ML16363A119

Wolf Creek Generating Station, Submittal of Revision 18A to Procedure AP 06-002, Radiological Emergency Response Plan.

ML16363A119
Person / Time
Site:	Wolf Creek
Issue date:	12/13/2016
From:	Hafenstine C R Wolf Creek
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RA 16-0073
Download: ML16363A119 (99)

Text

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'NUCLEAR OPERATING CORPORATION Cynthia R. Hafenstine Manager Regulatory Affairs December 13, 2016 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 RA 16-0073

Subject:

Docket No. 50-482: Revision of the Radiological Emergency Response Plan (RERP) for Wolf Creek Generating Station (WCGS) and Revision of Two Procedures and 11 Forms that Implement the WCGS RERP Gentlemen:

In accordance with 10 CFR Part 50.54(q)(5) and 10 CFR 50.4, a summary of the changes made to the Radiological Emergency Response Plan (RERP) for Wolf Creek Generating Station (WCGS) in revision 18A of procedure AP 06-002, "Radiological Emergency Response Plan (RERP)" is attached.

Revision 18A of procedure AP 06-002 became effective on November 29, 2016 and is enclosed.

Additionally, two procedures and 11 forms that implement the WCGS RERP have been revised.

The two revised implementing procedures and the 11 revised forms are identified below: Procedures Effective Dates EPP 06-011, Rev. 1 OA December 8, 2016 EPP 06-018, Rev. 13 November 29, 2016 Forms EPF 06-007-01, Rev.13 EPF 06-011-01, Rev. 4A EPF 06-011-02, Rev. 4A EPF 06-018-04, Rev. 4 EPF 06-018-05, Rev. 10A EPF 06-018-07, Rev. 68 EPF 06-018-08, Rev. 6A EPF 06-018-09, Rev. BA EPF 06-018-11, Rev. 14A EPF 06-018-12, Rev. 15A EPF 06-018-15, Rev. 138 P.O. Box 411 / Burlington, KS 66839 / Phone: (620} 364-8831 An Equal Opportunity Employer M/F/HCNET Effective Dates November 29, 2016 December 8, 2016 December 8, 2016 November 29, 2016 December 8, 2016 November 29, 2016 November 29, 2016 December 8, 2016 December 8, 2016 December 8, 2016 November 29, 2016 RA 16-0073 Page 2 of 2 The attached summary of the changes to the WCGS RERP, the implementing procedures and the implementing forms explains that these changes do not reduce the effectiveness of the WCGS RERP. This letter contains no commitments.

If you have any questions concerning this matter, please contact me at (620) 364-4204.

Sincerely, l',... ..

par Cynthia R. Hafenstine CRH/rlt

Attachment:

Summary of Changes to the Wolf Creek Generating Station (WCGS) Radiological Emergency Response Plan (RERP) and to Two Procedures and 11 Forms That Implement the WCGS RERP

Enclosure:

Procedure AP 06-002, "Radiological Emergency Response Plan (RERP),"

Revision 18A. cc: K. M. Kennedy (NRC), w/a, w/e (2) B. K. Singal (NRC), w/a, w/e N. H. Taylor (NRC), w/a, w/e Senior Resident Inspector (NRC), w/a, w/e Attachment to RA 16-0073 Page 1 of 3 Summary of Changes to the Wolf Creek Generating Station (WCGS) Radiological Emergency Response Plan (RERP) and to Two Procedures and 11 Forms That Implement the WCGS RERP 1. Procedure AP 06-002, "Radiological Emergency Response Plan (RERP),"

Rev. 18A The term "ROD" has been changed to the term "dosimeter

in step 6.3.9 and in Figure 9, "Direct Radiation Pathway Sampling Locations,"

in accordance with industry guidance.

The term "Health Physics" has been changed to "Radiation Protection" in steps 6.3.12, 6.3.12.2, 6.15.3 and in Attachment D, "WCGS Minimum Staffing for Emergencies."

These changes are editorial in nature and do not decrease the effectiveness of the WCGS RERP. 2. Procedure EPP 06-011, "Emergency Team Formation and Control,"

Rev. 10A In step 7.4.2, the term, "A Record Dose Dosimeter (ROD)" has been changed to "A Dosimeter of Legal Record (DLR)" and the term "ROD" has been changed to "DOSIMETER" in Figure 2, "Wolf Creek Atmospheric Sampling."

Conditional statements in many procedural steps were changed to boldface type in accordance with station procedure writing requirements.

Additional spelling and hyphenation changes were made in other steps in accordance with station procedure writing requirements.

The changes to procedure EPP 06-011 are editorial in nature and do not decrease the effectiveness of the WCGS RERP. 3. Procedure EPP 06-018, "Maintenance of Emergency Facilities and Communications Checks,"

Rev. 13 Editorial changes were made to multiple steps to correct typographical errors, align wording with industry guidance and internal organizational names, and change sentence structures in accordance with station procedure writing requirements.

The responsibilities assigned to the Manager Operations in step 5.2.1 have been revised because the emergency diesel generator at the Emergency Operations Facility (EOF) is maintained according to vendor specifications, and radiological monitors and airlock doors are not required because the EOF is located approximately 12 miles from WCGS. The changes to step 5.2.1 *align responsibilities for the Manager Operations with equipment that is maintained and used at the Technical Support Center. The other changes to procedure EPP 06-018 are editorial in nature. Therefore these changes do not decrease the effectiveness of the WCGS RERP. 4. Form EPF 06-007-01, "Wolf Creek Generating Station Emergency Notification,"

Rev. 13 A new primary contact telephone number for the State of Kansas Emergency Operations Center has been added to form EPF 06-007-01.

This change is administrative in nature and does not decrease the effectiveness of the WCGS RERP.

Attachment to RA 16-0073 Page 2 of 3 5. Form EPF 06-011-01, "Plant Team Brief," Rev. 4A On page 1, the term "ROD" has been changed to "DLR" in accordance with industry guidance.

This change is editorial in nature and does not decrease the effectiveness of the WCGS RERP. 6. Form EPF 06-011-02, "Field Team Brief," Rev. 4A The term "ROD" has been changed to "DLR" in accordance with industry guidance.

This change is editorial in nature and does not decrease the effectiveness of the WCGS RERP. 7. Form EPF 06-018-04, "Offsite Medical Emergency Supplies Inventory Checklist,"

Rev.4 A reference to the Anderson County Hospital has been deleted from form EPF 06-018-04 and an equipment entry for a garden hose and spray attachment has also been deleted from this inventory checklist.

The Anderson County Hospital was deleted from the Coffey County Emergency Plan with the approval of the Federal Emergency Management Agency. An improved method for caring for potentially contaminated injured personnel, which uses a minimal amount of liquid, has been implemented and the garden hose and spray attachment are no longer required.

These changes delete references to a hospital that has been removed from the Coffey County Emergency Plan and to equipment that is no longer needed. Therefore, these changes do not decrease the effectiveness of the WCGS RERP. 8. Form EPF 06-018-05, "Control Room Inventory Checklist,"

Rev. 10A The term "ROD" has been changed to "DLR" on page one in accordance with industry guidance.

This change is editorial in nature and does not decrease the effectiveness of the WCGS RERP. 9. Form EPF 06-018-07, "Primary Access Control Station Inventory Checklist,"

Rev.SB The term "DLR" has replaced the term "ROD" on page one in accordance with nuclear power industry guidance.

This change is editorial in nature and does not decrease the effectiveness of the WCGS RERP. 10. Form EPF 06-018-08, "Ambulance Radiological Emergency Kit Inventory Checklist,"

Rev. SA The term "DLRs" has replaced the term "RDDs" on page one in accordance with nuclear power industry guidance.

This change is editorial in nature and does not decrease the effectiveness of the WCGS RERP.

.. Attachment to RA 16-0073 Page 3 of 3 11. Form EPF 06-018-09, "Off-Site Monitoring Inventory Checklist,"

Rev. SA The term "ROD" has been changed to "Dosimeter" on page two in accordance with industry guidance.

This change is editorial in nature and does not decrease the effectiveness of the WCGS RERP. 12. Form EPF 06-018-11, "Technical Support Center Inventory Checklist,"

Rev. 14A The term "DLRs" has replaced the term "RDDs" on page one in accordance with nuclear power industry guidance.

This change is editorial in nature and does not decrease the effectiveness of the WCGS RERP. 13. Form EPF 06-018-12, "Emergency Operations Facility Inventory Checklist,"

Rev. 15A . The term "DLRs" has replaced the term "RDDs" on pages one and six in accordance with nuclear power industry guidance.

This change is editorial in nature and does not decrease the effectiveness of the WCGS RERP. 14. Form EPF 06-018-15, "Emergency Planning Quarterly Communications Checklist,"

Rev.138 The telephone numbers for the Joint Information Clearinghouse in Topeka on page 14 have been changed from a 274 prefix to a 646 prefix. These changes are editorial in nature and do not decrease the effectiveness of the WCGS RERP.

• AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN

• Responsible Manager Superintendent Emergency Planning I Revision Number 18A

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18A RADIOLOGICAL EMERGENCY RESPONSE PLAN Information Use TABLE OF CONTENTS SECTION 1.0 PURPOSE 2.0 SCOPE TITLE

3.0 REFERENCES

AND COMMITMENTS 4.0 DEFINITIONS 5.0 RESPONSIBILITIES 6.0 PROCEDURE 6.3 Emergency Measures 6.4 Emergency Facilities 6.5 Control Room Organization 6.6 Technical Support Center (TSC) Organization 6.7 Operations Support Center (OSC) Organization 6.8 Emergency Operations Facility (EOF) Organization 6.9 Public Information Organization 6.10 Local Off-Site Organizations 6.11 State Organizations 6.12 Federal Organizations 6.13 Additional Support Agencies 6.14 Plant Monitoring 6.15 Emergency Supplies 6.16 Communications 6.17 Emergency Plan Training 6.18 Emergency Plan Drills 6.19 Emergency Planning Exercises AP Page 6.20 Emergency Plan and Procedures Administrative Controls 6.21 Recovery Plan 7.0 RECORDS 8.0 FORMS EFFECTIVE 10-MILE EPZ POPULATION SUBZONE EVACUATION TIMES06-002 1 of 93 2 2 3 4 9 11 14 21 27 30 34 35 40 43 47 50 52 53 56 57 59 60 61 63 64 65 65 66 67 ATTACHMENT A ATTACHMENT B ATTACHMENT C CROSS REFERENCE BETWEEN NUREG 0654, RERP, & WCGS ATTACHMENT ATTACHMENT ATTACHMENT ATTACHMENT ATTACHMENT FIGURE 1 FIGURE 2 FIGURE 3 FIGURE 4 FIGURE 5 FIGURE 6 FIGURE 7 FIGURE 8 FIGURE 9 FIGURE 10 FIGURE 11 PROCEDURES 69 D WCGS MINIMUM STAFFING FOR EMERGENCIES 77 E EPA/KANSAS PROTECTIVE ACTION GUIDES 78 F USAR CHAPTER 15 POSTULATED EVENTS 80 G LETTERS OF AGREEMENT 81 H REPORTING OF INCIDENTS PER 10 CFR 20 82 EFFECTIVE 10-MILE EPZ, SUBZONES AND EVACUATION ROUTES 83 MINIMUM SHIFT STAFFING 84 TSC/OSC ORGANIZATION 85 EOF ORGANIZATION 86 PUBLIC INFORMATION ORGANIZATION 87 EMERGENCY ORGANIZATION INTERFACES 88 WCGS EMERGENCY RESPONSE FACILITIES 89 AIRBORNE PATHWAY SAMPLING LOCATIONS 90 DIRECT RADIATION PATHWAY SAMPLING LOCATIONS 91 WATERBORNE PATHWAY SAMPLING LOCATIONS 92 FIXED SIREN SITING 93

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18A AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Information Use !Page 2 of 93 1. 0 PURPOSE 1.1 The purpose of the Wolf Creek Generating Station (WCGS) Radiological Emergency Response Plan (RERP) is to classify emergencies, assign responsibilities for actions, and to establish the lines of authority and communications to protect the public and plant personnel in the event of an emergency.

2.0 SCOPE 2.1 The RERP has been developed in accordance with lOCFR Part 50, Paragraph 50.47 and Appendix E, Regulatory Guide 1.101 and generally follows the guidelines of NUREG 0696 and 0654. The RERP is sensitive to a broad spectrum of emergency conditions which have been postulated for a commercial pressurized water reactor.

Although the probability of an accident is low, the RERP is maintained to assure the safety and well-being of plant personnel and members of the public in the vicinity of WCGS. 2.2 The RERP interfaces with several related documents such as the Administrative Procedures (APs) and Emergency Plan Procedures (EPPs). Detailed instructions necessary to support the RERP are included in these procedures and are available for training, drill, and actual emergency use. The RERP references the WCGS Fire and Security Plans, Vendor contingency plans as well as those of medical support facilities and the Institute of Nuclear Power Operations (INPO). This document has been designed to coordinate with the State Emergency Operations Plan and the Coffey County Contingency Plan for Incidents Involving Commercial Nuclear Power, which govern the activities of these support groups in response to events at WCGS. 2.3 The RERP is based on a graduated, escalating level of emergency response which is activated as conditions at the plant warrant.

This approach provides the flexibility necessary to ensure adequate emergency response to a spectrum of possible events. The RERP is designed to control emergency response activities ranging from initial event detection, classification of the event, notification of off-site authorities and providing protective action recommendations to the county and state. 2.4 The RERP reflects three chief phases of activation.

First the response is dominated solely by the site staff, next the on-site and off-site public information facilities are jointly activated, and finally the recovery efforts are performed by site, public information facilities, vendor, and other critical support groups.

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18A AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Information Use Page 3 of 93 2.5 The WCGS normal operating organization and its functional responsibilities are described in the WCGS Technical Specifications, Administrative Procedures, Human Resources company organization charts and the WCGS Updated Safety Analysis Report (USAR) . No further discussion of the normal operating organization is contained within the RERP. 2.6 The WCGS design bases accidents and various plant systems are listed and described in the WCGS Technical Specifications and USAR. No further discussion of these accidents or systems is contained within the RERP. 2.7 The owners of WCGS do not respond to the site during emergency events for augmentation.

The Wolf Creek Nuclear Operating Corporation organization functions from the site during normal everyday operations.

3.0 REFERENCES

AND COMMITMENTS 3.1 References 3 .1.1 3 .1. 2 3 .1. 3 3 .1. 4 3 .1. 5 3 .1. 6 3 .1. 7 3 .1. 8 3 .1. 9 3 .1.10 3 .1.11 3 .1.12 Coffey County Contingency Plan for Incidents Involving Commercial Nuclear Power (County Plan) The State of Kansas Radiological Emergency Response Plan for Nuclear Facilities Updated Safety Analysis Report (USAR) NUREG 0654, Criteria For Preparation And Evaluation Of Radiological Emergency Response Plans And Preparedness In Support Of Nuclear Power Plants NUREG 0696, Functional Criteria For Emergency Response Facilities NUREG 0737, Clarification Of TMI Action Plan Requirements Title 10, Code Of Federal Regulations, Part 50 Regulatory Guideline 1.101 Regulatory Guide 1.145 PIR 2002-1524, Minimum Staffing Requirements Wolf Creek On-Shift Staffing Analysis Wolf Creek Generating Station Development of Evacuation Time Estimate (October 2012)

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18A AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Information Use 4 of 93 3.2 Commitments 3.2.1 3.2.2 3.2.3 3.2.4 3.2.5 RCMS #93-325, Emergency Action Levels Converted To NUMARC EALs APF 06-002-01, EMERGENCY ACTION LEVELS, required to have a 50.54(q) review performed for each revision.

RCMS #05-115, NRC Regulatory Guide 1.101 Guidance Definitions RCMS #05-118, NRC Bulletin 2005-02 Guidance For Drills And Exercises CR 00086306, Minimum Staffing Requirements not Met 4.0 DEFINITIONS 4.1 Administrative Procedures (APs) 4.1.1 4.1.2 Procedures which provide programmatic responsibilities and are typically used to solve problems, assemble documentation, process information, and present results of administrative functions.

Administrative procedures control activities affecting quality or nuclear safety. 4.2 As Low As Reasonably Achievable (ALARA) 4.2.1 4.3 Alert 4.3.1 Making every reasonable effort to maintain exposures to radiation as far below dose limits as is practical, consistent with the purpose for which the licensed activity is undertaken, taking into account the state of technology, the economics of improvements in relation to benefits to the public health safety, and other societal and socioeconomic considerations.

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 Environmental Protection Agency (EPA) Protective Action Guideline (PAG) exposure levels. [Commitment Step 3.2.3]

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18A AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Information Use Page 5 of 93 4.4 Assessment Actions 4. 4 .1 Those actions taken during or after an accident to obtain and process information that is necessary to make decisions to implement specific emergency measures.

4.5 Coffey County Emergency Operations Center (County EOC) 4.5.1 The base of operations for the Coffey County Emergency Response Organization.

4.6 Consultant/Vendor

4. 6 .1 The Nuclear Steam System Supplier (NSSS), Architect/Engineer, and other organizations who have available multidiscipline teams ready to support emergency response and Recovery Operations.

4.7 Control Room 4.7.1 4.8 Drill 4.8.1 The location at the WCGS from which the reactor and its auxiliary systems are normally controlled

. A supervised activity used to develop and maintain skills. On the spot correction of erroneous performance is permitted.

4.9 Emergency Action Levels (EALs) 4. 9 .1 Radiological dose rates; specific contamination levels of airborne, waterborne or surface-deposited concentrations of radioactive materials; or specific instrument indications that may be used as thresholds for designating a particular class of emergency.

4.10 Emergency Alert System (EAS) 4.10.1 A coordinated network of broadcasters (e.g. Radio, Television, Cable) that allows the President to address the nation, Governors to address their State and public safety officials to address local citizens with emergency information.

