NL-16-0868, Edwin I. Hatch Nuclear Plant, and Vogtle Electric Generating Plant - Report of Changes to Emergency Plan

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Edwin I. Hatch Nuclear Plant, and Vogtle Electric Generating Plant - Report of Changes to Emergency Plan
ML16200A187
Person / Time
Site: Hatch, Vogtle, Farley, 07200042, 07200036, 07201039  Southern Nuclear icon.png
Issue date: 06/17/2016
From: Pierce C
Southern Nuclear Operating Co
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
NL-16-0868
Download: ML16200A187 (55)


Text

Charles 'R. Pierce Southern Nuclear Regulatory Affairs Director Operating Company, Inc.

40 Inverness Center Parkway Post Office Box 1295 Birmingham, AL 35242 Tel 205.992.7872 SOUTHERN Fax 205.992.7601 NUCLEAR A SOUTHERN COMPANY June 17, 2016 NL-16-0868 10 CFR 50.54 (q)

Docket Nos.: 50-348 50-321 50-424 50-364 50-366 50-425 72-42 72-36 72-1039 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant Edwin I. Hatch Nuclear Plant Vogtle Electric Generating Plant Report of Changes to Emergency Plan Ladies and Gentlemen:

In accordance with 1o. CFR 50.54(q)(5) and 10CFR 72.44(f), Southern Nuclear Operating Company (SNC) hereby submits descriptions of changes to plant emergency plans and a summary of the analysis demonstrating that the changes did not reduce the effectiveness of the plans and the plans, as changed, continue to meet the requirements in 10 CFR 50 Appendix E and the planning standards of 10 CFR 50.47(b).

Description of Changes and Summary of Analysis On May 23, 2016, following the guidance of INPO Guideline 10-007, SNC made changes to procedure NMP-EP-305 to eliminate unnecessary 10 CFR 50.54(q) evaluations for work involving Equipment Important To Emergency Response (EITER) when adequate compensatory measures are already in place.

On May 31, 2016, version 66 of the Vogtle emergency plan was published. The revision describes certain organizational changes in functional relationships due to the continuing construction work on the plant site, and the time for operation of Vogtle Units 3 and 4 grow nearer. The authorities, competencies, and overall responsibilities have not changed. In addition, the revision includes a better description of the location designated for the NRC and offsite response organizations during an emergency. The location itself has not changed.

On June 1, 2016, version 39 of the Hatch emergency plan was published. *Following guidance from the industry BWR owners group, the revision replaces direction to use containment flooding procedures with direction. to use severe accident guidelines for entry criteria used when declaring an emergency. This process maintains the same level and frequency of expected entry.

U. S. Nuclear Regulatory Commission NL-16-0868 Page 2 These changes were evaluated in accordance with 10 CFR 50.54(q)(3); and it was determined that these changes did not reduce the effectiveness of the SNC Emergency Plans and continue to meet the requirements in 10 CFR 50 Appendix E and the planning standards of 10CFR 50.47(b).

This letter contains no NRC commitments. If you have any questions, please contact Ken McElroy at (205) 992-7369.

RespecJpl~f!Jitted, Cn, µMk C. A. Pierce Regulatory Affairs Director CRP/EFB cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Ms. C. A. Gayheart, Vice President - Farley Mr. D. A. Vineyard, Vice President- Hatch Mr. B. K. Taber, Vice President - Vogtle Unit 1 & 2 Mr. M. D. Meier, Vice President- Regulatory Affairs Mr. R. L. Mansfield - Director, Emergency Preparedness 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 RType: Farley:::CFA04.054; Hatch=CHA02.004; Vogtle=CVC7000 U. S. Nuclear Regulatory Commission Ms. C. Haney, Regional Administrator Mr. Scott Moore, Acting Director, Division of Spent Fuel Management Mr. S. A. Williams, NRR .Project Manager - Farley Mr. P. K. Niebaum, Senior Resident Inspector- Farley Mr. M. D. Orenak, NRR Senior Project Manager - Hatch Mr. D. H. Hardage, Senior Resident Inspector - Hatch Mr. A. E. Martin, NRA Senior Project Manager - Vogtle Mr. A. M. Alen, Resident Inspector - Vogtle State of Alabama Dr. T. M. Miller, MD, State Health Officer - Department of Public Health State of Georgia Mr. J.:H. Turner, Director- Environmental Protection Division

VOGTLE ELECTRIC GENERATING PLANT UNIT 1 AND UNIT 2 EMERGENCY PLAN Revision 66 March 2016 Revision Insertion Instructions Please replace the affected pages in your copy of the Plan with the corresponding Revision 66 pages. Pages included in this package are:

Title Page List of Effective Pages page x, xi, xiii, xiv, and xvii Section A pages A-5 and A-6 Section B pages B-1, B-5, B-6. Table B-1 sheet 1, Table B-2 sheets 1 and 2, Figures B-1, B-2, and B-3 Section C page C-4 Section D page D-6 Section H pages H-2, H-4, H-6, H-18 Section I pages 1-6, 1-9 Section J pages J-3, J-4, Table J-1 Section K pages K-1, K-2, K-3, K-4 Section L pages L-1, L-3 Section M pages M-3, M-4 Section 0 Table 0-2 sheet 3, Table 0-2 sheets 1 and 2 Section P pages P-1, P-2, P-3, P-4 Appendix 1 pages 1-2 and 1-4 Appendix 8 page 1O Appendix 9 page 9-1 Discard these instructions after use and sign and return Transmittal Acknowledgment to address indicated.

VOGTLE ELECTRIC GENERATING PLANT UNIT 1 AND UNIT 2 EMERGENCY PLAN Revision 66 March 2016 Revision Insertion Instructions Please replace the affected pages in your copy of the Plan with the corresponding Revision 66 pages. Pages included in this package are:

Title Page List of Effective Pages page x, xi, xiii, xiv, and xvii Section A pages A-5 and A-6 Section B pages 8-1, 8-5, 8-6. Table 8-1 sheet 1, Table 8-2 sheets 1 and 2, Figures 8-1, 8-2, and 8-3 Section C page C-4 Section D page D-6 Section H pages H-2, H-4, H-6, H-18 Section I pages 1-6, 1-9 Section J pages J-3, J-4, Table J-1 Section K pages K-1, K-2, K-3, K-4 Section L pages L-1, L-3 Section M pages M-3, M-4 Section 0 Table 0-2 sheet 3, Table 0-2 sheets 1 and 2 Section P pages P-1, P-2, P-3, P-4 Appendix 1 pages 1-2 and 1-4 Appendix 8 page 1O Appendix 9 page 9-1 Discard these instructions after use and sign and return Transmittal Acknowledgment to address indicated.

CHANGE NUMBER PAGE CHANGE DESCRIPTION CHANGE EVAWATION and BASIS I HP, Health Physics Is no longer the title of the group an~ was removed as an entry Jn 1 Appendix 1-2 Deleted "HP Health Physics" the Glossary. RP, Radiation Protection, ls the new title of the group and has been added In the Glossary. This Is an editorial change.*

RP*. Radiation Protection was added to the Glossary to Indicate the current title of 2 Appendix 1-4 Added "RP Radiation Protection" the 11roup. This Is an edltorJal change. I NMP*EP-002 procedure Is no longer an Emergency Preparedness procedure. It Is Replaced "Emergency Planning NMP*EP-002" with nNMP*GM- now NMP*GM*036 and.is owned by the Operations group. The Duty Manager 3 Appendix 8*10 036" position continues to do notlflcatrons as*previously describ.ed to support the .f Emergency Plan. This. Is an editorial change for the Emergency Plan. j No change in duties. is being made, only the title of the group. This is an editorial 4 Appendix 9*1 Changed "Health Physics" to "~adlatlon Protection" cha nae.

No.change in duties is being made, only the title of.the group. This is. an editorial 5 A*S Changed "Health Physics" to "Radiation Protection" change.

No dtange i!l duties Is being made, only the title ofthe group. This Is an editorial 6 A*6 Changed "Health Physics" to "Radiation Protection" change.

No change In duties Is being made, only the title c;if the group. This Is an editorial 7 8*1 Changed "Health Physics" to "Radiation Protection" change.

No change in duties is being made, only the title of the group. This is an editorial 8 8-5 Changed "Health Physics" to "Radiation Protection" change.

No Change in duties Is being made, only the title of the, group. This Is an editorial 9 e-6 Changed "Health Physics" to "Radiation Protection" change.

Changed "HP" to "RP" and "Health Physics" to "RadlatltJn No change in duties Is being made, only the title of the group. This is an editorial 10 Table 8-1 Protection" change.

~o change In duties is being made, only the title of .t~ group. This Is an editorial 11 TableB*2 Changed "Health Physics to "Radiation Protection" dtange; The Orga 0 1~atlt1n Chart has been revised to reflect only the Vogtle Unit 1 and 2 operating organization. The changes are to titles. Responsibilities have not changed, o.nly molied to different.positions. The Emerg~ncy Preparedness Supervisor now 12 Figure B*l Replaced Organization Chart reports to the Regulatory Affairs Manager rather than the Site Integration D!rector.

The change does not modify arw dutie!! for the Supeivlsor and continues to provide direct access to the Vogtle. Vice President.

