RS-03-184, Revised Procedures, Including, EP-AA-111, Emergency Classification and Protective Action Recommendations, and EP-AA-115, Termination and Recovery.

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Revised Procedures, Including, EP-AA-111, Emergency Classification and Protective Action Recommendations, and EP-AA-115, Termination and Recovery.
ML032671253
Person / Time
Site: Dresden, Peach Bottom, Byron, Three Mile Island, Braidwood, Limerick, Clinton, Quad Cities, LaSalle  Constellation icon.png
Issue date: 09/19/2003
From: Jury K
AmerGen Energy Co, Exelon Nuclear
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-03-184
Download: ML032671253 (44)


Text

AmerGen., ExelnM An Exelon/Btish EneTgy Company www.exeloncorp.com AmerGen Energy Company, LLC Nuclear 200 Exelon Way Exelon Generation Suite 345 4300 Winfield Road Kennett SquaTe, PA 19348 WaTrenville, IL 60555 10 CFR 50, Appendix E RS-03-184 September 19, 2003 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Braidwood Station, Units I and 2 Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457 Byron Station, Units 1 and 2 Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455 Clinton Power Station, Unit 1 Facility Operating License NPF-62 NRC Docket Nos. STN 50-461 Dresden Nuclear Power Station, Units 2 and 3 Facility Operating License DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249 LaSalle County Station, Units 1 and 2 Facility Operating License NPF-1 I and NPF-18 NRC Docket Nos. 50-373 and 50-374 Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353 Peach Bottom Atomic Power Station, Units 2 and 3 Facility Operating License Nos. DPR44 and DPR-56 NRC Docket Nos. 50-277 and 50-278 Quad Cities Nuclear Power Station, Units I and 2 Facility Operating License DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265 Three Mile Island, Unit I Facility Operating License No. DPR-50 NRC Docket No. 50-289 Ao5f

September 19, 2003 U. S. Nuclear Regulatory Commission Page 2

Subject:

Revisions to the Exelon Nuclear Standardized Radiological Emergency Plan Implementing Procedure In accordance with 10 CFR 50, Appendix E, Section V, "Implementing Procedures," Exelon Generation Company, LLC (EGC) and AmerGen Energy Company (AmerGen) are submitting changes to the following Exelon procedures:

  • EP-AA-1 11 "Emergency Classification and Protective Action Recommendations"
  • EP-AA-1 15 "Termination and Recovery" The procedure revisions incorporate enhancements to the usability and efficiency of the procedures in response to insights gained from their use in the Quad Cities Alert of April 16, 2003. Additionally, EP-M-1 11 is revised to address the use of potassium iodide for events originating at the Limerick, Peach Bottom or Three Mile Island stations. These procedure changes were implemented on August 21, 2003, and are being submitted within 30 days of implementation.

Attachment A provides EP-AA-1 11, Revision 7, "Emergency Classification and Protective Action Recommendations."

Attachment B provides EP-AA-1 15, Revision 2, "Termination and Recovery."

Should you have any questions concerning this letter, please contact Mr. T.W. Simpkin at 630-657-2821.

Respectfully, Keith R. Jury Director - Licensing and Regulatory Affairs Exelon Generation Company, LLC AmerGen Energy Company, LLC cc: Regional Administrator - NRC Region IlIl (two copies)

Regional Administrator - NRC Region I (two copies)

NRC Senior Resident Inspector - Braidwood Station NRC Senior Resident Inspector - Byron Station NRC Senior Resident Inspector - Clinton Power Station NRC Senior Resident Inspector - Dresden Nuclear Power Station NRC Senior Resident Inspector - LaSalle County Station NRC Senior Resident Inspector - Limerick Generating Station NRC Senior Resident Inspector - Peach Bottom Atomic Power Station NRC Senior Resident Inspector - Quad Cities Nuclear Power Station NRC Senior Resident Inspector - Three Mile Island, Unitl Attachment A - Exelon Nuclear Procedure, EP-AA-1 11, Emergency Classification and Protective Action Recommendations" Attachment B - Exelon Nuclear Procedure EP-AA-1 15, "Termination and Recovery"

ATTACHMENT A EP-AA-111, EMERGENCY CLASSIFICATION AND PROTECTIVE ACTION RECOMMENDATIONS

EP-AA-111 Exelem

. ~~~~~~~~~~~~~Revision 7 Page 1 of 19 Nuclear Level 2- Reference Use EMERGENCY CLASSIFICATION AND PROTECTIVE ACTION RECOMMENDATIONS

1. PURPOSE 1.1 This procedure provides guidance for the classification of an emergency condition.

1.2 This procedure provides guidelines for determining Protective Action Recommendations (PARs) to be made to offsite authorities during a General Emergency.

1.3 This procedure provides guidance for event termination and entry into Recovery.

Emergency Classification ......................... REFER to Section 4.1 Transition to Recovery/Termination .......................... REFER to Section 42 Plant Based PARs ......................... REFER to Section 43 Dose Based PARs .......................... REFER to Section 44 Overall PAR Determination ......................... REFER to Section 45

2. TERMS AND DEFINITIONS 2.1 Classification- Emergency classifications are divided into FIVE (5) categories or conditions, covering the postulated spectrum of emergency situations. The first four (4) emergency classifications are characterized by Emergency Action Levels (EALs) associated with Initiating Conditions and address emergencies of increasing severity. The fifth, the Recovery classification, is unique in that it may be viewed as a phase of the emergency, requiring specific criteria to be met and/or considered prior to its declaration. The classifications are as follows:

2.1.1 Unusual Event - Events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety occurs.

2.1.2 Alert - events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant. Any releases are expected to be limited to small fractions of the Environmental Protection Agency (EPA) Protective Action Guideline (PAG) exposure levels.

EP-AA-111 Revision 7 Page 2 of 19 2.1.3 Site Area Emerenc, - Events are in progress or have occurred that involve actual or likely major failures of plant functions needed for protection of the public. Any releases are not expected to exceed EPA PAG exposure levels except near the site boundary.

2.1.4 General Emeraenc,- Events are in progress or have occurred which involve actual or imminent substantial core degradation or melting with potential for loss of containment integrity. Releases can be reasonably expected to exceed EPA PAG exposure levels offsite for more than the immediate site area.

2.1.5 Recovery - That period when the emergency phase is over and activities are being taken to return the situation to a normal state (acceptable condition). The plant is under control and no potential for further degradation to the plant or the environment is believed to exist.

2.2 Emergency Action Levels (EALs) - a Pre-determined, Site-specific, observable threshold for a plant Initiating Condition that places the plant in a given emergency class. An EAL can be: an instrument reading; an equipment status indicator; a measurable parameter; a discrete, observable event; or another phenomenon which, if it occurs, indicates entry into a particular emergency class.

2.3 Emergency Director (ED) - the Director of the facility in Command and Control.

One of the following: the Shift Emergency Director (CR), Station Emergency Director (TSC) or the Corporate Emergency Director (EOF).

2.4 EPA Protective Action Guideline - exposure levels determined by the Environmental Protection Agency for the evacuation of the offsite public following a release of radioactive materials. These levels have been established at one (1)

Rem TEDE or five (5) Rem CDE Thyroid.

2.5 Imminent - mitigation actions have been ineffective and trended information indicates that the event or condition will occur within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

2.6 Initiating Condition (IC) - one of a predetermined subset of nuclear power plant conditions where either the potential exists for a radiological emergency, or such an emergency has occurred.

2.7 Potential - mitigation actions are not effective and trended information indicates that the parameters are outside desirable bands and not stable or improving.

2.8 Protective Action Recommendations (PARs) - PARs are made by Exelon personnel whenever a General Emergency is declared. Additionally, if in the opinion of the Emergency Director, conditions warrant the issuance of PARs, a General Emergency will be declared (Exelon will not issue PARs for any accident classified below a General Emergency).

EP-AA-1 1 Revision 7 Page 3 of 19 2.8.1 Offsite protective actions provided in response to a radioactive release include evacuation and taking shelter.

