ML15106A223

April 22, 2015, Meeting with Southern Nuclear Company, Draft Standard Emergency Plan

ML15106A223
Person / Time
Site:	Hatch, Vogtle, Farley
Issue date:	04/17/2015
From:	Southern Nuclear Operating Co
To:	Office of Nuclear Reactor Regulation
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ML15106A195	List: ML15106A204 ML15106A223 ML15106A265 ML15106A361
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Download: ML15106A223 (84)

Text

Southern Nuclear Operating Company Standard Emergency Plan T

FINAL DRAFT AF R

D

SNC Emergency Plan DRAFT Table of Contents INTRODUCTION......................................................................................................................................6 DEFINITIONS ...........................................................................................................................................7 SECTION A: ASSIGNMENT OF RESPONSIBILITY .......................................................................10 A.1 Primary Federal Organizations .....................................................................................................10 A.2 State and Local Organizations .......................................................................................................11 A.4 Other Utilities ..................................................................................................................................13 A.5 Agreements ......................................................................................................................................13 SECTION B: EMERGENCY RESPONSE ORGANIZATION (ERO) .............................................14 B.1 Normal Plant Organization ............................................................................................................14 B.2 On Site Emergency Response Organization (ERO) ....................................................................15 B.2.1 T

Figure B.2.A Transition of Command and Control Functions ............................................................. 15 Technical Support Center (TSC) ......................................................................................... 15 B.2.2 B.3.1 B.3.2 AF Operations Support Center (OSC) ........................................................................................ 17 B.3 Offsite Emergency Response Organization (ERO) ......................................................................18 EOF Organization................................................................................................................. 19 Joint Information Center (JIC) .............................................................................................. 21 B.5 Letters of Agreement (LOAs) .........................................................................................................23 R

B.6 Local Emergency Support Organizations......................................................................................23 Figure B.2.B - Technical Support Center Organization ...................................................................... 29 Figure B.2.C - Operational Support Center Organization ................................................................... 30 D

Figure B.2.D - Emergency Operations Facility Organization ............................................................. 31 Figure B.2.E - Joint Information Center Organization ........................................................................ 32 SECTION C: EMERGENCY RESPONSE SUPPORT AND RESOURCES ....................................33 C.1 Federal Assistance ...........................................................................................................................33 C.2 State Interfaces ................................................................................................................................33 C.3 Radiological Laboratories ...............................................................................................................33 C.4 Assistance Agreements ....................................................................................................................33 SECTION D: EMERGENCY CLASSIFICATION SYSTEM ............................................................36 D.1 Classification of Emergencies .........................................................................................................36 D.2 Basis for Emergency Classification Criteria ..................................................................................37 SECTION E: NOTIFICATION METHODS AND PROCEDURES..................................................41 E.1 Notification Methodology................................................................................................................41 2

SNC Emergency Plan DRAFT E.2 Notification of Personnel .................................................................................................................41 SECTION F: EMERGENCY COMMUNICATIONS .........................................................................46 F.1 Communications ..............................................................................................................................46 F.2 Medical Emergency Communications ...........................................................................................47 F.3 Communications Tests ....................................................................................................................48 SECTION G: PUBLIC EDUCATION AND INFORMATION ..........................................................49 G.1 Purpose.............................................................................................................................................49 G.2 News Media Training .....................................................................................................................49 G.3 News Releases ..................................................................................................................................49 G.4 Press Briefings .................................................................................................................................49 G.5 Public Response...............................................................................................................................49 G.6 Resource Materials .........................................................................................................................49 T

G.7 Public Information Plan For Recovery .........................................................................................50 G.8 Public Information and Education Program ...............................................................................50 AF SECTION H: EMERGENCY FACILITIES AND EQUIPMENT .....................................................51 H.1 Onsite Emergency Response Facilities ..........................................................................................51 H.2 Offsite Emergency Facilities ..........................................................................................................53 Figure H.2.A - Emergency Operations Facility Layout (Typical)....................................................... 55 H.3 State and local Emergency Operations Centers (EOC) ..............................................................56 R

H.4 Emergency Response Facility Staffing and Activation................................................................56 H.5 Onsite Monitoring ...........................................................................................................................56 D

H.6 Offsite Monitoring ..........................................................................................................................58 H.7 Meteorological Equipment .............................................................................................................59 H.8 Emergency Equipment Inventories and Checks ..........................................................................59 H.9 Emergency Kits ...............................................................................................................................59 H.10 Collection Point for Field Samples ................................................................................................59 SECTION I: ACCIDENT ASSESSMENT ............................................................................................60 I.1 Systems and Parameters Monitored ..............................................................................................60 I.2 Continuing and Post Accident Assessment ....................................................................................60 I.3 Offsite Dose Assessment ..................................................................................................................60 I.4 Effluent Monitor Readings and Exposures....................................................................................61 I.5 Meteorological Monitoring .............................................................................................................61 I.6 Unmonitored Release ......................................................................................................................61 3

SNC Emergency Plan DRAFT I.7 Environs Surveys and Monitoring .................................................................................................61 I.8 Release Assessments ........................................................................................................................62 I.9 Environmental Radioiodine Monitoring Capabilities ...................................................................62 SECTION J: PROTECTIVE RESPONSE............................................................................................63 J.1 Alarm Responses .............................................................................................................................63 J.2 Radiological Monitoring of Evacuated Personnel .........................................................................63 J.3 Non-essential Personnel Evacuation and Decontamination .........................................................63 J.4 Onsite Protective Actions ................................................................................................................63 J.5 Offsite Protective Action Recommendations (PARs) ....................................................................65 J.6 Evacuation Time Estimates (ETE) .................................................................................................65 J.7 Protective Action Maps ...................................................................................................................65 SECTION K: RADIOLOGICAL EXPOSURE CONTROL ...............................................................66 T

K.1 Emergency Workers and Lifesaving Protective Actions ..............................................................66 Table K.1.A Emergency Worker Dose Limits ..................................................................................... 66 AF K.2 Emergency Exposure Authorization ..............................................................................................67 K.3 Exposure Controls ...........................................................................................................................67 K.4 Offsite Emergency Workers ...........................................................................................................68 K.5 Decontamination ..............................................................................................................................68 K.6 Contamination Controls..................................................................................................................68 R

K.7 Offsite Decontamination .................................................................................................................68 SECTION L: MEDICAL AND PUBLIC HEALTH SUPPORT.........................................................69 D

L.1 Hospital and Medical Services ........................................................................................................69 L.2 First Aid ...........................................................................................................................................69 L.3 State Emergency Medical Services .................................................................................................69 L.4 Medical Transport ...........................................................................................................................69 SECTION M: RECOVERY AND REENTRY PLANNING AND POSTACCIDENT OPERATIONS ................................................................................................................................70 M.1 Recovery ...........................................................................................................................................70 M.2 Recovery Organization....................................................................................................................72 Figure M.2 Typical Long Term Recovery Organization ..................................................................... 72 M.3 Recovery Notification ......................................................................................................................73 M.4 Population Exposure Estimates ......................................................................................................73 M.5 Termination of Recovery Phase......................................................................................................73 4

SNC Emergency Plan DRAFT SECTION N: EXERCISES AND DRILLS ...........................................................................................74 N.1 Exercises ...........................................................................................................................................74 N.2 Drills .................................................................................................................................................75 N.3 Scenarios ..........................................................................................................................................77 N.4 Exercise Evaluation and Critique...................................................................................................78 N.5 Exercise/Drill Corrective Actions ...................................................................................................78 SECTION O: RADIOLOGICAL EMERGENCY RESPONSE TRAINING ....................................79 O.1 Training ............................................................................................................................................79 O.2 Performance Demonstration...........................................................................................................79 O.3 First Aid Training............................................................................................................................79 O.4 ERO Training ..................................................................................................................................80 O.5 Emergency Preparedness Staff Training .......................................................................................81 T

SECTION P: RESPONSIBILITY FOR THE PREPAREDNESS EFFORT ....................................82 P.1 Fleet Emergency Preparedness.......................................................................................................82 AF P.2 Site Emergency Preparedness.........................................................................................................82 P.3 Coordination ....................................................................................................................................83 Figure P.1 - Typical Emergency Preparedness Organization............................................................... 84 R

D 5

SNC Emergency Plan DRAFT INTRODUCTION Purpose The Southern Nuclear Operating Companys (SNC) Emergency Plan provides the means to protect the health and safety of the general public, persons temporarily visiting or assigned to nuclear power plants operated by SNC, and plant employees. SNC operates the Hatch Nuclear Plant (HNP), Farley Nuclear Plant (FNP) and Vogtle Electric Generating Plant (VEGP).

Background

The SNC Emergency Plan was developed with the guidance 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." The SNC Emergency Plan meets the emergency planning standards of 10 CFR 50.47(b), the requirements of Appendix E and the intent of NUREG 0654 Revision 1. The SNC Emergency Plan is organized using the structure of NUREG-0654 Revision 1 and that structure provides the cross-reference to the base document.

Scope T

Detailed procedures concerning the implementation of the SNC Emergency Plan are in the Emergency Plan Implementing Procedures (EPIPs). Those documents describe the duties of individuals and groups in the event of emergencies and also serve as the interface between the AF SNC Emergency Plan and plant operations, security and radiological control programs. SNC also has procedures in place that implement on-site protective actions and personnel accountability during hostile action threats or events that are appropriate for plant and environmental conditions. These procedures are available for use at the plants. There are also various supporting and complementing emergency plans, including those of federal agencies and those for the states of Alabama, Georgia, South Carolina, and associated counties.

R SNC has overall responsibility for maintaining a state of readiness to implement this Plan for the protection of plant personnel, the general public and property from hazards associated with any facility operated by the company. The authority for planning, developing, and D

coordinating emergency control measures is derived from being the Nuclear Regulatory Commission (NRC) license holder for the nuclear power plants operated by SNC.

The SNC Emergency Plan describes the organization and facilities, training, maintenance of facilities and equipment, both onsite and off-site, which will be used to address a wide spectrum of accidents ranging from minor onsite incidents to those that could affect the general public.

There are three phases of responsive action contained within the SNC Emergency Plan. The first phase includes initial actions directed toward the protection of personnel and the elimination of the potential for further exposure to the hazard. The second phase includes immediate and planned action directed toward termination of the condition, containment of any effluent, establishment of incident boundaries, establishment of control, channeling of information, and protection of the facility and equipment. The third phase is to restore the facility to its normal operating condition. To respond effectively utilizing these phases, emergencies are classified according to increasing severity as Unusual Event, Alert, Site Area Emergency or General Emergency.

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SNC Emergency Plan DRAFT DEFINITIONS The following are definitions of terms commonly used in this Emergency Plan and each site specific Annex.

Area Radiation Monitoring System (ARMS)

An instrumentation system designed to detect abnormal area radiation levels and activate corresponding station alarms.

Committed Dose Equivalent (CDE)

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

Committed Effective Dose Equivalent (CEDE)

CEDE is the sum of the products of the weighting factors applicable to each of the body organs or tissues that are irradiated and the CDE to these organs or tissues.

Deep-Dose Equivalent (DDE)

T DDE is the dose equivalent at a tissue depth of 1 cm (1000 mg/cm2), which applies to external whole- body exposure.

Dose Equivalent (DE)

AF DE is the product of the absorbed dose in tissue, quality factor and all other necessary modifying factors at the location of interest. The units of dose equivalent are the rem and sievert (Sv).

Effective Dose Equivalent (EDE)

R EDE is the sum of the products of the dose equivalent to each organ or tissue and a weighting factor applicable to each of the body organs or tissues that are irradiated.

Emergency Action Levels (EALs)

D Parameters used to designate a particular classification of emergency. These parameters may include radiological dose rates, levels of airborne or waterborne activity, or instrument indications/plant parameter values.

Exclusion Area Boundary An area surrounding the reactor in which the reactor licensee has the authority to determine all activities, including exclusion or removal of personnel and property from the area.

Hostile Action An act towards a nuclear power plant or its personnel that includes the use of violent force to destroy equipment, take hostages, and/or intimidates the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, projectiles, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. Hostile action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the nuclear power plant. Non-terrorist based EALs should be used to address such activities, (e.g., violent acts between individuals in the owner controlled area).

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SNC Emergency Plan DRAFT Independent Spent Fuel Storage Installation (ISFSI)

A complex designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage.

Ingestion Exposure Pathway Emergency Planning Zone (IPZ)

The IPZ is the fifty-mile radius area around an SNC operated plant site for which protective actions for the general population, farmers, dairy farmers, ranchers, food processors and distributors are planned.

Inplant The area located within the confines of the SNC Plant Power Block Protected Area.

Letters of Agreement (LOA)

Letters of agreement include contracts, letters or other formal agreements between Southern Company and/or SNC operated plants and certain off site resources who provide assistance during emergency events, including a Hostile Action, at SNC operated plants.

Nuclear Administrative and Technical Manual (NATM)

T The collection of onsite programs and procedures which prescribes how SNC operated plants are controlled, operated, maintained, and tested to meet the requirements of applicable licenses, AF standards, codes, and guides. It establishes effective management practices.

Offsite Any position or area not located within the confines of the Site Boundary.

Onsite Any position or area located within the confines of the Site Boundary.

R Owner Controlled Area The area owned by the licensee and located within the confines of the Site Boundary.

D Plume Exposure Pathway Emergency Planning Zone (EPZ)

The Plume Exposure Pathway EPZ is the ten-mile radius area around an SNC operated plant site for which protective actions are planned.

Protected Area(s) (PA)

An area, located within the Site Exclusion Area Boundary, encompassed by physical barriers and to which access is controlled per 10 CFR 73.55. The SNC Power Block Protected Area and the ISFSI Protected Area are two Protected Areas located within the Site Owner Controlled Area.

Protective Actions Emergency measures taken to avoid or reduce radiation dose. These commonly include sheltering, evacuation, and prophylaxis.

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SNC Emergency Plan DRAFT Protective Action Recommendations (PARs)

Protective actions recommended by an SNC operated plant to governmental authorities to protect the health and safety of the public within the plume exposure pathway during an emergency event at an SNC operated plant.

Protective Action Guides (PAGs)

The projected dose to individuals that would warrant consideration of protective action against an accidental release of radioactive material.

Sabotage Deliberate damage, misalignment, or mis-operation of plant equipment with the intent to render the equipment inoperable. Equipment found tampered with or damaged due to malicious mischief may not meet the definition of sabotage until this determination is made by security supervision.

Security Condition Any security event as listed in the approved security contingency plan that constitutes a T

threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A security condition does not involve a hostile action.

Site Boundary AF The boundary of a reactor site beyond which the land or property is not owned, leased, or otherwise controlled by the licensee.

Total Effective Dose Equivalent (TEDE)

TEDE is the sum of the Deep-Dose Equivalent (for external exposures) and the CEDE (for internal exposures).

Vital Areas R

Areas within the protected area that contain equipment vital to the operations of the plant.

D 9

SNC Emergency Plan DRAFT SECTION A: ASSIGNMENT OF RESPONSIBILITY A.1 Primary Federal Organizations A.1.1 Nuclear Regulatory Commission (NRC)

The NRC acts as the lead federal agency regarding technical matters during a nuclear incident, with the Chairman of the Commission as the senior NRC authority for response aspects. The Chairman can transfer control of emergency response activities when deemed appropriate.

Incident Response Centers have been established at the four NRC Regional Offices and NRC Headquarters, to centralize and coordinate NRCs emergency response.

Provision is made for NRC personnel at the plants Technical Support Center and the Emergency Operations Facility.

A.1.2 Department of Homeland Security (DHS)

In accordance with the National Response Framework (NRF), DHS is responsible for the overall coordination of a multi-agency Federal response to a significant radiological incident.

T A.1.3 Federal Emergency Management Agency (FEMA)

The primary role of FEMA is to support the states by coordinating the delivery of AF federal non-technical assistance. FEMA coordinates state requests for federal assistance, identifying which federal agency can best address specific needs. If deemed necessary, FEMA will establish a nearby Joint Field Office from which it will manage its assistance activities.

A.1.4 Department of Energy (DOE)

R The DOE provides radiological assistance upon request, and has radiological monitoring equipment and personnel resources that it can assemble and dispatch to the scene of a radiological incident. Following a radiological incident, DOE operates as outlined in the Federal Radiological Monitoring and Assessment Plan (FRMAP).

D The Radiological Assistance Team can be expected to respond to SNC operated sites as directed by the Savannah River Operations Office of DOE.

A.1.5 Federal Bureau of Investigation (FBI)

Support from the FBI is available through its statutory responsibility, based in Public Law and the US code, and through a memorandum of understanding for cooperation with the NRC. Notification to the FBI of emergencies in which they would have an interest will be through the provisions of a plant security plan, or by the NRC.

A.1.6 National Weather Service (NWS)

NWS provides meteorological information during emergency situations, if required.

Data available will include existing and forecasted wind directions, wind speeds, and ambient air temperatures.

A.1.7 Environmental Protection Agency (EPA)

The EPA can assist with field radiological monitoring, sampling, and non-plant related recovery and reentry guidance.

