Text

Southern Nuclear Operating Company Response to Third Request for Additional Information Regarding Standard Emergency Plan: Cover Letter, Attachment 1 and Enclosures 1 - 10
	ML16167A415
Person / Time
Site:	Hatch, Vogtle, Farley
Issue date:	06/09/2016
From:	Pierce C; Southern Nuclear Operating Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML16167A468	List: NL-16-0169, Southern Nuclear Operating Company Response to Third Request for Additional Information Regarding Standard Emergency Plan: Enclosure 11, Vogtle Units 1 and 2 Standard Emergency Plan Annex (Marked-Up Pages and Clean Copy); NL-16-0628, Southern Nuclear Operating Company Response to Third Request for Additional Information Regarding Standard Emergency Plan: Cover Letter, Attachment 1 and Enclosures 1 - 10;
References
	NL-16-0628
	Download: ML16167A415 (805)
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{{#Wiki_filter:Charles R. Pierce Southern Nuclear Regulatory Affairs Director Operating Company, Inc. 40 Inverness Center Parkway Post Office Box 1295 SOUTHERN Birmingham, AL 35242 Tel 205.992.7872 NUCLEAR Fax 205.992.7601 A SOUTHERN .COMPANY NL-16-0628 JUN 0 9 2016 10 CFR 50.90 Docket Nos.: 50-321 50-348 50-424 52-025 50-366 50-364 50-425 52-026 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 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 Response to Third Request for Additional Information Regarding Standard Emergency Plan Ladies and Gentlemen: By letter dated August 31, 2015 (NL-15-1392), Southern Nuclear Operating Company (SNC) requested license amendments (LARs) for approval of a fleet standard emergency plan (SEP) for Edwin I. Hatch Nuclear Plant Units 1 and 2 (Hatch), Joseph M. Farley Nuclear Plant Units 1 and 2 (Farley), and Vogtle Electric Generating Plant Units 1, 2, 3 and 4 (Vogtle) (ML15246A045). In addition, SNC is requesting an amendment to the Combined Licenses (COLs) for VEGP, Units 3 and 4, to address conforming changes to emergency planning inspections, tests, analyses, and acceptance criteria (ITAAC) resulting from the proposed changes. By letter dated April 14, 2016, the U.S. Nuclear Regulatory Commission (NRG) issued its third Requests for Additional Information (RAls) (ML16096A217). Specifically, the NRG staff reviewed the requested license amendment against the standards of 10 CFR 50.47 a11d Appendix E to 10 CFR 50. The NRG RAls and the SNC responses are provided in Attachment 1. Additional information that supports the SNC responses to the RAls is attached in the enclosures. The enclosures including revisions to the SNC documents which were enclosed in the August 31, 2015 submittal (ML15246A045), updated on February 17, 2016 (ML16060A283) in response to the NRC's first set of RAls (ML15334A009), and then updated again on April 8, 2016 (ML16105A194) in response to the.NRC's second set of RAls (ML16029A035). Also included is the conforming change to Table 2.2.A of the Vogtle 3&4 Annex (See Enclosure 14) per SNC correction letter dated May 26, 2016 (ML16147A294). 16 (+X~. 1

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U.S. Nuclear Regulatory Commission NL-16-0628 Page2 SNC is notifying the states of Georgia and Alabama of this response to the NRG RAI by transmitting a copy of this letter and enclosures to. the designated state official. This letter contains no new regulatory commitments. If you have any questions, please contact Ken McElroy at (205) 992-7369. Mr. C. R. Pierce states he is the Regulatory Affairs Director for Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and, to the best of his knowledge and belief, the facts set forth in this letter are true.

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                                                                                     'I';   '.       .. ... 1, C. R. Pierc*e                                                                                                   .*,

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day of-----'-~-!-=----'-----' 2016. My commission expires: /D ~ g~ JC> t1 - NRG RAls and SNC Responses Enclosures (Changes from the original August 31, 2015 SEP enclosures as updated on February 17, 2016 and April 8, 2016 in response to the *first and second set of RAls):

1. Evaluation of the Proposed Changes - LAR for the Adoption of a Standard Emergency Plan for the SNC Fleet (No changes)

2. SNC Standard Emergency Plan. (Marked-up pages and clean copy)

3. Corporate Joint Information Center Staffing - Detailed Description and Technical Evaluation. (Deleted)

4. Farley Staffing - Detailed Description and Technical Evaluation. (Marked-up pages and clean copy)

5. Farley Standard Emergency Plan Annex. (Marked-up pages and clean copy)

6. Farley Justification Matrix (Marked-up pages and clean copy)

7. Hatch Staffing - Detailed Description and Technical Evaluation. (no changes)

8. Hatch Standard Emergency Plan Annex (Marked-up pages and clean copy)

9. Hatch Justification Matrix. (Marked-up pages and clean copy)

U. S. Nuclear Regulatory Commission NL-16-0628 Page 3 1O. Vogtle (Units 1 and 2) Staffing - Detailed Description and Technical Evaluation. (no changes)

11. Vogtle (Units 1 and 2) Standard Emergency Plan Annex. (Marked-up pages and clean copy)

12. Vogtle (Units 1 and 2) Justification Matrix. (Marked-up pages and clean copy)

13. Vogtle (Units 3 and 4) Staffing - Detailed Description and Technical Evaluation. (no changes)

14. Vogtle (Units 3 and 4) Standard Emergency Plan Annex. (Marked-up pages and clean copy) *

15. Vogtle (Units 3 and 4) Justification Matrix. (Marked-up pages and clean copy)

16. Evaluation of Proposed Changes - LAR for the Revision to Vogtle 3 and 4 Emergency Planning ITAAC. (Marked-up pages and clean copy)

17. Vogtle (Units 3 and 4) Revision to Unit 3 COL Appendix C - Proposed Changes - Markups. (Marked-up pages)

18. Vogtle (Units 3 and 4) Revision to Unit 4 COL Appendix C - Proposed.

Changes - Markups. (Marked-up pages)

19. Off-site Response Organizations - Letters of Consultation and Concurrence (No changes) cc: Nuclear Regulatory Commission Mr. W. M. Dean, Director of the Office of Nuclear Reactor Regulations Ms. C. Haney, Regional Administrator Mr. M. Delligatti, Deputy Division Director, DNRL Mr. L. Burkhart, Branch Chief, LB4, DNRL Mr. M. E. Ernstes, Branch Chief, DRP, Rll Mr. R. E. Martin, NRR Senior Project Manager- Vogtle 1 & 2 Mr. S. A. Williams, NRR Project Manager - Farley Mr. M. D. Orenak, NRR Project Manager - Hatch Mr. C. Patel, NRO Project Manager - Vogtle 3 & 4 Mr. P. Kallan, Senior Project Manager- Vogtle 3 & 4 Mr. B. M. Bavol, Project Manager - Vogtle 3 & 4 Ms. R. Reyes, Project Manager - Vogtle 3 & 4 Ms. M. A. Sutton, Project Manager - Vogtle 3 & 4 Mr. G. Khouri, Senior Project Inspector - Vogtle 3 & 4 Mr. D. H. Hardage, Senior Resident Inspector- Hatch Mr: A. M. Alen, Resident Inspector- Vogtle 1 & 2 Mr. P. K. Niebaum, Senior Resident Inspector- Farley Mr. J. D. Fuller, Senior Resident Inspector, Vogtle 3 & 4 Ms. S. Temple, Resident Inspector - Vogtle 3 & 4 Alabama Department of Public Health Dr. T. M. Miller, State Health Officer State of Georgia Mr. J. H. Turner, Director- Environmental Protection Division

U.S. Nuclear Regulatory Commission NL-16-0628 Page 4 Blind Copy List (without enclosures unless noted): Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Mr. M. D. Rauckhorst, Construction V.P. -Vogtle 3-4

Mr. D. H. Jones, Vice President Technical Compliance - Vogtle 3-4 Ms. K. D. Fili - Vice President - Operational Readiness Ms. C. A. Gayheart, Vice President - Farley Mr. D. A. Vineyard, Vice President - Hatch Mr. B. K. Taber, Vice President - Vogtle 1-2 Mr. D. R. Madison, Vice President - Fleet Operations Mr. M. D. Meier, Vice President - Regulatory Affairs Mr. B. J. Adams, Vice President - Engineering Mr. C. R. Pierce, Regulatory Affairs Director - Fleet Mr. B. H. Whitley, Regulatory Affairs Director - Nuclear Development Mr. M. J. Yox, Regulatory Affairs Director - Vogtle 3-4 Ms. B. L. Taylor, Regulatory Affairs Manager - Farley Mr. G. L. Johnson, Regulatory Affairs Manager - Hatch Mr. G. W. Gunn, Regulatory Affairs Manager-Vogtle 1-2 Mr. W. A. Sparkman, Licensing Manager- Nuclear Development Mr. T. W. Yelverton - Commercial Director - Vogtle 3-4 Mr. D. L. Fulton - Nuclear Development Environmental Manager Mr. J.C. Harrelson - Project Manager Mr. T. R. Takats - Engineering Supervisor Mr. J. P. Redd - Licensing Supervisor Mr. J. G. Hall - Emergency Preparedness Supervisor RTYPEs: CFA04.054; CHA02.004; CVC7000; VND.Ll.LOO (w/enclosures)

File AR.01.02.06 (w/enclosures) Oglethorpe Power Corporation Mr. M. W. Price Mr. Ms. K. T. Haynes Ms. A Whaley Municipal Electric Authority of Georgia Mr. J. E. Fuller Mr. S. M. Jackson Dalton Utilities Mr. T. Bundros WECTEC Ms. K. Stoner Mr. C. A. Castell Westinghouse Electric Company, LLC Mr. R. Easterling Mr. J. W. Crenshaw Mr. C. D. Churchman Mr. L. Woodcock Mr. P.A. Russ Mr. G. F. Couture Mr. M. Y. Shaqqo Mr. J. E. Hesler, Bechtel Power Corporation Ms. L.A. Matis, Tetra Tech NUS, Inc. Dr. W. A. Jacobs, Jr., Ph.D., GOS Associates, Inc. Mr. S. Roetger, Georgia Public Service Commission Ms. S. W. Kernizan, Georgia Public Service Commission Mr. K. C. Greene, Troutman Sanders Mr. S. Blanton, Balch Bingham Mr. R Grumbir, APOG Ms. A. RiceMr. J. A. Bouknight, South Carolina Electric & Gas Company Mr. D. Kersey, South Carolina Electric & Gas Company Mr. B. Kitchen, Duke Energy Mr. S. Franzone, Florida Power & Light

ATTACHMENT 1 Third Set of Requests for Additional Information On License Amendment Request For Fleet Standard Emergency Plan 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 Un!ts 1 and 2; ' Vogtle Electric Generating Plant Units 3 and 4 SNC Response

SNC Response to 3rd Set of RAls Standard E-Plan LAR Attach. 1 Universal RAls that Apply to all Plants RAl-GEN-1 Please confirm that no current emergency plan commitments from the approved emergency plans for HNP, Units 1 and 2; FNP, Units 1 and 2; and VEGP, Units 1, 2, 3, and 4, have been deleted. SNC Response. SNC has reviewed its commitment database for Farley (Units 1&2), Hatch (Units 1&2) and Vogtle (Units 1,2,3&4) and has determined that no changes are proposed beyond those already submitted to the NRC in the Standard Emergency Plan (SEP) License Amendment Request (LAR). Two specific points related to this question are:

1) SNC has reduced the level of detail in the SEP and site-specific Annexes and placed these details in the emergency plan implementing procedures. Put simply,.

the SEP and Annexes document "what" the plan is and the implementing procedures document "how the plan is executed.

2) On Vogtle Units 3 & 4, the initial proposed staffing was estimated prior to the NEI 10-05 staffing assessment. This subsequent analysis demonstrated that SNC's initial proposed staffing estimated were extremely conservative.

RAl-GEN-2 The proposed SNC SEP removed significant details contained in currently approved emergency plans for the respective sites. As such, please address the following:

a. Please describe where the level of detail removed from the approved emergency plans for the respective sites, and necessary to implement the proposed SNC SEP and site-specific annexes, will be specifically addressed (i.e.,

emergency plan implementing procedures) and process to be used to maintain in . order to ensure the continued effective implementation of the SNC SEP and site-specific annexes. SNC Response The SNC SEP and Annexes document the commitments which facilitate implementation of the Emergency Plan. The details of how to implement the commitments are contained in the Emergency Plan Implementing Procedures; The SEP Annexes have been revised to provide a cross reference of the required procedures to the Plan by section. The u*pdated Annexes are provided as part of this response. SNC will continue to use its current procedures for evaluating changes to its implementing procedures, including 10 CFR 50.54(q) requirements, in order to Page 1

SNC Response to 3rd Set of RAls Standard E-Plan LAR Attach. 1 ensure the continued effective implementation of the SNC SEP and site-specific annexes. RAl-GEN-2

b. Consistent with the guidance in Section 11.P.7 of NUREG-0654, please provide an appendix for each respective site that lists, by title, "procedures required to implement the plan. The listing shall include the section(s) of the plan to be implemented by each procedure."

SNC Response The.Annexes have been revised to include an Appendix meeting the guidance provided in Section 11.P.7 of NUREG-0654 including the reference to specific plan sections implemented by the various procedures. The updated Annexes are provided as part of this response. RAl-GEN-2

c. Consistent with the guidance in Section 11.P.B of NUREG-0654, please provide a cross-reference to the evaluation criteria in Section II to NUREG-0654 for each respective site.

SNC Response An Appendix to each Annex has been developed meeting the criteria of Section 11.P.8 of NUREG-0654 and is provided as part of the response. Fleet Emergency Plan RAls RAl-FLEET-1 Section A.1.1 describes the NRC responsibilities during an emergency, stating, "The NRC acts as the lead federal agency for technical matters during a nuclear incident. .. " The statement is inconsistent with the language in the National , Response Framework/Nuclear-Radiological Annex; where it states, "The NRC is the coordinating agency for incidents at or caused by a facility or an activity that is licensed by the NRC or an Agreement State." Please revise the language to reflect the designated role of the NRC in the above-referenced documents or provide further basis for retaining the proposed statement (Note: Also on page E12-47 of the VEGP, Units 1 and 2, Justification Matrix.) SNC Response The Standard Emergency Plan, Section A.1.1 and the Justification Matrices have been revised to reflect the language identified in RAl-FLEET-1 and are provided as a part of this response. RAl-FLEET-2 Section A.2.1 contains the following statements: Page2

SNC Response to 3rd Set of RAls Standard E-Plan LAR Attach. 1 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 .... 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. In addition, in Section A.2.1, it also states that the Georgia Emergency Management Agency has "responsibilities for coordinating the state of Georgia response to emergencies at nuclear power plants," while the Department of Natural Resources Environmental Protection Division has "primary responsibility for implementation and administration of the state radiological emergency response function." These statements appear to be contradictory or at least confusing. Please revise, as necessary, to clarify the roles. SNC Response Alabama The Governor of the State of Alabama has* overall responsibility for emergency preparedness and response concerning a nuclear incident. The Alabama Emergency Management Agency (AEMA) is the primary offsite agency for radiological emergencies. The AEMA Director has responsibility for coordinating the activities of all departments, agencies, and organizations of state government and local emergency management agencies to carry out emergency functions relating to a nuclear incident. The AEMA Director has responsibility for maintaining and operating a State Emergency Operation Center (SEOC) with procedures and equipment capable of continuous (24-hour) operations for an extended period. The station sends emergency notifications to the 24-hour notification point maintained by AEMA, who in turn, informs other state agencies. The Alabama Department of Public Health, Office of Radiation Control (ADPH-ORC) has responsibility for issuing orders for protective actions necessary due to a radiological emergency. ADPH-ORC has responsibility for evaluating radiation hazards, ordering protective actions, advising state and local agencies, coordinating radiological technical assistance, and disseminating information to ensure the health and safety of the population. ADPH-ORC provides technical support to AEMA including radiation monitoring of areas around the station. / AEMA keeps ADPH-ORC informed as notifications come in from the station. Georgia The Governor of the State of Georgia has general direction and control of the Georgia Emergency Management Agency (GEMA) with overall responsibility for emergency management functions. GEMA is the primary offsite agency for coordinating responses to emergencies. GEMA provides for 24-hour notification and staffing of the State Operations Page3

SNC Response to 3rd Set of RAls Standard E-Plan LAR Attach. 1 Center (SOC) and/or the Forward Emergency Operations Center (FEOC), as required, throughout an event. As stated in the Georgia Emergency Operations Plan (GEOP), GEMA coordinates with state, county and municipal agencies, including the Department of Natural Resources-Environmental Protection Division (DNR-EPD). DNR-EPD has responsibility for the state radiological and hazardous material functions. The SEP Section A.2.1. (Alabama) and Section A.2.2 (Georgia) and the Justification Matrices have been revised to clarify the respective State organizational responsibilities. RAl-FLEET-3 Section E.1.1 appears to have an inadvertent error in the following bolded wording: "NRC-will be notified by the Headquarters Operations Officer immediately following state and local notifications, but within an hour of an emergency classification." Please revise, as necessary, to clarify. SNC Response Section E.1.1 of the SEP has been revised to address notification of the NRC by the impacted site. The revised Plan is provided as part of this response. RAl-FLEET-4 In Section E.2.5.2, it states (balding added), "State and local emergency management will detail the Prompt Notification System (PNS) activation." It is unclear what the word "detail" refers to, and there is no additional perspective on the meaning of PNS versus generic alert and notification system (ANS) terminology, as there is no additional reference in the plan. Please revise as necessary to clarify. SNC Response The Standard Emergency Plan, Section E.2.5.2 has been revised to clarify that details for activation are provided in State and local emergency management plans and procedures. In addition, the ANS sections in the Standard Plan (Section E.2.5.1) and respective Annexes (Section 4.2) have been revised to better describe the overall ANS and concept of operations in response to this particular question and subsequent related questions. The revised Plan and Annexes are provided as part of this RAI response. RAl-FLEET-5 Section F.1.4 incorrectly references the acronym "FTS" as the Federal Telephone System rather than the correct terminology-- Federal Telecommunications System. Please revise as appropriate. Additionally, please confirm that a quarterly check of phone numbers is still required in the SNC SEP or site-specific annex (Section 11.P.10 of NUREG-0654). Page4

SNC Response to 3rd Set of RAls Standard E-Plan LAR Attach. 1 SNC Response The Standard Emergency Plan, Section F.1.4 has been revised to address the correct terminology for the FTS. Additionally, Section F.4 has been added to address quarterly checks of phone numbers. The revised Plan is provided as part of the response. RAl-FLEET-6 Section H.2.1 states, "Staffing and activation of the EOF is mandatory upon declaration of an Alert or higher classification." Please explain why there is no timing criteria associated with this section, similar to Section H.1, or modify the section to address as appropriate. SNC Response The Standard Emergency Plan, Section H.2.1 has been revised to use the same wording as the Technical Support Center (TSC) activation including the timeliness criteria of 75 minutes. The revised Plan is provided as part of this response. RAl-FLEET-7 Section H.8 states, "Emergency facilities and equipment are inspected and inventoried using appropriate administrative or department procedures." Please confirm that provisions to inspect, inventory, and operationally check emergency equipment/instruments at least once each calendar quarter and after each use is still required in the SNC SEP or site-specific annex (Section 11.H.1 O of NUREG-0654). SNC Response The Standard Emergency Plan, Section H.8 has been revised to include the criteria addressed in RAl-FLEET-7. The revised Plan is provided as part of this response. RAl-FLEET-8 In Section N.1, it states (balding added), "Remedial exercises will be required if the emergency plan is not satisfactorily tested during the Biennial Exercise, and it is determined that reasonable as~urance that adequate protective measures are not taken in the event of a radiological emergency." In the context of exercises, please clarify whether the bolded wording should read "cannot be taken" and revise accordingly. SNC Response The Standard Emergency Plan, Section N.1 has been revised to read "cannot be taken". The revised Plan is provided as part of this response. Page 5

SNC Response to 3rd Set of RAls Standard E-Plan LAR Attach. 1 RAl-FLEET-9 In Section N.1.3, "Ingestion Exposure Pathway Exercise," two unrelated subject areas are combined, resulting in the intent being confusing/unclear. Specifically, it states: States within an ingestion exposure pathway EPZ are expected to exercise plans and preparedness related to ingestion exposure 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. Please provide further clarification on the language or revise appropriately to clarify respective areas. SNC Response The Standard Emergency Plan, Section N.1.3 was revised such that the wording related to opportunities for .offsite participation in drills and exercises was removed and relocated to Section N.2.1 titled "Off-Year Drills". The revised Plan is provided as part of this response. RAl-FLEET-10 Section N.2.2 addresses Hostile Action Based (HAB) drills rather thah an exercise, noting it will occur at least once every 8 years, per the NRG/Federal Emergency Management Agency (FEMA) guidance. Please provide additional information regarding an HAB exercise versus drill or revise accordingly to reflect the guidance in NSIR/DPR-ISG-01. .. SNC Response The Standard Emergency Plan, Section N.2.2 has been revised to reflect the requirement for an HAB exercise every 8 years. The wording has also been relocated from Section N.2.2 to Section N.1.4. The revised Plan is provided as part of this response. RAl-FLEET-11 NUREG-0654, Section 11.1.9, states (balding added): Each organization shall have a capability to detect and measure radioiodine concentrations in air in the plume exposure EPZ as low as 10-7 uCi/cc {microcuries per cubic centimeter) under field conditions. Interference from the presence of noble gas and background radiation shall not decrease the stated minimum detectable activity. Section 1.9 of the SNC Standard Emergency Plan states, "Field monitoring equipment has the capability to detect and measure airborne radioiodine in the I * , presence of noble gases." Page6

SNC Response to 3rd Set of RAls Standard E-Plan LAR Attach. 1 This information was identified in the applicable Justification Matrixes for VEGP, Units 1 and 2 (E12-126), and VEGP, Units 3 and 4 (E15-106), as being relocated to the SNC Standard Emergency Plan. It was identified for FNP (E6-16) as being maintained in the applicable procedures. However, the SNC Standard Emergency Plan lacks the specific detail of the NUREG-0654 evaluation criteria. Please explain how this evaluation criteria of NUREG-0654 is being addressed. SNC Response The Standard Emergency Plan, Section 1.9 has been revised to reflect the required minimum detectable activity. The revised Plan is provided as part of this response. FNPAnnex RAl-FNP-1 In Sections 1.2.1 and 1.7.1, it is noted that Henry County is referenced in the two plan statements, but additional narrative is not included in the plan, as was done for all states (including Florida, an Ingestion Pathway Zone state) and other counties (Houston, Alabama, and Early, Georgia). In Section 4.11, Henry County is also absent from the agencies to be notified by FNP. Specifically, Section 4.2 states: 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. ... Capability to activate the calling system is provided by Houston County and Henry County, Alabama, and Early County, Georgia.

Please provide further perspective on Henry County's involvement in the radiological emergency preparedness program for FNP and revise the annex accordingly to address this.

SNC Response Henry County, because of its limited exposure, is managed through th9' State of Alabama Radiological Emergency Plan (REP). Specifically, Henry County is not notified by Farley Nuclear Plant. Henry County notification requirements for Plant Farley are met through the notification of Houston County. In accordance with the State of Alabama REP: "The Chairman of the Houston County Commission and the Probate Judge of Henry County will assume responsibility for all Emergency Management operations and actions in their counties.

The Houston County Emergency Management Director will oversee and coordinate emergency operations within Houston and Henry Counties during an incident at Farley Nuclear Plant. Emergency Management will take actions as outlined in the Master Checklist Guide (Attachment 4 to Appendix 1 of the Basic Plan) to coincide with the current situation."

Page7

SNC Response to 3rd Set of RAls Standard E-Plan LAR Attach. 1 Section 1.7.3 of the Farley Annex has been revised to clarify Henry County responsibilities for implementation ot'the Farley Emergency Plan and is provided as part of the RAI response. RAl-FNP-2 Section 1.4 states that the Alabama Department of Public Health, Office of Radiation Control (ADPH-ORC) is responsible for initiating the Alabama Radiological Response Plan for Nuclear Power Plants in support of an emergency at FNP. The Alabama Emergency Management Agency (AEMA) is not referenced here, yet on page E5-5, AEMA is categorized as one of the "primary offsite authorities." ADPH is not referenced on page E5-5, nor anywhere else in the annex, including receiving notifications from the plant. Please provide further perspective on the roles of these respective agencies and revise accordingly to ensure .that information is fully documented in -the FNP Annex, where appropriate. SNC Response In response to RAl-FLEET-2, the overall responsibilities of the State of Alabama were clarified in Section A.2.1.1 of the Standard Plan. This information is consistent with Section 1.4 of the Farley Site Annex. RAl-FNP-3 Section 5.3.1 states, "The primary means of communication between FNP, the state of Alabama, state of Georgia, Houston County, and Early County is the Emergency Notification Network (ENN)." See earlier comment in RAl-FNP-1 regarding the lack of reference to Henry County notification from FNP. Please clarify or revise accordingly to address. SNC Response Henry County is not notified by Farley Nuclear Plant. As provided in the answer to RAl-FNP-1, the responsibility for Henry County notification and subsequent actions is managed in accordance with the State of Alabama REP by the Houston County Emergency Management Director. Section 1.7.3 of the Farley Annex has been revised to clarify Henry County responsibilities. FNP Staffing- Detailed Description and Technical Evaluation RAl-FNP-4 Regarding the Emergency Operations Facility (EOF) Emergency Director* (ED) on page E4-5, it states: Under this proposal, within 75 minutes of classification, the Shift Manager/ED is relieved in the TSC [Technical Support Center] 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. Page 8

SNC Response to 3rd Set of RAls Standard E-Plan LAR Attach. 1 This appears to contradict the table on page E4-3 where notification is shown as transferring directly from the CR ED to the EOF ED .. Please provide additional clarification regarding the turnover of notifications from the Shift Manager/EC and revise accordingly. SNC Response has been revised to align with the table on page E4-3 and is provided as part of the RAI response package. FNP Justification Matrix RAl-FNP-5 The EP Introduction to the SNC Emergency Plan {reference page E6-5 of the Justification Matrix) states, "There are supporting and complementing emergency plans, including those of federal agencies, the states of Alabama, Georgia, South Carolina, and individual counties." Realizing that Florida is an Ingestion Only state, it is referenced in other parts of the plan. Please clarify why the State of Florida should not be included as part of this introductory statement or revise accordingly.

SNC Response The Standard Emergency Plan Scope and the Farley Justification Matrix reference have been updated to include a reference to Florida (ingestion pathway only for Farley). Both documents are provided as part of the RAI response.

RAl-FNP-6 On page E6-11, Section EP 8.2.1.1, TSC Emergency Director {ED) states, "Once Command and Control has been completed, the TSC ED assumes the non-delegable duties .... "This would also apply to plan sections referenced on pages E6-8/9. Please clarify this statement intende.d to address the transition of command and control and revise accordingly. SNC Response The Standard Emergency Plan, Section B.2.1.1 and the associated pages of the Farley Justification Matrix have been updated to clarify that the sentence applies to after the transfer of Command and Control. The documents are provided as part of the RAI response. RAl-FNP-7 On page E6-20, the current Emergency Plan states that Field Monitoring Teams, "will provide radiation protection support at the Southeast Alabama Medical Center, during transport of potentially irradiated and/or contaminated casualties. The Emergency Plan Equivalent Description no longer includes such a commitment .... " Page 9

SNC Response to 3rd Set of RAls Standard E-Plan LAR Attach. 1 Please provide additional details around the radiation protection support that will continue to be provided to the Southeast Alabama Medical Center, including interface with offsite authorities, and revise as appropriate to address. SNC Response The Standard Emergency Plan, Section L.4 contains the commitment for: "L.4 Medical Transport Contaminated and injured persons are transported to a facility specified for SNC-operated nuclear power plants. Arrangements have been made by nuclear power plants for ambulance transport of persons with injuries involving radioactivity to designated hospitals. Such services are available on a 24-hour-per-day basis arid are confirmed by letters of agreement. Radiation monitoring services are provided by SNC plant personnel whenever it becomes necessary to use an ambulance service for the transportation of contaminated persons." The Justification Matrix was updated to include Section L.4 of the Standard Emergency Plan and is provided as part of the RAI. response. RAl-FNP-8 On page E6-22, it references the current FNP Emergency Plan, which contains a section on Additional Plant Staff Assignments. Specifically, it states the senior individual at each of the Assembly Areas will become the supervisor at that location. The revised SNC Emergency Plan Equivalent Description makes no reference to such a position. Please provide clarification as to the supervision status at Assembly Areas and revise as appropriate to address. SNC Response The senior individual referenced in the current Plan is not an ERO assigned position. In accordance with existing procedures, the most senior person responding takes on a general leadership role in that area. Standard Emergency Plan Section J.4.1, Assembly, has been revised to include the statement with respect to assumption of leadership responsibilities at an assembly area. The Standard Emergency Plan and FNP Justification Matrix revisions are provided as part of the RAI response. RAl-FNP-9 On page E6-73, the description of the Radiation Monitoring System (RMS) provides that there are three types of monitors, area airborne, and air particulate monitors. Please provide further perspective as to why the two bullets discuss additional details for the area and airborne monitors but do not discuss air particulate monitors or revise accordingly. Page 10

SNC Response to 3rd Set of RAls Standard E-Plan LAR Attach. 1 SNC Response The Standard Emergency Plan, Section H.5.2.1 and the corresponding reference in the Farley Justification Matrix have been updated to include a third bullet for air particulate monitors. The documents are provided as part of the RAI response. RAl-FNP-10 On page ES-80, the current FNP Emergency Plan states, "Results of dose estimates and projections are provided to off-site agencies responsible for initiating protective actions .... " This language has apparently been deleted in the SNC SEP and is not in the FNP Annex. Please explain why the referenced language was removed and, if so, whether or not there was consultation with applicable offsite agencies or revise accordingly to address. SNC Response The Standard Emergency Plan, Section J.5 was revised to better explain how the site personnel provide dose projections and field team information to offsite agencies. The associated section of the Farley Justification Matrix has been updated and is provided as part of the RAI response.

RAl-FNP-11 On page ES-98, the current FNP Emergency Plan, states:

The Dose Assessment Supervisor will work with the state/local agency representatives to determine the Total Effective Dose Equivalent (TEDE) exposure (resulting from external exposure and inhalation of the plume and external exposure from deposition) and thyroid Committed Dose Equivalent (COE) exposure (resulting from the inhalation of radio-iodines). This language has apparently been deleted in the SNC SEP and is not in the FNP Annex. Please explain why the referenced language was removed and, if so, whether or not there was consultation with applicable offsite agencies, or revise accordingly to address. SNC Response Similar to question RAl-FNP-10, actual practice has been to provide dose projections, dose rates and field team data to the respective offsite agencies. The Standard Emergency Plan Section J.5 language was revised to reflect actual practice. RAl-FNP-12 On page E6-98, the current FNP Emergency Plan, states: If a site evacuation is warranted, personnel will be advised as to which routes should be used. The normal routes are State Highway 95 North or South and County Road 42 West (Figures 17and19). All personnel being evacuated from Page 11

SNC Response to 3rd Set of RAls Standard E-Plan LAR Attach. 1 the site will be monitored before being released. Personnel leaving the site would then proceed, in their own vehicles, on one of these major routes, to their residences. Transportation for persons without vehicles will be arranged. This language has apparently been deleted in the SNC SEP and is not in the FNP Annex. Please explain why the referenced language was removed or where the information was relocated, or revise accordingly to address. SNC Response The current Plan had significant detail that included information that may not be appropriate to a specific event. Planned evacuation routes are useful to maintain in Emergency Plan Implementing Procedures (EPIPs) as they may require adjustment based on environmental and plant conditions. Similarly, other factors contained in this paragraph are more appropriately handled on an event specific basis. The use of site resources to monitor all personnel prior to leaving the site may not be required if the site evacuation occurs prior to any release. Evacuation using personnel vehicles may or may not be appropriate. The Standard Plan, supported by the Site Annexes, maintains the commitment to conduct a Site Evacuation if conditions dictate. The details on the process of conducting the Evacuation has been moved to EPIPs to allow flexibility based on event conditions. The Justification Matrix has been revised to include the explanation for elimination of the specific detail. RAl-FNP-13 On page E6-107, the current FNP Emergency Plan states: Accountability within the Controlled Area will be determined by the senior individual at each assembly area coordinating with the Security Response Center (SRC) Staff and then will be reported to the Emergency Director by the senior individual in the SRC. This language has apparently been deleted in the SNC SEP and is not ih the FNP Annex. Please explain why the referenced language was removed or where the information was relocated, or revise accordingly to address. SNC Response The Standard Plan reflects a standardized process for Security at SNC sites to perform and report accountability. The senior individual as identified in the current Plan is not an ERO assigned position. In accordance with existing procedures, the most senior person responding takes a general leadership role in that area. Security, per the revised Standard Plan, has the overall authority for conduct of Assembly and Accountability. Standard Emergency Plan Section J.4.1, Assembly has been revised to include the statement with respect to assumption of leadership activities at an assembly area. The Standard Emergency Plan revision is provided as part of the RAI response. Page 12

SNC Response to 3rd Set of RAls Standard E-Plan LAR Attach. 1 RAl-FNP-14 On page E6-122, the current FNP Emergency Plan states (balding added):

The authority for initiation or relaxation of protective action recommendations is vested solely with the Emergency Director and may not be delegated to any other member of the emergency organization. This language has apparently been deleted in the SNC SEP and is not in the Farley Annex.

Please explain why the referenced language was removed or where the information is located, or revise accordingly. SNC Response The language was eliminated from the Emergency Plan because the offsite agencies through their independent analyses determine the appropriateness of relaxation of protective action recommendations. Standard Emergency Plan Section D.2.5 was revised to provide additional information on the site determination to downgrade the Emergency Classification. The Standard Emergency Plan revision is provided as part of the RAI response. RAl-FNP-15 On pages E6-136 through E6-t39, significant detail describing the primary and backup ANS was removed. The ANS design report is reviewed and approved by FEMA, not the NRG. As such, an adequate description of the primary and backup ANS needs to be included in the FNP Annex. SNC Response The Standard Plan (Section E.2.5.1 ),the Farley Annex (Section 4.2) and the respective Justification Matrices have been updated to reflect a more extensive description of the FEMA-approved primary and back-up systems. The revised sections are provided as part of the RAI response. RAl-FNP-16 On page E6-154, the current FNP Emergency Plan, states," ... a formal critique will be performed for all exercises, drills, and training that provide performance opportunities to develop, maintain, or demonstrate key skills in order to identify weak or deficient areas that need correction." This language has apparently been deleted in the SNC SEP and is not in the FNP Annex. Please explain why the referenced language was removed or where the information was relocated, or

revise accordingly to address.

SNC Response Standard Emergency Plan Section N.4 was revised to clearly state the requirement to conduct formal critiques for exercises, drills and training tabletops. Standard Emergency Plan Section 0.1, Training, has similarly been revised to Page 13

SNC Response to 3rd Set of RAls Standard E-Plan LAR Attach. 1 ensure EP training is evaluated. The revised Standard Emergency Plan and Justification Matrices are provided as part of the RAI response. RAl-FNP-17 (This question number was not used by the NRC) RAl-FNP-18 On page E6-188, the current FNP Emergency Plan states, "If both units are in concurrent classifications, the highest classification would be used for the notification and the other unit classification noted on the notification form." This language has apparently been deleted in the SNC SEP and is not in the FNP Annex. Please explain why the referenced language was removed or where the information was relocated, or revise accordingly to address. SNC Response The Standard Emergency Plan, Section E.1.1 addresses the reporting of classifications in which multiple units at a site are affected by an emergency and has been revised to address the classification included in initial notifications as well as routine updates. Offsite agency response is a direct result of that highest classification and

providing multiple classifications on the same form could lead to an inappropriate response. Lower/later classifications will be communicated as part of routine updates as noted in Standard Emergency Plan Section E.2.2.2 and E.2.2.3 HNP Justification Matrix RAl-HNP-1 On page E9-93, the current HNP Emergency Plan, states:

Any proposed change in the method of dissemination of emergency information to the public must be coordinated and discussed with, and agreed upon by appropriate State and local offsite emergency officials prior to implementation of the change. This language has apparently been deleted in the SNC SEP and is not in the HNP Annex. Please explain why the referenced language was removed and, if so, whether or not there was consultation with applicable offsite agencies, or revise accordingly to address. SNC Response The Standard Emergency Plan, Section G.1 and the respective Justification Matrix have been revised to document the concurrence of appropriate offsite agencies if the method of information dissemination is changed. The revised documents are provided as part of the RAI response. Page 14

SNC Response to 3rd Set of RAls Standard E-Plan LAR Attach. 1 RAl-HNP-2 On page E9-132, the current HNP Emergency Plan states, "Initially at least two persons can be dispatched from on-shift personnel for offsite surveys. The on-shift HP/Chem department foreman will provide for field monitoring coordination until the TSC is activated." This language has apparently been deleted in the SNC SEP and is not in the HNP Annex. Please explain why the referenced language was removed or where the information is located, or revise accordingly. SNC Response Field team staffing was described in detail in responses to the second set of RAls (See RAl-HNP-2, RAl-HNP-4, RAl-HNP-6 in ML16105A194). Those responses are in review by NSIR staff in parallel with this set of RAI responses. Any further clarification will be resolved following NRG review of the revised SNC position based on those responses. RAl-HNP-3 On pages E9-225 through E9-231, significant detail describing the primary and backup ANS was removed. The ANS design report is reviewed and approved by FEMA, not the NRG. As such, an adequate description of the primary and backup ANS needs to be included iri the HNP Annex. SNC Response The detail~d descriptions of the site Alert and Notification Systems (ANS) contained in the Standard Emergency Plan (Section E.2'.5.1) and the Hatch Annex (Section 4.2) have been revised to provide additional information. The revised Plan and Annex sections are provided as part of the RAI response. VEGP. Units 1 and 2. Justification Matrix RAl-VEGP1&2-1 On page E12-149, the proposed VEGP, Units 1 and 2, Annex, Section 2.3.2, states (bolding added): Agreements are in place with the University of Alabama at Birmingham (UAB) Hospit~I, Burke Medical Center, Doctors Hospital, and Burke County Emergency Management Agency, to provide assistance for injured personnel, including cases involving radioactive contamination. On page E12-155, the proposed VEGP, Units 1 and 2, Annex, Section 5.8.1', states, "Agreements are in place with the Burke Medical Center, Doctors Hospital, and Burke County Emergency Management Agency to provide assistance for injured personnel, including cases involving radioactive contamination." Please explain why reference to the UAB Hospital was removed in the proposed VEGP, Units 1 and 2, Annex, Section 5.8.1, or revise accordingly to address. Page 15

SNC Response to 3rd Set of RAls Standard E-Plan LAR Attach. 1

SNC Response The Vogtle 1 and 2 Annex Section 5.8.1 and respective Justification Matrix have been revised to include the University of Alabama at Birmingham (UAB) Hospital.

The revised documents are provided as part of the RAI response. RAl-VEGP1 &2-2 On page E12-172, the current VEGP, Units 1 and 2, Section M.4, states: VEGP will provide radiological information including estimated quantity of radioactivity released, isotopic composition of released material, and meteorological data to assist the governmental authorities in their determinations. Please explain why the referenced language was removed and, if so, whether or not there was consultation with applicable offsite agencies, or revise accordingly to address. SNC Response Standard Emergency Plan Section J.5, Protective Action, was revised to better explain how the site personnel provide dose projections and field team information to offsite agencies. The .Standard Emergen.cy Plan and associated Justification Matrix revisions are provided as part of the RAI response. RAl-VEGP1 &2-3 On pages E12-193 through E12-197, there are numerous references relating to tone alert radios. Understanding the proposed language and justification reference the FEMA-approved design report, and also that, "The combination of Sirens and Tone Alert Radios is conducted in accordance with the FEMA approved Design Report." Additionally, there are specific commitments identified:

SNC, in conjunction with Georgia Power Company, provides National Oceanic and Atmospheric Administration (NOAA) radio receivers for all known establishments (residence, businesses, schools, etc.) within the plume exposure pathway EPZ that choose to accept them.
During the distribution to those accepting the radios, a brochure is handed out.
That brochure will be redistributed on an annual basis to NOAA recipients.
Public information will be distributed on an annual basis to the NOAA radio recipients.
SNC will replace any defective radios upon request or discovery that the radios are defective.
SNC will annually distribute replacement batteries to all recipients of tone alert radios.
SNC will maintain a register of all radio recipients.
The Emergency Preparedness staff distributes tone alert radios to any new residents and updates the register of radio recipients periodically.

Page 16

SNC Response to 3rd Set of RAls Standard E-Plan LAR Attach. 1

The Emergency Preparedness staff also determines whether there are any permanent Burke County EPZ residents with electricity. A list of these residents is maintained.

The ANS design report is reviewed and approved by FEMA, not the NRC. As such, an adequate description of the primary and backup ANS needs to be included in the VEGP, Units 1 and 2, Annex. Also, please explain why the commitments listed above, which are currently contain in the VEGP, Units 1 and 2, Emergency Plan Appendix 3, are not being maintained in the site-specific annex. SNC Response The detailed descriptions of the site ANS contained in the Standard Emergency Plan (Section E.2.5.1) and the Vogtle Units 1 & 2 Site Annex have been revised to provide additional information. Specific details of how the systems are maintained are contained in the FEMA-approved design reports. The Plan and Annex revisions are provided as part of the RAI response. RAl-VEGP1 &2-4 On page E12-199, the current plan language states, "The periodic test program will consist of a weekly silent test, from the county activation points, and an annual full scale activation of the system," while proposed wording reads, "Annually the system will be activated in the normal mode." Please explain why the referenced language regarding the weekly silent test was removed and, if so, whether or not there was consultation with applicable offsite agencies, or revise

accordingly to address.
SNC Response The periodic testing program as well as the overall siren maintenance program is documented in the FEMA-approved design report. The approved report contains the requirement to continue the test program, including the weekly silent tests.

VEGP, Units 3, and 4, Annex .RAl-VEGP3&4-1 On page E14-13, the proposed VEGP, Units 3 and 4, Annex, Section 2.3.2, states (bolding added): Agreements are in place with the University of Alabama at Birmingham (UAB) , Hospital, Burke Medical Center, Doctors Hospital, and Burke County Emergency Management Agency, to provide assistance for injured personnel, including cases involving radioactive contamination. On page E14-26, the proposed VEGP, Units 3 and 4, Annex, Section 5.8.1, states, "Agreements are in place with the Burke Medical Genter, Doctors Hospital, and Burke County Emergency Management Agency to provide assistance for injured personnel, including cases involving radioactive Page 17

SNC Response to 3rd Set of RAls Standard E-Plan LAR Attach. 1 contamination." Please explain why reference to the UAB Hospital was removed in the proposed VEGP, Units 3 and 4, Annex, Section 5.8.1, or revise accordingly to address. SNC Response The Vogtle 3 and 4 Annex Section 5.8.1 and respective Justification Matrix has been revised to include the University of Alabama at Birmingham (UAB) Hospital. The revised documents are provided as part of the RAI response. VEGP, Units 3 and 4, Annex Justification Matrix RAl-VEGP3&4-2 On page E15-156, the current VEGP, Units 3 and 4, Section M.4, states, "VEGP will provide radiological information including estimated quantity of radioactivity released, isotopic composition of released material, and meteorological data to assist the governmental authorities in their determinations." Please explain why the referenced language was removed and, if so, whether or not there was consultation with applicable offsite agencies, or revise accordingly to address. SNC Response Standard Emergency Plan Section J.5, Protective Action, was revised to better explain how the site personnel provide dose projections and field team information to offsite agencies. The Standard Emergency Plan and associated Justification Matrix revisions are provided as part of the RAI response. RAl-VEGP3&4-3 On pages E15-183 through E15-186, there are numerous references relating to tone alert radios. Understanding the proposed language and justification reference the FEMA-approved design report, and also that, '.'The combination of Sirens and Tone Alert Radios is conducted in accordance with the FEMA approved Design Report." Additionally, there are specific commitments identified:

SNC, in conjunction with Georgia Power Company, provides NOAA radio receivers for all known establishments (residence, businesses, schools, etc.)

within the plume exposure pathway EPZ that choose to accept them.

During the distribution to those accepting the radios, a brochure is handed out.
That brochure will be redistributed on an annual basis to NOAA recipients.
Public information will be distributed on an annual basis to the NOAA radio recipients.
SNC will replace any defective radios upon request or discovery that the radios are defective.
SNC will annually distribute replacement batteries to all recipients of tone alert radios.
SNC will maintain a register of all radio recipients.
The Emergency Preparedness staff distributes tone alert radios to any new residents and updates the register of radio recipients periodically.

Page 18

SNC Response to 3rd Set of RAls Standard E-Plan LAR Attach. 1

The Emergency Preparedness staff also determines whether there are any permanent Burke County EPZ residents with electricity. A list of these residents is maintained.

The ANS design report is reviewed and approved by FEMA, not the NRC. As such, an adequate description of the primary and backup ANS needs to be included in the VEGP, Units 3 and 4, Annex, as well as site-specific annexes for HNP and FNP. Also, please explain why the commitments listed above, which are currently contained in the VEGP, Units 3 and 4, Emergency Plan Appendix 3 are not being maintained in the site-specific annex. SNC Response The detailed descriptions of the site ANS contained in the Standard Emergency Plan (Section E.2.5.1) and the Vogtle Units 3 & 4 Site Annex have been revised to provide additional information. Specific details of how the systems are maintained are contained in the FEMA-approved design reports. The Plan and Annex revisions are provided as part of the RAI response. RAl-VEG P3&4-4 On page E15:.190, the current plan language states, "The periodic test program will consist of a weekly silent test, from the county activation points, and an annual full scale activation of the system," while proposed wording reads, "Annually the system will be activated.in the normal mode." Please explain why the referenced language regarding the weekly silent test was removed and, if so, whether or not there was consultation with applicable offsite agencies, or revise accordingly to address. SNC Response The periodic testing program as well as the overall siren maintenance program is documented in the FEMA-approved design report. The approved report contains the requirement to continue the test program, including the weekly silent tests. RAl-VEGP3&4-5 VEGP, Units 3 and 4, EP ITAAC E.3.9.08.01.01 -The language in EP ITAAC, "Acceptance Criteria 8.1.1.8.3.a (for both Units 3 and 4) currently ends with "within 15 minutes of notification." Should this be changed to "within 15 minutes of event classification," in order to be consistent with other similar ITAAC acceptance criteria? SNC Response VEGP EP ITAAC E.3.9.08.01.01 Criterion 8.1.1.8.3.a is based on SNC's drill and exercise performance objectives and criteria. The current Plan includes a requirement to notify augmented ERO responders within 15 minutes of event classification and a 60 minute augmentation time from the time of ERO notification. The* proposed Standard Emergency Plan, Section H identifies facility Page 19

SNC Response to 3rd Set of RAls Standard E-Plan LAR Attach. 1 activation requirements of 75 minutes from event classification, effectively subsuming the ERO notification under the ERO augmentation and facility activation activity.

Because the proposed Standard Emergency Plan does not contain a specific commitment to time frame for informing on-site personnel, it is proposed that the acceptance criteria for 8.1.1.B.3.a be changed to rec:td:

Demonstrate the ability to notify onsite individuals (via plant page or telephone) in accordance with Emergency Plan Implementing Procedures. See revised Enclosure 16 for a technical justification of the proposed change. See Enclosures 17 and 18 for markups of revised VEGP EP ITAAC E.3.9.08.01.01, Criterion 8.1.1.B.3.a for Units 3 and Unit 4. During the review of the affected ITAAC, SNC identified one additional clarification. In ITAAC E.3.9.08.01.02, a reference to Section B, VEGP Emergency Organization is replaced by a reference to the Standard Emergency Plan, Section B and the Vogtle Annex, Section 2. See revised Enclosure 16 for a technical justification of this clarification. See Enclosures 17 and 18 for markups of revised VEGP EP ITAAC E.3.9.08.01.02. RAl-VEGP3&4-6 VEGP, Unit 4, EP ITAAC E.3.9.08.01.0f -Description No. t for Unit 4 lists the affected criteria as 8.1.1.B.2.a, 8.1.1.B.2.b, 8.1.1.B.2.c, and 8.1.1.8.3.a. In contrast, the comparable Unit 3 description also includes affected criteria 8.1.1.B.1.a. Should 8.1.1.B.1.a be added to the Unit 4 listing of affected criteria, as it too includes the "designated checklist" reference that is being removed from the other criteria? SNC Response Description no. 1 for VEGP, Unit 4, EP ITAAC E.3.9.08.01.01 is revised to add criterion 8.1.1.B.1.a. Revised Enclosure 16 is provided as part of the RAI response. RAl-VEGP3&4-7 VEGP, Unit 4, EP ITAAC E.3.9.08.01.01 -Description No.7 for Unit 4 (Acceptance Criterion 8.1.1.D.1) repeats the same description that is provided for Unit 3, Description No. 7 (acceptance criterion 8.1.1.D.1 ). In Appendix C of the COLs, the Unit 3 and Unit 4 language for acceptance criterion 8.1.1.D.1 are not the same, as the Unit 4 language does not include reference to the TSC and EOF. Should the Unit 4, Description No. 7 (for Criterion 8.1.1.D.1) be deleted, as the change to Unit 3 Criterion 8.1.1.D.1 is not applicable to Unit 4? SNC flesponse Because the proposed change to VEGP, Unit 4, EP ITAAC E.3.9.08.01.01 Page 20

SNC Response to 3rd Set of RAls Standard E-Plan LAR Attach. 1 Criterion 8.1.1.D.1 affects the operations support center (OSC), the Unit 4, Description No. 7, should not be deleted. However, references in the description to the TSC and EOF are proposed to be removed. Description No. 7 will be revised to read: "Criterion 8.1.1.D.1 requires that the activation of the operations support center (OSC) occur within 60 minutes of activation. The Standard Emergency Plan changes this commitment to 75 minutes from declaration of an Alert *or higher classification. As a result, it is proposed to change criterion 8.1.1.D.1 to read, "The OSC is activated within 75 minutes following declaration of an Alert or higher classification." Revised Enclosure 16 is provided as part of the RAI response. Page 21

I \J I, ' '* 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 2

SNC Standard Emergency Plan (Marked-Up Pages and Clean Copy)

Enclosure 2 to NL-16-0169 SNC Standard Emergency Plan INTRODUCTION Purpose The Southern Nuclear Operating Company's (SNC) Emergency Plan provides the means to protect the health and safety of the general public, persons temporarily visiting or assigned to nuclear power plants operated by SNC, and plant employees. SNC operates the Hatch Nuclear Plant (HNP), Farley Nuclear Plant (FNP), and Vogtle Electric Generating Plant (VEGP).

Background

The SNC Emergency Plan was developed with the guidance ofNUREG-0654, FEMA-REP-1 , Revision l , "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support ofNuclear 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 ofNUREG 0654 Revision 1. The SNC Emergency Plan is organized using the structure ofNUREG-0654 Revision I, and that structure provides the cross-reference to the base document. Scope Detailed procedures concerning the implementation of the SNC Emergency Plan are in the Emergency Plan Implementing Procedures (EPIPs). Those documents describe the duties of individuals and groups in the event of emergencies, and also serve as the interface between the SNC Emergency Plan, plant operations, security, and radiological control programs. SNC also has procedures in place that implement onsite protective actions and personnel accountability during hosti le action threats or events that are appropriate fo r plant and environmental conditions. These procedures are avai lable for use at the plants. There are supporting and complementing emergency plans, including those of federal agencies, the states of Alabama, Georgia, South Carolina, Florida (Ingesti on pathway only fo r -Plant [Farle and indi vidual ( Comment [Ml]: RAl-FNP-5 counties. 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 SNC. The SNC Emergency Plan describes the organization, facilities, training, and maintenance of both onsite and offsite 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. Three phases of responsive action are 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. E2-6

Enclosure 2 to NL-16-0169 SNC Standard Emergency Plan SECTION A: ASSIGNMENT OF RESPONSIBILITY A. I Primary Federal Organizations A. I. I Nuclear Regulatory Commission (NRC) The NRC is the coordinating agency for i11cidents at or caused by a facility or an activity that is licensed by the NRC or an Agreement State,aets as tl'le lead federal ageAey fer teel'IAieal matters dHriAg a m1elear iAeideAt. it the Chairman of the ( Comment [M2] : RAl-FLEET-l Commission as the senior NRC authority for response. The Chairman can transfer control of emergency response activities when deemed appropriate. Incident Response Centers have been established at the 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. A.1.2 Department of Homeland Security (DHS) In accordance with the National Response Framework (NRF), DHS is responsible for the overall coordination of a multi-agency Federal response to a significant radiological incident. A. 1.3 Federal Emergency Management Agency (FEMA) The primary role ofFEMA is to support the states by coordinating the delivery of federal non-technical assistance. FEMA coordinates state requests for federal assistance, identifying which federal agency can best address specific needs. If deemed necessary, FEMA will establish a nearby Joint Field Office from which it will manage its assistance activities. A.1.4 Department of Energy (DOE) The DOE provides radiological assistance on request, and has radiological monitoring equipment and person11el resources that it can assemble and dispatch to the scene of a radiological incident. Following a radiological incident, DOE operates as outlined in the Federal Radiological Monitoring and Assessment Plan (FRMAP). The Radiological Assistance Team can be expected to respond to SNC-operated sites as directed by the Savannah River Operations Office of DOE. A. 1.5 Federal Bureau of In vestigation (FBI) Support from the FBI is available through its statutory responsibility, based in public law and the US code, and through a memorandum of understanding for cooperation with the NRC. Notification to the FB I of emergencies in which they would have an interest will be through the provisions of a plant security plan, or by the NRC. A.1 .6 National Weather Service (NWS) NWS provides meteorological information during emergency situations, if required. Data avai lable will include existing and forecasted wind directions, wind speeds, and ambient air temperatures. E2-10 to NL-16-0169 SNC Standard Emergency Plan A.1.7 Environmental Protecti on Agency (EPA) The EPA can assist w ith fie ld radiological mo nitoring, sampling, and non-plant related recovery and reentry guidance. A.2 State and Local Organizations A.2.1 State of Alabama The Go verno r of the State of Al abama has overa ll responsibility for emergency preparedness and response concerning a n incident at a NPP. Al abama law designates the Al abama Department of Public Health, Office of Radiation Control (ADPH -ORC) as the agency responsibl e for iss uing any order requiring actions to be taken necessary to meet the emergency. In day-to-day operati ons this fun ctio n is fulfill ed by the ADPH-ORC. The Governor has charged the Al abama Emergency Management Agency Director with the res ponsibility of coordinating the activities of departm ents , agencies, and organizati ons of state government a nd local emergency management agencies to carry out emergency fun ctions relating to a NPP incident. These ass igned responsibilities merge in the joint development and issuance of the state plan by the ADPH-ORC and the !Alabama Emergency Ma nagement Agt:,n~~*- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ___ - -{ Commented [M3): RAI-FLEET-2 A.2. 1.1 Alabama Emergency Management Agency (AEMA) The Al abama Emergency Management Agency (AEM A) is the primary offsite agency for radi ological emergencies. The stati on send s emergency noti ficati ons to the 24 hour notifi cati on point mai ntained by iAEM A[. ________ - -{ commented [M4J: RAI-FNP-2 The Alabama Emergency Management Agency coordinates the Radiolog ical Emergency Plans and offs ite operations of affected state agencies and local governments including noti fication 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, coordin ation of non-radiological operati ons with utility and federal authoriti es, and coordination of news information. A.2. 1.2 Al abama Department of Public Health Office of Radi ation ontro( ________ - -{ Commented [M5]: RAI-FLEET-2 (ADPH-ORC) The Al abam a Department of Public Health Office of Rad iati on Control (ADPH -ORC) prov ides technical support to AEMA. They perform radi ation monitoring of areas around the station and provide the res ults back to A.EMA. Communications of events are tra nsmitted to AEMA who in turn info rms ADPH-ORC. This relati onship is furth er defi ned in the FEMA approved state emergency pla n. Through the Alabama Department of Public Health, the Alabama Office of Radiation Control is responsibl e for initiating the "Alabama Radi ological Response Plan for Nucl ear Power Plants" in support of an emergency at the Farley Nuclear Plant. The state plan provides a E2-11 to NL-16-0169 SNC Standard Emergency Plan detailed description of the notification procedures and the responsibilities and duties of the local and state agenc ies in volved. The Alabama Office of Radiation Control has primary responsibility and authority fo r handling the offsite aspects of an emergency in Alabama with primary focus on the welfare and safety of the general public. 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. A.2.2 State ofbeorgi , ( Comment [M6): RAJ.FLE ET-2 The Governor is authorized and empowered under Official Code of Georgia Annotated (O.C.G.A.) § 38-3-22: To have general direction and control of the Georgia Emergency Management Agency and to be responsible for the carrying out of the provisions of this chapter, and, in the event of disaster or emergency beyond local control, may assume direct operational control over all or any part of the emergency management functions within this state. The Governor' s Executive Order provides current authority and assignment of the various emergency response functions to the appropriate state agencies. A.2.2 .1 Georgia Emergency Management Agency (9EMA)) l Comment [M7]: RAJ-FLEET-2 As the overall state coordinating agency GEMA will coordinate with the Department of Natural Resources-Environmental Protection Division (DNR-EPD) on emergency response activities with state, county and municipal agencies and departments as stated in the Georgia Emergency Operations Plan (GEOP). GEMA provides for 24-hour notification and staffing of the State Operations Center (SOC) and/or the Forward Emergency Operations Center (FEOC). as required, throughout the event. GEMA is responsible for general state emergency planning and overall direction and control of emergency or disaster operations as assigned by executive order and in accordance with the Georgia Emergency Operations Plan (GEOP). GEMA has responsibilities for coord inating the state of Georgia response to emergencies at nuclear power plants. A.2.2.2 Department of Natural Resources Environmental Protection Division (DNR-EP~ ( Comment [MS]: RAJ-FLEET-2 Department of Natural Resources-Environmental Protection Division (DNR-EPD) is assigned as the coordinating and a primary agency responsible by Executive Order for implementation and administration of the state radiological and hazardous material function . E2-12 to NL-16-0169 SNC Standard Emergency Plan B.2 On Site Emergency Response Organization (ERO) Augmentation ofon-shift staffing wi ll 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 (OSC), 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-hour-a-day basi s for an extended event. On-shift as well as offsite state and local government interfaces are detailed in the site-specific Annexes. Command and Control normall y shifts from the Control Room to the TSC and subsequently to the EOF. Command and Control may move in either direction, depending on conditions that wou ld warrant passing such authority. Command and Control may be completed sequentially or in parallel , based on the discretion of the EDs. A qualified ED in either facility can relieve the other facility of the Command and Control authority and responsibilities. Figure B.2.A depicts the transition of Command and Control responsibilities between fac ilities. Alternative Facilities have been identified to ensure timely ERO response during a hostile action event. Details on the Alternative Facilities are included in Section H. CONTROL ROOM TSC EOF Shift Manager I TSC Emergencll Director EOF Emergencll Director Emergencll Director Classificati:- Classification Notifica ti o n ~ ~ Notifications PA Rs PARs Emergency Exposure "' Emerg ency Exposure Controls Controls Figure B.2.A Transition of Command and Control Functions B.2.1 Technical Support Center (TSC) See Figure B.2.1.A at the end of Section B. B.2.1 . 1 TSC Emergency Director (ED) The TSC ED has the authority and responsibility to immediately initiate any emergency actions. Once transfer of Command and Contro l has been completed, ( Comment [M9 ] : RN-FNP-6 the TSC ED assumes the non-delegable duties of event Classification, on-site Emergency Exposure Authorization, and on-site protecti ve actions. B.2.1.2 TSC Manager The TSC Manager reports to the TSC ED and is responsible for coordinating activities between the TSC and other emergency response facilities, directing the activities of the TSC staff, and ensuring communications are established with applicable offsite agencies. E2-17 to NL-16-0169 SNC Standard Emergency Plan recognize that some events may represent a challenge to more than one barrier, and that the containment barrier is weighted less than the reactor coolant system pressure boundary and the fuel clad barriers. 0.2.3 Emergency Action Level Threshold Values The most common bases for establishing Threshold Values are the Technical Specifications, Operating Procedures, the Offsite Dose Calculation Manual (ODCM), and setpoints that have been developed in the design basis calculations for the Final Safety Analysis Report (FSAR). Another critical element of the analysis to arrive at Threshold Value conditions is the time that the plant might stay in that cond ition before moving to a higher emergency classification level. The time dimension is critical to the EAL, since the purpose of the emergency classification level for state and local officials is to notify them of the level of mobilization that may be necessary to address the emergency. This is particularly true when a Site Area Emergency or General Emergency is imminent. A time variable is used to allow for correction of the condition before a classification is made. Site-specific Threshold Values for Emergency Action Level Initiating Conditions are maintained in the station ' s Emergency Action Level Technical Basis document. D.2.4 Treatment of Mu ltiple events and Classification Level Upgrading When multip le simultaneous events occur, the emergency classification level is based on the highest EAL reached. Emergency classification level upgrading considers the potential for radioactive release from the entire site due to the event or simultaneous events. D.2 .5 Emergency Classification Level Downgrading and Termination The SNC policy is that once an emergency classification is made, it cannot be downgraded to a lower classification. Termination criteria contained in the Emergency Plan Implementing Procedures shall be completed for an event to be terminated. At termination, on an event specific basis, the site can either enter normal operating conditions or enter a recovery condition with a recovery organization established for turnover from the ERO. When the site determines that transition to termination or recovery is appropriate, the information will be transmitted to respective offsite gencies. ( Comment (M10): RAl -F P- 14 D.2.6 Classifying Transient Events Many of the Initiating Conditions and/or EALs described in this document employ time-based threshold criteria. These criteria will require that the threshold conditions be present for a defined period of time before an emergency classification is warranted. ln cases where no time-based criteria are specified, it is recognized that some transient events may cause an EAL threshold to be met for a few seconds to a few minutes. The following guidance should be applied to the classification of these events. E2-41

Enclosure 2 to NL-16-0169 SNC Standard Emergency Plan SECTION E: NOT IFI CATION METHODS AND PROCEDURES E. 1 Notification Methodology E.1 .1 S C, in cooperation with state and county authorities, has established methods 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. The primary notification method wi ll be by a dedicated communications system. SNC-operated plants maintain the capability of notifying state and local agencies within 15 minutes of a dec lared emergency as required by 10CFR50 Append ix E, IV.D.3. The methods and forms used for notifying state and county authorities are site-specific and detailed in plant specific Emergency Plan Implementing Procedures (EPIPs). NRC will be notified by the Hea6Ejuarters OiieratieAs Offieerthe impacted site

                ~ mmediatel    following state and local notifications, but within an hour of an             ( Comment [MU] : RAl-FLEET-3 emergency classification using ENS.

When multiple units of a multi-unit site are affected by an emergency, the classification shall be reported as app licable to all affected units. Ln situat ions where mu ltiple un its of a mu lti-unit site are affected by emergency events, but the events are not related and the classification for each unit is different, initial notificatio*n will be made for the highest classification. Additional classification information is provided in accordance with Section E.2 .2 .. ( Comment [M12]: RAJ-FNP-18 An accelerated call to the RC Headquarters Operations Officer will be made following discovery of an imminent threat or attack against a plant. During a plant transient or an imminent threat situation requiring physical security response, plant personnel are primarily responsible for stabilizing the plant and keeping it safe. An accelerated notification will not interfere with plant or personnel safety or physical security response. The accelerated notification will be completed after or concurrent with notification of local law enforcement agencies. The goal will be to initiate the notification within 15 minutes of discovery of an imminent threat or attack against a plant. The information provided in the accelerated notification will be limited to the following:

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

E.2 Notification of Personnel E.2. 1 Notification of Onsite Personnel The Emergency Director is responsible for class ifying an event into the appropriate emergency classificat ion and then notifying on-site personnel of the emergency declaration in accordance with procedures. This not ification may consist of the use of E2-43 to NL-16-0169 SNC Standard Emergency Plan the plant emergency alarm, announcements over the plant public address system , or activation of the recall system. Emergency Response personnel respond to their assigned Emergency Response Facilities upon notification of an Alert or higher classification level. In the event of a Design Basis Threat, personnel may be directed to respond to alternative facilities. Notification of persons who are in the public access areas, on or passing through the site, or within the contro lled area, will be performed by the Security Department. Such notifications wi ll be in accordance with the Emergency Plan Impl ementing Procedures (EPfPs). Visitors with in the protected area are escorted by a permanently badged individual. This individual is responsible for informing the visitors of emergencies when they occur and for taking action to evacuate the visitors from the site, as necessary. Notification procedures include notification of Emergency Response Organization Personnel (ERO) not on site or during backshift hours. ERO members wi ll be notified by means of an automated callout system activated by on-shift personnel. E.2.2 Notification of State and local Authorities A dedicated ENN wi ll normally be used to accomplish state and local notifications. Backup means of communication are described in Section F, Emergency Communications, of thi s plan. E.2.2.1 State and Local Agencies State and local agencies listed in the site specific Annexes shall be notified within fifteen ( I 5) minutes of:

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

E.2.2.2 Initial Notification Message Form ln conjunction with state and county authorities, SNC-operated plants have established the contents of the initial B:Ae suese~ueAt state notification message fo rms to be used aurin . an emergency. These forms are described in EP!Ps. The ( Comment [M13]: RAl-FNP-18 content of the forms has been reviewed and agreed on by the respective Offsite Response Organizations. E.2.2.3 Follow-up Emergency Message In conjunction with state and county authorities, SNC-opcrated plants have established the contents of the subsequent state notification message forms to be used during an mergenc*. The Emergency Director is responsible for the ( Comment [M14]: RAl-FNP-18 completion of a follow-up emergency message. The appropriate ERO personnel wi ll ensure the emergency communicator(s) periodically provide fo llow-up messages to the appropriate offsite federal , state, and local authorities. E2-44 to NL-16-0169 SNC Standard Emergency Plan E.2.3 Notification of the Nuclear Regulatory Commission (NRC) The NRC is notified via the ENS. If the ENS is inoperative, the required notification will be made using alternate means in accordance with regulatory requirements. The Emergency Response Data System (ERDS), will be initiated within one hour of the declaration of an Alert or higher classification. Specific information on the notifications to the NRC for emergency events is detailed in the reporting requirements of I 0 CFR 50.72. E.2.4 Notification of Other Federal Agencies Notification of other Federal Agencies will be made in accordance with site specific Procedures. E.2.5 Notification of the Public 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. An overview of these means excluding the Savannah River Site is listed in the site specific Annex of this Plan. Initial notification of the public will occur in a manner consistent with assuring the public health and safety. The design objective for the system is to meet the acceptance criteria provided in a subsequent section of the FEMA approved design report for each SNC-operated plant. The design objective does not constitute a guarantee that prompt notification can be provided for everyone with I 00 percent assurance, or that the system when tested under actual field conditions will meet the design objectives. In the event of an emergency, the Emergency Director is responsible for notifying appropriate state and local response organizations, plant emergency response organization, and plant personnel. E.2.5.1 Concept of Operation ( Comment [M15]: RAl -FNP- 1s In the event of a serious emergency at any SNC site, the primary means for alerting the public wi ll be by the FEMA approved Alert and Notification System (ANS) referenced in the site specific Annex. Each site has a FEMA approved backup notification system in the event of a loss of the primary alert and notification system. State and local plans maintain additional processes to alert the public using emergency vehicles. automated dialing systems, public address systems. etc. Details of the backup methods can be found in the site specific Annex. The capability exists to promptly alert and notify the general public within the Plume Exposure Pathway. The Alert and Notification Systems (ANS) for each station includes an acoustic alerting signal from sirens and notification of the public by the Emergency Alert System (EAS). Station specific information regarding the ANS is contained in each station's ANS Design Certification Package. E2-45 to NL-16-0169 SNC Standard Emergency Plan The acoustical siren system desi gn meets FEMA standards and require me nts and has been approved to alert populati ons of an event. Each county controls the acti vation of the si rens within its boundaries (except for Henry County whic h reli es on Houston County to acti vate their sirens). Acti vati on of the ANS sirens by the local authorities will alert the public to turn to a local EAS station for detail ed inform ation on the emerge ncy situation. The siren system is tested in accordance with the stati on's FEM A approved ANS des ign certifi cation package. SNC prov ides for the repair and preventive maintenance of the EPZ sirens. Procedure instructi o ns have been developed to res pond to any spurious activation of the ANS sirens. Detai led informat ion and instructions will be provided on local EAS radi o and telev ision stations. Commercial radi o stations and television stati ons whose broadcasts are received in the plume exposure pathway EPZs have agreed to broadcast emergency instructions and informati on in cooperati on with offs ite officials. These continuin g instructions will provide more specific or detailed in formati on of any protective actions advised for affected areas. In formati on on the nature of the acc ident, on any releases, and on the progress in ameliorating or termin ating the emergency event, will also be provided periodically on the commercial station s, along with a prognos is fo r escalation or termin ati on of the event. E.2.5.2 Criteria for Acceptance I . Within the plume exposure pathway EPZ, the prompt alerting and notifi cati on system will provide an alerting signal and notifi cation by fix ed sirens; further notificati on will be provided by local commercial radio and television stations acti vated by EAS .

2. The minimum acceptable des ign objectives for coverage by the system are:

a) Capability for both an alerting signal and an informational or instructional message to the popul ation on an area-wide basis throughout the plume ex posure pathway EPZ, within 15 minutes. b) The initial notificati on system will assure direct coverage of essentially I 00 percent of the popul ation wi thin five miles of the site. These design objecti ves have been met by FEMA approved ANS Des ign report referenced in the site specific Annex.

3. Local a nd state agenc ies have the capabi lity to provide in fo rmati on promptly over local commercial radi o and telev ision at the time of the activation of the alerting signal. Authority for activation of the EAS , which permits designated governmental officials to issue emergency in form ati on and instruction in threatened or actual emergenci es, is given by 47CFR part I I, EAS Rules.

In formation will be distributed on an annual bas is to residents and businesses within the EPZ. E2-46 to NL-16-0169 SNC Standard Emergency Plan The testing and maintenance of the public alerting sirens are the responsibility of SNC. The maintenance program will consist of both periodic routine checks and, as required, corrective maintenance. The periodic routine maintenance and test program will be based on the manufacturers' recommendations and experience gained with the installation. Annually, the system will be activated in the normal mode. Advance notice of the test will be provided to the public. Activation of sirens will be verified by the system. Reports of siren failures will be investigated and repaired by the respective SNC site. Unsatisfactory conditions detected by any means will be promptly repaired. State and local emergency management Plans and procedures detail the Prompt Notification System (PNS) activation process in addition to the information provided in the Emergency Ian. ( Comment [M16): RAJ-FLEET-4 Activation of the alert and notification system (ANS) is discussed in the offsite agencies' specific emergency response plans. E2-47

Enclosure 2 to NL-16-0169 SNC Standard Emergency Plan SECTION F: EMERGENCY COMMUNICATIONS F. I Communi cations F.1.1 At SNC-operated nu clear power plants, several modes of reliable communi cation are avail able, during both normal and emergency conditions, to transmit and receive information among the Control Room, TSC, OSC, EOF, and other locations ons ite and offs ite including the Joint Information Center near the SNC site. Reli able primary and backup means of communication have been establi shed. The use of the communicati ons systems during normal and emergency conditions has been integrated into plans, procedures°, and the trai ning program. F.1 .2 SNC-operated plants maintai n the capability to make initial notifications to the designated offs ite agencies 24 hours per day. Offsite notificati ons can be made to state and county warning points and Emergency Operations Centers from the Control Room.. l"e~k'a~-£t1pptiH-f'.erut'f, and Emergency Operations Facility using the ENN. { Commented [SGL17]: lna<-curato Reliable backup methods have been written into procedures. State and county warning po ints are continuously staffed. F. l .3 Provisions exist for continuous communications with state and local governments with in the Emergency Planning Zones, as detail ed above. At least one on- site and one offs ite communications system is mai ntai ned, each with a backup power source to ensure continuous communicati ons. F.1.4 SNC has established communications systems to provide reli ab le communications with federal emergency response organizations. Communications with federal agenci es is primaril y by commercial tel ephone, with alternate systems being utilized as needed. Communication with the Nuclear Regul atory Commission (NRC) is on the Federal T elecommunications ephooe-S ystem (FTS) telephone ~etworki, which conn ects the -{ Commented [MlB]: RAJ-FLEET-5 SNC plant site and EOF with the NRC Operations Center. Site extensions are located in the Control Room, TSC, and Site NRC Resident Inspector's Office. Site extensions include ENS , HPN, EROS, and other des ignated counterpart links connecting to the NRC Operations Center. Commercial telephon e lines serve as the backup to the ENS and other FTS lines. F.1.4.1 NRC Emergency Notification System (ENS ) This communications line provides a communi cations link to the NRC Operations Center in Rockville, Maryland, and is used for continuous communicati ons in a class ified emergency. F.1.4.2 NRC Health Phys ics Network (HPN) Thi s communi cations line provides a communi cations link with the NRC to provide radiological informati on. E2-49 to NL-16-0169 SNC Standard Emergency Plan SNC Emere:encv Communications Matrix On Site State Counties

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SNC Phone System x x x x x x x x x x x x x x x x x x x x Commercial Phones x x x x x x x x x x x x x x x x x x x x Sound Powered Phones x Emergency Notification x tXl x x x x x x x x x x x x x x x * (C;;~~~t~[SGLt9f: ln-:.-c~~;;,;--- --*--- - -J Network (ENN) Radios x x x x Public Address (PA) x x x x NRC Line Access x x x Emergency Response Data x x x System (ERDS ) Table 5 E2-51 to NL-16-0169 SNC Standard Emergency Plan F.2 Medical Emergency Communications Communications have been established between the primary and bad..'1lp medical hospitals and transportation services with S C-operated plants. F.3 Communications Tests Communications tests will be conducted on the frequency specified below. Each of these tests includes provisions to ensure participants in the test are able to understand the content of the messages in the test.

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

F.4 Validation of Phone umbers A quarterly check of telephone numbers required to implement the SNC Emergency Plan will be performed and (iocumente . ( Comment [M18]: RAl-FLEET-5 E2-52

Enclosure 2 to NL-16-0169 SNC Standard Emergency Plan SECTION G: PUBLIC EDUCATION AN D INFORMATION G.l Purpose Southern Nuclear Company (SNC) will provide education and emergency information to the public consisting of the followin g:

The release of information to the public through the dissemination of timely, accurate emergency communications.
The orderly flow of emergency information during the recovery period.
Providing public education and information for the distribution of emergency preparedness materials to residents and transient populations.

SNC uses a number of way to communicate the information to the EPZ population. These means are developed in coordination with respective offsite agencies. Any proposed change in the method of dissemination of emergency information to the public must be coordinated and discussed with. and agreed upon by appropriate State and local offsite emergency officials prior to implementation of the hang . ( Comment [M19]: RAl-HNP-1 G.2 ews Media Training A program wi ll be offered each calendar year to acquaint the news media with the methodology for obtaining information during an emergency and with overall emergency preparedness at APC/GPC nuclear plants, as appropriate. Training will include information about the plant, emergency response, and the ro le of the J IC, as we ll as opportunities to participate in drill activities. G.3 News Releases The Uti lity wi ll issue news releases covering events, conditions, and actions at the Plant. News releases are designed to be a written confirmation of events and are public information. The SNC News Writer will write news releases in the EOF and obtain S C 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 rel ease. G.4 Press Briefings Press briefings will be conducted to keep the media informed of events and activities relating to the emergency. Briefings will provide the most current, up-to-date information about events and response to the incident. Public Information Officers (PIOs) from offsite agencies responding to the emergency will be encouraged to participate in the briefings to discuss their particular activities. G.S Public Response Appropriate information will be released as clearly, concisely, and quickl y as possible. Public announcements will be made on a frequent and regu lar basi s. G.6 Reso urce Materials Media guides are available on the Utility websites and are access ible from the CMC and JIC. These gui des are updated regu larly and are available to news media. An emergency web page will be activated and will replace the no rmal web page on the appropriate Utility's website at the PLD's discretion. E2-53

Enclosure 2 to NL-1 6-0169 SNC Standard Emergency Plan

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

The functions ofNotification and PARs will be performed from the EOF should the Alternative Facility be activated. Details of Alternative Facilities can be found in the Site Specific Annex. H.2 Offsite Emergency Facilities H.2.1 Emergency Operations Facility The EOF is the central location for management of the offsite emergency response, coordination of radio logical assessment, and management of initial recovery operations. The EOF is a dedicated faci li ty located in Birmingham, Alabama, and serves as the EOF for SNC sites (VEGP, FNP, and HNP). The EOF is procedurally required to be activated within 75 minutes following the declaration of an Alert or higher lassiticatio . £taffiAg and aetiYatioA ( Comment [M20]: RAI-FLEET-6 of the EOf is maAdatory upoA deelaratioA ofaA Alert or higher elassifieatioA. The EOF provides for:

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

The EOF is capable of accommodating 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. Based on the physical location of the EOF, specialized ventilation systems are not required. The EOF ventilation system is consistent in design with standard building codes. Similarly, EOF functions would not be interrupted by radiation releases from any SNC site. Normal power to the EOF is from a reliable offsite source. Emergency lighting is provided by battery-operated lights. Backup power for the EOF is supplied by onsite diesel generation. Essential equipment is backed up by the diesel generation system. The EOF is located at SNC Corporate Headquaiters. The following records or information are available:

Technical Specifications.
Selected plant operating procedures.
Emergency Plans.
Emergency Plan Implementing Procedures.

E2-57

Enclosure 2 to NL-16-0169 SNC Standard Emergency Plan

Minimum staffing has been achieved.
Personnel have been briefed on the situation and are ready to assume Command and Control functions .

H.5 Onsite Monitoring S C-operated nuclear power plants have installed monitoring instrumentation for seismic monitoring, radiation monitoring, fire protection and meteorological monitoring, in accordance with its Final Safety Analysis Report (FSAR) and plant Technical Specifications (TS), or commitments made to the NRC. Details of these systems differ from plant to plant, and are in the site specific Annexes. H.5 . 1 Geophysical Monitors

Meteorological Instrumentation: A permanent meteorological monitoring station is located near the plant for the acquisition and recording of wind speed, wind direction, and ambient and differential temperatures for use in making offsite dose projections. Meteorological information is displayed in the CR, TSC, and EOF.

Additional information located in Section H.7.

Seismic Monitoring: The seismic monitoring system measures and records the acceleration of the structure if activated by an earthquake of sufficient magnitude.

It also provides signals for immediate remote indication that specific preset response accelerations have been exceeded.

Hydrological Monitors: SNC-operated nuclear power plants have hydrological monitors as appropriate. The design basis flood, probable maximum precipitation, and other extremes in hydrologic natural phenomena are as detailed in the FSAR as appropriate.

H.5.2 Radiological Monitors and Samp ling H.5.2.1 Radiation Monitoring System (RMS) Radiation monitoring instruments are located at selected areas within the plant to detect, measure, and record radiation levels. The monitors are comprised of area, airborne and air particulate monitors.

Area monitors respond to gamma radiation.
Airborne monitors detect and measure radioactive gaseous effluent concentrations.
Air Particulate detectors capture and measure airborne articulat . ( Comment [M21]: RAl-FNP-9 Emergency response procedures provide methods for determining relationships between monitor readings and releases, material available for release and extent of core damage.

H.5.2.2 Liquid and Gaseous Sampling Systems The process sampling system consists of the normal sampling system and additional sampling panels located throughout the plant. Pre-designated monitoring and sampling points are listed in site procedures. Sampling systems are installed or can be modified to permit reactor coolant and containment atmosphere sampling even under severe accident conditions. E2-61 to NL-16-0169 SNC Standard Emergency Plan The system can provide information on post-accident plant conditions to allow operator actions to mitigate and control the course of an accident. Various chemical analyses and radiological measurements on these samples can be performed, including the determination of radionuclide concentrations. H.5.2.3 Laboratory Facility S C sites have a laboratory facility for analysi s of radioactive samples. H.5.2.4 Portable Radiation Monitoring Equipment Portable radiation survey instruments are available for a wide variety of uses such as area, sample, personnel surveys, and continued accident assessment. H.5.3 Process Monitors The Control Room and redundant backup locations are equipped with extensive plant process monitors for use in both normal and emergency conditions. These indications include reactor coolant system pressure and temperatures, containment pressure and temperature, and various liquid levels, flow rates, status, or lineup of equipment components. H.5.3 .1 Plant Monitoring/Information System A plant monitoring/information system provides the data acquisition and database capability for performing plant monitoring and functions. The system is designed to scan, convert to engineering units, make sensor range and alarm limit checks, apply required transformations, store for recall and analysis, and display the reading of transformed data from plant instrumentation. The system scans flows, pressures, temperatures, fluid levels, radiation levels, equipment, and valve status at required frequencies . H.5.3.2 Safety Parameter Display System (SPDS) The SPDS parameters are available during normal and abnormal operating conditions in the Control Room, TSC, and EOF. H.5.4 Fire Detection System The Fire Detection System is designed to detect products of combustion or heat in designated areas of the plant. The fire alarm communication systems and subsystems are located at strategic points throughout the plant to warn personnel of a fire or other emergency conditions. Additional description of the fire system is provided in the FSAR. H.5.5 Fire Station Firefighting equipment and supplies are available for damage control operations. The equipment is stored in various areas within the plant. E2-62

Enclosure 2 to NL-16-0169 SNC Standard Emergency Plan H.6 Offsite Monitoring SNC-operated nuclear power plants have made provisions to access data from the following offsite sources of monitoring and analysis equipment: H.6. 1 Geophysical Monitors:

Jn the event that the onsite meteorological tower or monitoring instrumentation becomes inoperative, meteorological data may be obtained directly from the National Weather Service.
A central point of contact to obtain information about a seismic event is the National Earthquake lnfomrntion Center.

H.6.2 Radiological Environmental Monitors, Sampling, and Monitoring Equipment SNC-operated nuclear power plants maintain a sufficient supply of portable offsite radiological monitoring equipment. These supplies are located at each staging point for Field Monitoring Teams. S C-operated nuclear power plants have a Radiological Environmental Monitoring Program (REMP) consisting of locations with dose recording devices and air sampling equipment. H.6.3 Laboratory Facilities External facilities for counting and analyzing samp les, and for dosimetry processing, can be provided by other SNC-operated plants including the GPC Central Laboratory, state, federal , or contracted laboratories. Outside analytical assistance may be requested from state and federal agencies, or through contracted vendors. The DOE, through the Radiological Assistance Program (RAP) has access to any national laboratory. H.7 Meteorological Equipment S C-operated nuclear power plants have meteorological towers equipped with instrumentation for continuous reading of wind speed, wind direction, air temperature and differential air temperature. Meteorological tower details are in the site-specific Annexes. Additional capabilities are available to obtain representative current meteorological information from other sources, such as the ational Weather Service. H.8 Emergency Equipment Inventories and Checks Emergency facilities and equipment are inspected and inventoried using appropriate administrative or department procedures. These inventories will include requirements that provisions are in place to inspect, inventory, and operationally check emergency equipment/instruments at least once each calendar quarter and as needed . ese procedures [ Comment [M22]: RAJ-FLEET-7 provide information on location and availability of emergency equipment and supplies. Sufficient reserves of instruments and equipment are maintained to replace those removed from emergency kits or lockers for calibration or repair. E2-63

Enclosure 2 to NL-16-0169 SNC Standard Eme rgency Plan be aimed at further defi ning the offsite co nsequences, including institu ting an expanded mo nitoring program to enable pro mpt assess ments of any subsequent releases from the plant. 1.8 Release Assess ments SNC-operated nuclear power plants have instrumentation, procedures, and trai ned personnel with th e expertise to make rapid assess ments of the actual or potential magni tude and location of any radi ological hazards through liquid or gaseous release path ways. l.9 En vironmental Radi oiodine Moni toring Capabilities Field monitoring equipment has the capability to detect and measure airborne radi oiodine in the presence of noble gases that has the capability to detect and measure radioiodine concentrations in air in the plume exposure EPZ as low as 10-7 uCi/cc (microcuries per cubic centimeter) under field conditions. Interference from the presence of noble gas and background radiation shall not decrease the stated minimum detectable pctivit{ __________ - -{ commented [M2SJ: RAJ -FLEET-1 E2-67 to NL-16-0169 SNC Standard Emergency Plan Measures that 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.

SNC-operated nuclear power plants are responsible for maintaining a supply of KI at their respective site. The Emergency Director has the responsibility for approval of issuing Kl to site emergency workers. On site protection of employees during hostile action involves a combination of restricted movement, movement to safe locations, and site evacuation depending on the nature of the hostile event and advance warning. Site-specific procedures provide specific actions to take during hostile action or severe weather events. During a hostile action or severe weather event, Assembly and Accountability actions may be delayed in favor of other onsite protective actions required to ensure the safety of the site and its personnel. In these cases, accountability will be completed once safe conditions have been established. 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 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 anage . [ Comment [M24]: RN -FNP-8 J.4.2 Accountability Personnel accountability is mandatory at the Site Area or General Emergency classification. Accountability may be initiated at other times at the discretion of the Emergency Director to support worker safety. Accountability of personnel within the Protected Area is accomplished within 30 minutes of the declaration of Site Area Emergency or higher, and maintained continuously thereafter, using Protected Area(s) boundary access control as described in the Security Plan. If there are station personnel who are unaccounted for, the public address system or other suitable communication methods are used to locate 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. E2-69

Enclosure 2 to NL-16-0169 SNC Standard Emergency Plan J.4.3 Site Evacuation Lf a Site Evacuation is required, personnel are directed to either assemble within designated Assembly Areas or immediately leave the site. Personnel will be directed to either proceed to their homes or reassemble at designated locations. Visitors to the plant will assemble with and follow the instructions of their escorts. Personal transportation will normally be used and established evacuation routes will be followed . Personnel without transportation will be identified and provided transportation as necessary. Evacuation of personnel is usually conducted immediately after accountability ifa Site Area Emergency or General Emergency has been declared and no impediments exist. Evacuation shall commence as directed by the Emergency Director. J.5 Offsite Protective Action Recommendations (PARs) Plant conditions, projected dose and dose rates, field monitoring data, and evacuation time estimates are evaluated to develop PARs for preventing or minimizing exposure to the public. PARs are provided to the offsite agencies responsible for implementing protective actions for the public within the I 0-mile EPZ. The Emergency Director will approve PARs. The PAR decision-making flowcharts are site-specific in nature, and are provided in the site-specific implementing procedures. SNC-operated plants have the capability to provide state and local agencies a PAR for beyond the 10-mile EPZ. Plant conditions, projected dose and dose rates and field monitoring data are communicated to offsite agencies responsible for dose assessment/PA Rs to assist them in developing parallel sessment . Comment [M25]: RAl-FNP-10 RAI-FNP-11 There are various types of protective actions that can be recommended to the state and RAl-VEGP1&2-2 RAJ-VEGP3&4-2 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.

J.6 Evacuation Time Estimates (ETE) An independent ETE report has been performed for SNC-operated nuclear power plants, which provides estimates of the time required to evacuate resident and transient populations surrounding the plant for various times of the year under favorable and adverse conditions. ETEs for evacuation of the plume exposure EPZ surrounding S C-operated nuclear power plants are summarized in the site-specific Annex and detailed in the ETE report. J.7 Protective Action Maps SNC nuclear power plants have maps depicting local roads, primary evacuation travel routes, and the Emergency Planning Zone (EPZ). Maps are also availab le which show the population distribution within the plant EPZ, and are described in the site-specific Annexes. E2-70

Enclosure 2 to NL-16-0169 SNC Standard Emergency Plan SECTION N: EXERCISES AND DRILLS N.1 Exercises S C-operated nuclear power plants will conduct a biennial exercise and additional periodic drills. An exercise is an event that tests integrated capability, and a major portion of the basic elements of emergency preparedness plans and organizations. Drills and 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 fami liar with their duties.

S C-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. Joint exercises shall be conducted on a frequency described in NRC/FEMA guidance. A foFfflal eritiei1:1e shall be eoR61:1eteEI followiRg the Elrill or e1tereise to e*t'al1:1ate the ability of orgaAiHttioRs to reSf.lOAEI as reei1:1iree in the SNC StaRElarEI EmergeAey Plan aREI site Sf.leeifie EmergeRS)' PlaR lmf.llemeRtiRg Proeee1:1res. Critiei1:1e items will be eRteree iRto the SNC eorrestive aetioR f.lFOgram as af.lf.lFOf.lFiate. Remedial exercises will be required ifthe emergency plan is not satisfactorily tested during the Biennial Exercise, and it is determined that reasonable assurance that adequate protective measures canare-not be takelll in the event of a radiological emergency or the ERO has not [ Comment [M26]: RAl-FLEET-8 maintained key skills specific to emergency response. N.1.1 Biennial Exercises Federally prescribed Biennial Exercises are conducted at SNC-operated nuclear power plants. Exercises involving offsite agency participation, required under 10 CFR 50 Appendix E, are conducted at SNC-operated nuclear plants based on Federal Emergency Management Agency (FEMA) guidance and the respective state and local emergency response plans. N.1.2 Participation SNC-operated nuclear power plants exercise with offsite authorities to allow state(s) and local governments within the plume exposure pathway EPZ to exercise their emergency plans for operating nuclear power plants biennially, with full or partial participation. Full and partial participation exercises are described as follows :

Full participation exercises will include, as appropriate, offsite local and state authorities and S C personnel actively participating in testing the integrated capability to assess and respond to an accident at a nuclear power plant.

Additionally, full participation exercises will include, as appropriate, testing the major observable portions of the on site and offsite emergency plans and E2-79

Enclosure 2 to NL-16-0169 SN C Standard Emergency Plan mobilization of state, local, and SNC personnel, and other resources in sufficient numbers to verify the capability to respond to the accident scenario.

Partial participation means offsite authorities shall take part in the exercise sufficient to test direction and control functions, including protective action decision-making and communication capabilities among affected state and local authorities and SNC-operated plants. Where partial or full participation by offsite agencies occurs, the sequence of events simulates an emergency that results in the release of radioactivity to the offsite environs, sufficient in magnitude to warrant a response by offsite authorities.

At a minimum, state and local governments are expected to fully participate in accordance with the requirements of 10CFR50 Appendix E, section fV(F)(2)(c). N.1.3 Ingestion Exposure Pathway Exercise States within an ingestion exposure pathway EPZ are expected to exercise plans and preparedness related to ingestion exposure pathway measures at least once every 8 years . N. 1.4 Hostile Action Based (HAB) Exercises Hostile Action Based {HAB) exercises involving an air, land or water based attack scenario will be conducted at sites on a frequency of at least once every eight (8) ear. [ Comment [M27]: RAl-FL EET-10 Q!!!!Sfttmiti@s aFil flFS :'iss8 te Im) stat@ er lesal ge,*0Ru1H11tl leeat@s 'Yitkin tk0 fll111t~il ilHfl8Slll"il fltltk ii ti)" eP6 18 !Jtll'ti@ifl8lil iR tlllf\lltll drills !IRS Bi@nnial i!H@ri!iBi!B ':': 'h@n F@i!Hi!Sli!S B)' tkm stat@ Br IB@al ~eve1'RnH!Rt. N.1.54 Exercise Planning Cycle The Exercise planning cycle will consist of eight (8) successive calendar years. N.2 Drills A drill in this context is a supervised instruction period aimed at testing, developing, and maintaining skills in a particular operation

       .2.1 Off-Year Drills S C-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 .
otification of offsite authorities.
Assessment of the onsite and offsite impact of radiological releases.
Protective action recommendation development.

E2-80 to NL-16-0169 SNC Standard Emergency Plan

Protective action decision making.
Plant system repair and corrective actions.

During these drills, activation of all of the licensee's emergency response facilities (TSC, OSC, and the EOF) would not be necessary. The ERO would have the opportunity to consider accident management strategies, supervised instruction would be permitted, operating staff in participating facilities would have the opportunity to resolve problems (success paths) rather than have controllers intervene, and the drills may focus on the onsite exercise training objectives. Opportunities are provided to any state or local government located within the plume exposure pathwav EPZ to participate in annual drills and biennial exercises when requested by that state or local ~oyemment. [ Comment [M28]: RAl-FLEET-9 N.2 .2 Hostile AetioA Bases (HAB) Drills Hostile AetioA Bases (HAB) srills iAYOIYiRg BA air, laAs or water bases attaek scenario .,.,*ill be e0As1:1etes at sites OR a freEJl:leAey of at least OACe e\'ery eight (8) years .

  .2.2J Fire Drills Fire drills will be conducted at nuclear plants in accordance with Plant Technical Specifications and Plant procedures.

N.2.34 Medical Emergency Drills A medical emergency drill, involving a simulated contaminated individual, and containing provisions for participation by local support services organizations including ambulance response, are conducted annually at the nuclear plants. Local support service organizations that support more than one plant shall only be required to participate once each calendar year. N.2.M Environs Drills Plant environs and radiological monitoring drills are conducted annually. These drills include collection and analysis of sample media and provisions for communications and record keeping. These drills also evaluate the response to, and analysis of, simulated airborne and direct radiation measurements in the environment. N.2.56 Radiation Protection Drills Radiation Protection Drills involving a response to, and analysis of, simulated airborne and liquid samples and direct radiation measurements are conducted semi-annually. At least annually, these drills shall include a demonstration of the sampling system capabilities, as applicable. N.2.6-7 Accountability Drills Accountability drills are conducted annually. N.2.7& Alternative Facility Drills At least once per drill cycle, use of designated Alternative Facilities to stage Onsite ERO Responders to facilitate rapid activation following a hostile action. N.2. 89 Rapid Escalation E2-81

Enclosure 2 to NL-16-0169 SNC Standard Emergency Plan At least one per drill cycle, a scenario resulting in an initial classification of, or rapid escalation to, a Site Area or General Emergency, will be conducted. N.2.9+G Minimal/No Release Drill At least once per drill cycle, a scenario resulting in no radiological release, or an unplanned minimal release resulting in a classification of a Site Area Emergency but not requiring declaration of a General Emergency, shall be conducted. N.2.l o+ Multi-Site Drills At least once in every five years, a drill involving more than one SNC site will be conducted demonstrating the ability of the Common EOF to effectively implement the Emergency Plan for an event involving more than one site. N.3 Scenarios When a major drill or exercise is required, the Emergency Preparedness (EP) group will coord inate the preparation of a scenario. The EP group will also coordinate efforts with appropriate federal, state and local emergency organizations and agencies, schedule a date to conduct the drill or exercise, and assign qualified controllers. The Emergency Preparedness group retains critique results for review prior to future drills or exercise and for guidance in properly modifying the site-specific Annexes, Emergency Plan lmplementing Procedures (EPIPs), or other procedures as appropriate. A scenario, prepared in advance, will govern the conduct of exercises and drills. Scenarios will include the fo llowing:

Objectives of the drill or exercise; a measurable and observable objective must be specified for each major problem and solution.
Dates, time period, places, personnel, and participating organizations.
Simulated events.
Time schedule of real and simu lated initiating events.
arrative summary describing the conduct of the exercise or drill, including simu lated casualties, offsite fire department assistance, rescue of personnel, use of protective clothing and associated equipment, deployment of personnel and radiological teams, and public info rmation activities.

During the exercise planning cycle described in Section N.1.4, S C 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). E2-82

Enclosure 2 to NL-16-0169 SN C Standard Emergency Plan

lntegration of offsite resources with onsite response.
A drill initiated between the hours of6 p.m. and 4 a.m.
Drills using essentially 100 percent oflnitiating 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. S C sites submit Biennial Exercise scenarios under I 0 CFR 50.4 for NRC review 60 days prior to the exercise. N.4 Exercise Evaluation and Critique A formal critique will be performed for exercises, drills, and training tabletops to develop, maintain , or demonstrate key skills in order to identify weak or deficient areas that need orrectio . ( Comment [M29]: RAl-FNP-1 6 A critique shall be conducted at the conclusion of the exercise, to evaluate the organization's ability to respond as called for in the S C Standard Emergency Plan. Qualified personnel will observe and perform a critique of exercises and drills. Provisions will be made for federal , state, and local observers, as well as SNC personnel, to observe and critique required exercises. Biennially, representatives from the NRC observe and evaluate the licensee's ability to conduct an adequate self-critical critique. For partial and full offsite participation exercises, the NRC and Federal Emergency Management Agency (FEMA), will observe, evaluate, and critique. Drill and exercise performance objectives will be evaluated against measurable . demonstration criteria. As soon as possible following the conclusion of the drill or exercise, a critique is conducted to evaluate the ability of the Emergency Response Organization (ERO) to implement the emergency plan and procedures, and a formal evaluation will result from the critique. A written critique report is prepared by the Emergency Preparedness group following a drill or exercise involving the evaluation of designated objectives or following the final simulator set with ERO participation. The report will evaluate the ability of the ERO to respond to a simulated emergency situation. The report will also contain corrective actions and recommendations. N.5 Exercise/Drill Corrective Actions The critique and evaluation process is used to identify areas of the Emergency Preparedness Program that require improvement. The Emergency Preparedness group is responsible for evaluating recommendations and comments, determining which items will be incorporated into the program or require corrective actions, and for scheduling, tracking, and evaluating item resolution . Whenever exercises or drills indicate deficiencies in the SNC Standard Emergency Plan, site-specific Annexes, corresponding implementing procedures, or training lesson plans, such documents will be revised as necessary. E2-83

Enclosure 2 to NL-16-0169 SNC Standard Emergency Plan SECTION 0: RADIOLOGICAL EMERGENCY RESPONSE TRAINING 0.1 Training To achieve and maintain an acceptable level of emergency preparedness, training will be conducted for members of the Emergency Response Organization (ERO) and those offsite organizations that may be called on to provide assistance in the event of an emergency. Training will be evaluated in accordance with the requirements of Systematic Approach to Training ractices to ensure effectiveness and in order to identify weak or deficient areas that need orrectio . ( Comment [MJO]: RAl-FNP-1 6 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. Personnel from nuclear power plants annually offer to train those non-S C organizations referenced in the Plant Annexes that may provide specialized services during a nuclear plant emergency. The training offered will acquaint the participants with the special problems potentially encountered during a nuclear plant emergency, notification procedures, and their expected roles. Organizations that must enter the site shall also receive site-specific emergency response training and be instructed as to the identity of those persons in the onsite organization who will control their support activities. Training of state and local offsite emergency response organizations is described in their respective radiological emergency plans, with support provided by S C if requested. 0.1 .1 Training of Local Services Groups A training opportunity will be offered annually for offsite organizations and agencies as specified in respective agreements and understandings. Jn addition, those offsite organizations and agencies that may provide onsite emergency assistance will be encouraged to become familiar with the general layout of SNC plants, and will be invited to attend applicable Emergency Plan training and orientation courses. Annually, training will be offered for hospital personnel , ambulance and rescue personnel , police, and fire departments. The training shall include the procedures for notification, basic radiation protection, and their organizations' expected role. 0 .2 Perfonnance Demonstration In addition to general and specialized classroom training, members of the S C ERO receive periodic perfonnance-based emergency response training. Perfonnance-based training is generally provided by participation in a perfonnance drill or exercise. A drill is a supervised instruction period aimed at testing, developing, and maintaining skills in a particular operation. Drills described in Section N of this plan are a part of training. These drills allow individuals to demonstrate the ability to perfonn their assigned emergency E2-85

Sout4ern Nuclear Operating Company* Standard Emergency Plan Revision 0 to NL-16-0169. SNC Standard Emergency Plan Table of Contents INTRODUCTION ..................................................................................................................................... 6 DEFINITIONS ........................................................................................................................................... 7 SECTION A: ASSIGNMENT OF RESPONSIBILITY ....................................................................... 10 A.1 Primary Federal Organizations~****************************************************************************************************lO A.2 State and Local Organizations ...................................................................................................... 11 A.3 Contractor and Private Organizations ......................................................................................... 13 A.4 Other Utilities ............................................................................................ ~ ..................................... 15 A.5 Agreements ............................................................................*..................................................... ~ .... 15 SECTION B: EMERGENCY RESPONSE ORGANIZATION (ERO) ............................,................. 16 B.1 Normal Plant Organization ........................................................................................................ ~***1~ B.2 On Site Emergency Response Organization (ERO) .................................................................... 17 Figure B.2.A Transition of Command and Control Functions .............................................................. 17 B.2.1 Technical Support Center (TSC) .......................................................................................... 17 B.2.2 Operations Support Center (OSC) ......................................................................................... 19 B.3 Offsite Emergency Response Organization (ERO) ..................................................................... 20 B.3.1 EOF Organization ........................................................ ~ ........................................................ 21 B.3.2 Joint Information Center (JIC) ............................................................................................... 23 B.4 Contractor and Private Organizations ......................................................................................... 25 B.5 Letters of Agreement (LOAs) *..*.**.*.*.*.*.*.****.*...**..**.****.*.**.**.*******.*****..***.*.*.***..****.*..***.*.**.*.**. ., ***.*.* 25 B.6 Local Emergency Support Organizations *************************************!t**************************:.................... 25 Figure B.2.1.A -Technical Support Center Organization ......... :.......................................................... 31 Figure B.2.2.A - Operations Support Center Organization ................................................................. .32 Figure B.3.1.A-Emergency Operations Facility Organization ........................................................... 33 Figure B.3.2.A - Joint Information Center Organization ..................................................................... 34 SECTION C: EMERGENCY RESPONSE SUPPORT AND RESOURCES .................................... 35 C.1 Federal Assistance ...*.....................................*....*.............................................................................. 35 C.2 State Interfaces ................................................................................................................................ 35 C.3 Radiological Laboratories ................................................................................................................ 35 C.4 Assistance Agreements .................................................................................................................... 35 SECTION D: EMERGENCY CLASSIFICATION SYSTEM ............................................................ 38 D.1 Classification of Emergencies .......................................................................................................... 38 D.2 Basis for Emergency Classification Criteria ............... ., .................................................................. 39 E2-2 to NL-16-0169 SNC Standard Emergency Plan SECTION E: NOTIFICATION METHODS AND PROCEDURES ................................................. 43 E.1 Notification Methodology................................................................................................................ 43 E.2 Notification of Personnel ................................................................................................................. 43 SECTION F: EMERGENCY COMMUNICATIONS ......................................................................... 49 F .1 Communications ....................................................................................... ~ ..........................*........... 49 F.2 Medical Emergency Communications ........................................................................................... 52 F .3 Communications Tests ..................................................................................................................... 52 SECTION G: PUBLIC EDUCATION AND INFORMATION .......................................................... 53 G.1 Purpose ............................................................................................................................................ 53 G.2 News Media Training ....................................................................................................................*. 53 G .3 News Releases ....................*.............................................................................................................53 G.4 Press Briefings .....................................*........................................................................................... 53 G.5 Public Response .............................................................................................................................. 53 G.6 Resource Materials ......................................................................................................................... 53 G.7 Public Information Plan For Recovery .........................................................................*............... 54 G.8 Public lnformation and Education Program ............................................................................... 54 SECTION H: EMERGENCY FACILITIES AND EQUIPMENT ..................................................... 55 H.1 Onsite Emergency Response Facilities .......................................................................................... 55 H.2 Offsite Emergency Facilities ...............................................*.......................................................... 57 Figure H.2.A - Emergency Operations Facility Layout (Typical) ....................................................... 59 H.3 State and lo~al Emergency Operations Centers (EOC) .............................................................. 60 H.4 Emergency Response Facility Staffing and Activation ............................................................... 60 H.5 Onsite Monitoring .....................................................*....................................................*................. 61 H.6 Offsite Monitoring ..................*.............................................*.......................................................... 63 H.7 Meteorological Equipment ...........................................................................................*................. 63 H.8 Emergency Equipment Inventories and Checks .................................................... ~*********** .......... 63 H.9 Emergency Kits ............................................................................................................................... 64 H.10 Collection Point for Field Samples .........................-....................................................................... 64 SECTION I: ACCIDENT ASSESSMENT ............................................................................................ 65 1.1 Systems and Parameters Monitored ...........................................................................*.................. 65 1.2 Continuing and Post Accident Assessment .................................................................................... 65 1.3 Offsite Dose Assessment .................................................................................................................. 65 E2-3 to NL-16-0169 SNC Standard Emergency Plan 1.4 Effluent Monitor Readings and Exposures ................................................................................... 66 1.5 Meteorological Monitoring ............................................................................................................. 66 1.6 Unmonitored Release ...................................................................................................................... 66 I.7 Environs Surveys and Monitoring **********************************************************************************************~** 66 1.8 Release Assessmen'f:s .....................................................................................*.................................. 67 1.9 Environmental Radioiodine Monitoring Capabilities ................................................................... 67 SECTION J: PROTECTIVE RESPONSE .........................*................................................................... 68 J.1 Alarm Responses ............................................................................................................................. 68 J.2 Radiological Monitoring of Evacuated Personnel ......................................................................... 68 J.3 Non-essential Personnel Evacuation and Decontamination ......................................................... 68 J.4 Onsite Protective Actions ................................................................................................................ 68 J.5 Offsite P~otective Action Recommendations (PARs) .................................................................... 70 J.6 Evacuation Time Estimates (ETE) ................................................................................................. 70 J.7 Protective Action Maps**********************************************~******************************************************************** 70 SECTION K: RADIOLOGICAL EXPOSURE CONTROL. .............................................................. 71 K.1 Emergency Workers and Lifesaving Protective Actions .............................................................. 71 Table K. l .A Emergency Worker Dose Limits ...................................................................................... 71 K.2 Emergency Exposure Authorization .............................................................................................. 72 K.3 Exposure Controls******~******************************************************************************************************************** 72 K.4 Offsite Emergency Workers .............*......................................................................................*...... 73 K.5 Decontamination................................*............................................................................................* 73 K.6 Contamination Controls ............................*...................................*........*............... ~ ......*..........*..... 73 K. 7 Offsite Decontamination ............*.........................................................................................*.......... 73 SECTION L: MEDICAL AND PUBLIC HEALTH SUPPORT ........................................................ 74 L.1 Hospital and Medical Services ...................................................................................................*.... 74 L.2 First Aid .*.......................................................................................*...*.............................................. 7 4 L.3 State Emergency Medical *services ........................................................*........................................ 74 L.4 Medical Transport ........................................................................................................................... 7 4 SECTION M: RECOVERY AND REENTRY PLANNING AND POSTACCIDENT OPERATIO NS .............................. ~................................ ~ ................................................................ 75 M.1 Recovery .................................................................................................................... ~ ...................... 75 M.2 Recovery Organization .........................................................................................................*......... 77 Figure M.2 Typical Long Term Recovery Organization *******:**************************************************************77 E2-4 to NL-16-0169 SNC Standard Emergency Plan M.3 Recovery Notification ...................................................................................................................... 78 M.4 Population Exposure Estimates ...................................................................................................... 78 M.5 Termination of Recovery Phase .........................................................................*............................ 78 SECTION N: EXERCISES AND DRILLS ...............................*........................................................... 79 N.1 Exercises .... ~ ...................................................*.................................................*.....*............................ 79 N.2 Drills ................................................................................................................................................. 80 N.3 Scenarios .......................................................................................................................................... 82 N.4 Exercise Evaluation and Critique ........................ ~ ................................*........................................ 83 N.5 Exercise/Drill Corrective Actions ................................................................................................... 83 SECTION 0: RADIOLOG~CAL EMERGENCY RESPONSE TRAINING .................................... 84 0.1 Training..........*.............................................................................................**....................... ~ ........... 84 0.2 Performance Demonstration ****************************************************************~*****************************************84 0.3 First Aid Training ..............................*....................*....................................................................... 85 0.4 ERO Training .......................................................................................................................*.......... 85 0.5 Emergency Preparedness Staff Training ******************************************-:********************************************86 SECTION P: RESPONSIBILITY FOR THE PREPAREDNESS EFFORT .................................... 87 P.1 Fleet Emergency Preparedness ............................................................................*......................... 87 P.2 Site Emergency Preparedness ...............~ ......................................................................................... 87 P.3 Coordination ..................................................................................................................................... 88 Figure P.1 - Typical Emergency Preparedness Organization ... ,.................................... ~*...................... 89 E2-5

Enclosure 2 to NL-16-0169 SNC Standard Emergency Plan INTRODUCTION Purpose The Southern Nuclear Operating Company's (SNC) Emergency Plan provides the means to protect the health and safety of the general public, persons temporarily visiting or assigned to nuclear power plants operated by SNC, and plant employees. SNC operates the Hatch Nuclear Plant (HNP), Farley Nuclear Plant (FNP), and Vogtle Electric Generating Plant (VEGP).

