ML032721601

Emergency Plan for the Exelon Generation Company, LLC Early Site Permit, Chapter 10 Through Appendiix C, References

ML032721601
Person / Time
Site:	Clinton, 05200007, PROJ0718
Issue date:	09/25/2003
From:	Exelon Generation Co, Exelon Nuclear
To:	Office of New Reactors
Shared Package
ML032721596	List: ML032721594 ML032721599 ML032721600 ML032721601 ML032721602 ML032721603 ML032721604 ML032721605 ML032721606 ML032721607 ML032721608 ML032721609 ML032721610 ML032721611 ML032721613 ML032721615 ML032721617 ML032721619 ML032721620 ML032721621 ML032730608 ML032730609 ML032730610 ML032730612 ML032730613 ML032730614 ML032730615 ML032730616 ML032730617 ML032730618 ML032730619
References
+ReviewedClintonESP, +reviewednvg DEL-096-REV0
Download: ML032721601 (119)

Text

CHAPTER 10 Protective Response The protective response information in this chapter is presented in the following sections:

• Notification of On-Site Personnel (Section 10.1)

• Protective Action Recommendation (Section 10.2)

• Monitoring of Evacuees (Section 10.3).

Protective response consists of emergency actions, taken during or after an emergency situation, which are intended to minimize or eliminate hazards to the health and safety of the public and/or facility personnel. A range of protective actions has been developed for emergency workers and the general public in the plume exposure pathway EPZ.

Additionally, guidelines have been established to aid in choosing protective actions during an emergency that are consistent with federal guidance. The information in this chapter is based on and consistent with the Exelon Nuclear Standardized Radiological Emergency Plan (EGC, 2003). The Applicant will be responsible for on-site actions, while the responsibility for off-site actions will belong to the state, county, and other off-site response agencies (State of Illinois, 2001).

DEL-096-REV0 10-1

CHAPTER 10 - PROTECTIVE RESPONSE EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT SECTION 10.1 - NOTIFICATION OF ON-SITE PERSONNEL 10.1 Notification of On-Site Personnel For all emergency classifications at the EGC ESP Site, all personnel within the protected area will be notified within 15 minutes of the initial classification or escalation of an emergency by recognizable alarms and/or verbal announcements over the plant PA system (see Section 5.2.1). Announcements will include the emergency classification and response actions to be taken by personnel on site, such as ERO, non-ERO, contractor personnel, and visitors.

Provisions will be made to alert personnel in high noise areas and outbuildings within the protected area as applicable. Each facility will identify locations where people might be expected to be present outside the protected area but within the owner-controlled area.

Accountability of persons within the owner controlled area, but outside the protected area, is not required. However, provisions will be established for notification of personnel within the owner-controlled area, including high noise areas and outbuildings within the Protected Area.

10.1.1 Evacuation Locations If a site evacuation is required, non-essential personnel will be directed to either assemble at the designated assembly areas or immediately evacuate the site. Following assembly, personnel will be directed to either proceed to their homes or reassemble off site at designated relocation centers. Visitors to the facility will assemble with and follow the instructions of their escorts. Non-essential personnel within the protected area will normally exit through the security building. Personal transportation, if available, will normally be used, and established evacuation routes will be followed. Personnel without transportation will be identified and provided transportation as necessary.

10.1.2 Radiological Monitoring of Evacuees Personnel evacuating the site will be monitored for contamination by the portal monitors as they exit the protected area, with portable friskers in the assembly areas, or sent to off-site monitoring locations on an as-needed basis.

10.1.3 Evacuation Evacuation is the primary protective action anticipated for on-site personnel not having emergency response assignments. The EGC ESP Facility will choose locations to serve as on-site assembly areas for all personnel and off-site relocation centers for non-essential personnel when they are not instructed to proceed home. The specific locations of these areas are shown in Figure 2.2-1. Implementing procedures will describe equipment, supplies, and general operation of these facilities. Personnel known to be within the site boundary will be judged as essential or non-essential personnel by the Station Emergency Director. If conditions permit, evacuation of non-essential personnel will be conducted immediately after accountability if a site area emergency or general emergency has been declared. Evacuation routes are shown in Figure 2.2-1 and Figure 2.3-1. Evacuation will commence in accordance with future EGC ESP Facility procedures as directed by the Station Emergency Director or his/her designee, unless one of the following conditions exist (see Section 3.3.5.1.2):

• Severe weather conditions threaten safe transport; DEL-096-REV0 10.1-1

CHAPTER 10 - PROTECTIVE RESPONSE SECTION 10.1 - NOTIFICATION OF ON-SITE PERSONNEL EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT

• A significant radiological hazard would be encountered;

• There is a security threat occurring that would have an adverse impact on the personnel while leaving the site; and/or

• A condition similar to these in magnitude, which, in the opinion of the Station Emergency Director, would adversely affect the site personnel.

Security forces will be dispatched, when available, to access road(s) in order to control entry to site facilities. Unauthorized and non-ERO personnel will be denied entry. In addition, the initiation of a site evacuation will be reported to the appropriate state/local agency.

10.1.4 Accountability The Station Emergency Director will initiate assembly and accountability procedures whenever it is deemed necessary (see Section 3.3.5.1.2). The purpose of the assembly will be to account for all personnel inside the protected area, and to gather emergency personnel at prearranged locations.

A site assembly with accountability will be required to be initiated whenever a site area emergency or higher level event is declared. The movement of personnel for the purposes of accountability may be delayed if their health and safety could be in jeopardy, such as severe weather or for security reasons.

If it is determined that the prearranged assembly area is unfit for personnel, the Station Emergency Director may designate an alternative site assembly area and assemble personnel using appropriate communication systems that are available.

When accountability of on-site personnel is determined necessary by the Station Emergency Director, then all personnel within the protected area shall be accounted for, and the names of missing individuals will be ascertained within 30 minutes of announcing the assembly.

Once established, accountability within the protected area will be maintained throughout the course of the event. If missing personnel are identified, search and rescue operations will be initiated.

10.1.5 Provisions for On-Site Personnel The Applicant will maintain an inventory of respiratory protection equipment, anti-contamination clothing, and KI that will be made available to emergency workers remaining on site should conditions warrant. During the course of an emergency, protective actions will be considered to minimize radiological exposures or contamination problems associated with all on-site personnel. For those who must work within the restricted area of the EGC ESP Site, measures will be considered and are described in the following sections.

10.1.5.1 Use of Respirators On-shift and emergency response personnel will use respiratory protection in any environment involving exposure to high-level gaseous activity, an oxygen deficient atmosphere, or where air quality is in doubt. In the presence of airborne particulates, emergency response personnel may be directed by health physics personnel to use full-face 10.1-2 DEL-096-REV0

CHAPTER 10 - PROTECTIVE RESPONSE EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT SECTION 10.1 - NOTIFICATION OF ON-SITE PERSONNEL filter type respirators. The criteria for issuance of respiratory protection will be described in the EGC ESP Facility RP procedures (see Section 11.2).

10.1.5.2 Use of Protective Clothing Anti-contamination clothing, located in the TSC, OSC, and facility dress out areas is available for use by on-site personnel. The criteria for issuance of protective clothing will be described in the EGC ESP Facility RP procedures.

10.1.5.3 Use of Potassium Iodide The use of KI may be recommended when a projected dose of 50 rem committed dose equivalent (CDE) is exceeded for an emergency workers thyroid. This is the value specified by USEPA-400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents (USEPA, 1992). The EGC ESP Facility will be responsible for maintaining a supply of KI. The Station Emergency Director will have the responsibility for approval of issuing KI to the Applicant's emergency workers (see Section 3.3.4).

10.1.6 Mechanism for Implementing Protective Action Recommendations Plant conditions, projected dose and dose rates, and/or field monitoring data will be evaluated to develop PARs for the purpose of preventing or minimizing exposure to the general public. The PARs will be made to the off-site agencies responsible for implementing protective actions for the general public within the 10-mi EPZ, and will be approved by the Emergency Director in command and control. In an emergency that requires immediate protective actions be taken prior to activation of the emergency facilities, PARS are provided directly to the state and county 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> warning points by the Emergency Director.

10.1.7 Capability of Implementing Protective Action Recommendations Implementing protective measures, based on PAGs for the off-site population-at-risk, is the responsibility of state and local governments. Detailed procedures for public protective actions are contained in the state and local radiological emergency response plans (State of Illinois, 2001 and 2001a).

State agencies will be responsible for the evaluation of the Applicant's recommended protective actions, and for preparing a recommendation to the Governor, or his/her appointed agent. Only when the state acts under the Governors order does a recommended protective action become a directed protective action (State of Illinois, 2001).

If the plant conditions are stable and off-site radiological conditions are such that the public health and safety are not endangered, then the return to the evacuated areas may be discussed with the state. State authorities will be responsible for actually recommending return, and for transmitting this recommendation.

10.1.8 Implementation of Protective Action Recommendations This plan, as well as the state and county emergency plans used to implement the protective measures for the plume exposure pathway, takes numerous factors into consideration when determining protective actions.

DEL-096-REV0 10.1-3

CHAPTER 10 - PROTECTIVE RESPONSE SECTION 10.1 - NOTIFICATION OF ON-SITE PERSONNEL EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT 10.1.8.1 Evacuation Routes and Destinations Most of the public evacuees are expected to travel in their own vehicles, leaving the EPZ via designated evacuation routes. Figure 2.2-1 and Figure 2.3-1 show the evacuation routes and EPZ subareas. The state and county plans contain official maps and information on the locations of relocation centers (State of Illinois, 2001 and 2001a). Figure 2.3-1 shows registration and congregate care centers.

10.1.8.2 Population Distribution Population distribution for the plume exposure pathway EPZ is provided in Table 2.1-1, Table 2.3-1, Figure 2.2-2, and Figure 2.3-2.

10.1.8.3 Notification Time As indicated in Chapter 5, off-site agencies will be notified within 15 minutes of classification of an emergency. State and county agencies have the capability to notify all members of the transient and resident population within the plume exposure pathway EPZ (State of Illinois, 2001 and 2001a).

10.1-4 DEL-096-REV0

CHAPTER 10 - PROTECTIVE RESPONSE EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT SECTION 10.2 - PROTECTIVE ACTION RECOMMENDATION 10.2 Protective Action Recommendation At a general emergency classification, the Applicant will provide the State of Illinois with recommendations for protective actions for the public. For incidents involving actual, potential, or imminent releases of radioactive material to the atmosphere, USEPA-400-R 001, NUREG-0654, Supplement 3, and the USNRC Response Technical Manual (RTM-96) will be used as the basis for the general public PARs (USEPA, 1992; USNRC 1996a, and 1996b).

10.2.1 Plant-Based Protective Action Recommendations Figure 10.2-1 has been developed to aid the Applicant's personnel by providing PARs based on the above recommendations (USNRC, 1996b). The EGC ESP Facility specific PAR flowcharts will be documented in the Final Emergency Plan. These flowcharts and tables will provide technically-based PARs based on plant conditions and core damage indicators.

These flowcharts will be consistent with the Illinois Plan (State of Illinois, 2001). Possible plant-based PARs issued by the Applicant at a general emergency will include the following:

• Evacuation of the general public within a 2-mi radius and 5-mi downwind (minimum PAR issued); and

• Evacuation of the general public within a 5-mi radius and 10-mi downwind.

10.2.2 Dose-Based Protective Action Recommendation Evacuation will be recommended if projected doses reach the minimum USEPA PAGs (greater than or equal to 1 rem EPA TEDE1 or greater than or equal to 5 rem CDE Thyroid).

Many assumptions exist in dose assessment calculations, involving both source term and meteorological factors, which make computer predictions over long distances highly questionable. However, in the event dose assessment results indicate the need to recommend actions beyond the outer EPZ boundaries, that is past 10 miles, Field Monitoring Teams are dispatched to downwind areas to verify the calculated exposure rates prior to issuing PARs outside the EPZ.

Applicant personnel normally do not have the necessary information to determine whether off site conditions would require sheltering instead of evacuation. An effort to base PARs on external factors (such as road conditions, traffic/traffic control, weather, or offsite emergency response capabilities) is usually performed by the State.

1 EPA TEDE is defined as the sum of the doses from external exposure and inhalation from the plume, and from 4 days of external exposure to deposited materials.

DEL-096-REV0 10.2-1

CHAPTER 10 - PROTECTIVE RESPONSE EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT SECTION 10.3 - MONITORING OF EVACUEES 10.3 Monitoring of Evacuees The state and county organizations currently (2003) have the capability to register and monitor evacuees at designated reception centers. This capability includes personnel and equipment capable of monitoring residents and transients evacuating from the plume exposure pathway EPZ and arriving at the reception centers, in accordance with FEMA guidelines (State of Illinois, 2001).

DEL-096-REV0 10.3-1

Emergency Plan for the EGC Early Site Permit Figure 10.2-1 Generic PAR Flowchart Data Source:

USEPA, 1992 USNRC, 1996b Not to Scale

CHAPTER 11 Radiological Exposure Control The radiological exposure control information in this chapter is presented in the following sections:

• Emergency Exposure Guidelines (Section 11.1)

• Emergency Radiation Protection Program (Section 11.2).

This chapter describes the means for controlling emergency worker radiological exposures during an emergency, as well as the measures that will be used by the Applicant to provide necessary assistance to persons injured or exposed to radiation and/or radioactive materials. This information is based on and consistent with the Exelon Nuclear Standardized Radiological Emergency Plan (EGC, 2003). Exposure guidelines in this chapter are consistent with the USEPA Emergency Worker and Lifesaving Activity PAGs described in USEPA-400-R-92-001 (USEPA, 1992).

DEL-096-REV0 11-1

CHAPTER 11 - RADIOLOGICAL EXPOSURE CONTROL EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT SECTION 11.1 - EMERGENCY EXPOSURE GUIDELINES 11.1 Emergency Exposure Guidelines After being licensed by the USNRC, the EGC ESP Facility will maintain personnel exposure control programs in accordance with 10 CFR 20 under normal operating conditions. The Station Emergency Director shall have the non-delegable responsibility for authorizing personnel exposure levels under emergency conditions per USEPA Emergency Worker and Lifesaving PAGs (USEPA, 1992). In emergency situations, workers may receive exposure under a variety of circumstances in order to assure safety and protection of others and of valuable property. These exposures will be justified if the maximum risks or costs to others that are avoided by their actions outweigh the risks to which the workers are subjected. The emergency worker dose limits are provided in Table 11.1-1. Dose extensions beyond 10 CFR 20 limits must be authorized by the Emergency Director (see Section 3.3.4) (USEPA, 1992).

