ML16020A368

Emergency Plan Implementing Procedure Revision, EP-IP-310, Offsite Monitoring Team Activation and Response, Revision 10 and Associated 10 CFR 50.54(q) Review

ML16020A368
Person / Time
Site:	Pilgrim
Issue date:	01/12/2016
From:	Calabrese D Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2.16.002
Download: ML16020A368 (23)

Text

'~' n teigj{600 EntegyiNuclear OPoerSationsIc Rocky Hill Road PyotMA 02360 January 12, 2016 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Emergency Plan Implementing Procedure Revision Pilgrim Nuclear Power Station Docket No. 50-293 License No. DPR-35 LETTER NUMBER: 2.16.002

Dear Sir or Madam:

" In accordance with 10 Code of Federal Regulations (CFR) 50.4, Entergy Nuclear Operations, Inc. is providing the latest revision to the Entergy EP-IP-310. The procedure revisions were reviewed in accordance with 10 CFR 50.54(q). The 50.54(q) reviews are also provided in the letter attachment.

The PNPS Emergency Plan continues to meet the planning standards outlined in 10 CER 50.47, the effectiveness of the emergency plan is not reduced, and the changes did not require prior U.S. Nuclear Regulatory Commission approval.

If you have any questions or require additional information, please contact me at (508) 830-8227.

There are no commitments contained in this letter.

-Donna Calabrese Emergency Planning Manager KLS/jc

Attachment:

Entergy Nuclear Operations,Inc. Letter No. 2.16.002 Pilgrim Nuclear Power Station Page 2 cc:

Director of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555 U.S. Nuclear Regulatory Commission Region 1 - Incident Response Center 2100 Renaissance Blvd., Suite 100 King of Prussia, PA 19406-2713 NRC Resident Inspector Pilgrim Nuclear Power Station

Attachment 1 Letter Number 2.16.002 EP-IP-310, Offsite Monitoring Team Activation and Response, Revision 10 and associated 10 CFR 50.54(q) Review

PNPS NON-QUALNTY EP-IP-310 Revision 10 EMERGENCY,;*RELATED MPLAMNTING _____

PROCEDURE~SG REFERENCE USE Page 1 of 17 Offsite Monitoring Team Activation And Response RTYPE H8.24 Offsite Monitoring Team Activation And Response Change Statement (a) Clarify wording regarding placement of detector when performing Iodine Cartridge Field Analysis.

Page 9.

ii!*EERENY PNPS NON-QUALITY EP-IP-310 Revision 10 EMERGENCY RELATED E ray bY' PLAN__

IMPLEMENTING PROCEDURES REFERENCE USE Page 2 of 17

........... ..Offsite Monitoring Team Activation And Response TABLE OF CONTENTS Section Title P~

1.0 PURPOSE ............................................................................. 3

2.0 REFERENCES

........................................................................ 3 3.0 DEFINITIONS.......................................................................... 3 4.0 RESPONSIBILITIES .................................................................. 3 5.0 DETAILS................................................................................ 4 5.1 PRECAUTIONS AND LIMITATIONS ................................................ 4 5.2 PROCEDURE.......................................................................... 4 5.2.10OMT Activation ........................................................................ 4 5.2.2 Equipment Checks And Inventory.................................................... 4 5.2.30Offsite Monitoring...................................................................... 6 5.2.4 Surveys ................................................................................. 7 5.2.5 Team Deactivation ................................................................... 10 6.0 INTERFACES ........................................................................ 11 7.0 RECORDS............................................................................ 11 8.0 REQUIREMENTS AND COMMITMENTS......................................... 11 9.0 ATTACHMENTS ..................................................................... 11 ATTACHMENT 9.1 OMT EQUIPMENT CHECKLIST ................................. 12 ATTACHMENT 9.2 OMT VEHICLE/COMMUNICATIONS CHECKLIST............. 14 ATTACHMENT 9.3 OMT SAMPLE/SURVEY SHEET ................................. 15 ATTACHMENT 9.4 DOCUMENT CROSS-REFERENCE ............................. 17

PNPSNNQULTEPI-0

• i:; EMERGENCY NNUATYP--30Revision 10 PLAN

• "*RELATED Efeg VPROEDUENSN REFERENCE USE Page 3 of 17 Offsite Monitoring Team Activation And Response 1.0 PURPOSE This Procedure provides instructions to Offsite Monitoring Team (OMT) members assigned to the Emergency Operations Facility (EOF). The OMTs will ascertain the radiological conditions in the environment during an emergency situation. The survey results obtained will help to determine and verify the protective action recommendations for the general public.

2.0 REFERENCES

[1] EP-PP-01, "PNPS Emergency Plan" 3.0 DEFINITIONS None 4.0 RESPONSIBILITIES

[1] The Offsite Monitoring Team (OMT) Coordinator is responsible for:

(a) Dispatching and directing the Offsite Monitoring Teams.

(b) Reporting directly to the Radiological Assessment Coordinator (RAC) all survey and sample results obtained by the OMTs.

[2] The Offsite Monitoring Teams (OMTs) are responsible for:

(a) Directly monitoring radiological conditions in the environs as directed by the OMT Coordinator.

5.0 DETAILS 5.1 PRECAUTIONS AND LIMITATIONS None 5.2 PROCEDURE 5.2.10OMT Activation When the Emergency Operations Facility (EOF) is to be activated, upon arrival the Radiological Monitoring Teams shall:

[1] Obtain team assignments and designation from the OMT Coordinator. If the Rad Lab and OMT Coordinator is not present, pair up in RP Monitor/Driver Teams.

[2] Sign in on the EOF manpower status board.

[3] Obtain an OMT procedure packet from the procedure cabinet.

[4] When all checks and inventories according to Section 5.2.2 have been completed, report to the OMT Coordinator for the dispatch briefing.

NOTES

1. The key to the Field Logistics area is located in the key box outside the door. The combination to the padlock is 000.

2. The keys to the OMT vehicles are located in the key box inside the security area.

5.2.2 Equipment Checks And Inventory

[1] Instrument Checks (a) Obtain a set of instruments.

(b) Perform the necessary instrument checks. Conduct physical checks, calibration checks, battery checks, and source checks as appropriate.

(c) Verify operability of each type of air sampler.

(d) Record the equipment checks as listed on Attachment 9.1 (OMT Equipment Checklist).

