Text

Emergency Plan Implementing Procedure, Revision 25 to Training Program Procedure 101
	ML16061A006
Person / Time
Site:	Cooper
Issue date:	02/18/2016
From:	Shaw J; Nebraska Public Power District (NPPD)
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NLS2016015
	Download: ML16061A006 (48)
	v • d • e

N!

Nebraska Public Power District Always there when you need us NLS2016015 February 18, 2016 50.54(q)

U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001

Subject:

Emergency Plan Implementing Procedure Cooper Nuclear Station, Docket No. 50-298, DPR-46

Dear Sir or Madam:

The purpose of this letter is to report a change to the following Emergency Plan Implementing Procedure (EPIP) and provide a summary of the associated 10 CFR 50.54(q) analysis for the change to the EPIP:

Training Program Procedure 101 Revision 25 Emergency Response Organization This letter contains no regulatory commitments.

If you have any questions regarding this submittal, please contact me at (402) 825-2788.

Sincerely,

.Licensing Manager

/bk

Attachment:

Enclosure:

Report of Change and Summary of 50.54(q) Analysis - Emergency Preparedness Training Program Procedure 101, Revision 25 Emergency Preparedness Training Program Procedure 101, Revision 25 Telephone: (402) 825-3811 / Fax:- (402) 825-5211

~www.nppd.com

NLS20 16015 Page 2 of 2 cc:

Regional Administrator, w/ attachment and enclosure (2)

USNRC - Region IV Director, Spent Fuel Project Office, wI/attachment and enclosure Office of Nuclear Material Safety and Safeguards Senior Resident Inspector, wI/attachment and enclosure USNRC - CNS NPG Distribution, w/ attachment and w/o enclosure CNS Records, w/ attachment and w/o enclosure

NLS20 16015 Attachment Page 1 of 1 Attachment Report of Change and Summary of 50.54(q) Analysis -

Emergency Preparedness Training Program Procedure 101, Revision 25 Description of Change The change to Emergency Preparedness Training Program Procedure (TPP) 101, Emergency Response Organization, added a training module for protective action recommendations (PAR) as required training for the Chemistry/Radiation Coordinator position in the Technical Support Center.

Other editorial changes were also made that did not require a 10 CFR 50.54(qj) evaluation.

Summary of Analysis (10 CFR 50.54(q) evaluation)

Licensing Basis Affected by Change:

Cooper Nuclear Station (CNS) Emergency Plan (E-Plan) Section 8.1.1, Training for CNS Emergency Response Organization (ERO), discusses initial and requalification training aspects, conduct of training, and required areas of training for ERO members.

The change does not affect ERO Training Program requirements and maintains compliance with the CNS E-Plan.

How Change Complies with Regulations and Previous Commitments:

10 CFR 50.47(b)(15), requires that radiological emergency response training is provided to those who may be called on to assist in an emergency.

10 CFR 50, Appendix B, Sections IV.F, Training, provides supporting training requirements.

The change to TPP 101 does not impact and continues to comply with the above requirements.

Additionally, there were no applicable regulatory commitments identified.

Affected Emergency Planning Functions/Impact on Effectiveness of Emergency Planning Functions:

10 CFR 50.47(b)(15); Function - Training is provided to emergency responders.

Although the Chemistry/Radiation Coordinator position does not develop or approve PARs, an individual filling this ERO position could have the proper skill set to provide input and should have adequate knowledge of the process.

The change to add a PAR training module does not reduce the frequency of required training or remove training required for this ERO position. This change complies with the planning standard and associated requirements and does not constitute a reduction in effectiveness of the CNS E-Plan.

NLS2016015 Enclosure Page 1 of 45 Enclosure Emergency Preparedness Training Program Procedure 101, Emergency Response Organization, Revision 25

/

N TPP

Title:

Emergency Response Organization Number: 101 Present Revision: 24 New Revision: 25 Date: 9/10/2015 ChangeTamKnp Author:TamKnp NOTE - Procedure 0-EN-TQ-212 may be referred to if changes require evaluation of incumbents for inclusion or exemption.

[ ] Approval: Training Supervisor - All; Line Program Owner or Manager - Revision 0, change to qual. Requirement or Retirement of TPP.

[] Pre-/post-implementation actions identified. If YES, describe them here and, if applicable, list the tracking number for each.

SDESCRIPTION OF CHANGE:

WT 2013-0033 CA-001; Revised standard verbiage when referring to field or survey teams to "Field Monitoring Team".

Revised Initial and Requal Matrix and added to Chemistry/RP Coordinator Training Module EP04 - PARS review. This was due to the Initial and Requal Matrix identifying procedure 5.7.20, PROTECTIVE ACTION RECOMMENDATIONS, as a topic for Chemistry/RP Coordinators.

Minor reformatting of document.

ITPP101 REVISION 25 PAGE 1iOF 44

APPROVAL CHECKLIST3 APPROVAL ROUTING APPROVALCHECKLIST3 APPROVALROUTING This checklist is to be completed by the change author. A check mark or other identifying device next to the checklist step indicates compliance.

[X] 1. A description and reason for all significant changes is included.

[N/A] 2.Approval signatures that are not required are N/A'd.

[x] 3. Revised pages and this page are routed to appropriate NTD/Line Management for approval.

[X] 4. For a new or revised TPP, notification of the appropriate Supervisor has been performed so incumbents are evaluated for inclusion or exemption. 2

[X] 5 Perform a 100FR50.54(q) screen (and evaluation if indicated by the screen) on all changes to any Emergency P~reparedness TPP, TQD, or Lesson.

[N/A] 6. If applicable, pre-/post-implementation actions are described above and tracked.

[N/A] 7. Pre-implementation actions are complete.

[X] 8. When approved, route the hardcopy document to Training Records.

[X ] 9. Route approved EP TPPs to Licensing for NRC submittal.

[IX 10. Move the electronic copy to T:/Trng-Approved.

Tammv KnaDo 1/27/2016 Change Author Signature Date Tammy Knapp (TA for Jim Florence) 1/28/2016 Training Supervisor Signature Date Jim Stouqh 1/28/2016 Line Program Owner or Date Manager Signature N/A Effective Date, if different from the approval date.

TPPI01 REVISION 25 PAGE 2OF 441

COOPER NUCLEAR STATION EFFECTIVE: 112812016 APPROVAL: EP MGR TRAINING PROGRAM PROCEDURE 101 OWNER: EP MGR MANAGER: EP MGR EMERGENCY RESPONSE ORGANIZATION DEPARTMENT: EP 1.2.

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INTRODUCTION.................................................................................. 3 DEFINITIONS..................................................................................... 5 DESCRIPTION..................................................................................... 6 ADMINISTRATION.............................................................................. 20 EVALUATION.................................................................................... 26 ATTACHMENT 1 ERO INITIAL QUALIFICATION REQUIREMENTS MATRIX.......... 31 ATTACHMENT 2 ERO REQUALIFICATION REQUIREMENTS MATRIX................ 33 ATTACHMENT 3 SAMG MATRIX............................................................ 35 ATTACHMENT 4 ERO INITIAL AND REQUAL TRAINING RECORDS................... 36 ATTACHMENT 5 EP01 - EP FUNDAMENTALS EMERGENCY PLANNING............ 38 ATTACHMENT 6 EP02 - EP FUNDAMENTALS EMERGENY RESPONSE............. 39 ATTACHMENT 7 EP03 - EMERGENCY CLASSIFICATION.............................. 40 ATTACHMENT 8 EP04 - PROTECTIVE ACTION RECOMMENDATIONS.............. 41 ATTACHMENT 9 EPO5 - DOSE ASSESSMENT............................................ 42 ATTACHMENT 10 EP06 - CORE DAMAGE ASSESSMENT............................... 43 ATTACHMENT 11 COMMITMENTS AND OBLIGATIONS MATRIX....................... 44 1.INTRODUCTION 1.1 Goal The Emergency Response Organization (ERO) Training Program provides for initial qualification, requalification training and evaluation of CNS emergency response personnel. The ERO Training Program is designed to ensure that personnel are qualified to perform their functions and responsibilities as documented within the CNS Emergency Plan and Emergency Plan Implementing Procedures. Initial training and evaluation qualifies selected personnel to respond and participate in an emergency as an active member of the ERO. Annual requalification training and evaluation ensures that ERO members maintain their readiness to respond.

