Latest revision as of 00:45, 7 May 2019

Text

to EN-RW-106, Integrated Transportation Security Plan.
	ML16132A508
Person / Time
Site:	Waterford
Issue date:	04/08/2015
From:	; Entergy Operations
To:	; Office of Nuclear Reactor Regulation
Shared Package
ML16132A496	List: ML16132A494; ML16132A506; ML16132A507; ML16132A508; ML16132A509; ML16132A510; W3F1-2016-0038, UNT-005-014, Rev. 306, Offsite Dose Calculation Manual.;
References
	W3F1-2016-0038 EN-RW-106, Rev 4
	Download: ML16132A508 (46)
	v • d • e

NUCLEARMANAGEMENTMANUAL N ON-QUALITY RELATED EN-RW-106REV. 4 INFORMATIONAL U SEPage 1 of 46Integrated Transportation Security PlanProcedure Contains NMM ECH eB REFLIBForms: YES NOProcedure Revision Type: New NO N-EditorialEditorial TCCancellationHQN EffectiveDateProcedure Owner:Title: Site:Alan ZelieManager, RP PNPSGovernance Owner:Title: Site:David MooreManager, Fleet RPHQN4/8/15 SiteSite Procedure ChampionTitle ANODonnie MarvelManager, RP BRPN/AN/A CNS Bob BeilkeManager, RPGGNSRoy MillerManager, RP IPECFrank MitchellManager, RP JAFRobert HeathManager, RP PLPDoug WatkinsManager, RP PNPSAlan ZelieManager, RP RBSBrad ColeManager, RP W3Daniel FreyManager, RPHQNDavid MooreManager, Fleet RPFor site implementation dates see ECH eB REFLIB using site tree view (Navigation panel).Site and NMM Procedures Canceled or Superseded By This Revision NoneProcess Applicability Exclusion:All Sites:Specific Sites: ANO BRP CNS GGNS IPEC JAF PLP PNPS RBS W3Change Statement Attachment 9.2, "10 CFR Part 37 Subpart D Physical Protection in Transit Required Summary" is deletedand being replaced by other Attachments. What was formerly Attachment 9.3, now becomes Attachment9.2. Changed reference within the procedure body to reflect this change. Added new Attachments 9.3 - 9.8 Section 4.0: deleted steps [1] and [6] as Physical Security is not responsible for transportation security (perCR-HQN-2015-00098, CA-2) Step 4.0[2]: added new responsibility for Training Manager Step 5.5[1]: reworded for clarity Step 5.5[4]: inserted new step regarding annual review of Carrier TSP (per CR-HQN-2015-0105, CA-3) Step 5.5[9]: Changed reference to Attachment from 9.3 to 9.2 to reflect change in attachment number Step 5.7.1[2]: revised to reflect new checklist attachments Step 5.7.2.1[1]: added reference to Attachment 9.3 Step 5.7.2.1[2] is separated into two steps and reworded to improve clarity and to provide reference toAttachments 9.4 and 9.5 Added new steps 5.6[4] and 5.6[5] to address hazmat training requirements identified in CR-HQN-2015-00043 Added Attachments 9.6, 9.7 and 9.8 to Section 7.0 RECORDSAssociated PRHQN #:

2014-00545Procedure Writer:Ron SchwartzContains Proprietary Information:

YES NO NUCLEARMANAGEMENTMANUAL N ON-QUALITY RELATED EN-RW-106REV. 4 INFORMATIONAL U SEPage 2 of 46Integrated Transportation Security Plan__________________________________________________________________________TABLE OF CONTENTS Section Title Page1.0PURPOSE .............................................................................................

32.0REFERENCES

....................................................................................... 33.0DEFINITIONS......................................................................................... 44.0RESPONSIBILITIES .............................................................................. 75.0DETAILS ............................................................................................. 85.1PRECAUTIONSANDLIMITATIONS ...................................................... 85.2GENERAL ............................................................................................. 85.3RISKASSESSMENT.............................................................................. 85.4CARRIERTSPANDCONTRACTSMANAGEMENT .............................. 95.5CARRIERHAZARDOUSMATERIALTRANSPORTATIONSECURITYPLAN ........................................................................................... 105.6TRAINING ........................................................................................... 115.7ADDITIONALSECURITYMEASURESFORRADIOACTIVESHIPMENTS-CATEGORY1ANDCATEGORY2QUANTITIES ......... 125.8TYPESOFHAZMATSHIPMENTSADDRESSEDBYTHEENTERGY(EOI/ENOI)TSP-RA............................................................................ 255.9INFORMATION .................................................................................... 266.0INTERFACES ...................................................................................... 267.0RECORDS ........................................................................................... 278.0SITESPECIFICCOMMITMENTS ......................................................... 279.0ATTACHMENTS .................................................................................. 27 ATTACHMENT9.1TSP-RATABLES .................................................................. 28 ATTACHMENT9.2SAMPLE CARRIER AFFIRMATION LETTER ................................. 34 ATTACHMENT9.3LICENSE VERIFICATION SYSTEM CREDENTIAL GUIDE ................ 35 ATTACHMENT9.4MANUAL LICENSE VERIFICATION FORM GUIDE ......................... 36 ATTACHMENT9.5MANUAL LICENSE VERIFICATION PROCEDURE GUIDE ............... 38 ATTACHMENT9.610CFR37SUBPART DCATEGORY 1PHYSICAL PROTECTION REQUIREMENT CHECKLIST ...................................................................... 40 ATTACHMENT9.710CFR37SUBPART DCATEGORY 2PHYSICAL PROTECTION REQUIREMENT CHECKLIST ...................................................................... 44 ATTACHMENT9.810CFR37SUBPART DCATEGORY 1QUANTITIES OF C ONCERN STATE COORDINATION L OG ..................................................................... 46__________________________________________________________________________

NUCLEARMANAGEMENTMANUAL N ON-QUALITY RELATED EN-RW-106REV. 4 INFORMATIONAL U SEPage 3 of 46Integrated Transportation Security Plan1.0 PURPOSEThis document implements the requirements of the DOT Transportation SecurityRequirements and the NRC's Additional Security Measures for Radioactive Material -Category 1 and Category 2 Quantities. The requirements stem from the Department ofTransportation as well as the Nuclear Regulatory Commission.

2.0 REFERENCES

[1] 49 Code of Federal Regulations, Part 172-173, Hazardous Materials[2] EPRI Hazardous Material Transportation Security Plan Risk Assessment[3] 10 CFR Parts 70, 71, 72 and 73 (NRC Regulations)[4] 33 CFR 105, Temporary Interim Rule, Effective July 1, 2003 (US Coast GuardRegulations)[5] 49 CFR 172.800, Revised Regulations, Effective March 25, 2003 (DOT Regulations)[6] American Chemistry Council, et al; Transportation Security Guidelines for the U.S.Chemical Industry, 2001[7] DOE Memorandum, Jessie Roberson to Distribution, Approval of CommercialShipments of Radioactive Materials and Waste on Behalf of the Office ofEnvironmental Management, June 27, 2003[8] DOT-RSPA, Enhancing Security of Hazardous Materials Shipments Against Acts ofTerrorism or Sabotage Using RSPA's Risk Management Self-Evaluation Framework(RMSEF), January 2002[9] DOT-RSPA, Three Case Studies for the Risk Management Framework for HazardousMaterials Transportation, November 1, 2000[10] DOT-RSPA, Flyer DHM50-0023-1002, Shippers and Carriers Enhanced SecurityMeasures, not dated[11] DOT Slide Presentation, Hazardous Materials Transportation Security, NEITransportation Security Meeting, May 29, 2003[12] DOT Federal Motor Carrier Safety Administration, Hazardous Materials CompanyAnti-Terrorism Tips, DOT Web Site, Internet download July 7, 2003[13] Federal Register, Volume 68, Number 126, page 39315-39338, 33 CFR 105, July 1, 2003 NUCLEARMANAGEMENTMANUAL N ON-QUALITY RELATED EN-RW-106REV. 4 INFORMATIONAL U SEPage 4 of 46Integrated Transportation Security Plan2.0 continued[14] GAO Report to Congressional Requesters, GAO-03-435 Rail Safety and Security,Some Actions Already Taken to Enhance Rail Security, but Risk-based Plan Needed,April 2003[15] NRC, Fact Sheet on Dirty Bombs, NRC Web Site, internet download, June 30. 2003[16] U.S. Department of Justice, Special Report, A Method to Assess the Vulnerability ofU.S. Chemical Facilities, November 2002[17] NRC letter from J. E. Dyer dated July 19, 2005, "Issuance of Order for AdditionalSecurity Measures on the Transportation of Radioactive Material Quantities ofConcern" EA 05-007[18] NEI 14-XX [Rev C], Implementation Guidelines for 10 CFR 37 Subpart D PhysicalProtection in Transit[19] 10 CFR Part 37, "Physical Protection Of Category 1 And Category 2 Quantities OfRadioactive Material"3.0 DEFINITIONS[1] Acronyms:ASM - Additional Security Measures (EA 05-007)COTP - Captain of the Port (US Coast Guard designation)DAW - Dry Active WasteDOT - Department of TransportationENOI - Entergy Nuclear Operations, IncorporatedEOI - Entergy Operations, IncorporatedFBI - Federal Bureau of InvestigationLLEA - Local Law Enforcement AgenciesNEI - Nuclear Energy InstituteNRC - Nuclear Regulatory CommissionSRCP - Security Risk Control PointsTSA - Transportation Security AdministrationTSP - Transportation Security PlanTSP-RA - Transportation Security Plan - Risk AssessmentUSCGS - U.S. Coast Guard Service NUCLEARMANAGEMENTMANUAL N ON-QUALITY RELATED EN-RW-106REV. 4 INFORMATIONAL U SEPage 5 of 46Integrated Transportation Security Plan3.0 continued

