PNP 2016-035, Revision to Big Rock Point Emergency Plan Implementing Procedure

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Revision to Big Rock Point Emergency Plan Implementing Procedure
ML16127A105
Person / Time
Site: Big Rock Point  File:Consumers Energy icon.png
Issue date: 05/04/2016
From: Hardy J
Entergy Nuclear Operations
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
IEPIP-08, Rev. 10, PNP 2016-035
Download: ML16127A105 (14)


Text

  • Entergy

-===-

Entergy Nuclear Operations, Inc.

Big Rock Point 10269 US 31 North Charlevoix, Ml 49720 Jeffery A. Hardy Regulatory Assurance Manager PNP 2016-035 May4, 2016 10 CFR 50.4(b)(5)

ATTN: Document Control Desk Director, Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Revision to Big Rock Point Emergency Plan Implementing Procedure Big Rock Point Dockets 50-155 and 72-043 License No. DPR-6

Dear Sir or Madam:

In accordance with 10 CFR 50.4(b)(5), enclosed is a revision to Big Rock Point (BRP)

Independent Spent Fuel Storage Installation (ISFSI) Emergency Plan Implementing Procedure Volume 35A, IEPIP-08, "Emergency Preparedness Drills, Exercises and Equipment Checks, Revision 10, and Volume 35A-TOC, Table of Contents, Revision 26. The changes were made in accordance with 10 CFR 50.54(q), and do not decrease the effectiveness of the Emergency Plan.

This letter contains no new commitments and no revisions to existing commitments.

JAH/bed Attachment 1: Volume 35A, IEPIP-08, Revision 10 Volume 35A-TOC, Table of Contents, Revisions 26 CC Administrator, Region Ill, USNRC

ATTACHMENT 1 Big Rock Point ISFSI Volume 35A, IEPIP-08, Revision 10 Volume 35A-TOC, Table of Contents, Revision 26

QUALITY RELATED Volume 35A-TOC Revision 26

  • Entergy,. PAGE 1OF1 INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

EMERGENCY PLAN IMPLEMENTING PROCEDURES TABLE OF CONTENTS PROCEDURE TITLE REVISION PAGES IEPIP 35A-02 ISFSI Emergency Response Organization Responsibilities 13 28 IEPIP 35A-07 Emergency Medical Response 6 6 IEPIP 35A-08 Emergency Preparedness Drills, Exercises and Equipment Checks 10 9 IEPIP 35A-09 Emergency Preparedness Equipment Readiness 9 13 IEPIP 35A-10 Emergency Response Organization Training 5 7 IEPIP 35A-11 Radiological Environmental Monitoring 5 9 IEPIP 35A-12 Dose Assessment 5 8 IEPIP-TOC

BIG ROCK POINT PROCEDURE APPROVAL AND AUTHORIZATION Procedure No. VOLUME 35A. IEPIP-08 Rev No. 10 Procedure

Title:

EMERGENCY PREPAREDNESS DRILLS, EXERCISES AND EQUIPMENT CHECKS CURRENT REVISION STATUS Author Lawrence R. Potter Date 04/11/16 Quality Review Form No. 004-16 APPLICABILITY ISSUE HISTORY Revision No. ---~9_ _ _ _ Date 06/29/15 Quality Review Form No. 018-15 Approved for use Procedure Sponsor/Designate _ _~\s~\=La_w_r~e_nc~e~R~*~P_o_tt_e_r_ _ _ Date 04/11/16 Authorized Period of Use -----=Jo.=u..;..:.ne=-=2""""9'--".2=-=0'--'"1-=-5--=th"""r"""ou""""g"""h"--"J"""'u~n"""e-=2""""9"'""',2=0'-'1'""""7_ __

BEFORE USING THIS PROCEDURE FOR WORK ACTIVITIES, VERIFY WITH THE RESPECTIVE PROCEDURE CONTROLLING DEPARTMENT THERE ARE NO OUTSTANDING TEMPORARY CHANGES When applicable:

PROCEDURE IMPLEMENTATION HISTORY Reviewed for System or Component Operability Performed by Completed/Reviewed by Method of Verification Title Title o Functional Test o Physical Inspection Date Tr me Date Time o Administrative Review AMMS WORK ORDER NO. (if a p p l i c a b l e ) - - - - - - - - - - - - - -

IEPIP-08.doc

QUALITY RELATED Volume 35A-oa I Revision 1O

  • Enteqw. PAGE 1OF1 INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

EMERGENCY PLAN IMPLEMENTING PROCEDURE 35A EMERGENCY PREPAREDNESS DRILLS, EXERCISES AND EQUIPMENT CHECKS TABLE OF CONTENTS Section 1.0 PURPOSE ............................................................................................1