ITPP101 REVISION 25 PAGE 3 OF 441

1.2 General Training And Qualification Process 1.2.1 The responsibilities and tasks for each of the ERO positions are defined by the CNS Emergency Plan, Implementing Procedures and Position Instruction Manuals.

A. The provisions for initial training are addressed by position specific requirements provided in the ERO Qualifications Requirements Matrix (Attachment 1).

1) Initial qualification training is designed to provide the appropriate knowledge and skills necessary to obtain qualification.

2) Knowledge based training is required for each ERO position's initial qualification./

3) Performance based training is required for each ERO position's initial qualification.

B. The provisions for requalification training are addressed by position specific requirements outlined in the ERO Requalification Requirements Matrix (Attachment 2).

1) Requalification training is designed to reinforce and improve the knowledge necessary for ERO personnel to maintain qualification.

2) Knowledge based training for requalification is selected by importance and level of difficulty specific to each ERO position.

3) Performance based training is required for requalification or performance in an actual event (drill participation or appropriate demonstration of position proficiency).

1.2.2 Emergency Response Organization candidates initially qualify for a position upon completion of all the training and evaluation elements contained on the ERO Initial Qualification Record. Once the initial qualification record is completed, the individual is placed into an annual requalification cycle.

1.2.3 At a minimum, a yearly drill will be scheduled for each of the 3 ERO Teams. NRC PI counting opportunities shall be scheduled for each Team on a 2 year periodicity. ERO qualified individuals will have these opportunities to participate, mentor or perform as a Controller or Evaluator.

1.2.4 Content of the ERO Training Program is defined by the CNS Emergency Plan and through ongoing review, audits, evaluation and self-assessment programs.

ITPP10I REVISION 25 PAGE 4 OF 44]

2. DEFINITIONS 2.1 Computer Based Training (CBT) - Training conducted using a computer workstation tied to a Local Area Network (LAN).

2.2 Classroom Training - A type of training typically utilized to provide fundamental or technical knowledge for new or complex information necessary to realize a concept or to perform a responsibility or task.

2.3 Drill - A supervised instruction and/or evaluation period conducted as a dynamic scenario event simulation used to train or evaluate the performance and proficiency of individual ERO members and the organization as a whole.

2.4 Evaluation - An objective assessment of the knowledge and/or skill utilized to accomplish or demonstrate an objective or task.

2.5 Exercise - A supervised evaluation period conducted as a dynamic scenario event simulation used to evaluate the performance and proficiency of individual ERO members and the organization as a whole.

2.6 Experience - The knowledge and skill derived from direct participation in specific subject related activities. Knowledge derived from others or from observation of others performing the activities is not experience.

2.7 Knowledge Based Instruction - Training designed to provide a fundamental or technical understanding of the information necessary to realize a concept or to perform a responsibility or task. Typically, knowledge based instruction is conducted within a classroom or other removed environmental setting.

2.8 Job Analysis - A method used to obtain a detailed list of responsibilities and tasks of a specific job. Job analysis is the first step to obtain information required for a task analysis.

2.9 Needs Analysis - A process of identifying potential or existing training needs by examining gaps between performance requirements and existing or expected performance.

2.10 Performance Based Instruction - A systematic functional training designed around specific responsibilities and tasks to provide the related experience and skills required for competent job performance.

2.11 Refresher Training - Training provided in various forms i.e. information packages, classroom training, etc. to qualified ERO personnel based on performance deficiencies identified in EP drills or as requested by ERO personnel.

2.12 Self-Directed Training - A type of training typically utilized to provide fundamental knowledge or technical refresher information of the knowledge necessary to reinforce a concept or to perform a responsibility or task.

ITPP101 REVISION 25 PAGE 5 OF 44J

2.13 Table Top Instruction - A supervised instruction period conducted as a situation analysis used to train the programmatic knowledge and understanding of individual ERO members and coordinated elements of the response organization.

2.14 Task Analysis - A systematic process of examining a task to identify conditions, standards, elements and required skills or knowledge.

2.15 Walk-Through - A supervised instruction and/or evaluation period conducted to provide hands-on experience and knowledge in organizational relationships and the use of emergency procedures, equipment and facilities. Walk-Throughs may also be utilized to evaluate the practical knowledge and capabilities of individual ERO members.

3. DESCRIPTION 3.1 Prerequisites - General prerequisites for the ERO Training Program are reviewed in the ERO staffing process. The following information is to be used as.quidance for the selection of personnel to fill an ERO position. A more senior or qualified individual may fill any of these positions.

The appropriate CNS Management and Supervisory personnel are contacted by the EP Department when ERO vacancies or upcoming vacancies are identified. Names of candidates are provided to the EP department from the appropriate management or supervisory personnel using the selection guidance listed or using the guidance, EP may request a specific candidate that meets the criteria listed in this TPP.

The EP Manager has the final decision on candidates selected to fill ERO positions. The EP Manager will validate that for a given ERO position the individual is selected based on the guidance listed in this TPP.

3.1.1 Control Room A. On-Shift Emerqency Director - Has overall authority for the direction and management of the response to an incident requiring implementation of the CNS Emergency Plan. Major responsibilities include classification of the emergency, issuing offsite Protective Action Recommendations, and initial notification of CNS and offsite governmental Emergency Response Organizations.

Selection Guidance - Shift Manager or Control Room Supervisor.

Candidate provided by Operations Management.

B. Shift Communicator - Reports to the On-Shift Emergency Director and is responsible for assisting in the notification of CNS, State, local and Federal emergency response personnel.

Selection Guidance - CNS operations or shift support personnel.

Typically assigned to Control Room Crew. Candidate provided by Operations Management.

TPP101 REVISION 25 PAGE 6 OF 441

C. CR Chem/RP Technician - Reports to the On-Shift Emergency Director and is responsible for performing radiological support functions in support of the Control Room.

Selection Guidance - CNS Radiological Department personnel qualified as a "Shift" technician. Candidate provided by Radiological Protection Management.

D. CR Dose Assessor - Reports to the On-Shift Emergency Director and is responsible for performing dose assessment activities in support of the Control Room.

Selection Guidance - CNS personnel qualified as a Dose Assessor.

Candidate provided by RP or Chemistry Management.

E. CR Technical Communicator - Reports to the On-Shift Emergency Director and is responsible for maintaining a flow of technical data between the Control Room, JIC, TSC, OSC and EOF.

Selection Guidance - Knowledge of plant operations, preferably either an Operations or Operations Training individual. Candidate provided by Operations Management.

F. CR Log Keeper - Reports to the On-Shift Emergency Director and is responsible for maintaining a log of CR activities.

Selection Guidance - CNS Operations or Operations Training personnel, or an individual with equivalent experience. Candidate provided by Operations Management.

3.1.2 Technical Support Center A. TSC Director - Reports to the Emergency Director and has the authority and responsibility for directing response activities, including protective actions for emergency workers within the Protected Area. Advises the Emergency Director regarding emergency classifications warranted by changes in plant conditions.

Selection Guidance - CNS Operations, Engineering, Maintenance, familiar with overall plant operations. Preferably active or past operating license and/or active or past Operations, Engineering or Maintenance Supervisory experience. Candidate provided by the GMPO.

B. Chemistry/RP Coordinator - Reports to the TSC Director and is responsible for radiological monitoring, analysis of plant radiological data, and determination and implementation of radiation protection measures within the Protected Area. Advises the TSC Director of the radiological impact of the incident regarding emergency classification and onsite protective and corrective actions.

ITPP101 REVISION 25 PAGE 7 OF 441

Selection Guidance - Active/Past Management or Supervisory personnel from the CNS Radiological Department, or an individual with experience planning, supervising or coordinating radiological or chemistry work activities. Candidate provided by Radiological Protection Management.

