ML17317A471

Evaluation of Proposed Change Regarding Revision to the Emergency Plan for Technical Support Center Relocation & Revised Pages to Emergency Plan

ML17317A471
Person / Time
Site:	Cook
Issue date:	11/07/2017
From:	Indiana Michigan Power Co
To:	Office of Nuclear Reactor Regulation
Shared Package
ML17317A454	List: AEP-NRC-2017-49, License Amendment Request Regarding Revision to the Emergency Plan for Technical Support Center Relocation ML17317A471
References
AEP-NRC-2017-49
Download: ML17317A471 (34)

Text

Enclosure 2 to AEP-NRC-2017-49 Evaluation of Proposed Change Regarding Revision to the Emergency Plan for Technical Support Center Relocation 1.0

SUMMARY

DESCRIPTION Pursuant to 10 CFR 50.90, "Application for Amendment of License, Construction Permit, or Early Site Permit," Indiana Michigan Power Company (l&M), the licensee for Donald C. Cook Nuclear Plant (CNP) Unit 1 and Unit 2, requests U. S. Nuclear Regulatory Commission (NRC) review and approval of amendments to the CNP Unit 1 Operating License DPR-58 and Unit 2 Operating License DPR-74. The proposed change is a request to revise the CNP Emergency Plan (CEP) to re locate the Technical Support Center (TSC) within the CNP Protected Area (PA) . l&M has reviewed the proposed changes against the standards in 10 CFR 50.47(b) and requirements in 10 CFR 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities." Although this evaluation resulted in a determination that this proposed change causes a reduction in effectiveness of the CEP in accordance with 10 CFR 50.54q , the changes continue to meet the requirements of 10 CFR 50.47(b) and 10 CFR 50 Appendix E.

l&M is proposing to change the location of the CNP TSC to a new location on the second floor of the TSC/North Access Building (NAB). This change has been evaluated under 10 CFR 50.54, "Conditions of Licenses ," paragraph (q), "Emergency Plans," and a reduction in effectiveness has been identified. Therefore, in accordance with 10 CFR 50.54(q)(4) , this change requires prior NRC approval via a license amendment request.

2.0 DETAILED DESCRIPTION Current Design and Requirements The current TSC is located within the Turbine Building adjacent to the Unit 1 and Unit 2 Control Room (CR) complex and is accessed by a flight of stairs near the CR door. To walk from the main CR to the TSC is approximately a one minute walk. The current TSC meets the requirements, or intent of the requirements, set forth in 10 CFR 50.47(b)(8), 10 CFR 50 Appendix E, Section IV, NUREG-0654 I FEMA-REP-1 (Reference 1), and NUREG-0696 (Reference 2) . A review of current licensing basis information was conducted for the evaluation of relocating the TSC , which included the Updated Final Safety Analysis Report, Regulatory Commitments, and the CEP. This review did not identify any additional requirements or capabilities for the current TSC other than those set forth in the regulations and NUREGs discussed above.

The current TSC is located within two minutes of walking distance from the CR. The current TSC is adequately sized with sufficient space and is approved by the NRC even though it does not meet the 75 square foot (sq ft) per occupant requirements of NUREG-0696 (Reference 2). The current TSC structure meets the minimum requirements to be able to withstand the most adverse conditions reasonably expected during the design life of the plant. The current TSC has the same radiological habitability as the CR, with a comparable ventilation system and a radiation monitoring system . The current TSC has reliable voice communications equipment and systems. The current TSC has reliable equipment to gather, store, and display data needed in the TSC to analyze plant to AEP-NRC-2017-49 Page 2 conditions with an uninterruptible power supply (UPS) and a backup power source provided by the Security Diesel generator. The current TSC has a data system that provides access to accurate and reliable information that is needed to perform the TSC functions. The current TSC has a repository of up-to-date plant records, operational specifications, and procedures sufficient to assist in analysis and evaluation of emergency conditions.

Table 1 below, in Section 3, Technical Evaluation, provides a comparison overview of the current TSC elements and the proposed new TSC elements.

Proposed Change Planning Standard 10 CFR 50.47(b)(8) specifies that adequate emergency facilities and equipment must be provided and maintained to support the emergency response. This is further expanded in regulatory guidance provided in NUREG-0696, "Functional Criteria for Emergency Response Facilities," (Reference 2) which specifies that the TSC should be in close proximity to the CR to facilitate face-to-face interaction between CR personnel and the senior plant manager working in the TSC during an emergency. It further specifies that the walking time from the TSC to the CR should not exceed two minutes and should have no major security barriers between the TSC and the CR.

l&M is proposing a change to the CEP that relocates the TSC from its current location adjacent to the CNP Unit 1 and Unit 2 CR complex to a new facility at the northeast corner of the PA. The proposed new location for the TSC is on the second floor of the TSC/NAB. This new facility is a two story building that contains the security control point for access to the PA on the first floor. After passing through security controls to access the PA on the first floor, personnel will have access to stairways or an elevator to the second floor of the building , where the proposed TSC is located.

The proposed location for the TSC is an alternative to the NUREG-0696 requirements that the TSC be within two minutes of the CR and that the TSC location should facilitate face-to-face communication with the CR. The new TSC will continue to meet the intent and guidelines of NUREG-0696 (Reference 2) with the exception of the TSC location . The proposed new location for the TSC is on the second floor of the new TSC/NAB.

The proposed TSC is in the northeast corner of the CNP PA and is separated from the CR by a walking time of less than six minutes. This timeframe is based on a person leaving the CR, passing through the plant, walking between the buildings, and entering the second floor of the TSC/NAB to access the TSC. There are no normally employed security barriers in the new travel path .

l&M evaluated the proposed TSC relocation and determined that the relocation of the TSC will not alter the functions of the TSC as described in NUREG-0696 and will enhance the coordination of support activities with the overall emergency response effort. The proposed CNP TSC will have capabilities that are the same as or exceed those of the existing TSC. Since the proposed change represents a new location for the TSC, the adequacy of the facility was evaluated against the criteria in NUREG-0696 (Reference 2), Section 2, "Technical Support Center."

Because of the increased travel time between the TSC and the CR, the proposed change to relocate the TSC is a reduction in effectiveness from the current emergency plan requirements.

to AEP-NRC-2017-49 Page 3 Reason for the Proposed Change The new facility design and layout provides a larger facility with updated audio/visual equipment to establish and maintain command and control of on-site evaluations and mitigation strategy development. Features of the new TSC include emergency power from the Security Diesel Generator, additional telephones , and computer resources. The number of TSC phone lines and the number of networked personal computers will be increased to improve Emergency Response Organization (ERO) communications and access to plant data, drawings, procedures, and other computer applications.

The new TSC will continue to provide plant management and technical support to plant operations personnel during emergency conditions and relieve Operations staff of peripheral duties and communications not directly related to system manipulations. The new TSC will have access to plant process computer (PPC) data via the Safety Parameter Display System displays. The new TSC is designed to meet the protected envelope functional requirements for habitability and ventilation similar to the CR. In addition, the new TSC will meet the appropriate construction codes and standards and will be capable of withstanding the most adverse conditions reasonably expected during the design life of the plant, including adequate capabilities for earthquakes, high winds , and flood conditions.