2.0 REFERENCES

..................................................................... ;............... 1 3.0 DEFINITIONS ....................................................................:.................. 1 4.0 RESPONSIBILITIES ............................................................................2 4.1 INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

SUPERVISOR ......................................................................................2 4.2 MANAGER, ENTERGY NUCLEAR PALISADES, LLC (ENP)

EMERGENCY PLANNING ...................................................................2 5.0 DETAILS ..............................................................................................2 5.1 COMMUNICATION TEST ....................................................................2 5.2 EMERGENCY MEDICAL DRILLS, RADIOLOGICAL MONITORING DRILLS, AND EMERGENCY PREPAREDNESS EXERCISES .........................................................................................3 6.0 INTERFACES .......................................................................................3 7 .0 RECORDS ...........................................................................................3 8.0 OBLIGATIONS AND COMMITMENTS IMPLEMENTED BY THE PROCEDURE .......................................................................................3 9.0 ATTACHMENTS ..................................................................................3 IEPIP-08.doc

QUALITY RELATED Volume 35A-oa I Revision 1O

  • Entergy, PAGE 1OF9 INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

EMERGENCY PLAN IMPLEMENTING PROCEDURE 35A EMERGENCY PREPAREDNESS DRILLS, EXERCISES AND EQUIPMENT CHECKS 1.0 PURPOSE Emergency drills and exercises are conducted to ensure the capability of the Emergency Response Organization (ERO) to execute the Independent Spent Fuel Storage Installation (ISFSI) Emergency Plan (IEP) and the ISFSI Emergency Plan Implementing Procedures (IEPIPs).

Periodic drills and exercises are conducted to evaluate emergency response capabilities and to develop and maintain key skills. Some drills may be included as a portion of the radiological emergency preparedness exercise.

2.0 REFERENCES

[1] Big Rock Point Volume 35, Independent Spent Fuel Storage Installation (ISFSI) Emergency Plan 3.0 DEFINITIONS

[1] DRILLS Drills are supervised instruction periods designed to develop and maintain skills in a particular operation.

[2] ISFSI EMERGENCY PLAN MEDICAL DRILLS A medical emergency drill involving a simulated contaminated individual with provisions for participation by the local support service agencies (i.e.,

ambulance and off-site medical treatment facility) will be conducted annually.

[3] RADIOLOGICAL MONITORING DRILLS A site radiological monitoring drill to evaluate the response to emergency radiation protection situations will be conducted annually. These radiological drills can be run in conjunction with the medical drills, emergency drills or as tabletop drills.

IEPIP-08.doc

QUALITY RELATED

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Volume 35A-oa I Revision 1 O PAGE 2 OF 9 INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

EMERGENCY PLAN IMPLEMENTING PROCEDURE 35A EMERGENCY PREPAREDNESS DRILLS, EXERCISES AND EQUIPMENT CHECKS

[4] TESTS Tests are conducted to ensure equipment operates as intended and that specific emergency response information is correct (i.e., telephone numbers).

A communication test with the Michigan State Police, Emergency Manager Homeland Security (EMHSD) - State Emergency Operations Center (SEOC),

the NRC, and off-site support agencies will be performed quarterly.

[5] EXERCISES Exercises are events that test the integrated capability and major portions of the basic elements existing within the IEP and emergency organization.

A radiological emergency preparedness exercise will be conducted biennially.

The exercise will include the mobilization of utility personnel to verify the capability to effectively respond to an accident. Performance will be evaluated and critiqued in order to judge the effectiveness of emergency planning elements.

4.0 RESPONSIBILITIES 4.1 INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

SUPERVISOR The ISFSI Supervisor shall ensure quarterly communication tests are completed as described in Attachment 9.1, Quarterly Communication Test.

4.2 MANAGER, ENTERGY NUCLEAR PALISADES, LLC (ENP) EMERGNECY PLANNING The Manager, ENP Emergency Planning, shall ensure the annual medical drills, radiological monitoring drills, and the biennial exercise are completed as described in Attachment 9.2, Annual Drills and Biennial Exercise 5.0 DETAILS 5.1 COMMUNICATION TEST The ISFSI Supervisor shall perform the quarterly communication test as described in Attachment 9.1, Quarterly Communication Test.

IEPIP-08.doc

QUALITY RELATED Volume 35A-08 Revision 10

  • Entergy: PAGE 3 OF 9 INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

EMERGENCY PLAN IMPLEMENTING PROCEDURE 35A EMERGENCY PREPAREDNESS DRILLS, EXERCISES AND EQUIPMENT CHECKS 5.2 EMERGENCY MEDICAL DRILLS, RADIOLOGICAL MONITORING DRILLS, AND EMERGENCY PREPAREDNESS EXERCISES The Big Rock Site General Manager, or designate shall review the quarterly communication test as described in Attachment 9.1, Quarterly Communication Test and ensure the annual medical drills, radiological monitoring drills, and the biennial exercise are completed as described in Attachment 9.2, Annual Drills and Biennial Exercise.