1. Evacuation is the preferred action unless external conditions impose a greater risk from the evacuation than from the dose received.
2. Exelon personnel do not have the necessary information to determine whether offsite conditions would require sheltering instead of an evacuation.

Therefore, an effort to base PARs on external factors (such as road conditions, traffic/traffic control, weather or offsite emergency worker response) should not be attempted.

2.8.2 At a minimum, a plant-based PAR to evacuate a 2-mile radius and 5 miles downwind, is issued at the declaration of a General Emergency based on NUREG-0654, Rev.1 Supplement 3.

1. Depending on pbnt conditions (e.g., a LOSS of all three fission product barriers per the EALs), a PAR to evacuate a 5-mile radius and 10 miles downwind may be issued instead of the minimum PAR.

At a minimum, a plant-based PAR to evacuate a 5-mile radius is issued at the declaration of a General Emergency. Depending on plant conditions (e.g., a LOSS of all three fission product barriers per the EALs), a PAR to evacuate a 10-mile radius may be issued instead of the minimum PAR.

2. The PAR must be provided to the State, and designated local agencies as applicable, within 15 minutes of (1) the classification of the General Emergency or (2) any change in recommended actions.
3. The PAR must be provided to the NRC as soon as possible and within 60 minutes of (1) the classification of the General Emergency or (2) any change in recommended actions.

2.8.3 The Emergency Director may elect to specify PARs for any combinations of

[MWROG] Subareas / [PB/LG] Sectors / [TMI] Radius or the entire EPZ (or beyond) regardless of plant and dose based guidance.

2.8.4 PARs should not be extended based on the results of dose projections unless the postulated release is likely to occur within a short period of time. Plant based PARs are inherently conservative such that expanding the evacuation zone as an added precaution would result in a greater risk from the evacuation than from the radiological consequences of a release. It also would dilute the effectiveness of the offsite resources used to accommodate the evacuation.

EP-AA-111 Revision 7 Page 4 of 19 2.8.5 Protective actions taken in areas affected by plume deposition following the release are determined and controlled by offsite governmental agencies.

1. Exelon is not expected to develop offsite recommendations involving ingestion or relocation issues following plume passage.
2. Exelon may be requested to provide resources to support the determination of post plume protective actions.
3. RESPONSIBILITIES 3.1 The Shift Emergency Director (Shift Manager), when in Command and Control (C&C), has the non-delegable responsibility for classification of emergencies and final determination of PARs.

3.2 The Station Emergency Director, when in Command and Control, has the non-delegable responsibility for classification of emergencies and final determination of PARs.

3.3 The Corporate Emergency Director, when in Command and Control, has the non-delegable responsibility for final determination of PARs. Classification remains with the Station Emergency Director.

3A The TSC groups (e.g., Technical Support, Operations, Facility Support, RP/Chemistry) are responsible for monitoring and assessing conditions within their areas in support of classification.

3.5 The Shift Emergency Director (CR) I Technical Manager (TSC) or Technical Support Manager (EOF), in the facility with the Emergency Director having Command and Control, is responsible for evaluating the plant-based PARs from the PAR flowcharts.

3.6 The designated Shift Dose Assessor (CR) I Radiation Protection Manager (TSC) I Radiation Protection Manager (EOF), in the facility with the Emergency Director having Command and Control, is responsible for evaluating the dose-based PARs from the results of the dose assessment analyses and field team surveys/samples.

EP-AA-111 Revision 7 Page 5 of 19

4. MAIN BODY 4.1 Emercency Classification NOTE: Once indication of an abnormal condition is available, classification declaration must be made within 15 minutes. This time is available to ensure that the classification and subsequent actions associated with the classification, if warranted, are appropriate. Itdoes not allow a delay of 15 minutes if the classification is recognized to be necessary. It is meant to provide sufficient time to accurately assess the emergency conditions and then evaluate the need for an emergency classification based on the assessment performed.

The decision to terminate the event or enter Recovery is NOT time dependent.

NOTE: If the event escalates to a higher classification before the notification can be made for an initial (or previous) declaration, the time requirements in the previous note restart and notification for the first classification is not made.

4.1.1 When an abnormal condition is being evaluated, REFER to the appropriate Station EAL Matrix and PERFORM the following:

1. IDENTIFY the Unit Mode for the state of the plant prior to the abnormal condition (Operating Modes are identified in respective EALs).
2. REVIEW the Initiating Conditions (ICs) applicable to the operating mode as follows.

A. Starting with the highest (General Emergency) classification level on the left side of the matrix and continue to the lowest (Unusual Event) classification level on the right side of the matrix.

B. If more than one IC applies to the event, then SELECT the highest IC (from all of the ICs that were determined to have been met).

NOTE: Classification is made on a Unit basis. For events affecting both Units, the highest classification on either Unit is used for notification.

3. REVIEW the EAL Threshold Values for the IC.

A. If the EAL Threshold Values have been met or exceeded, then:

- NOTE the EAL number associated with the IC.

- DECLARE the event (by announcing it within the facility).

- RETURN to the appropriate EP-AA-1 12 ERO position checklist and immediately begin notifications.

B. If the EAL Threshold Values have not been met or exceeded, then return to the appropriate EP-AA-1 12 ERO position checklist.

EP-AA 11 Revision 7 Page 6 of 19 4.2 Transition to Recovery/Termination 4.2.1 Complete the Termination/Recovery Checklist (Attachment 1).

1. If conditions will allow for the termination of the event or entry into Recovery, exit this procedure and enter EP-AA-1 15, Termination and Recovery."
2. If conditions do not support termination of the event or entry into Recovery, continue following the guidance provided in Section 4.1.1.

4.3 Plant-Based Protective Action Recommendations (PARs) 4.3.1 Upon declaration of a General Emergency, EVALUATE the results of the plant-based PARs using the following attachments:

- Attachment 2, Braidwood Plant-Based PAR Flowchart

- Attachment 3, Byron Station Plant-Based PAR Flowchart

- Attachment 4, Dresden Station Plant-Based PAR Flowchart

- Attachment 5, LaSalle Station Plant-Based PAR Flowchart

- Attachment 6, Quad Cities Station Plant-Based PAR Flowchart

- Attachment 7, Clinton Station Plant-Based PAR Flowchart

- Attachment 8, Limerick/Peach Bottom Plant-Based PAR Flowchart

- Attachment 9, Three Mile Island Plant-Based PAR Flowchart 4.3.2 Continue to EVALUATE plant based PARs as Fission Product Barrier status or wind direction changes.

4A Dose Assessment Based Protective Action Recommendations (PARs)

NOTE: Dose projections are NOT required to support the decision process in the plant-based PAR Flowcharts. However, it is expected that a dose projection be performed as soon as possible at a General Emergency with a release in progress per EP-MW(MA)-1 10-200.

  • For the Control Room, as soon as possible is determined by the Shift Emergency Director based on whether personnel are involved in immediate actions to recover the plant or fight the casualty.
  • For the TSC and EOF, as soon as possible means within 15 minutes of a release occurring or the escalation of an event with a release in progress.
  • If radiation monitor readings provide sufficient data for assessment, it is NOT appropriate to wait for field monitoring data to become available to confirm or expand a PAR within the 10-mile EPZ.

EP-AA-1 11 Revision 7 Page 7 of 19 4.4.1 From the Control Room:

1. If a release is in progress at a General Emergency classification, and time permits, then PERFORM an offsite dose assessment using the "Quick Assessment" dose model option.

4.4.2 From the TSC or EOF:

1. ENTER current meteorological and core damage data (if available) for dose projections.
2. PERFORM dose projections, using the "Full Assessment" dose model option, to determine whether the plant-based protective actions are adequate using the following methods as applicable:

NOTE: Many assumptions exist in dose assessment calculations, involving both source term and meteorological factors, which make computer predictions over long distances highly questionable.

A. Monitored Release:

- If dose assessment results indicate the need to recommend actions beyond 10 miles, then DISPATCH Field Monitoring Teams to downwind areas to verify the calculated exposure rates prior to issuing PARs outside the 10 mile EPZ.