C. Maintenance Coordinator - Reports to the TSC Director and is responsible for coordinating and supervising the in-plant repair, monitoring, and mitigating activities. Assists the TSC Director in establishing priorities for response and work activities.

Selection Guidance - Active/Past Management or Supervisory personnel from the CNS Maintenance Department, or an individual with experience planning, supervising or coordinating maintenance and repair activities. Candidate provided by Maintenance Management.

D. Engqineeringq Coordinator - Reports to the TSC Director and is responsible for coordinating the activities of the reactor, mechanical, electrical, and civil engineers.

Selection Guidance - Active/Past Management or Supervisory personnel from the CNS Engineering Department, or an individual with experience planning, supervising or coordinating engineering activities. Familiar with overall plant operations. Candidate provided by Engineering Management.

E. Engqineeringq Team Leader - Reports to the Engineering Coordinator and is responsible for coordinating and implementing tasks assigned to the Engineering Group.

Selection Guidance - Active/Past Supervisory personnel from the CNS Engineering Department or an individual with experience supervising and coordinating engineering activities. Familiar with overall plant operations. Candidate provided by Engineering Management.

F. Engqineeringq Group (Reactor. Mechanical. Electrical. Civil) - Report to the Engineering Team Leader and are responsible for providing engineering analysis and troubleshooting, as directed, to assist in accident mitigation.

Selection Guidance - Experience in the specific engineering discipline. Candidate provided by Engineering Management.

ITPP101 REVISION 25 PAGE 8 OF 441

G. Operations Coordinator - Reports to the TSC Director and is responsible for coordinating with and acting as the primary liaison to the Control Room.

Selection Guidance - CNS Operations, or Operations Support Group personnel familiar with plant operations. Experience in the coordination and management of Operations activities. SRO license is required. Candidate provided by Operations Management.

H. Operations/EOP Advisor - Reports to the Operations Coordinator and is responsible for providing analysis and advice regarding the impact of plant conditions on emergency classifications, Protective Action Recommendations, and accident mitigation.

Selection Guidance - Knowledge of plant systems and operations.

SRO license or certification preferred. Candidate provided by Operations Management.

I.ENS Communicator - Reports to the TSC Director and is responsible for providing continuous communication with the NRC.

Selection Guidance - Familiar with overall plant operations.

Candidate provided by Licensing Management.

J. Security Coordinator - Reports to the TSC Director and is responsible for coordinating assembly, accountability and evacuation and for supervising the security force) activities.

Selection Guidance - Personnel from the CNS Security Department. Knowledge of available security resources and Security Safeguards Plan actions. Involved in the coordination and management of security activities. Candidate provided by Security Management.

K. Administrative Assistant - Reports to the TSC Director and is responsible for providing administrative support while the TSC is operational.

Selection Guidance - CNS administrative personnel, or an individual with acceptable skills. Candidate provided by Administrative Services Superintendent.

L. TSC Lopq Keeper - Reports to the TSC Director and is responsible for maintaining a log of TSC activities.

Selection Guidance - CNS administrative personnel, or an individual with acceptable skills. Proficiency with company word processing software. Candidate provided by Administrative Services Superintendent.

ITPP101 REVISION 25 PAGE 9 OF 441

M. TSG Assessment Enqineer - Report to the Engineering Team Leader and is responsible for performing the duties of Functional Status Assessment Engineer or Control Parameter Assessment Engineer and defined by the Severe Accident Management Guidelines (SAMG).

Selection Guidance - Experience in an engineering discipline, preferably a previously qualified member of the ERO TSC Engineering staff. Candidate provided by Engineering Management.

3.1.3 Operations Support Center A. OSC Supervisor - Reports to the Maintenance Coordinator and is responsible for activation and operation of the OSC. Ensures that all emergency teams are adequately equipped, briefed, and prepared to accomplish their assigned tasks.

Selection Guidance - Knowledge of plant operations and work planning activities, SRO license or certification preferred. Candidate provided by Maintenance Management.

B. Chemistry/Radiation Protection Lead - Reports to the OSC Supervisor and is responsible for advising the OSC Supervisor and dispatched teams regarding radiological monitoring requirements, appropriate radiation protection/ALARA, and contamination control measures for emergency response teams dispatched from the OSC.

Selection Guidance - Active/Past Supervisory personnel from the CNS Radiological Department with knowledge of CNS radiation protection/ALARA, contamination controls policies, and procedures.

Familiar with the plant layout and systems locations. Candidate provided by Radiological Protection Management.

C. Mechanical Lead - Reports to the 0SC Supervisor and is responsible for assisting with preparations (work orders, procedure review, etc.) as well as subsequent analysis of data for 0S0 activities with regards to mechanical maintenance activities.

Selection Guidance - Active/Past Supervisory personnel from the CNS Mechanical Maintenance Department, or an individual with experience in the planning and conduct of mechanical maintenance activities. Candidate provided by Maintenance Management.

ITPP101 REVISION 25 PAGE 10 OF 441

D. Electrical Lead - Reports to the OSC Supervisor and is responsible for assisting with preparations (work orders, procedure review, etc.)

as well as subsequent analysis of data for OSC activities with regards to electrical maintenance activities.

Selection Guidance - Active/Past Supervisory personnel from the CNS Electrical Maintenance Department, or an individual with experience in the planning and conduct of electrical maintenance activities. Candidate provided by Maintenance Management.

E. l&C Lead - Reports to the OSC Supervisor and is responsible for assisting with preparations (work orders, procedure review, etc.) as well as subsequent analysis of data for OSC activities with regards to I&C maintenance activities.

Selection Guidance - Active/Past Supervisory personnel from the I

& C Department, or an individual with experience in the planning and conduct of I & C maintenance activities. Candidate provided by Maintenance Management.

F. Utility Lead - Reports to the OSC Supervisor and is responsible for assisting with preparations (work orders, procedure review, etc.) as well as subsequent analysis of data for OSC activities with regards to utility maintenance activities.

Selection Guidance - Active/Past Supervisory personnel from the Utility Department, or an individual with experience in the planning and conduct of utility maintenance activities. Candidate provided by Maintenance Management.

G. Maintenance OSC Pool Personnel - Report to the OSC Leads and are responsible for performing assigned tasks in support of repair and mitigating response activities.

Selection Guidance - Personnel from mechanical, electrical, l&C and utility disciplines. Candidate provided by Maintenance Management.

H. OSC RP Pool Personnel - Report to the Chemistry/RP Lead and are responsible for supporting the radiological emergency response efforts as directed.

Selection Guidance - Qualified Chemistry or Radiation Protection Technician. Candidate provided by Radiological Protection Management.

I.Warehouse Personnel - Report to the OSC Supervisor and are responsible for assisting OSC staff and other personnel in researching parts, determining inventories and locations, and inspecting and issuing parts or equipment.

Selection Guidance - Assigned from Material Services Department.

Candidate provided by Materials, Purchasing & Contracts Management.

ITPP101 REVISION 25 PAGE 11 OF 441 IItPPO EISO 5PGE1 IF

J. OSC Clerk - Reports to the OSC Supervisor and is responsible for maintaining a log of all OSC activities.

Selection Guidance - CNS administrative personnel, or an individual with acceptable skills. Proficiency with company word processing software. Candidate provided by Maintenance Management.

K. OSO Technical Communicator - Reports to the OSC Supervisor and is responsible for maintaining communications between the OSC, EOF, TSC, JIC and Control Room.

Selection Guidance - Knowledge of plant operations, preferably either an Operations or Operations Training individual. Candidate provided by Operation Management.

3.1.4 Emergency Operations Facility A. Emergqency Director - Has overall authority for the direction and management of the NPPD response to an incident requiring implementation of the CNS Emergency Plan. Major responsibilities include classification of the emergency, development of offsite Protective Action Recommendations, and notification of and coordination with offsite governmental response organizations.

Selection Guidance - Active/Past Manager position, or individual with equivalent experience. Experience with daily management or prioritization of plant activities. Multi-discipline department experience preferred. Candidate provided by the GM P0.