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SNC Emergency Plan DRAFT A.2 State and Local Organizations A.2.1 State of Alabama A.2.1.1 Alabama Emergency Management Agency (AEMA)

The Alabama Emergency Management Agency coordinates the Radiological Emergency Plans and offsite operations of affected state agencies and local governments including notification of state and local agencies of a nuclear incident at a Nuclear Power Plant impacting the State of Alabama, direction of activities at the state Emergency Operations Center, coordination of non-radiological operations with utility and federal authorities, and coordination of news information.

A.2.1.2 Alabama Department of Public Health, Radiation Control Division Through the State of Alabama Department of Public Health, the Alabama Radiation Control Division is responsible for initiating the "Alabama Radiological Response Plan for Nuclear Power Plants" in T

support of an emergency at the Farley Nuclear Plant. The State plan provides a detailed description of the notification procedures and responsibilities and duties of the local and state agencies involved.

A.2.1.3 public.

AF The Alabama Radiation Control Division has primary responsibility and authority for handling the offsite aspects of an emergency in Alabama with primary focus on the welfare and safety of the general Other Alabama State Agencies Responsibilities of the other state agencies are described in the R Alabama Radiological Response Plan for Nuclear Power Plants.

A.2.2 State of Georgia D

A.2.2.1 Georgia Emergency Management Agency (GEMA)

GEMA is responsible for general State emergency planning and overall direction and control of emergency or disaster operations as assigned by Executive Order and in accordance with the Georgia Emergency Operations Plan (GEOP). GEMA has responsibilities for coordinating the State of Georgia response to emergencies at nuclear power plants.

A.2.2.2 Department of Natural Resources (DNR)

The DNR has primary responsibility for implementation and administration of the State radiological emergency response function.

A.2.2.3 Other Georgia State Agencies Responsibilities of the other state agencies are described in the Georgia Emergency Operations Plan (GEOP).

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SNC Emergency Plan DRAFT A.2.3 State of South Carolina A.2.3.1 Emergency Management Division (EMD)

The EMD is assigned the responsibility for coordinating the emergency planning efforts of state, county, and municipal agencies in accordance with the South Carolina Radiological Emergency Response Plan (SCORERP);

conducting a preparedness program to assure capability of the government to execute the plan; establishing and maintaining a State EOC and providing support of the State emergency staff and work force; and establishing an effective system for reporting, analyzing, and disseminating emergency information.

A.2.3.2 Department of Health and Environmental Control (DHEC), Nuclear Emergency Planning Section The Department of Health and Environmental Control (DHEC) maintains a radiological hazard assessment capability and provides technical support, coordination, and guidance for the State and local T

governments. It will conduct and/or coordinate radiological surveillance and monitoring in coordination with DOE-Savannah River Site (SRS) and nuclear power plants. DHEC will obtain and A.2.3.3 AF coordinate radiological assistance resources from the Federal Government, other states, and the nuclear industry as required.

Other South Carolina State Agencies Responsibilities of the other state agencies are described in the South Carolina Radiological Emergency Response Plan (SCORERP).

A.2.4 Emergency Planning Zone (EPZ) Counties R

The Aiken, Allendale, Appling, Barnwell, Burke County, Early, Henry, Houston, Jeff Davis, Tattnall, and Toombs Emergency Management Organizations have the responsibility for notification and providing direction D to residents in the event of a major emergency that affects their respective area of responsibility. 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> notification points have the responsibility to notify necessary local civil support groups in the event of an accident. The County is responsible for protection of the public and can provide personnel and equipment for evacuation, relocation and isolation.

A.3 Contractor and Private Organizations A.3.1 Southern Nuclear/Southern Company Services Southern Company Services, Incorporated (SCS), serves as the architect-engineer.

A.3.2. Bechtel Power Corporation SNC has established an agreement with Bechtel Power Corporation to obtain engineering and construction services which may be required following an accident.

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SNC Emergency Plan DRAFT A.3.3 Westinghouse SNC has established an agreement with Westinghouse to obtain general services related to nuclear steam supply system (NSSS) operations during and following an accident situation. Westinghouse provides a capability to respond on a 24-hour-a-day basis.

A.3.4 General Electric Company (GE)

The licensee has established an agreement with GE to obtain general services related to nuclear steam supply system (NSSS) operations during and following an accident situation. GE provides a capability to respond on a 24-hour-a-day basis.

A.3.5 Radiological Monitoring Assistance Radiological monitoring in the plant and in the environs both onsite and offsite will be augmented by outside vendors as necessary. Initial radiological monitoring will be performed by available Southern Company resources, (e.g., Georgia Power Company (GPC) Central Laboratory).

A.3.6 Contract Laboratories T

SNC operated plants maintain contracts with offsite laboratories to assist with emergency analytical services. Copies of these contracts are maintained A.4 Other Utilities AF on file with the corporate Radiation Protection Department.

The Institute of Nuclear Power Operations (INPO) aids nuclear utilities in obtaining resources beyond their usual capabilities during recovery from an emergency. As one of its roles, INPO will assist affected utilities by applying the resources of the nuclear industry to meet the needs of an emergency.

A.5 Agreements R

Letters of Agreement (LOAs) are not necessary with federal and state agencies that are D

legally required to respond to an emergency; however, agreements are necessary if an agency is expected to provide assistance not required by law. Written agreements have been developed which establish the extent of operations between SNC operated plants and other support organizations which have an emergency response role consistent with this plan.

These agreements identify the emergency measures to be provided, the mutually accepted criteria for implementation, and the arrangements for exchange of information.

The respective nuclear power plants have obtained LOAs with private contractors and others who provide emergency support services. LOAs, as a minimum, state that the cooperating organization will provide their normal services in support of an emergency at the affected plant. LOAs are referenced in the site-specific plant Annexes and the actual letters are maintained on file for each plant in accordance with 10 CFR 50, Appendix E, IV.A.7.

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SNC Emergency Plan DRAFT SECTION B: EMERGENCY RESPONSE ORGANIZATION (ERO)

B.1 Normal Plant Organization The normal onsite organization of a SNC operated nuclear power plant provides a staff capable of providing the initial response to an emergency event. The On-Shift staff was validated by performing a detailed staffing analysis as required by Part 50 Appendix E.IV.9.

Organizational structures for each of the sites and the on-shift staffing tables are provided in the Site Specific Annex. The number and ERO position titles of personnel available within 90 minutes following declaration of an Alert or higher classification is shown in Tables 2, 3, 4 and 5.

SNC plants maintain 24-hour emergency response capability. The normal on-shift complement provides the initial response to an emergency. This group is trained to respond to emergency situations until the augmented Emergency Response Organization (ERO) arrives. The ERO is composed of personnel with specialties in operations, maintenance, engineering, radiochemistry, radiation protection, material control, fire protection, and security.

T B.1.1 The Shift Manager (SM) is in direct charge of plant operations during their shift and is directly responsible for the actions of the on-shift crew. In an emergency, the SM assumes the responsibility of the Emergency Director (ED) and takes necessary AF actions to identify and respond to the emergency until relieved by another qualified ED. The ED has the responsibility and authority to immediately and unilaterally initiate emergency actions, including providing notification of Protective Action (PAR) Recommendations to State and Local government organizations responsible for implementing off site emergency measures. The ED, at their discretion or when procedurally required, activates the ERO.

R The Emergency Directors non-delegable duties include:

Event classification in accordance with the emergency classification system; Perform the duties and responsibilities of Protective Action Recommendation D

(PAR) determination; Notifications of offsite agencies (approval of State /local and NRC notifications);

Authorization of emergency exposures in excess of federal limits; Issuance of potassium iodide (KI) to plant employees as a thyroid blocking agent; Request Federal assistance as needed.

After being relieved as Emergency Director, the Shift Manager directs the activities of the operating crew and is responsible for the safe operation of the plant. The Shift Manager, after relinquishing duties and responsibilities of the Emergency Director, functionally reports to the Operations Manager in the TSC.

B.1.2 Shift Supervisors, who hold Senior Reactor Operator (SRO) licenses, supervise operation of the unit and may assume the duties of the ED in the absence of the Shift Manager. Additional details of the normal on-shift organization are contained in the site-specific annexes to this Plan.

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SNC Emergency Plan DRAFT B.2 On Site Emergency Response Organization (ERO)

Augmentation of on-shift staffing will occur within 90 minutes of the declaration of an Alert or higher classification by the Emergency Response Organization (ERO). ERO positions for the TSC, OSC, EOF and JIC are detailed below. A sufficient number of personnel are qualified to ensure that positions listed in this section can be staffed on a 24 hour/day basis for an extended event. Figures B.2.B through B.2.E illustrate the overall augmented emergency response organization. On-shift as well as Offsite state/ local government interfaces are detailed in the site-specific Annexes.

Command and Control normally shifts from the Control Room to the Technical Support Center (TSC) and subsequently to the Emergency Operations Facility EOF. Command and control may move in either direction, depending upon conditions which would warrant passing such authority. Command and control may be completed sequentially or parallel, based upon the discretion of the ED's. A qualified ED in either facility can relieve the other facility of the command and control authority and responsibilities. Table B.2.A depicts the transition of command and control responsibilities between facilities. Alternative Facilities have been identified to ensure timely ERO response during a hostile action event. Details on T

the Alternative Facilities are included in Section H.

CONTROL ROOM Shift Manager/Emergency Director Classification Notifications PARs AF TSC TSC Emergency Director Classification EOF EOF Emergency Director Notifications PARs Controls R Emergency Exposure Emergency Exposure Controls Figure B.2.A Transition of Command and Control Functions D

B.2.1 Technical Support Center (TSC)

B.2.1.1 TSC Emergency Director (ED)

The TSC ED has the authority and responsibility to immediately initiate any emergency actions. Once command and control has been completed, the TSC ED assumes the non-delegable duties of event Classification, on site Emergency Exposure Authorization and on site protective actions.

B.2.1.2 TSC Manager The TSC Manager reports to the TSC ED and is responsible for coordination of activities between the TSC and other emergency response facilities, directs the activities of the TSC staff and ensures communications are established with applicable offsite agencies.

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SNC Emergency Plan DRAFT B.2.1.3 Operations Supervisor The Operations Supervisor reports to the TSC Manager. Major position functions include evaluating plant conditions and initiating mitigative actions, coordinating TSC efforts in determining the nature and extent of plant conditions affecting plant equipment, actions to limit or contain the emergency, invoking the provisions of 10 CFR 50.54(x) if appropriate, assist the OSC Manager in determining the priority assigned to OSC activities and timely completion of offsite notifications.

B.2.1.4 Maintenance Supervisor The Maintenance Supervisor reports to the TSC Manager and is responsible for planning and coordination of repair, damage control, and plant modification activities. The Maintenance Supervisor works closely with the Engineering Supervisor in planning for plant modifications and repairs.

B.2.1.5 Radiation Protection (RP) Supervisor The RP Supervisor reports to the TSC Manager and supervises the activities of the radiation protection staff and Health Physics Network (HPN) Communicator. The T

RP Supervisor assists the Radiation Protection/Chemistry Group Lead in the OSC in determining the extent and nature of radiological or hazardous conditions and coordinates offsite dose assessment and offsite Field Monitoring Teams prior to AF EOF activation.

B.2.1.6 Dose Analyst The Dose Analyst reports to the RP Supervisor. The Dose Analyst operates the dose assessment model to provide estimates of environmental dose in the event of a radiological release attributable to the event.

R B.2.1.7 Engineering Supervisor The Engineering Supervisor reports to the TSC Manager. The TSC Engineering Supervisor is responsible for the overall direction of Engineering Group activities D and assessment. The Engineering Supervisor also directs the analysis of plant problems, core damage, and provides recommendations for plant modifications to mitigate the effects of the accident.

B.2.1.8 Reactor Engineer The Reactor Engineer reports to the Engineering Supervisor in the TSC. The Reactor Engineer is responsible for monitoring core conditions and providing recommendations to maintain the viability of the core. The Reactor Engineer relieves the STA of Core Thermal analysis responsibilities.

B.2.1.9 Electrical Engineer The Electrical Engineer reports to the Engineering Supervisor in the TSC. The Electrical Engineer is responsible for monitoring the site electrical systems and planning corrective actions as appropriate.

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SNC Emergency Plan DRAFT B.2.1.10 Mechanical Engineer The Mechanical Engineer reports to the Engineering Supervisor in the TSC. The Mechanical Engineer is responsible for monitoring the site electrical systems and planning corrective actions as appropriate.

B.2.1.11 Chemistry Support The TSC Chemistry Support reports to the RP Supervisor. The TSC Chemistry Support is responsible for directing and evaluating in-plant chemistry and analyses, directing and evaluating post-accident sampling, and assisting in core damage assessment.

B.2.1.12 ENS Communicator The ENS Communicator reports to the Operations Supervisor and is responsible for ensuring NRC notifications are completed in accordance with the requirements of 10 CFR 50.72 and 73.

B.2.1.13 HPN Communicator T

The HPN Communicator reports to the RP Supervisor and is responsible for providing radiological and environmental information to the NRC via the HPN Line.

AF B.2.1.14 ERF Communicator The ERF Communicator reports to the TSC ED. The ERF communicator is responsible for staffing continuous communications links with their CR, OSC, EOF and JIC counterparts.

B.2.1.15 Security Supervisor R

The Security Supervisor reports to the TSC Manager. The TSC Security Supervisor is responsible for carrying out the plant security and Access Control program, maintaining personnel accountability onsite, assisting in evacuation of onsite areas.

D B.2.1.16 Support Coordinator The Support Coordinator reports to the TSC Manager and directs the clerical and logistic activities in the TSC and ensures that support staff, including clerks, status board keepers, and communicators, are available in sufficient numbers and that office supplies, drawings, and other documents are available to TSC and OSC personnel.

B.2.2 Operations Support Center (OSC)

B.2.2.1 OSC Manager The OSC Manager reports to the TSC Manager and directs a staff in providing labor, tools, protective equipment and parts needed for emergency repair, damage control, firefighting, search and rescue, first aid, and recovery.

B.2.2.2 Mechanical Maintenance Group Lead Mechanical Maintenance Group Lead reports to the OSC Manager and provides oversight for Mechanical Maintenance personnel. Their responsibilities include 17

SNC Emergency Plan DRAFT planning the activities, briefing/debriefing the Teams, tracking job progress and maintaining periodic communication with the teams.

B.2.2.3 Electrical Group Lead Electrical Group Lead reports to the OSC Manager and provides oversight for Electrical Maintenance personnel. Their responsibilities include planning work activities, team member selection and briefing, tracking job progress and maintaining communication B.2.2.4 RP / Chemistry Group Lead The RP / Chemistry Group Lead reports to the OSC Manager and provides oversight for RP and Chemistry Technicians. Their responsibilities include onsite radiological surveys, access control, personnel monitoring and decontamination, dosimetry issuance and monitoring, and onsite habitability surveys.

B.2.2.5 I&C Group Lead The I&C Group Lead reports to the OSC Manager and provides oversight for I&C Maintenance personnel. Their responsibilities include planning work activities, T

team member selection and briefing, tracking job progress and maintaining communication.

AF B.2.2.6 ERF Communicator The ERF Communicator reports to the OSC Manager and is responsible for maintaining communications with their counterpart in the Control Room, TSC, EOF and JIC.

B.2.2.7 OSC Personnel R

Selected personnel report to the OSC, as directed. Emergency personnel from the Maintenance, the Operations, and the RP/Chemistry Departments are directed to report to the OSC. OSC teams are headed by a designated team leader, who maintains communication with the OSC. The following emergency teams may be D formed by OSC personnel, as necessary; Search and rescue Repair Post accident sampling Internal survey Field monitoring B.3 Offsite Emergency Response Organization (ERO)

The EOF and JIC Organizations consist of staff members from the SNC, Alabama Power Company and Georgia Power Company Corporate Offices. This organization is responsible for providing offsite emergency response support and resources as needed. The EOF and JIC Organizations are displayed in Figures B.1.C and B.1.D.

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SNC Emergency Plan DRAFT B.3.1 EOF Organization The EOF Organization consists of selected management and staff members located in the SNC Corporate Office. This organization is responsible for providing offsite emergency response support and resources, as needed. The EOF Organization is displayed on Figure B.1.D. When the EOF is activated, EOF staff electronic devices are activated, and EOF personnel are expected to report to the EOF. Personnel who are not needed to augment positions are briefed and dismissed with a standby status.

B.3.1.1 EOF Emergency Director The EOF ED has overall coordinating authority for Southern Nuclear Company resources. Upon EOF activation, the EOF ED accepts responsibility for Notification and Protective Action Recommendation functions from the Control Room. The EOF ED is also responsible for keeping SNC Corporate Management informed regarding the emergency response and Classification upgrades.

B.3.1.2 EOF Manager The EOF Manager reports to the EOF ED and is responsible for managing and T

directing EOF activities, developing recovery plans, procuring outside services and equipment, as necessary, coordination with offsite agencies and approving news releases.