This change will strengthen the TSC command and control function by allowing the TSC ERO a larger, better designed working area. With the larger work area, more equipment will be available to the TSC ERO to perform their functions. With the increase in working space the change will provide an improvement over the existing TSC and will enhance compliance with program requirements. The function of the new TSC will provide for the same or improved support to plant operations personnel during emergency conditions as the existing TSC and will meet the intent of requirements specified in NUREG-0696 (Reference 2) for an acceptable TSC .

3.0 TECHNICAL EVALUATION

Table 1 below provides a comparison overview of the current TSC elements and the new TSC elements. Figure 1 and Figure 2 at the end of this Enclosure provide a building floor plan drawing of the proposed new TSC and a typical layout arrangement of resources inside of the proposed new TSC .

Table 1 TSC Resource Comparison Overview Resource Current TSC Proposed New TSC Personnel TSC-15 CNP, 5 NRC TSC-15 CNP, 5 NRC Location Adjacent to CR complex 2nd floor of building in the north east

(<two minutes) corner of the PA(< six minutes)

Square Footage Approximately 1211 sq ft Approximately 5015 sq ft (total) to AEP-NRC-2017-49 Page 4 Resource Current TSC Proposed New TSC Personnel Accommodates 20 Accommodates 42, with additional Seating conference tables and seating around the perimeter of the Plant Evaluation Team Room NRC Area NRC Room is approximately A dedicated room for the NRC has 405 sq ft . This room contains the been allocated for the five NRC staff.

TSC copiers and is shared with the This room has a closable door for TSC Admin support Staff. The privacy and is approximately 441 sq ft dedicated NRC area is 165 sq ft which includes two workstation type desks and a conference table Rest Rooms One unisex bathroom , no shower. Two unisex bathrooms and a separate shower room Break/Serving Within the TSC Communications Separate Break Room with tables and Area Room , is a sink and water with small chairs, which includes a full sink and countertop area, and small water with a countertop area, a full refrigerator refrigerator, and room for a serving area Work Stations 15 32 which includes NRC counterpart (total) seating and two additional conference table seating areas Communications 17 Telephone( voice over internet 35 Telephone (VOiP)

Equipment protocol (VOiP))

Two Telephone (Commercial Lines)

Two Telephone (Commercial Lines)

Three Hand-held Radios Three Hand-held Radios Data System 11 workstation computers with 32 workstation computers with LAN Business Local Area Network (LAN) access access Two PPC terminals Two PPC terminals One Dose Assessment computer One Dose Assessment computer Four Data Display monitors Four Data Display monitors to AEP-NRC-2017-49 Page 5 Resource Current TSC Proposed New TSC Power source Normal power source from Unit 1 Normal power source from offsite balance-of-plant bus (powered by 12 kilovolt (kV) power station transformer)

UPS with 30 minutes of battery backup Additional normal power source Alternate power source from Security from Unit 1 balance-of-plant bus Diesel Generator through a Constant Voltage Transformer (powered by station transformer)

UPS with 30 minutes of battery backup Alternate power source from Security Diesel Generator Habitability Ventilation system that is Ventilation system that is comparable comparable to the CR to the CR

• normal and pressurization

• normal and pressurization modes modes

• HEPA and Charcoal filters

• high-efficiency particulate air Potassium Iodide tablets for CR and (HEPA) and Charcoal filters TSC personnel Potassium Iodide tablets for CR and Anti-contamination Clothing and TSC personnel respiratory protective equipment Anti-contamination Clothing and respiratory protective equipment Radiation One continuous air monitor Permanently installed digital Radiation Monitoring Monitor system with a local display unit One area radiation monitor that includes:

One hand-held frisker instrument

• Two area radiation monitors

• One airborne alpha beta particulate monitor

• One airborne iodine monitor

• One hand-held frisker instrument Plant Records Business LAN access for Business LAN access for workstation workstation computers allowing computers allowing access to plant access to plant controlled document controlled document system , internet, system, internet, and other and other electronic software electronic software applications applications Up-to-date repository of selected Up-to-date repository of selected plant plant records and procedures records and procedures to AEP-NRC-2017-49 Page 6 Evaluation against NU REG 0696 (Reference 2). Section 2.1. Function When activated , the TSC functions include:

• Support for the affected CR's emergency response efforts

• Continued evaluation of event classification

• Assessment of the plant status and potential offsite impact

• Coordination of emergency response actions within the PA

• Communication with the NRC via Emergency Notification System (ENS)

• Activation of the Emergency Response Data System (EROS) or ensuring that it is activated While the proposed location of the new TSC does not lend itself to direct face-to-face communications between the Shift Manager/Site Emergency Coordinator (SEC) in the CR and the SEC in the TSC, adequate communications lines and designated positions will ensure continued and effective communication . With improved electronic communication capabilities and technologies , face to face interactions between the TSC and CR personnel are not required in order to meet the intent of NUREG-0696 guidance. The site currently demonstrates the effectiveness of the communications lines and designated positions as a substitute for face-to-face communications during emergency plan drills with the CNP Simulator CR and the current TSC.

The CNP drills are currently conducted in a manner that does not afford the face to face interactions, due to the Simulator being in the Training Center building , outside the PA.

Therefore , it can be demonstrated , relocation of the TSC to the new TSC/NAB will not prevent CNP from meeting the intent of the guidance in NUREG-0696 for TSC Function.

The new location also provides for improved off-hours staffing capabilities since responders upon processing through Security Access in the TSC/NAB will go directly upstairs to enter the new TSC and will not need to obtain personal protective equipment from lockers and walk through the plant to get to the TSC. The relocation of the TSC will improve activation time and transfer of critical tasks from the CR. The location of the TSC will also provide managerial and technical support to plant operations personnel via the communication links during emergency conditions without congesting the CR. The new TSC will have access to the PPC data via the Plant System Server (PSS) displays to provide for continued evaluation and assessment of the emergency.

There is not an anticipated need to regularly traverse from the TSC to the CR. The increase in distance will be more than compensated by the fact that this change will strengthen the TSC Command and Control function by allowing the TSC ERO a larger, better-designed working area.

The TSC is sized to accommodate 42 personnel and their supporting equipment. This includes provisions for 14 NRC representatives. The larger work area facilitates personnel more effectively performing their ERO functions.

Based on the above, the function of the new TSC will meet the requirements of NUREG-0696 (Reference 2) for TSC Function.

to AEP-NRC-2017-49 Page 7 Evaluation against NUREG 0696 (Reference 2). Section 2.2. Location CNP's new TSC is located in the northeast corner of the protected area boundary on the second floor of the newly constructed TSC/NAB. Figure 3 at the end of this Enclosure provides an overview drawing of the PA showing the location of the new TSC/NAB relative to the CR. The distance between the CR and the new TSC location is less than a six minute walk. This timeframe is based on a person leaving the CR, walking to the new TSC/NAB and entering the second floor TSC. The proposed TSC location does not lend itself to face-to-face communications with the CR as recommended by NUREG-0696, Section 2.2. The location of the TSC is an alternative method to NUREG-0696 requiring the TSC to be within two minutes walking distance of the CR and that there be no major security barriers between the two facilities. There is a security delay fence that is located between the new TSC and the CR. The security barrier performs a defense-in-depth security function and is not considered to be a major security barrier between the TSC and CR.