13 Figure B*2 Updated Chart to change "Health Physics'" to Radiation Protection" No change in duties Is being made, only the title of the group. This Is an editorial challl!e. I Updated Chart ta change "Health Physics" to Radiation No change In duties Is being made, only the title of the group. This Js i!n editorial i 14 Figure B-3 J Protection" cha nee.

No change in duties I~ being made, only the title of ~e group. This IS an editorial 15 C-4 Changed "Health Physics" to "Radiation Protection" change.

No change in duties Is being made, only tile UUe of the group. This is an e.dltorial 16 D-6 Changed "Health Physics" to "Radiation Protection" change.

No change In duties is being made, only the title of tile group. This Is an editorial 17 H-2 Changed "Health Physics" to '"Radiation Protection" c:hange.

No change in duties Is being mad~. only the tiUe ofthe group. This is an editorial 18 H-4 Changed "Health Physics" to "Radiation Protection" change.

Added "5. NRC and Offslte Response Organization Support Facilities Support facilities for the NRC and OROS have been The Inclusion of the NRC and Offslle Response Organization Support Facility is to provided at Training Center A. Adequate working space, access accuratelv describe the locatioll designated for these groups. The facility has been 19 H*S to plant data and communication capability to facllitate NRC designated since the creation of the offslte Ffflet EOF. "f'.he plan now .clearly defines and ORO coordlnat.lon With emergency responders has be.en the facility and Its capabilities.

provided in this near-site facility."

No change in duties is being made, only the title of the group. 'This Is an editorial 20 H-18 Changed "Health Physics" to "Radiation Protection" change.

No change in duties Is beif)g ma.de, only the title of the group. Thls Is an editorial 21 1*6 Changed "Health Physics" to "R;tdlation Protection" change.

No change.In duties Is being made, only the title orth.e gro.up. This is an editorial 22 i-9 Change "HP" to "RP" change.

No change if) ~lutles Is being made, only.the title of the group. This Is an editorial 23 1*3 Changed "Health Physics" to "Radiation Protection" change.

No. change in dutiel' is being made, only the title of the group. This Is an editorial 24 J-4 Changed "Health Phy$iCSu to. "Radiation Protection" change.

No change in duties is being, made, only the title of the group. This is an editorial 2S TableH Changed "Health Physics" to "Radiation Protection" change.

I No change in d4ties Is bl!lng made, only the title of the group. This Is an editorial I 26 K*l Changed "Health Pflyslcs~ to "Radiation Protection'"

change.

No change in duties is being 111ade, only the title of the group. This is an editorial 27 k-2 Changed "Health Physics" to "Radiation Protection" change.

No change in duties Is being made, only the title of the group. This Is an editorial 28 K-3 Changed "Health Physics" to "Radiation Protectlonn change.

No change in duties Is being made, only the title of the group. This is an editorial 29 K-4 Changed "Health Physics" to "Radiation Protection" change.

  • Changed "Health Physics" to "Radiation Protection" and "HP" No change in duties is being made, only the title of the group. This. ls an editorial 30 L*l to "RP" chanae.

No change In duties ls being made, only the ti.tie of the group *. This*is an editorial 31 L-3 Changed "Health Physics" to "Radiation Protection" change.

No change in dut.les is being made, only the title of the group. This is an editorial 32 M*3 Changed "Health Physics" tO "Radiation Protection" change ..

33 M-4 Changed "Health Physics" to "Radiation Protectlorl" an No change In duties Is ~elng made, only the title of the group. This Is editori.al change. *

  • No change In duties Is being made, only the title of the group. This Is an editorlill 34 Table 0-1, Pg 3 Changed "Health Physics" to "Radiation ProtecUon" change. * .

No change in duties is being made, only the tiJle of the group. This Is an editorial 35 Table0*2 Changed "Health Physics" to "Radiation Protection" I change.

The Emergency Preparedness Supervisor now reports to the Regulatory Affairs Deleted "Reporting to the Executive Vice President of Manager rather than the Site Integration Director. The change does not modify any 36 P-1 Operational Readiness and Site Integration Is the Site Integration Director (Plant)."

duties for the Supervisor aod continues to provide direct access to the Vogtle Vice President. I l

l 37 P-2 Changed "manager" to "director" and "Planning Coordinator" to "Preoaredness Manaaer" No change In duties 1.s being made, only the title. This Is an editorial change.

li The Site Integration Director is now only for Vogtle 3-4. The Regulatory Affairs 38 P-3 Changed "Site Integration Director" to "Regulato,Y Affairs Manager" Manager for Vogtle Units 1 an<! 2 is who the EP Supervisor reports to with the Regualtory Affairs Manager rep()rting to the vrce President, The duties have not I

b:een modified or eliminated*

The Eicecutlve V(!:e President of Operational Readiness and Site Integration is now Changed "Executive Vice President of Operational Readiness the title for Vogtll! 3-4 only, The same role is performed by the Vk;e President 39 P-3 and Site Integration (Plant)" to *vice President Nudear Plant Nuclear Plant Si~e for th.e '?Peratiog Vogtle Units 1 and 2. This change reflects only Site" the.operating units. The duties have not changed. .

40 p.3 Changed "Planning to "Preparedness" No change in duties is being made, only the title. This Is an edllorial change.

The Site Integration Director ls now only for Vogtle 3-4. The Regulatory Affairs I

Changed "Site Integration Directoru to "Regulatory Affairs. Manager for Vogtle Units 1 ancl 2 is who the. EP Supeivisor reports to with the 41 P-3 Manager" Regualtory Affairs Manager reporting to the Vice President The duties have not been modified or eliminated.

42 P-3 Changed "Planning Coordinator to "Preparedness ~anager" No change In duties is being mi!de, only the title. This Is an edltoriaLchange.

I 43 P-4 Changed *Manager" to "director" No change In duties Is being made, only the title._ This Is an editorlafchange.

I 44 p.5 Ch;inged "Manager" to Director" No change In duties is being made, only the title. This.is an editorial change.

II 45 P-5 Changed ."Planning Coordinator* to "Preparedness Manager No change in duties is being made, only the title. This Is an editorial change~ I The title of Hie procedure referenced.has changed. The proi:et!4re continues to Changed MCorporate Emergency Planning ActMtles" to 46 P*S describe the duties of the Emergency Preparedness Organization. This is a.n edltorlal "Emergency Preparedness Conduct of Operations" cham?e.

The Figure P*l was revlsect to reflect the current titles. Thediart no longer 47 FlgureP-1 Updated Emergency Preparedness Organization Chart represents the relationship to Vogtle Unit 3 and 4. The chart shows the reporting line for the operating units only. This is an ectltorlal change.

l*

l

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I I

Il 4

VOGTLE ELECTRIC GENERATING PLANT UNIT 1 AND UNIT 2 EMERGENCY PLAN REV 66 3/16

VEGP EMERGENCY PLAN LIST OF EFFECTIVE PAGES WITH REVISIONS Table of Contents (i) 51 ii 43 iii 57 iv 21 v 46 vi 27 vii 63 viii 38 ix 63 x 66 xi 66 xii 60 xiii 66 xiv 66 xv 63 xvi 60 xvii 66 xviii 60 Pref ace xix 39 xx 41 Figure i 5 Figure ii 27 Figure iii 14 Figure iv 23 Figure v NONE Figure vi 12 A-1 56 A-2 30 A-3 23 A-4 30 A-5 66 A-6 66 A-7 23 A-8 18 A-9 61 A-10 61 A-11 35 A-12 35 A-13 31 A-14 23 A-15 35 A-16 61 A-17 56 A-18 23

"' A-19 35 A-20 38 A-21 24 Table A-1 (1 of 2) 35 Table A-1 (2 of 2) 14 Figure A-1 35 x REV 66 3/16

VEGP EMERGENCY PLAN LIST OF EFFECTIVE PAGES WITH REVISIONS PAGE REV.

Figure A-2 22 Figure A-3 2 Figure A-4 35 Figure A-5 35 Figure A-6 35 Figure A-7 35 B-1 66 B-2 61 B-3 57 B-4 57 B-5 66 B-6 66 B-7 61 B-8 38 B-9 56

  • B-10 19 Table B-1 (1 of 2) 66 Table B-1 (2 of 2) 60 Table B-2 (1 of 2) 66 Table B-2 (2 of 2) 66 Figure B-1 66 Figure B-2 66 Figure B-3 66 C-1 61 C-2 61 C-3 61 C-4 66 C-5 61 Table C-1 (1 of 2) 2 Table C-1 (2 of 2) 28 Table C-2 56 Section D (pp D-1 to D-:5) 48 D-6 66 D-7 48 D-8 48 D-9 48 D-10 48 D-11 48 D-12 48 D-13 48 D-14 to D-16 57 D-17 62 D-18 57 D-19 to D-21 57 D-22 62 D-23 to D-25 62 D-26 to D-28 57 D-29 62 D-30 57 D-31 62 D-32 57 D-33 48 xi REV 66 3/16

VEGP EMERGENCY PLAN LIST OF EFFECTIVE PAGES WITH REVISIONS PAGE REV.