6.0 INTERFACES

[1] Big Rock Point Volume 34A-03, Records Management.

7.0 RECORDS

[1] Any attachments generated in the performance of this procedure, shall be maintained in accordance with Big Rock Point Volume 34A-03, Records Management.

8.0 OBLIGATIONS AND COMMITMENTS IMPLEMENTED BY THE PROCEDURE BRP Volume 35, Independent Spent Fuel Storage Installation (ISFSI)

Emergency Plan, Section 5.8[2].

9.0 ATTACHMENTS 9.1 QUARTERLY COMMUNICATION TEST 9.2 ANNUAL DRILLS AND BIENNIAL EXERCISE 9.3 BIG ROCK POINT DRILL RECORD PACKAGE TURNOVER CHECKLIST IEPIP-08.doc

QUALITY RELATED Volume 35A-08 Revision 10 f)EntetgY. PAGE40F9 INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

EMERGENCY PLAN IMPLEMENTING PROCEDURE 35A-08 EMERGENCY PREPAREDNESS DRILLS, EXERCISES AND EQUIPMENT CHECKS ATTACHMENT 9.1 QUARTERLY COMMUNICATION TEST Page 1 of 3 RESPONSIBILITIES The ISFSI Supervisor, or designate shall ensure the quarterly communication tests are completed as follows:

NOTE: Quarterly: Occurring within the first week of the calendar quarter (Jan-Mar; Apr-Jun; Jul-Sept; Oct-Dec) plus or minus one week.

ACTIONS

1. Perform the designated checks. System failures or incorrect telephone numbers should be noted in the comments section. Corrections are made by the ISFSI Supervisor and noted in the comments section of this attachment.
2. The dedicated telephone lines shall be tested by activating the telephone and transmitting a simulated message, such as:

"This is the Big Rock Point ISFSI testing its emergency communications system. This message is to verify that the system is working. This is not an emergency, it is only a test."

3. The commercial and site telephones should be tested by dialing the appropriate number and transmitting a simulated message (see Action 2, above).
4. After completing the tests, the ISFSI Supervisor signs the bottom of this attachment and forwards it to the Site General Manager, or designate for review.
5. The Big Rock Site General Manager, or designate shall verify the quarterly telephone number verification checklist against IEPIP-02, Attachment 9.2.2, Emergency Notifications. If the telephone numbers have changed as indicated in the quarterly check, the Site General Manager, or designate shall initiate a change to IEPIP-02, Attachment 9.2.2, Emergency Notifications; within 14 working days after the completion of this attachment.
6. Completed attachments shall be filed in the Big Rock Point Document Control after review in accordance with Big Rock Point Volume 34A-03, Records Management.

IEPIP-08.doc

QUALITY RELATED Volume 35A-08 Revision 10 (tEntetgy; PAGE 5 OF 9 INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

EMERGENCY PLAN IMPLEMENTING PROCEDURE 35A-08 EMERGENCY PREPAREDNESS DRILLS, EXERCISES AND EQUIPMENT CHECKS ATTACHMENT 9.1 QUARTERLY COMMUNICATION TEST Page 2 of 3 EMERGENCY SUPPORT CENTER (ESC)

1. Nuclear Regulatory Commission (NRC)

Verify dial tone on NRC phone located in Central Alarm Station (CAS)

Dial Tone? Yes No Date - - - - - - - - Time - - - - - - - -

If no dial tone, report trouble to NRC Operations Center (301-816-5100)

Name of Person Contacted -------- Date - - - - Time - - - -

2. 911 - Charlevoix. Cheboygan. Emmet County Emergency Dispatch Dial 911 and transmit "test" message.

Name of Person Contacted - - - - - - - - Date - - - - Time - - - -

3. Michigan State Police. State Emergency Operations Center (SEOC)

Dial (517) 241-8000 and transmit "test" message.

Alternate number is (517) 334-6223.