Background

The SNC Emergency Plan was developed with the guidance ofNUREG-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. Scope Detailed procedures concerning the implementation of the SNC Emergency Plan are in the Emergency Plan Implementing Procedures (EPIPs). Those documents describe the duties of individuals and groups in the event of emergencies, and also serve as the interface between the SNC Emergency Plan, plant operations, security, and radiological control programs. SNC also has procedures in place that implement onsite protective actions and personnel accountability during hostile action threats or events that are appropriate for plant and environmental conditions. These procedures are available for use at the plants. There are supporting and complementing emergency plans, including those of federal agencies, the states of Alabama, Georgia, South Carolina, Florida (Ingestion pathway only for Plant Farley) and individual counties. 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 SNC. The SNC Emergency Plan describes the organization, facilities, training, and maintenance of both onsite and offsite 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. Three phases of responsive action are 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. E2-6

Enclosure 2 to NL-16-0169 SNC Standard Emergency Plan DEFINITIONS The following are definitions of terms commonly used in this Emergency Plan and each site specific Annex: Area Radiation Monitoring System (ARMS) An instrumentation system designed to detect abnormal area radiation levels and activate corresponding station alarms. Committed Dose Equivalent (CDE) CDE is the dose equivalent to organs or tissues of reference that will be received from an intake of radioactive material by an individual during the 50-year period following the intake. Committed Effective Dose Equivalent (CEDE) CEDE is the sum of the products of the weighting factors applicable to each of the body organs or tissues that are irradiated and the CDE to these organs or tissues. Deep-Dose Equivalent (DDE) DDE is the dose equivalent at a tissue depth of 1 cm (1000 mg/cm2), which applies to external whok-body exposure. Dose Equivalent (DE) DE is the product of the absorbed dose in tissue, quality factor and all other necessary modifying factors at the location of interest. The units of dose equivalent are the rem and sievert (Sv). Effective Dose Equivalent (EDE) EDE is the sum of the products of the dose equivalent to each organ or tissue and a weighting factor applicable to each of the body organs or tissues that are irradiated. Emergency Action Levels (EALs) Parameters used to designate a particular classification of emergency. These parameters may include radiological dose rates, levels of airborne or waterborne activity, or instrument indications/plant parameter values. Exclusion Area Boundary An area surrounding the reactor in which the reactor licensee has the authority to determine all activities, including exclusion or removal of personnel and property from the area. Hostile Action An act towards a nuclear power plant or its personnel that includes the use of violent force to destroy equipment, take hostages, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, projectiles, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. Hostile action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the nuclear power plant. Non-terrorist based EALs should be used to address such activities, (e.g., violent acts between individuals in the owner controlled area). E2-7 to NL-16-0169 SNC Standard Emergency Plan Hostile Force One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction. Independent Spent Fuel Storage Installation (ISFSI) A complex designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage. Ingestion Exposure Pathway Emergency Planning Zone (IPZ) The IPZ is the fifty-mile radius area around an SNC-operated plant site for which protective actions are planned for the general population, farmers, dairy farmers, ranchers, food processors and distributors. Inplant The area located within the confines of the SNC Plant Power Block Protected Area. Letters of Agreement (LOA) Letters of agreement include contracts, letters or other formal agreements between Southern Company and/or SNC-operated plants and certain off site resources who provide assistance during emergency events, including a Hostile Action, at SNC-operated plants. Nuclear Administrative and Technical Manual (NATM) The collection of onsite programs and procedures that prescribes how SNC-operated plants are controlled, operated, maintained, and tested to meet the requirements of applicable licenses, standards, codes, and guides. It establlshes effective management practices. Offsite Any position or area not located within the confines of the Site Boundary. Onsite Any position or area located within the confines of.the Site Boundary. Owner Controlled Area The area owned by the licensee and located within the confines of the Site Boundary. Plume Exposure Pathway Emergency Planning Zone (EPZ) The Plume Exposure Pathway EPZ is. the ten-mile radius area around an SNC-operated plant site for which protective actions are planned. Protected Area(s) (PA) An area, located within the Site Exclusion Area Boundary, encompassed by physical barriers and to which access is controlled per 10 CFR 73.55. The SNC Power Block Protected Area and the ISFSI Protected Area are two Protected Areas located within the Site Owner Controlled Area. Protective Actions Emergency measures taken to avoid or reduce radiation dose. These comrµonly include sheltering, evacuation, and prophylaxis. E2-8 to NL-16-0169 SNC Standard Emergency Plan Protective Action Recommendations (PARs) Protective actions recommended by an SNC-operated plant to governmental authorities to protect the health and safety of the public within the plume exposure pathway during an emergency event at an SNC-operated plant. Protective Action Guides (PAGs) The projected dose to individuals that would warrant consideration of protective action against an accidental release of radioactive material. Sabotage Deliberate damage, misalignment, or misoperation of plant equipment with the intent to render the equipment inoperable. Equipment found tampered with or damaged due to malicious mischief may not meet the definition of sabotage until this determination is made by security supervision. Security Condition Any security event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A security condition does not involve a hostile action. Site Boundary The boundary of a reactor site beyond which the land or property is not owned, leased, or otherwise controlled by the licensee. Total Effective Dose Equivalent (TEDE) TEDE is the sum of the Deep-Dose Equivalent (for external exposures) and the CEDE (for internal exposures). Vital Areas Areas within the protected area that contain equipment vital to the operations of the plant. E2-9

Enclosure 2 to NL-16-0169 SNC Standard Emergency Plan SECTION A: ASSIGNMENT OF RESPONSIBILITY A.1 Primary Federal Organizations A.1.1 Nuclear Regulatory Commission (NRC) The NRC is the coordinating agency for incidents at or caused by a facility or an activity that is licensed by the NRC or an Agreement State, with the Chairman of the Commission as the senior NRC authority for response. The Chairman can transfer control of emergency response activities when deemed appropriate. Incident Response Centers have been established at the 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. A.1.2 Department of Homeland Security (DHS) In accordance with the National Response Framework (NRF), DHS is responsible for the overall coordination of a multi-agency Federal response to a significant radiological incident. A.1.3 Federal Emergency Management Agency (FEMA) The primary role of FEMA is to support the states by coordinating the delivery of federal non-technical assistance. FEMA coordinates state requests for federal assistance, identifying which federal agency can best address specific needs. If deemed ne~essary, FEMA will establish a nearby Joint Field Office from which it will manage its assistance activities. A.1.4 Department of Energy (DOE) The DOE provides radiological assistance on request, and has radiological monitoring equipment and personnel resources that it can assemble and dispatch to the scene of a radiological incident. Following a radiological incident, DOE operates as outlined in the Federal Radiological Monitoring and Assessment Plan (FRMAP). The Radiological Assistance Team can be expected to respond to SNC-operated sites as directed by the Savannah River Operations Office of DOE. A.1.5 Federal Bureau of Investigation (FBI) Support from the FBI is available through its statutory responsibility, based in public law and the US code, and through a memorandum of understanding for cooperation with the NRC. Notification to the FBI of emergencies in which they would have an interest will be through the provisions of a plant security plan, or by the NRC. A.1.6 National Weather Service (NWS) NWS provides meteorological information during emergency situations, if required. Data available will include existing and forecasted wind directions, wind speeds, and ambient air temperatures. E2-10 to NL-16-0169 SNC Standard Emergency Plan A. I .7 Environmental Protection Agency (EPA) The EPA can assist with field radiological monitoring, sampling, and non-plant related recovery and reentry guidance. A.2 State and Local Organizations A.2.1 State of Alabama The Governor of the State of Alabama has overall responsibility for emergency preparedness and response concerning an incident at a NPP. Alabama law designates the Alabama Department of Public Health, Office of Radiation Control (ADPH-ORC) as the agency responsible for issuing any order requiring actions to be taken necessary to meet the emergency. In day-to-day operations this function is fulfilled by the ADPH-ORC. The Governor has charged the Alabama Emergency Management Agency Director with the responsibility of coordinating the activities of departments, agencies, and organizations of state government and local emergency management agencies to carry out emergency functions relating to a NPP incident. These assigned responsibilities merge in the joint development and issuance of the state plan by the ADPH-ORC and the Alabama Emergency Management Agency. A.2.1.l Alabama Emergency Management Agency (AEMA) The Alabama Emergency Management Agency (AEMA) is the primary offsite agency for radiological emergencies. The station sends emergency notifications to the 24 hour notification point maintained by 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. A.2.1.2 Alabama Department of Public Health Office of Radiation Control (ADPH-ORC) The Alabama Department of Public Health Office of Radiation Control (ADPH-ORC) provides technical support to AEMA. They perform radiation monitoring of areas around the station and provide the results back to AEMA. Communications of events are transmitted to AEMA who in turn informs ADPH-ORC. This relationship is further defined in the FEMA approved state emergency plan. 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 E2-11 to NL-16-0169 SNC Standard Emergency Plan 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. 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. A.2.2 State of Georgia The Governor is authorized and empowered under Official Code of Georgia Annotated (O.C.G.A.) § 38-3-22: To have general direction and control of the Georgia Emergency Management Agency and to be responsible for the carrying out of the provisions of this chapter, and, in the event of disaster or emergency beyond local control, may assume direct operational control over all or any part of the emergency management functions within this state. The Governor's Executive Order provides current authority and assignment of the various emergency response functions to the appropriate state agencies. A.2.2.1 Georgia Emergency Management Agency (GEMA) As the overall state coordinating agency GEMA will coordinate with the Department of Natural Resources-Environmental Protection Division (DNR-EPD) on emergency response activities with state, county and municipal agencies and departments as stated in the Georgia Emergency Operations Plan (GEOP). GEMA provides for 24-hour notification and staffing of the State Operations Center (SOC) and/or the Forward Emergency Operations Center (FEOC), as required, throughout the event. GEMA is responsible for general state emergency planning and overall direction and control of emergency or disaster operations as assigned by executive order and in accordance with the Georgia Emergency Operations Plan (GEOP). GEMA has responsibilities for coordinating the state of Georgia response to emergencies at nuclear power plants. A.2.2.2 Department of Natural Resources Environmental Protection Division (DNR-EPD) Department of Natural Resources-Environmental Protection Division (DNR-EPD) is assigned as the coordinating and a primary agency responsible by Executive Order for implementation and administration of the state radiological and hazardous material function. E2-12

Enclosure 2 to NL-16-0169 . SNC Standard Emergency Plan The DNR-EPD has primary responsibility for implementation and administration of the state radiological emergency response function. A.2.2.3 Other Georgia State Agencies Responsibilities of other state agencies are described in the Georgia Emergency Operations Plan (GEOP). A.2.3 State of South Carolina A.2.3.1 Emergency Management Division (EMD) The EMD is assigned the responsibility for coordinating the emergency planning efforts of state, county, and municipal agencies in accordance with the South Carolina Radiological Emergency Response Plan (SCORERP); conducting a preparedness program to assure capability of the government to execute the plan; establishing and maintaining a State EOC and providing support of the State emergency staff and work force; and establishing an effective system for reporting, analyzing, and disseminating emergency information. A.2.3.2 Department of Health and Environmental Control (DHEC), Nuclear Emergency Planning Section The Department of Health and Environmental Control (DHEC) maintains a radiological hazard assessment capability and provides technical support, coordination, and guidance for the State and local governments. It will conduct qnd/or coordinate radiological surveillance and monitoring in coordination with DOE-Savannah River Site (SRS) and nuclear power plants. DHEC will obtain and coordinate radiological assistance resources from the Federal *

                      . Government, other states, and the nuclear industry as required.

A.2.3.3 Other South Carolina State Agencies Responsibilities of the other state agencies are described in the South Carolina Radiological Emergency Response Plan (SCORERP). A.2.4 Emergency Planning Zone (EPZ) Counties The Emergency Management Agencies representing the counties of Aiken, Allendale, Appling, Barnwell, Burke, Early, Henry, Houston, Jeff Davis, Tattnall, and Toombs have the responsibility for notification and providing direction to residents in the event of an emergency that affects their respective jurisdiction. The 24-hour notification points have the responsibility to notify necessary local civil support groups in the event of an accident. The County is responsible for protection of the public and can provide personnel and equipment for evacuation, relocation and isolation. A.3 Contractor and Private Organizations A.3.1 Southern Nuclear E2-13 to NL-16-0169 SNC Standard Emergency Plan Southern Nuclear Operating Company (SNC) serves as the architect-engineer. E2-14 to NL-16-0169 SNC Standard Emergency Plan A.3.2. Bechtel Power Corporation SNC has established an agreement with Bechtel Power Corporation to obtain engineering and construction services which may be required following an accident. A.3.3 Westinghouse SNC has established an agreement with Westinghouse to obtain general services related to nuclear steam supply system (NSSS) operations during and following an accident situation. Westinghouse provides the capability to respond on a 24-hour-a-day basis. A.3.4 General Electric Company (GE) The licensee has established an agreement with GE to obtain general services related to nuclear steam supply system (NSSS) operations during and following an accident situation. GE provides a capability to respond on a 24-hour-a-day basis. A.3.5 Radiological Monitoring Assistance Radiological monitoring in the plant and in the environs, both onsite and offsite, will be augmented by outside vendors as necessary. Initial radiological monitoring will be performed by available Southern Company resources (e.g., Georgia Power Company (GPC) Central Laboratory). A.3.6 Contract Laboratories SNC-operated plants maintain contracts with offsite laboratories to assist with emergency analytical services. Copies of these contracts are maintained in accordance with Emergency Plan procedures. A.4 Other Utilities The Institute of Nuclear Power Operations (INPO) aids nuclear utilities in obtaining resources beyond their usual capabilities during recovery from an emergency. As one of its roles, INPO will assist affected utilities by applying the resources of the nuclear industry to meet the needs of an emergency. A.5 Agreements Letters of Agreement (LOAs) are not necessary with federal and state agencies that are legally required to respond to an emergency; however, agreements are necessary if an agency is expected to provide assistance not required by law. Written agreements have been developed which establish the extent of operations between SNC-operated plants and other support organizations that have an emergency response role consistent with this plan. These agreements identify the emergency measures to be provided, the mutually accepted criteria for implementation, and the arrangements for exchange of information. The respective nuclear power plants have obtained LOAs with private contractors and others who provide emergency support services. LOAs, as a minimum, state that the cooperating organization will provide its normal services in support of an emergency at the affected plant. LOAs are referenced in the site-specific plant Annexes and the actual letters are maintained in accordance with 10 CFR 50, Appendix E, N.A.7. E2-15

Enclosure 2 to NL-16-0169 SNC Standard Emergency Plan SECTION B: EMERGENCY RESPONSE ORGANIZATION (ERO) B.1 Normal Plant Organization The normal onsite organization of an SNC-operated nuclear power plant provides a staff 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, 3, and 4. SNC plants maintain 24-hour emergency response capability. The normal on-shift complement provides the initial response to an emergency. This group is trained to respond to emergency situations until the augmented Emergency Response Organization (ERO) arrives. The ERO is composed of personnel with specialties in operations, maintenance, engineering, radiochemistry, radiation protection, fire protection, and security. B.1.1 The Shift Manager (SM) is in direct charge of shift plant operations and is directly responsible for the actions of the on-shift crew. In an emergency, the SM assumes the responsibility of the Emergency Director (ED) and takes necessary actions to identify and respond to the emergency until relieved by another qualified ED. The ED has the responsibility and authority to immediately and unilaterally initiate emergency actions, including providing notification of Protective Action Recommendations (PAR) to state and local government organizations responsible for implementing off site emergency measures. The ED, at their discretion or when procedurally required, activates the ERO. The Emergency Director's non-delegable duties include:

Event classification in accordance with the emergency classification system.
Perform the duties and responsibilities of Protective Action Recommendation (PAR) determination.
Notifications of offsite agencies and approval of state, local, and NRC notifications.
Authorization of emergency exposures in excess of federal limits.
Issuance of potassium iodide (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). B.1.2 Shift Supervisors, who hold Senior Reactor Operator (SRO) licenses, supervise operation of the unit and may assume the duties of the ED in the absence of the Shift Manager. Additional details of the normal on-shift organization are contained in the site specific annexes to this Plan. E2-16 to NL-16-0169 SNC Standard Emergency Plan B.2 On Site Emergency Response Organization (ERO) 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 (OSC), 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-hour-a-day basis for an extended event. On-shift as well as offsite state and local government interfaces are detailed in the site-specific Annexes. Command and Control normally shifts from the Control Room to the TSC and subsequently to the EOF. Command and Control may move in either direction, depending on conditions that would warrant passing such authority. Command and Control may be completed sequentially or in parallel, based on the discretion of the EDs. A qualified ED in either facility can relieve the other facility of the Command and Control authority and responsibilities. Figure B.2.A depicts the transition of Command and Control responsibilities between facilities. Alternative Facilities have been identified to ensure timely ERO response during a hostile action event. Details on the Alternative Facilities are included in Section H. CONTROL ROOM TSC EOF Shift Manager I TSC Emergenc~ Director EOF Emergenc~ Director Emergenc~ Director Classification .., Classification Notification:: .~ Notifications PARs ~

PARs Emergency Exposure .., Emergency Exposure Controls Controls Figure B.2.A Transition of Command and Control Functions B.2.1 Technical Support Center (TSC) See Figure B.2.1.A at the end of Section B. B.2.1.l TSC Emergency Director (ED) The TSC ED has the authority and responsibility to immediately initiate any emergency actions. Once transfer of Command and Control has been completed, the TSC ED assuJlleS the non-delegable duties of event Classification, on-site Emergency Exposure Authorization, and on-site protective actions. B.2.1.2 TSC Manager The TSC Manager reports to the TSC ED and is responsible for coordinating activities between the TSC and other emergency response facilities, directing the activities of the TSC staff, and ensuring communications are established with applicable offsite agencies. E2-17 to NL-16-0169 SNC Standard Emergency Plan B.2.1.3 TSC Operations Supervisor The Operations Supervisor reports to the TSC Manager. Major position functions include evaluating plant conditions and initiating mitigation actions, coordinating TSC efforts in determining the nature and extent of plant conditions affecting plant equipment, actions to limit or contain the emergency, invoking the provisions of 10 CFR 50.54(x) if appropriate, assisting the OSC Manager in determining the priority assigned to OSC activities, and timely completing offsite notifications. B.2.1.4 TSC Maintenance Supervisor The Maintenance Supervisor reports to the TSC Manager and is responsible for planning and coordination of repair, damage control, and plant modification activities. The Maintenance Supervisor works closely with the Engineering Supervisor in planning for plant modifications and repairs. B.2.1.5 TSC Radiation Protection (RP) Supervisor The RP Supervisor reports to the TSC Manager and supervises the activities of the radiation protection staff and Health Physics Network (HPN) Communicator. The RP Supervisor assists the Radiation Protection/Chemistry Group Lead in the OSC in determining the extent and nature of radiological or hazardous conditions and coordinates offsite dose assessment and offsite .Field Monitoring Teams prior to EOF activation. 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. 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. B.2.1.8 TSC Reactor Engineer The Reactor Engineer reports to the Engineering Supervisor in the TSC. The Reactor Engineer is responsible for monitoring core conditions and providing recommendations to maintain the viability of the core. The Reactor Engineer relieves the Shift Technical Advisor (STA) of Core Thermal Analysis responsibilities. B.2.1.9 TSC Engineering Support The TSC Engineering Support reports to the Engineering Supervisor in the TSC. The TSC Engineering Support is responsible for monitoring the plant systems and planning corrective actions as appropriate. E2-18 to NL-16-0169 SNC Standard Emergency Plan 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. B.2.1.11 TSC Emergency Notification System (ENS) Communicator The ENS Communicator reports to the Operations Supervisor and is responsible for ensuring NRC notifications are completed in accordance with the requirements of 10 CPR 50.72 and 73. B.2.1.12 TSC Health Physics Network (HPN) Communicator The HPN Communicator reports to the RP Supervisor and is responsible for providing radiological and environmental information to the NRC on the HPN Line. B .2.1.13 TSC Emergency Response Facility (ERP) Communicator The ERP Communicator reports to the TSC ED. The ERP communicator is responsible for staffing continuous communications links with their CR, OSC and EOF counterparts. B.2.1.14 TSC Security Supervisor The Security Supervisor reports to the TSC Manager. The TSC Security Supervisor is responsible for carrying out the plant security and Access Control program, maintaining personnel accountability onsite, and assisting in evacuation of onsite areas. B.2.1.15 TSC Support Coordinator* 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. B.2.2 Operations Support Center (OSC) See Figure B.2.2.A at end of Section B. B.2.2.l OSC Manager The OSC Manager reports to the TSC Manager and directs a staff in providing labor, tools, protective equipment, and parts needed for emergency repair, damage control, firefighting, search and rescue, first aid, and recovery. B.2.2.2

OSC Mechanical Maintenance Group Lead The Mechanical Maintenance Group Lead reports to the OSC Manager and provides oversight for Mechanical Maintenance personnel. Their responsibilities include planning the activities, briefing and debriefing the teams, tracking job progress, and maintaining periodic communication with the teams.

E2-19 to NL-16-0169 SNC Standard Emergency Plan B.2.2.3 OSC Electrical Group Lead The Electrical Group Lead reports to the OSC Manager and provides oversight for Electrical Maintenance personnel. Their responsibilities include planning work activities, team member selection and briefing, tracking job progress, and maintaining communication. B.2.2.4 OSC RP/Chemistry Group Lead The RP/Chemistry Group Lead reports to the OSC Manager and provides oversight for RP and Chemistry Technicians. Their responsibilities include onsite radiological surveys, access control, personnel monitoring and decontamination, dosimetry issuance and monitoring, and onsite habitability surveys. B.2.2.5 OSC l&C Group Lead The l&C Group Lead reports to the OSC Manager and provides oversight for l&C Maintenance personnel. Their responsibilities include planning work activities, team member selection and briefing, tracking job progress, and maintaining communication. B.2.2.6 OSC ERF Communicator The ERF Communicator reports to the OSC Manager and is responsible for maintaining communications with their counterpart in the Control Room, TSC and EOF. B.2.2.7 OSC Personnel Selected personnel report to the OSC as directed. Emergency personnel from the Maintenance, Operations, and RP/Chemistry Departments are directed to report to the OSC. OSC teams are headed by a designated team leader, who maintains communication with the OSC. The following emergency teams may be formed by OSC personnel, as necessary:

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

B.3 Offsite Emergency Response Organization (ERO) The EOF and JIC Organizations consist of staff members from the SNC, Alabama Power Company, and Georgia Power Company corporate offices. This organization is responsible for providing offsite emergency response support and resources as needed. The EOF and JIC Organizations are displayed in Figures B.l.D and B.l.E. The EOF and JIC Organizations may also include state and local personnel. E2-20 to NL-16-0169 SNC Standard Emergency Plan B.3.1 EOF Organization The EOF Organization consists of selected management and staff members located in the SNC Corporate Office. This organization is responsible for providing offsite emergency response support and resources, as needed. The EOF Organization is displayed on Figure B.l.D. When the EOF is activated, EOF staff electronic devices are activated, and EOF personnel are expected to report to the EOF. Personnel who are not needed to augment positions are briefed and dismissed with a standby status. See Figure B.3.1.A at end of Section B. B.3.1.1 EOF 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. B.3.1.2 EOF Manager The EOF Manager reports to the EOF ED and is responsible for managing and directing EOF activities, developing recovery plans, procuring outside services and equipment, as necessary, coordination with offsite agencies and approving news releases. B.3.1.3 EOF Support Coordinator The Support Coordinator reports to the EOF Manager. The duties and responsibilities of the Support Coordinator in the EOF include 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. B .3 .1.4 EOF Dose Assessment Supervisor The Dose Assessment Supervisor reports to the EOF Manager and provides oversight of dose assessment, field team control, and protective action recommendation activities in the EOF; and coordinates communication of results with offsite agencies. B.3.1.5 EOF Dose Analyst The Dose Analyst reports to the Dose Assessment 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. B.3.1.6 EOF Field Team Coordinator The Field Team Coordinator reports to the Dose Assessment Supervisor. The Field Team Coordinator develops the environmental sampling strategy in response to potential radiological releases and advises the Dose Assessment Supervisor and Dose Analyst of measured radiological values in the environment. E2-21 to NL-16-0169 SNC Standard Emergency Plan B.3.1.7 EOF Field Team Communicator The Field Team Communicator reports to the Field Team Coordinator. The Field Team Communicator is responsible for communications with the Environmental Teams, providing them sampling direction and plant status with respect to team safety: B.3.1.8 EOF Emergency Notification Network (ENN) Communicator The ENN Communicator in the EOF reports to the Emergency Communication Coordinator and is responsible for providing offsite agency notifications and periodic updates. B.3.1.9 EOF Emergency Notification System (ENS) Communicator The ENS Communicator reports to the Emergency Communication Coordinator and is responsible for ensuring NRC notifications applicable to EOF operations are completed in accordance with the requirements of 10 CFR 50.72 and 73. B.3.1.10 EOF Emergency Communications Coordinator The Emergency Coinmunications Coordinator reports to the EOF Manager. The Emergency Communications Coordinator is responsible for assisting with the coordination and facilitation of communications both within the facility as well as with external agencies. B.3.1.11 EOF Security Coordillator The Security Coordinator reports to the EOF Manager. The duties and responsibilities of the Security Coordinator will be assumed by SNC corporate personnel. Responsibilities include supporting the plant security'manager, keeping the EOF Manager informed of any security events or issues, communication of Security Related information to the NRC using the security bridge line, and as establishing and maintaining access control for the EOF. B.3.1.12 EOF Offsite Response Coordinator The Offsite Response Coordinator reports to the EOF Manager. The duties and responsibilities of the Offsite Response Coordinator include coordination of activities for the dispatch and update of technical liaisons to state and local authorities and monitoring EOF functional areas to facilitate coordination between the licensee and state and local agencies. B.3.1.13 EOF Health Physics Network (HPN) Communicator The HPN Communicator reports to the Dose Assessment Supervisor and is responsible for providing radiological and environmental information to the NRC using the HPN Line. B.3.1.14 EOF Administrative Support Staff The Administrative Support Staff report to the EOF Support Coordinator. The administrative support staff is responsible for providing clerical and administrative E2-22 to NL-16-0169 SNC Standard Emergency Plan support to the Emergency organization, making entries to and retrieving data from the Nuclear Network, retrieval of file documents, and updating status boards using information provided from the sites. B.3.1.15 EOF Liaisons Liaisons report to the Offsite Response Coordinator and respond to the applicable state and county 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. B.3.1.16 EOF Emergency Response Facility (ERF) Communicator The ERF Communicator reports to the EOF Emergency Director and is responsible for maintaining communications with their counterpart in the Control Room, TSC and OSC. B.3.1.17 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. B.3.1.18 EOF News Writer The News Writer reports to the EOF Manager, gathers information, and prepares news bulletins verified for distribution. The News Writer coordinates technical approval with the EOF Manager. B.3.2 Joint Information Center (JIC) See Figure B.3.2.A at end of Section B. B.3.2.1 Public Information Director (PID) The PID is responsible for coordination of emergency information between the utility and responding offsite organizations participating in the Corporate Media Center (CMC) or Joint Information Center (JIC). Additional duties include managing approval and dissemination of utility news bulletins, facilitating news briefings, overseeing public response, serving as liaison to the media and coordinating offsite agencies. The PID is responsible for evaluating the emergency's severity in terms of public interest and safety. The PID may delegate emergency communications approval authority to other staff members. B.3.2.2 JIC Manager The JIC Manager reports to the PID and supervises the activities of the technical and communications advisors, technical communicator and an administrative staff. The JIC Manager responsibilities include:

Providing the EOF Manager with an overview of the public and media impacts of plant and governmental activities.

E2-23 to NL-16-0169 SNC Standard Emergency Plan

Advising the Nuclear Spokesperson regarding information to be released to the public.
Maintaining up-to-date knowledge of conditions of the plant and environment, and the actions of SNC and governmental support personnel.
Coordinating with the state to review and access media coverage of the emergency event.

B.3.2.3 JIC Assistant The JIC Assistant reports to the JIC Manager and is responsible for supervision and direction of clerical staff in the facility; verification, approval, and distribution of news bulletins; direction of support staff activities; and maintenance of an accurate record of facility activities. B.3.2.4 Facility Coordinator The Facility Coordinator reports to the JIC Manager and is responsible for setting up the facility and ensuring ongoing operability, as well as providing oversight for facility Security personnel. B.3.2.5 Public Response Coordin.ator The Public Response Coordinator reports to the PID and is responsible for directing the facility's public response activities, keeping staff informed of the most current plant status, and obtaining responses for rumors and public inquiries. B.3.2.6 Public Response Staff The Public Response Staff reports to the Public Response Coordinator and is responsible for coordinating and developing responses to rumors and public inquiry. B.3.2.7 Media Relations Representative The Media Relations Representative reports to the JIC Manager and is responsible for implementing utility media response and supervision of AV staff. B.3.2.8 Nuclear Spokesperson The Nuclear Spokesperson speaks on behalf of the company, providing plant status updates during news briefings. The Spokesperson also may do one-on-one media interviews. The position works with the Technical Assistant in keeping abreast of the event status and keeps the Public Information Director (PID) posted on that status B.3.2.9 Technical Assistant The Technical Assistant reports to the Nuclear Spokesperson and is responsible for gathering accurate and timely information about the event and the plant's status from displays, ENN Forms and the EOF staff. E2-24 to NL-16-0169 SNC Standard Emergency Plan B.4 Contractor and Private Organizations B.4.1 Vendors and Contractors Major equipment providers or Architect-Engineers include Westinghouse Electric Corporation, General Electric Corporation, and Bechtel Power Corporation, which can provide the following assistance in an emergency:

Trained personnel.
Technical analysis.
Operational analysis.
Accident and transient analysis.

B.4.2 Other Utilities

Other nuclear power plant organizations may provide personnel and equipment.

Prior written agreements frequently exist in these situations.

The unaffected SNC plants provide mutual support;
Assistance from any nuclear power plant may be requested through an existing INPO link;
Voluntary Assistance Groups.

B.4.3 Other Organizations B.4.3.1 Contract laboratories can provide assistance in environmental monitoring and sampling. B.4.3.2 National Weather Service (NWS) provides up to date meteorological information to the individual nuclear power plants. B.4.3.3 Local Organizations Other local organizations are detailed in the site-specific Annexes. B.5 Letters of Agreement (LOAs) The respective nuclear power plants have obtained LO As with private contractors and others who provide emergency support services. LOAs, as a minimum, state that the cooperating organization will provide its normal services in support of an emergency at the affected plant. LOA's are referenced in the site-specific plant Annex and the actual letters are maintained in accordance with Emergency Plan procedures. B.6 Local Emergency Support Organizations B.6.1 Local Law Enforcement Agencies Local law enforcement agencies may be called upon to lend assistance during the response to emergencies at any of the SNC-operated nuclear power plants. Details on the services offered are in the SNC plant's site-specific Annex. E2-25 to NL-16-0169 SNC Standard Emergency Plan B.6.2 Ambulance Services Agreements for ambulance services are in place to transport injured personnel from the plants to the designated medical facility. Training is provided for the transport of contaminated personnel, and qualified utility personnel may accompany the ambulance. Details on the services offered are in the SNC plant's site-specific Annex. B.6.3 Medical Services Prior arrangements have been made for medical treatment at a variety of facilities. SNC-operated nuclear power plants are supported, and sites offer training to the medical staff in dealing with contaminated injured personnel. Details on the services offered are the SNC plant's site-specific Annex. B.6.4 Fire Fighting To supplement the Fire Brigade on-site, agreements are made with local fire departments. Details on the services offered may be found in the SNC plant's site-specific Annex. E2-26 to NL-16-0169 SNC Standard Emergency Plan TSC 75 Minute Augmentation ERO Major Functional Area Major Task Position Title Emergency Director TSC Manager Emergency Direction and Operations Supervisor Control Security Supervisor* Support Coordinator** Notify licensee, state, local Emergency Notification and federal personnel & System (ENS) Communicator maintain communication Health Physics Network Notification I Communication (HPN) Communicator Intra-facility Emergency Response Facility Communications (ERP) Communicator Offsite dose assessment Radiation Protection (RP) Supervisor Radiological Accident Dose Analyst* Assessment and Support of Operational Accident Offsite surveys Not applic,able for this facility Assessment Onsite and in-plant surveys Chemistry/Radio Chemistry Chemistry Support Technical Support Engineering Supervisor Reactor Engineer Plant System Engineering, Engineering Support (2) 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, & firefighting Personnel monitoring Dosimetry Total 13 Note: Site Annexes contain any additional site specific staffing.

Security Supervisor is filled by on shift Security Supervisor. Dose Analyst is filled by the on-shift Chemistry Technician.
- Support Coordinator does not have a 75-minute Augmentation Time.

Table 1 E2-27 to NL-16-0169 SNC Standard Emergency Plan OSC 75 Minute Augmentation ERO Major Functional Area Major Tasks Position Title Emergency Direction and OSCManager Control Notify licensee, state, local Not applicable for this facility and federal personnel & Notification I Communication maintain communication Intra-facility ERF Communicator communications Offsite dose assessment Not applicable for this facility Offsite surveys Field Monitoring Team Lead Radiological Accident (1) Assessment and Support of Field Monitoring Team Operational Accident Assistant (2) Assessment Onsite and in-plant surveys RP Technicians (2) Chemistry/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 l&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, &

firefighting

Personnel monitoring
Dosimetry Total 14 Table 2 E2-28 to NL-16-0169 SNC Standard Emergency Plan

                              . EOF 75 Minute Augmentation ERO Major Functional Area                 Major Task                     Position Title Emergency Direction and          Emergency Operations           Emergency Director (ED)

Control Facility (EOF) Director EOFManager Support Coordinator** Emergency Communication Coordinator Security Coordinator Offsite Response Coordinator Administrative Support Staff Liaisons (at EOCs)**

                                                                -      GA
                                                                -      AL
                                                                -      SC Notification I                   Notify licensee, state, local  ENN Communicator Communication                    and federal personnel &        ENS Communicator maintain communication         HPN Communicator Intra-facility                 ERF Communicator Communications                 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 Repair and corrective Not required in this facility Actions 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 Total 17 Table 3

- Support Coordinator, Administrative Support Staff, Liaisons (at EOCs) GA, AL, SC do not have a 75 minute Augmentation Time.

E2-29 to NL-16-0169 SNC Standard Emergency Plan

                                            .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 Total 5 Note:

JIC Staff does not have a 75-minute Augmentation Time.

Table 4 E2-30 to NL-16-0169 SNC Standard Emergency Plan TSC Emergency Director ERF Communicator I osc I TSC I Manager 1-- Manager L _____ J I I I I I I Operations RP Security Maintenance Engineering Support

-             Supervisor Supervisor        Supervisor        Supervisor          -     Supervisor     Coordinator ENS                          Dose Communicator Analyst                                                -   Reactor Engineer r-----,

y Shift Manager L--,-- I I - HPN Communicator - Staff Engineer I r--1--, ERF I Chemistry I Communicator Support

                                                                                                   -    Staff Engineer L ____ I Minimum Staff positions are shaded boxes Figure B.2.1.A -Technical Support Center Organization E2-31 to NL-16-0169 SNC Standard Emergency Plan
                ,--------1 I

I TSC : osc

                !    Manager        :                                      Manager I                   I L---------

ERF Communicator I RP/Chemistry Mechanical Electrical l&C Group Lead Group Lead Group Lead Group Lead I I I RP Chemistry l&C Mechanics Electricians Technicians Technicians Technicians Minimum Staff positions are shaded boxes Figure B.2.2.A - Operations Support Center Organization E2-32 to NL-16-0169 SNC Standard Emergency Plan

                                                                                                                       ~ - - - - P~bii~ - - - - :

Emergency Director

                                                                           >-- - - -   -  -  -  -  - - - - -  - -   -i        Information       1 Director 1L _ _ _________          :

ERF Communicator EOF Manager I I I I I I EOF Dose Emergency Off site Techn ical Security News Writer Support ~ Assessment Supervisor - Communication Coordinator I

Response

Coordinator Supervisor Coordinator Coordinator I I I I I L__ Administrative Support Staff

                                        ,....___     Dose Analyst                  -             ENN Communicator                                I State Liaison Georgia I

I I I ENS I

                                        ,....___      HPN                    -       Communicator                                I- - -

State Liaison Commuicator I Alabama I I I I State Liaison Field Team

I- - - South Coordinator I Carolina I I I I Minimum Staff pos itions are shaded boxes I Other State I Field Team L __ County Communicator Liaisons Figure B.3.1.A - Emergency Operations Facility Organization E2-33 to NL-16-0169 SNC Standard Emergency Plan

     '                  I 1                                           Public 1   Emergency

Director ~-------------- Information Director

    '-----r----'I I

I Nuclear Spokesperson I JIC Public Response Manager Coordinator Technical Assistant I I JIC Facility Media Relations Public Response Assistant Coordinator Representative Staff I Clerical Security Staff Minimum Staff Positions are shaded boxes Figure B.3.2.A -Joint Information Center Organization E2-34

Enclosure 2 to NL-16-0169 SNC Standard Emergency Plan SECTION C: EMERGENCY RESPONSE SUPPORT AND RESOURCES Once an emergency has been declared, the Emergency Director (ED) has the authority and responsibility to request aid from offsite organizations, whether they are other SNC-operated nuclear power plants, federal, state, local, or private organizations. C. l Federal Assistance Federal agencies that may provide assistance in direct support of SNC in the event of an accident are identified in Section A of this plan. If needed, federal resources are expected to be made available to SNC. C.2 State Interfaces Designated SNC personnel are assigned to the state or county Emergency Operations Centers (EOCs). Locations have been provided in the EOF for liaisons from the state and county. C.3 Radiological Laboratories C.3 .1 Onsite Laboratory The onsite laboratory/counting rooms at SNC-operated nuclear power plants are the primary facility for radiation monitoring and analysis efforts. The onsite laboratory is the central point for receipt and analys'is of onsite samples and includes equipment for chemical and radiological analyses. The plant laboratories have the capability of quantitative analysis of marine and air samples, and qualitative analysis of terrestrial samples. Additional facilities for counting and analyzing samples are available at the other SNC-operated nuclear plants or state and federal laboratory services. These laboratories can act as backup facilities in the event that the affected nuclear power plant's counting room and laboratory become unusable or the capacity or capability of the plant's laboratory is exceeded. C.3.2 Contract Laboratories Additional outside analytical assistance may be requested from contracted vendors. These laboratories provide bioassay analysis and radiochemical analysis services. C.4 Assistance Agreements C.4.1 Nuclear Industry The nuclear industry provides a reservoir of personnel with a wide range of technical expertise and knowledge. A nuclear industry national inventory of personnel who may be called upon to supplement company personnel has been developed through the Institute of Nuclear Power Operations (INPO). In addition, a number of utilities have entered into an INPO coordinated Voluntary Assistance Agreement program. This provides a mechanism to draw on industry resources during an emergency. Support may also be requested from neighboring utilities for the following:

Personnel and equipment to assist with in-plant and emergency field monitoring.

E2-35 to NL-16-0169 SNC Standard Emergency Plan

Engineering, design, and technical expertise to assist in determining the cause of the accident and to support recovery.
Personnel and equipment to assist in maintenance and repairs to the facility.
SNC-operated plants are a signatory to two comprehensive agreements among electric utility companies:
Nuclear Power Plant Emergency Response Voluntary Assistance Agreement.
Voluntary Assistance Agreement By and Among Electric Utilities Involved in Transportation of Nuclear Materials.

C.4.2 Offsite resources SNC supports the sharing of personnel and resources among SNC-operated nuclear power plants, providing a large personnel and equipment base. C.4.2.1 American Nuclear Insurers (ANI) ANI provides insurance to cover SNC legal liability up to the limits imposed by the Price-Anderson Act, for bodily injury and/or property damage caused by the nuclear energy hazard resulting from an accident at a nuclear power plant. C.4.2.2 Civil/Structural Engineers Plants have an Architect-Engineer that could be called on to provide engineering expertise in dealing with a nuclear power plant accident. C.4.2.3 Nuclear Steam Supply System Vendor Under established contracts, the following will supply available engineering expertise, specialized equipment, and other services identified as needed and deemed appropriate to provide in an emergency situation:

General Electric (GE) Nuclear Energy.
Westinghouse Electric Company.

C.4.2.4 Supplemental Emergency Assistance to the ERO SNC-operated nuclear power plants maintain agreements with outside support agencies that do not take part in the organizational control of the emergency, but provide assistance when called on during an emergency or during the recovery phase. These agreements identify the emergency measures to be provided, the mutually accepted criteria for implementation, and the arrangements for exchange of information. These support agencies provide services of:

Law enforcement.
Fire protection.
Ambulance services.
Medical and hospital support.
DOE Radiological Assistance Program (RAP).

E2-36 to NL-16-0169 SNC Standard Emergency Plan C.4.2.5 Local Response Organizations In many cases, local groups provide for emergency communications and other services, such as transportation and medical assistance. References to these groups are contained in the site-specific Annexes. E2-37

Enclosure 2 to NL-16-0169 SNC Standard Emergency Plan SECTION D: EMERGENCY CLASSIFICATION SYSTEM D.1 Classification of Emergencies D .1.1 Emergency Conditions D.1.1.l Emergency classification is divided into four classification levels described in 10 CPR 50 Appendix E and NUREG 0654 and based on NEI 99-01and07-01 methodologies. Emergency Action Levels (EALs), based on indications available in the control room and correlated to the emergency classifications, are provided to the operator. SNC has and maintains the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an EAL threshold has been met or exceeded. Upon identification of the appropriate emergency classification level, the emergency condition will be promptly declared. The classification scheme is provided to and discussed' by Southern Nuclear Company, agreed upon by state and county governmental authorities and approved by the NRC. The classification scheme and specific Emergency Action Levels are reviewed with the State and local governmental authorities on an annual basis. D.1.1.2 Emergency Classification Level Descriptions There are three considerations related to emergency classification levels. These are: (1) The potential impact on radiological safety, either as known now or as can be reasonably projected. (2) How far the plant is beyond its predefined design, safety, and operating envelopes. (3) Whether or not conditions that threaten health are expected to be confined to within the site boundary. The Initiating Conditions (ICs) deal explicitly with radiological safety impact by escalating from levels corresponding to releases within regulatory limits to releases beyond EPA Protective Action Guideline (PAG) plume exposure levels. The four emergency classification levels are described as follows: UNUSUAL EVENT (UE) Events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs. ALERT Events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment ( E2-38 to NL-16-0169 SNC Standard Emergency Plan because of hostile action. Any releases are expected to be limited to small fractions of the EPA PAG exposure levels. SITE AREA EMERGENCY (SAE) Events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or hostile action that results in intentional damage or malicious acts toward site personnel or equipment that could 1) lead to the likely failure of, or 2) prevent effective access to, equipment needed for the protection of the public. Any releases are not expected to result in exposure levels that exceed EPA PAG exposure levels beyond the site boundary. GENERAL EMERGENCY (GE) Events are in progress or have <?ccurred which involve actual or imminent substantial core degradation or melting with potential for loss of containment integrity or hostile action that results in an actual loss of physical control of the facility. Releases can be reasonably expected to exceed EPA PAG exposure levels offsite for more than the immediate site area. D.2 Basis for Emergency Classification Criteria D.2.1 Emergency Action Levels. Planned evolutions involve preplanning to address the limitations imposed by the condition, the performance of required surveillance testing, and the implementation of specific controls prior to knowingly entering the condition, in accordance with the specific requirements of Technical Specifications. Planned or unplanned activities that cause the plant to operate beyond the limits allowed by Technical Specifications may result in an EAL threshold being met or exceeded. Planned evolutions to test, manipulate, repair, or perform maintenance or modifications to systems and equipment that result in an EAL value being met or exceeded are not subject to classification as long as the evolution proceeds as planned and is within the operational limitations imposed by the operating license. Classifications are based on evaluation of the applicable Unit. Classifications are based on valid indications, reports, or conditions. Thresholds assume valid indications. Reports or conditions are considered valid when they are verified by 1) an instrument channel check, or 2) indications on related or redundant indications, or 3) by direct observation by plant personnel, in such a way that any doubt as to th@ indication's operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment. Although the majority of the EALs provide very specific thresholds, the Emergency Director must remain alert to events or conditions that lead to the conclusion that exceeding the EAL is imminent. If, in the judgment of the Emergency Director, an imminent situation is at hand, the classification should be made as if the threshold has been exceeded. An Emergency Action Level has two distinct parts. The Initiating Condition (IC) is a brief description of conditions that are compared to existing abnormal plant E2-39 to NL-16-0169 SNC Standard Emergency Plan conditions. The ICs are segregated into Recognition Categories. The Recognition Categories are:

R - Abnormal Radiological Levels/Radiological Effluent.
C - Cold Shutdown/Refueling System Malfunctions.
E- Independent Spent Fuel Storage Installations (ISFSI).
F - Fission Product Barrier.
H - Hazards and Other Conditions Affecting Plant Safety.
S - System Malfunction.

With each IC are Threshold Values (TV) that provide the criteria for classification associated with the appropriate classification level. When the IC is observed to exist, the TV must also be met; exceeded or il). some cases imminent to become a classifiable Emergency Action Level. The Fission Product Barrier and System ¥alfunction criteria are only applicable when in the hot operating modes. The Cold Shutdown/Refueling System malfunctions are only applicable in cold shutdown and Defueled modes or as specifically designated in each EAL. The EALs associated with the Radiological, ISFSI, and Hazards categories are applicable in all modes of operation. D.2.2 Initiating Conditions have symptom-based, event-based, or barrier-based criteria. Symptom-based ICs refer to those indicators that are measurable over some continuous spectrum, such as core temperature, coolant levels, or containment pressure. When one or more of these indicators begin to show off-normal readings, reactor operators are trained to identify the probable causes and potential consequences of these "symptoms" and take corrective action. The level of seriousness that these symptoms indicate depends on the degree to which they have exceeded technical specifications, the other symptoms, or events that are occurring contemporaneously, and the capability of the licensed operators to gain control and bring the indicator back to safe levels. Event-based ICs refer to occurrences with potential safety significance, such as the failure of a safety valve or a loss of electric power to some part of the plant. The range of seriousness of these "events" is dependent on the location, number of contemporaneous events, remaining plant safety margin, and so forth. Barrier-based ICs refer to the level of challenge to the principal barriers that ensure containment of radioactive materials contained within a nuclear power plant. For radioactive materials that are contained within the reactor core, these barriers are: fuel cladding, reactor coolant system pressure boundary, and containment. The level of challenge to these barriers encompasses the extent of damage (loss or potential loss) and the number of barriers concurrently under challenge. In general, challenge to one or more barriers is initially identified through instrument readings and periodic sampling. Deterioration of the reactor coolant system pressure boundary or the fuel clad barrier usually indicates an Alert condition, two barriers under challenge a Site Area Emergency, and* loss of two barriers with the third barrier under challenge is a General Emergency. The fission product barrier criteria E2-40 to NL-16-0169 SNC Standard Emergency Plan recognize that some events may represent a challenge to more than one barrier, and that the containment barrier is weighted less than the reactor coolant system pressure boundary and the fuel clad barriers. D.2.3 Emergency Action Level Threshold Values The most common bases for establishing Threshold Values are the Technical Specifications, Operating Procedures, the Offsite Dose Calculation Manual (ODCM), and setpoints that have been developed in the design basis calculations for the Final Safety Analysis Report (FSAR). Another critical element of the analysis to arrive at Threshold Value conditions is the time that the plant might stay in that condition before moving to a higher emergency classification level. The time dimension is critical to the EAL, since the purpose of the emergency classification level for state and local officials is to notify them of the level of mobilization that may be necessary to address the emergency. This is particularly true when a Site Area Emergency or General Emergency is imminent. A time variable is used to allow for correction of the condition before a classification is made. Site-specific Threshold Values for Emergency Action Level Initiating Conditions are maintained in the station's Emergency Action Level Technical Basis document. D.2.4 Treatment of Multiple events and Classification Level Upgrading When multiple simultaneous events occur, the emergency classification level is based on the highest EAL reached. Emergency classification level upgrading considers the potential for radioactive release from the entire site due to the event or simultaneous events. D.2.5 Emergency Classification Level Downgrading and Termination The SNC policy is that once an emergency classification is made, it cannot be downgraded to a lower classification. Termination ,criteria contained in the Emergency Plan Implementing Procedures shall be completed for an event to be terminated. At termination, on an event specific basis, the site can either enter normal operating conditions or enter a recovery condition with a recovery organization established for turnover from the ERO. When the site determines that transition to termination or recovery is appropriate, the information will be transmitted to respective offsite agencies. D.2.6 Classifying Transient Events Many of the Initiating Conditions and/or EALs described in this document employ time-based threshold criteria. These criteria will require that the threshold conditions be present for a defined period of time before an emergency classification is warranted. In cases where no time-based criteria are specified, it is recognized that some transient events may cause an EAL threshold to be met for a few seconds to a few minutes. The following guidance should be applied to the classification of these events. E2-41 to NL-16-0169 SNC Standard Emergency Plan EAL threshold momentarily met during expected plant response - There may be instances where an EAL threshold is briefly met during an expected plant response. In these cases, an emergency declaration is not warranted, provided that systems and components are operating as expected, and associated operator actions are appropriate. EAL threshold met but the condition clears or is corrected prior to emergency declaration - The key consideration is to determine if any plant damage occurred as a result of the transient event.

If plant damage is readily apparent, or if further assessment is necessary to confirm or rule out such damage, then the EAL threshold should be considered met and the appropriate emergency declaration made. Terminate the emergency if the assessment determines that there was no plant damage from the event and when other termination criteria are met.
If no plant damage is readily apparent and no further damage assessment is warranted, no emergency declaration is required; however, the event should be reported to the NRC per 10 CFR 50.72 within one hour, aQd notification of the state and local emergency response organizations should be made in accordance with the arrangements made between the site and offsite organizations.

EAL threshold met but classification was not made at the time of the event. - This situation occurs when personnel discover that a condition existed which met an EAL threshold but no emergency was declared and the condition no longer exists at the time of this discovery. This may be due to the emergency condition not being recognized at the time, or an error was made in the emergency classification process. In these cases, the guidance contained in NUREG-1022, section 3.1.1 is applicable. Specifically, the event should be reported to the NRC per 10 CFR 50.72 within one hour of the discovery of the undeclared event, and notification of the state and local emergency response organizations should be made in accordance with the arrangements made between the site and offsite organizations. D.2.7 Operating Mode Applicability The plant operating mode that existed at the time that the event occurred, prior to any protective system or operator action initiated in response to the condition, is compared to the mode applicability of the EALs. If an event occurs, and a lower or higher plant operating mode is reached before the emergency classification level can be declared, the emergency classification level shall be based on the mode that existed at the time the event occurred. E2-42

Enclosure 2 to NL-16-0169 SNC Standard Emergency Plan SECTION E: NOTIFICATION METHODS AND PROCEDURES E.1 Notification Methodology E.1.1 SNC, in cooperation with state and county authorities, has established methods 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. The primary notification method will be by a dedicated communications system. SNC-operated plants maintain the capability of notifying state and local agencies within 15 minutes of a declared emergency as required by 10CFR50 Appendix E, IV.D.3. The methods and forms used for notifying state and county authorities are site-specific, and detailed in plant specific Emergency Plan Implementing Procedures (EPIPs). NRC will be notified by the impacted site immediately following state and local notifications, but within an hour of an emergency classification using ENS. When multiple units of a multi-unit site are affected by an emergency, the classification shall be reported as applicable to all affected units. In situations where multiple units of a multi-unit site are affected by emergency events, but the events are not related and the classification for each unit is different, initial notification will be made for the highest classification. Additional classification information is provided in accordance with Section E.2.2.3. An accelerated call to the NRC Headquarters Operations Officer will be made following discovery of an imminent threat or attack against a plant. During a plant transient or an imminent threat situation requiring physical security response, plant personnel are primarily responsible for stabilizing the plant and keeping it safe. An accelerated notification will not interfere with plant or personnel safety or physical security response. The accelerated notification will be completed after or concurrent with notification of local law enforcement agencies. The goal will be to initiate the notification within 15 minutes of discovery of an imminent threat or attack against a plant. The information provided in the accelerated notification will be limited to the following:

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

E.2 Notification of Personnel E.2.1 Notification of Onsite Personnel The Emergency Director is responsible for classifying an event into the appropriate emergency classification and then notifying on-site personnel of the emergency declaration in accordance with procedures. This notification may consist of the use of E2-43 to NL-16-0169 SNC Standard Emergency Plan the plant emergency alarm, announcements over the plant public address system, or activation of the recall system. Emergency Response personnel respond to their assigned Emergency Response Facilities upon notification of an Alert or higher classification level. In the event of a Design Basis Threat, personnel may be directed to respond to alternative facilities. Notification of persons who are in the public access areas, on or passing through the site, or within the controlled area, will be performed by the Security Department. Such notifications will be in accordance with the Emergency Plan Implementing Procedures (EPIPs). Visitors within the protected area are escorted by a permanently badged individual. This individual is responsible for informing the visitors of emergencies when they occur and for taking action to evacuate the visitors from the site, as necessary. Notification procedures include notification of Emergency Response Organization Personnel (ERO) not on site or during backshift hours. ERO members will be notified by means of an automated callout system activated by on-shift personnel. E.2.2 Notification of State and local Authorities A dedicated ENN will normally be used to accomplish state and local notifications. Backup means of communication are described in Section F, Emergency Communications, of this plan. E.2.2.1 State and Local Agencies State and local agencies listed in the site specific Annexes shall be notified within fifteen (15) minutes of:

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

E.2.2.2 Initial Notification Message Form In conjunction with state and county authorities, SNC-operated plants have established the contents of the initial state notification message forms to be used during an emergency. These forms are described in EPIPs. The content of the forms has been reviewed and agreed on by the respective Offsite Response Organizations. E.2.2.3 Follow-up Emergency Message In conjunction with state and county authorities, SNC-operated plants have established the contents of the subsequent state notification message forms to be used during an emergency. The Emergency Director is responsible for the completion of a follow-up emergency message. The appropriate ERO personnel will ensure the emergency communicator(s) periodically provide follow-up messages to the appropriate offsite federal, state, and local authorities. E2-44 to NL-16-0169 SNC Standard Emergency Plan E.2.3 Notification of the Nuclear Regulatory Commission (NRC) The NRC is notified via the ENS. If the ENS is inoperative, the required notification will be made using alternate means in accordance with regulatory requirements. The Emergency Response Data System (ERDS), will be initiated within one hour of the declaration of an Alert or higher classification. Specific information on the notifications to the NRC for emergency events is detailed in the reporting requirements of 10 CFR 50. 72. E.2.4 Notification of Other Federal Agencies Notification of other Federal Agencies will be made in accordance with site specific Procedures. E.2.5 Notification of the Public 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. An overview of these means excluding the Savannah River Site is listed in the site specific Annex of this Plan. Initial notification of the public will occur in a manner consistent with assuring the public health and safety. The design objective for the system is to meet the acceptance criteria provided in a subsequent section of the FEMA approved design report for each SNC-operated plant. The design objective does not constitute a guarantee that prompt notification can be provided for everyone with 100 percent assurance, or that the system when tested under actual field conditions will meet the design objectives. In the event of an emergency, the Emergency Director is responsible for notifying appropriate state and local response organizations, plant emergency response organization, and plant personnel. E.2.5 .1 Concept of Operations In the event of a serious emergency at any SNC site, the primary means for alerting the public will be by the FEMA approved Alert and Notification System (ANS) referenced in the site specific Annex. Each site has a FEMA approved backup notification system in the event of a loss of the primary alert and notification system. State and local plans maintain additional processes to alert the public using emergency vehicles, automated dialing systems, public address systems, etc. Details of the backup methods can be found in the site specific Annex. The capability exists to promptly alert and notify the general public within the Plume Exposure Pathway. The Alert and Notification Systems (ANS) for each station includes an acoustic alerting signal from sirens and notification of the public by the Emergency Alert System (EAS). Station specific information regarding the ANS is contained in each station's ANS Design Certification Package. E2-45 to NL-16-0169 SNC Standard Emergency Plan The acoustical siren system design meets FEMA standards and requirements and has been approved to alert populations of an event. Each county controls the activation of the sirens within its boundaries (except for Henry County which relies on Houston County to activate their sirens). Activation of the ANS sirens by the local authorities will alert the public to turn to a local EAS station for detailed information on the emergency situation. The siren system is tested in accordance with the station's FEMA approved ANS design certification package. SNC provides for the repair and preventive maintenance of the EPZ sirens. Procedure instructions have been developed to respond to any spurious activation of the ANS sirens. Detailed information and instructions will be provided on local EAS radio and television stations. Commercial radio stations and television stations whose broadcasts are received in the plume exposure pathway EPZs have agreed to broadcast emergency instructions and information in cooperation with offsite officials. These continuing instructions will provide more specific or detailed information of any protective actions advised for affected areas. Information on the nature of the accident, on any releases, and on the progress in ameliorating or terminating the emergency event, will also be provided periodically on the commercial stations, along with a prognosis for escalation or termination of the event. E.2.5.2 Criteria for Acceptance

1. Within the plume exposure pathway EPZ, the prompt alerting and notification system will provide an alerting signal and notification by fixed sirens; further notification will be provided by local commercial radio and television stations activated by EAS.

2. The minimum acceptable design objectives for coverage by the system are:

a) Capability for both an alerting signal and an informational or instructional message to the population on an area-wide basis throughout the plume exposure pathway EPZ, within 15 minutes. b) The initial notification system will assure direct coverage of essentially 100 percent of the population within five miles of the site. These design objectives have been met by FEMA approved ANS Design report referenced in the site specific Annex.

3. Local and state agencies have the capability to provide information promptly over local commercial radio and television at the time of the activation of the alerting signal. Authority for activation of the EAS, which permits designated governmental officials to issue emergency information and instruction in threatened or actual emergencies, is given by 47CFR part 11, EAS Rules.

Information will be distributed on an annual basis to residents and businesses within the EPZ. E2-46 to NL-16-0169

SNC Standard Emergency Plan The testing and maintenance of the public alerting sirens are the responsibility of SNC. The maintenance program will consist of both periodic routine checks and, as required, corrective maintenance.

The periodic routine maintenance and test program will be based on the manufacturers' recommendations and experience gained with the installation. Annually, the system will be activated in the normal mode. Advance notice of the test will be provided to the public. Activation of sirens will be verified by the system. Reports of siren failures will be investigated and repaired by the respective SNC site. Unsatisfactory conditions detected by any means will be promptly repaired. State and local emergency management Plans and procedures detail the Prompt Notification System (PNS) activation process in addition to the information provided in the Emergency Plan. Activation of the alert and notification system (ANS) is discussed in the offsite agencies' specific emergency response plans. E2-47 to NL-16-0169 SNC Standard Emergency Plan E.2.6 Public Protective Action Messages State and local authorities have developed procedures and messages to be provided to the public in the event of an emergency at an SNC-operated nuclear power plant. Details of these procedures and messages are in the appropriate state and local emergency plans. E.2. 7 Verification of Notification Messages The SNC emergency notification form is transmitted electronically to the responsible state and local agencies using a secure data sharing system provided by SNC. Once transmitted to the OROs, the receipt of this information is confirmed using a dedicated communications link. In the event an agency is unable to obtain the emergency notification form electronically, the affected agency will be contacted using a dedicated communication link and the content of the form will be communicated verbally to the agency. As these systems are dedicated systems, no additional verification of the authenticity of the message is required for verification of messages with state and local agencies in the states of Alabama and Georgia. Communications with agencies in the state of South Carolina will be authenticated using the authentication system provided by the South Carolina Emergency Management Division. In the unlikely event both the electronic notification transmittal capability and dedicated communications links are lost then the emergency notification form will be communicated verbally using commercial telephone lines, and the receiving agency may verify authenticity of the message by calling the licensee back. E2-48

Enclosure 2 to NL-16-0169 SNC Standard Emergency Plan SECTION F: EMERGENCY COMMUNICATIONS F.l Communications F.1.1 At SNC-operated nuclear power plants, several modes ofreliable communication are available, during both normal and emergency conditions, to transmit and receive information among the Control Room, TSC, OSC, EOF, and other locations onsite and offsite including the Joint Information Center near the SNC site. Reliable primary and backup means of communication have been established. The use of the communications systems during normal and emergency conditions has been integrated into plans, procedures, and the training program. F .1.2 SN C-operated plants maintain the capability to make initial notifications to the designated offsite agencies 24 hours per day. Offsite notifications can be made to state and county warning points and Emergency Operations Centers from the Control Room and Emergency Operations Facility using the ENN. Reliable backup methods have been written into procedures. State and county warning points are continuously staffed. 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. F.1.4 SNC has established communications systems to provide reliable communications with federal emergency response organizations. Communications with federal agencies is primarily by commercial telephone, with alternate systems being utilized as needed. Communication with the Nuclear Regulatory Commission (NRC) is on the Federal Telecommunications System (FTS) telephone network, which connects the SNC plant site and EOF with the NRC Operations Center. Site extensions are located in the Control Room, TSC, and Site NRC Resident Inspector's Office. Site extensions include ENS, HPN, ERDS, and other designated counterpart links connecting to the NRC Operations Center. Commercial telephone lines serve as the backup to the ENS and other FTS lines. F.1.4.1 NRC Emergency Notification System (ENS) This communications line provides a communications link to the NRC Operations Center in Rockville, Maryland, and is used for continuous communications in a classified emergency. F.1.4.2 NRC Health Physics Network (HPN) This communications line provides a communications link with the NRC to provide radiological information. E2-49 to NL-16-0169 SNC Standard Emergency Plan F.1.4.3 NRC Reactor Safety Counterpart Link (RSCL) This communications line provides a communications link for the NRC to conduct internal NRC discussions on plant equipment conditions separate from the licensee. F.1.4.4 Protective Measures Counterpart Link (PMCL) This communications line provides a communications link for the NRC to conduct internal NRC discussions on radiological releases, meteorological conditions, and the need for protective actions. F.1.4.5 Management Counterpart Link (MCPL) (Executive Bridge Line) This communications line provides a communications link for any NRC internal discussions between the NRC Executive Team Director or Executive Team members and the NRC response team leader or top-level licensee management at the site. F.1.4.6 Security Bridge Line This communications line provides a communications link with the NRC to provide security-related information by the site team with access to the NRC Headquarters Operations Center LAN F.1.4.7 Southern Company Network Access This communications line provides the NRC site team with access to the NRC Operations Center's LAN. LAN connections are provided on the Sm.~thern Company network.

F.1.4.8 Emergency Response Data System (ERDS)

ERDS is a dedicated network and is a direct near real-time electronic data link between the plant's on-site computer system and the NRC Operations Center. It provides for the automated transmission of a limited data set of selected parameters. F.1.5 SNC-operated nuclear power plants have reliable communications between the plants and the EOF, state and local emergency operations centers, and radiological monitoring teams, as detailed above. F.1.6 SNC-operated nuclear power plants use an automated ERO Notification System to rapidly notify members of the ERO. The system is designed with redundant power, and with geographic separation. E2-50 to NL-16-0169 SNC Standard Emergency Plan SNC Emergency Communications Matrix On Site State Counties ro ro a Q) s-. u u .s 0 <i:: 0 0 0s-. 0 µ.:j

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Q) E-< 0 µ.:j <i:: 0 r:ri µ.:j t:O t:O µ.:j ::r:: ::r:: ......, E-< E-< SNC Phone System x x x x x x x x x x x x x x x x x x x x Commercial Phones x x x x x x x x x x x x x x x x x x x x Sound Powered Phones x Emergency Notification x x x x x x x x x x x x x x x x Network (ENN) Radios x x x x Public Address (PA) x x x x NRC Line Access x x x Emergency Response Data x x x System (ERDS) Table 5 E2-51 to NL-16-0169 SNC Standard Emergency Plan F.2 Medical Emergency Communications Communications have been established between the primary and backup medical hospitals and transportation services with SNC-operated plants. F.3 Communications Tests Communications tests will be conducted on the frequency specified below. Each of these tests includes provisions to ensure participants in the test are able to understand the content of the messages in the test.

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

F.4 Validation of Phone Numbers A quarterly check of telephone numbers required to implement the SNC Emergency Plan will be performed and documented. E2-52

Enclosure 2 to NL-16-0169 SNC Standard Emergency Plan SECTION G: PUBLIC EDUCATION AND INFORMATION G.l Purpose Southern Nuclear Company (SNC) will provide education and emergency information to the public consisting of the following:

The release of information to the public through the dissemination of timely, accurate emergency communications.
The orderly flow of emergency information during the recovery period.
Providing public education and information for the distribution of emergency preparedness materials to residents and transient populations.

SNC uses a number of ways to communicate the information to the EPZ population. These means are developed in coordination with respective offsite agencies. Any proposed change in the method of dissemination of emergency information to the public must be coordinated and discussed with, and agreed upon by appropriate State and local offsite emergency officials prior to implementation of the change. G.2 News Media Training A program will be offered each calendar year to acquaint the news media with the methodology for obtaining information during an emergency and with overall emergency preparedness at APC/GPC nuclear plants, as appropriate. Training will include information about the plant, emergency response, and the role of the JIC, as well as opportunities to participate in drill activities. G.3 News Releases The Utility will issue news releases covering events, conditions, and actions at the Plant. News releases are designed to be a written confirmation of events and are public information. 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. G.4 Press Briefings Press briefings will be conducted to keep the media informed of events and activities relating to the emergency. Briefings will provide the most current, up-to-date information about events and response to the incident. Public Information Officers (PIOs) from offsite agencies responding to the emergency will be encouraged to participate in the briefings to discuss their particular activities. G.5 Public Response Appropriate information will be released as clearly, concisely, and quickly as possible. Public announcements will be made on a frequent and regular basis. G.6 Resource Materials Media guides are available on the Utility websites and are accessible from the CMC and JIC. These guides are updated regularly and are available to news media. An emergency web page will be activated and will replace the normal web page on the appropriate Utility's website at the PID's discretion. E2-53

Enclosure 2 to NL-16-0169 SNC Standard Emergency Plan Maps, photographs, and diagrams of the plant and its operations are stored and maintained at the JIC for use during news briefings G.7 Public Information Plan For Recovery The lead emergency communications representative in the Recovery Organization will be the Public Information Director. This person or designee will maintain close contact with the Recovery Manager. Emergency communications response will follow the guidelines and procedures described for accident response. As conditions and public interest warrant, additional Public Information personnel will be assigned to support the flow of information concerning recovery operations. Information for possible release will be cleared with the Recovery Manager and the Public Information Director and given to the media through established procedures. Information will be released through established channels of communication to federal and state authorities, the utility industry, the public, and employees. Advance notice will be given to the public through the media, of any Company action that will or may affect the health and safety of the plume exposure pathway EPZ residents. Information of this type will be followed up with a news release as soon as the results of any such action are known. G.8 Public Information and Education Program The goal of the public information program is to acquaint the general public with the emergency plans for the operation of 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 in the plume exposure pathway Emergency Planning Zone. E2-54

Enclosure 2 to NL-16-0169 SNC Standard Emergency Plan SECTION H: EMERGENCY FACILITIES AND EQUIPMENT H.1 Onsite Emergency Response Facilities SNC-operated nuclear power plants have established a TSC and an onsite OSC, which are staffed and activated within 75 minutes of the declaration of an Alert or higher classification. Emergency Response Facilities may be activated at an Unusual Event at the discretion of the Emergency Director. Until the TSC and OSC are activated, required functions of these facilities are performed in the Control Room. H.1.1 Control Room

           . The Control Room is the centralized onsite location from which the plant's reactors and major plant systems are operated. The Control Room is equipped with instrumentation to supply detailed information on the reactors and major plant systems. The Control Room is continuously staffed with qualified, licensed operators, and is the first onsite facility to respond to emergency events. Control Room personnel evaluate and effect control over emergencies until support centers can be activated. As other Emergency Response Facilities (ERFs) become activated, they will support the Control Room, and overall Command and Control of the emergency will transfer to the TSC. Offsite Agency Notification and Protective Action Recommendation determination will transfer to the EOF. Control Room activities may include:

Reactor and plant control.
Initial direction of plant related operations.
Accident recognition, classification, mitigation and initial corrective actions.
Alerting of onsite personnel.
Notification of appropriate individuals.
Activation of emergency response facilities and ERO notification.
Notification of offsite agencies.
Notification and update of the NRC via ENS.
Continuous evaluation of the magnitude and potential consequences of any incident.
Recommendations for immediate protective actions for the public.
Activation of the Emergency Response Data System (ERDS).

H.1.2 Technical Support Center (TSC) SNC-operated nuclear power plants have established a TSC for use during emergency* situations by plant management, technical, and engineering support personnel. The TSC is procedurally required to be activated within 75 minutes following the declaration of an Alert or higher classification. Activation for Unusual Events or unclassified incidents is optional. When activated, TSC functions include:

Support for the Control Room's emergency response efforts.
Performance of response management functions when in Command & Control.
Continued evaluation of event classification.
Assessment of the plant status and potential offsite impact.

E2-55 to NL-16-0169 SNC Standard Emergency Plan

Coordination of emergency response actions.
Notification of appropriate corporate and plant management.
Notification and update of the NRC via the ENS.
Notification and update of the NRC via Health Physics Network (HPN).

The TSC is the on-site location used to support the Control Room for assessment of plant status and for implementation of emergency actions. TSC personnel provide technical data and information to the EOF. Each TSC provides reliable voice and electronic communications to the Control Room, the OSC, the EOF, the NRC, and state Emergency Operations Centers. The TSC is sized to accommodate ERO responders and NRC Representatives. State and county personnel are not expected to report to.the TSC. Personnel in the TSC are protected from radiological hazards, including direct radiation and airborne contaminants under accident conditions, with similar radiological habitability standards as Control Room personnel. To ensure adequate radiological protection, radiation monitoring equipment has been installed in the TSC, or periodic radiation surveys are conducted. These systems indicate radiation dose rates while in use. In addition, potassium iodide (KI) is available for use. The TSC has access to a controlled set of drawings and other records, including general arrangement diagrams, piping and instrumentation diagrams (P&IDs), and electrical schematics. The TSC has the capability to display vital plant data, in real time, to be used by knowledgeable individuals responsible for engineering and management support of reactor operations, and for implementation of emergency procedures. Details of the TSC configuration and location are in the site specific Annexes. H.1.3 Operations Support Center (OSC) The OSC has been established to provide an area for coordinating and planning activities and staging personnel and equipment. The OSC responders include groups such as Instrument and Control Technicians, Mechanics, Electricians, Nuclear Chemistry and RP Technicians, Operations personnel, and oncoming shift personnel. Additional space is available to accommodate personnel as required. If the OSC is deemed uninhabitable, the OSC may be moved to other locations as deemed appropriate by the OSC Manager. Emergency supplies are maintained in the OSC. When an emergency condition exists at one SNC-operated nuclear power plant, additional supplies can be obtained from other unaffected plants and SNC resources upon request. Details of the OSC configuration and location are in the site specific Annexes. H.1.4 Alternative Facilities An Alternative Facility for staging of ERO personnel has been designated at the sites. In the event of a Security or Hostile Action threat or event, the designated Alternative Facility may also serve as an evacuation location for TSC and OSC personnel. The Alternative Facility is designed to be accessible in the event of an onsite HAB event and has the capability to:

Communicate with the Control Room, Security, and the EOF.

E2-56

Enclosure 2 to NL-16-0169 SNC Standard Emergency Plan

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

The functions of Notification and PARs will be performed from the EOF should the Alternative Facility be activated. Details of Alternative Facilities can be found in the Site Specific Annex. H.2 Offsite Emergency Facilities H.2.1 Emergency Operations Facility The EOF is the central location for management of the offsite emergency response, coordination of radiological assessment, and management of initial recovery operations. The EOF is a dedicated facility located in Birmingham, Alabama, and serves as the EOF for SNC sites (VEGP, FNP, and HNP). The EOF is procedurally required to be activated within 75 minutes following the declaration of an Alert or higher classification. The EOF provides for:

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

The EOF is capable of accommodating 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. Based on the physical location of the EOF, specialized ventilation systems are not required. The EOF ventilation system is consistent in design with standard building codes. Similarly, EOF functions would not be interrupted by radiation releases from any SNC site. Normal power to the EOF is from a reliable offsite source. Emergency lighting is provided by battery-operated lights. Backup power for the EOF is supplied by onsite diesel generation. Essential equipment is backed up by the diesel generation sy~tem. The EOF is located at SNC Corporate Headquarters. The following records or information are available:

Technical Specifications.
Selected plant operating procedures.
Emergency Plans.
Emergency Plan Implementing Procedures.
Final Safety Analysis Reports (FSARs).

E2-57 to NL-16-0169 SNC Standard Emergency Plan

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

The above records are updated as necessary to ensure currency and completeness. Access to the EOF is controlled through the use of electronic card readers. SNC will maintain space for members of an NRC Site Team and federal, state and local responders at a location near the site that includes space for conducting briefings with emergency response personnel and communications with other licensee and offsite emergenc~ responders. Details on the near site location are in the site-specific Annexes. E2-58 to NL-16-0169 SNC Standard Emergency Plan i:ll MCL Lakeside NRG IO!lRSCL Patio tiiHPNO IO!lPMCL 0 0 RAD Oil ENS 0 STATUS D0 0 1~

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Entrance Oo~~~~~~ To Atrium FFD Facility Loading D Dock D D D Video Conference 0 Break & Copier Elevator D Room Room Lobby D D D To Document Services Exit Figure H.2.A - Emergency Operations Facility Layout (Typical) E2-59

Enclosure 2 to NL-16-0169 SNC Standard Emergency Plan H.2.2 Corporate Media Center (CMC) Upon notification of an Alert or higher classification, the Public Information Director and corporate staff assigned to JIC functions will assemble at the CMC. The CMC, located at the Atlanta/Birmingham corporate headquarters building of Georgia Power Company/Alabama Power Company, as appropriate, is the official location for coordination of emergency communications response until the site specific JIC has been activated. The Public Information Director will coordinate with the EOF Emergency Director and affected OROs and determine whether to activate the site specific JIC. When the decision is made to activate the JIC the CMC will maintain emergency communications response coordination until the site specific JIC is ready to assume these responsibilities. Once overall responsibility for emergency communications response transfers to the site specific JIC the remaining CMC staff will provide support for the JIC as needed. H.2.3 Joint Information Center (JIC) After the initial notification of an emergency at 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 CMC to the site specific JIC. Once the JIC is staffed the Public Information Director will manage the emergency communications response from the JIC in coordination with ORO public information officers (PIOs). Site specific JIC is provided in the site specific Annexes. H.3 State and local Emergency Operations Centers (EOC) EOCs operated by the state and by local communities allow direction and control of emergency response functions. The states' 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. H.4 Emergency Response Facility Staffing and Activation SNC-operated nuclear power plants have plans and procedures to ensure timely activation of its emergency response facilities. The Shift Manager, as Emergency Director, will initiate a call-out in accordance with the implementing procedures. The ERO augmentation process identifies individuals who are capable of fulfilling the specific response functions listed in Tables 2 through 5. Although the response time will vary due to factors such as weather and traffic conditions, a goal of 75 minutes for minimum staffing, following the declaration of an Alert or higher emergency classification, has been established for ERO personnel responding to plant emergency facilities including the TSC, OSC and EOF. The facility can be declared activated when the following conditions are met: E2-60

Enclosure 2 to NL-16-0169 SNC Standard Emergency Plan

Minimum staffing has been achieved.
Personnel have been briefed on the situation and are ready to assume Command and Control functions.

H.5

Onsite-Monitoring SNC-operated nuclear power plants have installed monitoring instrumentation for seismic monitoring, radiation monitoring, fire protection and meteorological monitoring, in accordance with its Final Safety Analysis Report (FSAR) and plant Technical Specifications (TS), or commitments made to the NRC. Details of these systems differ from plant to plant, and are in th~ site specific Annexes.

H.5.1 Geophysical Monitors

Meteorological Instrumentation: A permanent meteorological monitoring station is located near the plant for the acquisition and recording of wind speed, wind direction, and ambient and differential temperatures for use in making offsite dose projections. Meteorological information is displayed in the CR, TSC, and EOF.

Additional information located in Section H.7.

Seismic Monitoring: The seismic monitoring system measures and records the acceleration of the structure if activated by an earthquake of sufficient magnitude.

It also provides signals for immediate remote indication that specific preset response accelerations have been exceeded.

Hydrological Monitors: SNC-operated nuclear power plants have hydrological monitors as appropriate. The design basis flood, probable maximum precipitation, and other extremes in hydrologic natural phenomena are as detailed in the FSAR as appropriate.

H.5.2 Radiological Monitors and Sampling H.5.2.1 Radiation Monitoring System (RMS) Radiation monitoring instruments are located at selected areas within the plant to detect, measure, and record radiation levels. The monitors are comprised of area, airborne and air particulate monitors.

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

Emergency response procedures provide methods for determining relationships between monitor readings and releases, material available for release and extent of core damage. H.5.2.2 Liquid and Gaseous Sampling Systems The process sampling system consists of the normal sampling system and additional sampling panels located throughout the plant. Pre-designated monitoring and sampling points are listed in site procedures. Sampling systems are installed or can be modified to permit reactor coolant and containment atmosphere sampling even under severe accident conditions. E2-61 to NL-16-0169 SNC Standard Emergency Plan The system can provide information on post-accident plant conditions to allow operator actions to mitigate and control the course of an accident. Various chemical analyses and radiological measurements on these samples can be performed, including the determination of radionuclide concentrations. H.5.2.3 Laboratory Facility SNC sites have a laboratory facility for analysis of radioactive samples. H.5.2.4 Portable Radiation Monitoring Equipment Portable radiation survey instruments are available for a wide variety of uses such as area, sample, personnel surveys, and continued accident assessment. H.5.3 Process Monitors The Control Room and redundant backup locations are equipped with extensive plant process monitors for use in both normal and emergency conditions. These indications include reactor coolant system pressure and temperatures, containment pressure and temperature, and various liquid levels, flow rates, status, or lineup of equipment components. H.5.3.1 Plant Monitoring/Information System A plant monitoring/information system provides the data acquisition and database capability for performing plant monitoring and functions. The system is designed to scan, convert to engineering units, make sensor range and alarm limit checks, apply required transformations, store for recall and analysis, and display the reading of transformed data from plant instrumentation. The system scans flows, pressures, temperatures, fluid levels, radiation levels, equipment, and valve status at required frequencies. H.5.3.2 Safety Parameter Display System (SPDS) The SPDS parameters are available during normal and abnormal operating conditions in the Control Room, TSC, and EOF. H.5.4 Fire Detection System The Fire Detection System is designed to detect products of combustion or heat in designated areas of the plant. The fire alarm communication systems and subsystems are located at strategic points throughout the plant to warn personnel of a fire or other emergency conditions. Additional description of the fire system is provided in the FSAR. H.5.5 Fire Station Firefighting equipment and supplies are available for damage control operations. The equipment is stored in various areas within the plant. E2-62

Enclosure 2 to NL-16-0169 SNC Standard Emergency Plan H.6 Offsite Monitoring SNC-operated nuclear power plants have made provisions to access data from the following offsite sources of monitoring and analysis equipment: H.6.1 Geophysical Monitors:

In the event that the onsite meteorological tower or monitoring instrumentation becomes inoperative, meteorological data may be obtained directly from the National Weather Service.
A central point of contact to obtain information about a seismic event is the National Earthquake Information Center.

H.6.2 Radiological Environmental Monitors, Sampling, and Monitoring Equipment SNC-operated nuclear power plants maintain a sufficient supply of portable offsite radiological monitoring equipment. These supplies are located at each staging point for Field Monitoring Teams. SNC-operated nuclear power plants have a Radiological Environmental Monitoring Program (REMP) consisting of locations with dose recording devices and air sampling equipment. H.6.3 Laboratory Facilities External facilities for counting and analyzing samples, and for dosimetry processing, can be provided by other SNC-operated plants including the GPC Central Laboratory, state, federal, or contracted laboratories. Outside analytical assistance may be requested from state and federal agencies, or through contracted vendors. The DOE, through the Radiological Assistance Program (RAP) has access to any national laboratory. H.7 Meteorological Equipment SNC-operated nuclear power plants have meteorological towers equipped with instrumentation for continuous reading of wind speed, wind direction, air temperature and differential air temperature. Meteorological tower details are in the site-specific Annexes. Additional capabilities are available to obtain representative current meteorological information from other sources, such as the National Weather Service. H.8 Emergency Equipment Inventories and Checks Emergency facilities and equipment are inspected and inventoried using appropriate administrative or department procedures. These inventories will include requirements that provisions are in place to inspect, inventory, and operationally check emergency equipment/instruments at least once each calendar quarter and as needed. These procedures provide information on location and availability of emergency equipment and supplies. Sufficient reserves of instruments and equipment are maintained to replace those removed from emergency kits or lockers for calibration or repair. E2-63

Enclosure 2 to NL-16-0169 SNC Standard Emergency Plan H.9 Emergency Kits Emergency kits are available at SNC-operated nuclear power plants. Designated site or department procedures identify the equipment in the various emergency kits. Details as to kit locations are found in the plant-specific procedures. H.10 Collection Point for Field Samples SNC-operated nuclear power plants have designated a point as the location for receipt and analysis of field monitoring team environmental samples. Sampling and analysis equipment is available for quantitative activity determination of marine and air samples, and qualitative activity determination of terrestrial samples. E2-64

Enclosure 2 to NL-16-0169 SNC Standard Emergency Plari SECTION I: ACCIDENT ASSESSMENT 11 Systems and Parameters Monitored SNC-operated nuclear power plants have a comprehensive set of plant system and effluent monitors, as required by the plants' Final Safety Analysis Report. Sites have identified values characteristic of off-normal values and accidents, and identified the plant parameter values that correspond to the example initiating conditions in the Nuclear Energy Institute (NED 99-01and07-01 Emergency Action Levels (EALs). These are described in Section D of this plan, and detailed in the site-specific Annexes. Plant system and effluent parameter values are used to determine accident severity and subsequent emergency classification. Environmental and meteorological events are also determining factors in emergency classification. An emergency condition can be the result of just one parameter or condition change, or the combination of several. The specific symptoms, parameter values or events for emergency classification levels are detailed in the plant's site-specific Annex. 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. Some of the key plant parameters monitored in the Control Room are assembled into a single display on the Safety Parameter Display System (SPDS). The SPDS monitors such parameters as reactor coolant system pressure, reactor or pressurizer water level, containment pressure, suppression pool water level and temperature, reactor power, safety system status, containment radiation level, and effluent monitor readings. The instrumentation and equipment capabilities available for emergency facilities are described in Section H. For Vogtle Unit 3 and Unit 4, the Safety Parameter Display System (SPDS) is integrated into the overall human interface design so that the SPDS parameters are available to Operators on workstation visual display units. Select plant parameters are available to state and local authorities on a secure network dedicated to data distribution among the various offsite emergency response facilities. 12 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. 13 Offsite 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. E2-65

Enclosure 2 to NL-16-0169 SNC Standard Emergency Plan 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. I.4 Effluent Monitor Readings and Exposures The offsite dose assessment program addresses the relationship between effluent monitor readings, onsite and offsite exposures, and contamination for various meteorological conditions. I.5 Meteorological Monitoring SNC-operated nuclear power plants have a meteorological monitoring system sufficient to acquire and evaluate meteorological information for accident assessment. This information can be accessed in the Control Room, TSC, and EOF, and is transmitted by the Emergency Response Data System (ERDS) for NRC and offsite authorities use. I.6 Unmonitored Release Dose projections can be made during a release through use of sample data in situations where effluent monitors are either off-scale, inoperative, or the release occurs by an unmonitored flow path. In the absence of effluent sample data, a computerized offsite dose projection can be performed by specifying the accident category as a default. I.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 in situations potentially involving 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 initial environmental surveys involve measurements to confirm or modify the dose projections based on plant parameters. Subsequent environmental monitoring efforts will E2-66

Enclosure 2 to NL-16-0169 SNC Standard Emergency Plan be aimed at further defining the offsite consequences, including instituting an expanded monitoring program to enable prompt assessments of any subsequent releases from the plant. I.8 Release Assessments SNC-operated nuclear power plants have instrumentation, procedures, and trained personnel with the expertise to make rapid assessments of the actual or potential magnitude and location of any radiological hazards through liquid or gaseous release pathways. I.9 Environmental Radioiodine Monitoring Capabilities Field monitoring equipment has the capability to detect and measure airborne radioiodine in the presence of noble gases that has the capability to detect and measure radioiodine concentrations in air in the plume exposure EPZ as low as 10-7 uCi/cc (microcuries per cubic centimeter) under field conditions. Interference from the presence of noble gas and background radiation shall not decrease the stated minimum detectable activity. E2-67

Enclosure 2 to NL-16-0169 SNC Standard Emergency Plan SECTION J: PROTECTIVE RESPONSE Protective response consists of emergency actions, taken during or after an emergency situation, which are intended to minimize or eliminate hazards to the health and safety of the public and plant personnel. Protective actions have been developed for emergency workers 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. , J .1 Alarm Responses The actuation of alarms associated with fire and radiation levels are available to alert personnel of hazardous conditions and protective actions. Site communications methods may also be used as needed. The site-specific procedures describe the assembly areas for personnel on-site. For emergency classifications, personnel within the Protected Area are notified of the classification or escalation of an emergency. Provisions are made to alert personnel in high noise areas and outbuildings within the Protected Area and within the Owner Controlled Area. The primary protective measure for non-essential onsite personnel during a Site Area or* General Emergency is assembly in a designated area, followed by accounting of site personnel and then determination ,of appropriate protective actions including Site Evacuation. The designated assembly areas are outside the Protected Area and inside the Owner Controlled Area~ J.2 Radiological Monitoring of Evacuated Personnel Personnel evacuated from the site will be monitored for' contamination, if needed by portal monitors as they exit the Protected Area, or with portable friskers in Assembly Areas, or sent to offsite monitoring locations. J.3 Non-essential Personnel Evacuation and Decontamination Requirements for radiological monitoring of personnel evacuated from the site for external radiation exposure are contained in Section K. Section K addresses appropriate actions for any known or suspected overexposures or contamination. Details on the decontamination of non-essential evacuees are in the Emergency Plan Implementing Procedures. J.4 Onsite 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. E2-68 to NL-16-0169 SNC Standard Emergency Plan Measures that 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.

SNC-operated nuclear power plants are responsible for maintaining a supply of KI at their respective site. The Emergency Director has the responsibility for approval of issuing KI to site emergency workers. Onsite protection of employees during hostile action involves a combination of restricted movement, movement to safe locations, and site evacuation depending on the nature of the hostile event and advance warning. Site-specific procedures provide specific actions to take during hostile action or severe weather events. During a hostile action or severe weather event, Assembly and Accountability actions may be delayed in favor of other onsite protective actions required to ensure the safety of the site and its personnel. In these cases, accountability will be completed once safe conditions have been established. 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 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. J .4.2 Accountability Personnel accountability is mandatory at the Site Area or General Emergency classification. Accountability may be initiated at other times at the discretion of the Emergency Director to support worker safety. Accountability of personnel within the Protected Area is accomplished within 30 minutes of the declaration of Site Area Emergency or higher, and maintained continuously thereafter, using Protected Area(s) boundary access control as described in the Security Plan. If there are station personnel who are unaccounted for, the public address system or other suitable communication methods are used to locate 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. E2-69

Enclosure 2 to N L-16-0169 SNC Standard Emergency Plan J.4.3 Site Evacuation If a Site Evacuation is required, personnel are directed to either assemble within designated Assembly Areas or immediately leave the site. Personnel will be directed to either proceed to their homes or reassemble at designated locations. Visitors to the plant will assemble with and follow the instructions of their escorts. Personal transportation will normally be used and established evacuation routes will be followed. Personnel without transportation will be identified and provided transportation as necessary. Evacuation of personnel is usually conducted immediately after accountability if a Site Area Emergency or General Emergency has been declared and no impediments exist. Evacuation shall commence as directed by the Emergency Director. J .5 Offsite Protective Action Recommendations (PARs) Plant conditions, projected dose and dose rates, field monitoring data, and evacuation time estimates are evaluated to develop PARs for preventing or minimizing exposure to the public. PARs are provided to the offsite agencies responsible for implementing protective actions for the public within the 10-mile EPZ. The Emergency Director will approve P ARs. The PAR decision-making flowcharts are site-specific in nature, and are provided in the site-specific implementing procedures. SNC-operated plants have the capability to provide state and local agencies a PAR for beyond the 10-mile EPZ. Plant conditions, projected dose and dose rates and field monitoring data are communicated to offsite agencies responsible for dose assessment/PARs to assist them in developing parallel assessments. There are various types of protective actions that can be recommended to the state and counties. They may include the following:

Evacuation.
Shelter in place.
Monitor and prepare.
Thyroid blocking agent (consider using KI (potassium iodide)) in accordance with state plans and policy.

J.6 Evacuation Time Estimates (ETE) An independent ETE report has been performed for SNC-operated nuclear power plants, which provides estimates of the time required to evacuate resident and transient populations surrounding the plant for various times of the year under favorable and adverse conditions. ETEs for evacuation of the plume exposure EPZ surrounding SNC-operated nuclear power plants are summarized in the site-specific Annex and detailed in the ETE report. J.7 Protective Action Maps SNC nuclear power plants have maps depicting local roads, primary evacuation travel routes, and the Emergency Planning Zone (EPZ). Maps are also available which show the population distribution within the plant EPZ, and are described in the site-specific Annexes. E2-70

Enclosure 2 to NL-16-0169 SNC Standard Emergency Plan SECTION K: RADIOLOGICAL EXPOSURE CONTROL K.1 Emergency Workers and Lifesaving Protective Actions SNC-operated nuclear power plant management will make every reasonable effort to minimize radiation exposure to emergency personnel. Plant management approval is required before emergency workers are allowed to exceed the maximum administrative radiation dose. 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 l~vels 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." In emergency situations, workers may receive exposure under a variety of circumstances in order to assure safety and protection of others and of valuable property. If emergency operations demand life-saving or rescue actions and external radiation fields are minimal, individuals may be allowed exposures to airborne contamination of 10,000 Derived Air Concentration (DAC)-hours. If external radiation fields are not minimal, the sum of the external and internal doses should be limited to 25 rem Total Effective Dose Equivalent (TEDE). Exposures above 2,000 DAC-hours should be received only with the approval of the Emergency Director. These exposures will be justified if the reduced risks and costs to others outweigh the risks to which the workers are subjected. , Table K.1.A Emergency Worker Dose Limits Dose (TEDE) Applicability Conditions 5rem All -- lOrem Protecting valuable property (or equipment) Lower dose ncit practicable 25rem Lifesaving or protection of large populations Lower dose not practicable

    >25 rem         Lifesaving or protection of large populations  Only on a voluntary basis to persons fully aware of the risks involved K.1.1 Removal of Injured Persons Injured persons will receive prompt first aid and decontamination, as practical, before transport by ambulance to a local hospital.

E2-71

Enclosure 2 to NL-16-0169 SNC Standard Emergency Plan K.1.1.1 Transportation Services Agreements have been made for ambulance services near the SNC-operated nuclear power plants. Training is offered to ambulance personnel, and they participate in drills or exercises simulating the transportation of a contaminated, injured individual. K.1.2 Decontamination and First Aid K.1.2.1 Onsite Responsive Action Selected plant workers at SNC-operated plants have received first aid and decontamination training. If a plant employee cannot be easily decontaminated, the individual is treated as contaminated and measures are taken to prevent the spread of contamination during ambulance transportation and upon arrival at a local hospital. K.1.3 Medical Treatment Agreements have been made with local hospitals near SNC-operated nuclear power plants. Training is offered to medical staffs regarding the treatment of contaminated, injured individuals, and hospitals participate in periodic drills using simulated contaminated, injured individuals. K.2 Emergency Exposure Authorization SNC-operated plants have a Radiation Protection Program. The Emergency Director may authorize emergency workers to receive doses in excess of the administrative dose levels. In some situations, it is possible that certain activities or duties for the protection of persons or the substantial protection of property may result in doses in excess of 10 CFR 20.1201 limits. Decisions to accept doses in excess of occupational limits will be on a volunteer basis and prospective volunteers shall be made aware of the risks. K.3 Exposure Controls K.3.1 24-Hour Capabilities Plant Radiological Protection Groups have the equipment and personnel to provide 24-hour capability to determine and control radiation exposures of emergency organization personnel. Equipment to perform the following functions:

Radiation detection devices.
Personnel monitoring.
Record keeping equipment.

Contractor and vendor representatives may also be present to assist in exposure control and augment the Radiation Protection Group capabilities. In an emergency situation, onsite personnel, offsite support personnel and local government - emergency response personnel may be issued monitoring devices. Exposure records will be maintained for emergency response personnel who are issued dosimetry. E2-72

Enclosure 2 to NL-16-0169 SNC Standard Emergency Plan K.3.2 Personnel Monitoring Equipment SNC-operated nuclear power plants have equipment for radiological monitoring of personnel, ranging from hand-held survey equipment to installed or portable portal monitors. Details of plant monitoring equipment are included in the site-specific Annexes. K.3.3 Radiation Work Permit Procedures Where possible, the normal radiation work permit procedure will be used to control exposures. Based on conditions and urgency Radiation Protection supervision may approve emergency radiological work permit controls. K.4 Offsite Emergency Workers The responsibility for authorizing offsite emergency workers to receive exposures in excess of the EPA General Public Protective Action Guides rests with the state. 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. K.6 Contamination Controls Contaminated areas.are isolated as restricted areas with appropriate radiological protection and access control. Measures will be taken to control onsite access to potentially contaminated potable water and food supplies. K.7 Offsite Decontamination Nonessential on-site 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. E2-73

Enclosure 2 to NL-16-0169 SNC Standard Emergency Plan SECTION L: MEDICAL AND PUBLIC HEALTH SUPPORT L.1 Hospital and Medical Services In addition to the on-site first aid response, arrangements have been made with local hospitals for treatment and evaluation of serious injuries or sicknesses. SNC-operated nuclear power plants have arranged for hospital and medical services having the capability to evaluate radiation exposure and uptake, including assurance that persons providing these services are adequately prepared to handle contaminated 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. L.2 First Aid SNC-operated nuclear power plants maintain onsite first aid supplies and equipment necessary for the treatment of contaminated and/or injured persons. L.3 State Emergency Medical Services The states of Alabama and Georgia have developed lists of facilities that can provide medical support for treating injured, contaminated individuals. Details are found in the respective state emergency plan. L.4 Medical Transport Contaminated and injured persons are transported to a facility specified for SNC-operated nuclear power plants. Arrangements have been made by nuclear power plants for ambulance transport of persons with injuries involving radioactivity to designated hospitals. Such services are available on a 24-hour-per-day basis and are confirmed by letters of agreement. Radiation monitoring services are provided by SNC plant personnel whenever it becomes necessary to. use an ambulance service for the transportation of contaminated persons. E2-74

Enclosure 2 to NL-16-0169 SNC Standard Emergency Plan SECTION M: RECOVERY AND REENTRY PLANNING AND POSTACCIDENT OPERATIONS 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 SNC Emergency Plan addresses general principles that serve as guides for developing a Recovery Plan. It is the responsibility of the Emergency Director (ED) to determine that the facility and surroundings are safe for reentry. The Emergency Director will designate a recovery manager to constitute the recovery organization. The following guidelines, as applicable to the specific situation, will be addressed prior to terminating the emergency:

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

Upon termination of the emergency phase and at the discretion of the Emergency Director, following consultation with offsite authorities, the SNC Emergency Organization will shift to the Recovery Phase Organization. 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 affe9ted 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.

E2-75 to NL-16-0169 SNC Standard Emergency Plan

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.

Other recovery operations will not be initiated until the area affected by the emergency has been defined. Particular attention will be directed toward isolating and tagging out components and systems as required for controlling or minimizing hazards. A systematic investigation will be conducted to determine the equipment damaged and the extent of the damage. Investigation into the accident causes and consequences, both to the plant and to the environment, will be conducted. Test programs to confirm fitness for return to service will be developed and executed. Recovery operations will be conducted in compliance with normal operational radiation exposure level limits as specified in 10 CFR 20. When possible, any necessary releases of radioactive materials or effluent during recovery will be planned, controlled, evaluated in advance for radiological impact, and appropriate offsite organizations and agencies informed of the scheduled releases and estimated impact. E2-76

Enclosure 2 to NL-16-0169 SNC Standard Emergency Plan M.2 Recovery Organization Figure M.2 Typ~cal Long Term Recovery Organization

                                                                                              *1 Corporate                                             :

Headquarters I I i L.;_ ~'---*-*-**-***:. *-*. ~....:,..~ _.,** "'. '.;;,._, __,_:. ~ I I Administration Public Recovery and Affairs Manager Logistics Planning and

                                                    -               Logistics I                                                                                  I            I Chemistry I Engineering                Operations                                                           Maintenance Radiation Protection M.2.1 Recovery Manager The nature and extent of the emergency situation will determine what recovery operations are required. The Recovery Organization, shown above, will be established as directed by the Recovery Manager.

M.2.2 Plant Actions Recovery actions will be preplanned. Specific actions will be developed in advance and discussed with responsible and knowledgeable personnel.

Reasonable efforts will be made to limit radiation exposure of personnel involved in the recovery to levels as low as reasonably achievable. Exposures should not exceed 10 CFR 20 limits. The Recovery Manager is responsible for evaluating the advisability and timing of authorizing personnel to reenter affected area( s). The Recovery Manager is responsible for gathering available evidence on contributory factors to the accident, and reviewing the recovery operations to ensure that causal factors have been specifically identified. The Recovery Manager will . provide a liaison for the NRC Accident Investigation Team, which will interview primary responders, review any documents generated during the accident, and inspect or test damaged equipment prior to its repair. E2-77

Enclosure 2 to NL-16-0169 SNC Standard Emergency Plan M.3 Recovery Notification Members of the ERO will be informed when Recovery is initiated. The recovery organization may be structured like the emergency response organization, with additional modifications depending on the nature of the accident, post-accident conditions, and other factors. The State BOC will be advised when the plant deems it safe to begin the reentry phase of the offsite recovery operation. If the Governor ordered an evacuation, the law requires the governor to officially rescind the order before any return can be made to evacuated areas. The states are responsible for coordinating reentry procedures for the offsite population. M.4 Population Exposure Estimates It is anticipated that the Federal Radiological Monitoring and Assessment Center (FRMAC) will make a total population exposure calculation, based on estimated dose rates and population representing exposed areas. M.5 Termination of Recovery Phase Following the completion of the Recovery Phase, the site.will transition to an Outage Organization to complete necessary repairs. E2-78

Enclosure 2 to NL-16-0169 SNC Standard Emergency Plan SECTION N: EXERCISES AND DRILLS N .1 Exercises SNC-operated nuclear power plants will c*onduct a biennial exercise and additional periodic drills. An exercise is an event that tests integrated capability, and a major portion of the basic elements of emergency preparedness plans and organizations. Drills and 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.

SNC-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. Joint exercises shall be conducted on a frequency described in NRC/FEMA guidance. Remedial exercises will be required if the emergency plan is not satisfactorily tested during the Biennial Exercise, and it is determined that reasonable assurance that adequate protective measures cannot be taken in the event of a radiological emergency or the ERO has not maintained key skills specific to emergency response. N.1.1 Biennial Exercises Federally prescribed Biennial Exercises are conducted at SNC-operated nuclear power plants. Exercises involving offsite agency participation, required under 10 CFR 50 Appendix E, are conducted at SNC-operated nuclear plants based on Federal Emergency Management Agency (FEMA) guidance and the respective state and local emergency response plans. N.1.2 Participation SNC-operated nuclear power plants exercise with offsite authorities to allow state(s) and local governments within the plume exposure pathway EPZ to exercise their emergency plans for operating nuclear power plants biennially, with full or partial participation. Full and partial participation exercises are described as follows:

Full participation exercises will include, as appropriate, offsite local and state authorities and SNC personnel actively participating in testing the integrated capability to assess and respond to an accident at a nuclear power plant.

Additionally, full participation exercises will include, as appropriate, testing the major observable portions of the onsite and offsite emergency plans and mobilization of state, local, and SNC personnel, and other resources in sufficient numbers to verify the capability to respond to the accident scenario.

Partial participation means offsite authorities shall take part in the exercise sufficient to test direction and control functions, including protective action decision-making and communication capabilities among affected state and local E2-79

Enclosure 2 to NL-16-0169 SNC Standard Emergency Plan authorities and SNC-operated plants. Where partial or full participation by offsite agencies occurs, the sequence of events simulates an emergency that results in the release of radioactivity to the offsite environs, sufficient in magnitude to warrant a response by offsite authorities. At a minimum, state and local governments are expected to fully participate in accordance with the requirements of IOCFR50 Appendix E, section IV(F)(2)(c). N.1.3 Ingestion Exposure Pathway Exercise States within an ingestion exposure pathway EPZ are expected to exercise plans and preparedness related to ingestion exposure pathway measures at least once every 8 years. N.1.4 Hostile Action Based (HAB) Exercises Hostile Action Based (HAB) exercises involving an air, land or water based attack scenario will be conducted at sites on a frequency of at least once every eight (8) years. N. l .5Exercise Planning Cycle The Exercise planning cycle will consist of eight (8) successive calendar years. N.2 Drills A drill in this context is a supervised instruction period aimed at testing, developing, and maintaining skills in a particular operation N.2.1 Off-Year Drills 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.