Whenever possible, the concurrence of the Radiation Protection Manager (RPM) should be secured before individuals are exposed to dose equivalents beyond the USEPA-400 lower limit.

DEL-096-REV0 11.1-1

CHAPTER 11 - RADIOLOGICAL EXPOSURE CONTROL EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT SECTION 11.2 - EMERGENCY RADIATION PROTECTION PROGRAM 11.2 Emergency Radiation Protection Program The TSC RPM will be the individual responsible for the implementation of the RP actions during an emergency (see Section 3.3.5.1.9). RP guidelines are described below.

• Volunteers over 45 years of age will be considered first for any emergency response action requiring exposure greater than normal limits. Routine dose limits shall not be extended to emergency dose limits for declared pregnant individuals. As in the case of normal occupational exposure, doses received under emergency conditions should be maintained as low as reasonably achievable.

• Persons undertaking any emergency operation in which the dose will exceed 25 rem TEDE shall do so only on a voluntary basis and with full awareness of the risks involved.

This includes the numerical levels of dose in which acute effects of radiation will be incurred and the numerical estimates of the risk of delayed effects.

• In the context of the emergency limits, exposure to workers that is incurred for the protection of large populations may be considered justified for situations in which the collective dose avoided by the emergency operation is significantly larger than that incurred by the workers involved.

• Exposure accountability will be maintained and proper personnel radiological monitoring equipment will be provided for all personnel during emergency conditions.

• Access to high radiation areas will be only permitted with prior approval of the applicable RPM. In addition, personnel will not be allowed to enter known or potentially high radiation areas unless their exposure has been properly evaluated.

• Periodic habitability surveys of emergency facilities will be performed during an emergency. If the facility is determined to be uninhabitable, the facility will be evacuated in order to prevent or minimize exposure to radiation and radioactive materials. Alternate assembly areas will be established, as necessary, to relocate and monitor evacuated personnel.

11.2.1 Personnel Monitoring Emergency workers will receive TLD badges and personal self-reading dosimeters capable of measuring expected exposures on a real time basis. The capability exists for the emergency processing of TLDs on a 24-hr per day basis, if necessary (see Section 3.4.7).

In addition, emergency worker dose records will be maintained by the RPMs (as appropriate) in accordance with future emergency and radiological protection procedures.

Emergency workers will be instructed to read their dosimeters frequently, and TLDs may be processed with increased periodicity.

11.2.2 Non-Applicant Personnel Exposure Authorization The responsibility for authorizing non-Applicant emergency workers (i.e., state and local agency emergency workers) to receive exposures in excess of the USEPA general public PAGs does and will belong to the state and county organizations, except when such DEL-096-REV0 11.2-1

CHAPTER 11 - RADIOLOGICAL EXPOSURE CONTROL SECTION 11.2 - EMERGENCY RADIATION PROTECTION PROGRAM EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT emergency workers are on site. Authorization of exposures in excess of USEPA General Public PAGs, in this latter instance, will belong to the Station Emergency Director (see Section 3.3.5.1.2).

11.2.3 Contamination and Decontamination During an emergency, the Station Emergency Director will be responsible for preventing or minimizing personnel exposure to radioactive materials deposited on the ground or other surfaces. Special consideration should be given to setting up contamination control arrangements for personnel entering the OSC after completion of assigned activities.

During emergency conditions, normal plant contamination control criteria will be adhered to as much as possible. However, these limits may be modified by the applicable RPM per existing RP procedures should conditions warrant (see Section 3.3.5.1.9).

11.2.3.1 Contamination Control Means Personnel found to be contaminated will normally be attended to at decontamination areas located on site. Temporary decontamination areas can also be set up inside at various locations. Decontamination showers and supplies will be provided on site with additional personnel decontamination equipment and capabilities. Shower and sink drains in the controlled area will be routed to the miscellaneous waste processing system, where the liquid is processed and monitored prior to discharge. Potentially contaminated emergency vehicles will be surveyed before they are allowed to leave the EGC ESP Facility or off-site assembly area. If the survey area is not suitable for monitoring and decontamination due to radiological or other concerns, vehicles will be surveyed at an alternate location.

11.2.4 Contamination Control Measures Controls will be established 24-hrs per day in order to contain the spread of loose surface radioactive contamination.

Areas in the EGC ESP Facility found to be contaminated will be isolated as restricted areas with appropriate radiological protection and access control. Personnel leaving contaminated areas will be monitored to ensure they and their clothing are not contaminated. If found contaminated above acceptable levels, they will be decontaminated in accordance with future EGC ESP Facility procedures. If normal decontamination procedures do not reduce personnel contamination to acceptable levels, the case will be referred to a competent medical authority. Supplies, instruments, and equipment that are in contaminated areas or have been brought into contaminated areas will be monitored prior to removal. If found to be contaminated, they will be decontaminated using normal EGC ESP Facility decontamination techniques or may be disposed of as radwaste. Furthermore, contaminated vehicles will be decontaminated before being released.

Measures will be taken to control on-site access to potentially contaminated potable water and food supplies. Under emergency conditions when uncontrolled releases of activity have occurred, eating, drinking, smoking, and chewing will be prohibited in all Facility ERFs until such time as habitability surveys indicate that such activities are permissible.

Restricted areas and contaminated items will be returned to normal use when contamination levels have been returned to acceptable levels. Contamination control 11.2-2 DEL-096-REV0

CHAPTER 11 - RADIOLOGICAL EXPOSURE CONTROL EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT SECTION 11.2 - EMERGENCY RADIATION PROTECTION PROGRAM criteria for returning areas and items to normal use will be contained in the EGC ESP Facility procedures.

11.2.5 Decontamination of Relocated Personnel Non-essential on-site personnel may be evacuated to an off-site relocation center or assembly area. Radiological controls personnel, at that location, will monitor evacuees and determine the need for decontamination. Existing and temporary facilities to limit contamination and exposure will be utilized and established at the site as necessary during an emergency situation. In the event that decontamination of evacuees is not locally possible, personnel will be sent to designated locations for monitoring and decontamination. Provisions for extra clothing will be made and suitable decontaminates will be available for the expected type of contamination, particularly with regards to skin contamination.

DEL-096-REV0 11.2-3

CHAPTER 11 Tables TABLE 11.1-1 Emergency Exposure Guidelines Dose Limit (rem TEDE) Activity Condition 0-5 All Personnel should be kept within normal 10 CFR 20 limits during bona fide emergencies, except as authorized for activities as indicated below.

5-10 Protecting valuable property Lower dose not practicable.

10-25 Lifesaving or protection of large Lower dose not practicable.

populations

> 25 Lifesaving or protection of large Only on a voluntary basis to persons fully aware of populations the risks involved.

Source: USEPA, 1992 Note: Limit dose to the lens of the eye to 3 times the above values and doses to any other organ (including skin and other body extremities) to 10 times the above values.

DEL-096-REV0 11.T-1

CHAPTER 12 Medical and Public Health Support The medical and public health support information in this chapter is presented in the following sections:

• Off-Site Hospital and Medical Services (Section 12.1)

• On-Site First Aid Capability (Section 12.2)

• Medical Service Facilities (Section 12.3)

• Medical Transportation (Section 12.4).

This chapter describes the arrangements for medical services for contaminated injured individuals sent from the EGC ESP Facility. These arrangements are identical to those established for the CPS. This information is based on and consistent with the Exelon Nuclear Standardized Radiological Emergency Plan (EGC, 2003).

DEL-096-REV0 12-1

CHAPTER 12 - MEDICAL AND PUBLIC HEALTH SUPPORT EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT SECTION 12.1 - OFF-SITE HOSPITAL AND MEDICAL SERVICES 12.1 Off-Site Hospital and Medical Services Medical treatment given to injured persons at the EGC ESP Facility will be of a first aid nature. When more professional care is needed, injured persons will be transported to a local hospital or clinic. Hospital personnel are trained and hospitals are equipped to handle contaminated or radiation injured individuals. Specifically, training of medical support personnel at the agreement hospitals will include basic training on the nature of radiological emergencies, diagnosis and treatment, and follow-up medical care. EGC ESP Facility personnel will be available to assist medical personnel with decontamination radiation exposure and contamination control. Arrangements, confirmed by letter of agreement or contract every two (2) calendar years, will be maintained with a qualified hospital located in the vicinity of the EGC ESP Facility for receiving and treating contaminated or exposed persons with injuries requiring immediate hospital care. The Applicant will provide medical consultants to aid in any special care necessary at these facilities.

Arrangements, confirmed by letter of agreement every two or more calendar years, will also be maintained by the corporate office with a qualified major medical facility well-equipped and staffed for dealing with persons having radiation injuries. John Warner Hospital in Clinton, IL will be the primary supporting medical facility for injured persons who are contaminated with radioactivity. Whenever necessary, such persons will be transferred to this major hospital facility for extended specialized treatment (see Appendix A). The Applicant will have available to the staff of this hospital, medical consultants who will provide the direction of the special care necessary for the treatment of persons having radiation injuries (see Section 3.4.5).

DEL-096-REV0 12.1-1

CHAPTER 12 - MEDICAL AND PUBLIC HEALTH SUPPORT EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT SECTION 12.2 - ON-SITE FIRST AID CAPABILITY 12.2 On-Site First Aid Capability The EGC ESP Site will maintain on-site first aid supplies and equipment necessary for the treatment of contaminated or injured persons (NFPA, 1997). In general, physicians or nurses will not be staffed at the Applicants generating facilities, and as such, medical treatment given to injured persons will be of a first aid nature. However, each facility currently (2003) has an industrial hygiene advisor. Additionally, the RP technicians at each nuclear facility are experienced in control of radioactive contamination and decontamination work. EGC ESP Facility personnel will also be trained and qualified to administer first aid. At least two of these individuals will be available on-shift at all times.

The functions of facility personnel in handling on-site injured people will include the following:

• Afford rescue;

• Administer first aid including such resuscitative measures as are deemed necessary;

• Begin decontamination procedures; and

• Arrange for suitable transportation to a hospital when required.

Primary attention shall be directed to the actual factors involved in the treatment of casualties, such as control of bleeding, resuscitation including heart and lung, control of bleeding after resuscitation, protection of wounds from bacterial or radioactive contamination, and the immobilization of fractures.

Facility personnel will provide an initial estimate of the magnitude of surface contamination of the injured and preliminary estimates of total body dose to the injured. Primary rapid and simple decontamination of the surface of the body (when possible and advisable) before transportation to a designated hospital may be carried out as directed or performed by RP personnel. When more professional care is needed, injured persons will be transported to the John Warner Hospital in Clinton, IL, which is the primary supporting medical facility (see Appendix A).

DEL-096-REV0 12.2-1

CHAPTER 12 - MEDICAL AND PUBLIC HEALTH SUPPORT EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT SECTION 12.3 - MEDICAL SERVICE FACILITIES 12.3 Medical Service Facilities Radiation injuries involve specialized diagnosis and treatment; therefore, Exelon Corporate Emergency Preparedness maintains an agreement with the REAC/TS (see Section 3.4.5).

The REAC/TS is a radiological emergency response team of physicians, nurses, health physicists, and necessary support personnel on 24-hr call to provide consultative or direct medical or radiological assistance at the REAC/TS facility or at the accident site (see Appendix A). Specifically, the team has expertise in and is equipped to conduct medical and radiological triage; decontamination procedures and therapies for external contamination and internally deposited radionuclides including chelation therapy; diagnostic and prognostic assessments or radiation-induced injuries; and radiation dose estimates by methods that include cytogenetic analysis, bioassay, and in vivo counting.

DEL-096-REV0 12.3-1

CHAPTER 12 - MEDICAL AND PUBLIC HEALTH SUPPORT EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT SECTION 12.4 - MEDICAL TRANSPORTATION 12.4 Medical Transportation Arrangements will be made by the Applicant for prompt ambulance transport of persons with injuries involving radioactivity to designated hospitals (see Appendix A). Such service will be available on a 24-hr per day basis, and will be confirmed by letter of agreement.

Radiation monitoring services shall be provided by the Applicant whenever it becomes necessary to use the ambulance service for the transportation of contaminated persons. A qualified RP technician shall accompany the ambulance to the hospital. Additional RP technicians may be contacted and dispatched to local hospitals to assist in the monitoring and decontamination of the injured victim, hospital facilities and personnel, and ambulance facilities and personnel.

DEL-096-REV0 12.4-1

CHAPTER 13 Recovery and Re-Entry This section describes the measures to be taken for re-entry into the areas of the ESP Facility which will have been evacuated as a result of an accident. It also outlines the Applicant's recovery organization and its concepts of operations. This information is presented in the following sections:

• Re-Entry and Recovery Planning Concepts (Section 13.1)

• Recovery Organization (Section 13.2)

• Recovery Phase Notification (Section 13.3)

• Total Population Exposure (Section 13.4).

The information in the chapter is based on and consistent with the Exelon Nuclear Standardized Radiological Emergency Plan (EGC, 2003).

DEL-096-REV0 13-1

CHAPTER 13 - RECOVERY AND RE-ENTRY EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT SECTION 13.1 - RE-ENTRY AND RECOVERY PLANNING CONCEPTS 13.1 Re-Entry and Recovery Planning Concepts During an emergency, immediate actions are directed toward limiting the consequences of the accident to afford maximum protection to station personnel and the general public.

Once corrective measures have been taken and effective control of the plant has been re-established, a more methodical approach to re-entry will be taken. This Emergency Plan divides re-entry into two categories:

• Re-entry during the emergency phase of an accident is performed to save a life, control release of radioactive material, prevent further damage to plant equipment of restore plant equipment. If necessary, this category of re-entry may be performed using emergency exposure limits. Briefings, rather than written radiation protection procedures, may be used when making these entries.

All re-entry activities conducted during the emergency are authorized by the Station Emergency Director (Section 3.3.5.1.2), and coordinated by the OSC Director (Section 3.3.5.1.14) and the Radiation Protection Manager (Section 3.3.5.1.9).