PNPSNO-ULT

,,::**:*;*EMERGENCY REL-QALTEPI-30Rviin1

• • ._E"PLAN _____E

• t~er"g/ IMPLEMENTING PROCEDURES REFERENCE USE Page5 of 1 Offsite Monitoring Team Activation And Response

[2] Field Kit Checks (a) Obtain an OMT field kit from the Field Logistics area.

(b) If the seal on the kit has been broken, then inventory the field kit.

(c) Obtain a package of silver zeolite cartridges from the cabinet in the Field Logistics area.

(d) Synchronize watches with the EOF clock.

(e) Distribute thermoluminescent dosimetry (TLD) and self-indicating dosimetry (SID) to each team member.

(f) Record name and Social Security number on the TLD. Don the TLD.

(g) Zero and don the SID.

(h) Record the results of the field kit inventory on Attachment 9.1 (OMT Equipment Checklist) (inventory is "SAT" if seal is intact).

[3] Vehicle Checks (a) Obtain a set of keys for an OMT vehicle.

(b) Perform the vehicle checks in accordance with Attachment 9.2 (OMT Vehicle/Communications Checklist).

[4] Communications Checks (a) Obtain a portable radio from the Field Logistics area.

(b) Verify communications with the EOF by testing the equipment listed on Attachment 9.2 (OMT Vehicle/Communications Checklist).

PNPSNNQALT PI3O

• • .EMERGENCY ONUAIYpl-30Revision 10 i:"*'***;*PLANRELATED

• • Enterg*y JMPLEMENTING PROCEDURES REFERENCE USE Page 6 of 17 Offsite Monitoring Team Activation And Response NOTE OMTs are not to proceed from the EOF without a full briefing by the OMT Coordinator or Radiological Assessment Coordinator.

5.2.30Offsite Monitoring

[1] Continuously observe radiation levels while traveling.

[2] While operating inside a radiation field, periodically check the SID reading. If it becomes necessary to rezero the SID, ensure the final and new initial values are reported to the OMT Coordinator.

[3] Boundary information on the leading edge, trailing edge, and outer edges of the plume should be relayed to the OMT Coordinator when available.

PMRGNPS NON-QUALITY EP-IP-310 Revision 10 EMERGENCY *RELATED EtPLAN___

L'nir ) IMPLEMENTING PROCEDURES REFERENCE USE Page7 of 1 Offsite Monitoring Team Activation And Response 5.2.4 Surveys

[2] Surveys taken in the early stages of an accident will be primarily involved with plume assessment and tracking.

NOTE Radiation and airborne surveys reported to the ECE for use in dose assessment should be centerline values. Survey data reported to the EOF is recorded on Attachment 9.3 (OMT Sample/Survey Sheet).

[3] Radiation Surveys (a) Using the dose rate meter, perform and record the survey at waist level with the beta window closed.

(b) Using the dose rate meter, perform and record the survey at waist level with the beta window open.

(c) Using the dose rate meter, perform and record the survey at ground level with the beta window closed.

(d) Using the dose rate meter, perform and record the survey at ground level with the beta window open.

(e) Report radiation levels to the OMT Coordinator. Record all information on Attachment 9.3 (OMT Sample/Survey Sheet).

PNPSNOQULTEPI-1

... *:, EMERGENCY NOELQALTEDP-P- Revision 10 PLAN ______-____R__LATE _

Ent!erg IMPLEMENTING PROCEDURES REFERENCE USE Page 8 of 17 Offsite Monitoring Team Activation And Response

[4] Airborne Surveys (a) Load a silver zeolite cartridge, arrow pointing in the direction of the air flow, into the sample apparatus.

(b) Place the air sampler 3 to 4 feet off the ground.

NOTE Exceeding a 2 SCFM flow rate may give erroneous iodine concentration levels.

(c) Draw a 20 cu. ft. air sample (2 SCFM for 10 minutes) unless otherwise directed by the EOF.

(d) Continue to monitor radiation levels while sampling. Record and report any significant changes.

(e) After the sample has been obtained, record the start time, stop time, and sample flow rate on Attachment 9.3 (OMT Sample/Survey Sheet).

(f) Proceed to an area of low background for counting of the sample. Monitor and report radiation levels while tracking plume boundaries.

(g) Particulate Filter Field Analysis (1) Determine background using a count rate meter with an HP-210 probe (or equivalent).

(2) Count the particulate filter.

(3) Store the particulate filter in a sealed petri dish. Mark the dish with the appropriate sample number and record all information on Attachment 9.3 (OMT Sample/Survey Sheet).

PNPSNOQULTEPI-1

• !:iEMERGENCY NNUATYE-P30Revision 10

",'.*:.:*RELATED

-~Etr PLAN_______

• iMPLEMENTING PROCEDURES REFERENCE USE Page 9 of 17 Offsite Monitoring Team Activation And Response (h) Iodine Cartridge Field Analysis (1) Connect the Nat probe to the E-600 (or equivalent).

(2) Turn the function switch to the scaler position.

NOTE Avoid using the E-600 in high background locations (e.g., 2 to 5 mR/hr). The OMT Coordinator is to be contacted if background count rates exceed 40,000 cpm for a 1-minute count time.

OMT Coordinator should recommend another counting location (i.e., one with a lower background).

(3) Perform a 1-minute background count by pressing the "," button located on the E-600 handle.

(4) Place the iodine cartridge in a sample bag and record its dose rate.

(5) Place the detector on top of the sample with the flow arrow *pointing away from the detector face (6) Count the sample for 1 minute by pressing the "*" button.

(7) Remove and label the sample. Record all information on Attachment 9.3 (OMT Sample/Survey Sheet).

(8) Perform another background count by pressing the "*" button. Notify the EOF if background has changed by more than a factor of two. Recount the sample and verify background as directed by the EOF.

(i) Record all data on Attachment 9.3 (OMT Sample/Survey Sheet) and report the results to the OMT Coordinator.

PNPSNN-ULTEPI-0

,;- EMERGENCY ONUATYP--30Revision 10

! PLAN RELATED nnC/,i"r " IMUPLEMENTING PROCEDURES REFERENCE USE Page 10 of 17 Offsite Monitoring Team Activation And Response 5.2.5 Team Deactivation When told to deactivate by the OMT Coordinator, the OMTs shall:

[1] Return to the EOF and transfer all samples to the OMT Coordinator.

NOTE Vehicle air cleaners could have high dose rates.