During these drills, activation of all of the licensee's emergency response facilities (TSC, OSC, and the EOF) would not be necessary. The ERO would have the opportunity to consider accident management strategies, supervised instruction would be permitted, opyrating staff in participating facilities would have the opportunity to resolve problems (success paths) rather than have controllers intervene, and the drills may focus on the onsite exercise training objectives. E2-80 to NL-16-0169 SNC Standard Emergency Plan 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. N .2.2 Fire Drills Fire drills will be conducted at nuclear plants in accordance with Plant Technical Specifications and Plant procedures. N.2.3 Medical Emergency Drills A medical emergency drill, involving a simulated contaminated individual, and containing provisions for participation by local support services organizations including ambulance response, are conducted annually at the nuclear plants. Local support service organizations that support more than one plant shall only be required to participate once each calendar year. N.2.4 Environs Drills Plant environs and radiological monitoring drills are conducted annually. These drills include collection and analysis of sample media and provisions for communications and record keeping. These drills also evaluate the response to, and analysis of, simulated airborne and direct radiation measurements in the environment. N.2.5 Radiation Protection Drills Radiation Protection Drills involving a response to, and analysis of, simulated airborne and liquid samples and direct radiation measurements are conducted semi-annually. At least annually, these drills shall include a demonstration of the sampling system capabilities, as applicable. N.2.6 Accountability Drills Accountability drills are conducted annually. N.2.7 Alternative Facility Drills At least once per drill cycle, use of designated Alternative Facilities to stage Onsite ERO Responders to facilitate rapid activation following a hostile action. N.2.8 Rapid Escalation At least one per drill cycle, a scenario resulting in an initial classification of, or rapid escalation to, a Site Area or General Emergency, will be conducted. N.2.9 Minimal/No Release Drill At least once per drill cycle, a scenario resulting in no radiological release, or an unplanned minimal release resulting in a classification of a Site Area Emergency but not requiring declaration of a General Emergency, shall be conducted. N.2.10 Multi-Site Drills At least once in every five years, a drill involving more than one SNC site will be conducted demonstrating the ability of the Common EOF to effectively implement the Emergency Plan for an event involving more than one site. E2-81

Enclosure 2 to NL-16-0169 SNC Standard Emergency Plan N.3 Scenarios When a major drill or exercise is required, the Emergency Preparedness (EP) group will coordinate the preparation of a scenario. The EP group will also coordinate efforts with appropriate federal, state and local emergency organizations and agencies, schedule a date to conduct the drill or exercise, and assign qualified controllers. The Emergency Preparedness group retains critique results for review prior to future drills or exercise and for guidance in properly modifying the site-specific Annexes, Emergency Plan Implementing Procedures (EPIPs), or other procedures as appropriate. A scenario, prepared in advance, will govern the conduct of exercises and drills. Scenarios will include the following:

Objectives of the drill or exercise; a measurable and observable objective must be specified for each major problem and solution.
Dates, time period, places, personnel, and participating organizations.
Simulated events.
Time schedule of real and simulated initiating events.
Narrative summary describing the conduct of the exercise or drill, including simulated casualties, offsite fire department assistance, rescue of personnel, use of protective clothing and associated equipment, deployment of personnel and radiological teams, and public information activities.

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. E2-82

Enclosure 2 to NL-16-0169 SNC Standard Emergency Plan N .4 Exercise Evaluation and Critique A formal critique will be performed for exercises, drills, and training tabletops to develop, maintain, or demonstrate key skills in order to identify weak or deficient areas that need correction. A critique shall be conducted at the conclusion of the exercise, to evaluate the organization's ability to respond as called for in the SNC Standard Emergency Plan. Qualified personnel will observe and perform a critique of exercises and drills. Provisions will be made for federal, state, and local observers, as well as SNC personnel, to observe and critique required exercises. Biennially, representatives from the NRC observe and evaluate the licensee's ability to conduct an adequate self-critical critique. For partial and full offsite participation exercises, the NRC and Federal Emergency Management Agency (FEMA), will observe, evaluate, and critique. Drill and exercise performance objectives will be evaluated against measurable demonstration criteria. As soon as possible following the conclusion of the drill or exercise, a critique is conducted to evaluate the ability of the Emergency Response Organization (ERO) to implement the emergency plan and procedures, and a formal evaluation will result from the critique. A written critique report is prepared by the Emergency Preparedness group following a drill or exercise involving the evaluation of designated objectives or following the final simulator set with ERO participation. The report will evaluate the ability of the ERO to respond to a simulated emergency situation. The report will also contain corrective actions and recommendations. N.5 Exercise/Drill Corrective Actions The critique and evaluation process is used to identify areas of the Emergency Preparedness Program that require improvement. The Emergency Preparedness group is responsible for evaluating recommendations and comments, determining which items will be incorporated into the program or require corrective actions, and for scheduling,. tracking, and evaluating item resolution. Whenever exercises or drills indicate deficiencies in the SNC Standard

    ~mergency Plan, site-specific Annexes, corresponding implementing procedures, or training lesson plans, such documents will be revised as necessary.

The results of exercise critiques, particularly comments on identified areas that require improvement or reevaluation, will be submitted to the Emergency Preparedness Supervisor or designee, for review. The Emergency Preparedness Supervisor or designee will consult with responsible department heads and assign corrective action activities, as appropriate. E2-83

Enclosure 2 to NL-16-0169 SNC Standard Emergency Plan SECTION 0: RADIOLOGICAL EMERGENCY RESPONSE TRAINING 0 .1 Training To achieve and maintain an acceptable level of emergency preparedness, training will be conducted for members of the Emergency Response Organization (ERO) and those offsite organizations that may be called on to provide assistance in the event of an emergency. Training will be evaluated in accordance with the requirements of Systematic Approach to Training practices to ensure effectiveness and in order to identify weak or deficient areas that need correction. The ERO Training Program ensures the training, qualification, and requalification of individuals who may be called on for assistance during an emergency. Specific emergency response task training, prepared for response positions, is described in lesson plans and study guides. The lesson plans, study guides, and written tests are contained in the ERO Training Program. Responsibilities for implementing the training program are contained in plant procedures. Offsite training is provided to support organizations that may be called on to provide assistance in the event of an emergency. Personnel from nuclear power plants annually offer to train those non-SNC organizations referenced in the Plant Annexes that may provide specialized services during a nuclear plant emergency. The training offered will acquaint the participants with the special problems potentially encountered during a nuclear plant emergency, notification procedures, an~ their expected roles. Organizations that must enter the site shall also receive site-specific emergency response training and be instructed as to the identity of those persons in the onsite organization who will control their support activities. Training of state and local offsite emergency response organizations is described in their respective radiological emergency plans, with support provided by SNC if requested. 0.1. l Training of Local Services Groups A training opportunity will be offered annually for offsite organizations and agencies as specified in respective agreements and understandings. In addition, those offsite organizations and agencies that may provide onsite emergency assistance will be encouraged to become familiar with the general layout of SNC plants, and will be invited to attend applica_?le Emergency Plan training and orientation courses. Annually, training will be offered for hospital personnel, ambulance and rescue personnel, police, and fire departments. The training shall include the procedures for notification, basic radiation protection, and their organizations' expected role. 0.2 Performance Demonstration In addition to general and specialized classroom training, members of the SNC ERO receive periodic performance-based emergency response training. Performance-based training is generally provided by participation in a performance drill or exercise. A drill is a supervised instruction period aimed at testing, developing, and maintaining skills in a particular operation. Drills described in Section N of this plan are a part of training. These drills allow individuals to demonstrate the ability to perform their assigned emergency E2-84

Enclosure 2 to NL-16-0169 SNC Standard Emergency Plan functions. During drills, on-the-spot correction of erroneous performance may be made and a demonstration of the proper performance offered by the Controller. 0.3 First Aid Training Individuals assigned.as First Aid responders shall maintain qualifications for first aid and Cardio-Pulmonary Resuscitation (CPR) training. 0.4 ERO Training SNC ERO personnel who are responsible for 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 to onsite emergency response positions will receive training specific to their position. 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.

0.4.2 Active Senior Licensed Control Room Personnel Active Senior Licensed Control Room Personnel shall have training to maintain proficiency on the topics listed below. These subjects shall be covered, as a minimum, on an annual basis:

Event Classification.
Protective Action Recommendations.
Radioactive Release Rate Determination.
Offsite dose assessment.
Notification form completion and communication.
Federal, state, and local notification procedures as appropriate.
Activating the onsite and offsite ERO.

0.4.3 Radiological Field Monitoring Teams E2-85

Enclosure 2 to NL-16-0169 SNC Standard Emergency Plan Radiological Field Monitoring Team personnel will receive classroom and hands-on training for the actions they will be expected to perform during an e,mergency. The following general topics will be included in the training:

Equipment and Equipment Checks.
Communications.
Plume Tracking Techniques.
Personnel monitoring.
Emergency exposure criteria.
Locations and use of radiological emergency equipment.

0.4.4 Fire Brigade Training Individuals assigned to Fire Brigade shall maintain fire brigade qualifications. 0.4.5 Operations, Maintenance, Chemistry and Radiation Protection Training Operations, Maintenance, Chemistry and Radiation Protection personnel who would be assigned to Repair and Damage Control Teams are trained as part of their normal job-specific duties to respond to both normal and abnormal plant operations. 0.4.6 Medical Support On-site medical personnel receive specialized training in the handling of contaminated victims and hospital interface. Offsite ambulance and hospital personnel are offered annual training as outlined in Section 0.1.1. 0.4.7 News Media Training Local news media personnel will be offered an annual training opportunity as described in Section G. 0.4.8 General Employee Training (GET) GET will include general training in emergency preparedness for plant and other site personnel. GET will include classification, individual response, signals, accountability, and site evacuation procedures. 0.5 Emergency Preparedness Staff Traini.ng Training for the Emergency Preparedness Staff at an SNC-operated plant consists of initial and continuing training process. Details can be found in site specific procedures and processes. E2-86

Enclosure 2 to NL-16-0169 SNC Standard Emergency Plan SECTION P: RESPONSIBILITY FOR THE PREPAREDNESS EFFORT The President/Chief Executive Officer (CEO) Southern Nuclear Operating Company (SNC) has direct responsibility for the operation and maintenance of the SNC Plants. The president/CEO is also responsible for all technical and administrative support activities provided by SNC. The president/CEO directs the chief nuclear officer/executive vice president, Executive Vice President-Operational Readiness and Integration, and the vice president of regulatory affairs in fulfillment of their responsibilities. Responsibility for the performance of Emergency Preparedness functions is assigned to various members of the SNC organization and coordinated as follows. P .1 Fleet Emergency Preparedness The Vice President - Regulatory Affairs is responsible for the overall coordination of the corporate emergency preparedness programs and Emergency Plans. Their direct report, the Fleet Emergency Preparedness Director, has governance and oversight responsibility for the SNC Fleet Emergency Preparedness functional area. The Fleet Emergency Preparedness Director is responsible for the oversight of Emergency Preparedness activities and coordinating those activities with Licensee, federal, state, and local response organizations. The Fleet Emergency Preparedness organization in the SNC Corporate office provides oversight and support for site and corporate functions. Reporting to the Fleet Emergency Preparedness Director are the EP Programs Manager and the EP Planning Manager. EP Programs Manager responsibilities include Regulations, Projects, Procedures and Performance Improvement. EP Planning Manager responsibilities include offsite interface, Drill and Exercise Coordination and Training. Strategic direction for the emergency preparedness program and maintenance of the SNC Emergency Plan(s) is provided by the 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. Emergency Plan changes are reviewed to determine if the effectiveness of the specific plans have been reduced, in accordance with the requirements of 10 CFR 50.54q. Changes that are judged to reduce the effectiveness of the Plan will be submitted to the NRC for approval prior to implementation. P.2 Site Emergency Preparedness The Vice President-(Site) is responsible for the site Emergency Preparedness aspects of the program at each site. The Emergency Preparedness Supervisor is responsible for coordinating onsite emergency preparedness activities and supports offsite emergency preparedness activities in the plant vicinity. The Emergency Preparedness Supervisor reports through the Regulatory Affairs Manager to the Vice President-(Site) for Plants Hatch, Farley and Vogtle 1-2. During project construction for Vogtle 3 and 4 Emergency Preparedness Supervisor reports to the Emergency Preparedness/Security Project Manager, who reports to the ~ite Integration Director. The Site Integration Director reports to the Executive Vice President - Operational Readiness and Integration. The Emergency E2-87

Enclosure 2 to NL-16-0169 SNC Standard Emergency Plan Preparedness Supervisor is responsible for the implementation of emergency planning strategies provided by the Fleet Emergency Preparedness Director. P.3 Coordination The Fleet Emergency Preparedness Director coordinates site input and involvement in emergency planning programs with the Emergency Preparedness Supervisor. The Emergency Preparedness Supervisor is responsible for the implementation of the Emergency Plan and program maintenance activities. Figure P.1 shows the EP organization. EPIPs and administrative procedures for the Emergency Preparedness function are maintained by the Fleet Emergency Preparedness Director with a designated EP staff member as the principal contact. Approved changes to the Emergency Plan are forwarded to key organizations and appropriate individuals who are responsible for implementing the Plan. The Emergency Plan, agreements, and the EPIPs are reviewed once per calendar year and updated as needed. These updates take into account changes identified by drills and exercises, and the independent review described below. An independent review of the EP program is conducted, as required by 10 CFR 50.54(t). The review includes the Emergency Plan, implementing procedures and practices, training, readiness testing, equipment, and interfaces with offsite agencies. The results of the review, along with recommendations for improvements, are documented and reported to plant management and to appropriate offsite agencies. Management controls are implemented for evaluation and correction of the review findings. Records of these audits and recommendations are maintained for at least 5 years. In addition to this Plan, several other formal emergency plans have been developed to support the overall emergency response effort. Once per calendar year, the designated Emergency Planning staff performs a review of the emergency plans for Southern Nuclear. This review includes a comparison for consistency of emergency plans for a specific site including the Security Plan, and state and county plans as appropriate. E2-88 to NL-16-0169 SNC Standard Emergency Plan Figure P.1 - Typical Emergency Preparedness Organization President and CEO I I Executive Vice President - Vice President - Regulatory Executive Vice President I Operational Reaciness and Affairs CNO Integration I Fleet Emergency Vice President - Fleet

                                          ------------1                                                 Site Integration Director Preparedness Director                             Operations Support I                                   I                             I Emergency Preparedness            Emergency Preparedness       Vice President- Nuclear Programs Manager                    Planning Manager                  Plant Site                    Emergency Preparedness I Security Project Manager I          I I

I Staff Staff I I Regulatory Affairs Manager I I I I I I I Emergency Preparedness Emergency Preparedness I Supervisor ---------- Supervisor (Farley, Hatch & Vogtle 1-2) (Vogtle 3-4) I

           - - - Coordination                                             Staff                                    Staff E2-89

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 4 Farley Staffing - Detailed Description and Technical Evaluation (Marked-Up Pages and Clean Copy) to NL-16-0169 Farley Staffing - Detailed Description and Technical Evaluation 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: 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 cooli ng 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 75 minutes of declaration 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 by iA-the TSC [Technical Support Center] ~ ED who assumes esponsibili for Classification and Emergency Exposure Controls ~md the , who then [ Comment [Ml]: RAl-rNP-4 assumes overall oontrol of the response efforts. The EOF ED who assumes responsibility for PARs, emergency notifications and arrives and relie*~es the TSC ED ef overall emergency management response . and off site responsibilities inolt1din9 PARs, dose assessment, and omer9enoy notifioations. 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-1 , during the period prior to augmentation . E4-5

J, \'\' Enclosure 4 to NL-16-0169 Farley Staffing - Detailed Description and Technical Evaluation

       'This License Amendment Request (LAR) revises the current on-shift and augmented
       *Emergency Response Organization (ERO) for Farley Nuclear Plant (FNP) Unit 1 and Unit 2
       'Emergency Plan to incorporate a standard on-shift and augmented ERO staffing plan for the Southern Nuclear Operating Company (SNC) 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 FNP Unit 1 and Unit 2 Emergency Plan Revision 64.0 requires staffing of augmented ERO for the Technical Support Center (TSC) and Operations Support Center (OSC) at 75 minutes from time of declaration of an Alert or higher emergency classification. The FNP 75 minute Emergency Response Facility (ERF) augmentation time for on-site ERFs was established in Revision 25.0 of the FNP Unit 1 and Unit 2 Emergency Plan in coordination with and with concurrence from the NRC Headquarters and Region II staff. FNP Unit 1 and Unit 2 Emergency Plan Revision 64.0 also directs that the SNC Fleet Emergency Operations Facility (EOF) " ... will be operational within about an hour qf the initial notification. 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." This wording was first incorporated in version 41 of the FNP Emergency Plan following prior approval of the SNC Fleet EOF. The augmentation time requirement for the EOF is consistent for the entire SNC Fleet and consistent with the on-site ERF requirements for VEGP 1-2, VEGP 3-4 and HNP, which provide for ERO augmentation within "approximately" one hour. The proposed SNC Fleet standard definition for ERO augmentation is 75 minutes fro"m declaration. This proposed change redefines the SNC Fleet augmentation time without extension, as 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. Since FNP augmentation time is already defined as 75 minutes from declaration of an Alert or higher emergency, it is not an actual change for FNP. However, since the SNC ERF augmentation time is part of the SNC Fleet Based Plan, it is being addressed in the FNP technical discussion for consistency.

E4-1

Enclosure 4 to NL-16-0169 Farley Staffing - Detailed Description and Technical Evaluation Assignment of Responsibility/Organizational Control The FNP Unit 1 and Unit 2 Emergency Plan maintains an on-shift organization as documented in the site Emergency Plan Revision 64.0. 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 FNP. Plant Operations and Assessment of Operational Aspects NUREG-0654/FEMA REP-01 Revision 1 guidance assumes the on-shift staff will provide the Plant Operations and Assessment of Operational Aspects function throughout the emergency. The on-shift operations staffing as provided in the current FNP Unit 1 and Unit 2 Emergency Plan Revision 64.0 meets the operations staffing requirements of 10 CFR 50.54(m)(2)(i) and the FNP Unit 1 and Unit 2 Technical Specifications. In addition to these requirements, the FNP Unit 1 and Unit 2 Emergency Plan provides for a dedicated Shift Manager position to perform 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 FNP 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 FNP Unit 1 and Unit 2 Emergency Plan and proposed SNC Fleet Emergency Plan, the on-shift staffing exceeds the requirements of NUREG-0654/FEMA REP-01 ' Revision 1 Table B-1, as well as those prescribed in Revision 25.0 of the FNP Unit 1 and Unit 2 Emergency Plan. The on-shift control room staff for FNP, as described, remains unchanged in the proposed SNC Fleet Emergency Plan and continues to ensure 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-01 Revision 1 guidance provides that the Emergency Direction and Control function may be fulfilled by personnel assigned other functions. Per Revision 25.0 of the FNP Unit 1 and Unit 2 Emergency Plan, the Emergency Director (ED) function is a collateral duty of an ED-qualified individual {Shift Manager or ED) assigned to the Plant Operations and Assessment of Operational Aspects. function until relieved by an augmented ED in the TSC within 75 minutes of declaration of an emergency. As provided in the current Revision 64.0 of the FNP 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 TSC ED within 75 minutes of declaration of an Alert or higher emergency. This remains unchanged in the proposed SNC Fleet Emergency Plan. 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. 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 Protective Action Recommendations (PARs). This ensures that in the unlikely event of a Hostile E4-2 to NL-16-0169 Farley Staffing - Detailed Description and Technical Evaluation Action Based (HAB) event in which the site is not accessible to the ERO, an ED would be available in the EOF within 75 minutes of an Alert or higher declaration to assume these aspects of the Emergency Direction and Control function and minimize the burden on the Shift Manager/ED. 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 l Emergencv TSC Emergenc:it Director EOF Emergencv Director Director Classification ~

Classification Notifications ~

                                                                    ~    Notifications
                                                                    ~

PARs ~ PARs Emergency Exposure ~ Emergency Exposure

Controls Controls Finally, the proposed rev1s1on to the FNP Unit 1 and Unit 2 Emergency Plan requires augmentation of the following TSC and EOF positions, which support activation of the TSC and EOF, within 75 minutes of declaration of Alert or higher emergency classification event:

TSC Emergency Director
TSC Manager
TSC Operations Supervisor
TSC Emergency Notification System (ENS) Communicator
TSC Health Physics Network (HPN) Communicator
TSC ERF Communicator
TSC Radiation Protection (RP) Supervisor
TSC Chemistry Support
TSC Engineering Supervisor
TSC Reactor Engineer
TSC Engineering Support
TSC Maintenance Supervisor
EOF 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 News Writer
EOF Field Team Communicator
EOF Dose Assessment Supervisor E4-3 to NL-16-0169 Farley Staffing - Detailed Description and Technical Evaluation
EOF Dose Analyst
EOF Technical Supervisor Notification and Communication NUREG-0654/FEMA REP-01 Revision 1 guidance addresses the Communicator function on-shift. Revision 64.0 of the FNP Unit 1 and Unit 2 Emergency Plan provides. for two Communicators modified by a note providing that this function may be fulfilled by individuals assigned other functions (Shift Manager, Shift Supervisor, Shift Support Supervisor, Shift Technical Advisor, Reactor Operator, or other appropriately qualified personnel). In the proposed SNC Fleet Emergency Plan, the FNP staffing for this function is addressed as provided in NUREG-0654/FEMA REP-01 Revision 1 guidance. The number of control room personnel available to perform this task will remain unchanged. This will ensure there will be sufficient, appropriately trained personnel on-shift so that the Communications function may be assigned to a member of the control room staff with no conflicting tasks. This has been demonstrated and documented by performing a 10 CFR Part 50, Appendix E shift staffing evaluation.
In addition, the proposed SNC 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 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 on site 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-110, 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 Chemistry Technician takes direction from the Control Room to provide radiological assessment support until the TSC 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 base~ on symptoms that are described in the EOPs, not based on specific accident assessment. Similarly, the Shift Manager/ED uses flowcharts in NMP-EP-112, Protective Action Recommendations procedure, which prescribes the decision-making processes for directing on-site protective measures. The simple information needed to accomplish allows for rapid decision making by the Shift Manager/ED using readily available information. E4-4 to NL-16-0169 Farley Staffing - Detailed Description and Technical Evaluation 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:

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 75 minutes of declaration 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 by the TSC [Technical Support Center] ED who assumes responsibility for Classification and Emergency Exposure Controls and the EOF ED who assumes responsibility for PARs, emergency notifications and overall emergency management response. 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-1, during the period prior to augmentation. E4-5 to NL-16-0169 Farley Staffing - Detailed Description and Technical Evaluation The proposed change presents no adverse impact to ERO staffing because TSC and EOF EDs will continue to provide timely relief to the on-shift ED from the duties and responsibilities for offsite functions. Offsite Dose Assessment (ODA)/Chemistry NUREG-0654/FEMA REP-01 Revision 1 does not specify a resource for the on-shift dose assessment task. The current version of the FNP Unit 1 and Unit 2 Emergency Plan does provide for an on...;shift capability for performance of dose assessment and is currently assigned to a Radiation Protection individual. In the proposed change, on-shift dose assessment will be assigned to an on-shift Chemistry individual appropriately trained for this task with no other conflicting emergency response duties. In turn, this will free the Radiation Protection individual to perform other radiation protection 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 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), FNP 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 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 Radiatjon Protection (RP) NUREG-0654/FEMA REP-01 Revision 1 identifies one on-shift RP Technician who is responsible for .performing in-plant surveys. NUREG-0654/FEMA REP-01 Revision 1 does not provide for any on-shift personnel for on-site out of plant surveys or for off-site surveys. NUREG-0654 I 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 64.0 of the FNP Unit 1 and Unit 2 Emergency Plan provides for two individuals to perform on-site out of plant surveys - an individual qualified to perform the survey and an E4-6 to NL-16-0169 Farley Staffing - Detailed Description and Technical Evaluation assistant to drive a vehicle. A Chemistry technician credited under the Protective Actions (in-plant) function also provides support to coordinate communications between the out of plant team and the dose assessor as needed. As part of the proposed SNC Fleet Emergency Plan, the FNP on-shift staffing for the on-site out of plant survey will be performed by a single RP technician or other appropriately trained individual. SNC currently uses predesignated, readily accessible survey points around the FNP 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 FNP 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 SNC Fleet Emergency Plan FNP on-shift staffing will eliminat~ 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 E;ixpedite 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 64.0 of the FNP 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. A third augmented individual, together with the on-site out of plant technician will make up the second off-site field monitoring team. On-site monitoring will then become a function of the OSC. 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 Integrated Plant Computer (IPC) system 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. E4-7 to NL-16-0169 Farley Staffing ..:. Detailed Description and Technical Evaluation Sufficient instrumentation, communication equipment, and transportation will be maintained on-site for augmenting and dispatching additional teams if needed. Regarding in-plant surveys, Revision 64.0 of the FNP Unit 1 and Unit 2 Emergency Plan provides for two individuals to perform in-plant surveys. These individuals include a qualified RP technician to perform the survey and an assistant (typically a maintenance individual). As part of the proposed change to the SNC Fleet Emergency Plan, the role of in-plant survey assistant is being eliminated from the FNP on-shift staff, with one RP technician assigned to the task of in-plant 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-01 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 64.0 of the FNP 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 IPC, which graphically displays the pertinent parameters with trending and graphing capabilities, alarm functions, and color-coded indication for changes in state for the Critical Safety Function Status Trees. This enhances critical parameter monitoring and the rapid identification and assessment of in-plant conditions. This remains unchanged for FNP in the SNC Fleet Emergency Plan. Repair and Corrective Actions NUREG-0654/FEMA REP-01 Revision 1 Table B-1 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/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. E4-8 to NL-16-0169 Farley Staffing - Detailed Description and Technical Evaluation Typically, the initial stages of Corrective Actions are 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.
l&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 of the FNP Unit 1 and Unit 2 Emergency Plan (Revision 64.0) provides for one mechanical journeyman, one electrical journeyman, and one instrument and controls technician on-shift to support the Repair and Corrective Action task. These numbers will be maintained in the proposed SNC Fleet Emergency Plan FNP on-shift staffing. In addition to these personnel, a maintenance supervisor will be added on-shift to provide supervisory. oversight for repair and corrective actions, further enhancing the on-shift response capability. The proposed SNC Fleet Emergency Plan provides for augmentation of maintenance discipline specific leads in the OSC as well as an overall OSC Manager within 75 minutes of an Alert or higher emergency classification. The proposal removes one mechanical journeyman, one electrical journeyman, and one instrument and controls technician. who currently fulfill Technical Support tasks (Fire Tanker Driver, FMT driver, and in-plant survey* assistant) that are addressed elsewhere in this document. This is a reduction in staffing. A 10 CFR 50 Appendix E shift staffing evaluation was performed to* validate that removal of the individuals performing the Technical Support tasks did not impact the ability of the proposed on-shift staff to perform all of their assigned tasks during the 75 minutes prior to aug!llentation. 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-1 _and the proposed NUREG-0654/FEMA REP-01 Revision 2 (ML14246A519). Based on FNP 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 l&C Maintenance augmented within the 75 minute timeframe. ESF systems are redundant in trains (physical separation) and have diveirsity of subsystems. Therefore, the inoperability of different system components in different trains is not expected to result in a loss of function of the ESF. 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 assigne.d

other functions." The major tasks of this function are access control, RP. coverage for repair,.

corrective actions, search and rescue, first aid, firefighting, personnel monitoring, and dosimetry. Revision 64.0 of the FNP Unit 1 and Unit 2 Emergency Plan provides two individuals for performing this function. One is an RP technician and the other is a chemistry technician who, as needed, supports dosimetry issuance, and also supports briefing the on-shift on-site out of E4-9

Enclosure 4 to NL-16-0169 Farley Staffing - Detailed Description and Technical Evaluation plant survey team prior to dispatch and communication with this team. 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 FNP 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. 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 before exceeding the 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 FNP 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 For the Fire Fighting function, NUREG-0654/FEMA REP-01 Revision 1 specifies that staffing is per the site Technical Specifications. Revision 64.0 of the FNP Unit 1 and Unit 2 Emergency Plan states the Fire Brigade staffing is in accordance with the FNP FSAR, where the Fire Brigade commitments for FNP are maintained. The on-shift Fire Brigade is assigned this task throughout the emergency with off-site support provided by local fire departments. The Fire Brigade staffing and associated off-site fire response support remains unchanged in the proposed SNC Fleet Emergency Plan. Revision 64.0 of the FNP Unit 1 and Unit 2 Emergency Plan provides an additional individual designated as Fire Tanker Driver, who is assigned to drive a large transport vehicle pulling a trailer-mounted water tank, used for fires affecting areas external to the plant such as grass fires or outbuildings outside the installed plant fire protection header. There is no requirement in the FNP FSAR for this position, nor is there any regulatory requirement for maintaining this position E4-10

Enclosure 4 to NL-16-0169 Farley Staffing - Detailed Description and Technical Evaluation as part of the site's emergency planning basis. Furthermore, the type of fires for which this equipment would be used will be addressed by off-site fire responders with whom FNP maintains support agreements. These agreements with off-site firefighting resources are provided in the current FNP Emergency Plan as well as in the proposed SNC Fleet Emergency Plan. Since the equipment operated by this position is not used to fight fires affecting actual plant equipment, there is no impact to the performance of the Fire Fighting function as the result of eliminating this position from minimum FNP on-shift staffing requirements in the SNC Fleet Emergency Plan. A staffing analysis meeting the requirements of 10 CFR 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 FNP 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 (ER0)-10 CFR 50.47(b) (2) The current ERO provided in Revision 64.0 of the FNP 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 documented in 10 CFR 50 Appendix E.IV.A.9. In support of this submittal, the proposed ERO for the FNP 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 Change 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 6. E4-11 to NL-16-0169 Farley Staffing - Detailed Description and Technical Evaluation Planning Basis for Augmented Emergency Response Organization (ERO) Positions have been designated as 75 minutes responders in the TSC, OSC, EOF, and JIG. These positions perform major functions and supporting functions in each facility. The tables below outline these positions and functions as provided in the proposed SNC Fleet Emergency Plan. E4-12 to NL-16-0169 Farley 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* Suooort Coordinator** Notify licensee, state, local, Emergency Notification and federal personnel & System (ENS) Communicator Notification/Communication maintain communication HPN Communicator Intra-facility Communications Emergency Response Facility (ERF) Communicator Offsite Dose Assessment Radiation Protection (RP) Supervisor Radiological Accident Dose Analyst* Assessment and Support of Operational Accident Assessment Offsite surveys Not applicable for this facility 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 & firefighting Personnel monitoring Dosimetry

Security Supervisor filled by one of the on-shift Security Supervisors. Dose Analyst filled by the on-shift chemistry technician.
- Support Coordinator does not have a 75 minute augmentation time.

E4-13 to NL-16-0169 Farley Staffing - Detailed Description and Technical Evaluation 0$C 75 Minute Augmentation ERO ,* Major Functional Area Major Tasks Position Title Emergency Direction and OSC Manager Control Notify licensee, state, local

Not applicable. for this facility'
and federal personnel &

Notification/Communication maintain communication Intra-facility communications ERF Communicator Offsite Dose Assessment Not applicable for this facility Offsite surveys Field Monitoring Team Lead Radiological Accident (1) Assessment and Support of Field Monitoring Team Operational Accident Assistant (2) Assessment Onsite and in-plant surveys RP Technicians (2) Chemistry/Radio Chemistry Chemistry Technician Technical Support Not*aoolicable for this'facilitv. Repair and corrective Mechanical Maintenance Plant System Engineering, actions Group Lead Repair and Corrective Actions Electrical Maintenance Group Lead l&C Maintenance Group Lead Access Control RP I Chemistry Group Lead

RP coverage for repair, RP Technicians (2) corrective actions, search Protective Actions and rescue, first aid &

firefighting

Personnel monitoring
Dosimetry E4-14 to NL-16-0169 Farley 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 Manaoer Suooort Coordinator*

Emergency Communication Coordinator Security Coordinator Offsite Response Coordinator Administrative Suooort 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                  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 Chemistrv/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 &

fi refig hti ng Personnel monitorino Dosimetry

Support Coordinator, Administrative Support Staff, Liaisons (at EOCs) GA, AL, SC do not have a 75 minute augmentation time.

E4-15

Enclosure 4 to NL-16-0169 Farley 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. The minimum staff identified in Standard Plan figures B.2.1.A, B.2.2.A, B.3.1.A are not intended to further reduce the augmentation requirements, but instead delineate a subset of the 75 minute responders that, if available prior to full staffing, can 'activate' the facility and reduce the event management . burden on the Control Room through transfer of command and control functions to the ERFs. 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. This criteria was developed to comport with the guidance in NSIR/DPR/ISG-01, Emergency Planning for Nuclear Power Plants. Minimum staffing positions for the TSC Organization are as follows:

TSC Emergency Director (ED)
TSC Emergency Response Facility (ERF) Communicator

TSC Manager
TSC Operations Supervisor
TSC ENS Communicator
TSC Radiation Protection (RP) Supervisor
TSC Reactor Engineer 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 E4-16 to NL-16-0169 Farley Staffing - Detailed Description and Technical Evaluation
EOF ENN Communicator Minimum st9ffing positions for the Joint Information Center (JIC) Organization are as follows:
Public Information Director (PIO)
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 . Plant Computer System At the time of the original approval of the FNP Unit 1 and Unit 2 Emergency Plan, the site used a Westinghouse P2500 Plant Computer System. The operator interface consisted of a small number of printers located in the control room and computer room. In the mid-1980s, the Westinghouse P2500 Plant Computer System was upgraded to a Gould Encore 32/67 Computer System. The design criteria for the new plant computer were based on the *requirements of NUREG-0737, Supplement 1 for a Safety Parameter Display System (SPDS) and the upgrading of ERFs. The requirements specified for the SPDS were met or exceeded by a system of displays provided by the Gould Encore 32/67 Computer System. The parameters on the SPDS displays were provided by integrated software on the plant computer system. 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 2006 for Unit 1 and 2007 for Unit 2, the site installed a Data Systems and Solutions (DS&S) SAIPMS Integrated Plant Computer System. The new IPC significantly improved plant monitoring capabilities in the control room as well as in the site's ERFs, 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.

E4-17 to NL-16-0169 Farley Staffing - Detailed Description and Technical Evaluation Computer basic functions are supported by instrument buses with back-up power provided by vital buses.

Dose Assessment The original FNP dose assessment program used the automated rapid dose assessment (ARDA) software for per.forming dose assessment. The ARDA model was a Class A dose assessment model with limited user interface. In 1994, the FNP dose assessment capability was upgraded when the MIDAS dose assessment program was installed on the ERF Computer to provide FNP a Class B dose assessment modeL 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 Chemistry personnel using the MIDAS-NU program. 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) progr~m. 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 2007 (Reference Revision 43.0 of FNP Unit 1 and Unit 2 Emergency Plan) FNP 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 FNP Unit 1 and Unit 2. Since

E4-18 to NL-16-0169 Farley Staffing - Detailed Description and Technical Evaluation NRC approval of the FNP 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.

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 re~ulting 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 (LOCT) Program includes licensed crew performance evaluations that consider the scenario guidance attributes of INPO Operations Department Standing Instruction, ODSl-3, and "Operations Department Guidance." Attachment C of ODSl-3 provides guidance on the realistic integration of the emergency response into crew performance evaluations. The purpose is to ensure 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 to mitigate the consequences of an accident and protect public health and safety. Increases in On-Shift Staff,ing There has been an increase in on-shift staffing since the original approval of the FNP Unit 1 and Unit 2 Emergency Plan, in order to ensure adequate performance of the major emergency plan functions and tasks. A total of 28 persons are identified for on-shift staffing in Revision 64.0 of the FNP 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, Revision 25.0 of the FNP Unit 1 and Unit 2 Emergency Plan, Revision 64.0.0 of the FNP Unit 1 and Unit 2 Emergency Plan, and proposed revisions are included in Enclosure 6. E4-19 to NL-16-0169 Farley Staffing - Detailed Description and Technical Evaluation E4-20 to NL-16-0169 Farley Staffing - Detailed Description and Technical Evaluation 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 system.s at the time the original FNP Unit 1 and Unit 2 Emergency Plan was approved. Real-time plant data is communicated to the Nuclear Regulatory Commission using the approved Emergency Response Data System (EROS). Additionally, local OROs are provided real-time data with automated methods (currently WebEOC). These enhancements provide more timely ahd 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 FNP 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-01 Revision 1, the proposed Emergency Response Organization is capable of implementing'the Emergency Plan in accordance with the requirements of 10 CFR 47 and 10 CFR 50 Appendix E. E4-21

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 5 Farley Standard Emergency Plan Annex (Marked-Up Pages and Clean Copy) to NL-16-0169 Farley Standard Emergency Plan Annex These resources include, but are not limited to, Local Law Enforcement Agency (LLEA) assets , fire fighting assets, medica l 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 tim ing of the event. 1.7.2 Early County, Georgia (SEP A.2.4) The Chairman , Early County Board of Commissioners, has responsibility for overall radiological emergency response planning. The actual plan development and coordination of emergency actions is carried out by the Blakely-Early County Emergency Management Agency. The "Blakely-Early County Emergency Management Agency Radiological Emergency Plan for Nuclear Incidents/Accidents Involving Joseph M. Farley Nuclear Power Plant" is given as part of the "State of Georg ia Rad iolog ical Emergency Plan. " An agreement is in place with Early County, Georg ia, to provide available resources and equ ipment 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. 1.7.3 HenryCounty The Probate Judge of Henry County will assume responsibility for Emergency Management operations and actions in the county. The Houston County Emergency Management Director will oversee and coordinate emergency operations within Houston and Henry Counties during an incident at Farley Nuclear Plant. Emergency Management will take actions as outlined in the Master Checklist Guide (Attachment 4 to Appendix 1 of the Basic Plan) to coincide with the current situation . Because of the limited EPZ area in Henry County the State of Alabama REP directs Houston County to assume overall direction of emergency response. Notification of Henry County by Farley Nuclear Plant is met with the notification of Houston County. ( Comment [Ml]: RA I-FNl'-1 1.7.4 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 E5-5 to NL-16-0169 Fa rley Standard Emergency Plan Annex Section 4: Emergency Measures (SEP E) 4.1 Notification of Off-Site Agencies (SEP E.2.2) 4.1.1 Notification Process (SEP E.2 .2.1) State and local counties surrounding FNP will be notified within 15 minutes of the declaration of an emergency condition are: State of Alabama

Alabama Emergency Management Agency (AEMA).

State of Georg ia:

Georg ia Emergency Management Agency (GEMA).

Alabama County Authorities

Houston County - Sheriff's Dispatch Center.

Georg ia County Authorities:

Early County - Sheriff's Dispatch Center.

4.2 Alert and Notification System (ANS) (SEP E.2 .5) ( Comment [M2]: RA l-FNP- 15 With in the Plume Exposure Emergency Planning Zone (EPZ), there exist provisions fo r alerting and providing notification to the public. The state and/or local authorities are responsible for activation of this system. The FEMA approved Farley ANS consists of a primary ANS and a backup system should there be a fa ilure of the primary system .

Primary - Sirens and Emergency Alert System (EAS) stations
System Backup - Reverse calling system The primary ANS has two communications pathways. The fi rst pathway is through the primary agency via the UHF or VHF radio . Should the primary agency fa il to activate the system, the secondary pathway will be utilized by the secondary agency. The secondary pathway functions in the same manner as the primary pathway utilizing a separate activation console that is physically located in separate location . If neither agency can activate the system, the backup system will be utilized to notify the residents of the 10 mile EPZ.

The hierarchy for system activation is provided below: Agency Radio Systems Primary Agency UHF VHF Primary Sirens & EAS Secondary Agency UHF VHR Backup Each County EMA Calling System E5-1 6 to NL-16-0169 Farley Standard Emergency Plan Annex Alabama Georgia Primary Agency Houston County Early County Secondary Agency Henry County State of Georgia (GEMA) Primary alerting is accomplished by use of a siren system. 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(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. Special alerting uses a calling system. Special alerting is initiated in the event of a failure of the system to activate multiple sirens resulting in a loss of coverage in any area. Special alerting may be initiated for a predefined area , a user specified area , user defined groups , or the entire Emergency Planning Zone (EPZ). The calling system serves as a complete independent backup to the ANS. The system provides both alerting and notification of EPZ residents independent of the alerting capabilities of the installed siren system and the notification capability of local radio and television stations through EAS . Capability to activate the calling system is provided by Houston County and Henry County, Alabama , and Early County, Georgia. A full description of the Farley ANS design is provided in the FEMA approved ANS Design located in the SNC document management system. Residents in the plume exposure pathway EPZ have been instructed to tune to specific emergency alert radio or TV stations if the sirens are activated . 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. 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 . 4.3 Protective Actions for Onsite Personnel (SEP J.4) Protective response for onsite personnel (including visitors and contractor personnel) depends on alerting , assembly and accountability, site evacuation , monitoring , and decontamination. Protective actions may also be taken for onsite personnel for emergencies such as fires , security related events, or natural disasters where personnel safety is threatened . 4.3.1 Alerting (SEP E.2.1, J.1) Section E of the Emergency Plan (EP), Notification Methods and Procedures, describes the methods to alert onsite personnel of emergency cond itions. 4.3.2 Assembly (SEP J.4.1) Personnel assembly is mandatory at the Site Area Emergency or higher level classification. Upon activation of the plant emergency alarm, plant personnel who are assigned specific emergency responsibilities will proceed to their designated emergency response locations. Assembly of site personnel who are outside the Protected Areas is accomplished by non-essential personnel reporting E5-17 to NL-16-0169 Farley Standard Emergency Plan Annex OPERATIONS SUPPORT CENTER (Room 2452) AIRTIGHT DOOR TECHNICAL SUPPORT CENTER PLANNING AND COORDINATION AREA AIRTIGHT STAJRWELL DOOR MAIN ENTRY CONTROL ROOM Figure 5.1.A- Sample Technical Support Center ES-21 to NL-16-0169 Farley Standard Emergency Plan Annex Appendix C - Farley Nuclear Plant NUREG-0654 Cross Reference Table NUREG 0654 Rev 1 FNP SEP SNC SEP Section Ref Section Annex Criteria II.A - Assianment of Responsibility A.1 .a A.1 , A.2, A.3, A.4 1.3-1 .9 A.1 .b Introduction Section 1: Introduction A.1.c Figures 8 .2.1.A, 8 .2.2.A, 8.3.1.A & -- 8.3.2.A A.1.d 8 .3.1.1 -- A.1 .e 8 .1 Table 2.2 .A A.2 .a N/A N/A A.2.b N/A N/A A.3 A.5 1.3-1 .9 A.4 8 .2, 8 .2.1.15, 8 .3.1.3 -- Criteria 11.B - Onsite Emeraencv Oraanization 8 .1 8 .2 - 8 .2 8 .1.1 Table 2.2.A 8.3 8 .1.2 -- 8.4 8 .1.1, Figure 8 .2.A -- 8 .5 Tables 1 - 4 Table 2.2.A 8 .6 8 .2, 8 .3, Figures 8.2 .1.A, 8.2.2.A, -- 8 .3.1.A & 8 .3.2.A 8 .7 Tables 1-4 -- Figures 8.2.1.A, 8.2.2.A, 8 .3.1.A & 8.3.2.A 8 .7.a 8 .2.1.15, 8.3.1 .3 -- 8 .7.b 8.3.1.2, 8 .3.1.17 -- 8.7.c 8 .3.1.1, 8.3.1.2 -- 8 .7.d 8 .3.2.1, 8 .3.2.2 8 .3.2.8 8 .8 8.4, C.4.2 2. 3 8 .9 8.6, K.1 2.3 Criteria 11.C - Emeraencv Resoonse Sunnort and Resources C.1.a Section C -- C.1.b A.1 1.3 C.1.c A.1.1 , A.2, A.3, C.1-C.4, F.1 Section 1 C.2.a N/A NIA C.2.b A.1.1 , H.2.1 5.1.2 C.3 H.5.2.3, H.6.3 -- C.4 Sections A & C, 8.4-8 .6, H.6.3, L.1- 1.3 - 1.9, 2.3, 5.8 L.4 Criteria 11.D - Emergency Classification System 0 .1 Section O Append ix 8 0 .2 Section O Aooendix 8 0 .3 N/A N/A 0 .4 N/A N/A Criteria 11.E - Notification Methods and Procedures E.1 E.1 .1 Append ix 0 E.2 E.2.1 -- E.3 E.2.2.2 -- E.4 E.2.2.2 -- E.4 .a E.2.2.2 -- E.4.b E.2.2.2 -- E.4.c E.2.2 .2 -- NOTE : N/A =Not required by Licensee in accordance with NUREG-0654 E5-29 to NL-16-0169 Farley Standard Emergency Plan Annex NUREG 0654 Rev 1 FNP SEP SNC SEP Section Ref Section Annex Criteria 11.E - Notification Methods and Procedures (continued) E.4.d E.2.2.2 -- E.4.e E. 2.2.2 -- E.4.f E.2.2.2 -- E.4.o E.2.2.2 -- E.4.h E.2.2.2 -- E.4.i E.2.2.2 -- E.4.j E.2.2.2 -- E.4.k E.2.2.2 -- E.4.1 E.2.2.2 -- E.4 .m E.2 .2.2 -- E.4.n E. 2. 2.2 -- E.5 N/A N/A E.6 E.2.5 E.7 E.2.6 -- Criteria 11.F - Emergency Communications F.1.a F.1.1, F.1 .2 4.1.1 F.1.b F. 1.3 -- F.1.c F.1.4 -- F.1.d F.1.5 -- F.1.e F.1.6 -- F.1.f F.1.4 -- F.2 F.2 -- F.3 F.3 5.4 Criteria 11.G - Public Education and Info rmatio n G.1 G.1 -- G.2 G.8 2.3.5 G.3.a B.3.2.1, H.2.2, H.2.3 5.1.6 G.3.b N/A N/A G.4.a B.3.2.8 -- G.4.b G.2 -- G.4.c B.3.2.5, B.3.2.6 -- G.5 G.2 -- Criteria 11.H - Emergency Equipment and Facilities H.1 H.1.2 5.1.2 H.2 H.2.1 5.1.5 H.3 H.2.2, H.2.3 -- H.4 H.1 -- H.5 H.5 5.6 H.5.a H.5.1 5.6.1 H.5.b H.5.2 -- H.5.c H.5.3 -- H.5.d H.5.4 -- H.6.a H.5.1 5.6.1 H.6 .b H.5.2 -- H.6 .c H.5.2.3, H.6.3 -- H.7 H.6 -- H.8 H.7 5.6.1 H.9 H.1.3 5.1.3 H.10 H.8 -- H.11 H.9 -- H.12 H.10 -- NOTE: N/A = Not required by Licensee in accordance with NUREG-0654 E5-30 to NL-16-0169 Farley Standard Emergency Plan Annex NUREG 0654 Rev 1 FNP SEP SNC SEP Section Ref Section Criteria II.I - Accident Assessment

                                                           ---     - - - -Annex 1.1                                1.1                     --

1.2 1.2 -- 1.3.a 1.3 -- 1.3.b 1.3 -- 1.4 1.4 -- 1.5 1.5 -- 1.6 1.6 -- 1.7 1.7 -- 1.8 1.8 -- 1.9 1.9 -- 1.10 1.7 -- 1.11 NIA NIA Criteria 11.J - Protective Response J.1.a J.1 -- J.1 .b J.1 -- J.1.c J.1 -- J.1.d J.1 -- J .2 J.4.3 -- J .3 J.2 -- J.4 J.3, J.4 .3 -- J.5 J.4.2, 4.3.2 -- J.6.a J.4 -- J.6.b J.4 -- J .6.c J.4 -- J.7 J.5 -- J .8 J.6 Appendix A J.9 NIA NIA J.10.a J.7 -- J.10.b J.7 -- J.10.c E.2.5 4 .2 J.10.d NIA NIA J.10.e NIA NIA J.10.f NIA NIA J.10.a NIA NIA J.10.h NIA NIA J.10.i NIA NIA J.10.i NIA NIA J .10.k NIA NIA J.10.1 NIA NIA J.10.m J.5 -- J.11 NIA NIA J.12 NIA NIA Criteria 11.K - Radioloaical Exposure Control K.1.a K.1.1 -- K.1.b K.1 -- K.1.c K.1 -- K.1.d K.1 .2.1 -- K.1 .e K.1.2.1, K.5 -- K.1.f K.1.1.1 -- K.1.q K.1 .3 -- K.2 K.1 - NOTE : N/A = Not required by Licensee in accordance with NUREG-0654 ES-31 to NL-16-0169 Farley Standard Emergency Plan Annex NUREG 0654 Rev 1 FNP SEP SNC SEP Section Ref Section Annex Criteria 11.K - Radioloaical Exoosure Control lcontinuedl K.3.a K.3 -- K.3.b K.3 -- K.4 N/A N/A K.5.a K.5 -- K.5.b K.5 -- K.6.a K.6 -- K.6.b K.6 -- K.6.c K.6 -- K.7 K.7 -- Criteria 11.L - Medical and Public Health Suooort L.1 L.1 -- L.2 L.2 -- L.3 N/A N/A L.4 L.4 -- Criteria 11.M - Recovery and Reentry Plannina and Post-Accident Operations M.1 M.1 -- M.2 M.2 -- M.3 M.3 -- M.4 M.4 -- Criteria 11.N - Exercises and Drills N.1.a N.1 -- N.1.b N.1 -- N.2.a F.3 -- N.2.b N.2.3 - N.2.c N.2.4 -- N.2.d N.2.5 -- N.2.e(1) N.2.6 -- N.2.e(2) N.2. 6 -- N.3.a N.3 -- N.3.b N.3 -- N.3.c N.3 -- N.3.d N.3 -- N.3.e N.3 -- N.3.f N.3 -- N.4 N.4 -- N.5 N.5 -- Criteria 11.0 - Radioloaical Emer~encv Resoonse Trainina 0.1 0 .1 -- 0 .1.a 0 .1.1 -- 0 .1.b 0 .1.1 -- 0 .2 0 .3 -- 0 .3 0 .4 -- 0.4.a 0.4 -- 0 .4.b 0 .4 - 0.4.c 0.4 .3 -- 0 .4.d 0.4.1, 0.4.4 -- 0 .4.e 0.4.5 -- 0.4.f 0 .4.6 - 0.4.Q 0 .1.1 -- 0 .4.h 0 .1.1 -- 0.4 .i 0.4 -- NOTE: N/A =Not required by Licensee in accordance with NUREG-0654 ES-32 to NL-16-0169 Farley Standard Emergency Plan Annex NUREG 0654 Rev 1 FNP SEP SNC SEP Section Ref Section Annex Criteria 11.0 - Radioloaical Emeraencv Response Trainina (continued 0.4 .i 0 .4, 0.4.7 -- 0.5 0.4 -- Criteria 11.P - Responsibility for the Planning Effort: Development, Periodic Review and Distribution of Emergency Plans P.1 0 .5, Section P -- P.2 Section P -- P.3 P.1 -- P.4 P.1 -- P.5 P.3 -- P.6 P.3 -- P7 - Appendix D P.8 Table of Contents -- P.9 P.3 - P.10 F.1.4 -- NOTE : N/A =Not required by Licensee in accordance with NUREG-0654 E5-33 to NL-16-0169 Farley Standard Emergency Plan Annex Appendix D - Supporting Plans & Implementing Procedures (SEP P.3) Supporting Plans

State of Alabama Radiological Emergency Response Plan
State of Georgia Radiological Emergency Plan
State of Florida Emergency Response Plan
Early County Georgia Emergency Response Plan
Houston County Alabama Emergency Response Plan
FNP Security Plan Administrative and Emergency Plan Implementing Procedures (E PIP)

Plan Section Title EPIP EPIP Title Section A Assignment of Responsibility NMP-EP-300 SNC Emergency Preparedness (under Conduct of Operations development) FNP-O-EIP-0.0 Emergency Organization B Emergency Response NMP-EP-146 ERO Position Checklists Organization FNP-O-EIP-4.0 Health Physics Support to the Emergency Plan FNP-O-EIP-5.0 Maintenance Support to the Emergency Plan FNP-O-EIP-7.0 Security Support to the Emergency Plan FNP-O-EIP-20.0 Chemistry and Environmental Support to the Emergency Plan c Emergency Response Support and NMP-EP-300 SNC Emergency Preparedness Resources (under Conduct of Operations development) D Emergency Classificati on System NMP-EP-141 Emergency Classification FNP-O-EIP-1 .0 Duties of An Individual Who Discovers an Emergency Condition E Notification Methods and NMP-EP-142 Emergency Notification Procedures NMP-EP-308 SNC Emergency Alert Siren Operation, Testing And Maintenance F Emergency Communications NMMP-EP-300 SNC Emergency Preparedness (under Conduct of Operations development) FNP-O-EIP-2.0 Handling of Incoming Calls During Emergencies or Emergency Exercises FNP-O-EIP-8.0 Non-Emergency Notifications FNP-O-EIP-8.1 Emergency Phone Directory FNP-O-EIP-8.2 Plant Personnel Home Telephone Directory FNP-O-EIP-8.3 Communications Equipment Operating Procedures E5-34 to NL-16-0169 Farley Standard Emergency Plan Annex Plan Section Title EPIP EPIP Title Section G Public Education and Information NMP-EP-203 Corporate Media Center Operations NMP-EP-204 Emergency News Center/Joint Information Center Operations NMP-EP-205 Emergency Communications News Releases NMP-EP-206 Emergency Communications News Briefings NMP-EP-207 Emergency Communications Public

Response

H Emergency Facilities and NMP-EP-143 Facility Activation Equipment NMP-EP-305 Equipment Important to the EP Function FNP-O-EIP-16.0 Emergency Equipment and Supplies I Accident Assessment NMP-EP-140 Accident Assessment J Protective Response NMP-EP-144 Protective Actions FNP-O-EIP-1 1.0 Handling of Injured Personnel FNP-O-EIP-14.0 Emergency Response Teams K Radiological Exposure Control NMP-EP-144 Protective Actions FNP-O-EIP-4.0 Health Physics Support to the Emergency Plan FNP-O-EIP-20 .0 Chemistry and Environmental Support to the Emergency Plan L Medical and Public Health Support NMP-EP-300 SNC Emergency Preparedness (under Conduct of Operations development) M Recovery and Re-entry Planning NMP-EP-145 Termination and Recovery and Post Accident Operations N Exercises and Drills NMP-EP-303 Drill and Exercise Standards 0 Radiological Emergency Response NMP-EP-301 EOF Emergency Response Training Organization And EP Staff Training p Responsibility for the Planning NMP-EP-300 SNC Emergency Preparedness Effort NMP-EP-310 Conduct of Operations NMP-EP-312 Maintaining The Emergency Plan NMP-TR-1 04-006 Development Of Emergency Preparedness Technical Products SEPTOC E5-35

Southern Nuclear Operating Company STANDARD EMERGENCY PLAN ANNEX for Farley Nuclear Plant Units 1and2 Revision 0 to NL-16-0169 Farley Standard Emergency Plan Annex Table of Contents Section 1: Introduction (SEP) .............................................................................;................................3 1 :1 Facility Description .......................................................................................................................... 3 1.2 Emergency Planning Zones (SEP J.5) ........................................................................................ 3 1.3 Department of the Army - 891h Explosive Ordnance Disposal (EOD) Detachment ............. 3 1 .4 State of Alabama (SEP A.2 .1) ....................................................................................................... 3 1.5 State of Georgia (SEP A.2.2) ........................................................................................................ 4 1.6 State of 'Florida ................................................................................................................................ 4 1.7 Local Organizations (SEP A.2.4, 8.6.1) ...................................................................................... 4 1.8 24-Hou r Staffing (SEP F .1 .2) ...............................................................................................-......... 6 1.9 Hostile Action Based Events (SEP H.1.4) ................................................................................... 6 Figure 1.1.A - Location and Vicinity Map ............................................................................................. 7 Figure 1.1.B - Joseph M. Farley Nuclear Plant Site Plan ................................................................. 8 Figure 1.2.A Mile Emergency Planning Zone (EPZ) ................................................................. 9 Figure 1.2.B - 50 Mile Ingestion Pathway IPZ .................................................................................. 10 Section 2: Organizational Control of Emergencies (SEP B.1) ..................................................11 2.1 Normal Plant Organization (SEP 8.1 ) ........................................................................................ 11 2.2 Emergency Organization (SEP 8.2, 8.3) .................................................................................. 11 Table 2.2.A - Farley Nuclear Plant On-Shift Staffing ....................................................................... 12 2.3 Non-SNC Support Groups (SEP 8.4, 8.5, 8.6) ........................................................................ 13 Section 3: Classification of Emergencies (SEP D.1) ...................................................................15 3.1 Emergency Classifications: (SEP D.1) ...................................................................................... 15 3.2 Determination of Levels: (SEP D.1.2) ........................................................................................ 15 3.3 Operating Mode Applicability (SEP D.2.7) ................................................................................ 15 Section 4: Emergency Measures (SEP E) .......................................................................................16 4.1 Notification of Off-Site Agencies (SEP E.2.2) ........................................................................... 16 4.2 Alert and Notification System (ANS) (SEP E.2.5) ......................................................~ ............. 16 4.3 Protective Actions for Onsite Personnel (SEP J.4) .................................................................. 17 4.4 Protective Actions for the Offsite Public (SEP J.5) .................................................................. 18 Section 5: Emergency Facilities and Equipment (SEP H) ..........................................................19 5.1 Emergency Response Facilities (SEP H.1, H.2) ...................................................................... 19 Figure 5.1.A- Sample Technical Support Center ............................................................................ 21 Figure 5.1.B - Sample Operations Support Center .......................................................................... 22 5.2 On-Site Communications (SEP F.1) .......................................................................................... 23 5.3 Offsite Communications (SEP F.1) ............................................................................................ 23 5.4 Communications System Testing (SEP F.3) ............................................................................ 23 5.5 Emergency Kits (SEP H.9) .......................................................................................................... 23 5.6 Facilities and Equipment for On-site Monitoring (SEP H.5) ................................................... 23 5.7 Protective Facilities and Equipment (SEP J) ............................................................................ 24 5.8 Medical Support (SEP 8.6, SEP L) ............................................................................................ 25 Appendix A- Evacuation Time Estimate Study and Map Reference (SEP J.6) ...................26 Appendix B - Emergency Action Level (EAL) Scheme (SEP D.1) ............................................28 Appendix C - Farley Nuclear Plant NUREG-0654 Cross Reference Table ............................29 Appendix D - Supporting Plans & Implementing Procedures (SEP P.3)................................34 E5-2 to NL-16-0169 Farley Standard Emergency Plan Annex Section 1: Introduction (SEP) This document serves as the Farley Nuclear Plant (FNP) Units 1 and 2 Annex and contains information and guidance that is unique to FNP. This includes Emergency Action Levels (EALs) and facility geography. In an emergency situation at FNP, the initial response would be made by the site staff and, if needed, by local support agencies. This Annex addresses the actions and responsibilities of the FNP plant staff and the offsite support agencies. 1.1 Facility Description The Farley Nuclear Plant (FNP) is a two unit pressurized water reactor. The plant site is in Houston County, Alabama, approximately 15 miles east of Dothan, Alabama. 1.2 Emergency Planning Zones (SEP J.5) 1.2.1 Plume Exposure Pathway (SEP J.7) The 10-mile Emergency Planning Zone (EPZ) for FNP approximates a 10-mile radius around the plant site and is depicted in Figure 1.2.A.

                      .Alabama and Georgia, as well as the counties (Early County in Georgia and Houston and Henry Counties in Alabama) are located within the plume exposure pathway EPZ.

1.2.2 Ingestion Pathway (SEP J.7) The area between the 10-mile and 50-mile radius is considered the Ingestion Pathway Zone (IPZ). The 50-mile IPZ is depicted in Figure 1.2.B. Planning for the ingestion exposure pathway is a responsibility of the states of Alabama, Florida, and Georgia. More information about the IPZ can be obtained from the States' Radiological Emergency Plans. 1.3 Department of the Army - 891h Explosive Ordnance Disposal (EOD) Detachment In the event of an emergency involving the discovery of unexploded ordnance or an improvised explosive device at FNP, an agreement has been established with the 891h Explosive Ordnance Disposal Detachment of Ft. Benning, Georgia for the collection and disposal of the discovered device(s). 1.4 State of Alabama (SEP A.2.1) The Alabama Department of Public Health, Office of Radiation Control (ADPH-ORC) 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 the welfare and safety of the general public, it will have primary responsibility and authority for handling the offsite aspects of the emergency in Alabama. An agreement is in place with the State of Alabama to provide available resources and equipment to support mitigation and response to an emergency at Plant Farley, including Hostile Action Based events. These resources include, but are not limited to, Local Law Enforcement Agency (LLEA) assets, fire fighting assets, medical support resources (including transportation), and coordination through an Incident Command Post. Requests for offsite resources and E5-3 to NL-16-0169 Farley Standard Emergency Plan Annex 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. 1.5 State of Georgia (SEP A.2.2) Upon notification of an emergency condition, the Georgia Emergency Management Agency will implement the "State of Georgia Radiological Emergency Plan." The Georgia Emergency Management Agency has the authority and responsibility for coordinating the efforts of local and state agencies in Georgia to provide for the health and safety of the general public in the event of a radiological incident. An agreement is in place with the State of Georgia to provide available resources and equipment to support the mitigation and response to an emergency at Plant Farley, including Hostile Action Based events. These resources include, but are not limited to, Local Law Enforcement Agency (LLEA) assets, fire fighting assets, medical support resources (including transportation), and coordination through an Incident Command Post. Requests for offsite resources and equipment will be communicated from the control room to the Early County 911 center, the county EOC, or through the Incident Command Post, as applicable, based on the nature and timing of the event.

1.6 State of Florida Upon notification of an emergency condition by SNC or the Alabama Emergency Management Agency, the Florida Department of Community Affairs, Division of Emergency Management, State Warning Point will implement the "State of Florida Radiological Emergency Management Plan for Nuclear Power Plants."

The Department of Community Affairs, Division of Emergency Management has the authority and responsibility for coordinating the efforts of local and state agencies in Florida to provide for the health and safety of the general public in the event of a radiological incident. The Department of Health-Bureau of Radiation Control will provide support to Plant Farley in matters related to the

            . Florida ingestion pathway radiological emergency response.

1.7 Local Organizations (SEP A.2.4, B.6.1) Principal activities of Local Emergency Management Agencies (LEMA) and Local Law Enforcement Agencies (LLEA) in Georgia, Alabama, and Florida are described in the respective State and County Emergency Operations Plans. 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. ES-4 to NL-16-0169 Farley Standard Emergency Plan Annex These resources include, but are not limited to, Local Law Enforcement Agency (LLEA) assets, fire fighting assets, medic;:il 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.

1. 7.2 Early County, Georgia (SEP A.2.4)

The Chairman, Early County Board of Commissioners, has responsibility for overall radiological emergency response planning. The actual plan development and coordination of emergency actions is carried out by the Blakely-Early County Emergency Management Agency. The "Blakely-Early County Emergency Management Agency Radiological Emergency Plan for Nuclear Incidents/Accidents Involving Joseph M. Farley Nuclear Power Plant" is given as part of the "State of Georgia 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. 1.7.3 Henry County The Probate Judge of Henry County will assume responsibility for Emergency Management operations and actions in the county. The Houston County Emergency Management Director will oversee and coordinate emergency operations within Houston and Henry Counties during an incident at Farley Nuclear Plant. Emergency Management will take actions as outlined in the Master Checklist Guide (Attachment 4 to Appendix 1 of the Basic Plan) to coincide with the current situation. Because of the limited EPZ area in Henry County the State of Aiabama REP directs Houston County to assume overall direction of emergency response. Notification of Henry County by Farley Nuclear Plant is met with the notification of Houston County. 1.7.4 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 ES-5 to NL-16-0169 Farley Standard Emergency Plan Annex the Incident Command Post, as applicable, based on the nature and timing of the event. 1.8 24-Hour Staffing (SEP F.1.2) Primary offsite authorities provide 24-hour-per-day staffing of communications links as follows:

State of Alabama
Alabama Emergency Management Agency.

State of Georgia:

Georgia Emergency Management Agency (GEMA).

Alabama Counties:

Houston County - Sheriffs Department.

Georgia County Authorities:

Early County - Sheriff's Department.

1.9 Hostile Action Based Events (SEP H.1.4) Agreements are in place with the states of Alabama and Georgia, Houston County, Alabama and Early County, Georgia to provide available resources and equipment to support mitigation and response to an emergency at Farley Nuclear Plant, including Hostile Action Based events. These resources include, but are not limited to, Local Law Enforcement Agency (LLEA) assets, Firefighting assets, medical support resources (including transportation), and coordination through an Incident Command Post. Requests for offsite resources and equipment will be communicated from the control room or site security to Houston County 911 Center, the EOC or through the Incident Command Post as applicable based on the nature of the event. Copies of these agreements are maintained in accordance with Emergency Plan procedures. ES-6 to NL-16-0169 Farley Standard Emergency Plan Annex E Figure 1.1.A - Location and Vicinity Map ES-7 to NL-16-0169 Farley Standard Emergency Plan Annex Warehouse N

High Voltag1: Switchyard Pi1ai1A I O\ltttQt t....._____...rf' *

                                                                                     ,......,---. &:~~ ~=
                                                                                      ~~tr:i                         0 0

0 0 Control OS(' 4'U{i* Pu~*

                                                                             \f* * *
                                                                                    ~.1~..-f-.1}-P-**-. ~.J.......... ,.

Figure 1.1.B - Joseph M. Farley Nuclear Plant Site Plan ES-8 to NL-16-0169 Farley Standard Emergency Plan Annex N NNE NNW NE NW ENE H-10 1-10 SSE SSW s Vt!rtlon2.0 IXV!J .. Joseph M. Farley Nuclear Plant + ~--- GiS SERVICES Emergency Planning Zone 10 Mile Radius Figure 1.2.A Mile Emergency Planning Zone (EPZ) ES-9 to NL-16-0169 Farley Standard Emergency Plan Annex llo..._ _ __,

                                                                                      /"t./

Joseph M. Farley Nuclear Plant .-.. /"V W ,,.,,._ Emergency Plan Map -. -..- O *-w:- 50 Mile Radius Figure 1.2.B- 50 Mile Ingestion Pathway IPZ E5-10 to NL-16-0169 Farley Standard Emergency Plan Annex Section 2: Organizational Control of Emergencies (SEP B.1) 2.1 Normal Plant Organization (SEP B.1) The normal plant operating crew is staffed and qualified to perform actions that may be necessary to initiate immediate protective actions and implement the emergency plan, and is designated as the responsible group for such actions. The normal plant organization is described in Section B.1 of the Emergency Plan. 2.2 Emergency Organization (SEP B.2, B.3) 2.2.1 The FNP On-Shift Emergency Response Organization is described in Table 2.2.A (SEP B.1). 2.2.2 The FNP Augmented Emergency Response Organization is described in Figures B.2.1.A, B.2.2.A, B.3.1.A, and B.3.2.A in the Emergency Plan (SEP B.2, B.3). An On-Shift Staffing Analysis was completed in accordance with the requirements of 10 CFR 50 Appendix E IV.A.9. This analysis forms the basis for the on-shift staff as described in Table 2.2.A. A copy of the analysis is maintained in the SNC document management system . ES-11

Enclosure 5 to NL-16-0169 Farley Standard Emergency Plan Annex Table 2.2.A- Farley Nuclear Plant On-Shift Staffing Major Functional Area Major Tasks Position On-Shift Emergency Direction Shift Manager (SM)/ 1 and Control Emergency Director (ED) Plant Operations and Shift Supervisor (SRO) 2 Assessment of Reactor Operator (RO) 4 Operational Aspects Shift Support 1 Supervisor/Fire Bri ~ade Leader (SRO/FBL) ote 1 System Operator (SO) Note 1 7 Plant System Technical Support Shift Support 1 Engineering , Repair Supervisor/Sh ift Techn ical and Corrective Actions Advisor (SRO/STA) Notification/ Notify licensee , state, local, and Licensed Operator (RO or Note 2 Communication federal personnel and maintain SRO) communication Radiological Accident Offsite Dose Assessment Chemistry Technician or 1 Assessment and other trained personnel Support of Operational In-plant surveys RP Technician or other 1 Accident Assessment tra ined personnel Offsite Surveys, Onsite (out-of- RP Technician or other 1 plant) trained personnel Protective Actions Radiation Protection : RP Technician 1

a. Access Control

b. RP Coverage for repa ir, corrective actions , search and rescue, first-aid , and firefighting

c. Personnel monitoring

d. Dosimetry Chemistry/Rad io-chemistry Chemistry Techn ician 1 Plant System Repa ir and Corrective Actions Maintenance Supervisor 1 Eng ineering, Repair and Corrective Actions Electrical Maintenance 1 Mechanical Maintenance 1 l&C Maintenance 1 Total : 25 1

Fire Fighting Fire Brigade Note 5 Rescue Operations and Rescue Operations/First 2 First Aid Aid Note2 Site Access Control Security Security and Personnel Plan Accountability Note 1 - Fire Brigade made up of FB Leader (SSS) and 4 System Operators not assigned safe shutdown responsibilities. Note 2 - May be provided by shift personnel assigned other functions ES-12 to NL-16-0169 Farley Standard Emergency Plan Annex 2.3 Non-SNC Support Groups (SEP B.4, B.5, B.6) 2.3.1 Fire Fighting (SEP B.6.4) 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. The Dothan Fire Department resources are listed in applicable site procedures. 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. Fire Drills are conducted annually and involve the Dothan Fire Department.

2.3.2 Hospital and Medical Support (SEP B.6.3, K.1.3, L.1) The detailed plans for the handling and care of injured personnel potentially contaminated and/or highly irradiated are contained in site procedures. A brief description of the facilities and services available for medical support is given below. 2.3.2.1 Southeast Alabama Medical Center The Southeast Alabama Medical Center in Dothan, Alabama, has agreed to receive and care for injured personnel that may be contaminated or irradiated. In addition to routine medical care; space has been provided for decontamination and emergency treatment and for storage of emergency medical equipment, monitoring equipment and dosimeters. Entrance to this facility will not affect the use of the hospital emergency room. 2.3.2.2 University of Alabama at Birmingham Hospital The Division of Oncology of the University of Alabama at Birmingham (UAB) Hospital in Birmingham, Alabama, has agreed to provide, on a priority basis, definitive care for irradiated and/or contaminated casualties. An area of the hospital has been modified to provide for such radiological emergencies. At the physicians' discretion, persons who have been exposed rnay be sent to UAB after receiving treatment at the Southeast Alabama Medical Center. 2.3.2.3 Oak Ridge Institute for Science and Education - REAC/TS The Oak Ridge Institute for Science and Education-REAC/TS team at Oak Ridge, Tennessee, has agreed to accept any type of radiation accident victim in need of hospitalization. At the physicians' discretion, persons who have been exposed may be sent to. ORISE-REAC/TS after receiving treatment at the Southeast Alabama Medical Center. ES-13 to NL-16-0169 Farley Standard Emergency Plan Annex 2.3.3 Ambulance Services (SEP B.6.2, L.4) Requests for ambulance 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. 2.3.3.1 Local Ambulance and Rescue Squads

Ashford Rescue Squad.
Columbia Rescue Squad.
Dothan Ambulance Service (Pilchers Ambulance Service), Inc.

2.3.4 Voluntary Assistance Group (SEP B.4.2) SNC is a signatory to two comprehensive agreements among electric utility companies:

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

2.3.5 Information for Transients (SEP G.8) Several communications methods may be used to acquaint the public with plans for their protection during a Plant emergency. Effort will be concentrated on providing information to the public by written material that is likely to be available in residences and in locations frequented by transients. The information will also provide instructions on which local media will be providing additional information in the event of an emergency. ES-14 to NL-16-0169 Farley Standard Emergency Plan Annex Section 3: Classification of Emergencies (SEP D.1) 3.1 Emergency Classifications: (SEP D.1) There are four classes of Emergency Action Levels based on severity, taking into consideration both potential and actual events in progress. They are, from the least to the most serious, Unusual Event, Alert, Site Area Emergency, and General Emergency. Initiating Conditions (ICs), which determine which level will be declared, are predetermined subsets of plant conditions where the potential exists for a radiological emergency, or such an emergency has occurred. Emergency Action Levels (EALs) are plant-specific indications, conditions, or instrument readings used to classify emergency conditions. 3.1.1 The described emergency classes and the emergency action levels are agreed on by SNC and state and local authorities. The emergency action levels will be reviewed by state and local officials annually. 3.2 Determination of Levels: (SEP D.1.2) Appendix B to this Annex contains the matrix for Initiating Conditions used to determine an Emergency Action Level (EAL). They are part of the scheme established by NEI 99-01, Methodology for Development of Emergency Action Levels. 3.3* Operating Mode Applicability (SEP D.2. 7) The plant operating mode that *existed at the time the event occurred, prior to 'any protective system or operator action initiated in response to the condition, is compared to the mode applicability of the EALs. If an event occurs, and a lower or higher plant operating mode is reached before the emergency classification level can be declared, the emergency classification level shall be based on the mode that existed at the time the event occurred. PWR Oper~ting Modes at FNP 1&2 Power Operations (1): Reactor Power> 5%, Kett~ 0.99 Startup (2): Reactor Power::; 5%, Kett~ 0.99 Hot Standby (3): RCS ~ 350 °F, Kett< 0.99 Hot Shutdown (4): 200 °F < RCS < 350 °F, Kett< 0.99 Cold Shutdown (5): RCS :s 200 °F, Kett< 0.99 Refueling (6): One or more vessel head closure bolts less than fully tensioned Defueled (None): All reactor fuel removed from reactor pressure vessel. (Full core off load during refueling or extended outage) E5-15 to NL-16-0169 Farley Standard Emergency Plan Annex Section 4: Emergency Measures (SEP E) 4.1 Notification of Off-Site Agencies (SEP E.2.2) 4.1.1 Notification Process (SEP E.2.2.1) State and local counties surrounding FNP will be notified within 15 minutes of the declaration of an emergency condition are: State of Alabama

Alabama Emergency Management Agency (AEMA).

State of Georgia:

Georgia Emergency Management Agency (GEMA).

Alabama County Authorities

Houston County - Sheriff's Dispatch Center.

Georgia County Authorities:

Early County - Sheriff's Dispatch Center.

4.2 Alert and Notification System (ANS) (SEP E.2.5) Within the Plume Exposure Emergency Planning Zone (EPZ), there exist provisions for alerting and providing notification to the public. The state and/or local authorities are responsible for activation of this system. The FEMA approved Farley ANS consists of a primary ANS and a backup system should there be a failure of the primary system.

Primary - Sirens and Emergency Alert System (EAS) stations
System Backup - Reverse calling system The primary ANS has two communications pathways. The first pathway is through the primary agency via the UHF or VHF radio. Should the primary agency fail to activate the system, the secondary pathway will be utilized by the secondary agency. The secondary pathway functions in the same manner as the primary pathway utilizing a separate activation console that is physically loc.ated in separate location. If neither agency can activate the system, the backup system will be utilized to notify the residents of the 10 mile EPZ.

The hierarchy for system activation is provided below: Agency Radio Systems Primary Agency UHF VHF Primary Sirens & EAS Secondary Agency UHF VHR Backup Each County EMA Calling System E5-16 to NL-16-0169 Farley Standard Emergency Plan Annex Alabama Georgia Primary Agency Houston County Early County Secondary Agency Henry County State of Georgia (GEMA) Primary alerting is accomplished by use of a siren system. 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(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. Special alerting uses a calling system. Special alerting is initiated in the event of a failure of the system to activate multiple sirens resulting in a loss of coverage in any area. special alerting may be initiated for a predefined area, a user specified area, user defined groups, or the entire Emergency Planning Zone (EPZ). The calling system serves as a complete independent backup to the ANS. The system provides both alerting and notification of EPZ residents independent of the alerting capabilities of the installed siren system and the notification capability of local radio and television stations through EAS. Capability to activate the calling system is provided by Houston County and Henry County, Alabama, and Early County, Georgia. A full description of the Farley ANS design is provided in the FEMA approved ANS Design located in the SNC document management system. Residents in the plume exposure pathway EPZ have been instructed to tune to specific emergency alert radio or TV stations if the sirens are activated. 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. 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. 4.3 Protective Actions for Onsite Personnel (SEP J.4) Protective response for onsite personnel (including visitors and contractor personnel)

depends on alerting, assembly and accountability, site evacuation, monitoring, and decontamination. Protective actions may also be taken for onsite personnel for emergencies such as fires, security related events, or natural disasters where personnel safety is threatened.
4.3.1 Alerting (SEP E.2.1, J.1)

Section E of the Emergency Plan (EP), Notification Methods and Procedures, describes the methods to alert onsite personnel of emergency conditions. 4.3.2 Assembly (SEP J.4.1) Personnel assembly is mandatory at the Site Area Emergency or higher level classification. Upon activation of the plant emergency alarm, plant personnel who are assigned specific emergency responsibilities will proceed to their designated emergency response locations. Assembly of site personnel who are outside the Protected Areas is accomplished by non-essential personnel reporting ES-17 to NL-16-0169 Farley Standard Emergency Plan Annex to designated assembly areas. Assembly may be initiated any time site management deems it appropriate for personnel safety reasons. Nonessential plant personnel located within the Protected Area will exit the protected area upon hearing the Site Area or the General Emergency alarm and report to designated assembly areas. Visitors, contractors, and escorted personnel will leave the protected area during an Alert or higher declaration. 4.3.3 Security Event~ (SEP J.4) Onsite protection of employees during security events involves a combination of restricted movement, movement to safe locations, and site evacuation depending on the nature of the event and advance warning. Specific actions to be taken during such events are included in site procedures. 4.3.4 Monitoring and Decontamination (SEP K) When an Alert is declared but no site evacuation is anticipated, personnel who have left the protected area are monitored by portal monitors. If necessary, decontamination is completed using the plant decontamination facilities located in the Auxiliary building or other onsite locations. For a Site Area Emergency or a General Emergency, or when site evacuation with monitoring is expected and release of radioactivity has occurred, monitoring is performed by Houston County and/or Alabama emergency workers at an established reception center. 4.4 Protective Actions for the Offsite Public (SEP J.5) The Emergency Director will recommend the necessary protective actions to offsite authorities, based on predetermined protective actions for a General Emergency Classification or results of offsite dose assessment. Upon activation of the EOF, the EOF Manager will be responsible for recommending protective actions for the offsite population. Responsibility for carrying out .the protective actions rests with offsite authorities. 4.4.1 Protective Action Recommendations (SEP J.5) Protective actions have been developed and agreed on with state and local authorities. They may include the following:

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

E5-18 to NL-16-0169 Farley Standard Emergency Plan Annex Section 5: Emergency Facilities and Equipment (SEP H) 5.1 Emergency Response Facilities (SEP H.1, H.2) 5.1.1 Control Room (SEP H.1.1) The Control Room contains the necessary im~trumentation, both process and radiological, to evaluate plant conditions, as detailed in the plant Final Safety Analysis Report. Habitability is maintained by shielding and by the Emergency Filtration Train (EFT) ventilation system, which is capable of operating in a cleanup or recycle mode. Alf plant emergency equipment is supplied power from the emergency diesel generators, with- vital instrumentation powered from inverters connected to the storage batteries located in the battery rooms. 5.1.2 Technical Support Center (SEP H.1.2) 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, waif 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. These records include but are not limited to:

Technical specifications.
Plant operating procedures.
Final safety analysis report.
Emergency Plan.
Emergency Plan Implementing Procedures.
Plant operating records.
System piping and instrumentation diagrams; heating, ventilation, and air-conditioning (HVAC) flow diagrams.
Electrical one-line, elementary, and wiring diagrams.
Control logic and loop diagrams.

The above records are updated as necessary to ensure currency and completeness. E5-19 to NL-16-0169 Farley Standard Emergency Plan Annex 5.1.3 Operations Support Center (SEP H.1.3) The break room adjacent to the TSC (outside the Technical Support Center) will serve as the Operations Support Center (Figure 5.1.B), from which 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 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. 5.1.4 Alternative Facility (SEP H.1.4) During a security-related event or other event that precludes onsite access, the TSC and OSC ERO staff will be directed to an alternative facility. This facility is located in the Alabama Power Company (APC) Old Crew Headquarters Building in Headland, Alabama. The alternative facility is equipped with the necessary communications and data links to support communications with the control room, site security, and the EOF. The available communications and

data links also provide access to SNC document management resources, work planning resources, plant technical data displays, and other SNC-specific resources for performing engineering assessment activities, including damage control team planning and preparation for return to the site. Guidance for the alternative facility activation and operation is provided in implementing procedures.
5.1.5 Emergency Operations Facility (SEP H.2.1)

The EOF is the central location for management of the offsite emergency response, coordination of radiological assessment, and management of initial recovery operations. The EOF is a dedicated facility located in Birmingham, Alabama, and serves as the EOF for SNC sites (VEGP, FNP, and HNP). Additional details of the EOF are in section H.2.1 of the Emergency Plan. A near site location is maintained at the FNP Training Center. It has space for members of an NRC Site Team and federal, state, and local responders, including space for conducting briefings with emergency response personnel and communications with other licensee and offsite emergency responders, access to plant data and radiological information, and access to copying equipment and office supplies. 5.1.6 Joint Information Center (JIC) (SEP H.2.2) The FNP JIC is located in Dothan, Alabama at the Houston County Juvenile Court Services Building. The JIC is the central location for the coordination and dissemination of information to news media and responses to public and media inquiries. Details of the JIC for FNP are in section H of the Emergency Plan. If the decision is made to activate the JIC, the CMC in Birmingham, Alabama will maintain emergency communications response coordination until the JIC is ready to assume these responsibilities. E5-20 to NL-16-0169 Farley Standard Emergency Plan Annex OPERATIONS SUPPORT CENTER (Room2452) AIRTIGHT DOOR TECHNICAL SUPPORT CENTER PLANNING AND COORDINATION AREA AIRTIGHT STAIRWELL DOOR MAIN ENTRY CONTROL ROOM Figure 5.1.A - Sample Technical Support Center E5-21 to NL-16-0169 Farley Standard Emergency Plan Annex Rm 2462 Rm2453 TSC Rm2454 Rad Side FAC Foreman*s Office Figure 5.1.B - Sample Operations Support Center ES-22 to NL-16-0169 Farley Standard Emergency Plan Annex 5.2 On-Site Communications (SEP F.1) Normal on-site communications is provided by the plant telephone system (network and commercial). The plant public address (PA) system also may be used for in-plant communications. The PA system is powered by normal plant 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. 5.3 Offsite Communications (SEP F.1) 5.3.1 Communications with the States and Local Counties (SEP F.1.2) The primary means of communication between FNP, the state of Alabama, state of Georgia, Houston County, and Early County is the Emergency Notification Network (ENN). The ENN is a dedicated communications system from the plant to the Alabama Emergency Management Agency Communication Center, Georgia Emergency Management Agency, the Houston County Sheriff's Dispatch Office, and the Early County Sheriff's Dispatch Office, which are staffed 24 hours per day. Extensions for this system are located in the Control Room, the TSC, and the EOF. 5.3.2 Alternate Offsite Communications (SEP F.1.1) Commercial telephones or land lines provide backup for the ENN. 5.4 Communications System Testing (SEP F.3) Communication channels with the state of Alabama, the state of Georgia, the plume exposure pathway EPZ counties, and the NRC (with the exception of EROS) are tested each calendar month, using the extensions in the Control Room, the TSC, and the EOF. EROS is tested each calendar quarter. Communications procedures and systems are also tested each calendar year. 5.5 Emergency Kits (SEP H.9) Emergency supplies and equipment are located at various places at the plant. 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. 5.6 Facilities and Equipment for On-site Monitoring (SEP H.5) The plant instrumentation and monitors perform indicating, recording, and protective functions. The Reactor Protection System and associated plant instrumentation provide the ability to maintain plant safety from shutdown to full power operations, and to monitor and maintain key variables such as reactor power, flow, temperature, and radioactivity levels within predetermined safe limits at both steady state conditions and during plant transients. Plant instrumentation and control systems also provide means to cope with abnormal operating conditions. The control and display of information of these various systems are centralized in the unit Control Room. This instrumentation would provide the basis for initiation of protective actions. E5-23 to NL-16-0169 Farley Standard Emergency Plan Annex 5.6.1 Geophysical Phenomena Monitors (SEP H.5.1) Meteorological (SEP H.5.1) A meteorological monitoring program is in place at 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 m and 45.7 m).
Wind direction (10 m and 45.7 m).
Vertical temperature difference (10 m and 60 m).
Ambient temperature (10 m and 60 m).
Dewpoint temperature (10 m).
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 froni 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. Hydrologic (SEP H.5.1) The plant is equipped with hydrologic monitors to monitor river water level and service water pond level. These monitors have readout and annunciation in the control room. Redundant river water level monitors provide control room indication from 65 to 130 feet MSL river level. A discussion of service water pond level monitors is given in FSAR Section 9.2.1.5. Seismic (SEP H.5.1) Various types of seismic instrumentation are located throughout the site, a number of which have readout and/or annunciation in the control room. A complete discussion of these monitors is given in FSAR Section 3.7.4. Seismic information may also be obtained from the National Earthquake Center in Golden, Colorado. 5.7 Protective Facilities and Equipment (SEP J) Assembly Areas (SEP J.4.1) In the event of a plant evacuation, the On-Site Assembly Areas (or Off-Site Assembly Areas, as appropriate) will be used. The function of the assembly area is to provide a E5-24 to NL-16-0169 Farley Standard Emergency Plan Annex 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. 5.8 Medical Support (SEP 8.6, SEP L) 5.8.1 Hospital and Medical Support (SEP B.6.3, L.1) Agreements are in place with the Southeast Alabama Medical Center, the University of Alabama in Birmingham (UAB) Hospital and Oak Ridge Institute for Science and Education to provide assistance for injured personnel, including cases involving radioactive contamination. This assistance will be requested whenever necessary in accordance with plant procedures. 5.8.2 Ambulance Service (SEP B.6.2, L.4) Injured or externally contaminated personnel who require medical attention will normally be transported by ambulance to the cooperating hospitals. Ambulance

                     . crews are trained to handle external contamination cases. Ambulance services are coordinated through the Houston County 911 center. Houston County maintains agreements with local fire and ambulance services that may respond toFNP.

ES-25 to NL-16-0169 Farley Standard Emergency Plan Annex Appendix A - Evacuation Time Estimate Study and Map Reference (SEP J.6) In order to ensure the safety of the public living in the vicinity of nuclear power plants in the nation, the U.S. Nuclear Regulatory Commission (NRC) requires licensees to develop and update evacuation times estimates (ETEs) for areas within the emergency planning zone (EPZ). Population reviews will be conducted annually using the most recent U.S. Census and local information. Updates are required following the availability of data from the decennial census (1 O years) or when the sensitivity factor for changes in population within the EPZ has been exceeded. This appendix contains information from the ETE update performed in 2012. This update implements the requirements of the revised regulations relevant to ETE updates in accordance with the guidance provided in NUREG/CR-7002, Criteria for Development of Evacuation Time Estimate Studies. Southern Nuclear Operating Company (SNC) contracted IEM to estimate evacuation times for the 2012 populations within the 10-mile plume exposure pathway emergency planning zone (EPZ) surrounding the Joseph M. Farley Nuclear Plant (FNP). This appendix provides a summary of the final report describing the methods used to obtain population data, and to estimate evacuation times, population figures, evacuation road network information, and ETEs. The report provides a breakdown of the population by geographic areas and protective action zones (PAZ). Five categories of population are identified in the report: Permanent residents. Transient population.

Transit dependent permanent residents.

Special facility residents.

Schools The permanent resident population is made up of individuals residing in the 10-mile EPZ. The total year 2012 permanent resident populations within the 10-mile EPZ for FNP are estimated to be 7, 188. The transient population consists of workers employed within the area, recreational sportsmen, and visitors. The total transient population within the 10-mile EPZ is estimated to be 4,734, which includes 600 transient workers at FNP. The school populations identified in the FNP EPZ include six schools, which are a combination of both public and private. In these analyses, IEM contacted the schools within the EPZ area to collect current enrollment and staff figures. The total peak population for the schools in the 10-mile EPZ is estimated to be 3,225.

Transit dependent permanent residents in the 10-mile EPZ are estimated to be 94. This study also considered the voluntary evacuees, who are also known as shadow evacuees and consist of 20% of the residents within 1O to 15 miles from FNP. IEM utilized a computer traffic simulation model, PTV Vision VISUM, to perform the ETE analyses. For the analyses, the 10-mile plume exposure pathway EPZ was divided into 25 unique geographic areas based on two-mile, five-mile, and ten-mile radius rings, the 16 22.5-degree PAZs, as well as keyhole and staged evacuation logic. In order to represent the most realistic emergency scenarios, evacuations for the 25 geographic evacuation areas were modeled individually for the midweek daytime, midweek - weekend evening, and weekend daytime scenarios. Each of these scenarios was then considered under both normal and adverse weather conditions using the 2012 population projections. A total of 150 evacuation scenarios were considered as part of this study to represent different wind, temporal, and seasonal weather conditions. Both 100% and 90% ETEs for each scenario were collected. The 100% ET Es for 2012 normal weather conditions ranged from 2 hours to 3 hours 20 minutes. The 100% ETEs for 2012 E5-26 to NL-16-0169 Farley Standard Emergency Plan Annex adverse weather conditions ranged from 2 hours 5 minutes to 3 hours 25 minutes. The 90% ETEs for 2012 normal weather conditions ranged from 1 hour 15 minutes to 1 hour 50 minutes. The 90% ETEs for 2012 adverse weather conditions ranged from 1 hour 20 minutes to 1 hour 50 minutes. The factors that contributed to the variations in ETEs between scenarios include differences in the number of evacuating vehicles, the capacity of the evacuation routes used, the type of warning systems Within the zones, or the distance from the origin zones to the EPZ bounda~.

Based on the data gathered and the results of the evacuation simulations, the existing evacuation strategy was determined to be functional for the 2012 conditions, given the lack of severe congestion or ve~ high ETEs. Recommendations were provided for enhancements to improve the evacuation time estimate.

Assumptions utilized in the ETE will be reviewed when evaluating changes to roadways or evacuation networks to ensure the results of the ETE remain valid. Changes in population will be evaluated utilizing the sensitivity factor developed during the ETE analysis. The full Evacuation Time Estimate was submitted for NRC review in accordance with NRC regulations 10 CFR 50, Appendix E, Section IV.3. Following the NRC review, the results of the study and recommendations were reviewed with applicable offsite agencies. The review focused on the utilization of the results of the evacuation simulations provided in the ETE for comparison to existing protective action strategies. Modifications were incorporated as part of the ongoing emergency planning process. (

Reference:

Evacuation Time Estimates Update dated November 26, 2013 NL-13-2340; ETE Report ETE-FNP-001; Annual ETE Review ETE-FNP-002). E5-27 to NL-16-0169 Farley Standard Emergency Plan Annex Appendix B - Emergency Action Level (EAL) Scheme (SEP 0.1) HOLD FOR EAL SCHEME ES-28 to NL-16-0169 Farley Standard Emergency Plan Annex Appendix C - Farley Nuclear Plant NUREG-0654 Cross Reference Table NUREG 0654 Rev 1 FNP SEP SNC SEP Section Ref Section Annex Criteria II.A - Assignment of Responsibility A.1 .a A.1 , A.2 , A.3, A.4 1.3-1 .9 A.1 .b Introduction Section 1: Introduction A.1 .c Figures B.2.1.A, B.2.2.A, B.3.1.A & -- B.3.2.A A.1.d B.3.1. 1 -- A .1.e B.1 Table 2.2.A A .2.a N/A N/A A .2.b N/A N/A A.3 A.5 1.3-1 .9 A.4 B.2, B.2.1.15, B.3.1.3 -- Criteria 11.B - Onsite Emergency Organization B.1 B.2 - B.2 B.1.1 Table 2.2.A B.3 B.1 .2 -- B.4 B.1.1, Figure B.2.A -- B.5 Tables 1 - 4 Table 2.2.A B.6 B.2, B.3, Figures B.2.1.A, B.2.2.A, -- B.3.1.A & B.3.2.A B.7 Tables 1-4 -- Figures B.2.1.A , B.2.2.A, B.3.1.A & B.3.2.A B.7.a B.2.1 .15, B.3.1.3 -- B.7.b B.3.1.2, B.3. 1.17 -- B.7.c B.3.1.1, B.3.1.2 -- B.7.d B.3.2.1, B.3.2.2, B.3.2.8 B.8 B.4 , C.4.2 2.3 B.9 B.6, K. 1 2.3 Criteria 11.C - Emergency Response Suooort and Resources C.1.a Section C -- C.1.b A.1 1.3 C.1.c A.1 .1, A.2, A.3 , C.1-C.4, F.1 Section 1 C.2.a N/A N/A C.2 .b A.1.1 , H.2.1 5.1.2 C.3 H.5.2.3, H.6.3 -- C.4 Sections A & C, B.4-B.6, H.6.3, L.1- 1.3 - 1. 9, 2.3, 5.8 L.4 Criteria 11.D - Emergency Classification System D.1 Section D Append ix B D.2 Section D Append ix B D.3 N/A NIA D.4 N/A N/A Criteria 11.E - Notification Methods and Procedures E.1 E.1.1 Append ix D E.2 E.2.1 -- E.3 E.2.2.2 -- E.4 E.2.2.2 -- E.4.a E.2.2.2 -- E.4.b E.2.2.2 -- E.4.c E.2.2.2 -- NOTE: N/A = Not required by Licensee in accordance with NUREG-0654 ES-29 to NL-16-0169 Farley Standard Emergency Plan Annex NUREG 0654 Rev 1 FNP SEP SNC SEP Section Ref Section Annex Criteria 11.E - Notification Methods and Procedures (continued) E.4.d E.2.2.2 -- E.4.e E.2.2.2 -- E.4.f E.2 .2.2 -- E.4.q E.2 .2.2 -- E.4.h E.2.2.2 -- E.4.i E.2.2.2 -- E.4.i E.2.2.2 -- E.4.k E.2.2.2 -- E.4.1 E.2.2.2 -- E.4.m E.2.2.2 -- E.4.n E.2 .2.2 -- E.5 N/A N/A E.6 E.2.5 E.7 E.2.6 -- Criteria 11.F - Emeraency Communications F.1.a F.1.1, F.1.2 4.1.1 F.1.b F.1.3 -- F.1.c F.1.4 -- F.1.d F.1.5 -- F.1.e F.1 .6 -- F.1.f F.1.4 -- F.2 F.2 -- F.3 F.3 5.4 Criteria 11.G - Public Education and Information G.1 G.1 -- G.2 G.8 2.3.5 G.3.a B.3.2.1, H.2.2, H.2 .3 5.1.6 G.3.b N/A N/A G.4.a B.3.2.8 -- G.4.b G.2 -- G.4 .c B.3.2.5, B.3.2.6 -- G.5 G.2 -- Criteria 11.H - Emergency Equipment and Facilities H.1 H.1.2 5.1.2 H.2 H.2.1 5.1.5 H.3 H.2.2, H.2.3 -- H.4 H.1 -- H.5 H.5 5.6 H.5.a H.5.1 5.6.1 H.5.b H.5.2 -- H.5.c H.5.3 -- H.5.d H.5.4 -- H.6.a H.5.1 5.6.1 H.6.b H.5.2 -- H.6.c H.5.2.3, H.6.3 -- H.7 H.6 -- H.8 H.7 5.6.1 H.9 H.1.3 5.1.3 H.10 H.8 -- H.11 H.9 -- H.12 H.10 -- NOTE: N/A = Not required by Licensee in accordance with NUREG-0654 E5-30 to NL-16-0169 Farley Standard Emergency Plan Annex NUREG 0654 Rev 1 FNP SEP SNC SEP Section Ref Section Annex Criteria II.I - Accident Assessment 1.1 1.1 -- 1.2 1.2 -- 1.3.a 1.3 -- 1.3.b 1.3 -- 1.4 1.4 -- 1.5 1.5 -- 1.6 1.6 -- 1.7 1.7 -- 1.8 1.8 -- 1.9 1.9 -- 1.10 1.7 -- 1.11 N/A N/A Criteria 11.J - Protective Response J.1.a J.1 -- J.1.b J.1 -- J.1.c J.1 -- J.1.d J.1 -- J.2 J.4 .3 -- J.3 J.2 -- J.4 J.3, J.4 .3 -- J.5 J.4.2, 4.3.2 -- J.6.a J.4 -- J.6.b J.4 -- J.6.c J.4 -- J.7 J.5 -- J.8 J.6 Aooend ix A J.9 N/A N/A J.10.a J.7 -- J.10.b J.7 -- J.10.c E.2.5 4.2 J.10.d N/A NIA J.10.e N/A NIA J.10.f N/A N/A J.10.g N/A N/A J.10.h N/A N/A J.10.i N/A N/A J.10.i N/A N/A J.10.k N/A N/A J.10.1 N/A N/A J.10.m J.5 -- J.11 NIA N/A J.12 N/A N/A Criteria 11.K - Radiological Exposure Control K.1.a K.1.1 -- K.1.b K.1 -- K.1.c K.1 -- K.1.d K.1 .2.1 -- K.1.e K.1 .2.1, K.5 -- K.1.f K.1.1.1 -- K.1.Q K.1.3 -- K.2 K.1 -- NOTE: N/A = Not required by Licensee in accordance with NUREG-0654 ES-31 to NL-16-0169 Farley Standard Emergency Plan Annex NUREG 0654 Rev 1 FNP SEP SNC SEP Section Ref Section Annex Criteria 11.K - Radiological Exposure Control (continued) K.3.a K.3 -- K.3.b K.3 -- K.4 N/A N/A K.5.a K.5 -- K.5.b K.5 -- K.6.a K.6 -- K.6.b K.6 -- K.6.c K.6 -- K.7 K.7 -- Criteria 11.L - Medical and Public Health Support L.1 L.1 -- L.2 L.2 -- L.3 N/A NIA L.4 L.4 -- Criteria 11.M - Recovery and Reentry Planninn and Post-Accident Operations M.1 M.1 -- M.2 M.2 -- M.3 M.3 -- M.4 M.4 -- Criteria 11.N - Exercises and Drills N.1.a N.1 -- N.1.b N.1 -- N.2.a F.3 -- N.2 .b N.2.3 -- N.2.c N.2.4 -- N.2.d N.2.5 -- N.2.e(1) N.2.6 -- N.2.e(2) N.2.6 -- N.3.a N.3 -- N.3.b N.3 -- N.3.c N.3 -- N.3.d N.3 -- N.3.e N.3 -- N.3.f N.3 -- N.4 N.4 -- N.5 N.5 -- Criteria 11.0 - Radiolog ical Emerqencv Response Traininn 0.1 0 .1 -- 0 .1.a 0 .1.1 -- 0 .1.b 0 .1.1 -- 0 .2 0 .3 -- 0 .3 0 .4 -- 0.4.a 0.4 -- 0.4.b 0.4 -- 0.4 .c 0.4.3 -- 0 .4.d 0.4.1, 0.4.4 -- 0.4.e 0.4.5 -- 0.4.f 0.4.6 -- 0.4.g 0 .1.1 -- 0.4.h 0 .1.1 -- 0.4.i 0.4 -- NOTE: NIA = Not required by Licensee in accordance with NUREG-0654 ES-32 to NL-16-0169 Farley Standard Emergency Plan Annex NUREG 0654 Rev 1 FNP SEP SNC SEP Section Ref Section Annex Criteria 11.0 - Radiological Emer:1encv Response Trainine1 (continued) 0.4.j 0.4, 0.4.7 -- 0.5 0.4 -- Criteria 11.P - Responsibility for the Planning Effort: Development, Periodic Review and Distribution of Emergency Plans P.1 0 .5, Section P -- P.2 Section P -- P.3 P.1 -- P.4 P.1 -- P.5 P.3 -- P.6 P.3 -- P.7 -- Aooe ndix D P.8 Table of Contents -- P.9 P.3 -- P.10 F.1.4 -- NOTE: N/A = Not required by Licensee in accordance with NUREG-0654 E5-33 to NL-16-0169 Farley Standard Emergency Plan Annex Appendix D - Supporting Plans & Implementing Procedures (SEP P.3) Supporting Plans

State of Alabama Radiological Emergency Response Plan
State of Georgia Radiological Emergency Plan
State of Florida Emergency Response Plan
Early County Georgia Emergency Response Plan
Houston County Alabama Emergency Response Plan
FNP Security Plan Administrative and Emergency Plan Implementing Procedures (EPIP)

Plan Section Title EPIP EPIP Title Section A Assignment of Respons ibility NMP-EP-300 SNC Emergency Preparedness (under Conduct of Operations development) FNP-O-EIP-0.0 Emergency Organization B Emergency Response NMP-EP-146 ERO Position Checklists Organization FNP-O-EIP-4 .0 Health Physics Support to the Emergency Plan FNP-O-EIP-5.0 Maintenance Support to the Emergency Plan FNP-O-EIP-7.0 Security Support to the Emergency Plan FNP-O-EIP-20.0 Chemistry and Environmental Support to the Emeq::iency Plan c Emergency Response Support and NMP-EP-300 SNC Emergency Preparedness Resources (under Conduct of Operations development) D Emergency Classification System NMP-EP-141 Emergency Classification FNP-O-EIP-1 .0 Duties of An Individual Who Discovers an Emergency Condition E Notification Methods and NMP-EP-142 Emergency Notification Procedures NMP-EP-308 SNC Emergency Alert Siren Operation , Testing And Maintenance F Emergency Communications NMMP-EP-300 SNC Emergency Preparedness (under Conduct of Operations development) FNP-O-EIP-2 .0 Handling of Incoming Calls During Emergencies or Emergency Exercises FNP-O-EIP-8.0 Non-Emergency Notifications FNP-O-EIP-8.1 Emergency Phone Directory FNP-O-EIP-8.2 Plant Personnel Home Telephone Directory FNP-O-EIP-8.3 Communications Equipment Operating Procedures ES-34 to NL-16-0169 Farley Standard Emergency Plan Annex Plan Section Title EPIP EPIPTitle Section G Public Education and Information NMP-EP-203 Corporate Media Center Operations NMP-EP-204 Emergency News Center/Joint Information Center Operations NMP-EP-205 Emergency Communications News Releases NMP-EP-206 Emergency Communications News Briefings NMP-EP-207 Emergency Communications Public

Response

H Emergency Facilities and NMP-EP-143 Facil ity Activation Equ ipment NMP-EP-305 Equipment Important to the EP Function FNP-O-EIP-16.0 Emergency Equipment and Supplies I Accident Assessment NMP-EP-140 Accident Assessment J Protective Response NMP-EP-144 Protective Actions FNP-O-EIP-11 .0 Handling of Injured Personnel FNP-0-EI P-14.0 Emergency Response Teams K Rad iological Exposure Control NMP-EP-144 Protective Actions FNP-O-EIP-4 .0 Health Physics Support to the Emergency Plan FNP-O-EIP-20.0 Chemistry and Environmental Support to the Emergency Plan L Medical and Public Health Support NMP-EP-300 SNC Emergency Preparedness (under Conduct of Operations development) M Recovery and Re-entry Planning NMP-EP-145 Term ination and Recovery and Post Accident Operations N Exercises and Drills NMP-EP-303 Drill and Exercise Standards 0 Radiological Emergency Response NMP-EP-301 EOF Emergency Response Training Organization And EP Staff Training p Responsibility for the Plann ing NMP-EP-300 SNC Emergency Preparedness Effort NMP-EP-310 Conduct of Operations NMP-EP-312 Maintaining The Emergency Plan NMP-TR-104-006 Development Of Emergency Preparedness Technical Products SEPTOC E5-35

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 (Marked-Up Pages and Clean Copy) to NL-16-0169 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, Florida offsite resources are individually (Ingestion pathway only for Plant Farley) and discussed below. The onsite and individual counties. offsite organizations provide +l=leFe aFe Sblf3f38FtiA§ aAEl G9FflJ3leFfleAtiA§ emergency response during the eFftOF§eAGy 13laAS, iAGlblEliA§ tl=leso ef foEloFal activation , emergency, and recovery a§eAGios, tl=lo states ef Ala9aFfla, GoeF§ia, phases of accident response . ~ebltR GamliAa, aAEl iAEli*.iiElblal G9blAties. Principal federal , state, local and SNC has overall responsibility for maintaining a private agencies are also discussed. state of readiness to implement this Plan for the Figures 12 and 13 illustrate the protection of plant personnel, the general interrelationships of these public, and property from hazards associated organizations before and after with any facility operated by the company. Emergency Operations Facility There are three phases of responsive action activation respectively. contained within 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 as Unusual Event, Alert, Site Area Emergency, or General Emergency. E6-5 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Section 11.A.1 .a: a. Emergency EP 8.1.1: 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. In responsibility of overall direction of an emergency, the SM assumes the position of the Emergency Director (ED) and takes necessary onsite emergency activity including actions to identify and respond to the emergency near-site field monitoring team until relieved by another qualified ED. dispatch and control and interfacing with offsite organizations and EP 8.2.1.1 TSC Emergency Director (ED) agencies until the Emergency Tho TSC e:O has tho ablthority an9 responsibility to Operations Facility (EOF) is immo9iatoly initiate any emergency actions The activated . After the EOF is TSC ED has the authority and responsibility to functional , the ED is responsible for immediately initiate any emergency actions. Once overall direction of all in-plant transfer of Command and Control has been completed, the TSC ED assumes the non-delegable emergency activity. The ED shall duties of event Classification, on-site Emergency supervise the TSC , and manage the Exposure Authorization , and on-site protective in plant recovery efforts and the in actions. plant recovery organization. The ED shall commun icate directly with the . Onco Comman9 an9 Control has boon comploto9 , EOF Manager when the EOF is tho TSC ED assblmos tho non 9ologablo Gbltios of activated and shall have full authority event Classification, on site Emergency Exposblro to direct the onsite recovery efforts ablthorization , an9 on site protective actions. without further consultation when the EP 8.3.1.1 EOF Emergency Director situation demands such action. The EOF ED has overall coordinating authority for Following EOF activation when t ime Southern Nuclear Company resources. Upon EOF permits the ED will consult with EOF activation, the EOF ED accepts responsibility for personnel prior to initiating major Notification and Protective Action Recommendation evolutions or changes in plant functions from the Control Room . The EOF ED is configuration . also responsible for keeping SNC corporate management informed regarding the emergency response and Classification upgrades. E6-8 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description The ED's general responsibilities include: EP B.1.1: The Shift Manager (SM) is in direct The wording was standardized and relocated to

1) Staffing the TSC . The TSC will be charge of shift plant operations and is directly the SNC Standard Emergency Plan.

staffed by plant supervisory personnel responsible for the actions of the on-shift crew. In supplemented by plant engineering , an emergency, the SM assumes the position of the technical and administrative personnel as Emergency Director (ED) and takes necessary necessary to staff the TSC 24 hours a actions to identify and respond to the emergency day and discharge the responsibilities until relieved by another qualified ED. discussed below. EP B.2.1.1 TSC Emergency Director (ED)

2) Evaluating the classification of the The TSC ED has the authority and responsibility to emergency and amending as immediately initiate any emergency actions. Once appropriate. Terminating an emergency transfer of Command and Control has been level will not be delegated to other completed, the TSC ED assumes the non-delegable elements of the emergency organization duties of event Classification, on-site Emergency and will be performed in accordance with Exposure Authorization , and on-site protective approved procedures. actions.