- If a release is in progress, then ASSESS the calculated impact to determine whether the plant based PARs are adequate.

NOTE: Re-establish threshold values whenever meteorological conditions or core damage assessment values change.

- If a release is not in progress, then PROJECT effluent monitor threshold values that would require 2, 5, and 10 mile evacuations.

B. Containment Leakage/Failure:

- If a release is in progress, then ASSESS the calculated impact to determine whether the plant based PARs are adequate.

- Ifa release is not in progress, then ASSESS various scenarios (design leakage, failure to isolate, catastrophic failure) to project the dose consequences and determine whether the plant based PARs are adequate.

EP-AA-1 11 Revision 7 Page 8 of 19 C. Field Survey Analysis: Actual field readings from Field Teams should be compared to dose assessment results and used as a dose projection method to validate calculated PARs and to determine whether the plant or dose based protective actions are adequate.

D. Release Point Analysis: Actual sample data from monitored or unmonitored release points should be utilized in conjunction with other dose assessment and projection methods to validate calculated PARs and to determine whether the plant based protective actions are adequate.

4.5 Overall Protective Action Recommendations (PARs) 4.5.1 EVALUATE the results of the plant based PARs and determine which Areas/Subareas/Sectors are to be evacuated.

4.5.2 IF a release is in progress, THEN:

1. EVALUATE the results of the dose based PARs and determine if EPA Protective Action Guides (EPA PAGs) of 1 Rem TEDE or 5 Rem CDE Thyroid are exceeded and if additional Areas/Subareas/Sectors require evacuation.
2. ADD any Subarea/Sector/Area requiring evacuation as determined by dose assessment to the plant based PARs.

4.5.3 If no release is in progress, then:

1. PERFORM dose projections on possible conditions as time permits to determine if PAGs could be exceeded.
2. CONSIDER adding any Subareas/Sectors/Areas requiring evacuation as determined by dose projection to the plant based PARs.

4.5.4 COMBINE the results of the plant based and appropriate dose based PARs onto the State/Local notification form.

Limerick / Peach Bottom / TMI

1. RECOMMEND potassium iodide (KI) for the general public in affected areas where EVACUATION is recommended following the classification o a General Emergency.

4.5.5 RETAIN any copies of plant and/or dose based PAR reports (Attachments 1-9 or dose code printouts).

5. DOCUMENTATION None

EP-AA-111 Revision 7 Page 9of19

6. REFERENCES None
7. ATTACHMENTS Attachment 1,Termination/Recovery Checklist Attachment 2, Braidwood Plant-Based PAR Flowchart Attachment 3, Byron Plant-Based PAR Flowchart Attachment 4, Dresden Plant-Based PAR Flowchart Attachment 5,LaSalle Plant-Based PAR Flowchart Attachment 6, Quad Cities Plant-Based PAR Flowchart Attachment 7, Clinton Plant-Based PAR Flowchart Attachment 8, Limerick/Peach Bottom Plant-Based PAR Flowchart Attachment 9, Three Mile Island Plant-Based PAR Flowchart

EP-AA- 11 Revision 7 Page 10 of 19 ATTACHMENT I TERMINATION I RECOVERY CHECKLIST Page of 2 Station: Event:

Ie al NI I

1. Conditions no longer meet an Emergency Action Level D Do LI' and it appears unlikely that conditions will deteriorate.

List any EAL(s) which is/are still exceeded and a justification as to why a state of emergency is no longer applicable:

IGO TO the comments/approval section for Unusual Events.

CONTINUE for Alert, Site Area and General Emergency classifications.

2. All required state, local and NRC notifications for entry into LIU D the Recovery Phase have been prepared per EP-AA-1 14 and EP-MW(MA1 14-1 00.
3. Plant releases of radioactive materials to the environment DUUU are under control (within Tech Specs) or have ceased and the potential for a uncontrolled radioactive release is acceptably low.
4. The radioactive plume has dissipated and plume tracking UU U3D is no longer required. The only environmental assessment activities in progress are those necessary to determine the extent of deposition resulting from passage of the plume.
5. In-plant radiation levels are stable or decreasing, and 0 UU3 acceptable given the plant conditions.
6. The reactor is in a stable shutdown condition and long- UU OU term core cooling is available.

EP-AA-111 Revision 7 Page 11 of 19 TTACHMENT 1 TERMINATION I RECOVERY CHECKLIST Page 2 of 2 0ne False tg1 I

7. The integrity of the Reactor Containment Building is within El 0 0No Technical Specification limits.
8. The operability and integrity of radioactive waste systems, decontamination facilities, power supplies, electrical equipment and plant instrumentation including radiation monitoring equipment is acceptable.
9. Any fire, flood, earthquake or similar emergency condition or threat to security no longer exists.
10. Any contaminated injured person has been treated and/or transported to a medical care facility.
11. Offsite conditions do not unreasonably limit access of 1000 outside support to the station and qualified personnel and support services are available.
12. Discussions have been held with Federal, State and 03 00 County agencies and agreement has been reached and coordination established to terminate the emergency.

It is not necessary that all responses listed above be TRUE'; however, all items must be considered prior to event termination or entry into Recovery. For example, it is possible that some conditions remain which exceed an Emergency Action Level following a severe accident but entry into Recovery is appropriate. Additionally, other significant items not included on this list may warrant consideration such as severe weather.

Comments:

Approved: Date/Time: ____

Emergency Director (in C&C of event classification)

EP-AA-1 11 Revision 7 Page 12 of 19 ATTACHMENT 2 BRAIDWOOD PLANT-BASED PAR FLOWCHART Page Iof I Classification is a INo General Emergency I Yes Loss of 'Fuel Clad' Fission Product Barrier Yes Loss of 'RCS' Fission Product Barrier Yes 2 Mile Radius, 5 Miles Downwind WD (from) Subareas Loss of 'Containment' 0240 to 0430 1,10,14 Fission Product Barrier 044° to 0590 1,10,11,14 0600 to 1120 1.10,11 Yes 113°to 1360 1, 7,10,11 E. .He d.i .= 0 .. Mi^

1370 to 1530 1.7,10

&Miles 10 Downwind~~~~~~ ,1,-~,,-~ 1540 to 1790 1, 2.7, 7.10 1800 to 2040 1,2,10 2050 to 2360 1, 2, 3,10 5 Mile Radius, 10 Miles Downwind 2370 to 2890 1, 3,10 WD (from) - Subareas 2900 to 3290 1, 3, 6, 10 0140 to 02701, 2, 3,6, 7, 10, 11, 14,15 3300 to 3540 1, 6.10 0280 to 0560 1, 2, 3, 6, 7, 10, 11, 14,15,16 3550 to 0230 1,6,-10,14 0570 to 0730 1. 2.3, 6.7. 10, 11, 12, 14, 15. 16 0740 to 0830 1,2,3,6,7,10,11,12,14,16 0840 to 0930 1, 2, 3, 6, 7,10,11,12,14 0940 to 1040 1.2, 3, 6 7. 810.11,12, 14 105 0 to 1210 1, 2, 3, 4, 6, 7, 8, 10,11, 12, 14 1220 to 1490 1,2,3,4,6,7,8,10, 11, 14 1500 to 1630 1,2,3,4,6,7,10,11, 14 1640 to 181' 1, 2, 3,4, 5, 6, 7, 10, 11, 14 1820 to 2100 1,2,3,5,6,7,10,11,14 2110 to2420 1,2,3,5,6,7,10,11,13,14 2430 to 274 1, 2, 3, 6,7 10, 11, 13 14 2750 to 307 1, 2.3, 6.7, 9.10,11, 13, 14 3080 to 0130 1,2,3,6,7,9,10,11,14 Date: NOTE: Ensure dose based PARs are evaluated when a Time: release is in progress.

EP-AA-1 1 Revision 7 Page 13 of 19 ATTACHMENT 3 BYRON PLANT-BASED PAR FLOWCHART Page 1 of I Classification is a I No SU AN WM mloPARsi~">I General Emergency I l ;I . quire I Yes Loss of 'Fuel Clad' Fiss.ion Product Barrier Yes .