[2] Survey the OMT vehicles. Pay particular attention to the wheel wells, air cleaner, and door handles.

[3] Remove any anti-contamination clothing (as applicable) and perform a whole body frisk.

[4] Report any contamination found to the OMT Coordinator and await further instructions.

[5] Debrief with the OMT Coordinator. Ensure at least the following is done:

(a) All survey records are turned in.

(b) All checks and inventories are turned in.

(c) Any procedural problems are reported.

(d) Any equipment problems are reported.

(e) All applicable exposure records are correct and current.

[6] Inventory and restock the field kits.

[7] Clean out the OMT vehicles and refill the fuel tank.

PNPSNO-ULT

• i;!**EMERGENCY N-UATYEP-IP-310 Revision 10

• Er~t PLANRELATED 8)'oIMPLEMENTJNG PROCEDURES REFERENCE USE Page 11 of 17 Offsite Monitoring Team Activation And Response 6.0 INTERFACES None 7.0 RECORDS The following documents are generated as a result of the implementation of this Procedure:

o OMT Equipment Checklist o OMT Vehicle/Communications Checklist o OMT Sample/Survey Sheet The completed documents are to be turned in to the OMT Coordinator in the EOF.

8.0 REQUIREMENTS AND COMMITMENTS None 9.0 ATTACHMENTS 9.1 OMT EQUIPMENT CHECKLIST 9.2 OMT VEHICLE/COMMUNICATIONS CHECKLIST 9.3 OMT SAMPLE/SURVEY SHEET 9.4 DOCUMENT CROSS-REFERENCE

"PNPSNN-ULT

,***EMERGENCY REL-QALETY EP-IP-310 Revision 10

"-:4;*?*T PLAN _____ED izirherg,*'*y IMPLEMENTING{________________

PROCEDURES REFERENCE USE Page 12 of 17 Offsite Monitoring Team Activation And Response ATTACHMENT 9.1 OM~T EQUIPMENT CHECKLIST Sheet 1 of 2 TEAM: DATE:

TEAM MEMBERS:

Ion Chamber Dose Rate Meter Type:, Type: _____

Serial No.: ____________ Serial No.: ___

Cal Due:________ ___ Cal Due:____

Source Check:___ ______ Source Check: _

Beta Corr. Factor:________

Analyzer with Nal probe Count Rate Meter Type: Type:_____

Serial No.:_______ _____ Serial No.:

Cal Due:_________ ___ Cal Due:____

Efficiency: _________ Source Check:

HP-210 Probes (2).

Serial No.:____________ Serial No.

Cal Due: ___________ Cal Due:

RENSNO-ULITYD EP=IP-3t 0 Revision 10

ETteFO/.IMPLEMENTINGPA PROCEDURES REFERENCE USE Page 13 of 17

, Offsite Monitoring Team Activation And Response ATTACHMENT 9.1 OM~T EQUIPMENT CHECKLIST Sheet 2 of 2 Air Sampler Air Sampler Type: _____________Type: ____________

Serial No.: _______ _____ Serial No.:____________

Cal Due: ____________Cal Due: ____________

Instrument Check(s): __________________(SAT/U NSAT)

Kit Inventory: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __(SAT/U NSAT)

Comments:

ATTACHMENT 9.2 OMT VEHICLE/COM~MUNICATIONS CHECKLIST Sheet I of 1 TEAM:____ __

DATE:

Vehicle No.:______

Fuel Level (fill if < 1/2) (Check)

Vehicle Lights (Operates)

Spotlights (Operates)

Emergency (Strobe) Lights (Operates)

Power Inverter (Operates)

Spare Tire (Check)

Tow Strap (Available)

Condition of Tires (Sat/Unsat)

Jump Battery or Cables (Available)

Communications Vehicle Radio (Operates)

Portable Radio (Operates)

Cellular Telephone (Operates)

Vehicle Check: (Sat/Unsat)

Communications Check: (Sat/U nsat)

COMMENTS:

PNP..ON-QULITYEP-IP-310

• .;***EMERGENCY REL-ALTEY Revision 10 PLAN gYt

<f'*'"Enteyoy IMPLEMENTING _______

PROCEDURES REFERENCE USE Page 15 of '17 Offsite Monitoring Team Activation And Response ATTACHMENT 9.3 OM~T SAMPLE/SURVEY SHEET Sheet 1 of 2 TEAM: ____

DATE:

Sample No.: ___

Detailed Location:_

Distance from Plant: ____

____ ____miles Radiation Survey Survey Time: A)

Dose Rate (Closed Window waist high): B) mR/h, r Dose Rate (Open Window waist high): C) r mR/hi Dose Rate (Closed Window 2" off ground): D) mRlhi r

Dose Rate (Open Window 2" off ground): E) mR/hr Airborne Activity Survey Sample Start Time: F)

Sample Stop Time: G)

Sample Flow Rate: H) CFM Cartridge Dose Rate: mR/hr I)

ATTACHMENT 9.3 OM~T SAMPLE/SURVEY SHEET Sheet 2 of 2 Frisker

Background:

J) __________cpm Particulate Filter Count Rate: K) __________cpm Initial E-600/Nal

Background:

L) __________cpm Iodine Cartridge Count Rate: M) _______cpm Final E-600/Nal

Background:

N) _ _ _ _ _ _ _ _cpm E-600/Nal Probe Efficiency: 0) __________cpm/dpm (fractional value)

COMMENTS:

Note if survey/sample was not taken at plume centerline or large variances in background occurred while sampling.

PNPSNO-ULTEPI-1 EMERGENCY ONQAIYE-P30Revision 10

Ente

"*: ii~i~i *'*RELATED

• !*; r~o PLAN

.IMPLEMENTING _______

PROCEDURES REFERENCE USE Page 17 of 17 Offaite Monitoring Team Activation And Response ATTACHMENT 9.4 DOCUMENT CROSS-.REFERENCE Sheet 1 of 1 This Attachment lists those documents, other than References, which may be affected by changes to this Procedure.

Document Number Document Title EP-IP-260 EOF Operations

ATTACHMENT 9.1 10OCFR50.54(q) SCREENING SHEET 1 OF 3 ProcedurelDocument Number: EP-IP-31 0 Revision: 10 EquipmentlFacilitylOther: Pilgrim Nuclear Power Station

Title:

Offsite Monitoring Team Activation and Response Part I. Description of Activity Being Reviewed (event or action, or series of actions that may result in a change to the emergency plan or affect the implementation of the emergency plan):

This non-intent change to this procedure revised the wording: "Place the sample bag next to the detector ensuring that the flow arrow is pointing away from the face of detector." to read: "Place the detector on top of the sample with the flow arrow pointing away from the detector face."