Is number working? Yes_ No_

List any alternate numbers called _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

Name of Person Contacted - - - - - - - - Date - - - - Time - - - -

4. Michigan State Police - Petoskey Post Dial 1-855-677-9619 and transmit "test" message.

Name of Person Contacted - - - - - - - - Date - - - - Time - - - -

IEPIP-08.doc

QUALITY RELATED Volume 35A-08 Revision 10

  • EnteigY. PAGE 6 OF 9 INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

EMERGENCY PLAN IMPLEMENTING PROCEDURE 35A-08 EMERGENCY PREPAREDNESS DRILLS, EXERCISES AND EQUIPMENT CHECKS ATTACHMENT 9.1 QUARTERLY COMMUNICATION TEST Page 3 of 3

5. On-Call Emergency Director (ED)

Verify and call ED as listed on CAS board. Transmit "test" message Name of Person Contacted Date Time - - -

Verify home and office numbers and operability. Are numbers working? Yes _No_

Office Phone Number Home Phone Number *

6. Site General Manager - Big Rock Dial phone number (269) 764-2856 and transmit "test" message.

Name of Person Contacted Date Time - - -

Verify home and office numbers and operability. Are numbers working? Yes_ No_

Cell Phone Number Home Phone Number- - - - - -

7. Chief Nuclear Officer (CNO)

Dial Office phone 1 number (601) 368-5440 and transmit "test" message.

Name of Person Contacted Date Time - - -

Verify home and cell numbers and operability. Are numbers working? Yes No Cell Phone Number Home Phone Number- - - - - -

8. ANI -American Nuclear Insurers Dial (877) 680-2644 and transmit "test" message.

Name of Person Contacted Date - - - - Time - - - -

Performed b y : - - - - - - - - - - - - - - - - - - - Date: _ _ __

Comments:

Resolution:

Reviewed by:


Date: - - - - - -

1 If Communication test is performed during non-working hours, note and skip test of CNO IEPIP-08.doc

QUALITY RELATED Volume 35A-08 Revision 10 PAGE 7 OF 9 INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

EMERGENCY PLAN IMPLEMENTING PROCEDURE 35A-08 EMERGENCY PREPAREDNESS DRILLS, EXERCISES AND EQUIPMENT CHECKS ATTACHMENT 9.2 ANNUAL DRILLS AND BIENNIAL EXERCISE Page 1of2 RESPONSIBILITIES The Manager, ENP Emergency Planning shall ensure drills and exercises are developed, performed, evaluated and documented.

ACTIONS The following actions should be performed as needed for the drill or exercise being developed:

1. Drill/Exercise Preparation
a. Schedule drill/exercise, coordinating date with plant management and involved off-site agencies.
b. Determine the type of drill/exercise and establish appropriate objectives.
c. Coordinate development of scenario.
d. Assign drill/exercise players and controllers.
e. Prepare draft scenario package including:

- drill/exercise objectives

- sequence of events

- evaluation forms

f. Coordinate review of draft scenario package and resolve comments.
g. Prepare final scenario package.

IEPIP-08.doc

QUALITY RELATED Volume 35A-08 Revision 10

  • Enteqzy; PAGE 8 OF 9 INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

EMERGENCY PLAN IMPLEMENTING PROCEDURE 35A EMERGENCY PREPAREDNESS DRILLS, EXERCISES AND EQUIPMENT CHECKS ATTACHMENT 9.2 ANNUAL DRILLS AND BIENNIAL EXERCISE Page 2 of 2

2. Drill/Exercise Performance
a. Distribute scenario packages to controllers.
b. Determine what will be allowed to be prestaged and/or simulated.
c. Conduct controller training/briefing.
d. Conduct player briefing.
e. Conduct drill/exercise.
3. Drill/Exercise Critique and Evaluation
a. Distribute evaluation forms to be completed by players and controllers.
b. Conduct and document a critique with players and controllers.
4. Drill/Exercise Reporting and Tracking
a. Determine what corrective actions are necessary to resolve drill/exercise weaknesses or areas for improvement.
b. Write a summary of the drill/exercise and critique results.
c. Develop an action plan to address drill/exercise weaknesses and/or areas for improvement.
5. Drill/Exercise Record Keeping

_ _ a. Send drill/exercise documentation to the Big Rock Point Document Control in accordance with Big Rock Point Volume 34A-03, Records Management.

NOTE: Typical documents to include in drill/exercise documentation are scenario package, player and controller critique/evaluation forms, attendance sheets and executive summary of drill performance, including reference to any Condition Reports resulting from the drill/exercise.

IEPIP-08.doc

QUALITY RELATED Volume 35A-08 Revision 10 PAGE 9 OF 9 INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

EMERGENCY PLAN IMPLEMENTING PROCEDURE 35A EMERGENCY PREPAREDNESS DRILLS, EXERCISES AND EQUIPMENT CHECKS ATTACHMENT 9.3 BIG ROCK POINT DRILL RECORD PACKAGE TURNOVER CHECKLIST Page 1 of 1 Event Scope/Objectives Scenario Time Line Notification Forms Summary Report Corrective Actions Critique Items Feedback Forms Evaluator Checklist Attendance Sheet Copies (Include Player/Controller List)

Miscellaneous Information (Include all logs, completed forms, etc)

IEPIP 35A-08 Checklists UFI#

Comments:

Completed By:

Reviewed By:

Palisades EP Manager IEPIP-08.doc

  • Entergy

-===-

Entergy Nuclear Operations, Inc.