3) Verifying correct control room The TSC ED has the authority and responsieility to 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 duties of e 1ent Classifisation, on site Emergensy 1

delegated to any other element of the Exposure ,A.uthorization, and on site protestive emergency organization. astions.

5) Initiating, on initial or upgrade Onse Command and Control has eeen sompleted ,

emergency notifications, the TSC ED assumes the non delegaele duties of recommendations to state agencies on event Classifisation, on site Emergensy Exposuro advisability of evacuations. authorization, and on site protestive astions. Recommendations to local agencies EP B.3.1.1 EOF Emergency Director when state authorities cannot be The EOF ED has overall coordinating authority for contacted for immediate evacuation may Southern Nuclear Company resources. Upon EOF not be delegated to any other element of activation, the EOF ED accepts responsibility for the emergency organization. Notification and Protective Action Recommendation

6) Initiating rescue or emergency repair functions from the Control Room . The EOF ED is operations as appropriate. also responsible for keeping SNC corporate

7) Maintaining plant security. management informed regarding the emergency

8) Establishing communications with and response and Classification upgrades.

providing information to the EOF Manager. E6-9 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description The ED position is initially filled by EP 8.1.1: 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 rel ieved by another qualified ED . EP 8.2.1.1 TSC Emergency Director (ED) The TSC ED has the authority and responsibility to immediately initiate any emergency actions. Once transfer of 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 . The TSC ED has the authority and responsibility to immediately initiate any emergency actions. Once Command and Control has boon completed , the TSC ED assumes the non delegable duties of event Classification, on site Emergency Exposure authorization, and on site protective actions. EP 8.3.1.1 EOF 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. E6-11 to NL-16-0169 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 The responsibility to provide radiological support Medical Center, during transport of measured radiological values in the to offsite medical response was maintained in the potentially irradiated and/or environment. standard plan but removed from a specific contaminated casualties, and at the EP 1.7 The capability to take offsite soil , water, responsibility of the field teams to allow a more Assembly Areas, and at any other and vegetation samples is provided by a flexible response. location onsite or offsite as instructed minimum of two (2) Field Monitoring Teams by the Emergency Director (ED) or (FMTs). EOF Manager. Field Monitoring T earns 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 L.4 Medical Transport technician. Contaminated and injured persons are Assistant - Any qualified plant transported to a facility specified for SNC-employee or vendor personnel. operated nuclear power plants. Arrangements have been made by nuclear power plants for ambulance transport of persons with injuries involving radioactivity to designated hospitals. Such services are available on a 24-hour-per-day basis and are confirmed by letters of agreement. Radiation monitoring services are provided by SNC plant personnel whenever it becomes necessary to use an ambulance service for the transportation of contaminated persons. E6-20 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Normally, dose projections are EP 8.3.1.4 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 EOF 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 EOF; and coordinates communication of Emergency Notification System resu lts with offsite agencies . (ENS) , Health Physics Network EP 8.3.1.13 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 Assignments EP 8.2.2 Operations Support Center (OSC) The wording was standardized and relocated to 1} 012erations Su1212ort Center (OSC} EP 8.2.2.1 OSC Manager the SNC Standard Emergency Plan.

Manager 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. The senior individual referenced in the current coordinating the activities of the OSC J.4.1 Assembly Plan is not an ERO assigned position. In or other location directed by the Assembly is mandatory following the accordance with existing procedures, the most Emergency Director per FNP-0-EIP- declaration of a Site Area or General senior person responding takes on a general 5.0. The senior individual at each of Emergency, or at the discretion of the leadership role in that area. Standard Emergency the Assembly Areas will become the Emergency Director. When Accountability of Plan Section J.4.1 , Assembly, has been revised to supervisor at that location. The onsite personnel is determined to be necessary Assembly Area senior individual will by the Emergency Director, personnel within the include the statement with respect to assumption take the lead in coordinating the Protected Area will be accounted for and the of leadership responsibilities at an assembly area. activities of the Assembly Area in names of missing individuals determined within support of OSC operations as 30 minutes of the emergency declaration. directed by the OSC Manager. The Assembly Area senior individual will take the lead in coord inating the activities of the Assembly Area in support of OSC operations as directed by the OSC Manager. E6-22 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

1. Emergenc)'.'. 012erations Facilit)'.'. EP 8.3 Offsite Emergency Response The offsite organization is integrated into the SNC (EOF) 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 8.2.D and 8 .2.E. The EOF and JIC Organizations may also include state and local personnel.

2. Cor12orate Organization 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) . The EOF is procedurally required to be activated within 75 minutes following the declaration of an Alert or higher classification ~taHiRJ aREI astivatieR ef U:ie eGi;; is maRElatery upeR EleslaratieR ef aR Alert er t:liJt:ler slassifisatieR. E6-27 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

1. Government Agencies 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 is the coordinating agency for plan in NUREG-0728, specifying incidents at or caused by a facility or an activity NRC actions , responsibilities , that is licensed by the NRC or an Agreement functions and authorities during an State, with the Chairman of the Commission as emergency. the senior NRC authority for response . The Chairman can transfer control of emergency response activities when deemed appropriate. The NRG acts as the lead federal agency for technical Fflatters d1::1ring a n1::1clear incident, with tho Chairfflan ef the Cefflfflissien as tho sonier ~JRC a1::1therity fer res13enso. Tho Chairfflan can transfer centrel ef efflergency res13ense activities when deeffled a1313rewiato. 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 8.5 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(8) . E6-37 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

b. Nuclear Regulato[Y 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 is the coordinating agency for the incident response plan described incidents at or caused by a facility or an activity in NUREG-0728. In addition to that is licensed by the NRC or an Agreement fulfilling its regulatory responsibilities , State.acts as the lead federal agency for it is expected that the NRC will technical ffiatters dl:lring a nyclear incident, provide techn ical assistance and with the Chairman of the Commission as the recommendations . For Site Area and senior NRC authority for response. The General Emergencies, dispatch to Chairman can transfer control of emergency SNC facilities of a NRC Region II site response activities when deemed appropriate. team is anticipated with arrival Incident Response Centers have been expected 2 to 6 hours following established at the four NRC Regional Offices notification. As described in Section and NRC Headquarters, to centralize and Ill, office space, telephones, etc. coordinate NRC's emergency response. have been provided for NRC Provision is made for NRC personnel at the personnel at the Technical Support plant's Technical Support Center and the Center and Emergency Operations Emergency Operations Facility. Facility. E6-39 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

c. State of Alabama EP A.2.1 State of Alabama The wording was relocated and transferred to the SNC The Alabama Radiation Control Division of the The Governor of the State of Alabama has overall responsibility for Standard Emergency Plan .

State of Alabama Department of Public Health emergency preparedness and response concerning an incident at a NPP. is responsible for initiating the "Alabama Alabama law designates the Alabama Department of Public Health, Office of Radiation Control (ADPH-ORC) as the agency responsible for issuing any Radiological Response Plan for Nuclear order requiring actions to be taken necessary to meet the emergency. In day-Power Plants' in support of an emergency at to-day operations this function is fulfilled by the ADPH-ORC. the Farley Nuclear Plant. This plan provides a The Governor has charged the Alabama Emergency Management Agency detailed description of the notification Director with the responsibility of coordinating the activities of departments. procedures and responsibilities and duties of agencies, and organizations of state government and local emergency management agencies to carry out emergency functions relating to a NPP the local and state agencies involved . Since incident. These assigned responsibilities merge in the joint development and the primary concern of the Alabama Radiation issuance of this plan by the ADPH-ORC and the Alabama Emergency Control Division is for the welfare and safety of Management Agency. the general public, they will have primary EP A.2.1.1 Alabama Emergency Management Agency (AEMA) responsibility and authority for handling the The Alabama Emergency Management Agency (AEMA) is the primary offsite offsite aspects of the emergency in Alabama. agency for radiological emergencies. The station sends emergency notifications to the 24 hour notification point maintained by 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

                                                 +Re-Ala9aFfla eFfle*geRoy ' ~aRageFfleRt *geAoy oea*siAates the l'lasielag1sal eFfle*geAoy PlaAs aAs ellsite epe*atieRs ef alfeGled-slate ageAoies aAs leoal Q0"BFAmonts. iAGl1::19ing netifisat1en ef state anEJ lesal agenGtes ef a nuslear 1ns19oi:it at a n1:1slear fJewor fJlaRt 1mfJast1Rg tRo state ef 0 1al3ama, Sirostlon of aotl"1t1es at the state eFfle*geAoy Ope*at1eAs CeAte" oee*d1AatieA ef ASA
                                                 *as1eleg1oal epe*atieAs with *lil1ty aAs fede*al a*the*it1es, aAd oeerd1AatieA ef ne"'s iRfermatien.

EP A.2.1.2 Alabama Department of Public Health, Ottice of Radiation Control (ADPH-OR C) The Alabama Department of Public Health Office of Radialion Control (ADPH-ORC) provides technical support to AEMA. They perform radiation moniloring of areas around the station and provide the results back to AEMA. Communications of events are transmitted to AEMA who in turn informs ADPH-ORC with lhe information. This relationship is further defined in the FEMA approved state emergency plan. Through the Alabama Department of Public Heallh, 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.

                                                 ~he Alal3aFfla De~aFtFfleAt ef P*l31io Health , the *1al3aFfla OHiee af l'ladiat1aA Ca Atral 1s *espaAsil31e fa* 1Ait1at1Ag the ** 1al3aFfla l'lasialagisal l'les~aAse PlaA fa* N*slea r Pe*" e' PlaAts' iA s*ppeFt af aA eFflergeAsy at the
                                                 ~arley N"olear PlaAt. The state plaA weuises a setailes sessriptieA ef the Aetifioa11eA prnoes*res aAs the res~eAsil3ilities aAs s*t1es af the lesal aAd state ageAs1es 1A"elues. The *1al3aFfla OHise ef l'lasiatiaA CaAtrel has pnFflal')I
                                                 *es~eAs1l31ht y aAs a* thenty fer haAdl1Ag the affs11e as~eot s af aA eFflergeAsy IA

lal3aFfla "'1th P""'B'Y fao*s eA the "'elfare aAs safety ef the geAeral P*l3l1e.

EP A.2.1.3 Other Alabama State Agencies Responsibilities of other state agencies are described in the Alabama Rad iological Response Plan for Nuclear Power Plants. E6-40 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description EP A.2.1 State of Alabama An agreement is in place with the The wording was relocated and transferred to the State of Alabama to provide The Governor of the State of Alabama has overall responsibili ty for SNC Standard Emergency Plan. emergency preparedness and response concerning an incident at a NPP. available resources and equipment Alabama law designates the Alabama Department of Public Health, Office of Radiation Control (ADPH-ORC) as the agency responsible for issuing any to support the mitigation and order requiring actions to be taken necessary to meet the emergency. In day-response to an emergency at Plant to-day operations this !unction is fulfilled by the ADPH-ORC. Farley to include Hostile Action The Governor has charged the Alabama Emergency Management Agency Director with the responsibility of coordinating the activities of departments, Based events. These resources agencies, and organizations of state government and local emergency management agencies to carry out emergency functions relating to a NPP include, but are not limited to, Local incident. These assigned responsibilities merge in the joint development and Law Enforcement Agency (LLEA) issuance of this plan by the ADPH-ORC and the Alabama Emergency Management Agency. assets, Fire Fighting assets, medical EP A.2.1.1 Alabama Emergency Management Agency (AEMA) support resources (including The Alabama Emergency Management Agency (AEMA) is the primary offsite transportation), and coordination agency for radiological emergencies. The station sends emergency notifications to the 24 hour notification point maintained by AEMA. through an Incident Command Post. The Alabama Emergency Management Agency coordinates the Radiological Requests for offsite resources and Emergency Plans and offsite operations of affected state agencies and local equipment will be communicated governments including notification of state and local agencies of a nuclear incident at a nuclear power plant impacting the state of Alabama, direction of from the control room to the Houston activities at the state Emergency Operations Center, coordination of non-radiological operations with utility and federal authorities, and coordination of County 911 center, the county EOC, news information or through the Incident Command EP A.2.1.2 Alabama Department of Public Health, Office of Radiation Control Post, as applicable, based on the The Alabama Department of Public Health Office of Radiation Control (ADPH-ORC) provides technical support to AEMA. They perform radiation monitoring nature and timing of the event. of areas around the station and provide the results back to AEMA. Communications of events are transmitted to AEMA who in turn informs ADPH-ORC with the information. This relationship is further defined in the FEMA approved state emergency plan. 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.EP 0 2 1 Stat e of Alabama

                                      -~-~

TRe AJabaFRa i;.FAeFgeRGY t4aRagei:ReRt " geRsry Geerd1Rates the Radielegisal i;FAergeRsy PlaRs aRd etfeite eperatieRs ef aJfeGt&d state ageRsies aRd lesal ge.,emmeAts 11u:l1:1diRg RelifisatieR 9f state aRd lesal ageRsies ef a RYslear iRsideRI al a R' slear pe"'er plaRt lmpasllAg tRe state gf AJabaFRa . dir&Gt1eR ef aGIP'rl1es at tl:le state t;;mergeRsy OperalieR& CeRler, seer:Q1RatieR ef RSA radiele91sal eperatieRs "~tR wt1lity aRd lederal al:MReRl1es aRd seerdiRalie R gf Re' '6 iRfeFFRat1eR

                                      ~l abama Cepartmant ef Publie H H lthr--RadiatioA-CGRt~isie>A Tl:lrewgl:I tl:le bJabama QepaFtment ef Pwl:llis Mealll:I , tRe 0 1al:lama RadialleR GaRIFQI Q~

is1aR Is re&pen&il:lle fer 1Ritia11R9 ll:le "0 1al:lama Radiele91sal RespeRse PlaR fer f>lyslear Pe er PlaRts*

1R sYppeFt ef aR emergeRsy al tRe l=ai:tey fllt1slear PlaRt Tl:le state plaR pre.,ides a detailed de&GnplteR ef IRe RetilisatieR presed<1res aRd tRe respeRsil:lililles and dt11ies ef tl:le lesal and slate ageRsles IR"9i"ed. Tl:le '\lal:lama Rad1atieR CeRIF91 01* 1sieR !:las primapt respeRs11:lility a.Rd a1Al:ler1ty fer l:laRdliRg tl:le effs11e aspests af aR emergeRsy iR 0 tal:lama "'ill:I primai:y fgs1:.1s eR tRe "'elf are and safety af tRe geReral pYblis iiP 6 a 1 ;ll Oll:l ar Mabama Sitate 0 gaR GIH RespeRS*l:liliHes at atl:ler stale ageRsies are dessnl:led iR tl:le "laba!fla Rad1ele91sal i=lespeR&e PlaR fer f>h 1slear Pe"'er PlaRI&. E6-41 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

d. State of Georgia EP A.2.2 State of Georgia The wording was relocated and transferred to the The Governor is authorized and empowered under Official SNC Standard Emergency Plan.

Upon notification of an emergency Code of Georgia Annotated (O.C.G.A.) § 38-3-22: condition , the Georgia Emergency To have general direction and control of the Georgia Management Agency will implement Emergency Management Agency and to be responsible the "State of Georgia Radiological for the carrying out of the provisions of this chapter, and , in the event of disaster or emergency beyond local control , Emergency Plan" . The Georgia may assume direct operational control over all or any part Emergency Management Agency of the emergency management functions within this state. has the authority and responsibility The Governor's Executive Order provides current for coordinating the efforts of local authority and assignment of the various emergency response functions to the appropriate state agencies. and state agencies in Georgia to provide for the health and safety of EP A.2.2.1 Georgia Emergency Management Agency the general public in the event of a (GEMA) radiological incident. As the overall state coordinating agency GEMA will coordinate with Department of Natural Resources-Environmental Protection Division (DNR-EPD) on emergency response activities with state, county and municipal agencies and departments as stated in the Georgia Emergency Operations Plan (GEOP). GEMA provides for 24-hour notification and staffing of the State Operations Center (SOC) and/or the Forward Emergency Operations Center (FEOC) , as required , throughout the event. GEMA is responsible for general state emergency planning and overall direction , and control of emergency or disaster operations as assigned by executive order and in accordance with the Georgia Emergency Operations Plan (GEOP). GEMA has responsibilities for coordinating the state of Georgia response to emergencies at nuclear power plants . EP A.2.2.2 Department of Natural Resources-Environmental Protection Division (DNR-EPD) Department of Natural Resources-Environmental Protection Division (DNR-EPD) is assigned as the coordinating and a primary agency responsible by Executive Order for implementation and administration of the state radiological and hazardous material function . 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 to NL-16-0169 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 The Governor is authorized and empowered under Official State of Georg ia to provide available SNC Standard Emergency Plan. Code of Georgia Annotated (O.C.G.A.) § 38-3-22 : resources and equipment to support To have general direction and control of the Georgia the mitigation and response to an Emergency Management Agency and to be responsibl e emergency at Plant Farley to include for the carrying out of the provisions of this chapter, and , in the event of disaster or emergency beyond local control , Hostile Action Based events. These may assume direct operational control over all or any part resources include, but are not limited of the emergency management functions within this state. to, Local Law Enforcement Agency The Governor's Executive Order provides current authority (LLEA) assets, Fire Fighting assets, and assignment of the various emergency response functions to the appropriate state agencies. medical support resources (including transportation) , and coordination EP A.2.2.1 Georgia Emergency Management Agency through an Incident Command Post. (GEMA) Requests for offsite resources and As the overall state coordinating agency GEMA will coordinate with Department of Natural Resources-equipment will be communicated Environmental Protection Division (DNR-EPD) on from the control room to the Early emergency response activities with state, county and County 911 center, the county EOC , municipal agencies and departments as stated in the or through the Incident Command Georgia Emergency Operations Plan (GEOP). GEMA provides for 24-hour notification and staffing of the State Post, as applicable, based on the Operations Center (SOC) and/or the Forward Emergency nature and timing of the event. Operations Center (FEOC), as required , throughout the event. GEMA is responsible for general state emergency planning and overall direction, and control of emergency or disaster operations as assigned by executive order and in accordance with the Georgia Emergency Operations Plan (GEOP) . GEMA has responsibilities for coord inating the state of Georgia response to emergencies at nuclear power plants. EP A.2.2.2 Department of Natural Resources-Environmental Protection Division (DNR-EPD) Department of Natural Resources-Environmental Protection Division (DNR-EPD) is assigned as the coordinating and a primary agency responsible by Executive Order for implementation and administration of the state radiological and hazardous material function . 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 Responsibi lities of other state agencies are described in the Georgia Emergency Operations Plan (GEOP). E6-43 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

h. City of Dothan. Alabama - Fire Annex 1.7.3 Henry County Henry County because of its limited Department The Probate Judge of Henry County will exposure is managed through the State In the event an emergency (Section assume responsib ility for Emergency of Alabama REP Plan . Specifically, IV) is declared as a result of a fire at Management operations and actions in the Henry County is not notified by FNP.

Farley Nuclear Plant, the Dothan Fire county. Henry County notification requirements Department has agreed to provide The Houston County Emergency Management for Plant Farley are met through the support to help combat the fire . The Director will oversee and coordinate notification of Houston County. In Dothan Fire Department resources emergency operations within Houston and accordance with the State of Alabama are listed in FNP-O-EIP-13, "Fire Henry Counties during an incident at FNPP. REP Plan : Emergencies". The estimated Emergency Management will take actions as "The Chairman of the Houston County response time to Farley Nuclear outlined in the Master Checklist Guide Commission and the Probate Judge of Henry Plant is 30 minutes. The Emergency (Attachment 4 to Appendix 1 of the Basic Plan) County will assume responsibility for all Director is authorized to request this to coincide with the current situation. Emergency Management operations and actions assistance. Request for fire support Because of the limited EPZ area in Henry in their counties . will be made by the control room or County the State of Alabama REP Plan directs The Houston County Emergency Management site security to the Houston County Houston County to assume overall direction of Director will oversee and coordinate emergency 911 center, Houston County EOC , or emergency response. Notification of Henry operations within Houston and Henry Counties the Incident Command Post, as County by FNP is met with the notification of during an incident at FNPP. Emergency applicable, based on the nature and Houston County. Management will take actions as outlined in the timing of the event. Master Checklist Guide (Attachment 4 to Annex 1.7.43 City of Dothan, Alabama (SEP Appendix 1 of the Basic Plan) to coincide with the B.6.4) current situation." In the event an emergency is declared as a Section 1.7.3 of the Farley Annex has been result of a fire at Farley Nuclear Plant, the revised to clarify Henry County responsibilities for Dothan Fire Department has agreed to provide implementation of the Farley Emergency Plan is support to help combat the fire . The estimated provided as part of the RAI response . response time to Farley Nuclear Plant is 30 The wording was relocated and transferred to the minutes. The Emergency Director is Site Annex. 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. E6-48 to NL-16-0169 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

Air Particulate detectors capture and itemized listing can be found in FNP- measure airborne particulate.

O-EIP-16, "Emergency Equipment Emergency response procedures provide and Supplies". methods for determining relationships between monitor readings and releases, material 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-O- 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 . E6-72 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Results of dose estimates and EP 1.3 Offsite 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 avai lable 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 capab ility. The MIDAS model meets all The program estimates reactor source term, existing regulatory requirements , so the ARDA atmospheric transport, and doses resu lting 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 condit ions wil l not be precisely known. EP J.5 Offsite Protective Action Recommendations (PARsS) Plant conditions, projected dose and dose rates and field monitoring data are . communicated to offsite agencies responsible for dose assessment/PARs to assist them in developing parallel assessments. E6-79 to NL-16-0169 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 transpo rtation as necessary. Evacuation of personnel is usually conducted immed iately 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, EP J.4.1 Assembly The wording was relocated and transferred to the General Emergency, or an Alert be Assembly is mandatory following the SNC Standard Emergency Plan . declared , immediate notification of all declaration of a Site Area or General persons onsite may be accomplished Emergency, or at the discretion of the The senior individual referenced in the current by sounding the Plant Emergency Emergency Director. When Accountability of Plan is not an ERO assigned position. In Alarm and announcing the cond ition onsite personnel is determined to be accordance with existing procedures, the most over the plant public add ress system. necessary by the Emergency Director, senior person responding takes on a general Personnel onsite would report to personnel within the Protected Area wi ll be leadership role in that area. Standard their pre-assigned assembly area accounted for and the names of missing Emergency Plan Section J.4.1, Assembly, has and preparations for evacuation of individuals determined within 30 minutes of the nonessential persons from the site emergency declaration. been revised to include the statement with would begin. Depending on the respect to assumption of leadership The Assembly Area senior individual will take responsibilities at an assembly area. severity of the emergency condition , the lead in coordinating the activities of the these individuals will be held in an Assembly Area in support of OSC operations assembly area, evacuated , or as directed by the OSC Manager. returned to work. E6-1 04 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. The current Plan had significant detail that South and County Road 42 West Personnel will be directed to either proceed to included information that may not be appropriate (Figures 17 and 19). All personnel their homes or reassemble at designated to a specific event. Planned evacuation routes being evacuated from the site will be locations. Visitors to the plant will assemble are useful to maintain in an EPIP but may require monitored before being released. with and follow the instructions of their escorts. adjustment based on environmental and plant Personnel leaving the site would Personal transportation will normally be used conditions. Similarly, other factors contained in then proceed, in their own vehicles, and established evacuation routes will be this paragraph are more appropriately handled on on one of these major routes , to their followed . Personnel without transportation will an event specific bases . The use of site residences. Transportation for be identified and provided transportation as resources to monitor all personnel prior to leaving persons without vehicles will be necessary. the site may not be required if the site evacuation arranged . Evacuation of personnel is usually conducted occurs prior to any release. Evacuation using immediately after accountability if a Site Area personnel vehicles may or may not be Emergency or General Emergency has been appropriate. declared and no impediments exist. Evacuation shall commence as directed by the The Standard Plan, supported by the Site Emergency Director. Annexes, maintains the commitment to conduct a Site Evacuation if conditions dictate. The process of conducting the Evacuation has been moved to EPIPs to allow flexibility based on event conditions. E6-105 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revis ion 64 Description

b. Personnel Accountabilit~ 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 The senior individual referenced in the current persons working in or visiting his at the discretion of the Emergency Director to Plan is not an ERO assigned position. In group. Accountability within the support worker safety. accordance with existing procedures, the most Protected Area will be determined by Accountability of personnel within the senior person responding takes on a general the senior individual at the assembly Protected Area is accomplished within 30 leadership role in that area. Standard Emergency area coordinating with the Security minutes of the declaration of Site Area Plan Section J.4.1, Assembly, has been revised to Response Center (SRC) and then Emergency or higher, and maintained include the statement with respect to assumption will be reported to the Emergency continuously thereafter, using Protected of leadership responsibilities at an assembly area. Director by the senior plant security Area(s) boundary access contro l 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 (PMMS) 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 to NL-16-0169 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.5 Offsite 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 ri gid 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. SNC-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 Plant conditions, projected dose and dose rates would make an evacuation and field monitoring data are communicated to dangerous. Areas within a ten mile offsite agencies responsible for dose radius in which protective action is assessment/PARs to assist them in developing deemed necessary will be referred to parallel assessments by Evacuation Zone as shown in There are various types of protective actions Figure 21. The population distribution that can be recommended to the state and within this ten-mile radius has been counties. They may include the fo llowing: predicted for the life of the plant and

Evacuation .

is summarized graphically in Figure

Shelter in place .

22.

Monitor and prepare .
Thyroid blocking agent (consider using Kl (potassium iodide)) in accordance with state plans and policy.

E6-118 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

b. Response EP J.5 Offsite Protective Action The wording was relocated and transferred to the Recommendations (PARs) SNC Standard Emergency Plan.

GENERAL Plant cond itions, 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 exposu re to the Authorities public. PARs are provided to the offsite agencies responsible for implementing NMP-EP-112, "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 implementi ng (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 Plant conditions, projected dose and dose rates Response Organizations were fully and field monitoring data are communicated to involved in the development of the offsite agencies responsible for dose PARs . assessment/PARs to assist them in developing The Emergency Director will approve parallel assessments the PAR decision developed by the There are various types of protective actions methodology in the Initial and Follow- that can be recommended to the state and Up Flowcharts, shown as Chart 1, counties. They may include the following : Initial and Chart 2, Follow-Up.

Evacuation .

Recommendations will be based on

Shelter in place .

plant conditions, projected dose

Monitor and prepare .

estimates, or available monitoring

Thyroid blocking agent (consider using data. Kl (potassium iodide)) in accordance with state plans and policy.

E6-120 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description SITE AREA EP J.5 Offs ite 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 Site Area emergency level. The protective actions for the public within the 10-Emergency Director shou ld 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. Plant conditions, projected dose and dose rates and field monitoring data are communicated to offsite agencies responsible for dose assessmenVPARs to assist them in developing parallel assessments There are various types of protective actions that can be recommended to the state and counties. They may include the following:

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

E6-121 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description ALERT EP J.5 Offsite 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 determ ined 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. SNC operated plants have the capability to provide state and local agencies a PAR for beyond the 10-mile EPZ. Plant conditions, projected dose and dose rates and field monitoring data are communicated to offsite agencies responsible for dose assessment/PARs to assist them in developing parallel assessments There are various types of protective actions that can be recommended to the state and counties . They may include the following:

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

E6-122 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description The authority for initiation or EP 8.1.1 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) The language related to relaxation of PARs was may not be delegated to any other determination. eliminated from the Emergency Plan because the member of the emergency offsite agencies through their independent organization. Processes for analyses determine the appropriateness of development, approval, and relaxation of protective action recommendations.

notification of protective action Section D.2.S contains guidance on the site recommendations are described in determination to downgrade the Emergency NMP-EP-111, "Emergency Classification. Additional guidance was provided Notifications", and NMP-EP-112 as part of this response to communicate any "Protective Action decision to terminate or transition to recovery and Recommendations". will be submitted as part of this response. Chart 1 Initial Protective Actions No equivalent Plan/Annex chart Section JS of the SNC Standard Emergency Plan Recommendations specifies the requirement to make Protective Action Recommendations consistent with NUREG-06S4 Supplement 3. PAR flowcharts are controlled at the procedural level. Chart 2 Follow Up Protective Action No equivalent Plan/Annex chart Section JS of the SNC Standard Emergency Plan Recommendations specifies the requirement to make Protective Action Recommendations consistent with NUREG-06S4 Supplement 3. PAR flowcharts are controlled at the procedural level. V. ACTIVATION OF EMERGENCY EP 8.1.1 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. E6-123 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Within 16 hours after declaration of EP H.1 Onsite Emergency Response The wording was relocated and transferred to the an emergency, sufficient personnel Facilities SNC Standard Emergency Plan. shall have been notified and placed SNC-operated nuclear power plants have on-call to ensure that the OSC can established a TSC and an onsite OSC, 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. Emergency O~erations 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 HNP). The EOF is procedurally required to be activated within 75 minutes following the declaration of an Alert or higher classification ~taHiAQ aA9 aGtii.<<atioA of tt:ie eGi;: is maA9atory upoA 9eGlaratioA of aA Alert or AiQAer GlassifiGatioA. E6-129

Enclosure 6 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description 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 EOF 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 Append ix 10(J). and HNP). The EOF is procedurally required to be activated within 75 minutes following the declaration of an Alert or higher classification. StaffiRQ aR9 astivatieR ef tRe eGi;; is maRElatery upeR EleslaratieR ef aR Alert er RiQR8F GlassifiGatieR. D. OFFSITE LOCAL, STATE AND EP H.3 State and local Emergency The wording was relocated and transferred to the FEDERAL AGENCIES Operations Centers (EOC) SNC Standard Emergency Plan . Notification of offsite governmental EOCs 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. E6-131 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description NMP-EP-111 , "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 SNC sites and messages that will be used by the established the contents of the initial a00 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-111 , "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 E6-136 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equ ivalent Justification Revision 64 Description Required follow-up message EP E.2.2.3: In conjunction with state and The wording was standardized and relocated to information has been agreed upon county authorities, SNC-operated plants have the SNC Standard Emergency Plan.

by the states. NMP-EP-111 makes established the contents of the subsequent provisions for follow-up messages to state notification message forms to be used be sent to the states. These during an emergency. The Emergency messages contain the following Director is responsible for the completion of a information as appropriate: follow-up emergency message. The

1. Location of incident and name and appropriate ERO personnel will ensure the telephone number (or emergency communicator(s) periodically communications channel provide follow-up messages to the appropriate identification) of caller offsite federal, state, and local authorities+J::\e

2. Date/time of accident ~l+leFgeAGY l:;)iFeGteF is Fes13eAsi91e feF tRe

3. Class of emergency se1+113letieA ef a follew 1:113 e1+1eFgeAGY

4. Type of actual or projected release 1+1essage. +Re a1313m13Fiate s1:11313eFt (airborne, liquid) and estimated G99FEliAateF will eASl:IFe tRe e1+1eFgeAGY duration times se1+11+11:1AiGateF~s) 13eFieElisally 13mviEle fellew 1:113

5. Estimate of quantity of radioactive 1+1essages te tRe a1313Fe13Fiate eHsite feEleFal ,

material released or being released state , aAEI lesal a1:1tReFities . 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 . Meteorologica l 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 E6-137 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revis ion 64 Description EP E.2.5: Prompt alerting and notification of th e public within the plume B. PLUME EXPOSURE PATHWAY exposure pathway EPZ is the obligation of state and local govern ment or other The Standard Plan (Section E.2.5.1 ),the Farley EMERGENCY PLANNING ZONE responsible authority. The responsibility for ensuring the means exist to carry Annex (Section 4.2) and the respective PUBLIC NOTIFICATION AND out this purpose rests with Southern Nuclear Operating Company.

Justification Matrices have been updated to reflect INFORMATION Annex 4.2: Within the Plume Exposure Emergency Planning Zone (EPZ), a more extensive description of the FEMA

1. Notification there exist provisions for alerting and providing notification to the public.

The FEMA approved Farley ANS consists of a primary ANS and a backup approved primary and back-up systems. The

a. Primary system should there be a failure of the primary system.

Southern Nuclear Operating Company

Primary - Sirens and Emergency Alert System (EAS) stations wording was standardized and aligned with
System Backup - Reverse calling system current wording. Specific requirement for the has provided the administrative and The primary ANS has two communications pathways. The first pathway is physical means for alerting and providing through the primary agency via the UHF or VHF radio. Should the primary communities is maintained in the revised agency fail to activate the system, the secondary pathway will be utilized by prompt instructions to the public within the secondary agency. The secondary pathway functions in the same manner description in the Site Annex.

the plume exposure pathway EPZ by as the primary pathway utilizing a separate activation console that is physically located in separate location . If neither agency can activate the system, the providing an Alert and Notification backup system will be utilized to notify the residents of the 10 mile EPZ. System (ANS) for the entire plume The hierarchv for svstem activation is orovided below: AQencv Radio Systems exposure pathway EPZ. Pri mary alerting is accomplished by use of a siren Primary Agency UHF system. The siren alerting system VHF consists of 89 pole mounted sirens . Each Primary Sirens & EAS siren operates on battery power with Secondary UHF battery charge maintained through an Agency inverter that receives power from the VHR local electri cal grid or from a solar panel. Each siren site contains two radios - one Backup Each County EMA Calling System for the primary radio signal frequency operating in the UHF band and one for the backup radio frequency operating in the VHF band. Repeaters fo r the primary Alabama Georgia and backup radio frequencies are provided on two separate radio towers Primary Agency Houston County Early County with associated power, control , and radio communication provided. Siren system Secondary Agency Henry County State of Georgia activation, test, and monitoring panels (GEMA) are provided at each for the counties of Houston and Henry County, Alabama; one for Early County, Georgia; and one An nex 4.2: Si ren system activation, test, and monitoring panels are provided for Houston County and Henry County in Alabama, Early County in Georgia, for the State of Georgia. and the state of Georgia. E6-138 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Following activation of the siren Annex 4.2 Within the Plume Exposure Eme rgency Planning Zone The Standard Plan (Section E.2.5.1),the Farley (EPZ) , the re exist provisions for alerting and providing notification system , emergency notifications will to the public. The state and/or local authorities are responsible for Annex (Section 4.2) and the respective be made to the public within the 10 activation of this system. The FEMA approved Farley ANS Justification Matrices have been updated to reflect consists of a primary ANS and a backup system should there be a mile plume exposure pathway EPZ failure of the primary system. a more extensive description of the FEMA by activation of the Emergency Alert

Primary - Sirens and Emergency Alert System (EAS) approved primary and back-up systems. The System (EAS) . State and local stations wording was relocated and transferred to the Site
System Backup - Reverse calling system Emergency Management Agenci es The primary ANS has two communications pathways. The first Annex.

will initiate activation of the local EAS pathway is through the primary agency via the UHF or VHF radio. Should the primary agency fail to activate the system , the stations through a dedicated EAS secondary pathway will be utilized by the secondary agency. The activation console . The EAS secondary pathway functions in the same manner as the primary pathway utilizing a separate activation console that is physically activation console provides a located in separate location. If neither agency can activate the connecti on to designated EAS system , the backup system will be utilized to notify th e residents of stations that allows for activation of the 10 mile EPZ. The hierarchy for system activation is orovided below: the station through redundant AQencv Radio Svstems comm unications pathways . Primary UHF Emergency messages are Agency transm itted from the EAS activation VHF console via phone line, internet, or Primary Sirens & EAS satellite connections. Activation of Secondary UHF the station does not require that the Agency station be manned. Emergency VHR messages are coordinated between Backup Each County Calling the local Emergency Management EMA System Agencies and the State Emergency Management Agencies prior to activation of the local radio stations, as specified in the local area plans . A Alabama Georgia full descri ption of the Farley ANS Primary Agency Houston Early County design is provided in the FEMA County approved ANS Design Re port (ANS-FNP-001 ) in the SNC document Secondary Henry County State of management system . Agency Georgia (GEMA) Primary ale rting is accomplished by use of a si ren system. Each si ren ope rates 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 monitori ng panels are provided for Houston County and Henry County in Alabama, Ea rl y County in Georgia, and the State of Georgia. A full description of the Fa rley ANS design is provided in the FEMA approved ANS Design located in the SNC document management system . E6-140 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

b. Special Alerting and System Annex 4.2 The Standard Plan (Section E.2.5.1),the Farley The FEMA approved Farley ANS consists of a primary ANS and a Backup backup system shou ld there be a failure of the primary system. Annex (Section 4.2) and the respective Special alerting is accomplished

Primary - Sirens and Emergency Alert System {EAS) Justification Matrices have been updated to reflect stations through the use of a calling system.
System Backup - Reverse calling system a more extensive description of the FEMA Special alerting is initiated in the The primary ANS has two communications pathways. The first approved primary and back-up systems. The event of a failure of the system to pathway is through the primary agency via the UHF or VH F radio. wording was relocated and transferred to the Site Should the primary agency fail to activate the system , the activate multiple sirens resulting in a secondary pathway will be utilized by the secondary agency. The Annex.

loss of coverage in any area. Special secondary pathway functions in the same man ner as the primary pathway utilizing a separate activation console that is physically alerting may be initiated for a located in separate location. If neither agency can activate the predefined area, a user specified system, the backup system will be utilized to notify the residents of the 10 mile EPZ. area, user defined groups, or the The hierarchv for svstem activation is orovided below: entire Emergency Planning Zone A11encv Radio Systems (EPZ) . The calling system serves as Primary UHF a complete backup to the ANS . The Agency system provides both alerting and VHF notification of EPZ residents Primary Sirens & EAS independent of the alerting Secondary UHF Agency capabilities provided by the installed siren system and notification VHR capabil ity of local radio and television Backup Each County Calling stations through EAS. Capability for EMA System 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 Alabama Georgia Georgia. Primary Agency Houston Early County County Secondary Henry County State of Agency Georgia (GEMA) Special alerting uses a call ing system. Special alerting is initiated in the event of a failure of the system to activate multiple sirens resulting in a loss of coverage in any area. Special alerting may be initiated for a predefined area, a user-specified area, user defined groups, or the entire Emergency Planning Zone (EPZ) . The ca lling system serves as a complete backup to the ANS. The system provides both alerting and notification of EPZ residents independent of the alerting capabilities of the installed siren system and the notification capability of local radio and television stations through EAS. Capability to activate of the calling system is provided for Houston County and Henry County, Alabama and Early County, Georgia. E6-141 to NL-16-0169 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 formal critique will be performed for SNC Standard Emergency Plan . observe each individual's ability to exercises, drills , and training tabletops to perform his assigned emergency develop, maintain, or demonstrate key skills in function . During drills and Nuclear order to identify weak or deficient areas that Regulatory Commission (NRC) non- need correction. evaluated exercises, on-the-spot A critique shall be conducted at the conclusion correction of erroneous performance of the exercise, to evaluate the organization's and a demonstration of proper ability to respond as called for in the SNC performance may be made by the Standard Emergency Plan . Qualified monitoring personnel. personnel will observe and perform a critique of exercises and drills. Provisions wi ll be made for federal , state, and local observers, as well as SNC personnel, to observe and critique required exercises. E6-148 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

b. Both full-scale and small-scale EP N.3 The wording was relocated and transferred to the exercises will be conducted and will During the exercise planning cycle described SNC Standard Emergency Plan.

include participation by appropriate State in Section N.1.54 , SNC sites vary the content and local government agencies as of exercise scenarios to provide ERO follows : members the opportunity to demonstrate

1) A full scale exercises which tests as much of the Plant Farley, State, and local proficiency in key skills necessary to respond emergency plans as is reasonably to several specific scenario elements including :

achievable without mandatory public

Hostile Action directed at the plant site.

participation will be conducted on a

No radiological release, or unplanned biennial basis and evaluated by NRC and release that does not require public FEMA. protective actions .

(a) Biennial exercise scenarios will be submitted to the NRC under§ 50.4 at

An initial classification of, or rapid least 60 days before use in the biennial escalation to , a Site Area Emergency or exercise. General Emergency.

(b} Each biennial exercise scenario will

Implementation of strategies , procedures ,

provide the opportunity for the ERO to and guidance developed in 50.54(hh) (i.e., perform their key skills, as applicable, to potential aircraft threat, explosion or large their emergency response duties in fire) . the CR, TSC, OSC, EOF, and joint information center to implement the EP

Integration of offsite resources with on-site response .

principal functional areas. (c) Biennial evaluated exercises will be

A drill initiated between the hou rs of 6 varied such that the following scenario p.m. and 4 a.m.

elements are demonstrated over the

Drills using essentially 100 percent of course of an 8-year exercise cycle: Initiating Conditions in the 8- year cycle.
Hostile action directed at the plant site. Drills and exercise scenarios wi ll be varied
No radiological release or an unplanned from year to year to test major components of minimal radiological release that does the plans and preparedness organizations .

not require public protective actions.

Initial classification of or rapid A record of exercises conducted during the 8-escalation to a Site Area Emergency or year exercise planning cycle that documents General Emergency. the contents of scenarios used during that
Implementation of strategies, cyc le shall be maintained in accordance with procedures, and guidance developed Drill and Exercise procedure guidance.

under 10 CFR 50.54 (hh}(2}. SNC sites submit Biennial Exercise scenarios

Integration of offsite resou rces with under 10 CFR 50.4 for NRG review 60 days onsite response. prior to the exercise.

E6-150 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description (d) An ingestion pathway exercise EP N.1.3 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 . GppeFtl:lRities aFe pmviEleEI te aRy state eF lesal 9e 1.iernR=1eRt lesateEI witRiR tl:le pll:ll'fle e*p9Sl:JFe patl:lway eJ2~ te paFtisipate iR aRRl:lal EIFills aREI eieRRial e*eFSises WReR FeEJl:lesteEI ey tRat state 9F lesal Q91JeFRFfleRt. E6-151 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

a. Periodic Emergencl'. Drills EP N.3 The wording was relocated and transferred to the

1) During each exercise cycle, periodic During the exercise planning cycle described SNC Standard Emergency Plan.

drills will be conducted to ensure the in Section N.1 .54 , SNC sites vary the content ERO teams (not necessarily each of exercise scenarios to provide ERO individual) are provided the opportunity to members the opportunity to demonstrate develop and maintain key emergency response skills within the scope of their proficiency in key skills necessary to respond duties. The ERO (not necessarily each to several specific scenario elements including : ERO team) will be provided the

Hostile Action directed at the plant site.

opportunity to demonstrate key skills in

No radiological release, or unplanned response to the following scenario release that does not require public elements in drills or exercises. protective actions .
All functions in each ERF (e.g., all ERFs that are responsible for dose
An initial classification of, or rapid assessment perform those duties in escalation to , a Site Area Emergency or response to a radiological release) . General Emergency.
Use of alternative facilities to stage the
Implementation of strategies , procedures ,

ERO for rapid activation during hostile and guidance developed in 50.54(hh) (i.e. , action. potential aircraft threat, explosion or large

Real-time staffing of facilities during off- fire).

hours (i.e. , 6:00 p.m. to 4:00 a.m .).

Providing medical care for injured,
Integration of offsite resources with onsite response.

contaminated personnel (every 2 years).

Response to essentially 100 percent of
A drill initiated between the hours of 6 initiating conditions identified in the p.m. and 4 a.m .

site emergency plan implementing

Drills using essentially 100 percent of procedure for classification of Initiating Conditions in the 8-year cycle emergencies. Drills and exercise scenarios will be varied
Response to actual industry event from year to year to test major components of sequences appropriate for the nuclear the plans and preparedness organizations .

plant technology (e.g. , PWR). A record of Exercises conducted during the 8-

Use of procedures developed in response to an aircraft threat and in year exercise planning cycle that documents compliance with 10 CFR 50.54 (hh)(1 ). the contents of scenarios used during that
Use of the strategies associated with 10 cycle shall be maintained in accordance with CFR 50.54 (hh)(2) to mitigate spent fuel Drill and Exercise procedure guidance ..

pool damage scenarios (all strategies, SNC sites submit Biennial Exercise scenarios such as makeup, spray, and leakage under 10 CFR 50.4 for NRC review 60 days control , but not every variation of a given prior to the exercise. strategy).

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

E6-154 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

b. Fire Drills EP N.2.2J: 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.2.34: 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. Radiological Monitoring Drills EP N.2.45 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 Phy:sics Drills EP N.2.56 : Radiation Protection Drills involving The commitment was relocated to the SNC Health Physics drills will be a response to, and analysis of, simulated Standard Emergency Plan.

conducted semiannually which will airborne 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 th e post accident sampling system will be conducted annually. E6-155 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

3. Evaluations and Corrective N.4 Exercise Evaluation and Critique The wording was relocated and transferred to the Actions A formal critique will be performed for all exercises, SNC Standard Emergency Plan .

A formal critique will be performed drills, and training tabletops to develop, maintain, or for all exercises, drills , and training demonstrate key skills in order to identify weak or The evaluation of drills and training was deficient areas that need correction. that provide performance separated to ensure compliance with existing opportunities to develop, maintain , or EP N.5 Exercise/Drill Corrective Actions Systematic Approach to Training (SAT) demonstrate key skills in order to The critique and evaluation process is used to requirements for evaluation of any training. identify weak or deficient areas that identify areas of the Emergency Preparedness need correction. All observing or Program that require improvement. The Emergency participating agencies will be Preparedness group is responsible for evaluating requested to provide comments on recommendations and comments, determining drill evaluation. Any weaknesses o r which items will be incorporated into the program or deficiencies that are identified in a require corrective actions, and for scheduling, tracking, and evaluation of item resolution . critique of exercises , drills , or training Whenever exercises or drills indicate deficiencies in will be corrected . Corrective action , the SNC Standard Emergency Plan, site-specific as appropriate, for company onsite Annexes, corresponding implementing procedures, and offsite weaknesses shall be the or training lesson plans, such documents will be respons ibility of the Vice President- revised as necessary. Nuclear Plant Site. Corrective action , The results of exercise critiques, particularly as appropriate, for company public comments on identified areas that require information weaknesses shall be the improvement or reevaluation , will be submitted to responsibility of the APC Public the Emergency Preparedness Supervisor or designee, for review. The Emergency Relations Senior Vice President and Preparedness Supervisor or designee will consult the SNC Vice President and General with responsible department heads and assign Counse l. corrective action activities, as appropriate. 0.1 Training To achieve and maintain an acceptable level of emergency preparedness, training will be conducted for members of the Emergency Response Organization (ERO) and those offsite organizations that may be called on to provide assistance in the event of an emergency. Training will be evaluated in accordance with the requirements of Systematic Approach to Training practices to ensure effectiveness and in order to identify weak or deficient areas that need correction . E6-157 to NL-16-0169 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 EROS) are Notification Network. tested each calendar month , using the extensions in the Control Room , the TSC, and the EOF. EROS is tested each calendar quarter. Communications procedures and systems are also tested each calendar year.

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-O-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. EP F.4 Validation of Phone Numbers A quarterly check of telephone numbers required to implement the SNC Emergency Plan will be performed and documented.

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. E6-164 to NL-1 6-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description 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. 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) An nex Appendix A The wording was re located and tra nsferred 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 SUPPORTI NG EMERGE NCY Site Annex. PLANS APPENDIX 7(G) The information is in the Standard SNC 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 append ix. Appendix 7 A.3: Upon notification of EP H.2.1: The EOF is procedurally required to The commitment wording was standardized and an ALERT or higher classification or be activated within 75 minutes following the relocated to the SNC Standard Emergency Plan as directed by the ED, the EOF will declaration of an Alert or higher be activated as described in classification. ltaffiA1 aAEl aGtivatieA ef tl=le !;Qi;: emergency implementing is maAElatery upeA EleGlaratieA ef aA Alert er procedures. Ri§Rer GlassifiGatieA. Appendix 7 A.3: Offsite support EP B.2.1.1 5: 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. E6-166 to NL-16-0169 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 hours 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: The EOF is procedurally required to The commitment wording was standardized and activated for an ALERT, SITE AREA be activated within 75 minutes following the relocated to the SNC Standard Emergency Plan. or GENERAL emergency declaration of an Alert or higher classifications. classification. StaffiR!iJ aREl astivatieR ef tl:le eGP: is maRdatery upeR deslaratieR ef aR Alert er l:li91:ler slassifisatieR. Appendix 7 A.3: This facility (EOF) EP 8.2: Augmentation of on-shift staffing will The commitment wording was standardized and will be operational within about an occur within 75 minutes of 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 JIG 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. E6-167 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equ ivalent Justification Revision 64 Description Appendix 7 A.3: Upon notification of EP H.2.1: The EOF is procedurally required to The commitment wording was standardized and an ALERT or higher classification or be activated within 75 minutes following the relocated to the SNC Standard Emergency Plan as directed by the ED, the EOF will declaration of an Alert or higher be activated as described in classification. StaffiAQ aA9 astii.1atieA ef tl:ie eGi;: emergency implementing is maA9atery upeA 9eslaratieA ef aA Alert er procedures. AiQl:ier slassifisatieA. Appendix 7 A.3: Offsite support EP B.2.1.15: The Support Coord inator 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 suffi cie nt numbers, and ensu res office Director. supplies, drawings , and other documents are available to TSC and OSC personnel. Appendix 7 A.3: The co rporate EP 8.3.1.3 EOF Support Coordinator The commitment wording was standardized and emergency organization wi ll provide The Support Coordinator reports to the EOF relocated to the SNC Standard Emergency Plan . offsite emergency response support Manager. The duties and respons ibilities of and resources to SNC sites 24 hours 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 comm unications hardware, transportation, food, and lodging. Appendix 7 A.3: The EOF will be EP H.2. 1: The EOF is procedurally required to The commitment wording was standardized and activated for an ALERT, SITE AREA be activated within 75 minutes following the relocated to the SNC Standard Emergency Plan. or GENERAL emergency declaration of an Alert or higher classifications . classification. StaffiAQ aA9 astii.<atieA ef tl:ie eGi;: is maA9atery upeA 9eslaratieA ef aA Alert er AiQl:ier slassifisatieA. E6-168 to NL-16-0169 Farley Justification Matrix Cu rrent Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Appendix 7 8.1: The EOF Managers EP 0 .1 Training The commitment was modified to requ ired will typically have either previous To achieve and maintain an acceptable level qual ified 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. Training will be evaluated in accordance with the requirements of Systematic Approach to Training practices to ensure effectiveness and in order to identify weak or deficient areas that need correction. The ERO Training Program ensu res the train ing , 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 . Responsibi lities 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. Append ix 7 8 .1: The duties and EP 8 .3.1.1: The EOF ED has overall The commitment word ing was standardized and responsibi lities 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 keepi ng SNC corporate management informed regarding the emergency response and Classification upgrades. E6-171 to NL-16-0169 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 word ing 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 . Append ix 7 C.1 : The On-call EOF EP E.2.1: Emergency Response personnel The commitment wording was standardized and Manager will be notified of all respond to their assigned Emergency relocated to the SNC Standard Emergency Plan . emergencies classified at any SNC Response Facilities upon notification of an site. Alert or higher classification level. Append ix 7 D.1 : The EOF is located EP H.2.1: The EOF is a dedicated facility The commitment wording was standardized and in Birmingham , Alabama and serves located in Birmingham , Alabama, and serves as relocated to the SNC Standard Emergency Plan. as the EOF for all SNC sites (VEGP , the EOF for SNC sites (VEGP, FNP, and HNP). FNP, and HNP). Append ix 7 D.1: The EOF will be EP H.2.1: The EOF is procedurally required to The commitment wording was standardized and activated as prescribed in the site be activated within 75 minutes following the relocated to the SNC Standard Emergency Plan . specific Emergency Plan declaration of an Alert or higher implementing procedures. classification. ~taffiAg aA9 astivatieA ef tl=le eGi;: is maAE!atery upeA EleslaratieA ef aA Alert er l=ligl=ler slassifisatieA. Append ix 7 D.1: Plant systems EP H.5.1: A permanent meteorological The commitment wording was standardized and information, radiological data, and monitoring station is located near the plant for relocated to the SNC Standard Emergency Plan. meteorological data are provided via the acquisition and recording of wind speed , the SNC Integrated Data Display wind direction, 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 EOF. Append ix 7 D.1: Data displays are EP H.5.1: Meteorological information is The commitment wording was standardized and located in the main caucus area of displayed in the CR, TSC, and EOF 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. E6-174 to NL-16-0169 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. Append ix 7 E.1: Provisions have EP F.1.4: Communication with the Nuclear T he commitment word ing was standardized and been made to have direct NRC FTS Regulatory Comm ission (NRC) is on the relocated to the SNC Standard Emergency Plan. lines in the TSC and the EOF during Federal Telephono Telecommunications an emergency. System (FTS) telephone network, which connects the SNC plant site and EOF with the NRC Operations Center. Append ix 7 F.2.4: The GPC Central EP H.6.3: External facilities for counting and The commitment word ing was standardized and Laboratory has personnel and analyzing samples and for dosimetry relocated to the SNC Standard Emergency Plan . facilities available to provide offsite processing can be provided by other SNC-monitoring, sample analysis , and operated plants including the GPC Central dosimetry processing for the affected Laboratory, state, federal or contracted site. laboratories. Outside analytical assistance may be requested from state and federal agencies, or through contracted vendors. The DOE, through the Radiological Assistance Program (RAP) has access to any national laboratory. Append ix 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 . E6-178 to NL-16-0169 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 incorporates will be conducted each calendar year SNC-operated nuclear power plants will the EOF 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.

SNC-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 N.2.1 O+ Multi-Site Drill The SNC Standard Emergency Plan incorporates activation every 5 years will require a At least once in every five years, a drill the EOF multi-site drill into the base Plan concurrent EOF support response for involving more than one SNC site will be response. more than one SNC site. conducted demonstrating the ability of the Common EOF to effectively implement the Emergency Plan for an event involving more than one site. E6-180 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Appendix 7 G.1.2: Each drill/exercise EP N.1: Drills and exercises shall: The commitment wording was standardized and will test, as a minimum, the

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

communication links and notification implementing procedures and methods. procedures.

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

Appendix 7 G.1.2: Provisions are EP N.4: A formal critique will be performed for The commitment wording was standardized and made for critique of all exercises, drills, and training tabletops to relocated to the SNC Standard Emergency Plan. drills/exercises. develop, maintain, or demonstrate key skills in order to identify weak or deficient areas that need correction. A critique shall be conducted at the conclusion of the exercise, to evaluate the organization's ability to respond as called for in the SNC Standard Emergency Plan. Appendix 7 G.1 .2: Critique items will EP N.5: The Emergency Preparedness group The commitment wording was standardized and be forwarded to the site emergency is responsible for evaluating recommendations relocated to the SNC Standard Emergency Plan. preparedness coordinator for and comments , determining which items will 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 Emergency 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-refe rence . APPENDIX 9(1) SECTION P: RESPONSIBILITY FOR THE The commitment was relocated to the SNC RESPONSIBILITY FOR THE PREPAREDNESS EFFORT Standard Emergency Plan as described below. PLANNING EFFORT E6-181 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description The SNC Classification procedures EP 0.2.1 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 EP E.1.1 for the notification and the other unit When multiple units of a multi-unit site are class ification noted on the affected by an emergency, the classification notification form. shall be reported as applicable to all affected units. In situations where multiple units of a multi-unit site are affected by emergency events , but the events are not related and the classification for each unit is different, initial notification will be made for the highest classification. Additional classification information is provided in accordance with Section E.2.2.3. 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 specific 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 thresho ld has been exceeded . E6-192 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description 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 turnover from the ERO. When the site determines that transition to termination or recovery is appropriate, the information will be transmitted to respective offsite agencies. 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 SNC 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 . E6-193

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. to NL-16-0169 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 SNC, and set forth in Appendix E, "Emergency plant employees. SNC operates the Hatch Plans for Production and Utilization Nuclear Plant (HNP), Farley Nuclear Plant Facilities", of 10CFR50, "Licensing of (FNP), and Vogtle Electric Generating Plant Production and Utilization Facilities". (VEGP).

Background

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 Pla.n is organized using the structure of NUREG-0654 Revision 1 and that structure provides the cross-reference to the base document. E6-2 to NL-16-0169 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 (EOF) 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 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description B.

SUMMARY

EP

Introduction:

SNC has overall The wording was standardized and relocated to Southern Nuclear Operating Company responsibility for maintaining a state of the SNC Standard Emergency Plan. corporate management has overall readiness to implement this Plan for the responsibility for maintaif)ing a state of protection of plant personnel, the general readiness to implement emergency plans public, and property from hazards associated for the protection of plant personnel, the general public and property from hazards with any facility operated by the company. The associated with ionizing radiation authority for planning, developing, and originating within a company facility. The coordinating emergency control measures is authority for planning, developing, and derived from being the Nuclear Regulatory coordinating emergency control Commission (NRC) license holder for the measures is discussed in Appendix 9 (I), nuclear power plants operated by SNC. Responsibility For The Planning Effort. The SNC Emergency Plan describes the The Farley Plant Emergency Plan organization and facilities, training, and describes the organization and facilities maintenance of both onsite and off-site both onsite and offsite that will be used to deal with a spectrum of accidents facilities and equipment, that will be used to ranging from minor onsite incidents to address a wide spectrum of accidents ranging those that could affect the general public. from minor onsite incidents to those that could There are thr~e phases of responsive affect the general public. action contained within the Farley Plant There are three phases of responsive action Emergency Plan. The first phase described in the SNC Emergency Plan. The includes initial actions directed toward first phase includes initial actions to protect the protection of personnel and the personnel and eliminate the potential for elimination of the potential for further further exposure to the hazard. The second exposure to the hazard. The second phase includes immediate and planned phase includes immediate and planned action action directed toward termination of the to terminate the condition, contain any effluent, incident, containment of the effluent, establish incident boundaries, establish establishment of incident boundaries, control, channel information, and protect the establishment of control, channeling of facility and equipment.* The third phase is to information, and protection of the facility restore the facility to its normal operating and equipment. The third phase is to condition. To respond effectively using these restore the facility to its normal operating phases, emergemcies are classified according condition. To respond effectively utilizing to increasing severity: Unusual Event, Alert, these phases, emergencies are classified according to increasing severity as Site Area Emergency, or General Emergency. Notification of Unusual Event, Alert, Site Area Emergency or General Emergency. E6-4 to NL-16-0169 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, Florida offsite resources are individually (Ingestion pathway only for Plant Farley) and discussed below. The onsite and individual counties. offsite organizations provide SNC has overall responsibility for maintaining a emergency response during the state of readiness to implement this Plan for the activation, emergency, and recovery protection of plant personnel, the general phases of accident response. public, and property from hazards associated Principal federal, state, local and with any facility operated by the company. private agencies are also discussed. There are three phases of responsive action Figures 12 and 13 illustrate the contained within the SNC Emergency Plan. interrelationships of these The first phase includes initial actions to protect organizations before and after personnel and eliminate the potential for further Emergency Operations Facility exposure to the hazard. The second phase activation respectively. 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 as Unusual Event, Alert, Site Area Emergency, or General Emergency. E6-5 to NL-16-0169 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 SNC 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 II.A: 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 N18.1-1971. 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 to onsite emergency response positions will receive training specific to their position. E6-6 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Section II.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 N18.1-1971. emergency response personnel is developed based on the requirements of 10 CFR 50, Appendix E and position specific responsibilities. Requalification training for onsite 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 to onsite emergency response positions will receive training specific to their position.

1. Technical Sui;mort Center (TSC} EP Figure B.2.B - Technical Support Center Figure 8.2.B is provided to address the TSC The emergency onsite organization organization organization proposed for the SNC Standard implemented for events requiring Emergency Plan. Individual positions are activation of the TSC is described in described below.

FNP-0-EIP-O and is shown in Figure 2. Responsibilities and authorities of personnel in the TSC emergency organization are as follows: E6-7 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Section 11.A.1.a: a. Emergency EP 8.1.1: 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 8.2.1.1 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 transfer of overall direction of all in-plant Command and Control has been completed, emergency activity. The ED shall the TSC ED assumes the non-delegable supervise the TSC, and manage the duties of event Classification, on-site in plant recovery efforts and the in Emergency Exposure Authorization, and on-plant recovery organization. The ED site protective actions. shall communicate directly with the EP 8.3.1.1 EOF Emergency Director EOF Manager when the EOF is The EOF ED has overall coordinating authority activated and shall have full authority for Southern Nuclear Company resources. to direct the onsite recovery efforts Upon EOF activation, the EOF ED accepts without further consultation when the responsibility for Notification and Protective situation demands such action. Action Recommendation functions from the Following EOF activation when time Control Room. The EOF ED is also permits the ED will consult with EOF responsible for keeping SNC corporate personnel prior to initiating major management informed regarding the evolutions or changes in plant emergency response and Classification configuration. upgrades. E6-8 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description The ED's general responsibilities include: EP B.1.1: The Shift Manager (SM) is in direct The wording was standardized and relocated to

1) Staffing the TSC. The TSC will be charge of shift plant operations and is directly the SNC Standard Emergency Plan.

staffed by plant supervisory personnel responsible for the actions of the on-shift crew. supplemented by plant engineering, In an emergency, the SM assumes the position technical and administrative personnel as of the Emergency Director (ED) and takes necessary to staff the TSC 24 hours a day and discharge the responsibilities necessary actions to identify and respond to discussed below. the emergency until relieved by another

2) Evaluating the classification of the qualified ED.

emergency and amending as EP B.2.1.1 TSC Emergency Director (ED) appropriate. Terminating an emergency The TSC ED has the authority and level will not be delegated to other responsibility to immediately initiate any elements of the emergency organization emergency actions. Once transfer of and will be performed in accordance with Command and Control has been completed, approved procedures. the TSC ED assumes the non-delegable

3) Verifying correct control room response to the emergency classification. duties of event Classification, on-site

4) Determining radiological status and Emergency Exposure Authorization, and on-initiating notifications to state agencies site protective actions.

(and local agencies for General EP 8.3.1.1 EOF Emergency Director Emergencies). The decision to notify The EOF ED has overall coordinating authority offsite government agencies may not be for Southern Nuclear Company resources. delegated to any other element of the Upon EOF activation, the EOF ED accepts emergency organization. responsibility for Notification and Protective

5) Initiating, on initial or upgrade emergency notifications, Action Recommendation functions from the recommendations to state agencies on Control Room. The EOF ED is also advisability of evacuations. responsible for keeping SNC corporate Recommendations to local agencies management informed regarding the when state authorities cannot be emergency response and Classification contacted for immediate evacuation may upgrades.

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.

E6-9 to NL-16-0169 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-O-EIP-8.1 Emergency Phone response will be developed as part of the Directory approval process for this License Amendment FNP-O-EIP-8.3 Communication Request. Equipment Operating Procedures NMP-EP-104 Dose Assessment NMP-EP-110 Emergency Classification Determination and Initial Action NMP-EP-111 Emergency Notifications NMP-EP-112 Protective Action Recommendations E6-10 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description The ED position is initially filled by EP 8.1.1: 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 8.2.1.1 TSC Emergency Director (ED) The TSC ED has the authority and responsibility to immediately initiate any emergency actions. Once transfer of 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 8.3.1.1 EOF 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. E6-11 to NL-16-0169 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 to NL-16-0169 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 T.SC staff, and ensuring communications are based procedures. classification assessment and established with applicable offsite agencies. emergency plan implementation per NMP-EP-110, "Emergency Classification Determination and Initial Action" and coordination of communications between the TSC and other locations per NMP-EP-111, "Emergency Notifications ".

c. 0Qerations SuQervisor 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 SNC 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 OSC activities, and timely Senior Reactor Operator License completing offsite notifications. rotate as the on-call Operations Supervisor. E6-13 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

d. Maintenance Su12ervisor 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 l&C and Maintenance personnel designated by the Plant Manager rotate as the on-call Maintenance Supervisor. E6-14 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

e. Health Physics Su1;1ervisor 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-O-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 OSC 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-O-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. E6-15 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

g. Engineering SuQervisor EP 8.2.1.7 TSC Engineering Supervisor The wording was standardized and relocated to The on-call Engineering Supervisor The Engineering Supervisor reports to the TSC the SNC Standard Emergency Plan.

provides engineering expertise for Manager. The TSC Engineering Supervisor is advising the ED in the development responsible for the overall direction of of plans for modifications, alterations, Engineering Group activities and assessment. or repairs to plant systems. The on- The Engineering Supervisor also directs the call Engineering Supervisor is analysis of plant problems and core damage, responsible for assisting the on call and provides recommendations for plant Maintenance Supervisor with plant modifications to mitigate the effects of the repair and mitigation activities by accident. coordinating the necessary engineering resources.

h. Chemist!Y SuQervisor _ EP 8.2.1.10 TSC Chemistry Support Specific references to procedure usage were The on-call Chemistry Supervisor The TSC Chemistry Support reports to the RP deleted based on the conversion to function reports to the TSC and is responsible Supervisor. The TSC Chemistry Support is based procedures.

for implementation of FNP-O-EIP-20, responsible for directing and evaluating in- "Chemistry and Environmental plant chemistry and analyses, directing and The SNC Standard Emergency Plan uses on-shift Support to the Emergency Plan" evaluating post-accident sampling, and Chemistry to perform the Dose Assessment including coordination of offsite dose assisting in core damage assessment. function. projections and in plant sampling. The on-call Chemistry Supervisor is EP 8.2.1.6 TSC Dose Analyst responsible for coordinating offsite The Dose Analyst reports to the RP dose projections until relieved by the Supervisor. The Dose Analyst operates the Emergency Operations Facility dose assessment model to provide estimates (EOF) staff. of environmental dose in the event of a radiological release attributable to the event.

i. Emergency Notification Network EP 8.3.1.8 EOF Emergency Notification The revised Plan provides for simultaneous (ENN) Communicator Network (ENN) Communicator activation of the TSC and EOF. The Control The on-call ENN Communicator The ENN Communicator in the EOF reports to Room will be relieved for the ENN function by the reports to the TSC and is responsible the Emergency Communication Coordinator EOF ENN Communicator.

for communications with the state and is responsible for providing offsite agency and local government agencies using notifications and periodic updates. the guidance found in NMP-EP-111, "Emergency Notifications ". E6-16 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

j. Emergency Notification System EP 8.2.1.9 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-111, 50.72 and 73. "Emergency Notifications". E6-17 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

k. Shift Manager EP B.1.1 The Shift Manager (SM) is in direct The wording was standardized and relocated to The Shift Manager is responsible for charge of shift plant operations and is directly the SNC Standard Emergency Plan.

directing operational activities to responsible for the actions of the on-shift crew. classify and combat the emergency In an emergency, the SM assumes the as delineated in NMP-EP-110, responsibility of the Emergency Director (ED) "Emergency Classification and takes necessary actions to identify and Determination and Initial Action". The respond to the emergency until relieved by Shift Manager acts as the another qualified ED. The ED has the responsibility and authority to immediately and Emergency Director (ED) until unilaterally initiate emergency actions, including relieved by the on-call ED and until providing notification of Protective Action relieved has the authority and Recommendations (PAR) to state and local responsibility to immediately and government organizations responsible for unilaterally initiate any necessary implementing offsite emergency measures. The emergency actions, including ED, at their discretion or when procedurally providing protective action required, activates the ERO. recommendations to authorities The Emergency Director's non-delegable duties responsible for implementing offsite include: emergency measures.

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 NRG notifications.
Authorization of emergency exposures in excess of federal limits.
Issuance of potassium iodide (Kl) to plant employees as a thyroid blocking agent.
Request federal assistance as needed .

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). E6-18 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description I. Emergency Re12air Party B.2.2 Operations Support Center (OSC) Terminology in the SNC Standard Emergency The Emergency Repair Party, as B.2.2.1 OSC Manager

Plan was updated to describe the industry shown in Figure 2, is a group of B.2.2.2 OSC Mechanical Maintenance Group standard OSC organization.

personnel competent in operations Lead and repair work who will be used . B.2.2.3 OSC Electrical Group Lead The contents of that organization are in Section during an emergency situation to B.2.2.4 OSC RP I Chemistry Group Lead B.2.2 of the SNC Standard Emergency Plan. make temporary repairs to B.2.2.5 QSC l&C Group Lead

systems/components in order to B.2.2.6 OSC 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 OSC Personnel tothe 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 Instrumentation and Control

Field monitoring .

Personnel Health Physics Personnel Chemistry Personnel E6-19 to NL-16-0169 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 The responsibility to provide radiological support Medical Center, during transport of measured radiological values in the to offsite medical response was maintained in the potentially irradiated and/or environment. standard plan but removed from a specific contaminated casualties, and at the EP 1.7 The capability to take offsite soil, water, responsibility of the field teams to allow a more Assembly Areas, and at any other and vegetation samples is provided by a flexible response. 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 L.4 Medical Transport technician. Contaminated and injured persons are Assistant - Any qualified plant transported to a facility specified for SNC-employee or vendor personnel. operated nuclear power plants. Arrangements have been made by nuclear power plants for ambulance transport of persons with injuries involving radioactivity to designated hospitals. Such services are available on a 24-hour-per-day basis and are confirmed by letters of agreement. Radiation monitoring services are provided by SNC plant personnel whenever it becomes necessary to use an ambulance service for the transportation of contaminated persons. E6-20 to NL-16-0169 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 8.2.1.6 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 8.3.1.4 EOF Dose Assessment Emergency Operations Facility Supervisor (EOF) 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 offsite 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 8.3.1.5 EOF Dose Analyst FNP-O-M-007, Emergency Dose The Dose Analyst reports to the Dose Calculation Manual, using guidance Assessment Supervisor. The Dose Analyst found in FNP-O-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 to NL-16-0169 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 EOF 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 EOF; 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 NRG. Assessment Supervisor and is responsible for Data will be provided as directed by providing radiological and environmental the NRG at the time of need. information to the NRG using the HPN Line.

o. Additional Plant Staff Assignments EP B.2.2 Operations Support Center (OSC) The wording was standardized and relocated to 1} 012erations Su1212ort Center .(OSC} EP B.2.2.1 OSC Manager the SNC Standard Emergency Plan.

Manager 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. The senior individual referenced in the current coordinating the activities of the OSC J.4.1 Assembly Plan is not an ERO assigned position. In or other location directed by the Assembly is mandatory following the accordance with existing procedures, the most Emergency Director per FNP-0-EIP- declaration of a Site Area or General senior person responding takes on a general 5.0. The senior individual at each of Emergency, or at the discretion of the leadership role in that area. Standard Emergency the Assembly Areas will become the Emergency Director. When Accountability of supervisor at that location. The Plan Section J.4.1, Assembly, has been revised to onsite personnel is determined to be necessary Assembly Area senior individual will by the Emergency Director, personnel within the include the statement with respect to assumption take the lead in coordinating the Protected Area will be accounted for and the of leadership responsibilities at an assembly area. activities of the Assembly Area in names of missing individuals determined within support of OSC operations as 30 minutes of the emergency declaration. directed by the OSC Manager. 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 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan RevisE!d SNC Emergency Plan- Equivalent Justification Revision 64 Description

2) Radiological monitoring EP B.2.2.4 OSC 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 . OSC 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-O-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 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

5) Decontamination EP K.5 Decontamination The wording was standardized and relocated to Personnel decontamination is the The Radiation Protection Group will be the SNC Standard Emergency Plan.

responsibility of the Health Physics responsible for controlling or minimizing direct Group and during an emergency the or subsequent internal exposure from responsibility of the Field Monitoring radioactive materials deposited on the ground Team. Area and equipment or other surfaces, and for determining the decontamination onsite as the result extent of contamination in controlled and of an accident will be a joint effort of normally uncontrolled areas. During normal personnel from the Operations, conditions or an emergency, guidelines to Maintenance, Chemistry and Health follow for contamination limits are established Physics Groups. 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.7 Offsite 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. E6-24 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description 6} Personnel Accountabilit~ 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-O-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 of 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 to NL-1s..:01sg Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

8) Communications EP 8.1.1 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 arid 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 individual. 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.

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

8. OFFSITE EP 8.3 Offsite Emergency Response The offsite organization is integrated into the SNC The normal Alabama Power Organization (ERO)

Standard Emergency Plan in the proposed Company (APC) offsite 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 8.2.D and 8.2.E. The EOF and JIC in the Emergency Communications Organizations may also include state and local Plan in Appendix 10(J}. personnel. E6-26 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

1. Emergency 0Qerations Facility EP B.3 Offsite Emergency Response The offsite organization is integrated into the SNC (EOF) 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 8.2.D and 8.2.E. The EOF and JIC Organizations may also include state and local personnel.

2. CorQorate Organization 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). The EOF is procedurally required to be activated within 75 minutes following the declaration of an Alert or higher classification. E6-27 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergenc;y Plan Equivalent Justification Revision 64 Description

a. CorQorate Dutll Manager EP 8.3.1.1 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. is specifically identified as the individual in emergency support at FNP. The Upon EOF activation, the EOF ED accepts Command and Control of the respective facilities.

Duty Manager is the primary contact responsibility for Notification and Protective 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 8.3.2.1 EOF Nuclear Spokesperson alternate Duty Manager or other The Nuclear Spokesperson speaks on behalf trained individual is available to of the company, providing pl~mt 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 lnfo~mation Director (PIO) posted on that status.

3. Emergencll Communication EP 8.3 Offsite Emergency Response The offsite organization is integrated into the SNC Organization Organization (ERO) Standard Emergency Plan in the proposed The Emergency Communication The EOF 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 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

4. Recovery Phase Organization EP M.1 Recovery The wording was standardized and relocated to Upon termination of the emergency Guidance for determining the transition from the SNC Standard Emergency Plan.

condition and at the discretion of the Emergency to Recovery Organization is Emergency Director, the SNC provided in the plant Emergency Plan See SNC Standard Emergency Plan Section M1 Emergency Organization will shift to Implementing Procedures. The composition of for additional direction for determining when to the Recovery Phase Organization the Recovery Organization will depend on the enter the Recovery Phase and the purpose of shown in Figure 10. The Recovery nature of the accident and the conditions recovery actions. Manager has authority to modify the following the accident. organization as deemed necessary. The SNC Emergency Plan addresses general The actual recovery organization below the principles that serve as guides for developing recovery manager will be event-specific and a Recovery Plan. determined on the transition to recovery. Section It is the responsibility of the Emergency M provides a generic organization and guidance Director (ED) to determine that the facility and for determination of the specific needs of the surroundings are safe for reentry. The event. 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 SNC Emergency Organization will shift to the Recovery Phase Organization. Figure M.2 provides a typical recovery operation organization. E6-29 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

a. Recover~ Manager EP M.1: 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 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

b. Recovei:y Suggort Director EP M.1: The Recovery Manager will structure The SNC 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 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

c. Technical Sui;mort Director EP M.1: The Recovery Manager will structure The SNC Standard Emergency Plan outlines a The Technical Support Director is the recovery organization to accomplish the general recovery organization and provides responsible for managing all following general objectives: overall responsibility for the event under the supplemental engineering, technical

Maintain comprehensive radiation Recovery Manager.

and licensing support resources surveillance of the site until levels return to needed in the recovery effort. The normal. The specific event will drive individual line of succession for the Technical

Control access to the affected area of the responsibilities.

Support Director shall be designated plant and exposures to workers. by the Vice President - Nuclear

Decontaminate affected areas and Plant Site, should the Recovery equipment.

Organization be required.

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. E6-32 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

d. Recovery Sum~ort SuQervisor EP M.1: The Recovery Manager will structure The SNC Standard Emergency Plan outlines a The Recovery Support Supervisor is the recovery organization to accomplish the general recovery organization and provides responsible for coordinating or following general objectives: overall responsibility for the event under the monitoring operational support

Maintain comprehensive radiation Recovery Manager.

recovery activities as directed by the surveillance of the site until levels return to Recovery Support Director. This normal. The specific event will drive individual position will be filled by a qualified

Control access to the affected area of the responsibilities.

individual designated by the plant and exposures to workers. Recovery Support Director.

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. E6-33 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

e. Administrative Sum;iort Sugervisor EP M.1: The Recovery Manager will structure The SNC Standard Emergency Plan outlines a The Administrative Support the recovery organization to accomplish the general recovery organization and provides Supervisor is responsible for following general objectives: overall responsibility for the event under the supervising EOF recovery

Maintain comprehensive radiation Recovery Manager.

phase administrative activities surveillance of the site until levels return to including: normal. The specific event will drive individual

1) Special communications needs

Control access to the affected area of the responsibilities.

2) Manpower augmentation plant and exposures to workers.

3) Personnel Affairs for temporarily

Decontaminate affected areas and assigned personnel equipment.

4) Special Budget Activities

Conduct activities in radiation areas in

5) Clerical Support accordance with the plant's standard

6) Other activities as assigned by the radiation work practices.

Recovery Support Director

Isolate and repair damaged systems.

This position will be filled by a

Document proceedings of the accident and qualified individual designated by the review the effectiveness of the emergency Recovery Support Director. 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. E6-34 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Descri_ption -

f. Engineering Su!;!ervisor 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.

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.

Figure iVl.2 provides a typical recovery operation organization. E6-35 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

g. Licensing Su12ervisor 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 NR.C 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.

resulting from licensing issue

Document proceedings of the accident and resolution review the effectiveness *at 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 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

1. Government Agencies 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 is the coordinating agency for plan in NUREG-0728, specifying incidents at or caused by a facility or an activity NRC actions, responsibilities, that is licensed by the NRC or an Agreement functions and authorities during an State, with the Chairman of the Commission as emergency. the senior NRC authority for response. The 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(8). E6-37 to NL-16-0169 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 (OHS) 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. Degartment of Energy Savannah EP A.1.4 Department of Energy (DOE) The wording was standardized and relocated to River Ogerations 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 (FRMAP). 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 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

b. Nuclear Regulato[Y 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 NRG will implement The NRG is the coordinating agency for the incident response plan described incidents at or caused by a facility or an activity in NUREG-0728. In addition to that is licensed by the NRG or an Agreement fulfilling its regulatory responsibilities, State, with the Chairman of the Commission as it is expected that the NRG will the senior NRC authority for response. The provide technical assistance and Chairman can transfer control of emergency recommendations. For Site Area and response activities when deemed appropriate. General Emergencies, dispatch to Incident Response Centers have been SNC facilities of a NRG Region II site established at the four NRG Regional Offices team is anticipated with arrival and NRG Headquarters, to centralize and expected 2 to 6 hours following coordinate NRC's emergency response. notification. As described in Section Provision is made for NRG personnel at the Ill, office space, telephones, etc. plant's Technical Support Center and the have been provided for NRG Emergency Operations Facility. personnel at the Technical Support Center and Emergency Operations Facility. E6-39 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

c. State of Alabama EP A.2.1 State of Alabama The wording was relocated and transferred to the SNC The Alabama Radiation Control Division of the Standard Emergency Plan.

The Governor of the State of Alabama has overall responsibility for State of Alabama Department of Public Health emergency preparedness and response concerning an incident at is responsible for initiating the "Alabama a NPP. Alabama law designates the Alabama Department of Radiological Response Plan for Nuclear Public Health, Office of Radiation Control (ADPH-ORC) as the Power Plants" in support of an emergency at agency responsible for issuing any order requiring actions to be the Farley Nuclear Plant. This plan provides a taken necessary to meet the emergency. In day-to-day operations detailed description of the notification this function is fulfilled by the ADPH-ORC. procedures and responsibilities and duties of The Governor has charged the Alabama Emergency Management the local and state agencies involved. Since Agency Director with the responsibility of coordinating the activities the primary concern of the Alabama Radiation of departments, agencies, and organizations of state government Control Division is for the welfare and safety of and local emergency management agencies to carry out the general public, they will have primary emergency functions relating to a NPP incident. These assigned responsibilities merge in the joint development and issuance of this responsibility and authority for handling the plan by the ADPH-ORC and the Alabama Emergency offsite aspects of the emergency in Alabama. Management Agency. EP A.2.1.1 Alabama Emergency Management Agency (AEMA) The Alabama Emergency Management Agency (AEMA) is the primary offsite agency for radiological emergencies. The station sends emergency notifications to the 24 hour notification point maintained by 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 (ADPH-ORC) The Alabama Department of Public Health Office of Radiation Control (ADPH-ORC) provides technical support to AEMA. They perform radiation monitoring of areas around the station and provide the results back to AEMA. Communications of events are transmitted to AEMA who in turn informs ADPH-ORC with the information. This relationship is further defined in the FEMA approved state emergency plan. 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. E6-40 to NL-16-0169 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.2.1 State of Alabama The wording was relocated and transferred to the State of Alabama to provide The Governor of the State of Alabama has overall responsibility for SNC Standard Emergency Plan. emergency preparedness and response concerning an incident at available resources and equipment a NPP. Alabama law designates the Alabama Department of to support the mitigation and Public Health, Office of Radiation Control (ADPH-ORC) as the response to an emergency at Plant agency responsible for issuing any order requiring actions to be taken necessary to meet the emergency. In day-to-day operations Farley to include Hostile Action this function is fulfilled by the ADPH-ORC. Based events. These resources The Governor has charged the Alabama Emergency Management include, but are not limited to, Local Agency Director with the responsibility of coordinating the activities Law Enforcement Agency (LLEA) of departments, agencies, and organizations of state government and local emergency management agencies to carry out assets, Fire Fighting assets, medical emergency functions relating to a NPP incident. These assigned support resources (including responsibilities merge in the joint development and issuance of this plan by the ADPH-ORC and the Alabama Emergency transportation), and coordination Management Agency. through an Incident Command Post. Requests for offsite resources and EP A.2.1.1 Alabama Emergency Management Agency (AEMA) The Alabama Emergency Management Agency (AEMA) is the equipment will be communicated primary offsite agency for radiological emergencies. The station from the control room to the Houston sends emergency notifications to the 24 hour notification point maintained by AEMA. County 911 center, the county EOC, or through the Incident Command The Alabama Emergency Management Agency coordinates the Radiological Emergency Plans and offsite operations of affected Post, as applicable, based on the state agencies and local governments including notification of state nature and timing of the event. 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 The Alabama Department of Public Health Office of Radiation Control (ADPH-ORC) provides technical support to AEMA. They perform radiation monitoring of areas around the station and provide the results back to AEMA. Communications of events are transmitted to AEMA who in turn informs ADPH-ORC with the information. This relationship is further defined in the FEMA approved state emergency plan. 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. E6-41

Enclosure 6 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Revised SNC Emergency Plan Justification Plan Revision 64 Eauivalent Descriotion

d. State of Georgia EP A.2.2 State of Georgia The wording was relocated and transferred to The Governor is authorized and empowered under Upon notification of an emergency the SNC Standard Emergency Plan.

Official Code of Georgia Annotated (O.C.G.A.) § 38 condition, the Georgia Emergency 22: Management Agency will To have general direction and control of the Georgia implement the "State of Georgia Emergency Management Agency and to be responsible for the carrying out of the provisions of this chapter, and, Radiological Emergency Plan". The in the event of disaster or emergency beyond local Georgia Emergency Management control, may assume direct operational control over all or Agency has the authority and any part of the emergency management functions within responsibility for coordinating the this state. The Governor's Executive Order provides current efforts of local and state agencies authority and assignment of the various emergency in Georgia to provide for the health response functions to the appropriate state agencies. and safety of the general public in EP A.2.2.1 Georgia Emergency the event of a radiological incident. Management Agency (GEMA) As the overall state coordinating agency GEMA will coordinate with Department of Natural Resources-Environmental Protection Division (DNR-EPD) on emergency response activities with state, county and municipal agencies and departments as stated in the Georgia Emergency Operations Plan (GEOP). GEMA provides for 24-hour notification and staffing of the State Operations Center (SOC) and/or the Forward Emergency Operations Center (FEOC), as required, throughout the event. GEMA is responsible for general state emergency planning and overall direction, and control of emergency or disaster operations as assigned by executive order and in accordance with the Georgia Emergency Operations Plan (GEOP). GEMA has responsibilities for coordinating the state of Georgia response to . emergencies at nuclear power plants. EP A.2.2.2 Department of Natural Resources-Environmental Protection Division (DNR-EPD) Department of Natural Resources-Environmental Protection Division (DNR-EPD) is assigned as the coordinating and a primary "!gency responsible by Executive Order for implementation and administration of the state radiological and hazardous material function. 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 to NL-16-0169 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 The Governor is authorized and empowered under Official State of Georgia to provide available SNC Standard Emergency Plan. Code of Georgia Annotated (O.C.G.A.) § 38-3-22: resources and equipment to support To have general direction and control of the Georgia the mitigation and response to an Emergency Management Agency and to be responsible emergency at Plant Farley to include for the carrying out of the provisions of this chapter, and, in the event of disaster or emergency beyond local control, Hostile Action Based events. These may assume direct operational control over all or any part resources include, but are not limited of the emergency management functions within this state. to, Local Law Enforcement Agency The Governor's Executive Order provides current authority (LLEA) assets, Fire Fighting assets, and assignment of the various emergency response functions to the appropriate state agencies. medical support resources (including transportation), and coordination EP A.2.2.1 Georgia Emergency Management Agency through an Incident Command Post. (GEMA) Requests for offsite resources and As the overall state coordinating agency GEMA will coordinate with Department of Natural Resources-equipment will be communicated Environmental Protection Division (DNR-EPD) on from the control room to the Early emergency response activities with state, county and County 911 center, the county EOC, municipal agencies and departments as stated in the or through the Incident Command Georgia Emergency Operations Plan (GEOP). GEMA provides for 24-hour notification and staffing of the State Post, as applicable, based on the Operations Center (SOC) and/or the Forward Emergency nature and timing of the event. Operations Center (FEOC), as required, throughout the event. GEMA is responsible for general state emergency planning and overall direction, and control of emergency or disaster operations as assigned by executive order and in accordance with the Georgia Emergency Operations Plan (GEOP). GEMA has responsibilities for coordinating the state of Georgia response to emergencies at nuclear power plants. EP A.2.2.2 Department of Natural Resources-Environmental Protection Division (DNR-EPD) Department of Natural Resources-Environmental Protection Division (DNR-EPD) is assigned as the coordinating and a primary agency responsible by Executive Order for implementation and administration of the state radiological and hazardous material function. 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). E6-43 to NL-16-0169 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 of 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 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

f. Houston County, Alabama Annex 1.7.1 Houston County, Alabama The wording was relocated and transferred to the The Chairman of the Houston (SEP A.2.4) Site Annex.

County Commission has the overall The Chairman of the Houston County responsibility for emergency Commission has the overall responsibility for preparedness and local response in emergency preparedness and local response Houston County. Houston County in Houston County. Houston County also has has also accepted responsibility for accepted responsibility for evacuations in evacuations in Henry County out to Henry County out to the 10 mile EPZ. The the 10 mile EPZ. The Houston Houston County Emergency Management County Emergency Management Agency coordinates planning and operations Agency coordinates planning and of all local agencies in support of an incident at operations of all local agencies in Farley Nuclear Plant. A detailed emergency support of an incident at Farley plan is maintained in case of an emergency at Nuclear Plant. A detailed emergency the Farley Nuclear Plant. plan is maintained in case of an An agreement is in place with Houston County, emergency at the Farley Nuclear Alabama to provide available resources and Plant. This plan is Part I of the equipment to support mitigation and response "Alabama Radiological Response to an emergency at Plant Farley to include Plan for Nuclear Power Plants". 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 Houston County 911 center, the county EOC, or through the Incident Command Post, as applicable, based on the nature and timing of the event. E6-45 to NL-16-0169 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) asset~. 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 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

g. Early County, Georgia 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 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

h. City of Dothan. Alabama - Fire Annex 1.7.3 Henry County Henry County because of its limited Department The Probate Judge of Henry County will exposure is managed through the State In the event an emergency (Section assume responsibility for Emergency of Alabama REP Plan. Specifically, IV) is declared as a result of a fire at Management operations and actions in the Henry County is not notified by FNP.

Farley Nuclear Plant, the Dothan Fire county. Henry County notification requirements Department has agreed to provide The Houston County Emergency Management for Plant Farley are met through the support to help combat the fire. The Director will oversee and coordinate notification of Houston County. In Dothan Fire Department resources emergency operations within Houston and accordance with the State of Alabama are listed in FNP-O-EIP-13, "Fire Henry Counties during an incident at FNPP. REP Plan: Emergencies". The estimated Emergency Management will take actions as "The Chairman of the Houston County response time to Farley Nuclear outlined in the Master Checklist Guide Commission and the Probate Judge of Henry Plant is 30 minutes. The Emergency (Attachment 4 to Appendix 1 of the Basic Plan) County will assume responsibility for all Director is authorized to request this to coincide with the current situation. Emergency Management operations and actions assistance. Request for fire support Because of the limited EPZ area in Henry in their counties. will be made by the control room or County the State of Alabama REP Plan directs The Houston County Emergency Management site security to the Houston County Houston County to assume overall direction of Director will oversee and coordinate emergency 911 center, Houston County EOG, or emergency response. Notification of Henry operations within Houston and Henry Counties the Incident Command Post, as County by FNP is met with the notification of during an incident at FNPP. Emergency applicable, based on the nature and Houston County. Management will take actions as outlined in the timing of the event. Master Checklist Guide (Attachment 4 to Annex 1.7.4 City of Dothan, Alabama (SEP Appendix 1 of the Basic Plan) to coincide with the 8.6.4) current situation." In the event an emergency is declared as a Section 1.7.3 of the Farley Annex has been result of a fire at Farley Nuclear Plant, the revised to clarify Henry County responsibilities for Dothan Fire Department has agreed to provide implementation of the Farley Emergency Plan is support to help combat the fire. The estimated provided as part of the RAJ response. response time to Farley Nuclear Plant is 30 The wording was relocated and transferred to the minutes. The Emergency Director is Site Annex. 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 EOG, or the Incident Command Post, as applicable, based on the nature and timing of the event. E6-48 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

2. Contractor and Private Offsite EP A.3.1 Southern Nuclear Operating The wording was relocated and transferred to the Organizations Company (SNC) SNC Standard Emergency Plan.

a. Southern Nuclear/Southern Southern Nuclear Operating Company (SNC) .

Company Services Southern serves as the architect-engineer. Company Services, Incorporated (SGS), an affiliated service company, served as the original architect-engineer. As a result of the consolidation of SGS 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 SGS to include design, licensing, and fuel management support during normal operation.

b. Bechtel Power CorQoration 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. E6-49 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equ!valent Justification Revision 64 Description

c. Westinghouse 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.

d. Institute of Nuclear Power EP A.4 Other Utilities The wording was relocated and transferred to the Ogerations (INPO), Nuclear Energy 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(8)). Also, r 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(8)). E6-50 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

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 (GPC) Central Company resources, (e.g., Georgia Laboratory). Power Company (GPC) Central Laboratory).

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 (INPO) 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(8)). 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 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

1. Technical Support Center (TSC) Annex 5.1.2 Technical Support Center The wording was relocated and transferred to the During any emergency condition the (SEP H.1.2) Site Annex.

center for coordinating all in-plant Located immediately north of the Unit 2 control activities will be the TSC. room area, the TSC (Figure 5.1.A) is designed Located immediately north of the for the evaluation of plant status, coordination Unit 2 control room area, the TSC is of damage assessment and emergency designed to accommodate up to 25 actions, and interface with the NRC, people for the evaluation of plant Emergency Operations Facility (EOF), and status, coordination of damage Operations Support Center (OSC). Provision assessment and emergency actions, is also made for control and coordination of and interface with the NRC, communications with offsite agencies and of Emergency Operations Facility out-of-plant radiation monitoring activities until (EOF) and Operations Support the EOF is activated and assumes these Center (OSC). functions. Provision is also made for control The TSC is designed to be habitable to the and coordination of communications same extent as the control room for postulated with offsite agencies and of out-of- radiological accidents. Its ventilation system plant radiation monitoring activities includes a deep-bed charcoal filter to remove until the EOF is activated and air-borne contamination, and it has the assumes these functions. The TSC capability of pressurizing the TSC area and when activated will normally maintain recirculating the room air through the charcoal the function of offsite filter. A permanent radiation monitor is communications for initial and provided to continuously indicate radiation upgrade notifications to federal, dose rates and airborne activity. A radiation state, and local authorities. An alarm in the main control room make-up air overall space of 22 feet x 65 feet, supply duct automatically initiates room with a 9-foot ceiling height, has been pressurization and recirculation. Electrical provided. Room layout is as follows: power sources are designed so the HVAC,

a. Monitoring Area wall outlets, and lighting can be powered from

b. Planning and Coordination the diesel generators if offsite power is lost.

Area The TSC maintains access to drawings and

c. Document Room records necessary for the response to an

d. Conference Area emergency event at FNP. These records can Figure 14 shows the above layout. 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 E6-52 to NL-16-0169 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 to NL-16-0169 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, and Unit Operating Procedures along

Emergency Plan Implementing Procedures.

with other general reference material.

Plant operating records .
System piping and instrumentation diagrams; heating, ventilation, and air-conditioning (HVAC) flow diagrams.
Electrical one-line, elementary, and wiring diagrams.
Control logic and loop diagrams .

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 012erations Facility EP H.2 Offsite 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 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

3. NRC Su1212ort 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 ft2) has been provided in this near-site facility.

4. 012erations Sur;mort 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 senie 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. 8), 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 to NL-16-0169 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 c;ind 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 OSC 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 NMP-EP-135, Alternative Facility Setup and Operation. E6-56 to NL-16-0169 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 JIC 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.

6. APC Cor12orate Media Center EP H.2.2 Corporate Media Center (CMC) The wording was relocated and transferred to the (CMC) Upon notification of an Alert or higher classification, SNC Standard Emergency Plan.

The APC Corporate Media Center the Public Information Director and corporate staff will be staffed by the Emergency assigned to JIC functions will assemble at the CMC. The CMC, located at the Atlanta/Birmingham Communication Organization and corporate headquarters building of Georgia Power serve as the coordination point for Company/Alabama Power Company, as APC corporate public information appropriate, is the official location for coordination of support. emergency communications response until the site specific JIC has been activated. The Public Information Director will coordinate with the EOF Emergency Director and affected OROs and determine whether to activate the site specific JIC. When the decision is made to activate the JIC the CMC will maintain emergency communications response coordination until the site specific JIC is ready to assume these responsibilities. Once overall responsibility for emergency communications response transfers to the site specific JIC the remaining CMC staff will provide support for the JIC as needed. E6-57 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 JIG. Upon the decision to activate the JIG, the Public Information Director and JIG staff transfer from the CMG to the site specific JIG. Once the JIG is staffed the Public Information Director will 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. 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. E6-58 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

1. Commercial Tele12hones 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, OSC, EOF, and at other locations private automatic exchange (PAX) onsite an*d 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. E6-59 to NL-16-0169 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 OSC) 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 EOC 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). E6-60 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description In addition to the PAX network, Annex 5.2 On-Site Communications (SEP The wording was relocated and transferred to the selected phones operate as off- F.1) Site Annex. premises extensions (OPX) of the Normal on-site communications is provided by APC Corporate Headquarters private the plant telephone system (network and automatic exchange and operate commercial). The plant public address (PA) independently of the plant PAX system also may be used for in-plant system. These phones may be used communications. The PA system is powered for calling APC/SNC facilities and by normal plant power, backed up by offices connected to the APC uninterruptible power. Corporate Headquarters PAX system Portable radios are used for communications or for accessing Bell Telephone between individuals and base stations located System commercial lines in in the Control Room, TSC, OSC EOF, and Birmingham. OPX and PAX phone Security. There is also a plant intercom availability is tabulated in Table 1. 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. E6-61 to NL-16-0169 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 012erations freguency - 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 freguency - 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. E6-62 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

c. Plant field monitoring freguency - EP F Table 5 The wording was relocated and transferred to the This radio frequency provides SNC 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 freguency) - This radio system SNC 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. E6-63 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

7. Sound Powered TeleQhone 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 SNC 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 Emergency 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, EOF, and in the Shift Foreman's office adjacent to the Control Room. E6-64 to NL-16-0169 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. E6-65 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

11. State/Local Agency Emergency EP F .1.2 SNC-operated plants maintain the The wording was relocated and transferred to the Notification Network (ENN} capability to make initial notifications to the SNC Standard Emergency Plan.

This communications system designated offsite agencies 24 hours per day. provides an immediate Offsite notifications can be made to state and communications link with the State of county warning points and Emergency Alabama, the State of Georgia and Operations Centers from the Control Room, local county personnel in Alabama Technical Support Center, and Emergency and Georgia who would possibly be Operations Facility using the ENN. Reliable notified in the event of an backup methods have been written into emergency. Telephones with procedures. State and county warning points speakers on this communication are continuously staffed. network are located at the EOF; EP F.1.3 Provisions exist for continuous TSC; Shift Foreman's Office adjacent communications with state and local to the control room; Alabama governments within the Emergency Planning Radiation Control Division; Alabama Zones, as detailed above. At least one on-site Emergency Management Agency; and one offsite communications system is State of Alabama Department of maintained, each with a backup power source Public Safety; Houston County (AL) to ensure continuous communications. Sheriffs 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 Sheriffs Dispatcher's Office, and the Early County Sheriffs Dispatcher's Office are staffed 24 hours a day. E6-66 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

12. NRG Reactor Safety Counteq~art 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 NRG to conduct The current operation of the FTS system allows communications link for the NRG to internal NRG discussions on plant equipment any phone with long distance capability to call into conduct internal NRG discussions on conditions separate from the licensee. the Headquarters Operations Center and be plant equipment conditions separate patched into any bridge. The specific listing from the licensee. becomes redundant to the expanded capability Phones are located in the TSC and EOF.

13. Protective Measures CounterQart EP F .1.4.4 Protective Measures Counterpart The wording was relocated and transferred to the Link (PMCL) Link (PMCL) SNC Standard Emergency Plan.

This dedicated FTS communications This communications line provides a line provides a dialup communications link for the NRG to conduct The current operation of the FTS system allows communications link for the NRG to internal NRG discussions on radiological any phone with long distance capability to call into conduct internal NRG 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. Management CounterQart Link EP F.1.4.5 Management Counterpart Link The wording was relocated and transferred to the (MCL) (MCPL) (Executive Bridge Line) SNC Standard Emergency Plan:

This dedicated FTS communications This communications line provides a line provides a dialup communications link for any NRG internal The current operation of the FTS system allows communications link for any NRG discussions between the NRG 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 NRG Executive Team Director or NRG 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 NRG Director of Site Operations or top level licensee management at the site. Phones are located in the TSC and EOF. E6-67 to NL-16-0169 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 FTS 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 Integrated 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. E6-68 to NL-16-0169 Farley Justification-Matrix Current F~rley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

18. Emergency Res~onse Data EP F.1.4.8 Emerg(!ncy Response Data The wording was relocated and transferred to the System (EROS) System (EROS) SNC Standard Emergency Plan.

These communications lines provide EROS 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 NRG any phone with long distance capability to call into the site to the NRG. The affected Operations Center. It provides for the the Headquarters Operations Center and be Unit EROS 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 indivi_dual 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. E6-69 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

1. Onsite S~stems and EguiQment Annex 5.6.1 Geophysical Phenomena The wording was relocated and transferred to the

a. Natural Phenomena Monitors Monitors (SEP H.5.1) Site Annex.

The plant is equipped with a Meteorological (SEP H.5.1) meteorological tower instrumented A meteorological monitoring program is in as shown in Table 2, with both place at FNP. Instruments are mounted on a primary and secondary 60-meter tower located on the plant site. instrumentation for wind speed (1 Om Parameters measured and transmitted to the and 45.7m), wind direction (10m and control room include: 45.7m), ambient temperature (10m

Windspeed (10 m and 45.7 m).

and 60m), and dew point (1 Om and

Wind direction (10 m and 45.7 m) .

60m). There is also a single channel

Vertical temperature difference (1 Om and of instrumentation for precipitation 60m).

with associated data loggers located

Ambient temperature (10 m and 60 m) .

at the meteorological tower building. The meteorological tower

Dewpoint temperature (10 m) .

instrumentation feeds wind speed,

Precipitation (base) .

The meteorological tower instrumentation wind direction, precipitation, dew feeds wind speed, wind direction, precipitation, point, delta temperature, and sigma dew point, delta temperature, and sigma theta theta data to the plant computer. data to the plant computer. This data is used This data is utilized for dose for dose calculations. Computer terminals_ in calculations. Computer terminals in the TSC and EOF can obtain real time or 15-the TSC and EOF can be utilized to minute average readouts of meteorological obtain real time or 15 minute data. Should the plant's meteorological average readouts of meteorological equipment become inoperable, information is data. Should the plant's available from the approved Flight Service, meteorological equipment become from the Georgia Pacific Paper Company, or inoperable, information is available from the regional National Weather Service from the approved Flight Service, offices. from the Georgia Pacific Paper The important parameters for characterizing Company, or from the regional the transport of airborne radioactivity are wind National Weather Service offices. 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. E6-70 to NL-16-0169 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 FSAR A discussion of service water pond level Section 9.2.1.5. monitors is given in FSAR Section 9.2.1.5. E6-71 to NL-16-0169 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

Air Particulate detectors capture and itemized listing can be found in FNP- measure airborne particulate.

O-EIP-16, "Emergency Equipment Emergency response procedures provide and Supplies". methods for determining relationships between monitor readings and releases, material

                                   -   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 12.104. 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. E6-72 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

c. Post Accident Sam~ling 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 throughout the course of an event inclu,de pressurized (RCS) and plant parameter display systems, liquid and unpressurized (RHR/containment gaseo1,1s 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". E6-73 to NL-16-0169 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 SNC 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 SNC Standard Emergency Plan. assessment is as follows: nuclear power plants. Designated site or

a. OSLDs 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.

E6-74 to NL-16-0169 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-O-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 FNP 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 GPC 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 hours. E6-75 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description The plant is equipped with a EP 1.3 Offsite Dose Assessment The wording was relocated and transferred to the computer which utilizes automatically SNC-operated nuclear power plants use an SNC Standard Emergency Plan. input meteorological data, effluent offsite dose assessment program that monitor data and selected plant estimates doses from radiological accidents for The MIDAS-NU model in use for the Fleet is a full parameter data (e.g. steam comparison with the EPA Protective Action class B dose assessment model that supports generator pressure, plant vent stack Guidance and acute health effect thresholds. multi-unit and multi-accident modeling, while the flow rate, etc.) to calculate estimated The dose calculation model is available in the ARDA program is a simple Class A dose and projected offsite dose. Control Room, TSC, and EOF for use in assessment model without multi-unit and multi-The system automatically actuates projecting potential offsite doses. accident capability. The MIDAS model meets all when effluent monitors indicate The program estimates reactor source term, existing regulatory requirements, so the ARDA abnormal release point activity and atmospheric transport, and doses resulting program is no longer needed. continues until manually terminated. from radiological emergencies, and can be Calculational results are available at used to assist in making protective action computer terminals located at the determinations The system supplements TSC, EOF and other selected assessments based on plant conditions. locations. 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. E6-76 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description In the event that the above computer EP 1.3 Offsite 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. E6-77 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description A detailed discussion of the EP 1.3 Offsite 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-O-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 no~ be precisely known. E6-78 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Results of dose estimates and EP 1.3 Offsite 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. EP J.5 Offsite Protective Action Recommendations (PARs) Plant conditions, projected dose and dose rates and field monitoring data are communicated to offsite agencies responsible for dose assessmenUPARs to assist them in developing parallel assessments. E6-79 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

3. Personnel Monitoring Eguigment 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 ~ection 111.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 hours. All dose results will be retained in permanent records for each individual. E6-80 to NL-16-0169 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 Equipment 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). EEl-81

Enclosure 6 to NL-16-0169 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 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 I 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. E6-82 to NL-16-0169 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. E6-83 to NL-16-0169 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 on$ite 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 to NL-16-0169 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. E6-85 to NL-16-0169 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. E6-86 to NL-16-0169 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. E6-87 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

2. Decontamination and First Aid EP K.1.2.1 Onsite Responsive Action The wording was relocated and transferred to the A first aid station and a Selected plant workers at SNC-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 TrainingNisitors 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.1.2.1 Onsite 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. E6-88 r to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

3. Medical Trans1;1ortation 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 EOC, 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 FNP.

a. Local Rescue Sguads 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.

