the EP F Table 5 discretion of the Shift Supervisor in order to alert personnel.

Blue beacon lights located in high noise areas or other locations where the alarms may not be audible are also activated to provide a visual emergency notification.

9. NRC Emerqency Notification EP F.1 .4.1 NRC Emergency Notification The wording was relocated and transferred to the System (ENS) System (ENS) SNC Standard Emergency Plan.This dedicated Federal Telephone This communications line provides a System (FTS) communications line communications link to the NRC Operations The current operation of the FTS system allows provides a dialup communications Center in Rockville, Maryland, and is used for any phone with long distance capability to call into link to the NRC operations office in continuous communications in a classified the Headquarters Operations Center and be Bethesda, MD and would be used for emergency.

patched into any bridge. The specific listing continuous communications in the becomes redundant to the expanded capability.

event of an emergency.

Phones are located in the control room, TSC, EQF, and in the Shift Foreman's office adjacent to the Control Room.E6-65 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

10. NRC Health Physics Network EP F.1.4.2 NRC Health Physics Network The wording was relocated and transferred to the (HPN) (HPN) SNC Standard Emergency Plan.This dedicated Federal Telephone This communications line provides a System (FTS) communications line communications link with the NRC to provide The current operation of the FTS system allows provides a dialup communications radiological information, any phone with long distance capability to call into link with the NRC to provide the Headquarters Operations Center and be radiological information.

Phones are patched into any bridge. The specific listing located in the TSC and in the EOF. becomes redundant to the expanded capability.

E6-66 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description_____________________

11. State/Local Aaencv Emeroencv Notification Network This communications system provides an immediate communications link with the State of Alabama, the State of Georgia and local county personnel in Alabama and Georgia who would possibly be notified in the event of an emergency.

Telephones with speakers on this communication network are located at the EQF;TSC; Shift Foreman's Office adjacent to the control room; Alabama Radiation Control Division; Alabama Emergency Management Agency;State of Alabama Department of Public Safety; Houston County (AL)Sheriff's Dispatcher; Houston County Office of Radiological Health;Georgia Emergency Management Agency (GEMA); Early County (GA)Sheriff's Dispatcher; Early County Emergency Management Agency;and GEMA Forward Emergency Operations Center (Early County).The communications system locations listed above for the FNP Shift Support Supervisor's Office; the Alabama Department of Public Safety, the Georgia Emergency Management Agency, the Houston County Sheriff's Dispatcher's Office, and the Early County Sheriff's Dispatcher's Office are staffed 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months a day.EP F.1 .2 SNC-operated plants maintain the capability to make initial notifications to the designated offsite agencies 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months per day.Offsite notifications can be made to state and county warning points and 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.EP F.1 .3 Provisions exist for continuous communications with state and local governments within the Emergency Planning Zones, as detailed above. At least one on-site and one offsite communications system is maintained, each with a backup power source to ensure continuous communications.

The wording was relocated and transferred to the SNC Standard Emergency Plan.E6-67 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

12. NRC Reactor Safety Counterpart EP F,1 .4.3 NRC Reactor Safety Counterpart The wording was relocated and transferred to the Link (RSCL) Link (RSCL) SNC Standard Emergency Plan.This dedicated FTS communications This communications line provides a line provides a dialup communications link for the NRC to conduct The current operation of the FTS system allows communications link for the NRC to internal NRC discussions on plant equipment any phone with long distance capability to call into conduct internal NRC discussions on conditions separate from the licensee, the Headquarters Operations Center and be plant equipment conditions separate patched intoany bridge. The specific listing from the licensee.

becomes redundant to the expanded capability Phones are located in the TSC and EQF.13. Protective Measures Counterpart EP F.1.4.4 Protective Measures Counterpart The wording was relocated and transferred to the Link (PMCL) Link (PM CL) SNC Standard Emergency Plan.This dedicated FTS communications This communications line provides a line provides a dialup communications link for the NRC to conduct The current operation of the FTS system allows communications link for the NRC to internal NRC discussions on radiological any phone with long distance capability to call into conduct internal NRC discussions on releases, meteorological conditions, and the the Headquarters Operations Center and be radiological releases, meteorological need for protective actions. patched into any bridge. The specific listing conditions, and the need for becomes redundant to the expanded capability protective actions. Phones are located in the TSC and EOF.14. Managqement Counterpart Link EP F.1 .4.5 Management Counterpart Link The wording was relocated and transferred to the (L)(MCPL) (Executive Bridge Line) SNC Standa~rd Emergency Plan.This dedicated FTS communications This communications line provides a line provides a dialup communications link for any NRC internal The current operation of the FTS system allows communications link for any NRC discussions between the NRC Executive Team any phone with long distance capability to call into internal discussions between the Director or Executive Team members and the the Headquarters Operations Center and be NRC Executive Team Director or NRC response team leader or top-level patched into any bridge. The specific listing Executive Team members and the licensee management at the site. becomes redundant to the expanded capability NRC Director of Site Operations or top level licensee management at the site. Phones are located in the TSC and EOF._________________

__________________

E6-68 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description_____________________

15. Local Area Network (LAN) EP F.1.4.7 Southern Company Network The wording was relocated and transferred to the Access Access SNC Standard Emergency Plan.This dedicated ETS communications This communications line provides the NRC line provides the NRC site team with site team with access to the NRC Operations access to the NRC Operations Center's LAN. LAN connections are provided Center's LAN. Connections are on the Southern Company Network.provided in the TSC and EOF.16. Telecopier No equivalent Plan/Annex statement No specific reference to copying equipment was Telecopiers are located at the TSC, provided in the SNC Standard Emergency Plan EOF, Alabama Radiation Control Division, Alabama Emergency Management Agency, GEMA, Houston County Emergency Management Agency, and Early County Emergency Management Agency. ______________________

17. SNC Integqrated Data Display EP 1.1 Select plant parameters are available to The wording was relocated and transferred to the_System state and local authorities on a secure network SNC Standard Emergency Plan.This system provides a direct data dedicated to data distribution among the link via the internet between Farley various offsite emergency response facilities.

Nuclear Plant and at Houston County Emergency Management Agency (EMA), Alabama Radiation Control Division in Montgomery, Georgia EMA in Atlanta, Early County EMA, and the EOF. It may be used to rapidly transmit information on current emergency classification, radiological conditions, and meteorological conditions.

E6-69 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

18. Emergency Response Data EP F.1 .4.8 Emergency Response Data The wording was relocated and transferred to the System (ERDS) System (ERDS) SNC Standard Emergency Plan.These communications lines provide ERDS is a dedicated network and is a direct channels by which raw reactor near real-time electronic data link between the The current operation of the FTS system allows parametric data is transmitted from plant's on-site computer system and the NRC any phone with long distance capability to call into the site to the NRC. The affected Operations Center. It provides for the the Headquarters Operations Center and be Unit ERDS will be activated within automated transmission of a limited data set of patched into any bridge. The specific listing one hour following the declaration of selected parameters.

becomes redundant to the expanded capability an Alert emergency or above.19. Other Communication Systems No equivalent Plan/Annex statement The specific communications systems required to A cellular phone is provided for use support the functions of the Emergency Plan are by the EOF Manager while in transit provided in the Plan and Site Annex. The to the EOF. proliferation of individual cell phones precluded the need to provide the ED with a specific phone.C. ASSESSMENT FACILITIES Introductory wording in the current Plan was In order to carry out the assessment omitted. No change was made to the facilities.

actions described in Section IV, facilities must be available for initial as well as continuous evaluation of emergency conditions.

E6-70 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan 1Revised SNC Emergency Plan Equivalent 1Justification Revision 64 Description

____________________

1. Onsite Systems and Equipment a. Natural Phenomena Monitors The plant is equipped with a meteorological tower instrumented as shown in Table 2, with both primary and secondary instrumentation for wind speed (10in and 45.7m), wind direction (l1in and 45.7m), ambient temperature (l10m and 60m), and dew point (10Om and 60m). There is also a single channel of instrumentation for precipitation with associated data loggers located at the meteorological tower building.The meteorological tower instrumentation feeds wind speed, wind direction, precipitation, dew point, delta temperature, and sigma theta data to the plant computer.This data is utilized for dose calculations.

Computer terminals in the TSC and EOF can be utilized to obtain real time or 15 minute average readouts of meteorological data. Should the plant's meteorological equipment become inoperable, information is available from the approved Flight Service, from the Georgia Pacific Paper Company, or from the regional National Weather Service offices.Annex 5.6.1 Geophysical Phenomena Monitors (SEP H.5.1)Meteorological (SEP H.5.1)A meteorological monitoring program is in place at FNP. Instruments are mounted on a 60-meter tower located on the plant site.Parameters measured and transmitted to the control room include:* Windspeed (10 in and 45.7 in).* Wind direction (10 m and 45.7 in).* Vertical temperature difference (l1in and 60m).* Ambient temperature (10 m and 60 m).* Dewpoint temperature (10 in).* Precipitation (base).The meteorological tower instrumentation feeds wind speed, wind direction, precipitation, dew point, delta temperature, and sigma theta data to the plant computer.

This data is used for dose calculations.

Computer terminals in the TSC and EOF can obtain real time or 15-minute average readouts of meteorological data. Should the plant's meteorological equipment become inoperable, information is available from the approved Flight Service, from the Georgia Pacific Paper Company, or from the regional National Weather Service offices..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.

The wording was relocated and transferred to the Site Annex.E6-71 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Various types of seismic Annex 5,6.1 Geophysical Phenomena The wording was relocated and transferred to the instrumentation are located on vital Monitors (SEP H.5.1) Site Annex.pieces of equipment and structures Seismic .(SEP H.5.1)throughout the site, a number of Various types of seismic instrumentation are which have readout and/or located on vital pieces of equipment and annunciation in the control room. A structures throughout the site, a number of complete discussion of these which have readout and/or annunciation in the monitors is given in FSAR Section control room. A complete discussion of these 3.7.4. Seismic information may also monitors is given in FSAR Section 3.7.4.be obtained from the National Seismic information may also be obtained from Earthquake Center in Golden, the National Earthquake Center in Golden, Colorado.

Colorado.The plant is equipped with hydrologic Annex 5.6.1 Geophysical Phenomena The wording was relocated and transferred to the monitors to monitor river water level Monitors (SEP H.5.1) Site Annex.and service water pond level. These Hydrologic (SEP H.5.1)monitors have readout and The plant is equipped with hydrologic monitors annunciation in the control room. to monitor river water level and service water Redundant river water level monitors pond level. These monitors have readout and provide control room indication from annunciation in the control room. Redundant 65 to 130 feet MSL river level. A river water level monitors provide control room discussion of service water pond indication from 65 to 130 feet MSL river level.level monitors is given in ESAR A discussion of service water pond level Section 9.2.1.5. monitors is given in FSAR Section 9.2.1 .5.E6-72 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description_____________________

b. Radiological Monitors EP H.5.2.1 Radiation Monitoring System The wording was relocated and transferred to the Portable monitors and sampling (RMS) Site Annex.equipment used during normal plant Radiation monitoring instruments are located operations are available in the Health at selected areas within the plant to detect, Physics Instrument Issue Room on measure, and record radiation levels. The elevation 155 of the auxiliary building monitors are comprised of area, airborne, and for use during emergencies.

Portable air particulate monitors.monitors and/or sampling equipment

° Area monitors respond to gamma designated for emergency use are radiation.

located in various areas of the plant.

Airborne monitors detect and measure A general category listing of radioactive gaseous effluent emergency supplies and equipment concentrations.

is included in Appendix 1 (A) and an Emergency response procedures provide itemized listing can be found in FNP- methods for determining relationships between 0-EIP-16, "Emergency Equipment monitor readings and releases, material and Supplies".

available for release, and extent of core damage.Process, area and effluent monitors EP H.5.2.2 Liquid and Gaseous Sampling The wording was relocated and transferred to the that may be used for emergency Systems SNC Standard Emergency Plan.assessment are described in The process sampling system consists of the Appendix 3(C). A complete normal sampling system and additional discussion of these monitors is given sampling panels located throughout the plant.in FSAR Sections 11.4 and 12.1.4. Pre-designated monitoring and sampling Monitors on gaseous effluent release points are listed in site procedures.

Sampling points provide input signals to a plant systems are installed or can be modified to computer utilized for offsite dose permit reactor coolant and containment calculations; computer terminals in atmosphere sampling even under severe the TSC and EOF can be utilized to accident conditions.

The system i can provide obtain one minute or 15 minute information on post-accident plant conditions average effluent activity data. FNP to allow operator actions to mitigate and EIP-30, "Post Accident Core control the course of an accident.

Various Damage Assessment", provides chemical analyses and radiological correlations between containment measurements on these samples can be high range area monitor readings performed, including the determination of and core damage. radionuclide concentrations.

E6-73 Enclosure 6 to NL-1 6-01 69 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description c..Post Accident Samplingq Facilities EP 1.2 Continuing and Post Accident The wording was relocated and transferred to the Facilities are provided for obtaining Assessment SNC Standard Emergency Plan.highly radioactive samples while The resources available to provide initial and minimizing personnel exposure.

continuing information for accident assessment Reactor coolant samples, both througho[Jt the course of an event include pressurized (RCS) and plant parameter display systems, liquid and unpressurized (RHR/containment gaseous sampling system, area and process sump) may be obtained utilizing a radiation monitoring systems, and Accident remotely operated sampling panel. Radiation Monitoring Systems. Descriptions of The panel provides for obtaining these systems are given in Section H. Details samples of both liquid phase and on performing post-accident sampling are in non-condensable gas phase the plant-specific procedures.

components.

Particulate, iodine and noble gas samples may be obtained from the containment atmosphere or the plant vent stack Utilizing remotely operated valves. All systems provide for collection of small aliquots of the sampled media. Sampling capability also exists for the steam generators and steam jet air ejectors.

Shielded containers, portable shielding and remote handling apparati allow analysis with minimum exposure.d. Fire Detection EP H.5.4 Fire Detection System The wording was relocated and transferred to the Fire and smoke detection monitors The Fire Detection System is designed to SNC Standard Emergency Plan.are located in all vital buildings on detect products of combustion or heat in the plant site with extensive designated areas of the plant. The fire alarm coverage in the Auxiliary Building, communication systems and subsystems are Containment and Turbine Building.

A located at strategic points throughout the plant complete description of the fire to warn personnel of a fire or other emergency protection and detection systems is conditions.

Additional description of the fire given in FSAR Section 9.5, and fire system is provided in the FSAR.protection re-evaluation report entitled, "Farley Nuclear Plant Fire Protection Program Re-evaluation".

E6-74 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description_____________________

2. Environs Monitoring Facilities and EP H.10 Collection Point for Field Samples The wording was relocated and transferred to the Equipment SNC-operated nuclear power plants have SNO Standard Emergency Plan.A comprehensive environmental designated a point as the location for receipt monitoring program is established for and analysis of field monitoring team the Farley Plant covering both onsite environmental samples. Sampling and and offsite areas analysis equipment is available for quantitative activity determination of marine and air samples, and qualitative activity determination of terrestrial samples.Equipment used in this program that EP H.9 Emergency Kits The wording was relocated and transferred to the may be used for emergency Emergency kits are available at SNC-operated SNO Standard Emergency Plan.assessment is as follows: nuclear power plants. Designated site or a. OSL~s department procedures identify the equipment b. Air particulate and iodine monitors in the various emergency kits. Details as to kit c. Portable radiation survey locations are found in the plant-specific instruments procedures.

E6-75 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Although the OSLDs and the air No equivalent Plan/Annex statement The counting specific information was maintained particulate and iodine samples may in applicable procedures.

be evaluated by an outside vendor, the capability for evaluating the air particulate and iodine samples exists at the plant. FNP-0-RCP-25 provides methodology for utilizing available air sampling and monitoring equipment to measure radioiodine concentrations in air in the plume exposure EPZ as low as 10-7 uCi/ml under field conditions.

Interference from noble gas and background radiation will not decrease the minimum detectable activity.

A detailed description of the minimum portable and fixed health physics equipment available at the site is given in FSAR Section 12.3.Predesignated monitoring and sampling points are listed in EN P-0-EIP-4, "Health Physics Support to the Emergency Plan".The states of Georgia and Florida EP H.6.3 Laboratory Facilities The wording was relocated and transferred to the have mobile laboratory facilities that External facilities for counting and analyzing SNC Standard Emergency Plan.could be used in case of samples, and for dosimetry processing, can be emergencies.

All field monitoring provided by other SNC-operated plants data will be transmitted to and including the GPO Central Laboratory, state, analyzed at the EOF (the TSC until federal, or contracted laboratories.

Outside the EOF is staffed).

The University of analytical assistance may be requested from Georgia and Oak Ridge National state and federal agencies, or through Laboratories have fixed radiological contracted vendors. The DOE, through the laboratories in the general Radiological Assistance Program (RAP) has geographic area that can aid in access to any national laboratory.

radiological analysis.

It is estimated that the response time for these organizations will range from 2 to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .E6-76 Enclosure 6 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revision 64 Revised SNC Emergency Plan Equivalent Description Justification I- +The plant is equipped with a computer which utilizes automatically input meteorological data, effluent monitor data and selected plant parameter data (e.g. steam generator pressure, plant vent stack flow rate, etc.) to calculate estimated and projected offsite dose.The system automatically actuates when effluent monitors indicate abnormal release point activity and continues until manually terminated.

Calculational results are available at computer terminals located at the TSC, EOF and other selected locations.

EP 1.30Offsite Dose Assessment SNC-operated nuclear power plants use an offsite dose assessment program that estimates doses from radiological accidents for comparison with the EPA Protective Action Guidance and acute health effect thresholds.

The dose calculation model is available in the Control Room, TSC, and EOF for use in projecting potential offsite doses.The program estimates reactor source term, atmospheric transport, and doses resulting from radiological emergencies, and can be used to assist in making protective action determinations The system supplements assessments based on plant conditions.

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.The wording was relocated and transferred to the SNC Standard Emergency Plan.The MIDAS-NU model in use for the Fleet is a full class B dose assessment model that supports multi-unit and multi-accident modeling, while the ARDA program is a simple Class A dose assessment model without multi-unit and multi-accident capability.

The MIDAS model meets all existing regulatory requirements, so the ARDA program is no longer needed.E6-77 Enclosure 6 to NL-1 6-01 69 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description In the event that the above computer EP 1.30Qffsite Dose Assessment The wording was relocated and transferred to the is not available and for long term SNC-operated nuclear power plants use an SNC Standard Emergency Plan.dose assessment, a manual offsite dose assessment program that personal computer method is estimates doses from radiological accidents for The MIDAS-NU model in use for the Fleet is a full provided in NMP-EP-104, Dose comparison with the EPA Protective Action class B dose assessment model that supports Assessment

". The system calculates Guidance and acute health effect thresholds.

multi-unit and multi-accident modeling, while the estimated and projected offsite dose, The dose calculation model is available in the ARDA program is a simple Class A dose and plume dimensions, location and Control Room, TSC, and EOF for use in assessment model without multi-unit and multi-arrival times out to 50 miles from the projecting potential offsite doses. accident capability.

The MIDAS model meets all plant site. Meteorological data, The program estimates reactor source term, existing regulatory requirements, so the ARDA effluent monitor data and plant atmospheric transport, and doses resulting program is no longer needed.parameter data utilized in the manual from radiological emergencies and can be calculations will usually be obtained used to assist in making protective action from local data systems. In the event determinations The system supplements that the local data systems are not assessments based on plant conditions.

available then data may be obtained The model was developed to allow from the control room meteorological consideration of the dominant aspects of data recorder, effluent monitor source term, transport, dose, and instruments and control room consequences.

Because the program is indicators, 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.E6-78 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description A detailed discussion of the EP 1.30Qffsite Dose Assessment The wording was relocated and transferred to the automatic offsite dose assessment SNC-operated nuclear power plants use an SNC Standard Emergency Plan.method is provided in FNP-0-M-007, offsite dose assessment program that"Emergency Dose Calculation estimates doses from radiological accidents for The MIDAS-NU model in use for the Manual". A detailed discussion of the comparison with the EPA Protective Action Fleet is a full class B dose manual offsite dose assessment Guidance and acute health effect thresholds, assessment model that supports method is provided in the MIDAS The dose calculation model is available in the multi-unit and multi-accident (Meteorological Information and Control Room, TSC, and EOF for use in modeling, while the ARDA program Dose Assessment System) projecting potential offsite doses. ' is a simple Class A dose assessment Technical Manual. The program estimates reactor source term, model without multi-unit and multi-atmospheric transport, and doses resulting accident capability.

The MIDAS from radiological emergencies and can be model meets all of the existing used to assist in making protective action regulatory requirements, so the determinations The system supplements ARDA program is no longer needed.assessments based on plant conditions.

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.E6-79 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Results of dose estimates and EP 1.30Offsite Dose Assessment The wording was relocated and transferred to the projections are provided to off-site SNC-operated nuclear power plants use an SNC Standard Emergency Plan.agencies responsible for initiating offsite dose assessment program that protective actions using the SNC estimates doses from radiological accidents for The MIDAS-NU model in use for the Fleet is a full Integrated Data Display System, comparison with the EPA Protective Action class B dose assessment model that supports telecopy system, ENN, ENS and/or Guidance and acute health effect thresholds.

multi-unit and multi-accident modeling, while the commercial telephones.

The dose calculation model is available in the ARDA program is a simple Class A dose Control Room, TSC, and EOF for use in assessment model without multi-unit and multi-projecting potential offsite doses. accident capability.

The MIDAS model meets all The program estimates reactor source term, existing regulatory requirements, so the ARDA atmospheric transport, and doses resulting program is no longer needed.from radiological emergencies and can be used to assist in making protective action determinations The system supplements assessments based on plant conditions.

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.E6-80 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

3. Personnel Monitorinci Eqiuipment EP K.3.1 In an emergency situation, on-site The wording was relocated and transferred to the In addition to the portable personnel, offsite support personnel, and local SNC Standard Emergency Plan.radiological monitors discussed in government emergency response personnel Section II1.C.1 .b external dosimetry may be issued monitoring devices. Exposure equipment is available for personnel records will be maintained for emergency monitoring and dose assessment.

response personnel who are issued dosimetry.

Digital alarming dosimeters (DADs)provide immediate dose assessment for emergency personnel.

Dose assessment will also be provided by plant OSLDs and vendor OSLDs which can be processed on an emergency basis within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . All dose results will be retained in permanent records for each individual.

E6-81 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description_____________________

D. PROTECTION, EP K.5 Decontamination The wording was relocated and transferred to the DECONTAMINATION AND FIRST The Radiation Protection Group will be SNC Standard Emergency Plan.AID FACILITIES responsible for controlling or minimizing direct 1. Protective Facilities and or subsequent internal exposure from Eqiuipment radioactive materials deposited on the ground The Plant Assembly Areas are or other surfaces, and for determining the designated as the Control Room, extent of contamination in controlled and Technical Support Center (TSC), normally uncontrolled areas. During normal Operations Support Center (Room conditions or an emergency, guidelines to 2452 -North of TSC), Support follow for contamination limits are established Building Auditorium, Support Building by the site radiation protection program.Cafeteria, Maintenance Training Facilities and supplies for decontaminating Center, PAP (Non-PA side), Visitor's personnel are available at various plant Center Auditorium, Switchhouse, locations.

Personnel leaving the Radiological Fabrication Shop, and Warehouse Controlled Area (RCA) or leaving a Receiving Area (Figure 19). All contaminated area will be monitored for personnel on the plant site will report contamination.

During emergencies, other to one of these designated assembly onsite personnel will be checked for areas when the Plant Emergency contamination as necessary.

Alarm is sounded. All personnel will Designated personnel, under the direction of be instructed in advance as to which the Radiation Protection Group, are assembly area to report in the event responsible for performing material that the Plant Emergency Alarm is decontamination.

Procedures and equipment sounded, for material decontamination are available at the plant, as specified in the site radiation protection program.Alternate Assembly Areas No equivalent Plan/Annex statement With the incorporation of more detailed protective designated for use at the discretion actions for the HAB event, the commitment to of the Emergency Director are the maintain the Assembly ability was maintained in Contractor Parking Lot, Switchhouse the SNC Standard Emergency Plan, but specifics Parking Lot, an area between the were eliminated to allow for more effective case-Unit #2, 2A, and 2B Cooling Towers, by-case management of the function.the Utility Building, the Southeast corner of the Control Room, the OPS Ready Room, and the Health Physics (HP) Office (Figure 19).E6-82 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description_____________________

The Operations Support Center will Annex 5.1.3 Operations Support Center The wording was relocated and transferred to the provide protection for emergency (SEP H.1 .3) Site Annex.Operations, Health Physics and The break room (outside the Technical Repair Party personnel.

An Support Center) will serve as the Operations emergency cabinet is provided which Support Center (Figure 5.1 .B), from which contains emergency supplies, emergency operations support will be provided.

The OSC is where operational support personnel such as instrument technicians, mechanics, electricians, chemical/radiation technicians, equipment operators, and incoming shift personnel assemble to aid in the response to an emergency.

The OSO will accommodate the support and technical staff to respond to an event on one or both Units. The OSC has the capability to communicate with the control room, the Technical Support Center (TSC) and the Emergency Operations Facility (EOF).Operations at this facility will be directed by the OSC Manager.The Maintenance Shop and Central Annex 5.5 Emergency Kits (SEP H.9) The wording was relocated and transferred to the Security Control have emergency Emergency supplies and equipment are Site Annex.cabinets provided which contain located at various places at the plant.emergency supplies.

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.

______________________

E6-83 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description The Support Building Auditorium will No equivalent Plan/Annex statement The SNC Standard Emergency Plan maintains provide for assembly of the commitment to support the Assembly function.Maintenance, and Facilities personnel.

No protective equipment is provided for this facility; however, if required, all non-essential personnel will be evacuated to a safe location.The Support Building Cafeteria will Annex 5.7 Protective Facilities and The wording was relocated and transferred to the provide for assembly of Support Equipment (SEP J) Site Annex.Building Personnel, Service Building, Assembly Areas (SEP J.4.1)and Service Building Annex In the event of a plant evacuation, the On-Site personnel.

No protective equipment Assembly Areas (or Off-Site Assembly Areas, is provided for this facility; however, as appropriate) will be used. The function of if required, all nonessential the assembly area is to provide a center for personnel will be evacuated to a safe personnel accountability and radiological location, contamination screening, along with any other immediately necessary actions.The assembly areas are located in various buildings throughout the site. Alabama Power Company facilities may be used as the off-site assembly area at the discretion of the Emergency Director.