Part II. Activity Previously Reviewed? [-YES 5o.54(q)(3)

[]NO Continue to Is this activity fully bounded by an NRC approved 10 CFR 50.90 submittal or Alert and Notification System Design Report? Evaluation is next part NOT required.

Enter If YES, identify bounding source document number/approval reference and justification ensure the basis for concluding the source document fully bounds the below and proposed change is documented below: complete Part VI.

Justification:

El Bounding document attached (optional)

Part III. Applicability of Other Regulatory Change Control Processes Check if any other regulatory change processes control the proposed activity.(Refer to EN-LI-100)

NOTE: For example, when a design change is the proposed activity, consequential actions may include changes to other documents which have a different change control process and are NOT to be included in this 50.54(q)(3)

Screening.

APPLICABILITY CONCLUSION

[] Ifthere are no controlling change processes, continue the 50.54(q)(3) Screening.

El One or more controlling change processes are selected, however, some portion of the activity involves the emergency plan or affects the implementation of the emergency plan; continue the 50.54(q)(3) Screening for that portion of the activity. Identify the applicable controlling change processes below.

El One or more controlling change processes are selected and fully bounds all aspects of the activity. 50.54(q)(3)

Evaluation is NOT required. Identify controlling change processes below and complete Part VI.

CONTROLLING CHANGE PROCESSES 10OCFR50.54(q)

Part IV. Editorial Change Li]YES 50.54(q)(3)

[]NO Continue to next Is this activity an editorial or typographical change such as formatting, paragraph Evaluation is part numbering, spelling, or punctuation that does not change intent. No NOT required.

Justification: Enter justification and complete Part VI.

EN-EP-305 REV 3

ATTACHMENT 9.1 10CFR50.54(q) SCREENING SHEET 2 OF 3 Procedure/Document Number: EP-IP-310 Revision: 10 Equipment/Facility/Other: Pilgrim Nuclear Power Station

Title:

Offsite Monitoring Team Activation and Response Part V. Emergency Planning Element/Function Screen (Associated 10 CFR 50.47(b) planning standard function identified in brackets) Does this activity affect any of the following, including program elements from NUREG-0654/FEMA REP-i Section I1?

1. Responsibility for emergency response is assigned. [1] _____

2. The response organization has the staff to respond and to augment staff on a continuing basis (24/7 []

staffing) in accordance with the emergency plan. [1]

3. The process ensures that on shift emergency response responsibilities are staffed and assigned. [2] Iii

4. The process for timely augmentation of onshift staff is established and maintained. [2] D]

5. Arrangements for requesting and using off site assistance have been made. [3] [

6. State and local staff can be accommodated at the EOF in accordance with the emergency plan. [3] [

7. A standard scheme of emergency classification and action levels is in use. [4] [

8. Procedures for notification of State and local governmental agencies are capable of alerting them of D]

the declared emergency within 15 minutes after declaration of an emergency and providing follow-up notifications. [5]

9. Administrative and physical means have been established for alerting and providing prompt [

instructions to the public within the plume exposure pathway. [5]

10. The public ANS meets the design requirements of FEMA-REP-1 0, Guide for Evaluation of Alert and D]

Notification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANS design report and supporting FEMA approval letter. [5]

11. Systems are established for prompt communication among principal emergency response D]

organizations. [6]

12. Systems are established for prompt communication to emergency response personnel. [6] D]

13. Emergency preparedness information is made available to the public on a periodic basis within the D]

plume exposure pathway emergency planning zone (EPZ). [7]

14. Coordinated dissemination of public information during emergencies is established. [7] [

15. Adequate facilities are maintained to support emergency response. [8] [

16. Adequate equipment is maintained to support emergency response. [8] D]

17. Methods, systems, and equipment for assessment of radioactive releases are in use. [9] Lii

18. A range of public PARs is available for implementation during emergencies. [10] D]

19. Evacuation time estimates for the population located in the plume exposure pathway EPZ are [

available to support the formulation of PARs and have been provided to State and local governmental authorities. [10]

20. A range of protective actions is available for plant emergency workers during emergencies, including []

those for hostile action events.[10]

21. The resources for controlling radiological exposures for emergency workers are established. [11] D]

22. Arrangements are made for medical services for contaminated, injured individuals. [12] LI

23. Plans for recovery and reentry are developed. [13] LI

24. A drill and exercise program (including radiological, medical, health physics and other program LI areas) is established. [14] ___

25. Drills, exercises, and training evolutions that provide performance opportunities to develop, LI EN-EP-305 REV 3

Ir I IIIIII . ... ii prl I II iii i ATTACHMENT 9.1 I10CFR5O.54(q) SCREENING SHEET 3 OF 3 ProcedurelDocument Number: EP-IP-31 0 Revision: 10 Equlpment/FacilitylOther: Pilgrim Nuclear Power Station

Title:

Offsite Monitoring Team Activation and Response maintain, and demonstrate key skills are assessed via a formal critique process in Order to identify weaknesses. [14]

286. Identified weaknesses are corrected. [14] [

27. Training is provided to emergency responders. (15] LI

28. Responsibility for emergency plan development and review is established. [16] [

29. Planners responsible for emergency plan development and maintenance are properly trained. [16] ____

APPLICABILITY CONCLUSION x If no Part V criteria are checked, a 50.54(q)(3) Evaluation is NOQT. required; document the basis for conclusion below and complete Part VI.

0 If any Part V criteria are checked, complete Part VI and perform a 50.54(q)(3) Evaluation.

BASIS FOR CONCLUSION The change made to this procedure was a non-intent revision made to clarify wording regarding the placement of the detector when performing iodine Cartridge Field Analysis. This change does not change intent, facilities, equipment or processes for this procedure or affect any planning standard elements. This revision does not affect the Emergency Plan. No further eval atlo Is required for this change.