The barrier has multiple normally-open access gates for personnel ingress and egress between the outer PA perimeter and the inner PA which contains the plant and office buildings. The only time the barrier's personnel gates are closed is when a security-related event is occurring , in which case TSC ERO responders would be directed to go to the alternative TSC location located in the Emergency Operations Facility (EOF) . Additionally, the CR and TSC access is controlled via security card access readers .

The original intent for the CR and TSC close proximity requirement was to ensure timely and accurate communication between the CR and the senior licensee manager in the TSC. The new TSC has dedicated and diverse communications with the CR, the Operations Support Center (OSC) and the EOF established by the CR Communicator. The CNP Emergency Plan describes the extensive communications capabilities between the TSC and the CR, OSC, and EOF.

These communications capabilities provide a variety of methods to ensure reliable communications and compensate for the TSC being relocated further from the CR.

Additionally, the new TSC has access to the PPC data via the PSS displays.

NUREG-0800 (Reference 4), Section 14.3 .10, Table 14.3.10-1 , Acceptance Criteria 8.1.2, includes a statement that "Advanced communication capabilities may be used to satisfy the two minute travel time ." The communication capabilities between the CR and the new TSC are a suitable alternative to the two minute travel time. Management interaction and technical information exchange will be accomplished using plant computer and communication (telephone, radio , etc.) systems that provide means to directly contact the CR. The capabilities to review and evaluate technical data , such as plant parameter display information , are provided in the TSC from real-time systems which receive their inputs from the same sources as the CR. Access to procedural information and plant reference material will continue to be available in the TSC as described in NUREG-0696 (Reference 2). The use of technology to access and evaluate plant parameters significantly reduces the need for face-to-face interactions described in NUREG-0696 (Reference 2) .

There is no anticipated need to regularly traverse from the new TSC to the CR . However, if the need were to arise requiring transit to the CR, the transit time would be less than six minutes.

In the event that TSC personnel were to travel to the CR during a radiological release or if a release is imminent, the TSC will have protective clothing and equipment and spare dosimetry if needed to ensure dose received during travel is as low as reasonably achievable.

to AEP-NRC-2017-49 Page 8 The location of the TSC also affords the opportunity to use multiple routes to reach the CR to minimize exposure to a potential plume or release path.

Based on the above, the relocation of the TSC to the new TSC/NAB will meet the intent of the*

guidance in NUREG-0696 (Reference 2) for TSC Location .

Evaluation against NUREG 0696 (Reference 2). Section 2.3. Staffing and Training The proposed TSC is designed to support an emergency for CNP Unit 1 and Unit 2. The TSC requires hosting equipment and work space to support approximately fifteen (15) ERO positions, including designated work space for the NRC Residents and the 5 responding NRC staff. This organization will have access to and can evaluate emergency conditions for both Units using plant computer systems to provide operational parameters and meteorological data . The organization structure can maintain communications with the CR, the OSC, and the EOF. This change will also strengthen the TSC command and control function by allowing the TSC ERO a larger, better designed working area. As discussed above, the relocation of the TSC will improve activation time and transfer of critical tasks from the CR.

ERO Training will be maintained as currently described in the emergency plan and implementing procedures. Personnel training specific to their ERO assignments will be modified to incorporate changes based on the relocation of the TSC and the new work station arrangements. Emergency drill training is currently conducted using the current TSC in the Turbine Building (adjacent to the actual CR) and the simulator CR located in the Training Center Building , without the ability to have face to face communication between TSC and CR personnel. These drills have successfully demonstrated the ability to implement the Emergency Plan with a physically separated CR and TSC . Familiarization training in the new TSC is planned to be conducted during the 1st Quarter of 2018 . Additionally , there will be a practice drill in the new TSC for NRC observation in June or July of 2018.

Based on the above, the relocation of the TSC to the new TSC/NAB will support the continued compliance with ERO staffing and training requirements set forth in NUREG-0696 (Reference 2).

Evaluation against NUREG 0696 (Reference 2). Section 2.4. Size The new TSC Plant Evaluation Team (PET) Room and adjacent work areas total approximately 5015 sq ft as compared to the current TSC space of approximately 1211 sq ft.

The new TSC provides more than adequate spacing and exceeds the 75 sq ft/person required in NUREG-0696 (Reference 2) . The TSC will be designed around a central command center with additional work spaces on its perimeter for designated personnel. The TSC includes restrooms with a shower facility , a break room (refrigerator, sink, and serving area), two storage/supply rooms , a TSC Data Room for communications/network, audio/visual equipment, a Records Room for the copier/printers , and a TSC Heating , Ventilation, and Air Conditioning (HVAC)/UPS Electrical Room supporting only the new TSC area. An established designated boundary will ensure the TSC is protected by the HVAC/Recirculation-Filtration envelope. A visual floor plan layout of the new TSC is provided as Figure 1 at the end of this enclosure.

to AEP-NRC-2017-49 Page 9 The new facility will provide larger individual work spaces and designated discipline work areas and conference areas as compared to the existing TSC . The PET Room will contain 21 work stations, of which 16 are double seating workstations to facilitate NRC counterpart seating ,

compared to 11 work stations in the current TSC PET Room . The Dose Assessment Room and Work Room contain an additional 11 work stations. The facility also includes a Conference Room that has seating for eight at the table . The TSC will also include a designated NRC Conference Room that has two dedicated work spaces and a conference table that can seat 12 NRC responding staff. A visual layout of work stations and resources is provided as Figure 2 at the end of this enclosure.

With larger work areas , additional technology (computers and telephones) has been provided to the TSC personnel. The new TSC will allow personnel to access plant data, drawings, procedures, and other computer applications more timely and effectively from individual work stations. Technology in the new TSC will also include large screen displays, teleconferencing, real time system monitoring through plant computer networks, Radio Communication System, VOiP telephone system, and commercial telephone lines.

Based on the above, the new TSC meets the TSC size requirements set forth in NUREG-0696 (Reference 2).

Evaluation against NUREG 0696 (Reference 2li Section 2.5, Structure The new TSC is located in the TSC/NAB at the northeast corner of the PA. The PA boundary extends to the new TSC, thus ensuring the TSC remains within the PA. Access into the TSC will be controlled through two direct points of ingress/egress , on the north and south ends of the west side of the TSC . These points do not open directly to the exterior of the building , but are accessed inside of the TSC/NAB through an entry vestibule (comprised of two steel doors, with the inner door providing a sealed pressure boundary for the TSC) that is interior to the building . The east half of the second floor of the TSC/NAB is dedicated solely for the TSC.

The TSC access is controlled via security card access readers or key locked doors.