• Re-entry during the recovery phase of an accident is performed using normal exposure limits. Either normal procedures or procedures that consider existing as well as potential conditions inside affected areas are developed specifically for each re-entry.

Re-entry activities during the recovery phase are authorized by the Recovery Director (Sections 13. 2.1 and 3.3.5.2.2) and coordinated by the recovery organization managers in charge of personnel making the re-entry.

13.1.1 Planning Phase The following items will be considered when planning for any re-entry:

• Review of available radiation surveillance data to determine plant areas potentially affected by radiation and/or contamination;

• Review of radiation exposure history of personnel required to participate in the accident migration or recovery operations;

• Determination of the need for additional personnel and the sources of these additional personnel;

• Review of adequacy of radiation survey, instrumentation and equipment (types, ranges, number, calibration, etc.);

• Review of non-radiological hazards and required protective measures (e.g., fire, electrical, hazardous materials);

• Pre-planning of activities and briefings for the re-entry team that include the following:

Personnel knowledge requirements; Methods and procedures that will be employed during the entry; Specific tasks to be performed; DEL-096-REV0 13.1-1

CHAPTER 13 - RECOVERY AND RE-ENTRY SECTION 13.1 - RE-ENTRY AND RECOVERY PLANNING CONCEPTS EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT Anticipated radiation and contamination levels; Radiation survey equipment and types and ranges of dosimetry required; Shielding requirements and availability; Appropriate communications; Protective clothing and equipment requirements; Access control procedures; Decontamination requirements; Debriefing requirements; and Respiratory protection.

• A review of security controls to prevent unauthorized or unintentional entry into hazardous areas.

13.1.2 Evaluating Entry into Recovery The recovery phase is that period when major repairs are being performed to return the plant to an acceptable condition and the possibility of the emergency condition degrading no longer exists. Once the plant has been stabilized, contained, and controlled, the recovery phase may be entered. It is the responsibility of the Station Emergency Director to classify recovery after obtaining authorization from the Corporate Emergency Director.

Establishment of recovery can be conducted from any emergency classification level.

However, it is possible that the lower classifications of unusual event and alert will conclude with the event being terminated (see Section 4.6). There may be cases where certain EAL initiating conditions remain exceeded, but the station is under control and no further danger of degradation exists. In such a case, it may be appropriate to enter recovery. Site Area and General Emergencies will require a recovery phase to be established prior to event termination. The Applicant may consult with/notify cognizant governmental agencies prior to declaring recovery or event termination (see Section 4.5).

The following conditions are guidelines for the determination of establishing recovery (this is not intended to be a complete list and additional criteria may apply, depending on the specifics of the event):

• The risk to the health and safety of the public has been mitigated;

• Plant parameters and equipment status have been established and controlled;

• In-plant radiation levels are stable or decreasing and acceptable, given the plant conditions;

• The potential for uncontrolled releases of radioactive material to the environment has been eliminated;

• Environmental monitoring has been established; 13.1-2 DEL-096-REV0

CHAPTER 13 - RECOVERY AND RE-ENTRY EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT SECTION 13.1 - RE-ENTRY AND RECOVERY PLANNING CONCEPTS

• The radioactive plume has dissipated and plume tracking is no longer required (the only environmental assessment activities in progress are those necessary to asses the extent of deposition resulting from passage of the plume);

• ESP Facility workers have been protected;

• Any security threat has been neutralized, and/or plant security is under the direction of Applicant personnel;

• Adequate plant safety systems are operable;

• The reactor is in a stable shutdown condition and long-term core cooling is available;

• The fuel pool damage has been mitigated, or spent fuel damage has been contained and controlled;

• Primary and/or secondary containment integrity has been established;

• Plant systems and equipment are restored and/or replaced such that plant conditions are stable, and highly unlikely to degrade further;

• Conditions that initiated the emergency have been contained, controlled, eliminated, or stabilized such that the classification is no longer applicable;

• The operability and integrity of radioactive waste systems, decontamination facilities, power supplies, electrical equipment and plant instrumentation, including radiation monitoring equipment has been established;

• Any fire, flood, earthquake, or similar emergency condition or threat to security no longer exists;

• All required notifications have been made;

• Discussions have been held with federal, state, and county agencies and agreement has been reached to terminate the emergency;

• At an alert or higher classification, the ERO is in place and emergency facilities are activated;

• Any contaminated injured person has been treated and/or transported to a medical care facility; and

• Off-site conditions do not unreasonably limit access of outside support to the station and qualified personnel and support services are available.

It is not necessary that all conditions above be met; however, all items must be considered prior to entering the recovery phase. For example, it is possible that after a severe accident that some conditions remain that exceed an Emergency Action Level, but entry into the recovery phase is appropriate.

DEL-096-REV0 13.1-3

CHAPTER 13 - RECOVERY AND RE-ENTRY EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT SECTION 13.2 - RECOVERY ORGANIZATION 13.2 Recovery Organization Once plant conditions have been stabilized and the recovery phase has been initiated, the Emergency Director may form a recovery organization for long-term operations. These types of alterations will be discussed with the USNRC prior to implementation.

• For events of a minor nature (i.e., for Unusual Event classifications), the normal on-shift organization should be adequate to perform necessary recovery actions.

• For events where damage to the plant has been significant, but no off-site releases have occurred and/or protective actions were not performed (i.e., for alert classifications), the ESP Facility ERO, or portions thereof, should be adequate to perform the recovery tasks prior to returning to the normal station organization.

• For events involving major damage to systems required to maintain safe shutdown of the plant and off-site radioactive releases have occurred (i.e., for Site Area Emergency or General Emergency classifications), the recovery organization will be put in place.

The specific members of the recovery organization are selected based on the sequence of events that preceded the recovery activities as well as the requirements of the recovery phase. Following is the basic framework of the recovery organization.

13.2.1 Recovery Director The Corporate Emergency Director is initially designated as the Recovery Director. The Recovery Director is charged with the responsibility for directing the activities of the station recovery organization. These responsibilities include the following:

• Ensuring that sufficient personnel, equipment, or other resources from Applicant and other organizations are available to support recovery;

• Directing the development of a recovery plan and procedures;

• Deactivating any of the ESP Facility ERO which was retained to aid in recovery, in the appropriate manner. Depending upon the type of accident and the on-site and off-site effects of the accident, portions of the ERO may remain in place after initiation of the recovery phase;

• Coordinating the integration of available federal and state assistance into on-site recovery activities;

• Coordinating the integration of Applicant staff with federal, state, and county authorities into required off-site recovery activities;

• Approving information released by the public information organization which pertains to the emergency or the recovery phase of the accident; and

• Determining when the recovery phase is terminated.

DEL-096-REV0 13.2-1

CHAPTER 13 - RECOVERY AND RE-ENTRY SECTION 13.2 - RECOVERY ORGANIZATION EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT 13.2.2 Recovery Plant Manager The ESP Station Manager or a designated alternate will become the Recovery Plant Manager. The Recovery Plant Manager reports to the Recovery Director and is responsible for the following:

• Coordinating the development and implementation of the recovery plan and procedures;

• Ensuring that adequate engineering activities to restore the plant are properly reviewed and approved;

• Directing all on-site activities in support of the station recovery effort; and

• Designating other Exelon recovery positions in supports of on-site recovery activities.

13.2.3 Recovery Off-Site Manager A senior Corporate Emergency Preparedness or Regulatory Affairs individual, or a designated alternate, will be the Recovery Off-Site Manager. The Recovery Off-Site Manager is responsible for the following:

• Providing liaison with off-site agencies and coordinating Applicant staff assistance for off-site recovery activities;

• Coordinating Applicant ingestion exposure pathway EPZ sampling activities and the development of an off-site accident analysis report;

• Developing a radiological release report; and

• Designating other recovery positions in supports of off-site recovery activities.

13.2.4 Company Spokesperson A senior manager will be designated as the Company Spokesperson. The Company Spokesperson reports to the Recovery Director and is responsible for the following:

• Functioning as the official spokesperson to the press for the Applicant on all matters relating to the accident or recovery;

• Coordinating non-Applicant public information groups (federal, state, county, etc.);

• Coordinating media monitoring and rumor control; and

• Determining what public information portions of the ERO will remain activated.

The remainder of the recovery organization will be established and an initial recovery plan will be developed at the end of the emergency phase or just after entry into the recovery phase. Consideration will be given to recovery activity needs and use of the normal ESP Station organizations. Individual recovery supervisors may be designated in any or all of the following areas:

• Training; 13.2-2 DEL-096-EP-REVX2

CHAPTER 13 - RECOVERY AND RE-ENTRY EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT SECTION 13.2 - RECOVERY ORGANIZATION

• Radiation Protection;

• Chemistry;

• Technical/Engineering Support;

• Nuclear Oversight;

• Operations;

• Security;

• Maintenance; and

• Special Off-Site Areas (Community Representatives, Environmental Samples, Investigations, etc.).

DEL-096-REV0 13.2-3

CHAPTER 13 - RECOVERY AND RE-ENTRY EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT SECTION 13.3 - RECOVERY PHASE NOTIFICATIONS 13.3 Recovery Phase Notifications When the decision is made to enter the recovery phase, all members of the Applicants ERO are informed of the change. All appropriate personnel are instructed of the recovery organization and their responsibilities to the recovery effort.

DEL-096-REV0 13.3-1

CHAPTER 13 - RECOVERY AND RE-ENTRY EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT SECTION 13.4 - TOTAL POPULATION EXPOSURE 13.4 Total Population Exposure Total population exposure calculations are performed and periodically updated during the recovery phase of an accident. A method has been developed for estimating the total population exposure resulting from the accident from data collected in cooperation with the federal and state agencies. Total population exposure is determined using a variety of methods such as the following:

• Examination of pre-positioned TLDs;

• Bioassay;

• Estimates based on release rates and meteorology; and

• Estimates based on environmental monitoring of food, water, and ambient dose rates.

The State of Illinois will be the lead agency in the collection and analysis of environmental air, soil, foliage, food, and water samples, and for the generation of radiation monitoring reports. The Applicant's environmental sampling activities will be coordinated with state efforts, as requested, and results shared with cognizant agencies.

DEL-096-REV0 13.4-1

CHAPTER 14 Drills and Exercises (Not required by rule or guidance [USNRC, 1996]. This is a place holder for alignment with Section N of the Exelon Nuclear Standardized Radiological Emergency Plan [EGC, 2003].)

DEL-096-REV0 14-1

CHAPTER 15 Radiological Emergency Response Training This chapter describes the emergency response training that will be provided to those who may be called upon in an emergency, and outlines the training provided by the Applicant to both its employees and off-site support personnel requiring site access, in the following sections:

• Assurance of Training (Section 15.1)

• Functional Training of the Emergency Response Organization (Section 15.2)

• First Aid Response (Section 15.3)

• Emergency Response Organization Training Program (Section 15.4)

• General, Initial, and Annual Training Program Maintenance (Section 15.5).

This information is based on and consistent with the Exelon Nuclear Standardized Radiological Emergency Plan (EGC, 2003).

DEL-096-REV0 15-1

CHAPTER 15 - RADIOLOGICAL EMERGENCY RESPONSE TRAINING EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT SECTION 15.1 - ASSURANCE OF TRAINING 15.1 Assurance of Training The Emergency Plan Training Program will assure the training, qualification, and requalification of individuals who may be called for assistance during an emergency.

Specific emergency response task training, prepared for each emergency plan position, will be described in lesson plans and study guides. The lesson plans, study guides, and written tests will be contained in the ERO Training Program. Responsibilities for implementing the training program will be contained in EGC ESP Facility procedures.

Off-site training will be provided to support organizations that may be called upon to provide assistance in the event of an emergency. The following paragraphs outline the training to be received by these organizations.

• At the appropriate time in the future, Emergency Preparedness shall make an annual written offer to train those non-Applicant organizations, referenced in the Final Emergency Plan for the EGC ESP Facility, which may provide specialized services during a nuclear plant emergency (e.g., local law enforcement, fire fighting, medical services, transport of injured). The training made available is designed to acquaint the participants with the special problems potentially encountered during a nuclear plant emergency, notification procedures, and their expected roles. Those organizations that must enter the site shall also receive site-specific emergency response training, and will be instructed as to the identity (by position and title) of those persons in the on-site organization who will control their support activities.

• Training of off-site EROs will be described in their respective emergency plans, with support provided by the Applicant as requested.

DEL-096-REV0 15.1-1

CHAPTER 15 - RADIOLOGICAL EMERGENCY RESPONSE TRAINING EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT SECTION 15.2 - FUNCTIONAL TRAINING OF THE EMERGENCY RESPONSE ORGANIZATION 15.2 Functional Training of the Emergency Response Organization In addition to general and specialized classroom training, members of the Applicant ERO will receive periodic performance-based emergency response training. Performance-based training will be provided using one or more of the methods described in the sections below.

15.2.1 Familiarization Sessions A familiarization session is an informal, organized tabletop discussion of predetermined objectives.

15.2.2 Walk-Throughs A walk-through consists of a facility tour to familiarize plant ERO personnel with procedures, communications equipment, and facility layout. Walk-throughs also provide the opportunity to discuss facility activities, responsibilities, and procedures with an instructor.

15.2.3 Drills A drill is a supervised instruction period aimed at testing, developing, and maintaining skills in a particular operation. These drills allow the individuals to demonstrate the ability to perform their assigned emergency functions. During drills, on-the-spot correction of erroneous performance may be made, and a demonstration of the proper performance is offered by a Controller.

DEL-096-REV0 15.2-1

CHAPTER 15 - RADIOLOGICAL EMERGENCY RESPONSE TRAINING EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT SECTION 15.3 - FIRST AID RESPONSE 15.3 First Aid Response Selected EGC ESP Facility personnel will be trained in accordance with an Applicant approved First Aid Program (NFPA, 1997). First aid teams will likely be augmented with additional personnel, such as fire brigade members and other personnel qualified to assist in the rescue.

DEL-096-REV0 15.3-1

CHAPTER 15 - RADIOLOGICAL EMERGENCY RESPONSE TRAINING EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT SECTION 15.4 - EMERGENCY RESPONSE ORGANIZATION TRAINING 15.4 Emergency Response Organization Training Program Applicant ERO personnel who will be responsible to implement this plan will receive specialized training. The training program for emergency response personnel will be developed based on the requirements of 10 CFR 50, Appendix E, and position-specific responsibilities as defined in this document (see Chapter 3).