Part VI. Signatures: _______________

Preparer Name (Print)Dae Karen Sullivan /El roni ignature 1211712015 (Optional) Reviewer Name (Print) eve Signature Date:

Reviewer Name (Print) ReviewerjS Ignature Date: , ,

Nuclear EP Project Manager 1 Approver Name (Print) SigatreDate,:**/7

• Donna Calabrese / --

EP manager or designee EN-EP-305 REV 3

'~' n teigj{600 EntegyiNuclear OPoerSationsIc Rocky Hill Road PyotMA 02360 January 12, 2016 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Emergency Plan Implementing Procedure Revision Pilgrim Nuclear Power Station Docket No. 50-293 License No. DPR-35 LETTER NUMBER: 2.16.002

Dear Sir or Madam:

" In accordance with 10 Code of Federal Regulations (CFR) 50.4, Entergy Nuclear Operations, Inc. is providing the latest revision to the Entergy EP-IP-310. The procedure revisions were reviewed in accordance with 10 CFR 50.54(q). The 50.54(q) reviews are also provided in the letter attachment.

The PNPS Emergency Plan continues to meet the planning standards outlined in 10 CER 50.47, the effectiveness of the emergency plan is not reduced, and the changes did not require prior U.S. Nuclear Regulatory Commission approval.

If you have any questions or require additional information, please contact me at (508) 830-8227.

There are no commitments contained in this letter.

-Donna Calabrese Emergency Planning Manager KLS/jc

Attachment:

Entergy Nuclear Operations,Inc. Letter No. 2.16.002 Pilgrim Nuclear Power Station Page 2 cc:

Director of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555 U.S. Nuclear Regulatory Commission Region 1 - Incident Response Center 2100 Renaissance Blvd., Suite 100 King of Prussia, PA 19406-2713 NRC Resident Inspector Pilgrim Nuclear Power Station

Attachment 1 Letter Number 2.16.002 EP-IP-310, Offsite Monitoring Team Activation and Response, Revision 10 and associated 10 CFR 50.54(q) Review

PNPS NON-QUALNTY EP-IP-310 Revision 10 EMERGENCY,;*RELATED MPLAMNTING _____

PROCEDURE~SG REFERENCE USE Page 1 of 17 Offsite Monitoring Team Activation And Response RTYPE H8.24 Offsite Monitoring Team Activation And Response Change Statement (a) Clarify wording regarding placement of detector when performing Iodine Cartridge Field Analysis.

Page 9.

ii!*EERENY PNPS NON-QUALITY EP-IP-310 Revision 10 EMERGENCY RELATED E ray bY' PLAN__

IMPLEMENTING PROCEDURES REFERENCE USE Page 2 of 17

........... ..Offsite Monitoring Team Activation And Response TABLE OF CONTENTS Section Title P~

1.0 PURPOSE ............................................................................. 3

2.0 REFERENCES

........................................................................ 3 3.0 DEFINITIONS.......................................................................... 3 4.0 RESPONSIBILITIES .................................................................. 3 5.0 DETAILS................................................................................ 4 5.1 PRECAUTIONS AND LIMITATIONS ................................................ 4 5.2 PROCEDURE.......................................................................... 4 5.2.10OMT Activation ........................................................................ 4 5.2.2 Equipment Checks And Inventory.................................................... 4 5.2.30Offsite Monitoring...................................................................... 6 5.2.4 Surveys ................................................................................. 7 5.2.5 Team Deactivation ................................................................... 10 6.0 INTERFACES ........................................................................ 11 7.0 RECORDS............................................................................ 11 8.0 REQUIREMENTS AND COMMITMENTS......................................... 11 9.0 ATTACHMENTS ..................................................................... 11 ATTACHMENT 9.1 OMT EQUIPMENT CHECKLIST ................................. 12 ATTACHMENT 9.2 OMT VEHICLE/COMMUNICATIONS CHECKLIST............. 14 ATTACHMENT 9.3 OMT SAMPLE/SURVEY SHEET ................................. 15 ATTACHMENT 9.4 DOCUMENT CROSS-REFERENCE ............................. 17

PNPSNNQULTEPI-0

• i:; EMERGENCY NNUATYP--30Revision 10 PLAN

• "*RELATED Efeg VPROEDUENSN REFERENCE USE Page 3 of 17 Offsite Monitoring Team Activation And Response 1.0 PURPOSE This Procedure provides instructions to Offsite Monitoring Team (OMT) members assigned to the Emergency Operations Facility (EOF). The OMTs will ascertain the radiological conditions in the environment during an emergency situation. The survey results obtained will help to determine and verify the protective action recommendations for the general public.

2.0 REFERENCES

[1] EP-PP-01, "PNPS Emergency Plan" 3.0 DEFINITIONS None 4.0 RESPONSIBILITIES

[1] The Offsite Monitoring Team (OMT) Coordinator is responsible for:

(a) Dispatching and directing the Offsite Monitoring Teams.

(b) Reporting directly to the Radiological Assessment Coordinator (RAC) all survey and sample results obtained by the OMTs.

[2] The Offsite Monitoring Teams (OMTs) are responsible for:

(a) Directly monitoring radiological conditions in the environs as directed by the OMT Coordinator.

5.0 DETAILS 5.1 PRECAUTIONS AND LIMITATIONS None 5.2 PROCEDURE 5.2.10OMT Activation When the Emergency Operations Facility (EOF) is to be activated, upon arrival the Radiological Monitoring Teams shall:

[1] Obtain team assignments and designation from the OMT Coordinator. If the Rad Lab and OMT Coordinator is not present, pair up in RP Monitor/Driver Teams.

[2] Sign in on the EOF manpower status board.

[3] Obtain an OMT procedure packet from the procedure cabinet.

[4] When all checks and inventories according to Section 5.2.2 have been completed, report to the OMT Coordinator for the dispatch briefing.

NOTES

1. The key to the Field Logistics area is located in the key box outside the door. The combination to the padlock is 000.

2. The keys to the OMT vehicles are located in the key box inside the security area.

5.2.2 Equipment Checks And Inventory

[1] Instrument Checks (a) Obtain a set of instruments.

(b) Perform the necessary instrument checks. Conduct physical checks, calibration checks, battery checks, and source checks as appropriate.

(c) Verify operability of each type of air sampler.

(d) Record the equipment checks as listed on Attachment 9.1 (OMT Equipment Checklist).

PNPSNO-ULT

,,::**:*;*EMERGENCY REL-QALTEPI-30Rviin1

• • ._E"PLAN _____E

• t~er"g/ IMPLEMENTING PROCEDURES REFERENCE USE Page5 of 1 Offsite Monitoring Team Activation And Response

[2] Field Kit Checks (a) Obtain an OMT field kit from the Field Logistics area.