[2]Aggregated - Accessible by the breach of a single physical barrier that would allowaccess to radioactive material in any form, including any devices that contain theradioactive material, when the total activity equals or exceeds a category 2 quantity ofradioactive material

[3]Dry Active Waste - Dry, solid radioactive waste (as opposed to wet wastes such asresins, filters, or filter media)

[4]Greater Than Class C Waste (GTCC) - Low-level radioactive waste that exceeds theconcentration limits of radionuclides established for Class C waste in 10 CFR Part 61.55.[5]Hazardous Material - For the purposes of the TSP-RA, this term includes thedefinition in 49CFR173.403 and as listed in associated table under 49CFR172.101.

[6]Highway Route Control Quantities (HRCQ) - A quantity within a single packagewhich exceeds 3000 times the A1 value for special form or 3000 times the A2 valuefor normal form or 1000 TBq (27,000 Ci), whichever is the least.

[7]Lost or Missing Licensed Material -Means licensed material whose location isunknown.[8]Low Specific Activity (LSA) - Radioactive material with limited specific activity whichsatisfies the following limits: ores containing only naturally occurring radionuclides,solid un-irradiated natural or depleted uranium or natural thorium or their solid or liquidmixtures, etc. (see 49CFR173.403 for exact definition).

[9]Materials of Significant Concern - For the purposes of the TSP-RA, this refers tohazardous materials which are known or presumed to be so acutely toxic to humansas to afford a hazard to health during transportation, thereby representing a significanttransportation security risk.

[10]Movement Control Center - An operations center that is remote from transportactivity and that maintains position information on the movement of radioactivematerial, receives reports of attempted attacks or thefts, provides a means forreporting these and other problems to appropriate agencies and can request andcoordinate appropriate aid.

NUCLEARMANAGEMENTMANUAL N ON-QUALITY RELATED EN-RW-106REV. 4 INFORMATIONAL U SEPage 6 of 46Integrated Transportation Security Plan3.0 continued

[11]National Security Threat Level - Transportation of certain types of hazmatshipments may be restricted during periods of elevated security threat levels. Thedegree of restriction, associated risk, and the affected hazmat shipments will affect thelevel of security control applied to certain hazmat shipments. The National SecurityThreat Level is established by the Department of Homeland Security and serves as ageneral guide for the security threat level established by other agencies, such as theNRC and USCGS. Also note that the NRC and USCGS may have different (higher)security threat levels than the national security threat level. Nuclear plant securityactivities are governed by the highest security threat level applied by the NRC and, asapplicable, the USCGS.

[12]NO-LATER-THAN Arrival Time - The date and time that the shipping licensee andthe receiving licensee have established as the time at which an investigation will beinitiated if the shipment has not arrived at the receiving facility.

[13]NRC Security Threat Level - Corresponds to the National Security Threat Level.However, it is independently controlled and established by the NRC, and fluctuatesindependently from the National Threat Level. This is the primary threat levelmonitored by nuclear plants, and it encompasses a combination of threats fromNational, Maritime, and other sources.

[14]MARSEC Level - Maritime Security [Threat] Level as identified and maintained by theUSCGS. It is independently controlled and established by the USCGS, and fluctuatesindependently from the National Threat Level or the NRC Threat Level. The MARSECis also monitored by the affected nuclear plants, which respond accordingly.

[15]Physical Security Plan (PSP) - For a nuclear plant, this is the PSP required by 10CFR 73. For some decommissioning nuclear plants and for other licensed nuclearsupport facilities (e.g., radioactive laundry vendors, waste processors, nuclear plantmaintenance facilities), this refers to the "industrial security plan." The term PSP alsoencompasses the USCGS FSP and all of the related requirements specified in 33CFR 105, Subpart D.

[16]Radioactive Material - For the purposes of the TSP-RA, this term includes bothradioactive materials and radioactive wastes.

[17]Safe Haven - Readily accessible site at which security is present or from which, in theevent of an emergency, the transport crew can notify and wait for local lawenforcement authorities.

[18]Storage Incidental to Movement - Storage that takes place between the time that ahazardous material is offered for transportation to a carrier and the time it reaches itsdestination.

NUCLEARMANAGEMENTMANUAL N ON-QUALITY RELATED EN-RW-106REV. 4 INFORMATIONAL U SEPage 7 of 46Integrated Transportation Security Plan3.0 continued

[19]Telemetric Positioning Monitoring- A data transfer system that capturesinformation by instrumentation and/or measuring devices about the location and statusof a transport vehicle or package between the departure and destination locations.

[20]TSP - Hazardous Material (and Radioactive Material) Transportation Security Plan.

[21]TSP-RA - Transportation Security Plan Risk Assessment.

[22]Unauthorized Persons - An unauthorized person is any person who is not authorizedby the shipper or the transportation carrier to have access to hazardous materials ortransport conveyances being prepared for transportation. This includes all personswho are not employed by the shipper or the transportation carrier, including membersof the general public, unless such persons are specifically authorized by the shipper ortransportation carrier to have access to hazardous materials or transport vehiclesbeing prepared for transportation.4.0 RESPONSIBILITIES

[1]Materials, Purchasing & Contracts Manager is responsible for supporting the keyelements of the procedure within the requirements of Section 5.0 [3].

[2]Training Manager is responsible for the key elements of the procedure to ensure thatHazardous Material (HAZMAT)AND 10 CFR Part 37.43(c) training requirementsoutlined in Section 5.0 of this procedure are developed and implemented.

[3]Radiation Protection Manager (RPM) is responsible for ensuring the RiskAssessment outlined in this procedure will meet radioactive hazardous materialsprocessing requirements and notifying MP&C of the need to ship materials, from a sitewarehouse, that meet the requirements of hazardous materials.

[4]Chemistry Superintendent is responsible for ensuring the Risk Assessment outlinedin this procedure will meet non-radioactive hazardous materials processingrequirements and notifying MP&C of the need to ship materials, from a sitewarehouse, that meet the requirements of hazardous materials.

NUCLEARMANAGEMENTMANUAL N ON-QUALITY RELATED EN-RW-106REV. 4 INFORMATIONAL U SEPage 8 of 46Integrated Transportation Security Plan5.0 DETAILS5.1 PRECAUTIONS AND LIMITATIONS None5.2 GENERALNOTE"Tables" referenced in this procedure are located in Attachment 9.1, "TSP-RA Tables"Table 1: Typical Radioactive and Hazardous Material ShipmentsTable 2: Hazmat Carriers, Types of Hazmat Shipments and Quantities ShippedTable 3: Determination of Hazardous Materials of Significance to This AssessmentTable 4: Category 1 and Category 2 ThresholdTable 5: Hazardous Materials of Significant Concern Shipped from Facilities[1] The Physical or Industrial Security Plans already contain security procedures, accesscontrols, requirements for employee background checks, etc. Such procedures,controls regulations and therefore need not be duplicated.[2] The Entergy (EOI / ENOI) standard language approach to the TSP consists of asimplified and minimal TSP document plus an attachment used in association with theprocedure.5.3 RISK ASSESSMENT[1] This TSP-RA is applicable to packaging, staging/storage in preparation for transport,and shipment of the radioactive and hazardous materials addressed in 49 CFR172.800. Table 1 identifies the types of radioactive and hazardous materialsshipments.[2] Transportation Carriers contracted to carry radioactive and/or hazardous materialsand who's TSPs are relied upon to provide all necessary security during transport andduring storage incidental to movement. This includes the categories of carriers listedin Table 2.