AF B.3.1.3 EOF Support Coordinator The Support Coordinator reports to the EOF Manager. The duties and responsibilities of the Support Coordinator in the EOF include providing oversight of the News Writer, providing assistance to the Support Coordinator in the Technical Support Center (TSC) for ordering equipment and materials needed and logistics arrangements for support personnel called in to assist in the emergency, including R

communications hardware, transportation, food, and lodging.

B.3.1.4 Dose Assessment Supervisor D The Dose Assessment Supervisor reports to the EOF Manager and provides oversight of dose assessment, field team control and protective action recommendation activities in the EOF and coordinates communication of results with offsite agencies.

B.3.1.5 Dose Analyst The Dose Analyst reports to the Dose Assessment Supervisor. The Dose Analyst operates the dose assessment model to provide estimates of environmental dose in the event of a radiological release attributable to the event.

B.3.1.6 Field Team Coordinator The Field Team Coordinator reports to the Dose Assessment Supervisor. The Field Team Coordinator develops the environmental sampling strategy in response to potential radiological releases and advises the Dose Assessment Supervisor and Dose Analyst of measured radiological values in the environment.

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SNC Emergency Plan DRAFT B.3.1.7 Field Team Communicator The Field Team Communicator reports to the Field Team Coordinator. The Field Team Communicator is responsible for communications with the Environmental Teams providing them sampling direction and plant status with respect to team safety.

B.3.1.8 ENN Communicator The ENN Communicator in the EOF reports to the Emergency Communication Coordinator and is responsible for providing Offsite Agency notifications and periodic updates.

B.3.1.9 ENS Communicator The ENS Communicator reports to the Emergency Communication Coordinator and is responsible for ensuring NRC notifications applicable to EOF operations are completed in accordance with the requirements of 10 CFR 50.72 and 73.

B.3.1.10 Emergency Communications Coordinator T

The Emergency Communications Coordinator reports to the EOF Manager. The Emergency Communications Coordinator is responsible for assisting with the coordination and facilitation of communications both within the facility as well as AF with external agencies.

B.3.1.11 Security Coordinator The Security Coordinator reports to the EOF Manager. The duties and responsibilities of the Security Coordinator will be assumed by SNC corporate security personnel. Responsibilities include supporting the plant security manager, keeping the EOF Manager informed of any security events/issues, communication of R

Security Related information to the NRC via the Security Bridge line as well as establishing and maintaining access control for the EOF.

B.3.1.12 Offsite Response Coordinator D The Offsite Response Coordinator reports to the EOF Manager. The duties and responsibilities of the Offsite Response Coordinator include coordination of activities concerning the dispatch and update of technical liaisons to State and local authorities and monitoring EOF functional areas to facilitate coordination between the licensee and State and local agencies.

B.3.1.13 HPN Communicator The HPN Communicator reports to the Dose Assessment Supervisor and is responsible for providing radiological and environmental information to the NRC via the HPN Line.

B.3.1.14 Administrative Support Staff The Administrative Support Staff report to the EOF Support Coordinator. The administrative support staff is responsible for providing clerical and administrative support to the Emergency organization, making entries to and retrieving data from 20

SNC Emergency Plan DRAFT Nuclear Network, retrieval of file documents and updating status boards using information provided from the sites.

B.3.1.15 Liaisons Liaisons report to the Offsite Response Coordinator and respond to the applicable State Emergency Operations Centers (EOCs) as required by the type and source of the event. Liaisons are assigned to Georgia, Alabama and/or South Carolina State EOCs depending on which SNC site declared the initiating event.

B.3.1.16 ERF Communicator The ERF Communicator reports to the EOF Emergency Director and is responsible for maintaining communications with their counterpart in the Control Room, TSC, OSC and JIC.

B.3.1.17 Nuclear Spokesperson The Nuclear Spokesperson speaks on behalf of the company, providing plant status updates during news briefings. The Spokesperson also may do one-on-one media interviews. The position works with the Technical Assistant in keeping abreast of the T

event status and keeps the PID posted on that status.

B.3.1.18 Technical Assistant AF The Technical Assistant reports to the Nuclear Spokesperson and is responsible for gathering accurate and timely information about the event and the plants status via displays, the ERF Communicator, ENN Forms and direct contact with the EOF Manager.

B.3.1.19 Technical Supervisor R

The Technical Supervisor reports to the EOF Manager and is responsible for providing engineering expertise during an emergency event at an SNC operated plant.

This may include interacting with non-SNC response groups, developing mitigation and recovery plans and coordinating work performed by SNC and non-SNC D engineering groups.

B.3.1.20 News Writer The News Writer reports to the EOF Manager and gathers information and prepares news bulletins verified for distribution. The News Writer Coordinates technical approval with the EOF Manager and Nuclear Spokesperson.

B.3.2 Joint Information Center (JIC)

B.3.2.1 Public Information Director (PID)

The PID is responsible for coordination of emergency information between the utility and responding offsite organizations participating in the Joint Information Center (JIC). Additional duties include managing approval and dissemination of utility news bulletins, facilitating news briefings, overseeing public response, serving as liaison to the media and coordinating off-site agencies. The PID is responsible for evaluating the emergencys severity in terms of public interest and safety.

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SNC Emergency Plan DRAFT B.3.2.2 JIC Manager The JIC Manager reports to the Public Information Director (PID) and supervises the activities of the technical and communications advisors, technical communicator and an administrative staff. The JIC Manager Responsibilities include:

Providing the EOF Manager with an overview of the public and media impacts resulting from plant and governmental activities; Advising the Nuclear Spokesperson regarding information to be released to the public; Maintaining cognizance of conditions of the plant and environment, and the actions of SNC and governmental support personnel; Coordinating with the state to review and access media coverage of the emergency event.

B.3.2.3 JIC Assistant The JIC Assistant reports to the JIC Manager and is responsible for supervision and direction of clerical staff in the facility, verification, approval and distribution of news facility activities.

B.3.2.4 Facility Coordinator T

bulletins, directs activities of the support staff and maintains an accurate record of AF The Facility Coordinator reports to the JIC Manager and is responsible for setting up the facility and ensuring ongoing operability as well as providing oversight for facility Security personnel.

B.3.2.5 Public Response Coordinator The Public Response Coordinator reports to the PID and is responsible for directing R

the facilitys public response activities, keeping staff informed of the most current plant status and obtaining responses for rumors and public inquiries.

B.3.2.6 Public Response Staff D The Public Response Staff reports to the Public Response Coordinator and is responsible for coordinating and developing responses to rumors and public inquiry.

B.3.2.7 Media Relations Representative The Media Relations Representative reports to the JIC Manager and is responsible for implementing utility media response and supervision of AV staff. This position may assume emergency communications approval authority at the discretion of the PID.

B.3.2.8 ERF Communicator The ERF Communicator reports to the PID and is responsible for maintaining communications with their counterpart in the Control Room, TSC, OSC and EOF.

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SNC Emergency Plan DRAFT B.4 Contractor and Private Organizations B.4.1 Vendors and Contractors Major equipment providers or Architect-Engineers include: Westinghouse Electric Corporation, General Electric Corporation, and Bechtel Power Corporation, which can provide the following assistance in an emergency:

Trained personnel; Technical analysis; Operational analysis; Accident and transient analysis.

B.4.2 Other Utilities Other nuclear power plant organizations may provide personnel and equipment. Prior written agreements frequently exist in these situations.

The unaffected SNC plants provide mutual support; T

Assistance from any nuclear power plant may be requested through an existing INPO link; AF Voluntary Assistance Group.

B.4.3 Other Organizations B.4.3.1 Contract laboratories can provide assistance in environmental monitoring and sampling.

B.4.3.2 National Weather Service (NWS) provides up to date meteorological information to R

the individual nuclear power plants.

B.4.3.3 Local Organizations Other local organizations are detailed in the site-specific Annexes.

B.5 D

Letters of Agreement (LOAs)

The respective nuclear power plants have obtained LOAs with private contractors and others who provide emergency support services. LOAs, as a minimum, state that the cooperating organization will provide their normal services in support of an emergency at the affected plant. LOAs are referenced in the site-specific plant Annex and the actual letters are maintained on file for the plants.

B.6 Local Emergency Support Organizations B.6.1 Local Law Enforcement Agencies Local law enforcement agencies may be called upon to lend assistance during the response to emergencies at any of the SNC operated nuclear power plants. Details on the services offered may be found in the SNC plants site-specific Annex.

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SNC Emergency Plan DRAFT B.6.2 Ambulance Services Agreements for ambulance services are in place to transport injured personnel from the plants to the designated medical facility. Training is provided for the transport of contaminated personnel, and qualified utility personnel may accompany the ambulance. Details on the services offered may be found in the SNC plants site-specific Annex.

B.6.3 Medical Services Prior arrangements have been made for medical treatment at a variety of facilities.

SNC operated nuclear power plants are supported, and sites offer training to the medical staff in dealing with contaminated injured personnel. Details on the services offered may be found in the SNC plants site-specific Annex.

B.6.4 Fire Fighting To supplement the Fire Brigade onsite, agreements are made for local fire departments. Details on the services offered may be found in the SNC plants site-specific Annex.

T AF R

D 24

SNC Emergency Plan DRAFT TSC 90 Minute Augmentation ERO Major Functional Area Major Task Position Title Emergency Director TSC Manager Emergency Direction and Operations Supervisor Control Security Supervisor Support Coordinator Notify licensee, State, local ENS Communicator Notification / Communication and Federal personnel & ERF Communicator maintain communication HPN Communicator Offsite dose assessment RP Supervisor Radiological Accident Assessment and Support of Offsite surveys Not applicable for this facility Operational Accident Onsite and in-plant surveys Assessment T

Chemistry/Radio Chemistry Technical Support Chemistry Support Engineering Supervisor Reactor Engineer Plant System Engineering, AF Repair and Corrective Actions Repair and corrective actions Access Control RP coverage for repair, Electrical Engineer Mechanical Engineer Maintenance Supervisor Not applicable for this facility Protective Actions R corrective actions, search and rescue first aid &

firefighting Personnel monitoring Total D Dosimetry Note: Site Annexes contain any additional site specific staffing.

Table 2 15 25

SNC Emergency Plan DRAFT OSC 90 Minute Augmentation ERO Major Functional Area Major Tasks Position Title Emergency Direction and OSC Manager Control Notify licensee, State, local Not applicable for this facility and Federal personnel &

Notification / Communication maintain communication Intra facility ERF Communicator communications Offsite dose assessment Not applicable for this facility Radiological Accident Offsite surveys Field Monitoring Team Assessment and Support of Personnel (2)

Operational Accident Onsite and in-plant surveys RP/Chemistry Technicians (3)

Assessment Chemistry/Radio Chemistry RP/Chemistry Technician Technical Support Not applicable for this facility Repair and corrective Mechanical Maintenance Plant System Engineering, Repair and Corrective Actions actions T Group Lead Electrical Maintenance Group Lead Protective Actions AF Access Control RP coverage for repair, corrective actions, search and rescue first aid &

firefighting I&C Maintenance Group Lead RP/Chemistry Group Lead RP/Chemistry Technicians (3)

Total R Personnel monitoring Dosimetry 15 D Table 3 26

SNC Emergency Plan DRAFT EOF 90 Minute Augmentation ERO Major Functional Area Major Task Position Title Emergency Direction and Emergency Operations Emergency Director Control Facility (EOF) Director EOF Manager Support Coordinator Emergency Communication Coordinator Security Coordinator Offsite Response Coordinator Administrative Support Staff Liaisons (at EOCs)

- GA

- AL

- SC Notification / Notify licensee, State, local ENN Communicator Communication and Federal personnel & ENS Communicator T

maintain communication Intra facility Communications HPN Communicator ERF Communicator Nuclear Spokesperson Radiological Accident Assessment and Support of Operational Accident AF Offsite dose assessment Offsite surveys Technical Assistant News Writer Field Team Communicator Dose Assessment Supervisor Dose Analyst Field Team Coordinator Assessment R

Plant System Engineering, Onsite and in-plant surveys Not required in this facility Chemistry/Radio Chemistry Not required in this facility Technical Support Technical Supervisor Actions D

Repair and Corrective Protective Actions Repair and corrective actions Access Control RP coverage for repair, corrective actions, search and rescue first aid &

Not required in this facility Not required in this facility firefighting Personnel monitoring Dosimetry Total 19 Table 4 27

SNC Emergency Plan DRAFT JIC 90 Minute Augmentation ERO Functional Area Major Task Position Title Media Response Media Response Public Information Director ERF Communicator JIC Manager JIC Assistant Facility Coordinator Clerical Staff Security Public Response Coordinator Public Response Staff Media Relations Representative Total 10 Table 5 T

AF R

D 28

SNC Emergency Plan DRAFT TSC Emergency Director ERF Communicator OSC TSC Manager Manager Operations Supervisor RP Supervisor Security Supervisor T Maintenance Supervisor Engineering Supervisor Support Coordinator ENS Communicator Shift Dose Analyst HPN AF Reactor Engineer Electrical Manager ERF RCommunicator Chemistry Engineer Mechanical Communicator D Support Minimum Staff positions are shaded boxes Figure B.2.B - Technical Support Center Organization Engineer 29

SNC Emergency Plan DRAFT TSC OSC Manager Manager ERF Communicator T

RP/Chemistry Group Lead AFMechanical Group Lead Electrical Group Lead I&C Group Lead RP Technicians R

Chemistry Technicians Mechanics Electricians I&C Technicians D

Minimum Staff positions are shaded boxes Figure B.2.C - Operational Support Center Organization 30

SNC Emergency Plan DRAFT T

AF R

D Figure B.2.D - Emergency Operations Facility Organization 31

SNC Emergency Plan DRAFT T

AF R

D Figure B.2.E - Joint Information Center Organization 32

SNC Emergency Plan DRAFT SECTION C: EMERGENCY RESPONSE SUPPORT AND RESOURCES Once an emergency has been declared, the Emergency Director (ED) has the authority and responsibility to request aid from offsite organizations, whether they are other SNC operated nuclear power plants, federal, state, local, or private organizations.

C.1 Federal Assistance Federal agencies that may provide assistance in direct support of SNC in the event of an accident are identified in Section A of this plan. If needed, federal resources are expected to be made available to SNC.

C.2 State Interfaces Designated SNC personnel are assigned to the state or county Emergency Operations Centers (EOCs). Locations have been provided in the Emergency Operations Facility (EOF) for liaisons from the state and county.

C.3 Radiological Laboratories C.3.1 Onsite Laboratory T

The onsite laboratory/counting rooms at SNC operated nuclear power plants are the primary facility for radiation monitoring and analysis efforts. The onsite laboratory is the central point for receipt and analysis of onsite samples and includes equipment for samples. AF chemical and radiological analyses. The plant laboratories have the capability of quantitative analysis of marine and air samples, and qualitative analysis of terrestrial Additional facilities for counting and analyzing samples are available at the other SNC operated nuclear plants or state and federal laboratory services. These laboratories can act as backup facilities in the event that the affected nuclear power R

plant's counting room and laboratory become unusable or the capacity or capability of the plants laboratory is exceeded.

C.3.2 Contract Laboratories C.4 D Additional outside analytical assistance may be requested from contracted vendors. These laboratories provide bioassay analysis and radiochemical analysis services.

Assistance Agreements C.4.1 Nuclear Industry The nuclear industry provides a reservoir of personnel with a wide range of technical expertise and knowledge. A nuclear industry national inventory of personnel who may be called upon to supplement company personnel has been developed through the Institute of Nuclear Power Operations (INPO). In addition, a number of utilities have entered into an INPO coordinated Voluntary Assistance Agreement program. This provides a mechanism to draw upon industry resources during an emergency. Support may also be requested from neighboring utilities for the following:

33

SNC Emergency Plan DRAFT Personnel and equipment to assist with in-plant and emergency field monitoring; Engineering, design, and technical expertise to assist in determining the cause of the accident and to support recovery; Personnel and equipment to assist in maintenance and repairs to the facility.

SNC operated plants are a signatory to two comprehensive agreements among electric utility companies:

The Nuclear Power Plant Emergency Response Voluntary Assistance Agreement, and; The Voluntary Assistance Agreement By and Among Electric Utilities Involved in Transportation of Nuclear Materials.

C.4.2 Offsite resources SNC supports the sharing of personnel and resources among SNC operated nuclear power plants, providing a large personnel and equipment base.

C.4.2.1 American Nuclear Insurers (ANI)

T ANI provides insurance to cover SNC legal liability up to the limits imposed by the Price-Anderson Act, for bodily injury and/or property damage caused by the nuclear energy hazard resulting from an accident at a nuclear power plant.

C.4.2.2 C.4.2.3 AF Civil/Structural Engineers Plants have an Architect-Engineer that could be called upon to provide engineering expertise in dealing with a nuclear power plant accident.