B. EOF Director - Reports to the Emergency Director and is

responsible for CNS response activities outside the protected area.

Advises the Emergency Director regarding notifications, offsite conditions, and on Protective Action Recommendations.

Selection Guidance - Active/Past Manager familiar with emergency preparedness program requirements and offsite agencies and authorities. Candidate provided by the GMPO.

C. Radiologqical Control Managqer - Reports to the EQE Director and is responsible for coordinating the C NS assessment and response to offsite radiological conditions.

Selection Guidance - Active/Past Supervisory personnel from the Radiological Department or individual familiar with CNS radiological controls, concepts and radiological measurement equipment.

Candidate provided by Radiological Protection Management.

[TPPI01 REVISION 25 PAGE 12 OF 44J

0. Radiological Assessment Supervisor - Reports to the Radiological Control Manager and is responsible for supervising the computation and evaluation of dose rates, cumulative doses, radiological exposure controls, and appropriate Protective Action Recommendations for individuals outside the Protected Area, including members of the general public within the plume exposure EPZ. Directs the Field Monitoring Teams.

Selection Guidance - Radiological Protection background adequate to provide an informed review and analysis of radiological conditions and PARs, NRRPT certification preferred. Candidate provided by Radiological Protection Management.

E. Dose Assessment Coordinator - Reports to the Radiological Assessment Supervisor and is responsible for dose/dose rate calculations and Protective Action Guide comparisons with regards to PARs.

Selection Guidance - Individual with mathematical and calculation skills. Familiar with radiological controls and concepts. Candidate provided by Radiological Protection Management.

F. Dose Assessment Clerk - Reports to the Dose Assessment Coordinator and is responsible for operating the dose assessment model.

Selection Guidance - CNS Administrative personnel or individual with acceptable skills. Candidate provided by Radiological Protection Management.

G. Field Monitorinq Teams - Report to the Radiological Assessment Supervisor and are responsible for the conduct of offsite plume tracking, monitoring, and sampling activities.

Selection Guidance - Qualified Radiation Protection Technician (note: individuals filling this position are drawn from the 0S0 RP pool and are ANSI 18.1 ). Candidate provided by Radiological Protection Management.

H. Operations/EOP Advisor - Reports to the EOF Director and is responsible for providing analysis and advice regarding the impact of plant conditions on emergency classifications, Protective Action Recommendations, and accident mitigation.

Selection Guidance - Knowledge of plant operations, SRO license or certification preferred. Candidate provided by Operations Management.

[TPP101 REVISION 25 PAGE 13 OF 441

I. Logqistics Coordinator - Reports to the EOF Director and is responsible for ensuring that resources (materials, equipment, personnel, provisions, transportation, etc.) are made available as required to support an effective emergency response. Additionally, responsible for coordinating assembly, accountability, and evacuation of personnel outside the Protected Area, and EOF Security.

Selection Guidance - CNS personnel familiar with procurement of available resources, both within and external to CNS, and how to access those resources. Candidate provided by the GMPO.

J. Emerqency Preparedness Coordinator - Reports to the EOF Director and is responsible for assisting with activation of the Emergency Response Facilities, ensuring ERO personnel are performing their duties as defined by the appropriate EPIPs and PIMs, and operating the Alert and Notification System.

Selection Guidance - Emergency Preparedness staff or personnel with past EP experience. Familiarity with Federal regulations associated with Emergency Preparedness activities and CNS Emergency Plan. Candidate provided by Emergency Preparedness Management.

K. Offsite Communicator - Reports to the EOF Director and is responsible for communications with corporate, local, State and Federal emergency response personnel and facilities.

Selection Guidance - Individual familiar with general plant operations. Candidate provided by GMPO.

L. Clerical Coordinator - Reports to the Logistics Coordinator and is responsible for ensuring that sufficient clerical support exists in the EOF to adequately support ERO personnel.

Selection Guidance - CNS administrative personnel, or an individual with acceptable skills. Candidate provided by Administrative Services Superintendent.

M. EOF Lopq Keeper - Reports to the EOF Director and is responsible for maintaining a log of EOF activities.

Selection Guidance - CNS administrative personnel, or an individual with acceptable skills. Proficiency with company word processing software. Candidate provided by Administrative Services Superintendent.

[TPP101 REVISION 25 PAGE 14 OF 441

N. Field Team Coordinator - Reports to the Radiological Assessment Supervisor and is responsible for coordinating the movement and sampling activities of the CNS Field Monitoring Teams.

Selection Guidance - CNS personnel with past RP experience are preferred. Candidate provided by Radiological Protection Management.

0. Downwind Driver - Assists the Field Monitoring Team as the driver of the Field Monitoring Team Vehicle.

Selection Guidance - CNS personnel familiar with the surrounding Emergency Planning Zone. Valid driver's license required.

Candidate provided by Radiological Protection Management.

3.1.5 Joint Information Center A. JIC Director - Reports to the Emergency Director and directs personnel in preparation of press releases, position statements, interviews, and dissemination of information to employees, industry organizations, legislative representatives, and members of the Board of Directors. Also responsible for ensuring that information authentication is being performed.

Selection Guidance - General Office or CNS personnel familiar with CNS emergency response and support functions and actively involved in Corporate Communication Department activities or CNS Supervisor or Manager. Candidate provided by Corporate Communications Management.

B. JIC Locqkeeper - Reports to the JIC Director and is responsible for maintaining a log of JIC activities.

Selection Guidance - General Office or ONS Clerical support personnel, or an individual with acceptable skills. Proficiency with company word processing software. Candidate provided by Corporate Communications Management.

C. Desigqnated Spokesperson - Reports to the JIC Director and has the responsibility for coordination of press information with offsite public information representatives, interaction with the news media, delivery of press briefings, and statements on behalf of NPPD.

Selection Guidance - General Office or CNS personnel with good public speaking skills and familiarity with nuclear power plant fundamental principles. Experience in Corporate Communications activities preferred. Candidate provided by Corporate Communications Management.

ITPP101 REVISION 25 PAGE 15 OF 441

D. Facility Managqer - Reports to the JIC Director and has the responsibility for facility setup and supplies for the JIC staff.

Selection Guidance - Personnel familiar with CNS emergency response and support functions. Working knowledge of available resources and equipment located in the JIC. Candidate provided by Corporate Communications Management.

E. Technical Briefer - Reports to the JIC Director and is responsible for receiving and relaying technical information from the EOF, advising the Public Affairs Director in matters regarding Tech Specs, USAR, EOPs, EPIPs, and assisting in the composition of news releases.

Selection Guidance - Personnel familiar with CNS emergency response and support functions. CNS engineering and/or radiological experience preferred. Candidate provided by Corporate Communications Management.

F. Media Monitor - Reports to the JIC Director and is responsible for monitoring press briefings and media reports.

Selection Guidance - Personnel familiar with CNS emergency response and support functions. Experience in the setup and operation of audio-visual equipment. Candidate provided by Corporate Communications Management.

G. Public Information Officer - Reports to the JIC Director and is responsible for providing information to support rumor control and employee information activities.

Selection Guidance - Personnel familiar with CNS emergency response and support functions. Good written and verbal communications skills. Proficiency with company word processing software. Candidate provided by Corporate Communications Management.

H. JIC Rumor Control Coordinator - Reports to the Public Information Officer and is responsible for rumor control activities.

Selection Guidance - Personnel familiar with CNS emergency response and support functions. Proficiency with company word processing software. Candidate provided by Corporate Communications Management.

I.JIC Employee Information Coordinator - Reports to the Public Information Officer and is responsible for employee information activities.

Selection Guidance - Personnel familiar with CNS emergency response and support functions. Proficiency with company word processing software. Candidate provided by Corporate Communications Management.

ITPP101 REVISION 25 PAGE 16 OF 441

J. JIC Clerical Coordinator - Reports to the JIC Director and is responsible for ensuring that sufficient clerical support exists in the JIC to adequately support ERO personnel.