NUCLEARMANAGEMENTMANUAL N ON-QUALITY RELATED EN-RW-106REV. 4 INFORMATIONAL U SEPage 9 of 46Integrated Transportation Security Plan5.3 continued[3] For bulk quantity shipments of hazardous material identified in Table 5 which willcross bridges spanning water, through tunnels under water, or on water which ispatrolled by the USCGS, regardless of whether the shipment is made by highway, railor vessel, advance notification of the shipment or of a series of shipments is to begiven to the affected USCGS Port Authority. The licensee SHALL notify the USCGSat least 10 days before the shipment physically begins within the United States. Forshipments where 10 days of advance notice is not possible, the notification is to bemade as soon as practicable. The notification SHALL be made to the appropriateUSCGS Port Authority. (The USCGS may choose to require facility-specificnotification for other materials.)[4] In the event that a shipment of material described in 5.2[3] arrives at the intendedconsignee but is refused by the consignee, the Carrier maintains responsibility forsecurity of the shipment until it arrives at an acceptable destination designated by the shipper.[5]IF the U.S. Department of Homeland Security's (DHS's) National Terrorism AdvisorySystem (NTAS) issues an "Elevated Alert" or "Imminent Alert",ORIF the USCGSMARSEC Level reaches 2 or 3 (as applicable to each plant),THENCategory 1 andCategory 2as well as HRCQ shipments arenot to be shipped

.[6] The shipment of all hazardous material described in Table 1 may have other controlsimplemented by the shipper (during shipment preparation & shipping coordination) orcarrier (en-route security).5.4 CARRIER TSP AND CONTRACTS MANAGEMENT[1] The optimum approach is for the carrier to implement its own TSP which addresses allaspects of the transportation security regulations, including hazmat employee trainingand driver commercial licenses and endorsements. Accordingly, MP&C willincorporate standard language in their Contracts and Purchase Orders, whereapplicable, that will require the transportation company to implement its own TSP. It isnot necessary to review and approve each carrier's TSP prior to implementation bythe carrier.[2] The language in Section 5.5, "Carrier Hazardous Material Transportation SecurityPlan," or similar language, is to appear in every carrier contract where the carrier isanticipated to transport any of the highly hazardous materials identified in 49 CFR172.800. The end user (contract requisitioner) should identify whether thetransportation of hazardous materials is anticipated when submitting a request for a new contract.

NUCLEARMANAGEMENTMANUAL N ON-QUALITY RELATED EN-RW-106REV. 4 INFORMATIONAL U SEPage 10 of 46Integrated Transportation Security Plan5.5 CARRIER HAZARDOUS MATERIAL TRANSPORTATION SECURITY PLAN[1] The Carrier will affirm each time (i.e., separate shipment) that it has a HazardousMaterial Transportation Security Plan in place prior to approval of the contract orcontract amendment, that the plan meets all applicable Federal and Internationaltransportation security regulations in effect as of the contract or contract amendmentdate, and that said TSP will be updated in a timely manner to remain current withrevised and new Federal and International transportation security regulations.[2] The Carrier is also responsible for implementing regulations for commercial driverlicenses hazardous material endorsements.[3] Advanced approval of the Carrier's TSP is not required for implementation of thiscontract. However, it will be made available for review and approval by an authorizedrepresentative of ENTERGY (EOI / ENOI) if requested and on reasonable verbal orwritten notice, with due consideration given to document security and control.[4] The Transportation Security Plan for Carriers under contract shall be reviewed at leastannually.[5] Prior to dispatching any driver to an ENTERGY (EOI / ENOI) facility for the purposesof transporting hazardous material, the Carrier is to verify that the driver has theappropriate commercial driver license hazardous material endorsements.[6] The carrier is to also notify the designated ENTERGY (EOI / ENOI) representative ofthe name of the driver and any other requested driver identification information, whichwill be used to verify that the appropriate driver has arrived to transport the shipment.[7] Transportation of any of the hazardous materials identified in 49 CFR 172.800 is notto be assigned or subcontracted without the prior written agreement of all parties.NOTESome vendors subcontract carriers to prepare and ship hazardous materials off-site. Forexample, a major maintenance contractor may subcontract an independent transportationcompany to ship hazardous materials from one plant to the next.[8] All contracts OR purchase orders, where applicable, which potentially involvetransportation of the hazardous materials covered in the TSP are to be examined toensure that subcontracted carriers haveAND maintain a TSP acceptable toENTERGY (EOI / ENOI). Consideration is to be given to amending any such contractsto include the preceding language OR to include a restriction similar to the following:"Transportation of any of the hazardous materials identified in 49 CFR 172.800 will notbe assigned or subcontracted without the prior written agreement of all parties."

NUCLEARMANAGEMENTMANUAL N ON-QUALITY RELATED EN-RW-106REV. 4 INFORMATIONAL U SEPage 11 of 46Integrated Transportation Security Plan5.5 continued[9] It is recommended that an affirmation letter on carrier letterhead paper be receivedfrom the carrier prior to awarding any transportation contract or other scheduledcarrier for radioactive and non-radioactive materials. A copy of the affirmation isavailable in Attachment 9.2, "Sample Carrier Affirmation Letter."

5.6 TRAINING[1] Employees involved with processing (including vehicles) and transporting hazardousmaterial must be provided with the following personnel security awareness andtransportation security training modules:Security Awareness TrainingIn-Depth Transportation Security Training module (including specificinformation on the existence of the company's TSP).[2] Both training modules may supplement the existing hazmat employee trainingprogram consistent with the intent of and frequency specified in 49 CFR 172.704. Re-qualification training will be provided at the same frequency as other hazmatemployee training.[3] All new hazardous material employees must receive this training within 90 days ofemployment.[4] Hazmat employees must receive training required by 49 CFR 172.704 at least onceevery three years.[5] Hazmat employees required to have In-Depth Security Training must receive trainingat least once every three yearsOR IF the security plan for which training is required isrevised during the three-year recurrent training cycle,THEN the employee mustreceive training within 90 days of implementation of the revised plan.

NUCLEARMANAGEMENTMANUAL N ON-QUALITY RELATED EN-RW-106REV. 4 INFORMATIONAL U SEPage 12 of 46Integrated Transportation Security Plan5.7 ADDITIONAL SECURITY MEASURES FOR RADIOACTIVE SHIPMENTS -CATEGORY 1 AND CATEGORY 2 QUANTITIES5.7.1 GeneralNOTEThis section is based on the 10 CFR part 37 subpart D final rule, NUREG 2155 Q & A, andNRC response to industry questions.[1] Section 5.7 applies to the following activitiesTransfer and receipt of a category 1 and category 2 quantity of radioactivematerial.Preplanning and coordination of shipments,Physical protection during shipment,Notifications, investigations, and event reporting,[2] Attachments 9.6 through 9.8 of this procedure includes a table of 10 CFR Part 37Subpart D Physical Protection requirement checklists for category 1 and category 2quantity of radioactive material shipments.5.7.2 Transfer of Category 1 and Category 2 Quantities of Radioactive Material 5.7.2.1License Verification[1] Any licensee transferring a category 2 quantity of radioactive material is required toperform and document licensee verification activities based on the quantity of materialbeing transferred. The purpose of the licensee verification is to make sure thetransferee's license is valid and authorized to receive the type, form and quantity ofradioactive material transferred. Use Attachment 9.3, "License Verification SystemCredential Guide" to obtain credentials for using the License Verification System.[2] Except for emergencies, the licensee is required to use the Licensee VerificationSystem (LVS) developed by the NRC or contact the regulatory agency (NRC orAgreement State) to verify that the license is valid before shipping a category 2quantity of radioactive material.

NUCLEARMANAGEMENTMANUAL N ON-QUALITY RELATED EN-RW-106REV. 4 INFORMATIONAL U SEPage 13 of 46Integrated Transportation Security Plan5.7.2.1 continued

[3]IF there exists an emergency where the licensee cannot verify the license of thetransferee by the LVS or regulatory agency, THEN the licensee may accept writtenverification by the transferee that it is authorized to receive the type, form and quantityof radioactive material being transferred. In which case use Attachment 9.4 "ManualLicense Verification Form Guide,"

OR Attachment 9.5, "Manual License VerificationProcedure Guide."[4] The licensee is not required to perform license verification of transfers to theDepartment of Energy, other Federal entities, or transfers within the sameorganization of the licensee. Verification is not required for imports and exports,however the requirements of 10 CFR Part 110, "Export and Import of NuclearEquipment and material," would apply 5.7.2.2 Category 2 Transfer[1] The licensee transferring the category 2 quantity of radioactive material will verify thetransferee is authorized to receive the radioactive material prior to shipment. Thelicensee uses the LVS or direct contact with the applicable regulatory agency.[2] The licensee may not use a fax, email, or a copy of the recipient's license to verify thetransferee is authorized to receive a category 2 quantity of radioactive material. Theverification of each shipment is required and the licensee should document theverification process used (i.e. LVS, regulatory agency contact, or recipient licenseecertification).

[3]IF the licensees rely on the recipient licensee's certification, as permitted in anemergency situation above,AND later discover the recipient's license is not valid,THEN the licensee should contact the LLEA and the NRC's Operation Center if theshipment has been delivered.

5.7.2.3 Category 1 Transfer[1] The licensee transferring a category 1 quantity of radioactive material is required tomeet the same requirements as the transfer of a category 2 quantity of radioactivematerial.[2] In addition to the requirements for transfer for category 2 transfers, verify that thereceiving licensee is authorized to receive radioactive material at the addressrequested for delivery.