On-shift emergency response personnel will perform emergency response activities as an extension of their normal duties, and will be trained annually as part of their duty specific training. Additional Emergency Preparedness information is provided as part of the Facility Nuclear General Employee Training.

New ERO personnel will receive an initial overview course that familiarizes them with the Emergency Plan by providing basic information in the following areas:

• Planning basis;

• Emergency classifications;

• ERO and responsibilities;

• Call-out of emergency organization;

• ERFs;

• Communications protocol/emergency public information; and

• Off-site organizations.

Emergency response personnel in the categories listed below will receive the knowledge, and/or performance-based initial training and annual retraining described in the following sections.

15.4.1 Directors, Managers, and Coordinators within the Facility and Corporate Emergency Response Organization Personnel identified as Directors, Managers, and Coordinators for the facility and corporate EROs will receive training appropriate to their position in accordance with the approved ERO training program. These personnel will receive specialized training in the following areas:

• Notifications;

• Emergency classifications;

• PARs;

• EALs; and

• Emergency exposure control.

DEL-096-REV0 15.4-1

CHAPTER 15 - RADIOLOGICAL EMERGENCY RESPONSE TRAINING SECTION 15.4 - EMERGENCY RESPONSE ORGANIZATION TRAINING EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT Selected Directors, Managers, Coordinators and Shift Emergency Directors receive training in accordance with the approved ERO Training Program. Training in accident assessment sufficient to classify an event and to mitigate the consequences of an event are also covered.

15.4.2 Personnel Responsible for Accident Assessment The skills and knowledge required to perform plant stabilization and mitigation will be a normal function of operations-specific positions, as identified in Chapter 3 of this plan.

Power changes and planned and unplanned reactor shutdowns will be handled on a normal operation basis. Subsequent EGC ESP Facility stabilization and restoration will be pursued utilizing normal operating procedures. Licensed operators will receive routine classroom and simulator training to ensure proficiency in this area.

Active senior licensed CR personnel will have training conducted in accordance with the approved ERO training program such that proficiency is maintained on certain topics. The topics listed below shall be covered on an annual basis at a minimum:

• Event Classification;

• PARs;

• Radioactive release rate determination;

• Notification form completion and use of the NARS system;

• Federal, state, and local notification procedures as appropriate; and

• Site-specific procedures for activating the on-site and off-site ERO.

To remove peripheral duties from the operations shift, those positions responsible for accident assessment, corrective actions, protective actions, and related activities will receive training in core damage assessment. During an emergency in which core/cladding damage is suspected, a specialized group of trained individuals will perform core damage assessment. At a minimum, these people will receive classroom and hands-on training in the following areas:

• Available instrumentation and equipment;

• Isotopic assessment and interpretation; and

• Computerized CDAM and/or proceduralized assessment methods.

15.4.3 Radiological Monitoring Teams and Radiological Analysis Personnel 15.4.3.1 Off-Site Radiological Monitoring Off-site radiological monitoring will be performed by trained individuals who provide samples and direct readings for dose assessment calculations and dose projection comparisons.

Personnel identified as members of field monitoring teams will receive classroom and hands-on training in the following areas (in accordance with the approved training program):

• Equipment and equipment checks; 15.4-2 DEL-096-REV0

CHAPTER 15 - RADIOLOGICAL EMERGENCY RESPONSE TRAINING EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT SECTION 15.4 - EMERGENCY RESPONSE ORGANIZATION TRAINING

• Communications; and

• Plume tracking techniques.

15.4.3.2 Personnel Monitoring Personnel monitoring will be performed by trained individuals who monitor facility personnel and their vehicles for contamination during an emergency. Personnel monitoring team members will receive classroom and hands-on training in the following areas:

• Personnel monitoring equipment and techniques;

• Decontamination techniques for personnel; and

• Decontamination techniques for vehicles.

15.4.3.3 Dose Assessment Dose assessment training includes the skills and knowledge necessary for calculation and interpretation of an off-site release and its impact on the environment under varying meteorological conditions. Individuals responsible for performing dose assessment will be trained in the following areas:

• Computerized dose assessment;

• PARs;

• Field monitoring team interface;

• Protective action guidelines associated with off-site plume exposure doses; and

• Basic meteorology.

15.4.4 Police, Security, and Fire Fighting Personnel 15.4.4.1 Local Police and Fire Fighting Personnel The local police and fire departments will be invited to receive training as outlined in Section 15.1.

15.4.4.2 Security Personnel EGC ESP Facility security personnel will be trained in accordance with training defined by the nuclear general employee training (NGET) (see Section 15.5.4 and Section 4.8) and the Applicant's Nuclear Security Program.

15.4.4.3 Fire Control Teams (Fire Brigades)

Facility fire brigades will be trained in accordance with training defined by the Applicant's Fire Protection Program (NFPA, 1996). Fire brigade personnel are considered the primary members of rescue teams, and will receive the appropriate Emergency Plan training as part of their training program. Training also will include rescue of personnel from hazardous environments.

DEL-096-REV0 15.4-3

CHAPTER 15 - RADIOLOGICAL EMERGENCY RESPONSE TRAINING SECTION 15.4 - EMERGENCY RESPONSE ORGANIZATION TRAINING EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT 15.4.5 Repair and Damage Control Teams Operations, maintenance, and RP personnel will be trained as part of their normal job specific duties to respond to both normal and abnormal plant operations.

Operations personnel will be trained to recognize and to mitigate degrading conditions in the plant; mechanically and electrically isolate damaged or malfunctioning equipment; isolate fluid leaks; and minimize transients.

Maintenance personnel will be trained to troubleshoot and repair damaged or malfunctioning electrical, mechanical, or instrumentation systems as appropriate to their job classification.

RP personnel will be trained to assess the radiological hazards associated with equipment repair and to instruct personnel in the appropriate protective clothing requirements, respiratory protection requirements, stay times, and other protective actions specific to the conditions present.

At least 50 percent of people from departments that provide potential responders to the OSC as damage control team members will be required to be qualified in the use of respiratory protection equipment. These departments will be Operations, Radiation Protection, Chemistry and Maintenance (or equivalents); respiratory protection qualified people from these departments will include in-plant supervisors as well as craft/technicians.

15.4.6 First Aid and Rescue Personnel First aid and rescue team members will receive training as outlined in Section 15.3.

15.4.7 Local Support Service Personnel Local support service personnel providing assistance during an emergency will be invited to receive training as outlined in Section 15.1.

15.4.8 Medical Support Personnel On-site medical personnel will receive specialized training in the handling of contaminated victims and hospital interface. Off-site ambulance and hospital personnel will be offered annual training in accordance with a program provided by emergency preparedness (see Section 15.1).

15.4.9 Public Information Personnel Corporate and facility personnel responsible to disseminate emergency public information and respond to media and public information requests will receive specialized public information training.

15.4.10 Communications Personnel ERO personnel will receive training on communications protocol as a part of the initial Emergency Response Overview Course. Personnel using specialized communications equipment that is not part of their normal daily function will receive initial and 15.4-4 DEL-096-REV0

CHAPTER 15 - RADIOLOGICAL EMERGENCY RESPONSE TRAINING EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT SECTION 15.4 - EMERGENCY RESPONSE ORGANIZATION TRAINING requalification training on the equipment. Personnel involved in notifications to off-site agencies will receive specialized training in the notification process.

DEL-096-REV0 15.4-5

CHAPTER 15 - RADIOLOGICAL EMERGENCY RESPONSE TRAINING EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT SECTION 15.5 - GENERAL, INITIAL, AND ANNUAL TRAINING PROGRAM MAINTENANCE 15.5 General, Initial, and Annual Training Program Maintenance The EGC ESP Facility departments and the Applicant's Emergency Preparedness Department will share the responsibility for ensuring that the ERO receives the necessary training and retraining. The following sections list the responsibilities that are assigned to execute these training requirements 15.5.1 Corporate Responsibilities for Corporate Emergency Response Organization Personnel The Corporate responsibilities for the Corporate ERO Personnel will include the following:

• Schedule and conduct initial, retraining, and make-up classes;

• Act as the sole contact point for ensuring attendance;

• Keep records for the training courses including dates of scheduled classes and non-attendance information;

• Verify that emergency response personnel training records are current; and

• Ensure instructional materials are prepared and reviewed every two years.

15.5.2 EGC ESP Facility Responsibilities for Facility Emergency Response Organization Personnel The responsibilities of the EGC ESP Facility for facility ERO personnel will include the following:

• EGC ESP Facility management shall ensure the attendance of on-site personnel for training including required Emergency Plan courses.

• The EGC ESP Facility shall conduct on-site emergency personnel initial and retraining for facility emergency response personnel using approved lesson plans.

• The EGC ESP Facility Training Department shall provide those shift personnel included in a continuing training program, an annual review of the following items, at a minimum:

Assembly areas; ERF assignment; Potential hazards (radiological and non-radiological); and Anticipated actions including assembly requirements, protective equipment requirements (clothing, masks, self contained breathing apparatus, etc.) the use of KI, emergency exposure limits, and accountability requirements.

15.5.3 Initial and Requalification Emergency Response Organization Training The proficiency of emergency response personnel (as defined in 10 CFR 50, Appendix E) is described below.

DEL-096-REV0 15.5-1

CHAPTER 15 - RADIOLOGICAL EMERGENCY RESPONSE TRAINING SECTION 15.5 - GENERAL, INITIAL, AND ANNUAL TRAINING PROGRAM MAINTENANCE EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT

• Assign people to emergency duties that are similar to those performed as a part of their regular work assignment or experience.

• Initial training and annual retraining on applicable generic and site-specific portions of the Emergency Plan and the corresponding implementing procedures. Individuals not demonstrating the required level of knowledge in initial or retraining classes will receive additional training in the areas requiring improvement. Annual retraining will be conducted on a calendar-year basis.

• Training in emergency plan changes shall be completed within 120 days of implementation of the change.

• Participate in exercises and/or drills as developed or authorized by the emergency preparedness department. These exercises and drills will be designed to sharpen those skills that personnel will be expected to use in the event of a nuclear emergency.

All personnel assigned specific position responsibilities in the ERO will be documented by inclusion in the emergency telephone directory listing of positions and personnel.

15.5.4 Nuclear General Employee Training All personnel with unescorted EGC ESP Facility access will be provided with initial orientation training on the notification and instruction methods used in the event of an emergency. Additionally, badged individuals will receive initial orientation on the basic principles of radiological safety, including the effects of radiation and the theory and use of radiation detection devices. Appropriate actions for escorted individuals shall be the responsibility of the escort. The NGET will provide initial and annual requalification training on the basic elements of the Emergency Plan for all personnel working at the EGC ESP Facility. Specifically, these elements will include the following:

• Facility emergency alarms and their meaning;

• Assembly areas;

• Site and exclusion area evacuation procedures;

• Special precautions and limitations during an emergency; and

• Purpose of the emergency plan.

15.5-2 DEL-096-REV0

CHAPTER 16 Responsibility for the Planning Effort The information in this chapter is presented in the following sections:

• Emergency Preparedness Staff Training (Section 16.1)

• Authority for the Emergency Preparedness Effort (Section 16.2)

• Responsibility for Development and Maintenance of the Plan (Section 16.3)

• Emergency Plan and Agreement Revisions (Section 16.4)

• Emergency Plan Distribution (Section 16.5)

• Supporting Emergency Response Plans (Section 16.6).

This chapter describes the responsibilities for development, review, and distribution of this Emergency Plan and actions that must be performed to maintain the Emergency Preparedness Program. Additionally, this chapter outlines the criteria for ensuring that personnel who perform the planning are properly trained. The information in this chapter is based on and consistent with the Exelon Nuclear Standardized Radiological Emergency Plan (EGC, 2003).

DEL-096-REV0 16-1

CHAPTER 16 - RESPONSIBILITY FOR THE PLANNING EFFORT EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT SECTION 16.1 - EMERGENCY PREPAREDNESS STAFF TRAINING 16.1 Emergency Preparedness Staff Training The Applicant's Emergency Preparedness Department staff will be involved in maintaining an adequate knowledge of state of the art planning techniques and the latest applications of emergency equipment and supplies. At least once a calendar year, each member of the emergency preparedness staff will be involved in one of the following activities:

• Training courses specific or related to emergency preparedness;

• Observation of, or participation in, drills and/or exercises at other facilities;

• Participation in industry review and evaluation programs;

• Participation in regional or national emergency preparedness seminars, committees, workshops, or forums; and/or

• Specific training courses in related areas, such as systems, equipment, operations, radiological protection, or problem identification and resolution.

DEL-096-REV0 16.1-1

CHAPTER 16 - RESPONSIBILITY FOR THE PLANNING EFFORT EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT SECTION 16.2 - AUTHORITY FOR THE EMERGENCY PREPAREDNESS EFFORT 16.2 Authority for the Emergency Preparedness Effort The Applicant's officers will be responsible for the safe and reliable operation of the EGC ESP Facility. The issuance and control of this plan and the activities associated with emergency preparedness at EGC shall be the overall responsibility of the Vice President of Licensing and Regulatory Affairs. The Vice President of Licensing and Regulatory Affairs will be assigned the responsibility for overall implementation of the EGC Emergency Plans.

DEL-096-REV0 16.2-1

CHAPTER 16 - RESPONSIBILITY FOR THE PLANNING EFFORT EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT SECTION 16.3 - RESPONSIBILITY FOR DEVELOPMENT AND MAINTENANCE OF THE PLAN 16.3 Responsibility for Development and Maintenance of the Plan The Applicant's MWROG Emergency Preparedness Manager will be responsible for the overall Radiological Emergency Preparedness Program associated with the EGC ESP Site and for administering the program to ensure availability of resources in the event of an emergency. The Emergency Preparedness Manager will report to the Vice President of Licensing and Regulatory Affairs.

16.3.1 Mid-West Regional Operating Group Emergency Preparedness Manager Responsibilities The MWROG Emergency Preparedness Manager will be assisted by the regional and facility emergency preparedness staff. The specific responsibilities of the MWROG Emergency Preparedness Manager are listed in the following sections.