Selection Guidance - CNS administrative personnel, or an individual with acceptable skills. Candidate provided by Administrative Services Superintendent.

K. JIC Rumor Control Staff - Reports to the Rumor Control Coordinator and is responsible for rumor control activities.

Selection Guidance - Personnel familiar with customer care and public inquires preferred. Proficiency with company word processing software. Candidate provided by Corporate Communications Management.

3.2 Program Syllabus 3.2.1 Study Modules A. EP Fundamentals: Emerqency Planning (EP01) - This module is an initial instruction for all Emergency Response Organization personnel. Following successful completion of this module, the trainee will be able to describe the fundamental emergency planning concepts as related to the CNS Emergency Plan. This module includes the following lessons and topics:

Emergency Planning Zones Emergency Plans Emergency Response Organizations B. EP Fundamentals: Emergqency Response (EP02) - This module is an initial and requalification instruction for all Emergency Response Organization personnel. This module provides an overall understanding of the functions and organization of emergency response personnel and facilities. Following successful completion of this module, the trainee will be able to describe the fundamental emergency response concepts as related to the CNS Emergency Plan and describe the functions, operations, inter-relations and personnel associated with each of the Emergency Response Facilities.

This module includes the following lessons and topics:

Emergency Measures Emergency Classification Levels Notifications and Communications Emergency Response Facilities ITPP101 REVISION 25 PAGE 17 OF44J

C. Emergqency Classification (EP03) - This module provides the definitions, concepts, and bases for the classification of emergencies. Following successful completion of this module, the trainee will be able to describe the CNS classification scheme, Emergency Action Level organization, and the process utilized to identify and declare emergencies at CNS.

D. Protective Action Recommendations (EP04) - This module provides the requirements and methods for determining Protective Action Recommendations. Following successful completion of this module, the trainee will be able to describe the process used to develop PARs at CNS.

E. Dose Assessment (EP05) - This module describes the background and the role of dose assessment in the emergency response process. Information is included which provides a fundamental understanding of the bases used to develop dose assessment data.

Following successful completion of this module, the trainee will be able to describe the methods used to verify and modify recommendations through the use of dose assessment and projection.

F. Core Damagqe Assessment (EP06) - This module describes the requirements and methods for determining the extent of core damage and the role of core damage assessment in the dose assessment process. Additionally, information is included which provides a fundamental understanding of the bases used to develop core damage assessment data. Following successful completion of this module, the trainee will be able to describe the process used to make core damage estimates and their relationship to dose assessment.

G. Requalification Period - ERO members complete requalification training annually. Requalification training on knowledge based elements generally will be offered on a 12-month cycle not to exceed 15 months. Requalification training on performance-based elements will be offered on a calendar year basis.

3.3 Schedule and Length of Program 3.3.1 Knowledge based training for initial qualification is self-paced. ERO candidates designated to fill vacant CNS ERO positions are assigned an overall course completion date to finish the applicable training elements.

3.3.2 Performance based training utilizing walk-through participation for initial qualification is scheduled upon completion of the knowledge based training requirements. Emergency Preparedness staff or qualified individuals may assign walk-through schedules to facilitate small groups or approaching deadlines.

ITPP101 REVISION 25 PAGE 18 OF 441

3.3.3 Performance based training utilizing drill participation for initial qualification is scheduled upon completion of the knowledge based training requirements.

A. Emergency Preparedness develops an annual drill and exercise schedule to demonstrate required programmatic objectives.

B. Emergency Preparedness staff or designated personnel will coordinate the assignment and scheduling of individuals selected to participate in a drill for training purposes.

3.3.4 Knowledge based training for requalification is self-paced. ERO members are notified of their anniversary date and are allowed to complete the assignment within the requalification period.

3.3.5 Participation in performance based continuing training is not required for annual requalification (note, a satisfactory performance evaluation is required annually to maintain qualification). Focused position specific or Facility specific participation is an acceptable method to complete annual requalification.

3.3.6 Refresher knowledge based training is available to all ERO personnel at all times through access to the CBT, self-study, and procedural materials.

3.3.7 Operations personnel will be scheduled and trained in accordance with the Operator Training Programs administered by the Training Department. EP personnel, a Simulator Instructor or an individual approved by the EP Manager that is qualified as an ERO Controller/Evaluator will evaluate Operations personnel performance in Simulator EPIP scenarios.

3.4 Instructor Qualifications 3.4.1 Individuals providing ERO position instruction or evaluation will meet one of the following requirements:

A. Emergency Preparedness Department personnel - "OJT Instructor" qualified for instruction or "TPE Evaluator" qualified for evaluation.

Emergency Preparedness Department personnel Mentor qualified or qualified as Nuclear Instructors have the required knowledge/standard for instruction or evaluation. EP Department personnel are considered proficient by the nature of their job and may provide instruction or evaluation without being qualified to the specific ERO position with approval of the EP Manager.

ITPP101 REVISION 25 PAGE 19 OF 44]

B. Other CNS Personnel - "OJT Instructor" qualified for instruction or "TPE Evaluator" qualified for evaluation. Other CNS Personnel Mentor qualified or qualified as Nuclear Instructors have the required knowledge/standard for instruction or evaluation. In addition, the individual shall be qualified for the ERO position for which they are providing either the instruction or evaluation. The EP Manager may authorize certain individuals to provide instruction or evaluation to students for applicable ERO subordinate positions without being qualified to the ERO position. (For example: a designated Dose Assessment Coordinator would be allowed to instruct a Dose Assessment Clerk).

4.

ADMINISTRATION 4.1 Administrative Responsibilities 4.1.1. The Emergency Preparedness Manager is responsible for:

A. Ensuring a qualified CNS Emergency Response Organization is available to respond to an emergency at all times.

B. Determining the final selection of personnel to fill the ERO positions.

C. Maintaining the list of authorized ERO instructors and evaluators.

D. Ensuring an annual drill schedule is developed and coordinated with Training personnel to facilitate the necessary training and evaluation needs of the ERO.

4.1.2. The Nuclear Training Manager is responsible for:

A. Administration of the ERO Training Program, specifically by:

1) Maintaining document administrative controls for the ERO Training Program Procedure and associated attachments.

2) Maintaining historical records, either electronic or hard copy, which document the qualification of each designated ERO member.

3) Providing the appropriate database reports used to identify training and evaluation requirements for initial qualification and requalification of ERO personnel.

B. Maintaining at least two training individuals certified as ERO evaluators to support drill and walk-through performance evaluations.

ITPP101 REVISION 25 PAGE 20 OF 44J

4.1.3. Line Management for various CNS departments are responsible for:

A. Providing candidates to fill vacancies in the ERO positions.

B. Ensuring that candidates finish their training in a timely manner based on the current staffing levels of the ERO.

4.2 Program Commitments 4.2.1 2 CR-CNS-2012-10158-CA-2. Perform a 10 CFR 50.54(q) screen (and evaluation if indicated) on all changes to any Emergency Preparedness TPP, TQD, or Lesson.

4.2.2 CNS will provide for the initial and annual retraining of personnel with emergency response responsibilities.

4.2.3 Specialized ERO initial training and periodic retraining (including the scope, nature and frequency) is provided by Emergency Preparedness for personnel in the following categories:

A. Directors of the response organization.

B. Personnel responsible for accident assessment.

C. Field monitoring teams and radiological analysis personnel.

D. Repair and damage control/corrective action teams.

E. Personnel responsible for transmission of emergency information and instructions F. Corporate support personnel.

4.2.4 Specialized initial training and periodic retraining programs (including the scope, nature and frequency) shall be provided by CNS in the following categories:

A. Security personnel.

B. Fire Brigade personnel.

C. First Aid and Rescue personnel.

4.4.2 The training program for ERO members shall include both knowledge and performance based training as well as evaluations in which each individual demonstrates the ability to perform his assigned emergency function.

ITPP101 REVISION 25 PAGE 21 OF 44]

A. All ERO positions are required to be trained on the requirement to report to their Emergency Response Facilities when made aware of a large scale event with degraded communications capabilities to or from the site and/or inability to respond to the site. This information is contained in procedure 0-EP-01, which is required reading for all ERO for both initial and requalification training.