Loss of 'RCS' INo _l. Evacuate ~ 2 Mile

~~~~~ ~ Rdis Fission Product Barrier I . & iespownwn s Yes 2 Mile Radius, 5 Miles Downwind I Loss of 'Containment' Fission Product Barrier WD (from) l-0690 to 1280 19, 23 Subareas 0080 to 0680 19, 20, 23 1290 to 2270 17, 19,23 2280 to 2880 19, 23 2890 to 3450 19, 23, 25 3460 to 0070 19, 20, 23, 25 5 Mile Radius, 10 Miles Downwind WD (from) Subareas 0220 to 0510 14, 17, 19, 20, 23, 25 0520 to 0820 12, 14, 17, 19, 20, 23, 25 0830 to 1000 12, 17, 19, 20, 23, 25 1010 to 1250 10, 12, 17, 19, 20. 23,25 1260 to 1390 10, 17, 19, 20, 23, 25 1400 to 1710 10,17, 19, 20, 23, 25, 40 1720 to 2090 17, 19, 20, 23, 25,40 2100 to 2200 17, 19, 20, 23, 25, 39, 40 2210 to 2520 17, 19, 20, 23, 25, 27, 39 2530 to 2640 17, 19, 20, 23, 25, 27 2650 to 2850 17, 19, 20, 23, 25, 27, 28 2860 to 3260 17. 19. 20. 23. 25. 28 3270 to 0210 17,19,20, 23, 25 Date: NOTE: Ensure dose based PARs are evaluated when a Time: release is in progress.

EP-AA-1 11 Revision 7 Page 14 of 19 ATTACHMENT 4 DRESDEN PLANT-BASED PAR FLOWCHART Page 1 of I Classification is a INo General Emergency I Yes Loss of 'Fuel Clad' Fission Product Barrier Yes Loss of RCS' Fission Product Barrier

- Yes 2 Mile Radius, 5 Miles Downwind Loss of 'Containment' WD (from) Subareas Fission Product Barrier 0020 to 0460 1, 3.4, 7 0470 to 1820 1, 3.4 1830 to 2920 1, 3,4, 12 2930 to 2990 1,3,4 3000 to 3380 1, 3.4. 9 3390 to 0010 1,3,4,7,9 5 Mile Radius, 10 Miles Downwind WD (from) Subareas 0020 to 0260 1, 3, 4, 7, 9, 10, 11, 12 0270 to 0440 1, 3, 4, 7, 8 9, 11, 12 0450 to 0680 1. 3,4, 7, 8, 9, 12 0690 to 0830 1,2,3,4,5,7,8,9,12 0840 to 0920 1,2,3,4,5,7,9,12 0930 to 1120 1,2,3,4,7,9,12 1130 to 1430 1,2,3,4,6,7,9,12 1440 to 1770 1, 3,4, 6, 7, 9, 12 1780 to 1990 1,3,4,6,7,9,12,13 2000 to 2250 1, 3,4 7,9. 12. 13 2260 to 2490 1, 3,4, 7, 9,12,13,14 2500 to 2660 1, 3,4. 7, 9,12,14 2670 to 2860 1, 3. 4. 7. 9. 12, 14, 15 2870 to 3210 1, 3. 4, 7 9, 12,15 3220 to 3440 1, 3, 4, 7, 9, 12, 15, 16 3450 to 3530 1, 3. 4. 7. 9. 10, 12, 15, 16 3540 to 0010 1, 3,4,7,9,10,12,16 NOTE: Ensure dose based PARs Date: are evaluated when a release is in progress.

Time:

EP-AA-1 11 Revision 7 Page 15 of 19 ATTACHMENT 5 LASALLE PLANT-BASED PAR FLOWCHART Page 1 of I Classification is a INo 7-s DL , *~M.

General Emergency I ' l equlrepallv I s Yes

[ Loss of 'Fuel Clad' Fission Product Barrier s Yes r Loss of RCS' Fission Product Barrier Yes Loss of 'Containment' I

No Nol

. i Iz

, w^E'

/ ysited Eac'uatHe'2Ml

&Siestwnwin 2 Mile Radius, 5 Miles Downwind WD (from) a i ..ts_,S, ark i-9>at,1a eI 6ffi .5S'

&i :.i LoiLi 5hi - by Subareas

@E, Fission Product Barrier 0190 to 0350 1. 2. 3 0360 to 1680 1, 3 1690 to 3010.1 Yes 3020 to 0180 1, 2 I Evacuate 5 Mile Radiu 5 Mile Radius, 10 Miles Downwind WD (from) Subareas 002° to 0260 1, 2, 3,4, 5 027' to 0560 1, 2, 3,4 0570 to 0760 1 2, 3, 4, 7 0770 to 0960 1, 2, 3, 7 0970 to 1160 1, 2, 3, 7,8 1170 to 1210 1,2,3,8 1220 to 1490 1, 2, 3, 8,11 1500 to 1780 1, 2, 3, 10,11 1790 to 1970 1 2 3, 10 1980 to 2180 1 2 3 6,10 2190 to 2330 1, 2, 3, 6, 9, 10 2340 to 2420 1 2, 3, 6, 9,13 2430 to 2650 1 2 3, 913 2660 to 2810 1, 2, 3,13 2820 to 3160 1, 2, 3, 13, 17 3170 to 3420 1 23.517 3430 to 0010 1, 2, 3, 5 NOTE: Ensure dose based PARs Date: are evaluated when a Time: release is in progress.

- EP-AA-1 11 Revision 7 Page 16 of 19 ATTACHMENT 6 QUAD CITIES PLANT-BASED PAR FLOWCHART Page 1 of I

[ Classification is a General Emergency 4 Yes No: w' WX eqD~~~~~~% t -R Loss of 'Fuel Clad' No Vt Require -=

Fission Product Barrier 4 Yes -

Loss of 'RCS' No NEW thy-i 1 I -U Fission Product Barrier & Miles LJownwn Yes 2 Mile Radius, 5 Miles Downwind Loss of 'Containment' No WD (from) Illinois Iowa Fission Product Barrier 0090 to 0240 1,3 1,2,6 0250 to 0290 1,3 1,2,4.6 0300 to 0810 1 1,2,4.6 l Yes 0820 to 0900 1 1,2,3,4,6

- - - , - - - ->iyY 7777~wft4, -.

z-< a.

0910 to 1160 1 1,2,3.4 Evcae5MleRiu 1170 to 1650 1 1,2,3 1660 to 1860 1 1,2,3,-5 I_- --- 5 Mile Radius, 10 Miles Downwind 1870 to 2150 1 1,2,5 WD (from) Illinois Iowa 2160 to 2400 1,2 1,2,5 0020 to 0250 1,2,3,6 1,2,3,4,5,6,12 2410 to 2890 1,2 1,2 0260 to 031° 1,2,3 1,2,3,4,5,6,12 2900 to 3180 1,2.3- 1.2 0320 to 0490 1.2.3 1,2,3 4,5.6.10.12 3190 to 0080 1,3 1,2 0500 10 0580 1,2,3 1,2,3,4,5, 6, 8,10,12 0590 to 0750 1.2.3 1, 2,3.4,5, 6, 8,10 0760 to 0870 1.2. 3 1,2,3 45. 68 0880 to 1060 1,2,3 1,2, 3,4, 5,6,7,8 1070 to 1160 1.2,3 1,2.3,4,5,6,7 1170 to 1460 1,2,3 1,2,3,4,5,6,7,9 NOTE: Ensure dose based 1470 to 1690 1,2,3 1, 2, 3,4, 5, 6,9 PARs are evaluated 1700 to 1860 1,2,3 1,2,3,4,5,6,9,11 when a release is in 1870 to 2150 1,2,3 1,2,3,4,5,6,11 progress.

2160 2300 to to 2290 1,2,3,4 2390 1,2,3.4 1,2,3.4,5,6,11 1,2.3.4.5.6 I'

2400 to 2670 1,2,3,4,5 1,2,3,4,5,6 2680 to 2960 1,2,3,5 1,2,3,4,5,6 2970 to 3180 1.2.3.5,6 1.2,3.4,5,6 Date:

3190 to 0010 1,2,3,6 1,2, 3,4, 5,6 Time:_

EP-AA-111 Revision 7 Page 17 of 19 ATTACHMENT 7 CLINTON PLANT-BASED PAR FLOWCHART Page 1 of I Classification is a No General Emergency I Yes Loss of 'Fuel Clad' Fission Product Barrier

,_I ~ ~ ~ U~n IYes Loss of 'RCS' INo 1*'--. -

2 v VdI.UW,,aS ij;:;

IJUa Ij I

Fission Product Barrier I

- Yes Loss of 'Containment' No Fission Product Barrier J Yes I Evacuate SMile Radius

& 10 MikSDOW!IWIflcI I 5 Mile Radius, 10 Miles Downwind WD (from) Subareas 0210 to 0480 1,5,6 0490 to 0660 1, 6 0670 to 0900 1, 6, 7 0910 to 0940 1, 7 0950 to 1320 1, 7, 8 1330 to 1570 1, 2. 8 1580 to 196 1,2 1970 to 2280 1, 2, 3 2290 to 2510 1, 3 2520 to 2810 1, 3, 4 2820 to 3080 I, 4 3090 to 3380 1.4.5 339° to 0200 1, 5 NOTE: Ensure dose based PARs Date:

are evaluated when a Time: release is in progress.

EP-AA-111 Revision 7 Page 18 of 19 ATTACHMENT 8 LIMERICK/PEACH BOTTOM PLANT-BASED PAR FLOWCHART Page 1 of I I

ii;- -; , .: -

General Einergency Declared? l'.'<A I V:h , 12A la , -:.' IV

- _ i YES r

LOSS of 'FUEL CLAD' Fission Product Barrier?

YES LOSS of 'REACTOR COOLANT SYSTEM' Fission Product Barrier?

I

[ LOSS of 'PRIMARY CONTAINMENT' Fission Product Barrier?

qrYES NOTE: Ensure dose-based PARs are evaluated when a release is in progress. I.

(L SS AL B rres)

EVACUATE ile RadiusAND` .i` .^,'

1,0 Miles Downwinl; AND Recommend' KI for genera ublic in evacuated areas .

WIND DIRECTION DOWNWmN WIND DIRECTION OWNWIN (FROM) _ F___ S_*

_ (FROM) ___ E___ __ _

355 to 005 SSE/S/SSW 175 to 185 NNW/N/NNE 006 to 017 SSE / S SSW ISW 186 to 197 NNW/N/NNE/NE 018 to 027 S SSW /SW 198 to 207 N/NNE/NE 028 to 039 SfSSW/SW/WSW 208 to 219 N/NNE/NE/ENE 040 to 050 SSW /SW WSW 220 to 230 NNE/NE/ENE 051 to 062 SSW /SW I WSW/ W 231 to 242 NNE/NE/ENE/E 063 to 072 SW /WSW W 243 to 252 NE/ENE/E 073 to 084 SW/WSW/W/WNW 253 to 264 NE/ENE/E/ESE 085 to 095 WSWIWIWNW 265 to 275 ENE/ E /ESE 096 to 107 WSW W / VNW NW 276 to 287 ENEIE/ESE/SE 108to 117 W/WNW/NW 288to297 EIESEISE 118 to 129 W/WNW/NWINNW 298 to 309 EIESE/SEISSE 130to 140 WNW/NW/NNW 310to320 ESE/SEISSE 141 to 12 WNW/NWINNWWIN 321 to 332 ESE I SE / SSE I S 153 to 162 NW/NNW/N 333 to 342 SE SSE I S 163 to 174 NW/NNW/NINNE 343 to 354 SE I SSE / S I SSW

  • BOLD refers to affected Sector(s). These sectors are based on dose model stability class "D", and in some cases, an extra sector was included for conservatism.

EP-AA-1 1 Revision 7 Page 19 of 19 ATTACHMENT 9 THREE MILE ISLAND PLANT-BASED PAR FLOWCHART Page 1 of I NO General Emergency Declared? bII . WI.

YES NO LOSS of 'FUEL CLAD' Fission Product Barrier?