16.3.1.1 Program Administration Program Administration responsibilities of the MWROG Emergency Preparedness Manager will include the following:

• Develop and maintain the Emergency Plan, future implementing procedures, and administrative documents;

• Develop and maintain 10 CFR 50.54(q) evaluations for changes to emergency planning documents;

• Coordinate and maintain the emergency planning activities schedule;

• Develop and maintain working relationships and coordinate meetings with federal, state, and local agencies;

• Ensure integration of plans between the Applicant and off-site agencies;

• Provide an opportunity to discuss EALs and the availability of nuclear oversight audit results relating to interface with governmental agencies;

• Coordinate, negotiate, and maintain agreements and contracts with off-site agencies and support organizations;

• Obtain letters of agreement with major medical facilities and medical consultants specifically skilled in the medical aspects of radiation accidents. (In addition, other medical consultants might be necessary for the case of a person involved in a radiation incident);

• Coordinate the development and annual distribution of the facilitys public information publication;

• Coordinate and administer the Self Evaluation Program to monitor and evaluate the adequacy of the Emergency Preparedness Program; DEL-096-REV0 16.3-1

CHAPTER 16 - RESPONSIBILITY FOR THE PLANNING EFFORT SECTION 16.3 - RESPONSIBILITY FOR DEVELOPMENT AND MAINTENANCE OF THE PLAN EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT

• Coordinate and support emergency planning self-assessments, audits, and inspections;

• Ensure the documentation and resolution of adverse conditions in the Emergency Preparedness Program discovered through drills, audits, etc., in accordance with the Applicant's Corrective Action Program;

• Coordinate and develop operational experience responses;

• Coordinate, document, and review MWROG performance indicator data and reports;

• Provide oversight of drill and exercise performance evaluations during licensed operator requalification training;

• Coordinate and conduct emergency planning event reviews and reports;

• Maintain adequate documentation/files to support emergency planning activities;

• Develop and manage the emergency planning budget; and

• Maintain the Emergency Phone Directory.

16.3.1.2 Drills and Exercises Tasks of the MWROG Emergency Preparedness Manager concerning drills and exercises will include the following:

• Coordinate and maintain the emergency planning drill and exercise schedule;

• Coordinate and conduct exercises and drills;

• Coordinate USNRC, FEMA, state, and local exercise scheduling and development activities;

• Coordinate drill and exercise scenario development activities;

• Develop and publish drill and exercise scenario manuals;

• Coordinate and perform controller and evaluator functions for drills and exercises;

• Coordinate response cells for drills and exercises; and

• Develop and issue drill and exercise reports.

16.3.1.3 Facilities and Equipment Tasks concerning facilities and equipment for which the MWROG Emergency Preparedness Manager will be responsible include the following:

• Provide maintenance and administration of the ANS;

• Provide maintenance of the ERO call-out system;

• Ensure the emergency response facilities are maintained in a constant state of readiness;

• Coordinate and review the emergency planning equipment inventories; 16.3-2 DEL-096-REV0

CHAPTER 16 - RESPONSIBILITY FOR THE PLANNING EFFORT EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT SECTION 16.3 - RESPONSIBILITY FOR DEVELOPMENT AND MAINTENANCE OF THE PLAN

• Coordinate and conduct maintenance and testing of the communications systems; and

• Maintain the emergency planning computer applications.

16.3.1.4 Emergency Response Organization Qualification and Administration ERO Qualification and Administration tasks for which the MWROG Emergency Preparedness Manager will be responsible include the following:

• Develop and maintain ERO lesson plans, examinations, and qualification cards;

• Maintain emergency planning NGET training content;

• Coordinate, schedule, and conduct ERO qualification and requalification training;

• Oversee the maintenance of ERO training records;

• Maintain and coordinate publishing of the ERO duty rosters;

• Provide adequate oversight and support for the training of off-site response personnel;

• Coordinate and conduct Emergency Medical Assistance Program training; and

• Coordinate annual training for the media.

16.3.2 EGC ESP Facility Manager Responsibilities The EGC ESP Facility Manager will be responsible for implementation of the Emergency Plan for the EGC ESP Facility. The Facility Manager responsibilities for maintenance of the Emergency Preparedness Program will include the following:

• Ensure adequate staffing and training of facility ERO members;

• Schedule and conduct drills and exercises to maintain the state of readiness of the Emergency Preparedness Program;

• Ensure the operational readiness of facility and communication systems for use during an emergency;

• Ensure that the operational readiness of facility emergency equipment and supplies is maintained; and

• Ensure the emergency response procedures for training and retraining of facility emergency response personnel are maintained.

DEL-096-REV0 16.3-3

CHAPTER 16 - RESPONSIBILITY FOR THE PLANNING EFFORT EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT SECTION 16.4 - EMERGENCY PLAN AND AGREEMENT REVISIONS 16.4 Emergency Plan and Agreement Revisions The Exelon Nuclear Standardized Radiological Emergency Plan (EGC, 2003) and supporting agreements will be reviewed on an annual basis. The annual plan review/update will include required changes identified during audits, assessments, training, drills, and exercises. The MWROG Emergency Preparedness Manager will be responsible for determining which recommended changes are incorporated into a plan or emergency procedure revision. In those years when the review does not warrant a revision, a letter to that effect will be issued.

This major features Emergency Plan for the EGC ESP Facility will not be revised for the duration of the ESP. When the EGC ESP is referenced in an application for a COL pursuant to 10 CFR 52, Subpart C, the COL application will incorporate by reference the Exelon Nuclear Standardized Radiological Emergency Plan in effect at that time. The COL application will also address any changes from this major features Emergency Plan for the EGC Facility that represent a decrease in the effectiveness, if any, pursuant to 10 CFR 50.54(q). As this major features Emergency Plan for the EGC ESP Facility is currently aligned with the Exelon Nuclear Standardized Radiological Emergency Plan, such changes will essentially be those already identified to the USNRC by EGC pursuant to 10 CFR 50.54(q) as changes to the Exelon Nuclear Standardized Radiological Emergency Plan. As such, the identification of most changes will be through reference to the 50.54(q) submittals, if any, and subsequent USNRC approvals.

DEL-096-REV0 16.4-1

CHAPTER 16 - RESPONSIBILITY FOR THE PLANNING EFFORT EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT SECTION 16.5 - EMERGENCY PLAN DISTRIBUTION 16.5 Emergency Plan Distribution The Emergency Plan for the EGC ESP Facility will not be distributed for implementation.

The Final Emergency Plan and future EGC ESP Facility implementing procedures will be distributed on a controlled basis to the ERFs, selected federal, state, and local agencies, and other appropriate locations requiring them in association with pertinent activities prior to initial fuel loading. Controlled document holders will be issued revision changes upon approval. Procedures that control the revision of the Emergency Plan will require the use of revision bars and individual page identifications (i.e., section of plan, revision number).

DEL-096-REV0 16.5-1

CHAPTER 16 - RESPONSIBILITY FOR THE PLANNING EFFORT EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT SECTION 16.6 - SUPPORTING EMERGENCY RESPONSE PLANS 16.6 Supporting Emergency Response Plans Other plans that support this Emergency Plan include the following:

• NUREG-1471, USNRC, Concept of Operations: NRC Incident Response (USNRC, 1994);

• FRERP (FERA, 1996);

• INPO Emergency Resources Manual, No.03-001 (INPO, 2003);

• IPRA (State of Illinois, 2001);

• EGC ESP Facility Security Plan (to be developed for the COL); and

• USDOE, Region 5, Radiological Assistance Plan (USDOE, no date).

The plan is formatted to align with the planning standards and evaluation criteria of NUREG-0654/FEMA-REP-1, Revision 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants (USNRC, 1980) and NUREG-0654/FEMA-REP-1, Revision 1, Supplement 2, Criteria for Emergency Planning in an Early Site Permit Application (USNRC, 1996). The use of this format lends itself to an uncomplicated comparison of the criteria set forth in those documents. A cross reference matrix linking planning standards and evaluation criteria from that document to sections of this plan and the state (State of Illinois, 2001) and local plans (State of Illinois, 2001a) is provided in Appendix B.

DEL-096-REV0 16.6-1

Glossary Accident assessment Accident assessment consists of a variety of actions taken to determine the nature, effects, and severity of an accident; and includes evaluation of reactor operator status reports, damage assessment reports, meteorological observations, seismic observations, fire reports, radiological dose projections, in-plant radiological monitoring, and environmental monitoring.

Annual Frequency of occurrence equal to once per calendar year, January 1 to December 31.

Assembly/Accountability A procedural or discretionary protective action taken for all persons within the security protected area, which involves the gathering of personnel into predesignated areas and the subsequent verification that the location of these personnel is known.

Assessment actions Those actions taken during or after an emergency to obtain and process information necessary to make decisions to implement specific emergency measures.

Classification The classification of emergencies is divided into five categories or conditions covering the postulated spectrum of emergency situations. The first four emergency classifications are characterized by emergency action levels (EALs) or event-initiating conditions and address emergencies of increasing severity. The fifth, the recovery classification, is unique in that it may be viewed as a phase of the emergency, requiring specific criteria to be met and/or considered prior to its declaration.

DEL-096-REV0 GLOSSARY - 1

GLOSSARY EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT Command and control When in command and control, the designated emergency response facility (ERF) has overall responsibility for Exelon Nuclear's emergency response efforts, including the non-delegable responsibilities of command and control.

Committed dose The dose equivalent to organs or tissues of reference that will equivalent be received from an intake of radioactive material by an individual during the 50-year period following the intake.

Control room The operations center of a nuclear power plant from which the plant can be monitored and controlled.

Corrective action Those emergency measures taken to lessen or terminate an emergency situation at or near the source of the problem, to prevent an uncontrolled release of radioactive material, or to reduce the magnitude of a release. Corrective actions include equipment repair or shutdown, installation of emergency structures, fire fighting, repair, and damage control.

Damage assessment Estimates and descriptions of the nature and extent of damages resulting from an emergency or disaster; of actions that can be taken to prevent or mitigate further damage; and of assistance required in response and recovery efforts based on actual observations by qualified engineers and inspectors.

Damage control The process of preventing further damage from occurring and preventing the increase in severity of the accident.

Decontamination The reduction or removal of contaminated radioactive material from a structure, area, material, object, or person.

Decontamination may be accomplished by (1) treating the surface so as to remove or decrease the contamination; (2) letting the material stand so that the radioactivity is decreased as a result of natural decay; and (3) covering the contamination.

GLOSSARY - 2 DEL-096-REV0

EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT GLOSSARY Dedicated communications A communications link between two or more locations, access to which is limited to designated locations, and which is used only for the intended purpose. The communications link may be either telephone or radio.

Dose A generic term that means absorbed dose, dose equivalent, effective dose equivalent, deep dose equivalent, committed dose equivalent, committed effective dose equivalent, or total effective dose equivalent.

Dose equivalent The product of the absorbed dose in tissue, quality factor, and all other necessary modifying factors at the location of interest. The unit of dose equivalent is the rem.

Dose projection The calculated estimate of a radiation dose to individuals at a given location (normally off site), determined from the source term/quantity of radioactive material (Q) released, and the appropriate meteorological dispersion parameters (Chi/Q).

Dose rate The amount of ionizing (or nuclear) radiation to which an individual would be exposed per unit of time. As it would apply to a person, dose rate is usually expressed as rems per hour or in submultiples of this unit, such as millirems per hour. The dose rate is commonly used to indicate the level of radioactivity in a contaminated area.

Dosimeter An instrument such as a thermo-luminescent dosimeter (TLD), self-reading pocket dosimeter, or electronic dosimeter for measuring, registering, or evaluating total accumulated dose or exposure to ionizing radiation.

Drill A supervised instruction period aimed at testing, developing, and maintaining skills in a particular operation.

DEL-096-REV0 GLOSSARY- 3

GLOSSARY EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT Early Phase The period at the beginning of a nuclear incident when immediate decisions for effective use of protective actions are required and must be based primarily on predictions of radiological conditions in the environment. This phase may last from hours to days. For the purposes of dose projections, it is assumed to last four days.

Emergency action level A predetermined, site-specific, observable threshold for a plant initiating condition that places the plant in a given emergency class. An emergency action level (EAL) can be an instrument reading; an equipment status indicator; a measurable parameter (on-site or off-site); a discrete, observable event; or another phenomenon which, if it occurs, indicates entry into a particular emergency class.

Emergency alert system A network of broadcast stations and interconnecting facilities which have been authorized by the Federal Communications Commission to operate in a controlled manner during a war, state of public peril or disaster, or other national or local emergency. In the event of a nuclear reactor accident, instructions/notifications to the public on conditions or protective actions would be broadcast by state or local government authorities on the emergency alert system (EAS).

Emergency Director The director of the facility in command and control. One of the following: the Acting Station Director, Station Director or the Manager of the emergency operations facility (EOF).

Emergency notification The USNRC emergency notification system (ENS) hot line is system a dedicated telephone system that connects the plant with USNRC headquarters in White Flint, Maryland. It is directly used for reporting emergency conditions to USNRC personnel.

Emergency operating The emergency operating procedures (EOPs) are step-by-step procedures procedures for direct actions taken by licensed operators to mitigate and/or correct an off normal plant condition through the control of plant systems.

GLOSSARY - 4 DEL-096-REV0

EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT GLOSSARY Emergency operations A facility designed and equipped for effective coordination center and control of emergency operations carried out within an organization's jurisdiction. The emergency operations center (EOC) is the site from which civil government officials (municipal, county, state, and federal) exercise direction and control in a civil defense emergency.

Emergency personnel Those organizational groups that perform a functional role during an emergency condition. Within EGC, emergency personnel include the managers and directors of the ERO, accident assessment personnel, radiological monitoring teams, fire brigades, first aid teams and security personnel.

Emergency planning zone That area surrounding a nuclear station in which emergency planning is conducted for the protection of the public. With respect to protecting the public from the plume exposure resulting from an incident, the emergency planning zone (EPZ) is usually an area with a radius of about 10-mi surrounding the facility. With respect to the ingestion exposure pathway, the EPZ is usually an area with a radius of about 50 mi.

Emergency preparedness A state of readiness that provides reasonable assurance that adequate protective measures can and will be taken upon implementation of the emergency plan in the event of a radiological emergency.

Emergency response data Emergency response data system is a direct near real-time system electronic data link between the licensees on-site computer system and the USNRC Operations Center that provides for the automated transmission of a limited data set of selected parameters.

Essential personnel Essential personnel are those needed to achieve the goals and tasks as deemed necessary by the Emergency Director.