The off-site assembly area location will be announced over the public address system when the announcement of evacuation is made.Protective actions, including relocation of on-site 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._____________________

E6-84 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description_____________________

Contractor Personnel, MODS Annex 5.7 Protective Facilities and The wording was relocated and transferred to the Building, and ES Building Personnel Equipment (SEP J) Site Annex.will assemble in the Fabrication Assembly Areas (SEP J.4.1)Shop. After accountability, these In the event of a plant evacuation, the On-Site personnel will be evacuated if Assembly Areas (or Off-Site Assembly Areas, necessary.

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. Alabama Power Company facilities may be used as the off-site assembly area at the discretion of the Emergency Director.

The off-site assembly area location will be announced over the public address system when the 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.______________________

E6-85 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description OPS Training Center personnel and Annex 5.7 Protective Facilities and The wording was relocated and transferred to the personnel training in the OPS Equipment (SEP J) Site Annex.Training Center will assemble in the Assembly Areas (SEP J.4.1)Visitor Center Auditorium.

In the event of a plant evacuation, the On-Site Assembly Areas (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. Alabama Power Company facilities may be used as the off-site assembly area at the discretion of the Emergency Director.

The off-site 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.______________________

E6-86 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Maintenance Training Center Annex 5.7 Protective Facilities and The wording was relocated and transferred to the Personnel and personnel training in Equipment (SEP J) Site Annex.the Maintenance Training Center will Assembly Areas (SEP J.4.1)assemble in the Maintenance In the event of a plant evacuation, the On-Site Training Assembly Areas (or Off-Site Assembly Areas, Center. 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. Alabama Power Company facilities may be used as the off-site assembly area at the discretion of the Emergency Director.

The off-site 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._____________________

E6-87 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description If necessary, Alternate Assembly-Annex 5.7 Protective Facilities and The wording was relocated and transferred to the Areas will be utilized to conduct Equipment (SEP J) Site Annex.accountability and non-essential Assembly Areas (SEP J.4.1)personnel will be evacuated from the In the event of a plant evacuation, the On-Site plant site. In the event that the PAP Assembly Areas (or Off-Site Assembly Areas, becomes untenable due to accident as appropriate) will be used. The function of conditions, the Switchhouse and/or the assembly area is to provide a center for Maintenance Training Center will personnel accountability and radiological become the alternate shelter(s).

contamination screening, along with any other Protective equipment for these immediately necessary actions.locations is listed in Appendix 1 (A). The assembly areas are located in various Under extreme conditions, APCo buildings throughout the site. Alabama Power facilities that may be used as a Company facilities may be used as the off-site personnel staging area are available assembly area at the discretion of the -approximately eight miles from the Emergency Director.

The off-site assembly plant site. 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.______________________

E6-88 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

2. Decontamination and First Aid EP K.1 .2.10Onsite Responsive Action The wording was relocated and transferred to the A first aid station and a Selected plant workers at SNO-operated plants SNC Standard Emergency Plan.decontamination area are located on have received first aid and decontamination the plant site. The decontamination training.

If a plant employee cannot be easily area is located in the Auxiliary decontaminated, the individual is treated as Building at elevation 155 near the contaminated and measures are taken to Health Physics Office. The first aid prevent the spread of contamination during station is located in the Auxiliary ambulance transportation and upon arrival at a Building at elevation 155 and a local hospital.Nurses Station is located in the EP K.5 Decontamination Training/Visitors Center. Personnel Facilities and supplies for decontaminating decontamination and first aid personnel are available at various plant supplies are provided for each of the locations.

Personnel leaving the Radiological two areas. Stretchers and first aid Controlled Area (RCA) or leaving a kits are located strategically contaminated area will be monitored for throughout the plant. contamination.

During emergencies, other onsite personnel will be checked for contamination as necessary.

There is at least one person on each EP K.1 .2.10Onsite Responsive Action The wording was relocated and transferred to the shift qualified to perform first aid. Selected plant workers at SNC-operated plants SNC Standard Emergency Plan.Plant employees are considered to have received first aid and decontamination be first aid qualified upon successful training.

If a plant employee cannot be easily completion of the Company's First decontaminated, the individual is treated as Aid Course and are required to be contaminated and measures are taken to requalified within three years. prevent the spread of contamination during ambulance transportation and upon arrival at a______________________________local hospital.________________________

E6-89 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

3. Medical Transportation Annex 5.8.2 Ambulance Service (SEP B.6.2, The wording was relocated and transferred to the Request for ambulance support will L.4) Site Annex.be made by the control room or site Injured or externally contaminated personnel security to the Houston County 911 who require medical attention will normally be center, Houston County EGO, or the transported by ambulance to the cooperating incident command post, as hospitals.

Ambulance crews are trained to applicable, based on the nature and handle external contamination cases.timing of the event. Ambulance services are coordinated through the Houston County 911 center. Houston County maintains agreements with local fire and ambulance services that may respond to_____ ____ ____ ____ __ _ FN P.a. Local Rescue Squads Annex 2.3.3.1 Local Ambulance and Rescue The wording was relocated and transferred to the Ashford Rescue Squad Squads Site Annex.Columbia Rescue Squad

Ashford Rescue Squad.Dothan Ambulance Service

Columbia Rescue Squad.* Dothan Ambulance Service (Pilchers Ambulance Service), Inc.E6-90 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description 4.Medical Treatment:

EP L.1 Hospital and Medical Services The wording was relocated and transferred to the The detailed plans for the handling In addition to the on-site first aid response, SNC Standard Emergency Plan and Site Annex.and care of injured personnel arrangements have been made with local potentially contaminated and/or hospitals for treatment and evaluation of highly irradiated are contained in serious injuries or sicknesses.

Part II, Medical Plan and FNP-0-EIP-SNO-operated nuclear power plants have 11, "Handling of Injured Personnel".

arranged for hospital and medical services A brief description of the facilities having the capability to evaluate radiation and services available for medical exposure and uptake, including assurance that support is given below. Letters of persons providing these services are agreement on file from these adequately prepared to handle contaminated facilities, individuals.

The hospitals are equipped and hospital personnel trained to address contaminated injured individuals.

Training of medical support personnel at the agreement hospitals includes basic training on the nature of radiological emergencies, diagnosis and treatment, and follow-up medical care.Plant personnel are available to assist medical personnel with decontamination, radiation exposure and contamination control.Arrangements, by letter of agreement or contract, are maintained by SNC-operated plants with a qualified hospital located in the vicinity of the nuclear power plant for receiving and treating contaminated persons with injuries requiring immediate hospital care.E6-91 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

a. Southeast Alabama Medical Annex Section 2.3.2 The wording was relocated and transferred to the Center Annex 2.3.2.1 Southeast Alabama Medical Site Annex.The Southeast Alabama Medical Center Center in Dothan, Alabama, has The Southeast Alabama Medical Center in agreed to receive and care for Dothan, Alabama, has agreed to receive and injured personnel that may be care for injured personnel that may be contaminated or irradiated.

In contaminated or irradiated.

In addition to addition to routine medical care, routine medical care, space has been provided space has been provided for a for decontamination and emergency treatment decontamination and emergency and for storage of emergency medical treatment facility and for storage of equipment, monitoring equipment, and emergency medical equipment, dosimeters.

Entrance to this facility will not monitoring equipment and affect the use of the hospital emergency room.dosimeters.

Entrance to this facility will not affect the use of the hospital emergency room.b. University of Alabama Hospital Annex 2.3.2.2 University of Alabama The wording was relocated and transferred to the The Division of Oncology of the Hospital Site Annex.University of Alabama Hospital in The Division of Oncology of the University of Birmingham, Alabama, has agreed to Alabama at Birmingham (UAB) Hospital in provide, on a priority basis, definitive Birmingham, Alabama, has agreed to provide, care for irradiated and/or' on a priority basis, definitive care for irradiated contaminated casualties.

An area of and/or contaminated casualties.

An area of the hospital has been modified to the hospital has been modified to provide for provide for such radiological such radiological emergencies.

At the emergencies.

At the physicians physicians' discretion, persons who have been discretion, persons who have been exposed may be sent to UAB after receiving exposed may be sent to the treatment at the Southeast Alabama Medical University of Alabama Medical Center.Center after receiving treatment at the Southeast Alabama Medical Center.E6-92 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

c. Oak Ridgqe Institute for Science Annex 2.3.2.3 Oak Ridge Institute for The wording was relocated and transferred to the and Education

-REAC/TS Science and Education

-REACITS Site Annex.The Oak Ridge Institute for Science The Oak Ridge Institute for Science and and Education-REAC/TS team at Education-REAC/TS team at Oak Ridge, Oak Ridge, Tennessee, has agreed Tennessee, has agreed to accept any type of to accept any type of radiation radiation accident victim in need of accident victim in need of hospitalization.

At the physicians' discretion, hospitalization.

At the physician's persons who have been exposed may be sent discretion, persons who have been to ORISE-REAC/TS after receiving treatment exposed may be sent to ORISE- at the Southeast Alabama Medical Center.REAC/TS after receiving treatment at the Southeast Alabama Medical Center.IV. ASSESSMENT ACTIONS AND SECTION D: EMERGENCY The SNC Standard Emergency Plan incorporated PROTECTIVE MEASURES CLASSIFICATION SYSTEM the Classification discussion in Section 0. This A. CLASSIFICATION OF D.1 Classification of Emergencies submittal does not impact the current approved EMERGENCIES Emergency Action Level Scheme.CLASSIFICATION OF EMERGENCIES IS DESCRIBED IN See Appendix 11 (k) Justification section for the APPENDIX 11 (k) ___________________

details of the Classification Process.E6-93 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

____________________

B. POST ACCIDENT ASSESSMENT EP 1.1 To adequately assess the emergency The wording was relocated and transferred to the ACTIONS condition, applicable emergency facilities have SNC Standard Emergency Plan.Effective coordination and direction the equipment and instrumentation necessary of all elements of the emergency to monitor essential plant information, except organization require continuing where local monitoring is required.

Evaluation assessment through the duration of- of plant conditions is accomplished by the emergency situation.

In addition monitoring plant parameters from both the to continued monitoring of control Control Room and within the plant.room instrumentation and plant EP 1.2 Continuing and Post-Accident parameters, some special Assessment assessment actions are, initiated if The resources available to provide initial and appropriate.

These assessment continuing information for accident assessment functions are identified below: throughout the 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 on performing post-accident sampling are in the plant-specific procedures._______________________

E6-94 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

1. Reactor Coolant Sampling, EP 1.1 To adequately assess the emergency The wording was relocated and transferred to the Containment Atmosphere Sampling condition, applicable emergency facilities have SNC Standard Emergency Plan.and Plant Vent Stack Samplingq.

the equipment and instrumentation necessary RCS, containment atmosphere to monitor essential plant information, except and/or plant vent stack samples will where local monitoring is required.

Evaluation be taken and analyzed to assess the of plant conditions is accomplished by severity of core damage and the monitoring plant parameters from both the potential radiological consequences.

Control Room and within the plant.The detailed sampling procedures for EP 1.2 Continuing and Post-Accident each area are provided in FNP-1/2- Assessment CCP-1300, "Chemistry and The resources available to provide initial and Environmental Activities During a continuing information for accident assessment Radiological Accident".

FNP-0-EIP-throughout the course of an event include 30, "Post Accident Core Damage plant parameter display systems, liquid and Assessment" provides a method to gaseous sampling system, area and process estimate the extent of core damage radiation monitoring systems, and Accident utilizing various plant monitor Radiation Monitoring Systems. Descriptions of readings.

these systems are given in Section H. Details on performing post-accident sampling are in the plant-specific procedures._______________________

E6-95 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revision 64 Revised SNC Emergency Plan Equivalent Description Justification

2. Surveillance of Control Room Monitors Surveillance of radiological and meteorological monitors in the control room is primarily the responsibility of operations personnel.

However, in the event that offsite assessments based on this data are necessary, an individual designated by the Emergency Director will maintain surveillance over effluent monitor readings and dose projections, periodically reporting them to those designated in FNP-0-EIP-6, "TSC Setup and Activation".

If the dose assessment computer is inoperable, the designated individual will periodically log the monitor values.EP 1,i To adequately assess the emergency condition, applicable emergency facilities have the equipment and instrumentation necessary to monitor essential plant information, except where local monitoring is required.

Evaluation of plant conditions is accomplished by monitoring plant parameters from both the Control Room and within the plant.EP 1.2 Continuing and Post Accident Assessment The resources available to provide initial and continuing information for accident assessment throughout the 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 on performing post-accident sampling are in the plant-specific procedures.

The wording was relocated and transferred to the SNC Standard Emergency Plan.E6-96 Enclosure 6 to NL-1 6-01 69 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent 1Justification Revision 64 Description I____________________

3. In-Plant and Site Surveys During emergency conditions in-plant, site and site boundary surveys will be performed as appropriate by the Field Monitoring Team as described in FNP-0-EIP-4, "Health Physics Support to the Emergency Plan." The Field Monitoring Team will be capable of sampling under field conditions and will be capable of measuring radioiodine in the presence of noble gas and background radiation to as low as 5 x 10-8 uCi/cc.EP 1.7 Environs Surveys and Monitoring 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).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 determining and assessing 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.The wording was relocated and transferred to the SNC Standard Emergency Plan.E6-97 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

4. Population Exposure EP 1.30Offsite Dose Assessment The wording was relocated and transferred to the Exposure projections shall be SNC-operated nuclear power plants use an SNC Standard Emergency Plan.periodically estimated in the affected offsite dose assessment program that sectors utilizing projected dose and estimates doses from radiological accidents for The MIDAS-NU model in use for the Fleet is a full measured dose rates. The Dose comparison with the EPA Protective Action class B dose assessment mode! that supports Assessment Supervisor will work Guidance and acute health effect thresholds.

multi-unit and multi-accident modeling, while the with the state/local agency The dose calculation model is available in the ARDA program is a simple Class A dose representatives to determine the Control Room, TSC, and EOF for use in assessment model without multi-unit and multi-Total Effective Dose Equivalent projecting potential offsite doses. accident capability.

The MIDAS model meets all (TEDE) exposure (resulting from The program estimates reactor source term, existing regulatory requirements, so the ARDA external exposure and inhalation of atmospheric transport, and doses resulting program is no longer needed.the plume and external exposure from radiological emergencies and can be from deposition) and thyroid used to assist in making protective action Committed Dose Equivalent (CDE) determinations The system supplements exposure (resulting from the assessments based on plant conditions.

inhalation of radio-iodines).

5. Environs Surveys and Monitorinq EP 1.7 Environs Surveys and Monitoring The wording was relocated and transferred to the a. Short Term Assessment The initial environmental surveys involve SNC Standard Emergency Plan.Short term assessment will involve measurements to confirm or modify the dose the use of the estimates and projections based on plant parameters.

projections provided by the Subsequent environmental monitoring efforts emergency dose calculation will be aimed at further defining the offsite computer programs performed in consequences, including instituting an accordance with NMP-EP-104, expanded monitoring program to enable"Dose Assessment".

prompt assessments of any subsequent releases from the plant.______________________

E6-98 Enclosure 6 to NL-1 6-01 69 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Onsite and offsite surveys will be EP 1.30Offsite Dose Assessment The wording was relocated and transferred to the performed as necessary to verify SNC-operated nuclear power plants use an SNC Standard Emergency Plan.release information or as a backup offsite dose assessment program that assessment method should the estimates doses from radiological accidents for The MIDAS-NU model in use for the Fleet is a full instrumentation used for dose comparison with the EPA Protective Action class B dose assessment model that supports assessment go off-scale or become Guidance and acute health effect thresholds.

multi-unit and multi-accident modeling, while the inoperable.

The dose calculation model is available in the ARDA program is a simple Class A dose Control Room, TSC, and EOF for use in assessment model without multi-unit and multi-projecting potential offsite doses, accident capability.

The MIDAS model meets all The program estimates reactor source term, existing regulatory requirements, so the ARDA atmospheric transport, and doses resulting program is no longer needed.from radiological emergencies and can be used to assist in making protective action determinations The system supplements assessments based on plant conditions.

E6-99 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent

[Justification Revision 64 Description_____________________

Monitoring teams will normally be dispatched in vehicles and will be equipped with two-way radios for communication with the TSC or EOF.EP 1.7 Environs Surveys and Monitoring 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).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 determining and assessing 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.The wording was relocated and transferred to the SNO Standard Emergency Plan.E6-100 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Teams will be equipped with liquid EP 1.7 Environs Surveys and Monitoring The wording was relocated and transferred to the sampling equipment, a GM In addition to the capabilities and resources SNO Standard Emergency Plan.instrument, an ion chamber described in Section H, SNO-operated nuclear instrument, and/or an air sampler as power plants have the ability to take offsite air deemed appropriate by the samples and to directly measure gamma dose Emergency Director, Health Physics rates from a radioactive material release. The Supervisor or Dose Assessment capability to take offsite soil, water, and Supervisor.

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 determining and assessing 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 OEO staff.______________________

E6-101 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description An environs survey team could be in EP 1.7 Environs Surveys and Monitoring The wording was relocated and transferred to the the field within one hour. In addition to the capabilities and resources SNC Standard Emergency Plan.Radiological survey and sampling described in Section H, SNO operated nuclear points will be identified by sector as power plants have the ability to take offsite air shown in Figure 20. 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).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 determining and assessing 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.______________________

E6-102 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description The correlation of various measured EP 1.7 Environs Surveys and Monitoring The wording was relocated and transferred to the parameters (contamination levels, In addition to the capabilities and resources SNC Standard Emergency Plan.water and air activities) to dose rates described in Section H, SNC operated nuclear for key isotopes and gross power plants have the ability to take offsite air radioactivity levels is provided by samples and to directly measure gamma dose FNP-0-RCP-25.

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 determining and assessing 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.______________________

E6-103 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

b. Long Term Assessment No equivalent Plan/Annex statement Long term assessment will be event-specific and The long term aspects involving subject to ORO control in conjunction with the offsite assessments of contamination FRMAC if required.

The statement was not involving analysis of soil, vegetation, carried forward to the SNC Standard Emergency food, milk and water will be primarily Plan.handled by the states of Alabama, Georgia, and Florida as discussed in their Radiological Emergency Plans.The response of SNC would be to increase the sampling frequency of its established environmental monitoring program.C. PROTECTIVE ACTIONS AND SECTION J" PROTECTIVE RESPONSE The wording was relocated and transferred to the EMERGENCY ACTION LEVELS Protective response consists of emergency SNC Standard Emergency Plan.The nature of protective actions to be actions, taken during or after an emergency implemented, the criteria for situation, which are intended to minimize or application, and the area involved or eliminate hazards to the health and safety of the groups of persons for whom the public and plant personnel.

Protective actions protective actions would be taken are have been developed for emergency workers given here. and the general public located in the Plume Exposure Pathway Emergency Planning Zone.Guidelines consistent with federal guidance have been established to aid in choosing protective actions during an emergency.

The responsibility for actions outside the owner-controlled area rests with state, county, and other offsite response agencies._______________________

E6-104 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

1. Onsite Protective Action EP J.4,3 Site Evacuation The wording was relocated and transferred to the a. Evacuation In the event of a If a Site Evacuation is required, personnel are SNC Standard Emergency Plan.Notification of Unusual Event an area directed to either assemble within designated of the turbine building, auxiliary Assembly Areas or immediately leave the site.building, or containment may have to Personnel will be directed to either proceed to be evacuated.

Personnel would be their homes or reassemble at designated notified to evacuate the affected area locations.

Visitors to the plant will assemble via the public address system as with and follow the instructions of their escorts.directed by the Emergency Plan Personal transportation will normally be used Implementing Procedures.

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.Should a Site Area Emergency, General Emergency, or an Alert be declared, immediate notification of all persons onsite may be accomplished by sounding the Plant Emergency Alarm and announcing the condition over the plant public address system.Personnel onsite would report to their pre-assigned assembly area and preparations for evacuation of nonessential persons from the site would begin. Depending on the severity of the emergency condition, these individuals will be held in an assembly area, evacuated, or returned to work.EP J.4.1 Assembly Assembly is mandatory following the declaration of a Site Area or General Emergency, or at the discretion of the Emergency Director.

When Accountability of onsite personnel is determined to be necessary by the Emergency Director, personnel within the Protected Area will be accounted for and the names of missing individuals determined within 30 minutes of the emergency declaration.

The wording was relocated and transferred to the SNC Standard Emergency Plan.E6-105 Enclosure 6 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description_____________________

If a site evacuation is warranted, EP J.4.3 Site Evacuation The wording was relocated and transferred to the personnel will be advised as to which If a Site Evacuation is required, personnel are SNC Standard Emergency Plan.routes should be used. The normal directed to either assemble within designated routes are State Highway 95 North or Assembly Areas or immediately leave the site.South and County Road 42 West Personnel will be directed to either proceed to (Figures 17 and 19). All personnel their homes or reassemble at designated being evacuated from the site will be locations.

Visitors to the plant will assemble monitored before being released.

with and follow the instructions of their escorts.Personnel leaving the site would Personal transportation will normally be used then proceed, in their own vehicles, and established evacuation routes will be on one of these major routes, to their followed.

Personnel without transportation will residences.

Transportation for be identified and provided transportation as persons without vehicles will be necessary.

arranged.

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.The details for evacuation and EP J.4.3 Site Evacuation The wording was relocated and transferred to the personnel accountability of all If a Site Evacuation is required, personnel are SNC Standard Emergency Plan.categories of personnel listed above directed to either assemble within designated are given in FNP-0-EIP-10, Assembly Areas or immediately leave the site."Evacuation, Personnel Personnel will be directed to either proceed to Accountability, and Site Dismissal" their homes or reassemble at designated and FNP-0-EIP-14 "Emergency.

locations.

Visitors to the plant will assemble Response Teams". 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.E6-106 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

b. Personnel Accountability EP J.4.2 Accountability The wording was relocated and transferred to the Each plant supervisor or the senior Personnel accountability is mandatory at the SNC Standard Emergency Plan.individual onsite from his group is Site Area or General Emergency classification.

responsible for accounting for all Accountability may be initiated at other times persons working in or visiting his at the discretion of the Emergency Director to group. Accountability within the support worker safety.Protected Area will be determined by Accountability of personnel within the the senior individual at the assembly Protected Area is accomplished within 30 area coordinating with the Security minutes of the declaration of Site Area Response Center (SRC) and then Emergency or higher, and maintained will be reported to the Emergency continuously thereafter, using Protected Director by the senior plant security Area(s) boundary access control as described force member at the SRC. in the Security Plan. If there are station Accountability within the Controlled personnel who are unaccounted for, the public Area will be determined by the senior address system or other suitable individual at each assembly area communication methods are used to locate the coordinating with the Security personnel, or, in extreme cases such as fire, Response Center (SRC) Staff and toxic gas release, explosions, or structural then will be reported to the damage, trained search and rescue personnel Emergency Director by the senior are deployed to search for and assist the individual in the SRC. Contractor missing personnel.

personnel assigned to Plant Modification and Maintenance Support (PM MS) report to the Fabrication Shop and will assemble by individual craft. Fitness for Duty Facility personnel outside the Protected Area report to the Visitor's Center Auditorium No public access areas pass through No equivalent Plan/Annex statement The Security Patrols referenced in the current or are within the owner controlled Plan statement are a function of Security Plan not area. The owner controlled area is Emergency Plan requirements.

fenced and/or posted. Security patrols are conducted at random intervals as a part of daily routine.E6-107 Enclosure 6 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Detailed procedures for determining EP J.4.2 Accountability The wording was relocated and transferred to the and reporting accountability and Personnel accountability is mandatory at the SNC Standard Emergency Plan.Responsibilities for accountability Site Area or General Emergency, classification.

during local evacuations are given in Accountability may be initiated at other times FN P-0-EI P-10, "Evacuation, at the discretion of the Emergency Director to Personnel Accountability, and Site support worker safety.Dismissal".

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 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._______________________

E6-108 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Following accountability initiation, EP J.4.2 Accountability The wording was relocated and transferred to the security personnel will control site Personnel accountability is mandatory at the SNC Standard Emergency Plan.access and egress for the duration of Site Area or General Emergency classification.

the emergency, maintaining Accountability may be initiated at other times entry/exit logs to allow accountability at the discretion of the Emergency Director to of all personnel onsite. 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 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.

c. Hostile Action Protective EP J.40Onsite Protective Actions The wording was relocated and transferred to the Measures Onsite protection of employees during hostile SNC Standard Emergency Plan.Onsite protection of employees action involves a combination of restricted during hostile action involves a movement, movement to safe locations, and combination of restricted movement, site evacuation depending on the nature of the movement to safe locations, and site hostile event and advance warning. Site-evacuation depending on the nature specific procedures provide specific actions to of the hostile event and advance take during hostile action or severe weather warning. Site procedures provide events. During a hostile action or severe specific actions to take during hostile weather event, Assembly and Accountability action based events. These actions actions may be delayed in favor of other onsite will be communicated to onsite protective actions required to ensure the safety personnel via the plant PA system of the site and its personnel.

In these cases, and other communications means as accountability will be completed once safe applicable, conditions have been established.

E6-1 09 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

c. Contamination and Exposure EP K.1 Under normal operating conditions, The wording was relocated and transferred to the Control Measures SNO-operated plants maintain personnel SNC Standard Emergency Plan.The limits for personnel exposure set exposure control programs in accordance with forth in 100FR20 shall not be 10 CER 20. The Emergency Director has exceeded without approval of the responsibility for authorizing personnel Emergency Director or his designee, 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." E6-1 10 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

1) Farley Nuclear Plant EP Table K.I.A The wording was relocated and transferred to the personnel who have SNC Standard Emergency Plan.completed the onsite radiation protection training, may receive 0 10 Remn When emergency onsite action is required to eliminate a source or potential source that represents a hazard to the general public or to prevent a substantial loss in property and a lower dose is not practicable.

o 25 Rem For life-saving operations such as rescue and search for known missing persons or for protection of large populations when a lower dose is not practicable.

0 >25 Rem but not to exceed 100 Rem For lifesaving or protection of large populations only on a voluntary basis. The volunteer worker should do so with full awareness of the associated risks for the radiation dose to be incurred.E6-111 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

2) Hospital and Ambulance EP Table K.I.A The wording was relocated and transferred to the Service Personnel, may SNC Standard Emergency Plan.receive o 3 Rem If there is an adequate number of attendants such that rotation may be accomplished without further endangering the patient(s).

o05 Remn If the number of attendants is limited such that personnel cannot be rotated.o 25 Rem To save a life.E6-112 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Dosimetry, respiratory protection equipment and protective clothing will be issued for use in accordance with established Radiological Control Procedures.