E6-89 to NL-16-0169 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- SNC-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. E6-90 to NL-16-0169 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 Hosgital 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. E6-91 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

c. Oak Ridge 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 - REAC/TS 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 D. 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. E6-92 to NL-16-0169 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. E6-93 to NL-16-0169 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 Sampling. 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-O-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. E6-94 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

2. Surveillance of Control Room EP 1.1 To adequately assess the emergency The wording was relocated and transferred to the Monitors condition, applicable emergency facilities have SNC Standard Emergency Plan.

Surveillance of radiological and the equipment and instrumentation necessary meteorological monitors in the to monitor essential plant information, except control room is primarily the where local monitoring is required. Evaluation responsibility of operations of plant conditions is accomplished by personnel. However, in the event monitoring plant parameters from both the that offsite assessments based on Control Room and within the plant. this data are necessary, an individual EP 1.2 Continuing and Post Accident designated by the Emergency Assessment Director will maintain surveillance The resources available to provide initial and over effluent monitor readings and continuing information for accident assessment dose projections, periodically throughout the course of an event include reporting them to those designated in plant parameter display systems, liquid and FNP-O-EIP-6, "TSC Setup and gaseous sampling system, Area and Process Activation". If the dose assessment Radiation Monitoring Systems, and Accident computer is inoperable, the Radiation Monitoring Systems. Descriptions of designated individual will periodically these systems are given in Section H. Details log the monitor values. on performing post-accident sampling are in the plant-specific procedures. E6-95 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

3. In-Plant and Site Surveys EP 1.7 Environs Surveys and Monitoring The wording was relocated and transferred to the During emergency conditions in- In addition to the capabilities and resources SNC Standard Emergency Plan.

plant, site and site boundary surveys described in Section H, SNC-operated nuclear will be performed as appropriate by power plants have the ability to take offsite air the Field Monitoring Team as samples and to directly measure gamma dose described in FNP-O-EIP-4, "Health rates from a radioactive material release. The Physics Support to the Emergency capability to take offsite soil, water, and Plan." The Field Monitoring Team will vegetation samples is provided by a minimum be capable of sampling under of two (2) Field Monitoring Teams (FMTs). field conditions and will be capable of The environmental monitoring ~quipment measuring radioiodine in the includes portable survey, counting, and air presence of noble gas and sampling instrumentation, and other background radiation to as low as 5 x radiological monitoring equipment and 10-8 uCi/cc. 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. E6-96 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

4. Po12ulation Ex12osure EP 1.3 Offsite 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 model 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 (COE) determinations The system supplements exposure (resulting from the assessments based on plant conditions. inhalation of radio-iodines).

5. Environs Surveys and Monitoring 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. E6-97 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Onsite and offsite surveys will be EP 1.3 Offsite 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. E6-98 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Monitoring teams will normally be EP 1.7 Environs Surveys and Monitoring The wording was relocated and transferred to the dispatched in vehicles and will be In addition to the capabilities and resources SNC Standard Emergency Plan. equipped with two-way radios for described in Section H, SNC-operated nuclear communication with the TSC or EOF. 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. E6-99 to NL-16-0169 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 SNC Standard Emergency Plan. instrument, an ion chamber described in Section H, SNC-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 EOF staff.

E6-100 to NL-16-0169 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, SNC 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. E6-101 to NL-16-0169 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-O-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. E6-102 to NL-16-0169 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 applicatior:i, 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 agencie~. E6-103 to NL-16-0169 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, EP J.4.1Assembly The wording was relocated and transferred to the General Emergency, or an Alert be Assembly is mandatory following the SNC Standard Emergency Plan. declared, immediate notification of all declaration of a Site Area or General persons onsite may be accomplished Emergency, or at the discretion of the The senior individual referenced in the current by sounding the Plant Emergency Emergency Director. When Accountability of Plan is not an ERO assigned position. In Alarm and announcing the condition onsite personnel is determined to be accordance with existing procedures, the most over the plant public address system. necessary by the Emergency Director, senior person responding takes on a general Personnel onsite would report to personnel within the Protected Area will be leadership role in that area. Standard their pre-assigned assembly area accounted for and the names of missing and preparations for evacuation of Emergency Plan Section J.4.1, Assembly, has individuals determined within 30 minutes of the nonessential persons from the site emergency declaration. been revised to include the statement with would begin. Depending on the respect to assumption of leadership The Assembly Area senior individual will take responsibilities at an assembly area. severity of the emergency condition, the lead in coordinating the activities of the these individuals will be held in an Assembly Area in support of OSC operations assembly area, evacuated, or as directed by the OSC Manager. returned to work. E6-104 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. The current Plan had significant detail that South and County Road 42 West Personnel will be directed to either proceed to included information that may not be appropriate (Figures 17 and 19). All personnel their homes or reassemble at designated to a specific event. Planned evacuation routes being evacuated from the site will be locations. Visitors to the plant will assemble are useful to maintain in an EPIP but may require monitored before being released. with and follow the instructions of their escorts. adjustment based on environmental and plant Personnel leaving the site would Personal transportation will normally be used conditions. Similarly, other factors contained in then proceed, in their own vehicles, and established evacuation routes will be this paragraph are more appropriately handled on on one of these major routes, to their followed. Personnel without transportation will an event specific bases. The use of site residences. Transportation for be identified and provided transportation as resources to monitor all personnel prior to leaving persons without vehicles will be necessary. the site may not be required if the site evacuation arranged. Evacuation of personnel is usually conducted occurs prior to any release. Evacuation using immediately after accountability if a Site Area personnel vehicles may or may not be Emergency or General Emergency has been appropriate. declared and no impediments exist. Evacuation shall commence as directed by the The Standard Plan, supported by the Site Emergency Director. Annexes, maintains the commitment to conduct a Site Evacuation if conditions dictate. The process of conducting the Evacuation has been moved to EPIPs to allow flexibility based on event conditions. E6-105 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description 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-O-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 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

b. Personnel Accountabilit~ 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 The senior individual referenced in the current persons working in or visiting his at the discretion of the Emergency Director to Plan is not an ERO assigned position. In group. Accountability within the support worker safety. accordance with existing procedures, the most Protected Area will be determined by Accountability of personnel within the senior person responding takes on a general the senior individual at the assembly Protected Area is accomplished within 30 leadership role in that area. Standard Emergency area coordinating with the Security minutes of the declaration of Site Area Plan Section J.4.1, Assembly, has been revised to Response Center (SRC) and then Emergency or higher, and maintained include the statement with respect to assumption will be reported to the Emergency continuously thereafter, using Protected of leadership responsibilities at an assembly area. 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 (PMMS) 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 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 FNP-0-EIP-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 to NL-16-0169 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.4 Onsite 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. E6-109 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

c. Contamination and Ex12osure EP K.1 Under normal operating conditions, The wording was relocated and transferred to the Control Measures SNC-operated plants maintain personnel SNC Standard Emergency Plan.

The limits for personnel exposure set exposure control programs in accordance with forth in 10CFR20 shall not be 10 CFR 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." E6-110 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

1) Farley Nuclear Plant EP Table K.1.A The wording was relocated and transferred to the personnel who have SNC Standard Emergency Plan.

completed the onsite radiation protection training, may receive o 10 Rem 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. o >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 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

2) Hospital and Ambulance EP Table K.1.A The wording was relocated and transferred to the Service Personnel, may SNC Standard Emergency Plan.

receive o3 Rem If there is an adequate number of attendants such that rotation may be accomplished without further endangering the patient(s). o5 Rem If the number of attendants is limited such that personnel cannot be rotated. 025 Rem To save a life. E6-112 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Dosimetry, respiratory protection EP J.4 Onsite Protective Actions The wording was relocated and transferred to the equipment and protective clothing Onsite protective actions for routine and SNC Standard Emergency Plan. will be issued for use in accordance emergency conditions are detailed in the with established Radiological Control plant's Radiation Protection Program. SNC-Procedures. A supply of radio operated nuclear power plants maintain an protective drugs (potassium iodide) inventory of respiratory protection equipment, is available onsite and, if necessary, anti-contamination clothing, and potassium will be issued at the direction of the iodide (Kl) that is available to emergency Emergency Director to emergency workers remaining on site. During an personnel remaining or arriving emergency, protective actions would be taken onsite. 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 (Kl - Potassium Iodide) to emergency personnel depends on the projected absorbed dose to the thyroid based on the severity and magnitude of the accident.

E6-113 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description The levels of permissible radioactive No equivalent Plan/Annex 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 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description However, the Emergency Director EP K.1 Under normal operating conditions, The wording was relocated and transferred to the may authorize higher levels based SNC-operated plants maintain personnel SNC Standard Emergency Plan. on plant conditions and exposure control programs in accordance with recommendations from the HP 10 CFR 20. The Emergency Director has Supervisor. When levels above these responsibility for authorizing personnel values are encountered, exposure levels under emergency conditions decontamination will be initiated. using the guidance in Environmental Facilities, supplies and waste Protection Agency (EPA) 400-R-92-001, disposal capability exists to provide "Manual of Protective Action Guides and for both personnel (emergency or Protective Actions for Nuclear Incidents." onsite relocated) and equipment EP K.5 Decontamination decontamination. Methods for The Radiation Protection Group will be equipment decontamination are responsible for controlling or minimizing direct discussed in or subsequent internal exposure from NMP-HP-304, "Decontamination of radioactive materials deposited on the ground* Areas, Tools, and Equipment" and or other surfaces, and for determining the for personnel in NMP-HP-303, extent of contamination in controlled and "Personnel Decontamination" with normally uncontrolled areas. During normal particular attention being given to conditions or an emergency, guidelines to radioiodine contamination of the skin. follow for contamination limits are established Extra clothing for personnel will be by the site radiation protection program. provided in the event personal Facilities and supplies for decontaminating clothing is confiscated. Information personnel are available at various plant on personnel decontamination locations. Personnel leaving the Radiological facilities is contained in Section Ill. 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. EG-115 to NL-16-0169 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.7 Offsite Decontamination The wording was relocated and transferred to the contaminated when monitored during Nonessential onsite personnel may be SNC 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.7 Offsite Decontamination The wording was relocated and transferred to the described in the states of Alabama, Nonessential onsite personnel may be SNC 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 to NL-16-0169 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 to NL-16-0169 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.5 Offsite 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. SNC-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 Plant conditions, projected dose and dose rates would make an evacuation and field monitoring data are communicated to dangerous. Areas within a ten mile offsite agencies responsible for dose radius in which protective action is assessmenUPARs to assist them in developing deemed necessary will be referred to parallel assessments by Evacuation Zone as shown in There are various types of protective actions Figure 21. The population distribution that can be recommended to the state and within this ten-mile radius has been counties. They may include the following: predicted for the life of the plant and

Evacuation .

is summarized graphically in Figure

Shelter in place .

22.

Monitor and prepare .
Thyroid blocking agent (consider using Kl (potassium iodide)) in accordance with state plans and policy.

E6-118 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

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 Rem Thyroid COE The data is not needed in the plan. SITE AREA 0.1 Rem TEDE 0.5 Rem Thyroid COE E6-119 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

b. Response EP J.5 Offsite 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-112, "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 Plant conditions, projected dose and dose rates Response Organizations were fully and field monitoring data are communicated to involved in the development of the offsite agencies responsible for dose PARs. assessment/PARs to assist them in developing The Emergency Director will approve parallel assessments the PAR decision developed by the There are various types of protective actions methodology in the Initial and Follow- that can be recommended to the state and Up Flowcharts, shown as Chart 1, counties. They may include the following: Initial and Chart 2, Follow-Up.

Evacuation .

Recommendations will be based on

Shelter in place .

plant conditions, projected dose

Monitor and prepare .

estimates, or available monitoring

Thyroid blocking agent (consider using data. Kl (potassium iodide)) in accordance with state plans and policy.

E6-120 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description SITE AREA EP J.5 Offsite 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 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. Plant conditions, projected dose and dose rates and field monitoring data are communicated to offsite agencies responsible for dose assessment/PARs to assist them in developing parallel assessments There are various types of protective actions that can be recommended to the state and counties. They may include the following:

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

E6-121 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description ALERT EP J.5 Offsite 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. SNC operated plants have the capability to provide state and local agencies a PAR for beyond the 10-mile EPZ. Plant conditions, projected dose and dose rates and field monitoring data are communicated to offsite agencies responsible for dose assessmenUPARs to assist them in developing parallel assessments There are various types of protective actions that can be recommended to the state and counties. They may include the following:

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

E6-122 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description The authority for initiation or EP 8.1.1 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) The language related to relaxation of PARs was may not be delegated to any other determination. eliminated from the Emergency Plan because the member of the emergency offsite agencies through their independent organization. Processes for analyses determine the appropriateness of development, approval, and relaxation of protective action recommendations.

notification of protective action Section D.2.5 contains guidance on the site recommendations are described in determination to downgrade the Emergency NMP-EP-111, "Emergency Classification. Additional guidance was provided Notifications", and NMP-EP-112 as part of this response to communicate any "Protective Action decision to terminate or transition to recovery and Recommendations". will be submitted as part of this response. 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 8.1.1 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. E6-123 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Upon declaration of an emergency EP 8.1.1 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 SNC 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 8.1.1 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 EOF 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.

8. ORGANIZATION ACTIVATION EP 8.1 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. E6-124 to NL-16-0169 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 8.1: 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 8.1.1 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-110, "Emergency Classification Determination and Initial Action". E6-125 to NL-16-0169 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 8.2.8 through 8.2.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. E6-126 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

1. Technical Support Center EP H.1 Onsite 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 II. The TSC will be staffed and ready (OSC), 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. E6-127 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description There shall be sufficient personnel EP 8.1 SNC plants maintain 24-hour The wording was relocated and transferred to the available within 16 hours 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. Ogerations Suggort Center {OSC) EP H.1 Onsite 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 8.2.C requiring OSC 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 hours after qeclaration of an EP H.1 Onsite Emergency Response The wording was relocated and transferred to the emergency, sufficient personnel shall Facilities SNC Standard Emergency Plan. be available in the OSC to ensure SNC 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 Fig1:1re 8.2.C E6-128 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Within 16 hours after declaration of EP H.1 Onsite Emergency Respom;e The wording was relocated and transferred to the an emergency, sufficient personnel Facilities SNC Standard Emergency Plan. shall have been notified and placed SNC-operated nuclear power plants have on-call to ensure that the OSC can established a TSC and an onsite OSC, 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 8.2.C

3. Emergency 012erations 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 HNP). The EOF is procedurally required to be activated within 75 minutes following the declaration of an Alert or higher classification, E6-129 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

4. Alternative Facilit~ 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 OSC personnel. The emergency response staff and Alternative Facility is designed to be provides the capability for accessible in the event of an onsite HAS 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-135, 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 EOF 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 1O(J). and HNP). The EOF is procedurally required to be activated within 75 minutes following the declaration of an Alert or higher classification. E6-130 to NL-16-0169 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 AGENCIES Operations Centers (EOC) SNC Standard Emergency Plan. Notification of offsite governmental EOCs 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 Georgia:

Georgia Emergency Management Agency (GEMA).

Georgia County Authorities:

Early County Sheriff's Dispatcher's Office .

E6-131 to NL-16-0169 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.

E6-132 to NL-16-0169 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 - (OSC), 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 hour 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-EI P-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-O-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. E6-133 to NL-16-0169 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 SNC, 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. E6-134 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description NMP-EP-111, "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 SNC sites and messages that will be used by the established the contents of the initial state expanded to better align with current guidance. Emergency Director to notify the notification message forms to be used during state and local agencies for the an emergency. These forms are described in different classifications of EPIPs. The content of the forms has been emergencies. The content of reviewed and agreed on by the respective emergency messages has been Offsite Response Organizations. mutually agreed upon with State and Local agencies. The procedure to be followed for message authentication is contained in NMP-EP-111, "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 E6-135 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Required follow-up message EP E.2.2.3: In conjunction with state and The wording was standardized and relocated to information has been agreed upon county authorities, SNC-operated plants have the SNC Standard Emergency Plan.

by the states. NMP-EP-111 makes established the contents of the subsequent provisions for follow-up messages to state notification message forms to be used be sent to the states. These during an emergency. The Emergency messages contain the following Director is responsible for the completion of a information as appropriate: follow-up emergency message. The

1. Location of incident and name and appropriate ERO personnel will ensure the telephone number (or emergency communicator(s) periodically communications channel provide follow-up messages to the appropriate identification) of caller offsite federal, state, and local authorities

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 E6-136 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description B. PLUME EXPOSURE PATHWAY EP E.2.5: Prompt alerting and notification of the public within the The Standard Plan (Section E.2.5.1 ),the Farley plume exposure pathway EPZ is the obligation of state and local EMERGENCY PLANNING ZONE government or other responsible authority. The responsibility for Annex (Section 4.2) and the respective PUBLIC NOTIFICATION AND ensuring the means exist to carry out this purpose rests with Justification Matrices have been updated to reflect Southern Nuclear Operating Company.

INFORMATION a more extensive description of the FEMA

1. Notification Annex 4.2: Within the Plume Exposure Emergency Planning Zone approved primary and back-up systems. The (EPZ). there exist provisions for alerting and providing notification

a. Primary to the public.

wording was standardized and aligned with Southern Nuclear Operating The FEMA approved Farley ANS consists of a primary ANS and a current wording. Specific requirement for the Company has provided the backup system should there be a failure of the primary system. communities is maintained in the revised

Primary - Sirens and Emergency Alert System (EAS) administrative and physical means stations description in the Site Annex.

for alerting and providing prompt

System Backup - Reverse calling system The primary ANS has two communications pathways. The first instructions to the public within the pathway is through the primary agency via the UHF or VHF radio.

plume exposure pathway EPZ by Should the primary agency fail to activate the system, the providing an Alert and Notification secondary pathway will be utilized by the secondary agency. The secondary pathway functions in the same manner as the primary System (ANS) for the entire plume pathway utilizing a separate activation console that is physically exposure pathway EPZ. Primary located in separate location. If neither agency can activate the system, the backup system will be utilized to notify the residents of alerting is accomplished by use of a the 10 mile EPZ. siren system. The siren alerting The hierarchy for system activation is provided below: AQencv Radio Svstems system consists of 89 pole mounted sirens. Each siren operates on Primary UHF Agency battery power with battery charge maintained through an inverter that VHF Primary Sirens & EAS receives power from the local Secondary UHF electrical grid or from a solar panel. Agency Each siren site contains two radios - VHR one for the primary radio signal frequency operating in the UHF band Backup Each County Calling and one for the backup radio EMA System frequency operating in the VHF band. Repeaters for the primary and backup radio frequencies are Alabama Georgia provided on two separate radio towers with associated power, Primary Agency Houston Early County control, and radio communication County provided. Siren system activation, Secondary Henry County State of test, and monitoring panels are Agency Georgia provided at each for the counties of (GEMA) Houston and Henry County, Alabama; one for Early County, Annex 4.2: Siren system activation. test, and monitoring panels are provided for Houston County and Henry County in Alabama, Georgia; and one for the State of Early County in Georgia, and the state of Georgia. Georgia. ic;u- I.JI to NL-16-0169 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. E6-138 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Following activation of the siren Annex 4.2 Within the Plume Exposure Emergency Planning Zone The Standard Plan (Section E.2.5.1 ),the Farley (EPZ), there exist provisions for alerting and providing notification system, emergency notifications will to the public. The state and/or local authorities are responsible for Annex (Section 4.2) and the respective be made to the public within the 10 activation of this system. The FEMA approved Farley ANS Justification Matrices have been updated to reflect consists of a primary ANS and a backup system should there be a mile plume exposure pathway EPZ failure of the primary system. a more extensive description of the FEMA by activation of the Emergency Alert

Primary - Sirens and Emergency Alert System (EAS) approved primary and .back-up systems. The stations System (EAS). State and local wording was relocated and transferred to the Site
System Backup - Reverse calling system Emergency Management Agencies The primary ANS has two communications pathways. The first Annex.

will initiate activation of the local EAS pathway is through the primary agency via the UHF or VHF radio. Should the primary agency fail to activate the system, the stations through a dedicated EAS secondary pathway will be utilized by the secondary agency. The activation console. The EAS secondary pathway functions in the same manner as the primary pathway utilizing a separate activation console that is physically activation console provides a located in separate location. If neither agency can activate the connection to designated EAS system, the backup system will be utilized to notify the residents of stations that allows for activation of the 10 mile EPZ. The hierarchv for svstem activation is orovided below: the station through redundant Agency Radio Systems communications pathways. Primary UHF Emergency messages are Agency transmitted from the EAS activation VHF console via phone line, internet, or Primary Sirens & EAS satellite connections. Activation of Secondary UHF the station does not require that the Agency station be manned. Emergency VHR messages are coordinated between Backup Each County Calling the local Emergency Management EMA System Agencies and the State Emergency Management Agencies prior to activation of the local radio stations, as specified in the local area plans. A Alabama Georgia full description of the Farley ANS Primary Agency Houston Early County . design is provided in the FEMA County approved ANS Design Report (ANS-FNP-001) in the SNC document Secondary Henry County State of management system. Agency Georgia (GEMA) 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. E6-139 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

b. Special Alerting and System Annex4.2 The Standard Plan (Section E.2.5.1 ),the Farley The FEMA approved Farley ANS consists of a primary ANS and a Backup backup system should there be a failure of the primary system. Annex (Section 4.2) and the respective Special alerting is accomplished

Primary - Sirens and Emergency Alert System (EAS) Justification Matrices have been updated to reflect stations through the use of a calling system.
System Backup - Reverse calling system a more extensive description of the FEMA Special alerting is initiated in the The primary ANS has two communications pathways. The first approved primary and back-up systems. The event of a failure of the system to pathway is through the primary agency via the UHF or VHF radio. wording was relocated and transferred to the Site Should the primary agency fail to activate the system, the activate multiple sirens resulting in a secondary pathway will be utilized by the secondary agency. The Annex.

loss of coverage in any area. Special secondary pathway functions in the same manner as the primary pathway utilizing a separate activation console that is physically alerting may be initiated for a located in separate location. If neither agency can activate the predefined area, a user specified system, the backup system will be utilized to notify the residents of the 10 mile EPZ. area, user defined groups, or the The hierarchy for system activation is provided below: entire Emergency Planning Zone A<1encv Radio Svstems (EPZ). The calling system serves as Primary UHF a complete backup to the ANS. The Agency system provides both alerting and VHF notification of EPZ residents Primary Sirens & EAS independent of the alerting Secondary UHF Agency capabilities provided by the installed VHR siren system and notification capability of local radio and television Backup Each County Calling stations through EAS. Capability for EMA System 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 Alabama Georgia Georgia. Primary Agency Houston Early County County Secondary Henry County State of Agency Georgia (GEMA) Special alerting uses a calling system. Special alerting is initiated in the event of a failure of the system to activate multiple sirens resulting in a loss of coverage in any area. Special alerting may be initiated for a predefined area, a user-specified area, user defined groups, or the entire Emergency Planning Zone (EPZ). The calling system serves as a complete backup to the ANS. The system provides both alerting and notification of EPZ residents independent of the alerting capabilities of the installed siren system and the notification capability of local radio and television stations through EAS. Capability to activate of the calling system is provided for Houston County and Henry County, Alabama and Earty County, Georgia.

                                                                                      --       ~

c::u-1'"tU to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

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 1O(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.

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 JIG as appropriate. The Facility Manager at that location will obtain communications approval and direct distribution of the release. C. NRG OFFICE OF INSPECTION EP 8.1.1 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 NRG Regulatory Commission of any notifications.

emergency condition utilizing the Emergency Notification System. E6-141 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Section Vl.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 lnteragency Radiological Assistance Team can be expected to respond to SNC operated sites as directed by the Savannah River Operations Office of DOE. F. FIRE VII. RECOVERY EP M.1 Recovery The wording was relocated and transferred to the A. METHODOLOGY Guidance for determining the transition from SNC 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. E6-142 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description The decision to relax protective EP M.1: The following guidelines, as The SNC 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.

5. The integrity of power supplies

For a site area emergency or general 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.

E6-143 to NL-16-0169 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 SNC Standard Emergency Plan. areas listed above to determine if to terminating the emergency: pl~nt restoration efforts can begin. The following criteria sh~ll be

The affected reactor is in a stable condition and can be mair;itained in that considered appropriate. for the condition indefinitely.

consideration of relaxation of protective measures:

Plant radiation levels are stable or are decreasing with time.

1. Plant parameters of operation no longer indicate a potential or actual

Releases of radioactive material to the emergency exists. 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 susta.ining

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.

E6-144 to NL-16-0169 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 11.8.3. 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.

E6-145 to NL-16-0169 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 SNC 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 EP N.2.1 SNC-operated nuclear power plants The wording was relocated and transferred to the PREPAREDNESS shall ensure adequate emergency response SNC Standard Emergency Plan. A. EXERCISES AND DRILLS capabilities are maintained during the interval Periodic drills and exercises will be between biennial exercises by conducting conducted as described below. The drills, including at least one drill involving a scenarios for use in these drills will combination of some of the principal functional include the following elements: areas of the licensee's onsite emergency

The basic objective, response capabilities. The principal functional
The date, time, place(s) and areas of emergency response include:

participating organizations,

Management and coordination of
The simulated event, emergency response .
A time schedule of real and
Accident assessment; simulated events,
Event classification.
A narrative summary
Notification of offsite authorities.

describing conduct of the

Assessment of the onsite and offsite drill. impact of radiological releases.
Protective action recommendation development.
Protective action decision making .
Plant system repair and corrective actions.

E6-146 to NL-16-0169 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 formal critique will be performed for SNC Standard Emergency Plan. observe each individual's ability to exercises, drills, and training tabletops to perform his assigned emergency develop, maintain, or demonstrate key skills in function. During drills and Nuclear order to identify weak or deficient areas that Regulatory Commission (NRG) non- need correction. evaluated exercises, on-the-spot A critique shall be conducted at the conclusion correction of erroneous performance of the exercise, to evaluate the organization's and a demonstration of proper ability to respond as called for in the SNC performance may be made by the Standard Emergency Plan. Qualified monitoring personnel. personnel will observe and perform a critique of exercises and drills. Provisions will be made for federal, state, and local observers, as well as SNC personnel, to observe and critique required exercises. E6-147 to NL-16-0169 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 handling emergencies,

Notification of offsite authorities .

2) To evaluate communications and

Assessment of the onsite and offsite impact of radiological releases.

action support with offsite agencies,

3) To evaluate the interface with and

Protective action recommendation development.

the response of the Company Emergency Organization,

Protective action decision making .

4) Test the adequacy, timing, and

Plant system repair and corrective 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.

E6-148

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

b. Both full-scale and small-scale EP N.3 The wording was relocated and transferred to the exercises will be conducted and will During the exercise planning cycle described SNC Standard Emergency Plan.

include participation by appropriate State in Section N.1.5, SNC sites vary the content of and local government agencies as exercise scenarios to provide ERO members follows: the opportunity to demonstrate proficiency in

1) A full scale exercises which tests as much of the Plant Farley, State, and local key skills necessary to respond to several emergency plans as is reasonably specific scenario elements including:

achievable without mandatory public

Hostile Action directed at the plant site.

participation will be conducted on a

No radiological release, or unplanned biennial basis and evaluated by NRC and release that does not require public FEMA. protective actions.

(a) Biennial exercise scenarios will be submitted to the NRC under§ 50.4 at

An initial classification of, or rapid least 60 days before use in the biennial escalation to, a Site Area Emergency or exercise. General Emergency.

(b) Each biennial exercise scenario will

Implementation of strategies, procedures, provide the opportunity for the ERO to and guidance developed in 50.54(hh) (i.e.,

perform their key skills, as applicable, to potential aircraft threat, explosion or large their emergency response duties in fire). the CR, TSC, OSC, EOF, and joint information center to implement the EP

Integration of offsite resources with on-principal functional areas. site response.

(c) Biennial evaluated exercises will be

A drill initiated between the hours of 6 varied such that the following scenario p.m. and 4 a.m.

elements are demonstrated over the

Drills using essentially 100 percent of course of an 8-year exercise cycle: Initiating Conditions in the 8- year cycle.
Hostile action directed at the plant site. Drills and exercise scenarios will be varied
No radiological release or an unplanned from year to year to test major components of minimal radiological release that does the plans and preparedness organizations.

not require public protective actions. A record of exercises conducted during the 8-

Initial classification of or rapid escalation to a Site Area Emergency or year exercise planning cycle that documents General Emergency. the contents of scenarios used during that
Implementation of strategies, cycle shall be maintained in accordance with procedures, and guidance developed Drill and Exercise procedure guidance.

under 10 CFR 50.54 (hh)(2). SNC sites submit Biennial Exercise scenarios

Integration of offsite resources with under 10 CFR 50.4 for NRC review 60 days onsite response. prior to the exercise.

E6-149 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description (d) An ingestion pathway exercise EP N.1.3 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.

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 functional areas of emergency

Notification of offsite authorities; response include:
Assessment of the on-site and offsite impact of radiological releases.
Event classification.
Notification of offsite authorities.
Protective action recommendation development.
Management and coordination of emergency response.
Protective action decision making .
Accident assessment.
Plant system repair and corrective actions.
Assessment of the onsite and offsite impact of radiological releases.
Protective action recommendation development.
Protective action decision making.
Plant system repair and mitigative action implementation.

E6-150 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

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 SNC 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.

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. E6-151 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

a. Periodic Emergenc}'. Drills EP N.3 The wording was relocated and transferred to the

1) During each exercise cycle, periodic During the exercise planning cycle described SNC Standard Emergency Plan.

drills will be conducted to ensure the in Section N.1.5, SNC sites vary the content of ERO teams (not necessarily each exercise scenarios to provide ERO members individual) are provided the opportunity to the opportunity to demonstrate proficiency in develop and maintain key emergency response skills within the scope of their key skills necessary to respond to several duties. The ERO (not necessarily each specific scenario elements including: ERO team) will be provided the

Hostile Action directed at the plant site.

opportunity to demonstrate key skills in

No radiological release, or unplanned response to the following scenario release that does not require public elements in drills or exercises. protective actions.
All functions in each ERF (e.g., all ERFs that are responsible for dose
An initial classification of, or rapid assessment perform those duties in escalation to, a Site Area Emergency or response to a radiological release). General Emergency.
Use of alternative facilities to stage the
Implementation of strategies, procedures, ERO for rapid activation during hostile and guidance developed in 50.54(hh) (i.e.,

action. potential aircraft threat, explosion or large

Real-time staffing of facilities during off- fire).

hours (i.e., 6:00 p.m. to 4:00 a.m.).

Providing medical care for injured,
Integration of offsite resources with onsite response.

contaminated personnel (every 2 years).

Response to essentially 100 percent of
A drill initiated between the hours of 6 initiating conditions identified in the p.m. and 4 a.m.

site emergency plan implementing

Drills using essentially 100 percent of procedure for classification of Initiating Conditions in the 8-year cycle emergencies. Drills and exercise scenarios will be varied
Response to actual industry event from year to year to test major components of sequences appropriate for the nuclear the plans and preparedness organizations.

plant technology (e.g., PWR). A record of Exercises conducted during the 8-

Use of procedures developed in response to an aircraft threat and in year exercise planning cycle that documents compliance with 10 CFR 50.54 (hh)(1 ). the contents of scenarios used during that
Use of the strategies associated with 10 cycle shall be maintained in accordance with CFR 50.54 (hh)(2) to mitigate spent fuel Drill and Exercise procedure guidance ..

pool damage scenarios (all strategies, SNC sites submit Biennial Exercise scenarios such as makeup, spray, and leakage under 10 CFR 50.4 for NRC review 60 days control, but not every variation of a given prior to the exercise. strategy).

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

E6-152 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

b. Fire Drills EP N.2.2: 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.2.3: 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. Radiological Monitoring Drills EP N.2.4 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.2.5: 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 to NL-16-0169 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. E6-154 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

3. Evaluations and Corrective N.4 Exercise Evaluation and Critique The wording was relocated and transferred to the Actions A formal critique will be performed for all exercises, SNC Standard Emergency Plan.

A formal critique will be performed drills, and training tabletops to develop, maintain, or for all exercises, drills, and training demonstrate key skills in order to identify weak or The evaluation of drills and training was deficient areas that need correction. that provide performance separated to ensure compliance with existing opportunities to develop, maintain, or EP N.5 Exercise/Drill Corrective Actions Systematic Approach to Training demonstrate key skills in order to The critique and evaluation process is used to (SAT)requirements for evaluation of any training. identify weak or deficient areas that identify areas of the Emergency Preparedness need correction. All observing or Program that require improvement. The Emergency participating agencies will be Preparedness group is responsible for evaluating requested to provide comments on recommendations and comments, determining drill evaluation. Any weaknesses or which items will be incorporated into the program or deficiencies that are identified in a require corrective actions, and for scheduling, tracking, and evaluation of item resolution. critique of exercises, drills, or training Whenever exercises or drills indicate deficiencies in will be corrected. Corrective action, the SNC Standard Emergency Plan, site-specific as appropriate, for company onsite Annexes, corresponding implementing procedures, and offsite weaknesses shall be the or training lesson plans, such documents will be responsibility of the Vice President- revised as necessary. Nuclear Plant Site. Corrective action, The results of exercise critiques, particularly as appropriate, for company public comments on identified areas that require information weaknesses shall be the improvement or reevaluation, will be submitted to responsibility of the APC Public the Emergency Preparedness Supervisor or designee, for review. The Emergency Relations Senior Vice President and Preparedness Supervisor or designee will consult the SNC Vice President and General with responsible department heads and assign Counsel. corrective action activities, as appropriate. 0.1 Training To achieve and maintain an acceptable level of emergency preparedness, training will be conducted for members of the Emergency Response Organization (ERO) and those offsite organizations that may be called on to provide assistance in the event of an emergency. Training will be evaluated in accordance with the requirements of Systematic Approach to Training practices to ensure effectiveness and in order to identify weak or deficient areas that need correction. E6-155 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

8. 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 Organization 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.

E6-156 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

b. Field Monitoring Team Training 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 SNC 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. E6-157 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

e. Emergency Re~air Party Training EP 0.4.5 Operations, Maintenance, The wording was relocated and transferred to the (annually) 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-O-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 (annually) 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). E6-158 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

2. Training of the Coq2orate EP 0.4 ERO Training The wording was relocated and transferred to the Emergency 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. Training of Local Services Grou12s 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 sheriffs 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. E6-159 to NL-16-0169 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 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. E6-160 to NL-16-0169 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.

E6-161 to NL-16-0169 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 EROS) are Notification Network. tested each calendar month, using the extensions in the Control Room, the TSC, and the EOF. EROS is tested each calendar quarter. Communications procedures and systems are also tested each calendar year.

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-EI P-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.

EP F.4 Validation of Phone Numbers A quarterly check of telephone numbers required to implement the SNC Emergency Plan will be performed and documented.

d. The EOFffSC/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.

E6-162 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

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.

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(1). 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(8) 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. E6-163 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description 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. 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 SNC 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: The EOF is procedurally required to The commitment wording was standardized and an ALERT or higher classification or be activated within 75 minutes following the relocated to the SNC Standard Emergency Plan as directed by the ED, the EOF will declaration of an Alert or higher classification. be activated as described in emergency implementing procedures. Appendix 7 A.3: Offsite support EP 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. E6-164 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Appendix 7 A.3: The corporate EP 8.3.1.3 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 hours 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: The EOF is procedurally required to The commitment wording was standardized and activated for an ALERT, SITE AREA be activated within 75 minutes following the relocated to the SNC Standard Emergency Plan. or GENERAL emergency declaration of an Alert or higher classification. classifications. Appendix 7 A.3: This facility (EOF) EP 8.2: Augmentation of on-shift staffing will The commitment wording was standardized and will be operational within about an occur within 75 minutes of 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: SN C'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. E6-165 to NL-16-0169 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: The EOF is procedurally required to The commitment wording was standardized and an ALERT or higher classification or be activated within 75 minutes following the relocated to the SNC Standard Emergency Plan as directed by the ED, the EOF will declaration of an Alert or higher classification. be activated as described in emergency implementing procedures. Appendix 7 A.3: Offsite support EP 8.2.1.15: 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 8.3.1.3 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 hours 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 EOF will be . EP H.2.1: The EOF is procedurally required to The commitment wording was standardized and activated for an ALERT, SITE AREA be activated within 75 minutes following the relocated to the SNC Standard Emergency Plan. or GENERAL emergency declaration of an Alert or higher classification. classifications. Appendix 7 A.3: This facility (EOF) EP 8.2: Augmentation of on-shift staffing will The commitment wording was standardized and will be operational within about an occur within 75 minutes of 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 JIG are detailed below. E6-166 to NL-16-0169 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 8.2.D EOF Organization Chart. The commitment wording was standardized and is displayed in Figure 1 and typical EP 8.3 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 8.3.1.2 EOF Manager The commitment wording was standardized and EOF positions has site-specific The EOF Manager reports to the EOF ED and relocated to the SNC Standard Emergency Plan. personnel designated: is responsible for managing and directing EOF 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 8.3.1.19 EOF Technical Supervisor The Technical Supervisor reports to the EOF Manager and is responsible for providing engineering expertise during an emergency event at an SNC operated plant. This may include interacting with non-SNC response groups, developing mitigation and recovery plans, and coordinating work performed by SNC and non-SNC engineering groups. E6-167 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Appendix 7 B: In order to augment EP 8.3.1.3 EOF 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 8.2: Augmentation of on-shift staffing will The commitment wording was standardized and activated, all EOF staff pagers are occur within 75 minutes of 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. E6-168 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Appendix 7 8.1: 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. Training will be evaluated in accordance with the requirements of Systematic Approach to Training practices to ensure effectiveness and in order to identify weak or deficient areas that need correction. The ERO Training Program ensures the training, qualification, and requalification of individuals who may be called on for assistance during an emergency. Specific emergency response task training, prepared for response positions, is described in. lesson plans and study guides. The lesson plans, study guides, and written tests are contained in the ERO Training Program. Responsibilities for implementing the training program are contained in plant procedures. Offsite training is provided to support organizations that may be called on fo provide assistance in the event of an emergency. Appendix 7 8.1: The duties and EP 8.3.1.1: The EOF ED has overall The commitment wording was standardized and responsibilities of the EOF Manager coordinating authority for Southern Nuclear relocated to the SNC Standard Emergency Plan. are as follows: (As listed in App. 7, Company resources. Upon EOF activation, 14 items listed)* the EOF ED accepts responsibility for Notification and Protective Action Recommendation functions from the Control Room. The EOF ED is also responsible for keeping SNC corporate management informed regarding the emergency response and Classification upgrades. E6-169 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Appendix 7 8.2: 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 8.2: 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 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 8.3: 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 8.4: 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. E6-170 to NL-16-0169 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 SNC Standard Emergency Plan. Coordinator are as follows: (As listed responsibilities of the Security Coordinator will in App. 7, 3 items listed). The be assumed by SNC corporate security individuals designated to assume the personnel. Responsibilities include supporting position will be indicated on a the plant security manager, keeping the EOF predetermined rotational schedule. Manager informed of any security events or issues, communication of security-related information to the 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. E6-171

Enclosure 6 to NL-16-0169 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 C.1: The On-call EOF EP E.2.1: Emergency Response personnel The commitment wording was standardized and Manager will be notified of all respond to their assigned Emergency relocated to the SNC Standard Emergency Plan. emergencies classified at any SNC Response Facilities upon notification of an site. Alert or higher classification level. Appendix 7 D.1: The EOF is located EP H.2.1: The EOF is a dedicated facility The commitment wording was standardized and in Birmingham, Alabama and serves located in Birmingham, Alabama, and serves as relocated to the SNC Standard Emergency Plan. as the EOF for all SNC sites (VEGP, the EOF for SNC sites (VEGP, FNP, and HNP). FNP, and HNP).

Appendix 7 D.1: The EOF will be EP H.2.1: The EOF is procedurally required to The commitment wording was standardized and activated as prescribed in the site be activated within 75 minutes following the relocated to the SNC Standard Emergency Plan.

specific Emergency Plan implementing procedures. Appendix 7 D.1: Plant systems meteorological data are provided via EP H.5.3.2: The SPDS parameters Appendix 7 D.1: Data displays are the EOF, dose assessment area, E6-172 to NL-16-0169 Farley responding to the EOF. Responders from state and Appendix 7 D.1: This data is authorities via a secure network Appendix 7 D.1: Data may also be from the Control Room and the TSC Appendix 7 D.1: Contained equipment necessary to provide EP Section B: Emergency phone systems to and from the Appendix 7 D.1: A communication maintained between the Emergency Appendix 7 D.1: The EOF is sized to 25 pre-designated persons, 9 from the Federal Emergency Appendix 7 D.1: Table 4 provides E6-174 to NL-16-0169 Farley Emergency Director. Appendix 7 D.1: The EOF is a as the EOF for SNC sites Appendix 7 D.1: Back-up power for generation. All essential equipment system. Appendix 7 D.1: The following Technical Specifications. Emergency Plans. declaration of an Alert or higher classification. 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. 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. are available during normal and abnormal operating conditions in the Control Room, TSC, and EOF. EP H.5.1: Meteorological information is The commitment wording was standardized and located in the main caucus area of displayed in the CR, TSC, and EOF using the relocated to the SNC Standard Emergency Plan. 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. Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Appendix 7 D .1: Data is also EP H.2.1 Emergency Operations Facility The commitment wording was standardized and available to all state agencies The EOF is capable of accommodating relocated to the SNC Standard Emergency Plan. 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). local agencies have access to plant parameters through the various data displays available in the EOF. See Figure H.2.A. 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. 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. 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. communication are available, during both to the EOF. normal and emergency conditions, to transmit and receive information among the Control Room, TSC, OSC, EOF, and other locations on-site and offsite including the Joint Information Center near the SNC site. 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. communication are available, during both dedicated direct communication links normal and emergency conditions, to transmit to the plant site(s). and receive information among the Control Room, TSC, OSC, EOF, and other locations onsite and offsite including the Joint Information Center near the SNC site. Response Facility (ERF) Communicators E6-173 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Appendix 7 D.1: In addition, there EP F .1.1: Reliable primary and backup means The commitment wording was standardized and are commercial and company wide of communication have been established. relocated to the SNC Standard Emergency Plan. Annex Section 5.3.2: Commercial telephones site(s). or land lines provide backup for the ENN. EP F.1.1: At SNC-operated nuclear power The commitment wording was standardized and link will be established and plants, several modes of reliable relocated to the SNC Standard Emergency Plan. communication are available, during both Operations Facility and the Technical normal and emergency conditions, to transmit Support Center {TSC) until the and receive information among the Control emergency director determines that Room, TSC, OSC, EOF, and other locations the communication link is no longer onsite and offsite including the Joint needed. Information Center near the SNC site Appendix 7 D.1: Computer No equivalent Plan statement. 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. 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. and offsite local, state, and federal responders persons from the NRC, and 1 person including NRC and FEMA. Management Agency (FEMA). EP F Table 5 The SNC Standard Emergency Plan and Annex additional information concerning provide commitments to maintain the EOF communications capabilities. communications capabilities within the ERO, 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. Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Append ix 7 D .1 : Upon activation of EP 8.3.1.3 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 hours 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. 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 lodging. EP H.2.1: The EOF is a dedicated facility The commitment wording was standardized and dedicated facility. located in Birmingham, Alabama, and serves relocated to the SNC Standard Emergency Plan. (VEGP, FNP, and HNP). 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. equipment is backed up by the diesel is backed up by the diesel generation generation system. 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. management section for SNC. The following Selected plant operating procedures. records or information are available:

Technical Specifications.

Emergency Plan Implementing

Selected plant operating procedures.

Procedures.

Emergency Plans.

FSA Rs.

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.

E6-175 to NL-16-0169 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 NRG FTS Regulatory Commission (NRC) is on the relocated to the SNC Standard Emergency Plan. lines in the TSC and the EOF during Federal Telecommunications System (FTS) an emergency. telephone network, which connects the SNC plant site and EOF with the NRG Operations Center. Appendix 7 F.2.4: The GPC Central EP H.6.3: External facilities for counting and The commitment wording was standardized and Laboratory has personnel and analyzing samples and for dosimetry relocated to the SNC Standard Emergency Plan. facilities available to provide offsite processing can be provided by other SNC-monitoring, sample analysis, and operated plants including the GPC Central dosimetry processing for the affected Laboratory, state, federal or contracted site. laboratories. Outside analytical assistance may be requested from state and federal agencies, or through contracted vendors. The DOE, through the Radiological Assistance Program (RAP) has access to 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. E6-176 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Appendix 7 G.1.1: The training EP 0.4: SNC ERO personnel who are The commitment wording was standardized and consists of familiarization with the responsible for implementing this plan receive relocated to the SNC Standard Emergency Plan. Site Emergency Plans and specialized training. The training program for applicable emergency implementing emergency response personnel is developed procedures required to carry out their based on the requirements of 10 CFR 50, specific functions. Appendix E and position-specific responsibilities. Appendix 7 G.1.1: A training matrix EP 0.4: SNC ERO personnel who are The commitment wording was standardized and for corporate personnel assigned to responsible for implementing this plan receive relocated to the SNC Standard Emergency Plan. the ERO is shown in Table 2, and specialized training. The training program for training course summaries are emergency response personnel is developed presented in Table 3. Training will based on the requirements of 10 CFR 50, be documented in accordance with Appendix E and position-specific established practices. responsibilities. EP 0.4.1: ERO members will receive Emergency Plan training on an annual basis. Personnel identified receive training appropriate to their position in the areas of:

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

Appendix 7 G.1.1: The corporate 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. E6-177 to NL-16-0169 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 incorporates will be conducted each calendar year SNC-operated nuclear power plants will the EOF 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.

SNC-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 N.2.10 Multi-Site Drill The SNC Standard Emergency Plan incorporates activation every 5 years will require a At least once in every five years, a drill the EOF multi-site drill into the base Plan concurrent EOF support response for involving more than one SNC site will be response. more than one SNC site. conducted demonstrating the ability of the Common EOF to effectively implement the Emergency Plan for an event involving more than one site. E6-178 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description Appendix 7 G.1.2: Each drill/exercise EP N.1: Drills and exercises shall: The commitment wording was standardized and will test, as a minimum, the

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

communication links and notification implementing procedures and methods. procedures.

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

Appendix 7 G.1.2: Provisions are EP N.4: A formal critique will be performed for The commitment wording was standardized and made for critique of all exercises, drills, and training tabletops to relocated to the SNC Standard Emergency Plan. drills/exercises. develop, maintain, or demonstrate key skills in order to identify weak or deficient areas that need correction. A critique shall be conducted at the conclusion of the exercise, to evaluate the organization's ability to respond as called for in the SNC Standard Emergency Plan. Appendix 7 G.1.2: Critique items will EP N.5: The Emergency Preparedness group The commitment wording was standardized and be forwarded to the site emergency is responsible for evaluating recommendations relocated to the SNC Standard Emergency Plan. preparedness coordinator for and comments, determining which items will 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 Emergency 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 NU REG-NUREG 0654 CROSS REFERENCE 0654 Revision 1. The Plan/Annex as reflected in INDEX the Table of Contents functions as the cross-reference. APPENDIX 9(1) SECTION P: RESPONSIBILITY FOR THE The commitment was relocated to the SNC RESPONSIBILITY FOR THE PREPAREDNESS EFFORT Standard Emergency Plan as described below. PLANNING EFFORT E6-179 to NL-16-0169 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 PresidenUChief Vice PresidenUChief Nuclear Officer (CNO) Standard Emergency Plan. Nuclear Officer (CNO) 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 Vice 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 P .1: 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. E6-180 to NL-16-0169 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. The 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. E6-181 to NL-16-0169 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 to 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 the 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 plant 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. E6-182 to NL-16-0169 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 SNC 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. E6-183 to NL-16-0169 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 SNC 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 take into account changes identified by drills and exercises, and the independent review described below. E6-184

Enclosure 6 to NL-16-0169 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). E6-185 to NL-16-0169 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 offsite 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 1O(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. E6-186 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description APPENDIX 11 (K) EP Section D The wording was standardized and relocated to ASSESSMENT ACTIONS Annex Section 3 the SNC Standard Emergency Plan and Site Annex ASSESSMENT ACTIONS EP D.1.1.2 Emergency 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. E6-187 to NL-16-0169 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 D.1.1.2 The Initiating Conditions (ICs) 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. E6-188 to NL-16-0169 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. The 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. E6-189 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description 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 !Cs 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 EP E.1.1 for the notification and the other unit When multiple units of a multi-unit site are classification noted on the affected by an emergency, the classification notification form. shall be reported as applicable to all affected units. In situations where multiple units of a multi-unit site are affected by emergency events, but the events are not related and the classification for each unit is different, initial notification will be made for the highest classification. Additional classification information is provided in accordance with Section E.2.2.3. At all times, when conditions present EP D.2.1 Although the majority of the EALs The wording was standardized and relocated to themselves that are not explicitly provide very specific 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. E6-190 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description 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 he 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 turnover from the ERO. When the site determines that transition to termination or recovery is appropriate, the information will be transmitted to respective offsite agencies. 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 SNC and State and local county governmental authorities, and authorities. The emergency action approved by the NRG. 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. E6-191 to NL-16-0169 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 min. of classifying the emergency. Notify the Nuclear Regulatory Commission (NRG) as soon as possible (ASAP) but no later than 1 hour following classification of the emergency.

2) Augment on-shift resources, as needed.

3) Assess and responcl 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 hours.

E6-192 to NL-16-0169 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 the 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 offsite alert is to assure that emergency personnel are readily available to respond if the situation becomes more serious or to perform confirrriatory 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. E6-193 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description The Emergency Organization will then No equivalent Plan/Annex statement. Section B provides the position specific duties perform the following: related to Classification Notification.

1) Within 15 min. of classification, inform State and local offsite Section E provides notification information.

authorities of Alert Emergency and reasons for emergency. Notify the NRG ASAP but no later than 1 hour 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 hour 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 hours of closeout.

E6-194 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description

c. Site Area Emergency SITE AREA EMERGENCY (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) prevent 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 E provides notification information. the Classification EIP. E6-195 to NL-16-0169 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 perform the following: related to Classification Notification.

1) Within 15 min. of classification, inform State and local offsite Section E provides notification information.

authorities of Site Area Emergency and reasons for emergency. Notify the NRC ASAP but no later than 1 hour 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 delayed 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 survey 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.

E6-196 to NL-16-0169 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 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 hour 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 hours of closeout.

d. General Emergency GENERAL EMERGENCY 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 General involve actual or imminent substantial core Emergency applies to those events degradation or melting with potential for loss of which are in progress or have containment integrity, or hostile action that occurred which involve actual or results in an actual loss of physical control of imminent substantial core the facility. Releases can be reasonably degradation or melting with potential expected to exceed EPA PAG exposure levels loss of containment integrity or off-site for more than the immediate site area. 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.

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 EIP. E6-197 to NL-16-0169 Farley Justification Matrix Current Farley Emergency Plan Revised SNC Emergency Plan Equivalent Justification Revision 64 Description The Emergency Organization will then No equivalent Plan/Annex statement Section B provides the position specific duties perform the following: related to Classification Notification.

1) Within 15 min. of classification, inform State and local offsite Section E provides notification information.

authorities of General Emergency and reason for emergency. Notify the NRC ASAP but no later than 1 hour following classification of the emergency.

2) Provide 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.

E6-198 to NL-16-0169 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 hour following declaration of the General Emergency.

11) Close out the emergency class by briefing of offsite authorities followed by written summary within 8 hours 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, ISFSI, 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. E6-199 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 D.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 I Refueling System
System Malfunctions (Hot - S Malfunctions.

series)

E - Independent Spent Fuel Storage
System Malfunctions (Cold - C Installations (ISFSI).

series)

F - Fission Product Barrier.
ISFSI (Hot and Cold - E series)
Hazards (Hot and Cold - H series)
H - Hazards and Other Conditions Affecting Plant Safety.
S - System Malfunction .

Within each category, sub categories EP D.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 D.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. E6-200 to NL-16-0169 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 8 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 8 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-100 submittal. EMERGENCY PLAN SNC Standard Emergency Plan Sections The commitment was standardized and relocated Part II A.2, 8.5, F.2 and L (entire section) to the SNC Standard Emergency Plan and Annex. MEDICAL PLAN Annex Sections 1.7.1.10, and 2.3 E6-201

Enclosure 6 to NL-16-0169 Farley Justification Matrix I 0 n- Sh"ft Farey I T a bl e C ompanson Major Functional Area Major Tasks Position Title I Expertise Table B-1 Farley Farley Farley on-shift* Rev25 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 Auxiliarv 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 I 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 Chemistrv I Radiochemistrv Chem/HP Technicians 1 1 1 1 Plant System Enr:iineerinQ Technical suooort Shift Technical Advisor 1 1 1 1 Repair and Corrective Repair and Corrective Actions Maintenance Supervisor 1 Actions Mechanical Maintenance 1** 1** 1 1 Electrical Maintenance 1** 1 1 1 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 Brir:iade per Tee Specs 5 5**

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 Total On-Shift 10 19 28 25

 *For each unaffected unit, maintain at least 1 SF, 1 CRO, 1 AO             ***Overall direction to be assumed by EOF Dire when ERFs are fully manned
 **May be provided by shift personnel assigned other functions              ****May be performed by engineering aid to shift supervisor E6-202

Enclosure 6 to NL-16-0169 Farley Justification Matrix Farley Augmented ERO Table Comparison Major Functional Area Major Tasks Position Title I Expertise Table B-1 Farley Farley Farley Augment (75 min) (75 min) Proposed Rev25 Rev64 (75 min) Emergency Direction and ,. 9 Control Notification I Notify State/local and federal 2 2 2 11 Communication personnel, maintain communication Radiological Accident EOF Director Senior Manager 1 1 1 (a) Assessment and Support of Dose Assessment HP Expertise 3 Operational Accident Offsite Survevs HP Technicians 2 2 6 6 Assessment On-Site Survevs HP Technicians 1 2 In-Plant survevs HP Technicians 1 2 Chemistrv I Radiochemistrv Chem/HP Technicians 1 1 1 2 Plant System Engineering Technical Support Electrical 1 1 1 1 Mechanical 1 1 1 1 EnQineering Supervision 2 Core Thermal I Hydraulic 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 2 Protective Actions (In-Plant) Radiation Protection: HP Technicians 2 2 2 3

a. Access Control

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

firefighting

c. Personnel monitoring

d. Dosimetrv Total AuQmented ERO 15 18 19 44 (a) EOF Emergency Director counted in Emergency Direction and Control.

E6-203

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 8

Hatch Standard Emergency Plan Annex (Marked-Up Pages and Clean Copy) to NL-16-0169 Hatch Standard Emergency Plan Annex Section 4: Emergency Measures (SEP E) 4.1 Notification of Off-Site Agencies (SEP E.2 .2) 4.1.1 Notification Process (SEP E.2.2.1)

State and local warning points are staffed 24 hours per day. State and county authorities to be notified within 15 minutes of the declaration of an emergency condition are: State of Georgia:

Georg ia Emergency Management Agency (GEMA).

Georgia county authorities:

Appl ing County warning point.
Jeff Davis County warning point.
Tattnall County warning point.
Toombs County warning point.

4.2 Alert and Notification System (ANS) (SEP E.2 . ~J [ Comment [Ml]: RAl-FLEET-4 RAl- HNP-3 Within the Plume Exposure Emergency Planning Zone (EPZ), there exist provisions for alerting and providing notification to the public. The state and/or local authorities are responsible for activation of this system. The FEMA approved Hatch ANS consists of a primary ANS and a backup system should there be a failure of the primary system.

Primary - Sirens and Emergency Alert System (EAS) stations
System Backup - Reverse calling system The primary ANS has two communications pathways. The first pathway is through the primary agency via the UHF or VHF rad io. Should the primary agency fail to activate the system , the secondary pathway will be utilized by the secondary agency. The secondary pathway functions in the same manner as the primary pathway utilizing a separate activation console that is physically located in separate location. If neither agency can activate the system , the backup system will be utilized to notify the residents of the 10 mile EPZ.

The hierarchy for system activation is provided below: Agency Radio Systems Primary Agency UHF VHF Primary Sirens & EAS Secondary Agency UHF VHR Backup Each County EMA Calling System EB-13 to NL-16-0169 Hatch Standard Emergency Plan Annex Georgia Primary Agency State of Georgia (GEMA) Secondary Agency Appling County 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 capability are provided for Appling County, Georgia and for the state of

Georgia.

Special alerting is accomplished through the use of a calling system . Special alerting is initiated in the event of a failure of the system to activate multiple sirens resulting in a loss of coverage in any area . Special alerting may be initiated for a predefined area, a user specified area, user defined groups, or the entire Emergency Planning Zone (EPZ). The calling system serves as a complete backup to the ANS . The system provides both alerting and notification of EPZ residents independent of the alerting 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 for Appling County , Georgia, and for the state of Georgia. A full description of the Hatch ANS design is provided in the FEMA approved ANS Design Report located in the SNC document management system . Residents in the plume exposure pathway EPZ have been instructed to tune to specific emergency alert radio or TV stations if the sirens are activated . 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. Emergency messages are coordinated between the local Emergency Management Agencies and the State Emergency Management Agencies prior to activation of the local rad io stations, as specified in the local area plans. 4.3 Protective Actions for Onsite Personnel (SEP J.4) Protective response for onsite personnel (including visitors and contractor personnel) includes alerting , assembly and accountability, site evacuation , monitoring , and decontamination . Protective actions may also be taken for onsite personnel for emergencies such as fires , security related events or natural disasters where personnel safety is threatened . 4.3 .1 Alerting (SEP E.2.1, J.1) Section E of the Emergency Plan (EP), Notification Methods and Procedures , describes the methods to be used to alert on-site personnel of emergency conditions. 4.3.2 Assembly (SEP J.4.1) Personnel assembly is mandatory at the Site Area Emergency or higher level classification . Upon activation of the plant emergency alarm , plant personnel E8-14

Enclosure B to NL-16-0169 Hatch Standard Emergency Plan Annex HP/CHEM TSC Workroom ~ Figure 5.1.A - Sample Technical Support Center EB-19 to NL-16-0169 Hatch Standard Emergency Plan Annex Appendix C - Hatch Nuclear Plant NUREG-0654 Cross Reference Table [ Comment [M2]: RAl-GEN-2 NUREG 0654 Rev 1 HNPSEP SNC SEP Section Ref Section Annex Criteria II.A - Assianment of Responsibility A.1 .a A.1, A.2, A.3, A.4 1.3-1 .5 A.1.b Introduction Section 1: Introduction A.1 .c Figures B.2.1.A, B.2.2.A , B.3.1 .A & -- B.3 .2.A A.1 .d B.3.1 .1 -- A.1 .e B.1 Table 2.2.A A.2.a NIA NIA A.2 .b NIA NIA A.3 A.5 1.3 -1 .5, 2.3 A.4 B.2, B.2 .1.15, B.3.1.3 -- Criteria 11.B - Onsite Emeraenc* Oraanization B.1 B.2 -- B.2 B.1.1 Table 2.2 .A B.3 B.1.2 -- B.4 B.1 .1, Figure B.2.A -- B.5 Tables 1 - 4 Table 2.2 .A B.6 B.2, B.3, Figures B.2.1.A, B.2.2.A, -- B.3.1.A & B.3.2.A B.7 Tables 1-4 -- Figures B.2.1.A, B.2.2.A, B.3.1.A & B.3.2.A B.7.a B.2.1.15, B.3.1.3 -- B.7.b B.3.1.2 , B.3.1 .17 -- B.7.c B.3.1.1 , B.3.1.2 -- B.7.d B.3.2.1, B.3.2.2, B.3.2.8 -- B.8 B.4 , C.4.2 2.3 B.9 B.6, K.1 2.3 Criteria 11.C

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

C.1.b A.1 -- C.1 .c A.1.1 , A.2 , A.3, C. 1-C.4 , F.1 Section 1 C.2.a NIA NIA C.2.b A.1.1 , H.2.1 5.1.2 C.3 H.5.2.3, H.6.3 -- C.4 Sections A & C, B.4-B.6, H.6.3, L.1- 1.3-1.5, 2.3, 5.8 L.4 Criteria 11.D

Emergency Classification System D.1 Section D Append ix B D.2 , Section D Append ix B D.3 NIA NIA D.4 NIA NIA Criteria 11.E - Notification Methods and Procedures E.1 E.1.1 Appendix D E.2 E.2 .1 --

E.3 E.2.2.2 -- E.4 E.2.2.2 -- E.4.a E.2.2.2 -- E.4.b E.2.2.2 -- E.4 .c E.2.2 .2 -- NOTE: NIA = Not required by Licensee in accordance with NUREG-0654 EB-27

Enclosure 8 to NL-16-0169 Hatch Standard Emergency Plan Annex NUREG 0654 Rev 1 HNPSEP SNC SEP Section Ref Section Annex Criteria 11.E - Notification MethoCls an<t Procedures (continueCI) E.4.d E.2.2.2 -- E.4.e E.2.2.2 -- E.4 .f E.2.2.2 -- E.4 .Q E.2.2.2 -- E.4.h E.2.2.2 -- E.4.i E.2.2.2 -- E.4.i E.2.2.2 -- E.4 .k E.2.2.2 -- E.4.1 E.2.2.2 -- E.4.m E.2 .2.2 -- E.4.n E.2 .2.2 -- E.5 N/A N/A E.6 E.2.5 -- E.7 E.2.6 -- Criteria 11.F - Emeraencv Communications F.1.a F.1.1 , F.1 .2 4.1.1 F.1.b F.1.3 -- F.1.c F.1.4 -- F.1 .d F.1.5 -- F.1.e F.1.6 -- F.1 .f F.1.4 -- F.2 F.2 -- F.3 F.3 5.4 Criteria 11.G - Public Education and Information G.1 G.1 -- G.2 G.8 2.3.4 G.3.a B.3.2.1 , H.2.2 , H.2.3 5.1.6 G.3.b N/A N/A G.4.a B.3.2.8 -- G.4.b G.2 -- G.4.c B.3.2.5, B.3.2 .6 -- G.5 G.2 -- Criteria 11.H - Emergency Equipment and Facilities H.1 H.1.2 5.1.2 H.2 H.2.1 5.1.5 H.3 H.2.2, H.2.3 -- H.4 H.1 -- H.5 H.5 5.6 H.5.a H.5.1 5.6.1 H.5.b H.5.2 -- H.5.c H.5.3 -- H.5.d H.5.4 -- H.6.a H.5.1 5.6.1 H.6.b H.5.2 -- H.6.c H.5.2.3, H.6.3 -- H.7 H.6 -- H.8 H.7 5.6.1 H.9 H. 1.3 5.1.3 H.10 H.8 - H.11 H.9 -- H.12 H.10 -- NOTE: NIA =Not required by Licensee in accordance with NUREG-0654 E8-28 to NL- 16-0169 Hatch Standard Emergency Plan Annex NUREG 0654 Rev 1 HNP SEP SNC SEP Section Ref Section Annex Criteria II.I - Accident Assessment 1.1 1. 1 -- 1.2 1.2 -- 1.3.a 1.3 -- 1.3.b 1.3 -- 1.4 1.4 -- 1.5 1.5 -- 1.6 1.6 -- 1.7 1.7 -- 1.8 1.8 -- 1.9 1.9 -- 1.10 1.7 -- 1.11 NIA NIA Criteria 11.J - Protective Response J.1.a J.1 -- J.1 .b J.1 -- J.1.c J.1 -- J .1.d J.1 -- J.2 J.4.3 -- J.3 J.2 -- J.4 J.3, J.4.3 -- J.5 J.4 .2 , 4 .3.2 -- J .6 .a J.4 -- J.6 .b J.4 -- J.6.c J.4 -- J.7 J.5 -- J.8 J.6 Appendix A J.9 NIA NIA J.10.a J.7 -- J.10.b J.7 -- J.10.c E.2 .5 4 .2 J.10.d NIA NIA J.10.e NIA NIA J.1O.f NIA NIA J.10.g NIA NIA J.10.h NIA NIA J.10.i NIA NIA J.10.i NIA NIA J.10.k NIA NIA J.10.I NIA NIA J.10.m J.5 -- J.11 NIA NIA J.12 NIA NIA Criteria 11.K - Radiological Exoosure Control K.1.a K.1.1 -- K.1.b K.1 -- K.1.c K.1 -- K.1.d K.1.2 .1 -- K.1.e K.1.2.1, K.5 -- K.1.f K.1.1.1 -- K.1 .o K.1.3 -- NOTE: N/A =Not required by Licensee in accordance with NUREG-0654 E8-29 to NL-16-0169 Hatch Standard Emergency Plan Annex NUREG 0654 Rev 1 HNPSEP SNC SEP Section Ref Section Annex K.2 K.1 Criteria 11.K - Radiological Exposure Control (continued) K.3 .a K.3 -- K.3.b K.3 -- K.4 N/A N/A K.5.a K.5 -- K.5.b K.5 -- K.6.a K.6 -- K.6.b K.6 -- K.6.c K.6 -- K.7 K.7 -- Criteria 11.L - Medical and Public Health Support L.1 L.1 -- L.2 L.2 -- L.3 N/A N/A L.4 L.4 - Criteria 11.M - Recovery and Reentry Planning and Post-Accident Operations M.1 M.1 -- M.2 M.2 -- M.3 M.3 -- M.4 M.4 -- Criteria 11.N - Exercises and Drills N.1.a N.1 -- N.1.b N.1 -- N.2.a F.3 -- N.2.b N.2.3 -- N.2.c N.2.4 -- N.2.d N.2.5 -- N.2.e(1) N.2.6 -- N2.e(2) N.2.6 -- N.3.a N.3 -- N.3.b N.3 -- N.3.c N.3 -- N.3.d N.3 -- N.3.e N.3 -- N.3.f N.3 -- N.4 N.4 -- N.5 N.5 -- Criteria 11.0 - Radiological Emergency Response Training 0 .1 0 .1 -- 0 .1.a 0 .1.1 -- 0 .1.b 0 .1.1 -- 0 .2 0 .3 -- 0 .3 0.4 -- 0.4.a 0.4 -- 0 .4.b 0.4 -- 0.4 .c 0 .4.3 -- 0.4 .d 0 .4 .1 , 0.4.4 -- 0 .4.e 0.4.5 -- 0.4 .f 0.4.6 -- 0.4.g 0.1 .1 -- 0.4.h 0.1 .1 -- NOTE: N/A =Not required by Licensee in accordance with NUREG-0654 E8-30 to NL-16-0169 Hatch Standard Emergency Plan Annex NUREG 0654 Rev 1 HNPSEP SNC SEP Section Ref Section Annex 0.4. i 0.4 Criteria 11.0 - Raitiological Emergency Response Training (continued) 0.4.j 0 .4 0.4.7 -- 0 .5 0.4 -- Criteria 11.P - Responsibility for the Planning Effort: Development, Periodic Review and Distribution of Emergency Plans P.1 0 .5, Section P -- P.2 Section P -- P.3 P.1 -- P.4 P.1 -- P.5 P.3 -- P.6 P.3 -- P.7 -- Append ix D P.8 Table of Contents -- P.9 P.3 -- P.10 F.1.4 -- NOTE: N/A = Not required by Licensee in accordance w ith NUREG-0654 ES-31 to NL-16-0169 Hatch Standard Emergency Plan Annex Appendix D - Supporting Plans & Implementing Procedures (SEP P.3) Supporting Plans

State of Georgia Radiological Emergency Response Plan
Appling , Jeff Davis, Tattnall, and Toombs County Emergency Response Plans.
HNP Security Plan
HNP Fire Protection Plan Administrative and Emergency Plan Implementing Procedures {EPIP)

Plan Section Title EPIP EPIP Title Section A Assignment of Responsibility NMP-EP-300 SNC Emergency Preparedness (under Conduct of Operations development) 73EP-ADM-001 -0 Maintaining Emergency Preparedness B Emergency Response NMP-EP-146 ERO Position Checklists Organization 73EP-EIP-005-0 On Shift Operations Personnel Emergency Duties AG-EPX-01-0415 Emergency Response Organization Position Gu idance c Emergency Response Support NMP-EP-300 SNC Emergency Preparedness and Resources (under Conduct of Operations development) D Emergency Classification System NMP-EP-1 41 Emergency Classification E Notification Methods and NMP-EP-1 42 Emergency Notification Procedures NMP-EP-308 SNC Emergency Alert Siren Operation , Testing And Maintenance F Emergency Communications NMP-EP-300 SNC Emergency Preparedness (under Conduct of Operations development) G Public Education and Information NMP-EP-203 Corporate Media Center Operations NMP-EP-204 Emergency News Center/Joint Information Center Operations NMP-EP-205 Emergency Communications News Releases NMP-EP-2 06 Emergency Com munications News Briefings NMP-EP-207 Emergency Communications Public Response E8-32 to NL-16-0169 Hatch Standard Emergency Plan Annex Plan Section Title EPIP EPIP Title Section H Emergency Facilities and NMP-EP-143 Facility Activation Equipment NMP-EP-305 Equipment Important to the EP Function 73EP-EIP-016-0 TSC HVAC Operation 73EP-INS-001 -0 Emergency Equipment Inventory Emergency Response Facilities 73EP-INS-002-0 Supplies Inventory Control & Testing Of Emergency 73EP-TET-001-0 Equipment Repair and Corrective Action 73EP-RAD-006-0 During a Rad iological Emergency I Accident Assessment NMP-EP-140 Accident Assessment 73EP-EIP-014-0 Internal Survey Team Duties 73EP-EIP-020-0 Offsite Environmental Monitoring During Emergencies J Protective Response NMP-EP-144 Protective Actions 73EP-EIP-009-0 Nuclear Security Duties 73EP-EIP-012-0 Search and Rescue Team Duties 73EP-EIP-019-0 Rally Point Team Duties K Radiological Exposure Control NMP-EP-144 Protective Actions 73EP-EIP-013-0 Contaminated Injury and First Aid 73EP-EIP-017-0 Emergency Exposure Control L Medical and Public Health NMP-EP-300 SNC Emergency Preparedness Support (under Conduct of Operations development) M Recovery and Re-entry Planning NMP-EP-145 Termination and Recovery and Post Accident Operations N Exercises and Drills NMP-EP-303 Drill and Exercise Standards 0 Rad iologica l Emergency NMP-EP-301 EOF Emergency Response Response Training Organization And EP Staff Training 75TR-TRN-001-0 Emergency Preparedness Training p Responsibility for the Planning NMP-EP-300 SNC Emergency Preparedness Effort Conduct of Operations NMP-EP-310 Maintain ing The Emergency Plan NMP-EP-312 Development Of Emergency Preparedness Technical Products NMP-TR-104-006 SEPTOC 73EP-ADM-001-0 Maintaining Emergency Prepa redness E8-33

Southern Nuclear Operating Company STANDARD EMERGENCY PLAN ANNEX for Hatch Nuclear...Plant Units 1and2 Revision 0 to NL-16-0169 Hatch Standard Emergency Plan Annex Table of Contents Section 1: Introduction (SEP) ..............................................................................................................3 1.1 Facility Description .......................................................................................................................... 3 1.2 Emergency Planning Zones (SEP J.5) ........................................................................................ 3 1.3 State of Georgia (SEP A.2.2) ........................................................................................................ 3 1.4 Local Organizations (SEP A.2, B.6.1 ) .......................................................................................... 3 1.5 Hostile Action Based Events (SEP H.1.4) ................................................................................... 4 Figure 1.1.A - Location and Vicinity Map ............................................................................................. 5 Figure 1.1.B - Edwin I. Hatch Nuclear Plant Site Plan ...................................................................... 6 Figure 1.2.A - 10 Mile Emergency Planning Zone (EPZ) .................................................................. 7 Figure 1.2.B - 50 Mile Ingestion Pathway IPZ .................................................................................... 8 Section 2: Organizational Control of Emergencies (SEP 8.1) ....................................................9 2.1 Normal Plant Organization (SEP 8.1 ) .......................................................................................... 9 2.2 Emergency Organization (SEP 8.2, 8.3) .................................................................................... 9 Table 2.2.A - Hatch Nuclear Plant On-Shift Staffing ........................................................................ 10 2.3 Non-SNC Support Groups (SEP 8.4, 8.5, 8.6) ........................................................................ 11 Section 3: Classification of Emergencies (SEP D.1) ...................................................................12 3.1 Emergency Classifications: (SEP D.1) ...................................................................................... 12 3.2 Determination of Levels: (SEP D.1.2) ........................................................................................ 12 3.3 Operating Mode Applicability (SEP D.2.7) ................................................................................ 12 Section 4: Emergency Measures (SEP E) .......................................................................................13 4.1 Notification of Off-Site Agencies (SEP E.2.2) ........................................................................... 13 4.2 Alert and Notification System (ANS) (SEP E.2.5) .................................................................... 13 4.3 Protective Actions for Onsite Personnel (SEP J.4) .................................................................. 14 4.4 Protective Actions for the Offsite Public (SEP J .5) .................................................................. 15 Section 5: Emergency Facilities and Equipment (SEP H) ..........................................................16 5.1 Emergency Response Facilities (SEP H.1, H.2) ...................................................................... 16 Figure 5.1.A- Sample Technical Support Center ............................................................................ 19 Figure 5.1.B - Sample Operations Support Center .......................................................................... 20 5.2 On-Site Communications (SEP F.1) .......................................................................................... 21 5.3 Offsite Communications (SEP F.1) ............................................................................................ 21 5.4 Communications System Testing (SEP F.3) ............................................................................ 21 5.5 Emergency Kits (SEP H.9) .......................................................................................................... 21 5.6 Facilities and Equipment for On-site Monitoring (SEP H.5) ................................................... 21 5.7 Protective Facilities and Equipment (SEP J) ............................................................................ 23 5.8 Medical Support (SEP 8.6, SEP L) ............................................................................................ 23 Appendix A - Evacuation Time Estimate Study and Map Reference (SEP J.6) ...................24 Appendix B - Emergency Action Level (EAL) Scheme (SEP D.1) ............................................26 Appendix C - Hatch Nuclear Plant NUREG-0654 Cross Reference Table .............................27 Appendix D - Supporting Plans & Implementing Procedures (SEP P.3) ................................32 EB-2 to NL-16-0169 Hatch Standard Emergency Plan Annex Section 1: Introduction (SEP) This document serves as the Edwin I. Hatch Nuclear Plant (HNP) Units 1 and 2 Annex and contains information and guidance that is unique to HNP. This includes Emergency Action Levels (EALs) and facility geography. In an emergency situation at HNP, the initial response would be made by the site staff and, if needed, by local support agencies. This Annex addresses the actions and responsibilities of the HNP plant staff and the offsite support agencies. 1.1 Facility Description The Hatch Nuclear Plant (HNP) is a two-unit boiling water reactor. The plant is on a 2, 100-acre site located in Appling County, Georgia, approximately 11 miles north of Baxley, Georgia, on U.S. Highway 1. 1.2 Emergency Planning Zones (SEP J.5) 1.2.1 Plume Exposure Pathway (SEP J. 7) The 10-mile Emergency Planning Zone (EPZ) for HNP approximates a 10-mile radius around the plant site and is depicted in Figure 1.2.A. Located within the EPZ are the Georgia counties of Appling, Jeff Davis, Tattnall, and Toombs. 1.2.2 Ingestion Pathway (SEP J.7) The area between the 10-mile and 50-mile radius is considered the Ingestion Pathway Zone (IPZ). The 50-mile IPZ is depicted in Figure 1.2.B. Planning for the ingestion exposure pathway is a responsibility of the state of Georgia. More information about the IPZ can be obtained from the state's Radiological Emergency Plan. 1.3 State of Georgia (SEP A.2.2) Upon notification of an emergency condition, the Georgia Emergency Management Agency will imp!ement the "State of Georgia Radiological Emergency Plan." The Georgia Emergency Management Agency has the authority and responsibility for coordinating the efforts of local and state agencies in Georgia to provide for the health and safety of the general public in the event of a radiological incident. An agreement is in place with the state of Georgia to provide available resources and equipment to support the mitigation and response to an emergency at Plant Hatch to include Hostile Action Based events. These resources include, but are not limited to, Local Law Enforcement Agency (LLEA) assets, fire fighting assets, medical support resources (including transportation), and coordination through an Incident Command Post. Requests for offsite resources and equipment will be communicated from the control room to the Burke County 911 center, the county EOG, or through the Incident Command Post, as applicable, based on the nature and timing of the event. 1.4 Local Organizations (SEP A.2, B.6.1) Principal activities of Local Emergency Management Agencies (LEMA) and Local Law Enforcement Agencies (LLEA) in Georgia are described in the respective Emergency Operations Plans. E8-3 to NL-16-0169 Hatch Standard Emergency Plan Annex 1.4.1 Georgia Counties (SEP A.2.4) The area in the plume exposure pathway in the state of Georgia falls within Appling, Jeff Davis, Tattnall, and Toombs Counties. The responsibility for radiological emergency response planning rests with the Chairman of each County Board of Commissioners or the Mayor of a respective jurisdiction. It is this individual's responsibility to initiate actions and provide direction and control at a level consistent with the specific incident. Agencies within each county that have a primary role in radiological emergency planning and response include the EMA and local law enforcement agencies. Principal activities of the LEMAs include the following:

Receive notification from HNP and GEMA.
Activate county resources, as necessary, to respond to the emergency.
Maintain communications with HNP on emergency situation status.
Provide information to other county response elements, the media, and the public.
Activate the public notification system, if required.
Activate the county EOC.
Coordinate the county emergency response activities.
Activate and direct operations at the designated reception and care facility.

1.5 Hostile Action Based Events (SEP H.1.4) Agreements are in place with the state of Georgia and counties of Appling, Jeff Davis, Tattnall, and Toombs to provide available resources and equipment to support mitigation and response to an emergency at Edwin I. Hatch Nuclear Plant, including Hostile Action Based events. These resources include, but are not limited to, Local Law Enforcement Agency (LLEA) assets *. firefighting assets, medical support resources (including transportation), and coordination through an Incident Command Post. Requests for offsite resources and equipment will be communicated from the control room or site security to Appling County 911 Center, the county EOCs, or through the Incident Command Post as applicable based on the nature of the event. Copies of these agreements are maintained in accordance with Emergency Plan procedures. EB-4 to NL-16-0169 Hatch Standard Emergency Plan Annex t N Figure 1.1.A - Location and Vicinity Map EB-5 to NL-16-0169 Hatch Standard Emergency Plan Annex

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50 Mile Radius Figure 1.2.B - 50 Mile Ingestion Pathway IPZ E8-8 to NL-16-0169 Hatch Standard Emergency Plan Annex Section 2: Organizational Control of Emergencies (SEP B.1) 2.1 Normal Plant Organization (SEP B.1) The normal plant operating crew is staffed and qualified to perform actions that may be necessary to initiate immediate protective actions and to implement the emergency plan, and is designated as the responsible group for such actions. The normal plant organization is described in Section B.1 of the SNC Standard Emergency Plan. 2.2 Emergency Organization (SEP B.2, B.3) 2.2.1 The HNP On-Shift Emergency Response Organization is described in Table 2.2.A (SEP B.1). 2.2.2 The HNP Augmented Emergency Response Organization is described in Figures B.2.1.A, B.2.2.A, B.3.1.A, and B.3.2.A in the Emergency Plan (SEP B.2, B.3). An On-Shift Staffing Analysis was completed in accordance with the requirements of 10 CFR 50 Appendix E IV.A.9. This analysis forms the basis for the on-shift staff as described in Table 2.2.A. A copy of the analysis is maintained in the SNC document management system. EB-9 to NL-16-0169 Hatch Standard Emergency Plan Annex Table 2.2.A - Hatch Nuclear Plant On-Shift Staffing Maior Functional Area Major Tasks Position On-Shift Emergency Direction Shift Manager (SM)/ 1 and Control Emergency Director (ED) Plant Operations and Shift Supervisor (SRO) 2 Assessment of Operational Aspects Reactor Operator (RO) 4 Shift Support 1 Supervisor/Fire Bri~ade Leader (SRO/FBL)' ote 1 0 System Operator (SO) " 'e ' 7 Plant System Technical Support Shift Support Supervisor I 1 Engineering, Repair Shift Technical Advisor and Corrective Actions (SRO/STA) Notification/ Notify licensee, State local and Licensed Operator (RO or Note 2 Communication Federal personnel & maintain SRO) communication Radiological Accident Offsite Dose Assessment Chemistry Technician or 1 Assessment and other trained personnel Support of Operational In-plant surveys RP Technician or other 1 Accident Assessment trained personnel Offsite Surveys Onsite (out-of- RP Technician or other 1 plant) trained personnel Protective Actions Radiation Protection: RP Technician 1

a. Access Control

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

c. Personnel monitoring

d. Dosimetrv Chemistry/Radio- chemistry Chemistry Technician 1 Plant System Repair and Corrective Actions Maintenance Supervisor 1 Engineering Repair and Corrective Actions Electrical Maintenance 1 Mechanical Maintenance 1 l&C Maintenance 1 Total: 25 Fire Fighting Fire Brigade " 01e ., 5 Rescue Operations and Rescue Operations/First 2 First Aid Aid Note2 Site Access Control and Security Security Personnel Plan Accountability Note 1 - Fire Brigade made up of FB Leader (SSS) and 4 System Operators not assigned safe shutdown responsibilities.

Note 2 - May be provided by shift personnel assigned other functions. ES-10 to NL-16-0169 Hatch Standard Emergency Plan Annex 2.3 Non-SNC Support Groups (SEP B.4, B.5, B.6) 2.3.1 Fire Fighting (SEP B.6.4) Plant Hatch has established an agreement with the Appling County EMA to provide, upon request, offsite fire support to the HNP Fire Brigade. Support provided includes, but is not limited to, firefighters and firefighting equipment. Request for fire support will be made by the control room or site security to the Appling County 911 center, Appling County EOC, or the Incident Command Post, as applicable, based on the nature and timing of the event. 2.3.2 Hospital and Medical Support (SEP B.6.3, K.1.3, L.1) The detailed plans for the handling and care of injured personnel potentially contaminated and/or highly irradiated are contained in site procedures. A brief description of the facilities and services available for medical support is given below. 2.3.2.1 Appling Healthcare System The Appling Healthcare System in Baxley, Georgia has agreed to receive and care for injured personnel that may be contaminated or irradiated. In addition to routine medical care, space has been provided for a decontamination and emergency treatment facility and for storage of emergency medical equipment, monitoring equipment and dosimeters. 2.3.2.2 Meadows Regional Medical Center The Meadows Regional Medical Center in Vidalia, Georgia has agreed to receive and care for injured personnel that may be contaminated or irradiated. In addition to routine medical care, space has been provided for a decontamination and emergency treatment facility and for storage of emergency medical equipment, monitoring equipment and dosimeters. 2.3.3 Ambulance Services (SEP B.6.2, L.4) Plant Hatch has established agreements with the Appling County EMS and Toombs-Montgomery County EMS for the transportation of injured personnel, including people who may be radioactively contaminated, to hospital facilities for treatment. Request for medical support will be made by the control room or site security to the Appling County 911 center, Toombs County 911, or the Incident Command Post, as applicable, based on the nature and timing of the event. 2.3.4 Information for Transients (SEP G.8) Several communications methods may be used to acquaint the public with plans for their protection during a Plan emergency. Effort will be concentrated on providing information to the public by written material that is likely to be available in local residences and in locations frequented by transients. The information will also provide instructions on which local media will be providing in additional information in the event of an emergency. EB-11 to NL-16-0169 Hatch Standard Emergency Plan Annex Section 3: Classification of Emergencies (SEP D.1) 3.1 Emergency Classifications: (SEP D.1) There are four classes of Emergency Action Levels based on severity, taking into consideration both potential and actual, events in progress. They are, from the least to the most serious, Unusual Event, Alert, Site Area Emergency, and General Emergency. Initiating C~:mditions (ICs), which determine which level will be declared, are predetermined subsets of plant conditions where the potential exists for a radiological emergency, or such an emergency has occurred. Emergency Action Levels (EALs) are plant-specific indications, conditions, or instrument readings that are used to classify emergency conditions. 3.1.1 The described emergency classes and the emergency action levels are agreed on by SNC and state and local authorities. The emergency action levels will be reviewed by state and local officials annually.

3.2 Determination of Levels: (SEP D.1.2)

Appendix B to this Annex contains the matrix for Initiating Conditions used to determine an Emergency Action Level (EAL). They are part of the scheme established by NEI 99-01, Methodology for Development of Emergency Action Levels. 3.3 Operating Mode Applicability (SEP D.2. 7) The plant operating mode that existed at the time that the event occurred, prior to any protective system or operator action initiated in response to the condition, is compared to the mode applicability of the EALs. If an event occurs, and a lower or higher plant operating mode is reached before the emergency classification level can be declared, the emergency classification level shall be based on the mode that existed at the time the event occurred. BWR Operating Modes at HNP 1&2 Mode Mode Rx Mode Switch Avg. RCS Temperature Description Position (oF) 1 Power Rx Mode Switch in "Run" N/A Operations Position 2 Startup Refuel\ai or StartupiHot N/A Standby 3 Hot Shutdown RCS> 212°F Shutdown (a) 4 Cold Shutdown RCS~ 212 °F Shutdown <al 5 Refueling \OJ Shutdown or Refuel N/A (a) All reactor vessel head closure bolts fully tensioned. (b) One or more reactor vessel head closure bolts less than fully tensioned EB-12 to NL-16-0169 Hatch Standard Emergency Plan Annex Section 4: Emergency Measures (SEP E) 4.1 Notification of Off-Site Agencies (SEP E.2.2) 4.1.1 Notification Process (SEP E.2.2.1) State and local warning points are staffed 24 hours per day. State and county authorities to be notified within 15 minutes of the declaration of an emergency condition are: State of Georgia:

Georgia Emergency Management Agency (GEMA).

Georgia county authorities:

Appling County warning point.
Jeff Davis County warning point.
Tattnall County warning point.
Toombs County warning point.

4.2 Alert and Notification System (ANS) (SEP E.2.5) Within the Plume Exposure Emergency Planning Zone (EPZ), there exist provisions for alerting and providing notification to the public. The state and/or local authorities are responsible for activation of this system. The FEMA approved Hatch ANS consists of a primary ANS and a backup system should there be a failure of the primary system.

Primary - Sirens and Emergency Alert System (EAS) stations
System Backup - Reverse calling system The primary ANS has two communications pathways. The first pathway is through the primary agency via the UHF or VHF radio. Should the primary agency fail to activate the system, the secondary pathway will be utilized by the secondary agency. The secondary pathway functions in the same manner as the primary pathway utilizing a separate activation console that is physically located in separate location. If neither agency can activate the system, the backup system will be utilized to notify the .residents of the 1O mile EPZ.

The hierarchy for system activation is provided below: Agency Radio Systems Primary Agency UHF VHF Primary Sirens & EAS Secondary Agency UHF VHR Backup Each County EMA Calling System E8-13 to NL-16-0169 Hatch Standard Emergency Plan Annex Georgia Primary Agency State of Georgia (GEMA) Secondary Agency Appling County 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 capability are provided for Appling County, Georgia and for the state of Georgia. Special alerting is accomplished through the use of a calling system. Special alerting is initiated in the event of a failure of the system to activate multiple sirens resulting in a loss of coverage in any area. Special alerting may be initiated for a predefined area, a user specified area, user defined groups, or the entire Emergency Planning Zone (EPZ). The calling system serves as a complete backup to the ANS. The system provides both alerting and notification of EPZ residents independent of the alerting 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 for Appling County, Georgia, and for the state of Georgia. A full description of the Hatch ANS design is provided in the FEMA approved ANS Design Report located in the SNC document management system. Residents in the plume exposure pathway EPZ have been instructed to tune to specific emergency alert radio or TV stations if the sirens are activated. 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. 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. 4.3 Protective Actions for Onsite Personnel (SEP J.4) Protective response for onsite personnel (including visitors and contractor personnel) includes alerting, assembly and accountability, site evacuation, monitoring, and decontamination. Protective actions may also be taken for onsite personnel for emergencies such as fires, security related events or natural disasters where personnel safety is threatened. 4.3.1 Alerting (SEP E.2.1, J.1) Section E of the Emergency Plan (EP), Notification Methods and Procedures, describes the methods to be used to alert on-site personnel of emergency conditions. 4.3.2 Assembly (SEP J.4.1) Personnel assembly is mandatory at the Site Area Emergency or higher level classification. Upon activation of the plant emergency alarm, plant personnel E8-14 to NL-16-0169 Hatch Standard Emergency Plan Annex assigned specific emergency responsibilities will proceed to their designated emergency response locations. Assembly of site personnel outside of the Protected Areas is accomplished by non-essential personnel reporting to designated assembly areas. Assembly may be initiated at any time site management deems it appropriate for personnel safety reasons. Nonessential plant personnel located within the Protected Area will exit the protected area upon hearing the Site Area or the General Emergency alarm, and report to designated assembly areas. Visitors, contractors, and escorted personnel will leave the protected area during an Alert or higher declaration. 4.3.3 Security Events (SEP J.4) On-site protection of employees during security events involves a combination of restricted movement, movement to safe locations, and site evacuation depending

                    *on the nature of the event and advance warning. Specific actions to be taken during such events are included in site procedures.

4.3.4 Monitoring and Decontamination (SEP K) When an Alert is declared but no site evacuation is anticipated, personnel who have left the protected area are monitored by portal monitors. If necessary, decontamination is completed using the plant decontamination facilities located in the Control building or other onsite locations. For a Site Area Emergency or a General Emergency, or when site evacuation is expected and a release of radioactivity has occurred, monitoring is performed by portal monitors at the Plant Entry Security Building or by portable monitoring equipment at the rally point areas. The Rally Point Team establishes a control point at the rally point area and monitors evacuees before releasing them. The monitoring teams maintain the appropriate records. 4.4 Protective Actions for the Offsite Public (SEP J.5) The Emergency Director will recommend the necessary protective actions to offsite authorities based on predetermined protective actions for a General Emergency Classification or results of offsite dose assessment. Upon activation of the EOF, the EOF Manager will be responsible for recommending protective actions for the offsite population. Responsibility *for carrying out the protective actions rests with offsite authorities. 4.4.1 Protective Action Recommendations (SEP J.5) A range of Protective Actions have been developed and agreed on with State and Local authorities. They may include the following:

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

EB-15 to NL-16-0169 Hatch Standard Emergency Plan Annex Section 5: Emergency Facilities and Equipment (SEP H) 5.1 Emergency Response Facilities (SEP H.1, H.2) 5.1.1 Control Room (SEP H.1.1) The Control Room contains the necessary instrumentation, both process and radiological, to evaluate plant conditions, as detailed in the plant Final Safety Analysis Report. Habitability is maintained by shielding and the Emergency Filtration Train (EFT) ventilation system, which is capable of operating in a cleanup or recycle mode. Designated emergency equipment is supplied power from the emergency diesel generators with vital instrumentation powered from inverters connected to the storage batteries located in the battery rooms. 5.1.2 Technical Support Center (SEP H.1.2) The TSC, which is shared by both units, is located adjacent to the service building annex. A sample layout of the TSC is shown in Figure 5.1.A. The TSC provides plant management and technical support personnel, including NRC personnel, with aqequate space to assist plant operating personnel located in the Control Room during an emergency. The TSC is equipped with technical data displays and has ready access to plant records to allow TSC personnel to perform detailed analysis and diagnosis of abnormal plant conditions, including assessment of any release of radioactivity to the environment. The TSC structure and ventilation system is . designed to ensure that TSC personnel are protected from radiological hazards similar to that of the Control Room. An area radiation monitor, which alarms on abnormal radiation levels, is provided in the TSC. In addition, portable radiation monitors are available for personnel in transit from the TSC to other areas. Self-contained breathing apparatus (SCBA) are provided in the TSC. Anticontamination clothing is available at the nearby OSC. The TSC normal lighting is supplied from normal site power through a motor control center backed up by the security diesel generator. Power for the TSC vital equipment is provided either from the motor control center backed up by the security diesel generator, or from a battery-backed uninterruptible power supply system. Power to the DC power system is provided by battery chargers, one of which is powered from this same motor control center. The TSC maintains access to drawings and records necessary for the response to an emergency event at HNP. These records can be accessed on a digital records system. This system is supplied backup power by an uninterruptible power supply to allow retrieval of records in the event of a loss of power. These records include but are not limited to:

Technical Specifications.
Plant Operating Procedures.
Final Safety Analysis Report.
Emergency Plan.
Emergency Plan Implementing Procedures.
Plant operating records.

E8-16 to NL-16-0169 Hatch Standard Emergency Plan Annex

System piping and instrumentation diagrams; heating, ventilation, and air-conditioning (HVAC) flow diagrams.
Electrical one-line, elementary, and wiring diagrams.
Control logic and loop diagrams.

The above records are updated as necessary to ensure accuracy and completeness. 5.1.3 Operations Support Center (SEP H.1.3) The OSC consists of the service building break room and other areas available for staging of support personnel. This includes groups such as Instrument and Control Technicians, Mechanics, Electricians, Nuclear Chemistry and Radiation Protection (RP) Technicians, System Operators, and oncoming shift personnel who assemble to aid in the response to an emergency. Briefings will be held with each team prior to being dispatched. A sample layout of the OSC is shown in Figure 5.1.B. Emergency kits containing radiation monitoring equipment, first-aid supplies, decontamination supplies, breathing apparatus, portable lighting, and portable radios are available to the OSC. If the OSC is deemed uninhabitable, the OSC may be moved to other locations as deemed appropriate by the OSC Manager. 5.1.4 Alternative Facility (SEP H.1.4) During a security-related event or other event that precludes onsite access, the TSC and OSC ERO will be directed to an alternative facility. This facility is located adjacent to the Georgia Power Company operating headquarters in Vidalia, Georgia and is approximately 22 miles from HNP. The alternative facility is equipped with the necessary communications and data links to support communications with the control room, site security, and the EOF. The available communications and data links also provide access to SNC document management resources, and to work planning resources for performing engineering assessment activities including damage control team planning and preparation for return to the site. Guidance for use of the facility is in site procedures. 5.1.5 Emergency Operations Facility (SEP H.2.1) The EOF is the central location for management of the offsite emergency response, coordination of radiological assessment, and management of initial recovery operations. The EOF is a dedicated facility located in Birmingham, Alabama, and serves as the EOF for SNC sites (VEGP, FNP, and HNP). Additional details regarding the EOF are contained in section H.2.1 of the Emergency Plan. A near site location is maintained at the Simulator Building with space for members of an NRC Site Team. 5.1.6 Joint Information Center (JIC) (SEP H.2.2) The HNP JIC is located in Vidalia, Georgia, adjacent to the Georgia Power Company operating headquarters. The JIC is the central location for the coordination and dissemination of information to news media, and responses to public and media inquiries. Details of the JIC for HNP are in section H of the EB-17 to NL-16-0169 Hatch Standard Emergency Plan Annex Emergency Plan. If the decision is made to activate the JIC, the CMC in Atlanta, Georgia will maintain emergency communications response coordination until the JIC is ready to assume these responsibilities. ES-18 to NL-16-0169 Hatch Standard Emergency Plan Annex NRC Room

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HP *CHEM Supervisor TSC Workroom ENS IEOJRfTY 0 Figure 5.1.A - Sample Technical Support Center E8-19 to NL-16-0169 Hatch Standard Emergency Plan Annex Set up may be modified by the OSC Mgr i EE EE

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l~eofrlf~ v.- SPOS Critlul 0 j 8 Beverage Counter Figure 5.1.B - Sample Operations Support Center E8-20 to NL-16-0169 Hatch Standard Emergency Plan Annex 5.2 On-Site Communications (SEP F.1) Normal on-site communications is provided by the plant telephone system (network and commercial) . The plant public address (PA) system may also be used for in-plant communications . 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. 5.3 Offsite Communications (SEP F.1) 5.3.1 Communications with the State and Local Counties (SEP F.1.2) The primary means of communication between HNP, the State of Georgia, and the local counties (Appling , Jeff Davis, Tattnall , and Toombs) is the Emergency Notification Network (ENN) . The ENN is a dedicated communications system from the plant to the state and local warning points, which are staffed 24 hours per day. Extensions for this system are located in the Control Room , the TSC , and the EOF. 5.3.2 Alternate Offsite Communications (SEP F.1.1) Commercial telephones or land lines provide backup for the ENN . 5.4 Communications System Testing (SEP F.3) Communication channels with the state of Georgia, the plume exposure pathway EPZ counties, and the NRG (with the exception of EROS) are tested each calendar month , using the extensions in the Control Room , the TSC , and the EOF. EROS is tested each calendar quarter. Communications procedures and systems are also tested each calendar year. 5.5 Emergency Kits (SEP H.9) Emergency supplies and equipment are located at various plant locations. Procedures require an inspection and operational check of equipment in these kits on a quarterly basis and after each use. Equipment in these kits is calibrated in accordance with the suppliers' recommendations. A set of spares of certain equipment is also maintained to replace inoperative or out-of-calibration equipment. 5.6 Facilities and Equipment for On-site Monitoring (SEP H.5) The plant instrumentation and monitors perform indicating , recording , and protective functions. The Reactor Protection System and associated plant instrumentation provide the ability to maintain plant safety from shutdown to full power operations , and to monitor and maintain key variables such as reactor power, flow, temperature, and radioactivity levels within predetermined safe limits at both steady state conditions and during plant transients. Plant instrumentation and control systems also provide means to cope with abnormal operating conditions. The control and display of information of these various systems are centralized in the unit Control Room . This instrumentation would provide the basis for initiation of protective actions. E8-21 to NL-16-0169 Hatch Standard Emergency Plan Annex 5.6.1 Geophysical Phenomena Monitors (SEP H.5.1) Meteorological (SEP H.5.1) Meteorological monitoring is in place at HNP. The instruments are mounted on a 100-meter primary tower located to the south of the power block and on a 45-meter backup tower located to the southeast of the power block. Parameters measured and transmitted to the Control Room include:

Windspeed
Wind direction
Vertical temperature difference
Ambient temperature A building that houses meteorological equipment is located near the base of each tower. The system is powered by an uninterruptible power supply for high availability. Additionally , meteorological information can be obtained from the National Weather Service to supplement onsite data and provide a backup to the plant meteorological monitoring program on an as-needed basis.

The important parameters for characterizing the transport of airborne radioactivity are wind speed , wind direction, and atmospheric stability (e.g., 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 methodology is described in Section I, Accident Assessment, of the SNC Standard Emergency Plan. Hydrologic (SEP H.5.1) The normal and emergency source of plant cooling water is the Altamaha River, which provides makeup to the cooling towers. The probable maximum flood level is approximately 105 ft msl. Seism ic (SEP H.5.1) Seismic monitoring instrumentation for HNP consists of time-history accelerographs, peak recording accelerographs (PRAs) , a response-spectrum recorder, and seismic switches. One triaxial seismic switch , with a horizontal set point of 0.08 g, is installed on the drywell pedestal on the 87 ft level of the Unit 2 reactor building . A second seismic switch is located outside the biological shield on the 185 ft level of the Unit 2 reactor building and has a vertical set point of 0.063 g. They are backup devices that actuate visual and audible annunciators in the Control Room . Activation of the seismic switches causes an audible and visual annunciation in the Control Room to alert the plant operator (PO) that an earthquake has occurred . These initial set points are based on experience in existing plants and may be changed once significant plant operating data, which indicate that a different set point will provide better strong-motion accelerometer (SMA) system operation , are obtained. E8-22 to NL-16-0169 Hatch Standard Emergency Plan Annex 5.7 Protective Facilities and Equipment (SEP J) 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. Georgia 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. 5.8 Medical Support (SEP B.6, SEP L) 5.8.1 Hospital and Medical Support (SEP B.6.3, L.1) Arrangements for treating radiologically contaminated and/or irradiated patients have been made with the Appling Healthcare System, located approximately 11 miles south of the site, and Meadows Regional Medical Center, located approximately 22 miles north of the site. Each hospital has a radiation emergency area separate from the rest of the complex. Each area contains facilities and equipment for emergency surgery, personnel dosimetry, decontamination , radioactive waste recovery, and portable shields for attendant exposure control. These facilities enable the emergency treatment and the handling of contaminated individuals. Non-contamination injuries will be handled by the hospital with its routine facilities. The medical staff of each hospital is trained to treat externally contaminated patients or individuals who have received high exposures. Trained plant radiation protection personnel assist hospital staff when plant personnel are being evaluated . Following decontamination, personnel suspected to have ingested radionuclides will undergo bioassay analysis for determination of internal contamination . A medical consulting group will provide medical support services to coordinate the total radiological management of radiation accident victims . An emergency medical assistance program has been established to use available personnel , facil ities, and material in an effective manner. 5.8.2 Ambulance Service (SEP B.6.2, L.4) Injured/externally contaminated personnel who require medical attention will normally be transported by ambulance to the cooperating hospitals. Ambulance crews are trained to handle external contamination cases , and an RP technician accompanies any contaminated patients to the hospital. Support and backup ambulance service are provided by the Appling County EMS and Toombs Montgomery County EMS, respectively . These crews also receive sufficient training in handling contamination cases. E8-23 to NL-16-0169 Hatch Standard Emergency Plan Annex Appendix A- Evacuation Time Estimate Study and Map Reference (SEP J.6) In order to ensure the safety of the public living in the vicinity of nuclear power plants in the nation, the U.S . Nuclear Regulatory Commission (NRC) requires licensees to develop and update evacuation time estimates (ETEs) for areas within the emergency planning zone (EPZ) . Population reviews will be conducted annually using the most recent US Census and local information . Updates are required following the availability of data from the decennial census (10 years) or when the sensitivity factor for changes in population within the EPZ has been exceeded . This appendix contains information from the ETE update performed in 2012. This update implements the requirements of the revised regulations relevant to ETE updates in accordance with the guidance provided in NUREG/CR-7002, Criteria for Development of Evacuation Time Estimate Studies and the requirements in 10 CFR 50, Appendix E, Sections IV.3 and IV.4. Southern Nuclear Operating Company (SNC) contracted Innovative Emergency Management (IEM) to estimate evacuation times for the 2012 populations within the 10-mile plume exposure pathway emergency planning zone (EPZ) surrounding the Edwin I. Hatch Nuclear Plant (HNP) . This appendix provides a summary of the final report describing the methods used to obtain population data and to estimate evacuation times , population figures, evacuation road network information , and ETEs. The report provides a breakdown of the population by geographic areas and protective action zones (PAZ) . Five categories of population are identified in the report:

Permanent residents
Transient population
Transit dependent permanent residents
Special facility residents
Schools The permanent resident population is made up of individuals residing in the 10-mile EPZ. The total year 2012 permanent resident populations within the 10-mile EPZ for HNP are estimated to be 8,609. The transient population consists of workers employed within the area , recreational sportsmen , and visitors. The total transient population within the 10-mile EPZ is estimated to be 1,841 , which includes 657 workers at HNP. The populations of two public schools and one state-sponsored special facility in the HNP EPZ were identified . In these analyses, the study team contacted the schools and the special facility within the EPZ area to collect current enrollment and staff figures. The total peak population for the schools is estimated at 977, and the special facility is estimated to be 66. Transit dependent permanent residents in the 10-mile EPZ are estimated to be 74. This study also considered the voluntary evacuees , who are also known as shadow evacuees that reside within 10 to 15 miles from HNP.