4.11 Emergency Classification 4 .11.1 A system used to define the severity of emergencies into one of four categories based upon projected or confirmed emergency action levels. Classifications listed in order of increasing severity are Notification of Unusual Event (NUE), Alert, Site Area (SAE) and General Emergency (GE) .

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18A AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Information Use Page 6 of 93 4.12 Emergency Operations Facility (EOF) 4.12.1 This facility serves as a base of operations for all emergency plant support activities, site environmental surveillance, communications with supporting

agencies, and the WCGS Emergency Organization.

4.13 Emergency Plan Procedures (EPPs) 4.13.1 Specific procedures providing step-by-step actions to implement the WCGS Radiological Emergency Response and Recovery Plans, and to provide guidance to improve or terminate an emergency situation.

4.14 Evacuation Registration Center 4.14.1 Facility designated for receiving personnel evacuating the Emergency Planning Zone (EPZ) for accountability, contamination monitoring and decontamination.

4.15 Exclusion Area 4.15.1 That area within a 1200-meter radius of the Containment Building in which WCGS has the authority to determine all activities including exclusion or removal of persons and property from the area. 4.16 Executive Management 4.16.1 4.17 Exercise 4.17.1 Those members of WCGS management at the vice president level and above. An event that simulates a radiological emergency condition, incorporates the integrated capability of the basic elements existing within the Radiological Emergency Response Plan (RERP) . These events are normally evaluated by FEMA I NRC. 4.18 General Emergency (GE) 4.18.1 Events are in process or have occurred which involve actual or imminent substantial core degradation or melting with the 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 Protective Action Guideline exposure levels off-site for more than the immediate site area. [Commitment Step 3.2.3]

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18A AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Information Use IP age 7 of 93 4.19 Hostile Action 4.19.1 An act toward a Nuclear Power Plant (NPP) 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 NPP. Non-terrorism-based EALs should be used to address such activities (e.g., violent acts between individuals in the owner controlled area). [Commitment Step 3.2.3] 4.20 Hostile Force 4.20.1 One or more individuals who are engaged in a determined

assault, overtly, or by stealth and deception, equipped with suitable weapons capable of killing,

maiming, or causing destruction

. [Commitment Step 3.2.3] 4.21 Immediate Notification 4.21.1 Notification made to State of Kansas and Coffey County authorities within 15 minutes of a declared emergency at WGCS. 4.22 Joint Information Clearinghouse (JIC) 4.22.1 The facility where news statement and news conference materials for the media are prepared.

4.23 Kansas State Emergency Operations Center (State EOC) 4.23.1 The command-and-control center for the state. 4.24 Licensed Operators 4.24.1 WCGS Reactor Operators and Senior Reactor Operators who are licensed under 10CFR55 and who stand watches on shift and report to the Shift Manager.

4.25 Media Center (MC) 4.25.1 Facility utilized as a focal point for giving information to the media through news conferences.

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18A AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Information Use 8 of 93 4.26 Notification of Unusual Event 4.26.1 4.27 Off-Site 4.27.1 4.28 On-Site 4.28.1 Events are in process 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. [Commitment Step 3.2.3] Any area the Exclusion Area of WCGS. Any area inside the Exclusion Area of WCGS. 4.29 Operations Support Center (OSC) 4.29.1 A staging area for emergency teams to support the emergency response effort . 4.30 Owner Controlled Area 4.30.1 Property contiguous to the reactor site and acquired by fee, title or easement for Wolf Creek Generating Station for which public access is limited.

4.31 Protective Actions 4.31.1 Those emergency measures taken before or after a release of radioactive material has occurred for the purpose of preventing or minimizing radiological exposures to personnel.

4.32 Protective Action Guides (PAGs) 4.32.1 Guides promulgated by the Environmental Protection Agency (EPA) which set dose limits for the evacuation of the public during an accident condition at a nuclear power plant. 4.33 Radiologically Controlled Area (RCA) 4.33.1 An area to which access is controlled by WCGS for purposes of protection of individuals from exposure to radiation or radioactive materials.

• 4.34 Recovery 4.34.1 Post-emergency efforts initiated to restore WCGS to full operation or place the plant in a safe shutdown condition until full operation can be resumed.

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18A AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Information Use !Page 9 of 93 4.35 Site Area Emergency (SAE) 4.35.1 Events are in process or have occurred which involve an actual or likely major failure 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 Protective Action Guideline exposure levels beyond the site boundary.

[Commitment Step 3.2.3] 4.36 Technical Support Center (TSC) 5.0 4.36.1 The TSC serves as a center outside of the Control Room that acts in support of the command-and-control function and houses the OSC organization.

Plant status and diagnostic information are available at this location for use by technical and management personnel in support of reactor command-and-control functions

. RESPONSIBILITIES 5.1 Site Emergency Manager 5 .1.1 Assumes command and control of the emergency and directs on-site response to stabilize plant conditions.

5.2 Off-Site Emergency Manager 5.2.1 Assumes command and control of the emergency and interfaces with off-site agencies.

5.3 Superintendent Emergency Planning 5.4 5. 3 .1 5.3.2 Ensures the Emergency Planning and Preparedness Program is implemented and maintained as required to protect the health and safety of the public. Ensures changes to the overall Emergency Planning and Preparedness Program meets the standards of 10CFR50.47(b) and the requirements of 10CFR50, Appendix E. Manager Quality 5. 4 .1 Ensures a review of the WCGS Emergency Preparedness Program will be performed every twelve months in accordance with 50. 54 (t) . Planning and at least once lOCFR

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18A AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Information Use Page 10 of 93 5.5 President and Chief Executive Officer 5.5.1 Maintains overall authority and responsibility for the WCGS Emergency Preparedness Program.

5.6 Public Information Officer (PIO) 5.6.1 The PIO has the authority and responsibility for the WCGS Public Information Organization and all plant information disseminated to the media. 5.7 Shift Manager (SM) 5 . 7 . 1 The Senior Reactor Operator designated by WCGS management with immediate on-site authority and responsibility for the safe and proper operation of the plant. This position is staffed at all times. The Shift Manager is responsible for the initial evaluation of any abnormal or emergency situation and for directing the appropriate response.

He assumes responsibilities of the Emergency Manager until relieved

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18A AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Information Use. !Page 11 of 93 6.0 PROCEDURE 6.1 Site Description 6 .1.1 6 .1. 2 6 .1. 3 6.1. 4 6 .1. 5 WCGS is a Pressurized Water Reactor (PWR) nuclear generating station operated by Wolf Creek Nuclear Operating Corporation (WCNOC) . WCGS is located near the center of Coffey County, Kansas (KS), about 3.5 miles northeast of Burlington, the county seat, 90 miles southwest of Kansas City, MO and 55 miles south of the state capital Topeka, KS. The immediate site environs are sparsely populated.

Burlington and New Strawn .are the major population centers.

John Redmond Reservoir (JRR) and Coffey County Lake (CCL) are the major recreational facilities.

Most of the seasonal or daily shifts in population are associated with recreational areas around JRR and CCL. Approximately 70% of the annual visitors to the John Redmond Reservoir and Coffey County Lake come to the area during the summer months . The 10-mile Plume Exposure Emergency Planning Zone (EPZ) is a major consideration in the RERP. Approximately 99% of the 10-mile EPZ is located within Coffey County and 1% within Anderson County. The EPZ has been defined by developing sub-zones based upon natural and political subdivisions.

These have been described for evacuation zones approximating 2, 5 and 10-mile radial rings. This distribution allows ready identification of areas to be evacuated and facilitates public recognition of subzones in which they work or reside. FIGURE 1, EFFECTIVE 10 MILE EPZ, SUBZONES AND EVACUATION ROUTES, presents the 2, 5 and 10-mile radial zones and subzones which provides the basis for the design of an alert and notification system. The total population of the effective 10-mile EPZ is shown in ATTACHMENT B, SUBZONE EVACUATION TIMES. With the exception of Burlington and the other population centers listed in ATTACHMENT A, EFFECTIVE 10-MILE POPULATION

CENTERS, the population density of the effective 10-mile EPZ is approximately 4.4 persons per square mile. Other than the WCGS, there are no large industries in the area.

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18A Information Use 6 .1. 6 6 .1. 7 AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN !Page 12 of Principal geographical features within the effective 10-mile EPZ are the Neosho River, JRR, and CCL. The land around WCGS is flat with scattered low hills. Dense vegetation in the form of large trees exists on the banks of the river and in recreational areas. There are no topographical features within the effective 10-mile EPZ that significantly influence the design of the Alert and Notification System. 1. Sparsely populated farm land comprises the majority of the effective 10-mile EPZ. 2. The site also demonstrates favorable topography, demography, and meteorology, which have been factored into many analyses that support the emergency planning effort. 3. The Neosho River is oriented northwest-southeast and extends to within 3 miles southwest of the plant. 4. The main dam of the John Redmond Reservoir is 3.5 miles west of the plant. This water conservation pool is approximately 4 miles in diameter with a surface area of 15 square miles. 5. The Coffey County Lake is approximately 7 miles long with a normal surface area of 8 square miles. The meteorological conditions within the effective 10-mile EPZ are characterized by a distinctly continental climate with warm humid summers and highly variable winter weather.