YES VACUATE 5Mile adis LOSS of 'REACTOR COOLANT SYSTEM' Fission Product _ --- PI ReOmend DIfr'gnea Barrier? publc inevacatedareas,

____ YES NO LOSS of 'PRIMARY CONTAINMENT' Fission Product Barrier?

YES (LSSof ALL 3Brres EVACUATE 10-Mile Radius NOTE: Ensure dose-based PARs are evaluated when a Reomen K,4:;-Ii for/general1 E,-.tD E .. release is in progress.

BalticAI  : - ~~~~~~~~~~~~~~~~~~~~~~~~~I

ATTACHMENT B EP-AA-115, TERMINATION AND RECOVERY

EP-AA-115

- Exeln. Revision 2 Page! of 21 I NucleaT Level 2- Reference Use TERMINATION AND RECOVERY I

1. PURPOSE 1.1 This procedure provides guidance to the Station and Corporate Emergency Directors to accomplish transition to the Recovery Phase of an event and performance of activities associated with returning the station to a Forced Outage Management or normal organization.

Transitioning out of a Declared Event REFER to section 4.1 Termination Directly from a Declared Event REFER to section 4.2 Preparations to Enter Recovery REFER to section 4.3 Entering Recovery from a Declared Event REFER to section 4.4 Recovery Phase Actions REFER to section 4.5 Termination from Recovery REFER to section 4.6

2. TERMS AND DEFINITIONS 2.1 ANI- American Nuclear Insurers 2.2 INPO - Institute of Nuclear Power Operations 2.3 NEI- Nuclear Energy Institute 2.4 Recovery Phase - That period when major repairs are being performed to return the plant to an acceptable condition and the possibility of the emergency condition degrading no longer exists.

2.5 Detailed Incident Report - A written report that summarizes the facts and assigns corrective actions. The report includes the facts of the emergency, describes the root cause(s) of any emergency response problems and recommends corrective actions.

2.6 Event Summary Report - A written report summarizing the incident prepared for delivery to offsite authorities. This report is required within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of terminating an Unusual Event and within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of exiting any higher event.

I

EP-AA-115 Revision 2 Page 2 of 21 2.7 Termination - The point at which the Emergency Plan is deactivated and station operations are controlled under the normal organization, processes and procedures. Unusual Event classifications are directly terminated. Alert classification can be directly terminated or transitioned to Recovery. Site Area and General Emergency classifications must transition to Recovery prior to termination. Termination of the emergency is formally performed per EP-AA-111 with Notifications performed per EP-AA-1 14.

3. RESPONSIBILITIES 3.1 The Corporate Emergency Director is responsible for assignment of personnel for the Recovery Organization.

A typical Corporate Recovery Organization includes:

3.1.1 Recovery Director- Reports to the Chief Nuclear Officer and responsible for recovery planning and overall Exelon activities in coordination with the affected State(s).

3.1.2 Recovery Offsite Manager - Reports to the Recovery Director and is responsible for operation of the offsite facilities, communications, interface with purchasing, legal and insurance representatives.

3.1.3 Recovery Technical Support Manager- Reports to the Recovery Offsite Manager and is responsible for recovery planning and providing corporate technical and engineering support to the station.

3.1.4 Recovery Offsite RP Manager - Reports to the Recovery Offsite Manager and is responsible for environmental monitoring and providing corporate radiological support to the station.

3.1.5 Company Spokesperson - Reports to the Recovery Director and is responsible for media and public information and interfaces.

3.2 The Station Emergency Director is responsible for assignment of personnel for the Recovery Organization.

A typical Station Recovery Organization includes:

3.2.1 Recovery Plant Manager - Reports to the Recovery Director and is responsible for station recovery planning and overall station activities and communications.

3.2.2 Recovery Operations Manager - Reports to the Recovery Plant Manager and is responsible for recovery planning, plant operations and system manipulations through the Control Room.

EP-AA-1 15 Revision 2 Page 3 of 21 3.2.3 Recovery Engineering Manager- Reports to the Recovery Plant Manager and is responsible for recovery planning and technical and engineering support.

3.2.4 Recovery Maintenance Manager- Reports to the Recovery Plant Manager and is responsible for plant maintenance and repair activities.

3.2.5 Recovery Onsite RP Manager - Reports to the Recovery Plant Manager and is responsible for all radiological aspects supporting maintenance, operations and Rad Waste processing.

4. MAIN BODY 4.1 Transitioninq out of a Declared Event NOTE: Termination or transition to the Recovery Phase cannot be accomplished until the criteria of EP-AA-1 11, Attachment 1, Termination/Recovery Checklist have been evaluated. It is the responsibility of the Station Emergency Director, in consultation with the Corporate Emergency Director, to terminate the event or enter into Recovery.

4.1.1 REVIEW the criteria of EP-AA-1 11, Attachment 1,Termination/Recovery Checklist.

4.1.2 QUARANTINE or restrict access to any equipment, facilities or systems that may provide insight into the cause(s) of the event (Refer to OP-AA-1 06-101-1005rO Quarantine of Areas, Equipment, and Records as needed.)

4.1.3 ENSURE any reportable event(s) is/are assigned to be reported per the Reportability Manual.

4.1.4 ENSURE that an investigation is initiated in accordance with LS-AA-125, "Corrective Action Program (CAP) Procedure."

4.1.5 ASSIGN the Station EP Manager or designee to begin event documentation in accordance with EP-AA-1 20, Attachment 5, "Review of Actual Emergency Events."

4.1.6 TERMINATE the event or TRANSITION into the Recovery Phase based on the following:

1. PROCEED to Section 4.2 if terminating following an

- Unusual Event or

EP-AA-115 Revision 2 Page 4 of 21

- Alert with no need for recovery phase actions as determined through review of completed EP-AA-1 11, Attachment 1, Termination/Recovery Checklist.

2. PROCEED to Sections 4.3 through 4.5 if transitioning to Recovery following an Alert (requiring recovery phase actions), Site Area, or General Emergency.

4.2 Termination Directly from a Declared Event 4.2.1 DECLARE and log the official time the event is terminated.

4.2.2 DIRECT the announcement of the following message (or similar message) to station personnel over the public address system:

T Attention all personnel, attention all personnel. The emergency has been terminated. I repeat, the emergency has been terminated."

4.2.3 NOTIFY ERO personnel and the NDO of the event termination.

4.2.4 INITIATE a State/Local notification within one hour of event termination per EP-MA(MW)-1 14-1 00.

4.2.5 INITIATE an ENS notification within one hour of event termination per EP-AA-114.

4.2.6 ISSUE an Event Summary Report to offsite authority, using Attachment 8 as a guide, as follows:

- For an Unusual Event, the Event Summary Report must be transmitted within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of termination.

- For an Alert, the Event Summary Report must be transmitted within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of termination.

4.2.7 DEACTIVATE the emergency facilities and restore them to a state of readiness.

4.2.8 ENSURE that all emergency records (position logs and forms), are collected and submitted for records retention.