Big Rock Point 10269 US 31 North Charlevoix, Ml 49720 Jeffery A. Hardy Regulatory Assurance Manager PNP 2016-035 May4, 2016 10 CFR 50.4(b)(5)

ATTN: Document Control Desk Director, Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Revision to Big Rock Point Emergency Plan Implementing Procedure Big Rock Point Dockets 50-155 and 72-043 License No. DPR-6

Dear Sir or Madam:

In accordance with 10 CFR 50.4(b)(5), enclosed is a revision to Big Rock Point (BRP)

Independent Spent Fuel Storage Installation (ISFSI) Emergency Plan Implementing Procedure Volume 35A, IEPIP-08, "Emergency Preparedness Drills, Exercises and Equipment Checks, Revision 10, and Volume 35A-TOC, Table of Contents, Revision 26. The changes were made in accordance with 10 CFR 50.54(q), and do not decrease the effectiveness of the Emergency Plan.

This letter contains no new commitments and no revisions to existing commitments.

JAH/bed Attachment 1: Volume 35A, IEPIP-08, Revision 10 Volume 35A-TOC, Table of Contents, Revisions 26 CC Administrator, Region Ill, USNRC

ATTACHMENT 1 Big Rock Point ISFSI Volume 35A, IEPIP-08, Revision 10 Volume 35A-TOC, Table of Contents, Revision 26

QUALITY RELATED Volume 35A-TOC Revision 26

  • Entergy,. PAGE 1OF1 INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

EMERGENCY PLAN IMPLEMENTING PROCEDURES TABLE OF CONTENTS PROCEDURE TITLE REVISION PAGES IEPIP 35A-02 ISFSI Emergency Response Organization Responsibilities 13 28 IEPIP 35A-07 Emergency Medical Response 6 6 IEPIP 35A-08 Emergency Preparedness Drills, Exercises and Equipment Checks 10 9 IEPIP 35A-09 Emergency Preparedness Equipment Readiness 9 13 IEPIP 35A-10 Emergency Response Organization Training 5 7 IEPIP 35A-11 Radiological Environmental Monitoring 5 9 IEPIP 35A-12 Dose Assessment 5 8 IEPIP-TOC

BIG ROCK POINT PROCEDURE APPROVAL AND AUTHORIZATION Procedure No. VOLUME 35A. IEPIP-08 Rev No. 10 Procedure

Title:

EMERGENCY PREPAREDNESS DRILLS, EXERCISES AND EQUIPMENT CHECKS CURRENT REVISION STATUS Author Lawrence R. Potter Date 04/11/16 Quality Review Form No. 004-16 APPLICABILITY ISSUE HISTORY Revision No. ---~9_ _ _ _ Date 06/29/15 Quality Review Form No. 018-15 Approved for use Procedure Sponsor/Designate _ _~\s~\=La_w_r~e_nc~e~R~*~P_o_tt_e_r_ _ _ Date 04/11/16 Authorized Period of Use -----=Jo.=u..;..:.ne=-=2""""9'--".2=-=0'--'"1-=-5--=th"""r"""ou""""g"""h"--"J"""'u~n"""e-=2""""9"'""',2=0'-'1'""""7_ __

BEFORE USING THIS PROCEDURE FOR WORK ACTIVITIES, VERIFY WITH THE RESPECTIVE PROCEDURE CONTROLLING DEPARTMENT THERE ARE NO OUTSTANDING TEMPORARY CHANGES When applicable:

PROCEDURE IMPLEMENTATION HISTORY Reviewed for System or Component Operability Performed by Completed/Reviewed by Method of Verification Title Title o Functional Test o Physical Inspection Date Tr me Date Time o Administrative Review AMMS WORK ORDER NO. (if a p p l i c a b l e ) - - - - - - - - - - - - - -

IEPIP-08.doc

QUALITY RELATED Volume 35A-oa I Revision 1O

  • Enteqw. PAGE 1OF1 INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

EMERGENCY PLAN IMPLEMENTING PROCEDURE 35A EMERGENCY PREPAREDNESS DRILLS, EXERCISES AND EQUIPMENT CHECKS TABLE OF CONTENTS Section 1.0 PURPOSE ............................................................................................1

2.0 REFERENCES

..................................................................... ;............... 1 3.0 DEFINITIONS ....................................................................:.................. 1 4.0 RESPONSIBILITIES ............................................................................2 4.1 INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