NUCLEARMANAGEMENTMANUAL N ON-QUALITY RELATED EN-RW-106REV. 4 INFORMATIONAL U SEPage 14 of 46Integrated Transportation Security Plan5.7.3 Guidance for Physical Protection During TransitNOTESection 5.7.3 addresses the shipping licensee responsibility for implementing 10 CFR Part37 Subpart D requirements for preplanning and coordination and physical protection duringtransit.5.7.3.1Licensee Responsibility[1] The shipping licensee is responsible for meeting the requirements of 10 CFR Part 37Subpart D unless the receiving licensee has agreed in writing to arrange for the in-transit physical protection. The licensee is also responsible for meeting therequirements of Subpart D for category 1 or category 2 quantity of radioactive materialfrom the point that the material enters the United States for import and until thematerial is under the jurisdiction of a U.S. Government agency at a port, bordercrossing, or airport for material exported.[2] The licensee should have a contract with the carrier that obligates the carrier tocomply with the applicable requirements in Subpart D[3] The shipping licensee is responsible for providing physical security of a category 2 orgreater quantity of radioactive material until the carrier accepts the consignment ofradioactive material for shipment and begins movement of the loaded transportvehicle. The shipping licensee's control applies outside of the protective area until thedeparture of the shipment.

5.7.3.2Category 1 Shipment[1] The shipping licensee must conduct preplanning and coordination activities with thereceiving licensee and with each state that the shipment enters. The shipping licenseepreplanning and coordination procedures should address, as a minimum, the followingitems:Shipment contract(s) with a carrier that identify carriers responsibilities forimplementing applicable regulations,Protocol for carrier actions to take if a shipment is rerouted during bad weatheror other unusual event,Shipping licensee should preplan and coordinate the shipments arrival anddeparture time with the receiving licensee,Shipping licensee establish protocol for coordinating and contacting thegovernor of the State or the governor's designee, NUCLEARMANAGEMENTMANUAL N ON-QUALITY RELATED EN-RW-106REV. 4 INFORMATIONAL U SEPage 15 of 46Integrated Transportation Security Plan5.7.3.2[1] continuedShipping licensee works with the States to identify its intention to provideescorts and any additional State-imposed transportation security requirements',Shipping licensee works with the carrier to identify safe haven(s) along theroute at approximately 50 mile intervals, if available,Carrier coordination with State escorts if applicable.[2] The licensee maintains documentation of the above activities as attachments to theshipping package.[3] A licensee that transports, or delivers to a carrier for transport in a single shipment byroad, a category 1 quantity of radioactive material should address the following items,as a minimum:(a) Licensee establishes or uses a carrier that has established movement controlcenters (MCC). The MCC should:Monitor shipments on a continuous basis 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months a day, 7 days aweek,Maintain the ability to immediately communicate with LLEA in anemergency,Provide positive confirmation of the location of the shipment, its status,individuals in control of the shipment,Develop and implement preplanned procedures in response todeviations from the authorized route (s), ORProvide notification of actual or attempted theft or diversion or suspiciousactivity related to the theft, loss, or diversion of a shipment,Immediately awareness if a shipment deviates from shipping plans,planned route, unscheduled stops, or scheduled stops longer thanexpected,Redundant communications consisting of two systems that do not relyon the same hardware or software to transmit a signal,The use of telemetric monitoring system to permit the remote monitoringand reporting of the location of a transport vehicle or package, NUCLEARMANAGEMENTMANUAL N ON-QUALITY RELATED EN-RW-106REV. 4 INFORMATIONAL U SEPage 16 of 46Integrated Transportation Security Plan5.3.7.2[3](a) continuedEnsure carrier provides a second individual when the driving time periodis greater than the maximum number of allowable hours of service in a24-hour duty day as established by the DOT,The driver or accompanying individual or both perform the following:Periodically call the MCC to provide verbal status of the shipmentand delivery,Maintain vigilance of the surrounding environment duringtransport,Maintain constant visual surveillance when transport vehicle is stopped,Periodically walk around vehicle while it is not in motion, toconfirm no apparent safety or security related issues,Confirm no evidence of tampering with the contents of the vehicleor no unusual or suspicious activity in the immediate vicinity.Normal operating procedures address activities to meet regulatoryrequirements:Refueling and comfort stops,Meal stops, andRoutine check-in.(b) Contingency procedures address issues that could interfere with complianceduring preparation for transport or during transport:Bad weather,Suspicious activities,Mechanical breakdown,Road or bridge closures, detours, accidents, orAcute illness.

NUCLEARMANAGEMENTMANUAL N ON-QUALITY RELATED EN-RW-106REV. 4 INFORMATIONAL U SEPage 17 of 46Integrated Transportation Security Plan5.3.7.2[3](b) continuedCommunication protocol for:Duress codes to enable off-site individual to signal the need for assistance,Authentication codes to confirm the true identity of the employee,Loss of communication actions to take.(c) Licensee ensures access to normal and contingency procedures by drivers,accompanying personnel, and MCC personnel.

5.7.3.3Category 2 Shipment[1] A licensee that transports, or delivers to a carrier for transport in a single shipment byroad, a category 2 quantity of radioactive material should include the following itemsas a minimum in its preplanning and coordination process:Coordinate the expected arrival time and the no-later-than (NLT) arrival time,and the method of notification of receipt of shipment with the receiving licensee.Shipping licensee initiates investigation if shipment has not arrived by morethan 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months past NLTThe receiving licensee confirms to the shipping licensee that the shipment hasarrived by phone, e-mail, or facsimile as agreed in the preplanning andcoordination activities.Shipping licensee notifies the receiving licensee of any new NLT arrival time assoon as practicable after the driver or authorized member of the transfer crewdetermines the category 2 shipment cannot arrive before the NLT arrival time.[2] A licensee that transports category 2 quantity of radioactive material should addressthe following items, as a minimum:Establishment of a security zone around the radioactive material, the use of thetransport vehicle is permitted, [37.47(a)]Limit access to the security zone to authorized individuals, [37.47(c)]Monitor, detect, assess, and respond to any unauthorized access, [37.49]

NUCLEARMANAGEMENTMANUAL N ON-QUALITY RELATED EN-RW-106REV. 4 INFORMATIONAL U SEPage 18 of 46Integrated Transportation Security Plan5.7.3.3 continued[3] A licensee that transports, or delivers to a carrier for transport in a single shipment byroad, a category 2 quantity of radioactive material should address the following items,as a minimum:The use of carriers with an established, documented package tracking systemthat allows shipping licensee to see the chain of custody for the package andwho is accountable at each stage of the trip,The shipping licensee or carrier can promptly determine if the shipment is lostor missing,The tracking system requires an authorized signature (receiving licenseesemployee or contractor) before release for delivery or return,Licensee's carrier maintains constant control and surveillance during transitwith capability to immediately summon response by an armed LLEA, trainedemergency services personnel to prevent or mitigate any collateral impacts of asafety event, or immediately requests assistance for emergency or urgentconditions to avoid or minimize unplanned delay of shipment.Immediate communication to summon response or assistance may be met withcell or satellite phones and two-way radios. No backup communication systemis required.The licensee's carrier maintains a package-tracking system with a reliable on-demand capability to ascertain the last location and current status of theshipment.[4] A licensee who transports, or delivers to a carrier for transport in a single shipment byrail, a category 2 quantity of radioactive material should address the following items,as a minimum:The use of a carrier with a documented, proven, and reliable tracking system,The capability to allow the shipping licensee or carrier to identify when andwhere package was when the train last reported, and when it will arrive at thenext point of control,The carrier maintains constant control and surveillance during transit and hasthe capability for immediately communication to summon an appropriateresponse or assistance, NUCLEARMANAGEMENTMANUAL N ON-QUALITY RELATED EN-RW-106REV. 4 INFORMATIONAL U SEPage 19 of 46Integrated Transportation Security Plan5.7.3.3[4] continuedImmediate communication to summon response or assistance may be met withcell or satellite phones, and two-way radios. No backup communication systemis required,The tracking system requires an authorized signature (receiving licensees'employee or contractor) before release for delivery or return.5.7.4 Advance Notification of Shipment of Category 1 5.7.4.1Advance Notification[1] The shipping licensee provides advance notification to the NRC and the governor of aState or the governor's designee in writing and postmarked 7 days before theshipment begins.[2] Notifications by fax or email are required 4 days before transport within or through the state.[3] The shipping licensee should confirm the notification by fax or its intended recipientreceives email. The preferred notification method to the NRC is by email to RAMQCSHIPMENTS@nrc.gov or by fax to 301-816-5151. The contact information ofgovernors and governor's designee is available on the NRC Web site at http://nrc-stp.ornl.gov/special/designee.pdf[4] The following is a summary of the information to be furnished in an AdvanceNotification of Shipment:The name, address, and telephone number of the shipper, carrier, and receiverof the category 1 radioactive material,The license numbers of the shipper and receiver,A description of the radioactive material contained in the shipment, includingthe radionuclides and quantity,The point of origin of the shipment and the estimated time and date that theshipment will commence,The estimated time and date that the shipment is expected to enter each Statealong the route,The estimated time and date of arrival of the shipment at the destination,A point of contact, with a telephone number, for current shipment information.