4.3 Preparations to Enter Recovery 4.3.1 ESTABLISH Emergency Response Facilities staffing requirements until a Recovery Plan Outline, describing the necessary Recovery Organization, has been approved.

1. Maintain at least the minimum ERO staffing for the TSC, EOF and JPIC while preparations for enter into Recovery are completed.

EP-AA-115 Revision 2 Page of 21

2. Consider establishing a forced outage organization in order to deactivate the OSC. Ensure minimum staffing requirements are met at all times with onsite personnel until Recovery has been entered.

NOTES: Detailed plans and procedures are not required to be developed prior to entry into Recovery. However, a Recovery Plan Outline must be approved and the organizational staffing needs identified prior to exiting the emergency event.

For events of the Alert classification, Emergency Response Organization (ERO) personnel may be adequate to perform the necessary recovery actions.

For event classifications of Site Area or General Emergency, the typical Recovery Organization (as illustrated in Attachment 2) should be established. Additional positions may be assigned to perform specific recovery activities.

4.3.2 DIRECT the Station Emergency Director to develop a Station Issues/Strategies Package and determine staffing needs using Attachments 4 and 7 for guidance.

4.3.3 DIRECT the Corporate Spokesperson to develop a Public Information Issues/Strategies Package and determine staffing needs using Attachments 6 and 7 for guidance.

4.3.4 DIRECT the EOF Director to develop a Corporate Issues/Strategies Package and determine staffing needs using Attachments 5 and 7 for guidance.

4.3.5 CONVENE a joint conference with the EOF Director, Station Emergency Director, and the Corporate Spokesperson to:

- REVIEW the Recovery Issues/Strategies Packages.

- REVIEW the identified recovery staffing requirements.

- DEVELOP and APPROVE the Recovery Plan Outline using Attachment 3 as a guide.

4.3.6 CONDUCT a formal discussion with regulatory and State authorities to ensure coordination and agreement is met for entry into Recovery.

4.3.7 NOTIFY recovery personnel of assignments and stage or call-in for briefing and tumover.

4.3.8 CONTACT the Exelon Chief Nuclear Officer (CNO) and provide a briefing of the plans to exit the emergency and enter Recovery.

EP-AA-1 15 Revision 2 Page 6 of 21 4.4 Entering Recovery from a Declared Event 4.4.1 DECLARE and log the official time the emergency is exited and Recovery entered.

4.4.2 DIRECT the announcement of the following message (or similar message) to station personnel over the public address system:

Attention all personnel, attention all personnel. The emergency event has been exited and we have entered Recovery. I repeat, the emergency event has been exited and we have entered Recovery."

4.4.3 NOTIFY ERO personnel and the Nuclear Duty Officer (NDO) of entry into Recovery.

4.4.4 INITIATE a State/Local notification within one hour of entry into Recovery per EP-MA(MW)-1 14-1 00.

4.4.5 INITIATE an ENS notification within one hour of entry into Recovery per EP-AA-1 14.

4.4.6 ISSUE an Event Summary Report to offsite authority within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of exiting the emergency event, using Attachment 8 as a guide.

4.4.7 CONDUCT briefing and turnover to recovery personnel.

4.4.8 DEACTIVATE the emergency facilities and restore them to a state of

- readiness.

4.4.9 ENSURE that all emergency records (position logs and forms), are collected and submitted for records retention.

4.5 Recovery Phase Actions NOTE: Entry into the Recovery Phase can be accomplished when the Recovery Plan outline has been approved and the Recovery Organization has been identified, notified and is prepared to take turnover from the ERO.

4.5.1 General Guidance

1. Terminate the use of emergency exposure controls.

A. Revert to non-emergency (10 CFR 20) limits and controls for repair activities conducted during Recovery.

B. Refer to existing plant exposure control procedures for guidance.

EP-AA-115 Revision 2 Page 7 of 21

2. Terminate the use of other Emergency Procedures (e.g., EP-AA-1 13, Protective Actions).

A. Use existing plant procedures or procedures developed for specific tasks are used for plant repair activities during Recovery.

B. Obtain PORC approval for any special station procedures developed for Recovery activities.

4.5.2 Recovery Director

1. MAINTAIN a log of specific recovery actions taken such as:

- Specific actions taken per this procedure.

- Communication with offsite authorities related to emergency and/or Recovery.

- Any meetings held to discuss conduct or close out of the recovery phase.

2. DIRECT and/or COORDINATE all actions of the Recovery Organization.

A. ENSURE that sufficient personnel, equipment or.other resources from Exelon and other organizations are available to support Recovery activities.

B. COORDINATE the integration of available Federal and State assistance into onsite Recovery activities.

C. COORDINATE the integration of available Exelon support with Federal, State, county, and local authorities as applicable, into required offsite Recovery activities.

3. Ensure communications are established and maintained with the following:

- Senior corporate officials.

- Legal, Financial, Insurance, and Supply Management departments.

- INPO, NEI, and ANI

4. APPROVE any special procedures developed for corporate and offsite recovery activities.
5. APPROVE any reports released to offsite authorities.

EP-AA-115 Revision 2 Page 8 of 21

6. REVIEW information released by the Corporate Spokesperson that pertains to the emergency or recovery from the accident.

4.5.3 Recovery Plant Manager

1. MAINTAIN a log of specific recovery actions taken such as:

- Specific actions taken per this procedure.

- Communication with offsite authorities related to emergency and/or Recovery.

- Any meetings held to discuss conduct or close out of the recovery phase.

2. DIRECT all station activities in support of the recovery effort.
3. COORDINATE the implementation of the Recovery Plan and procedures with the Recovery Director.
4. CONTINUE to identify and document issues relating to recovery operations.
5. DEVELOP an action plan that will transition the Recovery Organization into a normal Forced Outage Organization through OU-AA-102, Forced Outage Management" as appropriate.
6. DESIGNATE other Exelon Recovery positions as necessary, in support of station Recovery activities.
7. ENSURE that engineering activities to restore the plant are properly reviewed and approved.

4.5.4 Recovery Offsite Manaer

1. COORDINATE all corporate activities in support of the recovery effort.
2. COORDINATE the implementation of the Recovery Plan and procedures with the Recovery Director.
3. CONTINUE to identify and document issues relating to recovery operations.
4. COMMUNICATE with offsite agencies and coordinate Exelon assistance for offsite recovery activities, including providing liaisons, as needed.
5. DESIGNATE other Exelon Recovery positions as necessary, in support of corporate Recovery activities.

EP-AA-115 Revision 2 Page 9 of 21l

6. PROVIDE post-accident reports to offsite agencies as directed, including the development of offsite accident analysis and radiological release reports (or equivalent) as required.