DEL-096-REV0 GLOSSARY- 5

GLOSSARY EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT Evacuation The urgent removal of people from an area to avoid or reduce high level, short-term exposure usually from the plume or from deposited activity.

Exclusion area An exclusion area is an area specified for the purpose of reactor site evaluation in accordance with 10 CFR 100. It is an area of such size that an individual located at any point on its boundary for two hours immediately following onset of the postulated release would not receive a total radiation dose to the whole body in excess of 25 rem or a total radiation dose of 300 rem to the thyroid from iodine exposure.

Exercise An event that tests the integrated capability of a major portion of the basic elements existing within emergency preparedness plans and organizations.

Field monitoring The use of radiological instruments or sample collecting devices to measure and assess background radiation levels and/or the extent and magnitude of radiological contamination in the environment around the plant. This may be done in various stages such as preoperational, operational, emergency, and post-operational.

Hazardous material A substance or material which has been determined by the U.S. Secretary of Transportation to be capable of posing an unreasonable risk to health, safety, and property when transported in commerce, and which has been so designated in 49 CFR 172.

GLOSSARY - 6 DEL-096-REV0

EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT GLOSSARY Health physics network In the event of a Site Area Emergency, the USNRC health physics network (HPN) line will be activated by the USNRC Operations center in White Flint, Maryland. This phone is part of a network that includes the USNRC Regional Office and the USNRC Operations Headquarters in White Flint, Maryland. This system is dedicated to the transmittal of radiological information by plant personnel to USNRC Operations Center and the Regional office. HPN phones are located in the technical support center (TSC) and emergency operations facility (EOF).

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

Ingestion pathway The potential pathway of radioactive materials to the public through consumption of radiologically contaminated water and foods such as milk or fresh vegetables. Around a nuclear power plant this is usually described in connection with the 50-mi EPZ.

Initiating condition A predetermined Unit condition where either the potential exists for a radiological emergency or such an emergency has occurred.

Joint Public Information A corporate emergency facility activated by the Applicant Center and staffed by EGC, state, and federal public information personnel. This facility serves as the single point of contact for the media and public to obtain information about an emergency.

Major features of the Also referred to as Option 1, these include the exact sizes of emergency plans the emergency planning zones (EPZs) and other features as described in Section V of NUREG-0654 Supplement 2.

(NUREG-0654 FEMA-REP-1 Revision 1, Supplement 2 [Draft Report for Comment] April, 1996,Section I. D.4.)

DEL-096-REV0 GLOSSARY- 7

GLOSSARY EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT Mandatory requirement Though not defined, this is stated in 10 CFR 52 and NUREG-0654 Supplement 2: An ESP application must identify physical characteristics unique to the proposed site, such as egress limitations from the area surrounding the site that could pose a significant impediment to the development of emergency plans. The USNRC shall determine, after consultation with FEMA, whether this information shows that there is no significant impediment to the development of emergency plans. (NUREG-0654 FEMA-REP-1 Revision 1, Supplement 2 [Draft Report for Comment] April, 1996,Section I. E.)

For the mandatory requirement and Option 1, the application must include a description of contacts and arrangements made with local, state, and federal agencies with emergency planning responsibilities. (NUREG-0654 FEMA-REP-1 Revision 1, Supplement 2 [Draft Report for Comment] April, 1996,Section I. E.) The descriptions should include the name and location of the organization contacted, the title and/or position of the person(s) contacted, and the role of the organization in emergency planning. (NUREG-0654 FEMA-REP-1 Revision 1, Supplement 2 [Draft Report for Comment]

April, 1996,Section II. B.)

Non-Essential Site Those personnel not needed for the continuing existence or Personnel functioning of the emergency response organization (ERO).

They are personnel not required to fill certain positions in the ERO. Identification of non-essential personnel is circumstance-oriented as determined by the Emergency Director.

Off-Site The area around a nuclear generating station that lies outside the station's "site boundary.

On-Site The area around a nuclear generating station that lies within the station's "site boundary.

Operations support center An emergency response facility at the plant to which support personnel report and stand by for deployment in an emergency situation.

GLOSSARY - 8 DEL-096-REV0

EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT GLOSSARY Personnel monitoring The determination of the degree of radioactive contamination on individuals using standard survey meters, and/or the determination of dosage received by means of dosimetry devices.

Plume exposure pathway The potential pathway of radioactive materials to the public through (1) whole body external exposure from the plume and from deposited materials; and (2) inhalation of radioactive materials.

Population-at-Risk Those persons for whom protective actions are being or would be taken. In the 10-mi emergency planning zone (EPZ), the population-at-risk consists of resident population, transient population, special facility population, and industrial population.

Population center A densely populated area containing more than about 25,000 residents.

Potassium iodide A chemical compound that readily enters the thyroid gland when ingested. If taken in a sufficient quantity prior to exposure to radioactive iodine, potassium iodide (KI) can prevent the thyroid from absorbing any of the potentially harmful radioactive Iodine-131.

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

Projected dose The calculated dose that some individuals in the population group may receive if no protective actions are implemented.

Projected doses are calculated to establish an upper limit boundary.

Protected area That on-site area within the security boundary as defined in each station's Security Plan.

DEL-096-REV0 GLOSSARY- 9

GLOSSARY EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT Protective action Those emergency measures taken for the purpose of preventing or minimizing radiological exposures to affected population groups.

Protective action guide Projected radiological dose values to individuals in the general population that warrant protective action. Protective action guides (PAGs) are criteria used to determine if the general population needs protective action regarding projected radiological doses, or from actual committed (measured) dose values.

Protective action Recommended action to the state for the protection of the off-recommendation site public from whole body external gamma radiation, and inhalation and ingestion of radioactive materials. The protective action recommendation (PAR) issued is evacuate.

Access control and other recommendations concerning the safeguards of affected food chain processes may be issued by the states as PARs.

Public Alerting/Warning The process of signaling the public, as with sirens, to turn on their televisions or radios and listen for information or instructions broadcast by state or local government authorities on the emergency alert system (EAS).

Public notification Public notification means to communicate instructions on the nature of an incident that prompted the public alerting/warning and on protective or precautionary actions that should be taken by the recipients of the alert. A state and local government process for providing information promptly to the public over radio and television at the time of activating the alerting (warning) signal (sirens). Initial notifications of the public might include instructions to stay inside, close windows and doors, and listen to radio and television for further instructions. Commercial broadcast messages are the primary means for advising the general public of the conditions of any nuclear accident. (See Emergency Alert System.)

GLOSSARY - 10 DEL-096-REV0

EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT GLOSSARY Recovery The process of reducing radiation exposure rates and concentrations of radioactive material in the environment to levels acceptable for unconditional occupancy or use.

Release A Release in Progress is defined as any radioactive release that is a result of, or associated with, the emergency event.

Restricted area Any area, to which access is controlled by the Applicant for purposes of protection of individuals from exposure to radiation and radioactive materials.

Shall, Should, and May The word shall is used to denote a requirement, the word should to denote a recommendation and the word may to denote permission, neither a requirement nor a recommendation.

Shielding Any material or barrier that attenuates (stops or reduces the intensity of) radiation.

Significant impediment A physical characteristic or combination of physical characteristics that would pose major difficulties for an evacuation or the taking of other protective actions as addressed in Section II Early Site Permits - Identification of Physical Characteristics of NUREG-0654 Supplement 2.

That section states that the ESP application must identify physical characteristics unique to the proposed site, such as egress limitations from the area surrounding the proposed site, which could pose a significant impediment to the development of emergency plans. It goes on to state that an ESP applicant may identify such unique physical characteristics by performing a preliminary evacuation time estimate within the plume exposure EPZ for transient and permanent populations, noting major impediments to the evacuation or the taking of other protective actions.

(NUREG-0654 FEMA-REP-1 Revision 1, Supplement 2 [Draft Report for Comment] April, 1996, Sections I. D.2. and II.)

DEL-096-REV0 GLOSSARY- 11

GLOSSARY EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT Site boundary The site boundary is company-owned property on which a nuclear station is located and may include EGC leased lands adjacent to that nuclear station. Each nuclear station's site boundary is described in detail in the off-site dose calculation manual (ODCM).

Site evacuation The evacuation of non-essential personnel from the plant site.

Source term Radioisotope inventory of the reactor core, or amount of radioisotope released to the environment, often as a function of time.

Technical support center A center outside of the control room (CR) in which information is supplied on the status of the plant to those individuals who are knowledgeable or responsible for engineering and management support of reactor operations in the event of an emergency, and to those persons who are responsible for management of the on-site emergency response.

Threshold value Measurable, observable detailed conditions, which must be satisfied to determine an emergency action level (EAL) applicability.

Thyroid blocking agent An agent which when properly administered to an individual will result in sufficient accumulation of stable iodine in the thyroid to prevent significant uptake of radioiodine. Potassium iodide is such an agent.

Total effective dose The sum of the deep dose equivalent (for external exposure) equivalent and the committed effective dose equivalent (for internal exposure) and four days of deposition exposure.

Vital area An area within the station security fence which contains vital equipment. Examples include CR, containment/reactor building, turbine building and electrical equipment room.

GLOSSARY - 12 DEL-096-REV0

APPENDIX A Contacts and Arrangements Organization/Agreement Type Expiration Date DOE Radiation Emergency Assistance Center/Training Site, REAC/TS (Letter June 13, 2004 on File)

Medical Consultant Environmental, Inc. (P.O.) April 30, 2005 Radiological Environmental Monitoring Framatome Technologies Co. (P.O.) December 31, 2003 Post-Accident Sampling INC Worldwide Dosimetry Service (P.O.) December 31, 2003 Emergency Dosimetry Institute of Nuclear Power Operations (Letter on File) Living Letter (until terminated in writing)

Emergency Event Support Murray & Trettel, Inc. (P.O.) June 30, 2005 Meteorological Support Teledyne Brown Engineering (P.O.) February 27, 2004 Bioassay Analysis/Radiochemical Analysis John Warner Hospital and Ambulance Service November 15, 2004 Medical Support Decatur Memorial Hospital November 15, 2004 Medical Support DeWitt County Sheriff's Department January 8, 2004 Traffic Control, Law Enforcement Clinton Fire Department November 14, 2004 Fire Response Illinois Department of Nuclear Safety None Illinois Emergency Management Agency None DEL-096-REV0 A-1

APPENDIX B Requirements Matrix TABLE B-1 Requirements Matrix Code Guidance Requirement Planning Standard Evaluation Criteria ESP Illinoisa DeWittb c

10 CFR 52.17 None The application must identify None None 2.3; 2.4 NR 1A (b) (1) physical characteristics unique to the proposed site, such as egress limitations from the area surrounding the site that could impose a significant impediment to the development of emergency plans.

10 CFR NUREG-0654 REV 1, The application may also propose 1.1; 2.2 NR NR 52.17(b)(2)(i) SUPPLEMENT 2, major features of the emergency Section III plans, such as the exact sizes of the EPZs that can be reviewed and approved by the USNRC in consultation with FEMA in the absence of complete and integrated emergency plans.

10 CFR NUREG-0654 REV 1, Description of contacts and Include the name and location 3.1, 3.2, NR NR 52.17(b)(3) SUPPLEMENT 2, arrangements made with local, state, of the organization contacted, 3.4 Section III C and federal government agencies the title and/or position of the Appendix with emergency planning person contacted, and the A; IPRA responsibilities role of the organization in Vol. I by emergency planning. ref.

Additional guidance concerning contacts and arrangements for this option of the rule from Section V planning standards and evaluation criteria.

10 CFR 50.47 Emergency Planning Zones 2.2 NR 1A DEL-096-REV0 B-1

APPENDIX B - REQUIREMENTS MATRIX EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT TABLE B-1 Requirements Matrix Code Guidance Requirement Planning Standard Evaluation Criteria ESP Illinoisa DeWittb 10 CFR 50.47 Plume Exposure Pathway 2.2 NR NR 10 CFR NUREG-0654 REV 1, A. Assignment of Responsibility CH 3 52.17(b)(2)(i) SUPPLEMENT 2, (Organization Control) 10 CFR Section V 50.47(b)(1) 10 CFR 50 APP E IV (A)

Primary responsibilities are CH 3 identified for emergency response by applicant and by state and local organizations within the EPZ.

1. Identify the state, local, federal 3.1.1; 3.2; 1F; 1I; 1J; 1C; 1D; 2B; and private sector organizations 3.3; 3.4 2A; 2B; 3A; 2E; 2F; (including utilities) that are intended 3B; 3C Annexes 2A-to be part of the overall response 2F d d d organization for EPZs. A , S , L

2. a. Each organization shall identify the functions and responsibilities for major elements of ER, such as:

Command and control, NR but in 1E; 2A; 2B; 1D; 2A; 2F; alerting and notification, 3.2; 3.3 3A; 3B; 3C Annexes 2A-communications, 2F public information, accident assessment, public health and sanitation, social services, fire and rescue, traffic control, Emergency Medical Services, law enforcement, transportation protective response, and radiological exposure control DEL-096-REV0 B-2

EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT APPENDIX B - REQUIREMENTS MATRIX TABLE B-1 Requirements Matrix Code Guidance Requirement Planning Standard Evaluation Criteria ESP Illinoisa DeWittb The description of these functions IPRA Figures may be shown in a table of primary Command F.2.b.1; and support responsibilities. S, L and F.2.c.1; Coordination F.2.c.2; Table, F.2.c.3; Chapter 2, F.2.c.4; Section B F.2.c.5 2.b. Each application shall contain NR but in Introduction 2F the legal basis for such authorities, 3.1 Section A by reference to specific acts, codes or statutes. S, L

3. Include a description of contacts 3.2.3; 3.2.4; Signature 2 and arrangements pertaining to the 3.2.5; 3.4; Sheet Signature concept of operations developed Appendix A Sheet d

between F , S, and L agencies and other support organizations having an emergency response role within the EPZs. Any written letters of agreement should be included. A signature page in the application may be appropriate for some organizations to signify their agreement. A, S ,L 10 CFR NUREG-0654 REV 1, B. On-Site Emergency Organization CH 3 52.17(b)(2)(i) SUPPLEMENT 2, 10 CFR Section V 50.47(b)(2) 10 CFR 50 APP E IV (A)

Interfaces among various on- CH 3 site response activities and off-site support and response activities are identified.