A supply of radio protective drugs (potassium iodide)is available onsite and, if necessary, will be issued at the direction of the Emergency Director to emergency personnel remaining or arriving onsite.EP J.40Onsite Protective Actions Onsite protective actions for routine and emergency conditions are detailed in the plant's Radiation Protection Program. SNC-operated nuclear power plants maintain an inventory of respiratory protection equipment, anti-contamination clothing, and potassium iodide (KI) that is available to emergency workers remaining on site. During an emergency, protective actions would be taken to minimize radiological exposures or contamination affecting onsite personnel.

Measures which would be taken are:* On-shift and emergency response personnel use respiratory protection in any environment involving exposure to high level airborne activity or oxygen deficient atmosphere, or where air quality is in doubt. The criteria for issuance of respiratory protection are described in plant Radiation Protection procedures.

Anti-contamination clothing is available for use by onsite personnel.

The criteria for issuance of protective clothing are described in plant Radiation Protection procedures.

The criteria for administering a thyroid-blocking agent (KI -Potassium Iodide) to emergency personnel depends on the projected absorbed dose to the thyroid based on the severity and magnitude of the accident.The wording was relocated and transferred to the SNO Standard Emergency Plan.E6-113 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description____________________

The levels of permissible radioactive No equivalent PlanlAnnex statement The release of material will be a function of post contamination for personnel and emergency plan actions and potentially ORO equipment to be released from an evaluation.

RCA during an emergency are as follows: Personnel Equipment<5,000 dpm/100 cm2 ND GMT/100 cm2 (smearable)

And < .25 mR/hr (fixed)E6-114 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan ]Revised SNC Emergency Plan Equivalent 1Justification Revision 64 Description_____________________

However, the Emergency Director may authorize higher levels based on plant conditions and recommendations from the HP Supervisor.

When levels above these values are encountered, decontamination will be initiated.

Facilities, supplies and waste disposal capability exists to provide for both personnel (emergency or onsite relocated) and equipment decontamination.

Methods for equipment decontamination are discussed in NMP-HP-304, "Decontamination of Areas, Tools, and Equipment" and for personnel in NMP-HP-303,"Personnel Decontamination" with particular attention being given to radioiodine contamination of the skin.Extra clothing for personnel will be provided in the event personal clothing is confiscated.

Information on personnel decontamination facilities is contained in Section III.EP K.1 Under normal operating conditions, SNC-operated plants maintain personnel exposure control programs in accordance with 10 CFR 20. 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." EP K.5 Decontamination The Radiation Protection Group will be responsible for controlling or minimizing direct or subsequent internal exposure from 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 on-site 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.The wording was relocated and transferred to the SNC Standard Emergency Plan.E6-1 15 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description To prevent or minimize direct or EP K.5 Decontamination The wording was relocated and transferred to the subsequent ingestion exposure to The Radiation Protection Group will be SNC Standard Emergency Plan.radioactive materials deposited on responsible for controlling or minimizing direct the ground or other surfaces, access or subsequent internal exposure from into the exclusion area will be radioactive materials deposited on the ground controlled by security personnel.

or other surfaces, and for determining the Additionally, if conditions warrant, the extent of contamination in controlled and site drinking water will be sampled normally uncontrolled areas. During normal and analyzed for radioactivity and conditions or an emergency, guidelines to quarantined, if necessary.

If a follow for contamination limits are established quarantine is placed on the water, it by the site radiation protection program.will not be returned to use until the activity has returned to within acceptable limits as dictated by the State of Alabama Board of Health"Regulations Governing Public Water Supplies".

Personnel which are found to be EP K.70Qffsite Decontamination The wording was relocated and transferred to the contaminated when monitored during Nonessential onsite personnel may be SNO Standard Emergency Plan.evacuation will be returned to the evacuated to an offsite reception center or plant for deconning if possible.

If the assembly area, as discussed in Section J.plant is not accessible, the personnel Radiological controls personnel at that location will be transported to the nearest will monitor evacuees and determine the need decontamination facility, for decontamination.

In the event that decontamination of evacuees locally is not possible, personnel can be sent to designated locations for monitoring and decontamination.

Offsite contamination controls are EP K.70Ofisite Decontamination The wording was relocated and transferred to the described in the states of Alabama, Nonessential onsite personnel may be SNO Standard Emergency Plan.Georgia, and Florida plans. evacuated to an offsite reception center or assembly area, as discussed in Section J.Radiological controls personnel at that location will monitor evacuees and determine the need for decontamination.

In the event that decontamination of evacuees locally is not possible, personnel can be sent to designated locations for monitoring and decontamination.

E6-116 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

2. Offsite Protective Action Annex 4.4 Protective Actions for the Offsite The wording was relocated and transferred to the The states of Alabama, Georgia, and Public (SEP J.5) SNC Standard Emergency Plan.Florida are responsible, in their The Emergency Director will recommend the respective state, for handling the necessary protective actions to offsite offsite radiological aspects of any authorities, based on predetermined protective emergency that should develop at actions for a General Emergency Classification the Farley Nuclear Plant. The or results of offsite dose assessment.

Upon Emergency Plans for Alabama, activation of the EOF, the EOF Manager will Georgia, and Florida are given in be responsible for recommending protective each states Radiological Emergency actions for the offsite population.

Plan. Responsibility for carrying out the protective actions rests with offsite authorities.

________________________

E6-117 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description The criteria to be used for offsite EP J.50Offsite Protective Action The wording was relocated and transferred to the protective action recommendations is Recommendations (PARs) SNC Standard Emergency Plan.given below. The basis for protective Plant conditions, projected dose and dose action guides is the "Manual of rates, field monitoring data, and evacuation Protective Action Guides and time estimates are evaluated to develop PARs Protective Action for Nuclear for preventing or minimizing exposure to the Incidents", EPA-400-R-92-001.

It public. PARs are provided to the offsite should be noted that these levels are agencies responsible for implementing quite low and are used as guidelines protective actions for the public within the 10-for protective action rather than rigid mile EPZ. The Emergency Director will levels of action. Recommendation of approve PARs. The PAR decision-making sheltering in residences shall be flowcharts are site-specific in nature, and are considered when there is radiological provided in the site-specific implementing puff release that exceeds the procedures.

SNO-operated plants have the projected dosage for a general capability to provide state and local agencies a emergency listed in section a below PAR for beyond the 10-mile EPZ.or there are hazards on or offsite that There are various types of protective actions would make an evacuation that can be recommended to the state and dangerous.

Areas within a ten mile counties.

They may include the following:

radius in which protective action is

Evacuation.

deemed necessary will be referred to

Shelter in place.by Evacuation Zone as shown in

Monitor and prepare.Figure 21. The population distribution

Thyroid blocking agent (consider using within this ten-mile radius has been KI (potassium iodide)) in accordance with predicted for the life of the plant and state plans and policy.is summarized graphically in Figure 22.a. Classification of Offsite Incidents .No equivalent Plan/Annex statement This section restates numerically the EPA SNC Protective Action Guidelines previously committed Classification -to. They are also the trigger for the equivalent Projected Dosage (Organ or Media radiologically based Emergency Action Levels in Involved) the site approved EALs.GENERAL 1.0 Rem TEDE 5.0 Remn Thyroid ODE The data is not needed in the plan.SITE AREA 0.1 Rem TEDE 0.5 Rem Thyroid ODE E6-118 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

b. Response EP J.50Offsite Protective Action The wording was relocated and transferred to the Recommendations (PARs) SNC Standard Emergency Plan.GENERAL Plant conditions, projected dose and dose rates, field monitoring data, and evacuation Classification Protective Actions to time estimates are evaluated to develop PARs be Recommended to State for preventing or minimizing exposure to the Authorities public. PARs are provided to the offsite agencies responsible for implementing NMP-EP-1 12, "Protective Action protective actions for the public within the 10-Recommendations," provides mile EPZ. The Emergency Director will detailed guidance on the approve PARs. The PAR decision-making methodology and determination of flowcharts are site-specific in nature, and are protective action recommendations provided in the site-specific implementing (PARs). PARs were developed in procedures.

SNC-operated plants have the accordance with NUREG-0654 capability to provide state and local agencies a Supplement 3 Rev. 1. Evacuation PAR for beyond the 10-mile EPZ.Time Estimates and Offsite There are various types of protective actions Response Organizations were fully that can be recommended to the state and involved in the development of the counties.

They may include the following:

PARs.

Evacuation.

The Emergency Director will approve

Shelter in place.the PAR decision developed by the ° Monitor and prepare.methodology in the Initial and Follow-

Thyroid blocking agent (consider using Up Flowcharts, shown as Chart 1, KI (potassium iodide)) in accordance with Initial and Chart 2, Follow-Up, state plans and policy.Recommendations will be based on plant conditions, projected dose estimates, or available monitoring data.E6-1 19 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description SITE AREA EP J.50Offsite Protective Action The wording was relocated and transferred to the Recommendations (PARs) SNO Standard Emergency Plan.Classification Protective Actions to Plant conditions, projected dose and dose be Recommended to State rates, field monitoring data, and evacuation Authorities time estimates are evaluated to develop PARs for preventing or minimizing exposure to the No Protective Action public. PARs are provided to the offsite Recommendations are to be made at agencies responsible for implementing the Site Area emergency level. The protective actions for the public within the 10-Emergency Director should upgrade mile EPZ. The Emergency Director will to a General approve PARs. The PAR decision-making Emergency if PARs are determined flowcharts are site-specific in nature, and are to be needed and not already in a provided in the site-specific implementing General Emergency.

procedures.

SNC operated plants have the capability to provide state and local agencies a PAR for beyond the 10-mile EPZ.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 using KI (potassium iodide)) in accordance with state plans and policy.______________________

E6-120 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description ALERT EP J.50Qffsite Protective Action The wording was relocated and transferred to the Recommendations (PARs) SNC Standard Emergency Plan.Classification Protective Actions to Plant conditions, projected dose and dose be Recommended to State rates, field monitoring data, and evacuation Authorities time estimates are evaluated to develop PARs for preventing or minimizing exposure to the No Protective Action public. PARs are provided to the offsite Recommendations are to be made at agencies responsible for implementing the Alert level, protective actions for the public within the 10-The Emergency Director should mile EPZ. The Emergency Director will upgrade to a General Emergency if approve PARs. The PAR decision-making PARs are determined to be needed flowcharts are site-specific in nature, and are and not already in a General provided in the site-specific implementing Emergency.

procedures.

SNO operated plants have the capability to provide state and local agencies a PAR for beyond the 10-mile EPZ.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 using KI (potassium iodide)) in accordance with state plans and policy.______________________

E6-1 21 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Rvso64Description_____________________

The authority for initiation or EP B.1 .1 The Emergency Director's non- The wording was relocated and transferred to the relaxation of protective action delegable duties include: SNC Standard Emergency Plan.recommendations is vested solely

Perform the duties and responsibilities of with the Emergency Director and Protective Action Recommendation (PAR)may not be delegated to any other determination.

member of the emergency organization.

Processes for development, approval, and notification of protective action recommendations are described in NMP-EP-111, "Emergency Notifications", and NMP-EP-1 12"Protective Action Recommendations".

Chart 1 Initial Protective Actions No equivalent Plan/Annex chart Section J5 of the SNC Standard Emergency Plan Recommendations specifies the requirement to make Protective Action Recommendations consistent with NUREG-0654 Supplement

3. PAR flowcharts are controlled at the procedural level.Chart 2 Follow Up Protective Action No equivalent Plan/Annex chart Section J5 of the SNC Standard Emergency Plan Recommendations specifies the requirement to make Protective Action Recommendations consistent with NUREG-0654 Supplement

3. PAR flowcharts are controlled at the procedural level.V. ACTIVATION OF EMERGENCY EP B.1 .1 The ED has the responsibility and The wording was relocated and transferred to the ORGANIZATION authority to immediately and unilaterally initiate SNC Standard Emergency Plan.A. DECLARATION OF AN emergency actions, including providing EMERGENCY notification of Protective Action The Shift Manager shall have the Recommendations (PAR) to state and local authority and responsibility to government organizations responsible for immediately and unilaterally declare implementing offsite emergency measures.an emergency and initiate emergency response.

Section IV of this plan delineates criteria for declaring emergency conditions.

E6-1 22 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Upon declaration of an emergency EP B.1 .1 The Shift Manager (SM) is in direct The wording was relocated and transferred to the the Shift Manager will immediately charge of shift plant operations and is directly SNO Standard Emergency Plan.notify the on-call Emergency Director responsible for the actions of the on-shift crew.(ED). Until the on-call ED arrives In an emergency, the SM assumes the onsite and relieves the Shift responsibility of the Emergency Director (ED)Manager, the Shift Manager shall and takes necessary actions to identify and complete the duties of the ED prior to respond to the emergency until relieved by the on-call ED taking full another qualified ED.responsibility for implementation of the Emergency Plan. Duties of the Shift Manager as an Emergency Director are addressed in NMP-EP-110, "Emergency Classification Determination and Initial Action' and NMPEP-111, "Emergency Notifications".

______________________

The ED, Shift Clerk, or designee will EP B.1 .1 The ED, at their discretion or when The SNC Standard Emergency Plan fully notify the EOF Manager of the procedurally required, activates the ERO. incorporates EQF activation into the site emergency condition.

The EOF organization.

Activation will be driven by event Manager will decide on the Classification.

The statement determining the appropriate level of activation need to activate is no longer required.utilizing the criteria shown in Table 4.B. ORGANIZATION ACTIVATION EP B.1 The number and ERO position titles of The wording was relocated and transferred to the The minimum quantity of personnel personnel available within 75 minutes following SNC Standard Emergency Plan and Site Annex.available on shift and the quantity of declaration of an Alert or higher classification additional personnel available within are shown in Tables 1, 2 and 3.75 minutes following declaration of the emergency to staff the emergency organization are shown in Table 3. A copy of the On-Shift Staffing Analysis which forms the technical basis for Minimum Shift Staffing provided in Table 3 is maintained in the SNC document management system. Reference OSA-FNP-001._________________

_____________

_____E6-123 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Each shift shall have a Shift Annex Table 2.2.A The wording was relocated and transferred to the Technical Advisor (STA). The STA Site Annex.will have No duties or responsibilities for manipulation of controls or command of operations during an emergency.

The normal shift crew will consist of EP B.1:* The normal on-site organization of an For Emergency Response purposes the at least those positions listed as "on SNC-operated nuclear power plant provides a operations staff has been validated by the shift" in Table 3. There will be a staff fully capable of providing the initial conduct of a staffing analysis meeting the licensed operator in each unit's response to an emergency event, requirements of 10 CFR 50 Appendix E.IV.A.9.control room at all times when fuel is Annex Section 2.1 : The normal plant in the core of the .respective unit. operating crew is staffed and qualified to Emergency Plan staffing will be controlled by the There will be a Senior Reactor perform actions that may be necessary to staffing plan contained in the SNC Standard Operator (SRO) in the control room initiate immediate protective actions and Emergency Plan and Site Annex.(shared) at all times when fuel is in implement the emergency plan, and is either core. Shift staffing for core designated as the responsible group for such The commitment for positioning of ROs/SROs is alterations will also include either a actions. not contained in the Fleet Emergency Plan or SRO limited to fuel handling or a annex but is a Technical Specification SRO not assigned any duties requirement.

concurrent with core alterations.

Upon receiving notification of an EP B.1 .1 In an emergency, the SM assumes The wording was relocated and transferred to the emergency, the Emergency Director the responsibility of the Emergency Director SNC Standard Emergency Plan.will proceed to the site. A shift (ED) and takes necessary actions to identify communicator will coordinate the and respond to the emergency until relieved by plant call list to notify those another qualified ED.individuals of the Emergency The ED, at their discretion or when Organization needed to meet initial procedurally required, activates the ERO.activation requirements.

The EOF Manager will be notified in accordance with NMP-EP-1 10,"Emergency Classification Determination and Initial Action". _____________________

E6-124 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description During hostile action based events, EP H.1 .4 Alternative Facilities The wording was relocated and transferred to the ERO members would likely not have An Alternative Facility for staging of ERO SNC Standard Emergency Plan.access to the onsite emergency personnel has been designated at the sites. In response facilities.

A security related the event of a Security or Hostile Action threat emergency may delay the ordering of or event, the designated Alternative Facility facility activation in order to protect may also serve as an evacuation location for plant personnel form the security TSC and OSC personnel.

The Alternative threat. The decision to delay Facility is designed to be accessible in the activation of the facilities will be event of an onsite HAB event and has the made by the Emergency Director.

In capability to: such cases, offsite ERO personnel

Communicate with the Control Room, will be directed to an alternative Security, and the EOF.facility to minimize delays in overall ° Conduct engineering assessment site response by permitting ERO activities including damage control team assembly without exposing planning and preparation.

responders to the danger of hostile The functions of Notification and PARs will be action. performed from the EOF should the Alternative Facility be activated.

Details of Alternative Facilities can be found in the Site Specific Annex.Criteria for the activation of the EP Figures B.2.B through B.2.E The wording was relocated and transferred to the Technical Support Center, SNC Standard Emergency Plan.Operations Support Center, and Emergency Operations Facility are shown in Table 4.E6-125 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description_____________________

1. Technical Support Center EP H.10Onsite Emergency Response The wording was relocated and transferred to the Activation Facilities SNC Standard Emergency Plan.The onsite emergency response SNC-operated nuclear power plants have organization which will be directed established a Technical Support Center (TSC)from the TSC is described in Section and an onsite Operations Support Center I1. The TSC will be staffed and ready (0S0), which are staffed and activated within-to receive emergency response 75 minutes of the declaration of an Alert or functions by the following on-call higher classification.

individuals within 75 minutes EP Figure B.2.B following declaration of an emergency requiring TSC activation:

Emergency Director TSC Manager Operations Supervisor Health Physics Supervisor Engineering Supervisor Maintenance Supervisor ENN Communicator.

Within eight hours of the declaration EP B.1 SNC plants maintain 24-hour The wording was relocated and transferred to the of the emergency one full emergency response capability.

The normal SNC Standard Emergency Plan.complement of personnel as on-shift complement provides the initial designated above will be available to response to an emergency.

This group is relieve the TSC personnel.

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._______________________

E6-126 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description There shall be sufficient personnel EP B.1 SNC plants maintain 24-hour The wording was reiocated and transferred to the available within 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months of the emergency response capability.

The normal SNC Standard Emergency Plan.declaration of the emergency to on-shift complement provides the initial ensure that the TSC can be staffed response to an emergency.

This group is on a 24-hour-a-day basis for at least trained to respond to emergency situations one week 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.2. Operations Support Center (0SC) EP H.10Onsite Emergency Response The wording was relocated and transferred to the Activation Facilities SNC Standard Emergency Plan.The Operations Support Center will SNC-operated nuclear power plants have be staffed and ready to provide established a TSC and an onsite OSC, which See separate justification related to augmentation support to the emergency response are staffed and activated within 75 minutes of timeliness.

effort as directed by the Emergency the declaration of an Alert or higher Director within 75 minutes following classification.

declaration of an emergency EP Figure B.2.C requiring OSO activation.

Other members of the Emergency No equivalent Plan/Annex statement The Plan specifies reporting responsibilities for Organization arriving at the plant will members of the ERO and assembly/evacuation report to their assigned assembly responsibilities for all others.areas.Within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months after declaration of an EP H.10Onsite Emergency Response The wording was relocated and transferred to the emergency, sufficient personnel shall Facilities SNC Standard Emergency Plan.be available in the 0S0 to ensure SNO operated nuclear power plants have that shift personnel can be relieved established a TSC and an onsite OSC, which by qualified individuals, are staffed and activated within 75 minutes of the declaration of an Alert or higher classification.

________________________EP Figure B.2.C E6-127 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Within 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months after declaration of EP H.10Onsite Emergency Response The wording was relocated and transferred to the an emergency, sufficient personnel Facilities SNO Standard Emergency Plan.shall have been notified and placed SNC-operated nuclear power plants have on-call to ensure that the 080 can established a TSC and an onsite 0S0, which be staffed on a 24-hour-a-day basis are staffed and activated within 75 minutes of for at least one week. the declaration of an Alert or higher classification.

EP Figure B.2.C 3. Emerqiency Operations Facility EP H.2.1 Emergency Operations Facility The wording was relocated and transferred to the (EOF) Activation The EOF is the central location for SNC Standard Emergency Plan.The corporate emergency response management of the offsite emergency organization which will be activated response, coordination of radiological to respond from the EOF is assessment, and management of initial described in Appendix 7(G). recovery operations.

The EOF is a dedicated facility located in Birmingham, Alabama, and serves as the EOF for SNC sites (VEGP, FNP, and H NP). Staffing and activation of the EOF is mandatory upon declaration of an Alert or_____________________________higher classification._______________________

E6-1 28 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

4. Alternative Facility Activation EP H.1.4 Alternative Facilities The wording was relocated and transferred to the The ERO staff will be directed to An Alternative Facility for staging of ERO SNC Standard Emergency Plan.report to the Alternative Facility personnel has been designated at the sites.during a security related event, or In the event of a Security or Hostile Action other events that preclude onsite threat or event, the designated Alternative access. This facility functions as a Facility may also serve as an evacuation staging area for augmentation of location for TSC and OSO personnel.

The emergency response staff and Alternative Facility is designed to be provides the capability for accessible in the event of an onsite HAB communication with the EOF, control event and has the capability to: room, and plant security.

From this

Communicate with the Control Room, facility the ERO will support event Security, and the EOF.response by performing engineering

Conduct engineering assessment assessment activities, including activities including damage control team damage control team planning and planning and preparation.

preparation for return to the site. The The functions of Notification and PARs will command and control function will be performed from the EOF should the remain with the ED in the control Alternative Facility be activated.

Details of room until relieved by another onsite Alternative Facilities can be found in the Site ED. Dose assessment and offsite Specific Annex.notifications will be performed by the EOF. Procedural guidance for the alternative facility is provided in NMP-EP-1 35, Alternative Facility Setup and Operation.

C. OFFSITE CORPORATE EP H.2.1 Emergency Operations Facility The wording was relocated and transferred to the ORGANIZATION ACTIVATION The EOF is the central location for SNC Standard Emergency Plan.The corporate emergency response management of the offsite emergency organization which will be directed response, coordination of radiological from the EOF is described in assessment, and management of initial Appendix 7(G). The corporate recovery operations.

The FOF is a dedicated Emergency Communication facility located in Birmingham, Alabama, and Organization activation is described serves as the EOF for SNC sites (VEGP, FNP, in Appendix 10(J). and HNP). Staffing and activation of the EOF is mandatory upon declaration of an Alert or higher classification.

E6-129 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description D. OFFSITE LOCAL, STATE AND EP H.3 State and local Emergency The wording was relocated and transferred to the FEDERAL AG ENCIES Operations Centers (EOC) SNC Standard Emergency Plan.Notification of offsite governmental EQOs operated by the state and by local agencies is discussed in Section VI. communities allow direction and control of Activation of the state agencies is emergency response functions.

The states'discussed in their respective plans. EOCs are capable of continuous (24-hour)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 in the state and county emergency plans.Section VI: Figure 24 illustrates the EP E.1.1: SNC, in cooperation with state and The commitment/process of notification was order and responsibilities for county authorities, has established methods maintained as currently described in Figure 24 of notification in the event of an and procedures for notification of offsite the Farley Plan. The figure was deleted and the emergency.

response organizations consistent with the process described in words in the Plan/Annex emergency classification and emergency sections.action level scheme.Annex Section 4.1.1: State and local counties surrounding FNP will be notified within 15 minutes of the declaration of an emergency Condition State of Alabama:* Alabama Emergency Management Agency (AEMA).Alabama County Authorities

Houston County Sheriff's Dispatcher's Office.State of Georqiia:* Georgia Emergency Management Agency (G EMA).Georcqia County Authorities:

Early County Sheriff's Dispatcher's Office.E6-130 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description*

Table 3 No title (Facility Staffing)

EP 0.4 ERO Training The wording was relocated and transferred to the SNC ERO personnel who are responsible for SNC Standard Emergency Plan.implementing this plan receive specialized training.

The training program for emergency response personnel is 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.EP 0.4.1 Emergency Response Organization (ERO)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.E6-1 31 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Table 4: Emergency Facility EP B.2 On Site Emergency Response The wording was relocated and transferred to the Activation Organization (ERO) SNC Standard Emergency Plan.Augmentation of on-shift staffing will occur within 75 minutes of the declaration of an Alert or higher classification by the Emergency Response Organization (ERO). ERO positions for the (TSC), Operations Support Center (OSO), Emergency Operations Facility (EOF), and JIC are detailed below. A sufficient number of personnel are qualified to ensure that positions listed in this section can be staffed on a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months a day basis for an extended event.VI. NOTIFICATION PROCEDURES EP F.1.1 At SNC-operated nuclear power The wording was relocated and transferred to the FNP-0-EIP-8.1, "Emergency Phone plants, several modes of reliable SNC Standard Emergency Plan.Directory", contains a listing (updated communication are available, during both quarterly) of the names, addresses, normal and emergency conditions, to transmit and telephone numbers of the and receive information among the Control individuals and organizations Room, TSC, OSC, EOF, and other locations referred to in this section. A copy of onsite and offsite including the Joint FNP-0-EIP-8.1 will be maintained in Information Center near the SNC site. Reliable the control room and by the on-call primary and backup means of communication Emergency Director.

have been established.

The use of the communications systems during normal and emergency conditions has been integrated into plans, procedures, and the training program.Figure 24 illustrates the order and No equivalent Plan/Annex figure The Plan provides the commitment for the various responsibilities for notification in the notification types and processes required to event of an emergency.

effectively implement the Emergency Plan.E6-132 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description An authentication method is used to -EP E.1 .1 SNO, in cooperation with state and The wording was relocated and transferred to the verify any notifications made by FNP county authorities, has established methods SNC Standard Emergency Plan.utilizing commercial telephones.

and procedures for notification of offsite response organizations consistent with the emergency classification and emergency action level scheme. These notifications include a means of verification or authentication.

The methods used for authentication are developed and mutually agreed to by the utility and offsite authorities.

A. STATE AND LOCAL AGENCY EP B.1 .1 The Emergency Director's non- The wording was relocated and transferred to the NOTIFICATION delegable duties include: SNC Standard Emergency Plan.The Emergency Director is

Notifications of offsite agencies and responsible for notifying the Alabama approval of state, /local, and NRC Emergency Management Agency notifications).

and the Georgia Emergency Management Agency of all declared emergencies.

The Alabama Emergency Management Agency will notify the Alabama Radiation Control Office of the State of Alabama Department of Public Health who will in turn notify the Florida Division of Emergency Management.