Maritime tropical air originating over the Gulf of Mexico is the dominant air mass from June through August. This air mass is quite humid resulting in considerable thunderstorm activity.

From November through February, continental polar air dominates the climate.

93 6.2 Emergency Classifications 6.2.1 10 CFR Part 50, Appendix E, Section IV.C, requires a classification scheme of four specific levels of emergencies.

NUMARC/NESP 007 is identified within REGULATORY GUIDE 1.101 and is considered by the NRC as an acceptable alternative method to that described in Appendix 1 to NUREG 0 654. [Cammi tment Step 3. 2 .1]

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18A Information Use

• 6.2.2 6.2.3 6.2.4

• 6.2.5 6. 2. 6 6. 2. 7

• AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN !Page 13 of An emergency class is a qualitative estimate of the status of the plant. Inputs to the emergency classification system include the status of plant systems and the levels of radiation in plant areas and effluents.

However, an emergency class does not give a qualitative or quantitative estimate of the subsequent status of the plant or radioactive release.

The emergency classes are used by off-site authorities to determine the level of preplanned actions to be taken by their emergency organizations.

Protective actions taken on behalf of members of the public are the legal responsibility of state and local government.

1. The functional interfaces between WCGS and other emergency organizations are shown in FIGURE 6, EMERGENCY ORGANIZATIONS INTERFACES.

The classification system used at WCGS is an approach that ranges from primarily event-based for Unusual Event to primarily symptom or barrier-based for General Emergencies.

This is to better assure that timely recognition and notification occurs, that events occurring during refueling and cold shutdown are appropriately

covered, and that multiple events can be effectively treated.

The Emergency Action Levels (EAL) are contained in APF 06-002-01, EMERGENCY ACTION LEVELS. The EAL have been developed and agreed upon by WCGS, the State of Kansas and Coffey County and approved by the NRC. [Commitment Step 3.2;1] 1. The EAL are reviewed annually by the State and County. 10 CFR Part 50, Appendix E, Section IV.C.2, requires licensees to establish and maintain the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded a.nd shall promptly declare the emergency.

Each emergency classification causes certain actions to happen such as notifications, activation and evacuation

. 1. An NUE requires plant personnel, the County and State to be notified.

No evacuation or activation required.

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18A Information Use AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN 14 of 2. An Alert requires plant personnel, the County and State to be notified.

The Emergency Response Organization (ERO) is called out and the emergency facilities are activated.

Accountability may be performed if necessary.

3. A Site Area Emergency requires plant personnel, the County and State to be notified.

The ERO is called out and the emergency facilities are activated.

The protected area is evacuated of non-responding personnel for accountability.

JRR and CCL are evacuated.

Accountability for site personnel is performed.

4. A General Emergency requires plant personnel, the County and State to be notified.

The ERO is called out and the emergency facilities are activated.

The site is evacuated of non-responding personnel.

JRR and CCL are evacuated.

Accountability for site personnel is performed.

93 6.3 Emergency Measures 6.3.1 6.3.2 Protective actions to minimize personnel exposure are taken when an incident has occurred, or may occur, which could result in a fission product barrier challenge or breach. In addition, protective actions are taken for personnel on-site for situations such as fires or flooding, where personnel safety is threatened.

Emergency measures consist of assessment, corrective, and protective actions.

The Shift Manager and Senior Reactor Operators assume immediate responsibility for accident assessment and mitigation.

The RERP and detailed emergency actions are based on the assumption that, in an emergency, licensed operators take appropriate measures to maintain or return the facility to a safe condition, in accordance with operating license conditions and the technical specifications.

1. Callout of the ERO to augment the on-shift staff and to activate the Emergency Facilities is performed at an Alert or higher classification or whenever augmentation is deemed necessary

.

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• AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Page 15 of Immediate and Follow-up notifications made to State and County authorities provide information for their use in making prompt decisions for notifying the public and ordering off-site protective actions.

1. Immediate notifications are made for each emergency classification.

2. Immediate notifications are made to the Coffey County Sheriff dispatcher and the Kansas Division of Emergency Management State Duty Officer within 15 minutes.

3. The notification form contains information agreed upon by WCGS, the State and County for each of the Immediate and Follow-up notifications.

The following is a list of information that may be on the form: o Name of facility o Date and time of classification o Classification o Release status, type of material and estimated duration o Message authentication of phone call o Subzones recommended for protective actions o Meteorological conditions o Dose rates at site boundary o Event Prognosis, worsening or termination 93 Revision:

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• 6.3.5 6.3.6

• AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN rage 16 of Actions to protect the general public, and criteria for their implementation, are described in the State Plan. Protective action recommendations are made to the County and State authorities.

1. ATTACHMENT E,. EPA/KANSAS PRO,TECTIVE ACTION GUIDES, illustrates the EPA/Kansas PAGs for members of the public in the vicinity of WCGS and contains information typical of what may be used for the PAR guidelines.

The ATTACHMENT provides guidelines and action levels to be used to develop protective action recommendations.

Wolf Creek makes PARs for releases beyond the 10 mile EPZ. County and State officials have authority to take protective actions off-site.

2. Evacuation is the normally anticipated off-site protective action. Sheltering may be the preferred protective action when it will provide protection equal to or greater than evacuation.

ATTACHMENT B, SUBZONE EVACUATION TIMES, contains evacuation times for the general and transient public. 3. An Alert and Notification System, made up of a number of sirens, is one means of alerting the public. Tone Alert radios are also used for notifications.

Contact point for information concerning the County Plan, protective

measures, and special needs of the handicapped is the County Emergency Management Office. Additional resources available for accident assessment include accident monitoring and in-plant iodine instrumentation under accident conditions.

Detailed discussions of these resources and their capabilities are found in the USAR . 93 Revision:

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• 6.3.8 6.3.9

• 6.3.10 AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN [:'age 17 of The Emergency Dose Calculation Program (EDCP) is a computerized method to provide dose estimates using actual or estimated meteorological data (wind speed, wind direction, degree of cloud cover, day or night determination) and radiological effluent data (actual measurements, estimated values based upon USAR source terms, or field measurements).

EDCP is designed to: [Reference Step 3.1.9] 1. Use radiological and meteorological information to provide an estimate of off-site exposure.

2. Be capable of estimating release rates and off-site exposures from off-site field team data. 3. Be capable of estimating release rates and off-site exposures for an unmonitored, pressure driven containment release using the Containment High Area Radiation Monitor readings and changes in containment pressure

. 4. Off-site dose predictions when combined with actual release duration information and meteorological data during an event, provide sufficient data to estimate the cumulative population dose resulting from the event. The actual off-site population dose is confirmed by off-site monitoring, sampling and analysis.

Radiological monitoring teams have a goal of 60 minutes from the declaration of Alert or greater emergency to be ready for deployment to confirm effluent readings and verify plume emission and locations.

FIGURE 7, WCGS EMERGENCY RESPONSE FACILITIES, provides a view of the off-site area, showing the location of the EOF. FIGURE 8, AIRBORNE PATHWAY SAMPLING LOCATIONS shows the fixed air sampling locations.

FIGURE 9, DIRECT RADIATION PATHWAY SAMPLING LOCATIONS, shows the direct radiation pathway sampling dosimeter locations.

FIGURE 10, WATERBORNE PATHWAY SAMPLING LOCATIONS, shows locations for collecting water samples.

At a Site Area Emergency, General Emergency, or when accountability is required, all personnel not responding to an Emergency Response Facility report to an assembly area for accountability and additional information.

ERO personnel report to their assigned emergency facility.

Security reports the results of accountability to the TSC. 93 Revision:

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• 6.3.11 6.3.12 ** 6.3.13 6.3.14

• AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN IP age 18 of IF the Exclusion Area is evacuated, THEN Security shall direct an inspection of the lake and land area within the Exclusion Area but outside of the Protected Area to ensure that all personnel not responding to an Emergency Response Facility are evacuated from the Exclusion Area. WCGS procedures contain decontamination instructions and guidelines.

Methods for determining if the individual is a potential inhalation or ingestion contamination case are also provided.

The Radiological Coordinator or appropriate Radiation Protection supervisory personnel will review the records generated by decontamination procedures.

1. Decontamination can be performed in the access control area of the Control Building, in the HVAC room of the TSC, and in the garage in the EOF. 2. Other decontamination areas are setup as designated by the Radiation Protection personnel on the ERO . Respiratory protective devices and protective clothing are stored at several locations on-site and at the EOF. The use of protective clothing and respiratory protection equipment is governed by normal WCGS procedures.

A supply of potassium iodide (KI) is maintained at the Control Room, TSC and the EOF to be used in the event that an individual may be exposed to radioiodine

. 93 Revision:

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• 6.3.16 6.3.17 6.3.18

• AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN IP age 19 of There are suggested levels of exposure to be accepted in emergencies.