NUCLEARMANAGEMENTMANUAL N ON-QUALITY RELATED EN-RW-106REV. 4 INFORMATIONAL U SEPage 20 of 46Integrated Transportation Security Plan5.7.4.1 continued[5] The licensee is expected to include all of the above information when it makes theinitial advance notification. Any missing information is required to be provided beforecommencement of the shipment.

5.7.4.2Updating Advance Notification[1] The shipping licensee is required to provide a revision notice with any information thatwas not available when the initial notification was submitted.[2] The shipping licensee is required to notify any affected State's governor or designeeas soon as it discovers or is advised of the following changes in the shipment:A change is made to the description of the radioactive material radionuclides orquantities,A change is made in the shipment's point of origin or estimated time or date ofcommencement,A change of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months or more is made in the estimated time or date that theshipment is expected to enter each State along the route,A change of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months or more is made in the estimated time or date of arrival ofthe shipment at the destination,A change is made in the name or telephone number of the point of contact forcurrent shipment information.[3] The driver or other authorized member of the transfer crew is to make notification ofany changes in shipment information en route as soon as the change is determined.

[4]IF the shipment is canceled,THEN the shipping licensee is required to notify theStates to which advance notification was providedAND the NRC, OR AgreementState agency with jurisdiction in the State of origin. The licensee is required to send acancellation notice via email, facsimile, or written correspondence as soon aspossible. A telephone call may be necessary to ensure timely receipt of the notice toprovide a State time to cancel any planned escorts.

NUCLEARMANAGEMENTMANUAL N ON-QUALITY RELATED EN-RW-106REV. 4 INFORMATIONAL U SEPage 21 of 46Integrated Transportation Security Plan5.7.5 Reporting of Events 5.7.5.1Shipment Investigations

[1]IF the licensee asks for a status of its shipment,AND the carrier's telemetricmonitoring system or railroad's communications center cannot tell where the shipmentis within a few minutesAND the shipping licensee is not confident that the trackingand communication system are functioning normally,THEN the licensee shouldconsider the shipment lost or missing[2] The shipping licensee must investigate immediately if a category 1 quantity shipmentis lost or missing.[3] The investigation of the lost or missing category 1 quantity shipment should include asa minimum the following actions:Determine the time and location of the last transport crew check-in.Determine where communication was lost.Determine where tracking was lost.Confirm that the equipment is working properly.Contact the escort if one was being used.[4] The shipping licensee must investigate immediately if a category 2 quantity shipmentdoes not arrive by the NLT arrival time based on the receiving licensee notification.[5] The investigation of the lost or missing category 2 quantity shipments should includeas a minimum the following actions:Determine the shipment's last known location from carrier.Determine the shipment's current location.

[6]IF the carrier cannot determine the location of the shipment,THEN the shippinglicensee notifies the NRC Operations Center that a category 2 quantity shipment islost or missing[7] Contact the NRC Operations Center if the shipment is still missing after 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ofthe initial notification.

NUCLEARMANAGEMENTMANUAL N ON-QUALITY RELATED EN-RW-106REV. 4 INFORMATIONAL U SEPage 22 of 46Integrated Transportation Security Plan 5.7.5.2Category 1 Notifications[1] The shipping licensee must make the following notifications after determining ashipment of category 1 quantities of radioactive material is lost or missing:Notify the LLEA as soon as the carrier has completed its first unsuccessfulattempt to locate the material and confirmed its inability to trace it was not aresult of human error, or a malfunction of the position monitoring system,Notify the NRC Operations Center within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after determining the category1 shipment is lost or missing. Discuss with the NRC the expected frequency of updates,Notify the NRC and the LLEA as soon as possible when the lost or missinglicensed material is again in the physical possession of, or in a locationotherwise under the control of the carrier, shipping, or recipient licensee,authorized State or Federal agency, or an LLEA that is able to prevent or deterunauthorized access to the material.[2] The shipping licensee must make the following notifications as soon as possible upondiscovery of any actual or attempted theft, or diversion of a shipment, or suspiciousactivities related to the theft or diversion of a shipment of a category 1 quantity ofmaterial:Notify the designated LLEA along the shipment route as soon as possible,ANDNotify the NRC Operations Center (301-816-5100). The NRC will notify otheraffected States and Federal partners as appropriate.[3] The Transportation Security Administration (TSA) has guidance for private or contractcarrier employees that list a number of activities that may be considered suspicious.[4] A written report is required to be submitted to the NRC within 30 days of the shippinglicensee's initial telephonic notifications that a shipment of category 1 material is lostor missing, or telephonic notification of actual, or attempted theft or diversion of ashipment of category 1 material.

NUCLEARMANAGEMENTMANUAL N ON-QUALITY RELATED EN-RW-106REV. 4 INFORMATIONAL U SEPage 23 of 46Integrated Transportation Security Plan5.7.5.2 continued[5] The written report is provided to the Director, Division of Security Policy, Office ofNuclear Security and Incident Response and must provide the following information:A description of the licensed material involved, including kind, quantity, andchemical and physical form;A description of the circumstances under which the loss or theft occurred;A statement of disposition, or probable disposition, of the licensed materialinvolved;Actions that have been taken, or will be taken to recover the material;Procedures or measures that have been, or will be, adopted to ensure againsta recurrence of the loss or theft of licensed material.[6] After filing the written report, if the shipping licensee gathers any information notpreviously reported to the NRC, such as findings from a completed investigation of theloss or theft of category 1 material, the licensee has to report that additionalinformation within 30 days.[7] A Condition Report will be initiated to document any actual or attempted theft ordiversion of a shipment or any suspicious activity related to a shipment of category 1quantities of radioactive material.

5.7.5.3Category 2 Notifications[1] The shipping licensee is required to notify the NRC Operations Center within 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months sof its determining a shipment of category 2 quantities of radioactive material is lost ormissing. If after 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from its determination the licensee still cannot locate thematerial, the NRC operations Center must be notified again.[2] The shipping licensee is also required to notify the NRC Operations Center as soon aspossible after discovery of an actual or attempted theft or diversion of a category 2quantity shipment or any suspicious activity related to a shipment.[3] The shipping licensee is required to notify the NRC Operations Center when a lost ormissing shipment of category 2 quantities of radioactive material has been located.[4] A written report is required to be submitted to the NRC within 30 days of the shippinglicensee initial telephonic notifications that a shipment of category 2 material is lost ormissing or telephonic notification of actual or attempted theft or diversion of ashipment of category 1 material.

NUCLEARMANAGEMENTMANUAL N ON-QUALITY RELATED EN-RW-106REV. 4 INFORMATIONAL U SEPage 24 of 46Integrated Transportation Security Plan5.7.5.3 continued[5] After filing the written report, if the shipping licensee gathers any information notpreviously reported to the NRC, such as findings from a completed investigation of theloss or theft of category 2 materials, the licensee has to report that additionalinformation to the NRC within 30 days.[6] A Condition Report will be initiated to document any actual or attempted theft ordiversion of a shipment or any suspicious activity related to a shipment of category 2quantities of radioactive material.

5.7.6 Records 5.7.6.1Documentation[1] The records that result from the activities in this procedure are to be retained aminimum of three years as required but typically through the life of the nuclear powerplant's license.[2] The following records are generated as a result of implementing this section:Licensee verification documentationDocumentation for preplanning and coordination, and any revisionAdvance notification and any revision and cancellation noticesWritten reports and additional substantive information[3] Records resulting from the activities in this procedure are to be retained with recordsgenerated by EN-RW-102, "Radioactive Shipping Procedure."

5.7.6.2Protection of Information[1] The information to be furnished in advance notification of category 1 quantities ofradioactive material shipment shall be protected against unauthorized disclosure asspecified in 10 CFR 73.21 Protection of Safeguards Information: Performancerequirements. The schedule information specified in 37.77(b) is provided to Stateofficials, State employees, and other individuals that are not licensees of the NRC oran Agreement State.[2] The governor of a State or his or her designated State employee representative,Federal, State, or local law enforcement personnel are relieved from the fingerprinting,identification, and criminal history records checks, and other elements of backgroundinvestigations and are permitted access to the category 1 shipping information.