In addition to these State EP B.1 .1 The Emergency Director's non- The wording was relocated and transferred to the notifications, the Emergency Director delegable duties include: SNC Standard Emergency Plan.will notify local emergency

Notifications of offsite agencies and management agencies in Houston approval of state, local, and NRC County, Alabama and Early County, notifications).

Georgia utilizing the Emergency Notification Network or commercial telephone.___________________________________________

E6-133 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description NMP-EP-1 11, "Emergency EP E.2.2.2: In conjunction with state and The description of the initial message was Notifications", contains the initial county authorities, SNC-operated plants have standardized between the SNO sites and messages that will be used by the established the contents of the initial and expanded to better align with current guidance.Emergency Director to notify the subsequent state notification message forms state and local agencies for the to be used during an emergency.

These forms different classifications of are described in EPIPs. The content of the emergencies.

The content of forms has been reviewed and agreed on by emergency messages has been the respective Offsite Response mutually agreed upon with State and Organizations.

Local agencies.

The procedure to be followed for message authentication is contained in NMP-EP-1 11,"Emergency Notifications." These initial messages shall contain, at a minimum the following if applicable and available:

1. Class of emergency 2. Actual or potential release information

3. Potentially affected population

4. Advisability of protective measures___________________________________________

E6-134 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan {Revised SNC Emergency Plan Equivalent TJustification Revision 64 Description t____________________

Required follow-up message information has been agreed upon by the states. NMP-EP-1 11 makes provisions for follow-up messages to be sent to the states. These messages contain the following information as appropriate:

1. Location of incident and name and telephone number (or communications channel identification) of caller 2. Date/time of accident 3. Class of emergency 4. Type of actual or projected release (airborne, liquid) and estimated duration times 5. Estimate of quantity of radioactive material released or being released and the height of release 6. Chemical and physical form of released material, including estimates of the relative quantities and concentrations of noble gases, iodines, and particulates

7. Meteorological conditions (wind speed, direction (from), stability classification; form of precipitation, if any)8. Projected dose at site boundary 9. Projected dose at about 2, 5, and 10 miles 10. Emergency response actions underway 11. Recommended emergency actions, including protective measures in sector(s) affected 12. Prognosis for worsening or termination of event based on plant information EP E.2.2.3: The Emergency Director is responsible for the completion of a follow-up emergency message. The appropriate support coordinator will ensure the emergency communicator(s) periodically provide follow-up messages to the appropriate offsite federal, state, and local authorities.

The wording was standardized and relocated to the SNC Standard Emergency Plan.E6-1 35 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revision 64 Revised SNC Emergency Plan Equivalent Description Justification R. PLUME EXPOSURE PATHWAY EMERGENCY PLANNING ZONE PUBLIC NOTIFICATION AND INFORMATION

1. Notification

a. Primary Southern Nuclear Operating Company has provided the administrative and physical means for alerting and providing prompt instructions to the public within the plume exposure pathway EPZ by providing an Alert and Notification System (ANS) for the entire plume exposure pathway EPZ. Primary alerting is accomplished by use of a siren system. The siren alerting system consists of 89 pole mounted sirens. Each siren operates on battery power with battery charge maintained through an inverter that receives power from the local electrical grid or from a solar panel.Each siren site contains two radios -one for the primary radio signal frequency operating in the UHF band and one for the backup radio frequency operating in the VHF band. Repeaters for the primary and backup radio frequencies are provided on two separate radio towers with associated power, control, and radio communication provided.

Siren system activation, test, and monitoring panels are provided at each for the counties of Houston and Henry County, Alabama; one for Early County, Georgia; and one for the State of SGeorgia.EP E.2.5: Prompt alerting and notification of the public within the plume exposure pathway EPZ is the 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.Annex 4.2: Within the Plume Exposure Emergency Planning Zone (EPZ), there exist provisions for alerting and providing notification to the public.Annex 4.2: Siren system activation, test, and monitoring panels are provided for Houston County and Henry County in Alabama, Early County in Georgia, and the state of Georgia.The wording was standardized and aligned with current wording. Specific requirement for the communities is maintained in the revised description in the Site Annex.Lr- ,. -IIOU Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description-Residents in the plume exposure Annex 4.2 Alert and Notification System The wording was relocated and transferred to the pathway EPZ have been instructed (ANS) (SEP E.2.5) Site Annex.to tune to specific emergency alert Within the Plume ExpOsure Emergency radio or TV stations if the sirens are Planning Zone (EPZ), there exist provisions for activated.

alerting and providing notification to the public.The state and/or local authorities are responsible for activation of this system.E6-137 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description_____________________

Following activation of the siren system, emergency notifications will be made to the public within the 10 mile plume exposure pathway EPZ by activation of the Emergency Alert System (EAS). State and local Emergency Management Agencies will initiate activation of the local EAS stations through a dedicated EAS activation console. The EAS activation console provides a connection to designated EAS stations that allows for activation of the station through redundant communications pathways.Emergency messages are transmitted from the EAS activation console via phone line, internet, or satellite connections.

Activation of the station does not require that the station be manned. Emergency messages are coordinated between the local Emergency Management Agencies and the State Emergency Management Agencies prior to activation of the local radio stations, as specified in the local area plans. A full description of the Farley ANS design is provided-in the FEMA approved ANS Design Report (ANS-FNP-001) in the SNO document management system.Annex 4.2 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.Primary alerting is accomplished by use of a siren system. Each siren operates on battery power with battery charge maintained by an inverter that receives power from the local electrical grid or from a solar panel(s).

Siren system activation, test, and monitoring panels are provided for Houston County and Henry County in Alabama, Early County in Georgia, and the State of Georgia. A full description of the Farley ANS design is provided in the FEMA approved ANS Design located in the SNC document management system.The wording was relocated and transferred to the Site Annex.E6-138 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

b. Special Alertingi and System Annex 4.2 Special alerting uses a calling The wording was relocated and transferred to the Backup system. Special alerting is initiated in the Site Annex.Special alerting is accomplished event of a failure of the system to activate through the use of a calling system. multiple sirens resulting in a loss of coverage Special alerting is initiated in the in any area. Special alerting may be initiated event of a failure of the system to for a predefined area, a user-specified area, activate multiple sirens resulting in a user defined groups, or the entire Emergency loss of coverage in any area. Special Planning Zone (EPZ). The calling system alerting may be initiated for a serves as a complete backup to the ANS. The predefined area, a user specified system provides both alerting and notification area, user defined groups, or the of EPZ residents independent of the alerting entire Emergency Planning Zone capabilities of the installed siren system and (EPZ). The calling system serves as the notification capability of local radio and a complete backup to the ANS. The television stations through EAS. Capability to system provides both alerting and activate of the calling system is provided for notification of EPZ residents Houston County and Henry County, Alabama independent of the alerting and Early County, Georgia.capabilities provided by the installed siren system and notification capability of local radio and television stations through EAS. Capability for activation of the calling system is provided at each for the counties of Houston and Henry, Alabama, at Early, Georgia, and for the State of Georgia.2. Information EP G.8 Public Information and Education The wording was relocated and transferred to the Processes for dissemination of Program SNC Standard Emergency Plan.information to local news media and The goal of the public information program is the public annually are discussed in to acquaint the general public with the the Emergency Communications emergency plans for the operation of Plan, Appendix 10(J). APC/GPC nuclear plants, as appropriate, and actions they should take 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.E6-139 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description_____________________

3. News Release Coordination and EP G.3 News Releases The wording was relocated and transferred to the Rumor Control The Utility will issue news releases covering SNC Standard Emergency Plan.Processes for news release events, conditions, and actions at the Plant.coordination and rumor control are News releases are designed to be a written discussed in the Emergency confirmation of events and are public Communications Plan, Appendix information.

10(J). The SNC News Writer will write news releases in the EOF and obtain SNC approval from the EOF Manager, then forward them to the JIC as appropriate..

The Facility Manager at that location will obtain communications approval and direct distribution of the release.C. NRC OFFICE OF INSPECTION EP B.1 .1 The Emergency Director's non- The wording was relocated and transferred to the AND ENFORCEMENT delegable duties include: SNC Standard Emergency Plan.The Emergency Director or his

Notifications of offsite agencies and designee will notify the Nuclear approval of state, local, and NRC Regulatory Commission of any notifications.

emergency condition utilizing the Emergency Notification System.Section VI.D: If conditions warrant, EP A.1.4: The DOE has agreed to provide Commitment wording was standardized within the immediate assistance will be radiological assistance on request, and has three SNC sites and relocated without process requested by the Emergency radiological monitoring equipment and change to the SNC Standard Emergency Plan.Director from the DOE Savannah personnel resources that it can assemble and River Operations Office dispatch to the scene of a radiological incident.The Interagency Radiological Assistance Team can be expected to respond to SNC operated sites as directed by the Savannah River Operations Office of DOE.F. FIRE E6-140 Enclosure 6 to NL-1 6-01 69 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description VII. RECOVERY EP M.1 Recovery The wording was relocated and transferred to the A. METHODOLOGY Guidance for determining the transition from SNO Standard Emergency Plan.Due to the unforeseeable conditions Emergency to Recovery Organization is that would exist in an emergency provided in the plant Emergency Plan condition, specific recovery criteria implementing Procedures.

The composition of and procedures will be developed the Recovery Organization will depend on the when required, considering nature of the accident and the conditions maximum protection for plant following the accident.personnel and the general public The SNC Emergency Plan addresses general consistent with reasonable efforts to principles that serve as guides for developing restore the affected Unit and a Recovery Plan.continuing operation of the

It is the responsibility of the Emergency unaffected unit. 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.

E6-141 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description The decision to relax protective EP M.I: The following guidelines, as The SNO Standard Emergency Plan establishes measures will be based upon a applicable to the specific situation, will be standard wording for the consideration of the comprehensive review of plant addressed prior to terminating the emergency:

relaxation of protective measures.system parameters.

These shall

The affected reactor is in a stable include but not be limited to the condition and can be maintained in that following:

condition indefinitely.

1. Stability of the reactor shutdown

Plant radiation levels are stable or are condition i.e., successful movement decreasing with time.toward a cold shutdown condition.

Releases of radioactive material to the 2. Integrity of the reactor environment have ceased or are being containment building.

controlled within permissible limits.3. Operability of radioactive waste

Fire or similar emergency conditions no systems and decontamination longer constitute a hazard to safety-facilities, related systems or equipment or 4. The availability and operability of a personnel.

heat sink.

For a site area emergency or general 5. The integrity of power supplies emergency, discussions with plant and electrical equipment.

management, applicable members of the 6. The operability and integrity of SNC emergency organization, or offsite instrumentation including radiation authorities do not result in identification of monitoring equipment.

In the latter any valid reason for not terminating the instance this shall include portable emergency.

equipment assigned to the emergency.

7. Availability of trained personnel and support services.E6-142 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description The Emergency Director will analyze EP M.1 The following guidelines, as applicable The wording was relocated and transferred to the the input from his advisors in the to the specific situation, will be addressed prior SNO Standard Emergency Plan.areas listed above to determine if to terminating the emergency:

plant restoration efforts can begin.

The affected reactor is in a stable The olloingcritriashal becondition and can be maintained in that considered appropriate for thecodtnidently consideration of relaxation of* Plant radiation levels are stable or are protective measures: 1. Plant parameters of operation no decreasing with time.longr idicte apotntil oractal

Releases of radioactive material to the lonergindcat axpotenilorata environment have ceased or are being 2. The release of radioactivity from controlled within permissible limits.the plant is controllable and no

Fire or similar emergency conditions no longer exceeds permissible levels longer constitute a hazard to safety-and no danger to the public from this related systems or equipment or source is credible.

personnel.

3. The plant is capable of sustaining

For a site area emergency or general itself in a long term shutdown emergency, discussions with plant condition, management, applicable members of the 4. Plant entry and clean-up is SNC emergency organization, or offsite possible without workers receiving in authorities do not result in identification of excess of their permissible any valid reason for not terminating the exposures.

emergency.

E6- 143 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description-B. ORGANIZATION EP M.1 The Recovery Manager will structure The wording was relocated and transferred to the The recovery organization which will the recovery organization to accomplish the SNC Standard Emergency Plan.conduct the activities of returning the following general objectives:

plant toward its pre-emergency

Maintain comprehensive radiation condition to the extent reasonable is surveillance of the site until levels return described in Section ll.B.3. 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.E6-1 44 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description C. NOTIFICATION EP M.3 Recovery Notification The wording was relocated and transferred to the The Emergency Director shall notify Members of the ERO will be informed when SNO Standard Emergency Plan.the Vice President

-Nuclear Plant Recovery is initiated.

The recovery Site and company management that organization may be structured like the a decision has been reached to emergency response organization, with initiate a recovery operation.

The ED additional modifications depending on the shall then notify offsite agencies' nature of the accident, post-accident representatives ensuring the NRC, conditions, and other factors.and state and local authorities are The State EOC will be advised when the plant provided with the same information, deems it safe to begin the reentry phase of the He shall also inform these agencies offsite recovery operation.

If the Governor if any change in the structure of the ordered an evacuation, the law requires the recovery organization is to occur. 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.

VIII. MAINTAINING EMERGENCY PREPAREDNESS A. EXERCISES AND DRILLS Periodic drills and exercises will be conducted as described below. The scenarios for use in these drills will include the following elements:* The basic objective,* The date, time, place(s) and participating organizations,* The simulated event,* A time schedule of real and simulated events,* A narrative summary describing conduct of the drill.EP N.2.1 SNC-operated nuclear power plants shall ensure adequate emergency response capabilities are maintained during the interval between biennial exercises by conducting drills, including at least one drill involving a combination of some of the principal functional 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.The wording was relocated and transferred to the SNC Standard Emergency Plan.E6-1 45 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Monitoring personnel shall be EP N.4 Exercise Evaluation and Critique The wording was relocated and transferred to the stationed at various locations to A critique shall be conducted at the conclusion SNC Standard Emergency Plan.observe each individual's ability to of the exercise, to evaluate the organization's perform his assigned emergency ability to respond as called for in the SNO function.

During drills and Nuclear Standard Emergency Plan. Qualified Regulatory Commission (NRC) non- personnel will observe and perform a critique evaluated exercises, on-the-spot of exercises and drills. Provisions will be correction of erroneous performance made for federal, state, and local observers, as and a demonstration of proper well as SNC personnel, to observe and critique performance may be made by the required exercises.

monitoring personnel._______________________

E6-1 46 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

1. Radiation Emergency Exercises EP N.2.1 SNC-operated nuclear power plants The wording was relocated and transferred to the a. Exercises simulating radiation shall ensure adequate emergency response SNC Standard Emergency Plan.emergencies will be conducted on a capabilities are maintained during the interval frequency consistent with 10 CFR between biennial exercises by conducting 50, Appendix E.IV.F. These drills, including at least one drill involving a scenarios will be varied from combination of some of the principal functional exercise to exercise such that all areas of the licensee's onsite emergency major elements of the plans and response capabilities.

The principal functional emergency organizations are areas of emergency response include activities exercised at least once every 8 such as: years. These exercises will be

Management and coordination of preplanned with the following emergency response.purposes:

Accident assessment.

1) To determine the effectiveness of

Event classification.

the FNP emergency organization in

Notification of offsite authorities.

handling emergencies,

Assessment of the onsite and offsite 2) To evaluate communications and impact of radiological releases.action support with offsite agencies,

Protective action recommendation

3) To evaluate the interface with and development.

the response of the Company

Protective action decision making.Emergency Organization,

Plant system repair and corrective

4) Test the adequacy, timing, and actions.content of the EIPs, 5) Test emergency equipment and communications networks, 6) Test the public Alert and Notification System, 7) Keep affected personnel aware of their role in the plan.E6-147 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent 1Justification Revision 64 Description_____________________

b. Both full-scale and small-scale exercises will be conducted and will include participation by appropriate State and local government agencies as follows: 1 ) A full scale exercises which tests as much of the Plant Farley, State, and local emergency plans as is reasonably achievable without mandatory public participation will be conducted on a biennial basis and evaluated by NRC and FEMA.(a) Biennial exercise scenarios will be submitted to the NRC under § 50.4 at least 60 days before use in the biennial exercise.(b) Each biennial exercise scenario will provide the opportunity for the ERO to perform their key skills, as applicable, to their emergency response duties in the CR, TSC, 0S0, EOF, and joint information center to implement the EP principal functional areas.(c) Biennial evaluated exercises will be varied such that the following scenario elements are demonstrated over the course of an 8-year exercise cycle:* Hostile action directed at the plant site.* No radiological release or an unplanned minimal radiological release that does not require public protective actions.* Initial classification of or rapid escalation to a Site Area Emergency or General Emergency.

Implementation of strategies, procedures, and guidance developed under 10 CFR 50.54 (hh)(2).* Integration of offsite resources with onsite response.EP N.3 During the exercise planning cycle described in Section N.1 .4, 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:

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 on-site 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.Drills and exercise scenarios will be varied from year to year to test major components of the plans and preparedness organizations.

A record of exercises conducted during the 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.SNC sites submit Biennial Exercise scenarios under 10 CFR 50.4 for NRC review 60 days prior to the exercise.The wording was relocated and transferred to the SNC Standard Emergency Plan.E6-148 Enclosure 6 to NL-1 6-01 69 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description (d) An ingestion pathway exercise EP Ni .3 Ingestion Exposure Pathway The wording was relocated and transferred to the will be conducted on a frequency to Exercise SNC Standard Emergency Plan.ensure the States have the States within an ingestion exposure pathway opportunity to participate in an EPZ are expected to exercise plans and ingestion pathway exercise at least preparedness related to ingestion exposure once every exercise cycle, pathway measures at least once every 8 years. Opportunities are provided to any state or local government located within the plume exposure pathway EPZ to participate in annual drills and biennial exercises when requested____________________________by that state or local government.______________________

E6-149 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

2) A small scale exercise will be EP N.2.1 SNC-operated nuclear power plants The wording was -relocated and transferred to the conducted each year that a full scale shall ensure adequate emergency response SNC Standard Emergency Plan.drill is not conducted.

This small capabilities are maintained during the interval scale exercise will include a between biennial exercises by conducting combination of some of the principal drills, including at least one drill involving a functional areas of the licensee's combination of some of the principal functional onsite emergency response areas of the licensee's onsite emergency capabilities and tests at least one response capabilities.

The principal functional other component (e.g., medical or areas of emergency response include activities offsite such as: monitoring) of the offsite emergency

Management and coordination of response plans for the company and emergency response.State and local agencies within the

Accident assessment.

plume exposure pathway EPZ. The

Event classification.

principal

Notification of offsite authorities; functional areas of emergency

Assessment of the on-site and offsite response include: impact of radiological releases.* Evnt lasifiatin.

Protective action recommendation

Notification of offsite authorities, development.

Maagemnt ad cordiatio ofProtective action decision making.emergency response.

° Plant system repair and corrective

Accident assessment.

Assessment of the onsite and atos offsite impact of radiological releases.* Protective action recommendation development.

Protective action decision making.* Plant system repair and mitigative action implementation.

c. For Nuclear Regulatory EP N.3 SNC sites submit Biennial Exercise The wording was relocated and transferred to the Commission (NRC) evaluated scenarios under 10 CFR 50.4 for NRC review SNO Standard Emergency Plan.exercises, the NRC will be provided*

60 days prior to the exercise.with a description of exercise objectives at least 75 days prior to the exercise.

Participation in the exercise by the NRC shall be at their discretion.

________________________

E6-150 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

d. The Alabama Emergency No equivalent Plan/Annex statement.

The rule change directing submittal to the Nuclear Management Agency will provide Regulatory Commission by the site effectively FEMA with a description of exercise separates the need to identify the offsite objectives at least 90 days prior to a requirements for submittal.

FEMA evaluated exercise.Participation in the exercise by FEMA shall be at their discretion.

_______________________________________________

E6-1 51 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent IJustification Revision 64 jDescription I____________________

a. Periodic Emergiencv Drills 1 ) During each exercise cycle, periodic drills will be conducted to ensure the ERO teams (not necessarily each individual) are provided the opportunity to develop and maintain key emergency response skills within the scope of their duties. The ERO (not necessarily each ERO team) will be provided the opportunity to demonstrate key skills in response to the following scenario elements in drills or exercises.

All functions in each ERF (e.g., all ERFs that are responsible for dose assessment perform those duties in response to a radiological release).* Use of alternative facilities to stage the ERO for rapid activation during hostile action.* Real-time staffing of facilities during off-hours (i.e., 6:00 p.m. to 4:00 a.m.).* Providing medical care for injured, contaminated personnel (every 2 years).* Response to essentially 100 percent of initiating conditions identified in the site emergency plan implementing procedure for classification of emergencies.

Response to actual industry event sequences appropriate for the nuclear plant technology (e.g., PWR).* Use of procedures developed in response to an aircraft threat and in compliance with 10 CFR 50.54 (hh)(1).* Use of the strategies associated with 10 CFR 50.54 (hh)(2) to mitigate spent fuel pool damage scenarios (all strategies, such as makeup, spray, and leakage control, but not every variation of a given strategy).

Use of the strategies associated with 10 CFR 50.54 (hh)(2) to mitigate reactor accidents and maintain containment.

EP N.3 During the exercise planning cycle described in Section N.1 .4, 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:

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 Drills and exercise scenarios will be varied from year to year to test major components of the plans and preparedness organizations.

A record of Exercises conducted during the 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..

SNC sites submit Biennial Exercise scenarios under 10 CFR 50.4 for NRC review 60 days prior to the exercise.The wording was relocated and transferred to the SNC Standard Emergency Plan.E6-152 Enclosure 6 to NL-1 6-01 69 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

b. Fire Drills EP N.2.3: Fire drills will be conducted at The commitment was relocated to the SNC 1) Fire Drills will be conducted with nuclear plants in accordance with Plant Standard Emergency Plan and Site Annex fire brigade members as required by Technical Specifications and Plant procedures.

the plant's FSAR.2) Fire Drills will be conducted Annex 2.3.1: Fire Drills will be conducted annually which will involve the annually and will involve the Dothan Fire Dothan Fire Department.

Department.9______________________

c. Medical Emergency Drills EP N.2.4: A medical emergency drill, involving The commitment was relocated unchanged to the A medical emergency drill will be a simulated contaminated individual, and SNC Standard Emergency Plan.conducted annually which will involve containing provisions for participation by local ambulance and offsite medical support services organizations including treatment facility participation, ambulance response, are conducted annually at the nuclear plants.d. Radiologqical Monitoringq Drills EP N.2.5 Environs Drills The wording was relocated and transferred to the Radiological monitoring drills will be Plant environs and radiological monitoring sNc Standard Emergency Plan.conducted annually which will drills are conducted annually.

These drills include initiating onsite and offsite include collection and analysis of sample radiological monitoring of vegetation, media and provisions for communications and soil, water, and air. record keeping. These drills also evaluate the response to, and analysis of, simulated airborne and direct radiation measurements in the environment.

e. Health Physics Drills EP N.2.6: Radiation Protection Drills involving a The commitment was relocated to the SNC Health Physics drills will be response to, and analysis of, simulated airborne Standard Emergency Plan.conducted semiannually which will and liquid samples and direct radiation involve response to simulated measurements are conducted semi-annually.

elevated airborne and liquid samples At least annually, these drills shall include a and direct radiation measurements in demonstration of the sampling system the plant environment.

Analysis of capabilities, as applicable.

reactor coolant samples including use of the post accident sampling system will be conducted annually._______________________________________________

E6-153 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

f. Appropriate local, state, and EP N.3 The EP group will also coordinate The wording was relocated and transferred to the federal agencies will be advised of efforts with appropriate federal, state, and local SNC Standard Emergency Plan.major drills in advance to allow their emergency organizations and agencies, observation or participation.

All schedule a date to conduct the drill or observing or participating agencies exercise, and assign qualified controllers.

will be EP- N.4 Exercise Evaluation and Critique requested to provide comments on Qualified personnel will observe and perform a drill evaluation and it will be the critique of exercises and drills. Provisions will responsibility of the Plant Manager to be made for federal, state, and local implement corrective action as observers, as well as SNC personnel, to appropriate, observe and critique required exercises.

3. Evaluations and Corrective EP N.5 Exercise/Drill Corrective Actions The wording was relocated and transferred to the Actions The critique and evaluation process is used to SNC Standard Emergency Plan.A formal critique will be performed identify areas of the Emergency Preparedness for all exercises, drills, and training Program that require improvement.

The that provide performance Emergency Preparedness group is responsible opportunitiesto develop, maintain, or for evaluating recommendations and demonstrate key skills in order to comments, determining which items will be identify weak or deficient areas that incorporated into the program or require need correction.

All observing or corrective actions, and for scheduling, tracking, participating agencies will be and evaluation of item resolution.

Whenever requested to provide comments on exercises or drills indicate deficiencies in the drill evaluation.

Any weaknesses or SNC Standard Emergency Plan, site-specific deficiencies that are identified in a Annexes, corresponding implementing critique of exercises, drills, or training procedures, or training lesson plans, such will be corrected.

Corrective action, documents will be revised as necessary.

as appropriate, for company onsite The results of exercise critiques, particularly and offsite weaknesses shall be the comments on identified areas that require responsibility of the Vice President-improvement or reevaluation, will be submitted Nuclear Plant Site. Corrective action, to the Emergency Preparedness Supervisor or as appropriate, for company public designee, for review. The Emergency information weaknesses shall be the Preparedness Supervisor or designee will responsibility of the APC Public consult with responsible department heads Relations Senior Vice President and and assign corrective action activities, as the SNC Vice President and General appropriate.

Counsel.E6-154 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description B. TRAINING EP 0.4.8: General Employee Training (GET). The SNC Standard Emergency Plan standardizes

1. Training of the Plant Emergency GET will include general training in emergency wording for generic emergency preparedness Orgqanization preparedness for plant and other site personnel.

training and specifies a location for the training All Farley Nuclear Plant personnel, without change in intent.including those assigned on a temporary basis or in a training status, will receive a thorough orientation on all emergency plans and procedures required to ensure their safety. Changes in emergency plans and EIPs applicable to all plant personnel will be presented using training notices or other appropriate means.Persons with specific duties during EP 0.1 The ERO Training Program ensures The wording was relocated and transferred to the an emergency will receive additional the training, qualification, and requalification of SNC Standard Emergency Plan.training appropriate to their individuals who may be called on for respective assignments.

The assistance during an emergency.

Specific responsibility for coordinating their emergency response task training, prepared training is that of the Plant Training for response positions, is described in lesson Manager. plans and study guides.Continuing training will be provided EP 0.4 ERO Training The wording was relocated and transferred to the to all personnel as described below: SNC ERO personnel who are responsible for SNC Standard Emergency Plan.Specific training that will be implementing this plan receive specialized conducted is listed below: training.