NLS2012048-01. © B. The following ERO positions are required to complete lesson EPO001 02, Degraded Core Bases, as listed in Attachment 1.

NLS2001081-09 © 2

1) CR On-Shift Emergency Director

2) EOF On-Call Emergency Director

3) EOF Director

4) EOF Radiological Control Manager

5) EQE Radiological Assessment Supervisor

6) TSC Director

7) TSC Chem./RP Coordinator C. Severe Accident Management Guidelines lessons are required as listed by specific position in Attachments 1 and 2. IER 11-1 Supplement I © 3 D. The following ERO positions are required to complete lesson EPO001-01-07, Fuel Damage Mitigation, (this is commonly referred to as B.5.b)as listed in Attachment I and 2. NLS2006023-08 ©4 IERI11-1 Supplement I ©5

1) EQE On-Call Emergency Director

2) EOF Director

3) TSC Director

4) OSC Supervisor

5) Operations Coordinator

6) Engineering Coordinator

7) Engineering Team Leader

8) Chem/RP Coordinator

9) Maintenance Coordinator 10)RPs 11 )Mechanical Maintenance 1 2)Utility 1 3)Electrician 14)l&C Techs I15)Security Coordinator 1 6)Shift Chem/RP Tech 17)EPC 1 8)Dose Assessor

[TPPI01 REVISION 25 PAGE 22 OF 44

4.2.6 The following ERO positions require drill participation prior to qualification. This requirement can be met either during the training or evaluation session. This requirement is intended to be a facility based session with the minimum staff to ensure interaction of those responsible for RSPS.

1) EQE On-Call Emergency Director

2) EOF Director

3) EOF Radiological Control Manager

4) EOF Off-Site Communicator

5) MCR On-Shift Emergency Director

6) MCR Shift Communicator

7) TSC Director 4.2.7 Individuals assigned to the Control Room, TSC, OSC and the EOF will be issued a TLD. CR-CNS-2006-05167 E I 4.2.8 Refresher training in the form of information packages, classroom training, tabletop discussions, etc. shall be offered to ERO personnel.

This training shall be based on drill performance criteria and also personnel requests. NLS980074-03 © 6 4.2.9 Dose Assessors may be available during implementation of 5.5AIRCRAFT to perform lighting walkdowns and were selected to be trained on turning off specific lighting per CHE005-03-01, 5.5AIRCRAFT Lighting Walk Down (RP/CHE). To facilitate this, the Dose Assessor qualification was used to track the lesson, it is for convenience only. This is not a specific EP requirement and may be changed in the future as deemed necessary.

4.2.10 Site-specific emergency response training shall be offered to those offsite emergency organizations who may be called upon to provide assistance in the event of an emergency.

A. Training for Local support services personnel including Civil Defense/Emergency Management personnel, hospital personnel, ambulance/rescue, police and fire departments shall include the procedures for notification, basic radiation protection, and their expected roles.

B. For those local services support organizations who will enter the site, training shall also include site access procedures and the identity (by position and title) of the individual in the onsite emergency organization who will control the organizations' support activities.

C. All materials and documentation associated with the training of offsite emergency organizations is maintained by Emergency Preparedness.

ITPPI01 REVISION 25 PAGE 23 OF 441

4.3 Program Presentation 4.3.1 Knowledge Requirements - Knowledge requirements are provided; (I) through the presentation of background and program level materials, in the form of CBT or self-directed study modules and (2) by the review of procedures and instructions applicable to the ERO position.

A. Study Modules - Study modules are designed to provide background and/or technical emergency preparedness information necessary to the ERO position. Study modules completed using CBT must be scheduled through the Training Department. Self-directed study modules are designed to be completed individually at any time and from any location.

B. Document Review - Document review is designed to provide a familiarity with the location and depth of information and instruction available to the position. Applicable documents specified for review include Emergency Plan Implementing Procedures (EPIPs) and Position Instruction Manuals (PIMs).

4.3.2 Performance Requirements - Performance requirements are designed to provide a practical element to the ERO training program and a familiarization with the conduct of operations associated with the assigned ERO position. Performance requirements are presented in the form of instructional walk-throughs and/or participation drills.

A. Walk-throughs are designed to provide one-on-one or small group training sessions with a qualified instructor in an interactive lecture type environment. The walk-through will take place within the emergency facility where the position is assigned and will cover the equipment, communications, procedures, and activities necessary to fulfill the responsibilities and activities of that position.

B. Drills are designed to provide facility or organizational training sessions with qualified instructors through interactive scenarios.

Drills are conducted as part of the overall training program for Emergency Preparedness and may sometimes be used to demonstrate periodically required objectives. Participation in a drill for purposes of training will not include an evaluation of an emergency preparedness objective specific to that position as this is designed to be a guided instructional period for the trainee.

ITPP101 REVISION 25 PAGE 24 OF 441

4.3.3 'Required' and 'For Information Only' Reading A. The use of memorandums or other prepared text to address ERO informational needs, identified as necessary for the effective performance of assigned ERO position responsibilities, is determined by the Emergency Preparedness Manager. Information administered through this process must meet the following criteria:

1) The information is Suitable for transmittal through company mail, hard-copy or electronic, or postal service

2) And either:

a) The information is relatively simple and can be adequately conveyed without a formal training session.

b) The information provided is suitable for self-study and does not require interface with an instructor or other knowledgeable individual.

B. If a formal commitment exists to inform personnel of program or procedure changes, required reading will be assigned in order to document receipt for compliance.

1) For Information Only reading is assigned when documentation of receipt and compliance is not required.

2) Reading assignments usually contain a cover letter explaining the reason for issuing the material, the subject material to be reviewed, a point of contact for questions, and any required verification documentation necessary.

3) The Emergency Preparedness Manager will assign a knowledgeable individual to review the materials prior to circulation.

4.4 Program Feedback 4.4.1 Trainingq Progqram Content Evaluation - Emergency Preparedness Department, with assistance from the Training Department, is responsible for overseeing the content and requirements of the ERO Training Program.

A. Training program review, periodic Emergency Preparedness program audits, and evaluations are used to analyze training needs and to evaluate training content.

B. The training program content is improved, refined, and maintained through feedback from the above sources and through accepted comments from previous training, drills, or reviews conducted through Emergency Preparedness activities.

ITPP101 REVISION 25 PAGE 25 OF 441

C. The Emergency Preparedness Manager is responsible for implementing changes or additions determined necessary for ERO training needs.

4.4.2 Traininq Progqram Effectiveness Evaluation - Evaluation is integral to the training process and is used to measure, control, and improve the training program.

A. ERO training program evaluations conducted from an Emergency Preparedness perspective are performed through drill and exercise performance evaluations, audits, surveys, or assessments.

B. ERO training program evaluation results are reviewed by the Emergency Preparedness Department for applicability and implementation as appropriate.

4.4.3 Trainee Feedback - Trainees are afforded the opportunity to provide feedback at the end of both knowledge and performance based training events. Additionally, personnel are encouraged to provide input to the Training or Emergency Preparedness Departments whenever an issue or improvement item is identified.

A. Trainee feedback will be collected using the guidance in EN-TQ-201-04 "SAT - Implementation Phase".

B. Feedback is reviewed by Emergency Preparedness departmental personnel to determine whether the item should be incorporated by the program or that the individual providing the feedback needs clarifying information to better understand or perform their responsibilities.

C. Feedback meeting the criteria for entry into the Corrective Action Program (CAP) will be entered into CAP. Corrections or suggestions entered into the CAP will be prioritized and completed based on input from the EP Department and the CAP process.

D. EP Department personnel will disposition feedback not meeting the criteria for entry into the CAP. Suggestions or recommendations for improvement will be validated, prioritized and completed based on available resources.

5.

EVALUATION 5.1 Requirements and Criteria 5.1.1 Knowledge based training elements are evaluated using CBT or written examinations and interviews.