Figure E-1 43 Figure E-2 (1 of 3) - DELETED 21 Figure E-2 (1 of 2) 35 Figure E-2 (2 of 2) 35 F-1 56 F-2 43 F-3 30 F-4 28 F-5 57 F-6 60 F-7 43 Table F-1 60 G-1 24 G-2 41 G-3 60 G-4 60 H-1 51 H-2 66 H-3 57 H-4 6'6 H-5 61 H-6 66 H-7 38 H-8 57 H-9 65 H-10 35 H-11 35 H-12 56 H-13 65 H-14 38 H-15 38 H-16 22 H-17 34 H-18 66 Table H-1 65 Figure H-1 34 Figure H-2 57 I-1 56 I-2 57 I-3 34 I-4 65 I-5 38 I-6 66 I-7 38 I-8 57 I-9 66 I-10 21 J-1 35 J-2 39 J-3 66 J-4 66 J-5 63 xiii REV 66 3/16

VEGP EMERGENCY PLAN LIST OF EFFECTIVE PAGES WITH REVISIONS PAGE REV.

J-6 11 Table J-1 66 Table J-2 63 Table J-3 63 Table J-4 61 Table J-5 (1 of 2) 39 Table J-5 (2 of 2) 41 Figure J-1 63 Figure J-2 63 K-1 66 K-2 66 K-3 66 K-4 66 Table K-1 23 Table K-2(DELETED) 23 L-1 66 L-2 56 L-3 66 L-4 19 M-1 37 M-2 19 M-3 66 M-4 66 Figure M-1 60 N-1 61 N-2 61 N-3 61 N-4 61 N-5 61 N-6 61 N-7 61 0-1 35 0-2 50 Table 0-1 (1 of 3) 57 Table 0-1 (2 of 3) 57 Table 0-1 (3 of 3) 66 Table 0-2 (1 of 2) 66 Table 0-2 (2 of 2) 66 P-1 66 P-2 66 P-3 66 Figure P-1 66 Appendix 1 0 1-1 39 1-2 66 1-3 49 1-4 66 1-5 22 Appendix 2 46 2-1 62 2-2 46 XIV REV 66 3/16

VEGP EMERGENCY PLAN LIST OF EFFECTIVE PAGES WITH REVISIONS REV.

Page 26 38 Page 27 49 Page 28 49 Attachment B (Mutual Assistance Agreements) DELETED 21

1) Nuclear Power Plant Assistance Agree. (16 pgs.)DELETED 21
2) Electric Utilities Assist Agreement (15 pages) DELETED 21 Appendix 8 (Emergency Commun. Plan) 57 Table of Contents (i) 57 ii 57 iii 57 1 57 2 57 3 57 4 57 5 57 6 57 7 57 8 57 9 57 10 66 11 57 12 60 13 60 14 60 15 57 16 60 17 60 18 57 19 57 20 57 21 57 22 57 23 57 24 57 25(TABLE 1) 57 26 60 27 60 XVll REV 66 3/16
g. Maintain liaison with DNR radiation emergency coordinator (REC) .
h. Activate public emergency warning and/or evacuation procedures, as needed, pursuant to the GEOP.
i. Assist radiological monitoring and provide instrumentation.

J. Provide radiological monitoring training assistance.

k. Assist in area security and control; request National Guard assistance if needed.
1. Provide for the coordination of land and air transportation for emergency personnel as requested.
m. Coordinate public information releases in cooperation with State and local agencies.
n. Communication links will be established with the state* of South Carolina Emergency Preparedness Division and DOE-SRS to ensure efficient coordination of emergency response activities.
2. DEPARTMENT OF NATURAL RESOURCES
a. DNR is assigned primary responsibility by Executive Order for implementation and administration of the State radiological emergency response function.

DNR will:

(1) Dispatch radiation emergency teams as needed.

(2) Perform radiation survey and monitoring.

(3) Provide radiation safety training.

(4) Direct recovery/reentry operation and provide radiation protection control of contaminated areas.

b. A radiation emergency coordinator (REC) in the Environmental Protection Division (EPD) interacts with appropriate State, local, and Federal agencies and private organizations to direct all necessary radiation control actions. The REC is on call 24 h and will be notified by the GEMA duty officer.
c. In situations beyond local government control, DNR provides program assistance in the application of available personnel, equipment, and technical expertise as required.
d. DNR requests State support agency(s) and Federal assistance pursuant to the GEOP as required.

A-5 REV 66 3/16

e. DNR will provide for radiation protection escort of media and other personnel within the plume exposure pathway emergency planning zone (EPZ) as conditions allow if access controls have been established.

A.2.2 State Support Agencies in Georgia The following State agencies are prepared to provide related support of this function as indicated pursuant to the GEOP:

1. DEPARTMENT OF HUMAN RESOURCES Coordinate emergency health and social assistance pursuant to the GEOP.
2. DEPARTMENT OF PUBLIC SAFETY
a. As applicable, assume control over the onsite situation until the arrival of radiation safety personnel.
b. Maintain liaison with DNR REC.
c. Provide communication linkage as required.
d. Provide land or air transportation or escort as available for radiation safety personnel, other necessary personnel, or equipment.
e. Assist in radiological monitoring as required.
f. Provide law enforcement assistance for area security or recovery of lost or stolen radioactive material.
g. Coordinate with DNR law enforcement and local police.
h. Assist in public warning or evacuation as required.
3. DEPARTMENT OF AGRICULTURE
a. Collect samples of food products, livestock, produce, and dairy products, as necessary.
b. Restrict the sale, production, distribution, and warehousing of livestock, produce, dairy, and processed food products contaminated beyond safe consumption.
c. Assist in disposal of contaminated products.

A-6 REV 66 3/16

B. VEGP EMERGENCY ORGANIZATION Initial staffing of the onsite emergency organization will be provided from personnel normally employed at the site. For reference throughout this section, the organizational chart for the Vogtle Electric Generating Plant (VEGP) staff is presented in figure B-1. If the need arises, this staff will be augmented substantially by the addition of Southern Nuclear Operating Company (SNC) personnel and by personnel from other organizations. This section includes a description of the emergency duties of the normal shift complement, a discussion of the manner in which emergency assignments are to be made, a listing of additional support personnel on whom VEGP can rely, and a description of the relationships between onsite and offsite response activities.

B.1 NORMAL PLANT ORGANIZATION The organizational structure shown on figure B-1 represents the pool of personnel available on site during normal working hours. Approximately 700 people are stationed at the site during the standard workday.

The normal operating crew for two units includes a shift supervisor, licensed plant operators, and non-licensed plant operators. A shift manager is also on shift during operation (as defined in the Technical Specifications) . Personnel from the Chemistry and Radiation Protetion, Maintenance, and Security Departments are also on site continuously. Refer to table B-1 of this section for minimum staffing requirements.

B.2 EMERGENCY ORGANIZATION The emergency director has the responsibility to classify an event in accordance with the emergency 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) 4.

activates the VEGP emergency organization. The extent to which the emergency organization is activated depends on the severity of the situation. Table B-1 provides a summary of personnel available on shift and those who would be available within 60 min of notification. A copy of the On-Shift Staffing Analysis which forms the technical basis for Table B-1 Minimum Shift Staffing is maintained in the SNC document management system.

Reference OSA-VEGP-001.

For an NUE, the emergency director assigns responsibility for making the appropriate notifications and directing the proper response; but no further activation of the emergency organization is required.

If the event is classified as an Alert, the technical support center (TSC) , operations support center (OSC) , and Emergency Operations Facility (EOF) will be activated.

B-1 REV 66 3/16

b. TSC Support Coordinator The TSC support coordinator directs the clerical and logistic activities in the TSC.

He ensures that support staff, including clerks, status board keepers, and communicators, are available in sufficient numbers and that office supplies, drawings, and other documents are available to TSC and OSC personnel. He is responsible for timely completion of offsite notification. He ensures that transportation and communication needs are satisfied. He arranges for additional offsite support personnel and equipment working in conjunction with the EOF support coordinator.

(Designees are identified on table B-2).

c. Engineering Supervisor The engineering supervisor directs a staff of engineers with expertise in reactor engineering, thermal and hydraulic analysis, instrumentation and control, and mechanical and electrical systems. He directs the analysis of plant problems, core damage, and provides recommendations for plant modifications to mitigate the effects of the accident.
d. Maintenance Supervisor The maintenance superyisor manages the planning and coordination of repair, damage control, and plant modification activities. He works closely with the engineering supervisor in planning for plant modifications and repairs.
e. Operations Supervisor The operations supervisor analyzes problems associated with systems operations and provides recommendations for procedures for mitigating the emergency situation.
f. Radiation Protection Supervisor The radiation protection supervisor is responsible for onsite and in-plant radiological controls. He provides guidance to the maintenance supervisor related to radiological considerations associated with plant modification and repair and provides direction to the OSC manager related to the radiation protection controls for emergency teams. He performs offsite dose assessment prior to EOF activation and keeps the dose assessment supervisor in the EOF informed of the radiological status of the plant.