The training program for emergency a. Emergency Director Training response personnel is developed based on the (annually) members of the plant staff requirements of 10 CFR 50, Appendix E and who may serve as Emergency position specific responsibilities.

Director will receive training in: 1) Supervision of emergency teams, Requalification training for onsite ERO 2) Emergency assessment including members consists of an annual review of the interpretation of data and estimation Emergency Plan in the form of a general of radiation exposure, overview.

In addition to SNC Emergency Plan 3) Coordination and communication overview training, personnel assigned on-site with offsite groups. emergency response positions will receive training specific to their position.E6-155 Enclosure 6 to NL-1 6-01 69 Farley Justification Matrix Current Farley Emergency Plan " Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

b. Field Monitoring Team Trainingq EP 0.4.3 Radiological Field Monitoring The wording was relocated and transferred to the (annually)

Teams SNC Standard Emergency Plan.This training will be given to plant Radiological Field Monitoring Team personnel and vendor personnel that may be will receive classroom and hands-on training required to perform surveys in-plant, for the actions they will be expected to perform on the environment, or at SAMC. It during an emergency.

The following general will include instruction in the topics will be included in the training: selection and use of survey

Equipment and equipment checks.instruments and air sampling

Communications.

equipment and in re-entry criteria.

Plume tracking techniques.

Personnel monitoring.

Emergency exposure criteria.* Locations and use of radiological

__________________________

emergency equipment.

c. First Aid Training (triennially)

EP 0.4.6 Medical Support The wording was relocated and transferred to the Plant personnel will be considered On-site medical personnel receive specialized SNC Standard Emergency Plan.first aid qualified upon successful training in the handling of contaminated victims completion of the Company's

-First and hospital interface.

Offsite ambulance and Aid and CPR Course. hospital personnel are offered annual training as outlined in Section 0.1 .1.d. Fire Control (per FSAR EP 0.4.4 Fire Brigade Training The wording was relocated and transferred to the requirements)

Individuals assigned to Fire Brigade shall SNO Standard Emergency Plan.A training program for the plant maintain fire brigade qualifications.

employees that serve on fire fighting teams is conducted under the direction of the Plant Training Manager. This course covers methods and equipment for fighting all types of fires that could occur on the site. Appropriate emphasis is placed on the radiological aspects of fire fighting.

Drills and critiques are conducted periodically to train Fire Brigade personnel and to maintain their efficiency._______________________________________________

E6-156 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

e. Emerqency Repair Party Training EP 0.4.5 Operations, Maintenance, The wording was relocated and transferred to the (anal)Chemistry, and Radiation Protection SNC Standard Emergency Plan.Maintenance and I and C personnel Training who may be assigned to the Operations, Maintenance, Chemistry, and Emergency Repair Party receive Radiation Protection personnel who would be training in Radiation Control assigned to Repair and Damage Control Procedures as part of their normal Teams are trained as part of their normal job-plant training.

Personnel selected for specific duties to respond to both normal and Emergency Repair Party work will abnormal plant operations.

possess the required journeyman skills for the particular activity.f. Security Personnel

('annually)

No equivalent Plan/Annex statement The SNC Standard Emergency Plan maintains Security personnel will receive the commitment to train all personnel assigned training on FNP-0-EIP-7, "Security Emergency Plan requirements in addition to those Support to the Emergency Plan", not assigned to the ERO. Security training including personnel evacuation and requirements are also controlled in the Security accountability, access control, Plan.vehicle escort, and bomb search activities.

Personnel will also receive training on Contingency Implementing Procedure 13 covering security activities during fire, explosion, or other catastrophe.

_____________________

______________________

g.Communications Personnel EP 0.4.7 News Media Training The wording was relocated and transferred to the (anal)Local news media personnel will be offered an SNC Standard Emergency Plan.Personnel responsible for the annual training opportunity as described in transmission of emergency Section G.information and instructions will receive training in accordance with Appendix_10(J).

___________________________________________

E6-157 Enclosure 6 to NL-1 6-01 69 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

2. Trainingq of the Corporate EP 0.4 ERO Training The wording was relocated and transferred to the Emergqency Organization SNC ERO personnel who are responsible for SNC Standard Emergency Plan.Information related to corporate implementing this plan receive specialized emergency organization training is training.

The training program for emergency provided in Appendix 7(G). response personnel is 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.3. Trainingq of Local Services Groups EP 0.1.1 Training of Local Services Groups The wording was relocated and transferred to the Offsite groups, such as fire A training opportunity will be offered annually SNC Standard Emergency Plan.departments, police and sheriff's for offsite organizations and agencies as departments, and ambulance specified in respective agreements and services, that may participate in understandings.

In addition, those offsite onsite activity will be encouraged to organizations and agencies that may provide attend a training course to ensure onsite emergency assistance will be that they are familiar with the plant encouraged to become familiar with the layout and their actions in the event general layout of SNC plants, and will be of radiological and non-radiological invited to attend applicable Emergency Plan incidents.

The Plant Training training and orientation courses.Manager is responsible for Annually, training will be offered for hospital coordinating this training, 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.E6-1 58 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

4. Training of SNC Emergency EP 0.5 Emergency Preparedness Staff The wording was relocated and transferred to the Planners Training SNC Standard Emergency Plan.The EP Supervisor, Emergency Training for the Emergency Preparedness Planning Coordinator, and other Staff at an SNO-operated plant consists of individuals with emergency planning initial and continuing training process. Details responsibilities are trained by self- can be found in site specific procedures and study and by attending industry processes.

seminars, short courses, workshops, etc.E6-159 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description C. INSPECTION, CALIBRATION Annex 5.5 Emergency Kits (SEP H.9) The wording was relocated and transferred to the AND TESTING OF EMERGENCY Emergency supplies and equipment are Site Annex.EQUIPMENT AND located at various places at the plant.SUPPLIES Procedures require an inspection and To insure the operational readiness operational check of equipment in these kits of emergency supplies and on a quarterly basis and after each use.equipment the following will be Equipment in these kits is calibrated in performed:

accordance with the suppliers'

1. Periodic calibration using recommendations.

A set of spares of certain manufacturers' recommendations as equipment is also maintained to replace guidelines on all portable emergency inoperative or out-of-calibration equipment.

instrumentation designated for emergency use. This includes both onsite equipment and offsite equipment at SAMC supplied by APC/SNC.2. Inspection quarterly of all onsite and SAMC emergency equipment and supplies designated for emergency use and supplied by APC/SNC. The purpose of the inspection is to ensure that the inventory is correct, that the supplies are functional and that instrument calibration is current.3. An adequate reserve of emergency equipment will be maintained to allow for equipment taken out of service for repair, calibration, or replacement.

E6- 160 Enclosure 6 to NL-1 6-01 69 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

4. Communications Checks Annex 5.4 Communication channels with the The wording was relocated and transferred to the a. Communications checks will be state of Alabama, the state of Georgia, the Site Annex.performed monthly with all locations plume exposure pathway EPZ counties, and which are part of the Emergency the NRC (with the exception of ERDS) are Notification Network. tested each calendar month, using the extensions in the Control Room, the TSC, and the EOF. ERDS is tested each calendar quarter. Communications procedures and__________________________systems are also tested each calendar year.b. The Emergency Notification EP F.3 Communications Tests The wording was relocated and transferred to the System shall be tested at least Communications tests will be conducted on the SNC Standard Emergency Plan.monthly. frequency specified below. Each of these c. The telephone numbers of tests includes provisions to ensure participants organizations listed in FNP-0-EIP-8.1 in the test are able to understand the content will be updated quarterly and verified of the messages in the test.annually.

Communication from the Control Room, TSC, and EOF to the NRC Operations Center will be tested monthly.d. The EOF/TSC/OSC conference EP F.3 Communications Tests The wording was relocated and transferred to the capability will be tested at least Communications tests will be conducted on the SNC Standard Emergency Plan.annually, frequency specified below. Each of these tests includes provisions to ensure participants in the test are able to understand the content of the messages utilized in the test.* Communication from the Control Room, TSC, and EOF to the NRC Operations

___________________________

Center will be tested monthly.e. Radio communication equipment EP F.3 Communications Tests The wording was relocated and transferred to the for Field Monitoring Team Communications tests will be conducted on the SNC Standard Emergency Plan.communications will be tested at frequency specified below. Each of these least annually.

tests includes provisions to ensure participants in the test are able to understand the-content of the messages utilized in the test.* Communication from the Control Room, TSC, and EOF to the NRC Operations Center will be tested monthly.E6-161 Enclosure 6 to NL-1 6-01 69 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

e. The public Alert and Notification EP F.3Communications Tests The wording was relocated and transferred to the System will undergo a full activation Communications tests will be conducted on the SNC Standard Emergency Plan.test at least annually.

frequency specified below. Each of these tests includes provisions to ensure participants in the test are able to understand the content of the messages utilized in the test.* The fixed siren portion of the Alert and Notification System (ANS) will be tested and verified in accordance with existing FEMA approvals.

D. REVIEW AND UPDATING OF EP P.3 EPIPs and administrative procedures The wording was relocated and transferred to the THE PLAN AND PROCEDURES for the Emergency Preparedness function are SNC Standard Emergency Plan.Responsibility for the planning effort, maintained by the Fleet Emergency including review and updating of the Preparedness Director with a designated EP emergency plans and procedures, is staff member as the principal contact.described in Appendix 9(l).APPENDIX 1(A) The SNC Standard Emergency Plan and Annex EMERGENCY SUPPLIES AND maintain the commitment to perform the functions EQUIPMENT required to implement the Emergency Plan.Equipment and supplies necessary to perform those functions are maintained in the procedure and surveillance processes.

APPENDIX 2(B) INDEX The agencies for which LOA are maintained are Letters of Agreement on File incorporated in the description of provided services in the respective sections of the SNC Standard Emergency Plan and Site Annex. A__________________________separate listing of LOAs is no longer required.APPENDIX 3(C) The SNC Standard Emergency Plan and Annex RADIATION MONITORING maintain the commitment to perform the functions SYSTEM required to implement the Emergency Plan.Equipment and supplies necessary to perform those functions are maintained in the procedure and surveillance processes.

E6-162 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description APPENDIX 4(D) The SNC Standard Emergency Plan and Annex I. EMERGENCY PLAN will be implemented through a function-based PROCEDURES procedure scheme developed parallel with the approval and implementation process as part of this submittal.

APPENDIX 5(E) Annex Appendix A The wording was relocated and transferred to the EVACUATION TIME ESTIMATES Site Annex.FOR THE FARLEY NUCLEAR PLANT APPENDIX 6(F) Annex Appendix C The wording was relocated and transferred to the SUPPORTING EMERGENCY Site Annex.PLANS APPENDIX 7(G) The information is in the Standard SNO The SNC Standard Emergency Plan incorporates EMERGENCY OPERATIONS Standard Emergency Plan and Farley Annex. the Central EOF into the overall Plan and FACILITY addresses EOF functions in the respective Plan areas rather than as a separate appendix.Appendix 7 A.3: Upon notification of EP H.2.1 : Staffing and activation of the EOF is The commitment wording was standardized and an ALERT or higher classification or mandatory upon declaration of an Alert or relocated to the SNC Standard Emergency Plan as directed by the ED, the EOF will higher classification.

be activated as described in emergency implementing procedures.

_____________________

______________________

Appendix 7 A.3: Offsite support personnel and equipment will be dispatched to the site Operations Support Center (OSC) or Technical Support Center (TSC) upon request from the specific site Emergency Director.EP B.2.1.15:

The Support Coordinator reports to the TSC Manager and directs the clerical 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.

The commitment wording was standardized and relocated to the SNC Standard Emergency Plan E6- 163 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Appendix 7 A.3: The corporate EP B.3.1 .3 EOF Support Coordinator The commitment wording was standardized and emergency organization will provide The Support Coordinator reports to the EOF relocated to the SNC Standard Emergency Plan.offsite emergency response support Manager. The duties and responsibilities of and resources to SNC sites 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months the Support Coordinator in the EOF include The SNC Standard Emergency Plan integrates per day until the emergency has providing oversight of the News Writer, the Corporate response as part of the trained and been terminated, providing assistance to the Support qualified ERO. A separate statement is not Coordinator in the Technical Support Center necessary.(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.Appendix 7 A.3: The EOF will be EP H.2.1" Staffing and activation of the EOF is The commitment wording was standardized and activated for an ALERT, SITE AREA mandatory upon declaration of an Alert or relocated to the SNC Standard Emergency Plan.or GENERAL emergency higher classification.

classifications.

Appendix 7 A.3: This facility (EOF) EP B.2: Augmentation of on-shift staffing will The commitment wording was standardized and will be operational within about an occur within 75 minutes of the declaration of relocated to the SNC Standard Emergency Plan.hour of the initial notification.

an Alert or higher classification by the Emergency Response Organization (ERO). The change in activation times will be justified ERO positions for the TSC, Operations separately in the Technical Analysis Section of Support Center (OSC), Emergency Operations this License Amendment Request.Facility (EOF), and JIC are detailed below.Appendix 7 A.3: SNC's goal is to No equivalent Plan/Annex statement.

The SNC Standard Emergency Plan moves to a begin notification of all required on- commitment to activate facilities within a call Emergency Response timeframe of 75 minutes. Notification of the Organization (ERO) personnel as responding ERO is a step in the overall process soon as practicable, within 15 and not needed as 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 site. _____________________this License Amendment Request.E6-164 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Appendix 7 A.3: Upon notification of EP H.2.1: Staffing and activation of the EOF is The commitment wording was standardized and an ALERT or higher classification or mandatory upon declaration of an Alert or relocated to the SNC Standard Emergency Plan as directed by the ED, the EOF will higher classification.

be activated as described in emergency implementing procedures.

Appendix 7 A.3: Offsite support EP B.2.1.15:

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, ensures Support Center (OSC) or Technical 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 ensures office Director.

supplies, drawings, and other documents are available to TSC and OSC personnel._____________________

Appendix 7 A.3: The corporate EP B.3.1.3 EOF Support Coordinator The commitment wording was standardized and emergency organization will provide The Support Coordinator reports to the EOF relocated to the SNC Standard Emergency Plan.offsite emergency response support Manager. The duties and responsibilities of and resources to SNC sites 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months the Support Coordinator in the EOF include The SNC Standard Emergency Plan integrates per day until the emergency has providing oversight of the News Writer, the Corporate response as part of the trained and been terminated, providing assistance to the Support qualified ERO. A separate statement is not Coordinator in the TSC for ordering equipment necessary.

and materials, 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 EQF will be EP H.2.1: Staffing and activation of the EOF is The commitment wording was standardized and activated for an ALERT, SITE AREA mandatory upon declaration of an Alert or relocated to the SNC Standard Emergency Plan.or GENERAL emergency higher classification.

classifications.

Appendix 7 A.3: This facility (EOF) EP B.2: Augmentation of on-shift staffing will The commitment wording was standardized and will be operational within about an occur within 75 minutes of the declaration of relocated to the SNC Standard Emergency Plan.hour of the initial notification.

an Alert or higher classification by the Emergency Response Organization (ERO). The change in activation times will be justified ERO positions for the TSC, Operations separately in the Technical Analysis Section of Support Center (OSC), Emergency Operations this License Amendment Request.Facility (EOF), and JIC are detailed below.E6-165 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description 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 badges. ____________________

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 access to offsite agency or other may want a more positive statement of building responders without pre-designated control.ID access.Appendix 7 B: The EOF Organization EP Figure B.2.D EQF Organization Chart. The commitment wording was standardized and is displayed in Figure 1 and typical EP B.3 Listing of typical duty assignments.

relocated to the SNC Standard Emergency Plan.duty assignments are shown on Table 1.Appendix 7 B: Each of the following EP B.3.1 .2 EOF Manager The commitment wording was standardized and EOF positions has site-specific The EOF Manager reports to the EQF ED and relocated to the SNC Standard Emergency Plan.personnel designated:

is responsible for managing and directing EQF EOF Manager activities, developing recovery plans, procuring EOF Technical Supervisor outside services and equipment as necessary, coordination with offsite agencies, and approving news releases.EP B.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.E6-166 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Appendix 7 B: In order to augment EP B.3.1 .3 EQF Support Coordinator General statement on activation of the ERO is additional staff that may be needed The Support Coordinator reports to the EOF sufficient for staffing.in the unlikely event of a multi-site Manager. The duties and responsibilities of accident, SNC will re-activate its the Support Coordinator in the EOF include ERO notification system. providing oversight of the News Writer, providing assistance to the Support Coordinator in the 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.Appendix 7 B: When the EOF is EP B.2" Augmentation of on-shift staffing will The commitment wording was standardized and activated, all EOF staff pagers are occur within 75 minutes of the declaration of relocated to the SNC Standard Emergency Plan.activated, and all EOF personnel are an Alert or higher classification by the expected to report to the EOF. Emergency Response Organization (ERO).ERO positions for the TSC, Operations Support Center (OSC), Emergency Operations

__________________________Facility (EOF), and JIC are detailed below. _____________________

E6-1 67 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Appendix 7 B.I: The EOF Managers EP 0.1 Training The commitment was modified to required will typically have either previous To achieve and maintain an acceptable level qualified personnel.

plant specific SRO background or of 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.

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 on 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._______________________

E6-168 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Appendix 7 B.2: The EOF Technical EP B.3.1.19 EOF Technical Supervisor The commitment was modified to required Supervisor will typically have plant The Technical Supervisor reports to the EOF qualified personnel.

specific long-term Manager and is responsible for providing engineering/design experience, 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.2: The duties and EP B.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 SNO operated plant.This may include interacting with non-SNO response groups, developing mitigation and recovery plans, and coordinating work performed by SNC and non-SN~engineering groups.Appendix 7 B.3: The duties and EP B.3.1 .3: The Support Coordinator reports The commitment wording was standardized and responsibilities of the EOF Support to 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 TSC for ordering predetermined rotational schedule.

equipment and materials, and logistics arrangements for support personnel called in to assist in the emergency, including communications hardware, transportation, food, and lodging.Appendix 7 B.4: The TSC will initially EP B.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.

E6-169 Enclosure 6 to NL-1 6-01 69 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Appendix 7 B.4: When the EOF is Figure B.2.A Figure B.2.A describes the transfer of non-activated and ready to assume EP B.3.1 .4: The Dose Assessment Supervisor delegable responsibilities between the ERFs.functions of dose projection!

reports to the EOF Manager and provides Section B.3 provides the overall responsibility of assessment activities, then the EOF oversight of dose assessment, field team EOF responders.

Dose Assessment Supervisor will control, and protective action recommendation coordinate transfer of dose activities in the EOF; and coordinates The commitment wording was standardized and assessment, field team control, and communication of results with offsite agencies.

relocated to the SNC Standard Emergency Plan.protective action determination from the TSC to the EOF.Appendix 7 B.4: The duties and EP B.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 B.5: The duties and EP B,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 SNO 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 SNO 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 NRC using the Security Bridge line, and establishing and maintaining access control for the EOF.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.E6-170 Enclosure 6 to NL-1 6-01 69 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description 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 0.1 : 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.I: 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 SNO sites (VEGP, FNP, and HNP).FNP, and HNP).Appendix 7 D. 1: The EOF will be EP H.2.1 : Staffing and activation of the EOF is The commitment wording was standardized and activated as prescribed in the site mandatory upon declaration of an Alert or relocated to the SNC Standard Emergency Plan.specific Emergency Plan higher classification.

implementing procedures.

Appendix 7 D.I: 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, and 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 EQF.Appendix 7 DlI: 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 EQF using the relocated to the SNC Standard Emergency Plan.the EOF, dose assessment area, plant computer system plant status area, and engineering EP H.5.3.2: The SPDS parameters are area within the facility.

available during normal and abnormal operating___________________________conditions in the Control Room, TSC, and EOF.______________________

E6-171 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Appendix 7 D.I: 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 0.1: 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 on a secure network the various offsite emergency dedicated to data distribution among the various response facilities.

offsite emergency response facilities.

Appendix 7 0.1 : 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, 050, EOF, and other locations on-site and offsite including the Joint Information Center near the SNC site.Appendix 7 0.1: 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, FOF, and other locations onsite and offsite including the Joint Information Center near the SNC site.EP Section B: Emergency Response Facility (ERF) Communicators E6-172 Enclosure 6 to NL-1 6-01 69 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Appendix 7 D.I: 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 Section 5.3.2: Commercial telephones site(s), or land lines provide backup for the ENN.Appendix 7 D.I: A communication EP F.1.1: At SNO-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.I: Computer No equivalent Plan statement.

Dose Assessment (Section I) describes the dose workstations are dedicated for assessment function and equipment needed to performing dose assessment for support that function.

Section B identifies multiple sites.,_____________________

required personnel.

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, a~nd federal responders persons from the NRC, and 1 person including NRC and FEMA.from the Federal Emergency Management Agency (FEMA).______________________

Appendix 7 D.1: Table 4 provides additional information concerning OEO communications capabilities.

EP F Table 5 The SNC Standard Emergency Plan and Annex provide commitments to maintain the communications capabilities within the ERO, for required offsite responders, and to the public through 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 Emergency Plan.E6-173 Enclosure 6 to NL-1 6-01 69 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Appendix 70.1I: Upon activation of EP B.3.1.3 EOF Support Coordinator The SNC Standard Emergency Plan incorporates the EOF, Corporate personnel will The Support Coordinator reports to the EOF the EOF as part of the general ERO supporting provide staffing 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months per day Manager. The duties and responsibilities of ongoing operations.

The separate statement is until directed otherwise by the the Support Coordinator in the EOF include not required.Emergency Director.

providing oversight of the News Writer, providing assistance to the Support Coordinator in the Technical Support 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 Iodgirhg.Appendix 701.: The EOF is a EP H.2.1: The EOF is a dedicated facility The commitment wording was standardized and dedicated facility.

Iocatedin Birmingham, Alabama, and serves relocated to the SNC Standard Emergency Plan.as the EOF for SNC sites (VEGP, FNP, and HNAP).Appendix 7 0.1: 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 generation system.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 diagrams.E6-174 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description_____________________

Appendix 7 D.2: In the unlikely event No equivalent Plan/Annex statement Egress of personnel from the EPZ falls 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 D.2: In the unlikely event No equivalent Plan/Annex statement The corporate EOF is located outside the that the EOF becomes uninhabitable, reasonable expectation for damage based on a resources and personnel will be naturally occurring event beyond the design basis transferred to the Corporate of the site. Should the EOF be so damaged, the Headquarters of Alabama Power site can re-assume control of the event.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 ETS Regulatory Commission (NRC) is on the relocated to the SNC Standard Emergency Plan.lines in the TSC and the EOF during Federal Telephone System (ETS) telephone an emergency.

network, which 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 G PC 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 any national laboratory.

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.

E6-1 75 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Appendix 7 G.1 .1: The training EP 0O4: SNC ERO personnel who are The commitment wording was standardized and consists of familiarization with the responsible for irnplementing 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: ERG 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 " EP 0.4: SNC ERO personnel who are The SNC Standard Emergency Plan maintains emergency planning coordinator(s) responsible for implementing this plan receive the commitment to conduct the training for are responsible for assuring that specialized training.

The training program for corporate personnel.

Who conducts the training training is conducted for corporate emergency response personnel is developed may depend on specific areas of expertise and emergency response personnel each based on the requirements of 10 CFR 50, has no purpose in the SNC Standard Emergency calendar year. Appendix E and position-specific Plan.______________________________responsibilities.________________________

E6-176 Enclosure 6 to NL-1 6-01 69 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Appendix 7 G.1 .2: Drills!/exercises EP N.1 Exercises The SNC Standard Emergency Plan incorporate~s will be conducted each calendar year SNO-operated nuclear power plants will the FOF into the base Plan response.

Separate to test the performance of conduct a biennial exercise and additional drill criteria for the EOF are no longer required.implementing procedures, personnel, periodic drills. An exercise is an event that and emergency equipment.

These tests integrated capability and a major portion drills/exercises will be conducted of the basic elements of emergency with each SNC site. preparedness plans and organizations.

Drills or exercises shall:* 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.SNO-operated nuclear power plants conduct an emergency response exercise to demonstrate the effectiveness of the SNC Standard Emergency Plan on a frequency determined by the NRC. Exercises may include mobilization of state and local personnel and resources, and are intended to verify their capability to respond to an accident.Appendix 7 G.1 .2: EOF activation is No equivalent Plan/Annex statement The SNC Standard Emergency Plan incorporates required at least 3 times annually (1 the EOF into the base Plan response.

Separate scenario per site per year). drill criteria for the EOF are no longer required.Appendix 7 G.1 .2: At least 1 No equivalent Plan/Annex statement The SNC Standard Emergency Plan incorporates activation every 5 years will require a the FOF into the base Plan response.

Separate concurrent EOF support response for drill criteria for the EOF are no longer required.more than one SNC site.E6-177 Enclosure 6 to NL-1 6-01 69 Farley Justification Matrix Current Farley Emergency Plan Revision 64 Revised SNC Emergency Plan Equivalent Description Justification Appendix 7 3.1.2: Each drill/exercise EP NI: 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 SNO 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 critique shall be conducted at the The commitment wording was standardized and made for critique of all conclusion of the exercise, to evaluate the relocated to the SNC Standard Emergency Plan.drills/exercises, 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 processing in the site specific be 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 E~mergency plan, site-specific Annexes, corresponding implementing procedures, or training lesson plans, such documents will be revised as necessary.

______________________

Appendix 8: FARLEY NUCLEAR No equivalent Plan/Annex cross reference The SNC Standard Emergency Plan and Annex PLANT EMERGENCY PLAN are structured in the same manner as NUREG-NUREG 0654 CROSS REFERENCE 0654 Revision 1. The Plan/Annex as reflected in INDEX the Table of Contents functions as the cross-ref erence.APPENDIX 9(l) SECTION P: FI;ESPONSlBILITY FOR THE The commitment was relocated to the SNC RESPONSIBILITY FOR THE PREPAREDNESS EFFORT Standard Emergency Plan as described below.PLANNING EFFORT E6-178 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Responsibility for the Planning Effort EP Section P

Introduction:

The Executive The commitment was relocated to the SNC The Executive Vice President/Chief Vice President/Chief Nuclear Officer (CNO) Standard Emergency Plan.Nuclear Officer (ONO) Southern Southern Nuclear Operating Company (SNC)Nuclear Operating has overall responsibility and authority for all Company(SNC)has overall nuclear activities, including the Emergency responsibility and authority for all Planning (EP) program.nuclear activities, including the emergency planning (EP) programs.Reporting to the Executive Vice President is the Vice President Fleet Operation Support and the President

-Nuclear Plant Site.The SNC Emergency Planning No direct equivalent Plan/Annex statement The SNC Standard Emergency Plan integrates program is comprised of two distinct the overall Emergency Planning/Preparedness and integral functions; emergency effort. The distinction previously separating planning and emergency corporate and site responsibilities is eliminated.

preparedness.