SUPERVISOR ......................................................................................2 4.2 MANAGER, ENTERGY NUCLEAR PALISADES, LLC (ENP)

EMERGENCY PLANNING ...................................................................2 5.0 DETAILS ..............................................................................................2 5.1 COMMUNICATION TEST ....................................................................2 5.2 EMERGENCY MEDICAL DRILLS, RADIOLOGICAL MONITORING DRILLS, AND EMERGENCY PREPAREDNESS EXERCISES .........................................................................................3 6.0 INTERFACES .......................................................................................3 7 .0 RECORDS ...........................................................................................3 8.0 OBLIGATIONS AND COMMITMENTS IMPLEMENTED BY THE PROCEDURE .......................................................................................3 9.0 ATTACHMENTS ..................................................................................3 IEPIP-08.doc

QUALITY RELATED Volume 35A-oa I Revision 1O

  • Entergy, PAGE 1OF9 INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

EMERGENCY PLAN IMPLEMENTING PROCEDURE 35A EMERGENCY PREPAREDNESS DRILLS, EXERCISES AND EQUIPMENT CHECKS 1.0 PURPOSE Emergency drills and exercises are conducted to ensure the capability of the Emergency Response Organization (ERO) to execute the Independent Spent Fuel Storage Installation (ISFSI) Emergency Plan (IEP) and the ISFSI Emergency Plan Implementing Procedures (IEPIPs).

Periodic drills and exercises are conducted to evaluate emergency response capabilities and to develop and maintain key skills. Some drills may be included as a portion of the radiological emergency preparedness exercise.

2.0 REFERENCES

[1] Big Rock Point Volume 35, Independent Spent Fuel Storage Installation (ISFSI) Emergency Plan 3.0 DEFINITIONS

[1] DRILLS Drills are supervised instruction periods designed to develop and maintain skills in a particular operation.

[2] ISFSI EMERGENCY PLAN MEDICAL DRILLS A medical emergency drill involving a simulated contaminated individual with provisions for participation by the local support service agencies (i.e.,

ambulance and off-site medical treatment facility) will be conducted annually.

[3] RADIOLOGICAL MONITORING DRILLS A site radiological monitoring drill to evaluate the response to emergency radiation protection situations will be conducted annually. These radiological drills can be run in conjunction with the medical drills, emergency drills or as tabletop drills.

IEPIP-08.doc

QUALITY RELATED

~-------+-----

Volume 35A-oa I Revision 1 O PAGE 2 OF 9 INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

EMERGENCY PLAN IMPLEMENTING PROCEDURE 35A EMERGENCY PREPAREDNESS DRILLS, EXERCISES AND EQUIPMENT CHECKS

[4] TESTS Tests are conducted to ensure equipment operates as intended and that specific emergency response information is correct (i.e., telephone numbers).

A communication test with the Michigan State Police, Emergency Manager Homeland Security (EMHSD) - State Emergency Operations Center (SEOC),

the NRC, and off-site support agencies will be performed quarterly.

[5] EXERCISES Exercises are events that test the integrated capability and major portions of the basic elements existing within the IEP and emergency organization.

A radiological emergency preparedness exercise will be conducted biennially.

The exercise will include the mobilization of utility personnel to verify the capability to effectively respond to an accident. Performance will be evaluated and critiqued in order to judge the effectiveness of emergency planning elements.

4.0 RESPONSIBILITIES 4.1 INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

SUPERVISOR The ISFSI Supervisor shall ensure quarterly communication tests are completed as described in Attachment 9.1, Quarterly Communication Test.

4.2 MANAGER, ENTERGY NUCLEAR PALISADES, LLC (ENP) EMERGNECY PLANNING The Manager, ENP Emergency Planning, shall ensure the annual medical drills, radiological monitoring drills, and the biennial exercise are completed as described in Attachment 9.2, Annual Drills and Biennial Exercise 5.0 DETAILS 5.1 COMMUNICATION TEST The ISFSI Supervisor shall perform the quarterly communication test as described in Attachment 9.1, Quarterly Communication Test.

IEPIP-08.doc

QUALITY RELATED Volume 35A-08 Revision 10

  • Entergy: PAGE 3 OF 9 INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

EMERGENCY PLAN IMPLEMENTING PROCEDURE 35A EMERGENCY PREPAREDNESS DRILLS, EXERCISES AND EQUIPMENT CHECKS 5.2 EMERGENCY MEDICAL DRILLS, RADIOLOGICAL MONITORING DRILLS, AND EMERGENCY PREPAREDNESS EXERCISES The Big Rock Site General Manager, or designate shall review the quarterly communication test as described in Attachment 9.1, Quarterly Communication Test and ensure the annual medical drills, radiological monitoring drills, and the biennial exercise are completed as described in Attachment 9.2, Annual Drills and Biennial Exercise.