B-5 REV 66 3/16

g. Chemistry Supervisor The chemistry supervisor is responsible for directing and evaluating in-plant chemistry and analyses, directing and evaluating post accident sampling, and assisting in core damage assessment.
h. TSC Security Supervisor The TSC security supervisor coordinates the security functions including accountability and site access control. He coordinates the processing of off site personnel who require authorization to enter the site. When directed by the emergency director, will request assistance from civil law enforcement authorities, as required.
3. OSC STAFF
a. OSC Manager The OSC manager receives direction from the TSC personnel to dispatch emergency teams (e.g.,

firefighting, search and rescue, first aid, repair, etc.) to prescribed areas of the plant or site. The OSC manager directs composition of the teams to ensure that appropriately qualified personnel are assigned. In particular, he will ensure that proper radiation protection coverage is provided. The OSC manager will provide specific instructions to the team leaders. He will also maintain communications with the teams that remain assigned to the OSC and monitor the status of their activities.

b. OSC Personnel Selected emergency response personnel will report to the_ OSC as directed. Depending on the nature of the emergency, personnel from the Maintenance, Operations, Chemistry and Radiation Protection Departments will be directed to report to the OSC. The following emergency teams will be formed as necessary:
  • Backup fire brigade.
  • Search and rescue .
  • First aid.
  • Damage assessment .
  • Damage control.

B-6 REV 66 3/16

TABLE B-1 (SHEET 1 OF 2)

MINIMUM STAFFING FOR POWER OPERATION hi~;,J~~?~,,~~wiiAil~~~~,z:~~{i~~~t~~i:~t~~tl ~~~~,~(~~~~t::~~, ~¥~~~~,~;~~J Plant operations and assessment Shift manager (SRO) l(a) of operational aspects Shift supervisor (SRO) 2(a)

Plant operator (RO) 4(a)

Sys tern opera tor 7 1*> 1*> Cf>

Shift Su ort Su ervisor (SSS) 1 Emergency direction and control Overall management of Shift supervisor; l(b)

(emer enc director) emer enc or anization shift mana er Notification/communication Notification of VEGP, State, Shift trained personnel 2(b) 2 local, and Federal ersonnel Radiological accident assessment EOF direction Corporate Management; 1 and support of operational Offsite dose assessment RP/Chemistry Shared foreman 1 accident assessment Offsite surveys Chemistry technicians, RP 2 3 onsite (out of plant) technicians, System operator or other trained ersonnel FMT Communicator Maintenance Su ervisor 1 Chemistry/radiochemistry Chemistry technicians or 1 1 e ivalent Plant system engineering, repair Technical support (including Shift technical advisor or 1 (c) and corrective actions core/thermal h draulics) en ineer Electrical 1 Mechanical 1 Repair and corrective actions Mechanical maintenance 1 1 System operator 1 Electrical maintenance 1 1 Instrumentation and control 1 technician Protective actions (in plant) Radiation_ protection: Radiation Protection 2 2

  • Access control technicians or other trained
  • RP coverage for repair, personnel corrective actions, search and rescue, first aid and fire fighting
  • Personnel monitoring
  • Dosimetry
  • Decontamination
  • In- lant Surve REV 66 3/16

TABLE B-2 (SHEET 1 OF 2}

EMERGENCY ORGANIZATION ASSIGNMENTS Emergency Director Operations Director; Maintenance Manager; Work Management Director; Engineering Director; Manager of Site Projects; Engineering Programs Manager or other qualified senior management personnel.

EOF Staff Corporate Staff as defined in Appendix 7 TSC Manager Supervision from onsite staff as designated in procedure 91101-C TSC Support Coordinator Onsite staff as designated in procedure 91101-C TSC Engineering Supervisor Supervision from onsite staff as designated in procedure 91101-C TSC Maintenance Supervisor Supervision from onsite staff as designated in procedure 91101-C TSC Operations Supervisor Supervision from onsite staff as designated in procedure 91101-C TSC Radiation Protection Supervision from onsite staff as designated in procedure 91101-C Su ervisor TSC Chemistry Supervisor Supervision from onsite staff as designated in procedure 91101-C Engineers Plant engineers TSC Security Supervisor Supervision from onsite staff as designated in procedure 91101-C REV 66 3/16

TABLE B-2 (SHEET 2 OF 2}

OSC manager Dosimetry team Qualified radiation protection personnel Communicators (Offsite for Plant engineers; nuclear specialist; administrative assistants; operations Control Room, TSC and EOF) ersonnel, cor orate staff Clerks Administrative assistants In-plant radiation monitoring Selected emergency response personnel team Post accident sampling team Selected emergency response personnel Damage control/assessment/ Selected emergency response personnel re air team Search and rescue team Selected emergency response personnel Backup fire brigade Selected emergency response personnel First aid team Selected emergency response personnel Field monitoring team Selected emergency response personnel Shift Normal operating shift personnel Plant Plant REV 66 3/16

Vice President - Vogtle I

I I I I I I Regulatory Affairs Site Projects Plant Manager Engineering Director Security Manager Training Manager Manager Manager I Emergency I

Operations Director Engineering Staff Preparedness Security Staff Training Staff Supervisor I Pertormance Improvement Maintenance Manager Director Fleet Procedure I Supervisor Work Management Director I

Radiation Protection :

Manager I

Chemistry Manager Figure B-1 VEGP Organization Chart REV 66 3/16

Emergency Director

  • - -*g

.--~~~~~~~~-ti EDF Staff

[ .

Described i.n Appendix7 l

TSC Support Coordinator I

Shift Manager osc (Control Room),

---==___J _____ _

TSC Security Supervisor I

Shift Supervisor I

TSC Radiation System I Plant I Protection Ql}.~ratQr,s, 01}.er:atqr,~;

Supervisor I

TSC Chemistry Supervisor TSC Maintenance Supervisor TSC Operations Supervisor I

TSC Engineering Supervisor ,

. I Vogtle Electric Generating Plant Response Organization For Alert Rev 66 3/16 T

TSC Engineers Figure B-2

.--------------11 ,---------~

Federal, State and Other Offsite Agencies Emergency Director I j

- ~;==================;==!!

EOF Manager I I

TSC Manager

-- **** 1 **** JI EOF Staff as TSC Support Coordinator I OSC Manager described in Appendix7 I

TSC Security I Supervisor Damage Control/ 1, Assessment/Repair I!

Team f Radiation Protection

~v,stem, I li'l.a_n~: I t Operators Operators Supervisor - In Plant Monitoring Search and Rescue i Team Team  !

<,-----~-._,,, __ ,'

I Chemistry Backup Fire Brigade Supervisor Maintenance Supervisor I First Aid I

Operations Supervisor I

Engineering Vogtle Electric Generating Plant Supervisor Site Area or General Rev 66 3/16 Emergency Response Organization Figure B-3

multiengine jet aircraft. It is also a military air headquarters for the U.S. Army operating out of Ft. Gordon, Georgia.

Daniel Field (Augusta, Georgia) and Aiken Municipal (Aiken, South Carolina) are air fields capable of servicing and maintai;ning medium-size jet and propeller aircraft. The Burke County Airport (Waynesboro, Georgia) is the nearest airport to the VEGP and is used only by small general aviation aircraft.

C.3 VEGP SUPPORT VEGP provides space, telephone communications, and administrative services for NRC and FEMA personnel at the TSC and EOF. Up to five NRC representatives can be accommodated at the TSC. In the EOF, space is provided for nine NRC personnel and one FEMA representative. NRC representatives may also be present in the control room. Emergency notification system (ENS) telephones and commercial telephones are available in the control room, TSC, and EOF.

Health physics network (HPN) telephones are available in the TSC and the EOF.

C.4 OTHER SUPPORT The onsite laboratory is equipped to analyze all normal in-plant samples. The equipment includes an ion chromatograph, gas chromatograph, gamma spectrometer, and other analytical support equipment.

Field samples will be taken by VEGP field monitoring teams.

These teams will take d~rect radiation readings.and will collect air samples, soil samples, vegetation samples, and water samples as directed by the dose assessment manager.

The samples will be scanned with field instrumentation and will then be taken to VEGP for laboratory analyses. If necessary, samples will be transported to the Georgia Power Company (GPC) Environmental Laboratory located in Smyrna, Georgia, or to Plant Hatch for more refined analyses.

Environmental samples will be collected by corporate personnel. These samples will be obtained from the current fixed environmental program which is described in section I.

Environmental samples will be sent to Plant Hatch or the GPC environmental laboratory.

In-plant samples such as effluent and air samples will be analyzed using a gamma spectrometer located in the counting room. Post-accident sampling is described in section I of the plan.

Private organizations that supply engineering, radiation protection, and general emergency support are listed below.

C-4 REV 66 3/16

i. Provide release and dose projections based on plant condition and foreseeable contingencies.
j. Activate the Emergency Response Data System for the affected unit within 1 h following declaration of the General Emergency.
k. Close out emergency class by briefing of offsite authorities followed by written summary within 8 h of closeout or class reduction.