IEM utilized a computer traffic simulation model, PRV Vision VISUM , to perform the ETE analyses. For the analyses , the 10-mile plume exposure pathway EPZ was divided into 17 unique geographic areas based on 2-mile, 5-mile, and 10-mile radius rings, the 16 22.5-degree PAZs, as well as keyhole and staged evacuation logic. In order to represent the most realistic emergency scenarios, evacuations for the 17 geographic evacuation areas were modeled individually for the midweek daytime, midweek - weekend evening , and weekend daytime scenarios. Each of these scenarios was then considered under both normal and adverse weather conditions using the 2012 population estimations. A total of 102 evacuation scenarios were considered to represent different wind , temporal, seasonal , and weather conditions . Both 100% and 90% ETEs for each scenario were collected . The 100% ETEs for 2012 normal weather conditions ranged from 2 hours 50 minutes to 3 hours 35 minutes. The 100% ETEs for E8-24 to NL-16-0169 Hatch Standard Emergency Plan Annex 2012 adverse weather conditions ranged from 2 hours 55 minutes to 3 hours 55 minutes. The 90% ETEs for 2012 normal weather conditions ranged from 1 hour 35 minutes to 2 hours 45 minutes. The 90% ETEs for 2012 adverse weather conditions ranged from 1 hour 40 minutes to 3 hours. The factors that contributed to the variations in ETEs between scenarios include differences in the number of evacuating vehicles, the capacity of the evacuation routes used , or the distance from the origin zones to the EPZ boundary. The factors that contributed to the variations in ETEs between scenarios include differences in the number of evacuating vehicles, the capacity of the evacuation routes used , or the distance from the origin zones to the EPZ boundary. Based on the data gathered and the results of the evacuation simulations, the existing evacuation strategy was determined to be functional for the 2012 conditions, given the lack of severe congestion or very high ETEs. Recommendations were provided for enhancements to improve the evacuation time estimate. Assumptions utilized in the ETE will be reviewed when evaluating changes to roadways or evacuation networks to ensure the results of the ETE remain valid . Changes in population will be evaluated utilizing the sensitivity factor developed during the ETE analysis. The full Evacuation Time Estimate was submitted for NRC review in accordance with NRC regulations 10 CFR Part 50, Appendix E, Section IV.3. Following the NRC review, the results of the study and recommendations were reviewed with applicable offsite agencies. The review focused on the utilization of the results of the evacuation simulations provided in the ETE for comparison to existing protective action strategies. Modifications were incorporated as part of the ongoing emergency planning process. (

Reference:

Annual ETE Review document ETE-HNP-002; ETE document ETE-HNP-001). ES-25

Enclosure 8 to NL-16-0169 Hatch Standard Emergency Plan Annex Appendix B - Emergency Action Level (EAL) Scheme (SEP D.1) HOLD FOR EAL SCHEME E8-26 to NL-16-0169 Hatch Standard Emergency Plan Annex Appendix C - Hatch Nuclear Plant NUREG-0654 Cross Reference Table NUREG 0654 Rev 1 HNP SEP SNC SEP Section Ref Section Annex Criteria II.A - Assignment of Responsibility A.1 .a A.1 , A.2 , A.3 , A.4 1.3-1 .5 A .1.b Introduction Section 1: Introduction A.1 .c Figures B.2 .1.A, B.2 .2.A, B.3.1.A & -- B.3.2 .A A.1 .d B.3.1.1 -- A.1 .e B.1 Table 2.2 .A A. 2. a NIA NIA A.2 .b NIA NIA A .3 A.5 1.3 - 1.5, 2. 3 A.4 B.2, B.2.1. 15, B.3.1 .3 -- Criteria 11.B - Onsite Emergenc ' Organization B.1 B.2 -- B.2 B.1 .1 Table 2.2.A B.3 B.1.2 -- B.4 B.1.1, Figure B.2 .A -- B.5 Tables 1 - 4 Table 2 .2 .A B.6 B.2, B.3, Figures B.2.1.A , B.2.2 .A , -- B.3.1.A & B.3.2 .A B.7 Tables 1-4 -- Figu res B.2.1.A , B.2 .2.A, B. 3.1.A & B.3.2 .A B.7.a B.2.1 .15, B.3.1.3 -- B.7.b B.3.1.2, B.3.1.17 -- B.7.c B.3.1.1, B.3.1.2 -- B.7.d B.3.2.1, B.3.2.2, B.3.2.8 -- B.8 B.4, C.4.2 2.3 B.9 B.6, K.1 2.3 Criteria 11.C - Emergency Response Suooort and Resources C.1.a Section C -- C.1.b A.1 -- C.1 .c A.1 .1, A .2, A.3 , C.1-C.4 , F.1 Section 1 C.2.a NIA NIA C.2.b A.1 .1, H.2.1 5.1.2 C.3 H.5.2.3, H.6.3 -- C.4 Sections A & C, B.4-B.6, H.6 .3, L.1 - 1.3-1.5, 2 .3, 5.8 L.4 Criteria 11.D - Emergency Classification System 0 .1 Section D Aooend ix B 0 .2 Section D Aooend ix B 0 .3 NIA NIA 0.4 NIA NIA Criteria 11.E - Notification Methods and Procedures E.1 E.1.1 Append ix D E.2 E.2.1 -- E.3 E.2.2.2 -- E.4 E.2.2.2 -- E.4.a E.2.2.2 -- E.4.b E.2.2 .2 -- E.4.c E.2.2 .2 -- NOTE: N/A = Not required by Licensee in accordance with NUREG-0654 E8-27 to NL-16-0169 Hatch Standard Emergency Plan Annex NUREG 0654 Rev 1 HNP SEP SNC SEP Section Ref Section Annex Criteria 11.E - Notification Methods and Procedures (continued) E.4.d E.2.2.2 -- E.4.e E.2.2 .2 -- E.4.f E.2.2.2 -- E.4.g E.2.2.2 -- E.4.h E.2.2.2 -- E.4.i E.2.2.2 -- E.4.j E.2.2.2 -- E.4.k E.2.2.2 -- E.4.1 E.2.2.2 -- E.4.m E.2.2 .2 -- E.4.n E.2.2.2 -- E.5 N/A NIA E.6 E.2.5 -- E.7 E.2.6 -- Criteria 11.F - Emergency Communications F.1.a F.1.1 , F.1.2 4.1.1 F.1.b F.1.3 -- F.1.c F.1.4 -- F.1.d F.1.5 -- F.1 .e F.1.6 -- F.1.f F.1.4 -- F.2 F.2 -- F.3 F.3 5.4 Criteria 11.G - Public Education and Information G.1 G.1 -- G.2 G.8 2.3.4 G.3.a 8 .3.2.1, H.2.2, H.2 .3 5.1.6 G.3.b N/A N/A G.4.a 8 .3.2 .8 -- G.4.b G.2 -- G.4 .c 8 .3.2.5, 8 .3.2.6 -- G.5 G.2 -- Criteria 11.H - Emergency Equipment and Facilities H.1 H.1.2 5.1 .2 H.2 H.2.1 5.1.5 H.3 H.2.2, H.2.3 -- H.4 H.1 -- H.5 H.5 5.6 H.5.a H.5.1 5.6.1 H.5.b H.5.2 -- H.5.c H.5.3 -- H.5.d H.5.4 -- H.6.a H.5.1 5.6.1 H.6.b H.5.2 -- H.6.c H.5.2.3, H.6.3 -- H.7 H.6 -- H.8 H.7 5.6.1 H.9 H.1.3 5.1.3 H.10 H.8 -- H.11 H.9 -- H.12 H.10 -- NOTE: NIA= Not required by Licensee in accordance with NUREG-0654 E8-28 to NL-16-0169 Hatch Standard Emergency Plan Annex NUREG 0654 Rev 1 HNP SEP SNC SEP Section Ref Section Annex Criteria II.I - Accident Assessment 1.1 1.1 -- 1.2 1.2 -- 1.3.a 1.3 -- 1.3.b 1.3 -- 1.4 1.4 -- 1.5 1.5 -- 1.6 1.6 --

1. 7 1. 7 --

1.8 1.8 --

1. 9 1.9 --

1.10 1.7 -- 1.11 NIA NIA Criteria 11.J - Protective Response J .1.a J.1 -- J .1.b J.1 -- J .1.c J.1 -- J.1.d J.1 -- J.2 J.4 .3 -- J.3 J.2 -- J.4 J.3, J.4.3 -- J .5 J.4 .2, 4 .3.2 -- J .6 .a J.4 -- J.6.b J.4 -- J.6 .c J.4 -- J .7 J.5 -- J.8 J.6 Append ix A J .9 NIA NIA J.1 0.a J.7 -- J .10.b J.7 -- J .10.c E.2.5 4 .2 J .10.d NIA NIA J .10.e NIA NIA J.1 O.f NIA NIA J.10.q NIA NIA J.10.h NIA NIA J.10.i NIA NIA J.10.j NIA NIA J .10.k NIA NIA J.10.1 NIA NIA J.10.m J.5 -- J.11 NIA NIA J.12 NIA NIA Criteria 11.K - Radiological Exposure Control K.1 .a K.1.1 -- K.1.b K.1 -- K.1.c K.1 -- K.1.d K.1.2 .1 -- K.1.e K.1.2.1, K.5 -- K.1.f K.1.1.1 -- K.1.q K.1.3 -- NOTE : N/A = Not required by Licensee in accordance with NUREG-0654 E8-29 to NL-16-0169 Hatch Standard Emergency Plan Annex NUREG 0654 Rev 1 HNP SEP SNC SEP Section Ref Section Annex K.2 K.1 -- Criteria 11.K - Radiological Exposure Control (continued) K.3.a K.3 -- K.3.b K.3 -- K.4 N/A N/A K.5.a K.5 -- K.5.b K.5 -- K.6.a K.6 -- K.6.b K.6 -- K.6.c K.6 -- K.7 K.7 -- Criteria 11.L - Medical and Public Health Suooort L.1 L.1 -- L.2 L.2 -- L.3 N/A N/A L.4 L.4 -- Criteria 11.M - Recovery and Reentry Planning and Post-Accident Operations M.1 M.1 -- M.2 M.2 -- M.3 M.3 -- M.4 M.4 -- Criteria 11.N - Exercises and Drills N.1.a N.1 -- N.1.b N.1 -- N.2.a F.3 -- N.2 .b N.2.3 -- N.2.c N.2.4 -- N.2.d N.2.5 -- N.2.e(1) N.2.6 -- N.2.e(2) N.2.6 -- N.3.a N.3 -- N.3.b N.3 -- N.3.c N.3 -- N.3.d N.3 -- N.3.e N.3 -- N.3.f N.3 -- N.4 N.4 -- N.5 N.5 -- Criteria 11.0 - Radiological Emergency Response Training 0 .1 0 .1 -- 0 .1.a 0 .1.1 -- 0 .1.b 0 .1.1 -- 0 .2 0 .3 -- 0 .3 0.4 -- 0.4.a 0.4 -- 0.4.b 0.4 -- 0.4 .c 0.4 .3 -- 0.4.d 0.4.1, 0.4.4 -- 0.4.e 0.4.5 -- 0.4.f 0.4.6 -- 0.4.Q 0 .1.1 -- 0.4.h 0 .1.1 -- NOTE: N/A = Not required by Licensee in accordance with NUREG-0654 EB-30

Enclosure 8 to NL-16-0169 Hatch Standard Emergency Plan Annex NUREG 0654 Rev 1 HNP SEP SNC SEP Section Ref Section Annex 0.4.i 0.4 -- - Criteria 11.0 - Radiological Emergency Response TraininQ (continued) 0.4.i 0.4, 0.4.7 -- 0 .5 0.4 -- Criteria 11.P - Responsibility for the Planning Effort: Development, Periodic Review and Distribution of Emeri:1encv Plans P.1 0 .5, Section P -- P.2 Section P -- P.3 P.1 -- P.4 P.1 -- P.5 P.3 -- P.6 P.3 -- P.7 -- Append ix D P.8 Table of Contents -- P.9 P.3 -- P.10 F.1 .4 -- NOTE: NIA = Not required by Licensee in accordance with NUREG-0654 E8-31 to NL-16-0169 Hatch Standard Emergency Plan Annex Appendix D - Supporting Plans & Implementing Procedures (SEP P.3) Supporting Plans

State of Georgia Radiological Emergency Response Plan
Appling , Jeff Davis, Tattnall , and Toombs County Emergency Response Plans .
HNP Security Plan
HNP Fire Protection Plan Administrative and Emergency Plan Implementing Procedures (EPIP)

Plan Section Title EPIP EPIP Title Section A Assignment of Responsibility NMP-EP-300 SNC Emergency Preparedness (under Conduct of Operations development) 73EP-ADM-001-0 Maintaining Emergency Preparedness B Emergency Response NMP-EP-146 ERO Position Checklists Organization 73EP-EIP-005-0 On Shift Operations Personnel Emergency Duties AG-EPX-01-0415 Emergency Response Organization Position Guidance c Emergency Response Support NMP-EP-300 SNC Emergency Preparedness and Resources (under Conduct of Operations development) D Emergency Classification System NMP-EP-141 Emergency Classification E Notification Methods and NMP-EP-142 Emergency Notification Procedures NMP-EP-308 SNC Emergency Alert Siren Operation , Testing And Maintenance F Emergency Communications NMP-EP-300 SNC Emergency Preparedness (under Conduct of Operations development) G Public Education and Information NMP-EP-203 Corporate Media Center Operations NMP-EP-204 Emergency News Center/Joint Information Center Operations NMP-EP-205 Emergency Communications News Releases NMP-EP-206 Emergency Communications News Briefings NMP-EP-207 Emergency Communications Public Response E8-32 to NL-16-0169 Hatch Standard Emergency Plan Annex Plan Section Title EPIP EPIP Title Section H Emergency Facilities and NMP-EP-143 Facility Activation Equipment NMP-EP-305 Equipment Important to the EP Function 73EP-EI P-016-0 TSC HVAC Operation 73EP-INS-001 -0 Emergency Equipment Inventory Emergency Response Facilities 73EP-INS-002-0 Supplies Inventory Control & Testing Of Emergency 73EP-TET-001-0 Equipment Repair and Corrective Action 73EP-RAD-006-0 During a Radiological Emergency I Accident Assessment NMP-EP-140 Accident Assessment 73EP-EIP-014-0 Internal Survey Team Duties 73EP-EIP-020-0 Offsite Environmenta l Monitoring During Emergencies J Protective Response NMP-EP-144 Protective Actions 73EP-EIP-009-0 Nuclear Security Duties 73EP-EIP-012-0 Search and Rescue T earn Duties 73EP-EIP-019-0 Rally Point Team Duties K Radiological Exposure Control NMP-EP-144 Protective Actions 73EP-EIP-013-0 Contaminated Injury and First Aid 73EP-EI P-017-0 Emergency Exposure Control L Medical and Public Health NMP-EP-300 SNC Emergency Preparedness Support (under Conduct of Operations development) M Recovery and Re-entry Planning NMP-EP-145 Termination and Recovery and Post Accident Operations N Exercises and Drills NMP-EP-303 Drill and Exercise Standards 0 Radiological Emergency NMP-EP-301 EOF Emergency Response Response Training Organization And EP Staff Tra ining 75TR-TRN-001-0 Emergency Preparedness Train ing p Respons ibility for the Planning NMP-EP-300 SNC Emergency Preparedness Effort Conduct of Operations NMP-EP-310 Maintaining The Emergency Plan NMP-EP-312 Development Of Emergency Preparedness Technical Products NMP-TR-104-006 SEPTOC 73EP-ADM-001 -0 Maintaining Emergency Preparedness EB-33

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 9 Hatch Justification Matrix (Marked-Up Pages and Clean Copy) to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 State and County Operations EP A.2.2 State of Georgia The word ing was standardized and relocated The State and County responses are EP A.2.2.1 Georgia Emergency Management Agency to the SNC Standard Emergency Plan. conducted in accordance with the (GEMA) following framework, as presented in the As the overall state coordinating agency GEMA will Georgia RERP: coordinate with DNR-EPD on emergency response

1. As the lead radiation emergency activities with state, county and municipal agencies and response agency, the DNR is involved in departments as stated in the Georgia Emergency virtually all peacetime radiation Operations Plan (GEOP) . GEMA provides for 24-hour emergencies , regardless of severity, due notification and staffing of the State Operations Center to its assigned responsibility and the (SOC) and/or the Forward Emergency Operations probable requirements for special Center (FEOC), as required, throughout the event.

techniques, equipment, and expert GEMA is responsible for general state emergency personnel. planning and overall direction and control of emergency

2. As the designated agency to administer or disaster operations as assigned by executive order NRC Agreement State Programs, the and in accordance with the Georgia Emergency Department of Natural Resources is the Operations Plan (GEOP). GEMA has responsibilities principal radiation emergency response for coordinating the state of Georgia response to support agency due to the probable emergencies at nuclear power plants.

requirements for special techniques, EP A.2.2.2 Department of Natural Resources equipment, and expert personnel. Environmental Protection Division (DNR-EPD)

3. As the overall State coordinating Department of Natural Resources-Environmental agency, GEMA coordinates the DNR Protection Division (DNR-EPD) is assigned as the emergency response activities with State, coordinating and a primary agency responsible by County, and municipal agencies and Executive Order for implementation and administration departments, as stated in the Georgia of the state radiological and hazardous material Emergency Operations Plan. function.

4. To the extent available, local The DNR-EPD has primary responsibility for resources, personnel authority, and implementation and administration of the state emergency plans are employed in radiological emergency response function.

response to radiation emergencies. EP A.2.2.3 Other Georgia State Agencies Responsibilities of other state agencies are described in the Georgia Emergency Operations Plan (GEOP) . E9-31 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36

4. Agency Support EP Section C Once an emergency has been declared , The wording was standardized and relocated Assistance may be requested from the the Emergency Director (ED) has the authority and to the SNC Standard Emergency Plan.

State of Georgia or the Federal agencies. responsibility to request aid from offsite organizations, Section A of this Plan describes the whether they are other SNC-operated nuclear power assistance that may be requested . Any plants , federal , state, local , or private organizations . requests for aid are made by the ED. Interfaces Among Res12onse Grou12s No equivalent Plan/Annex figure The SNC Standard Emergency Plan and Section A, Figure A-1, illustrates the Annex now specifically describe the integrated organization for response to an responsibilities of the various response emergency at HNP. groups. Figure A-1 is no longer required . TABLE B-1 Annex Table 2.2.A The wording was standardized and relocated MINIMUM STAFFING CAPACITY FOR to the Site Annex. EMERGENCIES TABLE B-2 EP 0.1 To achieve and maintain an acceptable level of The wording was standardized and relocated EMERGENCY ORGANIZATION emergency preparedness, training will be conducted for to the SNC Standard Emergency Plan. ASSIGNMENTS members of the Emergency Response Organization (ERO) and those offsite organizations that may be called on to provide assistance in the event of an emergency. Training will be evaluated in accordance with the requirements of Systematic Approach to Training practices to ensure effectiveness and in order to identify weak or deficient areas that need correction. The ERO Training Program ensures the train ing , qualification, and requalification of individuals who may be called on for assistance during an emergency. FIGURE B-1 EP Figure P.1 The wording was standardized and relocated TYPICAL HNP ORGANIZATION CHAR to the SNC Standard Emergency Plan . FIGURE B-2 EP 8.2: Figures B.2.B through B.2.E illustrate the The word ing was standardized and relocated TYPICAL ALERT, SITE AREA OR overall augmented emergency response organization . to the SNC Standard Emergency Plan . GENERAL EMERGENCY RESPONSE ORGANIZATION E9-50 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 The FEMA is assigned lead responsibility EP A.1.3 Federal Emergency Management Agency The wording was standardized and relocated for Federal offsite nuclear emergency (FEMA) to the SNC Standard Emergency Plan. planning and response (per Title 44 CFR The primary role of FEMA is to support the states by 351 ). FEMA is also delegated coordinating the delivery of federal non-technical responsibility for development and assistance. FEMA coordinates state requests for promulgation of the Federal Radiological federal assistance, identifying which federal agency can Emergency Response Plan (FRERP) best address specific needs. If deemed necessary, which assumes states will be responsible FEMA will establish a nearby Joint Field Office from for overall management of offsite which it will manage its assistance activities. emergency response. The Federal government's role consists of providing technical and/or logistical resource support at the request of State emergency management. Federal emergency response consists of No direct statement in Plan/Annex. The word ing was standardized and relocated technical and nontechnical components. EP A.1.1 Nuclear Regulatory Commission (NRC) to the SNC Standard Emergency Plan . The NRC and FEMA jointly coo rdinate The NRC is the coordinating agency for incidents at or federal emergency response actions. caused by a facility or an activity that is licensed by the NRC or an Agreement State, with the Chairman of the Commission as the senior NRC authority for response . The Chairman can transfer control of emergency response activities when deemed appropriate. The NRG acts as the lead federal agency for technical matters during a nuclear incident, with the Chairman of the Commission as the senior NRG authority for response . EP A.1.3 Federal Emergency Management Agency (FEMA) The primary role of FEMA is to support the states by coordinating the delivery of federal non-technical assistance. FEMA coordinates state requests for federal assistance, identifying which federal agency can best address specific needs. If deemed necessary, FEMA will establish a nearby Joint Field Office from which it will manage its assistance activities. E9-55 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 The NRC coordinates technical aspects, No direct statement in Plan/Annex. The wording was standardized and relocated and FEMA coordinates nontechnical EP A.1.1 Nuclear Regulatory Commission (NRC) to the SNC Standard Emergency Plan . aspects of Federal response. The NRC is the coordinating agency for incidents at or caused by a facility or an activity that is licensed by the NRC or an Agreement State, acts as tho load federal agency for technical matters during a nuclear incident, with the Chairman of the Commission as the senior NRC authority for response . EP A.1.3 Federal Emergency Management Agency (FEMA) The primary role of FEMA is to support the states by coordinating the delivery of federal non-technical assistance. The NRC and FEMA have stated that No equivalent Plan/Annex statement. Section H of the SNC Standard Emergency they each expect to have a representative Plan and Site Annex describe the space at HNP within approximately 3 hours after made available to federal responders. receiving notification. DOE can give assistance within approximately 2 hours. Airfields within the plant vicinity that may No equivalent Plan/Annex statement. Section H of the SNC Standard Emergency be used to support the Federal response, Plan and site annex describe the space made as well as that of other response groups , available to federal responders . include a commercial airport with scheduled service and nearby municipal airports that can accommodate small aircraft. The approximate distance and direction to these airfields are as follows : (List of Airfields and distance from site not included for simplicity) E9-56 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Once an emergency classification is EP D.2.5 Emergency Classification Level Downgrading The wording was standardized and relocated made, it cannot be downgraded to a lower and Termination to the SNC Standard Emergency Plan. classification. Actions associated with the The SNC policy is that once an emergency classification emergency classification level will is made, it cannot be downgraded to a lower normally be completed and then a classification. Termination criteria contained in the termination of the event can be affected. Emergency Plan Implementing Procedures shall be At termination, on an event specific basis , completed for an event to be terminated. At the site can either enter normal operating termination, on an event specific basis, the site can conditions or enter a recovery condition either enter normal operating conditions or enter a with a recovery organization established recovery condition with a recovery organization for turnover from the ERO. established for turnover from the ERO. When the site determines that transition to termination or recovery is appropriate, the information will be transmitted to respective offsite agencies. The described emergency classes and EP D.1.1.1 The classification scheme is provided to and The wording was standardized and relocated the emergency action levels (EAL) which discussed by Southern Nuclear Company, agreed upon to the SNC Standard Emergency Plan. determine them are agreed on by SNC by state and county governmental authorities and and State and local authorities. The EAL approved by the NRC. The classification scheme and will be reviewed by these officials specific Emergency Action Levels are reviewed with the annually. State and local governmental authorities on an annual basis.

1. Notification of Unusual Event (NUE) EP D.1.1.2 UNUSUAL EVENT (UE) The wording was standardized and relocated

a. Description Events are in progress or have occurred which indicate to the SNC Standard Emergency Plan.

The classification of a NUE applies to a potential degradation of the level of safety of the plant situations in which events are in process or indicate a security threat to facility protection has or have occurred which indicate a been initiated. No releases of radioactive material potential degradation of the level of safety requiring off-site response or monitoring are expected of the plant or indicate a security threat to unless further degradation of safety systems occurs. facility protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs. E9-64 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36

b. Response No direct equivalent Plan/Annex Statement Section B of the SNC Standard Emergency In the event of a NUE, the SM will assess Plan describes the overall responsibilities of the conditions, assume the ED duties , the Shift Manager/Interim ED. Repetition in and implement the classification this section was eliminated.

Emergency Implementing Procedure (EIP) . The Emergency Organization will perform EP E.1.1 SNC-operated plants maintain the capability of The wording was standardized and relocated the following: notifying state and local agencies within 15 minutes of a to the SNC Standard Emergency Plan.

1) Inform State and local offsite declared emergency as required by 10CFR50 Appendix authorities of the nature of the unusual E, section IV(D)(3}.

event within 15 min of classifying the NRC will be notified by the impacted site immediately emergency. Notify th e NRC as soon as following state and local notifications, but within an hour possible (ASAP), but no later than 1 hour of an emergency classification using ENS. following classification of the emergency. t>mG will ee RetifieEI ey tl=le l=leaEIEi1:JaFteFs Gf:leFatieRs

2) Augment on-shift resources, as GffiseF, irnrneEliately fellewiRg state aREI lesal needed . RetifisatieRs , 91:Jt witl=liR aR l=lem ef aR ernmgeRGY

3) Assess and respond to the event. slassifisatieR .

4) Escalate to a more severe class, if EP E.2.1 Notification procedures include notification of appropriate, or close out with a verbal Emergency Response Organization Personnel (ERO) summary to offsite authorities followed by not on site or during backshift hours. ERO members a written summary within 24 hours. will be notified by means of an automated callout system activated by on-shift personnel.

E9-65 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 The 15-minute period encompasses all EP D.1.1.1 SNC has and maintains the capability to The wording was standardized and relocated assessment, classification , and assess , classify, and declare an emergency condition to the SNC Standard Emergency Plan. declaration actions associated with within 15 minutes after the availability of indications to making an emergency declaration from plant operators that an EAL threshold has been met or the first availability of a plant indication or exceeded. Upon identification of the appropriate receipt of a report of an off-normal by emergency classification level, the emergency condition plant operators up to and including the will be promptly declared. declaration of the emergency. If classification 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 wh ich declarations are made} are included within the 15-minute criterion . FIGURE D "HOT" INITIATING Annex Appendix 8 The approved EAL scheme is not impacted CONDITION MATRIX by this submittal. FIGURE D "COLD" INITIATING Annex Appendix 8 The approved EAL scheme is not impacted CONDITION MATRIX by this submittal. E. NOTIFICATION METHODS AND EP E.1.1 SNC-operated plants maintain the capability of The wording was standardized and relocated PROCEDURES notifying state and local agencies within 15 minutes of a to the SNC Standard Emergency Plan . This section describes the plan for declared emergency as required by 10CFR50 Appendix notification of onsite and offsite licensee E, IV.D.3. The methods and forms used for notifying emergency response personnel for HNP, state and county authorities are site-specific, and State, local , and NRC emergency detailed in plant specific Emergency Plan Implementing response centers . Actual methods and Procedures (EPIPs). sequencing of notifications are covered in NRC will be notified by the impacted site immediately appropriate implementing procedures . following state and local notifications, but within an hour Table E-1 presents the initial notification of an emergency classification using ENS. concept for normal working hours and J':lmG will se AetifieEl sy H:ie l=leaEltil:laFtern G~eFatieAS backshift hours . GffiseF, iFAFAeEliately fellewiA!il state aAEl lesal AetifisatieAs, Sl:lt withiA aA hel:lF ef aA eFAeF!i19AGY slassifisatieA . E9-73 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Figure E-1 presents the sample EP E.2.2.2: Initial Notification Message Form The commitment wording was standard ized Emergency Notification Form for making In conjunction with state and county authorities , SNC and relocated to the SNC Standard notifications to these response centers . operated plants have established the contents of the Emergency Plan and Site Annex. This form has been developed in initial and subsequent state notification message forms conjunction with appropriate agencies . to be used during an emergency. These forms are The Emergency Notification Form may be described in EPIPs. The content of the forms has been revised upon receipt of State and utility reviewed and agreed on by the respective Offsite approval. Any revisions to the Notification Response Organizations . Form are incorporated into the applicable Annex 4.1.1 : State and local warning points are staffed implementing procedure are included in 24 hours per day. State county authorities to be notified the next revision to the Emergency Plan. within 15 minutes of the declaration of an emergency condition are:

Georgia Emergency Management Agency (GEMA).

Georgia County Authorities:

Appling County warning point.
Jeff Davis County warning point.
Tattnall County warning point.
Toombs County warning point.

Verification of Notification Messages EP E.2.7 Verification of Notification Messages The wording was standardized and relocated All ENN notification messages must be The SNC emergency notification form is transmitted to the SNC Standard Emergency Plan. verified as being received by the State of electronically to the responsible state and local Georgia and Appling, Jeff Davis, Tattnall, agencies using a secure data sharing system provided and Toombs Counties . Verification is by SNC. Once transmitted to the OROs , the receipt of normally accomplished by roll call. this information is confirmed using a dedicated communications link. E9-77 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 The initial notification, when appropriate, Annex 4.2 The wording was standardized and relocatec The FEMA approved Hatch ANS consists of a primary ANS and a backup of the affected population within the to the Site Annex. plume exposure pathway EPZ is to be .. system should there be a failure of the primary system . Primary - Sirens and Emergency Alert System (EAS) stations System Backup - Reverse calling system completed by the State and/or local The primary ANS has two communications pathways. The first pathway is authorities in a manner consistent with through the primary agency via the UHF or VHF radio. Should the primary assuring the public health and safety. agency fail to activate the system , the secondary pathway will be utilized by the secondary agency. The secondary pathway functions in the same manner as the primary pathway utilizing a separate activation console that is physically located in separate location. If neither agency can activate the system , the backup system will be utilized to notify the residents of the 10 mile EPZ. The hierarchv for svstem activation is orovided below: Agency Rad io Systems Primary Agency UHF VHF Primary Sirens & EAS Secondary Agency UHF VHR I Backup Each County EMA Calling System I Georg ia I Primary Agency State of Georgia (GEMA) Secondary Agency Appling County PFifl1ary alaftiRg is aGGefl1plislla9 ey lJS8 el a siFaR syslaf!1 . IOaGR siFaR eparalas eR t:Jattary peu*aF witll l:Jaliary GRa~a f!1aiRtaiRa9 l:Jy aR iRY8ft8f tllal F8Geiuas pe*"Sf lf8fl1 tlla leGal alaGIFiGal gfi9eF1Fefl1 a salaF paRel (s). SiFeR systefl1 aGliYatieR , test, aR9 fl1eRilefiRg Gapaeility aFe prnYi9e9 leF /\ppliRg CelJRly, Gee~ia aR9 ISF tile stale el GeeFgia. E9-79 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 The primary means for alerting and An nex 4.2 The wording was standardized and relocatec The FEMA approved Hatch AN S consists of a primary ANS a nd a backup to the SNC Standard Emergency Plan . providing instructions to the public is by a siren system and Emergency Alert .. system should there be a failure of the primary system. Primary - Sirens and Emergency Alert System (EAS) stations System Backup - Reverse calling system System (EAS). The prompt notification The primary ANS has two communications pathways. The first pathway is See detailed description of the Siren System system (PNS) is described in Appendix 3. through the primary agency via the UHF or VH F radio. Should the primary was relocated to the Site Annex. agency fail to activate the system , the secondary pathway will be utilized by the secondary agency. The secondary pathway functions in the same manner as the primary pathway utilizing a separate activation console that is physically See the details of Justification in the Append x located in separate location . If neither agency can activate the system , the 3 section of this document. backup system will be utilized to notify the residents of the 10 mile EPZ. The hierarchy for system activation is nrovided below: Agency Radio Systems Primary Agency UHF VHF Primary Sirens & EAS Secondary Agency UHF VHR Backup Each County EMA Calling System Georgia Primary Agency State of Georgia (GEMA) Secondary Agency Appling County I i;lliFRai:y al8ftiA!J is aGGeFRplisllaEf 0.,. use el a siFBA 6'1'61BFR . !>aGR siFBA eparalas BA 9allai:y f'J9U*9F witR 9allai:y GRaF!JB FRaiAtaiABEf 0.,. aA iAUBRBF tllal FBGaiues PB"'BF lreFR tile leGal BIBGIRGal !JRS BF IFBFR a selaF paAel{s). l>iFBA S'i'SIBFR aGti'*atieA , test, aAEf FRBAileFiA!J Gapa9ilil'I' aFe previEfaEf leF *ppliA!J CeuAly, GeeF!Jia aAEf leF tile state el GaeF!Jia E9-80 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Information for Transients An nex 2.3.4 Several commun ications methods may be The commitment wording was standardized Posted "Emergency Information" signs used to acquaint the public with plans for their and relocated to the Site Annex. and a notice published in the local protection during a Plant emergency. Effort will be telephone books are used to provide the concentrated on providing information to the public by transient population with appropriate written material that is likely to be available in local emergency information and instructions. residences and in locations frequented by transients . The information/instructions advise the The information will also provide instructions on which public on how they will be notified in the local media will be providing additional information in event of an emergency; indicate the the event of an emergency. actions to take if notified; and refer the public to designated broadcast stations for information in the event of a serious emergency. Method of Emergency Information EP G.8 Public Information and Education Program The commitment wording was standardized Dissemination The goal of the public information program is to and relocated to the SNC Standard Any proposed change in the method of acquaint the general public with the emergency plans Emergency Plan. dissemination of emergency information for the operation of APC/GPC nuclear plants, as to the public must be coordinated and appropriate, and actions they should take in the event of discussed with , and agreed upon by a pl ant emergency. appropriate State and local offsite Emergency information is disseminated each calendar emergency officials prior to year for residents and transients in the plume exposure implementation of the change. The pathway Emergency Plann ing Zone. Emergency Plan may be changed with EP G.1 Purpose regard to the manner in which the SNC uses a number of ways to communicate the information is provided to the publ ic under information to the EPZ population. These means are 10 CFR 50.54 (q) provided the requisite developed in coordination with respective offsite emergency information remains the same agencies. Any proposed change in the method of as currently approved by the NRC and dissemination of emergency information to the public FEMA as contained in the Hatch must be coordinated and discussed with, and agreed Emergency Plan and the FEMA-43 upon by appropriate State and local offsite emergency Report for the Edwin I. Hatch Nuclear officials prior to implementation of the change. Plant. E9-89 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Status boards containing plant conditions No equivalent Plan/Annex statement The SNC Standard Emergency Plan and and emergency classification will be Annex maintain the commitment to assemble available in the OSC. and dispatch event response teams from the OSC. The details of team management will be relocated to EPIPs. Emergency kits containing radiation EP H.1.3: Emergency supplies are maintained in the The commitment wording was standardized monitoring equipment, first-aid supplies, OSC. When an emergency condition exists at one and relocated to the SNC Standard decontamination supplies, breathing SNC-operated nuclear power plant, additional supplies Emergency Plan. apparatus, portable lighting , and can be obtained from other unaffected plants and SNC hand-held radios are available to the resources upon request. OSC. In the event the OSC becomes EP H 1.3: Alternate locations are available should the The commitment wording was standardized uninhabitable during an emergency, OSC OSC become uninhabitable. and relocated to the SNC Standard functions will be conducted from the Annex Section 5.1.3: If the OSC is deemed Emergency Plan . alternate OSC located in the Simulator uninhabitable, the OSC may be moved to other Build ing . locations as deemed appropriate by the OSC Manager Operations at the OSC are directed by EP 8.2.2.1 OSC Manager The commitment wording was standardized the OSC Manager. The OSC Manager reports to the TSC Manager and and relocated to the SNC Standard directs a staff in providing labor, tools, protective Emergency Plan . equipment, and parts needed for emergency repair, damage control , firefighting , search and rescue , first aid, and recovery. EOF EP H.2 Offsite Emergency Facilities The details of the EOF have been Description of EOF operations and EP H.2.1 Emergency Operations Facility incorporated into Section H of the SNC staffing is contained in Appendix 7. The EOF is the central location for management of the Standard Emergency Plan. offsite emergency response , coordination of radiological assessment, and management of initial recovery The comparative analysis is included in the operations. The EOF is a dedicated facility located in justification section for Appendix 7. Birmingham, Alabama, and serves as the EOF for SNC sites (VEGP, FNP, and HNP). The EOF is procedurally required to be activated within 75 minutes following the declaration of an Alert or higher classification. gtaffiAg aAEI activatioA of tho EOF is maAElatory upoA EleclaratioA of aA Alert or higher classificatioA. E9-98 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Activation and staffing of the EOF is EP H.2 Offsite Emergency Facilities EOF activation has been incorporated into contained in Appendix 7. EP H.2.1 Emergency Operations Facility Section H of the SNC Standard Emergency The EOF is the central location for management of the Plan. offsite emergency response, coordination of radiological assessment, and management of initial recovery The commitment to activate the facilities at operations. The EOF is a dedicated facility located in Alert or higher was relocated to the SNC Birmingham , Alabama, and serves as the EOF for SNC Standard Emergency Plan . sites (VEGP, FNP , and HNP). The EOF is procedurally required to be activated within 75 minutes following the The activation time commitment is justified in declaration of an Alert or higher classification. Staffing and the Technical Analysis Section of this LAR. activation of the EOF is mandatory upon declaration of an Alert or higher classification. For security related events, the activation EP H.1.4 Alternative Facilities The wording was standardized and relocated of emergency facilities may be delayed as An Alternative Facility for staging of ERO personnel has to the SNC Standard Emergency Plan. described in section B. Activation of ERO been designated at the sites. In the event of a Security members will be performed for hostile or Hostile Action threat or event, the designated action based events to promptly staff Alternative Facility may also serve as an evacuation alternative facilities, in order to minimize location for TSC and OSC personnel. The Alternative delays in overall site response. The ERO Facility is designed to be accessible in the event of an will be staged in a manner that supports onsite HAB event and has the capability to: rapid response to limit or mitigate site

Communicate with the Control Room , Security, damage or the potential for an offsite and the EOF.

radiological release.

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

The functions of Notification and PARs will be performed from the EOF should the Alternative Facility be activated . Details of Alternative Facilities can be found in the Site Specific Annex. E9-103 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Radiation Monitoring System (RMS) EP H.5.2.1 Radiation Monitoring System (RMS) The commitment wording was standardized The RMS receives and processes Radiation monitoring instruments are located at and relocated to the SNC Standard radiological input readings during normal selected areas within the plant to detect, measure, and Emergency Plan . and abnormal operating and accident record radiation levels. The monitors are comprised of conditions ; measures, evaluates , and area, airborne and air particulate monitors . reports radioactivity in designated areas;

Area monitors respond to gamma radiation .

and monitors releases of radioactive

Airborne monitors detect and measure radioactive materials in liquid and gaseous effluents. gaseous effluent concentrations .

Data from the RMS are available in the

Air Particulate detectors capture and measure Control Room. A more detailed airborne particulate description of the RMS is provided in the Emergency response procedures provide methods for HNP-2-FSAR, Section 11.4. determining relationships between monitor readings and releases , material available for release and extent of core damage.

Section H: The post-accident radiation EP H.5.2.2: The process sampling system consists of the The commitment wording was standardized monitors provide radiation monitoring normal sampling system and additional sampling panels and relocated to the SNC Standard after an accident. located throughout the plant. Pre-designated monitoring Emergency Plan . and sampling points are listed in site procedures. Sampling systems are installed or can be modified to permit reactor coolant and containment atmosphere sampling even under severe accident conditions. The system can provide information on post-accident plant conditions to allow operator actions to mitigate and control the course of an accident. Various chemical analyses and radiological measuremen ts on these samples can be performed , including the determination of radionuclide concentrations. E9-107 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 There are three types of radiation EP H.5.2.1 Radiation Monitoring System (RMS) The commitment wording was standardized monitors in the RMS: airborne and air Radiation monitoring instruments are located at and relocated to the SNC Standard particulate radiation monitors, liquid selected areas within the plant to detect, measure, and Emergency Plan. rad iation monitors , and post-accident record radiation levels. The monitors are comprised of rad iation Backup power to the post- area, airborne and air particulate monitors. accident monitors is supplied by a DG to

Area monitors respond to gamma rad iation .

ensure against interruption of monitor

Airborne monitors detect and measure radioactive operation and loss of data. gaseous effluent concentrations .
Air Particulate detectors capture and measure airborne particulate Emergency response procedures provide methods for determining relationships between monitor readings and releases , material available for release and extent of core damage.

The post-accident radiation monitors EP 1.2 Continuing and Post Accident Assessment The commitment wording was standardized provide radiation monitoring after an The resources available to provide initial and continuing and relocated to the SNC Standard accident. information for accident assessment throughout the Emergency Plan. course of an event include plant parameter display systems, liquid and gaseous sampling system, area and process radiation monitoring Systems, and Accident Radiation Monitoring Systems. The monitors are comprised of area, EP H.5.2.1: The monitors are comprised of area, The commitment wording was standardized airborne, and air particulate monitors. airborne, and air particulate monitors and relocated to the SNC Standard Emergency Plan . Area monitors respond to gamma EP H.5.2.1: Area monitors respond to gamma The commitment wording was standardized radiation photons within any energy range radiation. and relocated to the SNC Standard from 60 KeV to 3 MeV. Emergency Plan . E9-108

Enclosu re 9 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Procedures require an inspection and EP H.8: Emergency facilities and equipment are The commitment wording was standardized operational check of equipment in these inspected and inventoried using appropriate and relocated to the SNC Standard kits on a quarterly basis and after each administrative or department procedures. These Emergency Plan . use. inventories will include requirements that provisions are in place to inspect, inventory, and operationally check emergency equipment/instruments at least once each calendar quarter and as needed. These procedures provide information on location and availability of emergency equipment and supplies.E:rneFJ9AGy fasilities aA9 etiYiprneAt am iAspeste9 aA9 iAi.<eAteFie9 l:lSiAJ appFepFiate a9rniAistFati*.ie eF 9epaFtrneAt pmse91:lFes.

                                          +l=lese pmse9YFes pFevi9e iAfeFrnatieA eA lesatieA aA9 a>,<ailal::lility ef erneFJ9AGy etiYiprneAt aA9 sl:lpplies.

Section H: Spare equipment is also EP H.8: Sufficient reserves of instruments and equipment The commitment wording was standardized maintained to rep lace inoperative or out- are maintained to replace those removed from and relocated to the SNC Standard of-calibration equipm ent. emergency kits or lockers for calibration or repair Emergency Plan. Typical listings of the emergency supplies No direct equivalent Plan/Annex kit statement. The SNC Standard Emergency Plan and Site and equipment are included in Append ix EP H.9 Emergency Kits Annex retain the commitment to provide

4. Emergency kits are available at SNC-operated nuclear emergency supplies and equipment.

power plants. Designated site or department procedures identify the equipment in the various Appendix 4 was deleted . The specific emergency kits. Details as to kit locations are found in equ ipment and supplies is a procedural level the plant-specific procedu res. step. Elimination allows more flexibility in maintaining current equipment and supporting the needs of the ERO. E9- 11 8 to NL-16-0 169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 I. ACCIDENT ASSESSMENT SECTION I: ACCIDENT ASSESSMENT The wording was standardized and relocated This section describes the methods, 1.1 Systems and Parameters Monitored to the SNC Standard Emergency Plan. systems, and equipment available for SNC-operated nuclear power plants have a assessing and monitoring actual or comprehensive set of plant system and effluent monitors , potential offsite consequences of a as required by the plants' Final Safety Analysis Report. radiological emergency. Sites have identified values characteristic of off-normal values and accidents, and identified the plant parameter values that correspond to the example initiating conditions in the Nuclear Energy Institute (NEI) 99-01 and 07-01 Emergency Action Levels (EALs). These are described in Section D of this plan , and detailed in the site-specific Annexes. Initial assessment actions are the EP 8.2.1.1 TSC Emergency Director (ED) The commitment wording was standardized responsibility of the Operations SOS The TSC ED has the authority and responsibil ity to and relocated to the SNC Standard and/or the SS, using available shift immediately initiate any emergency actions. Once Emergency Plan . personnel. transfer of Command and Control has been completed, I the TSC ED assumes the non-delegable duties of event Classification, on-site Emergency Exposure Authorization , and on-site protective actions. EP 8.3.1.1 EOF 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. E9-119 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Emergency response procedures include EP D.1.1.1 SNC has and maintains the capability to The commitment wording was standardized methods for quickly assessing plant assess, classify, and declare an emergency condition and relocated to the SNC Standard system and effluent parameter values and within 15 minutes after the availability of indications to Emergency Plan. classifying the emergency condition. plant operators that an EAL threshold has been met or Additional information relative to plant exceeded . Upon identification of the appropriate instrumentation is provided in Section H. emergency classification level , the emergency condition will be promptly declared. Radiological Monitors EP H.5.2.1 Radiation Monitoring System (RMS) The commitment wording was standardized In-plant radiological measurements Radiation monitoring instruments are located at and relocated to the SNC Standard provide information helpful in assessing selected areas within the plant to detect, measure, and Emergency Plan . emergency conditions. Systems are record radiation levels. The monitors are comprised of installed to permit reactor coolant and area, airborne, and air particulate monitors. drywell atmosphere sampling under

Area monitors respond to gamma radiation .

emergency conditions. Post-accident

Airborne monitors detect and measure radioactive sampling capability and the RMS are gaseous effluent concentrations.

described in Section H of this Plan .

Air Particulate detectors capture and measure airborne particulate Emergency response procedures provide methods for determining relationships between monitor readings and releases , material available for release and extent of core damage.

The drywell wide-range radiation monitor EP H.5.2.1: Radiation monitoring instruments are located The commitment wording was standardized and the drywell hydrogen monitor are at selected areas within each plant to detect, measure, and relocated to the SNC Standard used to provide an early indication of the and record radiation levels. The monitors are comprised Emergency Plan. quantity of radioactivity available for of area, airborne, and air particulate monitors. release from the containment.

Area monitors respond to gamma radiation .
Airborne monitors detect and measure radioactive gaseous effluent concentrations.
Air Particulate detectors capture and measure airborne particulate E9-121

Enclosu re 9 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 To facilitate direction of the teams and EP 1.7: Samples are taken at predetermined locations The commitment wordi ng was standardized reporting of res ults, both the field as well as those locations specified during and after a and relocated to the SNC Standard monitoring teams and the communicator release . Emergency Plan . use identical maps showing the sampling locations. The cartridge and air particulate filter are EP 1.9: Field monitoring equipment has the capability to The commitment wording was standardized returned to the laboratory at the plant site detect and measure airborne radioiodine in the and relocated to the SNC Standard for isotopic analysis if the fie ld analysis presence of noble gases that has the capability to Emergency Plan . read ing is 100 cpm above background on detect and measure radioiodine concentrations in air in an HP-210 probe or equivalent. The the plume exposure EPZ as low as 10-7 uCi/cc cartridges can be counted in the field (microcuries per cubic centimeter) under field without interference from noble gas conditions. Interference from the presence of noble gas (background count rate below 300 cpm and background radiation shall not decrease the stated on an HP-210 probe or equivalent) . minimum detectable activity. i;:ielEI FflOAitoFiA§ eti~ipR'leAt l=las tl=le eapability to Eleteet aAEI Ffleas~rn aiFborne FaElioioEliAe iA tl=le prnseAee of Roble §ases. The cartridge and air particulate filter are EP H.10 Collection Point for Field Samples The commitment wording was standardized returned to the laboratory at the plant site SNC-operated nuclear power plants have designated a and relocated to the SNC Standard for isotopic analysis if the field analysis point as the location for receipt and analysis of field Emergency Plan. reading is 100 cpm above background on monitoring team environmental samples. Sampling and an HP-210 probe or equivalent. analysis equipment is available for quantitative activity determination of marine and air samples, and qualitative activity determination of terrestrial samples. In addition to direct monitoring and air EP 1.7: SNC-operated nuclear power plants have the The commitment wordi ng was standard ized sampling , the assessment program may abil ity to take offsite air sampl es and to directly measure and relocated to the SNC Standard utilize the environmental sampling gamma dose rates from a radioactive material release. Emergency Plan. program in which environmental samples The capability to take offsite soil , water, and vegetation (water, air, soil, and vegetation) are samples is provided by a minim um of two (2) Field collected and analyzed in the laboratory Monitoring Teams (FMTs). for detailed radionuclide data. E9-126 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Annex 4.1.1 Notification Process (SEP E.2.2.1)

1. Alerting State and local warning points are staffed 24 hours per day. State and cou nty authorities to The commitment wording was standardized The means used by HNP to alert local be notified within 15 minutes of the declaration of an emergency condition are: and relocated to the Site Annex.

and State agencies and the means used . State of Georgia: Georgia Emergency Management Agency (G EMA) by State and local agencies to alert the .. Georgia count~ authorities: Appling County warning point. public are described in Section E and Appendix 3 of this Plan .

                                            .. Jeff Davis County warni ng point.

Tattnall County warning point. Toombs County warning point. Annex 4.2 Alert and Notification System (ANS) (SEP E.2.5) Within the Plume Exposure Emergency Planning Zone (EPZ), there exist provisions for alerting and providing notification to the publi c. The state and/or local authorities are responsible for activation of this system. The FEMA approved Hatch ANS consists of a primary ANS and a backup system should there be a failure of the primary system. Primary - Sirens and Emergency Alert System (EAS) stations System Backup - Reverse calling system The pri mary ANS has two communications pathways. The first pathway is through the primary agency via the UHF or VHF radio. Should the primary agency fail to activate the system, the secondary pathway will be utilized by the secondary agency. The secondary pathway functions in the same manner as the primary pathway utilizing a separate activation console that is physically located in separate location. If neither agency can activate the system, the backup system will be utilized to notify the residents of the 10 mile EPZ. The hierarchy for s1 stem activation is provided below: Agency Radio Systems I Primary Agency UHF VHF Primary Sirens & EAS Secondary Agency UHF VHR Backup Each County EMA Calling System I Georgia I Primary Agency State of Georgia (GEMA) Secondary Agency Appling County l"*ima<y aleFliA§ is assemplisRee tiy "se el a slfeA system. EasR sirnA eperates eA 9atteFy pe"'eF u*itR 9atteFy sRaf§8 maiAtaiAeEJ 9y aA iA"8Fl8f tRal rnseiues pe*ueF lf8m IRS lesal eleslFisal §FIS eF lrnm a selaF paAel {s). SiFeA system asli,.alieA, lest, aAEJ meAiteFiA§ sapa9ilily aFe pFe,.iEJeEJ leF Appl iA§ Ge"Aly, GeeF§ia aAEJ leF !Re slate el GeeF§ia. I E9-140 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 The mechanism for making these EP J.5 Offsite Protective Action Recommendations The commitment wording was standardized recommendations is described in Section (PARs) and relocated to the SNC Standard E of this Plan . These recommendations Plant conditions, projected dose and dose rates, field Emergency Plan . are based upon the Environmental monitoring data and evacuation time estimates are Protection Agency (EPA) Protective evaluated to develop PARs for preventing or minimizing Action Guidelines and NUREG-0654 exposure to the public. PARs are provided to the offsite Supplement 3 Rev 1. NMP-EP-11 2, agencies responsible for implementing protective Protective Action Recommendation, actions for the public within the 10-mile EPZ. The provides detailed guidance on PAR Emergency Director will approve PARs. The PAR determinations. decision making flowcharts are site-specific in nature, and are provided in the site-specific implementing procedures. SNC-operated plants have the capability to provide state and local agencies a PAR for beyond the 10-mile EPZ. Plant conditions , projected dose and dose rates and field monitoring data are communicated to offsite agencies responsible for dose assessment/PARs to assist them in developing parallel assessments There are various types of protective actions that can be recommended to the state and counties. They may include the following:

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

E9-142 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Current PARs were developed in EP J.5 Offsite Protective Action Recommendations The commitment wording was standardized coordination with Offsite Response (PARs) and relocated to the SNC Standard Organizations . Table J-3 provides details Plant conditions, projected dose and dose rates , field Emergency Plan . regarding the determination of initial monitoring data and evacuation time estimates are protective actions recommendations for evaluated to develop PARs for preventing or minimizing the public. exposure to the public. PARs are provided to the offsite agencies responsible for implementing protective actions for the public within the 10-mile EPZ. The Emergency Director will approve PARs. The PAR decision making flowcharts are site-specific in nature , and are provided in the site-specific implementing procedures. SNC-operated plants have the capabil ity to provide state and local agencies a PAR for beyond the 10-mile EPZ. Plant conditions, projected dose and dose rates and field monitoring data are communicated to offsite agencies responsible for dose assessment/PARs to assist them in developing parallel assessments There are various types of protective actions that can be recommended to the state and counties. They may include the following :

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

Table J-4 provides details for determ ining No equivalent Plan/Annex Table. SNC Standard Emergency Plan Section J.5 followup PARs. maintains the commitment to provide PARs for the population . Specific designation of followup PARs is part of the general requirement. A separate table is no longer necessary. E9-143 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Plant conditions, plume dose projection EP J.5 Offsite Protective Action Recommendations The commitment wording was standardized calculations, and offsite monitoring results (PARs) and relocated to the SNC Standard should be evaluated when making Plant conditions , projected dose and dose rates, field Emergency Plan. protective action recommendations. monitoring data and evacuation time estimates are evaluated to develop PARs for preventing or minimizing exposure to the public. PARs are provided to the offsite agencies responsible for implementing protective actions for the public within the 10-mile EPZ. The Emergency Director will approve PARs. The PAR decision making flowcharts are site-specific in nature, and are provided in the site-specific implementing procedures. SNC-operated plants have the capability to provide state and local agencies a PAR for beyond the 10-mile EPZ. Plant cond itions, projected dose and dose rates and field monitoring data are communicated to offsite agencies responsible for dose assessment/PARs to assist them in developing parallel assessments There are various types of protective actions that can be recommended to the state and counties. They may include the following :

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

E9-144 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 If significant discrepancies exist between EP J.5 Offsite Protective Action Recommendations The commitment wording was standardized field monitoring results and plume dose (PARs) and relocated to the SNC Standard rate projection calculations , an evaluation Plant conditions, projected dose and dose rates, field Emergency Plan. should be made. The most conservative monitoring data and evacuation time estimates are valid dose projections based on evaluated to develop PARs for preventing or minimizing evaluation results should be used in the exposure to the public. PARs are provided to the offsite determination of protective action agencies responsible for implementing protective recommendations. actions for the public within the 10-mile EPZ. The Emergency Director will approve PARs . The PAR decision making flowcharts are site-specific in nature , and are provided in the site-specific implementing procedures. SNC-operated plants have the capability to provide state and local agencies a PAR for beyond the 10-mile EPZ. Plant conditions , projected dose and dose rates and field monitoring data are communicated to offsite agencies responsible for dose assessment/PARs to assist them in developing parallel assessments There are various types of protective actions that can be recommended to the state and counties. They may include the following :

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

E9-145 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Evacuation EP J.5 Offsite Protective Action Recommendations The commitment wording was standardized Determining the benefit of evacuation (PARs) and relocated to the SNC Standard must take into account the time needed to Plant conditions, projected dose and dose rates , field Emergency Plan. complete the evacuation. monitoring data and evacuation time estimates are evaluated to develop PARs for preventing or minimizing exposure to the public. PARs are provided to the offsite agencies responsible for implementing protective actions for the public within the 10-mile EPZ. The Emergency Director will approve PARs . The PAR decision making flowcharts are site-specific in nature, and are provided in the site-specific implementing procedures. SNC-operated plants have the capability to provide state and local agencies a PAR for beyond the 10-mile EPZ. Plant conditions , projected dose and dose rates and field monitoring data are communicated to offsite agencies responsible for dose assessment/PARs to assist them in developing parallel assessments. There are various types of protective actions that can be recommended to the state and counties. They may include the following:

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

Appendix 5 includes further detail Annex Appendix A The commitment wording was standardized regarding how these estimates were and relocated to the Site Annex. developed and presents information on evacuation routes , evacuation areas, relocation centers, shelter areas , and the population distribution by evacuation areas and zones . E9-146 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 N. EXERCISES AND DRILLS SECTION N: EXERCISES AND DRILLS The wording was standardized in the SNC HNP maintains an emergency drill and EP N.1 Exercises Standard Emergency Plan . exercise program in accordance with 10 SNC-operated nuclear power plants will conduct a biennial CFR 50 Appendix E.IV.F to test and exercise and additional periodic drills. An exercise is an event that tests integrated capability, and a major portion of the basic evaluate the adequacy of emergency elements of emergency preparedness plans and organizations. facilities , equipment, procedures, Drills and exercises shall: communication links, actions of

Test the adequacy of timing and content of emergency response personnel, and implementing procedures and methods.

coordination between the HNP and the

Test emergency equipment and communications offsite emergency response networks.

organizations. The exercise program for

Test the public notification system.

HNP consists of an 8-year cycle that

Ensure emergency organization personnel are familiar incorporates the use of both Exercises with their duties.

and Drills . SNC-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 NRG. Exercises may include mobilization of state and local personnel and resources, and are intended to verify their capability to respond to an accident. Joint exercises shall be conducted on a frequency described in NRC/FEMA guidance. A formal critique shall be conducted following the drill or exercise to evaluate the ability of organizations to respond as required in the SNC Standard Emergency Plan and site specific Emergency Plan Implementing Procedures. Critique items will be entered into the SNC corrective action program as appropriate. Remedial exercises will be required if the emergency plan is not satisfactorily tested during the Biennial Exercise and it is determined that reasonable assurance that adequate protective measures ai:ecan not be taken in the event of a radiological emergency or the ERO has not maintained key skills specific to emergency response. E9-175 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 The exercise program for HNP consists of an EP N.1.1 Biennial Exercises The commitment wording was standardized 8-year cycle that incorporates the following Federally prescribed Biennial Exercises are conducted at and relocated to the SNC Standard features: SNC-operated nuclear power plants. Exercises involving Emergency Plan .

1. A full participation exercise which tests as offsite agency participation , required under 10 CFR 50 much of the Plant Hatch, State, and local Appendix E, are conducted at SNC operated nuclear plants emergency plans as is reasonably achievable based on Federal Emergency Management Agency (FEMA) without mandatory public participation will be guidance and the respective state and local emergency conducted on a biennial basis and evaluated response plans.

by NRC and FEMA. EP N.3 Scenarios

2. Biennial exercise scenarios will be During the exercise planning cycle described in Section submitted to the NRC under§ 50.4 at least 60 N.1.54, SNC sites vary the content of exercise scenarios to days before use in the biennial exercise. provide ERO members the opportunity to demonstrate

3. Each biennial exercise scenario will provide proficiency in key skills necessary to respond to several the opportunity for the ERO to perform their specific scenario elements including:

key skills as applicable to their emergency

Hostile Action directed at the plant site.

response duties in the CR , TSC , OSC, EOF,

No radiological release or unplanned release that does and Joint Information Center to implement the not require public protective actions.

EP principal functional areas.

An initial classification of or rapid escalation to a Site

4. Biennial evaluated e~ercises will be varied Area Emergency or General Emergency.

such that the following scenario elements are

Implementation of strategies, procedures , and guidance demonstrated over the course of an 8-year developed in 50.54(hh) (i .e., potential aircraft threat, exercise cycle: explosion or large fire) .
Hostile action directed at the plant site.
Integration of offsite resources with onsite response.
No radiological release or an unplanned
A drill initiated between the hours of 6 p.m. and 4 a.m.

minimal radiological release that does not

Drills using essentially 100 percent of Initiating require public protective actions. Conditions in the 8-year cycle.
Initial classification of or rapid escalation to a EP N.1.3 Ingestion Exposure Pathway Exercise Site Area Emergency or General Emergency. EP N.3 SNC sites submit Biennial Exercise scenarios under
Implementation of strategies, procedures, 10 CFR 50.4 for N RC review 60 days prior to the exercise.

and guidance developed under 10 CFR 50.54(hh)(2).

Integration of offsite resources with onsite response.

5. An ingestion pathway exercise will be conducted on a frequency to ensure the State of Georgia has the opportunity to participate in an ingestion pathway exercise at least once every exercise cycle.

E9-177 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36

1. Periodic Emergency Drills EP N.3 Scenarios The commitment wording was standardized During each exercise cycle periodic drills will During the exercise planning cycle described in Section and relocated to the SNC Standard be conducted to ensure the ERO teams (not necessarily each individual} are provided the N.1 .54 , SNC sites vary the content of exercise Emergency Plan. I scenarios to provide ERO members the opportunity to opportunity to develop and maintain key demonstrate proficiency in key skills necessary to emergency response skills within the scope of their duties. The ERO (not necessarily each respond to several specific scenario elements including:

ERO team) will be provided the opportunity to

Hostile Action directed at the plant site.

demonstrate key skills in response to the

No radiological release or unplanned release that following scenario elements in drills or does not require public protective actions.

exercises.

All functions in each ERF (e.g. , all ERFs that
An initial classification of or rapid escalation to a Site Area Emergency or General Emergency.

are responsible for dose assessment perform those duties in response to a radiological

Implementation of strategies, procedures , and release) . guidance developed in 50.54{hh) (i.e. , potential
Use of alternative facilities to stage the ERO aircraft threat, explosion or large fire).

for rapid activation during hostile action.

Integration of offsite resources with onsite
Real-time staffing of facilities during off-hours response .

(i.e., 6:00 p.m. to 4:00 a.m.).

A drill initiated between the hours of 6 p.m. and 4
Providing medical care for injured, a.m .

contaminated personnel (every 2 years) .

Response to essentially 100 percent of
Drills using essentially 100 percent of Initiating initiating conditions identified in the site Conditions in the 8-year cycle.

emergency plan implementing procedure for Drills and exercise scenarios will be varied from year to classification of emergencies. year to test major components of the plans and

Response to actual industry event preparedness organizations.

sequences appropriate for the nuclear plant technology (e.g., BWR).

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.

E9-180 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Evaluations and Corrective Actions EP N.4 Exercise Evaluation and Critique The commitment wording was standardized All drills and exercises , with the exception A formal critique will be performed for exercises, drills, and relocated to the SNC Standard of fire drills, are evaluated via the and training tabletops to develop, maintain , or Emergency Plan following steps: demonstrate key skills in order to identify weak or

1. The exercise or drill deficient areas that need correction.

controllers/evaluators assemble the A critique shall be conducted at the conclusion of the players at the conclusion of activities for a exercise, to evaluate the organization 's ability to critique. Players are encouraged to respond as called for in the SNC Standard Emergency identify areas where improvements are Plan. Qualified personnel will observe and perform a required. The exercise or drill critique of exercises and drills. Provisions will be made controllers/evaluators also present their for federal , state, and local observers, as well as SNC observations to the players. Each personnel, to observe and critique required exercises. controller/evaluator submits his/her Biennially, representatives from the NRC observe and comments regarding the drill/exercise to evaluate the licensee's ability to conduct an adequate the Exercise Manager. Following the self-critical critique. For partial and full offsite exercise, an overall critique is presented participation exercises, the NRC and Federal to key players and the controller Emergency Management Agency (FEMA) , will observe, organization. evaluate, and critique.

2. A report, summarizing the drill/exercise Drill and exercise performance objectives will be and identifying items for improvement evaluated against measurable demonstration criteria.

and/or corrective actions , is provided to As soon as possible following the conclusion of the drill plant management by the EPS. These or exercise, a critique is conducted to evaluate the items will be tracked in accordance with ability of the Emergency Response Organization (ERO) the plant's corrective action program. to implement the emergency plan and procedures and a formal evaluation will result from the critique. A written critique report is prepared by the Emergency Preparedness group following a drill or exercise involving the evaluation of designated objectives or following the final simulator set with ERO participation. The report will evaluate the ability of the ERO to respond to a simulated emergency situation . The report will also contain corrective actions and recommendations . E9-189 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 In addition to the internal critique and EP N.4 Exercise Evaluation and Critique The commitment wording was standardized evaluation, Federal observers observe , A formal critique will be performed for exercises , drills , and relocated to the SNC Standard evaluate, and critique the biennial and training tabletops to develop, maintain, or Emergency Plan exercise. Corrective actions resulting from demonstrate key skills in order to identify weak or this critique will be tracked in accordance deficient areas that need correction . with the plant's corrective action program . A critique shall be conducted at the conclusion of the exercise, to evaluate the organization's ability to respond as called for in the SNC Standard Emergency Plan. Qualified personnel will observe and perform a critique of exercises and drills. Provisions will be made for federal , state, and local observers, as well as SNC personnel , to observe and critique required exercises . Biennially, representatives from the NRC observe and evaluate the licensee's ability to conduct an adequate self-critical critique. For partial and full offsite participation exercises, the NRC and Federal Emergency Management Agency (FEMA), will observe , evaluate, and critique. Drill and exercise performance objectives will be evaluated against measurable demonstration criteria. As soon as possible following the conclus ion of the drill or exercise, a critique is conducted to evaluate the ability of the Emergency Response Organization (ERO) to implement the emergency plan and procedures and a formal evaluation will result from the critique. A written critique report is prepared by the Emergency Preparedness group following a drill or exercise involving the evaluation of designated objectives or following the final simulator set with ERO participation . The report will evaluate the ability of the ERO to respond to a simulated emergency situation. The report will also contain corrective actions and recommendations. E9-190 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 The specialized radiological emergency EP 0.1 Training The wording was standardized and relocated response training is outlined herein ; To achieve and maintain an acceptable level of to the SNC Standard Emergency Plan. however, full details are provided in the emergency preparedness, training will be conducted for HNP procedures and appropriate train ing members of the Emergency Response Organization lesson plans. (ERO) and those offsite organizations that may be called on to provide assistance in the event of an emergency. Training will be evaluated in accordance with the requirements of Systematic Approach to Training practices to ensure effectiveness and in order to identify weak or deficient areas that need correction. The ERO Training Program ensures the training, qualification, and requalification of individuals who may be called on for assistance during an emergency. Specific emergency response task training , prepared for response positions, is described in lesson plans and study guides. The lesson plans, study guides , and written tests are contained in the ERO Training Program . Responsibilities for implementing the training program are contained in plant procedures . Offsite training is provided to support organizations that may be called on to provide assistance in the event of an emergency. Training for EOF emergency responders EP 0.1 Training With the incorporation of the EOF into the base is outlined in Appendix 7. To achieve and maintain an acceptable level of Plan as outlined in the SNC Standard emergency preparedness , training will be conducted for Emergency Plan, Section 0 of the SNC members of the Emergency Response Organization Standard Emergency Plan includes the EOF (ERO) and those offsite organizations that may be training descriptions. called on to provide assistance in the event of an emergency. See the Justification Matrix for Appendix 7 for Training will be evaluated in accordance with the specific comparison. requirements of Systematic Approach to Training practices to ensure effectiveness and in order to identify weak or deficient areas that need correction. E9-192 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Initial Emergency Response Training EP 0.1 Training The commitment wording was standardized Various personnel receive initial To achieve and maintain an acceptable level of and relocated to the SNC Standard emergency response training in the emergency preparedness, training will be conducted for Emergency Plan. subject areas identified in HNP members of the Emergency Response Organization procedures according to the respective (ERO) and those offsite organizations that may be emergency response position to which called on to provide assistance in the event of an they will be assigned. It should be noted emergency. that these subject areas do not Training will be evaluated in accordance with the necessarily represent specific course requirements of Systematic Approach to Training titles, since several individual courses practices to ensure effectiveness and in order to identify may be used to implement the training in weak or deficient areas that need correction . each area. Also, both the content and the depth of training may be varied slightly, The ERO Training Program ensures the training , depending upon the particular audience, qualification , and requalification of individuals who may to tailor the presentation to the specific be called on for assistance during an emergency. needs of the group. Initial emergency Specific emergency response task training, prepared for response training is offered on an as- response positions , is described in lesson plans and needed basis to fill various emergency study guides. The lesson plans, study guides, and response positions. 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. E9-193 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 The training is conducted in accordance EP 0.1 Training The comm itment wording was standardized with lesson plans. To achieve and maintain an acceptable level of and relocated to the SNC Standard emergency preparedness, training will be conducted for Emergency Plan. members of the Emergency Response Organization (ERO) and those offsite organizations that may be called on to provide assistance in the event of an emergency. Training will be evaluated in accordance with the requirements of Systematic Approach to Training practices to ensure effectiveness and in order to identify weak or deficient areas that need correction. The ERO Training Program ensures the training , qualification , and requalification of individuals who may be called on for assistance during an emergency. Specific emergency response task training , prepared for response positions, is described in lesson plans and study guides . The lesson plans, study guides, and written tests are contained in the ERO Train ing 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. E9-194 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 A written examination will be administered EP 0.1 Training The comm itment wording was standardized at the conclusion of a lesson, as To achieve and maintain an acceptable level of and relocated to the SNC Standard appropriate. emergency preparedness, training will be conducted for Emergency Plan. members of the Emergency Response Organization (ERO) and those offsite organizations that may be called on to provide assistance in the event of an emergency. Training will be evaluated in accordance with the requirements of Systematic Approach to Training practices to ensure effectiveness and in order to identify weak or deficient areas that need correction. The ERO Training Program ensures the training , qualification , and requalification of individuals who may be called on for assistance during an emergency. Specific emergency response task training , prepared for response positions, is described in lesson plans and study guides. The lesson plans, study guides , and written tests are contained in the ERO Training Program . Responsibilities for implementing the training program are contained in plant procedures. Offsite training is provided to support organizations that may be called on to provide assistance in the event of an emergency. E9-196 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Annex 4.2 With in the Plume Exposure Emergency Plann ing Zone (EPZ), there exist A. INTRODUCTION provisions for alerting and providing notification to the public. Th e state and/or local The comm itment wording was standardized Prompt alerting and notification of the authorities are re sponsible for activation of th is system. and relocated to the Site Annex. The FEMA approved Hatch ANS consists of a primary ANS and a backup system should public within the plume exposu re pathway there be a failure of the primary system. Primary - Sirens and Emergency Alert System (EAS) stations EPZ are th e obligation of State and local System Backup - Reverse calling system government or other responsible The primary ANS has two communications pathways. The first pathway is through the primary agency via the UHF or VHF radio. Should the primary agency fail to activate the authority. The responsibi lity that means system, the secondary pathway wi ll be utilized by the secondary agency. The secondary pathway functions in the same manner as the primary pathway utilizing a separate activation exist for th is purpose rests with the console that is physically located in separate location. If neither agency can activate the licensee. system, the backup system will be utilized to notify the residents of the 10 mile EPZ. The hierarchy for s1 stem activation is orovided below: Agency Radio Systems Primary Agency UHF VHF Primary Sirens & EAS Secondary Agency UHF VHR Backup Each County EMA Calling System Georgia Primary Agency State of Georgia (GEMA) Secondary Agen cy Appling County

                                               ~FimaFY aleFtiA§ is assemplisRes ey "se el a si*eA system. easR s1FeA epe*ates eA ealte*y P8"'8f U<ilR ealteFy sRaF§B ma1AlaiAeS ey aA iA"8Ft8F tRal F8691"9S PB'"'" lrnm IRS lesal eleslfisal §FIS eF lrnm a selaF pa*el(s) . Si*a* system as11.,a11aA , tasl, aAs meA1leFiA§ sapaeihly a*a p*a"1ses le* AppliA§ Ge"Aly, GeeF§1a aAs leF tRe stale el GeeF§1a.                                                                        I An overview of these means is given in         Annex 4.2 A full description of the Hatch ANS design is                                              The comm itment wording was standardized this Appendix. A full Al ert and Notification   provided in the FEMA approved ANS Design Report                                                     and relocated to the Site Annex.

System (ANS) description is provided in located in the SNC document management system . the FEMA approved Alert and Notification System Design Report (ANS-HNP-001 ) located in the SNC document management system . E9-210 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Annex 4.2 Initial notification of the public will occur in The FEMA approved Hatch ANS consists of a primary ANS and a backup system should The commitment wording was standardized a manner consiste nt with assuring the public health and safety. The design there be a failure of the primary system. Primary - Sirens and Emergency Alert System (EAS) stations System Backup - Reverse call ing system and relocated to the Site Annex. The primary ANS has two communications pathways. The first pathway is through the objective for the system is to meet the primary agency via the UHF or VHF radio . Should the primary agency fail to activate the acceptance criteria provided in a system, the secondary pathway will be utilized by the secondary agency. The secondary pathway functions in the same manner as the primary pathway utilizing a separate activation subsequent section of this Appendix. The console that Is physically located in separate location . If neither agency can activate the system. the backup system will be utilized to notify the residents of the 10 mile EPZ. design objective does not constitute a The hierarchy for S\ stem activation is provided below: guarantee that prompt notification can be Agency Radio Systems provided for everyone with 100-percent assurance or that the system when tested Primary Agency UHF under actual field conditions will meet the design objective in all cases . VHF Primary Sirens & EAS Secondary Agency UHF VHR Backup Each County EMA Calling System Georgia Primary Agency State of Georgia (GEMA) Secondary Agency Appling County PFlma*y ale~1A111s as*emt>lisRea ey use el a s"eA system. l';asR s"e" et>erates eA eatteFy

                                                 !'B"'e' '"ltR eatteFy GRa*!je maiAtaiAe8 ey aA IA"eAe* !Rat *0Ge1ues !'B"'e' l*em IR0 laGal elestF1sal !1"8 eF foam a sela* t>aAel{s) . SiFeA system astiuat1eA, test, aAa meAiteFiR!I Gat>allility a*e !9"ieee le* ~t>t>hAg CeuAty, Gee*11ia aAa le* tRe state el Gee*111a.

Special alerting is accomplished th roug h the use of a calling system. Special alerting is initiated in the event of a failure of the system to activate multiple sirens resulting in a loss of cove rage in any area. Special alerting may be initiated for a predefined area. a user specified area, user defined groups, or the entire Emergency Planning Zone (EPZ) . The calling system serves as a complete backup to the ANS. The system provides both alerting and notification of EPZ residents independent of the alerting 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 for Appling County, Georgia, and for the state of Georgia. E9-211 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Annex 4.2 Within the Plume Exposure Emergency Planning Zone (EPZ), there exist The ED at HNP is responsible for provisions for alerting and providing notification to th e public. The state and/or local The comm itment wording was standard ized notifying appropriate State and local authorities are responsible for activation of this system. and relocated to the Site Annex. The FEMA approved Hatch ANS consists of a primary ANS and a backup system should response organizations, as well as plant there be a failure of the primary system. Primary - Sirens and Emergency Alert System (EAS) stations emergency personnel , in the event of an System Backup - Reverse calling system emergency. The primary ANS has two communications pathways. The first pathway is through the primary agency via the UHF or VHF radio . Should the primary agency fail to activate the system, the secondary pathway will be utilized by the secondary agency. The secondary pathway functions in the same manner as the primary pathway utilizing a separate activation console that is physically located in separate location. If neither agency can activate the system, the backup system will be utilized to notify the residents of the 10 mile EPZ. The hierarchv for s stem activation is provided below: Agency Radio Systems I Primary Agency UHF VHF Primary Sirens & EAS Secondary Agency UHF VHR Backup Each County EMA Calling System Georgia Primary Agency State of Georgia (GEMA) I Secondary Agency Appling County I PFima'Y alMiA§ is aGGem~hsReEf ey "se el a SIFeA system. !OaGR SIFeA e~eFales eA 8alle>y

                                         ~e u *eF u*i!R ealleFy 6RaFge maiAlaiAeEf ey aA iA ..eFleF IRal Fe6e1ues ~e " '0F IFSm !Re leGal eleGIFIGal §FIB eF !Fem a selaF ~aAel{s) . iliFeA system aGt1ua11eA, test, aAe meA1leF1A§ Ga~aeihty a Fe ~Fe u 1Efe8 le* o ~~llA§ Ge"Al y, GeeFg1a aAe le* !Re stale el GeeFg1a.                                                                  I The ICs for each emergency class are      Appendix B Hatch Annex                                                                              The comm itment wording was standard ized delineated in Section D in the main body                                                                                                      and relocated to the Site Annex.

of this Emergency Plan . E9-212 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Annex 4.2 Within the Plume Exposure Emergency Planning Zone (EPZ) , there exist The capability for 24-hour-per-day alerting provisions for alerting and providing notificati on to the public. The state and/or local The commitment wording was standardized and notification of offsite response authorities are responsible for activation of this system. and relocated to the Site Annex. The FEMA approved Hatch ANS consists of a primary ANS and a backup system should organizations and plant emergency personnel is described in Section E. .. there be a failure of the primary system. Primary - Sirens and Emergency Alert System (EAS) stations System Backup - Reverse calling system The primary ANS has two communications pathways. The first pathway is through the primary agency via the UHF or VHF radio. Should the primary agency fail to activate the system, the secondary pathway will be utilized by the secondary agency. The secondary pathway functions in the same manner as the primary pathway utilizing a separate activation console that is physically located in separate location. If neither agency can activate the system, the backup system will be utilized to notify the residents of the 1o mile EPZ. The hierarchv for S\ stem activation is orovided below: Agency Rad io Systems I Primary Agency UHF VHF Primary Sirens & EAS

   .                                                                  Secondary Agency                UHF VHR Backup               Each County EMA                                  Calling System Georgia Primary Agency                              State of Georgia (G EMA)

Secondary Agency Appling County

                                             -A full description of the Hatch ANS design is provi ded in the FEMA approved ANS Design Report located in the SNC document management system.

In the event of a declared emergency at Annex 4.2 Primary alerting is accomplished by use of a The commitment wording was standardized HNP, initial alerting of the public would be siren system. Each siren operates on battery power with and relocated to the Site Annex. by the siren system and EAS. 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 capability are provided for Appling County, Georgia and for the state of Georgia. E9-213 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 B. CONCEPT OF OPERATIONS EP E.2.5.1 Concept of Operations The commitment wording was standardized The ANS co nsists of a primary ANS and a In the event of a serious emergency at any SNC site, the and relocated to the SNC Standard backup system should there be a failure primary means for alerting the public will be by the FEMA Emergency Plan. of the primary system: approved Alert and Notification System (ANS) referenced in the site specific Annex. Each site has a FEMA approved

Primary - Sirens and Emergency Alert backup notification system in the event of a loss of the primary System (EAS) stations alert and notification system. State and local plans maintain
System Backup - Reverse calling additional processes to alert the public using emergency system vehicles, automated dialing systems, public address systems, etc. Details of the backup methods can be found in the site specific Annex.

The capability exists to promptly alert and notify the general public within the Plume Exposure Pathway. The Alert and Notification Systems (ANS) for each station includes an acoustic alerting signal from sirens and notification of the public by the Emergency Alert System (EAS). Station specific information regarding the ANS is contained in each station's ANS Design Certification Package. The acoustical siren system design meets FEMA standards and requirements and has been approved to alert populations of an event. Each county controls the activation of the sirens within its boundaries (except for Henry County which relies on Houston County to activate their sirens). Activation of the ANS sirens by the local authorities will alert the public to turn to a local EAS station for detailed information on the emergency situation. The siren system is tested in accordance with the station 's FEMA approved ANS design certification package. SNC provides for the repair and preventive maintenance of the EPZ sirens. Procedure instructions have developed to respond to any spurious activation of the ANS sirens. E9-215 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 The concept of operation for the system is EP E.2.5.1 Concept of Operations The commitment wording was standardized In the event of a serious emergency at any SNC site, the primary as follows: means for alerting the public will be by the FEMA approved Alert and and relocated to the SNC Standard The Primary ANS has two communication Notification System (ANS) referenced in the site specific Annex. Each Emergency Plan. pathways. The first pathway is through site has a FEMA approved backup notification system in the event of a the primary agency (on site) via the UHF loss of the primary alert and notification system . In the event of a serious emergency at any SNC site, the primary or VHF radio. means for alerting the public will be by the FEMA approved Alert and Notification System (ANS) referenced in the site specific Annex. Each site has a FEMA approved backup notification system in the event of a loss of the primary alert and notification system . State and local plans maintain additional processes to alert the public using emergency vehicles, automated dialing systems, public address systems, etc. Details of the backup methods can be found in the site specific Annex. The capability exists to promptly alert and notify the general public within the Plume Exposure Pathway. The Alert and Notification Systems (ANS) for each station includes an acoustic alerting signal from sirens and notification of the public by the Emergency Alert System (EAS). Station specific information regarding the ANS is contained in each station's ANS Design Certification Package. The acoustical siren system design meets FEMA standards and requirements and has been approved to alert populations of an event. Each county controls the activation of the sirens within its boundaries (except for Henry County which relies on Houston County to activate their sirens). Activation of the ANS sirens by the local authorities will alert the public to turn to a local EAS station for detailed information on the emergency situation. The siren system is tested in accordance with the station's FEMA approved ANS design certification package. SNC provides for the repair and preventive maintenance of the EPZ sirens. Procedure instructions have developed to respond to any spurious activation of the ANS sirens. E9-216 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Annex 4.2 Should the primary agency fail to activate The FEMA approved Hatch ANS consists of a primary ANS and a backup system should Th e commitment wording was standardi zed the system, the secondary pathway will be utilized by the secondary agency (off there be a failure of the primary system. Primary - Sirens and Emergency Alert System (EAS) stations System Backup - Reverse calling system and relocated to th e Site Ann ex. The primary ANS has two communications pathways. The first pathway is through the site in Toombs County). primary agency via the UHF or VHF radio . Should lhe primary agency fail to activate the system, the secondary pathway will be utilized by the secondary agency. The secondary pathway functions in the same manner as the primary pathway utilizing a separate activation console that is physically located in separate location. If neither agency can activate the system, the backup system will be utilized to notify the residents of the 10 mile EPZ. The hierarchy for s1 stem activation is provided below: Agency Radio Systems Primary Agency UHF VHF Primary Sirens & EAS Secondary Agency UHF VHR I Backup Each County EMA Calling System I Georgia Primary Agency State of Georgia (GEMA) I Secondary Agency Appling County I

                                           ~*ima*y aleFtiRg is assemplisReEl lly "se el a siFeR system. t;asR SlfeR epe*ates eR llatte'Y pe,.*e* itR llatle<y GRa*ge maiRtaiReEl lly aR iRueFte* !Rat Fasei.,es pe,.*e* lrnm !Re lesal eleslFisal g*iEl eF frnm a selaF paRel {s). SiFaR system asti><atieR, test, aREl meRite*iRg sapallility a*e prn><1Elea le* ~ ppliRg Ge"RI)', Gee*gia aREl leF !Re slate el Gee*gia.

E9-217 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 If neither agency can activate the system , Annex 4.2 The calling system serves as a complete The commitment wording was standardized the backup system will be utilized to notify backup to the ANS. The system provides both alerting and relocated to the SNC Standard the residents of the 10 mile EPZ. and notification of EPZ residents independent of the Emergency Plan. alerting 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 for Appling County, Georgia, and for the state of Georgia. Annex 4.2 W ithin the Plume Exposure Emergency Planning Zone (EPZ), there exist The siren alerting system consists of provisions for alerting and providing notification to the public. The state and/or local The commitment wording was standardized Whelen Model 2900 series electronic authorities are responsible for activation of this system. and relocated to the Site Annex. The FEMA approved Hatch ANS consists of a primary ANS and a backup system should omnidirectional sirens. The siren system sound coverage is such that a loss of a .. there be a failure of the primary system. Primary - Sirens and Emergency Alert System (EAS) stations System Backup - Reverse calling system single speaker-driver can be tolerated on The primary ANS has two communications pathways. The first pathway is th rough the primary agency via the UHF or VHF radio . Should the primary agency fail to activate the any siren without reducing siren coverage system, the secondary pathway will be utilized by the secondary agency. The secondary below the minimum required for pathway functions in the same manner as the primary pathway utilizing a separate activation console that is physically located in separate location. If neither agency can activate the populated areas within the EPZ. system, the backup system will be utilized to notify the residents of the 1O mile EPZ. The hierarchv for s1 stem activation is orovided below: Agency Radio Systems I Primary Agency UHF VHF Primary Sirens & EAS Secondary Agency UHF VHR I Backup Each County EMA Calling System I Georgia I Primary Agency State of Georgia (GEMA) I Secondary Agency Appling County I F'Fiffia.y aleAiR§ 1s aeeeAi~listlea ey "se el a siFeA systeffi. Eaetl siFeA e~erates eA eaUe.y

                                             ~eu*eF   ouitR eaUe>y GRaF§e A1aiAlaiAea By aA 1AueFteF !Rat Feeeiues ~eu*eF IFSA1 ti1e leeal eleetFieal §Fia eF IFeA1 a selaF ~aAel(s) . SiFeA systeA1 aeti,.atieA, test, aAEl AieAiteFiR§ ea~aeility aFe ~,e,.iaea le* A~~liR§ Ge"Aty, GeeF§ia aAEl le* ti1e state el Gee*§ia.                                                                        I E9-218 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan                            Revised SNC Emergency Plan                                         Justification Revision 36 Special Alerting and System Backup            EP E.2.5.1 Each site has a FEMA approved backup                   The commitment wording was standardized Special alerting will be accomplished         notification system in the event of a loss of the primary alert   and relocated to the SNC Standard through the use of a calling system.          and notification system.                                          Emergency Plan.

Special alerting will be initiated in the In the event of a serious emergency at any SNC site, the primary means for alerting the public will be by the FEMA event of a failure of the system to activate approved Alert and Notification System (ANS) referenced in multiple sirens resulting in a loss of the site specific Annex. Each site has a FEMA approved coverage in any area. Special alerting backup notification system in the event of a loss of the primary may be initiated for a predefined area, a alert and notification system. State and local plans maintain user specified area, user defined groups, additional processes to alert the public using emergency or the entire EPZ. vehicles, automated dialing systems, public address systems, etc. Details of the backup methods can be found in the site specific Annex. The capability exists to promptly alert and notify the general public within the Plume Exposure Pathway. The Alert and Notification Systems (ANS) for each station includes an acoustic alerting signal from sirens and notification of the public by the Emergency Alert System (EAS). Station specific information regarding the ANS is contained in each station's ANS Design Certification Package. The acoustical siren system design meets FEMA standards and requirements and has been approved to alert populations of an event. Each county controls the activation of the sirens within its boundaries (except for Henry County which relies on Houston County to activate their sirens). Activation of the ANS sirens by the local authorities will alert the public to turn to a local EAS station for detailed information on the emergency situation. The siren system is tested in accordance with the station's FEMA approved ANS design certification package. SNC provides for the repair and preventive maintenance of the EPZ sirens. Procedure instructions have developed to respond to any spurious activation of the ANS sirens. E9-220 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 The calling system will serve as a EP E.2.5.1 Each site has a FEMA approved backup The commitment wording was standardized complete backu p to the ANS. The system notification system in the event of a loss of the primary alert and relocated to the SNC Standard will provide both a lerting and notification and notification system. Emergency Plan . of EPZ residents independent of the In the event of a serious emergency at any SNC site, the primary means for alerting the public will be by the FEMA alerting capabilities provided by the approved Alert and Notification System (ANS) referenced in installed siren system and notification the site specific Annex. Each site has a FEMA approved capability of local radi o and television backup notification system in the event of a loss of the primary stations. alert and notification system. State and local plans maintain additional processes to alert the public using emergency vehicles, automated dialing systems, public address systems, etc. Details of the backup methods can be found in the site specific Annex. The capability exists to promptly alert and notify the general public within the Plume Exposure Pathway. The Alert and Notification Systems (ANS) for each station includes an acoustic alerting signal from sirens and notification of the public by the Emergency Alert System (EAS) . Station specific information regarding the ANS is contained in each station's ANS Design Certification Package. The acoustical siren system design meets FEMA standards and requirements and has been approved to alert populations of an event. Each county controls the activation of the sirens within its boundaries (except for Henry County which relies on Houston County to activate their sirens). Activation of the ANS sirens by the local authorities will alert the public to turn to a local EAS station for detailed information on the emergency situation. The siren system is tested in accordance with the station's FEMA approved ANS design certification package. SNC provides for the repair and preventive maintenance of the EPZ sirens. Procedure instructions have developed to respond to any spurious activation of the ANS sirens. E9-22 1 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 The calling system is designed to be able EP E.2.5.1 Each site has a FEMA approved backup The commitment wording was standardized to contact residents within the EPZ via notification system in the event of a loss of the primary alert and relocated to the SNC Standard telephone or cellular phone with a custom and notification system. Emergency Plan . message specific to the event. Thus , it In the event of a serious emergency at any SNC site, the primary means for alerting the public will be by the FEMA meets or exceeds the relevant criteria for approved Alert and Notification System (ANS) referenced in backup notification of area residents and the site specific Annex. Each site has a FEMA approved businesses. backup notification system in the event of a loss of the primary alert and notification system. State and local plans maintain additional processes to alert the public using emergency vehicles, automated dialing systems, public address systems, etc. Details of the backup methods can be found in the site specific Annex. The capability exists to promptly alert and notify the general public within the Plume Exposure Pathway. The Alert and Notification Systems (ANS) for each station includes an acoustic alerting signal from sirens and notification of the public by the Emergency Alert System (EAS). Station specific information regarding the ANS is contained in each station 's ANS Design Certification Package. The acoustical siren system design meets FEMA standards and requirements and has been approved to alert populations of an event. Each county controls the activation of the sirens within its boundaries (except for Henry County which relies on Houston County to activate their sirens). Activation of the ANS sirens by the local authorities will alert the public to turn to a local EAS station for detailed information on the emergency situation. The siren system is tested in accordance with the station's FEMA approved ANS design certification package. SNC provides for the repair and preventive maintenance of the EPZ sirens. Procedure instructions have developed to respond to any spurious activation of the ANS sirens. E9-222 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Annex 4.2 W ithin the Plume Exposure Emerg ency Plann ing Zone (EPZ), th ere exist D. PHYSICAL IMPLEMENTATION provisions for alerting and providing noti fication to the public. The state and/or local The commitment wording was standardized In the event of an emergency, the authorit ies are responsible for activation of th is system. and relocated to the Site Annex. The FEMA approved Hatch ANS consists of a primary ANS and a backup system should licensee has developed and will maintain plans , systems, procedures, and .. there be a fai lure of the primary system. Primary - Sirens and Emergency Alert System (EAS) stations System Backup - Reverse calling system relationships that are effective in notifying The primary ANS has two communications pathways. The first pathway is through the primary agency via the UHF or VHF radio . Should the primary agency fail to activate the appropriate governmental and other system, the secondary pathway will be utilized by the secondary agency. The secondary pathway functions in the same manner as the primary pathway utilizing a separate activation responsible authorities . These authorities console that is physically located in separate location. If neither agency can activate the will have available to them the means for system, the backup system will be utilized to notify the residents of the 1o mile EPZ. The hierarchv for s1 stem activation is provided below: alerting and notifying the general public Agency Ra dio Systems and for advising of appropriate responses by the public. Primary Agency UHF VHF Prima ry Sirens & EAS Secondary Agency UHF VHR Backup Each County EMA Calling System Geo rgia Primary Agency State of Georgia (GEMA) I Secondary Agency Appling County I PFimaFy alefliA§ is assemF>lisReli lly "se el a si*eA system. EasR siFeA 0Fl0Fates eA llatteFy Fl0"'e' u*itR llatte*y sRaF§S ma1AtaiAeli lly aA iA"Mef tRat Fese1ues FlS"'e' lrnm IRe lesal elestFisal §Fili eF lrnm a selaF F>aAel(s). Si*eA system asti,.atieA, test, aAli meAiteFiA§ saF>allility a*e Fl'e"ilieli le* AF>F>liA§ Ge"Aty, Gee*§ia aAli lef tRe state el GeeF§ia I The communications network utilized No equivalent Plan/Annex statement. Section E of the SNC Standard Emergency between the plant and the responsible Plan and Site Annex has the description of authorities is described in section E. Communication and Notification requirements for the ANS system. Notification of the licensee's emergency No equivalent Plan/Annex statement. Section E of the SNC Standard Emergency response personnel is described in Plan and Site Annex has the description of Section E of the main body of this Communication and Notification requirements Emergency Plan. for the ANS system . E9-224 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Notification of State and local response No equivalent Plan/Annex statement. Section E of the SNC Standard Emergency organization personnel would be Plan and Site Annex has the description of described in their respective emergency Communication and Notification requirements plans. for the ANS system . APPENDIX 4 No equivalent Plan/Annex appendix/list. The SNC Standard Emergency Plan provides TYPICAL EMERGENCY EQUIPMENT commitments to perform the functions for LISTS which the Emergency Equipment is used. The specific equipment needed to perform those functions varies as equipment/vendors changes. The Plan retains the commitment to perform the function , which eliminates the need to provide the specific equipment listings. APPENDIX 5 Appendix A - Evacuation Time Estimate Study and The Evacuation Time Estimate report for EVACUATION TIME ESTIMATES Map Reference Plant Hatch was re located to the Site Annex. FOR HNP PLUME EXPOSURE PATHWAY EPZ APPENDIX 6 - TYPICAL EMERGENCY Annex Appendix C A complete set of function-based EPIPs will IMPLEMENTING PROCEDURES be developed to support the integrated Plan. Appendix will be updated prior to implementation of the revised Plan. Appendix 7 A.3: Upon notification of an EP H.2.1: The EOF is procedurally required to be The commitment wording was standardized ALERT or higher classification or as activated within 75 minutes following the declaration of an and relocated to the SNC Standard directed by the ED, the EOF will be Alert or higher classification. £taffiRg aREI astii.iatioR of tl:le Emergency Plan activated as described in emergency EOF is maRdatory upoR doslaratioR of aR Alert or l:ligl:ler implementing procedures . slassifisatioR . Appendix 7 A.3: Offsite support personnel EP B.2.1.15 : The TSC Support Coordinator reports to The commitment wording was standardized and equipment will be dispatched to the the TSC Manager and directs the clerical and logistic and relocated to the SNC Standard site Operations Support Center (OSC) or activities in the TSC, ensures support staff, including Emergency Plan Technical Support Center (TSC) upon clerks, status board keepers, and communicators, are request from the specific site Emergency avai lable in sufficient numbers, and ensures office Director. supplies, drawings, and other documents are available to TSC and OSC personnel. E9-225 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Appendix 7 A.3: The corporate EP 8.1 SNC plants maintain 24-hour emergency The commitment wording was standardized emergency organization will provide response capability. The normal on-shift complement and relocated to the SNC Standard offsite emergency response support and provides the initial response to an emergency. This Emergency Plan. resources to SNC sites 24 hours per day group is trained to respond to emergency situations until until the emergency has been terminated. the augmented Emergency Response Organization The SNC Standard Emergency Plan (ERO) arrives. The ERO is composed of personnel with integrates the Corporate response as part of specialties in operations, maintenance, engineering, the trained and qualified ERO. A separate radiochemistry, radiation protection, fire protection , and statement is not necessary. security. Appendix 7 A.3: The EOF will be EP H.2.1: The EOF is procedurally required to be The commitment wording was standardized activated for an ALERT, SITE AREA or activated within 75 minutes following the declaration of an and relocated to the SNC Standard GENERAL emergency classifications. Alert or higher classification. ~taffiAJ aAEl aGti1.iatioA of H:ie Emergency Plan. EOF is maAElatory upoA EleGlaratioA of aA Alert or hiJher GlassifiGatioA. Appendix 7 A.3: This facility (EOF) will be EP 8.2: Augmentation of on-shift staffing will occur The commitment wording was standardized operational within about an hour of the within 75 minutes of the declaration of an Alert or higher and relocated to the SNC Standard initial notification. classification by the Emergency Response Organization Emergency Plan . (ERO). ERO positions for the TSC, Operations Support Center (OSC), Emergency Operations Facility (EOF) , The change in activation times will be justified and JIC are detailed below. separately in the Technical Analysis Section of this License Amendment Request. Appendix 7 A.3: SNC's goal is to begin EP 8.1.1 The ED, at their discretion or when The SNC Standard Emergency Plan moves to notification of all required on-call procedurally required , activates the ERO. a commitment to activate facilities within a Emergency Response Organization timeframe of 75 minutes. Notification of the (ERO) personnel as soon as practicable, responding ERO is a step in the overall within 15 minutes, following the process and not needed as a separate declaration of an Alert emergency or commitment. higher emergency classification at any SNC site. The change in activation times will be justified separately in the Technical Analysis Section of this License Amendment Request. E9-226 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Appendix 7 B: When the EOF is EP 8.2: Augmentation of on-shift staffing will occur The commitment wording was standardized activated, all EOF staff pagers are within 75 minutes of the declaration of an Alert or higher and relocated to the SNC Standard activated, and all EOF personnel are classification by the Emergency Response Organization Emergency Plan. expected to report to the EOF. (ERO) . ERO positions for the TSC, Operations Support Center (OSC), Emergency Operations Facility (EOF), and JIC are detailed below Appendix 7 B.1: The EOF Managers will EP 0.1 Training The commitment was modified to required typically have either previous plant To achieve and maintain an acceptable level of qualified personnel. specific SRO background or long-term emergency preparedness , training will be conducted for supervisory/management experience . members of the Emergency Response Organization (ERO) and those offsite organizations that may be cal led on to provide assistance in the event of an emergency. Training will be evaluated in accordance with the requirements of Systematic Approach to Training practices to ensure effectiveness and in order to identify weak or deficient areas that need correction. The ERO Training Program ensures the training, qualification , and requalification of individuals who may be called on for assistance during an emergency. Specific emergency respo nse 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. E9-229 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Appendix 7 B.6: The duties and EP B.3.1.12: The EOF Offsite Response Coordinator The commitment wording was standardized responsibilities of the Offsite Response reports to the EOF Manager. The duties and and relocated to the SNC Standard Coordinator are as follows: (As listed in responsibil ities of the Offsite Response Coordinator Emergency Plan . App. 7, 2 items listed). The individuals include coordination of activities for the dispatch and designated to assume the position will be update of techn ical liaisons to state and local authorities ind icated on a predetermined rotational and monitoring EOF functional areas to facilitate schedule. coordination between the licensee and state and local agencies. Append ix 7 C: Initial notifications or EP E.2.1: Emergency Response personnel respond to The comm itment wording was standardized emergency response personnel will follow their assigned Emergency Response Facilities upon and relocated to the SNC Standard the guidelines specified in the site specific notification of an Alert or higher classification level. Emergency Plan. Emergency Plan and Emergency Plan Implementing Procedures. Appendix 7 C.1 : The On -call EOF EP E.2.1: Emergency Response personnel respond to The commitment wording was standardized Manager will be notified of all their assigned Emergency Response Facilities upon and relocated to the SNC Standard emergencies classified at any SNC site. notification of an Alert or higher classification level. Emergency Plan . Appendix 7 D.1: The EOF is located in EP H.2.1 : The EOF is a dedicated facility located in The comm itment wording was standardized Birmingham , Alabama and serves as the Birmingham, Alabama, and serves as the EOF for SNC and relocated to the SNC Standard EOF for all SNC sites (VEGP, FNP , and sites (VEGP, FNP , and HNP). Emergency Plan. HNP). Appendix 7 D.1: The EOF will be EP H.2.1 : The EOF is procedurally required to be The commitment wording was standardized activated as prescribed in the site specific activated within 75 minutes following the declaration of an and relocated to the SNC Standard Emergency Plan implementing Alert or higher classification. ~taffiR§ aREl astivatieR et tt:ie Emergency Plan . procedures . EOF is maRElatery upeR EleslaratieR et aR Alert er Ri§Fier slassitisatieR. E9-232 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Appendix 7 0 .1: The following records or EP H.2.1: The EOF is located at SNC Corporate The commitment wording was standardized information are available: Headquarters. The following records or information are and relocated to the SNC Standard Technical Specifications . available: Emergency Plan . Selected plant operating procedures .

Technical Specifications .

Emergency Plans.

Selected plant operating procedures.

Emergency Plan Implementing

Emergency Plans.

Procedures.

Emergency Plan Implementing Procedures.

FSARs .

Final Safety Analysis Reports (FSARs).

State and local emergency response

System piping and instrumentation diagrams and plans. HVAC flow diagrams .

Savannah River Site Emergency Plan.

Electrical one-line, elementary, and wiri ng diagrams .

Appendix 7 0.2: In the unlikely event that No equivalent Plan/Annex statement Egress of personnel from the EPZ falls under individuals should need to respond to the the provisions of the State Plan. A statement EOF from within the 10 mile EPZ of any in the SNC Standard Emergency Plan is not SNC plant, they would be surveyed prior required . to release by local emergency authorities. Appendix 7 0.2: In the unlikely event that No equivalent Plan/Annex statement The corporate EOF is located outside the the EOF becomes uninhabitable, reasonable expectation for damage based on resources and personnel will be a naturally occurring event beyond the design transferred to the Corporate basis of the site. Should the EOF be so Headquarters of Alabama Power damaged , the site can re-assume control of Company. the event. Appendix 7 E.1: Provisions have been EP F.1.4: Communication with the Nuclear Regulatory The commitment wording was standardized made to have direct NRC FTS lines in the Commission (NRC) is on the Federal Telephone and relocated to the SNC Standard TSC and the EOF during an emergency. Telecommunications System (FTS) telephone network which connects the SNC plant site and EOF with the Emergency Plan . I NRC Operations Center. E9-236 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Appendix 7 G.1.2: At least 1 activation N.2.11 Multi-Site Drill The SNC Standard Emergency Plan every 5 years will require a concurrent At least once in every five years, a drill involving more incorporates the EOF multi-site drill into the EOF support response for more than one than one SNC site will be conducted demonstrating the base Plan response. SNC site. ability of the Common EOF to effectively implement the Emergency Plan for an event involving more than one site. Appendix 7 G.1.2: Each drill/exercise will EP N.1: Drills and exercises shall: The commitment wording was standardized test, as a minimum, the communication

Test the adequacy of timing and content of and relocated to the SNC Standard links and notification procedures. implementing procedures and methods . Emergency Plan .
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 made EP N.4: A formal critique will be performed for exercises, The commitment wording was standardized for critique of all drills/exercises. drills, and training tabletops to develop, maintain , or and relocated to the SNC Standard demonstrate key skills in order to identify weak or Emergency Plan. deficient areas that need correction. A critique shall be conducted at the conclusion of the exercise, to evaluate the organization's ability to respond as called for in the SNC Standard Emergency Plan. Appendix 7 G.1 .2: Critique items will be EP N.5: The Emergency Preparedness group is The commitment wording was standardized forwarded to the site emergency responsible for evaluating recommendations and and relocated to the SNC Standard preparedness coordinator for processing comments, determining which items will be incorporated Emergency Plan. in the site specific corrective action into the program or require corrective actions , and for program . scheduling , tracking , and evaluating item resolution. Whenever exercises or drills indicate deficiencies in the SNC Standard Emergency Plan, site-specific Annexes , corresponding implementing procedures, or training lesson plans, such documents will be revised as necessary. E9-239

HATCH NUCLEAR POWER PLANT JUSTIFICATION MATRIX Purpose The purpose of this attachment is to identify the commitments in the current Hatch Nuclear Power Plant Emergency Plan Revision 36, identify the equivalent or modified commitment in the integrated Fleet Emergency Plan and Hatch Site Annex, and justify on a commitment-by-commitment basis the proposed License Amendment. to NL-16-0169 Hatch Justification Matrix CHANGE MATRIX Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36

The Hatch Nuclear Plant (HNP) is a two- Annex 1.1 Facility Description The words were standardized and relocated unit boiling water reactor operated by The Hatch Nuclear Plant (HNP) is a two-unit boiling to the Site Annex.

Southern Nuclear Operating Company water reactor. The plant is on a 2, 100-acre site located (SNC) (hereafter referred to as the in Appling County, Georgia, approximately 11 miles licensee). The plant is on a 2100-acre site north of Saxley, Georgia, on U.S. Highway 1. located in Appling County, Georgia, approximately 11 miles north of Baxley, Georgia, on U.S. Highway 1 (Figure i). Figure ii shows the site and locations of Annex Figure 1.1.B The figure was maintained with a new figure the buildings onsite. designation without change. The locations of the HNP emergency Annex Figure 1.1.B The figure was maintained with a new figure facilities and rally points are shown on designation without change. Figure ii. This Emergency Plan is applicable to

Annex 1 Introduction The words were standardized and relocated HNP, Units 1 and 2, and to its environs as This document serves as the Edwin I. Hatch Nuclear to the Site Annex specified by the emergency planning
Plant (HNP) Units 1 and 2 Annex and contains zones (EPZs): a plume exposure pathway information and guidance that is unique to HNP. This EPZs, which nominally consists of the includes Emergency Action Levels (EALs) and facility area within approximately 10 miles of the geography.

plant, and an ingestion exposure pathway Annex Figures 1.2.A and 1.2.B EPZ, which extends to approximately 50 miles. These distances are taken from the plant stack. The two EPZs are shown in Figures iii and iv. E9-2 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 The geographical boundaries of the Annex 1.2.1 Plume Exposure Pathway (SEP J.7) The words were standardized and relocated plume exposure pathway EPZ are shown The 10-mile Emergency Planning Zone (EPZ) for HNP to the Site Annex on Figure iii. These evacuation zones are approximates a 10-mile radius around the plant site and further detailed in the State Base Plan, is depicted in Figure 1.2.A. Located within the EPZ are Annex A, Table D-1, of each county the Georgia counties of Appling, Jeff Davis, Tattnall, and section (Toombs, Appling, Jeff Davis, and Toombs. Tattnall). These zones are presented in Annex Figure 1.2.A Tables i through iv. The EPZ for ingestion exposure includes Annex 1.2.2 Ingestion Pathway (SEP J.7) The words were standardized and relocated an area within 50 miles of the plant stack, The area between the 10-mile and 50-mile radius is to the Site Annex except for portions of Brantley and considered the Ingestion Pathway Zone (IPZ). The 50-Mcintosh Counties which were excluded mile IPZ is depicted in Figure 1.2.B. Planning for the to prevent crossing any additional ingestion exposure pathway is a responsibility of the state jurisdictional boundaries. Planning for the of Georgia. More information about the IPZ can be ingestion exposure pathway is a obtained from the state's Radiological Emergency Plan. responsibility of the State of Georgia. Annex Figure 1.2.B More information about the ingestion exposure pathway EPZ can be obtained from the State's Radiological Emergency Plan. The order of the presentation provided EP Background The words were standardized and relocated herein follows that of the 16 standards The SNC Emergency Plan was developed with the to the SNC Standard Emergency Plan delineated in Title 10 Code of Federal guidance of NUREG-0654, FEMA-REP-1, Revision 1, Regulations (CFR) Part 50, Section "Criteria for Preparation and Evaluation of Radiological 50.47(b). Appropriate criteria from Emergency Response Plans and Preparedness in NUREG-0654, Revision 1, "Criteria for Support of Nuclear Power Plants." The SNC Emergency Preparation and Evaluation of Plan meets the emergency planning standards of 10 CFR Radiological Emergency Response Plans 50.47(b), the requirements of Appendix E, and the intent (RERPs) and Preparedness in Support of of NU REG 0654 Revision 1. The SNC Emergency Plan Nuclear Power Plants," are addressed is organized using the structure of NUREG-0654 approximately in the sequence presented Revision 1 and that structure provides the cross-in that document. reference to the base document. E9-3 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Although this Plan is designed to stand on EP Scope The. words were standardized and relocated its own, additional plans expand on There are supporting and complementing emergency to the SNC Standard Emergency Plan matters mentioned here, as identified in plans, including those of federal agencies, the states of Section C. It is to be recognized that this Alabama, Georgia, and South Carolina, and individual is only a plan and not a prescriptive

counties.

document. Each incident is a unique The SNC Emergency Plan describes the organization, event; therefore, this Plan is designed t6 facilities, training, and maintenance of both onsite and incorporate the flexibility to tailor the off-site facilities and equipment that will be used to response and meet the emergency. address a wide spectrum ofaccidents ranging from minor onsite incidents to those that could affect the general public. This Plan is supported by a set of EP Scope The words were standardized and relocated implementing procedures. A typical list of Detailed procedures concerning the implementation of to the SNC Standard Emergency Plan these procedures is included as Appendix the SNC Emergency Plan are in the Emergency Plan

6. Implementing Procedures (EPIPs). Those documents describe the duties of individuals and groups in the event of emergencies and also serve as the interface between the SNC Emergency Plan, plant operations, security, and radiological control programs. SNC also has procedures in place that implement onsite protective actions and personnel accountability during hostile action threats or events that are appropriate for plant and environmental conditions. These procedures are available for use at the plants.