ITPP101 REVISION 25 PAGE 26 OF 44]

A. The criteria for successful completion of a written examination is established in accordance with Training Department instructions.

1) Remediation for missed questions will be provided immediately after examination grading.

2) Personnel who fail an examination must be interviewed by the Emergency Preparedness Manager or designee prior to remedial training and/or reexamination.

B. During initial qualification, personnel are required to review applicable reference documents (EPIPs, PIM) after completion of the training modules.

1 ) Following this review, a qualified instructor or evaluator performs a verbal spot check.

2) Successful demonstration of an understanding of the contents of the document is recorded by signature of the instructor or evaluator.

3) Interviews to verify understanding of the applicable documents are intended to take place in a one-on-one question and answer session.

4) The Emergency Preparedness Manager or designee must interview personnel who demonstrate a lack of knowledge on applicable reference documents after completion of the review.

5.1.2 A written examination and interviews of knowledge based training elements is not conducted as part of req ualification. Fundamental knowledge for the position is demonstrated as part of the performance evaluation. Performance based training elements are observed and assessed by individuals who have been designated as qualified evaluators.

A. The criteria for satisfactory demonstration of the trainee's capability to perform their duties and responsibilities is determined by the evaluator in accordance with applicable EPIP and PIM instructions and tasks.

B. Personnel initially qualifying for an ERO position who fail an evaluation cannot be placed on the ERO roster and must be interviewed by the Emergency Preparedness Manager prior to reevaluation.

C. Personnel who fail an evaluation during requalification or other evaluated event are removed from the ERO roster and must be interviewed by the Emergency Preparedness Manager or designee prior to reevaluation.

lTPP101 REVISION 25 PAGE 27 OF 441

D. Consideration should be given to the conduct of an Event Review for any identified human error that is associated with an event, drill, or exercise deficiency using the guidance in Administrative Procedure EN-HU-1 01 and EN-HU-1 03.

E. The Emergency Preparedness Manager maintains the authority to disqualify any individual, at any time, based on performance and to determine the level of remediation necessary for requalification.

5.1.3 Exemptions from Training A. Personnel may be exempted from some or all training. The Emergency Preparedness Manager shall approve requests for ERO training exemption.

B. Exemption - Personnel who can provide documented evidence of education, experience or training which fulfills course, lesson or topic requirements may be given credit on their records, indicating completion.

1) Exemption of training is effective for the same period as the training requirement.

2) Exemptions are documented in accordance with EN-TQ-201-04 "SAT - Implementation Phase It is the policy of this training program that all personnel attend or perform the required training. The exemption process should not commonly be used as a substitute.

C. The Emergency Preparedness Manager shall inform Training of any individuals granted approval for ERO training exemption.

5.2 Evaluation Methods 5.2.1 Examination - Examination of an individual will be conducted in a quiet controlled environment with minimal distractions. Proctor or other examination security controls are in accordance with Training Department instructions for examination security. The examination will involve knowledge related questions on defined objectives.

Examination questions are developed and maintained in accordance with Training Department instructions.

During the examination, students are allowed to use any formal reference materials (EPIPs, PIMs, etc.), which would be available to them as an ERO member. This practice recognizes that only knowledge based questions are being tested and the ability to locate the source of the information through available means is often as important as remembering the information itself (especially with information which is not reinforced through day to day exposure in their job).

ITPPI01 REVISION 25 PAGE 28O44I

5.2.2 Observation - Performance observation of an individual will be conducted in an environment similar to that of practical training in that either a walk-through session or drill participation may be utilized to perform the assessment. Evaluation will involve knowledge and practical demonstrations of the ability to perform the assigned duties and responsibilities for the position.

This evaluation is designed to observe the overall understanding and skills of the individual, not to test every aspect and possible circumstance, which could be addressed in an actual emergency.

Although this method involves a subjective performance evaluation on an individual level, the capability of the entire CNS ERO is evaluated on an annual basis as a direct reflection on the overall effectiveness of the training program. Items identified during these annual evaluations are incorporated as part of recurring performance training as a method to continuously improve the organization's ability to respond to an actual emergency.

5.3 Examination Security 5.3.1 Exam security will be maintained using the guidance contained in EN-TQ-21 7 "EXAMINATION SECURITY".

5.3.2 Access to the examination and question test bank electronic files will be controlled by the EP Training Coordinator 5.4 Documentation and Records 5.4.1 Initial training and qualification for each ERO position is documented and guided by position specific ERO Initial Qualification Records, as well as lessons specified in the Qualification Matrix. The qualification records are designed to specify and document the training and evaluation requirements necessary for qualification.

A. Documentation of Training

1) Initial knowledge and performance based training for each ERO position is documented on a position specific ERO Initial Qualification Record.

2) Requalification knowledge based training for each ERO position is documented on a position specific ERO Requalification Record, as well as lessons specified in the Requalification Matrix or entered via CBT.

ITPP101 REVISION 25 PAGE 29 OF 441

B. Documentation of Evaluation

1) Initial knowledge and performance based evaluation for each ERO position is documented on the ERO Initial Qualification Record, as well as lessons specified in the Qualification Matrix.

2) A written examination and interview of knowledge-based training is not conducted as part of requalification. Fundamental knowledge for the position is demonstrated as part of the performance evaluation.

3) Requalification performance based evaluation is documented on a position specific ERO Requalification Record, as well as lessons specified in the Requalification Matrix or entered via CBT.

4) Submittal of Qualification Records is by the EP Training Coordinator or as designated by the EP Manager.

C. Records of completion of any required initial or continuing training and evaluation are maintained by the Training Department.

ITPP101 REVISION 25 PAGE 30 OF 441

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JATTACHMENT 4 ERO INITIAL AND REQUAL TRAINING RECORDS A'1TACHMENT 4 ERO INITIAL AND REQUAL TRAINING RECORDS The attached training records are developed as individual ERO qualification records.

TQD UL Qual ID CONTROL ROOMION-SHIFT POSiTIONS

1.

On-Shift Emergency Director 0630 20

2.

Shift Communicator 0631 21

3.

Shift Chem./RP Technician 0689 23

4.

Dose Assessor 0697 1426

5.

Technical Communicator 0632 22

6.

Control Room Log Keeper 0633 19 TECHNICAL SUPPORT CENTER POSITIONS

7.

TSC Director 0634 44

8.

Chemistry/RP Coordinator 0635 47

9.

Maintenance Coordinator 0636 39

10.

Engineering Coordinator 0637 36

11.

Engineering Team Leader 0638 37

12.

Electrical Engineer 0639 49

13.

Mechanical Engineer 0640 40

14.

Reactor Engineer 0641 42

15.

Civil Engineer 0642 48

16.

Operations Coordinator 0643 41

17.

ENS Communicator 0645 38

18.

Security Coordinator 0646 43

19.

Administrative Assistant 0647 46

20.

TSG Assessment Engineer 0687 45 OPERATIONS SUPPORT CENTER POSITIONS

21.

OSC Supervisor 0649 33

22.

Chemistry/Radiological Protection Lead 0650 26

23.

Mechanical Lead 0651 30

24.

Electrical Lead 0652 27

25.

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26.

Utility Lead 0654 34

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OSC Maintenance Pool Personnel 0655 29

28.

OSC RP Pool Personnel 0656 32

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Warehouse Personnel 0657 35

30.

0S0 Clerk 0658 31 JTPP101 REVISION 25 PAGE 36 OF 44J

[ATTACHMENT 4 ERO INITIAL AND REQUAL TRAINING RECORDS TQD UL Qual ID EMERGENCY OPERATIONS FACILITY POSITIONS

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On-Call Emergency Director 0659 10

32.

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33.

Radiological Control Manager 0661 12

34.

Radiological Assessment Supervisor 0662 11

35.

Dose Assessment Coordinator 0663 3

36.

Dose Assessment Clerk 0664 2

37.

Logistics Coordinator 0668 8

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39.

Offsite Communicator 0670 9

40.

Clerical Coordinator 0671 1

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Field Team Coordinator 0686 7

42.

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43.