Nuclear Steam Supply System Vendor R Under established contracts, the following will supply available engineering expertise, specialized equipment and other services identified as needed and deemed appropriate to provide in an emergency situation:

D C.4.2.4 General Electric (GE) Nuclear Energy Westinghouse Electric Company Supplemental Emergency Assistance to the ERO SNC operated nuclear power plants maintain agreements with outside support agencies that do not take part in the organizational control of the emergency, but provide assistance when called upon during an emergency or during the recovery phase. These agreements identify the emergency measures to be provided, the mutually accepted criteria for implementation, and the arrangements for exchange of information. These support agencies provide services of:

Law enforcement; Fire protection; Ambulance services; Medical and hospital support; 34

SNC Emergency Plan DRAFT DOE Radiological Assistance Program (RAP).

C.4.2.5 Local Response Organizations In many cases, local groups provide for emergency communications and other services, such as transportation and medical assistance. References to these groups are contained in the site-specific Annexes.

T AF R

D 35

SNC Emergency Plan DRAFT SECTION D: EMERGENCY CLASSIFICATION SYSTEM D.1 Classification of Emergencies D.1.1 Emergency Conditions D.1.1.1 Emergency classification is divided into four classification levels described in 10 CFR 50 Appendix E and NUREG 0654 and based on NEI 99-01 and 07-01 methodologies.

Emergency Action Levels (EALs), based on indications available in the control room and correlated to the emergency classifications, are provided to the operator.

SNC has and maintains the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an EAL has been exceeded. Upon identification of the appropriate emergency classification level, the emergency condition will be promptly declared.

The classification scheme is provided to and discussed by Southern Nuclear Company, agreed upon by state and county governmental authorities and approved by the NRC. The classification scheme and specific Emergency Action Levels T

are reviewed with the State and local governmental authorities on an annual basis.

D.1.1.2 Emergency Classification Level Descriptions AF There are three considerations related to emergency classification levels. These are:

(1) The potential impact on radiological safety, either as known now or as can be reasonably projected; (2) How far the plant is beyond its predefined design, safety, and operating R

envelopes; and (3) Whether or not conditions that threaten health are expected to be confined to within the site boundary.

The Initiating Conditions (ICs) deal explicitly with radiological safety impact by D escalating from levels corresponding to releases within regulatory limits to releases beyond EPA Protective Action Guideline (PAG) plume exposure levels.

The four emergency classification levels are described as follows:

UNUSUAL EVENT (UE)

Events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring off-site response or monitoring are expected unless further degradation of safety systems occurs.

ALERT Events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of hostile action. Any releases are expected to be limited to small fractions of the EPA PAG exposure levels.

36

SNC Emergency Plan DRAFT SITE AREA EMERGENCY (SAE)

Events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or hostile action that results in intentional damage or malicious acts; 1) toward site personnel or equipment that could lead to the likely failure of or; 2) that prevent effective access to, equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA PAG exposure levels beyond the site boundary.

GENERAL EMERGENCY Events are in progress or have occurred which involve actual or imminent substantial core degradation or melting with potential for loss of containment integrity or hostile action that results in an actual loss of physical control of the facility. Releases can be reasonably expected to exceed EPA PAG exposure levels off-site for more than the immediate site area.

D.2 Basis for Emergency Classification Criteria D.2.1 Emergency Action Levels.

T Planned evolutions involve preplanning to address the limitations imposed by the AF condition, the performance of required surveillance testing, and the implementation of specific controls prior to knowingly entering the condition in accordance with the specific requirements of Technical Specifications. Activities which cause the plant to operate beyond that allowed by Technical Specifications, planned or unplanned, may result in an EAL threshold being met or exceeded. Planned evolutions to test, manipulate, repair, perform maintenance or modifications to systems and equipment that result in an EAL value being met or exceeded are not subject to classification R

as long as the evolution proceeds as planned and is within the operational limitations imposed by the operating license.

Classifications are based on evaluation of the applicable Unit. Classifications are D based upon valid indications, reports or conditions. Thresholds assume valid indications. Reports or conditions are considered valid when they are verified by (1) an instrument channel check, or (2) indications on related or redundant indications, or (3) by direct observation by plant personnel, such that doubt related to the indications operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

Although the majority of the EALs provide very specific thresholds, the Emergency Director must remain alert to events or conditions that lead to the conclusion that exceeding the EAL is imminent. If, in the judgment of the Emergency Director, an imminent situation is at hand, the classification should be made as if the threshold has been exceeded.

An Emergency Action Level has two distinct parts. The Initiating Condition (IC) is a brief description of conditions that are compared to existing abnormal plant conditions. The ICs are segregated into Recognition Categories. The Recognition Categories are:

37

SNC Emergency Plan DRAFT R - Abnormal Radiological Levels/Radiological Effluent; C - Cold Shutdown / Refueling System Malfunctions; E - Independent Spent Fuel Storage Installations (ISFSI)

F - Fission Product Barrier; H - Hazards and Other Conditions Affecting Plant Safety; S - System Malfunction.

With each IC are Threshold Values (TV) that provide the criteria for classification associated with the appropriate classification level. When the IC is observed to exist, the TV must also be met, exceeded or in some cases imminent to become a classifiable Emergency Action Level.

The Fission Product Barrier and System Malfunction criteria are only applicable when in the hot operating modes. The Cold Shutdown / Refueling System malfunctions are only applicable in cold shutdown and Defueled modes or as specifically designated in each EAL. The EALs associated with the Radiological, ISFSI and Hazards categories are applicable in all modes of operation.

D.2.2 T

Initiating Conditions have symptom-based, event-based, or barrier-based criteria.

The symptom based ICs refer to those indicators that are measurable over some AF continuous spectrum, such as core temperature, coolant levels, containment pressure, etc. When one or more of these indicators begin to show off-normal readings, reactor operators are trained to identify the probable causes and potential consequences of these "symptoms" and take corrective action. The level of seriousness these symptoms indicate depends on the degree to which they have exceeded technical specifications, the other symptoms or events that are occurring contemporaneously, and the capability of the licensed operators to gain control and R

bring the indicator back to safe levels.

Event based ICs refer to occurrences with potential safety significance, such as the failure of a safety valve failure or a loss of electric power to some part of the plant.

D The range of seriousness of these "events" is dependent on the location, number of contemporaneous events, remaining plant safety margin, etc.

Barrier based ICs refer to the level of challenge to principal barriers used to assure containment of radioactive materials contained within a nuclear power plant. For radioactive materials that are contained within the reactor core, these barriers are:

fuel cladding, reactor coolant system pressure boundary, and containment. The level of challenge to these barriers encompasses the extent of damage (loss or potential loss) and the number of barriers concurrently under challenge. Challenge to one or more barriers generally is initially identified through instrument readings and periodic sampling. Deterioration of the reactor coolant system pressure boundary or the fuel clad barrier usually indicates an Alert condition, two barriers under challenge a Site Area Emergency, and loss of two barriers with the third barrier under challenge is a General Emergency. The fission product barrier criteria recognize that some events may represent a challenge to more than one barrier, and that the containment barrier is weighted less than the reactor coolant system pressure boundary and the fuel clad barriers.

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SNC Emergency Plan DRAFT D.2.3 Emergency Action Level Threshold Values The most common bases for establishing Threshold Values are the Technical Specifications, Operating Procedures, the ODCM, and setpoints that have been developed in the design basis calculations for the Final Safety Analysis Report (FSAR).

Another critical element of the analysis to arrive at Threshold Value conditions is the time that the plant might stay in that condition before moving to a higher emergency classification level. The time dimension is critical to the EAL since the purpose of the emergency classification level for state and local officials is to notify them of the level of mobilization that may be necessary to address the emergency.

This is particularly true when a Site Area Emergency or General Emergency is imminent. A time variable is used to allow for correction of the condition before a classification is made.

D.2.4 T

Site specific Threshold Values for Emergency Action Level Initiating Conditions are maintained in the stations Emergency Action Level Technical Basis document.

Treatment of Multiple events and Classification Level Upgrading D.2.5 AF When multiple simultaneous events occur, the emergency classification level is based on the highest EAL reached. Emergency classification level upgrading considers the potential for radioactive release from the entire site due to the event or simultaneous events.

Emergency Classification Level Downgrading and Termination R

The SNC policy is that once an emergency classification is made, it cannot be downgraded to a lower classification. Termination criteria contained in the Emergency Plan Implementing Procedures shall be completed for an event to be D

D.2.6 terminated. At termination, on an event specific basis, the site can either enter normal operating conditions or enter a recovery condition with a recovery organization established for turnover from the ERO.

Classifying Transient Events Many of the Initiating Conditions and/or EALs contained in this document employ time-based threshold criteria. These criteria will require that the threshold conditions be present for a defined period of time before an emergency classification is warranted. In cases where no time-based criteria is specified, it is recognized that some transient events may cause an EAL threshold to be met for a few seconds to a few minutes. The following guidance should be applied to the classification of these events.

EAL threshold momentarily met during expected plant response - There may be instances where an EAL threshold is briefly met during an expected plant response.

In these cases, an emergency declaration is not warranted provided that systems and 39

SNC Emergency Plan DRAFT components are operating as expected, and associated operator actions are appropriate.

EAL threshold met but the condition clears or is corrected prior to emergency declaration - The key consideration is to determine if any plant damage occurred as a result of the transient event.

If plant damage is readily apparent, or if further assessment is necessary to confirm or rule out such damage, then the EAL threshold should be considered met and the appropriate emergency declaration made. Terminate the emergency if the assessment determines that there was no plant damage from the event and when other termination criteria are met.

If no plant damage is readily apparent and no further damage assessment is warranted, no emergency declaration is required; however, the event should be reported to the NRC per 10 CFR 50.72 within one hour and notification of the State and local emergency response organizations should be made in accordance with the arrangements made between the site and offsite organizations.

T EAL threshold met but classification was not made at the time of the event. - This situation occurs when personnel discover that a condition existed which met an AF EAL threshold but no emergency was declared and the condition no longer exists at the time of this discovery. This may be due to the emergency condition not being recognized at the time or an error was made in the emergency classification process.

In these cases, the guidance contained in NUREG-1022, section 3.1.1 is applicable.

Specifically, the event should be reported to the NRC per 10 CFR 50.72 within one hour of the discovery of the undeclared event and notification of the State and local emergency response organizations should be made in accordance with the D.2.7 R arrangements made between the site and offsite organizations.

Operating Mode Applicability The plant operating mode that existed at the time that the event occurred, prior to D any protective system or operator action initiated in response to the condition, is compared to the mode applicability of the EALs. If an event occurs, and a lower or higher plant operating mode is reached before the emergency classification level can be declared, the emergency classification level shall be based on the mode that existed at the time the event occurred.

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SNC Emergency Plan DRAFT SECTION E: NOTIFICATION METHODS AND PROCEDURES E.1 Notification Methodology E.1.1 SNC in cooperation with state, and county authorities, has established methods and procedures for notification of offsite response organizations consistent with the emergency classification and emergency action level scheme. These notifications include a means of verification or authentication. The methods used for authentication are developed and mutually agreed to by the utility and off-site authorities. The primary notification method will be by a dedicated communications system.

SNC operated plants maintain the capability of notifying state and local agencies within 15 minutes of a declared emergency as required per 10CFR50 Appendix E, section IV(D)(3). The methods and forms used for notifying state and county authorities are site-specific, and detailed in plant specific Emergency Plan Implementing Procedures (EPIPs).

NRC will be notified, via the Headquarters Operations Officer, immediately classification.

T following state and local notifications, but within an hour of an emergency When multiple units of a multi-unit site are affected by an emergency, the AF classification shall be reported as applicable to all affected units. In situations where multiple units of a multi-unit site are affected by emergency events, but the events are not related and the classification for each unit is different, notification will be made for the highest classification.

An accelerated call to the NRC Headquarters Operations Officer will be made following discovery of an imminent threat or attack against a plant. During a plant R

transient or an imminent threat situation requiring physical security response, plant personnel are primarily responsible for stabilizing the plant and keeping it safe. An accelerated notification will not interfere with plant or personnel safety or physical security response.

D The accelerated notification will be completed after or concurrent with notification of local law enforcement agencies. The goal will be to initiate the notification within 15 minutes of discovery of an imminent threat or attack against a plant. The information provided in the accelerated notification will be limited to the following:

Site name; Emergency classification if determined prior to the accelerated notification; Nature of the threat and the attack status.

E.2 Notification of Personnel E.2.1 Notification of Onsite Personnel The Emergency Director is responsible for classifying an event into the appropriate emergency classification and then notifying on site personnel of the emergency declaration in accordance with procedures. This notification may consist of the use of 41

SNC Emergency Plan DRAFT the plant emergency alarm signal, announcements over the plant public address system, or activation of the recall system.

Emergency Response personnel respond to their assigned Emergency Response Facilities upon notification of an Alert or higher classification level. In the event of a Design Basis Threat, personnel may be directed to respond to alternative facilities.

Notification of persons who are in the public access areas, on or passing through the site or within the controlled area will be performed by the Security Department. Such notifications would be accomplished in accordance with the Emergency Plan Implementing Procedures (EPIPs).

Visitors within the protected area are escorted by a permanently badged individual.

This individual is responsible for informing the visitors of emergencies when they occur and for taking action to evacuate the visitors from the site, as necessary.

Notification procedures include notification of Emergency Response Organization Personnel (ERO) not on site or during backshift hours. ERO members will be notified by means of an automated callout system activated by on-shift personnel.

T E.2.2 Notification of State and local Authorities A dedicated Emergency Notification Network (ENN), will normally be used to accomplish State and local notifications. Backup means of communication are AF described in Section F, Emergency Communication, of this plan.

E.2.2.1 Administrative Decision Line An Administrative Decision Line (ADL) connects the EOF, SRS Operations Center, the GEMA FEOC, the SEOCs of both states and the three South Carolina counties. This is a prearranged conference call over commercial telephone lines R

and may be used for discussions other than emergency notifications.

E.2.2.2 State/ Local Agencies State and local agencies listed in the site specific Annexes shall be notified within D fifteen (15) minutes of:

The initial emergency classification; Classification change; The issuance of, or change to, a Protective Action Recommendation (PAR);

Changes in radiological release status, occurring outside of an event classification or PAR notification, based on agreements with the state(s).

E.2.2.3 Initial Notification Message Form In conjunction with state and county authorities, SNC operated plants have established the contents of the initial and subsequent state notification message forms to be utilized during an emergency. These forms are described in EPIPs.

The content of the forms has been reviewed and agreed upon by the respective Offsite Response Organizations.

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SNC Emergency Plan DRAFT E.2.2.4 Follow-up Emergency Message The Emergency Director is responsible for the completion of a follow-up emergency message. The appropriate ERO personnel will ensure the emergency communicator(s) periodically provide follow-up messages to the appropriate offsite Federal, State, and local authorities.

E.2.3 Notification of the Nuclear Regulatory Commission (NRC)

The NRC is notified via the Emergency Notification System (ENS). If the ENS is inoperative, the required notification will be made using alternate means in accordance with regulatory requirements. The Emergency Response Data System (ERDS), will be initiated within one hour of the declaration of an Alert or higher classification.

Specific information on the notifications to the NRC for emergency events is detailed in the reporting requirements of 10 CFR 50.72.

E.2.4 Notification of Other Federal Agencies Notification of other Federal Agencies will be made in accordance with site specific Procedures.

E.2.5 Notification of the Public T

AF Prompt alerting and notification of the public within the plume exposure pathway EPZ is the obligation of State and local government or other responsible authority.

The responsibility that means exist for this purpose rests with Southern Nuclear Operating Company. An overview of these means excluding the Savannah River Site is listed in the site specific Annex of this Plan.

Initial notification of the public will occur in a manner consistent with assuring the R

public health and safety. The design objective for the system is to meet the acceptance criteria which are provided in a subsequent section of the FEMA approved design report for each SNC operated plant. The design objective does not constitute a D guarantee that prompt notification can be provided for everyone with 100%

assurance, or that the system when tested under actual field conditions will meet the design objectives.

In the event of an emergency the Emergency Director is responsible for notifying appropriate State and local response organizations, plant emergency response organization and plant personnel.

E.2.5.1 Concept of Operations In the event of a serious emergency at any SNC site, the primary means for alerting the public will be by a system of fixed sirens and providing initial instructions to the public will be by EAS. Having been alerted, the public will be instructed to turn on their radio or television to receive additional instructions from the EAS.

The initial message will state that an emergency condition exists and will also advise of any appropriate instructions for protective actions. Periodic broadcasts of short, updated messages will be performed as warranted.

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SNC Emergency Plan DRAFT The siren system consists of a network of fixed electronic sirens mounted on poles strategically located throughout the populated area of the plume exposure EPZ.

Based upon Appendix 3 of NUREG-0654 and FEMA REP-10, the system is designed to provide a minimum of 60 dBC coverage to residences within the plume exposure EPZ, plus adequate coverage for people outdoors in other areas of the plume exposure EPZ open to the public.

The locations and design coverage contours of the sirens are provided in the site specific Annexes.

Each site has a FEMA approved backup notification system in the event of a loss of the primary alert and notification system. Details of the backup methods can be found in the site specific Annex.

Detailed information and instructions will be provided on local EAS radio and television stations. Commercial radio stations and television stations whose broadcasts are received in the plume exposure pathway EPZs have agreed to broadcast emergency instructions and information in cooperation with offsite officials.