Immediate reentry may be necessary to save a life, account for missing personnel, or secure vital equipment.

The Emergency Managers are ultimately responsible for exposure control and can permit the receiving of up to 5 REM per person for work activities, 10 REM for saving valuable equipment and 25 REM for lifesaving after consulting with the NRC, if feasible.

Exposure which might exceed 25 REM, for lifesaving activities, must be approved by an Emergency Manager.

Although EPA and NRC do not provide specific guidance for the upper bounds for lifesaving

exposure, WCGS has chosen to use the following criteria:

1. Emergency Managers shall not knowingly permit an individual's exposure to exceed 25 REM, unless it is for lifesaving activities or protection of large populations.

Emergency Managers shall not knowingly permit an individual to enter a high dose area if the projected Total Effective Dose Equivalent (TEDE) is expected to exceed 75 REM . o Those individuals designated to exceed 25 REM must be volunteers and be fully aware of the risks involved.

2. Emergency Managers should obtain the advice and concurrence of the Radiological Coordinators in approving additional exposure.

Under emergency conditions, normal exposure controls are maintained.

This is ensured by the on-shift Health Physics Technician (HP) in the Control Room, the Radiological Coordinators in the TSC and EOF. The Radiological Coordinator has responsibility for maintaining exposure control for site activities, including establishment of access control at alternate locations.

Strict exposure control of individuals passing through the access point is maintained on a 24-hour-per-day basis. In order to enhance the exposure control process and to provide dosimetry for an expanded number of people, dosimetry vendors are available to expedite shipment of extra dosimetry devices to supplement existing on-site supplies of dosimetry equipment and to supply personnel to assist in on-site appraisal of exposures.

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• 6.3.19 6.3.20 6.3.21 6.3.22 *

• AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN 20 When activated, the Emergency Response Team covers emergency

sampling, surveying,

analysis, and hazard evaluation.

of Personnel, instruments, and equipment are to be monitored at the access control point. Personnel and equipment decontamination is controlled in accordance with WCGS procedures.

WCGS maintains control over the Exclusion Area as necessary, restoring affected on-site areas to acceptable conditions for access. 1. Reentry intd affected areas is a controlled evolution.

Surveys are performed, environmental samples are obtained and analyzed, and areas posted or decontaminated.

Contamination limits for food supplies and drinking water are based upon the State of Kansas Protective Action Guides . 93

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18A AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Information Use Page 21 of 93 6.4 Emergency Facilities 6.4.1 6.4.2 Control Room Facilities

1. The Control Room is designed to be habitable under emergency conditions.

The Control Room contains

controls, instruments, and communications equipment necessary for operation of the plant under both normal and emergency conditions.

The ventilation system, shielding, and structures are designed and built to permit continuous occupancy during a postulated design basis accident.

2. Equipment available in the Control Room gives early warning and continuous evaluation of potential emergency situations.

Portable radiation survey instruments are readily available within the Control Room. 3. Access to the Control Room is controlled by the Shift Manager . Technical Support Center Facilities 1 . 2 . 3 . The TSC is a brisk 2 minutes and 15 seconds walk from the Control Room inside the Protected Area. This is sufficiently close to permit face-to-face interaction between personnel in the Control Room and the TSC, should telephone communications become inoperable.

The TSC is activated in the event of an Alert or higher emergency.

The TSC may be activated during an NUE at the discretion of the Shift Manager.

The TSC is designed to the seismic criteria of the Uniform Building Code. It is designed to withstand 100-year-recurrence winds and is located above the probable maximum flood level. a. The manually activated single-train, non-seismic Category I TSC ventilation system utilizes high-efficiency particulate air and charcoal filters.

The radioiodine monitoring equipment in the TSC provides a designed minimum detectable level of 1.0E-07 uCi/cc radioiodine.

A radiation monitor (including the monitor for radioiodines) alarms to alert TSC personnel if radiation levels may affect the habitability of the TSC.

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• 6.4.3 AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN 4 . Page 22 of b. Portable radiation monitoring equipment is provided in the TSC for backup radiation monitoring capability.

c. Equipment for Emergency Response Teams is available in the TSC. This equipment includes protective

clothing, dosimetry, survey meters and respirators.

d. A diesel generator is available to provide backup power to the TSC. Until the diesel is loaded, batteries are available for Nuclear Plant Information System (NPIS) . e. The TSC is sized to accommodate a minimum of 25 persons and has the same radiological habitability as the Control Room under accident conditions.

Personnel in the TSC have access to the following materials:

o WCGS USAR, Environmental Report, and Technical Specifications o Plant operating and emergency procedures o WCGS, State, and Coffey County emergency response plans o System drawings, schematics, and diagrams

5. An Alternate TSC is located at the EOF. The Alternate TSC would be used in the case of a hostile action or other event impeding site access. The Alternate TSC provides access to the same materials as the primary TSC. The Alternate TSC has the capability to: o Communicate with the EOF, Control Room and Security personnel o Perform off-site notifications of a plant emergency o Perform engineering assessment activities, including damage control team planning and preparation Operations Support Center 1. The OSC is housed in the TSC and is activated whenever the TSC is activated.

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• AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN 23 of 2. The OSC serves as an assembly area for plant personnel immediately serving in emergency repair or Health Physics support capacity during an event. The OSC functions include the coordination, formation and dispatch of Emergency Response Teams. 3. The basement of the Security Building has been identified as an alternate location for the OSC function.

It contains telephones and a Gai-Tronic call box, which will allow direct communications with the other emergency centers.

Portable radios are available to key personnel to further provide communications with other emergency centers.

4. An alternative OSC muster area is included with the Alternate TSC at the EOF. The Alternative OSC muster area would be used in conjunction with the Alternate TSC. Emergency Operations Facility (EOF) 1. The EOF is located approximately 12 miles north northwest of WCGS, near the junction of I-35 and US-75, and is activated at an Alert or higher emergency.

Following facility activation, overall emergency response is managed from the EOF. a. This facility serves as a center for evaluation and coordination of environmental activities related to the emergency including radiological assessment and the evaluation of potential or actual radioactive releases from the plant. 2. The EOF is a commercial building that is well engineered for the design life of the plant. a. A diesel generator is available to provide backup power to the EOF. Until the diesel is loaded, UPS backup is available for equipment used to access plant data upon loss of AC power. b. The EOF is sized to accommodate at least 35 persons . 3. Accommodations and telephones are provided for a limited number of County, State and Federal personnel.

Facilities are provided for staging field survey efforts from the EOF. 93 Revision:

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• AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN 24 of 4. The EOF serves as the base of operations for evacuation assessments and for communications with federal, state, and local response organizations.

Radio and telephone links are available to the TSC, and Control Room. 5. Personnel in the EOF have access to the following materials:

o WCGS USAR, Environmental Report, and Technical Specifications o Plant operating and emergency procedures o WCGS, State, and Coffey County emergency response plans o System drawings, schematics, and diagrams Public Information Facilities

1. The Public Information Facilities include the Joint Information Clearinghouse (JIC), Media Center (MC) , Phone Team, and Media Monitoring.

These facilities may be established as follows:

a. The JIC, Phone team and Media Monitoring in either the Wolf Creek Dwight D. Eisenhower Learning Center or in Topeka at the Kansas State Defense Building.

b. The MC in either the Wolf Creek Dwight D. Eisenhower Learning Center or in Topeka at the Nickell Memorial Armory. 2. At an NUE, information is provided to the public by Corporate Communications.

The Wolf Creek Public Information Facilities may be staffed at any time, as determined by the Wolf Creek Public Information

Officer, to support the distribution of information to the public. 3. The Public Information Organization activates at an Alert or higher emergency

. 11 93 Revision:

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• AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN 4. Page 25 of The JIC, MC, and the Phone Team are kept in close proximity to each other to facilitate coordination of information in the form of news statements, news conferences or telephone conversations.

a. Dedicated telephone lines allow contact between the JIC, TSC, and the EOF. The JIC contains status boards, appropriate office supplies, computer(s),

printer(s),

faxing and photocopy capabilities, and outside telephone lines. 5. The Wolf Creek PIO, the State PIO and Coffey County PIO communicate with the Public Information Coordinators (PIC) to obtain technical information.

The PIOs prepare news statements at the JIC and coordinate their efforts.

6. The MC will accommodate media representatives in an auditorium and adjoining Media Room for news conferences.

The Media Room is a facility setup to provide the media with a work area, audio/visual

material, outside telephone lines and public information status boards. 7. Media Monitoring and Rumor Control functions for WCGS, the State and Coffey County are performed by members of the Public Information Organization.

Appropriate equipment and supplies, fax and telephone communications with the JIC are available.

Approved news statements and information are transmitted to the Media Monitoring Team after the JIC is activated.

a. The Media Monitoring Team reports any rumors or misinformation heard or observed from their monitoring of the media to the JIC. On-Site Medical Facility

1. A medical facility located in the Clyde Cessna building, is staffed with a full time Licensed Practitioner.

This facility is equipped to provide basic medical response capabilities.