NUCLEARMANAGEMENTMANUAL N ON-QUALITY RELATED EN-RW-106REV. 4 INFORMATIONAL U SEPage 25 of 46Integrated Transportation Security Plan5.7.6.2 continued[3] A licensee that plans to transport or deliver to a carrier for transport, licensed materialthat is a category 1 quantity of radioactive material will only use carriers that certifythey have an access authorization program that meets the requirements of 10 CFR73.21 and 10 CFR 73.23. The carrier must include in the access authorizationprogram the vehicle drivers, accompanying individuals, movement control centerpersonnel, and any individual whose assigned duties provide access to shipmentinformation on category 1 quantities of radioactive material.[4] The shipment of category 2 quantities of radioactive material does not require thecommercial drivers and package handlers to meet the access authorization programrequirements since these individuals are subject to DOT security requirements.5.8 TYPES OF HAZMAT SHIPMENTS ADDRESSED BY THE ENTERGY (EOI / ENOI)TSP-RA[1] Specifically for Nuclear Power Reactors, this transportation security plan (TSP)applies to:(a) Radioactive laundry shipments,(b) Some shipments of low-level radioactive waste (dry active waste) to offsite processors,(c) Some shipments of radioactive vendor equipment offsite, and(d) Shipments of processed radioactive waste and reactor hardware for offsitedisposal.NOTEFor Highway Route Controlled Quantity shipments of radioactive materials, the shipper mustrefer to the NRC Physical Security Plan along with the Additional Security Measures forRadioactive Shipments - Category 1 and Category 2 Quantities (Section 5.7 of thisprocedure).[2] A highway route-controlled quantity of a Class 7 (radioactive) material, as defined inPart 173.403 of this subchapter, in a motor vehicle, rail car, or freight container;[3] More than 25 kg (55 pounds) of a Division 1.1, 1.2, or 1.3 (explosive) material in amotor vehicle, rail car, or freight container;[4] More than one L (1.06 qt) per package of a material poisonous by inhalation, asdefined in Part 171.8 of this subchapter, that meets the criteria for Hazard Zone A, asspecified in § 173.116(a)or 173.133(a) of this subchapter; NUCLEARMANAGEMENTMANUAL N ON-QUALITY RELATED EN-RW-106REV. 4 INFORMATIONAL U SEPage 26 of 46Integrated Transportation Security Plan5.8 continued[5] A shipment of a quantity of hazardous materials in bulk packaging having a capacityequal to or greater than 13,248 L (3,500 gallons) for liquids or gases or more than13.24 cubic meters (468 cubic feet) for solids;[6] A shipment in other than a bulk packaging of 2,268 kg (5,000 pounds) gross weight ormore of one class of hazardous materials for which placarding of a vehicle, rail car, orfreight container is required for that class under the provisions of subpart F of this part;[7] A select agent or toxin regulated by the Centers for Disease Control and Preventionunder 42 CFR part 73; or[8] A quantity of hazardous material that requires placarding under the provisions ofsubpart F of this part.5.9 INFORMATION[1] Attachment 9.1 provides all associated tables that are applicable to the ENTERGY(EOI / ENOI) Risk Assessment.6.0 INTERFACES[1] EN-RW-102, "Radioactive Shipping Procedure" NUCLEARMANAGEMENTMANUAL N ON-QUALITY RELATED EN-RW-106REV. 4 INFORMATIONAL U SEPage 27 of 46Integrated Transportation Security Plan 7.0 RECORDSNOTERecords resulting from the activities in this procedure are retained with records generated byEN-RW-102, "Radioactive Shipping Procedure."[1] Licensee verification documentation[2] Documentation for preplanning and coordination, and any revision[3] Advance notification and any revision and cancellation notices[4] Written reports and additional substantive information[5] Attachment 9.6, "10 CFR37 Subpart D Category 1 Physical Protection Requirement Checklist"[6] Attachment 9.7, "10 CFR37 Subpart D Category 2 Physical Protection Requirement Checklist"[7] Attachment 9.8, "10 CFR 37 Subpart D Category 1 Quantities of Concern StateCoordination Log"8.0 SITE SPECIFIC COMMITMENTS None9.0 ATTACHMENTS9.1 TSP-RA Tables9.2 Sample Carrier Affirmation Letter9.3 License Verification System Credential Guide9.4 Manual License Verification Form Guide9.5 Manual License Verification Procedure Guide9.6 10 CFR 37 Subpart D Category 1 Physical Protection Requirement Checklist9.7 10 CFR 37 Subpart D Category 2 Physical Protection Requirement Checklist9.8 10 CFR 37 Subpart D Category 1 Quantities of Concern State Coordination Log NUCLEARMANAGEMENTMANUAL N ON-QUALITY RELATED EN-RW-106REV. 4 INFORMATIONAL U SEPage 28 of 46Integrated Transportation Security Plan ATTACHMENT9.1TSP-RATABLESSheet 1 of 6[33 CFR 105.400]TABLE 1Typical Radioactive and Hazardous Materials ShipmentsRADIOACTIVE MATERIALS SHIPMENTSTYPES OF MATERIALS SHIPPEDTYPICAL MATERIALS IN SHIPMENTRadioactive Material Category 1 and Category 2 asdefined in Attachment 9.1, Table 4, "Category 1 andCategory 2 Threshold".Examples include, but are not limited to: certain radioactivecalibration sources, ion-exchange resin, certain activated reactorcomponents and limited amounts of irradiated reactor fuel.Highway route controlled quantities (HRCQ) ofradioactive material.Highly irradiated reactor components; some Greater Than ClassC (GTCC) wastes.Shipment of Type B quantities of radioactive materialsin an NRC-approved shipping container.High activity resin, filters, and irradiated reactor components,such as control rod blades and velocity limiters.Shipment of radioactive materials in bulk packaging of3,500 gallons or more for liquids or 468 cubic feet ormore for solids.Radioactively contaminated oil or aqueous liquids; routine sea-land and inter-modal containers of dry active waste.Shipment in other than bulk packaging of 5,000pounds or more of radioactive materials that isrequired to be placarded.Most shipments made in Type A or Type B casks.A quantity of radioactive material that requiresplacarding.Most radioactive waste shipments, laundry shipments, vendorequipment shipments.HAZARDOUS MATERIALS SHIPMENTSTYPES OF MATERIALS SHIPPEDTYPICAL MATERIALS IN SHIPMENTA quantity of hazardous materials in a bulk packaginghaving a capacity equal to or greater than 3500 gallons(13,248 liters) for liquids or gases or more than 468 ft 3 (13.24 m 3) for solids.Most shipments of diesel fuel, used oil,acids, caustics, sodiumhypochlorite, and similar hazmat.A quantity of hazardous material that requiresplacarding.Most shipments of hazardous waste (such as paint waste, partscleaning solutions, and lab packs), liquid and solid mixed waste,PCB waste, asbestos and waste water treatment chemicals.

NUCLEARMANAGEMENTMANUAL N ON-QUALITY RELATED EN-RW-106REV. 4 INFORMATIONAL U SEPage 29 of 46Integrated Transportation Security Plan ATTACHMENT9.1TSP-RATABLESSheet 2 of 6TABLE 2Hazmat Carriers, Types of Hazmat Shipments, and Quantities Shipped CARRIERCATEGORYTYPICAL MATERIALSTRANSPORTED BY THISCARRIER CATEGORYMAXIMUM QUANTITIESPER SHIPMENTLaundry services suppliers1. Radioactive laundry2. Low activity DAWCo-60 = < 1 CiCs-137 = < 1 CiPlant maintenance equipmentand services suppliers (includingtheir subcontracted Carriers)1. Low activity radioactive materialCo-60 = < 8.1 CiCs-137 = < 10 CiWaste processors

, and otherwaste Carriers and HazmatCarriers1. Radioactive materials and waste2. Reactor components and otherirradiated hardware3. Vendor equipment4. Hazardous waste5. Mixed waste6. PCB waste 7. Asbestos wasteHRCQ, excluding spentfuel (rarely)RAMQC (rarely)Type A and Type BLSA/SCOBulk and/or placardedhazmatCommon carrier (FederalExpress, UPS)Radioactive sourcesCould be Category 1 or 2EntergyRadioactive material/specialtools/sourcesCould be Category 1 or 2 NUCLEARMANAGEMENTMANUAL N ON-QUALITY RELATED EN-RW-106REV. 4 INFORMATIONAL U SEPage 30 of 46Integrated Transportation Security Plan ATTACHMENT9.1TSP-RATABLESSheet 3 of 6TABLE 3Determination of Hazardous Materials of Significance to This Assessment (a)HazardClass (b)HazardClassDivisionOf Concern (c)(c)GeneralDescriptionof SignificantHazard or Class (d)Typical Materials Shipped in this Hazard ClassDivision by these Facilities and Discussion ofRelative Significance (e)Significanceto This RiskAssessment 11.1, 1.2,1.3ExplosivesNo significant quantity of explosives are shippedby these facilities.

None 22.3Poison Gas(inhalation hazard)Anhydrous ammonia gas, chlorine gas.High 3 NoneFlammable (liquids) Diesel fuel, gasoline, paint, solvents. Thesematerials are relatively low toxicity (i.e., are notacutely toxic; do not contain lethal concentrationsor doses).

Low 44.3Dangerous WhenWetSodium. No significant quantities of suchmaterials are shipped by these facilities.(Significant quantities may be shipped bysodium-moderated reactors if any are included inthe facility listing in Section 1.1. Significancewould be Low.)

None 55.2Organic Peroxide,Type B (may beliquid or solid andare thermallycontrolled)Type B organic peroxides can undergo a thermalexplosion. As a genera; rule, they are notshipped by any of these facilities. In the event ashipment becomes necessary, the shipment ispre-approved in writing by the DOT AssociateAdministrator and is shipped in accordance withthe instructions provided by the AssociateAdministrator.