D.3 CLASSIFICATION PROCESS The procedure by which the plant operational staff classifies emergencies is NMP-EP-110, "Emergency Classification Determination and Initial Actions." This procedure is used to classify the emergency condition upon recognition of an off-normal condition as determined by: direction from another procedure; instrument readings/alarms; a critical safety function status on the safety parameters display system; direct observation; or reported events. Plant procedures which direct reference to this procedure include control room annunciator response procedures, abnormal and emergency operating procedures that reflect directly on Emergency Action Levels (EAL), as well as chemistry and radiation protection procedures that are used in the conduct of shift activities. The Critical Safety Functions Status Trees (CSFSTs) contained in Emergency Operating Procedure 19200-C are an integral part of the EAL scheme and form the bases for numerous EALs. The instrument readings, alarms, conditions, and event(s) which may result in an emergency classification are as specified in the EALs themselves or in the off-normal procedures directing the operator to the Emergency Plan implementing procedures.

EMERGENCY ACTION LEVEL (EAL) : A pre-determined, site-specific, observable threshold for a plant Initiating Condition that places the plant in a given emergency class. An EAL can be: an instrument reading; an equipment status indicator; a measurable parameter (onsite or offsite); a discrete, observable event; results of analyses; entry into specific emergency operating procedures; or another phenomenon which, if it occurs, indicates entry into a particular emergency class.

INITIATING CONDITION (IC) : An emergency condition which sets it apart from the broad class of conditions that may or may not have the potential to escalate into a radiological emergency. It can be a continuous, D-6 REV 66 3/16

The air filtration system will be placed in service when required by Procedure 91110-C, Duties of the Radiation Protection Supervisor (TSC) . The ventilation I system can be manually controlled from the TSC. The air filtration system will also be placed in the filtration mode automatically whenever the control room HVAC is isolated. The air filtration system, when activated, automatically processes all of the outdoor air together with approximately 25 percent of the recirculated air through the filtration unit. In the initial actuation of the air filtration system, a parallel signal is initiated to deenergize the onsite technical support center battery room and toilet exhaust fans and dampers. The continuous influx of outdoor air with no positive exhaust is designed to pressurize the area to 0.125 in. WG. After the filtration process, the filtered air is mixed with the balance of recirculated air for further conditioning by the normal supply system.

When the TSC is activated, there will be a portable radiation monitor placed in the TSC to alert personnel of the presence of high radiation levels. In addition, portable radiation monitors are available for personnel in transit from the TSC to other areas.

Portable air breathing apparatus and anti-contamination clothing are provided in the TSC.

The TSC normal lighting is supplied from normal offsite power through a motor control center backed up by the security diesel generator. The TSC essential lighting is supplied from the essential lighting system. Self-contained, battery-operated emergency lighting is provided as a backup to the normal lighting for ingress and egress only and is located in the TSC hallway.

Power for TSC vital equipment is provided from either the motor control center packed up by the security diesel generator or from a battery-backed uninterruptible power supply system. Power to the de system is provided via battery chargers, one of which is powered from this same motor control center.

The records storage is shared by the control room and the TSC. Separate copies of the following documents will be stored in the control room complex and in the TSC:

  • Technical Specifications.
  • Plant Operating Procedures.
  • Final Safety Analysis Report.

H-2 REV 66 3/16

Preparations for dispatching maintenance teams to the plant will include the following steps as described in Procedure 91104, Duties of the OSC Manager, and Procedure 91202, Activation and Operation of the OSC.

A. Members of the team will be selected by the OSC manager based on the type of work to be conducted.

B. The work will be preplanned by the maintenance personnel.

C. Drawings, manuals, and other procedures will be obtained from the document control room or maintenance building. If the equipment manuals are not available in either facility, a complete set of manuals is available in the service building.

D. Dosimetry will be obtained from the OSC emergency kit or at the RP control point.

E. Protective clothing and equipment, radios, and other supplies will be obtained from the emergency kit stored in the OSC or the radiation protection control point. All equipment will be checked before leaving the OSC or radiation protection control point.

F. A radiation work permit (RWP) will be completed in accordance with standard practices at the radiation protection control point, TSC, or OSC. Standard procedures include emergency RWPs. Procedure 91301-C, Emergency Exposure Guidelines, provides instruction for emergency exposures.

G. The tools and equipment needed to conduct repairs and take corrective actions will be determined. This equipment may be available in the auxiliary building tool crib or in the maintenance building.

Arrangements for tools and equipment not located onsite will be made in coordination with the support coordinator.

H. ALARA and job briefings will be held with each team in the OSC, the TSC, or at the radiation protection control point, as appropriate. Work to be performed, special precautions, plant conditions, and radiological information will be included in the briefings.

I. Upon completion of the job, the team members will be debriefed and their exposures recorded.

H-4 REV 66 3/16

5. NRC AND OFFSITE RESPONSE ORGANIZATION SUPPORT FACILITIES Support facilities for the NRC and OROs have been provided at Training Center A. Adequate working space, access tq plant data, and communication capability to facilitate NRC and ORO coordination with emergency responders have been provided in this near-s i te facility.

H-6 REV 66 3/16

Radiological monitoring on the South Carolina side of the Savannah River will be conducted by personnel from the SRS, or the State of South Carolina. These field monitoring teams will be equipped with equipment similar to that used by the VEGP teams.

Results of the offsite monitoring activities will be provided to the TSC until the dose assessment activities are transferred from the TSC to the EOF.

3. LABORATORY FACILITIES VEGP has laboratory facilities for analysis of radioactive samples. The major pieces of equipment include a solid-state gamma spectrometer and a beta/gamma gas proportional counter.

The GPC environmental laboratory located in Smyrna, GA has the capability to perform isotopic analyses of drinking water, river water, milk, vegetation, sediment, and biological samples, as well as tritium and gross-beta analysis. In addition, processing of environmental optically stimulated luminescent dosimeters (OSLDs) will be handled by this laboratory.

Backup laboratory facilities are available at Plant Hatch. This backup capability could be used if facilities in VEGP were not available.

H.6 EMERGENCY KITS Emergency kits are located in the TSC (for control room also), the OSC, the radiation protection control point, the EOF and other plant locations. An ambulance kit will be carried by the VEGP radiation protection technician who accompanies the ambulance. Procedures require an inspection and operational check of equipment in these kits on a quarterly basis and after each use.

Equipment in these kits is calibrated in accordance with the suppliers' recommendations. A set of spares of certain equipment is also maintained to replace inoperative or out-of-calibration equipment.

A listing of the typical contents of each kit and the spares is included in appendix 4.

H-18 REV 66 3/16

Designated vehicles may be used which are equipped with two-way radios on plant-dedicated frequencies. Handheld radios will also be available as a backup. Vehicles will be available 24 h per day.

Prior to leaving for the field, the dose assessment supervisor, or designee, will normally direct and brief the teams on the initial survey and sample locations, suggested travel routes, meteorological conditions, and team identification name or number for communication purposes.

The teams will inspect their field monitoring kits, perform survey equipment operation checks, obtain dosimeters, and establish radio communications with the monitoring team communicator. Monitoring teams are instructed to contact the monitoring team communicator approximately every half hour.

The teams will obtain their briefing from the radiation protection supervisor in the TSC or in the OSC by the OSC manager. They will be controlled by the TSC until the responsibility is transferred to the EOF.

It is estimated that teams will be in the field and performing monitoring tasks within about 1 h of the determination of the need for field monitoring.

Additional field monitoring team formation and dispatch details are contained in Procedures 91201-C, 91202-C, NMP-EP-102, "EOF Manager," NMP-EP-104, "Dose Assessment Supervisor,"

NMP-EP-101, "Activation and Operation of the EOF," and NMP-EP-106, "EOF Support Coordinator."

Preselected radiological sampling and monitoring locations are designated in implementing procedureq and are shown on figure iii. Field monitoring teams may be directed to perform sampling at these locations and others by the dose assessment staff at the TSC or EOF. In-transit dose rate measurements will be made. The teams may conduct airborne and dose rate measurements near the expected plume centerline.

If the dose rate exceeds 100 mrem/h, off-centerline measurements will be made. Based on dose rates, the teams will be directed to sweep the plume to identify the centerline or maximum dose rate. Dose rate readings will be taken with open and closed window on the radiation meter.

When the ratio between open and closed window readings is a factor of 2 or higher, it will be assumed that the measurement was taken in the plume. If the open and closed window readings are the same, it indicates that the plume is probably overhead.

I-6 REV 66 3/16

Milk samples are collected semimonthly by taking grab samples from milk supplies at control and indicator stations. These samples are analyzed for gamma isotopics.

Vegetation is sampled monthly during the growing season by collecting grab samples of grass or leafy vegetation at control and indicator stations. Vegetation samples are analyzed for gamma isotopics.

The normal environmental sample analysis is performed at the Georgia Power Company's Environmental Laboratory located in Smyrna, Georgia. During and/or subsequent to emergency conditions, the routine environmental monitoring program will be modified to collect and analyze additional samples from existing stations. The dose assessment supervisor will coordinate sampling and analysis activities for those areas that may have been impacted by a release from the plant.

Sample results will be transmitted back to the dose assessment supervisor by the analyzing organization.

Data from fixed monitoring stations (OSLDs and air samplers) will be utilized to estimate population dose. The samples from fixed monitoring stations would be collected after termination of a radioactive release and analyzed. The results would then be reduced in a manner that would assist in defining the trajectory, radioactivity, and impact of the released plume.