T These continuing instructions will provide more specific or detailed information of any protective actions advised for affected areas. Information on the nature of the AF accident, on any releases, and on the progress in ameliorating or terminating the emergency event will also be provided periodically on the commercial stations, along with a prognosis for escalation or termination of the event.

E.2.5.2 Criteria for Acceptance

1. Within the plume exposure pathway EPZ, the prompt alerting and notification system will provide an alerting signal and notification by fixed sirens; further R

notification will also be provided by local commercial radio and television stations which will be activated via EAS.

2. The minimum acceptable design objectives for coverage by the system are:

D a) Capability for both an alerting signal and an informational or instructional message to the population on an area-wide basis throughout the plume exposure pathway EPZ, within 15 minutes.

b) The initial notification system will assure direct coverage of essentially 100% of the population within five miles of the site.

3. Local and State agencies have the capability to provide information promptly over local commercial radio and television at the time of the activation of the alerting signal. Authority for activation of the EAS, whereby designated governmental officials are permitted to issue emergency information and instruction in threatened or actual emergencies, is given by 47CFR part 11, EAS Rules.

Information will be distributed on an annual basis to residents and businesses within the EPZ.

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SNC Emergency Plan DRAFT The testing and maintenance of the public alerting sirens are the responsibility of SNC. The maintenance program will consist of both periodic routine checks and, as required, corrective maintenance.

The periodic routine maintenance and test program will be based on the manufacturers' recommendations and experience gained with the installation.

Annually the system will be activated in the normal mode. Advance notice of the test will be provided to the public. Activation of sirens will be verified by the system.

Reports of siren failures will be investigated and repaired by the respective SNC site.

Unsatisfactory conditions detected by any means will be promptly repaired.

Alabama Emergency Management Agency (AEMA), Georgia Emergency Management Agency (GEMA), and South Carolina Emergency Management Division (SC EMD) procedures detail the process for activating the prompt notification system for the SNC Fleet.

E.2.6 Public Protective Action Messages State and local authorities have developed procedures and messages to be provided to T

the public in the event of an emergency at an SNC operated nuclear power plant.

Details as to these procedures and messages are in the appropriate state and local emergency plans.

AF E.2.7 Verification of Notification Messages The SNC emergency notification form is transmitted electronically to the responsible state and local agencies using a secure data sharing system provided by SNC. Once transmitted to the OROs the receipt of this information is confirmed using a dedicated communications link. In the event an agency is unable to obtain the emergency R

notification form electronically the affected agency will be contacted using a dedicated communication link and the content of the form will be communicated verbally to the agency. As these systems are dedicated systems no additional verification of the authenticity of the message is required for verification of messages D with state and local agencies within the states of Alabama and Georgia.

Communications with agencies within the state of South Carolina will be authenticated using the authentication system provided by the South Carolina Emergency Management Division. In the unlikely event the electronic notification transmittal capability and dedicated communications links are lost then the emergency notification form will be communicated verbally using commercial telephone lines and the receiving agency may verify authenticity of the message by calling the licensee back.

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SNC Emergency Plan DRAFT SECTION F: EMERGENCY COMMUNICATIONS F.1 Communications F.1.1 At SNC operated nuclear power plants, several modes of reliable communication are available, during both normal and emergency conditions, to transmit and receive information among the Control Room, TSC, OSC, EOF, and at other locations onsite and offsite including the Joint Information Center near the SNC site. Reliable primary and backup means of communication have been established.

The use of the communications systems during normal and emergency conditions has been integrated into plans, procedures, and the training program.

F.1.2 SNC operated plants maintain the capability to make initial notifications to the designated offsite agencies 24-hours per day. Offsite notifications can be made to State and county warning points and Emergency Operations Centers from the Control Room, Technical Support Center, and Emergency Operations Facility via the Emergency Notification Network (ENN). Reliable backup methods have been proceduralized.

State and county warning points are continuously staffed.

T F.1.3 Provisions exist for continuous communications with State/ local governments within the Emergency Planning Zones, as detailed above. At least one onsite and one offsite communications system is maintained, each with a backup power source to ensure AF continuous communications.

F.1.4 SNC has established communications systems to provide reliable communications with Federal emergency response organizations. Communications with Federal agencies is primarily by commercial telephone, with alternate systems being utilized as needed.

R Communication with the Nuclear Regulatory Commission (NRC) is via the Federal Telephone System (FTS) telephone network which connects the SNC plant site and EOF with the NRC Operations Center. Site extensions are located in the Control Room, TSC, and Site NRC Resident Inspectors Office. Site extensions include ENS, D HPN, ERDS and other designated counterpart links connecting to the NRC Operations Center.

Commercial telephone lines and the microwave system serve as backups to the ENS and other FTS lines.

F.1.4.1 NRC Emergency Notification System (ENS)

This communications line provides a communications link to the NRC Operations Center in Rockville, MD and is used for continuous communications in a classified emergency. ENS phones are located in the Control Room, TSC, and EOF.

F.1.4.2 NRC Health Physics Network (HPN)

This communications line provides a communications link with the NRC to provide radiological information. HPN phones are located in the TSC and EOF.

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SNC Emergency Plan DRAFT F.1.4.3 NRC Reactor Safety Counterpart Link (RSCL)

This communications line provides a communications link for the NRC to conduct internal NRC discussions on plant equipment conditions separate from the licensee.

RSCL phones are located in the TSC and EOF.

F.1.4.4 Protective Measures Counterpart Link (PMCL)

This communications line provides a communications link for the NRC to conduct internal NRC discussions on radiological releases, meteorological conditions, and the need for protective actions. PMCL phones are located in the TSC and EOF.

F.1.4.5 Management Counterpart Link (MCPL) (Executive Bridge Line)

This communications line provides a communications link for any NRC internal discussions between the NRC Executive Team Director or Executive Team members and the NRC response team leader or top-level licensee management at the site. MCPL phones are located in the TSC and EOF.

F.1.4.6 Security Bridge Line T

This communications line provides a communications link with the NRC to provide security related information by the site team with access to the NRC Headquarters Operations Center LAN. Security link connections are provided in the TSC and EOF.

AF F.1.4.7 Local Area Network (LAN) Access This communications line provides the NRC site team with access to the NRC Operations Center's LAN. LAN connections are provided in the TSC and EOF.

F.1.4.8 Emergency Response Data System (ERDS)

R ERDS is a dedicated network and is a direct near real-time electronic data link between the plants on-site computer system and the NRC Operations Center that provides for the automated transmission of a limited data set of selected parameters.

D The ERDS supplements the existing voice transmission over the FTS-ENS. The ERDS is installed in the Computer Room and the TSC.

F.1.5 SNC operated nuclear power plants have reliable communications between the plants and the Emergency Operations Facility (EOF), State and local emergency operations center, and radiological monitoring teams, as detailed above.

F.1.6 SNC operated nuclear power plants utilize an automated ERO Notification System to rapidly notify members of the ERO. The system is designed with redundant power, and with geographic separation.

F.2 Medical Emergency Communications Communications have been established between the primary and backup medical hospitals and transportation services with SNC operated plants.

47

SNC Emergency Plan DRAFT F.3 Communications Tests Communications tests will be conducted on the frequency specified below. Each of these tests includes provisions to ensure that participants in the test are able to understand the content of the messages utilized in the test.

Communications with state and local governments within the plume exposure pathway will be tested monthly; Communications with federal response organizations and state governments within the plume exposure pathway will be tested quarterly; Communications between SNC operated nuclear power plants, state Emergency Operating Centers and local Emergency Operations Centers, and radiation monitoring teams will be tested annually; Communication from the Control Room, TSC and EOF to the NRC Operations Center will be tested monthly; The Emergency Response Data System (ERDS) will be tested on a quarterly basis; The fixed siren portion of the Alert and Notification System (ANS) will be tested and T

verified in accordance with existing FEMA approvals.

AF R

D 48

SNC Emergency Plan DRAFT SECTION G: PUBLIC EDUCATION AND INFORMATION G.1 Purpose The Southern Nuclear Company (SNC) Emergency Communications Plan (ECP) is designed to support the plants Emergency Plans.

The Vice President and General Counsel, SNC Corporate Council and Compliance, is responsible for coordination and administration of the SNC ECP.

The ECP directs:

Release of information to the public through the dissemination of timely, accurate emergency communications Orderly flow of emergency information during the recovery period Public education and information for the distribution of emergency preparedness materials to residents and transient populations.

G.2 News Media Training A program will be offered each calendar year to acquaint the news media with the methodology T

for obtaining information during an emergency and with overall emergency preparedness at APC/GPC nuclear plants, as appropriate. Training will include information about the plant, emergency response and the role of the JIC as well as opportunities to participate in drill activities.

G.3 News Releases AF The Utility will issue news releases concerning events, conditions and actions at the Plant. News releases are designed to be a written confirmation of events and public information.

The SNC News Writer will write news releases in the EOF and obtain SNC approval from the EOF Manager, then forward them to the JIC as appropriate. The Facility Manager at that location will obtain communications approval and direct distribution of the release.

G.4 Press Briefings R

Press briefings will be conducted to keep the media informed of events and activities relating to G.5 D

the emergency. Briefings will provide the most current, up-to-date information about events and response to the incident. Public Information Officers (PIOs) from all offsite agencies responding to the emergency will be encouraged to participate in the briefings to discuss their particular activities.

Public Response All appropriate information will be released as clearly, concisely and quickly as possible. Public announcements will be made on a frequent and regular basis.

G.6 Resource Materials Media guides are available on the Utility websites and are accessible from the JIC. These guides are updated regularly and are available to all news media.

An emergency web page will be activated and will replace the normal web page on the appropriate Utilitys website at the PIDs discretion.

Maps, photographs and diagrams of the plant and its operations are stored and maintained at the JIC for use during news briefings 49

SNC Emergency Plan DRAFT G.7 Public Information Plan For Recovery The lead emergency communications representative in the Recovery Organization will be the Public Information Director. This person or his designee will maintain close contact with the Recovery Manager. Emergency communications response will follow the guidelines and procedures described for accident response.

As conditions and public interest warrant, additional Public Information personnel will be assigned to support the flow of information concerning recovery operations.

Information for possible release will be cleared with the Recovery Manager and the Public Information Director and given to the media through established procedures.

All information will be released through established channels of communication to federal and state authorities, the utility industry, the public, and employees.

Advance notice will be given to the public through the media of any Company action that will or may affect the health and safety of the plume exposure pathway EPZ residents. Information of this type will be followed up with a news release as soon as the results of any such action are known.

G.8 Public Information and Education Program T

The goal of the public information program is to acquaint the general public with the emergency plans for the operation of APC/GPC nuclear plants, as appropriate, and actions they should in the event of a plant emergency.

AF Emergency Information is disseminated each calendar year for residents and transients in the plume exposure pathway Emergency Planning Zone.

R D

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SNC Emergency Plan DRAFT SECTION H: EMERGENCY FACILITIES AND EQUIPMENT H.1 Onsite Emergency Response Facilities SNC operated nuclear power plants have established a Technical Support Center (TSC) and an onsite Operations Support Center (OSC), which are staffed and activated within 90 minutes of the declaration of an Alert or higher classification. Emergency Response Facilities may be activated at an Unusual Event at the discretion of the Emergency Director. Until the TSC and OSC are activated, required functions of these facilities are performed in the Control Room.

H.1.1 Control Room The Control Room is the centralized onsite location from which the plants reactors and major plant systems are operated. The Control Room is equipped with instrumentation to supply detailed information on the reactors and major plant systems. The Control Room is continuously staffed with qualified, licensed operators, and is the first onsite facility to respond to emergency events. Control Room personnel evaluate and effect control over emergencies until support centers can be activated. As other Emergency Response Facilities (ERFs) become activated, they will support the Control Room, and overall Command and Control of the emergency will transfer to the TSC. Offsite Agency Notification and activities may include:

T Protective Action Recommendation determination will transfer to the EOF. Control Room AF Reactor and plant control; Initial direction of plant related operations; Accident recognition, classification, mitigation and initial corrective actions; Alerting of onsite personnel; Notification of appropriate individuals; R

Activation of emergency response facilities and ERO notification; Notification of offsite agencies; Notification and update of the NRC via Emergency Notification System (ENS);

D Continuous evaluation of the magnitude and potential consequences of any incident; Initial dose projections; Recommendations for immediate protective actions for the public; Activation of the Emergency Response Data System (ERDS).

H.1.2 Technical Support Center (TSC)

SNC operated nuclear power plants have established a TSC for use during emergency situations by plant management, technical, and engineering support personnel. The TSC is procedurally required to be activated within 90 minutes following the declaration of an Alert or higher classification. Activation for Unusual Events or unclassified incidents is optional.

When activated, TSC functions include:

Support for the Control Room's emergency response efforts; Performance of response management functions when in Command & Control; Continued evaluation of event classification; 51

SNC Emergency Plan DRAFT Assessment of the plant status and potential offsite impact; Coordination of emergency response actions; Notification of appropriate corporate and plant management; Notification and update of the NRC via the Emergency Notification System (ENS)

Notification and update of the NRC via Health Physics Network (HPN).

The TSC is the onsite location utilized to support the Control Room for assessment of plant status and for implementation of emergency actions. TSC personnel provide technical data and information to the EOF. Each TSC provides reliable voice and facsimile communications to the Control Room, the OSC, the EOF, the NRC, and state Emergency Operations Centers.

The TSC is sized to accommodate ERO responders and NRC Representatives. State and county personnel are not expected to report to the TSC. Personnel in the TSC are protected from radiological hazards, including direct radiation and airborne contaminants under accident conditions, with similar radiological habitability standards as Control Room personnel.

T To ensure adequate radiological protection, radiation monitoring equipment has been installed in the TSC, or periodic radiation surveys are conducted. These systems indicate radiation dose rates and airborne radioactivity inside the TSC while in use. In addition, AF potassium iodide (KI) is available for use.

The TSC has access to a controlled set of drawings and other records, including general arrangement diagrams, piping and instrumentation diagrams (P&IDs), and electrical schematics. The TSC has the capability to display vital plant data, in real time, to be used by knowledgeable individuals responsible for engineering and management support of reactor operations, and for implementation of emergency procedures.

R Details of the TSC configuration and location are in the site specific Annexes.

H.1.3 Operations Support Center (OSC)

D The OSC has been established to provide an area for coordinating and planning of activities and the staging of personnel and equipment. The OSC responders include groups such as Instrument and Control Technicians, Mechanics, Electricians, Nuclear Chemistry and RP Technicians, System Operators, and oncoming shift personnel. Additional space is available to accommodate personnel as required. Alternative locations are available should the OSC become uninhabitable.

Emergency supplies are maintained in the OSC. When an emergency condition exists at one SNC operated nuclear power plant, additional supplies can be obtained from other unaffected plants and SNC resources upon request.

Details of the OSC configuration and location are in the site specific Annexes.

H.1.4 Alternative Facilities An Alternative Facility for staging of ERO personnel has been designated at the sites. In the event of a Security or Hostile Action threat or event, the designated Alternative Facility may 52

SNC Emergency Plan DRAFT also serve as an evacuation location for TSC and OSC personnel. The Alternative Facility is designed to be accessible in the event of an onsite HAB event and has the capability to:

Communicate with the Control Room, Security, and the EOF.

Conduct engineering assessment activities including damage control team planning and preparation The functions of Classification and Notification will be performed from the EOF should the Alternative Facility be activated. Details of Alternative Facilities can be found in the Site Specific Annex.

H.2 Offsite Emergency Facilities H.2.1 Emergency Operations Facility The EOF is the central location for management of the offsite emergency response, coordination of radiological assessment, and management of initial recovery operations. The EOF is a dedicated facility located in Birmingham, Alabama, and serves as the EOF for SNC sites (VEGP, FNP, and HNP). Staffing and activation of the EOF is mandatory upon declaration of an Alert or higher classification. The EOF provides for:

T Management of overall emergency response; Coordination of radiological and environmental assessments; AF Protective Action Recommendations; Notification of Offsite Agencies; Management of recovery operations; Notification and update of the NRC via Emergency Notification System (ENS);

Notification and update of the NRC via Health Physics Network (HPN);

R Coordination of emergency response activities with federal, state, and local agencies.

The EOF is capable of accommodating designated SNC personnel and offsite Local, State and Federal responders including NRC and FEMA. It is anticipated that representatives from D

the State(s) of Georgia, South Carolina, Alabama, or Florida may be dispatched to the EOF for an event at specific SNC site(s). Responders from state and local agencies have access to plant parameters through the various data displays available in the EOF. See Figure H.2.A.

Based on the physical location of the EOF, specialized ventilation systems are not required.

The EOF ventilation system is consistent in design with standard building codes. Similarly, EOF functions would not be interrupted by radiation releases from any SNC site.

Normal power to the EOF is from a reliable offsite source. Emergency lighting is provided by battery operated lights. Backup power for the EOF is supplied by onsite diesel generation. Essential equipment is backed up by the diesel generation system.

The EOF is located at SNC Corporate Headquarters. The following records or information are available:

Technical Specifications.

Selected plant operating procedures.

Emergency Plans.