None 66.1Poison InhalationHazard (liquidpoisons)Hydrazine and most other hazmat in this divisionare not Hazard Zone A or B (Package Group I)and are, therefore, notHighsignificance.)Note: some plants may still have stabilizedacrolein on site, which would beHighsignificance.)Medium 8 NoneCorrosivesAcids, caustics. These materials are relativelylow toxicity (i.e., are not acutely toxic; do notcontain lethal concentrations or doses).

Low 9 NoneMiscellaneousHazardous waste, solid, n.o.s.; Hazardouswaste, liquid, n.o.s.; asbestos; PCBs. Thesematerials are relatively low toxicity (i.e., are notacutely toxic; do not contain lethal concentrationsor doses).

Low NUCLEARMANAGEMENTMANUAL N ON-QUALITY RELATED EN-RW-106REV. 4 INFORMATIONAL U SEPage 31 of 46Integrated Transportation Security Plan ATTACHMENT9.1TSP-RATABLESSheet 4 of 6TABLE 4Category 1 and Category 2 ThresholdThe terabecquerel (TBq) values are the regulatory standard. The curie (Ci) values specifiedare obtained by converting from the TBq value. The curie values are provided for practicalusefulness only.Radioactive materialCategory 1(TBq)Category 1 (Ci)Category 2(TBq)Category 2 (Ci)Americium-241 60 1,620 0.6 16.2Americium-241/Be 60 1,620 0.6 16.2Californium-252 20 540 0.2 5.40 Cobalt-60 30 810 0.3 8.10Curium-244 50 1,350 0.5 13.5Cesium-137 100 2,700 1 27.0Gadolinium-153 1,000 27,000 10 270Iridium-192 80 2,160 0.8 21.6Plutonium-238 60 1,620 0.6 16.2Plutonium-239/Be 60 1,620 0.6 16.2Promethium-147 40,0001,080,000 400 10,800Radium-226 40 1,080 0.4 10.8Selenium-75 200 5,400 2 54.0Strontium-90 1,000 27,000 10 270Thulium-170 20,000 540,000 200 5,400Ytterbium-169 300 8,100 3 81.0Continued on next page NUCLEARMANAGEMENTMANUAL N ON-QUALITY RELATED EN-RW-106REV. 4 INFORMATIONAL U SEPage 32 of 46Integrated Transportation Security Plan ATTACHMENT9.1TSP-RATABLESSheet 5 of 6 Note:Calculations Concerning Multiple Sources or Multiple RadionuclidesThe "sum of fractions" methodology for evaluating combinations of multiple sources ormultiple radionuclides is to be used in determining whether a location meets or exceeds thethreshold and is thus subject to the requirements of this procedure.I. If multiple sources of the same radionuclide and/or multiple radionuclides are aggregatedat a location, the sum of the ratios of the total activity of each of the radionuclides must bedetermined to verify whether the activity at the location is less than the category 1 orcategory 2 thresholds of Table 4, as appropriate. If the calculated sum of the ratios, using theequation below, is greater than or equal to 1.0, then the applicable requirements of this part apply.II. First determine the total activity for each radionuclide from Table 4. This is done by addingthe activity of each individual source, material in any device, and any loose or bulk materialthat contains the radionuclide. Then use the equation below to calculate the sum of the ratiosby inserting the total activity of the applicable radionuclides from Table 4 in the numerator ofthe equation and the corresponding threshold activity from Table 4 in the denominator of theequation.Calculations must be performed in metric values (i.e., TBq) and the numerator anddenominator values must be in the same units.

R 1 = total activity for radionuclide 1 R 2 = total activity for radionuclide 2 R N = total activity for radionuclide n AR 1 = activity threshold for radionuclide 1 AR 2 = activity threshold for radionuclide 2 AR N = activity threshold for radionuclide n NUCLEARMANAGEMENTMANUAL N ON-QUALITY RELATED EN-RW-106REV. 4 INFORMATIONAL U SEPage 33 of 46Integrated Transportation Security Plan ATTACHMENT9.1TSP-RATABLESSheet 6 of 6TABLE 5Hazardous Materials of Significant Concern Shipped From FacilitiesHazard Class DivisionOf ConcernGeneral Descriptionof SignificantHazard or ClassTypical Materials Shipped in this Hazard Class Division bythese Facilities and Discussion of Relative Significance 2.3Poison Gas(inhalation hazard)Anhydrous ammonia gas, chlorine gas.

NUCLEARMANAGEMENTMANUAL N ON-QUALITY RELATED EN-RW-106REV. 4 INFORMATIONAL U SEPage 34 of 46Integrated Transportation Security Plan ATTACHMENT9.2 SAMPLE CARRIER AFFIRMATION LETTERSheet 1 of 1EXAMPLE: Date:To: Entergy (EOI / ENOI)(Appropriate Site Address)

Subject:

Carrier Hazardous Material Transportation Security Plan(Carrier Company Name) affirms that we have a Hazardous Material Transportation SecurityPlan in place which meets all applicable Federal and International transportation securityregulations in effect as of the contract or contract amendment date, and that saidTransportation Security Plan will be updated in a timely manner to remain current withrevised and new Federal and International transportation security regulations. We furtheraffirm that our Transportation Security Plan fully implements the regulations for commercialdriver licenses hazardous material endorsements.Our Transportation Security Plan will be made available for review and approval by anauthorized representative of ENTERGY (EOI / ENOI) NS if requested and on reasonableverbal or written notice, with due consideration given to document security and control. Weunderstand that we will not mail, send, or otherwise transmit any confidential documents toENTERGY (EOI / ENOI).Prior to dispatching any driver to an ENTERGY (EOI / ENOI) facility for the purposes oftransporting hazardous material, we will verify that the driver has the appropriate commercialdriver license hazardous material endorsements. We also agree to notify a designatedENTERGY (EOI / ENOI) representative of the name of the driver and any other requesteddriver identification information, which will be used to verify that the appropriate driver hasarrived to transport the shipment.It is further agreed that transportation of any of the hazardous materials identified in 49 CFR172.800 will not be assigned or subcontracted without the prior written agreement of all parties.Authorized Carrier Representative Signature Block NUCLEARMANAGEMENTMANUAL N ON-QUALITY RELATED EN-RW-106REV. 4 INFORMATIONAL U SEPage 35 of 46Integrated Transportation Security Plan ATTACHMENT9.3 LICENSE VERIFICATION SYSTEM CREDENTIAL GUIDESheet 1 of 1NOTEThe purpose of this guide is to aid individuals in getting credentialed for using the NRCLicense Verification System (LVS).The NRC LVS web site provides an on-line User Guide.[1] Using a web browser, go to http://www.nrc.gov.[2] Click on "Nuclear Security" tab.[3] Click on the "Radioactive Material Security" bulleted item.[4] Click on "License Verification System (LVS)" under "NRC Activities for RadioactiveMaterial Security."[5] Click on "Get credentialed for LVS." A public Disclosure of Submitted Information will appear.IF you want to continue with getting your LVS Credentialed,THEN click on "IACCEPT."[6] After you mouse click on I ACCEPT, the Web Page Portfolio Enrollment Module willappear. Fill out all the information requested from the Portfolio Enrollment RequestForm. Once all the required information blocks are filled out, mouse click on Submit atthe lower right corner of the request form.

NUCLEARMANAGEMENTMANUAL N ON-QUALITY RELATED EN-RW-106REV. 4 INFORMATIONAL U SEPage 36 of 46Integrated Transportation Security Plan ATTACHMENT9.4 MANUAL LICENSE VERIFICATION FORM GUIDESheet 1 of 2[1] Using a web browser, go to http://www.nrc.gov.[2] Click on "Nuclear Security" tab.[3] Click on "Radioactive Material Security" bulleted item.[4] Click on "License Verification System (LVS)" under "NRC Activities for RadioactiveMaterial Security."[5] Click on "Manual License Verification Form." A PDF document similar to the followingshould display.

NUCLEARMANAGEMENTMANUAL N ON-QUALITY RELATED EN-RW-106REV. 4 INFORMATIONAL U SEPage 37 of 46Integrated Transportation Security Plan ATTACHMENT9.4 MANUAL LICENSE VERIFICATION FORM GUIDESheet 2 of 2[6] Save the form in PDF format.NOTEAt this time the green "Submit by E-mail" button on the form does not work.

[7]WHEN completed,THEN email the form to LVSHelp.Resource@nrc.gov.