I.7 USE OF FIELD MONITORING DATA Field monitoring measurements are important in determining the actual radiation levels in the environment. The dose assessment computer code provides only a rough approximation of radiation levels and location of the plume. The uncertainties in the source term and meteorological conditions in the affected areas are the chief contributors to the inaccuracies of projected dose and dose rate. Once field monitoring information becomes available, the dose assessment computer code becomes less important in providing data on which to base protective action recommendations.

There is no widely accepted formula to use field monitoring data to reduce the uncertainties and inaccuracies in the dose assessment computer code. The dose assessment supervisor or TSC RP supervisor must exercise professional judgement in determining the proper correction factors.

Field monitoring teams should not unnecessarily be exposed to high levels of radiation from a radioactive plume. ALARA principles should be applied to all field monitoring activities. Once the decision to evacuate the general public has been made, field monitoring activities should be restricted to such activities as determining the source term for an unmonitored release or confirming the presence of a radioactive plume. Plume centerline tracking is of I-9 REV 66 3/16

Upon site dismissal to a reception center, non-involved personnel will be monitored for contamination to determine gross contamination as per the Burke County Emergency Operations Plan.

Those personnel who are contaminated will undergo a decontaminatioh process in accordance with standard radiation protection procedures. Those personnel who are not contaminated will be released upon clearance of the vehicle.

Vehicles will be monitored by gamma instruments for contamination in the designated parking areas.

Those vehicles which indicate contamination will be marked or identified for decontamination.

Uncontaminated vehicles will be allowed to exit the area upon authorization of the reception center emergency workers. Contaminated vehicles will be decontaminated as per the Burke County Emergency Operations Plan.

Contaminated articles and clothing and waste material will be collected and placed in containers or bags for disposal and/or processing at the site.

5. SECURITY EVENTS 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 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.

6. MONITORING AND DECONTAMINATION When an Alert is declared and site dismissal with no monitoring 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 appropriate location.

When site dismissal with monitoring is expected and release of radioactivity has occurred, monitoring is performed by Burke County emergency workers at an established reception center.

J-3 REV 66 3/16

Should decontamination be necessary, the reception center establishes a field decontamination area, using materials from emergency kits located in the vicinity of the reception center. Decontamination and waste disposal are completed in accordance with the Burke County Emergency Operations Plan.

6. USE OF ONSITE PROTECTIVE EQUIPMENT AND SUPPLIES A supply of potassium iodide is stored in the TSC for TSC and control room use, OSC, main control point, or radiation protection room. The radiation protection supervisor will direct the issuance of potassium iodide when the projected thyroid exposure is greater than 25 rem. The radiation protection supervisor will direct radiological survey personnel to distribute potassium iodide and record the name and social security number of those individuals who are issued potassium iodide. Potassium iodide will be issued in 130-mg doses daily for at least 3 days, but not more than 10 days. Issuance will be performed immediately prior to exposure or not longer than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after exposure.

At the time potassium iodide is distributed, an iodine sensitivity check will be made by querying each individual concerning known reactions to iodine.

Individuals who have experienced reactions to iodine will be excused from duties requiring issuance of KI.

J.2 PROTECTIVE RESPONSE FOR THE PUBLIC VEGP is responsible for ensuring that timely recommendations for protective actions reach appropriate State and local officials. These officials (as described in section A) are then responsible for alerting the public and ordering shelter and/or evacuation, if necessary.

1. ALERTING The means used by VEGP to alert local and State agencies and the means used by local and State agencies to alert the public are described in section E and appendix 3 of this Plan.