JIC Director 0673 16

44.

JIC Logkeeper 0695 152

45.

Designated Spokesperson 0675 13

46.

Facility Manager 0676 14

47.

Technical Briefer 0677 18

48.

Media Monitor 0678 15

49.

Public Information Officer 0679 17

50.

Rumor Control Coordinator 0691 148

51.

JIC Rumor Control Staff 0692 149

52.

Employee Information Coordinator 0693 150

53.

JIC Clerical Coordinator 0694 151 MULTI-FACILITY POSITIONS

54.

Operations/EOP Advisor 0682 24

55.

Log Keeper (TSC/EOF) 0683 25

[TPP101 REVISION 25 PAGE 37 OF 441

[ATTACHMENT 5 EP01 - EP FUNDAMENTALS: EMERGENCY PLANNING I ATT-ACHMENT 5 EPO1 - EP FUNDAMENTALS EMERGENCY PLANNING The training module is formatted as a self-directed stand-alone document. For document control purposes:

EP0 1-Emergency Planning Fundamentals: Emergency Planning ITPP101 REVISION 25 PAGE 38 OF 441

IATTACHMENT 6 EP02 - EP FUNDAMENTALS: EMERGENCY RESPONSE ATT-]ACHMENT 6 EP02 - EP FUNDAM~ENTALS EMERGENY RESPONSE The training module is formatted as a self-directed stand-alone document. For document control purposes:

EP02-Emergency Planning Fundamentals: Emergency Response ITPPI01 REVISION 25 PAGE 39 OF 44]

ATTACHMENT 7 EP03 - EMERGENCY CLASSIFICATION ATTACHMENT 7 EP03 - EMERGENCY CLASSIFICATION The training module is formatted as a self-directed stand-alone document. For document control purposes:

EP03-Emergency Classification

[TPP101 REVISION 25 PAGE 40 OF 44J

IATTACHMENT 8 EP04 - PROTECTIVE ACTION RECOMMENDATIONS ATTrACHMENT 8 EPO4 - PROTECTIVE ACTION RECOMMENDATIONS The training module is formatted as a self-directed stand-alone document. For document control purposes:

EP04-Protective Action Recommendations

[TPP101 REVISION 25 PAGE 41 OF 441

IATTACHMENT 9 EP05 - DOSE ASSESSMENT A'n'ACIIMENT 9 EP05 - DOSE ASSESSMENT The training module is formatted as a self-directed stand-alone document. For document control purposes:

EP05-Dose Assessment

[TPPI01 REVISION 25 PAGE 42 OF 441

[ATTACHMENT 10 EP06 - CORE DAMAGE ASSESSMENT ATTIACHMENT 10 EP06 - CORE DAMAGE ASSESSMENT The training module is formatted as a self-directed stand-alone document. For document control purposes:

EP06-Core Damage Assessment ITPP101 REVISION 25 PAGE 43 OF 441

IATTACHMENT 11 COMMITMENTS AND OBLIGATIONS MATRIX A'I-IACHMENT 11 COMMITMENTS AND OBLIGATIONS MATRIX

1. COMMITMENTS AND OBLIGATIONS MATRIX COMMITMENTS AND OBLIGATIONS AFFECTED STEPS

©' NLS2012048-01.

3.2.5.A

©2 NLS2001081-09 3.2.5.B

©3 IER 11-1 Supplement I 3.2.5.C

©4 NLS2006023-08 3.2.5.D

©5 IER 11-1 Supplement I 3.2.5.D

©6 NLS980074-03 3.2.8 I CR-CNS-2006-05167 3.2.7 2 CR-CNS-201 2-01 01 58 CA 2 3.2.1 ITPP101 REVISION 25 PAGE 44 OF 441

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Nebraska Public Power District Always there when you need us NLS2016015 February 18, 2016 50.54(q)

U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001

Subject:

Emergency Plan Implementing Procedure Cooper Nuclear Station, Docket No. 50-298, DPR-46

Dear Sir or Madam:

The purpose of this letter is to report a change to the following Emergency Plan Implementing Procedure (EPIP) and provide a summary of the associated 10 CFR 50.54(q) analysis for the change to the EPIP:

Training Program Procedure 101 Revision 25 Emergency Response Organization This letter contains no regulatory commitments.

If you have any questions regarding this submittal, please contact me at (402) 825-2788.

Sincerely,

.Licensing Manager

/bk

Attachment:

Enclosure:

Report of Change and Summary of 50.54(q) Analysis - Emergency Preparedness Training Program Procedure 101, Revision 25 Emergency Preparedness Training Program Procedure 101, Revision 25 Telephone: (402) 825-3811 / Fax:- (402) 825-5211

~www.nppd.com

NLS20 16015 Page 2 of 2 cc:

Regional Administrator, w/ attachment and enclosure (2)

USNRC - Region IV Director, Spent Fuel Project Office, wI/attachment and enclosure Office of Nuclear Material Safety and Safeguards Senior Resident Inspector, wI/attachment and enclosure USNRC - CNS NPG Distribution, w/ attachment and w/o enclosure CNS Records, w/ attachment and w/o enclosure

NLS20 16015 Attachment Page 1 of 1 Attachment Report of Change and Summary of 50.54(q) Analysis -

Emergency Preparedness Training Program Procedure 101, Revision 25 Description of Change The change to Emergency Preparedness Training Program Procedure (TPP) 101, Emergency Response Organization, added a training module for protective action recommendations (PAR) as required training for the Chemistry/Radiation Coordinator position in the Technical Support Center.

Other editorial changes were also made that did not require a 10 CFR 50.54(qj) evaluation.

Summary of Analysis (10 CFR 50.54(q) evaluation)

Licensing Basis Affected by Change:

Cooper Nuclear Station (CNS) Emergency Plan (E-Plan) Section 8.1.1, Training for CNS Emergency Response Organization (ERO), discusses initial and requalification training aspects, conduct of training, and required areas of training for ERO members.

The change does not affect ERO Training Program requirements and maintains compliance with the CNS E-Plan.

How Change Complies with Regulations and Previous Commitments:

10 CFR 50.47(b)(15), requires that radiological emergency response training is provided to those who may be called on to assist in an emergency.

10 CFR 50, Appendix B, Sections IV.F, Training, provides supporting training requirements.

The change to TPP 101 does not impact and continues to comply with the above requirements.

Additionally, there were no applicable regulatory commitments identified.

Affected Emergency Planning Functions/Impact on Effectiveness of Emergency Planning Functions:

10 CFR 50.47(b)(15); Function - Training is provided to emergency responders.

Although the Chemistry/Radiation Coordinator position does not develop or approve PARs, an individual filling this ERO position could have the proper skill set to provide input and should have adequate knowledge of the process.

The change to add a PAR training module does not reduce the frequency of required training or remove training required for this ERO position. This change complies with the planning standard and associated requirements and does not constitute a reduction in effectiveness of the CNS E-Plan.

NLS2016015 Enclosure Page 1 of 45 Enclosure Emergency Preparedness Training Program Procedure 101, Emergency Response Organization, Revision 25

/

N TPP

Title:

Emergency Response Organization Number: 101 Present Revision: 24 New Revision: 25 Date: 9/10/2015 ChangeTamKnp Author:TamKnp NOTE - Procedure 0-EN-TQ-212 may be referred to if changes require evaluation of incumbents for inclusion or exemption.

[ ] Approval: Training Supervisor - All; Line Program Owner or Manager - Revision 0, change to qual. Requirement or Retirement of TPP.

[] Pre-/post-implementation actions identified. If YES, describe them here and, if applicable, list the tracking number for each.

SDESCRIPTION OF CHANGE:

WT 2013-0033 CA-001; Revised standard verbiage when referring to field or survey teams to "Field Monitoring Team".

Revised Initial and Requal Matrix and added to Chemistry/RP Coordinator Training Module EP04 - PARS review. This was due to the Initial and Requal Matrix identifying procedure 5.7.20, PROTECTIVE ACTION RECOMMENDATIONS, as a topic for Chemistry/RP Coordinators.