Responsibility for the performance of these functions is assigned to various members of the SNC Organization and coordinated as follows.The Vice President Regulatory EP P.1: The Vice President Regulatory Affairs The commitment was relocated to the SNC Affairs has Fleet responsibility for has Fleet responsibility for emergency Standard Emergency Plan.emergency planning.

planning.The Fleet EP PAI: The Fleet Emergency Preparedness The commitment was relocated to the SNC Emergency Preparedness Manager Manager is responsible for the oversight of Standard Emergency Plan.has overview management Emergency Planning activities and responsibility for the Fleet SNC coordinating those activities with Licensee, Emergency Planning program effort. federal, state, and local response The Fleet Emergency Preparedness organizations.

Manager is responsible for overseeing emergency planning activities offsite and coordinating those activities with Licensee, Federal, State and local response organizations.

E6-179 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description The Emergency Planning EP P.1 Strategic direction for the emergency The commitment was relocated to the SNC Coordinator(s) reports to the Fleet preparedness program and maintenance of the Standard Emergency Plan.Emergency Preparedness Manager SNC Emergency Plan(s) is provided by the in support of this effort. SNC Fleet Emergency Preparedness Director.Emergency Preparedness Coordinator(s) coordinate functional elements of the emergency preparedness program for the SNC fleet under the direction of the Fleet___________________________Emergency Preparedness Director.The Emergency Plans are EP P.1 The Fleet Emergency Preparedness The commitment was relocated to the SNC maintained by the Fleet Security and Director is responsible for the oversight of Standard Emergency Plan.Emergency Preparedness Manager. Emergency Preparedness activities and coordinating those activities with Licensee, federal, state, and local response organizations.

T-he Fleet Emergency Preparedness organization in the SNC Corporate office provides oversight and support for site and corporate functions.

The Fleet Emergency Preparedness EP P.1 : The Vice President Regulatory Affairs The wording was standardized and relocated to Manager provides strategic direction has Fleet responsibility for emergency the SNC Standard Emergency Plan.for SNC emergency planning and planning: coordinates with site management through the Vice President

-Fleet EP P.1:* The Fleet Emergency Preparedness Operations Support. Manager is responsible for the oversight of Emergency Planning activities and coordinating those activities with Licensee and federal, state, and local response___________________________organizations.

The Emergency Planning EP P.2 The Emergency Preparedness The commitment was relocated to the SNC Coordinator(s) coordinate site input Supervisor is responsible for coordinating on- Standard Emergency Plan.and involvement in emergency site emergency preparedness activities and planning programs with the supports offsite emergency preparedness Emergency Preparedness activities in the plant vicinity.Supervisor.

E6-180 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description The.Emergency Planning EP P.1 Emergency Plan changes are reviewed The commitment was relocated to the SNC Coordinator(s) review Emergency to determine if the effectiveness of the specific Standard Emergency Plan.Plan changes to determine if the plans have been reduced, in accordance with effectiveness of the specific plans the requirements of 10 CFR 50.54q. Changes have been reduced. Emergency Plan that are judged to0 reduce the effectiveness of changes which are judged to reduce the Plan will be submitted to the NRC for the effectiveness of the Plan will be approval prior to implementation.

submitted to the NRC for approval prior to implementation.

Emergency Preparedness:

EP P.2: The Vice President-(Site) is The commitment was relocated unchanged to the The Vice President

-(Nuclear Plant responsible for t~he site Emergency SNC Standard Emergency Plan.Site) is responsible for the site Preparedness aspects of the program.Emergency Preparedness aspects of the program..The Emergency Preparedness EP P.2 The Emergency Preparedness The wording was standardized and relocated to Supervisor is responsible for Supervisor is responsible for coordinating the SNC Standard Emergency Plan.coordinating emergency onsite emergency preparedness activities and preparedness activities onsite and supports offsite emergency preparedness supports offsite emergency activities in the p:lant vicinity., preparedness activities in the vicinity of the plant. ______________________

The Emergency Preparedness EP P.2 The Emergency Preparedness The wording was standardized and relocated to Supervisor reports through the Supervisor reports through the Regulatory the SNC Standard Emergency Plan.Regulatory Affairs Manager to the Affairs Manager to the Vice President-(Site) for Vice President

-(Nuclear Plant Site). Plants Hatch and Farley. During project construction for Vogtle 3 and 4, the Vogtle 1-2 Emergency Preparedness Supervisor reports to the Site Integration Director.

The Vogtle 3-4 Emergency Preparedness Supervisor reports to the Emergency Preparedness/Security Project Manager, who reports to the Site__________________________Integration Director.E6-181 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description The Emergency Planning Supervisor EP P.3 EPIPs and administrative procedures The wording was standardized and relocated to is responsible to the Regulatory for the Emergency Preparedness function are the SNC Standard Emergency Plan.Affairs Manager for implementation maintained by the Fleet Emergency of emergency planning strategies.

Preparedness Director with a designated EP staff member as the principal contact.Coordination:

EP P.3 The Fleet Emergency Preparedness The wording was standardized and relocated to The Fleet Emergency Preparedness Director coordinates site input and involvement the SNC Standard Emergency Plan.Manager coordinates site input and in emergency planning programs with the involvement in emergency planning Emergency Preparedness Supervisor.

The programs with the Emergency Emergency Preparedness Supervisor is Preparedness Supervisor.

The responsible for the implementation of the Emergency Preparedness Emergency Plan and program maintenance Supervisor is responsible for the activities.

implementation of the Emergency Plan and procedure development and maintenance.

Figure 1 shows the EP Organization.

EP Figure P.1 The wording was standardized and relocated to_________________________the SNO Standard Emergency Plan.The Fleet Emergency Preparedness EP 0.5 Emergency Preparedness Staff The wording was standardized and relocated to Manager, Emergency Planning Training the SNC Standard Emergency Plan.Coordinator, Emergency Training for the Emergency preparedness Preparedness Supervisor, and other Staff at an SNC-operated plant consists of individuals with emergency planning initial and continuing training process. Details responsibilities are trained by self.- can be found in site specific procedures and study and by attending industry processes.

seminars, short courses, workshops, etc.Onsite Emergency Plan EP P.3 EPIPs and administrative procedures The wording was standardized and relocated to Implementing Procedures (EIPs) are for the Emergency Preparedness function are the SNC Standard Emergency Plan.maintained by the Regulatory Affairs maintained by the Fleet Emergency Manager with the Emergency Preparedness Director with a designated EP Preparedness Supervisor being the staff member as the principal contact.principal site contact.E6-182 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64' Description EIPs for the corporate emergency EP P.1 Emergency Preparedness The wording was standardized and relocated to response organization and Coordinator(s) coordinate functional elements the SNC Standard Emergency Plan.procedures governing fleet of the emergency preparedness program for emergency planning activities are the SNC fleet under the direction of the Fleet maintained by the Fleet Emergency Emergency Preparedness Director.Preparedness Manager.The Fleet Emergency Preparedness EP P.3 Once per calendar year, the The wording was standardized and relocated to Manager or designee performs a designated Emergency Planning staff performs the SNC Standard Emergency Plan.review of the site specific emergency a review of the emergency plans for Southern plan annually and all onsite EIPs Nuclear.biennially.

The review includes the letters of agreement, which are updated as necessary.

____________________

The Fleet Emergency Preparedness EP P.3 Once per calendar year, the The wording was standardized and relocated to Manager performs a review of the designated Emergency Planning staff performs the SNO Standard Emergency Plan.emergency plans for Southern a review of the emergency plans for Southern Nuclear once each calendar year. Nuclear. This review includes a comparison The review includes a comparison for consistency of emergency plans for a for consistency of all emergency specific site including the Security Plan, and plans for the specific sites including state and county plans as appropriate.

the Security Plan, State, County, and the Savannah River Site plan, as appropriate._______________________

The Emergency plans and EIPs are EP P.3 Approved changes to the Emergency The wording was standardized and relocated to revised in accordance with Plan are forwarded to key organizations and the SNC Standard Emergency Plan.applicable site procedures.

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 lake into account changes identified by drills and exercises, and the__________________________independent review described below.E6-183 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Emergency Plan changes which are EP P.1 Emergency Plan changes are reviewed The wording was standardized and relocated to judged to reduce the effectiveness of to determine if the effectiveness of the specific the SNC Standard Emergency Plan.the Plan will be submitted to the plans have been reduced, in accordance with NRC for approval prior to the requirements of 10 CFR 50.54q. Changes implementation.

that are judged to reduce the effectiveness of the Plan will be submitted to the NRC for__________________________approval prior to implementation.

The Emergency Planning EP P.1 Emergency Plan changes are reviewed The wording was standardized and relocated to Coordinator will review Emergency to determine if the effectiveness of the specific the SNC Standard Emergency Plan.Plan changes to determine if the plans have been reduced, in accordance with effectiveness of the site specific plan the requirements of 10 CFR 50.54q. Changes has been reduced prior to submitting that are judged to reduce the effectiveness of the proposed change for the Plan will be submitted to the NRC for departmental review and approval prior to implementation.

subsequently to the PRB for approval.As required by 10CFR50.54(t).

An EP P.3: An independent review of the EP The wording was standardized and relocated to annual independent audit of the program is conducted as required by 10 CFR the SNC Standard Emergency Plan.emergency preparedness program is 50.54(t).conducted by the SNC Nuclear Oversight Department.

This audit is conducted as part of the standard audit program and will include a review of the Emergency Plan, its implementing procedures and practices, emergency preparedness training, annual exercises, equipment, and emergency response facilities.

In addition, an audit of the interfaces with offsite agencies is performed by the SNC Nuclear Oversight department.

Each audit is nominally conducted EP P.3- An independent review of the EP The wording was standardized and relocated to every 12 months. program is conducted as required by 10 CFR the SNC Standard Emergency Plan.50.54(t).

____________________________________

E6-184 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Audits are performed in accordance EP P.3: An independent review of the EP The wording was standardized and relocated to with SNC Nuclear Oversight program is conducted as required by 10 CFR the SNC Standard Emergency Plan.department procedures.

Audit 50.54(t).reports are written and distributed to management and, in addition, applicable portions of the corporate audit reports are made available to affected Federal, State, and local agencies, as appropriate, in accordance with 10CFR50.54(t).

Appropriate departments are EP P.3 The results of the review, along with The wording was standardized and relocated to responsible for implementing recommendations for improvements, are the SNC Standard Emergency Plan.corrective actions resulting from the documented and reported to plant audit findings.

Records of these management and to appropriate oftsite audits and exercise findings are agencies.

Management controls are maintained in accordance with plant implemented for evaluation and correction of procedures.

the review findings.

Records of these audits and recommendations are maintained for at least 5 years.In addition to this Plan, several other EP P.3 In addition to this Plan, several other The wording was standardized and relocated to formal emergency plans have been formal emergency plans have been developed the SNC Standard Emergency Plan.developed to support the overall to support the overall emergency response emergency response effort. These effort. Once per calendar year, the designated supporting plans and their sources Emergency Planning staff performs a review of are listed in procedure NMP-EP-300, the emergency plans for Southern Nuclear.SNC Corporate Emergency This review includes a comparison for Preparedness, Conduct of consistency of emergency plans for a specific Operations.

site including the Security Plan and state and__________________________county plans as appropriate.

APPENDIX 10(J) SECTION G: PUBLIC EDUCATION AND The appendix describing the Emergency EMERGENCY COMMUNICATIONS INFORMATION Communications Plan has been standardized and PLAN incorporated into the ERO Staffing as described in Section B, Facilities as described in Section H, the Emergency Communications portion of Section G of the SNC Standard Emergency Plan and Section 5.1.6 of the Farley Annex.E6-185 Enclosure 6 to NL-1 6-01 69 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description APPENDIX 11 (K) EP Section 0 The wording was standardized and relocated to ASSESSMENT ACTIONS Annex Section 3 the SNC Standard Emergency Plan and Site Annex ASSESSMENT ACTIONS EP 0.1.1.2 Eme~rgency Classification Level The wording was standardized and relocated to 1, CLASSIFICATION OF Descriptions the SNC Standard Emergency Plan.EMERGENCIES There are three considerations related to The classification system is based on emergency classification levels. These are: the four emergency classes (1) The potential impact on radiological described in 10CFR50 Appendix E safety, either as known now or as can be and NUREG 0654, established by reasonably projected.

the Nuclear Regulatory Commission (2) How far the plant is beyond its (NRC), for grouping off-normal predefined design, safety, and operating nuclear power plant conditions envelopes.

according to (1) their relative (3) Whether or not conditions that radiological seriousness, and (2) the threaten health are expected to be confined to time-sensitive onsite and off-site within the site boundary.radiological emergency preparedness actions necessary to respond to such conditions The existing radiological emergency EP D.1.1.2 The Initiating Conditions (ICs) deal The wording was standardized and relocated to classes, in ascending order of explicitly with radiological safety impact by the SNC Standard Emergency Plan.seriousness, are called: escalating from levels corresponding to* Notification of Unusual Event releases within regulatory limits to releases (NOUE) beyond EPA Protective Action Guideline* Alert (PAG) plume exposure levels.* Site Area Emergency (SAE) The four emergency classification levels are* General Emergency (GE) described as follows: The classes, therefore, determine UNUSUAL EVENT (UE)initial steps to be taken by on site ALERT and by corporate emergency SITE AREA EMERGENCY (SAE)response personnel.

The emergency GENERAL EMERGENCY classes are used by offsite authorities to determine which of the preplanned actions to be taken by their emergency organizations._______________________

E6-186 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description An emergency classification is EP D.1.1.1 Emergency Action Levels (EALs), The wording was standardized and relocated to indicative of the status of the plant. based on indications available in the control the SNC Standard Emergency Plan.Inputs to the emergency room and correlated to the emergency classification system include the classifications, are provided to the operator.status of various plant systems, EP 0.1.1.2 The Initiating Conditions (l~s) deal radiation levels in and around plant explicitly with radiological safety impact by areas, and the rate of release of escalating from levels corresponding to radioactivity from the plant. These releases within regulatory limits to releases are termed Initiating Conditions beyond EPA Protective Action Guideline which are a predetermined subset of, (PAG) plume exposure levels.nuclear power plant conditions where either the potential exists for a radiological emergency, or such an emergency has occurred.The SNC classification scheme is EP D.1 .1.1 Emergency classification is divided This submittal does not change the current based on NEI 99-01, Rev 4, into four classification levels described in 10 approved EAL scheme for Plant Farley.Methodology for CFR 50 Appendix E and NUREG 0654 and Development of Emergency Action based on NEI 99-01 and 07-01 methodologies.

Levels, January 2003 endorsed by Reg Guide 1.101, Rev 4, Emergency Planning and Preparedness for Nuclear Power Reactors.

The Initiating Conditions lead each plant to a classification Implementing Procedure which contains the Threshold values for each Initiating Condition.

E6-187 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Each Initiating Condition has specific EP D.2.1 An Emergency Action Level has two The wording was standardized and relocated to conditions associated that are distinct parts. T'he Initiating Condition (IC) is a the SNC Standard Emergency Plan.termed Threshold Values. When an brief description of conditions that are Initiating Condition is observed and compared to existing abnormal plant the criteria of it's associated conditions.

The ICs are segregated into Threshold Values are met, an Recognition Categories.

Emergency Action Level is met and With each IC are Threshold Values (TV) that the event is then classified and provide the criteria for classification associated declared at the appropriate level, with the appropriate classification level. When the IC is observed to exist, the TV must also be met, exceeded, or in some cases imminent to become a classifiable Emergency Action Level.The SNC Classification procedures EP D.2.1 An Emergency Action Level has two The wording was standardized and relocated to are written to classify events based distinct parts. The Initiating Condition (IC) is a the SNC Standard Emergency Plan.on meeting the Initiating Condition brief description of conditions that are (IC) and a Threshold Value (TV) for compared to existing abnormal plant an EAL considering each Unit conditions.

The ICs are segregated into independently.

During events, the Recognition Categories.

ICs and TVs are monitored and if With each IC are Threshold Values (TV) that conditions meet another higher EAL, provide the criteria for classification associated that higher emergency classification with the appropriate classification level. When is declared and appropriate the IC is observed to exist, the TV must also notifications made. Notifications are be met, exceeded or in some cases imminent made on a site basis. If both units to become a classifiable Emergency Action are in concurrent classifications, the Level.highest classification would be used for the notification and the other unit classification noted on the notification form.E6-188 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description At all times, when conditions present EP 0.2.1 Although the majority of the EALs The wording was standardized and relocated to themselves that are not explicitly provide very thresholds, the the SNC Standard Emergency Plan.provided in the EAL scheme the Emergency Director must remain alert to Emergency Director has discretion to events or conditions that lead to the conclusion declare an event based on his that exceeding the .EAL is imminent.

If, in the knowledge of the emergency classes judgment of the Emergency Director, an and judgment of the situation or imminent situation is at hand, the classification condition.

should be made as if the threshold has been exceeded.Once an emergency classification is EP D.2.5 Emergency Classification Level The wording was standardized and relocated to made, it cannot be downgraded to a Downgrading and Termination the SNC Standard Emergency Plan.lower classification.

All the actions The SNC policy is that once an emergency associated with the emergency classification is made, it cannot be classification level must be downgraded to a lower classification.

completed and then a termination of Termination criteria contained in the the event can be affected.

At Emergency Plan Implementing Procedures termination, on an event shall be completed for an event to be specific basis, the site can either terminated.

At termination, on an event-enter normal operating conditions or specific basis, the site can either enter normal enter a recovery condition with a operating conditions or enter a recovery recovery organization established for condition with a recovery organization turnover from the ERO. established for Thurnover from the ERO.The described emergency classes EP D.1.1.1 The classification scheme is The wording was standardized and relocated to and the emergency action levels provided to and discussed by Southern the SNC Standard Emergency Plan.which determine them are agreed on Nuclear Company, agreed upon by state and by SNO and State and local county governmental authorities, and authorities.

The emergency action approved by the NRC. The classification levels will be reviewed by these scheme and specific Emergency Action Levels officials annually.

are reviewed with the State and local governmental authorities on an annual basis.E6-189 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description_____________________

a. Notification of Unusual Event EP D.1.1.2 UNUSUAL EVENT (UE) The wording was standardized and relocated to 1. Description Events are in progress or have occurred which the SNC Standard Emergency Plan.The classification of Notification of indicate a potential degradation of the level of Unusual Event applies to situations safety of the plant or indicate a security threat in which events are in process or to facility protection has been initiated.

No have occurred which indicate a releases of radioactive material requiring off-potential degradation of the level of site response or monitoring are expected safety of the plant or indicate a unless further degradation of safety systems security threat to facility protection occurs.has been initiated.

No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.2. Response No equivalent Plan/Annex statement The responsibilities of the Shift Manager with In the event of a Notification of respect to Classification are provided in Section B Unusual Event, the Shift Manager of the Plan.will assesses the conditions and implement the Classification EIP.The Emergency Organization will No equivalent Plan/Annex statement Section B provides the position specific duties perform the following:

related to Classification Notification.

1) Inform State and local offsite authorities of the nature of the Section E provides notification information.

unusual event within 15 mmn. of classifying the emergency.

Notify the Nuclear Regulatory Commission (NRC) as soon as possible (ASAP)but no later than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months following classification of the emergency.

2) Augment on-shift resources, as needed.3) Assess and respond to the event.4) Escalate to a more severe class, if appropriate, or close out with a verbal summary to offsite authorities followed by a written summary within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . _____________________

E6-190 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

b. Alert ALERT The wording was standardized and relocated to 1. Description Events are in progress or have occurred which the SNC Standard Emergency Plan.The classification of Alert applies to involve an actual or potential substantial situations in which events are in degradation of thme level of safety of the plant process or have occurred which or a security event that involves probable life-involve an, actual or potential threatening risk to site personnel or damage to substantial degradation of the level site equipment because of hostile action. Any of safety of the plant or a security releases are expected to be limited to small event that involves probable life fractions of the EPA PAG exposure levels.threatening risk to site personnel or damage to site equipment because of intentional malicious dedicated efforts of hostile action. Any releases of radioactive material for the Alert classification are expected to be limited to small fractions of the U.S.Environmental Protection Agency (EPA) Protective Action Guideline (PAG) exposure levels. The purpose of ofisite alert is to assure that emergency personnel are readily available to respond if the situation becomes more serious or to perform confirmatory radiation monitoring if required and to provide offsite authorities current status information.

2. Response No equivalent Plan/Annex statement.

Section B provides the position specific duties In the event of an Alert the Shift related to Classification Notification.

Manager will assess the conditions and implement the Classification Section E provides notification information.

EIP.E6-1 91 Enclosure 6 to NL-1 6-01 69 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description The Emergency Organization will then perform the following:

1) Within 15 mim. of classification, inform State and local offsite authorities of Alert Emergency and reasons for emergency.

Notify the NRC ASAP but no later than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months following classification of the emergency.

2) Augment resources and activate the emergency response facilities (e.g.Technical Support Center (TSC), Operational Support Center (OSC) and the Emergency Operations Facility (EOF)). These actions may be delayed for security based events at the discretion of the emergency director.3) Assess and respond to the emergency.

4) Mobilize, and dispatch if necessary, onsite survey teams.5) Provide periodic plant status updates to offsite authorities.

6) Provide periodic meteorological assessments to offsite authorities and, if any emergency releases are occurring, field monitoring team readings or dose estimates for actual releases.7) Activate the Emergency Response Data System for the affected unit within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months following declaration of the Alert.8) 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 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months of closeout.No equivalent Plan/Annex statement.

related to Classification Notification.

Section E provides notification information.

E6-192 Enclosure 6 to NL-I 6-01 69 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

c. Site Area Emergency SiTE AREA EIMERGENCY (SAE) The commitment wording was standardized and 1. Description Events are in progress or have occurred which relocated to the SNC Standard Emergency Plan.The classification of Site Area involve actual or likely major failures of plant Emergency applies to those events functions needed for protection of the public or which are in progress or have hostile action that results in intentional damage occurred that involve actual or likely or malicious acts~toward site personnel or major failures of plant functions equipment that could 1) lead to the likely needed for protection of the public failure of, or 2) p:revent effective access to from radiation or contamination or equipment needed for the protection of the security events that result in public. Any releases are not expected to result intentional damage or malicious acts; in exposure levels that exceed EPA PAG (1) toward site personnel or exposure levels beyond the site boundary.equipment that could lead to the likely failure of or; (2) prevent effective access to, equipment needed for the protection of the public. Any releases of radioactive material for the Site Area Emergency classification are not expected to exceed EPA Protective Action Guideline exposure levels except near the site boundary.2. Response No equivalent Plan/Annex statement Section B provides the position-specific duties In the event of a Site Area related to Classification Notification.

Emergency, the Shift Manager will assess the conditions and implement Section Eprovides notification information.

the Classification EIP._____________________

E6-193 Enclosure 6 to NL-1 6-01 69 Farley Justification Matrix Current Farley Emergency Plan ]Revised SNC Emergency Plan Equivalent 1Justification Revision 64 JDescription_____________________

The Emergency Organization will perform the following:

1) Within 15 min. of classification, inform State and local offsite authorities of Site Area Emergency and reasons for emergency.

Notify the NRC ASAP but no later than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months following classification of the emergency.

2) If necessary, provide protective action recommendations to State and local authorities.

3) Augment resources and activate the emergency response facilities (e.g.Technical Support Center (TSC), Operational Support Center (OSC), and the Emergency Operating Facility (EOF)). These actions may be delajied for security based events at the discretion of the emergency director.4) Assess and respond to the emergency.

5) Dispatch as necessary onsite and offsite sLirvey teams.6) Dedicate individuals for plant status updates to offsite authorities and periodic press briefings.

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

8) Provide meteorological information and dose estimates to offsite authorities for actual releases via a dedicated individual.

8) Provide release and dose projections based on available plant condition information and foreseeable contingencies.

No equivalent Plan/Annex statement related to Classification Notification.

Section E provides notification information.

E6-194 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan TRevised SNC Emergency Plan Equivalent TJustification Revision 64 jDescription I____________________

The Emergency Organization will perform the following: (cont)10) Activate the Emergency Response Data System for the affected unit within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months following declaration of the Site Area Emergency.

11) Escalate to General Emergency, if appropriate, or close out the emergency class by briefing of offsite authorities followed by written summary within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months of closeout.No equivalent Plan/Annex statement related to Classification Notification.

Section E provides notification information.

d. General Emergency 1. Description The classification of General Emergency applies to those events which are in progress or have occurred which involve actual or imminent substantial core degradation or melting with potential loss of containment integrity or security events that result in an actual loss of physical control of the facility.

Release of radioactive material for the General Emergency classification can reasonably be expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area.GENERAL EMERGENCY Events are in progress or have occurred which involve actual or imminent substantial core degradation or melting with potential for loss of containment integrity, or hostile action that results in an actual loss of physical control of the facility.

Releases can be reasonably expected to exceed EPA FAG exposure levels off-site for more than the immediate site area.The commitment wording was standardized and relocated to the SNC Standard Emergency Plan.2. Response No equivalent Plan/Annex statement Section B provides the position specific duties In the event of a General Emergency related to Classification Notification.

the Shift Manager will assess the conditions and implement the Section E provides notification information.

Classification ElF.________________________

E6-195 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan fRevised SNC Emergency Plan Equivalent Justification Revision 64 Description_____________________

The Emergency Organization will then perform the following:

1) Within 15 min. of classification, inform State and local offsite authorities of General Emergency and reason for emergency.

Notify the NRC ASAP but no later than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months following classification of the emergency.

2) Prbvide protective action recommendations to State and local authorities based upon plant conditions and/or actual or projected releases of radioactive material.3) Augment resources and activate the emergency response facilities (e.g.Technical Support Center (TSC), Operational Support Center (OSC), and the Emergency Operating Facility (EOF)). These actions may be delayed for security based events at the discretion of the emergency director.4) Assess and respond to the emergency 5) Dispatch onsite and offsite survey teams.6) Dedicate an individual for plant status updates to offsite authorities and periodic press briefings.

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

8) Provide meteorological data and field monitoring team readings or dose estimates to offsite authorities for actual releases.9) Provide release and dose projections based on plant condition and foreseeable contingencies.