2. First aid kits, emergency equipment and supplies are available to ensure that assistance can be provided to injured and/or contaminated personnel.

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• AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN !Page 26 of 3. Shift personnel, trained in first aid, are available on-site 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day. Priority should be given to treating those with the most urgent medical needs. 4. In the case of contamination, efforts are made to decontaminate injured personnel on-site, as soon as practicable.

However, first aid or removal of the individual from a hazardous environment, takes precedence over decontamination efforts.

If decontamination is not possible, the victim is covered in such a manner as to avoid any spread of contaminatidn until medical aid can be obtained or hospitalization accomplished.

5. Personnel leaving the RCA are monitored for contamination.

All personnel are monitored for contamination before leaving the site. a. Personnel may be monitored by portal monitors or friskers when entering or leaving WCGS facilities

. b. Personnel found to be contaminated must undergo decontamination under the direction of Health Physics personnel using Health Physics supplies and equipment available during routine activities.

Release limits for personnel decontamination are found in the Health Physics Manual. State and County Facilities

1. Coffey County Emergency Operations Center (County EOC) is located in the Coffey County Courthouse, Burlington, KS. The County EOC is a command center for county agencies and a mustering area for personnel who arrive in the WCGS area in response to an emergency.

The County EOC is activated at the Alert level with the additional support staff activated upon declaration of an SAE or GE. Other centers are established as the emergency needs dictate.

2. Kansas State Emergency Operations Center (State EOC), located in the State Defense Building, 2800 South Topeka Boulevard, Topeka, KS, is the command-and-control center for the State. 93

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18A Information Use 6.4.8 AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN 27 of 3. The State Forward Staging Area is located about 11 miles north of WCGS in the roadside park at the intersection of Old Highway 50 and U.S. 75. When it becomes necessary for the State to dispatch emergency personnel to the plume exposure pathway emergency planning zone (EPZ), the State activates the State Forward Staging Area to serve as a secondary base of operations for state personnel and a local contact point with Coffey County. Evacuation Registration Center 1. People in the EPZ should evacuate to the Lyon County Reception Center using I-35 south toward Emporia, take Exit 141 for KS-130 toward Neosho Rapids/Hartford, travel two and one-half miles and go to the Neosho Rapids Grade School. 93 6.5 Control Room Organization 6.5.1 The-shift Manager is responsible for the initial evaluation and classification of any abnormal situation and for directing the appropriate

response, including initial activation of a callout.

1. Control Room personnel are on shift 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day. The shift complement is shown in Figure 2, MINIMUM SHIFT STAFFING

.

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• AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Page 28 of Upon declaration of an emergency, the Shift Manager assumes the duties of Emergency Manager.

The Shift Manager normally goes to and remains in the Control Room unless it is necessary for him to leave the Control Room in order to perform specific assessment, corrective, or protective actions.

The Shift Manager performs the following actions:

o Initiate appropriate technical measures to mitigate the event o Determine if releases have occurred, make the necessary assessment of the off-site concentration of radioactivity resulting from a release, and evacuate non-essential personnel if necessary o Direct the activities of the Control Room Emergency Notification System (ENS) and Off-site Communicators o Ensure immediate and follow-up notifications are made which provide sufficient information on emergency classification, plant status, off-site dose projections or measurements, and issue recommendations for off-site protective actions to authorities responsible for off-site emergency measures o Ensure NRC Resident Inspector is notified as soon as possible after the State and County are notified o Ensure notifications to the NRC are made as soon as possible within 60 minutes of classification of an emergency in accordance with 10CFR50.

72 (a) (3) o Ensure other notifications are made in accordance with EPPs o Activate on-site emergency teams if required o Notify plant personnel of the change in plant status 93 Revision:

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• 6. 5. 6 6.5.7 6.5.8 6. 5. 9

• AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN tpage 29 of Off-Site Communicator

1. The Off-site Communicator reports to the Shift Manager, performs initial notifications, and initiates the Automatic Dialing System (ADS) or Backup ADS to callout the ERO. a. A manual callout of personnel to staff the ERO is performed if the ADS and Backup ADS are not functioning.

Emergency Notification System (ENS) Communicator

1. The ENS Communicator reports to the Shift Manager and maintains communications with the NRC. Chemistry Technician

1. The Chemistry Technician reports to the Shift Manager and performs dose assessment until relieved by Dose Assessment personnel in the EOF . Health Physics Technician

1. The Health Physics Technician reports to the Shift Manager and performs radiation monitoring for personnel sent from and in the Control Room. Control Room Supervisor

1. Reports to the Shift Manager and provides direction to Reactor Operators and Nuclear Station Operators for the safe operation of the unit. Reactor Operators

1. The Reactor Operators report to the Control Room Supervisor and perform plant monitoring and reactor manipulations as needed from the Control Room. Nuclear Station Operators

1. Nuclear Station Operators report to the Control Room Supervisor and perform local plant monitoring and manipulations as directed.

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18A Information Use 6.5.10 6.5.11 6.5.12 AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Page 30 Shift Technical Advisor 1. The Shift Technical Advisor reports to the Shift Manager and performs STA requirements as assigned by the NRC. Initial emergency response to the major functional areas is within the capabilities of the minimum operations shift complement.

On-shift staff augmentation is available, when deemed necessary, in accordance with ATTACHMENT D, WCGS MINIMUM STAFFING FOR EMERGENCIES.

of 93 6.6 Technical Support Center (TSC) Organization 6.6.1 6. 6. 2 6. 6. 3 6. 6. 4 TSC activation will be performed as soon as practical and within the times as stated in the following:

1. During off-normal working hours, it is the goal to activate the TSC within 75 minutes of a declaration of an Alert or higher classification

. 2. During normal working hours, it is the goal to activate the TSC within 30 minutes of a declaration of an Alert or higher classification.

The TSC is considered activated when the following positions are present, the Site Emergency Manager determines the facility is ready to activate, and declares the facility activated:

o Site Emergency Manager o TSC Operations Coordinator o TSC Administrative Coordinator o TSC Radiological Coordinator o Maintenance Coordinator The TSC organization is shown in FIGURE 3, TSC/OSC ORGANIZATION.

Additional personnel to support repair efforts and recovery functions will be added as necessary.

Personnel reporting from off-site may initially report to the EOF/Alternate TSC, and then proceed to the TSC as plant/site conditions allow.

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• AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN 31 of Site Emergency Manager 1. The assigned Site Emergency Manager will assume command-and-control functions and will be the top line manager responsible for the emergenc¥.

An assigned Site Emergency Manager is available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day. The assigned Site Emergency Manager may assume command-and-control functions from the Shift Manager during an NUE if so requested by the Shift Manager.

2. The Shift Manager will transfer the Site Emergency Manager duties to the assigned Site Emergency Manager in accordance with EPPs. The Shift Manager resumes Control Room duties and reports to the Site Emergency Manager.

3. The Site Emergency Manager directs the on-site emergency effort, implements the applicable EPPs and, as appropriate, performs the following:

o Assess and verify the situation and assure that appropriate mitigating efforts are being taken o Review initial event classification and reclassify as appropriate o Determine the necessity for evacuation of personnel on-site o IF a release has occurred, THEN make the necessary assessment of the off-site concentration of radioactivity resulting from a release o Ensure immediate and follow-up notifications are made which provide sufficient information on emergency classification, plant status, off-site dose projections or measurements, and issue recommendations for off-site protective actions to authorities responsible for off-site emergency measures

4. The following responsibilities are those of the Emergency Managers and ma¥ not be delegated.

These responsibilities may be divided between the Site and Off-Site Emergency Managers:

o Classification of the emergency o Protective action recommendations o Authorization for notification of off-site authorities o Authorization of emergency exposure in excess of 10 CFR 20 limits 93 Revision:

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• AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Page 32 of TSC Operations Coordinator

1. The TSC Operations Coordinator reports to the Site Emergency Manager and is responsible for the following:

o Supervise reactor plant operations, which includes the Operations

Recorder, Engineering Coordinator, Engineering Team and ENS Communicator.

o Keep the Site Emergency Manager advised of plant conditions and operational manipulations.

2. The TSC Operations Coordinator may supervise other positions as directed by WCGS procedures.

Engineering Coordinator

1. The Engineering Coordinator reports to the TSC Operations Coordinator and directs the activities of the Engineering Team to technically assess plant status and the severity of emergency conditions.

Engineering Team 1. The Engineering Team reports to the Engineering Coordinator.

The Team evaluates current and historical plant parameters, assesses the severity of the emergency conditions and magnitude of fuel damage, and recommends corrective or preventive actions.

TSC Emergency Notification System (ENS) Communicator

1. The TSC ENS Communicator reports to the TSC Operations Coordinator and maintains communications with the NRC . 93 Revision:

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• 6.6.11 6. 6 .12

• AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN !Page 33 of TSC Radiological

1. The TSC Radiological Coordinator reports to the Site Emergency Manager and is responsible for preventing or minimizing direct exposure to, or ingestion/inhalation of, radioactive materials during a radiological emergency.