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SNC Emergency Plan DRAFT Emergency Plan Implementing Procedures.

Final Safety Analysis Reports (FSARs).

State and local emergency response plans.

Savannah River Site Emergency Plan.

The following records or information can be transmitted to the EOF.

Environs radiological monitoring records.

SNC employee radiation exposure histories.

System piping and instrumentation diagrams and HVAC flow diagrams.

Piping area diagrams.

Electrical one-line, elementary, and wiring diagrams.

The above records or information are available in current form and updated as necessary to ensure currency and completeness.

Access to the EOF is controlled through the use of electronic card readers.

T SNC will maintain space for members of an NRC Site Team and Federal, state and local responders at a location near the site which includes space for conducting briefings with emergency response personnel and communications with other licensee and offsite emergency responders.

AF Details on the near site location are in the site specific Annexes.

R D

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SNC Emergency Plan DRAFT MCL Supplies Supplies NRC PA Lakeside RSCL Patio HPN PMCL RAD ENS STATUS NRC Field RSCL HPN Team Tracking EOF Main T Entrance To Atrium AL SC AF FL GA FFD Facility Loading Dock R

D Video Conference Room Break &

Copier Room CC01 Elevator Lobby To Document Services Exit Figure H.2.A - Emergency Operations Facility Layout (Typical) 55

SNC Emergency Plan DRAFT H.2.2 Joint Information Center (JIC)

The JIC, located at the Atlanta/Birmingham corporate headquarters building of Georgia Power Company/Alabama Power Company, as appropriate, is the official location for coordination and issuance of news announcements and responses to news media inquiries The JIC is the point of contact with the news media during a declared emergency.

The JIC facilities used to coordinate the dissemination of information to the media will be established to accommodate public information representatives from the licensee, Federal, State, and local response agencies. News releases and media briefings are coordinated to the maximum extent possible.

At the discretion of the Public Information Director, a near site media center may be activated to coordinate press releases with local media.

H.3 State and local Emergency Operations Centers (EOC)

EOCs operated by the state and local communities allow direction and control of emergency response functions. The states EOCs are capable of continuous (24-hour) operations for a protracted period.

T The county EOCs serve as Command and Control headquarters for local emergency response activities as well as a center for the coordination of communications to field units and to the H.4 AF state EOCs. Additional details for state and county EOCs are found in the state and county emergency plans.

Emergency Response Facility Staffing and Activation SNC operated nuclear power plants have plans and procedures to ensure timely activation of its emergency response facilities. The Shift Manager, as Emergency Director, will initiate a R

call-out in accordance with the implementing procedures. The ERO augmentation process identifies individuals who are capable of fulfilling the specific response functions listed in Tables B.2.B through B.2.E.

D Although the response time will vary due to factors such as weather and traffic conditions, a goal of 90 minutes for minimum staffing, following the declaration of an Alert or higher emergency classification, has been established for ERO personnel responding to plant emergency facilities including the TSC, OSC, EOF and JIC.

The facility can be declared activated when the following conditions are met:

Minimum staffing has been achieved Personnel have been briefed on the situation and are ready to assume command and control functions.

H.5 Onsite Monitoring SNC operated nuclear power plants have installed monitoring instrumentation for seismic monitoring, radiation monitoring, fire protection and meteorological monitoring, in accordance with its Final Safety Analysis Report (FSAR) and plant Technical Specifications (TS), or commitments made to the NRC. Details as to these systems vary from plant to plant, and are found in the site specific Annexes.

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SNC Emergency Plan DRAFT H.5.1 Geophysical Monitors Meteorological Instrumentation: A permanent meteorological monitoring station is located near the plant for the acquisition and recording of wind speed, wind direction, ambient and differential temperatures for use in making offsite dose projections. Meteorological information is displayed in the CR, TSC, and EOF.

Seismic Monitoring: The seismic monitoring system measures and records the acceleration of the structure if activated by an earthquake of sufficient magnitude.

It also provides signals for immediate remote indication that specific preset response accelerations have been exceeded.

Hydrological Monitors: SNC operated nuclear power plants have hydrological monitors as appropriate. The design basis flood, probable maximum precipitation, and other extremes in hydrologic natural phenomena are as detailed in the FSAR as appropriate.

H.5.2 Radiological Monitors and Sampling H.5.2.1 Radiation Monitoring System (RMS)

T Radiation monitoring instruments are located at selected areas within the plant to detect, measure, and record radiation levels. The monitors are comprised of area, airborne and air particulate monitors.

AF Area monitors respond to gamma radiation; Airborne monitors are capable of detecting and measuring radioactive gaseous effluent concentrations.

Emergency response procedures provide methods for determining relationships between monitor readings and releases, material available for R

release and extent of core damage.

H.5.2.2 Liquid and Gaseous Sampling Systems The process sampling system consists of the normal sampling system and D additional sampling panels located throughout the plant. Pre-designated monitoring and sampling points are listed in site procedures. Sampling systems are installed or can be modified to permit reactor coolant and containment atmosphere sampling even under severe accident conditions. It is capable of providing information relative to post-accident plant conditions to allow operator actions to be taken to mitigate and control the course of an accident. Various chemical analyses and radiological measurements on these samples can be performed, including the determination of radionuclide concentrations.

H.5.2.3 Laboratory Facility SNC sites have a laboratory facility for analysis of radioactive samples.

H.5.2.4 Portable Radiation Monitoring Equipment 57

SNC Emergency Plan DRAFT Portable radiation survey instruments are available for a wide variety of uses such as area, sample, personnel surveys, and continued accident assessment.

H.5.3 Process Monitors The Control Room and redundant backup locations are equipped with extensive plant process monitors for use in both normal and emergency conditions. These indications include reactor coolant system pressure and temperatures, containment pressure and temperature, and various liquid levels, flow rates, status or lineup of equipment components.

H.5.3.1 Plant Monitoring/Information System A plant monitoring/information system provides the data acquisition and database capability for performing plant monitoring and functions. The system is designed to scan, convert to engineering units, make sensor range and alarm limit checks, apply required transformations, store for recall and analysis, and display the reading of transformed data from plant T

instrumentation. The system scans flows, pressures, temperatures, fluid levels, radiation levels, equipment, and valve status at required frequencies.

H.5.3.2 Safety Parameter Display System (SPDS)

H.5.4 Fire Detection System AF The SPDS is in operation during normal and abnormal operating conditions in the Control Room, TSC and EOF.

The Fire Detection System is designed to detect products of combustion or heat in designated areas of the plant. The fire alarm communication systems and subsystems R

are located at strategic points throughout the plant to warn personnel of a fire or other emergency conditions. Additional description of the fire system is provided in the FSAR.

H.6 D

H.5.5 Fire Station Firefighting equipment and supplies are available for damage control operations. The equipment is stored in various areas within the plant.

Offsite Monitoring SNC operated nuclear power plants have made provisions to access data from the following offsite sources of monitoring and analysis equipment:

H.6.1 Geophysical Monitors:

In the event that the onsite meteorological tower or monitoring instrumentation becomes inoperative, meteorological data may be obtained directly from the National Weather Service.

A central point of contact to obtain information about a seismic event is the National Earthquake Information Center.

H.6.2 Radiological Environmental Monitors, Sampling, and Monitoring Equipment 58

SNC Emergency Plan DRAFT SNC operated nuclear power plants maintain a sufficient supply of portable offsite radiological monitoring equipment. These supplies are located at each staging point for Field Monitoring Teams.

SNC operated nuclear power plants have a Radiological Environmental Monitoring Program (REMP) consisting of locations with dose recording devices and air sampling equipment.

H.6.3 Laboratory Facilities External facilities for counting and analyzing samples, dosimetry processing, can be provided by the other SNC operated plants including the GPC Central Laboratory, state, federal or contracted laboratories. Outside analytical assistance may be requested from state and federal agencies, or through contracted vendors. The DOE, through the Radiological Assistance Program (RAP) has access to any national laboratory.

H.7 Meteorological Equipment SNC operated nuclear power plants have meteorological towers equipped with T

instrumentation for continuous reading of the wind speed, wind direction, air temperature and differential air temperature. Meteorological tower details are in the site-specific Annexes.

Additional capabilities are available to obtain representative current meteorological H.8 AF information from other sources, such as the National Weather Service.

Emergency Equipment Inventories and Checks Emergency facilities and equipment are inspected and inventoried using appropriate administrative or department procedures. These procedures provide information on location and availability of emergency equipment and supplies.

H.9 R

Sufficient reserves of instruments and equipment are maintained to replace those removed from emergency kits or lockers for calibration or repair.

Emergency Kits H.10 D

Emergency kits are available at SNC operated nuclear power plants. Designated site or department procedures identify the equipment in the various emergency kits. Details as to kit locations are found in the plant-specific procedures.

Collection Point for Field Samples SNC operated nuclear power plants have designated a point as the location for receipt and analysis of field monitoring team environmental samples. Sampling and analysis equipment is available for quantitative activity determination of marine and air samples, and qualitative activity determination of terrestrial samples.

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SNC Emergency Plan DRAFT SECTION I: ACCIDENT ASSESSMENT I.1 Systems and Parameters Monitored SNC operated nuclear power plants have a comprehensive set of plant system and effluent monitors, as required by the plants Final Safety Analysis Report. Sites have identified values characteristic of off-normal values and accidents, and identified the plant parameter values which correspond to the example initiating conditions in the Nuclear Energy Institute (NEI) 99-01 and 07-01 Emergency Action Levels (EALs). These are described in Section D of this plan, and detailed in the site-specific Annexes.

Plant system and effluent parameter values are utilized in the determination of accident severity and subsequent emergency classification. Environmental and meteorological events are also determining factors in emergency classification. An emergency condition can be the result of just one parameter or condition change, or the combination of several. The specific symptoms, parameter values or events for emergency classification levels are detailed in the plants site-specific Annex.

To adequately assess the emergency condition, applicable emergency facilities have the T

equipment and instrumentation necessary to monitor essential plant information except where local monitoring is required. Evaluation of plant conditions is accomplished by monitoring plant parameters from both the Control Room and within the plant.

AF Some of the key plant parameters monitored in the Control Room are assembled into a single display on the "Safety Parameter Display System" (SPDS). The SPDS monitors such parameters as: reactor coolant system pressure, reactor or pressurizer water level, containment pressure, suppression pool water level and temperature, reactor power, safety system status, containment radiation level and effluent monitor readings. The instrumentation and equipment capabilities available for emergency facilities are described in Section H.

R Select plant parameters are available to state and local authorities via a secure network dedicated to data distribution among the various offsite emergency response facilities.

I.2 D

Continuing and Post Accident Assessment The resources available to provide initial and continuing information for accident assessment throughout the course of an event include plant parameter display systems, liquid and gaseous sampling system, Area and Process Radiation Monitoring Systems, and Accident Radiation Monitoring Systems. Descriptions of these systems are given in Section H.

Details as to how post-accident sampling will be performed are in the plant-specific procedures.

I.3 Offsite Dose Assessment SNC operated nuclear power plants utilize an offsite dose assessment program which estimates doses from radiological accidents for comparison with the EPA Protective Action Guidance and acute health effect thresholds. The dose calculation model is available in the Control Room, TSC, and EOF for use in projecting potential offsite doses.

The program estimates reactor source term, atmospheric transport, and doses resulting from radiological emergencies and can be used to assist in making protective action determinations The system supplements assessments based on plant conditions.

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SNC Emergency Plan DRAFT The model was developed to allow consideration of the dominant aspects of source term, transport, dose, and consequences. Because the program is designed to be used during a radiological emergency, it is assumed that the amount of activity being released and the meteorological conditions will not be precisely known.

I.4 Effluent Monitor Readings and Exposures The offsite dose assessment program addresses the relationship between effluent monitor readings, onsite and offsite exposures, and contamination for various meteorological conditions.

I.5 Meteorological Monitoring SNC operated nuclear power plants have a meteorological monitoring system sufficient to acquire and evaluate meteorological information for accident assessment. This information can be accessed in the Control Room, TSC, and EOF, and is transmitted by the Emergency Response Data System (ERDS), for NRC and offsite authorities use.

I.6 Unmonitored Release Dose projections can be made during a release through use of sample data in situations T

where effluent monitors are either off-scale, inoperative, or the release occurs by an unmonitored flow path. In the absence of effluent sample data, a computerized offsite dose projection can be performed by specifying the accident category as a default.

I.7 AF Environs Surveys and Monitoring In addition to the capabilities and resources described in Section H, SNC operated nuclear power plants have the ability to take offsite air samples and to directly measure gamma dose rates from a radioactive material release. The capability to take offsite soil, water, and vegetation samples is provided by a minimum of two (2) Field Monitoring Teams (FMTs).

R The environmental monitoring equipment include portable survey, counting, and air sampling instrumentation and other radiological monitoring equipment and supplies to be used by the FMTs. Samples are taken at predetermined locations as well as those locations D

specified during and after a release. Environmental measurements are used as an aid in the determination and assessment of protective actions for the general public and recovery actions for the plant.

Field Monitoring Teams are dispatched by SNC operated plants to perform a variety of functions during conditions that may involve significant releases of radioactive materials from a plant. Radiological survey and sample data is used to define affected area boundaries, verify or modify dose projections and protective action recommendations, and assess the actual magnitude, extent, and significance of a liquid or gaseous radioactive material release. Field monitoring data is analyzed by personnel in the TSC until relieved by the EOF staff.

The initial environmental surveys involve measurements to confirm or modify the dose projections based on plant parameters. Subsequent environmental monitoring efforts will be aimed at further defining the offsite consequences, including instituting an expanded monitoring program to enable prompt assessments of any subsequent releases from the plant.

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SNC Emergency Plan DRAFT I.8 Release Assessments SNC operated nuclear power plants have instrumentation, procedures, and trained personnel with the expertise to make rapid assessments of the actual or potential magnitude and location of any radiological hazards through liquid or gaseous release pathways.

I.9 Environmental Radioiodine Monitoring Capabilities Field monitoring equipment has the capability to detect and measure airborne radioiodine in the presence of noble gases.

T AF R

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SNC Emergency Plan DRAFT SECTION J: PROTECTIVE RESPONSE 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 plant personnel. A range of protective actions have been developed for emergency workers and the general public located in the Plume Exposure Pathway Emergency Planning Zone. Guidelines that are consistent with federal guidance have been established to aid in choosing protective actions during an emergency. The responsibility for actions outside of the owner-controlled area rests with the state, county, and other offsite response agencies.

J.1 Alarm Responses The actuation of alarms associated with fire and radiation levels are available to alert personnel to hazardous conditions and protective actions. Site communications methods may also be used as needed.

The site-specific procedures describe the assembly areas for personnel onsite.

For emergency classifications, personnel within the Protected Area are notified of the classification or escalation of an emergency.

T Provisions are made to alert personnel in high noise areas and outbuildings within the Protected Area and within the Owner Controlled Area.

J.2 AF The primary protective measure for non-essential onsite personnel during a Site Area or General Emergency is assembly in a designated area, followed by accounting of site personnel and then determination of appropriate protective actions including Site Evacuation. The designated assembly areas are outside the Protected Area and inside the Owner Controlled Area.

Radiological Monitoring of Evacuated Personnel R

Personnel evacuated from the site will be monitored for contamination if needed by portal monitors as they exit the Protected Area, or with portable friskers in Assembly Areas, or sent to offsite monitoring locations.

J.3 D

Non-essential Personnel Evacuation and Decontamination Requirements for radiological monitoring of personnel evacuated from the site for external radiation exposure are contained in Section K. Section K addresses appropriate actions for any known or suspected overexposures or contamination. Details on the decontamination of non-essential evacuees are found in the site-specific Emergency Plan Implementing Procedures.

J.4 Onsite Protective Actions Onsite protective actions for routine and emergency conditions are detailed under the plants Radiation Protection Program. SNC operated nuclear power plants maintain an inventory of respiratory protection equipment, anti-contamination clothing, and potassium iodide (KI) that is available to emergency workers remaining onsite. During an emergency, protective actions would be taken to minimize radiological exposures or contamination affecting onsite personnel.

Measures which would be taken are:

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SNC Emergency Plan DRAFT On-shift and emergency response personnel use respiratory protection in any environment involving exposure to high level airborne activity or oxygen deficient atmosphere, or where air quality is in doubt. The criteria for issuance of respiratory protection are described in plant Radiation Protection procedures.

Anti-contamination clothing is available for use by onsite personnel. The criteria for issuance of protective clothing are described in plant Radiation Protection procedures.

The criteria for administering a thyroid-blocking agent (KI - Potassium Iodide) to emergency personnel depends on the projected absorbed dose to the thyroid based on the severity and magnitude of the accident.

SNC operated nuclear power plants are responsible for maintaining a supply of KI at their respective site. The Emergency Director has the responsibility for approval of issuing KI to site emergency workers.

Onsite protection of employees during hostile action involves a combination of restricted movement, movement to safe locations, and site evacuation depending on the nature of the hostile event and advance warning. Site-specific procedures provide specific actions to T

take during hostile action or severe weather based events. During a hostile action or severe weather event, Assembly and Accountability actions may be delayed in lieu of other onsite protective actions required to ensure the safety of the site and its personnel. In these cases, J.4.1 Assembly AF accountability will be completed once safe conditions have been established.