No equivalent Plan/Annex statement related to Classification Notification.

Section E provides notification information.

E6-196 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description The Emergency Organization will No equivalent Plan/Annex statement Section B provides the position specific duties then perform the following: (cont) related to Classification Notification.

10) Activate the Emergency Response Data System for the Section E provides notification information.

affected unit within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months following declaration of the General Emergency.

11) Close out the emergency class by briefing of offsite authorities followed by written summary within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months of closeout.2. CLASSIFICATION PROCESS SECTION D: EMERGENCY Section D provides the description of the The Classification Emergency Plan CLASSIFICATION SYSTEM Classification process Implementing Procedure is used to EP D.1 Classification of Emergencies classify the emergency condition EP D.1,.1 Emergency Conditions upon recognition of an off- normal condition relative to an Initiating Condition.

Two Initiating Condition Matrices and EP D.2.1 The Fission Product Barrier and The commitment wording was standardized and a Fission Product Barrier Evaluation System Malfunction criteria are only applicable relocated to the SNC Standard Emergency Plan.table are used depending on the when in the hot operating modes. The Cold initial mode of the unit. The Hot Shutdown /Refueling System malfunctions are Initiating Condition matrix and the only applicable in cold shutdown and Defueled Fission Product Barrier Evaluation modes or as specifically designated in each table are used when the unit is in the EAL. The EALs associated with the Technical Specification defined Radiological, ISFS1, and Hazards categories modes of Hot Shutdown, Hot are applicable in all modes of operation.

Standby, Startup and Power Operation.

A Cold Initiating Condition matrix is used when the unit is in the Cold Shutdown, Refueling, or Defueled modes. The IC Matrices are human factored to read from top to bottom General Emergency to Notification of Unusual Event within a category or subcategory.

E6-1 97 Enclosure 6 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan' Revised SNC Emergency Plan Equivalent Justification Revision 64 Description To facilitate the expeditious EP 0.2.1 An Emergency Action Level has two The commitment wording was standardized and classification of emergencies, the distinct parts. The Initiating Condition (IC) is a relocated to the SNC Standard Emergency Plan.various initiating conditions which brief description of conditions that are may result in an emergency class compared to existing abnormal plant are grouped into six recognition conditions.

The ICs are segregated into categories as follows: Recognition Categories.

The Recognition

Radiological (Hot and Cold -R Categories are: series)

R -Abnormal Radiological

Fission Product Barriers (Hot -F Levels/Radiological Effluent.series)

C -Cold Shutdown / Refueling System* System Malfunctions (Hot -S Malfunctions.

series)

E -Independent Spent Fuel Storage* System Malfunctions (Cold -C Installations (ISFSI).series)

F -Fission Product Barrier.* ISFS1 (Hot and Cold -E series)

IH -Hazards and Other Conditions

Hazards (Hot and Cold -H series) Affecting Plant Safety.* S -System Malfunction.

Within each category, sub categories EP 0.2.1 With each IC are Threshold Values The commitment wording was standardized and and specific Initiating Conditions are (TV) that provide the criteria for classification relocated to the SNC Standard Emergency Plan.identified.

Each Initiating Condition associated with the appropriate classification has specific conditions associated level. When the IC is observed to exist, the TV that are termed Threshold Values. must also be met, exceeded or in some cases These Initiating Conditions, imminent to become a classifiable Emergency Threshold Values, and bases are Action Level.provided in this Appendix.The capability to assess, classify, EP 0.1 SNC has and maintains the capability The commitment wording was standardized and and declare an emergency condition to assess, classify, and declare an emergency relocated to the SNC Standard Emergency Plan.within 15 minutes after the condition within 15 minutes after the availability availability of indications to plant of indications to plant operators that an EAL operators that an EAL has been threshold has been met or exceeded.

Upon exceeded has been established and identification of the appropriate emergency is outlined in applicable procedures.

classification level, the emergency condition Emergency conditions are will be promptly declared.classified promptly upon identification that an emergency action level (EAL) threshold has been exceeded.E6-1 98 Enclosure 6 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description The 15-minute period encompasses EP D.1 SNC has and maintains the capability The commitment wording was standardized and all assessment, classification, and to assess, classify, and declare an emergency relocated to the SNC Standard Emergency Plan.declaration actions associated with condition within 15 minutes after the availability making an emergency declaration of indications to plant operators that an EAL from the first availability of a plant threshold has been met or exceeded.

Upon indication or receipt of a report of an identification of the appropriate emergency off-normal condition by plant classification level, the emergency condition operators up to and including the will be promptly declared.declaration of the emergency.

If classifications and declarations are performed away from the CR, all delays incurred in transferring information from the CR (where the alarms, indications, and reports are first received) to the ERF (at which declarations are made) are included within the 15-minute criterion.

Hot Initiating Conditions Matrix Annex Appendix B The approved EALs are not affected by this submittal.

Cold Initiating Conditions Matrix Annex Appendix B The approved EALs are not affected by this submittal.

Fission Product Barrier Evaluation Annex Appendix B The approved EALs are not affected by this Modes submittal.

Emergency Action Level Description Annex Appendix B The approved EALs are not affected by this (Rev. 63 pages K-10 to K-l00 submittal.

EMERGENCY PLAN SNC Standard Emergency Plan Sections The commitment was standardized and relocated Pa rt II A.2, B.5, F.2 arnd L (entire section) to the SNC Standard Emergency Plan and Annex.MEDICAL PLAN Annex Sections 1.7.1.10, and 2.3 E6-199 Enclosure 6 to NL-16-0169 Farley Justification Matrix Farley On-Shift Table Comparison Major Functional Area Major Tasks Position Title!/ Expertise Table B-i Farley Farley Farley on-shift*

Rev 25 Rev 64 Proposed 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 3 7________________

Shift Support Supervisor , ...1 Emergency Direction and STA. Shift Supervisor or facility 1 ** 1 ** 1 1"**Control (Emergency manager Coordinator)**

Notification

/ Notify State/local and federal 1 .... 2 2**1" Communication

...personnel, maintain communication Radiological Accident Offsite Dose Assessment Senior CHM & Env -':1 1 1 Assessment and Support of Offsite surveys HP/CHM technicians and other ,, ,, 2 2 1 Operational Accident On-site surveys trained personnel.

Assessment In-Plant surveys HP Technicians 1 2 2 1 Chemistry!/

Radiochemistry Chem/HP Technicians 1 1 1 1 __Plant System Engineering Technical support 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 l&C Maintenance

... .. 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 Tec Specs '*"." 55*Rescue Operations and 2 ** 2** 2** 2**First-Aid Site Access Control and Security, firefighting communications, Security personnel per security plan ..Personnel Accountability personnel accountability

....__________________

_.... __ 1______Total On-Shift 10 19 28 25*For each unaffected unit, maintain at least 1 SF, 1 CR0, 1 AO**May be provided by shift personnel assigned other functions***Overall direction to be assumed by EOF Dire when ERFs are fully manned....*May be performed by engineering aid to shift supervisor E6-200 Enclosure 6 to NL-1 6-01 69 Farley Justification Matrix Farley Augmented ERO Table Comparison Major Functional Area Major Tasks Position Title I Expertise Table B-i Farley Farley Farley Augment (75 min) (75 min) Proposed Rev 25 Rev 64 (75 min)Emergency Direction and Control Notification!/

Notify State/local and federal 2 2 2 11 Communication personnel, maintain communication Radiological Accident EOF Director Senior Manager 1 1 1_ a Assessment and Support of Dose Assessment HP Expertise

.... ,.. ..:...Operational Accident Offsite Surveys HP Technicians 2 2 6 5 Assessment On-Site Surveys HP Technicians 1 2 In-Plant surveys HP Technicians 1 2 Chemistry!/

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/IHydraulic 1 1 1 1 Repair and Corrective Repair and Corrective Actions Mechanical Maintenance 1 1 1 1 Actions Rad Waste Operator 1 1 .- .Electrical Maintenance 1 1 1 1 l&C Technician

'.

1 1 1 Maintenance Supervision

.. &r, *, .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. Dosimetr Total Augmented ERO 15 18 19 43 (a) EOF Emergency Director counted in Emergency Direction and Control.E6-201 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 7 Hatch Staffing Detailed Description and Technical Evaluation Enclosure 7 to NL-1 6-01 69 Hatch Staffing -Detailed Description and Technical Evaluation This License Amendment Request (LAR) revises the current on-shift and augmented Emergency Response Organization (ERO) for Hatch Nuclear Plant (HNP) Unit 1 and Unit 2 Emergency Plan to incorporate a standard on-shift and augmented ERO staffing plan for the Southern Nuclear Operating Company (SNO) Fleet. This proposed change to the ERO will result in an SNC Fleet standard definition of ERO augmentation time as well as an SNC Fleet standard complement of emergency response positions, titles, duties, and responsibilities.

EP Functions Impacted by the Proposed Change The proposed change impacts the ERO as outlined in 10 CFR 50.47(b) Planning Standards 1 and 2. This change addresses the following Planning Standard Functions:

10 CFR 50.47(b) (1): The response organization has the staff to respond and augment on a continuing basis (24/7 staffing) in accordance with the Emergency Plan.* 10 CFR 50.47(b) (2): Process for timely augmentation of on-shift staff is established and maintained.

The proposed change has been reviewed and continues to perform the functions required of 10 CFR 50.47(b) and the related requirements of 10 CFR 50 Appendix E.Emergency Response Organization (ERO) Activation HNP Unit 1 and Unit 2 Emergency Plan Revision 36.0 requires staffing of the augmented ERO at the Alert or higher classification

". ..ASAP, but not later than approximately 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months following the initial notification." It also states, "SNC's goal is to begin notification of all required on-call Emergency Response Organization (ERO) personnel as soon as practicable, within 15 minutes, following the declaration of an Alert emergency or higher emergency classification at any SNC site." The proposed SNO Fleet standard definition for ERO augmentation is 75 minutes from declaration.

This proposed change redefines the SNC Fleet augmentation time without extension, since the 15-minute notification period will be incorporated in the overall definition of augmentation time. The proposed SNC Fleet definition also removes ambiguous wording such as "about" and "approximately" in order to clearly define the augmentation requirement.

Assignment of Responsibility/Organizational Control The HNP Unit 1 and Unit 2 Emergency Plan maintains an on-shift organization as documented in the site Emergency Plan Revision 36.0. This Plan identifies the authority and responsibilities for emergency response and assigns major functional areas to on-site and offsite response facilities for augmented-~response.

In the following analysis, the impact of consolidating ERO positions and reassigning responsibilities is assessed based on the capacity of on-shift staff to perform major tasks for each major functional area of HNP.Plant Operations and Assessment of Operational Aspects NUREG-0654/FEMA REP-Ol Revision 1 guidance assumes the on-shift staff will provide the Plant Operations and Assessment of Operational Aspects functions throughout the emergency.

The on-shift operations staffing as provided in the current HNP Unit 1 and Unit 2 Emergency Plan Revision 36.0 meets the operations staffing requirements of 10 CFR 50.54(m)(2)(i) and the HNP Unit 1 and Unit 2 Technical Specifications.

In addition to these requirements, the HNP Unit 1 and Unit 2 Emergency Plan provides for a dedicated Shift Manager position to perform E7- 1 Enclosure 7 to NL-16-0169 Hatch Staffing -Detailed Description and Technical Evaluation the NUREG-0654/FEMA REP-01 Revision 1 function of Emergency Direction and Control. Per NUREG-0654/FEMA REP-01 Revision 1, this function may be performed as a collateral duty of one of the individuals performing the Plant Operations and Assessment of Operational Aspects function.

However, providing a Shift Manager to fill this function as a standalone position enhances the ability of the HNP Unit 1 and Unit 2 control room staff to fulfill the Plant Operations and Assessment of Operational Aspects function while the dedicated ED addresses aspects of the Emergency Direction and Control function.

This has been demonstrated and documented by performing a 10 CFR Part 50, Appendix E shift staffing evaluation.

In accordance with the current HNP Unit 1 and Unit 2 Emergency Plan, the on-shift staffing exceeds the requirements of NUREG-0654/FEMA REP-01 Revision 1 Table B-i, as well as those prescribed in the 1981 version of the HNP Unit 1 and Unit 2 Emergency Plan. The proposed SNC Fleet Emergency Plan will add another Reactor Operator to the HNP shift staff, ensuring further support of the Plant Operations and Assessment of Operational Aspects function at the start of an event and until the on-shift staff is properly augmented.

Emergency Direction and Control NUREG-0654/FEMA REP-Ol Revision 1 guidance provides that the Emergency Direction and Control function may be fulfilled by personnel assigned other functions.

Per the 1981 version of the HNP Unit 1 and Unit 2 Emergency Plan, the Emergency Director (ED) function is was a collateral duty of an ED-qualified individual assigned to the Plant Operations and Assessment of Operational Aspects function until relieved by an augmented ED in the TSC within approximately one hour of notification of an emergency.

As provided in the current version of the HNP Unit 1 and Unit 2 Emergency Plan, the Shift Manager is designated as the on-shift ED to fulfill the function of Emergency Direction and Control until relieved by the Technical Support Center (TSC) ED within approximately one hour of notification of an Alert or higher emergenCy.

With the proposed changes, the Shift Manager/ED is relieved within 75 minutes of declaration of an Alert or higher emergency by the ED in the TSC, who then assumes overall control of the response efforts. This remains unchanged in the proposed SNC Fleet Emergency Plan with the exception of redefining the augmentation time to include the time provided for notification of the ERO.In addition to the augmentation of an ED in the TSC within 75 minutes of an Alert or higher declaration the proposed SNC Fleet Emergency Plan provides an additional ED will be augmented in the Emergency Operations Facility (EOF) within 75 minutes of an Alert or higher declaration.

The aspects of the Emergency Direction and Control function assigned to the TSC and EOF EDs are clearly defined in the proposed SNC Fleet Emergency Plan. The primary role of the EOF ED will be to assume responsibility for state and local notifications and to approve of Protective Action Recommendations (PARs). This ensures that in the unlikely event of a Hostile Action Based (HAB) event in which the site is not accessible to the ERO, an ED would be available in the EQE within 75 minutes of an Alert or higher declaration to assume these aspects of the Emergency Direction and Control function to minimize the burden on the Shift Manager/ED.

E7-2 Enclosure 7 to NL-16-0169 Hatch Staffing -Detailed Description and Technical Evaluation There would be no undue burden on the Control Room staff or impact on the notification function from an addition of the EOF ED. (See table below.)CONTROL ROOM TSC EOF Shift Manager / Emergency TSC Emergency Director EOF Emergency Director Director Classification Classification Notifications Notifications PARS PARS Emergency Exposure Emergency Exposure Controls Controls Finally, the proposed revision to the HNP Unit 1 and Unit 2 Emergency Plan requires augmentation of the following TSC and EOF positions, which support activation of the TSC and OEO, within 75 minutes of event classification:

TSC Emergency Director* TSC Manager* TSC Operations Supervisor

TSC Emergency Notification System (ENS) Communicator

TSC Health Physics Network (HPN) Communicator

TSC ERE Communicator

TSC Radiation Protection (RP) Supervisor

TSC Chemistry Support* TSC Engineering Supervisor

TSC Reactor Engineer* TSC Engineering Support* TSC Maintenance Supervisor

EOE Emergency Director* EOF Manager* EOF Field Team Coordinator

EOF Emergency Communications Coordinator

EOF Security Coordinator

EOF Offsite Response Coordinator

EOF Emergency Notification Network (ENN) Communicator

EOF ENS Communicator

EOF HPN Communicator

EOF ERF Communicator

EOF Nuclear Spokesperson

EOF Technical Assistant* EOF News Writer* EOF Field Team Communicator

EOF Dose Assessment Supervisor E7-3 Enclosure 7 to NL-16-0169 Hatch Staffing -Detailed Description and Technical Evaluation

EOF Dose Analyst* EOF Technical Supervisor Notification and Communication NUREG-0654/FEMA REP-01 Revision 1 guidance requires one Communicator to be assigned on-shift.

Revision 36.0 of the HNP Unit 1 and Unit 2 Emergency Plan provides for one Communicator or other trained personnel to perform this function.

In the proposed SNC Fleet Emergency Plan staffing for HNP, this function will be modified by a note that indicates this function may be fulfilled by individuals assigned other functions.

However, an additional Reactor Operator will be added to the HNP control room staff to ensure there will be sufficient appropriately trained personnel on-shift for the Communications function to be assigned to a member of the control room staff with no collateral tasks. This has been demonstrated and documented by performing a 10 CER Part 50, Appendix E shift staffing evaluation.

In addition, the proposed SNO Fleet Emergency Plan provides for the transfer of state and local notifications, including authority to approve the content of the notification form, directly to the EOF from the control room. The proposed change includes both sufficient communications personnel to perform the communications and an ED with the authority to approve the content of the notification.

This ensures that in the unlikely event of an HAB event in which the site is not accessible to the ERO, sufficient personnel will be available in the EOF within 75 minutes from time of declaration of an Alert or higher emergency classification to assume the Communications function t and minimize the burden on the Shift Manager/ED.

The ability to transfer the Communications function directly to the EOF, and provision of sufficient augmented personnel in the EOF to perform the Communicator function within 75 minutes ensure no additional burden is incurred by the on-shift staff.Radiological Accident Assessment and Chemistry/Radio-Chemistry The function of on-site radiological assessment is to: review radiological conditions onsite using data from available instrumentation, assess the impact of changing radiological conditions on emergency classification, assist in accident assessment based upon those changing radiological conditions, and recommend appropriate on-site protective measures.Classification is performed by the Shift Manager/ED using NMP-EP-1 10, Emergency Classification Determination and Initial Action procedure, which uses readily available and easily recognized plant instrumentation to determine the appropriate emergency classification.

Off-site and onsite surveys provide additional information, such as direct radiation measurements that can be directly applied to emergency classification.

The on-shift Radiation Protection (RP)Technician takes direction from the Control Room to provide radiological assessment support until the OSC is activated.

As part of the Plant Operations and Assessment of Operational Aspects function, the operating crew uses symptom-based emergency operating procedures (EOPs) which minimize the need for specific accident assessment.

The operating crew performs actions based on symptoms that are described in the EOPs, not based on specific accident assessment.

Similarly, the Shift Manager/ED uses flowcharts in NMP-EP-1 12, Protective Action Recommendations procedure, which prescribes the decision-making processes for directing on-site protective measures.

The simple information needed to accomplish this for rapid decision making by the Shift Manager/ED using readily available information.

The Safety Parameter Display System (SPDS) provides the control room with a display of plant parameters from which the status of plant operation can be assessed.

The SPDS has the following functions:

E7-4 Enclosure 7 to NL-1 6-01 69 Hatch Staffing -Detailed Description and Technical Evaluation

Aids the control room operators in the rapid detection and identification of abnormal operating conditions.

Provides additional specific information to analyze and diagnose the cause of abnormal operating conditions.

Monitors plant response to corrective actions.* Provides grouping of parameters to enhance the operators' capability to assess plant status quickly without surveying all control room displays concurrently.

Directs the operators' attention to other specific confirmatory non-SPDS control room displays.* Provides human factors engineered display formats in simple and consistent display patterns and coding.* Provides display information on a real-time basis, along with validation of data.* Provides generated selectable trend displays on a real-time basis for monitoring reactivity control, reactor core cooling and heat removal from the primary system, reactor coolant system integrity, radioactivity control, containment integrity, and other selected parameters.

Therefore, with the proposed changes, the ERO structure continues to meet the intent of the requirements of Appendix E to 10 CFR Part 50 and the standards of 10 CFR 50.47(b).This Functional Area includes three tasks: EOF Emergency Director; Off-Site Dose Assessment and Chemistry/Radiochemistry; and Off-site, On-Site (out of plant), In-Plant Surveys, and Radiation Protection.

Emergency Operations Facility (EOF) Emergency Director (ED)The TSC ED is not assigned to the on-shift complement.

In the current plan, the TSC ED arrives within approximately 60 minutes of notification of an Alert or higher emergency classification, and relieves the on-shift ED of overall emergency management as well as all off-site responsibilities including PARs and emergency notifications.

The EOF is also staffed within this timeframe; however, there is currently no ED provided in the Emergency Operations Facility (EOF).Under this proposal, within 75 minutes of classification the Shift Manager/ED is relieved in the TSC by the ED who then assumes overall control of the response efforts. The EOF ED arrives and relieves the TSC ED of overall emergency management and off-site responsibilities including PARs, dose assessment, and emergency notifications.

This ensures that in the unlikely event of an HAB event in which the site is not accessible to the ERO, sufficient personnel to perform the Radiological Accident Assessment and Support of Operational Accident Assessment function will be available in the EOF within 75 minutes from time of an Alert or higher declaration and minimize the burden on the Shift Manager/ED.

As discussed earlier, the overall function is enhanced by providing a Shift Manager to fill this function as a standalone position beyond the collateral assignment as designated by NUREG-0654/FEMA REP-01 Revision 1 Table B-i, during the period prior to augmentation.

The proposed change presents no adverse impact to the ERO staffing because the TSC and EOF EDs will continue to provide timely relief to the on-shift ED from the duties and responsibilities for offsite functions.

Off site Dose Assessment (ODA) / Chemistry NUREG-0654/FEMA REP-0l Revision 1 does not provide for on-shift dose assessment capability.

The current version of the HNP Unit 1 and Unit 2 Emergency Plan does provide E7-5 Enclosure 7 to NL-16-0169 Hatch Staffing -Detailed Description and Technical Evaluation for an on-shift capability for performance of dose assessment and is currently assigned to a Reactor Operator.

In the proposed change, on-shift dose assessment will be assigned to appropriately trained on-shift personnel (typically a chemistry technician) who will be dedicated to this task with no other collateral emergency response duties. This will in turn free the Reactor Operator to perform other control room related tasks.With the improvements to the dose assessment software program, as well as plant status, meteorological, and radiation monitoring data, Chemistry can easily and rapidly perform dose assessments during emergency conditions.

Enhancements in dose assessment software have reduced to the time required to perform dose assessment runs and provide the results to the ED. In addition, the dose assessment software is operational in a Windows operating system on the SNC Local Area Network (LAN) and as such can be readily accessed from any LAN computer on the SNC network.A second Chemistry individual is provided as part of the minimum on-shift staffing so that any required chemistry samples may be collected without impacting the chemistry individual assigned to perform dose assessment.

A review of the Emergency Operations Procedures (EOPs), Abnormal Operating Procedures (AOPs), HNP Unit 1 and Unit 2 Emergency Plan, and the procedures used by Operations for off-normal plant conditions did not identify any conflicts between completion of dose assessment and other on-shift Chemistry functions within the 75 minute augmentation time frame. An additional Chemistry support individual will be augmented in the TSC within 75 minutes, who will provide oversight for chemistry sampling and analysis activities.

An additional Chemistry technician will be augmented in the OSC within 75 minutes to assist in performing chemistry sampling and analysis.-

Augmentation by the RP Supervisor TSC within 75 minutes will relieve the Shift Manager/ED of the role of oversight of the on-shift dose assessor.

The TSC will retain this task until relieved by the EOF dose assessment staff, which consists of the Dose Assessment Supervisor and Dose Analyst. There is no loss of function or impact on the timing for performing either of the tasks of dose assessment or required radiochemistry sampling by the proposed on-shift staffing provided in the SNC Fleet Emergency Plan.Offsite/Onsite Surveys, In-Plant surveys and Radiation Protection (RP)NUREG-0654/FEMA REP-Ol Revision 1 identifies one on-shift RP Technician who is responsible for performing in-plant surveys. NUREG-0654/FEMA REP-0l Revision 1 does not provide for any on-shift personnel for on-site out of plant surveys or for off-site surveys.NUREG-0654

/ FEMA REP-01 Revision 1 further identifies two RP technicians under the Protective Actions function for performing the tasks of Access Control, Radiation Protection coverage for repair, corrective actions, search and rescue, first aid, firefighting, Personnel monitoring, and dosimetry.

However, a note modification provides that these individuals may be assigned other functions, for example, the RP technician assigned to the in-plant surveys task and the individual assigned to the Chemistry/Radio-chemistry task under the Radiological Accident Assessment and Support of Operational Accident Assessment function.Revision 36.0 of the HNP Unit 1 and Unit 2 Emergency Plan provides two individuals for the task of off-site survey and an additional individual for the task of on-site (out of plant) survey.Collectively, these individuals include one individual qualified to perform the survey, an assistant to drive the team vehicle, and an individual is to coordinate communications between the survey team and the dose assessor.As part of the proposed SNC Fleet Emergency Plan the HNP on-shift staffing for the on-site out of plant survey will be performed by a single RP technician or other appropriately trained E7-6 Enclosure 7 to NL-16-0169 Hatch Staffing -Detailed Description and Technical Evaluation personnel.

SNC currently uses predesignated, readily accessible survey points around the HNP Unit 1 and Unit 2 plant site for collecting on-site survey data. Prior to dispatch of the on-site out of plant monitoring technician the dose assessor will brief the survey technician on the event conditions, direction of potential/actual plume path, potential radiological conditions, and so forth. The technician will be dispatched to one of the predesignated sample points in the downwind direction of the potential/actual plume path. The survey technician will then obtain the pre-staged on-site out of plant survey kit and vehicle and proceed to the designated location.

The dose assessor and the survey technician will have the capability to maintain near continuous communications, which will allow the dose assessor to redirect the technician while in route if needed. Since the designated sample points are on-site and readily accessible from the HNP Unit 1 and Unit 2 plant site road system, there will be no immediate need for the survey technician to travel off-site and this survey can be performed by a single individual without impacting the accuracy or timeliness of the survey.Additionally, the proposed SNO Fleet Emergency Plan HNP on-shift staffing will eliminate the on-shift individual coordinating communications between the out of plant survey technician and the dose assessor, and instead has the survey technician communicate directly with the dose assessor.

This will expedite communication of field survey readings to the dose assessor for input into the dose assessment program, resulting in a shorter completion time of dose assessment runs using actual field survey results.Revision 36.0 of the HNP Unit 1 and Unit 2 Emergency Plan provides for augmentation of two off-site*

survey teams as well as a Field Team Coordinator and Field Team Communicator at the EOF. The proposed staffing for the SNC Fleet Emergency Plan augments a single off-site survey team within 75 minutes of an Alert or higher declaration as well as maintaining the augmentation of the EOF Field Team Coordinator and Field Team Communicator positions currently provided.Installed effluent radiation monitors and in-plant radiation monitors are able to detect any radioactive release quickly and accurately.

The enhanced technology provided by the Safety Parameters Display System (SPDS) and the dose assessment computer model provides reliable visual indication of any radioactive plume and its calculated direction.