Annex Appendix C A. ASSIGNMENT OF EP Section A The words were standardized and relocated RESPONSIBILITIES Annex 1.3 State of Georgia to the SNC Standard Emergency Plan and In the event of a situation at the HNP Annex 1.4 Local Organizations Site Annex. which requires activation of the emergency response organizations, various Federal, State, local, and private sector organizations may be required to contribute to the emergency response. This section describes the responsibilities of these organizations. E9-4 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Table A-1 lists primary response No Equivalent Plan/Annex Table The primary response organizations are organizations and the emergency title of described in the SNC Standard Emergency the individual in charge. Plan and Site Annex. No agencies responding to a Classified Event were impacted by this change. Section A: The licensee accepts the EP

Introduction:

Detailed procedures concerning the The commitment wording was standardized responsibility of developing and implementation of the SNC EP are in the Emergency within the SNC system. The commitment maintaining an effective emergency plan Plan Implementing Procedures (EPIPs). assuming overall responsibility for maintaining and of maintaining proper preparedness SNC has overall responsibility for maintaining a state of the state of readiness for emergency through the development of formal readiness to implement emergency plans for the preparedness is unchanged. procedures for implementing the Plan as protection of plant personnel, the general public, and identified in Appendix 6, the training of property from hazards associated with any facility personnel in accordance with Section 0, operated by the company the procurement of necessary equipment, and the development of relationships with various governmental agencies and private organizations as identified in this section and in Appendix 2. E9-5 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Section A: The following tasks are part of EP

Introduction:

SNC has overall responsibility for The Introduction was standardized and - the licensee's responsibility: maintaining a state of readiness to implement emergency modified. The existing Plan wording stating plans for the protection of plant personnel, the general the performance of the Planning Standards

1. Recognize and declare the existence of public, and property from hazards associated with any from the current Plan is addressed in the an emergency condition. facility operated by the company. The SNC EP describes appropriate sections of the SNC Standard

2. Take corrective actions to mitigate the the organization, facilities, training, and maintenance of Emergency Plan and Annex. The intent to severity of the accident. both onsite and off-site facilities and equipment that will maintain the program consistent with the

3. Classify the event in accordance with be used to address a wide spectrum of accidents ranging Planning Standards was maintained in the the methodology described in Section D from minor onsite incidents to those that could affect the SNC Standard Emergency Plan.

of this Plan. general public.

4. Notify appropriate plant and corporate personnel and offsite authorities.

5. Request additional support, as deemed necessary.

6. Establish and maintain effective communications within HNP and with offsite response groups, as described in Section F.

7. Continuously assess the status of the accident and periodically communicate the status information to the appropriate response groups. This includes the collection and evaluation of onsite and offsite radiological monitoring data.

8. Take protective measures onsite and recommend protective measures to offsite authorities.

9. Monitor and control radiation exposures of all personnel responding to the emergency, under the direction of the licensee.

10. Provide timely and accurate emergency information to the public through press briefings in conjunction with State and local officials.

E9-6 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Section A: The following tasks are part of Extracted from SNC Standard Emergency Plan The SNC Standard Emergency Plan the licensee's responsibility: (cont) introduction was standardized. The TABLE OF CONTENTS organization of the Plan was aligned to the SECTION A: ASSIGNMENT OF RESPONSIBILITY Planning Standards/NUREG-0654 Revision 1. SECTION B: ONSITE EMERGENCY RESPONSE The commitment to perform in accordance ORGANIZATION (ERO) with the standards was. maintained SECTION C: EMERGENCY RESPONSE SUPPORT unchanged. AND RESOURCES SECTION D: EMERGENCYCLASSIFICATION SYSTEM SECTION E: NOTIFICATION METHODS AND PROCEDURES SECTION F: EMERGENCY COMMUNICATIONS SECTION G: PUBLIC EDUCATION AND INFORMATION SECTION H: EMERGENCY FACILITIES AND EQUIPMENT SECTION I: ACCIDENT ASSESSMENT SECTION J:* PROTECTIVE RESPONSE SECTION K: RADIOLOGICAL EXPOSURE CONTROL SECTION L: MEDICAL AND PUBLIC HEALTH SUPPORT SECTION M: RECOVERY AND REENTRY PLANNING AND POSTACCIDENT OPERATIONS SECTION N: EXERCISES AND DRILLS SECTION 0: RADIOLOGICAL EMERGENCY RESPONSE TRAINING SECTION P: RESPONSIBILITY FOR THE PLANNING EFFORT E9-7 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 The licensee emergency response is EP B.1.1: The Shift Manager (SM) is in direct charge The commitment wording was standardized carried out under the control of the of shift plant operations and is directly responsible for for the SNC sites. The intent of the Emergency Director (ED). the actions of the on-shift crew. In an emergency, the commitment was maintained. 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. State of Georgia Annex 1.3 State of Georgia (SEP A.2.2) The commitment wording was standardized Georgia has developed a RERP on a Upon notification of an emergency condition, the for the SNC sites and relocated to the Site statewide basis as an integral part of the Georgia Emergency Management Agency will Annex for those responders applicable to the Georgia Emergency Operations Plan. The implement the "State of Georgia Radiological site. No change in the overall expectations of Georgia Emergency Operations Plan is Emergency Plan." The Georgia Emergency response from the state of Georgia was made an emergency operations plan for all Management Agency has the authority and as a result of this submittal. natural disasters, accidents, and responsibility for coordinating the efforts of local and incidents, including radiological state agencies in Georgia to provide for the health and emergencies at fixed nuclear facilities. It safety .of the general public in the event of a radiological is a plan of action developed for use by incident. State and local government offiCials in An agreement is in place with the state of Georgia to preparing for, responding to, and dealing provide available resources and equipment to support with situations throughout the State. the mitigation and response to an emergency at Plant Hatch to include Hostile Action Based events. These resources include, but are not limited to, Local Law Enforcement Agency (LLEA) assets, fire fighting assets, medical support resources (including transportation),

and coordination through an Incident Command Post.

Requests for offsite resources and equipment will be communicated from the control room to the Burke County 911 center, the county EOC, or through the Incident Command Post, as applicable, based on the nature and timing of the event. E9-8 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 In accordance with Annex No. 12 of the Annex 1.3 State of Georgia (SEP A.2.2) The commitment wording was standardized Governor's Executive Order dated June Upon notification of an emergency condition, the for the SNC sites and relocated to the Site 3, 1983, the Georgia Department of Georgia Emergency Management Agency will Annex for those responders applicable to the Natural Resources (DNR) has the lead implement the "State of Georgia Radiological site. agency responsibility for responding to all Emergency Plan." The Georgia Emergency peacetime radiological emergency Management Agency has the authority and situations throughout Georgia. Under the responsibility for coordinating the efforts of local and procedure established by the Georgia state agencies in Georgia to provide for the health and Emergency Operations Plan, which was safety of the general public in the event of a radiological developed pursuant to the Governor's incident. Executive Order, the DNR radiological An agreement is in place with the state of Georgia to emergency response team assesses the. provide available resources and equipment to support radiological conditions of an incident at the mitigation and response to an emergency at Plant the site and confirms or determines Hatch to include Hostile Action Based events. These whether a state of emergency exists. resources include, but are not limited to, Local Law Enforcement Agency (LLEA) assets, fire fighting assets, medical support resources (including transportation), and coordination through an Incident Command Post. Requests for offsite resources and equipment will be communicated from the control room to the Burke County 911 center, the county EOC, or through the Incident Command Post, as applicable, based on the nature and timing of the event. E9-9 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Upon being advised that a radiological Annex 1.3 State of Georgia (SEP A.2.2) The commitment wording was standardized emergency exists, the Governor declares Upon notification of an emergency condition, the for the SNC sites and relocated to the Site an emergency condition, which then Georgia Emergency Management Agency will Annex for those responders applicable to the activates the Georgia Emergency implement the "State of Georgia Radiological site. Management Agency (GEMA) authorities Emergency Plan." The Georgia Emergency to deal with the situation. Under the Management Agency has the authority and statutory authority granted to the GEMA, responsibility for coordinating the efforts of local and the pre-established plans and procedures state agencies in Georgia to provide for the health and of all State agencies and applicable local safety of the general public in the event of a radiological government organizations are incident. automatically activated and coordinated An agreement is in place with the state of Georgia to by the GEMA State Emergency provide available resources and equipment to support Operations Center (EOC) in Atlanta. In the mitigation and response to an emergency at Plant the event of a radiological emergency, Hatch to include Hostile Action Based events. These GEMA has broad legal authority to take resources include, but are not limited to, Local Law whatever actions are deemed necessary Enforcement Agency (LLEA) assets, fire fighting assets, to protect the health and safety of medical support resources (including transportation), Georgia citizens. This authority includes, and coordination through an Incident Command Post. but is not limited to, evacuation of people Requests for offsite resources and equipment will be from private property, control of public communicated from the control room to the Burke and private transportation corridors, and County 911 center, the county EOC, or through the utilization of all public facilities in support Incident Command Post, as applicable, based on the of efforts to protect life and property. nature and timing of the event. E9-10 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 The fundamental legislation providing the No equivalent Plan/Annex statement. The paragraph in the current Plan is historic basis for emergency response by civil in nature and provides no specific direction to authorities is the Georgia Emergency response to the current Plan. Management Act of 1981, as amended. This Act in part creates a State The Site Annex clearly specifies the Emergency Management Agency (EMA); responsibilities of the respective OROs. authorizes the creation of local organizations for emergency management; confers upon the Governor and the executive heads of governing bodies of the State certain emergency powers; and provides the rendering of mutual aid among the political subdivisions of the State, and with other states, and with the Federal Government. E9-11 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Other documents providing bases for No equivalent Plan/Annex statement. The paragraph in the current Plan is historic emergency response are: in nature and provides no specific direction to

1. Governor's Executive Order, August response to the current Plan.

25, 1981: Recognizes the Georgia Emergency Management Act of 1981, The Site Annex clearly specifies the which redesignates the State Civil responsibilities of the respective OROs. Defense Agency as the GEMA.

2. Georgia Emergency Disaster Operations Plan: Contains the rules and regulations for operations, should an emergency or disaster occur in the State.

The Plan is binding on all local governments authorized or directed to conduct emergency management operations and on all State departments or agencies.

3. Radiation Control Act, Georgia Code Annex 88-1301 et seq.: Delegates emergency powers during radiation emergencies to the DNR, Division of Environmental Protection.

4. Georgia Water Quality Control Act of 1974, as amended, Act No. 870.

5. Georgia Air Quality Control Act of 1978, as amended, Act No. 794.

6. Georgia Transportation of Hazardous Materials Act of 1979, Act No. 487.

E9-12 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 The duties and responsibilities of the Annex 1.3 State of Georgia (SEP A.2.2) The wording describing the responsibilities of principal and support agencies of the Upon notification of an emergency condition, the the agencies responding within the overall State of Georgia are summarized below. Georgia Emergency Management Agency will scope of the state of Georgia were described A detailed discussion of the State's implement the "State of Georgia Radiological in the Site Annex. response is contained in the Georgia Emergency Plan." The Georgia Emergency RERP. Management Agency has the authority and Princii;:ial Agencies of the State of Georgia responsibility for coordinating the efforts of local and The following State agencies are state agencies in Georgia to provide for the health and assigned lead responsibility for safety of the general public in the event of a radiological radiological emergencies and for overall incident. State preparedness, respectively: An agreement is in place with the state of Georgia to provide available resources and equipment to support the mitigation and response to an emergency at Plant Hatch 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 Burke County 911 center, the county EOG, or through the Incident Command Post, as applicable, based on the nature and !iming of the event. E9-13 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Annex 1.3 State of Georgia (SEP A.2.2) The wording describing the responsibilities of

1. GEMA Upon notification of an emergency condition, the the agencies responding within the overall

a. GEMA is responsible for general State Georgia Emergency Management Agency will scope of the state of Georgia were described emergency planning and exercises, and implement the "State of Georgia Radiological in the Site Annex.

overall direction and control of emergency Emergency Plan." The Georgia Emergency or disaster operations as assigned by Management Agency has the authority and Executive Order. responsibility for coordinating the efforts of local and

b. The Director of Emergency state agencies in Georgia to provide for the health and Management as the State Disaster safety of the general public in the event of a radiological Coordinator coordinates DNR emergency incident.

activities with overall State response An agreement is in place with the State of Georgia to efforts. provide available resources and equipment to support

c. On behalf of the Governor, activate all the mitigation and response to an emergency at Plant or portions of the Georgia Emergency Hatch to include Hostile Action Based events. These Operations Plan to provide the necessary resources include, but are not limited to, Local Law overall coordinated response. Enforcement Agency (LLEA) assets, firefighting assets,

d. Provide communications for the State medical support resources (including transportation),

EOC, as required, through the 24-hour and coordination through an Incident Command Post. radio net, commercial telephone, National Requests for offsite resources and equipment will be Warning System (NAWAS), teletype, or communicated from the control room to the Burke other communications systems. County 911 center, the county EOC, or through the Communication links will be established, Incident Command Post, as applicable, based on the in accordance with existing procedures, nature and timing of the event. with the State EOC, as well as with additional State and local emergency response personnel within the plume exposure pathway and 50-mile radius EPZs. These functions will initially be handled from the State EOC in Atlanta and once activated will be transferred to the Forward Emergency Operations Center (FEOC) in Vidalia.

e. Maintain liaison with the DNR Radiation Emergency Coordinator (REC).

E9-14 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 GEMA (cont) The wording describing the responsibilities of

f. Activate public emergency warning the agencies responding within the overall and/or evacuation procedures, as scope of the state of Georgia were described needed, pursuant to the Georgia in the Site Annex.

Emergency Operations Plan.

g. Assist in performing radiological monitoring and provide radiological monitoring instrumentation.

h. Provide radiological monitoring training assistance.

i. In accordance with the Georgia Emergency Operations Plan, coordinate public information releases in cooperation with State and local agencies.

j. Contact the Governor for National Guard assistance.

E9-15 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 DNR Annex 1.3 State of Georgia (SEP A.2.2) The wording describing the responsibilities of

a. DNR is assigned primary responsibility Upon notification of an emergency condition, the the agencies responding within the overall by Executive Order for implementation Georgia Emergency Management Agency will scope of the state of Georgia were described and administration of the State implement the "State of Georgia Radiological in the Site Annex.

radiological emergency response Emergency Plan." The Georgia Emergency function. Management Agency has the authority and

b. An REC in the Environmental responsibility for coordinating the efforts of local and Protection Division (EPD) interacts with state agencies in Georgia to provide for the health and appropriate State, local, and Federal safety of the general public in the event of a radiological agencies and private organizations to incident.

direct all necessary radiation control An agreement is in place with the state of Georgia to actions. The REC is on call 24 hours a provide available resources and equipment to support day and will be notified by the GEMA the mitigation and response to an emergency at Plant Duty Officer. Hatch to include Hostile Action Based events. These

c. In situations beyond local government resources include, but are not limited to, Local Law control, DNR provides program Enforcement Agency (LLEA) assets, firefighting assets, assistance in the application of available medical support resources (including transportation),

personnel, equipment, and technical and coordination through an Incident Command Post. expertise, as required. Requests for offsite resources and equipment will be

d. DNR requests State support agency(s) communicated from the control room to the Burke and Federal assistance pursuant to the County 911 center, the county EOC, or through the Georgia Emergency Operations Plan, as Incident Command Post, as applicable, based on the required. nature and timing of the event.

e. DNR will escort media personnel within the plume exposure pathway EPZ as conditions allow, if access controls have been established.

f. Dispatch radiation emergency teams, as needed.

g. Perform radiation survey and monitoring, and provide protective equipment, as necessary.

h. Provide technical advice and assist in substance identification.

E9-16 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 State Support Agencies Annex 1.3 State of Georgia (SEP A.2.2) The wording describing the responsibilities of The following State agencies are Upon notification of an emergency condition, the the agencies responding within the overall prepared to provide related support of this Georgia Emergency Management Agency will scope of the state of Georgia were described function as indicated pursuant to the implement the "State of Georgia Radiological in the Site Annex. Georgia Emergency Operations Plan: Emergency Plan." The Georgia Emergency

1. Department of Human Resources Management Agency has the authority and Coordinate emergency health and social responsibility for coordinating the efforts of local and assistance pursuant to the Georgia state agencies in Georgia to provide for the health and Emergency Operations Plan. safety of the general public in the event of a radiological incident.

An agreement is in place with the state of Georgia to provide available resources and equipment to support the mitigation and response to an emergency at Plant Hatch 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 Burke County 911 center, the county EOC, or through the Incident Command Post, as applicable, based on the nature and timing of the event. E9-17 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Department of Public Safety Annex 1.3 State of Georgia (SEP A.2.2) The wording describing the responsibilities of

a. As applicable, assume control over the Upon notification of an emergency condition, the the agencies responding within the overall situation until the arrival of radiation Georgia Emergency Management Agency will scope of the state of Georgia were described safety personnel. implement the "State of Georgia Radiological in the Site Annex.

b. Maintain liaison with the DNR REC. Emergency Plan." The Georgia Emergency

c. Provide communication linkage, as Management Agency has the authority and required. responsibility for coordinating the efforts of local and

d. Provide land or air transportation, or state agencies in Georgia to provide for the health and escort, as available, for radiation safety safety of the general public in the event of a radiological personnel, other necessary personnel, or incident.

equipment. An agreement is in place with the state of Georgia to

e. Assist in radiological monitoring, as provide available resources and equipment to support required. the mitigation and response to an emergency at Plant

f. Provide law enforcement assistance for Hatch to include Hostile Action Based events. These area security or recovery of lost or stolen resources include, but are not limited to, Local Law radioactive material. Enforcement Agency (LLEA) assets, firefighting assets,

g. Coordinate with DNR law enforcement medical support resources (including transportation),

and local police. and coordination through an Incident Command Post.

h. Assist in public warning or evacuation, Requests for offsite resources and equipment will be as required, including ground and communicated from the control room to the Burke airborne means as available. County 911 center, the county EOC, or through the

i. Assist in area security and control. Incident Command Post, as applicable, based on the

j. Provide land or air transportation, as nature and timing of the event.

requested, for radiation safety personnel, other necessary personnel, or equipment. E9-18 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Department of Agriculture Annex 1.3 State of Georgia (SEP A.2.2) The wording describing the responsibilities of

a. Collect samples of food products, Upon notification of an emergency condition, the the agencies responding within the overall livestock, produce, and dairy products, as Georgia Emergency Management Agency will scope of the state of Georgia were described necessary. implement the "State of Georgia Radiological in the Site Annex.

b. Restrict the sale, production, Emergency Plan." The Georgia Emergency distribution, and warehousing of livestock, Management Agency has the authority and produce, dairy, and processed food responsibility for coordinating the efforts of local and products contaminated beyond safe state agencies in Georgia to provide for the health and consumption. safety of the general public in the event of a radiological

c. Assist in disposal of contaminated incident.

products. An agreement is in place with the state of Georgia to

d. Coordinate these activities with United provide available resources and equipment to support States Department of Agriculture (USDA) the mitigation and response to an emergency at Plant personnel. Hatch to include Hostile Action Based events. These

e. Maintain liaison with the DNR REC for resources include, but are not limited to, Local Law assessing degree of contamination. 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 Burke County 911 center, the county EOC, or through the Incident Command Post, as applicable, based on the nature and timing of the event. E9-19 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Department of Transportation Annex 1.3 State of Georgia (SEP A.2.2) The wording describing the responsibilities of

a. Assist in traffic control and routing, Upon notification of an emergency condition, the the agencies responding within the overall accident assessment, and recovery Georgia Emergency Management Agency will scope of the state of Georgia were described operations in transportation incidents. implement the "State of Georgia Radiological in the Site Annex.

b. As requested, provide land, air, or Emergency Plan." The Georgia Emergency water transportation for radiation safety Management Agency has the authority and personnel, other necessary personnel, or responsibility for coordinating the efforts of local and equipment. state agencies in Georgia to provide for the health and

c. Provide communications linkage, as safety of the general public in the event of a radiological required. incident.

d. Assist State Patrol and DNR law An agreement is in place with the state of Georgia to enforcement in security and radioactive provide available resources and equipment to support material escort, as requested. the mitigation and response to an emergency at Plant

e. Provide heavy equipment and Hatch to include Hostile Action Based events. These personnel, as required. 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 Burke County 911 center, the county EOG, or through the Incident Command Post, as applicable, based on the nature and timing of the event. E9-20 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Forestry Commission Annex 1.3 State of Georgia (SEP A.2.2) The wording describing the responsibilities of

a. Provide land or air transportation, as Upon notification of an emergency condition, the the agencies responding within the overall requested, for radiation safety personnel, Georgia Emergency Management Agency will scope of the state of Georgia were described other necessary personnel, or equipment. implement the "State of Georgia Radiological in the Site Annex.

b. Provide personnel and heavy Emergency Plan." The Georgia Emergency equipment, as required, to assist in Management Agency has the authority and recovery operations. responsibility for coordinating the efforts of local and

c. Provide communication linkage, as state agencies in Georgia to provide for the health and necessary. safety of the general public in the event of a radiological

d. Assist with public warning or incident.

evacuation, as required, including ground An agreement is in place with the state of Georgia to and air operations. provide available resources and equipment to support the mitigation and response to an emergency at Plant Hatch 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 Burke County 911 center, the county EOC, or through the Incident Command Post, as appiicable, based on the nature and timing of the event. E9-21 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Department of Administrative Services Annex 1.3 State of Georgia (SEP A.2.2) The wording describing the responsibilities of

a. Provide for expedient approval and Upon notification of an emergency condition, the the agencies responding within the overall purchase of equipment and supplies Georgia Emergency Management Agency will scope of the state of Georgia were described essential to emergency operations. implement the "State of Georgia Radiological in the Site Annex.

b. Provide land transportation vehicles for Emergency Plan." The Georgia Emergency emergency personnel. Management Agency has the authority and

c. Provide emergency communications responsibility for coordinating the efforts of local and equipment and repair. state agencies in Georgia to provide for the health and safety of the general public in the event of a radiological incident.

An agreement is in place with the state of Georgia to provide available resources and equipment to support the mitigation and response to an emergency at Plant Hatch 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 Burke County 911 center, the county EOC, or through the Incident Command Post, as applicable, based on the nature and timing of the event. E9-22 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 County Emergency Response Annex 1.4.1 Georgia Counties (SEP A.2) The wording was relocated to the Site Annex. The area within the plume exposure The area in the plume exposure pathway in the state of pathway in the State of Georgia falls Georgia falls within Appling, Jeff Davis, Tattnall, and within Appling, Jeff Davis, Tattnall, and Toombs Counties. The responsibility for radiological Toombs Counties. The responsibility for emergency response planning rests with the Chairman radiological emergency response of each County Board of Commissioners, or the Mayor planning rests with each Chairman of the of a respective jurisdiction. It is this individual's County Board of Commissioners or the responsibility to initiate actions and provide direction Mayor of his respective jurisdiction. It is and control at a level consistent with the specific this individual's responsibility to initiate incident. Agencies within each county that have a actions and provide direction and control primary role in radiological emergency planning and at a level consistent with the specific response include the EMA and local law enforcement incident. Agencies within each county agencies. which have a primary role in radiological emergency planning and response include the EMA, and local law enforcement agencies. E9-23 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Local Emergency Management Agencies Annex 1.4.1 Principal activities of the LEMAs include The wording was standardized and relocated (LEMAs) the following; to the Site Annex. No change in principal Principal activities include the following:

Receive notification from HNP and GEMA. activities of the Local Agencies was made by

1. Receive notification from HNP and

Activate county resources, as necessary, to respond this submittal.

GEMA. to the emergency.

2. Activate county resources, as

Maintain communications with HNP on emergency necessary, to respond to the emergency. situation status.

3. Maintain communications with HNP on

Provide information to other county response emergency situation status. elements, the media, and the public.

4. Provide information to other county response elements, the media, and the

Activate the public notification system, if required .

public.

Activate the county EOC .

5. Activate the public notification system,

Coordinate the county emergency response activities.

if required.

6. Activate the county EOC.

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

7. Coordinate the county emergency response activities.

8. Activate and direct operations at the designated reception and care facility.

Local Law Enforcement Agencies EP 8.6.1 Local Law Enforcement Agencies The wording was standardized and relocated Principal activities include the following: Local law enforcement agencies may be called upon to to the Site Annex. No change in principal

1. Control access to the plume exposure lend assistance during the response to emergencies at activities of the Local Agencies was made by pathway EPZ. any of the SNC-operated nuclear power plants. Details this submittal.

2. Provide traffic control and law on the services offered are in the SNC plant's site-enforcement measures in the event of an specific evacuation. Annex 1.4 Local Organizations (SEP A.2, 8.6.1)

3. Act as receiver of notification from HNP Principal activities of Local Emergency Management and GEMA. Agencies (LEMA) and Local Law Enforcement Agencies (LLEA) in Georgia are described in the respective Emergency Operations Plans.

E9-24 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Others Annex 1.3 State of Georgia (SEP A.2.2) The wording was standardized and relocated Other county resources, including the Fire Upon notification of an emergency condition, the to the Site Annex. No change in principal Department, Health Department, and Georgia Emergency Management Agency will activities of the Local Agencies was made by Public Works Department, may be implement the "State of Georgia Radiological this submittal. mobilized as described in Annex A to the Emergency Plan." The Georgia Emergency Georgia RERP. Management Agency has the authority and responsibility for coordinating the efforts of local and state agencies in Georgia to provide for the health and safety of the general public in the event of a radiological incident. An agreement is in place with the state of Georgia to provide available resources and equipment to support the mitigation and response to an emergency at Plant Hatch 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 Burke County 911 center, the county EOC, or through the Incident Command Post, as applicable, based on the nature and timing of the event. E9-25 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Medical Support EP B.6.2: Agreements with ambulance services are in The commitment was relocated to the SNC Plant Hatch has established agreements place to transport injured personnel from the plants to Standard Emergency Plan and Annex with the Appling Ambulance Service and the designated medical facility. unchanged. the Meadows Regional Medical Center for Annex Section 2.3.3: Plant Hatch has established the transportation of injured personnel, agreements with the Appling County EMS and Toombs-including people who may be Montgomery County EMS for the transportation of radioactively contaminated, to hospital injured personnel, including people who may be facilities for treatment. Agreements with radioactively contaminated, to hospital facilities for the Appling General Hospital in Baxley, treatment. the Meadows Regional Medical Center in Request for medical support will be made by the control Vidalia, and a contract with a medical room or site security to the Appling County 911 center, consulting group have also been Toombs County 911, or the Incident Command Post, as established for treatment of injured and applicable, based on the nature and timing of the event. contaminated/irradiated individuals. Support provided includes, but is not limited to, emergency medical services, ambulances, and emergency medical technicians. Request for medical support will be made Annex 2.3.3 Plant Hatch has established agreements The wording was standardized and relocated by the control room or site security to the with the Appling County EMS and Toombs-Montgomery to the Site Annex. No change in principal Appling County 911 center, Appling or County EMS for the transportation of injured personnel, activities of the Local Agencies was made by Toombs County EOCs, or the Incident including people who may be radioactively this submittal. Command Post, as applicable, based on contaminated, to hospital facilities for treatment. the nature and timing of the event. Copies Request for medical support will be made by the control of these agreements are maintained in room or site security to the Appling County 911 center, the SNC document management system Toombs County 911, or the Incident Command Post, as and are included by reference in applicable, based on the nature and timing of the event. Appendix 2. E9-26 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Fire Support Annex 2.3.1 Fire Fighting (SEP B.6.4) The wording was standardized and relocated Plant Hatch has established an Plant Hatch has established an agreement with the to the Site Annex. No change in principal agreement with the Appling County EMA Appling County EMA to provide, upon request, offsite activities of the Local Agencies was made by to provide, upon request, offsite fire fire support to the HNP Fire Brigade. Support provided this submittal. support to the HNP Fire Brigade. Support includes, but is not limited to, firefighters and firefighting provided includes, but is not limited to, equipment. Request for fire support will be made by the firefighters and firefighting equipment. control room or site security to the Appling County 911 Request for fire support will be made by center, Appling County EOG, or the Incident Command the control room or site security to the Post, as applicable, based on the nature and timing of Appling County 911 center, Appling the event. County EOC, or the Incident Command Post, as applicable, based on the nature and timing of the event. A copy of this agreement is maintained in the SNC document management system and is included by reference in Appendix 2. Private Sector Organizations EP A.3.2: SNC has established an agreement with The commitment was relocated to the SNC

1. Bechtel Power Corporation Bechtel Power Corporation to obtain engineering and Standard Emergency Plan unchanged.

The licensee has established an construction services which may be required following agreement with Bechtel Power an accident. Corporation to obtain engineering and construction services which may be required following an accident. Bechtel's assistance will not be required during the early stages of the emergency response but is more likely to be requested during recovery activities.

2. General Electric Company (GE) EP A.3.4: The licensee has established an agreement The commitment was relocated to the SNC The licensee has established an with GE to obtain general services related to nuclear Standard Emergency Plan unchanged.

agreement with GE to obtain general steam supply system (NSSS) operations during and services related to nuclear steam supply following an accident situation. GE provides a capability* system (NSSS) operations during and to respond on a 24-hour-a-day basis. following an accident situation. GE provides a capability to respond on a 24-hour-a-day basis. E9-27 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36

3. Voluntary Assistance Group EP A.4 Other Utilities The SNC Standard Emergency Plan updated The licensee is a signatory to two The Institute of Nuclear Power Operations (INPO) aids wording related to industry support from the comprehensive agreements among nuclear utilities in obtaining resources beyond their Institute of Nuclear Power Operations. The electric utility companies: the Nuclear usual capabilities during recovery from an emergency. intent of the commitment is unchanged.

Power Plant Emergency Response As one of its roles, INPO will assist affected utilities by Voluntary Assistance Agreement and the applying the resources of the nuclear industry to meet Voluntary Assistance Agreement By and the needs of an emergency. Among Electric Utilities Involved in Transportation of Nuclear Materials. Federal Government Support EP 8.1.1: The Emergency Director's non-delegable The SNC Standard Emergency Plan was The resources of the Federal agencies duties include: standardized and the commitment moved appropriate to the emergency condition

Request federal assistance as needed without change in intent to the responsibilities will be made available in accordance with section or the ED.

national response plans. The ED is specifically authorized to request Federal assistance on behalf of the licensee under the provisions of this Plan. In addition to the Nuclear Regulatory Commission (NRC), other agencies which may become involved are the Department of Energy (DOE), the Federal Emergency Management Agency (FEMA), the Environmental Protection Agency (EPA), the Department of Health and Human Services, the Department of Transportation, and the Department of Agriculture. E9-28 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Concept of Operations EP B.1.1: The Emergency Director's non-delegable The SNC Standard Emergency Plan was The emergency preparedness (EP) duties include: standardized and the commitment moved program for HNP requires the coordinated

Notification of offsite agencies and approval of without change in intent to the responsibilities response of several organizations. The state, local, and NRC notifications. section or the ED.

emergency organization for HNP is described in detail in Section B of this Plan. The ED is the key individual in the HNP emergency organization; one of his nondelegable responsibilities is the decision to notify the NRC and those authorities responsible for offsite emergency measures. The interfaces among the emergency No equivalent Plan/Annex figure The responsibilities of the agencies were organizations are shown on Figure A-1. described in the SNC Standard Emergency Plan and Site Annex. The Figure was no longer informative in the organization of the Plan/Annex. Continuous Communication Capability EP E.2.1 Notification of Onsite Personnel The wording was standardized and relocated The ED initiates the activation of various The Emergency Director is responsible for classifying to the SNC Standard Emergency Plan. emergency response organizations by an event into the appropriate emergency classification contacting the State of Georgia, county and then notifying on-site personnel of the emergency EMAs, and the NRC. All of these declaration in accordance with procedures. This organizations can be contacted 24 hours notification may consist of the use of the plant a day. The State of Georgia and counties emergency alarm, announcements over the plant public surrounding HNP have a continuously address system, or activation of the recall system. manned communication link, the Notification procedures include notification of Emergency Notification Network (ENN), Emergency Response Organization Personnel (ERO) for the purpose of receiving notification of not on site or during backshift hours. ERO members a radiological emergency. The preferred will be notified by means of an automated callout contact for the county is the EMA system activated by on-shift personnel. Director. In the event of inability to contact EP E.2.2 Notification of State and local Authorities the EMA Director, the designated 24-hour A dedicated ENN will normally be used to accomplish point of contact for each county will be state and local notifications. Backup means of contacted so the county officials can be communication are described in Section F, Emergency notified. Communication, of this plan. E9-29

Enclosure 9 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 The Federal agencies which may be EP E.2.3 Notification of the Nuclear Regulatory The wording was standardized and relocated . requested by HNP to provide assistance Commission (NRC) to the SNC Standard Emergency Plan. can be notified by contacting the NRC on The NRC is notified via the ENS. If the ENS is a dedicated communication link, the inoperative, the required notification will be made using Emergency Notification System (ENS). alternate means in accordance with regulatory requirements. The Emergency Response Data System (EROS), will be initiated within one hour of the declaration of an Alert or higher classification. Specific information on the notifications to the NRC for emergency events is detailed in the reporting requirements of 10 CFR 50.72. The capability for 24-hour-per-day alerting EP F .1.2 SNC-operated plants maintain the capability to The wording was standardized and relocated and notification of offsite response make initial notifications to the designated offsite to the SNC Standard Emergency Plan. organizations and plant emergency agencies 24 hours per day. Offsite notifications can be personnel is further described in Section made to state and county warning points and E. 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. E9-30 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 State and County Operations EP A.2.2 State of Georgia The wording was standardized and relocated The State and County responses are EP A.2.2.1 Georgia Emergency Management Agency to the SNC Standard Emergency Plan. conducted in accordance with the (GEMA) following framework, as presented in the As the overall state coordinating agency GEMA will Georgia RERP: coordinate with DNR-EPD on emergency response

1. As the lead radiation emergency activities with state, county and municipal agencies and response agency, the DNR is involved in departments as stated in the Georgia Emergency virtually all peacetime radiation Operations Plan (GEOP). GEMA provides for 24-hour emergencies, regardless of severity, due notification and staffing of the State Operations Center to its assigned responsibility and the (SOC) and/or the Forward Emergency Operations probable requirements for special Center (FEOC), as required, throughout the event.

techniques, equipment, and expert GEMA is responsible for general state emergency personnel. planning and overall direction and control of emergency

2. As the designated agency to administer or disaster operations as assigned by executive order NRC Agreement State Programs, the and in accordance with the Georgia Emergency Department of Natural Resources is the Operations Plan (GEOP). GEMA has responsibilities principal radiation emergency response for coordinating the state of Georgia response to support agency due to the probable emergencies at nuclear power plants.

requirements for special techniques, EP A.2.2.2 Department of Natural Resources equipment, and expert personnel. Environmental Protection Division (DNR-EPD)

3. As the overall State coordinating Department of Natural Resources-Environmental agency, GEMA coordinates the DNR Protection Division (DNR-EPD) is assigned as the emergency response activities with State, coordinating and a primary agency responsible by County, and municipal agencies and Executive Order for implementation and administration departments, as stated in the Georgia of the state radiological and hazardous material Emergency Operations Plan. function.

4. To the extent available, local The DNR-EPD has primary responsibility for resources, personnel authority, and implementation and administration of the state emergency plans are employed in radiological emergency response function.

response to radiation emergencies. EP A.2.2.3 Other Georgia State Agencies Responsibilities of other state agencies are described in the Georgia Emergency Operations Plan (GEOP). E9-31 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 State and County Operations (cont) Annex 1.3 State of Georgia (SEP A.2.2) The wording was standardized and relocated

5. When requested to assist in response Upon notification of an emergency condition, the to the Site Annex.

and recovery efforts to radiation Georgia Emergency Management Agency will emergencies, personnel from local and implement the "State of Georgia Radiological other State agencies are normally Emergency Plan." The Georgia Emergency expected to perform functions and Management Agency has the authority and activities in which they have expertise but responsibility for coordinating the efforts of local and may perform limited radiation safety state agencies in Georgia to provide for the health and functions under the guidance of the DNR safety of the general public in the event of a radiological REC. incident.

6. In the case of occurrences of limited An agreement is in place with the state of Georgia to severity and complexity, direction and provide available resources and equipment to support control of response and recovery the mitigation and response to an emergency at Plant operations will be assumed by the DNR Hatch to include Hostile Action Based events. These REC; GEMA will be kept informed of resources include, but are not limited to, Local Law conditions in order to facilitate GEMA Enforcement Agency (LLEA) assets, firefighting assets, response and Georgia Emergency medical support resources (including transportation),

Operations Plan activation, as deemed and coordination through an Incident Command Post. necessary. Requests for offsite resources and equipment will be

7. When necessitated by the magnitude communicated from the control room to the Burke and severity of an occurrence, GEMA will County 911 center, the county EOC, or through the activate the Georgia Emergency Incident Command Post, as applicable, based on the Operations Plan and coordinate overall nature and timing of the event.

response and recovery operations, with the DNR REC coordinating radiation protection activities through the State Disaster Coordinator. The organizational structures for State No equivalent Plan/Annex figures The specific organizational structures for state and County operations are illustrated on EP F.1.2 SNC-operated plants maintain the capability to and county operations are in their respective Figures A-2 and A-3, respectively. The make initial notifications to the designated offsite Plans. The SNC Standard Emergency Plan Georgia RERP and Annex A to the Plan agencies 24 hours per day. Offsite notifications can be and Site Annex contain the description of provide the bases for a 24-hour-a-day made to state and county warning points and support expected of the agencies. radiological emergency response Emergency Operations Centers from the Control Room, capability for extended periods. Technical Support Center, and Emergency Operations Facility using the ENN. E9-32 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 TABLE A-1 No equivalent Plan/Annex figure The specific organizational structures for state RESPONSIBLE INDIVIDUALS OF and county operations are in their respective PRIMARY RESPONSE Plans. The SNC Standard Emergency Plan ORGANIZATIONS and Site Annex contain the description of support expected of the agencies. B. ONSITE EMERGENCY EP 8.1 The normal on-shift complement provides the The commitment was revised in the SNC ORGANIZATION initial response to an emergency. This group is trained Standard Emergency Plan to allow qualified Initial staffing of the onsite HNP to respond to emergency situations until the augmented personnel from other nuclear sites to be emergency organization is provided from Emergency Response Organization (ERO) arrives. integrated into the site ERO should their skills personnel normally stationed at the site. be needed. For reference throughout this section, the Annex Table 2.2.A The wording was standardized and relocated organizational chart for the HNP staff is to the Site Annex. presented in Figure B-1 If the need arises, this staff is augmented

EP 8.2 On Site Emergency Response Organization The wording was standardized and relocated substantially by the addition of other (ERO) to the SNC Standard Emergency Plan.

licensee personnel and by personnel from Augmentation of on-shift staffing will occur within 75 other organizations. minutes of the declaration of an Alert or higher classification by the Emergency Response Organization (ERO). EP Tables 1-4 This section includes a description of the EP Section 8.1 The normal onsite organization of an The wording was standardized and relocated emergency duties of the normal shift SNC-operated nuclear power plant provides a staff to the SNC Standard Emergency Plan. complement, a discussion of the manner capable of providing the initial response to an in which emergency assignments are to emergency event. The On-Shift staff was validated by be made, a listing of additional support performing a detailed staffing analysis as required by personnel upon whom the licensee can Part 50 Appendix E, IV.A.9. Organizational structures rely, and a description of the relationships for each of the sites and the On-Shift staffing tables are between onsite and offsite response provided in the Site Specific Annex. activities. E9-33 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Normal Plant Organization EP B.1 Normal Plant Organization The wording was standardized and relocated The organizational structure shown on The normal onsite organization of an SNC-operated to the SNC Standard Emergency Plan. Figure B-1 represents the pool of nuclear power plant provides a staff capable of providing personnel normally available, the initial response to an emergency event. The On-approximately 900 people. 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. Annex Table 2.2.A The operating crew for each unit includes Annex Table 2.2.A The wording was standardized and relocated one Shift Supervisor (SS), two Nuclear to the Site Annex. Plant Operators (NPOs), and two System Operators (SOs). A Shift Manager (SM) and a Shift Technical Advisor (STA) are also on shift during operation. In addition, personnel from the Health Annex Table 2.2.A The wording was standardized and relocated Physics (HP) Chemistry, Maintenance, to the Site Annex. and Security Departments are continuously onsite. Section B: Once an emergency condition EP B.1.1: The Emergency Director's non-delegable The commitment wording was standardized in is determined and initial mitigating actions duties include: the SNC system and the commitment are underway, the ED has the

Event classification in accordance with the relocated to the SNC Standard Emergency responsibility to classify the event in emergency classification system. Plan description of responsibilities for the accordance with the emergency Emergency Director.

classification system (described in Section D). Classification of an event into one of the four emergency categories [Notification of Unusual Event (NUE), Alert, Site Area Emergency, or General Emergency] E9-34 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 The extent to which the onsite HNP EP 8.1 SNC plants maintain 24-hour emergency The wording was standardized and relocated emergency organization is activated response capability. The normal on-shift complement to the SNC Standard Emergency Plan. depends upon the severity of the provides the initial response to an emergency. This situation. group is trained to respond to emergency situations until the augmented Emergency Response Organization (ERO) arrives. EP 8.2 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 (OSC), 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-hour-a-day basis for an extended event. Section B: Table B-1 provides a summary EP Tables 1-4 The wording was standardized and relocated of personnel available on shift and those Annex Table 2.2.A to the SNC Standard Emergency Plan and who would be available within Site Annex. approximately 60 min. of notification. A copy of this On-Shift Staffing Analysis, EP 8.1 The On-Shift staff was validated by performing a The wording was standardized and relocated which forms the technical basis for Table detailed staffing analysis as required by Part 50 to the SNC Standard Emergency Plan. B-1, Minimum Shift Staffing, is maintained Appendix E, IV.A.9. in the SNC document management Annex 2.2 An On-Shift Staffing Analysis was completed system. Reference OSA-HNP-001. in accordance with the requirements of 10 CFR 50 Appendix E IV.A.9. This analysis forms the basis for the on-shift staff as described in Table 2.2.A. A copy of the analysis is maintained in the SNC document management system. E9-35 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 For an NUE, the ED assigns responsibility EP .B.1.1: The Shift Manager (SM) is in direct charge of The commitment wording was standardized. for making the appropriate notifications shift plant operations and is .directly responsible for the The SM acting as Emergency Director and directing the proper response; but no actions of the on-shift crew. In an emergency, the SM maintains the authority for all actions of further activation of the emergency assumes the responsibility of the Emergency Director Section B. organization is required. (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 implementin'g off site emergency measures. If the event is classified as an Alert, the EP H.1: SNC-operated nuclear power plants have The commitment wording was standardized Technical Support Center (TSC) and the established a TSC and an onsite OSC, which are staffed within SNC and the activation at Alert or Operations Support Center (OSC) are and activated within 75 minutes of the declaration of an higher transferred to the SNC Standard activated. Alert or higher classification .. Emergency Plan unchanged. This License Amendment Requests includes the request to modify augmentation times to 75 minutes and is justified in the technical analysis section of this LAR Figure B-2 shows the emergency EP Figure 8.2.8, 8.2.C, S.2.D, and 8.2.E: Illustrates The Emergency Response Organization was organization when fully activated. the standard Emergency Organization at all three sites. standardized within the three SNC sites. This License Amendment Requests includes approval of the standardized ERO. The ERO re-organization is justified in the technical analysis section of this LAR Corporate personnel who may report to EP 0.4.1: ERO members will receive Emergency Plan The commitment wording was standardized in the plant site are provided the necessary training on an annual basis. the SNC Standard Emergency Plan. The training and are integrated into the HNP EP 0.4: SNC ERO personnel who are responsible for SNC Standard Emergency Plan provides the emergency organization, as necessary. implementing this plan receive specialized training. The equivalent commitment for Corporate training program for emergency response personnel is personnel participating in the ERO to receive developed based on the requirements of 10 CFR 50, initial and annual retraining. Appendix E, and position-specific responsibilities. E9-36 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Relationships among the HNP emergency No equivalent Plan/Annex figure The SNC Standard Emergency Plan and organization and other elements of Annex describe the elements of response. emergency response are shown on The Figure is no longer needed in the Plan. Figure A-1. During hostile action, ERO members Annex 5.1.4 Alternative Facility (SEP H.1.4) The wording was standardized and relocated would likely not have access to the onsite During a security-related event or other event that to the Site Annex. emergency response facilities. A security precludes onsite access, the TSC and OSC ERO will be related emergency may delay the directed to an alternative facility. This facility is located ordering of facility activation in order to adjacent to the Georgia Power Company operating protect plant personnel from the security headquarters in Vidalia, Georgia and is approximately threat. The decision to delay activation of 22 miles from HNP. The alternative facility is equipped the facilities will be made by the with the necessary communications and data links to Emergency Director. In such cases, support communications with the control room, site offsite ERO personnel will be directed to security, and the EOF. an alternative facility to minimize delays in The available communications and data links also overall site response by permitting ERO provide access to SNC document management assembly without exposing responders to resources,* and to work planning resources for the danger of hostile action. performing engineering assessment activities including damage control team planning, and preparation for return to the site. Guidance for use of the facility is in site procedures. Emergency Organization Responsibilities EP Figure B.2.B, B.2.C, B.2.D, and B.2.E: Illustrates The Emergency Response Organization was Following an Alert or higher emergency the standard Emergency Organization at all three sites. standardized within the three SNC sites. The declaration, the positions shown on EP H.1: SNC-operated nuclear power plants have intent to activate facilities at an Alert or higher Figure B-2 will be filled by emergency established a TSC and an onsite OSC, which are staffed was relocated without change to the SNC response personnel as discussed below. and activated within 75 minutes of the declaration of an Standard Emergency Plan. Alert or higher classification .. This License Amendment Requests includes approval of the standardized ERO. The ERO re-organization is justified in the technical analysis section of this LAR. E9-37 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36

1. ED EP 8.1.1: The Shift Manager (SM) is in direct charge of The commitment wording is standardized and The ED has the authority, management shift plant operations and is directly responsible for the relocated to the SNC Standard Emergency ability, and knowledge to assume the actions of the on-shift crew. In an emergency, the SM Plan without change in_ intent.

overall responsibility for directing HNP assumes the responsibility of the Emergency Director staff in an emergency situation. (ED) and takes necessary actions fo 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 acti()ns, including providing notification of Protective Action Recommendations (PAR) to state and local government organizations responsible for implementing off site emergency measures. Initially this position is filled by the SM or EP B.1.1: The Shift Manager (SM) is in direct charge of The commitment wording is standardized and any ED qualified SS. shift plant operations and is directly responsible for the relocated to the SNC Standard Emergency actions of the on-shift crew. In an emergency, the SM Plan without change in intent. assumes the responsibility of the Emergency Director (ED) and takes necessary actions to identify and re~pond to the emergency until relieved by another qualified ED. The ED has the responsibility and authority to immediately and unilaterally initiate emergency actions, including providing notification of

                                              . Protective Action Recommendations (PAR) to state and local government organizations responsible for implementing off site emergency measures.

Section B.1: Any of these persons will EP 0.1 The ERO Training Program ensures the The commitment wording was standardized assume the ED position until the Plant training, qualification, and requalificatior;i of individuals with the SNC Standard Emergency Plan. Manager, the Site Support Manager, the who may be called on for assistance during an Specific titles were modified to allow flexibility Operations Manager, the Engineering emergency. Specific emergency response task training, in assignment of management resources. Director, the Maintenance Manager, the prepared for response positions, is described in lesson The intent of the commitment is maintained Vice President-Hatch, or other qualified plans and study guides. . unchanged.

EDs can arrive onsite and receive an adequate turnover.

E9-38 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 The ED manages the following activities EP 8.1.1 The Emergency Director's non-delegable The wording was standardized and relocated for the duration of the emergency: duties include: to the SNC Standard Emergency Plan.

Notification and communication: directs
Event classification in accordance with the the notification of HNP and licensee emergency classification system.

personnel and communications with

Perform the duties and responsibilities of Protective offsite authorities regarding all aspects of Action Recommendation (PAR) determination.

emergency response.

Notifications of offsite agencies and approval of
Emergency resQonse facilities (ERF): state, local, and NRC notifications.

oversees the activation and staffing and requests additional assistance, as

Authorization of emergency exposures in excess of federal limits.

needed.

Emergency OQerations: has authority
Issuance of potassium iodide (Kl) to plant employees as a thyroid blocking agent.

over those actions taken to mitigate the emergency condition or reduce the threat

Request federal assistance as needed .

to the safety of plant personnel or the public, including the recommendation of protective actions to offsite authorities.

Emergency services: provides overall direction for management of procurement of site-needed materials, equipment, and supplies; documentation; accountability; and security functions.
Emergency OQerations Qlanning:

provides overall direction for the management of planning for procedure, equipment, and system development to support emergency operations.

Discretionary authority: may tailor the emergency organization to fit the specific staffing needs on a case-by-case basis.

E9-39 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 The ED may not delegate the following EP 8.1.1 The Emergency Director's non-delegable The wording was standardized and relocated responsibilities: duties include: to the SNC Standard Emergency Plan.

The decision to notify offsite emergency
Event classification in accordance with the response agencies. emergency classification system.;
The decision to recommend protective
Perform the duties and responsibilities of Protective actions to offsite authorities. Action Recommendation (PAR) determination.
Declaration of emergency
Notifications of offsite agencies and approval of '

classifications. state, local, and NRC notifications.

Authorization for plant personnel to exceed 10 CFR 20 radiation exposure
Authorization of emergency exposures in excess of federal limits.

limits.

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

emergency.

The decision to request Federal
Request federal assistance as needed .

assistance.

The decision to dismiss nonessential personnel from the site at an Alert classification level or higher.
Authorization of the use of potassium iodide.

The ED may operate from the Control EP 8.1.1 The Shift Manager (SM) is in direct charge of The wording was standardized and relocated Room or the TSC at his discretion. He shift plant operations and is directly responsible for the to the SNC Standard Emergency Plan. may act as the TSC Manager during the actions of the on-shift crew. In an emergency, the SM early phases of emergency response, as assumes the responsibility of the Emergency Director needed. It is the intent of SNC that the ED (ED) and takes necessary actions to identify and will be transferred from the Control Room respond to the emergency until relieved by another as soon as practicable. qualified ED. EP Figure B.2.A E9-40 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 It is the intent of SNC that the ED will be EP 8.1.1 The Shift Manager (SM) is in direct charge of The wording was standardized and relocated transferred from the Control Room as shift plant operations and is directly responsible for the to the SNC Standard Emergency Plan. soon as practicable. 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. EP Figure B.2.A TSC Staff EP 8.2.1.2 TSC Manager The SNC Standard Emergency Plan provides

a. TSC Manager The TSC Manager reports. to the TSC ED and is standardized description of the position The TSC Manager performs the following responsible for coordinating activities between the TSC responsibilities. The intent of the position was activities: and other emergency response facilities, directing the not changed.

Coordinates inputs and activities of the TSC staff, and ensuring communications recommendations from technical and are established with applicable offsite agencies.

corrective action advisors.

Directs onsite HNP emergency personnel involved in restoration of the plant to a safe condition.
Provides technical assistance and operations guidance to Control Room personnel.
Directs TSC staff in analysis of problems, design and planning for temporary modifications, and development of temporary emergency operating procedures (EOP).
Recommends protective actions to the ED based on plant conditions.
Provides the ED recommendations on emergency classifications.

E9-41 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36

b. Support Coordinator (TSC) EP 8.2.1.15 TSC Support Coordinator The SNC Standard Emergency Plan provi<;les The Support Coordinator in the TSC The Support Coordinator reports to the TSC Manager . standardized description of the position directs the clerical and logistic and directs the clerical and logistic activities in the TSC, responsibilities. The intent of the position was activities in the TSC. He ensures ensures support staff, including clerks, status board not changed.

support staff, including Clerks and keepers, and communie<ators, are available in sufficient numbers, and ensures office supplies, drawings, and Communicators/Recorders, are other documents are available to TSC .and OSC available in sufficient numbers and personnel. that office supplies, drawings, and other documents are available to TSC personnel. He ensures transportation and communication needs are satisfied. When the EOF is activated, the Support

c. Engineering Supervisor EP 8.2.1.7 TSC Engineering Supervisor The SNC Standard Emergency Plan provides The Engineering Supervisor directs a staff The Engiheering Supervisor reports to the TSC standardized description of the position of engineers with expertise in reactor Manager. The TSC Engineering Supervisor is responsibilities. The intent of the position was engineering, thermal and hydraulic responsible for the overall direction of Engineering not changed.

analysis, instrumentation and control, and Group activities and assessment. The Engineering mechanical and electrical systems. He Supervisor also directs the analysis of plant problems directs the analysis of plant problems and and core damage, and provides recommendations for provides recommendations for plant plant modifications to mitigate the effects of the modifications to mitigate the effects of the accident. accident.

d. Maintenance Supervisor EP 8.2.1.4 TSC Maintenance Supervisor The SNC Standard Emergency Plan provides The Maintenance Supervisor manages The Maintenance Supervisor reports to the TSC standardized description of the position the planning and coordination of repair, Manager and is responsible for planning and responsibilities. The intent of the position was damage control, and plant modification coordination of repair, damage control, and plant not changed.

activities. He works closely with the modification activities. The Maintenance Supervisor Engineering Supervisor in planning for works closely with the Engineering Supervisor in plant modifications and repairs. planning f~r plant modifications and repairs. E9-42 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36

e. Operations Supervisor EP 8.2.1.3 TSC Operations Supervisor The SNC Standard Emergency Plan provides The Operations Supervisor analyzes The Operations Supervisor reports to the TSC Manager. standardized description of the position problems associated with systems Major position functions include evaluating plant responsibilities. The intent of the position was operations and provides conditions and initiating mitigation actions, coordinating not changed.

recommendations for procedures for TSC efforts in determining the nature and extent of plant mitigating the emergency situation. conditions affecting plant equipment, actions to limit or contain the emergency, invoking the provisions of 10 CFR 50.54(x) if appropriate, assisting the OSC Manager in determining the priority assigned to OSC activities, , and timely completing offsite notifications.

f. HP/Chem Supervisor EP 8.2.1.5 TSC Radiation Protection (RP) Supervisor The wording was standardized and relocated The HP/Chem Supervisor makes The RP Supervisor reports to the TSC Manager and to the SNC Standard Emergency Plan.

radiological accident assessments and supervises the activities of the radiation protection staff provides support for analyzing and Health Physics Network (HPN) Communicator. The The title was changed to reflect current site radiological changes during the event. RP Supervisor assists the Radiation terminology. Protection/Chemistry Group Lead in the OSC in determining the extent and nature of radiological or hazardous conditions and coordinates offsite dose assessment and offsite Field Monitoring Teams prior to EOF activation.

g. Security Supervisor EP 8.2.1.14 TSC Security Supervisor The SNC Standard Emergency Plan provides The Security Supervisor has the following The Security Supervisor reports to the TSC Manager. standardized description of the position responsibilities: The TSC Security Supervisor is responsible for carrying responsibilities. The intent of the position was

Processing of personnel who require out the plant security and Access Control program, not changed.

authorization to enter the site. maintaining personnel accountability onsite, and

Requesting assistance through the ED assisting in evacuation of onsite areas.

from civic law enforcement authorities, if required.

Ensuring site accountability and access control are maintained.

E9-43 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 OSC Staff EP B.2.2.1 OSC Manager The SNC Standard Emergency Plan provides

a. OSC Manager The OSC Manager reports to the TSC Manager and standardized description of the position The OSC Manager receives direction directs a staff in providing labor, tools, protective responsibilities. The intent of the position was from the TSC to dispatch emergency equipment, and parts needed for emergency repair, not changed.

teams (e.g., firefighting, rescue, first aid, damage control, firefighting, search and rescue, first aid, repair, etc.) to prescribed areas of the and recovery. plant or site. The OSC Manager directs composition of the teams to ensure appropriately qualified personnel are assigned. In particular, he ensures proper HP coverage is provided. The OSC Manager ensures specific instructions are provided to the team leaders and maintains communications with the teams to monitor the status of their activities.

b. OSC Personnel EP B.2.2.7 OSC Personnel The wording was standardized and relocated Selected personnel report to the OSC, as Selected personnel report to the OSC, as directed. to the SNC Standard Emergency Plan.

directed. Emergency personnel from the Emergency personnel from the Maintenance, Maintenance, the Operations, and the Operations, and RP/Chemistry Departments are The fire brigade is identified as part of the on-HP/Chemistry Departments are directed directed to report to the OSC. OSC teams are headed shift functional capabilities subsequently to report to the OSC. The following by a designated team leader, who maintains supported by offsite response. emergency teams are formed, as communication with the OSC. The following emergency necessary: teams may be formed by OSC personnel, as necessary:

Fire brigade.
Search and rescue .
Search and rescue.
Repair .
Repair.
Post-accident sampling .
Post-accident sampling.
Internal survey.
Internal survey .
Field monitoring.
Field monitoring .
Rally point.

E9-44 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Each OSC team is headed by a EP 8.2.2.7 OSC Personnel The wording was standardized and relocated designated team leader, who maintains Selected personnel report to the OSC, as directed. to the SNC Standard Emergency Plan. communication with the OSC. Emergency personnel from the Maintenance, Operations, and RP/Chemistry Departments are directed to report to the OSC. OSC teams are headed by a designated team leader, who maintains communication with the OSC. The field monitoring teams are dispatched EP 1.7 Field Monitoring Teams are dispatched by SNC- The wording was standardized and relocated to the Simulator Building to prepare for operated plants to perform a variety of functions in to the SNC Standard Emergency Plan. field monitoring activities. situations potentially involving significant releases of radioactive materials from a plant. These teams are under the control of the EP 8.2.1.5 TSC Radiation Protection (RP) Supervisor The wording was standardized and relocated on-shift HP/Chem Foreman until relieved The RP Supervisor reports to the TSC Manager and to the SNC Standard Emergency Plan. by the HP/Chem Supervisor in the TSC or supervises the activities of the radiation protection staff the Dose Assessment Supervisor in the and Health Physics Network (HPN) Communicator. The The title was changed to reflect current site EOF. RP Supervisor assists the Radiation terminology. Protection/Chemistry Group Lead in the OSC in determining the extent and nature of radiological or hazardous conditions and coordinates offsite dose assessment and offsite Field Monitoring Teams prior to EOF activation. EOF Staff EP 8.3.1 EOF Organization The SNC Standard Emergency Plan The description of the EOF staff positions integrates the EOF organization into the is contained in Appendix 7. overall ERO. See Appendix 7 section of the Justification Matrix for the detailed evaluation of the EOF positions. E9-45 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Emergency Organization Assignments EP B.2: A sufficient number of personnel are qualified The wording was standardized and relocated Table 8-2 identifies by title the individuals to ensure that positions listed in this section can be to the SNC Standard Emergency Plan. who will fill the key emergency positions. staffed on a 24-hour-a-day basis for an extended event. No individual listed in Table 8-2 is Figures 8.2.8 through 8.2.E illustrate the overall identified as the primary candidate for augmented emergency response organization. more than one emergency position. Some primary candidates are identified as alternates for other emergency positions. It is expected that one person may occupy up to two emergency positions within the same emergency. During the first 6 hours of an emergency, EP B.2: A sufficient number of personnel are qualified The wording was standardized and relocated the emergency response positions will be to ensure that positions listed in this section can be to the SNC Standard Emergency Plan. manned by qualified available personnel. staffed on a 24-hour-a-day basis for an extended event. A sufficient number of people are Figures 8.2.8 through 8.2.E illustrate the overall identified to ensure that all emergency augmented emergency response organization. positions listed on Table 8-2 will be filled on a 24-hour-a-day basis. E9-46 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Alternative Facility Staff Annex 5.1.4 Alternative Facility (SEP H.1.4) The wording was standardized and relocated The ERO staff will be directed to report to During a security-related event or other event that to the Site Annex. the Alternative Facility during a security precludes onsite access, the TSC and OSC ERO will be related event or other events that directed to an alternative facility. This facility is located preclude onsite access. This facility adjacent to the Georgia Power Company operating functions as a staging area for headquarters in Vidalia, Georgia and is approximately augmentation of emergency response 22 miles from HNP. The alternative facility is equipped staff and provides the capability for with the necessary communications and data links to communication with the EOF, control support communications with the control room, site room, and plant security. From this facility security, and the EOF. the ERO will support event response by The available communications and data links also performing engineering assessment provide access to SNC document management activities, including damage control team resources, and to work planning resources for planning and preparation for return to the performing engineering assessment activities including site. The command and control function damage control team planning and preparation for will remain with the ED in the control return to the site. Guidance for use of the facility is in room until relieved by another onsite ED. site procedures. Dose assessments and offsite notifications will be performed by the EOF. Other Support Services EP A.3.2: SNC has established an agreement with The wording was standardized and relocated

1. Contractor Support Bechtel Power Corporation to obtain engineering and to the SNC Standard Emergency Plan.

Arrangements have been made to obtain construction services which may be required following support services from Bechtel Power an accident. Corporation, and GE, if required. E9-47 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Support capability has been available EP A.3.1 Southern Nuclear Operating Company (SNC) The wording was standardized and relocated through the joint efforts of the SNC Southern Nuclear Operating Company (SNC) serves as to the SNC Standard Emergency Plan. corporate office staff and Southern the architect-engineer. Company Services (SCS) architect- EP B.4.1 Vendors and Contractors engineering and service company. As a Major equipment providers or Architect-Engineers result of the consolidation of SCS and include Westinghouse Electric Corporation, General SNC nuclear expertise, and in addition to Electric Corporation, and Bechtel Power Corporation, being the licensee, SNC also serves as which can provide the following assistance in an its own architect/engineer and performs emergency: the functions previously performed by

Trained personnel.

SCS.

Technical analysis.
Operational analysis.
Accident and transient analysis.

The EOF Support Coordinator initially EP B.3.1.12 EOF Offsite Response Coordinator The wording was standardized and relocated contacts these organizations to arrange The Offsite Response Coordinator reports to the EOF to the SNC Standard Emergency Plan. for the required assistance. Manager. The duties and responsibilities of the Offsite Response Coordinator include coordination of activities The title was changed to better describe the for the dispatch and update of technical liaisons to state expected responsibilities. and local authorities and monitoring EOF functional areas to facilitate coordination between the licensee and state and local agencies. E9-48 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36

2. Medical Assistance EP 8.6.3 Medical Services The wording was standardized and relocated Agreements are in place with the Appling Prior arrangements have been made for medical to the SNC Standard Emergency Plan and General Hospital, the Meadows Regional treatment at a variety of faciiities. SNC-operated Site Annex.

Medical Center, and the Appling and nuclear power plants are supported, and sites offer Toombs Counties Ambulance Services training to the medical staff in dealing with contaminated (Appendix 2) and a contract with a injured personnel. Details on the services offered are in medical consulting group to provide the SNC plant's site-specific Annex. assistance for injured personnel, including Annex 5.8.1 Hospital and Medical Support (SEP B.6.3, cases involving radioactive L.1) contamination. This assistance is Arrangements for_ treating radiologically contaminated requested whenever necessary in and/or irradiated patients have been made with the accordance with plant procedures. Appling Healthcare System, located approximately 11 miles south of the site, and Meadows Regional Medical Center, located approximately 22 miles north of the site. Each hospital has a radiation emergency area separate from the rest of the complex. Each area contains facilities and equipment for emergency surgery, personnel dosimetry, decontamination, radioactive waste recovery, and portable shields for attendant exposure control. These facilities enable the emergency treatment and the handling of contaminated individuals. Non-contamination injuries will be handled by the hospital with its routine facilities.

3. Offsite Fire Assistance Annex 2.3.1 Fire Fighting (SEP B.6.4) The wording was standardized and relocated Agreements are in place with the Appling Plant Hatch has established an agreement with the to the Site Annex.

County EMA to provide onsite HNP Fire Appling County EMA to provide, upon request, offsite Brigade in the unlikely event of a fire fire support to the HNP Fire Brigade. Support provided requiring offsite assistance. This includes, but is not limited to, firefighters and firefighting assistance is requested according to plant equipment. Request for fire support will be made by the procedures. control room or site security to the Appling County 911 center, Appling County EOC, or the Incident Command Post, as applicable, based on the nature and timing of the event. E9-49 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36

4. Agency Support EP Section C Once an emergency has been declared, The wording was standardized and relocated Assistance may be requested from the the Emergency Director (ED) has the authority and to the SNC Standard Emergency Plan.

State of Georgia or the Federal agencies. responsibility to request aid from offsite organizations, Section A of this Plan describes the whether they are other SNC-operated nuclear power assistance that may be requested. Any plants, federal, state, local, or private organizations. requests for aid are made by the ED. Interfaces Among ResQonse GrouQS No equivalent Plan/Annex figure The SNC Standard Emergency Plan and Section A, Figure A-1, illustrates the Annex now specifically describe the integrated organization for response to an responsibilities of the various response emergency at HNP. groups. Figure A-1 is no longer required. TABLE B-1 Annex Table 2.2.A The wording was standardized and relocated MINIMUM STAFFING CAPACITY FOR to the Site Annex. EMERGENCIES TABLE B-2 EP 0.1 To achieve and maintain an acceptable level of The wording was standardized and relocated EMERGENCY ORGANIZATION emergency preparedness, training will be conducted for to the SNC Standard Emergency Plan. ASSIGNMENTS members of the Emergency Response Organization (ERO) and those offsite organizations that may be called on to provide assistance in the event of an emergency. Training will be evaluated in accordance with the requirements of Systematic Approach to Training practices to ensure effectiveness and in order to identify weak or deficient areas that. need correction. The ERO Training Program ensures the training, qualification, and requalification of individuals who may be called on for assistance during an emergency. FIGURE B-1 EP Figure P.1 The wording was standardized and relocated TYPICAL HNP ORGANIZATION CHAR to the SNC Standard Emergency Plan. FIGURE B-2 EP B.2: Figures B.2.B through B.2.E illustrate the The wording was standardized and relocated TYPICAL ALERT, SITE AREA OR overall augmented emergency response organization. to the SNC Standard Emergency Plan. GENERAL EMERGENCY RESPONSE ORGANIZATION E9-50 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 C. EMERGENCY RESPONSE Annex 1.3 State of Georgia (SEP A.2.2) The wording was standardized and relocated SUPPORT AND RESOURCES Upon notification of an emergency condition, the to the Site Annex. State and Local Governmental Support Georgia Emergency Management Agency will The State of Georgia through the GEMA implement the "State of Georgia Radiological has the lead agency .responsibility for Emergency Plan." The Georgia Emergency responding to emergency situations Management Agency has the authority and throughout Georgia. Under the procedure responsibility for coordinating the efforts of local and established by the Natural Disaster state agencies in Georgia to provide for the health and Operation Plan, which was developed safety of the gener~I public in the event of a radiological pursuant to the Governor's Executive incident. Order, the DNR radiological emergency An agreement is in place with the state of Georgia to response team, under the direction of provide available resources and equipment to support GEMA, assesses the radiological the mitigation and response to an emergency at Plant conditions at the site of an incident and Hatch to include Hostile Action Based events. These determines whether a state of emergency resources include, but are not limited to, Local Law exists. Upon GEMA's advising the Enforcement Agency (LLEA) assets, fire fighting assets, Governor of the State of Georgia that a medical support resources (including transportation), radiological emergency exists, the and coordination through an Incident Command Post. Governor declares an emergency Requests for offsite resources and equipment will be condition which activates the GEMA. The communicated from the control room to the Burke LEMAs may activate independently or County 911 center, the county EOC, or through the prior to the Governor's declaration of a Incident Command Post, as applicable, based on the state of emergency. However, the LEMA nature and timing of the event. must be activated in conjunction with the GEMA activation. [(Reference the State of Georgia RERP).] E9-51 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 The concept of operations for which the Annex 1.3 State of Georgia (SEP A.2.2) The wording was standardized and-relocated State of Georgia discharges this Upon notification of an emergency condition, the to the Site Annex. responsibility, together with a discussion Georgia Emergency Management Agency will of action responsibilities assigned to implement the "State of Georgia Radiological various State/County governmental Emergency Plan." The Georgia Emergency agencies is contained in the State of Management Agency has the authority and Georgia REP, and Annex A to the REP, responsibility for coordinating the efforts of local and HNP. For a complete discussion of state agencies in Georgia to provide for the health and authority, assigned responsibilities, safety of the general public in the event of a radiological capabilities, and activation and incident. communication arrangements, refer to An agreement is in place with the state of Georgia to these plans. provide available resources and equipment to support the mitigation and response to an emergency at Plant Hatch to include Hostile Action Based events. These resources include, but are not limited to, Local Law Enforcement Agency (LLEA) assets, fire fighting assets, medical support resources (including transportation), and coordination through an Incident Command Post. Requests for offsite resources and equipment will be communicated from the control room to the Burke County 911 center, the county EOC, or through the Incident Command Post, as applicable, based on the nature and timing of the event. E9-52 to-NL-16:..0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Agreements are in place with the State of Annex 1.5 Hostile Action Based Events (SEP H.1.4)

The wording was standardized and relocated Georgia, Appling County, Toombs Agreements are in place with the.state of Georgia and to the Site Annex.

County, Tattnall County, and Jeff Davis counties of Appling, Jeff Davis, Tattnall, and Toombs to County to provide available resources provide available resources and equipment to support and equipment to support the mitigation mitigation and response to an emergency at Edwin I. and response to an emergency at Plant Hatch Nuclear Plant, including Hostile Action Based Hatch to include Hostile Action Based events. These resources include, but are not limited to, events. These resources include, but are Local Law Enforcement Agency (LLEA) assets, not limited to, Local Law Enforcement .firefighting assets, medical support resources (including Agency (LLEA) assets, Fire Fighting transportation), and coordination through an Incident assets, medical support resources Command Post. Requests for offsite resources and (including transportation), and equipment will be communicated from the control room coordination through an Incident or site security to Appling County 911 Center, the Command Post. Requests for offsite county EOCs, or through the Incident Command Post resources and equipment will be as applicable based on the nature of the event. Copies communicated from the control room to of these agreements are maintained in accordance with the Appling County 911 center, the county Emergency Plan procedures. EOCs, or through the Incident Command Post, as applicable, based on the nature and timing of the event. Copies of these agreements are maintained in the SNC document management system and are included by reference in Appendix2 It is expected that a few State EP 8.3.1.15 EOF Liaisons The wording was standardized and relocated representatives, including one skilled in Liaisons report to the Offsite Response Coordinator and to the SNC Standard Emergency Plan. making dose calculations and radiological respond to the applicable state and county Emergency assessments, will be dispatched to the Operations Centers (EOCs) as required by the type and EOF. The licensee will send a technical source of the event. Liaisons are assigned to Georgia, representative to the offsite governmental Alabama and/or South Carolina state EOCs depending centers, as needed or as requested. on which SNC site declared the initiating event. EP H.2.1 SNC will maintain space for members of an NRC Site Team. E9-53 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Federal Governmental Support No direct statement in Plan/Annex. The wording was standardized and relocated In addition to coordination with EP A.1 Primary Federal Organizations to the SNC Standard Emergency Plan. State/County governmental entities in an EP A.3.5 Radiological Monitoring Assistance emergency situation, the licensee may Radiological monitoring in the plant arid in the environs, require assistance from certain Federal both onsite and offsite, will be augmented by outside agencies in the areas of communications, Vendors as necessary. Initial radiological monitoring will radiological monitoring and laboratory be performed by available Southern. Company analysis, transportation, and disaster resources (e.g., Georgia Power Company (GPC) relief. Central Laboratory). EP A.3.6 Contract Laborato~ies SNC-operated plants maintain contracts with offsite laboratories to assist with emergency analytical services. Copies of these contracts are maintained in accordance with Emergency Plan procedures. Requests for Federal assistance are EP B.1.1 The Emergency Director's non-delegable The wording was standardized and relocated directed, as needed, by the ED, and duties include: to the SNC Standard Emergency Plan. usually these requests are channeled

Request federal assistance as needed.

through GEMA. The exceptions to this procedure are direct contacts between the licensee Emergency Organization and the NRG. In the event of an incident in which EP B.1.1 The Emergency Director's non-delegable The wording was standardized and relocated Federal assistance is needed to duties include: to the SNC Standard Emergency Plan. supplement State/County emergency

Request federal assistance as needed.

response capabilities, principal points of contact for State government are as follows:

The FEMA, Region Headquarters in Atlanta.
The DOE, Region Operations Office in Aiken, South Carolina.
The EPA, Region Headquarters in Atlanta.

E9-54 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 The FEMA is assigned lead responsibility EP A.1.3 Federal Emergency Management Agency The wording was standardized and relocated for Federal offsite nuclear emergency (FEMA) to the SNC Standard Emergency Plan. planning and response (per Title 44 CFR The primary role of FEMA is to support the states by 351). FEMA is also delegated coordinating the delivery of federal non-technical responsibility for development and assistance. FEMA coordinates state requests for promulgation of the Federal Radiological federal assistance, identifying which federal agency can Emergency Response Plan (FRERP) best address specific needs. If deemed necessary, which assumes states will be responsible FEMA will establish a nearby Joint Field Office from for overall management of offsite which it will manage its assistance activities. emergency response. The Federal government's role consists of providing technical and/or logistical resource support at the request of State emergency management. Federal emergency response consists of No direct statement in Plan/Annex. The wording was standardized and relocated technical and nontechnical components. EP A.1.1 Nuclear Regulatory Commission (NRC) to the SNC Standard Emergency Plan. The NRC and FEMA jointly coordinate The NRC is the coordinating agency for incidents at or federal emergency response actions. caused by a facility or an activity that is licensed by the NRC or an Agreement State, with the Chairman of the Commission as the senior NRC authority for response. The Chairman can transfer control of emergency response activities when deemed appropriate. EP A.1.3 Federal Emergency Management Agency (FEMA) The primary role of FEMA is to support the states by coordinating the delivery of federal non-technical assistance. FEMA coordinates state requests for federal assistance, identifying which federal agency can best address specific needs. If deemed necessary, FEMA will establish a nearby Joint Field Office from which it will manage its assistance activities. E9-55 to NL-16-0169 Hatch Justification Matrix. Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 The NRC coordinates technical aspects, No direct statement in Plan/Annex. The wording was standardized and relocated and FEMA coordinates nontechnical EP A.1.1 Nuclear Regulatory Commission (NRC) to the SNC Standard Emergency Plan. aspects of Federal response. The NRC is the coordinating agency for incidents at or caused by a facility or an activity that is licensed by the NRC or an Agreement State, with the Chairman of the Commission as the senior NRC authority for response. EP A.1.3 Federal Emergency Management Agency (FEMA) The primary role of FEMA is to support the states by coordinating the delivery of federal non-technical assistance. The NRC and FEMA have stated that No equivalent Plan/Annex statement. Section H of the SNC Standard Emergency they each expect to have a representative Plan and Site Annex describe the space at HNP within approximately 3 hours after made available to federal responders. receiving notification. DOE can give assistance within approximately 2 hours. Airfields within the plant vicinity that may No equivalent Plan/Annex statement. Section H of the SNC Standard Emergency be used to support the Federal response, Plan and site annex describe the space made as well as that of other response groups, available to federal responders. include a commercial airport with scheduled service and nearby municipal airports that can accommodate small aircraft. The approximate distance and direction to these airfields are as follows: (List of Airfields and distance from site not included for simplicity) Licensee Support EP H.1.2: SNC operated nuclear power plants have The wording was standardized and relocated The licensee provides space; telephone established a TSC for use during emergency situations to the SNC Standard Emergency Plan and communications, and administrative by plant management, technical, and engineering support Site Annex. services for up to five NRC personnel at personnel. the TSC. Annex 5.1.2: The TSC provides plant management and technical support personnel, including NRC personnel, with adequate space to assist plant operating personnel located in the Control Room_during an emergency. Annex Figure 5.1.A: TSCLayout E9-56 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Accommodations for the NRC, State of EP H.2.1 The EOF is capable of accommodating The wording was standardized and relocated Georgia, and FEMA representatives in designated SNC personnel and offsite local, state, and to the SNC Standard Emergency Plan. the EOF are described in Appendix 7. 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). Other Support EP C.3.2 Contract Laboratories The wording was standardized and relocated The licensee expect~ services to be Additional outside analytical assistance may be to the SNC Standard Emergency Plan. available from qualified organizations to requested from contracted vendors. These laboratories provide radiochemical laboratory analysis, provide bioassay analysis and radiochemical analysis environmental monitoring assistance, and services medical support services should a serious EP C.4.1 This provides a mechanism to draw on emergency occur. industry resources during an emergency. Support may also be requested from neighboring utilities for the following:

Personnel and equipment to assist with in-plant and emergency field monitoring.
Engineering, design, and technical expertise to assist in determining the cause of the accident and to support recovery.
Personnel and equipment to assist in maintenance and repairs to the facility.

Other private organizations that supply EP C.4.2.3 Nuclear Steam Supply System Vendor The wording was standardized and relocated engineering, HP, and general emergency Under established contracts, the following will supply to the SNC Standard Emergency Plan. support are as follows: available engineering expertise, specialized equipment,

GE, Wilmington, NC and San Jose, and other services identified as needed and deemed California. appropriate to provide in an emergency situation:
General Electric (GE) Nuclear Energy,
Westinghouse Electric Company, E9-57 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36
Institute of Nuclear Power Operations EP C.4.1 SNC-operated plants are a signatory to two The wording was standardized and relocated (INPO), Atlanta, Georgia. comprehensive agreements among electric utility to the SNC Standard Emergency Plan.

companies:

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

The NSSSs for the plant were purchased EP C.4.2.3 Nuclear Steam Supply System Vendor The wording was standardized and relocated from GE, who continues to provide Under established contracts, the following will supply to the SNC Standard Emergency Plan. operations support to the company in available engineering expertise, specialized equipment, plant modifications, licensing, and and other services identified as needed and deemed engineering. appropriate to provide in an emergency situation:

General Electric (GE) Nuclear Energy.
Westinghouse Electric Company.

As a member of INPO, the licensee is EP C.4.1 SNC-operated plants are a signatory to two The wording was standardized and relocated provided with INPO's Emergency comprehensive agreements among electric utility to the SNC Standard Emergency Plan. Response Manual. This manual identifies companies: the various organizations (utilities, service

Nuclear Power Plant Emergency Response companies, and reactor vendor) that Voluntary Assistance Agreement.

could be expected to provide resources in

Voluntary Assistance Agreement By and Among response to a request for emergency Electric Utilities Involved in Transportation of support. Nuclear Materials.

As referenced throughout this Plan, a EP C.4.2 Offsite resources The wording was standardized and relocated number of offsite licensee departments SNC supports the sharing of personnel and resources to the SNC Standard Emergency Plan. and the Southern Company companies among SNC-operated nuclear power plants, providing a may be involved in the emergency large personnel and equipment base. response effort. These departments have, where appropriate, developed separate nuclear emergency response plans and procedures governing their emergency functions. Coordination of these plans to ensure a consistent integrated response is the responsibility of the SNC. E9-58 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 These specific plans include: Annex Appendix C - Supporting Plans & Implementing The wording was standardized and relocated

HNP Emergency Communication Plan, Procedures (SEP P.3) to the SNC Standard Emergency Plan.

controlled by the GPC Corporate Supporting Plans Communications Department.

State of Georgia Radiological Emergency Response
HNP Security Plan, controlled by the Plan Security Department.
HNP Security Plan
HNP Fire Hazards Analysis and Fire
HNP Fire Protection Plan Protection Plan, controlled by Engineering Support.

D. ASSESSMENT ACTIONS EP D.1.1.1 Emergency classification is divided into four The commitment wording was standardized Classification of Emergencies classification levels described in 10 CFR 50 Appendix E and relocated to the SNC Standard The classification system is based on the and NUREG 0654 and based on NEI 99-01 and 07-01 Emergency Plan unchanged. four emergency classes described in 10 methodologies. CFR 50 Appendix E and NUREG 0654, established by the NRC, for grouping off-normal nuclear power plant conditions according to (1) their relative radiological seriousness and (2) the time-sensitive onsite and offsite radiological emergency preparedness actions necessary to respond to such conditions. The existing radiological emergency EP D.1.1.2 The four emergency classification levels are The commitment wording was standardized classes, in ascending order of described as follows: and relocated to the SNC Standard seriousness, are called: Unusual Event Emergency Plan unchanged.

Notification of Unusual Event (NUE) Alert
Alert Site Area Emergency
Site Area Emergency (SAE) General Emergency
General Emergency (GE)

The classes, therefore, determine initial EP D.1.1.2 The Initiating Conditions (ICs) deal explicitly The wording was standardized and relocated steps to be taken by onsite and corporate with radiological safety impact by escalating from levels to the SNC Standard Emergency Plan. emergency response personnel. The corresponding to releases within regulatory limits to emergency classes are used by offsite releases beyond EPA Protective Action Guideline authorities to determine which of the (PAG) plume exposure levels. preplanned actions are to be taken by their emergency organizations. E9-59 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 An emergency classification is indicative EP D.1.1.2 The Initiating Conditions (ICs) deal explicitly The wording was standardized and relocated of the status of the plant. Inputs to the with radiological safety impact by escalating from levels to the SNC Standard Emergency Plan. emergency classification system include corresponding to releases within regulatory limits to the status of various plant systems, releases beyond EPA Protective Action Guideline radiation levels in and around plant areas, (PAG) plume exposure levels. and the rate of release of radioactivity from the plant. These are termed Initiating Conditions (ICs), which are a predetermined subset of nuclear power plant conditions where either the potential exists for.a radiological emergency or such an emergency has occurred. The SNC classification scheme is based EP D.1.1.1 Emergency classification is divided into four The wording was standardized and relocated on NEI 99.:01, Revision 4, Methodology classification levels described in 10 CFR 50 Appendix E to Uie SNC Standard Emergency Plan. for Development of Emergency Action and NUREG 0654 and based on NEI 99-01 and 07-01 Levels, January 2003, endorsed by Reg. methodologies. This submittal does not change the existing Guide 1.101, Revision 4, Emergency approved EAL scheme. Planning and Preparedness for Nuclear Power Reactors. The !Cs lead each plant to a classification implementing procedure which contains the Threshold Values (TVs) for each IC. Each IC has specific conditions EP D.2.1 With each IC are Threshold Values (TV) that The wording was standardized and relocated associated that are termed TVs. When an provide the criteria for classification associated with the to the SNC Standard Emergency Plan. IC is observed and the criteria of its appropriate classification leveL When the IC is associated TVs are met, an Emergency observed to exist, the TV must .also be met, exceeded Actioh Level (EAL) is met and the event is or in some cases imminent to become a classifiable then classified and declared at the Emergency Action Level. appropriate level. E9-60 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 The SNC classification procedures are EP D.2.4 Treatment of Multiple events and The wording was standardized and relocated written to classify events based on Classification Level Upgrading to the SNC Standard Emergency Plan. meeting the IC and a TV for an EAL When multiple simultaneous events occur, the considering each unit independently. emergency classification level is based on the highest During events, the ICs and TVs are EAL reached. Emergency classification level upgrading monitored and, if conditions meet another considers the potential for radioactive release from the higher IC and EAL, then the higher entire site due to the event or simultaneous events. emergency classification is declared and appropriate notifications are made. Notifications are made on a site basis. If both units are in concurrent classifications, the highest classification will be used for the notification and the other unit's classification events are noted on the notification form. At all times, when conditions present No equivalent Plan/Annex statement. The approved EAL scheme provides for themselves that are not explicitly provided Emergency Director judgment in in the EAL scheme, the ED has discretion Classification with specific Emergency Action to declare an emergency based on his Levels. knowledge of the emergency classes and judgment of the situation or condition. E9-61 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Classification Timeliness EP D.1.1.1 Emergency Action Levels (EALs), based on The wording was standardized and relocated The emergency declaration process starts indications available in the control room and correlated to the SNC Standard Emergency Plan. with information being available to plant to the emergency classifications, are provided to the operators to recognize an off-normal plant operator. condition via indications on plant SNC has-and maintains the capability to assess, instrumentation, including alarms, or via classify, and declare an emergency condition within 15 reports from other plant personnel (e.g., minutes after the availability of indications to plant reports of fire) or from persons outside of operators that an EAL threshold has been met or the plant (e.g., severe weather warnings). exceeded. Upon identification of the appropriate The plant operators assess the validity of emergency classification level, the emergency condition these indications or reports by checking will be promptly declared. instruments, comparing indications on redundant instruments, or dispatching personnel to confirm reports. After validating the indication or report, the plant operators then compare the off-normal condition to the EAL thresholds in the emergency classification scheme. Not all off-normal conditions are immediately obvious, and not all indications are unambiguous. While some conditions can be classified upon recognition, others require further assessment. The capability to assess, classify, and EP D.1.1.1 Emergency Action Levels (EALs}, based on The wording was standardized and relocated declare an emergency condition within 15 indications available in the control room and correlated to the SNC Standard Emergency Plan. minutes after the availability of indications to the emergency classifications, are provided to the to plant operators that an EAL has been operator. exceeded has been established and is SNC has and maintains the capability to assess, outlined in applicable procedures. classify, and declare an emergency condition within 15 Emergency conditions are classified minutes after the availability of indications to plant promptly upon identification that an operators that an EAL threshold has been met or emergency action level (EAL) threshold exceeded. Upon identification of the appropriate has been exceeded. emergency classification level, the emergency condition will be promptly declared. E9-62 to NL..:16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 The 15-minute period encompasses all EP D.1.1.1 Emergency Action Levels (EALs), based on The wording was standardized and relocated assessment, classification, and indications available in the control room and correlated to the SNC Standard Emergency Plan. declaration actions associated with to the emergency classifications, are provided to the making an emergency declaration from operator. the first availability of a plant indication or SNC has and maintains the capability to assess, receipt of a report of an off-normal classify, and declare an emergency condition within 15 condition by plant operators up to and minutes after the availability of indications to plant including the declaration of the operators that an EAL threshold has been met or emergency. If classifications and exceeded. Upon identification of the appropriate declarations are performed away from the emergency classification level, the emergency condition CR, all delays incurred in transferring will be promptly declared. 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. Once an emergency classification is EP D.2.5 Emergency Classification Level Downgrading The wording was standardized and relocated made, it cannot be downgraded to a lower and Termination to the SNC Standard Emergency Plan. classification. Actions associated with the The SNC policy is that once an emergency classification emergency classification level will is made, it cannot be downgraded to a lower normally be completed and then a classification. Termination criteria contained in the termination of the event can be affected. Emergency Plan Implementing Procedures shall be At termination, on an event specific basis, completed for an event to be terminated. At the site can either enter normal operating termination, on an event specific basis, the site can conditions or enter a recovery condition either enter normal operating conditions or enter a with a recovery organization established recovery condition with a recovery organization for turnover from the ERO. established for turnover from the ERO. When the site determines that transition to termination or recovery is appropriate, the information will be transmitted to respective offsite agencies. E9-63 to NL-16-0169 Hatch Justification Matrix Current Hatch 'Emergency Plan Revised SNC Emergency Plan Justification Revision 36 The described emergency classes and EP D.1.1.1 The classification scheme is provided to and The wording was standardized and relocated the emergency action levels (EAL) which discussed by Southern Nuclear Company, agreed upon to the SNC Standard Emergency Plan. determine them are .agreed on by SNC by state and county governmental authorities and and State and local authorities. The EAL approved by the NRC. The classification scheme and will be reviewed by these officials specific Emergency Action Levels are reviewed with the annually. State and local governmental authorities on an annual basis.

1. Notification of Unusual fa'ent (NUE) EP D.1.1.2 UNUSUAL EVENT (UE) *.The wording was standardized and relocated

a. Description Events are in progress or have occurred which indicate to the SNC Standard Emergency Plan.

The classification of a NUE applies to a potential degradation of the level of safety of the plant situations in which events are in process or indicate a security threat to facility protection has or have occurred which indicate a

been initiated. No releases of radioactive material potential degradation of the level of safety requiring off-site response or monitoring are expected of the plant or indicate a security threat to unless further degradation of safety systems occurs.

facility protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.

b. Response No direct equivalent Plan/Annex S.tatement Section B of the SNC Standard Emergency In the event of a NUE, the SM will assess Plan describes the overall responsibilities of the conditions, assume the ED duties, the Shift Manager/Interim ED. Repetition in and implement the classification this section was eliminated.

Emergency Implementing Procedure (EIP). E9*64 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 The Emergency Organization will perform EP E.1.1 SNC-operated plants maintain the capability of The wording was standardized and relocated the following: notifying state and local agencies within 15 minutes of a to the SNC Standard Emergency Plan.

1) Inform State and local offsite declared emergency as required by 10CFR50 Appendix authorities of the nature of the unusual E, section IV(D)(3).

event within 15 min of classifying the NRC will be notified by the impacted site immediately emergency. Notify the NRC as soon as following state and local notifications, but within an hour possible (ASAP), but no later than 1 hour of an emergency classification using ENS. following classification of the emergency.

2) Augment on-shift resources, as EP E.2.1 Notification procedures include notification of needed. Emergency Response Organization Personnel (ERO)

3) Assess and respond to the event. not on site or during backshift hours. ERO members

4) Escalate to a more severe class, if will be notified by means of an automated callout appropriate, or close out with a verbal system activated by on-shift personnel.

summary to offsite authorities followed by a written summary within 24 hours. E9-65 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Alert EP D.1.1.2 ALERT The wording was standardized and relocated

a. Description Events are in progress or have occurred which involve to the SNC Standard Emergency Plan.

an actual or potential substantial degradation of the The classification of Alert applies to level of safety of the plant or a security event that situations in which events are in process involves probable life threatening risk to site personnel or have occurred which involve an actual or damage to site equipment because of hostile action. or potential substantial degradation of the Any releases are expected to be limited to small level of safety of the plant or a security fractions of the EPA PAG exposure levels. event that involves probable life 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 offsite notification 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.

b. Response No direct equivalent Plan/Annex Statement. Section B of the SNC Standard Emergency In the event of an Alert, the SM will Plan describes the overall responsibilities of assess the conditions, assume the ED the Shift Manager/Interim ED. Repetition in duties, and implement the classification this section was eliminated.

EIP. E9-66 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 The Emergency Organization will then No direct equivalent Plan/Annex Statement. Section B of the SNC Standard Emergency perform the following: Plan describes the overall responsibilities of

1) Within 15 min. of classification, inform the Emergency Organization. Repetition in State and local offsite authorities of Alert this section was eliminated.

and reasons for emergency. Notify the NRC ASAP but no later than 1 hour 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 ED.

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 (EROS) for the affected unit within 1 hour 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 hours of closeout.

E9-67 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Site Area Emergency (SAE) EP D.1.1.2 SITE AREA EMERGENCY (SAE) The wording was standardized and relocated

a. Description Events are in progress or have occurred which involve to the SNC Standard Emergency Plan.

actual or likely major failures of plant functions needed The classification of a SAE applies to for protection of the public or hostile action that results those events which are in progress or in intentional damage or malicious acts toward site have occurred that involve actual or likely personnel or equipment that could 1) lead to the likely major failures of plant functions needed failure of, or 2) prevent effective access to, equipment for protection of the public from radiation needed for the protection of the public. Any releases or contamination or hostile action that are not expected to result in exposure levels that results in intentional damage or malicious exceed EPA PAG exposure levels beyond the site acts; (1) toward site personnel or 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 SAE classification are not expected to exceed EPA PAG exposure levels except near the site boundary.

b. Response No direct equivalent Plan/Annex Statement. Section B of the SNC Standard Emergency In the event of a SAE, the SM will assess Plan describes the overall responsibilities of the conditions, assume the ED duties and the Shift Manager/Interim ED. Repetition in implement the classification EIP. this section was eliminated.

E9-68 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 The Emergency Organization will perform the No direct equivalent Plan/Annex Statement. Section B of the SNC Standard Emergency following: Plan describes the overall responsibilities of

1) Within 15 min of classification, inform State the Emergency Organization. Repetition in and local offsite authorities of SAE and this section was eliminated.

reasons for emergency. Notify the NRC ASAP but no later than 1 hour 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., TSC, OSC, and the EOF). These actions may be delayed for security based events at the discretion of the ED.

4) Assess and respond to the emergency.

5) Dispatch, as necessary, onsite and offsite survey 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.

9) Provide release and dose projections based on available plant condition information and foreseeable contingencies.

10) Activate the EROS for the affected unit within 1 hour following declaration of the SAE.

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

E9-69 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 General Emergency (GE) EP D.1.1.2 GENERAL EMERGENCY The wording was standardized and relocated

a. Description Events are in progress or have occurred which involve to the SNC Standard Emergency Plan.

actual or imminent substantial core degradation or The classification of GE applies to those melting with potential for loss of containment integrity or events which are in progress or have hostile action that results in an actual loss of physical occurred which involve actual or imminent control of the facility. Releases can be reasonably substantial core degradation or melting expected to exceed EPA PAG exposure levels off-site with potential loss of containment integrity for more than the immediate site area. or hostile action that results in an actual loss of physical control of the facility. Release of radioactive material for the GE classification can reasonably be expected to exceed EPA PAG exposure levels offsite for more than the immediate site area.

b. Response No direct equivalent Plan/Annex Statement. Section B of the SNC Standard Emergency In the event of a GE the SM will assess Plan describes the overall responsibilities of the conditions, assume the ED duties and the Shift Manager/Interim ED. Repetition in implement the classification EPIP. this section was eliminated.

E9-70 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 The Emergency Organization will then perform No direct equivalent Plan/Annex Statement. Section B of the SNC Standard Emergency the following: Plan describes the overall responsibilities of

1) Within 15 min of classification, inform State the Emergency Organization. Repetition in and local offsite authorities of GE and reason this section was eliminated.

for emergency. Notify the NRC ASAP but no later than 1 hour following classification of the emergency.

2) Provide 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. TSC, OSC, and the EOF). These actions may be delayed for security based events at the discretion of the ED.

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.

10) Activate the EROS for the affected unit within 1 hour following declaration of the GE.

11) Close out the emergency class by briefing offsite authorities, followed by a written summary within 8 hours of closeout.

E9-71 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Classification Process No direct equivalent Plan/Annex statement The site responsibility for Classification is The classification EIP is used to classify described throughout Section D of the SNC the emergency condition upon recognition Standard Emergency Plan and individually of an off-normal condition relative to an assigned in Section B. IC. To facilitate the expeditious classification EP D.2.1: The !Cs are segregated into Recognition The wording was standardized and relocated of emergencies, the various !Cs which Categories. The Recognition Categories are: to the SNC Standard Emergency Plan. may result in an emergency class are

R -Abnormal Radiological Levels/Radiological grouped into six recognition categories as Effluent.

follows:

C - Cold Shutdown/Refueling System Malfunctions .
Radiological (Hot and Cold - R series)
E - Independent Spent Fuel Storage Installations
Fission product barriers (Hot - F series) (ISFSI).
System malfunctions (Hot - S series)
F - Fission Product Barrier.
System malfunctions (Cold - C series)
ISFSI (Hot and Cold - E series)
H - Hazards and Other Conditions Affecting Plant Safety.
Hazards (Hot and Cold - H series)
S - System Malfunction .

Within each category, subcategories and Annex Appendix B The wording was standardized and relocated specific !Cs are identified. to the Site Annex. The EAL, !Cs, TVs, and bases are provided in Appendix 8. E9-72 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 The 15-minute period encompasses all EP D.1.1.1 SNC has and maintains the capability to The wording was standardized and relocated assessment, classification, and assess, classify, and declare an emergency condition to the SNC Standard Emergency Plan. declaration actions associated with within 15 minutes after the availability of indications to making an emergency declaration from plant operators that an EAL threshold has been met or the first availability of.a plant indication or exceeded. Upon identification of the appropriate receipt of a report of an off-normal by emergency classification level, the emergency condition plant operators up to and including the will be promptly declared. declaration of the emergency. If classification 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. FIGURE D "HOT" INITIATING Annex Appendix B The approved EAL scheme is not impacted CONDITION MATRIX by this submittal. FIGURE D "COLD" INITIATING Annex Appendix B The approved EAL scheme is not impacted CONDITION MATRIX by this submittal. E. NOTIFICATION METHODS AND EP E.1.1 SNC-operated plants maintain the capability of The wording was standardized and relocated PROCEDURES notifying state and local agencies within 15 minutes of a to the SNC Standard Emergency Plan. This section describes the plan for declared emergency as required by 10CFR50 Appendix notification of onsite ancl offsite licensee E, IV.D.3. The methods and forms used for notifying emergency response personnel for HNP; state and county authorities are site-specific, and State, local, and NRC emergency detailed in plant specific Emergency Plan Implementing response centers. Actual methods and Procedures (EPIPs). sequencing of notifications are covered in NRC will be notified by the impacted site immediately appropriate implementing procedures. following state and local notifications, but within an hour Table E-1 presents the initial notification of an emergency classification using ENS. concept for normal working hours and backshift hours. E9-73 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Notification of HNP Personnel EP E.2.1: The Emergency Director is responsible for The wording was standardized and relocated The ED is responsible for classifying an classifying an event into the appropriate emergency to the SNC Standard Emergency Plan. event (Section D) into the appropriate classification and then notifying on site personnel of the emergency class and ensuring onsite emergency declaration in accordance with procedures. personnel are notified accordingly. This This notification may consist of the use of the plant notification involves sounding the emergency alarm, announcements over the plant public appropriate plant emergency alarm address system, or activation of the recall system. signal, making appropriate announcements over the plant public address (PA) system, and using the plant telephone system. The primary means for notification of EP E.2.1: The Emergency Director is responsible for The wording was standardized and relocated personnel within the controlled area is the classifying an event into the appropriate emergency to the SNC Standard Emergency Plan. PA system. Upon declaration of an classification and then notifying on site personnel of the Emergency, personnel will be notified by emergency declaration in accordance with procedures. a page announcement. For declaration of This notification may consist of the use of the plant an Alert, a Site Area Emergency, or a emergency alarm, announcements over the plant public General Emergency, this notification will address system, or activation of the recall system. be preceded by a warning tone. Likewise, page announcements for a Fire will be preceded by a specific tone. During security related events, the ED may elect to not sound a warning tone and, in such cases, will provide event specific instructions for onsite personnel over the PA system as well as other available communications means as needed. Notification of persons who are in the EP E.2.1: Notification of persons who are in the public The commitment to warn plant personnel has public access areas, on or passing access areas, on or passing through the site, or within been relocated to the SNC Standard through the site, or within the controlled the controlled area, will be performed by the Security Emergency Plan. area will be performed by the Security Department. Such notifications*will be in accordance Department. All such notifications would with the Emergency Plan Implementing Procedures. be accomplished in accordance with the Emergency Plan implementing procedures. E9-74 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Visitors within the protected area are EP E.2.1 Visitors within the protected area are escorted The wording was standardized and relocated escorted by a permanently badged by a permanently badged individual. This individual is to the SNC Standard Emergency Plan. individual who is responsible for informing responsible for informing the visitors of emergencies the visitors of emergencies when they when they occur and for taking action to evacuate the occur and for taking action to evacuate visitors from the site, as necessary. the visitors from the site, as necessary. The ED is responsible for notifying the No Equivalent Plan/Annex Statement. The commitment to warn plant personnel has Hatch Duty Manager (who is on call 24 been relocated to the SNC Standard hours a day). This Duty Manager contacts Emergency Plan. Corporate. These notifications may be ' made utilizing available communications systems. Selected plant management can also be No equivalent Plan/Annex statement. The lack of specificity in the existing Plan reached utilizing available statement provides no benefit to the Plan. communications systems. Notification responsibilities for the ORO and ERO are specifically laid out. Additional notifications are an administrative decision and not needed in the Emergency Plan. During normal working hours, emergency EP E.2.1 Emergency Response personnel respond to The wording was standardized and relocated response personnel report to their their assigned Emergency Response Facilities upon to the SNC Standard Emergency Plan. assigned locations at the TSC and the notification of an Alert or higher classification level. In OSC, as required by the specific the event of a Design Basis Threat, personnel may be emergency classification. Notification of directed to respond to alternative facilities. EOF personnel will be accomplished utilizing available communications systems in accordance with Appendix 7. During backshift hours, the Operations EP E.2.1 Notification procedures include notification of The wording was standardized and relocated SM is responsible for initiating the Emergency Response Organization Personnel (ERO) to the SNC Standard Emergency Plan. notification process to required not on site or during backshift hours. ERO members emergency response personnel, directing will be notified by means of an automated callout them to report to their designated ERF. system activated by on-shift personnel. These notifications may be made utilizing available communications systems. E9-75 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Notification of State and Local Response EP E.2.1: The Emergency Director is responsible for The wording was standardized and relocated Personnel classifying an event into the appropriate emergency to the SNC Standard Emergency Plan. The ED is responsible for ensuring that classification and then notifying on site personnel of the the State and local counties surrounding emergency declaration in accordance with procedures. HNP are notified in a timely and accurate This notification may consist of the use of the plant manner of an emergency condition. emergency alarm, announcements over the plant public address system, or activation of the recall system. This notification consists of the EP E.1.1: SNC, in cooperation with state and county The wording was standardized and relocated information on the Emergency Notification authorities, has established methods and procedures for to the SNC Standard Emergency Plan and Form (Figure E-1) being given within notification of offsite response organizations consistent Site Annex. approximately 15 min of declaring an with the emergency classification and emergency action emergency to the following agencies: level scheme. Georgia EMA. Annex 4.1.1: State and local warning points are staffed The 24-hour warning points of Appling, 24 hours per day. State and county authorities to be Jeff Davis, Tattnall, and Toombs notified within 15 minutes of the declaration of an Coµnties. emergency condition are:

Georgia Emergency Management Agency (GEMA).

Georgia county authorities:

Appling County warning point.
Jeff Davis County warning point.
Tattnall County warning point.
Toombs County warning point.

These agencies are responsible for EP E.2.2 Notification of State and local Authorities The wording was standardized and relocated notifying appropriate response personnel A dedicated ENN, will normally be used to accomplish to the SNC Standard Emergency Plan. in accordance with their emergency plans State and local notifications. Backup means of and procedures. The ENN is a dedicated communication are described in Section F, Emergency communications system that is normally Communication, of this plan. used to accomplish these notifications. Commercial telephone, microwave, or land lines provide backup for the ENN. E9-76

Enclosure 9 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plaff Revised SNC Emergency Plan Justification Revision 36 Figure E-1 presents the sample EP E.2.2.2: Initial Notification Message Form The commitment wording was standardized Emergency Notification Form for making In conjunction with state and county authorities, SNC and relocated to the SNC Standard notifications to these response centers. operated plants have established the cont~nts of the Emergency Plan and Site Annex. This form has been developed in initial state notification message forms to be used during conjunction with appropriate agencies. an emergency. These forms are described in EPIPs. The Emergency Notification Form may be The content of the forms has been reviewed and agreed revised upon receipt of State and utility on by the respective Offsite Response Organizations. approval. Any revisions to the Notification Annex 4.1.1: State and local warning points are staffed Form are incorporated into the applicable 24 hours per day. State county authorities to be notified implementing procedure are included in within 15 minutes of the declaration of an emergency the next revision to the Emergency Plan. condition are:

Georgia Emergency Management Agency (GEMA).