Assembly is mandatory following the declaration of a Site Area or General Emergency, or at the discretion of the Emergency Director. When Accountability of onsite personnel is determined to be necessary by the Emergency Director, personnel within the Protected Area will be accounted for and the names of missing individuals J.4.2 R determined within thirty minutes of the emergency declaration.

Accountability Personnel accountability is mandatory at the Site Area or General Emergency D

classification. Accountability may be initiated at other times at the discretion of the Emergency Director to support worker safety.

Accountability of personnel within the Protected Area is accomplished within 30 minutes of the declaration of Site Area Emergency or higher, and maintained continuously thereafter, using Protected Area(s) boundary access control as described in the Security Plan. If there are station personnel who are unaccounted for, the Public Address System or other suitable communication methods are used to locate them, or, in extreme cases such as fire, toxic gas release, explosions, or structural damage, trained search and rescue personnel are deployed to search for and assist the missing personnel.

J.4.3 Site Evacuation If a Site Evacuation is required, personnel are directed to either assemble within designated Assembly Areas or to immediately leave the site. Personnel will be directed to either proceed to their homes or to reassemble at designated locations.

Visitors to the plant will assemble with and follow the instructions of their escorts.

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SNC Emergency Plan DRAFT Personal transportation will normally be used and established evacuation routes will be followed. Personnel without transportation will be identified and provided transportation as necessary.

Evacuation of personnel is usually conducted immediately after accountability if a Site Area Emergency or General Emergency has been declared and no impediments exist. Evacuation shall commence as directed by the Emergency Director.

J.5 Offsite Protective Action Recommendations (PARs)

Plant conditions, projected dose and dose rates, field monitoring data and evacuation time estimates are evaluated to develop PARs for preventing or minimizing exposure to the public. PARs are provided to the offsite agencies responsible for implementing protective actions for the public within the 10-mile EPZ. The Emergency Director will approve PARs.

The PAR decision making flowcharts are site-specific in nature, and are provided in the site-specific implementing procedures. SNC operated plants have the capability to provide state and local agencies a PAR for beyond the 10-mile EPZ.

There are various types of protective actions that can be recommended to the state and counties. They may include the following:

Shelter in Place; Evacuation; T

J.6 AF Controlling food, milk, and water distribution; Thyroid blocking agent; Heightened Preparedness Evacuation Time Estimates (ETE)

R An independent ETE report has been performed for SNC operated nuclear power plants, which provides estimates of the time required to evacuate resident and transient populations surrounding the plant for various times of the year under favorable and adverse conditions.

ETEs for evacuation of the plume exposure EPZ surrounding SNC operated nuclear power J.7 D plants are summarized in the site-specific Annex and detailed in the ETE report.

Protective Action Maps SNC nuclear power plants have maps depicting local roads, primary evacuation travel routes, and the Emergency Planning Zone (EPZ). Maps are also available which show the population distribution within the plant EPZ, and are described in the site-specific Annexes.

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SNC Emergency Plan DRAFT SECTION K: RADIOLOGICAL EXPOSURE CONTROL K.1 Emergency Workers and Lifesaving Protective Actions SNC operated nuclear power plant management will make every reasonable effort to minimize radiation exposure to emergency personnel. Plant management approval is required before emergency workers are allowed to exceed the maximum administrative radiation dose.

Under normal operating conditions, SNC operated plants maintain personnel exposure control programs in accordance with 10 CFR 20. The Emergency Director has the responsibility for authorizing personnel exposure levels under emergency conditions using the guidance in Environmental Protection Agency (EPA) 400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents. 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.

If emergency operations demand life-saving or rescue actions and external radiation fields are minimal, individuals may be allowed exposures to airborne contamination of 10,000 T

Derived Air Concentration (DAC)-hours. If external radiation fields are not minimal, the sum of the external and internal doses should be limited to 25 rem Total Effective Dose Equivalent (TEDE). Exposures above 2,000 DAC-hours should be received only with the Dose (TEDE) Applicability 5 rem All AF approval of the Emergency Director. These exposures will be justified if the reduced risks and costs to others outweigh the risks to which the workers are subjected.

Table K.1.A Emergency Worker Dose Limits Conditions 10 rem R

Protecting valuable property (or equipment) Lower dose not practicable 25 rem

>25 rem D Lifesaving or protection of large populations Lower dose not practicable Lifesaving or protection of large populations Only on a voluntary basis to persons fully aware of the risks involved K.1.1 Removal of Injured Persons Injured persons will receive prompt first aid and decontamination, as practical, before transport by ambulance to a local hospital.

K.1.1.1 Transportation Services Agreements have been made for ambulance services near the SNC operated nuclear power plants. Training is offered to ambulance personnel, and they participate in drills or exercises simulating the transportation of a contaminated, injured individual.

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SNC Emergency Plan DRAFT K.1.2 Decontamination and First Aid K.1.2.1 Onsite Responsive Action Selected plant workers at SNC operated plants have received first aid and decontamination training. If a plant employee cannot be easily decontaminated, the individual is treated as contaminated and measures are taken to prevent the spread of contamination during ambulance transportation and upon arrival at a local hospital.

K.1.3 Medical Treatment Agreements have been made with local hospitals near SNC operated nuclear power plants. Training is offered to medical staffs regarding the treatment of contaminated, injured individuals, and hospitals participate in periodic drills using simulated contaminated, injured individuals.

K.2 Emergency Exposure Authorization SNC operated plants have a Radiation Protection Program. The Emergency Director may authorize emergency workers to receive doses in excess of the administrative dose levels. In T

some situations, it is possible that certain activities or duties for the protection of persons or the substantial protection of property may result in doses in excess of 10 CFR 20.1201 limits.

Decisions to accept doses in excess of occupational limits will be on a volunteer basis and K.3.1 24 Hour Capabilities AF prospective volunteers shall be made aware of the risks.

K.3 Exposure Controls Plant Radiological Protection Groups have the equipment and personnel to provide 24-hour capability to determine and control radiation exposures of emergency R

organization personnel. Equipment to perform the following functions:

Radiation detection devices; D

Personnel monitoring; Record keeping equipment.

Contractor and vendor representatives may also be present to assist in exposure control and augment the Radiation Protection Group capabilities. In an emergency situation, onsite personnel, offsite support personnel and local governmental emergency response personnel may be issued monitoring devices. Exposure records will be maintained for emergency response personnel issued dosimetry.

K.3.2 Personnel Monitoring Equipment SNC operated nuclear power plants have equipment for radiological monitoring of personnel, ranging from hand-held survey equipment to installed or portable portal monitors. Details of plant monitoring equipment are included in the site-specific Annexes.

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SNC Emergency Plan DRAFT K.3.3 Radiation Work Permit Procedures Where possible, the normal radiation work permit procedure will be used to control exposures. Based on conditions and urgency Radiation Protection supervision may approve emergency radiological work permit controls.

K.4 Offsite Emergency Workers The responsibility for authorizing offsite emergency workers to receive exposures in excess of the EPA General Public Protective Action Guides rests with the state.

K.5 Decontamination The Radiation Protection Group will be responsible for controlling or minimizing direct or subsequent internal exposure from radioactive materials deposited on the ground or other surfaces, and for determining the extent of contamination in controlled and normally uncontrolled areas. During normal conditions or an emergency, guidelines to follow for contamination limits are established by the site radiation protection program.

Facilities and supplies for decontaminating personnel are available at various plant locations. Personnel leaving the Radiological Controlled Area (RCA) or leaving a T

contaminated area will be monitored for contamination. During emergencies, other onsite personnel will be checked for contamination as necessary.

AF Designated personnel, under the direction of the Radiation Protection Group, are responsible for performance of material decontamination. Procedures and equipment for material decontamination are available at the plant, as specified in the site radiation protection program.

K.6 Contamination Controls Contaminated areas are isolated as restricted areas with appropriate radiological protection R

and access control. Measures will be taken to control onsite access to potentially contaminated potable water and food supplies.

K.7 Offsite Decontamination D

Nonessential onsite personnel may be evacuated to an offsite reception center or assembly area, as discussed in Section J. Radiological controls personnel at that location monitor evacuees and determine the need for decontamination. In the event that decontamination of evacuees locally is not possible, personnel can be sent to designated locations for monitoring and decontamination.

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SNC Emergency Plan DRAFT SECTION L: MEDICAL AND PUBLIC HEALTH SUPPORT L.1 Hospital and Medical Services In addition to the onsite first aid response, arrangements have been made with local hospitals for treatment and evaluation of serious injuries or sicknesses.

SNC operated nuclear power plants have arranged for hospital and medical services having the capability for evaluation of radiation exposure and uptake, including assurance that persons providing these services are adequately prepared to handle contaminated individuals.

The hospitals are equipped and hospital personnel trained to address contaminated injured individuals. Training of medical support personnel at the agreement hospitals includes basic training on the nature of radiological emergencies, diagnosis and treatment, and follow-up medical care.

Plant personnel are available to assist medical personnel with decontamination, radiation exposure and contamination control. Arrangements, by letter of agreement or contract, are maintained by SNC operated plants with a qualified hospital located in the vicinity of the nuclear power plant for receiving and treating contaminated persons with injuries requiring immediate hospital care.

L.2 First Aid T AF SNC operated nuclear power plants maintain onsite first aid supplies and equipment necessary for the treatment of contaminated and/or injured persons.

L.3 State Emergency Medical Services The states of Alabama and Georgia have developed lists of facilities that can provide medical support for treating injured, contaminated individuals. Details are found in the respective state emergency plan.

L.4 Medical Transport R

Contaminated and injured persons are transported to a facility specified for SNC operated D

nuclear power plants. Arrangements have been made by nuclear power plants for ambulance transport of persons with injuries involving radioactivity to designated hospitals. Such services are available on a 24-hour per day basis and are confirmed by letters of agreement. Radiation monitoring services are provided by SNC plant personnel whenever it becomes necessary to use an ambulance service for the transportation of contaminated persons.

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SNC Emergency Plan DRAFT SECTION M: RECOVERY AND REENTRY PLANNING AND POSTACCIDENT OPERATIONS M.1 Recovery Guidance for determining the transition from Emergency to Recovery Organization are provided in the plant Emergency Plan Implementing Procedures. The composition of the Recovery Organization will depend upon the nature of the accident and the conditions following the accident.

SNC Emergency Plan addresses general principles that serve as guides for developing a Recovery Plan.

It is the responsibility of the Emergency Director (ED) to determine that the facility and surroundings are safe for reentry. The Emergency Director will designate a recovery manager to constitute the recovery organization.

The following guidelines, as applicable to the specific situation, will be addressed prior to terminating the emergency:

T The affected reactor is in a stable condition and can be maintained in that condition indefinitely.

Plant radiation levels are stable or are decreasing with time.

AF Releases of radioactive material to the environment have ceased or are being controlled within permissible limits.

Fire or similar emergency conditions no longer constitute a hazard to safety-related systems or equipment or personnel.

For a site area emergency or general emergency, discussions with plant management, applicable members of the SNC emergency organization, offsite authorities do not result in identification of any valid reason for not terminating the emergency.

R Upon termination of the emergency phase and at the discretion of the Emergency Director, following consultation with offsite authorities, the SNC Emergency Organization will shift to the Recovery Phase Organization.

D The Recovery Manager will structure the recovery organization to accomplish the following general objectives:

Maintain comprehensive radiation surveillance of the site until levels return to normal.

Control access to the affected area of the plant and exposures to workers.

Decontaminate affected areas and equipment.

Conduct activities in radiation areas in accordance with the plant's standard radiation work practices.

Isolate and repair damaged systems.

Document proceedings of the accident and review the effectiveness of the emergency response organization in mitigating plant damage and reducing radiation exposures to the public.

Provide offsite authorities with plant status reports and information concerning the plant recovery organization.

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SNC Emergency Plan DRAFT Provide assistance with recovery activities undertaken by State and county authorities, if requested.

Provide public information on the status of recovery operations via releases to the media.

Other recovery operations will not be initiated until the area affected by the emergency has been defined. Particular attention will be directed toward isolating and tagging out components and systems as required for controlling or minimizing hazards. A systematic investigation will be conducted to determine the equipment damaged and the extent of the damage.

Investigation into the accident causes and consequences, both to the plant and to the environment, will be conducted. Test programs to confirm fitness for return to service will be developed and executed.

Recovery operations will be conducted in compliance with normal operational radiation exposure level limits as specified in 10 CFR 20. When possible, any necessary releases of radioactive materials or effluent during recovery will be planned, controlled, evaluated in advance for radiological impact and appropriate offsite organizations and agencies informed of the scheduled releases and estimated impact.

T AF R

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SNC Emergency Plan DRAFT M.2 Recovery Organization Figure M.2 Typical Long Term Recovery Organization T

AF R

M.2.1 Recovery Manager The nature and extent of the emergency situation will determine what recovery operations are required. The Recovery Organization, shown above, will be D

established as directed by the Recovery Manager.

M.2.2 Plant Actions Recovery actions will be preplanned. Specific actions will be developed in advance and discussed with responsible and knowledgeable personnel.

Reasonable efforts will be made to limit radiation exposure of personnel involved in the recovery to levels as low as reasonably achievable. Exposures should not exceed 10 CFR 20 limits. The Recovery Manager is responsible for evaluating the advisability and timing of authorizing personnel to reenter affected area(s).

The Recovery Manager is responsible for gathering available evidence on contributory factors to the accident, and reviewing the recovery operations to ensure that causal factors have been specifically identified. The Recovery Manager will provide a liaison for the NRC Accident Investigation Team, which will interview primary responders, review any documents generated during the accident, and inspect or test damaged equipment prior to its repair.

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SNC Emergency Plan DRAFT M.3 Recovery Notification Members of the ERO will be informed when Recovery is initiated. The recovery organizational structure may be much the same as the emergency response organization with additional modifications depending upon the nature of the accident, post-accident conditions, and other factors to be determined.

The State EOC will be advised when the plant deems it safe to begin the reentry phase of the offsite recovery operation. If the governor has ordered an evacuation, it is legally required for the governor to officially rescind the order prior to return to evacuated areas. The states are responsible for coordinating reentry procedures for the offsite population.

M.4 Population Exposure Estimates It is anticipated that the Federal Radiological Monitoring and Assessment Center (FRMAC) will make a total population exposure calculation, based on estimated dose rates and population representing exposed areas.

M.5 Termination of Recovery Phase Following the completion of the Recovery Phase, the site will transition to an Outage Organization to complete necessary repairs.

T AF R

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SNC Emergency Plan DRAFT SECTION N: EXERCISES AND DRILLS N.1 Exercises SNC operated nuclear power plants will conduct a biennial exercise and additional periodic drills. An exercise is an event that tests the integrated capability, and a major portion of the basic elements existing within emergency preparedness plans and organizations.

Drills/exercises shall:

Test the adequacy of timing and content of implementing procedures and methods; Test emergency equipment and communications networks; Test the public notification system, Ensure that emergency organization personnel are familiar with their duties SNC operated nuclear power plants conduct an emergency response exercise to demonstrate the effectiveness of the SNC Standard Emergency Plan on a frequency determined by the NRC. Exercises may include mobilization of state and local personnel and resources, and are intended to verify their capability to respond to an accident. Joint exercises shall be T

conducted on a frequency described in NRC/FEMA guidance.

A formal critique shall be conducted following the drill/exercise to evaluate the ability of organizations to respond as required in the SNC Standard Emergency Plan and site specific AF Emergency Plan Implementing Procedures. Critique items will be entered into the SNC corrective action program as appropriate.

Remedial exercises will be required if the emergency plan is not satisfactorily tested during the Biennial Exercise and it is determined that reasonable assurance that adequate protective measures are not taken in the event of a radiological emergency or the ERO has not maintained key skills specific to emergency response.

R N.1.1 Biennial Exercises Federally prescribed Biennial exercises are conducted at SNC operated nuclear power plants. Exercises involving offsite agency participation, required under 10 CFR 50 DAppendix E, are conducted at SNC operated nuclear plants based on Federal Emergency Management Agency (FEMA) guidance and the respective state and local emergency response plans.

N.1.2 Participation SNC operated nuclear power plants exercise with offsite authorities such that state(s) and local governments, within the plume exposure pathway EPZ, exercise the state and local government emergency plans for operating nuclear power plants biennially, with full or partial participation.

Full and Partial participation exercises are described as follows:

Full participation exercises will include, as appropriate, offsite local and state authorities and SNC personnel actively participating in testing the integrated capability to assess and respond to an accident at a nuclear power plant.

Additionally, full participation exercises will include, as appropriate, testing the major observable portions of the onsite and offsite emergency plans and 74

SNC Emergency Plan DRAFT mobilization of state, local, and SNC personnel and other resources in sufficient numbers to verify the capability to respond to the accident scenario.