J-4 REV 66 3/16

TABLE J-1 USE OF PROTECTIVE EQUIPMENT AND SUPPLIES

~~~~~~,;**  ;' ~ :.~:;~)~~~~~~k~; ... *~;~i~j\tt~t** ' ::*~;~i~~,~~8~1t!\\~

Full face canister As needed by onsite a. Emergency kits a. Issued at OSC or respirator emergency teams in b. Radiation control point areas of high airborne Protection (RP) b. Issued as needed by radioactivit su 1 room RP ersonnel Self contained a. Firefighting a. Control room a. Used as needed by breathing apparatus b. Toxic Gas b. Emergency kits operators

c. Highly radioactive airborne activity
d. Lack of ox en Protective clothing As needed "in areas of a. Various areas of a. Issued as needed by (coveralls, hoods, known contamination the station RP personnel boots, gloves) b. Emergency kits b. Issued at OSC or
c. RP supply room control point for teams REV 66 3/16

K. RADIOLOGICAL EXPOSURE CONTROL K.l EMERGENCY EXPOSURE GUIDELINES During an emergency, it may be necessary to authorize radiation exposures above 10 CFR 20 limits. These higher exposures may be necessary to complete protective, corrective, or lifesaving actions. Table K-1 presents the emergency exposure limits for emergency workers involved in protecting valuable property, protection of large populations, or lifesaving actions. Under all such situations, every reasonable effort will be made to minimize exposures. Decisions as to appropriate exposures, considering the action required and relative risks, will be made by the emergency director ip consultation with radiation protection personnel.

Equipment and facilities have been designed in accordance with Title 10, Code of Federal Regulations, Part 50 (10 CFR 50), Appendix A, General Design Criteria for Nuclear Power Plants. Criterion 61, "Fuel Storage and Handling and Radioactivity Control," requires systems which may contain radioactivity to be designed to assure adequate safety under normal and postulated accident conditions.

Plant design has undergone an extensive As Low As Reasonably Achievable (ALARA) review. The ALARA reviews ensured that the design philosophies established in Regulatory Guide 8.8 were considered at the design stage.

Design features are considered for potential exposure and changes are recommended to reduce potentially high doses.

The post-accident sampling procedures have been designed to provide adequate protection to personnel during the collection of grab samples. Designated sample points are specified in plant procedures.

A plant shielding design review was conducted in accordance with the criteria for infrequently occupied areas in NUREG 0737, Item II.B.2. *The projected dose rates in the facility are presented in table 12.3.1-5 of the VEGP FSAR. The effluent sampling procedures have been written to assure that no individual receives a dose in excess of regulatory criteria as designated in Table K-1. A time and dose rate study has been conducted to assure that the exposure criteria can be achieved under accident conditions.

K-1 REV 66 3/16

K.2 ONSITE RADIATION PROTECTION PROGRAM When necessary, the emergency director can authorize emergency exposures in excess of 10 CFR 20 limits but within the limits in table K-1. Where possible, the normal radiation work permit (RWP) procedure will be used to control exposures. This procedure requires signature approval, prior knowledge of worker past exposures, and guidance on protective actions to be used in the course of the emergency work. If time and urgency do not allow this procedure to be followed, the radiation protection supervisor may approve emergency RWP controls. In all cases, a briefing is given to the emergency team by radiation protection staff, and each team is accompanied by a qualified radiation protection technician who meets the qualifications of ANSI 18.1 criteria set out in the VEGP Technical Specifications.

This briefing includes a discussion of the hazards involved in the planned action, as well as protective actions to be taken.

A record of individual and collective exposure received during the emergency will be maintained by the dosimetry team. Exposure records at the control point or the OSC will be updated after each entry into a radiologically controlled area. This may be accomplished through the dosimetry records computer system or manually. An individual's dose margin will be assessed by determining the difference between the updated exposure and current administrative limit; these margins are used to determine emergency assignments. Operation of the manual system and activation of the dosimetry team are described in Procedure 91110, Duties of the Radiation Protection Supervisor (TSC) .

In situations where exposures in excess of 10 CFR 20 limits are authorized, the following considerations will be made prior to emergency team selection:

1. Declared pregnant female employees shall not be allowed to participate.
2. For doses greater than 25 rem, personnel shall be volunteers and be fully aware of the risks involved.

All emergency exposures will be included in personnel radiation exposure records.

Emergency dosimetry is provided to each member of the emergency response organization for both onsite and offsite organizations as required by the radiological conditions existing at the time. Appendix 4 presents information on the types of dosimetry available in each emergency response facility and other locations.

K-2 REV 66 3/16

Emergency response personnel will be made aware that self reading dosimeters should be checked every 15 to 30 min. during the emergency. There is the capability to read optically stimulated luminescent dosimeters (OSLDs) within 24 h. They will also be read if the individual has received greater than a previously established value as determined by radiation protection procedures on their direct reading dosimeter.

Radiation dose will normally be controlled by the radiation protection supervisor within the limits authorized by routine station radiation protection procedures. The 10 CFR 20 limits will not be exceeded without the prior approval of the emergency director.

OSLDs are processed on a routine basis as delineated in chapter 12 of the FSAR.

K.3 DECONTAMINATION The action levels for determining the need for decontamination of personnel, equipment, and areas are delineated in plant admin. and radiation protection procedures. Personnel decontamination facilities are located on Level 1 of the control building in room R-110. The decontamination facility is located adjacent to the radiation protection station. Instrumentation to survey personnel during and after decontamination is located at the radiation protection station. The facility has vertical* showering and normal wash sinks.

Decontamination equipment for personnel is similar to that available in the Decontamination Emergency Equipment Kit (Appendix 4), except that the available supply is greater and stronger cleaning solutions are available. Waste generated through the use of the decontamination facilities is collected and processed by the. plant liquid radwaste system.

Decontamination of personnel will be conducted in accordance with standard radiation protection practices.

If decontamination activities are required, a controlled access area will be established by roping off the area.

Procedure 91306, Contamination Monitoring and Decontamination, addresses field decontamination and waste control. Supplies of clean clothing will be made available. Personnel decontamination will be accomplished using water washes or other methods for extreme cases as described in plant radiation protection procedures. These procedures will be applicable to removal of radioiodine from the skin. Decontamination of serious wounds will be accomplished at Doctors Hospital or the Burke Medical Center as described in section L of this Plan.

K-3 REV 66 3/16

Equipment and area decontamination will be conducted as determined by the TSC manager, maintenance supervisor, operations supervisor, or radiation protection supervisor. It is accomplished as described in plant radiation protection procedures and ranges from vacuum cleaning to wash downs with water and acid or caustic solutions.

Personnel exiting the radiation-controlled area will be monitored for contamination by stand-up monitoring booths or by a whole-body scan with a hand-held probe. The standard radiation protection contamination limits will be used for release of personnel. The decontamination facilities described above can accommodate both men and women who indicate low and high levels of contamination.

Plant areas that require access to facilitate recovery operations will be surveyed with portable instruments equipped with Beta/Gamma detectors. Appropriate protective clothing will be worn, as determined by this survey, to perform activities in these areas. Recovery operations will necessitate more detailed surveys on an as-needed basis.

K.4 ONSITE RADIOLOGICAL CONTAMINATION CONTROL Access control is provided by the Security Department during emergency conditions. Only authorized emergency response personnel are allowed to enter the protected area. Such personnel report to the appropriate emergency response facility for accountability prior to completing any emergency assignments.

Access to in-plant areas that are contaminated is controlled by barriers, signs, locked doors, or personnel stationed for that purpose. Emergency monitoring teams are responsible for determining the need for onsite access control and establishing the proper method through discussions with technical support center (TSC) personnel. Plant procedures used for determining contaminated areas will be used for determining the need for access control.

Any food, tobacco, or potable liquids that are inside a radiation or contamination controlled area, regardless of the packaging, will be considered to be contaminated until surveyed or otherwise determined to be free of contamination. These areas will be controlled by plant radiation protection procedures and no eating, smoking, or drinking will be allowed. The emergency director or designee will make arrangements for supplies to be brought in.

The emergency radiation protection supervisor is responsible for permitting return of onsite areas and K-4 REV 66 3/16

L. MEDICAL AND PUBLIC HEALTH SUPPORT L.1 ONSITE CAPABILITY Provisions have been made to assist personnel who are injured, who may have received high radiation doses, or who have been externally contaminated. Decontamination materials and portable first aid kits are available at strategic locations throughout the site. There are personnel on shift and in the Emergency Organization trained in first aid and decontamination procedures.

The onsite personnel responsible for responding to a medical emergency have had training per the OSHA standard 29 CFR 1910.151 and directive OSHA 3317-06N, Fundamentals of a Workplace First-Aid Program.

Radiation protection technicians will be assigned to first aid teams in accordance with Procedure 70302-C, Reporting and Documenting Occupational Injuries Or Illnesses. The radiation protection technician will direct and assist in decontamination of injured personnel as necessary. Personnel to perform first aid and decontamination will be available 24-h a day as identified in Section B, Table B-1.

In addition, an onsite first aid and decontamination area equipped with decontamination supplies and other specialized equipment is located near the radiation protection station on the 220 ft elevation in the control building. Personnel found to be externally contaminated but not requiring immediate medical attention will undergo decontamination in accordance with plant procedures.

L.2 MEDICAL TRANSPORTATION Injured and contaminated personnel requiring hospital medical attention will be transported to Doctors Hospital, Augusta, or Burke Medical Center, Waynesboro, by the Burke County Ambulance Service.

The ambulance will be met at the plant entry and security building, provided with dosimetry, and escorted to the patient pickup location. The ambulance and crew will be prepared to receive the contaminated patient as time permits by laying protective material in the ambulance and wearing protective clothing by the crew. Medical treatment of serious injuries will take precedence over contamination control. A radiation protection technician (RPT) will accompany the patient to the hospital. The RPT will provide advice and guidance to the ambulance crew and hospital staff regarding contamination control, decontamination, radiation exposure, and protective actions. The RPT will perform radiation surveys of the patient, ambulance, and attending hospital staff and assist in maintaining L-1 REV 66 3/16

protection personnel will assist hospital staff when plant personnel are being evaluated. Following decontamination, personnel suspected to have ingested radionuclides will undergo whole body counting at VEGP.

In addition, protection of attending personnel is afforded by the availability of disposable clothing and self-reading and badge-type dosimeters. Radiation survey instruments are available for monitoring patients and attending personnel. Each hospital has a comprehensive kit containing items necessary for removal of radioactive contamination from skin and wounds.

Included in this kit are culture tubes for nasal, oral, and aural samples, as well as containers for urine, fecal, and wound specimens. Large waste containers and plastic liners are available for the collection of contaminated articles.

Each hospital has a procedure entitled, "Decontamination and Treatment of the Radioactively Contaminated Patient." This protocol details the following procedures: notification responsibilities of associated individuals including VEGP radiation protection personnel, REA setup, emergency treatment, use of protective clothing, patient decontamination and sample collection techniques, handling multiple victims, and return of the REA to routine use. Upon notification of impending patient arrival, hospital personnel will initiate these procedures to prepare the REA for patient arrival.

Arrangements have also been made with local doctors to render medical assistance, both onsite and offsite, and to assume responsibility for the medical supervision of the patient. These doctors will be on emergency call at all times and will respond to an accident when called.

Southern Nuclear Operating Company (SNC) or contractor personnel will maintain programs at Doctors Hospital and Burke Medical Center for treatment of contaminated individuals. In addition, these personnel provide training for the hospital staffs. The current contractor is also on-call for assistance in handling the treatment of contaminated injured personnel.

In conjunction with the hospital of the University of Alabama in Birmingham, the current contractor has established advanced radiation medical facilities.

These facilities include qualified personnel trained in the care of radiation accident victims, a radiosurgery decontamination suite for surgery on contaminated patients, an exposure treatment suite for treatment of severely overexposed victims, and an exposure L-3 REV 66 3/16