Responsibilities are as follows: 2 . o Monitoring Dose rates and dose projections o Monitoring Radiological survey teams' results o Assists the On-site Emergency Manager in the formulation of recommended protective actions o Monitoring Personnel radiation exposures to ensure they are maintained in accordance with lOCFR 20 limits unless otherwise authorized by the Emergency Manager o Provides radiological data and concerns to plant teams for the team briefs The TSC Radiological Coordinator will transfer off-site duties to the EOF when the EOF is activated.

TSC Administrative Coordinator

1. The TSC Administrative Coordinator reports to and assists the Site Emergency Manager to ensure that emergency notifications are performed.

The TSC Administrative Coordinator is responsible for logistical support in the areas of TSC personnel, Control Room, procurement and warehouse

support, communications support and equipment repair services.

2. After EOF activation, the TSC Administrative Coordinator directs requests for logistical support beyond on-site staff capabilities to the EOF Administrative Coordinator.

TSC Team Director

1. The TSC Team Director reports to the TSC Maintenance Coordinator and provides advice on all matters concerning Emergency Response Team activities.

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18A Information Use 6.6.13 6.6.14 6.6.15 AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Page 34 of Maintenance Coordinator

1. The Maintenance Coordinator reports to the Site Emergency Manager and directs the Maintenance Assistant in the coordination of emergency team activities.

The Maintenance Coordinator also directs the formation of teams to be assigned to search and rescue. Operations Communicator

1. Provides data, progress and plant conditions from the Control Room via the Operations Recorders.

Additional Personnel 1 . The following are examples of positions that are not needed for activation and operation of the TSC but supplement those personnel which are essential to an emergency response:

o Operations Recorder maintains the Operations Status Board current . o Team Communicator reports to the Team Director and is responsible for communicating with On-site Teams. o Emergency Response Team Members perform tasks as assigned by the Maintenance Assistant.

o Administrative Assistants perform facility accountability, assist the Emergency

Manager, faxing and copying, log keeping, and Off-site notifications and communications as directed.

o Security Coordinator maintains a line of communications between the TSC and Security to cover security concerns.

93 6.7 Operations Support Center (OSC) Organization 6.7.1 Maintenance Assistant

1. The Maintenance Assistant reports to the Maintenance Coordinator and coordinates emergency repair and damage control activities, coordinates deployment of on-site teams, and coordinates the activities of the Maintenance Planners.

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18A Information Use 6.7.2 6.7.3 AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN IP age 35 of Emergency Response Team (ERT) 1. The ERT personnel may be selected from Health Physics Technicians (Tech), Chemistry Tech, and Instrumentation and Control, Mechanical, or Electrical Maintenance.

The ERT reports to the Maintenance Assistant and is responsible for repairs,

surveys, sampling,

analysis, and search and rescue. Additional Personnel

1. The following are examples of positions that are not needed for activation and operation of the OSC but supplement those personnel which are essential to an emergency response.

o Chemistry Technicians perform emergency chemical sampling and provide post-accident sample analysis.

o Maintenance Planners develop repair plans for use by the emergency repair and damage control teams . o Warehouse Support Personnel assist in locating and securing parts and equipment from the warehouse.

93 6.8 Emergency Operations Facility (EOF) Organization 6.8.1 EOF activation will be performed as soon as practical and within a goal of 90 minutes of a declaration of an Alert or higher Emergency.

1. The EOF is considered activated when the following positions are present, the Off-site Emergency Manager determines facility readiness, and declares the facility activated:

2. o Off-Site Emergency Manager o EOF Operations Coordinator o EOF Administrative Coordinator o EOF Radiological Coordinator o EOF Facility Technician The complete EOF organization is shown in FIGURE 4, EOF ORGANIZATION.

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• AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN 36 of Off-Site Emergency Manager 1. The Off-Site Emergency Manager will assume the command-and-control functions and direct the emergency from EOF. An assigned Off-Site Emergency Manager is available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day. 2. The Off-Site Emergency Manager is the official WCGS interface with government authorities.

The Manager may discuss events in progress with the County and State personnel present in the EOF when making decisions concerning the emergency.

Responsibilities include the following:

a. Supports and provides resources or performs tasks as requested by the Site Emergency Manager b. Directs all WCGS personnel in the EOF c. Obtains personnel and coordinates the efforts of the following:

o Emergency response personnel who perform off-site radiological

surveys, plus any other personnel deemed useful for the emergency response effort o Outside contractors and vendors, such as consultants, laboratories under contract, the Nuclear Steam Supply System (NSSS) vendor, the Architect/Engineer, and regional utilities o Additional technical resources may be called in during the emergency for further support or shift assignment on-site.

d. Coordinates with the Administrative Coordinator in the logistics effort to supply the plant with the necessary personnel and equipment

e. Briefs WCGS Executive Management on matters related to the emergency

f. Coordinates with the On-Site and Off-Site Public Information Coordinators*

(PICs) in providing technical input for news statements

g. Ensure immediate and follow-up notifications are made which provide sufficient information on emergency classification, plant status, off-site dose projections or measurements, and issue protective actions recommendations to off-site authorities responsible for off-site emergency measures 93 Revision:

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• AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN 3. Page 37 of h. Requests federal assistance through state officials per the State Plan The following responsibilities are those of the Emergency Managers and may not be delegated.

These responsibilities may be divided between the Site and Off-Site Emergency Managers:

o Emergency classification o Protective action recommendations o Authorization for notification of off-site authorities o Authorization of emergency exposure in excess of lOCFR 20 EOF Radiological Coordinator

1. The EOF Radiological Coordinator reports to the Off-Site Emergency Manager and is responsible for radiological monitoring and dose assessment activities off-site.

Responsibilities are as follows:

o Directs and coordinates activities of the Dose Assessment Coordinator and staff o Assists the Off-site Emergency Manager in the formulation of recommended protective actions o Provides the PIC with an assessment of radiological conditions o Requests through the EOF Administrative Coordinator additional radiation monitoring equipment, instrumentation and Health Physics support personnel as necessary o Interfaces with State and County emergency response personnel who are assigned to the EOF regarding matters related to off-site radiological assessment 93 Revision:

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• 6.8.5 6. 8. 6 6.8.7 6. 8. 8

• AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN !Page 38 of EOF Team Director

1. The EOF Team Director assumes responsibility for authorizing and supervising Off-Site Monitoring Teams. The EOF Team Director directs Emergency Response Teams and advises the EOF Radiological Coordinator on radiological conditions encountered by the Teams. a. Off-Site Monitoring Team authorization should be made promptly upon activation of the EOF. b. Monitoring teams are specially trained in field sampling techniques.

Each team will be equipped with equipment capable of detecting and measuring radioiodine concentrations in the air at levels as low as 10-7 uCi/cc. c. County and State personnel may become part of the Emergency Response Teams and assist with off-site monitoring

. EOF Facility Technician

1. Reports to the EOF within a goal of 60 minutes of declaration of an Alert or higher classification to ensure the EOF is prepared and functional.

Dose Assessment Coordinator

1. Reports to the EOF Radiological Coordinator and is responsible for directing/assisting with dose projection and protective action recommendation activities.

2. Ensures the Radiological Status Board is maintained current.

Dose Assessment Technician

1. Reports to and is responsible for providing completed off-site dose projections to the Dose Assessment Coordinator.

HPN Communicator

1. The HPN Communicator reports to the EOF Radiological Coordinator and maintains communications with the NRC via the Health Physics Network (HPN) telephone.

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• AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Page 39 of EOF Operations Coordinator

1. Reports to and briefs the Emergency Manager on plant conditions and mitigative strategies.

EOF Administrative Coordinator

1. The Administrative Coordinator is responsible for coordinating, directing, and responding to requests from the ERO for administrative and logistical support.

The techniques and procedures used during this effort are adapted from normal WCGS procurement practices.

The Administrative Coordinator also ensures notifications to off-site authorities are made. Representative At County 1. The Representative at the County is located in the County Emergency Operations Center in *Burlington, KS, and reports to the Off-Site Emergency Manager.

The Representative responds to requests from County personnel for clarification or verification of data received from the TSC or EOF. Additional Personnel

1. The following are examples of positions that are not needed for activation and operation of the EOF but supplement those personnel which are essential to an emergency response.

o Team Communicators communicate with Off-Site Monitoring Teams. o Operations Recorders maintain the Operations Status Board current.

o Administrative Assistants perform facility accountability, assist the Emergency

Manager, faxing and copying, log keeping, and Off-site notifications and communications as directed

. 93

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18A AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Information Use Page 40 of 93 6.9 Public Information Organization

6. 9 .1 6.9.2 6.9.3 The Public Information Organization is activated at an Alert or higher emergency declaration.

Information released to the public during an NUE will be provided by Corporate Communications.