DEL-096-REV0 B-3

APPENDIX B - REQUIREMENTS MATRIX EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT TABLE B-1 Requirements Matrix Code Guidance Requirement Planning Standard Evaluation Criteria ESP Illinoisa DeWittb

1. Identify interfaces between and Figure 3.1-2 NR NR but in 2; among the on-site functional areas Figure of emergency activity, local F.2.b.1 services support, and S and L Annex 2A government response Attachment 1 organizations. This may be illustrated in a block diagram. A

2. Identify services to be provided 3.2.4; 3.2.5; NR NR but in 2F; by local agencies for handling Appendix A 2H; Annexes emergencies (e.g. police, 2A-2F ambulance, medical, hospital, and fire fighting). A description of the arrangements involving these services shall be included in the plan. Any written letters of agreement should also be included.

A 10 CFR NUREG-0654 REV 1, C. Emergency Response Support CH 3 52.17(b)(2)(i) SUPPLEMENT 2, and Resources 10 CFR Section V 50.4(b)(3) 10 CFR 50 APP E IV (A)

Arrangements for requesting 3.4 assistance resources are described, and organizations capable of augmenting the planned responses are identified.

1. Each state and ESP applicant 3.1.1.1.4; 3 A(8); 3B NR shall make provisions for 3.4.5 requesting federal assistance through the Federal Radiological Emergency Response Plan. A,S DEL-096-REV0 B-4

EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT APPENDIX B - REQUIREMENTS MATRIX TABLE B-1 Requirements Matrix Code Guidance Requirement Planning Standard Evaluation Criteria ESP Illinoisa DeWittb

2. Identify radiation labs and their 3.4.3; 3.4.4; 3A(3); 3A(8) Included in general capabilities and expected 3.4.7; 3.4.8 Illinois Plan availability to provide radiation monitoring and analyses services during an emergency. A,S,L

3. Identify nuclear and other 3.4.1; 3.4.2; 1E(1); 3A(8) 2F; 2J; 3D facilities and organizations that can 3.4.9; be relied on to provide assistance 3.4.10 in an emergency. A,S,L

4. Include description of the Appendix A Signature 2F; 2J; 3D; contacts and arrangements made Sheet; Appendix D; with the response organizations 3A(12); 3C Appendix E; Identified above. A,S,L Map C 10 CFR NUREG-0654 REV 1, D. Emergency Classification System CH 4 52.17(b)(2)(i) SUPPLEMENT 2, 10 CFR Section V 50.47(b)(4) 10 CFR 50 APP E IV (B)

A standard emergency CH 4 classification system is specified.

1. An emergency classification 4.1 - 4.7 NR but in 1C NR but in 1C scheme as set forth in Appendix 1 and 4.9 of NUREG-0654 Revision 1 or Regulatory Guide 1.101 Revision 3 must be established by ESP applicant but need not include plant-specific initiating conditions.

A

2. Each S and L organization shall NR but in 1C 1C establish an emergency 4.10 classification system consistent with that established by the ESP applicant. S,L DEL-096-REV0 B-5

APPENDIX B - REQUIREMENTS MATRIX EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT TABLE B-1 Requirements Matrix Code Guidance Requirement Planning Standard Evaluation Criteria ESP Illinoisa DeWittb 10 CFR NUREG-0654 REV 1, E. Notification Methods and CH 5 52.17(b)(2)(i) SUPPLEMENT 2, Procedures 10 CFR Section V 50.47(b)(5) 10 CFR 50 APP E IV (C,D)

The means are established CH 5 for notification by the ESP applicant of S and L response organizations, and for notification of emergency personnel and the populace within the plume EPZ.

1. Each organization shall describe 5.1; 5.2 1D; 3A; 4A 1C; 1D; 2B; mutually agreeable bases for Annexes 2A-notification of response 2F organizations consistent with the emergency classification scheme set forth in Appendix 1 of NUREG-0654 Revision 1. A,S,L

2. Each organization shall describe 5.3; 5.4; 5.5 3A; 4A; 4B; 1C; 1D; 2B; a method for alerting, notifying, and 4C; 4D 2C; 2D; mobilizing emergency response Annexes 2A-personnel. A,S,L 2F DEL-096-REV0 B-6

EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT APPENDIX B - REQUIREMENTS MATRIX TABLE B-1 Requirements Matrix Code Guidance Requirement Planning Standard Evaluation Criteria ESP Illinoisa DeWittb

3. Each organization shall describe 5.5.1; 5.5.2 4A; 4B; 4C; 1D; Annexes the administrative and physical 4D 2A-2F means for notifying and promptly instructing the public within the plume EPZ. A,S,L 10 CFR NUREG-0654 REV 1, F. Emergency Communications CH 6 52.17(b)(2)(i) SUPPLEMENT 2, 10 CFR Section V 50.47(b)(6) 10 CFR 50 APP E IV (D)

Provisions are provided for CH 6 prompt communications among principal response organizations to emergency personnel and to the public.

1. The communication plans for emergencies shall describe:

a. Provision for communications 6.1 1E(2); 3A; 1C; 1D; 2A; with contiguous S and L 4A; 4B; 4C; 2B; 2C; 2D; governments within the EPZ. 4D 2G; Annexes A,S,L 2A-2F

b. Provision for communications 6.1 ERDS 1J; 3A(3); 2G; Annexes as needed with Federal 6.1.8 3A(8); 4A 2A-2F; emergency response Appendix A organizations. A,S,L DEL-096-REV0 B-7

APPENDIX B - REQUIREMENTS MATRIX EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT TABLE B-1 Requirements Matrix Code Guidance Requirement Planning Standard Evaluation Criteria ESP Illinoisa DeWittb

c. Provision for alerting and 6.2 2B; 3A(3); Annexes activating e personnel within 3A(8) 2A-2F each response organization.

A,S,L

2. The communication 6.4 3A(9) Appendix A arrangement for fixed and mobile medical support facilities shall be described A,S,L 10 CFR NUREG-0654 REV 1, G. Public Education and Information CH 7 52.17(b)(2)(i) SUPPLEMENT 2, 10 CFR Section V 50.47(b)(7)

An emergency information CH 7 program for the public and news media is described to address: (1) the provision of information to the public, on a periodic basis, on how they will be notified and what initial actions should be taken in an emergency; and (2) the means for acquainting the news media with emergency information.

1. Each organization shall describe 7.1; 7.2 5C 2K a program to provide a coordinated dissemination of information to the public on a periodic basis (at least annually) regarding how they will be notified and what their actions should be in an emergency. This program should include information on:

DEL-096-REV0 B-8

EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT APPENDIX B - REQUIREMENTS MATRIX TABLE B-1 Requirements Matrix Code Guidance Requirement Planning Standard Evaluation Criteria ESP Illinoisa DeWittb Educational information on 7.1 5C 2K radiation Contact for additional 7.1 5C 2K information Protective measures, e.g. 7.1; 7.2 5C 2K evacuation routes and relocation centers, sheltering, respiratory protection, radioprotection drugs Special needs of the 7.1 5C 2K handicapped and transient population Means for accomplishing this 7.1 5C 2K dissemination may include, but are not limited to: information in the telephone book, periodic information in utility bills, posting in public areas, and publications distributed on an annual basis.

A,S,L

2. Each organization shall describe 7.5 5C 2K a program for acquainting news media on a periodic basis (at least annually) with the emergency plans, information concerning radiation, and points of contact for release of public information in an emergency. A,S,L 10 CFR NUREG-0654 REV 1, H. Emergency Facilities and CH 8 52.17(b)(2)(i) SUPPLEMENT 2, Equipment 10 CFR Section V 50.47(b)(8) 10 CFR 50 APP E IV (E)

DEL-096-REV0 B-9

APPENDIX B - REQUIREMENTS MATRIX EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT TABLE B-1 Requirements Matrix Code Guidance Requirement Planning Standard Evaluation Criteria ESP Illinoisa DeWittb Adequate emergency facilities CH 8 and equipment to support the emergency response are described.

1. Each applicant shall describe a 8.1 NR NR TSC and an OSC in accordance with NUREG-0696 Functional Criteria for ER Facilities, Feb.

1981. A

2. Describe an EOF from which 8.2 NR NR evaluation and coordination of all licensee (applicant) activities related to an emergency is to be carried out and from which the licensee (applicant) shall provide information to F, S, and L authorities responding to emergencies in accordance with NUREG 0696. A

3. Each off-site organization shall NR but in 1F(1) 1C; 2E describe an EOC for use in 8.3 directing and controlling response functions. S,L 10 CFR NUREG-0654 REV 1, I. Accident Assessment CH 9 52.17(b)(2)(i) SUPPLEMENT 2, 10 CFR Section V 50.47(b)(9) 10 CFR 50 APP E IV (B)

Adequate methods, systems CH 9 and equipment are described for assessing and monitoring actual or potential off-site consequences of a radiological emergency condition.

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EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT APPENDIX B - REQUIREMENTS MATRIX TABLE B-1 Requirements Matrix Code Guidance Requirement Planning Standard Evaluation Criteria ESP Illinoisa DeWittb

1. Provide a description of the 9.1.3; APP NR but in NR contacts and arrangements made A 3A(8) with off-site organizations for acquiring and evaluating met information. Describe how suitable met data will be made available to the State. A

2. Describe the contacts and 9.2; 9.2.3 3A(4) Included in arrangements made for field Illinois Plan monitoring within the plume at 3a(4) exposure EPZ. A,S,L

3. Contacts and arrangements to 9.2; 9.2.1; 3A(8) NR but locate and track airborne 9.2.3 Included in radioactive plume, using either or Illinois State both F and S resources, shall be Plan at 3A(8) described. A,S 10 CFR NUREG-0654 REV 1, J. Protective Response CH 10 52.17(b)(2)(i) SUPPLEMENT 2, 10 CFR Section V 50.47(b)(10) 10 CFR 50 APP E IV (B)

A range of protective actions CH 10 is described for the plume exposure pathway EPZ for the public and emergency workers. Guidelines for the choice of protective actions during an emergency, consistent with federal guidance, and protective actions for the ingestion exposure pathway EPZ appropriate to the locale are described.

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APPENDIX B - REQUIREMENTS MATRIX EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT TABLE B-1 Requirements Matrix Code Guidance Requirement Planning Standard Evaluation Criteria ESP Illinoisa DeWittb

1. Describe the evacuation routes 10.1.3: 1E(4) Included in and transportation for on-site Illinois Plan individuals to some suitable off-site at 1E(4) location, including alternatives for inclement weather, high traffic density, and specific radiological conditions. A,S,L

2. Describe a mechanism for 10.1.6 NR NR recommending protective actions to the appropriate S and L authorities IAW the Manual of PAGs and Protective Actions for Nuclear Incidents (EPA 400-R-92-001). A

3. Prepare ETE within plume 2.3; Table NR NR exposure EPZ in accordance with 2.3-5 Appendix 4 of 0654 Revision 1. A

4. Each organization concept for 10.1.7; 1E(4) 2J implementing protective measures 10.1.8 for the plume EPZ shall be described, including items such as those listed below, if available.

Where appropriate, a description of contacts and arrangements made with off-site agencies with Appendix A emergency planning responsibilities must be included.

a. Maps showing evacuation Figs. 2.2-1; 1E(4) 2J; Annexes routes, evacuation areas, shelter 2.3-1 2A-2F; areas, and relocation centers in Map A; host areas. A,S,L Map C

b. Maps showing population Fig. 2.2-2 1E(4) 1A Table 1 districts around site. This shall and Map be by evacuation areas. Each applicant shall also present the information in a sector format.

A,S,L DEL-096-REV0 B-12

EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT APPENDIX B - REQUIREMENTS MATRIX TABLE B-1 Requirements Matrix Code Guidance Requirement Planning Standard Evaluation Criteria ESP Illinoisa DeWittb

c. Proposed means for notifying 6.1 1E(4) 2G; 2I; 2P; all segments of the transient and Annexes 2A-resident population. A,S,L 2F

d. Proposed means for protecting NR 1E(4) Annex 2A those persons whose mobility Attachments may be impaired (e.g., institution 1 and 5; or other confinement). S,L Annex 2B Attachment 4; Annex 2C Attachment 4; Annex 2E Attachment 4

e. Proposed means for the use of NR but in 1E(4) 2O(3)

KI for emergency workers and 10.1.5.3 institutionalized persons within the plume EPZ whose immediate evacuation may be infeasible or very difficult. S,L

f. Proposed means of relocation. NR 1E(4) 2J; Annexes S,L 2A-2F; Appendix C; Appendix D; Map C

g. Potential relocation centers in NR but in 1E(4) Appendix D; host areas, which are at least 5 10.3 Map C mi, and preferably 10 mi, beyond the boundaries of the plume EPZ. S,L

h. Projected traffic capacities of NR but in 1E(4) 2J; Map A; evacuation routes under 2.3; Map C emergency conditions. S,L DEL-096-REV0 B-13

APPENDIX B - REQUIREMENTS MATRIX EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT TABLE B-1 Requirements Matrix Code Guidance Requirement Planning Standard Evaluation Criteria ESP Illinoisa DeWittb

i. Control of access to evacuated NR 1E(4) 1D(1);

areas and organization Appendix B; responsibilities for such control. Annex 2A S,L Attachment 8; Map A

j. Identification of and means for NR 1E(4) 1D(1); 1D(4);

dealing with potential Appendix B; impediments (e.g., seasonable Annex 2A impassability of roads) to use of Attachment evacuation routes and 1; Map A contingency measures. S,L

k. Time estimates for evacuation NR but in 1E(4) Included in of various sectors and distances 2.3, Table Illinois Plan based on a dynamic analysis 2.3-5 at 1E(4)

(time-motion study under various conditions) for the plume EPZ (see Appendix 4 of 0654 Revision 1 and Section II of 0654 Revision 1 Supplement 2). S,L

l. The basis for the choice of NR but in 1E(4) 3 recommended PAs from the 2.3, Table plume exposure pathway during 2.3-5; 10.2; emergency conditions. This shall Figure 10.2-include expected local protection 1 afforded in residential units or other shelter for direct and inhalation exposure, as well as evacuation time estimates. S,L

5. Describe the means for NR but in 1E(4); 1E(5) 2J(3) (f);

registering and monitoring 10.3 (b); 3C(1) Appendix D; evacuees at reception centers in Appendix E; host areas. S,L 2J(4) 10 CFR NUREG-0654 REV 1, K. Radiological Exposure Control CH 11 52.17(b)(2)(i) SUPPLEMENT 2, 10 CFR Section V 50.47(b)(11)

DEL-096-REV0 B-14

EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT APPENDIX B - REQUIREMENTS MATRIX TABLE B-1 Requirements Matrix Code Guidance Requirement Planning Standard Evaluation Criteria ESP Illinoisa DeWittb Means are described for CH 11 controlling radiation exposure to emergency workers in an emergency.