  • Design and construction support manager: focuses necessary engineering, design, and construction resources on those aspects of plant recovery requiring redesign, modifications, or new construction; directs and coordinates nuclear steam supply system (NSSS) and balance-of-plant engineering and construction/repair work.
  • Chemistry manager: develops plans and procedures to process and control liquid, gaseous, and solid wastes to minimize adverse effects on the health and safety of the public and plant recovery personnel.

In addition, the chemistry manager coordinates the activities of staff radiological engineers and radiation protection personnel engaged in waste treatment operations.

  • Radiation protection manager: responsible for As Low As Reasonably Achievable (ALARA) planning, execution, and monitoring; plans and manages decontamination of affected areas and equipment; supervises and directs all special radiological controls required to support the recovery operation; and coordinates environmental assessment activities with the manager-environmental services.
  • Technical support manager: provides analyses, plans, schedules, and procedures in direct support of plant operations.
  • Nuclear oversight manager: ensures that the overall conduct of recovery operations is performed in accordance with corporate policy and rules and regulations governing activities which may affect public health and safety.
  • Scheduling/planning manager: prepares plans and schedules and tracks/expedites recovery operations.
  • Administration/logistics manager: supplies administrative, logistic, communications, and personnel support for the recovery operation.
  • Public information director: coordinates the flow of media information concerning recovery operations.

Once the organization is established and specific responsibilities are assigned, the recovery manager may relocate some or all of the recovery organization staff from the EOF.

M-3 REV 66 3/16

M.3 REENTRY PLANNING If the accident situation involved a release of radioactivity, appropriate areas of the plant and site will be monitored to determine contamination and radiation levels.

Identifying and controlling access to these areas will be in accordance with normal plant procedures. When reentry to a radiation area is required for inspection or work, the activity will be preplanned and plant radiation work practices and As Low As Reasonably Achievable (ALARA) program principles will be followed.

M.4 EXPOSURE MONITORING All personnel who require access to the plant or to radiation areas on site during the recovery phase will be issued dosimetry, as appropriate. The criteria for reading Optically Stimulated Luminescent Dosimeters (OSLDs) and assessing radiation dose will be in accordance with standard radiation protection practices. The results of the dosimeter readings, including integrated exposures (i.e., man-rems) will be reported to the recovery manager, the radcon/radwaste manager, and others in the plant organization who normally receive such reports.

The State of Georgia, the State of South Carolina, and SRS have the responsibility for determining population exposure of the public via plume exposure and ingestion pathways.

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.

By determining the affected population (see appendix 6) and by performing dose assessment calculations including determining the quantity of radioactivity and release rate, VEGP personnel can estimate the population exposure if necessary. Use of data from fixed monitoring stations (OSLDs and air samplers) can be used to confirm the exposure estimates.

M-4 REV 66 3/16

TABLE 0-1 (SHEET 3 OF 3}

Training Course Description Radiological Emergency This course covers methods for Team In Plant performing in-plant radiation, contamination, and airborne radioactivity surveys under emergency conditions; search and rescue of missing personnel; managing radiation protection activities; and communications for the above activities.

Security This course covers emergency response activities of the security department including personnel accountability; traffic control; communications; and access control to emergency response facilities.

Medical Support of This course covers the Radiation Emergencies responsibilities and methods for handling exposed and/or contaminated injuries. It includes interfacing with ambulance crews; radiation protection activities for transporting a contaminated injured patient to the hospital; monitoring and decontamination while at the hospital; and final disposition of the ambulance, ambulance crew, hospital staff, and radiation emergency area (REA) at the hospital.

SCBA This course covers the use of self-contained breathing apparatus including equipment description; proper donning and use; and inspection and actions in case of equipment failure.

REV 66 3/16

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P. RESPONSIBILITY FOR THE PLANNING EFFORT The Executive Vice President/Chief Nuclear Officer (CNO)

Southern Nuclear Operating Company (SNC) has overall responsibility and authority for all nuclear activities, including emergency planning (EP) programs.

The SNC Emergency Planning program is comprised of two distinct and integral functions; emergency planning and emergency preparedness. Responsibility for the performance of these functions is assigned to various members of the SNC Organization and coordinated as follows.

Emergency Planning:

The Vice President Regulatory Affairs reports to the president/CEO. This individual is responsible for licensing through: providing organizational support and management oversight of the sites to assure prompt and proper disposition of regulatory issues; the development of regulatory positions; advising senior management on priorities and activities affecting regulatory at the nuclear sites; and interfacing with NRC management on behalf of the sites. Other responsibilities include: developing policies, standardized processes, and procedures for the maintenance of the licensing basis; the preparation of submittals to the NRC and other regulatory organizations; and the dissemination of regulatory information. Reporting to the vice president-regulatory affairs is the fleet emergency preparedness director, the fleet performance improvement manager, the regulatory affairs director-fleet, and the regulatory affairs director-nuclear development. The regulatory affairs director-nuclear development is functionally independent of SNC's operating fleet and is noted here for completeness only. Accordingly, the vice president-regulatory affairs is responsible for administration of the corrective action program in the corporate headquarters, the overall coordination of the corporate emergency preparedness programs (including the common Emergency Operations Facility),

Emergency Plans, and site emergency response communication.

His direct report, the Fleet Emergency Preparedness Director, has the overall governance, oversight, and support of fleet emergency preparedness activities and programs.

The Fleet Emergency Preparedness Director is responsible for overseeing emergency planning activities offsite and coordinating those activities with Licensee, Federal, State and local response organizations. The Emergency Preparedness Manager(s) reports to the Fleet Emergency Preparedness Director in support of this effort.

P-1 REV 66 3/16

The Emergency Plans are maintained by the Fleet Emergency Preparedness Director. The Fleet Emergency Preparedness Director provides strategic direction for SNC emergency planning and coordinates with site management through the Vice President - Fleet Operations Support.

The Emergency Preparedness Manager(s) coordinates site input and involvement in emergency planning programs with the Emergency Preparedness Supervisor. The Emergency Preparedness Manager(s) reviews Emergency Plan changes to determine if the effectiveness of the specific plans have been reduced. Emergency Plan changes which are judged to reduce the effectiveness of the Plan will be submitted to the NRC for approval prior to implementation.

Emergency Preparedness:

The Vice President - (Plant) is responsible for the site Emergency Preparedness aspects of the program. The Emergency Preparedness Supervisor is responsible for coordinating emergency preparedness activities onsite and supports offsite emergency preparedness activities in the vicinity of the plant. The Emergency Preparedness Supervisor reports through the Regulatory Affairs Manager to the Vice President Nuclear Plant Site.

The Emergency Preparedness Supervisor is responsible to the Regulatory Affairs Manager for implementation of emergency planning strategies.

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 procedure development and maintenance.

Figure P-1 shows the EP Organization. The Fleet Emergency Preparedness Director, Emergency Preparedness Manager (s),

Emergency Preparedness Supervisor, and other individuals with emergency planning responsibilities are trained by self-study and by attending industry seminars, short courses, workshops, etc.

Onsite Emergency Plan Implementing Procedures (EPIP) are maintained by the Regulatory Affairs Manager with the Emergency Preparedness Supervisor being the principal site contact. EPIPs for the corporate emergency response organization and procedures governing fleet emergency planning activities are maintained by the Fleet Emergency Preparedness Director. The Fleet Emergency Preparedness Director performs a review of the site specific emergency plan annually and all onsite EPIPs biennially. The review P-2 REV 66 3/16

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

The Fleet Emergency Preparedness Director performs a review of the emergency plans for Southern Nuclear once each calendar year. The review includes a comparison for consistency of all emergency plans for the specific sites including the Security Plan, State, County, and the Savannah River Site plan as appropriate.

The Emergency plans and EPIPs are revised in accordance with applicable site procedures.

Emergency Plan changes which are judged to reduce the effectiveness of the Plan will be submitted to the NRC for approval prior to implementation. The Emergency Preparedness Manager (s) will review Emergency Plan changes to determine if the effectiveness of the site specific plan has been reduced prior to submitting the proposed change for departmental review and subsequently to the PRB for approval.

As required by 10 CFR 50.54(t), an annual independent audit of the emergency preparedness program is 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 every 12 months.

Audits are performed in accordance with SNC Nuclear Oversight department procedures. Audit 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 10 CFR 50.54(t).

Appropriate departments are responsible for implementing corrective actions resulting from the audit findings.

Records of these audits and exercise findings are maintained in accordance with plant procedures.

In addition to this Plan, several other formal emergency plans have been developed to support the overall emergency response effort. These supporting plans and their sources are listed in procedure NMP-EP-300, SNC Emergency Preparedness Conduct of Operations.

P-3 REV 66 3/16

President and CEO

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. . . *- I Staff FIGURE P-1 EMERGENCY PREPAREDNESS ORGANIZATIONS P-4 REV 66 3/16

GLOSSARY (Continued)

Term Definition EOP emergency operating procedure EPA Environmental Protection Agency EPC emergency preparedness coordinator EPD Environmental Protection Division of Georgia EMD Emergency Management Division of South Carolina EPO Emergency Plan Overview EPZ emergency planning zone ERF emergency response facilities FEMA Federal Emergency Management Agency FEOC forward emergency operations center FRERP Federal Radiological Emergency Response Plan FSAR Final Safety Analysis Report FT fire training GEMA Georgia Emergency Management Agency GET general employee training GPC Georgia Power Company HPN Health Physics Network HVAC heating, ventilation, and air conditioning I&C instrumentation and control INPO Institute of Nuclear Power Operations IPC Integrated Plant Computer MSIV main steam isolation valve MSL mean sea level 1-2 REV 66 3/16

GLOSSARY (Continued)

Term Definition RCP reactor coolant pump RCS reactor coolant system REC radiation emergency coordinator RERP Radiological Emergency Response Plan RET radiological emergency team RET/E radiological emergency team/environmental RET/I radiological emergency team/in plant RP Radiation Protection RO reactor operator RPU remote processing unit RTD resistance temperature detector RVLIS reactor vessel level instrumentation system RWP radiation work permit SAT satisfied SC South Carolina SCORERP South Carolina Operational Radiological Emergency Response Plan SEC security SG steam generator SLED State Law Enforcement Division of South Carolina SMA strong motion accelerometer SNC Southern Nuclear Operating Company SOE sequence of events SPDS safety parameter display system SRO senior reactor operator SRS Savannah River Site 1-4 REV 66 3/16

B. Alert and Higher Classifications The SNC On-Call Media Rep will be advised of an event classified as Alert level or higher. The SNC rep will notify the APC/GPC On-Call Media Rep, as appropriate, with a description of the situation. The APC/GPC on-call media rep will notify the PID who will:

1. Formally activate the Emergency Communications Plan.
2. Notify emergency communications staff per Nuclear Management Procedure NMP-GM-036.
3. Establish contact with the Emergency Operation Facility.
4. Establish contact with appropriate local, state and federal agencies.
5. Issue news release(s).

In addition, the PI Director will evaluate the following actions:

1. Activating the JIC and dispatch staff accordingly.
2. Conducting news briefings at the CMC or the JIC, which will include to the maximum extent possible, a panel composed of the Nuclear Spokesperson and representatives of government agencies.

10 REV 66 3/16

INDEX OF VEGP ADMINISTRATIVE, NUCLEAR MANAGEMENT AND EMERGENCY PLAN IMPLEMENTING PROCEDURES CROSS REFERENCED TO SECTIONS OF THE VEGP EMERGENCY PLAN (SHEET 1 OF 3)

NMP-AP-001 Development and Control of Southern Nuclear p Procedures 00910-C VEGP ALARA Pro ram K 00930-C Radiation and Contamination Control K L

K Ob960-C Control of Radioactive Materials L 00970-C K 91101-C B NMP-EP-110 Determination B 91103-C of the TSC B 91104-C Duties of the B 91106-C Duties of the Coordinator B 91107-C Duties of the B 91108-C Duties of the B 91109-C Duties of the B 91110-'C Duties of the Radiation Protection Supervisor B (TSC) 91111-C Duties of the (TSC) B 91201-C H 91202-C Activation and O eration of the OSC H 91204-C Erner Communications A,F 91301-C K 9-1 REV 66 3/16