7. COORDINATE Exelon and contractor environmental sampling activities with state and federal agencies. This should include calculations for total population exposure based on data from available sources and/or mathematical modeling.

4.5.5 Corporate Spokesperson

1. COORDINATE all public information activities in support of the recovery effort.
2. COORDINATE the implementation of the Recovery Plan and procedures with the Recovery Director.
3. CONTINUE to identify and document issues relating to recovery operations.
4. DESIGNATE other Exelon Recovery positions as necessary, in support of public information Recovery activities.
5. FUNCTION as the official spokesperson to the press for Exelon on all matters related to the accident or Recovery activities.
6. COORDINATE with non-Exelon public information groups (Federal, State, county, etc.).
7. COORDINATE continued media monitoring and rumor control activities.

4.6 Termination from Recovery 4.6.1 CONSIDER the following prior to terminating the recovery phase:

- Station and corporate organizations involved with the recovery have been appraised of the existing conditions and of the anticipated termination of recovery activities.

- The news media has received a final status report on the recovery operations.

- A review of actions taken during the emergency and recovery phases has been conducted and an investigation report has been prepared.

Necessary revisions to the Emergency Plan and procedures have been identified.

EP-AA-1 15 Revision 2 Page 10 of 21

- Concurrence has been obtained from the NRC and applicable State agencies.

4.6.2 NOTIFY the recovery organization and the NDO of the Recovery termination.

4.6.3 INITIATE a State/Local notification within one hour of Recovery termination per EP-MA(MW)-1 14-1 00.

4.6.4 INITIATE an ENS notification within one hour of Recovery termination per EP-AA-1 14.

4.6.5 DISBAND the Recovery Organization.

5. DOCUMENTATION None
6. REFERENCES None
7. ATTACHMENTS 7.1 Attachment 1: Recovery Process Illustration 7.2 Attachment 2: Typical Recovery Organization 7.3 Attachment 3: Recovery Plan Outline 7.4 Attachment 4: Station Recovery Issues/Strategies Guide 7.5 Attachment 5: Corporate Recovery Issues/Strategies Guide 7.6 Attachment 6: Public Information Recovery Issues/Strategies Guide 7.7 Attachment 7: Issue/Strategies Form 7.8 Attachment 8: Event Summary Report Format

EP-AA-115 Revision 2 Page 1 of 21 ATTACHMENT I RECOVERY PROCESS ILLUSTRATION Page 1 of I Emergency Event Is Declared

^

I t

  • Actions are taken to return the plant to a safe condition.

_ ~~~~~~~~~~~Transition Conditions are evaluated per EP-A-1 11 Attachment 1.

  • Investiqations and event reports/documentation are initiated.

UE Alert SAE GE I .  :: I Recovery Preparations

  • Selected facilities are kept at full or partial ERO staffing.
  • Recovery Issues/Strategies Package is prepared.
  • Organizational requirements are determined.
  • A Recovery Plan Outline is developed.
  • Personnel are placed on stand-by to assume the Identified recovery positions.

m i r i r- U- -

Emeraency Termination Exit Emergency Condition

  • The emergency event is declared over
  • The emergency event is declared over
  • Notifications are made
  • Notifications are made
  • An Event Summary Report issued
  • An Event Summary Report issued (wA 8 hrs)

(wA 24 hrs for UE, 8 hrs for Alert)

  • Emergency Facilities are deactivated
  • Emergency Facilities are deactivated
  • Records are collected
  • Records are collected Select Alerts and all SAEs and GEs Recovery Phase Entered
  • Recovery organization Is established.
  • Recovery activities are conducted.
0. U Recovery Termination
  • Notifications are made.
  • Recovery organization is disbanded.

The above markers represent points in time in the chronology of a classified emergency:

o The initiating state of emergency no longer exists.

0 Formal termination of the Emergency Phase occurs.

O Formal termination of the Recovery Phase occurs.

EP-AA-115 Revision 2 Page 12 of 21 ATTACHMENT 2 TYPICAL RECOVERY ORGANIZATION Page 1 of 1 l - Recovery Director I LRecovery Recovery Plant Manager OPs Manager Recovery Maint Manger Recovery Eng Manager Recovery Offsite Manager Company Spokesperson Recovery Tech Support Manager Recovery Offsite RP Manager Recovery Onsite RP Manager NOTES:

(1) The Recovery Director has overall control of the recovery organization. The position will normally be filled by the ROG, Senior Vice President or designee (Corporate Emergency Director during transition).

(2) The Recovery Plant Manager directs Recovery activities to restore the plant to pre-incident conditions. The position will normally be filled by the Plant Marger or designee (Station Emergency Director during transition).

(3) The Offsite Recovery Director Directs the interface with Federal, State and local agencies and coordinates corporate support for the station. The position will normally be filled by the Emergency Preparedness Manager Director or designee (EOF Director during transition).

(4) The Company Spokesperson directs the Public Information Program. The position will normally be filled by the Corporate Communications Manager or designee (Company Spokesperson during transition).

- EP-AA-1 15 Revision 2 Page 13of21 ATTACHMENT 3 RECOVERY PLAN OUTLINE Page 1 of I NOTE: The Corporate Emergency Director provides approval of the Recovery Plan Outline with the concurrence of the Station Emergency Director and the Corporate Spokesperson.

SECTION I. RECOVERY ORGANIZATION A. Organization structure B. Assignment of authorities/responsibilities SECTION II. ONSITE RECOVERY PROGRAM A. Major Goals B. Issues and Strategies SECTION II. OFFSITE RECOVERY PROGRAM A. Major Goals B. Issues and Strategies SECTION IV. PUBLIC INFORMATION RECOVERY PROGRAM A. Major Goals B. Issues and Strategies

EP-AA-115 Revision 2 Page 14 of 21 ATTACHMENT 4 STATION RECOVERY ISSUES I STRATEGIES GUIDE Page 1 of 3 NOTE: In addition to the ERO positions listed, members of the Security and the Outage Planning Group should attend the initial onsite recovery meeting as necessary.

1. CONVENE a meeting with at least the following positions:
  • Station Emergency Director
  • Radiation Protection Manager
  • Maintenance Manager
  • Technical Manager
  • Operations Manager NOTE: Attachment 7, Issue/Strategies Form should be used to document items identified during the meeting. Complete as much of the form as possible but only the 'Description of Issue' section needs to be completed.
2. REVIEW existing conditions, outline the onsite issues to be resolved, and develop an Issues/Strategies Package that will form the basis for the onsite portion of the plant's Recovery Plan. Issues that should be considered include:

A. Present Activities Being Performed by the ERO

  • Identify ongoing activities and determine the need to continue B. Equipment Status Verifications
  • Perform/Document secured lineups
  • Hang appropriate clearance order tags
  • Document temporary repairs/lineup
  • Obtain appropriate samples to verify core status

EP-AA-1 15 Revision 2 Page 15 of 21 ATTACHMENT 4 STATION RECOVERY ISSUES I STRATEGIES GUIDE Page 2 of 3 C. Stabilization of Plant Systems for Long Term Cooling

  • Identify present cooling lineup(s)
  • Document available back-up cooling lineup(s).
  • Confirm condition of cooling systems.
  • Develop a plan to transition to long term cooling if required D. System Repairs and Restorations
  • Prioritize out of service equipment for restoration
  • Plan restoration process by milestones