Quantification of a radioactive release is determined by dose assessment, which is performed by dedicated on-shift personnel then augmented by additional dose assessment personnel in the TSC and EOF. On-site, out of plant field teams and off-site field teams are typically used to verify the status of a potential release and Validate the dose assessment model. Dose assessment model validation strategies developed and implemented by the EOF staff typically include directing one team to track the leading edge of the radiological plume and one team to define the lateral edges of the plume and determine plume centerline radiological conditions.

If the field team survey data indicates a departure from the dose assessment model, the radiation surveys and air samples collected by these two field teams can be used to perform dose assessment back calculations.

SNC believes the two proposed field monitoring teams will be satisfactory for performing these surveys. To better support performing surveys off-site, the on-shift field team, which initially consisted of a single RP technician or appropriately trained individual, can be augmented by the on-shift dose assessor as a vehicle driver (once relieved by the EOF Dose Analyst).

Sufficient instrumentation, communication equipment, and transportation will be maintained on-site for augmenting and dispatching additional teams if needed.Regarding in-plant surveys, Revision 36.0 of the HNP Unit 1 and Unit 2 Emergency Plan provides for two RP technicians to perform in-plant surveys. The proposed SNC Fleet Emergency Plan HNP on-shift staffing provides one RP technician assigned to the task of E7-7 Enclosure 7 to NL-16-0169 Hatch Staffing -Detailed Description and Technical Evaluation in-plant surveys under the Radiological Accident Assessment and Support of Operational Accident Assessment function.

An additional RP technician will be provided for the Protective Actions function discussed later. However, since both of these individuals are qualified RP technicians, they will be available to collectively support either of these functions as needed. An additional two Radiation Protection technicians will respond within 75 minutes to support Radiological Accident Assessment (in-plant) function.

This will provide sufficient Radiation Protection resources to address the Radiological Accident Assessment needs of both the on-shift and augmented ERO personnel.

With improved installed instrumentation, dose calculation computer modeling, and dedicated on-shift staffing for dose assessment and on-site out of plant surveys, there is no more than minimal impact to the performance of these tasks as a result of the proposed staffing alignments in the SNC Fleet Emergency Plan.Plant System Engineering This functional area includes two tasks: Technical Support, and Repair and Corrective Actions.Technical Support NUREG-0654/FEMA REP-Ol Revision 1 guidance provided for a Shift Technical Advisor (STA) to be available on-shift to perform the Technical Support task including core/thermal hydraulics in response to the NUREG-0737 requirements resulting from the Three Mile Island accident.

Revision 36.0 of the HNP Unit 1 and Unit 2 Emergency Plan provides an individual to fulfill the STA task. The performance of the Technical Support task includes use of the SPDS computer, which graphically displays the pertinent parameters with trending and graphing capabilities, alarm functions, and color-coded indication for changes in state for various critical safety parameters.

This enhances critical parameter monitoring and the rapid identification and assessment of in plant conditions.

This remains unchanged for HNP in the SNC Fleet Emergency Plan.Repair and Corrective Actions NUREG-0654/FEMA REP-0! Revision 1 Table B-i specifies the functional area of Repair and Corrective Actions is to be provided on-shift by a total of two individuals who also "may be provided by shift personnel assigned other functions." It further states that the "position title or expertise" for the Repair and Corrective Actions task could be filled by Mechanical Maintenance I Radwaste Operator, Electrical Maintenance, or l&C Technician.

Due to the time needed to stabilize the plant and assess the event, the initial phase of an accident is not expected to involve a significant need for maintenance personnel.

Once plant status is understood and the plant is in a stable condition, attention can be focused on corrective maintenance that may be needed to restore plant capabilities.

Typically, the initial stages of Corrective Actions will be minor or of limited scope, such as:* Mechanical

-Identification and operation of faulty valves, clogged filters, packing and seal adjustments, or troubleshooting,* Electrical

-Identification and correction of tripped breakers and overloads, or hands-off troubleshooting,* I&C -Identification and correction of controller and set point adjustment, calibration, or hands-off troubleshooting.

Until the reactor is stabilized and the causal agents identified, actual repairs or realignment of plant equipment would not require large-scale maintenance support. The current version E7-8 Enclosure 7 to NL-16-0169 Hatch Staffing -Detailed Description and Technical Evaluation of the HNP Unit 1 and Unit 2 Emergency Plan provides for one mechanical journeyman, two electrical journeymen, and one instrument and controls technician on-shift to support the Repair and Corrective Action task. The proposed SNC Fleet Emergency Plan on-shift maintenance staffing numbers will be reduced to one on-shift electrical journeyman.

In addition to these personnel, a maintenance supervisor will be added to on-shift to provide supervisory oversight for repair and corrective actions, further enhancing the on-shift response capability.

A 10 CFR 50 Appendix E shift staffing evaluation demonstrated that no maintenance personnel were assigned tasks during the 75 minutes prior to augmentation.

Additionally, the proposed SNC Fleet Emergency Plan provides for augmentation of maintenance discipline specific leads in the 030 as well as an overall OSC Manager within 75 minutes of an Alert or higher emergency classification.

With the described on-shift maintenance staffing, there is no impact on the repair and corrective action tasks described under the Plant System Engineering, Repair and Corrective actions function as the result of removing the one electrical journeyman.

The NRC Public Meeting on July 16, 2015 discussing proposed changes to guidance regarding ERO staffing and augmentation (ML15174A309) identified that the proposed change primarily meets or exceeds the current regulatory guidance of NUREG-0654/FEMA REP-01 Revision 1 Table B-i and the proposed NUREG-0654/FEMA REP-01 Revision 2.Based on HNP Unit 1 and Unit 2 licensing basis (FSAR), the design philosophy with respect to Emergency Safety Features (ESF), and guidance for restoration, it is unnecessary to have additional Mechanical Maintenance, Electrical Maintenance and I&C Maintenance augmented within the 75 minute timeframe.

ESF systems are redundant in trains (physical separation) and have diversity of subsystems.

Therefore, the inoperability of different system components in different trains is not anticipated to result in a loss of function of the ESE.This allows flexibility in plant operations under circumstances where components in redundant subsystems may be inoperable.

Protective Actions (In-Plant)

For the Protective Actions (In-Plant) function, NUREG-0654/FEMA REP-01 Revision 1 specifies providing two personnel on-shift who "may be provided by shift personnel assigned other functions." The major tasks of this function are access control, RP coverage for repair, corrective actions, search and rescue, first aid, and firefighting, personnel monitoring, and dosimetry.

Revision 36.0 of the HNP Unit 1 and Unit 2 Emergency Plan provides four individuals for performing this function.

However, this number is modified by a note stating "may be provided by shift personnel assigned other functions." Under the proposed SNC Fleet Emergency Plan staffing a single RP technician will support this function.System Operators are typically dispatched prior to the call-out of augmented personnel.

Normally the initial response phase involves search and rescue operations or manual manipulation of equipment.

Maintenance actions in the initial response phase are anticipated to be minimal as discussed previously.

Installed plant area radiation monitors are used to provide indication of in-plant radiation levels prior to dispatch of personnel into the plant. This allows for personnel to be assigned the appropriate dose and dose rate alarms for their electronic personal dosimetry prior to dispatch and to assign additional Radiation Protection technician support as needed.Personnel accessing the Radiological Control Areas (RCA) at HNP Unit 1 and Unit 2 are required by procedure to obtain electronic personal dosimetry prior to entry. The same dosimetry is also used as a "key" to unlock turnstiles for access to the RCA. Radiation work permits (RWPs) establish the necessary preset warnings/alarms associated with the dosimetry.

E7-9 Enclosure 7 to NL-16-0169 Hatch Staffing -Detailed Description and Technical Evaluation During a declared emergency, the normal RCA entry process may use pre-prepared emergency RWPs using the Digital Alarming Dosimeters DADs. In the event the normal access system is non-functional an emergency reentry process has been developed to use the pre-prepared emergency RWP dose and dose rate alarms manually programed into the DADs. This ensures the teams dispatched to in-plant areas to perform any function during a declared emergency will be afforded ample warning/alarm prior to exceeding their allowed dose or dose rate. In-plant teams are briefed on radiological conditions prior to being dispatched, including plant event conditions, radiological conditions, dose and dose rate turn back values/alarms, and communications methods to be used if radiological conditions change or if unexpected radiological conditions are encountered.

Thus, under emergency conditions, responding personnel will be knowledgeable of dose rates in the area, and radiation protection personnel may not be required to accompany all teams into the plant areas. Dosimeters also can be programmed at the OSC by RP personnel as needed prior to team dispatch.

The proposed SNC Fleet Emergency Plan HNP on-shift staffing provides for a total of two Radiation Protection technicians between the Protective Actions (in-plant) and Radiological Accident Assessment (in-plant surveys) to ensure appropriate radiological protective measures are available to the on-shift staff.An additional two Radiation Protection technicians and an RP/Chemistry OSC lead will be augmented in the OSC within 75 minutes to support the Protective Actions (in-plant) function.This will provide sufficient Radiation Protection resources to address the needs of both the on-shift and augmented ERO personnel for the Protective Actions (in-plant) function.Fire Fighting There are no proposed changes to this area. The on-shift Fire Brigade is assigned this task throughout the emergency with off-site support provided by local fire departments.

A staffing analysis meeting the requirements of 10 CER 50 Appendix E.IV.A.9 for the proposed organization was performed.

The results of that analysis showed that the required response functions could 'be conducted with parallel activation of the fire brigade for the subject scenarios.

Rescue Operations and First Aid Per NUREG-0654/FEMA REP-01 Revision 1, the Rescue Operations and First Aid function"may be provided by shift personnel assigned other functions.

There are no proposed changes to this area. The HNP Unit 1 and Unit 2 Emergency Plan provides appropriately trained on-shift personnel to fulfill this function as a collateral duty. There are no additional personnel augmented for this task. Local off-site support provides for any additional assistance.

There are no proposed changes to this area.Site Access Controls and Personnel Accountability There are no proposed changes to this area. This function is part of the Security Contingency Plan and is staffed accordingly.

Onsite Emergency Response Organization (ERO) -10 CFR 50.47(b) (2)The current ERO provided in Revision 36.0 of the HNP Unit 1 and Unit 2 Emergency Plan was developed in response to NUREG-0654/FEMA REP-01 Revision 1. The ERO developed by NUREG-0654/FEMA REP-01 Revision 1 was developed without a specific technical basis. The Emergency Preparedness Enhanced Rulemaking of November 23, 2011 required the capabilities of the on-shift staff to be validated by a formal analysis.

This requirement was E7-10 Enclosure 7 to NL-16-0169 Hatch Staffing -Detailed Description and Technical Evaluation documented in 10 CFR 50 Appendix E.IV.A.9.

In support of this submittal, the proposed ERO for the HNP Unit 1 and Unit 2 Site was analyzed and it was determined that the on-shift staff proposed is capable of performing the response functions required of the revised rule.Reason for the Chanqe The proposed ERO in the SNC Fleet Emergency Plan provides a standard complement of emergency response positions, titles, duties, and responsibilities.

This will result in a more effective interface between ERO members at the sites and their counterparts at the SNC Fleet EOF. Having a common ERO organization for the SNC Fleet will also support sharing of ERO resources between affected and non-affected stations during emergencies.

Establishing an appropriately staffed SNC Fleet standard on-shift and an augmented ERO staffing model with an SNC Fleet standard definition for ERO augmentation time is a practical and prudent alternate method to ensure effective and timely emergency response augmentation.

Details associated with the on-shift ERO, revised augmented ERO, and revised key responsibilities and tasks as identified in NUREG-0654/FEMA REP-01 Revision 1, are included in Enclosure 9.Planning Basis for Augmented Emergency Response Organization (ERO)Positions have been designated as 75 minutes responders in the TSC, OSC, EOF, and JIC.These positions perform major functions and supporting functions in each facility.

The tables below outline these positions and functions as provided in the proposed HNP Unit 1 and Unit 2 Emergency Plan.E7-11 Enclosure 7 to NL-16-0169 Hatch Staffing -Detailed Description and Technical Evaluation TSC 75 Minute Augmentation ERO Major Functional Area Major Task Position Title Emergency Director (ED)TSC Manager Emergency Direction and Operations Supervisor Control Security Supervisor*

Support Coordinator**

Notify licensee, state, local, Emergency Notification and federal personnel

& System (ENS) Communicator Notification/Communication maintain communication H PN Communicator Intra-facility Communications Emergency Response Facility (ERF) Communicator Offsite Dose Assessment Radiation Protection (RP)Radiological Accident Supervisor Assessment and Support of OfiesresNtapial o hsfclt Operational AccidentOfstsuvyNoaplcbeorthsaiiy Assessment Onsite and in-plant surveys Chemistry/Radio Chemistry Chemistry Support Technical Support Engineering Supervisor Reactor Engineer Engineering Support (2)Plant System Engineering, Repair and Corrective Actions Repair and corrective Maintenance Supervisor actions Access Control Not applicable for this facility RP coverage for repair, corrective actions, search Protective Actions and rescue, first aid &firefig hting Personnel monitoring

____ ___ ____ ___ ____ ___ Dosimetry

_ _ _ _ _ _ _ _ _ _ _ _ _*Security Supervisor filled by one of the on-shift Security Supervisors.

- Support Coordinator does not have a 75 minute augmentation time.E7-12 Enclosure 7 to NL-1 6-01 69 Hatch Staffing -Detailed Description and Technical Evaluation OSC 75 Minute Augmentation ERO Major Functional Area Major Tasks Position Title Emergency Direction and 0S0 Manager Control Notify licensee, state, local Not applicable for this facility Notification/Communication anferlprsnl&

maintain communication I ntra-facility communications ERF Communicator Radoloicl AcidntOffsite Dose Assessment Not applicable for this facility Rassessmentand Suppornt of Offsite surveys Field Monitoring Team Assesmet ad Supor ofPersonnel (2)OpssserainalAcdn Onsite and in-plant surveys RP Technicians (2)AssssmntChemistry/Radio Chemistry Chemistry Technician Technical Support Not applicable for this facility Repair and corrective Mechanical Maintenance Plant System Engineering, actions Group Lead Repair and Corrective Actions Electrical Maintenance Group Lead I&C Maintenance Group Lead Access Control RP / Chemistry Group Lead* RP coverage for repair, RP Technicians (2)corrective actions, search Protective Actions and rescue, first aid &fi ref ighting* Personnel monitoring

Dosimetry E7-13 Enclosure 7 to NL-16-0169 Hatch Staffing -Detailed Description and Technical Evaluation EOF 75 Minute Augmentation ERO Major Functional Area Major Task Position Title Emergency Direction and EOF Director ED Control ____________EOF Manager Support Coordinator*

Emergency Communication Coordinator Security Coordinator Offsite Response Coordinator Administrative Support Staff *Liaisons (at EOCs)*-GA-AL-SC Notification/Communication Notify licensee, state, local ENN Communicator and federal personnel

& ENS Communicator maintain communication HPN Communicator Intra-facility ERF Communicator Communications Nuclear Spokesperson Technical Assistant News Writer Field Team Communicator Radiological Accident Offsite Dose Assessment Dose Assessment Supervisor Assessment and Support of Dose Analyst Operational Accident Offsite surveys Field Team Coordinator Assessment Onsite and in-plant surveys Not required in this facility Chemistry/Radio Chemistry Not required in this facility Plant System Engineering, Technical Support Technical Supervisor Repair and Corrective Actions Repair and corrective Not required in this facility actions Protective Actions Access Control Not required in this facility RP coverage for repair, corrective actions, search and rescue, first aid &firefighting Personnel monitoring

______________________

Dosimetry* Support Coordinator, Administrative Support Staff, Liaisons (at EOCs) GA, AL, SC do not have a 75 minute augmentation time.E7-14 Enclosure 7 to NL-16-0169 Hatch Staffing -Detailed Description and Technical Evaluation JIC Staff*Functional Area Major Task Position Title Media Response Media Response Public Information Director Nuclear Spokesperson Technical Assistant JIC Manager JIC Assistant Facility Coordinator Clerical Staff Security Public Response Coordinator Public Response Staff Media Relations______________________

_ ____ ___ ___ ____ ___ ___ Representative

JIC Staff do not have a 75 minute augmentation time.Minimum staff positions have been identified for each facility.

Facility activation may be completed upon filling of minimum staffing positions and completion of a briefing on the event to ensure personnel in these positions are ready to accept responsibility for their functions.

Minimum staffing positions for the TSC Organization are as follows:* TSC Emergency Director (ED)* TSC Emergency Response Facility (ERE) Communicator

TSC Manager* TSC Operations Supervisor

TSC ENS Communicator

TSC Radiation Protection (RP) Supervisor

TSC Engineering Supervisor Minimum staffing positions for the Operations Support Center (OSC) Organization are as follows:* OSC Manager* OSC Emergency Response Facility (ERF) Communicator

OSC RP / Chemistry Group Lead Minimum staffing positions for the EOF Organization are as follows:* EOF Emergency Director (ED)* EOF Emergency Response Facility (ERF) Communicator

EOF Manager° EOF Dose Assessment Supervisor

EOF Dose Analyst* EOF ENN Communicator Minimum staffing positions for the Joint Information Center (JIC) Organization are as follows:* Public Information Director (PID)E7-1 5 Enclosure 7 to NL-16-0169 Hatch Staffing -Detailed Description and Technical Evaluation

JIC Manager* Media Relations Representative

Public Response Coordinator In addition to the functional analysis provided, the key Emergency Response Facilities were analyzed to determine the minimum staffing (both numbers and positions) needed for the facilities to activate the facilities and begin facility operations.

Any personnel determined to be required to support the minimum staff activation and initiation of activities were added to the revised augmented ERO.Program Enhancements The following section discusses technical changes in plant systems, dose assessment, procedures, and training which have been completed in order to better support on-shift functions and ease operator burden. Additional information regarding on-shift and augmented positions and their responsibilities as identified in NUREG-0654/FEMA REP-01 Revision 1 are outlined in Enclosure 9.Plant Computer System At the time of the original approval of the 1981 version of the HNP Unit 1 and Unit 2 Emergency Plan, the site used an Emergency Response Facility Computer System. The operator interface consisted of a small number of printers located in the control room and computer room.In 1986, the Emergency Response Facility Computer System was housed in the TSC. The design criteria were based on the requirements of NUREG-0737, Supplement 1, for a Safety Parameter Display System (SPDS) and the upgrading of ERrs. The requirements were met or exceeded by a system of grouped displays of parameters from which plant safety status can be rapidly assessed, provided by Proteus software.

The system upgrade included introduction of automatic updates to plant overview and system displays on the computer monitors, consolidated safety parameter displays, and increased frequency of parameter updates.In 2008/2009, the site integrated SPDS into the plant process computer.

This significantly improved plant monitoring capabilities in the control room as well as in the site's ERrs by integrating other independent standalone systems.Benefits of the upgraded systems include:* Programming capability for automated response such as indication of critical parameter alarms.* Improved plant monitoring capability for ED functions.

Fewer keystrokes required to switch between graphical displays.* Real time plant data available through graphical displays.* Functions are available to any desktop computer through the plant's site-wide intranet.Computer basic functions are supported by instrument buses with back-up power provided by vital buses.Dose Assessment The original HNP dose assessment software used manual entry of basic meteorological data and either manual entry of radiological data or use of internally stored source terms. The HNP dose assessment capability was upgraded in the mid-i1990s when the MIDAS dose assessment program was installed on the ERF Computer to provide HNP a full Class B dose assessment model.E7-1 6 Enclosure 7 to NL-16-0169 Hatch Staffing -Detailed Description and Technical Evaluation Improvements have been made to the dose assessment program resulting in minimal user interface required to quickly produce results. Radiological dose assessment has benefited from technological advances that make dose assessment simpler and less time-consuming.

Dose assessment is currently performed by on-shift operations personnel using the prompt dose assessment mode of the MIDAS-N U program, which is a Class A model. Once the TSC and EOF staff arrive, a full Class B model of the MIDAS-NU program is employed to perform dose assessment.

This program supports multi-unit and multi-accident assessment of radiological releases.

The MIDAS-NU program has minimal data entry needs and a minimal number of program windows the user needs to access to perform a dose projection.

With the use of the dose assessment program, as well as plant status, meteorological, and radiation monitoring data, one person can easily and rapidly perform dose assessments during emergency conditions.

Specifically designed displays have been developed for obtaining the necessary plant, radiological effluent, area radiation monitor, and meteorological information for dose assessment personnel on-shift using the Meteorological Information Dose Assessment System-Nuclear (MIDAS-NU) program.Automated Call-Out System Automated call-out systems have been enhanced to streamline processes for activation of the ERO. A single phone call initiates rapid notification of ERO members, in lieu of individual calls to fill the ERO positions included in the Emergency Plan. The system includes a primary activation location as well as a remotely located back-up capability to ensure uninterrupted operation.

Procedure Improvements Emergency Operations Procedures (EOPs)/Abnormal Operating Procedures)AOPs)

Since the original emergency plan approval, EOPs have been improved through industry initiatives.

EOPs now use a symptom-based approach that demands less assessment and interpretation of plant conditions by the operating crews. EOPs interface well with new technology such as IPC. EOP curves are generated by IPC to graphically display plant conditions relative to limits or required actions.Emergency Plan Implementing Procedures (EPIPs)In 2008 (Reference NL-08-01 60; Revision 27.0 of HNP Unit 1 and Unit 2 Emergency Plan)HNP Unit 1 and Unit 2 updated the classification methodology to NEI 99-01, Revision 4.EALs now incorporate guidance that has simplified the classification process, including the use of an overview matrix of EAL initiating conditions and threshold values, which streamlines the process of evaluating EALs against plant conditions.

Training Improvements Operations Training Training is used to strategically drive improved performance at HNP Unit 1 and Unit 2.Since NRC approval of the HNP Unit 1 and Unit 2 Emergency Plan, the application of the Systematic Approach to Training (SAT) has resulted in developing a task list for Operations personnel.

The SAT process ensures training is conducted to industry-accepted standards and has led to accreditation of the Operations Training Programs by the National Academy for Nuclear Training.E7-1 7 Enclosure 7 to NL-1 6-01 69 Hatch Staffing -Detailed Description and Technical Evaluation A dynamic simulator is routinely used during Operations Training.

Simulator evaluations include emergency response scenarios that periodically exceed 75 minutes in length and are part of the requalification cycle. Simulator scenarios are designed to be realistic and reflect a wide range of plant conditions, including emergency conditions.

During evaluated simulator sessions, the control room staff is taken from normal operation to accident conditions resulting in declaration of at least one event, which can range from Unusual Event to General Emergency.

The crew performs critical tasks, classification, accident mitigation, response prioritization, and communications without augmentation from additional responders.

The proficiency of the control room staff to perform these functions while maintaining situational awareness, without additional support, is assessed in every training cycle.The Licensed Operator Continuing Training (LOOT) Program includes licensed crew performance evaluations that consider the scenario guidance attributes of INPO Operations Department Standing Instruction, ODSI-3, and "Operations Department Guidance." Attachment C of ODSI-3 provides guidance on the realistic integration of the emergency response into crew performance evaluations.

The purpose is to ensure the crew performance evaluations realistically represent the additional challenges that the emergency plan responsibilities add to the crew's ability to manage an event. Representing the event as realistically as possible, which includes the additional challenges of emergency plan responsibilities, helps promote the situational awareness necessary during a real event.STA Training The Shift Technical Advisor (STA) was originally trained as an advisor to the operating shift per NUREG-0737.

In 1990, additional guidelines were developed by INPO for the training of STAs. This is detailed in the document INPO 90-003, Guidelines for Training and Qualifications of Shift Technical Advisors.The INPO Guidelines describe the role of the STA. The STA performs independent assessments of plant operating concerns, technical support, appropriate corrective actions, analysis of events and their effects, effectiveness of response(s) to emergent conditions, classifications of emergencies, development of recommendations to protect the public, and any other actions related to critical safety functions and plant safety during abnormal and emergency situations.

By routinely monitoring equipment and plant operations, the STA can focus on preventive actions in order to mitigate the consequences of an accident and protect public health and safety.Increases in On-Shift Staffing There has been an increase in on-shift staffing from what was required in the 1981 Revision of the HNP Unit 1 and Unit 2 Emergency Plan, in order to ensure adequate performance of the major emergency plan functions and tasks. A total of 25 persons are identified for on-shift staffing in Revision 36.0 of the HNP Unit 1 and Unit 2 Emergency Plan, which is an increase from the total of 10 persons in the regulatory guidance provided by NUREG-0654/FEMA REP-01 Revision 1. A comparative chart depicting on-shift and augmented staffing based on NUREG-0654/FEMA REP-01 Revision 1, the 1981 version of the HNP Unit 1 and Unit 2 Emergency Plan, Revision 36.0 of the HNP Unit 1 and Unit 2 Emergency Plan, and proposed revisions are included in Enclosure 9.Enhancements in Information Sharing with Offsite Agencies There has been a dramatic increase in the ability of the site to share event-specific information with Offsite Response Organizations (OROs) from the one-to-one telephone systems at the time E7-1 8 Enclosure 7 to NL-16-0169 Hatch Staffing -Detailed Description and Technical Evaluation of the 1981 Revision of the HNP Unit 1 and Unit 2 Emergency Plan. Real-time plant data is communicated to the Nuclear Regulatory Commission using the approved Emergency Response Data System (ERDS). Additionally, local OROs are provided real-time data with automated methods (currently Web EOC). These enhancements provide more timely and accurate information of actual plant conditions than was originally available.

Improvement Summary The improvements to staffing, equipment, procedures, communication of plant information, and training since initial approval of the HNP Unit 1 and Unit 2 Emergency Plan have resulted in a significant increase in on-shift capabilities and knowledge.

The ERO maintains the depth and capability for continuous 24-hour coverage of the Emergency Response for a protracted period.Summary Based on overall improvements in technology, procedures, training, and staffing levels available to ERO since the original implementation of the guidance contained in NUREG-0654/FEMA REP-Ol Revision 1, the proposed Emergency Response Organization is capable of implementing the Emergency Plan in accordance with the requirements of 10 CER 47 and 10 CFR 50 Appendix E.E7-19 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 6 Farley Justification Matrix FARLEY NUCLEAR POWER PLANT JUSTIFICATION MATRIX Purpose The purpose of this attachment is to identify the commitments in the current Farley Nuclear Power Plant Emergency Plan Revision 64, identify the equivalent or modified commitment in the integrated Fleet Emergency Plan and Farley Site Annex, and justify on a commitment-by-commitment basis the proposed License Amendment.