(b) If the seal on the kit has been broken, then inventory the field kit.

(c) Obtain a package of silver zeolite cartridges from the cabinet in the Field Logistics area.

(d) Synchronize watches with the EOF clock.

(e) Distribute thermoluminescent dosimetry (TLD) and self-indicating dosimetry (SID) to each team member.

(f) Record name and Social Security number on the TLD. Don the TLD.

(g) Zero and don the SID.

(h) Record the results of the field kit inventory on Attachment 9.1 (OMT Equipment Checklist) (inventory is "SAT" if seal is intact).

[3] Vehicle Checks (a) Obtain a set of keys for an OMT vehicle.

(b) Perform the vehicle checks in accordance with Attachment 9.2 (OMT Vehicle/Communications Checklist).

[4] Communications Checks (a) Obtain a portable radio from the Field Logistics area.

(b) Verify communications with the EOF by testing the equipment listed on Attachment 9.2 (OMT Vehicle/Communications Checklist).

PNPSNNQALT PI3O

• • .EMERGENCY ONUAIYpl-30Revision 10 i:"*'***;*PLANRELATED

• • Enterg*y JMPLEMENTING PROCEDURES REFERENCE USE Page 6 of 17 Offsite Monitoring Team Activation And Response NOTE OMTs are not to proceed from the EOF without a full briefing by the OMT Coordinator or Radiological Assessment Coordinator.

5.2.30Offsite Monitoring

[1] Continuously observe radiation levels while traveling.

[2] While operating inside a radiation field, periodically check the SID reading. If it becomes necessary to rezero the SID, ensure the final and new initial values are reported to the OMT Coordinator.

[3] Boundary information on the leading edge, trailing edge, and outer edges of the plume should be relayed to the OMT Coordinator when available.

PMRGNPS NON-QUALITY EP-IP-310 Revision 10 EMERGENCY *RELATED EtPLAN___

L'nir ) IMPLEMENTING PROCEDURES REFERENCE USE Page7 of 1 Offsite Monitoring Team Activation And Response 5.2.4 Surveys

[2] Surveys taken in the early stages of an accident will be primarily involved with plume assessment and tracking.

NOTE Radiation and airborne surveys reported to the ECE for use in dose assessment should be centerline values. Survey data reported to the EOF is recorded on Attachment 9.3 (OMT Sample/Survey Sheet).

[3] Radiation Surveys (a) Using the dose rate meter, perform and record the survey at waist level with the beta window closed.

(b) Using the dose rate meter, perform and record the survey at waist level with the beta window open.

(c) Using the dose rate meter, perform and record the survey at ground level with the beta window closed.

(d) Using the dose rate meter, perform and record the survey at ground level with the beta window open.

(e) Report radiation levels to the OMT Coordinator. Record all information on Attachment 9.3 (OMT Sample/Survey Sheet).

PNPSNOQULTEPI-1

... *:, EMERGENCY NOELQALTEDP-P- Revision 10 PLAN ______-____R__LATE _

Ent!erg IMPLEMENTING PROCEDURES REFERENCE USE Page 8 of 17 Offsite Monitoring Team Activation And Response

[4] Airborne Surveys (a) Load a silver zeolite cartridge, arrow pointing in the direction of the air flow, into the sample apparatus.

(b) Place the air sampler 3 to 4 feet off the ground.

NOTE Exceeding a 2 SCFM flow rate may give erroneous iodine concentration levels.

(c) Draw a 20 cu. ft. air sample (2 SCFM for 10 minutes) unless otherwise directed by the EOF.

(d) Continue to monitor radiation levels while sampling. Record and report any significant changes.

(e) After the sample has been obtained, record the start time, stop time, and sample flow rate on Attachment 9.3 (OMT Sample/Survey Sheet).

(f) Proceed to an area of low background for counting of the sample. Monitor and report radiation levels while tracking plume boundaries.

(g) Particulate Filter Field Analysis (1) Determine background using a count rate meter with an HP-210 probe (or equivalent).

(2) Count the particulate filter.

(3) Store the particulate filter in a sealed petri dish. Mark the dish with the appropriate sample number and record all information on Attachment 9.3 (OMT Sample/Survey Sheet).

PNPSNOQULTEPI-1

• !:iEMERGENCY NNUATYE-P30Revision 10

",'.*:.:*RELATED

-~Etr PLAN_______

• iMPLEMENTING PROCEDURES REFERENCE USE Page 9 of 17 Offsite Monitoring Team Activation And Response (h) Iodine Cartridge Field Analysis (1) Connect the Nat probe to the E-600 (or equivalent).

(2) Turn the function switch to the scaler position.

NOTE Avoid using the E-600 in high background locations (e.g., 2 to 5 mR/hr). The OMT Coordinator is to be contacted if background count rates exceed 40,000 cpm for a 1-minute count time.

OMT Coordinator should recommend another counting location (i.e., one with a lower background).

(3) Perform a 1-minute background count by pressing the "," button located on the E-600 handle.

(4) Place the iodine cartridge in a sample bag and record its dose rate.

(5) Place the detector on top of the sample with the flow arrow *pointing away from the detector face (6) Count the sample for 1 minute by pressing the "*" button.

(7) Remove and label the sample. Record all information on Attachment 9.3 (OMT Sample/Survey Sheet).

(8) Perform another background count by pressing the "*" button. Notify the EOF if background has changed by more than a factor of two. Recount the sample and verify background as directed by the EOF.

(i) Record all data on Attachment 9.3 (OMT Sample/Survey Sheet) and report the results to the OMT Coordinator.

PNPSNN-ULTEPI-0

,;- EMERGENCY ONUATYP--30Revision 10

! PLAN RELATED nnC/,i"r " IMUPLEMENTING PROCEDURES REFERENCE USE Page 10 of 17 Offsite Monitoring Team Activation And Response 5.2.5 Team Deactivation When told to deactivate by the OMT Coordinator, the OMTs shall:

[1] Return to the EOF and transfer all samples to the OMT Coordinator.

NOTE Vehicle air cleaners could have high dose rates.

[2] Survey the OMT vehicles. Pay particular attention to the wheel wells, air cleaner, and door handles.

[3] Remove any anti-contamination clothing (as applicable) and perform a whole body frisk.