  • Determine testing to increase/ensure equipment reliability
  • Determine long term resolution of temporary repairs
  • Examine options for temporary systems
  • Bring in industry expertise as necessary
  • Ensure proper QA on any repairs made during the emergency E. Normal Radiological Controls
  • Perform comprehensive surveys of onsite areas
  • Establish additional survey and sampling frequency requirements
  • Determine if additional monitoring equipment is required
  • Develop a decontamination plan based on prioritized recovery of plant areas
  • Commence Bioassay program
  • Contract for large volume decontamination equipment/expertise F. Water Management
  • Identify sources, volumes and activity of water inventories
  • Prioritize clean-up
  • Verify/evaluate condition of existing clean-up systems
  • Establish controls to preclude inadvertent discharges

EP-AA-115 Revision 2 Page 16of21 ATTACHMENT 4 STATION RECOVERY ISSUES I STRATEGIES GUIDE Page 3 of 3

  • Evaluate need to contract portable filtering systems/expertise
  • Establish berms and restraints for control and mitigation of spills
  • Evaluate need for additional onsite waste storage capability
  • Evaluate need for additional burial space for waste G. Logistics of the Recovery Operation
  • Identify additional staffing needs.
  • Obtain necessary damage control equipment.
  • Consider use of outside specialist.
  • Set up training for off normal conditions (ALARA).
  • Consider restricting site access.
  • Order extra RP supplies to support recovery.
  • Evaluate the need for additional security.
  • Evaluate the need for remote technology for inspections and cleanup.
  • Evaluate the need for additional communications capabilities.

H. Documentation

  • Initiate actions to complete any required NRC reports per the Reportability Manual.
  • Develop onsite portions of the Detailed Incident Report
  • Develop onsite Recovery Plan (short/long term)
  • Write special procedures to perform tasks outside the scope of normal procedures.

EP-AA-1 15 Revision 2 Page 17of21 ATTACHMENT 5 CORPORATE RECOVERY ISSUES / STRATEGIES GUIDE Page 1 of 2 NOTE: In addition to the ERO positions listed, the VP-Licensing and Regulatory Affairs or a representative should attend this meeting.

1. CONVENE a meeting with the following:
  • Corporate Emergency Director
  • Radiation Protection Manager
  • Logistics Manager NOTE: Attachment 7, Issue/Strategies Form should be used to document items identified during the meeting. Complete as much of the form as possible but only the 'Description of Issue' section needs to be completed during initial meeting.
2. REVIEW existing conditions, outline the issues to be resolved, and develop an Issues/Strategies Package that will form the basis for the offsite portion of the Recovery Plan. Issues that should be considered include:

A. Present Activities Being Performed by EOF Staff

  • Identify ongoing activities and determine the need to continue B. Radiological
  • Evaluate the need for an environmental sampling program.
  • If required, estimate total population dose.
  • Evaluate reentry requirements.
  • Evaluate the need to bring in outside expertise for radiation monitoring.

C. Support to Offsite Authorities

  • Consider outstanding requests from offsite authorities
  • Keep offsite authorities apprised of onsite conditions and activities

EP-AA-115 Revision 2 Page 18 of 21 ATTACHMENT 5 CORPORATE RECOVERY ISSUES I STRATEGIES GUIDE Page 2 of 2 D. Corporate Interface

  • Keep corporate management apprised of conditions and activities.
  • Provide information to legal organization as requested.
  • Identify issues applicable to HR and Employee Assistance.

E. Logistics

  • Identify staffing needs to support offsite recovery activities.
  • Identify all non-Exelon personnel and activities currently in place.
  • Review equipment and material needs for EOF recovery activities.
  • Assist onsite and Public Information organizations in obtaining offsite support.
  • Evaluate the need for additional communications capabilities.

F. Documentation

  • Direct that an Event Summary Report be prepared
  • Develop offsite portions of the Detailed Incident Report 1-
  • Develop offsite Recovery Plan (short/long term)

EP-AA-115 Revision 2 Page 10 of 21 ATTACHMENT 6 PUBLIC INFORMATION RECOVERY ISSUES / STRATEGIES GUIDE Page 1 of I NOTE: In addition to the ERO positions listed, the Corporate Communications Manager or a representative should attend this meeting.

1. CONVENE a meeting with the following:
  • Corporate Spokesperson
  • JPIC Director
  • Public Information Director NOTE: Attachment 7, Issue/Strategies Form should be used to document items identified during the meeting. Complete as much of the form as possible but only the 'Description of Issue' section needs to be completed during initial meeting.
2. REVIEW existing conditions, outline the public information issues to be resolved, and develop an Issues/Strategies Package that will form the basis for the public information portion of the plant's Recovery Plan. Issues that should be considered in the formation of the package include:

A. Present Activities Being Performed by the Emergency Public Information Organization

  • Identify ongoing activities and determine the need to continue B. Offsite Interface
  • Identify activities needed to keep offsite authorities appraised of Exelon Public Information activities.

C. Documentation

  • Develop the Public Information portion of the Recovery Plan

EP-AA-1 15 Revision 2 Page 20 of 21 ATTACHMENT 7 ISSUES I STRATEGIES FORM Page 1 of I Area Owner Safet Priority Duration Related?

Estimated-hours Description of Issue Resources Needed Use this form to document malor items to be addressed during Recovery.

Area: Onsite I Offsite I Public Information Owner: Responsible individual or organization Safety Related: Yes or No Priority: I = Immediate (24 hr.) 2 = Short Term (1 Week) 3 = Intermediate (1 Month) 4 = Long Term (> 1 Month)

Duration: Estimated Calendar Duration Estimated-hours: Estimated Total Project Hours

EP-AA-115 Revision 2 Page 21 of 21 A1TACHMENT 8 EVENT

SUMMARY

REPORT FORMAT Page of I Date Time To: Offsite Authority (NRC, State, Local)

From: Name (Recovery Director or Emergency Director)

Subject:

Event Summary Report of Emergency Declared at the Exelon XX Station The Station has:

Transitioned into Recovery at -

1 Terminated from a _ classification at __ _

The following is a review of events and items pertaining to Indicate EAL and Type reported on _.

Provide a narrative of the event (describe the event giving the facts of the emergency including as a minimum:)

Initial Conditions

  • Provide unaffected unit status
  • Provide affected unit status
  • Provide any other pertinent equipment or condition status Initiating and Sequence of Events Time Description of event 0810 description of initiating events 0811 Performance of initial notifications to offsite authorities.

" 0812 Include information on personnel injuries and status. (Do not include name(s) of victims unless the family has been notified) 0813 Requests for offsite assistance, including time and type.

0814 The magnitude of any radiological release and Protective Action Recommendation information as applicable.

Conclusion

  • Provide an update of actions taken and results from investigations of the event.
  • Exelon contact for any additional information.