The TSC/NAB is constructed from 12 inches (") thick pre-cast concrete with lead-lined gypsum for the interior west wall of the new TSC . The wall between the HVAC room and the rest of the TSC is constructed of 12" thick poured concrete . The new TSC has two different fire protection systems, which are both fed from a 6" fire protection line entering the first floor mechanical room . The TSC portion of the fire protection system will be a pre-action sprinkler system while the charcoal filter will have a filled water pipe protecting it. The TSC/NAB is constructed to the requirements of the 2009 Michigan Building Code and ASCE 7 as called for in the Michigan Building Code. The TSC/NAB is designed to the requirements of the 2012 International Building Code Site Class D, Design Category C, and Occupancy Category IV. Therefore the TSC/NAB, with the new TSC within, is able to withstand the most adverse conditions ,

reasonably expected during the design life of the plant including adequate capabilities for high winds (other than tornadoes) and floods with a 100-year recurrence frequency and earthquakes as required by NUREG-0696 (Reference 2) .

Based on the above, the new TSC meets the TSC structure requirements set forth in NUREG-0696 (Reference 2).

to AEP-NRC-2017-49 Page 10 Evaluation against NUREG 0696 (Reference 2). Section 2.6, Habitability Similar to the current TSC, the new TSC is designed to meet the protected envelope functional requirements for habitability and ventilation similar to the CR as identified in NUREG-0696 (Reference 2) and Section 11.B.2 of NUREG-0737 (Reference 3). A stand-alone HVAC system will be provided. Shielding will be provided to significantly reduce the effects of external shine as well as TSC HVAC Unit filter unit shine following an accident. Radiation monitoring is provided to indicate radiation dose rates as well as airborne radioactivity levels.

Similar to the current TSC, the HVAC for the new TSC will be a stand-alone system that will be able to completely support the TSC during normal plant operation as well as following an accident. The new TSC system will consist of an Air Handling Unit (AHU) to provide conditioned air to the TSC during normal and accident scenarios. During emergency mode, outdoor air will be isolated from the AHU via a bubble tight damper and routed through the filter unit. The filter unit will contain HEPA and charcoal filters. Additionally, a bubble tight isolation damper is provided to seal off the TSC exhaust opening during the emergency mode of operation where the TSC envelope is maintained at a positive pressure with a filtration unit for makeup air.

The new TSC HVAC system will feature status light indication for emergency versus normal operation on the control panel, located in the main room of the new TSC. A push button is also on the control panel for switching the TSC HVAC between emergency and normal modes. There will be AHU mounted local gauges for monitoring of HVAC filter differential pressure. The HVAC System will feature automatic flow control for the filter unit to maintain proper flow as the filters accumulate debris. Automatic temperature controls are also present.

The HVAC design includes the following:

• HEPA filters that meet the requirements of ASME AG- 1-2012, Section FC

• Charcoal adsorbers that meet the requirements of ASME AG-1-2012 , Section FD

• Bubble tight dampers that isolate outside make-up air to the AHU and the exhaust plenum

• Outside air make-up flow rates between 650 standard cubic foot/feet per minute (scfm) and 1000 scfm

• Recirculation air flow rates between 7790 scfm and 8280 scfm

• Ability to maintain a positive pressure in the TSC of 0.125 inches water gauge (inwg) during emergency mode of operation Description of TSC HVAC System Operation :

• During emergency operation, the motor operated isolation supply damper (bubble tight) for outside make-up air flow to the TSC AHU will close to ensure the flow path of make-up air is directed through the filter unit. The motor operated supply and discharge dampers for the filter unit will open to allow the make-up air flow through the filter unit. A humidistat will detect the humidity upstream of the carbon filters and turn on and off a heating coil in the filter unit according to the humidity. This filtered air is then moved to the supply duct of the AHU by a separate filter unit fan . The fresh airflow mixes with the recirculation air-flow upstream of the AHU. Lastly, the motor operated exhaust discharge damper (bubble tight) closes and the exhaust fan turns off.

to AEP-NRC-2017-49 Page 11

• During normal operation , the supply damper to the AHU remains open and the supply and discharge dampers for the filter unit remain closed and the filter unit fan is off.

The fresh airflow mixes with the recirculation air-flow upstream of the AHU. It is then conditioned by the AHU and supplied to the TSC rooms. The airflow to the rooms is balanced and the temperature sensors in the room can be used to controJ the duct mounted heating coils in each room. The TSC Exhaust fan operates to exhaust airflow through the bathrooms and shower room with the exhaust discharge damper remaining open .

Radiological monitoring equipment in the new TSC is provided to monitor radiation exposure to personnel that occupy the TSC during accident conditions . The new TSC radiation monitoring maintains the functionality of that in the existing TSC. However, there are also additional components as part of the new radiation monitoring equipment that add new functionality such as an additional area monitor, an alpha beta particulate monitor and a local display unit. The radiation monitoring equipment includes one iodine monitor, one alpha beta particulate monitor, one local display unit, and two area radiation monitors. The iodine and particulate monitor equipment is located in the TSC mechanical room where the TSC HVAC filter unit is located . To minimize the effects of filter dose shine on indicated airborne iodine and particulate activities, a 2" thick lead brick inter-laced wall shields the monitor equipment from the filter unit.

Shielding is provided by the structure of the new TSC to protect personnel in the TSC from exceeding 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) for a 30-day accident mitigation period. The exterior walls of the TSC/NAB structure, are 12" thick concrete and the floor and roof are 6" thick concrete. A 12" thick concrete shield wall is provided between the TSC HVAC equipment room and adjoining TSC areas to protect TSC personnel in the TSC working areas from the filter unit gamma radiation field . The new TSC HVAC equipment is designed to maintain the new TSC envelope at a nominal .125 inwg positive pressure in the emergency mode of operation .

A radiological dose analysis is being performed for the new TSC based on CNP's current licensing basis for CR Dose Analysis which uses the Alternative Source Term. Preliminary results show that the resulting total dose for any individual is <5 rem TEDE for the 30 day period following a large break Loss-of-Coolant Accident (LOCA). The completed calculation is anticipated to be provided by the vendor to l&M by the end of November 2017 . l&M will supplement this License Amendment Request with a submittal with the final dose calculation for NRC review by the end of December 2017.

Key input assumptions used for the dose calculation are as follows:

• The TSC ventilation system is manually placed in emergency mode of operation within 20 minutes of the start of the accident for airborne source dose calculations . The m'odeled emergency mode of operation actuation time is at least 20 minutes post-accident to allow for this manual action to occur. For filter shine calculations the accident mode is conservatively assumed to be in effect immediately

• TSC HVAC intake flow rate in the normal mode is modeled as 1140 scfm , + or -

10 percent (%) and the intake flow rate in the emergency mode of operation is modeled as 650 scfm, +or - 10%

to AEP-NRC-2017-49 Page 12

• HEPA filter and charcoal adsorber fission product removal efficiencies of 99% efficiency for particulate and 95% efficiency for elemental and organic iodine and 1% bypass of the filter

• TSC unfiltered air in leakage of 25 scfm is modeled during both modes of operation

• External shine for the release plume is modeled to account for the 2nd story location of the new TSC , This model accounts for the fabrication thickness variations for pre-cast concrete walls, accounts for the lead lined gypsum west interior wall , and assumes the external post-LOCA plume surrounds the TSC on all sides

• Shield wall between TSC filter unit and the rest of the TSC is comprised of 12" thick poured concrete

• Atmospheric dispersion factors are calculated using the ARCON96 computer code based on the current dose analysis meteorological data for the site for LOCA release points to the new TSC HVAC intake

• Atmospheric dispersion factors are calculated for LOCA containment leakage, containment purge, Engineered Safeguards Features leakage, and Refueling Water Storage Tank back leakage Based on the above, the new TSC meets the habitability requirements set forth in NUREG-0696 (Reference 2) and is sim ilar to the protection that the CR structure provides the operators.