6.0 INTERFACES

[1] Big Rock Point Volume 34A-03, Records Management.

7.0 RECORDS

[1] Any attachments generated in the performance of this procedure, shall be maintained in accordance with Big Rock Point Volume 34A-03, Records Management.

8.0 OBLIGATIONS AND COMMITMENTS IMPLEMENTED BY THE PROCEDURE BRP Volume 35, Independent Spent Fuel Storage Installation (ISFSI)

Emergency Plan, Section 5.8[2].

9.0 ATTACHMENTS 9.1 QUARTERLY COMMUNICATION TEST 9.2 ANNUAL DRILLS AND BIENNIAL EXERCISE 9.3 BIG ROCK POINT DRILL RECORD PACKAGE TURNOVER CHECKLIST IEPIP-08.doc

QUALITY RELATED Volume 35A-08 Revision 10 f)EntetgY. PAGE40F9 INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

EMERGENCY PLAN IMPLEMENTING PROCEDURE 35A-08 EMERGENCY PREPAREDNESS DRILLS, EXERCISES AND EQUIPMENT CHECKS ATTACHMENT 9.1 QUARTERLY COMMUNICATION TEST Page 1 of 3 RESPONSIBILITIES The ISFSI Supervisor, or designate shall ensure the quarterly communication tests are completed as follows:

NOTE: Quarterly: Occurring within the first week of the calendar quarter (Jan-Mar; Apr-Jun; Jul-Sept; Oct-Dec) plus or minus one week.

ACTIONS

1. Perform the designated checks. System failures or incorrect telephone numbers should be noted in the comments section. Corrections are made by the ISFSI Supervisor and noted in the comments section of this attachment.
2. The dedicated telephone lines shall be tested by activating the telephone and transmitting a simulated message, such as:

"This is the Big Rock Point ISFSI testing its emergency communications system. This message is to verify that the system is working. This is not an emergency, it is only a test."

3. The commercial and site telephones should be tested by dialing the appropriate number and transmitting a simulated message (see Action 2, above).
4. After completing the tests, the ISFSI Supervisor signs the bottom of this attachment and forwards it to the Site General Manager, or designate for review.
5. The Big Rock Site General Manager, or designate shall verify the quarterly telephone number verification checklist against IEPIP-02, Attachment 9.2.2, Emergency Notifications. If the telephone numbers have changed as indicated in the quarterly check, the Site General Manager, or designate shall initiate a change to IEPIP-02, Attachment 9.2.2, Emergency Notifications; within 14 working days after the completion of this attachment.
6. Completed attachments shall be filed in the Big Rock Point Document Control after review in accordance with Big Rock Point Volume 34A-03, Records Management.

IEPIP-08.doc

QUALITY RELATED Volume 35A-08 Revision 10 (tEntetgy; PAGE 5 OF 9 INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

EMERGENCY PLAN IMPLEMENTING PROCEDURE 35A-08 EMERGENCY PREPAREDNESS DRILLS, EXERCISES AND EQUIPMENT CHECKS ATTACHMENT 9.1 QUARTERLY COMMUNICATION TEST Page 2 of 3 EMERGENCY SUPPORT CENTER (ESC)

1. Nuclear Regulatory Commission (NRC)

Verify dial tone on NRC phone located in Central Alarm Station (CAS)

Dial Tone? Yes No Date - - - - - - - - Time - - - - - - - -

If no dial tone, report trouble to NRC Operations Center (301-816-5100)

Name of Person Contacted -------- Date - - - - Time - - - -

2. 911 - Charlevoix. Cheboygan. Emmet County Emergency Dispatch Dial 911 and transmit "test" message.

Name of Person Contacted - - - - - - - - Date - - - - Time - - - -

3. Michigan State Police. State Emergency Operations Center (SEOC)

Dial (517) 241-8000 and transmit "test" message.

Alternate number is (517) 334-6223.

Is number working? Yes_ No_

List any alternate numbers called _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

Name of Person Contacted - - - - - - - - Date - - - - Time - - - -

4. Michigan State Police - Petoskey Post Dial 1-855-677-9619 and transmit "test" message.

Name of Person Contacted - - - - - - - - Date - - - - Time - - - -

IEPIP-08.doc

QUALITY RELATED Volume 35A-08 Revision 10

  • EnteigY. PAGE 6 OF 9 INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

EMERGENCY PLAN IMPLEMENTING PROCEDURE 35A-08 EMERGENCY PREPAREDNESS DRILLS, EXERCISES AND EQUIPMENT CHECKS ATTACHMENT 9.1 QUARTERLY COMMUNICATION TEST Page 3 of 3

5. On-Call Emergency Director (ED)

Verify and call ED as listed on CAS board. Transmit "test" message Name of Person Contacted Date Time - - -

Verify home and office numbers and operability. Are numbers working? Yes _No_

Office Phone Number Home Phone Number *

6. Site General Manager - Big Rock Dial phone number (269) 764-2856 and transmit "test" message.

Name of Person Contacted Date Time - - -

Verify home and office numbers and operability. Are numbers working? Yes_ No_

Cell Phone Number Home Phone Number- - - - - -

7. Chief Nuclear Officer (CNO)

Dial Office phone 1 number (601) 368-5440 and transmit "test" message.