Partial participation means offsite authorities shall take part in the exercise sufficient to test direction and control functions, including protective action decision making and communication capabilities among affected state and local authorities and SNC operated plants. Where partial or full participation by offsite agencies occurs, the sequence of events simulates an emergency that results in the release of radioactivity to the offsite environs, sufficient in magnitude to warrant a response by offsite authorities.

At a minimum, state and local governments are expected to fully participate in accordance with the requirements of 10CFR50 Appendix E, section IV(F)(2)(c).

N.1.3 Ingestion Exposure Pathway Exercise States within an ingestion exposure pathway EPZ, are expected to exercise its plans and preparedness related to ingestion exposure pathway measures at least once every 8 years. Opportunities are provided to any state or local government located within T

the plume exposure pathway EPZ to participate in Annual Drills and Biennial Exercises when requested by that state or local government.

N.1.4 Exercise Planning Cycle N.2 Drills AF The Exercise planning cycle will consist of eight (8) successive calendar years.

A drill in this context is a supervised instruction period aimed at testing, developing, and maintaining skills in a particular operation N.2.1 Off-Year Drills R

SNC operated nuclear power plants shall take actions necessary to ensure that adequate emergency response capabilities are maintained during the interval between biennial exercises by conducting drills, including at least one drill D

involving a combination of some of the principal functional areas of the licensees onsite emergency response capabilities. The principal functional areas of emergency response include activities such as:

management and coordination of emergency response; accident assessment; event classification; notification of offsite authorities; assessment of the onsite and offsite impact of radiological releases; protective action recommendation development; protective action decision making; and plant system repair and corrective actions.

During these drills, activation of all of the licensees emergency response facilities (Technical Support Center (TSC), Operations Support Center (OSC), and the 75

SNC Emergency Plan DRAFT Emergency Operations Facility (EOF)) would not be necessary. The ERO would have the opportunity to consider accident management strategies, supervised instruction would be permitted, operating staff in participating facilities would have the opportunity to resolve problems (success paths) rather than have controllers intervene, and the drills may focus on the onsite exercise training objectives.

N.2.2 Hostile Action Based (HAB) Drills Hostile Action Based (HAB) drills involving an air, land or water based attack scenario will be conducted at sites on a frequency of at least once every 8 years.

N.2.3 Fire Drills Fire drills will be conducted at nuclear plants in accordance with Plant Technical Specifications and Plant procedures.

N.2.4 Medical Emergency Drills A medical emergency drill, involving a simulated contaminated individual, and containing provisions for participation by local support services organizations including ambulance response are conducted annually at the nuclear plants. Local T

support service organizations, which support more than one plant, shall only be required to participate once each calendar year.

AF N.2.5 Radiological Monitoring Drills Plant environs and radiological monitoring drills are conducted annually. These drills include collection and analysis of sample media and provisions for communications and record keeping. These drills also evaluate the response to, and analysis of, simulated airborne and direct radiation measurements in the environment.

N.2.6 Health Physics Drills R

Health Physics Drills involving a response to, and analysis of, simulated airborne and liquid samples and direct radiation measurements are conducted semi-annually. At least annually, these drills shall include a demonstration of the sampling system D

capabilities, as applicable.

N.2.7 Accountability Drills Accountability drills are conducted annually.

N.2.8 Alternative Facility Drills At least once per drill cycle, use of designated Alternative Facilities to stage On-Site ERO Responders to facilitate rapid activation following a hostile action.

N.2.9 Rapid Escalation At least one per drill cycle, a scenario resulting in an initial classification of, or rapid escalation to a Site Area or General Emergency, will be conducted.

N.2.9 Minimal/No Release Drill At least once per drill cycle, a scenario resulting in no radiological release or an unplanned minimal release resulting in a classification of a Site Area Emergency, but does not require declaration of a General Emergency, shall be conducted.

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SNC Emergency Plan DRAFT N.3 Scenarios When a major drill or exercise is required, the Emergency Preparedness (EP) group will coordinate the preparation of a scenario. The EP group will also coordinate efforts with appropriate federal, state and local emergency organizations and agencies, schedule a date to conduct the drill or exercise, and assign qualified controllers.

The Emergency Preparedness group retains critique results for review prior to future drills or exercise and for guidance in properly modifying the site-specific Annexes, Emergency Plan Implementing Procedures (EPIPs), or other procedures as appropriate.

A scenario, prepared in advance, will govern the conduct of exercises and drills. Scenarios will include the following:

Objectives of the drill or exercise; a measurable and observable objective must be specified for each major problem and solution; Dates, time period, places, personnel, and participating organizations; Simulated events; T

Time schedule of real and simulated initiating events; Narrative summary describing the conduct of the exercise or drill, including simulated casualties, offsite fire department assistance, rescue of personnel, use of AF protective clothing and associated equipment, deployment of personnel and radiological teams, and public information activities.

During the exercise planning cycle described in Section N.1.4, SNC sites vary the content of exercise scenarios to provide ERO members the opportunity to demonstrate proficiency in key skills necessary to respond to several specific scenario elements including:

Hostile Action directed at the plant site; actions; R No radiological release or unplanned release that does not require public protective An initial classification of or rapid escalation to a Site Area Emergency or General D

Emergency; Implementation of strategies, procedures, and guidance developed in 50.54(hh), (i.e.,

potential aircraft threat, explosion or large fire);

Integration of offsite resources with onsite response A drill initiated between the hours of 6 p.m. and 4 a.m.

Drills utilizing essentially 100 % of Initiating Conditions in the 8 year cycle Drills and exercise scenarios will be varied from year to year so as to test major components of the plans and preparedness organizations.

Records of Exercises conducted during the eight (8) year exercise planning cycle that documents the contents of scenarios used during that cycle shall be maintained.

SNC sites submit Biennial Exercise scenarios under § 50.4 for prior NRC review and approval.

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SNC Emergency Plan DRAFT N.4 Exercise Evaluation and Critique A critique shall be conducted at the conclusion of the exercise, to evaluate the organization's ability to respond as called for in the SNC Standard Emergency Plan.

Qualified personnel will observe and perform a critique of exercises and drills. Provisions will be made for federal, state, and local observers, as well as SNC personnel, to observe and critique required exercises.

Biennially, representatives from the NRC observe and evaluate the licensees ability to conduct an adequate self-critical critique. For partial and full offsite participation exercises, the NRC and Federal Emergency Management Agency (FEMA), will observe, evaluate, and critique.

Drill and exercise performance objectives will be evaluated against measurable demonstration criteria. As soon as possible following the conclusion of the drill or exercise, a critique is conducted to evaluate the ability of the Emergency Response Organization (ERO) to implement the emergency plan and procedures and a formal evaluation will result from the critique.

T A written critique report is prepared by the Emergency Preparedness group following a drill or exercise involving the evaluation of designated objectives or following the final simulator set with ERO participation. The report will evaluate the ability of the ERO to AF respond to a simulated emergency situation. The report will also contain corrective actions and recommendations.

N.5 Exercise/Drill Corrective Actions The critique and evaluation process is used to identify areas of the Emergency Preparedness Program that require improvement. The Emergency Preparedness group is responsible for evaluation of recommendations and comments, to determine which items will be R

incorporated into the program or require corrective actions, and for the scheduling, tracking, and evaluation of item resolution. Whenever exercises or drills indicate deficiencies in the SNC Standard Emergency Plan, site-specific Annexes, corresponding implementing procedures, or training lesson plans, such documents will be revised as necessary.

D The results of exercise critiques, particularly comments on identified areas which require improvement or reevaluation, will be submitted to the Emergency Preparedness Supervisor or designee, for review. The Emergency Preparedness Supervisor or designee will consult with responsible department heads and assign corrective action activities, as appropriate.

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SNC Emergency Plan DRAFT SECTION O: RADIOLOGICAL EMERGENCY RESPONSE TRAINING O.1 Training To achieve and maintain an acceptable level of emergency preparedness, training will be conducted for members of the Emergency Response Organization (ERO) and those offsite organizations who may be called upon to provide assistance in the event of an emergency.

The ERO Training Program assures the training, qualification, and requalification of individuals who may be called on for assistance during an emergency. Specific emergency response task training, prepared for response positions, is described in lesson plans and study guides. The lesson plans, study guides, and written tests are contained in the ERO Training Program. Responsibilities for implementing the training program are contained in plant procedures. Offsite training is provided to support organizations that may be called upon to provide assistance in the event of an emergency.

Personnel from nuclear power plants annually offer to train those non-SNC organizations referenced in the Plant Annexes that may provide specialized services during a nuclear plant emergency. The training offered will acquaint the participants with the special problems T

potentially encountered during a nuclear plant emergency, notification procedures, and their expected roles. Organizations that must enter the site shall also receive site-specific emergency response training and be instructed as to the identity of those persons in the onsite AF organization who will control their support activities.

Training of state and local offsite emergency response organizations is described in their respective radiological emergency plans, with support provided by SNC if requested.

O.1.1 Training of Local Services Groups A training opportunity will be offered annually for offsite organizations and R

agencies as specified in respective agreements and understandings. In addition, those offsite organizations and agencies that may provide onsite emergency assistance will be encouraged to become familiar with the general layout of SNC plants, and will be invited to attend applicable Emergency Plan training and D

orientation courses.

Annually, training will be offered for hospital personnel, ambulance/rescue personnel, police, and fire departments. The training shall include the procedures for notification, basic radiation protection, and their organizations expected role.

O.2 Performance Demonstration In addition to general and specialized classroom training, members of the SNC ERO receive periodic performance based emergency response training. Performance based training is generally provided via participation in a performance drill or exercise.

A drill is a supervised instruction period aimed at testing, developing and maintaining skills in a particular operation. Drills described in Section N of this plan are a part of training.

These drills allow 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 offered by the Controller.

O.3 First Aid Training 79

SNC Emergency Plan DRAFT Individuals assigned to search and rescue teams shall maintain qualifications to meet the requirements of the supporting agency providing first aid and Cardio-Pulmonary Resuscitation (CPR) training.

O.4 ERO Training SNC ERO personnel who are responsible for implementing this plan receive specialized training. The training program for emergency response personnel is developed based on the requirements of 10 CFR 50, Appendix E and position specific responsibilities.

On-Shift emergency response personnel perform emergency response activities as an extension of their normal duties and are trained annually as part of their duty specific training.

Requalification training for onsite ERO members consists of an annual review of the Emergency Plan in the form of a general overview, and/or participation in a drill or exercise in their assigned position or a similar one. In addition to SNC Emergency Plan overview training, personnel assigned onsite emergency response positions will receive training specific to their position.

O.4.1 Emergency Response Organization (ERO)

T ERO members will receive Emergency Plan training on an annual basis. Personnel identified receive training appropriate to their position in the areas of:

Accident assessment; Accident mitigation; Notifications; AF Emergency Classifications; Protective Action Recommendations; R

Emergency Action Levels; Emergency Exposure Control.

D O.4.2 Active Senior Licensed Control Room Personnel Active Senior Licensed Control Room Personnel shall have training such that proficiency is maintained on the topics listed below. These subjects shall be covered, as a minimum, on an annual basis:

Event Classification; Protective Action Recommendations; Radioactive Release Rate Determination; Offsite dose assessment; Notification form completion and communication; Federal, state, and local notification procedures as appropriate; Activating the onsite and offsite ERO.

O.4.3 Radiological Field Monitoring Teams 80

SNC Emergency Plan DRAFT Radiological Field Monitoring Team personnel will receive classroom and hands-on training in the actions they will be expected to perform during an emergency. The following general topics will be included in the training:

Equipment and Equipment Checks; Communications; Plume Tracking Techniques; Personnel monitoring; Emergency exposure criteria; Locations and use of radiological emergency equipment.

O.4.4 Fire Brigade Training Individuals assigned to Fire Brigade shall maintain fire brigade qualifications.

O.4.5 Operations, Maintenance, Chemistry and Radiation Protection Training Operations, Maintenance, Chemistry and Radiation Protection personnel who would be assigned to Repair and Damage Control Teams are trained as part of their normal T

job specific duties to respond to both normal and abnormal plant operations.

O.4.6 Medical Support AF Onsite medical personnel receive specialized training in the handling of contaminated victims and hospital interface. Offsite ambulance and hospital personnel are offered annual training as outlined in Section O.1.1.

O.4.7 News Media Training Local news media personnel will be offered an annual training opportunity as R

described in Section G.

O.4.8 General Employee Training (GET)

GET will include general training in emergency preparedness for plant and other site D

personnel. GET will include classification, individual response, signals, accountability, and site evacuation procedures.

O.5 Emergency Preparedness Staff Training Training for the Emergency Preparedness Staff at an SNC operated plant consists of initial and continuing training process. Details can be found in site specific procedures and processes.

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SNC Emergency Plan DRAFT SECTION P: RESPONSIBILITY FOR THE PREPAREDNESS EFFORT The President/Chief Executive Officer (CEO) Southern Nuclear Operating Company (SNC) has direct responsibility for the operation and maintenance of the SNC Plants. The president/CEO is also responsible for all technical and administrative support activities provided by SNC. The president/CEO directs the chief nuclear officer/executive vice president, Executive Vice President-Operational Readiness and Integration and the vice president of regulatory affairs in fulfillment of their responsibilities.

Responsibility for the performance of Emergency Preparedness functions is assigned to various members of the SNC organization and coordinated as follows.

P.1 Fleet Emergency Preparedness The Vice President - Regulatory Affairs is responsible for the overall coordination of the corporate emergency preparedness programs and Emergency Plans. Their direct report, the Fleet Emergency Preparedness Director, has governance and oversight responsibility for the SNC Fleet Emergency Preparedness functional area.

The Fleet Emergency Preparedness Director is responsible for the oversight of Emergency T

Preparedness activities and coordinating those activities with Licensee, Federal, State, and local response organizations. The Fleet Emergency Preparedness organization in the SNC Corporate office provides oversight and support for site and corporate functions. Reporting AF to the Fleet Emergency Preparedness Director are the EP Programs Manager and the EP Planning Manager. EP Programs Manager responsibilities include Regulations, Projects, Procedures and Performance Improvement. EP Planning Manager responsibilities include offsite interface, Drill and Exercise Coordination and Training.

Strategic direction for the emergency preparedness program and maintenance of the SNC Emergency Plan(s) is provided by the SNC Fleet Emergency Preparedness Director.

R Emergency Preparedness Coordinator(s) coordinate functional elements of the emergency preparedness program for the SNC fleet under the direction of the Fleet Emergency Preparedness Director.

D Emergency Plan changes are reviewed to determine if the effectiveness of the specific plans have been reduced in accordance with the requirements of 10 CFR 50.54q. Changes which are judged to reduce the effectiveness of the Plan will be submitted to the NRC for approval prior to implementation.

P.2 Site Emergency Preparedness The Vice President-(Site) is responsible for the site Emergency Preparedness aspects of the program at each site. The Emergency Preparedness Supervisor is responsible for coordinating onsite emergency preparedness activities and supports offsite emergency preparedness activities in the plant vicinity. The Emergency Preparedness Supervisor reports through the Regulatory Affairs Manager to the Vice President-(Site) for Plants Hatch and Farley. During project construction efforts for Vogtle 3 and 4, the Vogtle 1-2 Emergency Preparedness Supervisor reports to the Site Integration Director. The Vogtle 3-4 Emergency Preparedness Supervisor reports to the Emergency Preparedness/Security Project Manager, who reports to the Site Integration Director. The Site Integration Director reports to the Executive Vice President - Operational Readiness and Integration. The 82

SNC Emergency Plan DRAFT Emergency Preparedness Supervisor is responsible for the implementation of emergency planning strategies provided by the Fleet Emergency Preparedness Director.

P.3 Coordination The Fleet Emergency Preparedness Director coordinates site input and involvement in emergency planning programs with the Emergency Preparedness Supervisor. The Emergency Preparedness Supervisor is responsible for the implementation of the Emergency Plan and program maintenance activities. Figure P.1 shows the EP organization.

EPIPs and administrative procedures for the Emergency Preparedness function are maintained by the Fleet Emergency Preparedness Director with a designated EP staff member being the principle contact.

Approved changes to the Emergency Plan are forwarded to key organizations and appropriate individuals who are responsible for implementing the Plan. The Emergency Plan, agreements, and the EPIPs are reviewed once per calendar year and updated, as needed. These updates take into account changes identified by drills and exercises, and the independent review described below.

T An independent review of the EP program is conducted, as required by 10 CFR 50.54(t).

The review includes the Emergency Plan, implementing procedures and practices, training, AF readiness testing, equipment, and interfaces with offsite agencies. The results of the review, along with recommendations for improvements, are documented and reported to plant management and to appropriate offsite agencies. Management controls are implemented for evaluation and correction of the review findings. Records of these audits and recommendations are maintained for at least 5 years.

In addition to this Plan, several other formal emergency plans have been developed to R

support the overall emergency response effort. Once per calendar year, the designated Emergency Planning staff performs a review of the emergency plans for Southern Nuclear.

This review includes a comparison for consistency of emergency plans for a specific site including the Security Plan, State, and County plans as appropriate.

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SNC Emergency Plan DRAFT Figure P.1 - Typical Emergency Preparedness Organization T

AF R

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