Evaluation against NUREG 0696 (Reference 2). Section 2.7. Communications The new TSC maintained the same communications features as the current TSC. The communication capability of the new TSC complies with the current requirements of the CEP and includes the following :

• The station VOiP Telephone lines will be increased from seventeen (17) to thirty five (35)

• Business LAN based terminals and personal computers along with LAN printers and local printers will be increased from 11 to 32 , allowing the ERO to access plant data, drawings, procedures and other computer applications

• Gaitronics Plant Public Address System equipment

• A portable radio communication system for plant communications . Radio coverage includes all general areas onsite, with the exception of Containment. The system is used daily by Security, Operations , and Fire Brigade for communications and is also utilized for medical emergencies and field team communications during emergencies

• Health Physics Network (1 line)

• ENS (2 lines)

• Plant Private Automatic Branch Exchange connections for Dedicated Lines to the CR

• Fax Capability

• Two (2) Commercial Telephone Service Lines The VOiP System in the TSC is powered by its own batteries. The batteries are constantly serviced by a trickle charger, powered from an alternating current station auxiliary. In the event of a power failure the Security Diesel generator will automatically supply power to the charger.

The battery alone is capable of operating the system for approximately one hour.

to AEP-NRC-2017-49 Page 13 While direct face-to-face communications are less likely to occur between the Shift Manager in the CR and the SEC in the TSC, adequate communication lines, dedicated bridge lines, and designated Communicator ERO positions are used to ensure continued and effective communications with the CR. Additionally , the data display of PPC data and Radiation Monitoring System (RMS) data serves to reduce the reliance on verbal and face-to-face communications between the CR and the TSC.

Based on the above, the new TSC communications capability provides for the same or improved communication capability when compared to the existing configuration and meets the requirements set forth in NUREG-0696 (Reference 2) .

Evaluation against NUREG 0696 (Reference 2), Section 2.8. Instrumentation. Data System Equipment. and Power Supplies The new TSC data system and instrumentation, providing inputs to the data used in the new TSC to analyze plant conditions , is routed through the same data server, the PSS, that the current TSC uses for its data system and instrumentation inputs of plant data. For construction of the new TSC , redundant hardware data connections were created on the data server such that the data server currently has the capability to simultaneously provide inputs to both the current TSC and the new TSC data systems. The data system is designed such that it does not degrade or interfere with CR and plant functions. The new TSC did not result in the need for any hardware changes to instrumentation and data system equipment and therefore does not affect the reliability of such.

Both the current TSC and new TSC normal power supplies meet the unavailability criteria established in the NUREG-0696 (Reference 2). The TSC/NAB building power is fed from a 12kV off site power source and is supplied from the same power source that supplies the CNP 69kV Emergency Power. The current TSC has dual normal power supplies from each Train of Unit 1 balance of plant buses. The back-up power source for the current TSC and the new TSC is the Security Diesel generator. An evaluation was performed on the available capacity of the Security Diesel generator and it was determined that the generator has sufficient capacity to power the designated new TSC power loads in addition to the existing loads cu rrently required of the Security Diesel generator. The current TSC and the new TSC both have a UPS for TSC-only HVAC, utility receptacles/lights, and both have emergency lights with batteries. Similar to the current TSC, the new TSC UPS is a 30kVA UPS with a battery backup that will provide backup power for 30 minutes in the case of a loss of all AC power, which allows sufficient time for the Security Diesel to be started and loaded.

Based on the above, the new TSC provides for the same level of instrumentation and data system equipment as the current TSC and meets the intent for power supply requirements as set forth in NUREG-0696 (Reference 2) .

Evaluation against NUREG 0696 (Reference 2). Section 2.9. Technical Data and Data System The current and the new TSC primary access to technical data will be through the business LAN .

The current data systems for technical data to the TSC use replicated data through a data diode to

Enclosure 2 to AEP-NRC-2017-49 Page 14 ensure that the actual PPC and the instrumentation supplying the data cannot be affected. The PPC data for each Unit is continuously replicated to the PSS, which functions as a read-only PPC.

Meteorological data is available on the read-only PPC for use in dose assessment. The read-only PPC is accessed through the station business LAN . The RMS data for each Unit is continuously replicated to the Plant Data Server (PDS) which functions as a read-only RMS . Radiation monitoring software that is used by the ERO Radiological Assessment Coordinator for on-site dose assessment, is accessed through the business LAN and uses technical data input from both the PSS and PDS.

The current TSC and the new TSC each have 2 PPC terminals that are connected to the PPC, one for each Unit, where the TSC Computer Analyst can troubleshoot and resolve PPC software issues.

These PPC terminals are not the primary source of technical data to the TSC and are used strictly by the Computer Analyst to avoid having to travel outside of the TSC to address PPC issues, should they arise. Access to the PPC terminals is limited to authorized users only who have a secure account issued in accordance with the CNP Cyber Security Program. The PPC terminal connections to the PPC for the new TSC are new connections to the PPC that are separate from the PPC terminal connections in the current TSC , such that the PPC will simultaneously serve both TSCs to allow for relocation of the PPC terminals to support transition from the current TSC to the newTSC.

Based on the above, the new TSC provides for the same technical data and data system as the cu rrent TSC and meets the requirements set forth in NUREG-0696 (Reference 2).

Evaluation against NUREG 0696 (Reference 2), Section 2.10. Records Availability and Management The same as the current TSC , the new TSC will have an up-to-date repository of selected plant records, drawings, and procedures for use by the TSC personnel to aid in their technical Analysis and Evaluation of emergency conditions. The plant records will be controlled to ensure they are current and complete . In addition , all controlled station documents will be available through the business LAN from the Nuclear Document Management system.

Based on the above, the new TSC provides for the same records availability and management as the current TSC and meets the requirements of NUREG-0696 (Reference 2).

Conclusion Although the change in location is considered a reduction in effectiveness due to the additional time required to travel to the CR, the additional travel time of <6 minutes is an alternative to meeting the requirements of NUREG-0696 (Reference 2). The changes continue to meet the requirements of 10 CFR 50.47(b) and 10 CFR 50 Appendix E. The TSC will continue to maintain adequate facilities and equipment. The new TSC will ensure the station's emergency response will protect the public health and safety while monitoring , evaluating , and developing mitigation strategies in response to the emergency conditions .

to AEP-NRC-2017-49 Page 15

4.0 REGULATORY EVALUATION

Applicable Regulatory Requirements/Criteria 10 CFR 50.47(b) and 10 CFR 50, Appendix E, establishes emergency planning standards that require: 1) adequate staffing ; 2) satisfactory performance of key functional areas and critical tasks; and 3) timely augmentation of the response capability. The proposed change has been evaluated to determine whether applicable regulations and requirements continue to be met. The proposed change has also been evaluated in accordance with 10 CFR 50.54(q) and results in a reduction in the effectiveness of the emergency plan and therefore, prior Nuclear Regulatory Commission (NRC) approval is required prior to implementing the change. The proposed change, will continue to meet the requirements of 10 CFR 50 Appendix E and the planning standards of 10 CFR 50.47(b).