Name of Person Contacted Date Time - - -

Verify home and cell numbers and operability. Are numbers working? Yes No Cell Phone Number Home Phone Number- - - - - -

8. ANI -American Nuclear Insurers Dial (877) 680-2644 and transmit "test" message.

Name of Person Contacted Date - - - - Time - - - -

Performed b y : - - - - - - - - - - - - - - - - - - - Date: _ _ __

Comments:

Resolution:

Reviewed by:


Date: - - - - - -

1 If Communication test is performed during non-working hours, note and skip test of CNO IEPIP-08.doc

QUALITY RELATED Volume 35A-08 Revision 10 PAGE 7 OF 9 INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

EMERGENCY PLAN IMPLEMENTING PROCEDURE 35A-08 EMERGENCY PREPAREDNESS DRILLS, EXERCISES AND EQUIPMENT CHECKS ATTACHMENT 9.2 ANNUAL DRILLS AND BIENNIAL EXERCISE Page 1of2 RESPONSIBILITIES The Manager, ENP Emergency Planning shall ensure drills and exercises are developed, performed, evaluated and documented.

ACTIONS The following actions should be performed as needed for the drill or exercise being developed:

1. Drill/Exercise Preparation
a. Schedule drill/exercise, coordinating date with plant management and involved off-site agencies.
b. Determine the type of drill/exercise and establish appropriate objectives.
c. Coordinate development of scenario.
d. Assign drill/exercise players and controllers.
e. Prepare draft scenario package including:

- drill/exercise objectives

- sequence of events

- evaluation forms

f. Coordinate review of draft scenario package and resolve comments.
g. Prepare final scenario package.

IEPIP-08.doc

QUALITY RELATED Volume 35A-08 Revision 10

  • Enteqzy; PAGE 8 OF 9 INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

EMERGENCY PLAN IMPLEMENTING PROCEDURE 35A EMERGENCY PREPAREDNESS DRILLS, EXERCISES AND EQUIPMENT CHECKS ATTACHMENT 9.2 ANNUAL DRILLS AND BIENNIAL EXERCISE Page 2 of 2

2. Drill/Exercise Performance
a. Distribute scenario packages to controllers.
b. Determine what will be allowed to be prestaged and/or simulated.
c. Conduct controller training/briefing.
d. Conduct player briefing.
e. Conduct drill/exercise.
3. Drill/Exercise Critique and Evaluation
a. Distribute evaluation forms to be completed by players and controllers.
b. Conduct and document a critique with players and controllers.
4. Drill/Exercise Reporting and Tracking
a. Determine what corrective actions are necessary to resolve drill/exercise weaknesses or areas for improvement.
b. Write a summary of the drill/exercise and critique results.
c. Develop an action plan to address drill/exercise weaknesses and/or areas for improvement.
5. Drill/Exercise Record Keeping

_ _ a. Send drill/exercise documentation to the Big Rock Point Document Control in accordance with Big Rock Point Volume 34A-03, Records Management.

NOTE: Typical documents to include in drill/exercise documentation are scenario package, player and controller critique/evaluation forms, attendance sheets and executive summary of drill performance, including reference to any Condition Reports resulting from the drill/exercise.

IEPIP-08.doc

QUALITY RELATED Volume 35A-08 Revision 10 PAGE 9 OF 9 INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

EMERGENCY PLAN IMPLEMENTING PROCEDURE 35A EMERGENCY PREPAREDNESS DRILLS, EXERCISES AND EQUIPMENT CHECKS ATTACHMENT 9.3 BIG ROCK POINT DRILL RECORD PACKAGE TURNOVER CHECKLIST Page 1 of 1 Event Scope/Objectives Scenario Time Line Notification Forms Summary Report Corrective Actions Critique Items Feedback Forms Evaluator Checklist Attendance Sheet Copies (Include Player/Controller List)

Miscellaneous Information (Include all logs, completed forms, etc)

IEPIP 35A-08 Checklists UFI#

Comments:

Completed By:

Reviewed By:

Palisades EP Manager IEPIP-08.doc