Georgia County Authorities:

Appling County warning point.
Jeff Davis County warning point.
Tattnall County warning point.
Toombs County warning point.
Verification of Notification Messages EP E.2.7 Verification of Notification Messages The wording was standardized and relocated All ENN notification messages must be The SNC emergency notification form is transmitted to the SNC Standard Emergency Plan.

verified as being received by the State of electronically to the responsible state and local Georgia and Appling, Jeff Davis, Tattnall, agencies using a secure data sharing system provided and Toombs Counties. Verification is by SNC. Once transmitted to the OROs, the receipt of normally accomplished by roll call. this information is confirmed using a dedicated communications link. Notification of Federal .Agencies EP E.2.3 Notification of the Nuclear Regulatory The wording was standardized and relocated The ED is responsible for ensuring Commission (NRC) to the SNC Standard Emergency Plan. notification calls are made to the NRC The NRC is notified via the ENS. If the ENS is Operations Center by the ENS or inoperative, the required notification will be made using commercial telephone as backup within alternate means in accordance with regulatory the prescribed time constraints from the requirements. The Emergency Response Data System declaration of an emergency. A sample of (EROS), will be initiated within one hour of the the form used to provide the notification to declaration of an Alert or higher classification. the NRC Operations Center is shown in Figure E-2. E9-77 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Notification of the Public EP E.2.5 Notification of the Public The wording was standardized and relocated Administrative and physical means have Prompt alerting and notification of the public within the to the SNC Standard Emergency Plan and been established for providing early plume exposure pathway EPZ is the obligation of state Site Annex. notification and clear instruction to the and local government or other responsible authority. populace within the plume exposure The responsibility for ensuring the means exist to carry pathway EPZ. (See Appendix 3.) The out this purpose rests with Southern Nuclear Operating prompt notification system has a Company. An overview of these means excluding the capability to complete the initial Savannah River Site is listed in the site specific Annex notification within 15 min. of this Plan. Annex 4.2 The calling system serves as a complete backup to the ANS. The system provides both alerting and notification of EPZ residents independent of the alerting 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 for Appling County, Georgia, and for the state of Georgia. E9-78 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 The initial notification, when appropriate, Annex4.2 The wording was standardized and relocated The FEMA approved Hatch ANS consists of a primary ANS and a backup of the affected population within the system should there be a failure of the primary system. to the Site Annex. plume exposure pathway EPZ is to be

Primary - Sirens and Emergency Alert System (EAS) stations
System Backup - Reverse calling system completed by the State and/or local The primary ANS has two communications pathways. The first pathway is authorities in a manner consistent with through the primary agency via the UHF or VHF radio. Should the primary assuring the public health and safety. agency fail to activate the system, the secondary pathway will be utilized by the secondary agency. The secondary pathway functions in the same manner as the primary pathway utilizing a separate activation console that is physically located in separate location. If neither agency can activate the system, the backup system will be utilized to notify the residents of the 1O mile EPZ.

The hierarchv for svstem activation is provided below: Agency Radio Systems Primary Agency UHF VHF Primary Sirens & EAS Secondary Agency UHF VHR Backup Each County EMA Calling System Georgia Primary Agency State of Georgia (GEMA) Secondary Agency Appling County E9-79 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 The primary means for alerting and Annex4.2 The wording was standardized and relocated The FEMA approved Hatch ANS consists of a primary ANS and a backup providing instructions to the public is by a system should there be a failure of the primary system. to the SNC Standard Emergency Plan. siren system and Emergency Alert

Primary - Sirens and Emergency Alert System (EAS) stations
System Backup - Reverse calling system System (EAS). The prompt notification The primary ANS has two communications pathways. The first pathway is See detailed description of the Siren System system (PNS) is described in Appendix 3. through the primary agency via the UHF or VHF radio. Should the primary was relocated to the Site Annex.

agency fail to activate the system, the secondary pathway will be utilized by the secondary agency. The secondary pathway functions in the same manner as the primary pathway utilizing a separate activation console that is physically See the details of Justification in the Appendix located in separate location. If neither agency can activate the system, the 3 section of this document. backup system will be utilized to notify the residents of the 10 mile EPZ. The hierarchy for system activation is provided below: Agency Radio Systems Primary Agency UHF VHF Primary Sirens & EAS Secondary Agency UHF VHR Backup Each County EMA Calling System Georgia Primary Agency State of Georgia (GEMA) Secondary Agency Appling County E9-80 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 The licensee will provide offsite EP E.2.5.1 Detailed information and instructions will be The wording was standardized and relocated authorities with supporting information for provided on local EAS radio and television stations. to the SNC Standard Emergency Plan. their messages to the public. Such messages, consistent with the emergency classification scheme, will provide the public with instructions in regard to specific protective actions to be taken by occupants of affected areas. F. EMERGENCY COMMUNICATIONS SECTION F: EMERGENCY COMMUNICATIONS The wording was standardized and relocated This section describes the provisions for to the SNC Standard Emergency Plan. communications among the principal response organizations and among the licensee ERF. Communications with the State of Annex 4.1.1 Notification Process (SEP E.2.2) The wording was standardized and relocated Georgia State and local warning points are staffed 24 hours per to the SNC Standard Emergency Plan and The primary means of communication day. State and county authorities to be notified within Site Annex. between the HNP and the State of 15 minutes of the declaration of an emergency condition Georgia is the ENN, which is a dedicated are: communications system from the plant to State of Georgia: the EOC at GEMA headquarters in

Georgia Emergency Management Agency (GEMA).

Atlanta, Georgia and the FEOC in Vidalia, Georgia County Authorities: Georgia. Extensions for this system are

Appling County warning point.

located in the Control Room, the TSC,

Jeff Davis County warning point.

and the EOF. The ENN system is

Tattnall County warning point.

available and manned 24 hours per day.

Toombs County warning point.

The ENN provides the licensee the Annex 5.3.1 Communications with the State and Local capability to notify State and local Counties (SEP F.1.2) authorities of an emergency within 15 The primary means of communication between HNP, min. of declaration. Commercial the State of Georgia, and the local counties (Appling, telephones, microwave, or land lines Jeff Davis, Tattnall, and Toombs) is the Emergency provide backup for the ENN. Notification Network (ENN). The ENN is a dedicated communications system from the plant to the state and local warning points, which are staffed 24 hours per day. Extensions for this system are located in the Control Room, the TSC, and the EOF. E9-81 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Communication with contiguous local No equivalent Plan/Annex statement. Communication requirements for the site are governments in the Ingestion Planning specified in the Site Plan and Annex. ORO Zone (IPZ) will be coordinated through communication is controlled by offsite plans the State of Georgia. and procedures. Communications with Plume Exposure Annex 5.3.1 Communications with the State of and The wording was standardized and relocated Pathway EPZ Counties Local Counties (SEP F.1.2) to the Site Annex. The primary means of communication The primary means of communication between HNP, between HNP and each EPZ county is the State of Georgia, and the local counties (Appling, the ENN, which is a dedicated Jeff Davis, Tattnall, and Toombs) is the Emergency communications system from the plant to Notification Network (ENN). The ENN is a dedicated each county EOC and 24-hour point of communications system from the plant to the state and contact. Commercial telephones, local warning points, which are staffed 24 hours per microwave or land lines discussed above day. Extensions for this system are located in the provide backups for the ENN. Radio Control Room, the TSC, and the EOF. contact between the plant and the Appling County Sheriffs Office can also be established, if necessary. The ENN is available and manned 24 Annex 4.1.1 Notification Process (SEP E.2.2.1) The wording was standardized and relocated hours per day. At the plant, the ED is State and local warning points are staffed 24 hours per to the Site Annex. responsible for ensuring contact with day. State and local county authorities to be notified each of the plume exposure pathway EPZ within 15 minutes of the declaration of an emergency counties. condition are: State of Georgia:

Georgia Emergency Management Agency (GEMA).

Georgia County Authorities:

Appling County warning point.
Jeff Davis County warning point.
Tattnall County warning point.
Toombs County warning point.

E9-82 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Communications with NRC and Other EP F.1.4.1 NRC Emergency Notification System (ENS) The wording was standardized and relocated Federal Agencies This communications line provides a communications to the SNC Standard Emergency Plan. The primary means of communication link to the NRC Operations Center in Rockville, between HNP and the NRC is the ENS, a Maryland, and is used for continuous communications in The current operation of the FTS system dedicated communications system from a classified emergency. allows any phone with long distance capability the plant to the NRC Operations Center. to call into the Headquarters Operations The NRC Region II office in Atlanta, Center and be patched into any bridge. The Georgia, may also be connected to the specific listing becomes redundant to the ENS through the NRC Operations Center. expanded capability. Additional dedicated telephone circuits [known as the Federal Telecommunications System (FTS)] are installed in the TSC and the EOF. The Emergency Response Data System EP F.1.4.8 Emergency Response Data System (EROS) The wording was standardized and relocated (EROS), which provides specific plant EROS is a dedicated network and is a direct near real- to the SNC Standard Emergency Plan. parameters to the NRC via internet time electronic data link between the plant's on-site connection, is installed in the Computer computer system and the NRC Operations Center. It The current operation of the FTS system Room and the TSC. provides for the automated transmission of a limited allows any phone with long distance capability data set of selected parameters. to call into the Headquarters Operations Center and be patched into any bridge. The specific listing becomes redundant to the expanded capability. Commercial telephone lines and the EP F .1.4 Commercial telephone lines serve as the The wording was standardized and relocated microwave system serve as backups to backup to the ENS and other FTS lines. to the SNC Standard Emergency Plan. the ENS. Communications with other Federal emergency response organizations would be by telephone; such communications would normally be completed by GEMA from the State EOC. E9-83 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Communications Among HNP ERF EP F Table 5. The wording was standardized and relocated Communications among the Control to the SNC Standard Emergency Plan. Room, the TSC, the OSC, and the EOF can be completed using various communications systems including dedicated telephone circuits, normal plant telephones, and radios. A radio system is also used for Section F Table 5 The wording was standardized and relocated communications with the radiological to the SNC Standard Emergency Plan. monitoring teams. Communications available at each ERF EP F Table 5 The wording was standardized and relocated are as follows: to the SNC Standard Emergency Plan.

1. Control Room

Dedicated Voice Over Internet Protocol (VOiP) phones to the TSC, the OSC, and the EOF.
One extension to the ENN.
One extension to the NRC ENS.
EROS to the NRC.
Normal plant phones (network or commercial).
Base station radio console (multiple frequencies).
Sound-powered phones (internal to Control Room only).

*Plant PA system.

One facsimile line.

E9-84 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 TSC EP F Table 5 The wording was standardized and relocated

Dedicated Voice Over Internet Protocol to the SNC Standard Emergency Plan.

(VOiP) phones to the Control Room, the OSC, and the EOF.

One extension to the ENN.
One extension to the NRC ENS.
EROS to the NRC.
One facsimile line.
Normal plant phones (network or commercial).
Base station radio console (multiple frequencies).
Plant PA system.

osc EP F Table 5 The wording was standardized and relocated

Dedicated Voice Over Internet Protocol to the SNC Standard Emergency Plan.

(VOiP) phones to the Control Room, the TSC, and the EOF.

Normal plant phones (network or commercial).
Base station radio console.
Plant PA system.

EOF EP F Table 5 The wording was standardized and relocated

Dedicated Voice Over Internet Protocol to the SNC Standard Emergency Plan.

(VOiP) phones to the Control Room, the TSC, and the OSC.

One extension to the ENN.
An extension to the NRC ENS.
Multiple facsimile lines.
Normal phones (network or commercial).
Southern LINC radio equipment.

E9-85 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Medical Support Facility Communications EP F.2 Medical Emergency Communications The wording was standardized and relocated Communication between HNP and the Communications have been established between the to the SNC Standard Emergency Plan. Appling General Hospital or the Meadows primary and backup medical hospitals and Regional Medical Center is by transportation services with SNC-operated plants. commercial telephone. The Appling Ambulance Service and the Meadows Regional Medical Center Ambulance Service are equipped with radio for communications with the hospitals. Normally, ambulance services and hospitals within the State are interconnected in a statewide hospital radio network. Alerting Emergency Response Personnel EP E.2.1 Notification of Onsite Personnel The wording was standardized and relocated As described in Section E, notification of The Emergency Director is responsible for classifying to the SNC Standard Emergency Plan. onsite personnel at HNP is completed an event into the appropriate emergency classification utilizing available communications and then notifying on site personnel of the emergency systems. HNP personnel not onsite at the declaration in accordance with procedures. This time of the emergency are also notified notification may consist of the use of the plant utilizing available communications emergency alarm, announcements over the plant public systems. address system, or activation of the recall system. Communications System Tests EP F.3 Communications tests will be conducted on the The commitment wording was standardized Communication channels with the State frequency specified below. Each of these tests includes and relocated to the SNC Standard of Georgia, the plume exposure pathway provisions to ensure participants in the test are able to Emergency Plan. EPZ counties, and the NRC (with the understand the content of the messages in the test. exception of EROS) are tested each

Communications with state and local governments calendar month, using the extensions in within the plume exposure pathway will be tested the Control Room, the TSC, and the EOF. monthly.
Communication from the Control Room, TSC, and EOF to the NRC Operations Center will be tested monthly.

EROS is tested each calendar quarter. EP F.3 The Emergency Response Data System (EROS) The commitment wording was standardized will be tested on a quarterly basis. and relocated to the SNC Standard Emergency Plan. E9-86 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 All communications procedures and Annex 5.4 Communications procedures and systems The wording was standardized and relocated systems are also tested each calendar are also tested each calendar year. to the Site Annex. year during a communications drill. This drill is normally conducted in an exercise each calendar year. G. PUBLIC EDUCATION AND No equivalent Plan/Annex statement. The SNC Standard Emergency Plan and Site INFORMATION Annex in Section G outline the Public The detailed planning for public Education and Information responsibilities of information actions during an emergency, SNC and the site. including rumor control, is contained in the GPC HNP Emergency Communication Plan. A general description of the public EP G.8 Public Information and Education Program The commitment wording was standardized education and information program The goal of the public information program is to and relocated to the SNC Standard follows. acquaint the general public with the emergency plans Emergency Plan. for the operation of APC/GPC nuclear plants, as Each calendar year, information is appropriate, and actions they should take in the event of provided to the public regarding how they a plant emergency. will be notified and what their actions Emergency information is disseminated each calendar should be in an emergency. The means year for residents and transients in the plume exposure for disseminating this information pathway Emergency Planning Zone. includes, but is not limited to, information in local telephone books, posting in public areas, and/or publications distributed by mail. E9-87 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Each calendar year, information is Annex 2.3.4 Several communications methods may be The commitment wording was standardized distributed to residents in the plume used to acquaint the public with plans for their and relocated to the Site Annex. exposure pathway EPZ through various protection during a Plant emergency. Effort will be publications. Information includes the concentrated on providing information to the public by following: written material that is likely to be available in local

Instructions in response to the SNC residences and in locations frequented by transients.

siren system including the annual audible The information will also provide instructions on which test. local media will be providing additional information in

How the emergency notification will take the event of an emergency.

place.

Discussions of protective measures such as sheltering and evacuation and actions to take in either case.
Radio stations where additional information will be broadcast.
Evacuation routes and reception centers including a map and instructions.
Educational information on radiation.
Special needs and considerations for the handicapped.
Contacts to obtain additional information.

A Visitors Center is operated onsite. The No equivalent Plan/Annex Statement. Section G of the SNC Standard Emergency center is staffed with public information Plan and Site Annex provide the specific personnel who provide public education responsibilities for Public Education for programs to the community and any other implementation of the Emergency Plan. The visitors. These programs typically focus educational aspects of the Visitor Center may on plant operational concepts, plant be beneficial but are not germane to safety considerations, and radiation. implementation of the Emergency Plan. E9-88 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Information for Transients Annex 2.3.4 Several communications methods may be The commitment wording was standardized Posted "Emergency Information" signs used to acquaint the public with plans for their and relocated to the Site Annex. and a notice published in the local protection during a Plant emergency. Effort will be telephone books are used to provide the concentrated on providing information to the public by transient population with appropriate written material that is likely to be available in local emergency information and instructions. residences.and in locations frequented by transients. The information/instructions advise the The information will also provide instructions on which public on how they will be notified in the local media will be providing additional information in event of an emergency; indicate the the event of an emergency. actions to take if notified; and refer the public to designated broadcast stations for information in the event of a serious emergency. Method of Emergency Information EP G.8 Public Information and Education Program The commitment wording was standardized Dissemination The goal of the public information program is to and relocated to the SNC Standard Any proposed change in the method of acquaint the general public with the emergency plans Emergency Plan. dissemination of emergency information for the operation of APC/GPC nuclear plants, as to the public must be coordinated and appropriate, and actions they should take in the event of discussed with, and agreed upon by a plant emergency. appropriate State and local offsite Emergency information is disseminated each calendar emergency officials prior to year for residents and transients in the plume exposure implementation of the change. The pathway Emergency Planning Zone. Emergency Plan may be changed with EP G.1 Purpose regard to the manner in which the SNC uses a number of ways to communicate the information is provided to the public under information to the EPZ population. These means are 10 CFR 50.54 (q) provided the requisite developed in coordination with respective offsite emergency information remains the same agencies. Any proposed change in the method of as currently approved by the NRC and dissemination of emergency information to the public FEMA as contained in the Hatch must be coordinated and discussed with, and agreed Emergency Plan and the FEMA-43 upon by appropriate State and local offsite emergency Report for the Edwin I. Hatch Nuclear officials prior to implementation of the change. Plant. E9-89 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Joint Information Center (JIC) Operations EP H.2.2 Corporate Media Center (CMC) The commitment wording was standardized The JIC is the point of contact with the Upon notification of an Alert or higher classification, the and relocated to the SNC Standard news media during an emergency. The Public Information Director and corporate staff assigned Emergency Plan. JIC facilities used to coordinate the to JIC functions will assemble at the CMC. The CMC, dissemination of information to the media located at the Atlanta/Birmingham corporate will be established to accommodate headquarters building of Georgia Power public information representatives from Company/Alabama Power Company, as appropriate, is the licensee, Federal, State, and local the official location for coordination of emergency response agencies. News releases and communications response until the site specific JIC has media briefings are coordinated to the been activated. The Public Information Director will maximum extent possible. coordinate with the EOF Emergency Director and affected OROs and determine whether to activate the site specific JIC. When the decision is made to activate the JIC the CMC will maintain emergency communications response coordination until the site specific JIC is ready to assume these responsibilities. Once overall responsibility for emergency communications response transfers to the site specific JIC the remaining CMC staff will provide support for the JIC as needed. Annex 5.1.6 The HNP JIG is located in Vidalia, Georgia, adjacent to the Georgia Power Company operating headquarters. The JIG is the central location for the coordination and dissemination of information to news media, and responses to media inquiries. Details of the JIG for HNP are in section H of the Emergency Plan. If the decision is made to activate the JIG, the CMG in Atlanta, Georgia will maintain emergency communications response coordination until the JIG is ready to assume these responsibilities. E9-90 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 EP H.2.3 Joint Information Center (JIC) The commitment wording was standardized After the initial notification of an emergency at the Alert and relocated to the SNC Standard classification or higher, the Public Information Director will Emergency Plan. 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 CMC to the site specific JIC. Once the JIC is staffed the Public Information Director will manage the emergency communications response from the JIC in coordination with ORO public information officers (PIOs). Site specific JIC is provided in the site specific Annexes. The licensee utilizes the GPC Corporate .EP H.2.2 Corporate Media Center (CMC) The commitment wording was standardized Headquarters Building located in Atlanta, Upon notification of an Alert or higher classification, the and relocated to the SNC Standard Georgia, to serve as a temporary Public Information Director and corporate staff assigned Emergency Plan. information center until the JIC located to JIC functions will assemble at the CMC. The CMC, next to the GPC Operating Headquarters located at the Atlanta/Birmingham corporate in Vidalia can be activated. The JIC is headquarters building of Georgia Power located approximately 22 miles from the Company/Alabama Power Company, as appropriate, is plant and is large enough to the official location for coordination of emergency accommodate a large numl;>er of communications response until the site specific JIC has reporters. Once activated, the JIC been activated. The Public Information Director will becomes the principal location for the coordinate with the EOF Emergency Director and dissemination of information relative to affected OROs and determine whether to activate the site the emergency. News media who may specific JIC. When the decision is made to activate the arrive at the plant site during a declared JIC the CMC will maintain emergency communications emergency will be directed to the Joint response coordination until the site specific JIC is ready Information Center to obtain approved to assume these responsibilities. Once overall news release information. responsibility for emergency communications response transfers to the site specific JIC the remaining CMC staff will provide support for the. JIC as needed. E9-91 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 EP H.2.3 Joint Information Center (JIG) The commitment wording was standardized After the initial notification of an emergency at the Alert and relocated to the SNC Standard classification or higher, the Public Information Director will Emergency Plan. coordinate with the EOF Emergency Director and affected OROs and determine whether to activate the JIG. Upon the decision to activate the JIG, the Public Information Director and JIG staff transfer from the CMG to the site specific JIG. Once the JIG is staffed the Public Information Director will 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. The principal licensee contacts for the EP 8.3.2.8 EOF Nuclear Spokesperson The commitment wording was standardized media are the Public Information Director The Nuclear Spokesperson speaks on behalf of the and relocated to the SNC Standard and the designated Company company, providing plant status updates during news Emergency Plan. Spokesperson. The Company briefings. The Spokesperson also may do one-on-one Spokesperson has access to the ED media interviews. The position works with the Technical The specific functioning of the Corporate JIG through the EOF Manager. The Company Assistant in keeping abreast of the event status and and optional local JIG are described Spokesperson briefs the media on plant keeps the Public Information Director (PIO) posted on separately. status and company emergency activities. that status. In addition, technical briefers who can EP 8.3.2.1 JIG Public Information Director (PID) provide general and background The PIO is responsible for coordination of emergency information, as appropriate, to reporters information between the utility and responding offsite at the JIG have been designated. organizations participating in the Joint Information Center (JIG). Additional duties include managing approval and dissemination of utility news bulletins, facilitating news briefings, overseeing public response, serving as liaison to the media and coordinating off-site agencies. The PID is responsible for evaluating the emergency's severity in terms of public interest and safety. E9-92 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan . Revised SNC Emergency Plan Justification Revision 36 Further information relative to the public No equivalent Plan/Annex statement. The REP requirements previously located in information organization and information the Emergency Communications Plan have flow to the public during an emergency is been incorporated in Section G of the SNC available in the HNP Emergency Standard Emergency Plan and Site Annex. Communications Plan. Offsite Agency Coordination EP G.4 Press Briefings The commitment wording was standardized Timely and accurate information is Press briefings will be conducted to keep the media and relocated to the SNC Standard provided to Federal, State, and local informed of events and activities relating to the Emergency Plan. agencies. The licensee seeks reciprocal emergency. Briefings will provide the most current, up-information from these agencies. Efforts to-date information about events and response to the The specific functioning of the Corporate JIC are made to coordinate periodic press incident. Public Information Officers (PIO$) from all and optional local JIC are described briefings and to issue public statements in offsite agencies responding to the emergency will be

separately.

conjunction with these government encouraged to participate in the briefings to discuss agencies. A joint public information center their particular activities. operation at the JIC provides ample opportunity for all parties represented to review all information prior to public release. Rumor Control EP 8.3.2.5 Public Response Coordinator The commitment wording was standardized Providing timely, accurate, and consistent The Public Response Coordinator reports to the PID and relocated to the SNC Standard information to the public is considered the and is responsible for directing the facility's public Emergency Plan. most effective method of dispelling response activities, keeping staff informed of the most rumors. Rumors are controlled by having current plant status and obtaining responses for rumors a single source of information. In an and public inquirie~. emergency, a rumor control network is EP 8.3.2.6 Public Response Staff activated. News media are monitored to The Public Response Staff reports to the Public detect and respond to misinformation. Response Coordinator and is responsible for Offsite information is the responsibility of coordinating and developing responses to rumors and offsite agencies; however, rumor control public inquiry. is coordinated between the State and licensee. E9-93 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emerge_ncy Plan Justification Revision 36 Media Education EP G.2 News Media Training The commitment wording was standardized Information is provided and a program is A program will be offered each calendar year to and relocated to the SNC Standard offered each calendar year to acquaint acquaint the news media with the methodology for Emergency Plan. the news media with the methodology for obtaining information during an emergency and with obtaining information during an overall emergency preparedness at APC/GPC nuclear emergency and background about overall plants, as appropriate. Training will include information EP at HNP. Included is information about about the plant, emergency response, and the role of the plant, radiation and the role of the JIC. the JIC, as well as opportunities to participate in drill activities H. EMERGENCY FACILITIES AND EP H.1 Onsite Emergency Response Facilities The commitment wording was standardized EQUIPMENT SNC-operated nuclear power plants have established a and relocated to the SNC Standard Following the declaration of an TSC and an onsite OSC, which are staffed and Emergency Plan. emergency, response activities will be activated within 75 minutes of the declaration of an Alert coordinated at a number of facilities. or higher classification .. Emergency Response The justification for augmentation of the ERO These facilities and the equipment which Facilities may be activated at an Unusual Event at the and activation of respective ERFs is provided will be used for assessment and discretion of the Emergency Director. Until the TSC and separately. monitoring functions are described in this OSC are activated, required functions of these facilities section. are performed in the Control Room. Emergency Facilities Annex 5.1.2: The TSC, which is shared by both units, is The commitment wording was standardized

1. TSC located adjacent to the service building annex. A and relocated to the SNC Standard The TSC, which is shared by both units, sample layout of the TSC is shown in Figure 5.1.A. Emergency Plan and Annex.

is located adjacent to the service building The TSC provides plant management and technical annex. The layout of the TSC is shown in support personnel, including NRC personnel, with Figure H-1. Walking time from the TSC to adequate space to assist plant operating personnel the Control Room is approximately 2 min. located in the Control Room during an emergency. The The TSC covers approximately 2620 ft2. TSC is equipped with technical data displays and has ready access to plant records to allow TSC personnel to. perform detailed analysis and diagnosis of abnormal plant conditions, including assessment of any release of radioactivity to the environment. E9-94 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Section H.1: The TSC provides plant EP H.1.2: The TSC is sized to accommodate ERO The commitment wording was standardized management and technical support responders and NRG Representatives and relocated to the SNC Standard personnel [including five NRG personnel] Emergency Plan with adequate space to assist plant operating personnel located in the Control Room during an emergency. The TSC is equipped with technical data Annex 5.1.2: The TSC maintains access to drawings The commitment wording was standardized displays and has ready access to plant and records necessary for the response to an and relocated to the Site Annex. records. emergency event at HNP. The TSC structure and ventilation system EP H.1.2: Personnel in the TSC are protected from The commitment wording was standardized are designed to ensure that TSC radiological hazards, including direct radiation and and relocated to the SNC Standard personnel are protected from radiological airborne contaminants under accident conditions, with Emergency Plan and Annex. hazards similar to that of the Control similar radiological habitability standards as Control Room. Room personnel. Annex 5.1.2: The TSC structure and ventilation system are designed to ensure that TSC personnel are protected from radiological hazards similar to that of the Control Room. An ARM which alarms on abnormal EP H.1.2: To ensure adequate radiological protection, The commitment wording was standardized radiation levels is provided in the TSC. radiation monitoring equipment has been installed in the and relocated to the SNC Standard TSC, or periodic radiation surveys are conducted. These Emergency Plan and Annex. systems indicate radiation dose rates while in use. Annex 5.1.2: An area radiation monitor, which alarms on abnormal radiation levels, is provided in the TSC. Portable radiation monitors are available Annex 5.1.2: In addition, portable radiation monitors are The commitment wording was standardized for personnel in transit from the TSC to available for personnel in transit from the TSC to other and relocated to the Site Annex. other areas. areas. Self-contained breathing apparatus Annex 5.1.2: Self Contained Breathing Apparatus The commitment wording was standardized (SCBA) are provided in the TSC. (SCBA) are provided in the TSC. and relocated to the Site Annex. Anticontamination clothing is available at Annex 5.1.2: Anticontamination clothing is available at The commitment wording was standardized the nearby OSC. the nearby OSC. and relocated to the Site Annex. E9-95 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 The TSC normal lighting is supplied from Annex 5.1.2: The TSC normal lighting is supplied from The commitment wording was standardized normal site power through a motor control normal site power through a motor control center backed and relocated to the Site Annex. center backed up by the security DG. up by the security DG. Power for the TSC vital equipment is Annex 5.1.2: Power for the TSC vital equipment is The commitment wording was standardized provided from either the motor control provided from either the motor control center backed up and relocated to the Site Annex. center backed up by the security DG or by the security DG, or from a battery backed from a battery-backed uninterruptible uninterruptible power supply system. power supply system. Power to the de system is provided via Annex 5.1.2: Power to the DC system is provided by The commitment wording was standardized battery chargers, one of which is powered battery chargers, one of which is powered from this and relocated to the Site Annex. from this same motor control center. same motor control center. The TSC records area maintains copies Annex 5.1.2: The TSC records area maintains copies The commitment wording was standardized of the following documents: TS. Plant Operating Procedures. of the following documents: Technical Specifications. Plant Operating Procedures. and relocated to the Site Annex. EOP.

Final Safety Analysis Reports (FSARs).

Final Safety Analysis Reports (FSARs).

Emergency Plan .

System piping and instrumentation

Emergency Plan Implementing Procedures .

diagrams and heating, ventilation,

Plant Operating Records .

and air-conditioning (HVAC) flow

System piping and instrumentation diagrams; diagrams. heating, ventilation, and air-conditioning (HVAC)

Piping area drawings. flow diagrams. Electrical one-line, elementary, and wiring

Electrical one line, elementary, and wiring diagrams. diagrams.

Control logic and loop diagrams.

Control logic and loop diagrams .

Emergency Plan and implementing procedures. Section H.1: The above records are Annex 5.1.2: The above records are updated as The commitment wording was standardized available in current form and are updated, necessary to ensure the content is accurate and and relocated to the Site Annex. as necessary. complete. E9-96 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Section H.1: In the event the TSC No equivalent Plan Statement. Relocation of the TSC will be controlled becomes uninhabitable during an procedurally on an event-specific basis. The emergency, the Control Room will serve Control Room is a potential relocation point. as an alternate location for TSC The alternative facility developed as part of management. the November Emergency Preparedness rulemaking provides another option. Operations at the TSC are directed by the EP B.2.1.2 TSC Manager The commitment wording was standardized TSC Manager. The TSC Manager reports to the TSC ED and is and relocated to the SNC Standard responsible for coordinating activities between the TSC Emergency Plan. and other emergency response facilities, directing the activities of the TSC staff, and ensuring communications are established with applicable offsite agencies. osc Annex 5.1.3 Operations Support Center (SEP H.1.3) The commitment wording was standardized The OSC consists of the service building The OSC consists of the service building break room and relocated to the Site Annex breakroom and other areas, as and other areas available for staging of support necessary, to stage support personnel. personnel. The OSC includes groups such as EP B.2.2.7: Selected personnel report to the OSC as The commitment wording was standardized Instrument Technicians, Mechanics, directed. Emergency personnel from the Maintenance, and relocated to the SNC Standard Electricians, Nuclear Chemistry and HP Operations, and RP/Chemistry Departments are Emergency Plan. Technicians, System Operators, and directed to report to the OSC. oncoming shift personnel who assemble to aid in the response to an emergency. In addition, the OSC is the initial Annex 5.1.3 Operations Support Center (OSC) The commitment wording was standardized assembly point for all radiological This includes groups such as Instrument and Control and relocated to the Annex emergency team (RET) members. Technicians, Mechanics, Electricians, Nuclear Chemistry and Radiation Protection (RP) Technicians, System Operators, and oncoming shift personnel who assemble to aid in the response to an emergency. Briefings will be held with each team prior Annex 5.1.3 Operations Support Center (OSC) The SNC Standard Emergency Plan and to being dispatched. Work to be Briefings will be held with each team prior to being Annex maintain the commitment to assemble performed, cautions, plant conditions, and dispatched. and dispatch event response teams from the radiological information will be included in OSC. The details of team management will the briefings. be relocated to EPIPs. E9-97 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Status boards containing plant conditions No equivalent Plan/Annex statement The SNC Standard Emergency Plan and and emergency classification will be Annex maintain the commitment to assemble available in the OSC. and dispatch event response teams from the OSC. The details of team management will be relocated to EPIPs. Emergency kits containing radiation EP H.1.3: Emergency supplies are maintained in the The commitment wording was standardized monitoring equipment, first-aid supplies, OSC. When an emergency condition exists at one and relocated to the SNC Standard decontamination supplies, breathing SNC-operated nuclear power plant, additional supplies Emergency Plan. apparatus, portable lighting, and can be obtained from other unaffected plants and SNC hand-held radios are available to the resources upon request. OSC. In the event the OSC becomes EP H 1.3: Alternate locations are available should the The commitment wording was standardized uninhabitable during an emergency, OSC OSC become uninhabitable. and relocated to the SNC Standard functions will be conducted from the Annex Section 5.1.3: If the OSC is deemed Emergency Plan. alternate OSC located in the Simulator uninhabitable, the OSC may be moved to other Building. locations as deemed appropriate by the OSC Manager Operations at the OSC are directed by EP 8.2.2.1 OSC Manager The commitment wording was standardized the OSC Manager. The OSC Manager reports to the TSC Manager and and relocated to the SNC Standard directs a staff in providing labor, tools, protective Emergency Plan. equipment, and parts needed for emergency repair, damage control, firefighting, search and rescue, first aid, and recovery. EOF EP H.2 Offsite Emergency Facilities The details of the EOF have been Description of EOF operations and EP H.2.1 Emergency Operations Facility incorporated into Section H of the SNC staffing is contained in Appendix 7. The EOF is the central location for management of the Standard Emergency Plan. offsite emergency response, coordination of radiological assessment, and management of initial recovery The comparative analysis is included in the operations. The EOF is a dedicated facility located in justification section for Appendix 7. Birmingham, Alabama, and serves as the EOF for SNC sites (VEGP, FNP, and HNP). The EOF is procedurally required to be activated within 75 minutes following the declaration of an Alert or higher classification. E9-98 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Available (Simulator Building) classrooms EP H.1.3 Operations Support Center (OSC) The SNC Standard Emergency Plan and and conference rooms will be utilized for The OSC has been established to provide an area for Annex maintain the commitment to assemble field monitoring team assembly and coordinating and planning activities and staging and dispatch event response teams from the dispatch activities and for the alternate personnel and equipment. The OSC responders OSC. The details of team management will OSC. include groups such as Instrument and Control be relocated to EPIPs. Technicians, Mechanics, Electricians, Nuclear Chemistry and RP Technicians, Operations personnel, and oncoming shift personnel. Additional space is available to accommodate personnel as required. If the OSC is deemed uninhabitable, the OSC may be moved to other locations as deemed appropriate by the OSC Manager. This area of the Simulator Building has a EP H 1.3: Alternate locations are available should the The commitment wording was standardized ventilation system that is functionally OSC become uninhabitable. and relocated to the SNC Standard similar to the system used in the TSC Annex Section 5.1.3: If the OSC is deemed Emergency Plan. without charcoal filtration. During normal uninhabitable, the OSC may be moved to other mode of operation, a slight positive locations as deemed appropriate by the OSC Manager. pressure is maintained. During emergency operation, no outside air is allowed and positive pressure is not maintained. The ventilation system has recirculation through high-efficiency particulate air filters during emergency mode only. Section H.4: This location is designed to provide a radiation protection shielding factor of 5. Dedicated portable radiation monitors are available for surveillance. Normal power to the simulator building is No equivalent Plan/Annex statement The simulator building is an alternative from offsite power. Emergency lighting is location for the OSC. The description of provided by 3-hour wall packs. power is not required in the Plan. E9-99 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Kits containing equipment for conducting Annex 5.1.3 Emergency kits containing radiation The commitment wording was standardized offsite radiological monitoring are located monitoring equipment, first-aid supplies, and relocated to the Site Annex. in the Simulator Building on plant site. decontamination supplies, breathing apparatus, portable lighting, and portable radios are available to the OSC. Alternative Facility EP H.1.4 Alternative Facilities The wording was standardized and relocated During a security related event or other An Alternative Facility for staging of ERO personnel has to the SNC Standard Emergency Plan and event that precludes onsite access, the been designated at the sites. In the event of a Security or Site Annex. TSC and OSC ERO staff will be directed Hostile Action threat or event, the designated Alternative to an alternative facility. This facility is Facility may also serve as an evacuation location for TSC located in the Plant Hatch JIC building and OSC personnel. The Alternative Facility is designed to across the hall from the Public be accessible in the event of an onsite HAB event and has Information Workroom and adjacent to the capability to: the Public Response Workroom. The

Communicate with the Control-Room, Security, and the EOF.

alternative facility is equipped with the

Conduct engineering assessment activities necessary communications and data links including damage control team planning and to support communications with the preparation.

control room, site security, and the EOF. The functions of Notification and PARs will be performed The available communications and data from the EOF should the Alternative Facility be activated. links also provide access to SNC Details of Alternative Facilities can be found in the Site document management resources and Specific Annex. work planning resources for performing Annex 5.1.4 Alternative Facility (SEP H.1.4) engineering assessment activities, During a security-related event or other event that including damage control team planning precludes onsite access, the TSC and OSC ERO will be and preparation for return to the site. directed to an alternative facility. This facility is located adjacent to the Georgia Power Company operating headquarters in Vidalia, Georgia and is approximately 22 miles from HNP. The alternative facility is equipped with the necessary communications and data links to support communications with the control room, site security, and the EOF. The available communications and data links also provide access to SNC document management resources, and to work planning resources for performing engineering assessment activities including damage control team planning and preparation for return to the site. Guidance for use of the facility is in site procedures. E9-100 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Joint Information Center (JIC) EP H.2.2 Corporate Media Center (CMC) The Emergency Communications Plan has Description of the JIC resides in the HNP Upon notification of an Alert or higher classification, the been standardized and incorporated into the Emergency Communications Plan. Public Information Director and corporate staff assigned ERO Staffing as described in Section B, to JIC functions will assemble at the CMC. The CMC, Facilities as described in Section H, the located at the Atlanta/Birmingham corporate Emergency Communications portion of headquarters building of Georgia Power Section G of the SNC Standard Emergency Company/Alabama Power Company, as appropriate, is Plan and Section 5.1.6 of the Hatch Annex. the official location for coordination of emergency communications response until the site specific JIC has been activated. The Public Information Director will coordinate with the EOF Emergency Director and affected OROs and determine whether to activate the site specific JIC. When the decision is made to activate the JIC the CMC will maintain emergency communications response coordination until the site specific JIC is ready to assume these responsibilities. Once overall responsibility for emergency communications response transfers to the site specific JIC the remaining CMC staff will provide support for the JIC as needed. EP H.2.3 Joint Information Center (JIC) The commitment wording was standardized After the initial notification of an emergency at the Alert and relocated to the SNC Standard classification or higher, the Public Information Director will Emergency Plan. 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 CMC to the site specific JIC. Once the JIC is staffed the Public Information Director will. manage the emergency communications response from the JIC in coordination with ORO public information officers (PIOs). Site specific JIC is provided in the site specific Annexes. E9-101 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Activation and Staffing of Emergency EP H.1: SNC-operated nuclear power plants have The wording was standardized to address the Facilities established a TSC and an onsite OSC, which are staffed levels activation would occur. The statement During the initial stages of an emergency, and activated within 75 minutes of the declaration of an of non-activation for the NUE was eliminated. activities at HNP are directed from the Alert or higher classification .. Control Room. For a NUE, no other facilities are activated. Upon declaration of an Alert or higher EP H.1: SNC-operated nuclear power plants have The commitment to activate the facilities at level classification, the TSC is activated established a TSC and an onsite OSC, which are staffed Alert or higher was relocated to the SNC and becomes fully operational ASAP, but and activated within 75 minutes of the declaration of an Standard Emergency Plan. not later than approximately 1 hour Alert or higher classification .. following the initial notification. The activation time commitment is justified in the Technical Analysis Section of this LAR. Overall direction and control are EP H.1.2 Technical Support Center (TSC) The wording was standardized and relocated exercised from the TSC for an Alert or TSC functions include: to the SNC Standard Emergency Plan. Higher situation.

Support for the Control Room's emergency response efforts.
Performance of response management functions when in Command & Control.

Activation of the OSC is initiated at an EP H.1 SNC-operated nuclear power plants have The commitment to activate the facilities at Alert or higher level classification. established a TSC and an onsite OSC, which are Alert or higher was relocated to the SNC staffed and activated within 75 minutes of the Standard Emergency Plan. declaration of an Alert or higher classification .. The OSC becomes operational ASAP, but EP H.1: SNC-operated nuclear power plants have The commitment to activate the facilities at not later than approximately 1 hour established a TSC and an onsite OSC, which are staffed Alert or higher was relocated to the SNC following initial notification. and activated within 75 minutes of the declaration of an Standard Emergency Plan. Alert or higher classification .. The activation time commitment is justified in the Technical Analysis Section of this LAR. E9-102 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Activation and staffing of the EOF is EP H.2 Offsite Emergency Facilities EOF activation has been incorporated into contained in Appendix 7. EP H.2.1 Emergency Operations Facility Section H of the SNC Standard Emergency The EOF is the central location for management of the Plan. offsite emergency response, coordination of radiological assessment, and management of initial recovery The commitment to activate the facilities at operations. The EOF is a dedicated facility located in Alert or higher was relocated to the SNC Birmingham, Alabama, and serves as the EOF for SNC Standard Emergency Plan. sites (VEGP, FNP, and HNP). The EOF is procedurally required to be activated within 75 minutes following the The activation time commitment is justified in declaration of an Alert or higher classification. the Technical Analysis Section of this LAR. For security related events, the activation EP H.1.4 Alternative Facilities The wording was standardized and relocated of emergency facilities may be delayed as An Alternative Facility for staging of ERO personnel has to the SNC Standard Emergency Plan. described in section B. Activation of ERO been designated at the sites. In the event of a Security members will be performed for hostile or Hostile Action threat or event, the designated action based events to promptly staff Alternative Facility may also serve as an evacuation alternative facilities, in order to minimize location for TSC and OSC personnel. The Alternative delays in overall site response. The ERO Facility is designed to be accessible in the event of an will be staged in a manner that supports onsite HAB event and has the capability to: rapid response to limit or mitigate site

Communicate with the Control Room, Security, damage or the potential for an offsite and the EOF.

radiological release.

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

The functions of Notification and PARs will be performed from the EOF should the Alternative Facility be activated. Details of Alternative Facilities can be found in the Site Specific Annex. E9-103 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Plant Monitoring and Data Handling EP H.5.1: Meteorological Instrumentation: A permanent The commitment wording was standardized Systems meteorological monitoring station is located near each and relocated to the SNC Standard

1. Geophysical Phenomena Monitors plant for the acquisition and recording of wind speed, Emergency Plan and Annex.

a. Meteorological wind direction, and ambient and differential temperatures Meteorological monitoring is in place at for use in making offsite dose projections. Meteorological HNP. The instruments are mounted on a information is displayed in the CR, TSC, and EOF.

100-meter primary tower located to the Annex Section 5.6.1: Meteorological monitoring is in south of the power block and on a place at HNP. The instruments are mounted on a 45-meter backup tower located to the 100-meter primary tower located to the south of the southeast of the power block. power block and on a 45-meter backup tower located to the southeast of the power block. Section H: Parameters measured and Annex 5.6.1: Parameters measured and transmitted to The commitment wording was standardized transmitted to the Control Room include: the Control Room include: and relocated to the Site Annex.

Winds peed .
Wind direction. ..
Wind speed.

Wind direction. Vertical temperature difference.

Vertical temperature difference.
Ambient temperature.
Ambient temperature.

A building that houses meteorological Annex 5.6.1: A building that houses meteorological The commitment wording was standardized equipment is located near the base of equipment is located near the base of each tower. The and relocated to the Site Annex. each tower. The system is powered by system is powered by an uninterruptible power supply an uninterruptible power supply. for high availability. Additionally, meteorological information Annex 5.6.1: Additionally, meteorological information The commitment wording was standardized can be obtained from the National can be obtained from the National Weather Service to and relocated to the Site Annex. Weather Service to supplement onsite supplement onsite data and provide a backup to the data and provide a backup to the plant plant meteorological monitoring program on an as-meteorological monitoring program. needed basis. The important parameters for Annex 5.6.1 The important parameters for The commitment wording was standardized characterizing the transport of airborne characterizing the transport of airborne radioactivity are and relocated to the Site Annex. radioactivity are windspeed, wind wind speed, wind direction, and atmospheric stability direction, and atmospheric stability (e.g., (e.g., derived from the standard deviation of the derived from the standard deviation of the horizontal wind direction or vertical temperature horizontal wind direction or vertical difference). temperature difference). E9-104 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 These meteorological parameters are Annex 5.6.1 These meteorological parameters are used The commitment wording was standardized used in a calculational methodology to in a calculation methodology to assess the offsite and relocated to the Site Annex. assess the offsite radiological radiological consequences of accidental releases of consequences of accidental releases of airborne radioactivity. The methodology is described in airborne radioactivity. The methodology is Section I, Accident Assessment, of the SNC Standard described in Section I, Accident Emergency Plan. Assessment.

b. Hydrologic Annex 5.6.1 Hydrologic_(SEP H.5.1) The commitment wording was standardized The normal and emergency source of The normal and emergency source of plant cooling and relocated to the Site Annex.

plant cooling water is the Altamaha River, water is the Altamaha River, which provides makeup to which provides makeup to the cooling the cooling towers. The probable maximum flood level towers. The probable maximum flood is approximately 105 ft msl. level is approximately 105 ft msl.

c. Seismic EP H.5.1: Seismic Monitoring: The seismic monitoring The commitment wording was standardized Seismic monitoring instrumentation for system measures and records the acceleration of the and relocated to the SNC Standard HNP consists of time-history structure if activated by an earthquake of sufficient Emergency Plan and Site Annex.

accelerographs, peak recording magnitude. It also provides signals for immediate remote accelerographs (PRAs), a indication that specific preset response accelerations response-spectrum recorder, and seismic have been exceeded. switches. Annex Section 5.6.1: Seismic monitoring instrumentation for HNP consists of time history accelerographs, peak recording accelerographs (PRAs), a response spectrum recorder, and seismic switches. Activation of the seismic switches causes an audible and visual annunciation in the Control Room to alert the plant operator (PO) that an earthquake has occurred. These initial set points are based on experience in existing plants and may be changed once significant plant operating data, which indicate that a different set point will provide better strong-motion accelerometer (SMA) system operation, are obtained. One triaxial seismic switch, with a Annex 5.6.1: One triaxial seismic switch, with a The commitment wording was standardized horizontal setpoint of 0.08 g, is installed horizontal set point of 0.08g, is installed on the drywell and relocated to the Site Annex. on the drywell pedestal on the 87 ft level pedestal on the 87 ft level of the Unit 2 reactor building. of the Unit 2 reactor building. E9-105 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 A second seismic switch is located Annex 5.6.1: A second seismic switch is located outside The commitment wording was standardized outside the biological shield on the 185 ft the biological shield on the 185 ft level of the Unit 2 and relocated to the Site Annex. level of the Unit 2 reactor building and reactor building and has a vertical set point of 0.063g. has a vertical setpoint of 0.063 g. They are backup devices which actuate Annex 5.6.1: They are backup devices which actuate The commitment wording was standardized visual and audible annunciators in the visual and audible annunciators in the Control Room. and relocated to the Site Annex. Control Room. Activation of the seismic switches causes Annex 5.6.1 Activation of the seismic switches causes The commitment wording was standardized an audible and visual annunciation in the an audible and visual annunciation in the Control Room and relocated to the Site Annex. Control Room to alert the plant operator to alert the plant operator (PO) that an earthquake has (PO) that an earthquake has occurred. occurred. These initial set points are based on These initial setpoints are based upon experience in existing plants and may be changed once experience in existing plants and may be significant plant operating data, which indicate that a changed once significant plant operating different set point will provide better strong-motion data, which indicate that a different accelerometer (SMA) system operation, are obtained. setpoint will provide better strong-motion accelerometer (SMA) system operation, are obtained.

d. Fire Detection EP H.5.4: The Fire Detection System is designed to The commitment wording was standardized The fire detection system at HNP includes quickly detect products of combustion or heat in and relocated to the SNC Standard smoke and thermal detectors and manual designated areas of the plant. The fire alarm Emergency Plan.

fire alarms. Fire detection systems are communication systems and subsystems are located at provided in all areas with safe shutdown strategic points throughout the plant to warn personnel of equipment, as well as other locations a fire or other emergency conditions. Additional throughout the plant. In addition to description of the fire system is provided in the FSAR. initiating fire suppression systems, indications from the fire detection system are transmitted to the Control Room. E9-106 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Radiation Monitoring System (RMS) EP H.5.2.1 Radiation Monitoring System (RMS) The commitment wording was standardized The RMS receives and processes Radiation monitoring instruments are located at and relocated to the SNC Standard radiological input readings during normal selected areas within the plant to detect, measure, and Emergency Plan. and abnormal operating and accident record radiation levels. The monitors are comprised of conditions; measures, evaluates, and area, airborne and air particulate monitors. reports radioactivity in designated areas;

Area monitors respond to gamma radiation.

and monitors releases of radioactive

Airborne monitors detect and measure radioactive materials in liquid and gaseous effluents. gaseous effluent concentrations.

Data from the RMS are available in the

Air Particulate detectors capture and measure Control Room. A more detailed airborne particulate description of the RMS is provided in the Emergency response procedures provide methods for HNP-2-FSAR, Section 11.4. determining relationships between monitor readings and releases, material available for release and extent of core damage.

Section H: The post-accident radiation EP H.5.2.2: The process sampling system consists of the The commitment wording was standardized monitors provide radiation monitoring normal sampling system and additional sampling panels and relocated to the SNC Standard after an accident. located throughout the plant. Pre-designated monitoring Emergency Plan. and sampling points are listed in site procedures. Sampling systems are installed or can be modified to permit reactor coolant and containment atmosphere sampling even under severe accident conditions. The system can provide information on post-accident plant conditions to allow operator actions to mitigate and control the course of an accident. Various chemical analyses and radiological measurements on these samples can be performed, including the determination of radionuclide concentrations. E9-107 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 There are three types of radiation EP H.5".2.1 Radiation Monitoring System (RMS) The commitment wording was standardized monitors in the RMS: airborne and air Radiation monitoring instruments are located at and relocated to the SNC Standard particulate radiation monitors, liquid selected areas within the plant to detect, measure, and Emergency Plan. radiation monitors, and post-accident record radiation levels. The monitors are comprised of radiation Backup power to the post- area, airborne and air particulate monitors. accident monitors is supplied by a DG to

Area monitors respond to gamma radiation .

ensure against interruption of monitor

Airborne monitors detect and measure radioactive operation and loss of data. gaseous effluent concentrations.
Air Particulate detectors capture and measure airborne particulate Emergency response procedures provide methods for determining relationships between monitor readings and releases, material available for release and extent of core damage.

The post-accident radiation monitors EPl.2 Continuing and Post Accident Assessment The commitment wording was standardized provide radiation monitoring after an The resources available to provide initial and continuing and relocated to the SNC Standard accident. information for accident assessment throughout the Emergency Plan. course of an event include plant parameter display systems, liquid and gaseous sampling system, area and process radiation monitoring Systems, and Accident Radiation Monitoring Systems. The monitors are comprised of area, EP H.5.2.1: The monitors are comprised of area, The commitment wording was standardized airborne, and air particulate monitors. airborne, and air particulate monitors and relocated to the SNC Standard Emergency Plan. Area monitors respond to gamma EP H.5.2.1: Area monitors respond to gamma The commitment wording was standardized radiation photons within any energy range radiation. and relocated to the SNC Standard from 60 KeV to 3 MeV. Emergency Plan. E9-108 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Airborne monitors are capable of EP H.5.2.1: Airborne monitors detect and measure The commitment wording was standardized detecting and measuring radioactive radioactive gaseous effluent concentrations. and relocated to the SNC Standard gaseous effluent concentrations with Emergency Plan. compositions ranging from fresh equilibrium noble gas fission product mixtures to 10-day-old mixtures. Backup power to the post-accident No equivalent Plan/Annex statement monitors is supplied by a DG. SPDS EP H 5.3.2: The SPDS parameters are available during The commitment wording was standardized The SPDS provides a display of plant normal and abnormal operating conditions in the Control and relocated to the SNC Standard parameters from which the status of Room, TSC, and EOF. Emergency Plan. operation can be assessed, in the Control Room, the TSC, and the EOF. E9-109 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 The SPDS performs the following EP H.5.3.2 Safety Parameter Display System (SPDS) The commitment wording was standardized functions: The SPDS parameters are available is in operation and relocated to the SNC Standard

Aids Control Room operators in the during normal and abnormal operating conditions in the Emergency Plan.

rapid detection and identification of Control Room, TSC, and EOF. abnormal operating conditions. EP 1.1 Some of the key plant parameters monitored in

Provides additional specific information the Control Room are assembled into a single display used to analyze and diagnose the cause on the Safety Parameter Display System (SPDS). The of abnormal operating conditions. SPDS monitors such parameters as: reactor coolant
Monitors plant response to corrective system pressure, reactor or pressurizer water level, actions. containment pressure, suppression pool water level and
Provides grouping of parameters to temperature, reactor power, safety system status, enhance the operators' capability to containment radiation level, and effluent monitor quickly assess plant status without readings. The instrumentation and equipment surveying concurrently all Control Room capabilities available for emergency facilities are displays. described in Section H
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 codings.
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, RCS integrity, radioactivity control, containment integrity, and other selected parameters.

E9-110 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 The SPDS in the Control Room consists EP 1.1 Some of the key plant parameters monitored in The commitment wording was standardized of displays of sets of concentrated the Control Room are assembled into a single display and relocated to the SNC Standard parameters from which plant safety status on the Safety Parameter Display System (SPDS). The Emergency Plan. can be rapidly assessed. SPDS monitors such parameters as: reactor coolant system pressure, reactor or pressurizer water level, containment pressure, suppression pool water level and temperature, reactor power, safety system status, containment radiation level, and effluent monitor readings. The instrumentation and equipment capabilities available for emergency facilities are described in Section H. SPDS can also be displayed in the TSC EP H.5.3.2 Safety Parameter Display System (SPDS) The commitment wording was standardized and the EOF to maximize the exchange The SPDS parameters are available during normal and and relocated to the SNC Standard of information between these facilities and abnormal operating conditions in the Control Room, Emergency Plan. the Control Room. TSC, and EOF. The SPDS is in operation during normal EP H.5.3.2 Safety Parameter Display System (SPDS) The commitment wording was standardized and abnormal operating conditions. The SPDS parameters are available during normal and and relocated to the SNC Standard abnormal operating conditions in the Control Room, Emergency Plan. TSC, and EOF. E9-111 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 The selection of parameters to be EP 1.1 Some of the key plant parameters monitored in The commitment wording was standardized displayed on the SPDS is based on the the Control Room are assembled into a single display and relocated to the SNC Standard parameters required to monitor the critical on the Safety Parameter Display System (SPDS). The Emergency Plan. safety functions identified by the General SPDS monitors such parameters as: reactor coolant Electric Owners Group (GEOG). These system pressure, reactor or pressurizer water level, parameters will aid Control Room containment pressure, suppression pool water level and operators in determining the safety status temperature, reactor power, safety system status, of the plant. The justification for selecting containment radiation level, and effluent monitor these parameters is contained in the readings. The instrumentation and equipment analyses and background -information capabilities available for emergency facilities are generated by the GEOG to support the described in Section H. critical safety function restoration guidelines. The emergency response guidelines, which contain the critical safety function restoration guidelines and identify the parameters used to monitor the critical safety functions, have been submitted to the NRC by the GEOG. Post-accident Sampling Capability EP 1.2 Continuing and Post Accident Assessment The commitment wording was standardized Capability exists for obtaining grab The resources available to provide initial and continuing and relocated to the SNC Standard samples of reactor coolant samples information for accident assessment throughout the Emergency Plan. (RCS), suppression pool coolant course of an event include plant parameter display samples, and primary containment systems, liquid and gaseous sampling system, area and atmosphere samples. Vcirious chemical process radiation monitoring Systems, and Accident analyses and radiological measurements Radiation Monitoring Systems. Descriptions of these on these samples can be performed, systems are given in Section H. Details on performing including the determination of post-accident sampling are in the plant-specific radionuclide concentrations. procedures. E9-112 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Analysis may be performed onsite if EP A.3.5 Radiological Monitoring Assistance The commitment wording was standardized radiological conditions allow; otherwise, Radiological monitoring in the plant and in the environs and relocated to the SNC Standard analysis will be performed at an offsite both, onsite and offsite, will be augmented by outside Emergency Plan. laboratory facility. vendors as necessary. Initial radiological monitoring will be performed by available Southern Company resources (e.g., Georgia Power Company (GPC) Central Laboratory). EP A.3.6 Contract Laboratories SNC-operated plants maintain contracts with offsite laboratories to assist with emergency analytical services. Copies of these contracts are maintained in accordance with Emergency Plan procedures. The results from these analyses are used EP C.3.1 Onsite Laboratory The commitment wording was standardized to assess the extent of core damage and The onsite laboratory/counting rooms at SNC-operated and relocated to the SNC Standard the potential source term. nuclear power plants are the primary facility for radiation Emergency Plan. monitoring and analysis efforts. The onsite laboratory is the central point for receipt and analysis of onsite samples and includes equipment for chemical and radiological analyses. The plant laboratories have the capability of quantitative analysis of marine and air samples, and qualitative analysis of terrestrial samples. Additional facilities for counting and analyzing samples are available at the other SNC-operated nuclear plants or state and federal laboratory services. These laboratories can act as backup facilities in the event that the affected nuclear power plant's counting room and laboratory become unusable or the capacity or capability of the plant's laboratory is exceeded. EP C.3.2 Contract Laboratories Additional outside analytical assistance may be requested from contracted vendors. These laboratories provide bioassay analysis and radiochemical analysis services. E9-113 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Laboratory Facilities EP H.5.2.3: SNC sites have a laboratory facility for The wording was standardized and relocated HNP has a laboratory facility for analysis analysis of radioactive samples. to the SNC Standard Emergency Plan. of radioactive samples. The major pieces of equipment include a solid-state gamma spectrometer and a beta/gamma gas proportional counter. The training section of the simulator EP C.3.1 Onsite Laboratory The commitment wording was standardized building includes a laboratory which can The onsite laboratory/counting rooms at SNC-operated and relocated to the SNC Standard be used for analysis of environmental nuclear power plants are the primary facility for radiation Emergency Plan. media. monitoring and analysis efforts. The onsite laboratory is the central point for receipt and analysis of onsite samples and includes equipment for chemical and radiological analyses. The plant laboratories have the capability of quantitative analysis of marine and air samples, and qualitative analysis of terrestrial samples. Additional facilities for counting ahd analyzing samples are available at the other SNC-operated nuclear plants or state and federal laboratory services. These laboratories can act as backup facilities in the event that the affected nuclear power plant's counting room and laboratory become unusable or the capacity or capability of the plant's laboratory is exceeded. EP C.3.2 Contract Laboratories Additional outside analytical assistance may be requested from contracted vendors. These laboratories provide bioassay analysis and radiochemical analysis services. E9-114 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Analysis instrumentation suitable for EP C.3.1 Onsite Laboratory The commitment wording was standardized analyzing environmental samples is The onsite laboratory/counting rooms at SNC-operated and relocated to the SNC Standard available at that location. nuclear power plants are the primary facility for radiation Emergency Plan. monitoring and analysis efforts. The onsite laboratory is the central point for receipt and analysis of onsite samples and includes equipment for chemical and radiological analyses. The plant laboratories have the capability of quantitative analysis of marine and air samples, and qualitative analysis of terrestrial samples. Additional facilities for counting and analyzing samples are available at the other SNC-operated nuclear plants or state and federal laboratory services. These laboratories can act as backup facilities in the event that the affected nuclear power plant's counting room and laboratory become unusable or the capacity or capability of the plant's laboratory is exceeded. EP C.3.2 Contract Laboratories Additional outside analytical assistance may be requested from contracted vendors. These laboratories provide bioassay analysis and radiochemical analysis services. Backup laboratory facilities are available EP H.6.3: External facilities for counting and analyzing The wording was standardized and relocated at Plant Vogtle. This backup capability samples, and for dosimetry processing, can be provided to the SNC Standard Emergency Plan. would be used if facilities at HNP were by other SNC-operated plants including the GPC Central not available. Laboratory, state, federal or contracted laboratories. Additionally, arrangements have been EP C.3.2 Contract Laboratories The commitment wording was standardized made for commercial offsite laboratory Additional outside analytical assistance may be and relocated to the SNC Standard analysis, as needed. requested from contracted vendors. These laboratories Emergency Plan. provide bioassay analysis and radiochemical analysis services. E9-115 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Other Process Parameters EP H.5.3 Process Monitors The commitment wording was standardized Several other process parameters, The Control Room and redundant backup locations are and relocated to the SNC Standard including RCS pressure and temperature, equipped with extensive plant process monitors for use Emergency Plan. containment pressure and temperature, in both normal and emergency conditions. These liquid levels and other system indications, indications include reactor coolant system pressure and are useful both for the initiation phase and temperatures, containment pressure and temperature, continued assessment. Several of these and various liquid levels, flow rates, status, or lineup of are used in the classification process as equipment components. discussed in Section D, Emergency EP H.5.3.1 Plant Monitoring/Information System Classification System. A plant monitoring/information system provides the data acquisition and database capability for performing plant monitoring and functions. The system is designed to scan, convert to engineering units, make sensor range and alarm limit checks, apply required transformations, store for recall and analysis, and display the reading of transformed data from plant instrumentation. The system scans flows, pressures, temperatures, fluid levels, radiation levels, equipment, and valve status at required frequencies. EP H.5.3.2 Safety Parameter Display System (SPDS) The SPDS is in operation during normal and abnormal operating conditions in the Control Room, TSC, and EOF. E9-116 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Offsite Radiological Monitoring EP H.6.2: SNC-operated nuclear power plants maintain The Fleet Commitment wording is HNP has sufficient portable equipment a sufficient supply of portable offsite radiological standardized to support initial deployment of and trained personnel to field a minimum monitoring equipment. These supplies are located at two environmental field teams. of three field monitoring teams. These each staging point for Field Monitoring Teams. teams are dispatched to offsite locations The two field teams deployment is based on and are also utilized for site boundary and existing industry standards and practices. owner-controlled area surveys. Each team obtains emergency monitoring materials and equipment including dosimetry, two-way radio equipment, meters for measuring gamma and beta/gamma dose rates, and air samplers for collecting particulates and iodines. Emergency Supplies and Equipment EP H.9: Emergency kits are available at each SNC- The commitment wording was standardized Emergency supplies and equipment are operated nuclear power plant. Designated site or and relocated to the SNC Standard located in the Control Room, the TSC, the department procedures identify the equipment in the Emergency Plan and Annex. OSC, and the Simulator Building. various emergency kits. Annex 5.5: Emergency supplies and equipment are located at various plant locations. Procedures require an inspection and operational check of equipment in these kits on a quarterly basis and after each use. Equipment in these kits is calibrated in accordance with the suppliers' recommendations. A set of spares of certain equipment is also maintained to replace inoperative or out-of-calibration equipment. Procedures require an inspection and EP H.8: Emergency facilities and equipment are The commitment wording was standardized operational check of equipment in these inspected and inventoried using appropriate and relocated to the SNC Standard kits on a quarterly basis and after each administrative or department procedures. These Emergency Plan. use. inventories will include requirements that provisions are in place to inspect, inventory, and operationally check emergency equipment/instruments at least once each calendar quarter and as needed. These procedures provide information on location and availability of emergency equipment and supplies. E9-117 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Section H: Spare equipment is also EP H.8: Sufficient reserves of instruments and equipment The commitment wording was standardized maintained to replace inoperative or out- are maintained to replace those removed from and relocated to the SNC Standard of-calibration equipment. emergency kits or lockers for calibration or repair Emergency Plan. Typical listings of the emergency supplies No direct equivalent Plan/Annex kit statement. The SNC Standard Emergency Plan and Site and equipment are included in Appendix EP H.9 Emergency Kits Annex retain the commitment to provide

4. Emergency kits are available at SNC-operated nuclear emergency supplies and equipment.

power plants. Designated site or department procedures identify the equipment in the various Appendix 4 was deleted. The specific emergency kits. Details as to kit locations are found in equipment and supplies is a procedural level the plant-specific procedures. step. Elimination allows more flexibility in maintaining current equipment and supporting the needs of the ERO. I. ACCIDENT ASSESSMENT SECTION I: ACCIDENT ASSESSMENT The wording was standardized and relocated This section describes the methods, 1.1 Systems and Parameters Monitored to the SNC Standard Emergency Plan. systems, and equipment available for SNC-operated nuclear power plants have a assessing and monitoring actual or comprehensive set of plant system and effluent monitors, potential offsite consequences of a as required by the plants' Final Safety Analysis Report. radiological emergency. Sites have identified values characteristic of off-normal values and accidents, and identified the plant parameter values that correspond to the example initiating conditions in the Nuclear Energy Institute (NEI) 99-01 and 07-01 Emergency Action Levels (EALs). These are described in Section D of this plan, and detailed in the site-specific Annexes. E9-118 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Initial assessment actions are the EP B.2.1.1 TSC Emergency Director (ED) The commitment wording was standardized responsibility of the Operations SOS The TSC ED has the authority and responsibility to and relocated to the SNC Standard and/or the SS, using available shift immediately initiate any emergency actions. Once Emergency Plan. personnel. transfer of 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 EOF 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. Section I: Subsequent assessment EP B.1.1: The Emergency Director's non-delegable The commitment wording was standardized actions are directed by the ED. duties include: and relocated to the SNC Standard

Event classification in accordance with the Emergency Plan.

emergency classification system.

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

E9-119 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Plant Parameters EP 1.1 Plant system and effluent parameter values are The commitment wording was standardized Plant system and effluent parameter used to determine accident severity and subsequent and relocated to the SNC Standard values characteristic of the spectrum of emergency classification. Environmental and Emergency Plan. off-normal conditions and accidents and meteorological events are also determining factors in the manner in which these values are emergency classification. An emergency condition can used to classify an emergency are be the result of just one parameter or condition change, provided in Section D or the combination of several. The specific symptoms, parameter values, or events for emergency classification levels are detailed in the plant's site-specific Annex.

. Some of the parameters monitored         EP 1.1 Some of the key plant parameters monitored in       The commitment wording was standardized include: RCS pressure, reactor water       the Control Room are assembled into a single display       and relocated to the SNC Standard level, drywell pressure, drywell radiation on the Safety Parameter Display System (SPDS). The         Emergency Plan.

level, effluent monitor readings, and ARM SPDS monitors such parameters as: reactor coolant readings. system pressure, reactor or pressurizer water level, containment pressure, suppression pool water level and temperature, reactor power, safety system status, containment radiation level, and effluent monitor readings. The instrumentation and equipment capabilities available for emergency facilities are described in Section H. Emergency response procedures include EP D.1.1.1 SNC has and maintains the capability to The commitment wording was standardized methods for quickly assessing plant assess, classify, and declare an emergency condition and relocated to the SNC Standard system and effluent parameter values and within 15 minutes after the availability of indications to Emergency Plan. classifying the emergency condition. plant operators that an EAL threshold has been met or Additional information relative to plant exceeded. Upon identification of the appropriate instrumentation is provided in Section H. emergency classification level, the emergency condition will be promptly declared. E9-120 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Radiological Monitors EP H.5.2.1 Radiation Monitoring System (RMS) The commitment wording was standardized In-plant radiological measurements Radiation monitoring instruments are located at and relocated to the SNC Standard provide information helpful in assessing selected areas within the plant to detect, measure, and Emergency Plan. emergency conditions. Systems are record radiation levels. The monitors are comprised of installed to permit reactor coolant and area, airborne, and air particulate monitors. drywell atmosphere sampling under

Area monitors respond to gamma radiation .

emergency conditions. Post-accident

Airborne monitors detect and measure radioactive sampling capability and the RMS are gaseous effluent concentrations.

described in Section H of this Plan.

Air Particulate detectors capture and measure airborne particulate Emergency response procedures provide methods for determining relationships between monitor readings and releases, material available for release and extent of core damage.

The drywell wide-range radiation monitor EP H.5.2.1: Radiation monitoring instruments are located The commitment wording was standardized and the drywell hydrogen monitor are at selected areas within each plant to detect, measure, and relocated to the SNC Standard used to provide an early indication of the and record radiation levels. The monitors are comprised Emergency Plan. quantity of radioactivity available for of area, airborne, and air particulate monitors. release from the containment.

Area monitors respond to gamma radiation .
Airborne monitors detect and measure radioactive gaseous effluent concentrations.
Air Particulate detectors capture and measure airborne particulate Plant procedures include a correlation EP H.5.2.1 Emergency response procedures provide The commitment wording was standardized between the monitor reading and the methods for determining relationships between monitor and relocated to the SNC Standard extent of core damage. Estimates derived readings and releases, material available for release Emergency Plan.

from these monitor readings are used and extent of core damage. until a sample using PASS has been obtained and analyzed. E9-121 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Determination of Release Rate EP 1.3 Offsite Dose Assessment The commitment wording was standardized Section H of this Plan describes RMS and SNC-operated nuclear power plants use an offsite dose and relocated to the SNC Standard PASS. These systems, in combination assessment program that estimates doses from Emergency Plan. with procedures located in the Control radiological accidents for comparison with the EPA Room, the TSC, and the EOF can provide Protective Action Guidance and acute health effect the information needed to determine the thresholds. The dose calculation model is available in radiological source term. 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. Emergency response procedures provide EP H.5.2.1: Emergency response procedures provide The commitment wording was standardized methods for determining relationships methods for determining relationships between monitor and relocated to the SNC Standard between monitor readings and releases readings and releases, material available for release Emergency Plan. and/or material available for release. and extent of core damage. Dose Projection System EP 1.3 Offsite Dose Assessment The commitment wording was standardized The Meteorological Information Dose SNC-operated nuclear power plants use an offsite dose and relocated to the SNC Standard Assessment System (MIDAS) is the dose assessment program that estimates doses from Emergency Plan. calculation computer model used at HNP. radiological accidents for comparison with the EPA Dispersion is computed using either a Protective Action Guidance and acute health effect straight line or the variable trajectory thresholds. The dose calculation model is available in dispersion model. Both models are time- the Control Room, TSC, and EOF for use in projecting dependent and provide integrated doses, potential offsite doses. as well as dose rates, using EPA 400 dose factors. The dose calculation model will be EP 1.3: The dose calculation model is provided in the The commitment wording was standardized provided in the Control Room, TSC, and Control Room, TSC, and EOF for use in projecting and relocated to the SNC Standard EOF for use in projecting potential offsite potential offsite doses. Emergency Plan. doses. E9-122 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 The TSC will assume responsibility for EP 8.2.1.5: The RP Supervisor assists the Radiation The commitment wording was standardized this function from the Control Room after Protection/Chemistry Group Lead in the OSC in and relocated to the SNC Standard the TSC is activated. determining the extent and nature of radiological or Emergency Plan. hazardous conditions and coordinates offsite dose assessment and offsite Field Monitoring Teams prior to EOF activation. This function will be transferred to the EP 8.3.1.4: The Dose Assessment Supervisor reports to The commitment wording was standardized EOF as soon as practicable from the the EOF Manager and provides oversight of dose and relocated to the SNC Standard TSC, to relieve the TSC of unnecessary assessment, field team control, and protective action Emergency Plan. burden; however, the TSC will maintain recommendation activities in the EOF; and coordinates the capability of dose projections should communication of results with offsite agencies. the EOF not be available. Backup calculations will be performed in the TSC, as needed. Meteorological data are obtained and H.5.1 Geophysical Monitors The commitment wording was standardized evaluated, as described in Section H. The Meteorological Instrumentation: A permanent and relocated to the SNC Standard meteorological data collection system can meteorological monitoring station is located near the Emergency Plan. be accessed directly from the Control plant for the acquisition and recording of wind speed, Room, the TSC, and the EOF. The EOF wind direction, and ambient and differential will be able to provide this information temperatures for use in making offsite dose projections. upon request to any offsite organization. Meteorological information is displayed in the CR, TSC, and EOF. Up to three teams will be deployed for EP 1.7 Environs Surveys and Monitoring The wording was standardized and relocated field monitoring. These teams are In addition to the capabilities and resources described in to the SNC Standard Emergency Plan. available for offsite field monitoring within Section H, SNC-operated nuclear power plants have the the plume exposure pathway EPZ, as ability to take offsite air samples and to directly measure The commitment was modified to support two described in Section H gamma dose rates from a radioactive material release. field teams based on industry norms. The capability to take offsite soil, water, and vegetation samples is provided by a minimum of two (2) Field Monitoring Teams (FMTs). E9-123 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Initially at least two persons can be EP 1.7 Environs Surveys and Monitoring The wording was standardized and relocated dispatched from on-shift personnel for In addition to the capabilities and resources described to the SNC Standard Emergency Plan. offsite surveys. The on-shift HP/Chem in Section H, SNC-operated nuclear power plants have department foreman will provide for field the ability to take offsite air samples and to directly The commitment was modified to support two monitoring coordination until the TSC is measure gamma dose rates from a radioactive material field teams based on industry norms. activated. release. The capability to take offsite soil, water, and vegetation samples is provided by a minimum of two (2) The justification for response in 75 minutes is Field Monitoring Teams (FMTs). provided separately in this License Amendment request. Once the emergency facilities are EP 8.2.1.5 TSC Radiation Protection (RP) Supervisor The wording was standardized and relocated activated, the HP/Chem Supervisor in the The RP Supervisor reports to the TSC Manager and to the SNC Standard Emergency Plan. TSC or the Dose Assessment Supervisor supervises the activities of the radiation protection staff in the EOF can request monitoring teams and Health Physics Network (HPN) Communicator. The commitment was modified to support two from support personnel located at the The RP Supervisor assists the Radiation field teams based on industry norms. OSC. Protection/Chemistry Group Lead in the OSC in determining the extent and nature of radiological or The justification for response in 75 minutes is hazardous conditions and coordinates offsite dose provided separately in this License assessment and offsite Field Monitoring Teams prior to Amendment request. EOF activation. EP 8.3.1.4 EOF Dose Assessment Supervisor The Dose Assessment Supervisor reports to the EOF Manager and provides oversight of dose assessment, field team control, and protective action recommendation activities in the EOF; and coordinates communication of results with offsite agencies. Field Monitoring Teams consist of at least EP 1.7 Field Monitoring Teams are dispatched by SNC- The commitment wording was standardized two people. These teams are formed at operated plants to perform a variety of functions in and relocated to the SNC Standard the OSC and dispatched as described in situations potentially involving significant releases of Emergency Plan and Site Annex. Section B. radioactive materials from a plant. Annex Table 2.2.A Conduct of initial Field Surveys by on-shift personnel can be performed by a single individual as designated in the Site Annex. E9-124 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Materials and equipment for conducting EP 1.7 Environs Surveys and Monitoring The wording was standardized and relocated offsite radiological monitoring are located In addition to the capabilities and resources described to the SNC Standard Emergency Plan. in the Simulator Building. Typical in Section H, SNC-operated nuclear power plants have equipment available for field monitoring is the ability to take offsite air samples and to directly listed in Appendix 4. 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). Offsite field monitoring teams normally EP F Table 5 The commitment wording was standardized use company vehicles and have a two- and relocated to the Site Annex. way radio for communications. It is estimated that teams can be in the EP 1.7 Environs Surveys and Monitoring Tne wording was standardized and relocated field and performing monitoring tasks In addition to the capabilities and resources described to the SNC Standard Emergency Plan. within approximately 1 hour of the in Section H, SNC-operated nuclear power plants have determination of the need for field the ability to take offsite air samples and to directly The commitment was modified to support two monitoring. measure gamma dose rates from a radioactive material field teams based on industry norms. release. The capability to take offsite soil, water, and vegetation samples is provided by a minimum of two (2) The justification for response in 75 minutes is Field Monitoring Teams (FMTs). provided separately in this License Amendment request. Preselected radiological sampling and EP 1.7: Samples are taken at predetermined locations The commitment wording was standardized monitoring locations are designated on as well as those locations specified during and after a and relocated to the SNC Standard the HNP 10-mile EPZ field monitoring release. Emergency Plan. map. Offsite field monitoring teams perform sampling at these locations and others as directed by the HP/Chem Supervisor in the TSC or the Dose Assessment Supervisor in the EOF. A communicator maintains periodic EP 8.3.1.7 EOF Field Team Communicator The commitment wording was standardized communications contact with all field The Field Team Communicator reports to the Field and relocated to the SNC Standard monitoring teams. Team Coordinator. The Field Team Communicator is Emergency Plan. responsible for communications with the Environmental Teams, providing them sampling direction and plant status with respect to team safety. E9-125 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 To facilitate direction of the teams and EP 1.7: Samples are taken at predetermined locations The commitment wording was standardized reporting of results, both the field as well as those locations specified during and after a and relocated to the SNC Standard monitoring teams and the communicator release. Emergency Plan. use identical maps showing the sampling locations. The cartridge and air particulate filter are EP 1.9: Field monitoring equipment has the capability to The commitment wording was standardized returned to the laboratory at the plant site detect and measure airborne radioiodine in the and relocated to the SNC Standard for isotopic analysis if the field analysis presence of noble gases that has the capability to Emergency Plan. reading is 100 cpm above background on detect and measure radioiodine concentrations in air in an HP-210 probe or equivalent. The the plume exposure EPZ as low as 10-7 uCi/cc cartridges can be counted in the field (microcuries per cubic centimeter) under field without interference from noble gas conditions. Interference from the presence of noble gas (background count rate below 300 cpm and background radiation shall not decrease the stated on an HP-210 probe or equivalent). minimum detectable activity. The cartridge and air particulate filter are EP H.10 Collection Point for Field Samples The commitment wording was standardized returned to the laboratory at the plant site SNC-operated nuclear power plants have designated a and relocated to the SNC Standard for isotopic analysis if the field analysis point as the location for receipt and analysis of field Emergency Plan. reading is 100 cpm above background on monitoring team environmental samples. Sampling and an HP-210 probe or equivalent. analysis equipment is available for quantitative activity determination of marine and air samples, and qualitative activity determination of terrestrial samples. In addition to direct monitoring and air EP 1.7: SNC-operated nuclear power plants have the The commitment wording was standardized sampling, the assessment program may ability to take offsite air samples and to directly measure and relocated to the SNC Standard utilize the environmental sampling gamma dose rates from a radioactive material release. Emergency Plan. program in which environmental samples The capability to take offsite soil, water, and vegetation (water, air, soil, and vegetation) are samples is provided by a minimum of two (2) Field collected and analyzed in the laboratory Monitoring Teams (FMTs). for detailed radionuclide data. E9-126 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 This program is implemented at the No direct equivalent Plan/Annex statement. Section B of the SNC Standard Emergency direction of the Dose Assessment EP 1.7 The environmental monitoring equipment include Plan provides specific responsibilities for Manager or designee. portable survey, counting, and air sampling Dose Assessment/radiological monitoring. 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 determining and assessing protective actions for the general public and recovery actions for the plant. Data obtained from the field monitoring EP 1.7 The initial environmental surveys involve The commitment wording was standardized program (including data from offsite measurements to confirm or modify the dose projections and relocated to the SNC Standard agencies) can be utilized to perform or based on plant parameters. Subsequent environmental Emergency Plan. refine dose projections. Any adjustments monitoring efforts will be aimed at further defining the to dose projections will be considered in offsite consequences, including instituting an expanded the evaluation of protective action monitoring program to enable prompt assessments of recommendations as described in Section any subsequent releases from the plant. J J. PROTECTIVE RESPONSE EP SECTION J: PROTECTIVE RESPONSE The commitment wording was standardized This section describes the protective Protective response consists of emergency actions, and relocated to the SNC Standard actions that were developed to limit taken during or after an emergency situation, which are Emergency Plan. radiation exposure of plant personnel and intended to minimize or eliminate hazards to the health the public following an accident at the and safety of the public and plant personnel. Protective plant. This section addresses conditions actions have been developed for emergency workers relative to the Alert, the Site Area and the general public located in the Plume Exposure Emergency, or the General Emergency Pathway Emergency Planning Zone. Guidelines classifications. Any protective response consistent with federal guidance have been established taken at the NUE level is done so at the to aid in choosing protective actions during an discretion of the ED. emergency. The responsibility for actions outside the owner-controlled area rests with state, county, and other offsite response agencies. E9-127 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Protective Response for Onsite Personnel EP SECTION J: PROTECTIVE RESPONSE The commitment wording was standardized Protective response for onsite personnel Protective response consists of emergency actions, and relocated to the SNC Standard (including visitors and contractor taken during or after an emergency situation, which are Emergency Plan. personnel) depends upon alerting, intended to minimize or eliminate hazards to the health assembly and accountability, evacuation, and safety of the public and plant personnel. Protective monitoring, and decontamination. actions have been developed for emergency workers 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.

1. Alerting Annex4.3.1 Alerting (SEP E.2.1, J.1) The commitment wording was standardized Section E of this Plan, Notification Section E of the Emergency Plan (EP), Notification and relocated to the Site Annex.

Methods and Procedures, describes the Methods and Procedures, describes the methods to be methods to be used to alert onsite used to alert on-site personnel of emergency conditions. personnel of emergency conditions. E9-128 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Assembly and Accountability EP J.4.1 Assembly The commitment wording was standardized Upon activation of the plant emergency Assembly is mandatory following the declaration of a and relocated to the SNC Standard alarm, plant personnel assigned specific Site Area or General Emergency, or at the discretion of Emergency Plan. emergency responsibilities proceed to the Emergency Director. When Accountability of onsite their designated respective emergency personnel is determined to be necessary by the response locations, where they are Emergency Director, personnel within the Protected logged in and accounted for. Area will be accounted for and the names of missing individuals determined within 30 minutes of the emergency declaration. EP J.4.2 Accountability Personnel accountability is mandatory at the Site Area or General Emergency classification. Accountability may be initiated at other times at the discretion of the Emergency Director to support worker safety. Accountability of personnel within the Protected Area is accomplished within 30 minutes of the declaration of Site Area Emergency or higher, and maintained continuously thereafter, using Protected Area(s) boundary access control as described in the Security Plan. If there are station personnel who are unaccounted for, the public address system or other suitable communication methods are used to locate 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. E9-129 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Accountability reports for the Control EP J.4.2 Accountability The commitment wording was standardized Room, the OSC, and the TSC are Personnel accountability is mandatory at the Site Area and relocated to the SNC Standard provided by the Security Department or General Emergency classification. Accountability Emergency Plan. ASAP. may be initiated at other times at the discretion of the Emergency Director to support worker safety. Accountability of personnel within the Protected Area is accomplished within 30 minutes of the declaration of Site Area Emergency or higher, and maintained continuously thereafter, using Protected Area(s) boundary access control as described in the Security Plan. If there are station personnel who are unaccounted for, the public address system or other suitable communication methods are used to locate 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. Thereafter, personnel emergency EP J.4.2 Accountability The commitment wording was standardized assignment tracking will be in place at Personnel accountability is mandatory at the Site Area and relocated to the SNC Standard each of the ERF to account for all onsite or General Emergency classification. Accountability Emergency Plan. individuals throughout the emergency. may be initiated at other times at the discretion of the This accountability may include use of the Emergency Director to support worker safety. security computer system, assignment Accountability of personnel within the Protected Area is logs, and required periodic accomplished within 30 minutes of the declaration of communications between emergency Site Area Emergency or higher, and maintained teams and the Control Room and the continuously thereafter, using Protected Area(s) TSC. 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. E9-130 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Nonessential plant personnel report to EP J.4.2 Accountability The commitment wording was standardized their normal reporting area during an Alert Personnel accountability is mandatory at the Site Area and relocated to the SNC Standard for the purpose of assembly and initial or General Emergency classification. Accountability Emergency Plan. accountability. may be initiated at other times at the discretion of the Emergency Director to support worker safety. Accountability of personnel within the Protected Area is accomplished within 30 minutes of the declaration of Site Area Emergency or higher, and maintained continuously thereafter, using Protected Area(s) boundary access control as described in the Security Plan. If there are station personnel who are unaccounted for, the public address system or other suitable communication methods are used to locate 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. Visitors, contractors, and escorted Annex 4.3.2 Assembly (SEP J.4.1) The commitment wording was standardized personnel will leave the protected area Nonessential plant personnel located within the and relocated to the SNC Standard during an Alert or higher declaration. Protected Area will exit the protected area upon hearing Emergency Plan. the Site Area or the General Emergency alarm, and report to designated assembly areas. Visitors, contractors, and escorted personnel will leave the protected area during an Alert or higher declaration. Nonessential plant personnel located Annex 4.3.2 Assembly (SEP J.4.1) The commitment wording was standardized within the protected area leave upon Nonessential plant personnel located within the and relocated to the SNC Standard hearing the Site Area or the General Protected Area will exit the protected area upon hearing Emergency Plan. Emergency alarm. the Site Area or the General Emergency alarm, and report to designated assembly areas. Visitors, contractors, and escorted personnel will leave the protected area during an Alert or higher declaration. E9-131 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 The Security Department accounts for EP J.4.2 : Accountability of personnel within the The commitment wording was standardized each person inside the protected area by Protected Area is accomplished within 30 minutes of the and relocated to the SNC Standard using the security computer system, declaration of Site Area Emergency or higher: and Emergency Plan. which is provided Emergency Diesel maintained continuously thereafter, using Protected backup power as well as an emergency Area(s) boundary access control as described in the backup fail-over computer. Security Plan. This system is supplemented by the EP J.4.2: : Accountability of personnel within the The commitment wording was standardized availability of telephone and radio Protected Area is accomplished within 30 minutes of the and relocated to the SNC Standard communications capability between the declaration of Site Area Emergency or higher, and Emergency Plan. Control Room, the OSC and the TSC. maintained continuously thereafter, using Protected This methodology provides for Area(s) boundary access control as described in the accountability of all individuals inside the Security Plan. protected area within approximately 30 minutes of the emergency declaration. Accountability reports are made No equivalent Plan/Annex statement The processing of Accountability reports is a periodically to the ED by the Security procedural action. The SNC Standard Department. Emergency Plan retains the commitment to perform the function in a timely manner. Nonessential plant personnel, visitors, Annex4.3.2 Assembly (SEP J .4.1) The commitment wording was standardized and contractors located within the Personnel assembly is mandatory at the Site Area and relocated to the SNC Standard protected area proceed to a rally point Emergency or higher level classification. Upon Emergency Plan. location outside the protected area activation of the plant emergency alarm, plant personnel [normally, the Plant Entry Security assigned specific emergency responsibilities will Building (PESB); however, if radiological proceed to their designated emergency response conditions prohibit its use, Gate 17 or any locations. Assembly of site personnel outside of the ED designated gate exiting the protected Protected Areas is accomplished by non-essential area may be used as a rally point]. personnel reporting to designated assembly areas. Assembly may be initiated at any time site management deems it appropriate for personnel safety reasons. E9-132 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 A security patrol periodically inspects all EPJ.4 The wording was standardized and relocated offices and work locations outside the Onsite protection of employees during hostile action to the SNC Standard Emergency Plan and protected area to ensure that all involves a combination of restricted movement, Site Annex. personnel have received instructions movement to safe locations, and site evacuation regarding onsite protective measures. depending on the nature of the hostile event and Conduct of the function is more appropriately advance warning. Site-specific procedures provide a procedural level function. specific actions to take during hostile action or severe weather events. During a hostile action or severe weather event, Assembly and Accountability actions may be delayed in favor of other onsite protective actions required to ensure the safety of the site and its personnel. In these cases, accountability will be completed once safe conditions have been established. Annex 4.3.3 Security Events (SEP J.4) On-site protection of employees during security events involves a combination of restricted movement, movement to safe locations, and site evacuation ' depending on the nature of the event and advance warning. Specific actions to be taken during such events are included in site procedures. Search and Rescue EP J.4.2 The commitment wording was standardized If protected area accountability reveals a If there are station personnel who are unaccounted for, and relocated to the SNC Standard missing person, the ED or designee the public address system or other suitable Emergency Plan. assembles a search and rescue team per communication methods are used to locate the the emergency response procedures. The personnel, or, in extreme cases such as fire, toxic gas search and rescue team can obtain release, explosions, or structural damage, trained information on last known location from search and rescue personnel are deployed to search for the security computer system or reports and assist the missing personnel. from other personnel. A search of likely areas will be conducted until the missing individual is located. E9-133 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Evacuation EP J.4.3 Site Evacuation The commitment wording was standardized Evacuation of all nonessential personnel If a Site Evacuation is required, personnel are directed and relocated to the SNC Standard (if feasible) is ordered by the ED to either assemble within designated Assembly Areas or Emergency Plan. whenever: immediately leave the site. Personnel will be directed to

a. It is determined that a threat to the either proceed to their homes or reassemble at safety of onsite personnel exists. designated locations. Visitors to the plant will assemble

b. A Site Area Emergency or a General with and follow the instructions of their escorts.

Emergency is declared. 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. The ED or designee provides evacuation EP J.4.3 Site Evacuation The commitment wording was standardized route directions to personnel directed to If a Site Evacuation is required, personnel are directed and relocated to the SNC Standard leave the plant site using the PA system to either assemble within designated Assembly Areas or Emergency Plan. and other communications means. This immediately leave the site. Personnel will be directed to information, including the evacuation either proceed to their homes or reassemble at routes (North and/or South on U.S. designated locations. Visitors to the plant will assemble Highway 1) are included in applicable with and follow the instructions of their escorts. implementing procedures. 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. E9-134 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Nonessential plant personnel, visitors, EP J.4.3 Site Evacuation The commitment wording was standardized and contractors will be directed to the If a Site Evacuation is required, personnel are directed and relocated to the SNC Standard designated county relocation centers if a to either assemble within designated Assembly Areas or Emergency Plan. radiological release is in progress during immediately leave the site. Personnel will be directed to the emergency. The appropriate either proceed to their homes or reassemble at relocation centers are Toombs County designated locations. Visitors to the plant will assemble High School for northern evacuations and with and follow the instructions of their escorts. Appling County High School for southern Personal transportation will normally be used and evacuations. Evacuation is generally by established evacuation routes will be followed. individually owned vehicles. 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. Directions provided to evacuees are No direct equivalent Plan/Annex statement. The responsibility to provide for site based or:i radiological necessities and evacuation is specified in the SNC Standard specific protective action requirements. Emergency Plan and Annex. Security Events Annex 4.3.3 Security Events (SEP J.4) The commitment wording was standardized Onsite protection of employees during On-site protection of employees during security events and relocated to the Site Annex. hostile actions involves a combination of involves a combination of restricted movement, restricted movement, movement to safe movement to safe locations, and site evacuation locations, and site evacuation depending depending on the nature of the event and advance on the nature of the hostile event and warning. Specific actions to be taken during such advance warning. Site procedures events are included in site procedures. provide specific actions to take during hostile action based events. These actions will be communicated to onsite personnel via the plant PA system and other communications means as applicable. E9-135 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Monitoring and Decontamination Annex 4.3.4 Monitoring and Decontamination (SEP K) The commitment wording was standardized When an Alert is declared but no site When an Alert is declared but no site evacuation is and relocated to the Site Annex. evacuation is anticipated, personnel who anticipated, personnel who have left the protected area have left the protected area are monitored are monitored by portal monitors. If necessary, by portal monitors. decontamination is completed using the plant decontamination facilities located in the Control building or other onsite locations. For a Site Area Emergency or a General Emergency, or when site evacuation is expected and a release of radioactivity has occurred, monitoring is performed by portal monitors at the Plant Entry Security Building or by portable monitoring equipment at the rally point areas. The Rally Point Team establishes a control point at the rally point area and monitors evacuees before releasing them. The monitoring teams maintain the appropriate records. If necessary, decontamination is Annex 4.3.4 Monitoring and Decontamination (SEP K) The commitment wording was standardized completed using the plant If necessary, decontamination is completed using the and relocated to the Site Annex. decontamination facilities located in the plant decontamination facilities located in the Control Control building or other onsite locations. building or other onsite locations. For a Site Area Emergency or a General Annex 4.3.4 Monitoring and Decontamination (SEP K) The commitment wording was standardized Emergency, or when site evacuation is For a Site Area Emergency or a General Emergency, or and relocated to the Site Annex. expected and a release of radioactivity when site evacuation is expected and a release of has occurred, monitoring is performed by radioactivity has occurred, monitoring is performed by portal monitors at the PESB or by portal monitors at the Plant Entry Security Building or by portable monitoring equipment at the rally portable monitoring equipment at the rally point areas. point areas. The Rally Point Team The Rally Point Team establishes a control point at the establishes a control point at the rally rally point area and monitors evacuees before releasing point area and monitors evacuees before them. The monitoring teams maintain the appropriate releasing them. records. The monitoring teams maintain the Annex 4.3.4 Monitoring and Decontamination (SEP The commitment wording was standardized appropriate records. K) and relocated to the Site Annex. The monitoring teams maintain the appropriate records. E9-136 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Should decontamination become EP K.5 Decontamination The commitment wording was standardized necessary, the Rally Point Team will The Radiation Protection Group will be responsible for and relocated to the SNC Standard conduct decontamination onsite, controlling or minimizing direct or subsequent internal Emergency Plan. preferably at the predesignated locations exposure from radioactive materials deposited on the in the Environmental Building or Building ground or other surfaces, and for determining the extent

10. 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. Decontamination and waste disposal are EP K.5 Designated personnel, under the direction of the The commitment wording was standardized completed in accordance with plant Radiation Protection Group, are responsible for and relocated to the SNC Standard procedures. performing material decontamination. Procedures and Emergency Plan. equipment for material decontamination are available at the plant, as specified in the site radiation protection program. E9-137 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Use of Onsite Protective Equipment and EP H.9 Emergency Kits The commitment wording was standardized Supplies Emergency kits are available at SNC-operated nuclear and relocated to the SNC Standard Plant emergency kits and other supplies power plants. Designated site or department Emergency Plan. are used to provide dosimetry, monitoring procedures identify the equipment in the various equipment, protective clothing, and emergency kits. Details as to kit locations are found in respiratory protection gear for individuals the plant-specific procedures. arriving or remaining onsite during the emergency. A supply of potassium iodide is stored in EP B.1.1 The Emergency Director's non-delegable The commitment wording was standardized the primary ERF and will be distributed as duties include: and relocated to the SNC Standard directed by the ED when thyroid

Issuance of potassium iodide (Kl) to plant Emergency Plan.

exposures are projected to be above 25 employees as a thyroid blocking agent. Rem CDE. EP H.1.2 To ensure adequate radiological protection, radiation monitoring equipment has been installed in the TSC, or periodic radiation surveys are conducted. These systems indicate radiation dose rates while in use. In addition, potassium iodide (Kl) is available for use. Plant radiation protection procedures EP H.9 Emergency Kits The commitment wording was standardized dictate the requirements for use of Emergency kits are available at SNC-operated nuclear and relocated to the SNC Standard dosimetry, respiratory protection, and power plants. Designated site or department Emergency Plan. protective clothing. A list of the procedures identify the equipment in the various emergency supplies available at ERF and emergency kits. Details as to kit locations are found in other onsite areas is detailed in the plant the plant-specific procedures. procedures. EP K.3.3 Radiation Work Permit Procedures Where possible, the normal radiation work permit procedure will be used to control exposures. Based on conditions and urgency Radiation Protection supervision may approve emergency radiological work permit controls. E9-138 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Protective Response for the Public EP J.5 Offsite Protective Action Recommendations The commitment wording was standardized The licensee is responsible for ensuring (PARs) and relocated to the SNC Standard that timely recommendations for Plant conditions, projected dose and dose rates, field Emergency Plan. protective actions reach appropriate State monitoring data, and evacuation time estimates are and local officials. These officials (as evaluated to develop PARs for preventing or minimizing described in Section A) are responsible exposure to the public. PARs are provided to the offsite for alerting the public and ordering shelter agencies responsible for implementing protective and/or evacuation, if necessary. actions for the public within the 10-mile EPZ. The Emergency Director will approve PARs. E9-139 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Annex 4.1.1 Notification Process (SEP E.2.2.1)

1. Alerting State and local warning points are staffed 24 hours per day. State and county authorities to The commitment wording was standardized The means used by HNP to alert local be notified within 15 minutes of the declaration of an emergency condition are: and relocated to the Site Annex.

State of Georgia: and State agencies and the means used

Georgia Emergency Management Agency (GEMA)

Georaia county authoriUes: by State and local agencies to alert the

Appling County warning point.

public are described in Section E and

Jeff Davis County warning point.
Tattnall County warning point.

Appendix 3 of this Plan.

Toombs County warning point.

Annex 4.2 Alert and Notification System (ANS) (SEP E.2.5) Within the Plume Exposure Emergency Planning Zone (EPZ), there exist provisions for alerting and providing notification to the public. The state and/or local authorities are responsible for activation of this system. The FEMA approved Hatch ANS consists of a primary ANS and a backup.system should there be a failure of the primary system.

Primary - Sirens and Emergency Alert System (EAS) stations
System Backup - Reverse calling system The primary ANS has two communications pathways. The first pathway is through the primary agency via the UHF or VHF radio. Should the primary agency fail to activate the system, the secondary pathway will be utilized by the secondary agency. The secondary pathway functions in the same manner as the primary pathway utilizing a separate activation console that is physically located in separate location. If neither agency can activate the system, the backup system will be utilized to notify the residents of the 1O mile EPZ.

The hierarchy for s1 stem activation is provided below: Agency Radio Systems Primary Agency UHF VHF Primary Sirens & EAS Secondary Agency UHF VHR Backup Each County EMA Calling System Georgia Primary Agency State of Georgia (GEMA) Secondary Agency Appling County E9-140 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Section J: The ED is responsible for EP 8.1.1: The Shift Manager (SM) is in direct charge of The commitment wording was standardized providing protective action shift plant operations and is directly responsible for the and relocated to the SNC Standard recommendations to State and local actions of the on-shift crew. In an emergency, the SM Emergency Plan. officials as part of initial notifications and assumes the responsibility of the Emergency Director follow-up communications. (ED) and takes necessary actions to identify and respond to the emergency until relieved by another qualified ED. The ED has the responsibility and authority to immediately and unilaterally initiate emergency actions, including providing notification of Protective Action Recommendations (PAR) to state and local government organizations responsible for implementing off site emergency measures. These recommendations are based upon Annex 4.4 Protective Actions for the Offsite Public (SEP The commitment wording was standardized assessment actions described in Section I J.5) and relocated to the Site Annex. of this Plan. Using available information The Emergency Director will recommend the necessary regarding plant conditions, projected dose protective actions to offsite authorities based on estimates, and any available monitoring predetermined protective actions for a General data, the ED recommends whether the Emergency Classification or results of offsite dose public should be advised to seek shelter assessment. Upon activation of the EOF, the EOF or evacuate. Emergency Director will be responsible for recommending protective actions for the offsite population. E9-141 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 The mechanism for making these EP J.5 Offsite Protective Action Recommendations The commitment wording was standardized recommendations is described in Section (PARs) and relocated tb the SNC Standard E of this Plan. These recommendations Plant conditions, projected dose and dose rates, field Emergency Plan. are based upon the Environmental monitoring data and evacuation time estimates are Protection Agency (EPA) Protective evaluated to develop PARs for preventing or minimizing Action Guidelines and NUREG-0654 exposure to the public. PARs are provided to the offsite Supplement 3 Rev 1. NMP-EP-112, agencies responsible for implementing protective Protective Action Recommendation,. actions for the public within the 10-mile EPZ. The provides detailed guidance on PAR Emergency Director will approve PARs. The PAR determinations. decision making flowcharts are site-specific in nature, and are provided in the site-specific implementing procedures. SNC-operated plants have the capability to provide state and local agencies a PAR for beyond the 10-mile EPZ. Plant conditions, projected dose and dose rates and field monitoring data are communicated to offsite agencies responsible for dose assessment/PARs to assist them in developing parallel assessments There are various types of protective actions that can be recommended to the state and counties. They may include the following:

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

E9'-142 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Current PARs were developed in EP J.5 Offsite Protective Action Recommendations The commitment wording was standardized coordination with Offsite Response (PARs) and relocated to the SNC Standard Organizations. Table J-3 provides details Plant conditions, projected dose and dose rates, field Emergency Plan. regarding the determination of initial monitoring data and evacuation time estimates are protective actions recommendations for evaluated to develop PARs for preventing or minimizing the public. exposure to the public. PARs are provided to the offsite agencies responsible for implementing protective actions for the public within the 10-mile EPZ. The Emergency Director will approve PARs. The PAR decision making flowcharts are site-specific in nature, and are provided in the site-specific implementing procedures. SNC-operated plants have the capability to provide state and local agencies a PAR for beyond the 10-mile EPZ. Plant conditions, projected dose and dose rates and field monitoring data are communicated to offsite agencies responsible for dose assessmenUPARs to assist them in developing parallel assessments There are various types of protective actions that can be recommended to the state and counties. They may include the following:

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

Table J-4 provides details for determining No equivalent Plan/Annex Table. SNC Standard Emergency Plan Section J.5 followup PARs. maintains the commitment to provide PARs for the population. Specific designation of followup PARs is part of the general requirement. A separate table is no longer necessary. E9-143 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Plant conditions, plume dose projection EP J.5 Offsite Protective Action Recommendations The commitment wording was standardized calculations, and offsite monitoring results (PARs) and relocated to the SNC Standard should be evaluated when making Plant conditions, projected dose and dose rates, field Emergency Plan. protective action recommendations. monitoring data and evacuation time estimates are evaluated to develop PARs for preventing or minimizing exposure to the public. PARs are provided to the offsite agencies responsible for implementing protective actions for the public within the 10-mile EPZ. The Emergency Director will approve PARs. The PAR decision making flowcharts are site-specific in nature, and are provided in the site-specific implementing procedures. SNC-operated plants have the capability to provide state and local agencies a PAR for beyond the 10-mile EPZ. Plant conditions, projected dose and dose rates and field monitoring data are communicated to offsite agencies responsible for dose assessmenUPARs to assist them in developing parallel assessments There are various types of protective actions that can be recommended to the state and counties. They may include the following:

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

E9-144 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 If significant discrepancies exist between EP J.5 Offsite Protective Action Recommendations The commitment wording was standardized field monitoring results and plume dose (PARs) and relocated to the SNC Standard rate projection calculations, an evaluation Plant conditions, projected dose and dose rates, field Emergency Plan. should be made. The most conservative monitoring data and evacuation time estimates are valid dose projections based on evaluated to develop PARs for preventing or minimizing evaluation results should be used in the exposure to the public. PARs are provided to the offsite determination of protective action agencies responsible for implementing protective recommendations. actions for the public within the 10-mile EPZ. The Emergency Director will approve PARs. The PAR decision making flowcharts are site-specific in nature, and are provided in the site-specific implementing procedures. SNC-operated plants have the capability to provide state and local agencies a PAR for beyond the 10-mile EPZ. Plant conditions, projected dose and dose rates and field monitoring data are communicated to offsite agencies responsible for dose assessmenUPARs to assist them in developing parallel assessments There are various types of protective actions that can be recommended to the state and counties. They may include the following:

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

E9-145 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 Evacuation EP J.5 Offsite Protective Action Recommendations The commitment wording was standardized Determining the benefit of evacuation (PARs) and relocated to the SNC Standard must take into account the time needed to Plant conditions, projected dose and dose rates, field Emergency Plan. complete the evacuation. monitoring data and evacuation time estimates are evaluated to develop PARs for preventing or minimizing exposure to the public. PARs are provided to the offsite agencies responsible for implementing protective actions for the public within the 10-mile EPZ. The Emergency Director will approve PARs. The PAR decision making flowcharts are site-specific in nature, and are provided in the site-specific implementing procedures. SNC-operated plants have the capability to provide state and local agencies a PAR for beyond the 10-mile EPZ. Plant conditions, projected dose and dose rates and field monitoring data are communicated to offsite agencies responsible for dose assessmenUPARs to assist them in developing parallel assessments. There are various types of protective actions that can be recommended to the state and counties. They may include the following:

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

Appendix 5 includes further detail Annex Appendix A The commitment wording was standardized regarding how these estimates were and relocated to the Site Annex. developed and presents information on evacuation routes, evacuation areas, relocation centers, shelter areas, and the population distribution by evacuation areas and zones. E9-146 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 TABLE J-3 No equivalent Plan/Annex Table SNC Standard Emergency Plan Section J.5 INITIAL PROTECTIVE ACTION maintains the commitment to provide PARs RECOMMENDATIONS for the population. Specific separation of initial and followup PARs is part of the general requirement. A separate table is no longer necessary. TABLE J-4 No equivalent Plan/Annex Table SNC Standard Emergency Plan Section J.5 FOLLOW UP PROTECTIVE ACTION maintains the commitment to provide PARs RECOMMENDATIONS for the population. Specific separation of initial and followup PARs is part of the general requirement. A separate table is no longer necessary. E9-147 to NL-16-0169 Hatch Justification Matrix Current Hatch Emergency Plan Revised SNC Emergency Plan Justification Revision 36 K. RADIOLOGICAL EXPOSURE K.1 Emergency Workers and Lifesaving Protective The commitment wording wa}}

NL-16-0628, Southern Nuclear Operating Company Response to Third Request for Additional Information Regarding Standard Emergency Plan: Cover Letter, Attachment 1 and Enclosures 1 - 10

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Background

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Response

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Response

Introduction:

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Introduction:

SUMMARY

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Introduction:

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