Precedent This request is similar in nature to other requests authorized by the NRC for Clinton Power Station

[ADAMS Accession No. ML070540270] and Three Mile Island Nuclear Station, Unit 1 [ADAMS Accession No. ML023460148]. These requests were submitted only as requests to revise their emergency plans pursuant to 10 CFR 50.54(q). However, in 2011 , the rule was amended to specify that licensees must use the license amendment process in 10 CFR 50.90 for changes evaluated as a potential reduction in effectiveness.

No Significant Hazards Consideration Determination Pursuant to 10 CFR 50.90, Indiana Michigan Power Company (l&M) , the licensee for Donald C. Cook Nuclear Plant (CNP) Unit 1 and Unit 2, proposes to revise the CNP Emergency Plan (CEP) to relocate the Technical Support Center (TSC) within the CNP Protected Area (PA).

The proposed change would relocate the TSC from the current location adjacent to the Control Room (CR) to the second floor of the PA access control building in the north east corner of the protected area, which is approximately a distance of less than 6 walking minutes from the CR. l&M has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change to the CNP emergency plan to relocate the TSC does not impact the physical function of plant structures, systems, or components (SSC) or the manner in which SSCs perform their design function . The proposed change neither adversely affects accident initiators or precursors, nor alters design assumptions. The proposed change does not alter or prevent the ability of SSCs to perform their intended function to mitigate the consequences of an initiating event

---

~-- - to AEP-NRC-2017-49 Page 16 within assumed acceptance limits. No operating procedures or administrative controls that function to prevent or mitigate accidents are affected by the proposed changes.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated .

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change does not impact the accident analysis. The proposed change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed or removed) or a change in the method of plant operation . The proposed change will not introduce failure modes that could result in a new accident, and the change does not alter assumptions made in the safety analysis. The proposed change to the location of the TSC is not an initiator of any accidents.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

Margin of safety is associated with confidence in the ability of the fission product barriers (i.e., fuel cladding, reactor coolant system pressure boundary, and containment structure) to limit the level of radiation dose to the public. The proposed change does not impact operation of the plant or its response to transients or accidents. The change does not affect the Technical Specifications or the operating license other than to amend the license to approve the change. The proposed change does not involve a change in the method of plant operation, and no accident analyses will be affected by the proposed changes .

Additionally, the proposed change will not relax any criteria used to establish safety limits and will not relax any safety system settings. The safety analysis acceptance criteria are not affected by these changes. The proposed change will not result in plant operation in a configuration outside the design basis. The proposed change does not adversely affect systems that respond to safely shut down the plant and to maintain the plant in a safe shutdown condition . The emergency plan will continue to activate an emergency response commensurate with the extent of degradation of plant safety.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, l&M concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c) , and accordingly, a finding of "no significant hazards consideration" is justified.

to AEP-NRC-2017-49 Page 17 Conclusions In conclusion , based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 51.20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51 .22(c)(9) . Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

1. NUREG-0654/FEMA-REP-1 , "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," Revision 1, U.S. Nuclear Regulatory Commission and Federal Emergency Management Agency, November 1980.

2. NUREG-0696, "Functional Criteria for Emergency Response Facilities," U.S. Nuclear Regulatory Commission, February 1981.

3. NUREG-0737, "Clarification of TMI Action Plan Requirements," Supplement 1, "Requirements for Emergency Response Capability," January 1983.

4. NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition ," Section 14.3.10, "Emergency Planning - Inspections, Tests, Analyses, and Acceptance Criteria," March 2007.

to AEP-NRC-2017-49 Page 18 Figure 1 TSC Floor Plan TSC is the right half of the floor diagram below 1\27

_ _ _ _ _L _ _

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SECOND FLOOR~.~ ~

I to AEP-NRC-2017-49 Page 19 Figure 2 TSC Resource Layout Diagram

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./

I lJ ISFX '

• no on"*~n RECORDS to AEP-NRC-2017-49 Page 20 Figure 3 Overview of Protected Area Arrangement Showing TSC/NAB Warehousr t Legend :

Red Line - Protected Area Fence Gray - Paved areas

Enclosure 3 to AEP-NRC-2017-49 Donald C. Cook Nuclear Plant Emergency Plan Pages Marked to Show Proposed Changes

Page 16of191

20. Protected Area The area encompassed by physical barriers to control access to the plant and to the ISFSI.

21 . Protective Action Guides (PAG) The projected dose to an individual from an unplanned release of radioactive material at which a specific protective action to reduce or avoid that dose is recommended . Protective actions would be warranted provided the reduction in individual dose expected to be achieved by carrying out the protective action is not offset by excessive risks to individual safety in taking the protective action . The PAG does not include the dose that has unavoidably occurred prior to the initiation of a protective action .

22 . State Emergency Operations Center (SEOC) This facility provides a central location from which the emergency functions of state government may be carried out in response to emergency conditions. The primary State EOC is located at 4000 Collins Road, Lansing , Michigan.

23. State Field Team Center (FTC) This facility provides the operational working area for State representatives assigned to coordinate the dispatch of field teams to monitor for radioactive contamination . The facility will be directed by a Field Team Center Coordinator assigned by the Michigan Department of State Police/Emergency Management and Homeland Security Division . A representative of the Department of Environmental Quality/Drinking Water and Radiological Protection Division will be assigned to this facility as the Radiological Monitoring Team Leader. The location for the FTC is the Michigan Department of Transportation's Coloma garage at the intersection of Red Arrow Highway and 1-196.

24. Technical Support Center (TSC) This facility is located adjacent to the Control Rooms at Elevation 644 '. in the northeast corner of the protected area boundary.

This center is physically separated from both Control Rooms. This facility has communication links to each Control Room, to the Emergency Operations Facility, Emergency News Center/Joint Information Center, Operations Support Center and offsite emergency operations centers established by State/County authorities. This area contains access to instrumentation and necessary reference material for plant management and support personnel.

The primary function of the TSC is to provide an area in close proximity to the Control Room from which plant operators can receive technical support and assistance from personnel who have the experience and expertise in nuclear plant operations, maintenance, safety and design. Their function is to mitigate the cause(s) of a nuclear incident and act as a data gathering center for plant parameters.

Access to the TSC will typically be limited immediately to those individuals listed in Figure 5, and as the situation demands, those individuals required by the SEC or alternate.

Introduction CEP Rev 38

Page 88 of1 91 H. EMERGENCY FACILITIES AND EQUIPMENT Plant personnel who are needed and are not onsite will be notified of the existing plant condition and will be directed to report to one of the following locations:

TSC 2 EOF 3 osc 4 Or an alternate location in the event of unsafe plant conditions.

H.1. Technical Support Center H.1.a. TSC Functions The onsite Technical Support Center (TSC) provides plant management and technical support to plant operations personnel during emergency conditions from a location outside the Control Room .