NUCLEARMANAGEMENTMANUAL N ON-QUALITY RELATED EN-RW-106REV. 4 INFORMATIONAL U SEPage 38 of 46Integrated Transportation Security Plan ATTACHMENT9.5 MANUAL LICENSE VERIFICATION PROCEDURE GUIDESheet 1 of 2Manual License VerificationNOTEThe purpose of this attachment is to guide licensees transferring Category 1 and/or Category2 quantities of radioactive materials in verifying licenses outside of the License VerificationSystem (LVS).Steps for Licensees[1] Contact the LVS Help Desk by phone at 1-877-671-6787 or by email atLVSHelp.Resource@nrc.gov.[2] Be prepared to provide the following information to the LVS Help Desk representative.(a) Transferring licensee information:License-issuing agencyLicensee nameLicense numberContact name and titleContact phoneContact emailContact fax number(b) Receiving licensee information:License-issuing agencyLicensee nameLicense numberAmendment number or license issue dateAuthorized storage location addressMaterial(s) being requestedChemical/Physical form of the material(s) being requestedQuantity/Activity being requested NUCLEARMANAGEMENTMANUAL N ON-QUALITY RELATED EN-RW-106REV. 4 INFORMATIONAL U SEPage 39 of 46Integrated Transportation Security Plan ATTACHMENT9.5 MANUAL LICENSE VERIFICATION GUIDESheet 2 of 2[3] The transferring licensee will receive notification from the LVS Help Desk of theverification outcome as soon as the verification is complete by the license issuingregulatory agency.[4] The verification outcome will include a notification of whether:(a) The requested materials, quantities, and authorized location are authorized onthe license, OR(b) The requested materials, quantities, and/or authorized location are NOTauthorized on the license, OR(c) Other reason (with an explanation)[5] The licenseemust keep a copy of the verification outcome sent by the LVS HelpDesk for their records in accordance with the 10 CFR Part 37 requirements forkeeping records of license verifications.

NUCLEARMANAGEMENTMANUAL N ON-QUALITY RELATED EN-RW-106REV. 4 INFORMATIONAL U SEPage 40 of 46Integrated Transportation Security Plan ATTACHMENT9.610CFR37SUBPART DCATEGORY 1PHYSICAL PROTECTION REQUIREMENT CHECKLISTSheet 1 of 4Shipment Number: _______________________[1] Verify the recipient is authorized to receive the type, form and quantity of material perNRC's License Verification System OR License Issuing Authority in accordance with 10 CFR 37.71(initials)[2] Verify the delivery address matches the location authorized in the recipient's license.(initials)[3] Attach documentation of license verification.(initials)

[4]IF shipping to a licensee in an agreement state,THEN obtain written verification oflicensee compliance with physical security requirements for Category 1 quantities ofradioactive materials in accordance with 10 CFR 37. Attach verificationdocumentation.(initials)[5] Pre-plan and coordinate shipment arrival and departure times with receiving licensee.Planned departure date and time: _________________________________Planned arrival date and time: __________________________________(initials)

NUCLEARMANAGEMENTMANUAL N ON-QUALITY RELATED EN-RW-106REV. 4 INFORMATIONAL U SEPage 41 of 46Integrated Transportation Security Plan ATTACHMENT9.610CFR37SUBPART DCATEGORY 1PHYSICAL PROTECTION REQUIREMENT CHECKLISTSheet 2 of 4[6] Provide advance notification to the NRC prior to transport per 10 CFR 37.77.Notification by mail must be postmarked at least seven (7) days prior tocommencement of transport. Other means of notification must reach NRC at leastfour (4) days prior to shipment commencement.Information required in notification.

IF information is not available at the time ofshipment,THEN provide the information as soon as possible, but before commencingshipment. Name, address, telephone number, and license number of shipper. Name, address, and telephone number of carrier. Name, address, telephone number, and license number of the recipient. Description of radioactive material, including radionuclides and quantities. Point of origin and estimated date and time shipment will commence. Estimated date and time shipment expected to enter each state along route. Estimated date and time of arrival Point of contact and telephone number to obtain current shipment informationDate and time of notification: ____________________(initials)[7] Pre-plan and coordinate shipment information with the Governor, or designee, of anystate through which the shipment will pass, including the State's intentions to providelaw enforcement escorts and identification of safe havens. Use attachment 9.8,"Category 1 Quantities of Concern State Coordination Log," or equivalent, todocument coordination activities.

IF coordination was performed carrier or recipient,attach copy of documentation.(initials)[8] Notify each state Governor or designee immediately of any changes or cancellation.Attach documentation of notification.(initials)

NUCLEARMANAGEMENTMANUAL N ON-QUALITY RELATED EN-RW-106REV. 4 INFORMATIONAL U SEPage 42 of 46Integrated Transportation Security Plan ATTACHMENT9.610CFR37SUBPART DCATEGORY 1PHYSICAL PROTECTION REQUIREMENT CHECKLISTSheet 3 of 4[9] Verify the carrier meets the requirements for physical protection of Category 1quantities of radioactive material during shipments by road per 10 CFR 37.79(a).(initials)

[10]IF provided,THEN attach carrier verification of 10 CFR 37 compliance.(initials)[11] Verify normal and emergency contingency procedures addressing the following areavailable to drivers, accompanying personnel AND the movement control center. Notification to communications center and law enforcement agencies Communication protocols that include a strategy for authentication and duresscodes and provisions for refueling or other stops. Loss of communications Response to actual or attempted theft or diversion of shipment(initials)[12] Verify movement control center(s) established to maintain position information from aremote location comply with the following: The center has the ability to immediately contact appropriate law enforcementagencies. The center has redundant communications with transport or escort vehicle. The center continuously and actively monitors shipment by telemetric positionmonitoring, or alternative tracking system, twenty-four hours a day, seven days aweek. The center is prepared to implement pre-planned procedures in response todeviations from authorized route or notification of suspicious activities or attemptedtheft or diversion of material.(initials)

NUCLEARMANAGEMENTMANUAL N ON-QUALITY RELATED EN-RW-106REV. 4 INFORMATIONAL U SEPage 43 of 46Integrated Transportation Security Plan ATTACHMENT9.610CFR37SUBPART DCATEGORY 1PHYSICAL PROTECTION REQUIREMENT CHECKLISTSheet 4 of 4

[13]IF the highway shipment driving time is greater than the maximum number of hoursestablished by the Department of Transportation,THEN verify there is anaccompanying individual.(initials)[14] Notify Site Security (S.A.S) of shipment AND have Security make a log entry.Date and time of notification: ________________________Security point of contact: ___________________________Security log entry number: __________________________(initials)Performed by (print, sign, date): _______________________________________________Reviewed by (print, sign, date): ________________________________________________

NUCLEARMANAGEMENTMANUAL N ON-QUALITY RELATED EN-RW-106REV. 4 INFORMATIONAL U SEPage 44 of 46Integrated Transportation Security Plan ATTACHMENT9.710CFR37SUBPART DCATEGORY 2PHYSICAL PROTECTION REQUIREMENT CHECKLISTSheet 1 of 2Shipment Number: _______________________[1] Verify the recipient is authorized to receive the type, form and quantity of material perNRC's License Verification System OR License Issuing Authority in accordance with 10 CFR 37.71(initials)[2] Attach documentation of license verification.(initials)

[3]IF shipping to a licensee in an agreement state,THEN obtain written verification oflicensee compliance with physical security requirements for Category 2 quantities ofradioactive materials in accordance with 10 CFR 37. Attach verificationdocumentation.(initials)[4] Pre-plan and coordinate shipment arrival and departure times with receiving licensee.Planned departure date and time: _________________________________Planned arrival date and time: __________________________________No-Later-Than date and time: ___________________________________(initials)[5] Verify the carrier meets the requirements for physical protection of Category 2quantities of radioactive material during shipments by road per 10 CFR 37.79(a).(initials)

NUCLEARMANAGEMENTMANUAL N ON-QUALITY RELATED EN-RW-106REV. 4 INFORMATIONAL U SEPage 45 of 46Integrated Transportation Security Plan ATTACHMENT9.710CFR37SUBPART DCATEGORY 2PHYSICAL PROTECTION REQUIREMENT CHECKLISTSheet 2 of 2[6] Verify the carrier has established a package tracking system that allows the shipper ortransporter to identify where the package was last and when it should arrive at thenext point of control.(initials)[7] Verify the carrier has constant control and/or surveillance during transit and has thecapability for immediate communication to summon appropriate response orassistance.(initials)[8] Verify the carrier has established a tracking system that requires an authorizedsignature prior to releasing the package for delivery or return.(initials)

[9]IF provided,THEN attach carrier verification of 10 CFR 37 compliance.(initials)[10] Notify Site Security (S.A.S) of shipment AND have Security make a log entry.Date and time of notification: ________________________Security point of contact: ___________________________Security log entry number: __________________________(initials)[11] Refer to 10 CFR 71.97 to see if the shipment also meets the criteria for HighwayRoute Control Quantity limits requiring advanced notification.(initials)Performed by (print, sign, date): _______________________________________________Reviewed by (print, sign, date): ________________________________________________

NUCLEARMANAGEMENTMANUAL N ON-QUALITY RELATED EN-RW-106REV. 4 INFORMATIONAL U SEPage 46 of 46Integrated Transportation Security Plan ATTACHMENT9.810CFR37SUBPART DCATEGORY 1QUANTITIES OF C ONCERN STATE COORDINATION L OGSheet 1 of 1Shipment Number: _______________________State:___________________________State representative name and title:Date of coordination conversation:Expected entry:Date and time: Location:Expected exit:Date and time: Location:Does the state intend to provide law enforcement escorts?Safe havens identified:Additional discussion items concerning shipment through state:Performed by (Print, sign, date):Reviewed by (Print, sign, date):