[4] Report any contamination found to the OMT Coordinator and await further instructions.

[5] Debrief with the OMT Coordinator. Ensure at least the following is done:

(a) All survey records are turned in.

(b) All checks and inventories are turned in.

(c) Any procedural problems are reported.

(d) Any equipment problems are reported.

(e) All applicable exposure records are correct and current.

[6] Inventory and restock the field kits.

[7] Clean out the OMT vehicles and refill the fuel tank.

PNPSNO-ULT

• i;!**EMERGENCY N-UATYEP-IP-310 Revision 10

• Er~t PLANRELATED 8)'oIMPLEMENTJNG PROCEDURES REFERENCE USE Page 11 of 17 Offsite Monitoring Team Activation And Response 6.0 INTERFACES None 7.0 RECORDS The following documents are generated as a result of the implementation of this Procedure:

o OMT Equipment Checklist o OMT Vehicle/Communications Checklist o OMT Sample/Survey Sheet The completed documents are to be turned in to the OMT Coordinator in the EOF.

8.0 REQUIREMENTS AND COMMITMENTS None 9.0 ATTACHMENTS 9.1 OMT EQUIPMENT CHECKLIST 9.2 OMT VEHICLE/COMMUNICATIONS CHECKLIST 9.3 OMT SAMPLE/SURVEY SHEET 9.4 DOCUMENT CROSS-REFERENCE

"PNPSNN-ULT

,***EMERGENCY REL-QALETY EP-IP-310 Revision 10

"-:4;*?*T PLAN _____ED izirherg,*'*y IMPLEMENTING{________________

PROCEDURES REFERENCE USE Page 12 of 17 Offsite Monitoring Team Activation And Response ATTACHMENT 9.1 OM~T EQUIPMENT CHECKLIST Sheet 1 of 2 TEAM: DATE:

TEAM MEMBERS:

Ion Chamber Dose Rate Meter Type:, Type: _____

Serial No.: ____________ Serial No.: ___

Cal Due:________ ___ Cal Due:____

Source Check:___ ______ Source Check: _

Beta Corr. Factor:________

Analyzer with Nal probe Count Rate Meter Type: Type:_____

Serial No.:_______ _____ Serial No.:

Cal Due:_________ ___ Cal Due:____

Efficiency: _________ Source Check:

HP-210 Probes (2).

Serial No.:____________ Serial No.

Cal Due: ___________ Cal Due:

RENSNO-ULITYD EP=IP-3t 0 Revision 10

ETteFO/.IMPLEMENTINGPA PROCEDURES REFERENCE USE Page 13 of 17

, Offsite Monitoring Team Activation And Response ATTACHMENT 9.1 OM~T EQUIPMENT CHECKLIST Sheet 2 of 2 Air Sampler Air Sampler Type: _____________Type: ____________

Serial No.: _______ _____ Serial No.:____________

Cal Due: ____________Cal Due: ____________

Instrument Check(s): __________________(SAT/U NSAT)

Kit Inventory: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __(SAT/U NSAT)

Comments:

ATTACHMENT 9.2 OMT VEHICLE/COM~MUNICATIONS CHECKLIST Sheet I of 1 TEAM:____ __

DATE:

Vehicle No.:______

Fuel Level (fill if < 1/2) (Check)

Vehicle Lights (Operates)

Spotlights (Operates)

Emergency (Strobe) Lights (Operates)

Power Inverter (Operates)

Spare Tire (Check)

Tow Strap (Available)

Condition of Tires (Sat/Unsat)

Jump Battery or Cables (Available)

Communications Vehicle Radio (Operates)

Portable Radio (Operates)

Cellular Telephone (Operates)

Vehicle Check: (Sat/Unsat)

Communications Check: (Sat/U nsat)

COMMENTS:

PNP..ON-QULITYEP-IP-310

• .;***EMERGENCY REL-ALTEY Revision 10 PLAN gYt

<f'*'"Enteyoy IMPLEMENTING _______

PROCEDURES REFERENCE USE Page 15 of '17 Offsite Monitoring Team Activation And Response ATTACHMENT 9.3 OM~T SAMPLE/SURVEY SHEET Sheet 1 of 2 TEAM: ____

DATE:

Sample No.: ___

Detailed Location:_

Distance from Plant: ____

____ ____miles Radiation Survey Survey Time: A)

Dose Rate (Closed Window waist high): B) mR/h, r Dose Rate (Open Window waist high): C) r mR/hi Dose Rate (Closed Window 2" off ground): D) mRlhi r

Dose Rate (Open Window 2" off ground): E) mR/hr Airborne Activity Survey Sample Start Time: F)

Sample Stop Time: G)

Sample Flow Rate: H) CFM Cartridge Dose Rate: mR/hr I)

ATTACHMENT 9.3 OM~T SAMPLE/SURVEY SHEET Sheet 2 of 2 Frisker

Background:

J) __________cpm Particulate Filter Count Rate: K) __________cpm Initial E-600/Nal

Background:

L) __________cpm Iodine Cartridge Count Rate: M) _______cpm Final E-600/Nal

Background:

N) _ _ _ _ _ _ _ _cpm E-600/Nal Probe Efficiency: 0) __________cpm/dpm (fractional value)

COMMENTS:

Note if survey/sample was not taken at plume centerline or large variances in background occurred while sampling.

PNPSNO-ULTEPI-1 EMERGENCY ONQAIYE-P30Revision 10

Ente

"*: ii~i~i *'*RELATED

• !*; r~o PLAN

.IMPLEMENTING _______

PROCEDURES REFERENCE USE Page 17 of 17 Offaite Monitoring Team Activation And Response ATTACHMENT 9.4 DOCUMENT CROSS-.REFERENCE Sheet 1 of 1 This Attachment lists those documents, other than References, which may be affected by changes to this Procedure.

Document Number Document Title EP-IP-260 EOF Operations

ATTACHMENT 9.1 10OCFR50.54(q) SCREENING SHEET 1 OF 3 ProcedurelDocument Number: EP-IP-31 0 Revision: 10 EquipmentlFacilitylOther: Pilgrim Nuclear Power Station

Title:

Offsite Monitoring Team Activation and Response Part I. Description of Activity Being Reviewed (event or action, or series of actions that may result in a change to the emergency plan or affect the implementation of the emergency plan):

This non-intent change to this procedure revised the wording: "Place the sample bag next to the detector ensuring that the flow arrow is pointing away from the face of detector." to read: "Place the detector on top of the sample with the flow arrow pointing away from the detector face."