During the short-term emergency conditions, the TSC is capable of serving the following purposes until all required response centers both on and offsite have been activated .

• Providing technica l support to operations personnel as requested .

• Directing the activities of site personnel.

• Evaluating offsite agency requests and recommendations to ensure compatibi lity with emergency response objectives.

The TSC shall be activated for any Alert, Site Area Emergency or General Emergency.

The TSC, combined with the Control Room, can perform the functions of the EOF until the EOF is activated .

Sufficient data to determine the plant steady state and dynamic behavior prior to and throughout the course of an accident is available for analysis in the TSC . TSC personnel shall have ready access to plant records and procedures to support detailed technica l analysis and evaluation of plant conditions.

The TSC facilities may be used by plant personnel for normal daily operations as well as for training and emergency drills provided that these activities do not interfere with the immediate activation of the TSC or the continuing TSC operations in the event of an accident.

The primary NRC role in the TSC will be supportive, advisory, and observational.

H.1.b. TSC Location The TSC is located adjacent to the Control Room to readily allow face to face interaction between Control Room personnel and the senior plant management working in the TSC. in the northeast corner of the protected area boundary and is within close walking distance should face-to-face interaction between Control Room and TSC personnel become necessary. (See Figures 10 and 11 )

Planning Standard H CEP Rev 38

Page 89of 191 An alternate location for the TSC is the Buchanan Office Build ing in the event of unsafe conditions at the plant.

H.1.c. TSC Staffing The TSC is staffed to provide tech nical support to the Control Room operating staff during accidents. The number and type of personnel assigned to the TSC and their time of arrival in the TSC may vary according to the emergency class. The TSC staff assignments are contained in Section B. The SEC, or in the absence of the SEC, the Assistant SEC shall coordinate activities in the TSC and interface with the Control Room and the EOF.

H.1.d. TSC Design The CNP TSC is located in the Turbine Building adjacent to the two Control Rooms. This location readily allows for face to face interaction between the Control Room personnel and TSC personnel. Because of the proximity of the TSC to the Control Room, it will normally take less than 2 minutes to travel from one facility to the other. The lower level of the TSC (elevation 634')

is comprised primarily of the Shift Manager's Office and the TSC computer room. The upper level (elevation 643') northeast comer of the protected area boundary and is within close walking distance should face-to-face interaction between Control Room and TSC personnel become necessary. Because of the proximity of the TSC in the protected area it will normally take approximately 5 minutes to travel from the TSC to the Control Rooms. The TSC houses the Plant Evaluation Team area which contains the computer consoles workstations, communications area and equipment, and a separate office with sufficient working space for at least five NRC representatives. The staffing and use of the TSC has been tested in emergency exercises with the result that there is sufficient space for plant emergency personnel to perform their assigned functions.

The TSC has been constructed to provide the same degree of radiologica l habitability as the Control Room under accident conditions. Concrete shielding has been provided to sig nificantly reduce the effects of containment building radiation shine during an accident. Radiation monitoring is provided to indicate radiation dose rates as well as airborne radioactivity levels.

The CNP TSC has been designed to:

1. Provide technical support to plant operations personnel during emergency conditions.

2. Relieve the reactor operators of peripheral duties not directly related to reactor system manipulation.

3. Prevent congestion in the Control Room .

4. If necessary, perform EOF functions for an Alert, Site Area Emergency or General Emergency until the EOF is fully functional.

The following communication systems have been provided in the TSC:

• Offsite emergency radio to communicate with the Offsite Survey Teams as well as with in-plant teams, and EOF.

• Ded icated line on the NRC Health Physics Network (HPN) and two dedicated lines on the NRC Emergency Notification System (ENS).

• Plant intercom/PA System .

• Dedicated communication circuit to the Control Room , OSC and EOF.

Planning Standard H CEP Rev 38

Page 103 ofl91 Maintenance Building Security

• Access Control :

• • • Security

• • • Access :

• • Control :

Unit 2 Main Transformers D

Turbine Building Operation Screen House Staging Area Planning Standard H CEP Rev 38

Page 104of191 FIGURE 11 CNP EMERGENCY RESPONSE CENTER LOCATIONS Entry at Elev. 633' Turbine Building Control Room Abo*,*e 8M's Office Complex Adjaceat to UA:its l aad 2 Coatrol Rooms Technical Support Center (TSC) In the northeast comer of the Protected Area Boundary Plant Offices - Basement Shelter Elev. 587' Operations Support Center (OSC)

In Nuclear Generation Group Headquarters Buchanan - Approximately Emergency Operations Facility (EOF) 14 miles Southeast of CNP In Nuclear Generation Group Headquarters Buchanan - Approximately Emergency News Center/Joint Information Center (ENC/JIC) 14 miles Southeast of CNP CEP Rev 38 Planning Standard H

Page 164of191 Emergency Kits and Equipment Location LOCATION Radiation Protection Emergency Kit Operations Support Center (OSC)

Emergency Operations Facility (EOF)

Survey Vehicles (1 in each of the 2 dedicated Survey Vehicles)

First Aid - Decon Equipment Radiation Protection Access Control (RPAC)

Anti-C Equipment for Ambulance Security Control Center In-Plant/On-Site Driver to Hospital Vehicle Search Portal Emergency Anti-C Equipment Technical Support Center (TSC)

Operations Support Center Area Training Center Emergency Operations Facility (EOF)

Both Control Rooms Control Room Emergency Cabinet Survey Vehicle Hospital Emergency Cabinet Lakeland Regional Medical Center, St. Joseph Niles Community Hospital , Niles Shift Supervisor Office Radiation Protection 633' Turbine Deck at TSC stairs outside the Emergency Locker Shift Managers Office by the west wall SCBAs 17 Auxiliary Building 10 RPAC 1O Basement Assembly Area (OSC) 10 633' Turbine Deck by TSC outside the Shift Managers Office by the west wall 2 Each Control Room 10 609' Turbine Bldg . - for Turbine Building use only Stretcher Lockers 1O Locations in Plant Appendix C CEP Rev 38

Enclosure 4 to AEP-NRC-2017-49 Donald C. Cook Nuclear Plant Emergency Plan Clean Pages

Page 16 of 191

20. Protected Area The area encompassed by physical barriers to control access to the plant and to the ISFSI.

21 . Protective Action Guides (PAG) The projected dose to an individual from an unplanned release of radioactive material at which a specific protective action to reduce or avoid that dose is recommended . Protective actions would be warranted provided the reduction in individual dose expected to be achieved by carrying out the protective action is not offset by excessive risks to individual safety in taking the protective action . The PAG does not include the dose that has unavoidably occurred prior to the initiation of a protective action .

22 . State Emergency Operations Center (SEOC) This facility provides a central location from which the emergency functions of state government may be carried out in response to emergency conditions. The primary State EOC is located at 4000 Collins Road, Lansing, Michigan.