1. Describe guidelines on dose 11.2; NR NR but in limits for: Table 11.1- 2O(2) 1

a. Removal of injured persons. 11.2 NR NR but in 2O(2)

b. Undertaking corrective actions. 11.2 NR NR but in 2O(2)

c. Performing assessment 11.2 NR NR but in actions. 2O(2)

d. Performing field radiological 11.2 NR NR but in measurements in the plume 2O(2)

EPZ.

e. Providing first aid. 11.2 NR NR but in 2O(2)

f. Performing personnel 11.2 NR NR but in decontamination. 2O(2)

g. Providing ambulance service. 11.2 NR NR but in 2O(2)

h. Providing medical treatment 11.2 NR NR but in services. A 2O(2)

2. Describe an on-site radiation 11.2 NR NR protection program to be implemented during emergencies, including methods to implement dose limits. General guidance on dose limits for workers performing emergency services can be found in EPA 400-R-92-001. A DEL-096-REV0 B-15

APPENDIX B - REQUIREMENTS MATRIX EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT TABLE B-1 Requirements Matrix Code Guidance Requirement Planning Standard Evaluation Criteria ESP Illinoisa DeWittb 3.a. Describe how to determine 11.2.1 1E(5) (b) 2O(1) doses received by emergency personnel involved in any nuclear accident, including volunteers.

A,S,L 3.b. Describe how to acquire and 11.2.1 1E(4); 1E(5) 2O(1) distribute dosimeters, both direct (b); 3A(8) reading and permanent record devices. A,S,L

4. Describe a decision chain for 11.2.2 1E(4); 3A(8) Included in authorizing emergency workers to Illinois Plan incur exposures in excess of the at 1E(4);

EPA dose limits for workers 3A(8) performing emergency services.

A,S,L 5.a. Specify action levels for 11.2.3; 1E(5) (b); Included in determining the need for 11.2.5 3A(8) Illinois Plan decontamination of emergency at 1E(5) (b);

workers, equipment and vehicles, 3A(8) and the general public and their possessions. A,S,L 5.b. Describe a means for 11.2.3 1E(5) (b); 2O(4) decontamination of emergency 3A(8) personnel wounds, supplies, instruments and equipment. A,S,L 10 CFR NUREG-0654 REV 1, L. Medical and Public Health CH 12 52.17(b)(2)(i) SUPPLEMENT 2, Support 10 CFR Section V 50.47(b)(12)

Contacts and arrangements CH 12 are described for medical services for contaminated injured individuals.

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EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT APPENDIX B - REQUIREMENTS MATRIX TABLE B-1 Requirements Matrix Code Guidance Requirement Planning Standard Evaluation Criteria ESP Illinoisa DeWittb

1. Describe the contacts and 12.1;12.3; Included in 1E; 2A arrangements made for local and APP A Local Plan at backup hospitals and medical 1E; 2A services having the capability for evaluation of radiation exposure and uptake. A,S,L

2. Each state shall develop lists NR 3A(9) NR but indicating the location of public, included at private, and military hospitals and Annex 2A other emergency medical services Attachment facilities within the state or 19 contiguous states considered capable of providing medical support for any contaminated injured individual. The listing shall include the name, location, type of facility and capacity, and any special radiation capabilities.

Contacts and arrangements made in developing this list should be described. S 10 CFR NUREG-0654 REV 1, M. General Plans for Recovery and NR but NR but 1B NR but 2F; 52.17(b)(2)(i) SUPPLEMENT 2, Re-entry are developed Chapter 13 Appendix F 10 CFR Section V 50.47(b)(13) 10 CFR 50 APP E IV (H) 10 CFR NUREG-0654 REV 1, N. Periodic Exercises are Conducted NR Chapter NR but 6A NR but 2M 52.17(b)(2)(i) SUPPLEMENT 2, 14 -

10 CFR Section V Placeholder 50.47(b)(14) only 10 CFR 50 APP E IV (F)

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APPENDIX B - REQUIREMENTS MATRIX EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT TABLE B-1 Requirements Matrix Code Guidance Requirement Planning Standard Evaluation Criteria ESP Illinoisa DeWittb 10 CFR NUREG-0654 REV 1, O. Radiological Emergency CH 15 52.17(b)(2)(i) SUPPLEMENT 2, Response Training 10 CFR Section V 50.47(b)(15) 10 CFR 50 APP E IV (F)

A Radiological Emergency CH 15 Response Training Program is described for those who may be called on to assist in an emergency.

1. Describe a training program for 15.1; 15.2 6B 2L instructing and qualifying personnel who will implement radiological emergency response plans.

Specialized internal training and periodic retraining shall be provided in the following categories: A,S,L

a. Directors or coordinators of the 15.4.1.1 6B 2L response organizations

b. Personnel responsible for 15.4.1.2 6B 2L accident assessment

c. Radiation monitoring teams 15.4.1.3 6B 2L and radiation analysis personnel

d. Police, security and fire 15.4.1.4 6B 2L fighting personnel

f. First aid and rescue personnel 15.4.1.6 6B 2L

g. Local support services 15.4.1.7 6B 2L personnel including Civil Defense

/emergency services personnel

h. Medical support personnel 15.4.1.8 6B 2L DEL-096-REV0 B-18

EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT APPENDIX B - REQUIREMENTS MATRIX TABLE B-1 Requirements Matrix Code Guidance Requirement Planning Standard Evaluation Criteria ESP Illinoisa DeWittb

i. Personnel responsible for 15.4.1.9; 6B 2L transmission of emergency 15.4.1.10 information and instructions.

10 CFR NUREG-0654 REV 1, P. Responsibility for the Planning CH 16 52.17(b)(2)(i) SUPPLEMENT 2, Effort: Development, Periodic 10 CFR Section V Review and Distribution of 50.47(b)(16) Emergency Plans 10 CFR 50 APP E IV (G)

Responsibilities are CH 16 established for plan development and review and for distribution of emergency plans, and training is described for planners.

1. Each organization shall provide 16.1 6B 2N for the training of individuals responsible for the planning effort.

A,S,L

2. Each organization shall identify 16.2 6C; 6D 2N by title the individual with the overall authority and responsibility for radiation emergency response planning. A,S,L

3. Each organization shall 16.3 6C 2N designate an Emergency Planning Coordinator with responsibility for the development and updating of emergency plans and coordination of these plans with other response organizations. A,S,L

4. Each organization shall update 16.4 6C 2N its plan and agreements as needed. A,S,L DEL-096-REV0 B-19

APPENDIX B - REQUIREMENTS MATRIX EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT TABLE B-1 Requirements Matrix Code Guidance Requirement Planning Standard Evaluation Criteria ESP Illinoisa DeWittb

5. The emergency plans and 16.4; 16.5 6C 2N approved changes to the plans shall be forwarded to all organizations and appropriate individuals with responsibility for implementation of the plans.

Revised pages shall be dated and marked to show where changes have been made. A,S,L

6. Each plan shall contain a 16.7 6D 2N specific table of contents. Plans submitted for review should be cross-referenced to this supplement. A,S,L Notes:

a Illinois Plan for Radiological Accidents (IPRA). Volume I. Concept of Operations. May 2001.

b Illinois Plan for Radiological Accidents (IPRA). Volume VIII. Clinton Plan. July 2001.

c NR = Not required.

d A = Applicant; S = State; L = Local; F = Federal DEL-096-REV0 B-20

APPENDIX C References 10 CFR 20. Code of Federal Regulations. Standards for Protection Against Radiation.

10 CFR 50. Code of Federal Regulations. Domestic Licensing of Production and Utilization Facilities.

10 CFR 52. Code of Federal Regulations. Early Site Permits; Standard Design Certification; and Combined Licenses for Nuclear Power Plants.

10 CFR 73. Code of Federal Regulations. Physical Protection of Plant and Materials.

10 CFR 100. Code of Federal Regulations. Reactor Site Criteria.

15 CFR 950. Code of Federal Regulations. Environmental Data and Information.

29 CFR 1910. Code of Federal Regulations. General Industry Standards.

44 CFR 350. Code of Federal Regulations. Review and Approval of State and Local Radiological Emergency Plans and Preparedness.

49 CFR 171. Code of Federal Regulations. General Information, Regulations, and Definitions.

49 CFR 172. Code of Federal Regulations. Hazardous Materials Table, Special Provisions, Hazardous Materials Communications, Emergency Response Information, and Training Requirements.

American Nuclear Insurers (ANI). Accident Notification Procedures for Liability Insureds. Bulletin #5B. 1981.

American Nuclear Insurers (ANI)/Mutual Atomic Energy Liability Underwriters (MAELU).

Emergency Planning. Engineering Inspection Criteria For Nuclear Liability Insurance. Section 6.0, Revision 1. No date.

Bureau of Transportation Statistics. National Transportation Atlas. 2000.

Clinton Chamber of Commerce (CCC). Number of Small Businesses. Available at:

www.clintonillinois.com. August 8, 2002.

Exelon Generation Company (EGC), LLC. Exelon Nuclear Standardized Radiological Emergency Plan. Revision 14. February 2003.

Federal Bureau of Investigation (FBI). Federal Bureau of Investigation and Nuclear Regulatory Commission Memorandum of Understanding for Cooperation Regarding Threat, Theft, or Sabotage in U.S. Nuclear Industry. Federal Register. Volume 44, p. 75535.

December 20, 1979.

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APPENDIX C - SOURCES AND REFERENCES EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT Federal Emergency Management Agency (FEMA). Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants. FEMA-REP-10. Section E.6.2.1. November 1985.

Federal Emergency Response Agency (FERA). Federal Radiological Emergency Response Plan.

May 1, 1996.

Illinois Agricultural Statistics Service (IASS). Illinois Farm Report. Volume 23. No. 4. March 25, 2002.

Institute of Nuclear Power Operations (INPO). "Emergency Resources Manual." No.03-001.

January 2003.

Institute of Nuclear Power Operations (INPO). Institute of Nuclear Power Operations (INPO) Coordination Agreement on Emergency Information among Society of Cost Estimating and Analysis, EPRI, INPO, Nuclear Utility Management and Resources Council and their Member Utilities. April 1988.

Memorandum of Understanding (MOU). Memorandum of Understanding (MOU) between U.S. Nuclear Regulatory Commission (USNRC) and Federal Emergency Management Agency (FEMA). December 1, 1991.

National Center for Education Statistics (NCES). Available at:

http://www.capitolimpact.com. July 2, 2002.

National Fire Protection Association (NFPA), Inc. Standards for Competencies for EMS Personnel Responding to Hazardous Materials Incidents. NFPA-473. February 7, 1997.

National Fire Protection Association (NFPA), Inc. Standard on Industrial Fire Brigades. NFPA-600. February 2, 1996.

Nuclear Utility Management and Resources Council (NUMARC. Now NEI.) Methodology for Development of Emergency Action Level. NESP-007. Revision 2. 1994.

State of Illinois. Concepts of Operations. The Illinois Plan for Radiological Accidents (IPRA).

Volume I. May 2001.

State of Illinois. Clinton Power Station. The Illinois Plan for Radiological Accidents (IPRA).

Volume VIII. July 2001a.

U.S. Census Bureau. 2000 Census Summary File 1. July 15, 2002.

U.S. Census Bureau. Census 2000 County and County Equivalent Areas of Illinois Generalized Boundary File. Available at:

http://www.census.gov/geo/www/cob/co2000.html. June 26, 2002b.

U.S. Census Bureau. Census 2000 Incorporated/Census Designated Places of Illinois Generalized Boundary File. Available at:

http://www.census.gov/geo/www/cob/pl2000.html. June 26, 2002a.

U.S. Census Bureau. Census 2000 TIGER/Line Files (machine-readable data files). Roads, Railroads, and Water Features. Washington D.C. 2000.

U.S. Department of Energy (USDOE), Region 5. Radiological Assistance Plan. No date.

C-2 DEL-096-REV0

EMERGENCY PLAN FOR THE EGC EARLY SITE PERMIT APPENDIX C - SOURCES AND REFERENCES U.S. Environmental Protection Agency (USEPA). Manual of Protective Action Guides and Protective Actions for Nuclear Incidents. 400-R-92-001. May 1992.

U.S. Nuclear Regulatory Commission (USNRC). Concept of Operations: NRC Incident Response. NUREG-1471. February 1994.

U.S. Nuclear Regulatory Commission (USNRC). Criteria for Emergency Planning in Early Site Permit Application, Draft Report for Comment. NUREG-0654/FEMA-REP-1. Revision 1.

Supplement 2. April 1996.

U.S. Nuclear Regulatory Commission (USNRC). Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants.

NUREG-0654/FEMA REP-1. Revision 1. November 1980.

U.S. Nuclear Regulatory Commission (USNRC). Criteria for Protective Action Recommendations for Severe Accidents, Draft Report for Interim Use and Comment. NUREG-0654/FEMA-REP-1. Revision 1, Supplement 3. July 1996b.

U.S. Nuclear Regulatory Commission (USNRC). Emergency Planning and Preparedness for Nuclear Power Reactors. Regulatory Guide 1.101. Revision 3. August 1992.

U.S. Nuclear Regulatory Commission (USNRC). Functional Criteria for Emergency Response Facilities. NUREG-0696. Revision 1. August 1980a.

U.S. Nuclear Regulatory Commission (USNRC). Incident Response Plan. NUREG-0728. June 1987.

U.S. Nuclear Regulatory Commission (USNRC). Planning Basis for the Development of State and Local Government Radiological Emergency Response Plans in Support of Light Water Nuclear Power Plants. NUREG-0396. December 1978.

U.S. Nuclear Regulatory Commission (USNRC). Response Technical Manual (RTM-96). March 1996a.

U.S. Nuclear Regulatory Commission (USNRC). Requirements for Emergency Response Capability. NUREG-0737. Supplement 1. December 1982.

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