Part II. Activity Previously Reviewed? [-YES 5o.54(q)(3)

[]NO Continue to Is this activity fully bounded by an NRC approved 10 CFR 50.90 submittal or Alert and Notification System Design Report? Evaluation is next part NOT required.

Enter If YES, identify bounding source document number/approval reference and justification ensure the basis for concluding the source document fully bounds the below and proposed change is documented below: complete Part VI.

Justification:

El Bounding document attached (optional)

Part III. Applicability of Other Regulatory Change Control Processes Check if any other regulatory change processes control the proposed activity.(Refer to EN-LI-100)

NOTE: For example, when a design change is the proposed activity, consequential actions may include changes to other documents which have a different change control process and are NOT to be included in this 50.54(q)(3)

Screening.

APPLICABILITY CONCLUSION

[] Ifthere are no controlling change processes, continue the 50.54(q)(3) Screening.

El One or more controlling change processes are selected, however, some portion of the activity involves the emergency plan or affects the implementation of the emergency plan; continue the 50.54(q)(3) Screening for that portion of the activity. Identify the applicable controlling change processes below.

El One or more controlling change processes are selected and fully bounds all aspects of the activity. 50.54(q)(3)

Evaluation is NOT required. Identify controlling change processes below and complete Part VI.

CONTROLLING CHANGE PROCESSES 10OCFR50.54(q)

Part IV. Editorial Change Li]YES 50.54(q)(3)

[]NO Continue to next Is this activity an editorial or typographical change such as formatting, paragraph Evaluation is part numbering, spelling, or punctuation that does not change intent. No NOT required.

Justification: Enter justification and complete Part VI.

EN-EP-305 REV 3

ATTACHMENT 9.1 10CFR50.54(q) SCREENING SHEET 2 OF 3 Procedure/Document Number: EP-IP-310 Revision: 10 Equipment/Facility/Other: Pilgrim Nuclear Power Station

Title:

Offsite Monitoring Team Activation and Response Part V. Emergency Planning Element/Function Screen (Associated 10 CFR 50.47(b) planning standard function identified in brackets) Does this activity affect any of the following, including program elements from NUREG-0654/FEMA REP-i Section I1?

1. Responsibility for emergency response is assigned. [1] _____

2. The response organization has the staff to respond and to augment staff on a continuing basis (24/7 []

staffing) in accordance with the emergency plan. [1]

3. The process ensures that on shift emergency response responsibilities are staffed and assigned. [2] Iii

4. The process for timely augmentation of onshift staff is established and maintained. [2] D]

5. Arrangements for requesting and using off site assistance have been made. [3] [

6. State and local staff can be accommodated at the EOF in accordance with the emergency plan. [3] [

7. A standard scheme of emergency classification and action levels is in use. [4] [

8. Procedures for notification of State and local governmental agencies are capable of alerting them of D]

the declared emergency within 15 minutes after declaration of an emergency and providing follow-up notifications. [5]

9. Administrative and physical means have been established for alerting and providing prompt [

instructions to the public within the plume exposure pathway. [5]

10. The public ANS meets the design requirements of FEMA-REP-1 0, Guide for Evaluation of Alert and D]

Notification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANS design report and supporting FEMA approval letter. [5]

11. Systems are established for prompt communication among principal emergency response D]

organizations. [6]

12. Systems are established for prompt communication to emergency response personnel. [6] D]

13. Emergency preparedness information is made available to the public on a periodic basis within the D]

plume exposure pathway emergency planning zone (EPZ). [7]

14. Coordinated dissemination of public information during emergencies is established. [7] [

15. Adequate facilities are maintained to support emergency response. [8] [

16. Adequate equipment is maintained to support emergency response. [8] D]

17. Methods, systems, and equipment for assessment of radioactive releases are in use. [9] Lii

18. A range of public PARs is available for implementation during emergencies. [10] D]

19. Evacuation time estimates for the population located in the plume exposure pathway EPZ are [

available to support the formulation of PARs and have been provided to State and local governmental authorities. [10]

20. A range of protective actions is available for plant emergency workers during emergencies, including []

those for hostile action events.[10]

21. The resources for controlling radiological exposures for emergency workers are established. [11] D]

22. Arrangements are made for medical services for contaminated, injured individuals. [12] LI

23. Plans for recovery and reentry are developed. [13] LI

24. A drill and exercise program (including radiological, medical, health physics and other program LI areas) is established. [14] ___

25. Drills, exercises, and training evolutions that provide performance opportunities to develop, LI EN-EP-305 REV 3

Ir I IIIIII . ... ii prl I II iii i ATTACHMENT 9.1 I10CFR5O.54(q) SCREENING SHEET 3 OF 3 ProcedurelDocument Number: EP-IP-31 0 Revision: 10 Equlpment/FacilitylOther: Pilgrim Nuclear Power Station

Title:

Offsite Monitoring Team Activation and Response maintain, and demonstrate key skills are assessed via a formal critique process in Order to identify weaknesses. [14]

286. Identified weaknesses are corrected. [14] [

27. Training is provided to emergency responders. (15] LI

28. Responsibility for emergency plan development and review is established. [16] [

29. Planners responsible for emergency plan development and maintenance are properly trained. [16] ____

APPLICABILITY CONCLUSION x If no Part V criteria are checked, a 50.54(q)(3) Evaluation is NOQT. required; document the basis for conclusion below and complete Part VI.

0 If any Part V criteria are checked, complete Part VI and perform a 50.54(q)(3) Evaluation.

BASIS FOR CONCLUSION The change made to this procedure was a non-intent revision made to clarify wording regarding the placement of the detector when performing iodine Cartridge Field Analysis. This change does not change intent, facilities, equipment or processes for this procedure or affect any planning standard elements. This revision does not affect the Emergency Plan. No further eval atlo Is required for this change.

Part VI. Signatures: _______________

Preparer Name (Print)Dae Karen Sullivan /El roni ignature 1211712015 (Optional) Reviewer Name (Print) eve Signature Date:

Reviewer Name (Print) ReviewerjS Ignature Date: , ,

Nuclear EP Project Manager 1 Approver Name (Print) SigatreDate,:**/7

• Donna Calabrese / --

EP manager or designee EN-EP-305 REV 3