23. State Field Team Center (FTC) This facility provides the operational working area for State representatives assigned to coordinate the dispatch of field teams to monitor for radioactive contamination . The facility will be directed by a Field Team Center Coordinator assigned by the Michigan Department of State Pol ice/Emergency Management and Homeland Security Division . A representative of the Department of Environmental Quality/Drinking Water and Rad iological Protection Division will be assigned to this facility as the Rad iological Monitoring Team Leader. The location for the FTC is the Michigan Department of Transportation 's Coloma garage at the intersection of Red Arrow Highway and 1-196.

24. Technical Support Center (TSC) This facility is located in the northeast corner of the protected area boundary. This center is physically separated from both Control Rooms. This facility has communication links to each Control Room , to the Emergency Operations Facility, Emergency News Center/Joint Information Center, Operations Support Center and offsite emergency operations centers established by State/County authorities. This area contains access to instrumentation and necessary reference material for plant management and support personnel.

The primary function of the TSC is to provide an area in close proximity to the Control Room from which plant operators can receive technical support and assistance from personnel who have the experience and expertise in nuclear plant operations, maintenance, safety and design . Their function is to mitigate the cause(s) of a nuclear incident and act as a data gathering center for plant parameters.

Access to the TSC will typically be limited immediately to those individuals listed in Figure 5, and as the situation demands, those individuals required by the SEC or alternate.

Introduction CEP Rev 39

Page 88of 191 H. EMERGENCY FACILITIES AND EQUIPMENT Plant personnel who are needed and are not onsite will be notified of the existing plant cond ition and will be directed to report to one of the following locations:

TSC 2 EOF 3 osc 4 Or an alternate location in the event of unsafe plant conditions.

H.1 . Technical Support Center H.1 .a. TSC Functions The onsite Technical Support Center (TSC) provides plant management and technical support to plant operations personnel during emergency conditions from a location outside the Control Room .

During the short-term emergency conditions, the TSC is capable of serving the following purposes until all required response centers both on and offsite have been activated .

• Providing technical support to operations personnel as requested .

• Directing the activities of site personnel.

• Evaluating offsite agency requests and recommendations to ensure compatibility with emergency response objectives.

The TSC shall be activated for any Alert, Site Area Emergency or General Emergency.

The TSC, combined with the Control Room , can perform the functions of the EOF until the EOF is activated .

Sufficient data to determine the plant steady state and dynamic behavior prior to and throughout the course of an accident is available for analysis in the TSC . TSC personnel shall have ready access to plant records and procedures to support detailed technical analysis and evaluation of plant conditions.

The TSC facilities may be used by plant personnel for normal daily operations as well as for training and emergency drills provided that these activities do not interfere with the immediate activation of the TSC or the continuing TSC operations in the event of an accident.

The primary NRC role in the TSC will be supportive, advisory, and observational.

H.1.b. TSC Location The TSC is in the northeast corner of the protected area boundary and is within close walking distance should face-to-face interaction between Control Room and TSC personnel become necessary. (See Figures 10 and 11)

Planni ng Standard H CEP Rev 39

Page 89of 191 An alternate location for the TSC is the Buchanan Office Building in the event of unsafe conditions at the plant.

H.1.c. TSC Staffing The TSC is staffed to provide technical support to the Control Room operating staff during accidents. The number and type of personnel assigned to the TSC and their time of arrival in the TSC may vary according to the emergency class. The TSC staff assignments are contained in Section B. The SEC , or in the absence of the SEC , the Assistant SEC shall coordinate activities in the TSC and interface with the Control Room and the EOF.

H.1.d. TSC Design The CNP TSC is located in the northeast corner of the protected area boundary and is within close walking distance should face-to-face interaction between Control Room and TSC personnel become necessary. Because of the proximity of the TSC in the protected area it will normally take approximately 5 minutes to travel from the TSC to the Control Rooms. The TSC houses the Plant Evaluation Team area which contains the computer workstations , communications area and equipment, and a separate office with sufficient working space for at least five NRC representatives.

The TSC has been constructed to provide the same degree of radiological habitability as the Control Room under accident conditions. Concrete shielding has been provided to significantly reduce the effects of containment building radiation shine during an accident. Radiation monitoring is provided to indicate radiation dose rates as well as airborne radioactivity levels.

The CNP TSC has been designed to:

1. Provide technical support to plant operations personnel during emergency conditions.

2. Relieve the reactor operators of peripheral duties not directly related to reactor system manipulation .

3. Prevent congestion in the Control Room .

4. If necessary, perform EOF functions for an Alert, Site Area Emergency or General Emergency until the EOF is fully functional.

The following communication systems have been provided in the TSC :

• Offsite emergency radio to communicate with the Offsite Survey Teams as well as with in-plant teams, and EOF.

• Dedicated line on the NRC Health Physics Network (HPN) and two dedicated lines on the NRC Emergency Notification System (ENS) .

• Plant intercom/PA System .

• Dedicated communication circuit to the Control Room , OSC and EOF.

• Fax capability.

• 2 private lines off the CNP PBX are dedicated for NRC use with outside capability.

• Add itional telephones to be used as needed.

Planning Standard H CEP Rev 39

Page 102 of191 Figure 10 LOCATIONS OF EMERGENCY RE En:iergency Operations Facility Emergency News Center/Joint I'----'

1n the Nuclear Generation Information Center in the M,rn1IPnanu* Group Headquarters Building Nuclear Generation Group Outage I acility in Buchanan Headquarters Building in CEP Rev 39 .____ _ _ _ _ _ _ _ _ _ __ J Buchanan

Page 104of191 FIGURE 11 CNP EMERGENCY RESPONSE CENTER LOCATIONS Entry at Elev. 633 ' Turbine Building Control Room In the northeast comer of the Protected Area Boundary Technical Support Center (TSC)

Plant Offices - Basement Shelter Elev. 587' Operations Support Center (OSC)

In Nuclear Generation Group Headquarters Buchanan -Approximately Emergency Operations Facility (EOF) 14 miles Southeast of CNP In Nuclear Generation Group Headquarters Buchanan - Approximately Emergency News Center/Joint Information Center (ENC/nC) 14 miles Southeast of CNP CEP Rev 39 Planning Standard H

Page 164 of 191 Emergency Kits and Equipment Location LOCATION Radiation Protection Emergency Kit Operations Support Center (OSC)

Emergency Operations Facility (EOF)

Survey Vehicles (1 in each of the 2 dedicated Survey Vehicles)

First Aid - Decon Equipment Radiation Protection Access Control (RPAC)

Anti-C Equipment for Ambulance Security Control Center In-Plant/On-Site Driver to Hospital Vehicle Search Portal Emergency Anti-C Equipment Technical Support Center (TSC)

Operations Support Center Area Training Center Emergency Operations Facility (EOF)

Both Control Rooms Control Room Emergency Cabinet Survey Vehicle Hospital Emergency Cabinet Lakeland Regional Medical Center, St. Joseph Niles Community Hospital , Niles Shift Supervisor Office Radiation Protection 633' Turbine Deck outside the Shift Managers Emergency Locker Office by the west wall SCBAs 17 Auxiliary Building 10 RPAC 1O Basement Assembly Area (OSC) 10 633' Turbine Deck outside the Shift Managers Office by the west wall 2 Each Control Room 10 609' Turbine Bldg . - for Turbine Building use only Stretcher Lockers 10 Locations in Plant Appendix C CEP Rev 39