If deemed necessary, the Wolf Creek Public Information Facilities may be staffed to assist in releasing news statements during an NUE. Wolf Creek Public Information Officer (WC PIO) 1. The WC PIO is the public voice for plant information.

The WC PIO is responsible for ensuring the timely issuance of accurate information to the public and media during an emergency at WCGS. Public interaction may be as a formal news conference or a telephone call. 2 . a. The WC PIO coordinates with the County and State for information to be released to the public . The WC PIO has overall responsibility for the Public Information Organization.

Wolf Creek Public Information Manager (WC PIM) 1. The Wolf Creek Public Information Manager is located in the JIC and reports to the WC PIO. The WC PIM works closely with the WC PIO, On-site PIC, Off-site PIC, News Writer, and Technical Support positions to ensure that information provided the public is timely and accurate.

2. The Wolf Creek Public Information Manager has responsibility for ensuring the Public Information Organization is activated and functions as directed in EPPs. 3. During a declared emergency the Public Information Manager determines and coordinates the activation of the Joint Information Clearinghouse, Media Center, Phone Team and Media Monitoring.

The Public Information Manager operates from the appropriate Joint Information Clearinghouse

. 4. The complete Public Information organization is shown in FIGURE 5, PUBLIC INFORMATION ORGANIZATION.

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• 6. 9. 7 6. 9. 8

• AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN a? age 41 On-Site Public Information Coordinator (PIC) 1. The On-Site PIC is located in the TSC and reports to the WC PIM. The On-site PIC gathers and transmits technical information to the Joint Information Clearinghouse for use in news statements.

Off-Site Public Information Coordinator (PIC) of 1. The Off-Site PIC is located in the EOF and reports to the WC PIM. The Off-site PIC gathers and transmits information related to the health and safety of the public to the Joint Information Clearinghouse for use in news statements.

Media Center Manager (MC Manager)

1. The MC Manager is located at the Media Center and reports to the WC PIM. Responsibilities include set-up of the Media Center, leadership for the Media Registrar, AV Support, and Media Liaison and management of the media news conferences.

The Media Center Manager maintains contact with the Joint Information Clearinghouse to provide news conference schedules.

Media Liaison 1. Media Liaison is located in the Media Center and reports to the MC Manager.

Responsibilities include managing the media crowd at the Media Center and assisting the media with registration and facility orientation, providing general Wolf Creek background information or approved emergency-related information, arranging individual interviews, and announcing and coordinating scheduled news conferences.

News Writer 1. The News Writer reports to and provides support for the WC PIM. The News Writer provides support to the PIO including:

answering telephones, writing and distributing news statements.

The News Writer maintains a chronological log of the events and news statements.

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• AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN !Page 42 of Phone Team Manager 1. The Phone Team Manager reports to the WC PIM and coordinates the rumor control activities of the Phone Team. Technical Support 1. The Technical Support staff discusses technical details of the news statement with EOF staff to ensure accuracy, updates the status log, maintains the media status board and provides technical interpretation for the Wolf Creek, Coffey County, and State of Kansas Public Information Officers.

Technical Support gathers information from the Emergency Facilities to communicate plant, health and safety issues to the public. Representative at the State 1. The Representative at the State is located in the Kansas State Emergency Operations Center in Topeka, KS, and reports to the WC PIO. The Representative responds to requests from State personnel for clarification or verification of information pertaining to Wolf Creek . 93

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18A Information Use 6.9.12 AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN IP age 43 of Additional Personnel

1. The following are examples of additional personnel used to fill ERO positions such as clerical, log keeping, or status board posting.

Staffing of these positions does not affect the activation of the facility.

o Media Center Registrar monitors access to the Media Center, records news conference attendance, provides media packets, provides directions for telephone use and work space information to the media representatives.

o Audio/Visual Support records on video and audio tape the proceedings of news conferences presented in the Media Center. o Information Messenger performs clerical and administrative duties at the direction of the Public Information Manager.

o The Phone Team may make initial media notifications at PIO discretion, addresses media and public questions to the extent possible and reports rumors or misinformation to the Phone Team Manager.

o The Media Monitoring Team notifies the Phone Team Manager of any rumors or misinformation heard or observed from their monitoring of the media. 93 6.10 Local Off-Site Organizations 6.10.1 The Coffey County Contingency Plan for Incidents Involving Commercial Nuclear Power describes the authorities, responsibilities, and agreements to which various county agencies are a party in their response to emergencies at WCGS. Information is provided therein about the various agencies' interrelationships and support roles provided to WCGS. o The updated evacuation time estimate (ETE) report contains the evacuation times for each subzone.

(Reference 3.1.12)

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• AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Page 44 of Coffey County Commissioners 1 . 2 . 3 . The Coffey County Board of Commissioners maintains the executive authority and responsibility for planning and coordinating the county response.

They have delegated responsibilities and tasks to the local support agencies and have established operating procedures.

After declaring a State of Local Disaster Emergency, the Chairman of the Coffey County Commissioners is responsible for making the decision to activate the alert and notification system. Emergency authority, as stated in County Plan, is given in an established line of succession.

If a State of Emergency has not been declared, after receipt of notification and in accordance with the County Plan, the Chairman decides which protective actions would be o When a protective action is decided upon, the County may notify the State to activate EAS or they may activate EAS. Coffey County Sheriff's Office 1. The Coffey County Sheriff's Office provides local notification, access control, and law enforcement support in accordance with the Coffey County Plan. 2. If time does not permit, or if he is unable to contact the Chairman or other members of the County Emergency Response Organization, the County Sheriff has the authority to make protective action decisions based upon recommendations by WCGS. 3. The County Dispatcher may contact the Kansas Division of Emergency Management to activate EAS or they may activate EAS . 93 Revision:

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• AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN

4. Specific services provided by the Coffey County Sheriff's Office include:

45 of o Perform notifications as defined within the County Plan and associated implementing procedures o Provide a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day manning of communications links between the County and WCGS, and between the County and State o Implement off-site protective actions as necessary and as specified in the County Plan implementing procedures o Initiate warning and initial notification of the population

• o Direct the evacuation of specific subzones of the EPZ upon the decision to evacuate o Provide traffic control and roadblocks per implementing procedures o Obtain additional assistance as necessary to secure the evacuated areas o Control access to the County EOC Coffey County Fire District

1. 1 (CCFD) 1. Contractual arrangements have been made with the Board of Trustees of Fire District No. 1, Coffey County, KS, for the provision of fire fighting support.

Services contracted are summarized in the Letter of Agreement and maintained in an Emergency Planning file. 2. The WCGS Fire Brigade Leader is also responsible for directing all fire fighting activities on site. Once on site, Fire District members and equipment shall be escorted by Security.

Off-site Medical Treatment

1. Coffey County Hospital and Newman Memorial Hospital each have developed emergency procedures to provide guidance in the rendering of medical treatment to contaminated patients.

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• AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Page 46 of 2. Coffey County Hospital, located in Burlington, KS, approximately 9 road miles from the WCGS site, has agreed to provide aid to injured/contaminated personnel.

3. Newman Memorial Hospital serves as a backup to Coffey County Hospital and is located in Emporia, Ks, approximately 40 miles from WCGS. 4. Contaminated injured personnel transported from WCGS to off-site medical facilities are attended by personnel qualified in radiological practices.

Once the patient(s) has been stabilized, WCGS personnel survey patient(s),

attending personnel,

vehicles, and equipment to ensure they have been decontaminated in accordance with WCGS, County, or State procedures.

Coffey County Emergency Medical Service (EMS) 1. Coffey County EMS provides medical assistance and transports victims to medical facilities for personnel requiring treatment for injuries, exposure to radiation, and contamination.

WCGS notifies the Ambulance Service by telephone or through the Coffey County Sheriff's Office. 2. If conditions

warrant, any vehicle at WCGS may be used to transport affected personnel.

Radiological Emergency Assistance Center/Training Site (REAC/TS)

1. REAC/TS maintains a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Hospital Disaster Network.

Consultation is available for medical emergencies involving radiologically contaminated patients

. 93

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18A AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Information Use ['age 47 of 93 6.11 State Organizations

6. 11.1 6.11.2 The Governor, by law, is the Chief Executive Officer of the State of Kansas and is responsible for the safety and well-being of all citizens within the State. The State Plan describes the responsibilities of local, federal, state, and volunteer agencies during nuclear emergencies.

Upon declaration of a State of Disaster Emergency the State has primary responsibility for responding to an off-site nuclear emergency.

Activation of the State EOC, located in the lower level of the State Defense Building, Topeka, KS, is the responsibility of the Governor or authorized representatives, depending on the nature of the emergency.

The Kansas Division of-Emergency Management, Technological Hazards Section, provides overall coordination as the responding state agency during a Fixed Nuclear Facilities Incident.

The State of Kansas Radiological Emergency Response Plan for Nuclear Facilities describes in detail, the authorities, responsibilities, and agreements to which various state agencies of their response to emergencies at WCGS. Reference to this document is made for detailed information on each agency's interrelation and support role provided to WCGS. 1. Upon declaration of an SAE or GE representatives of Kansas Division of Emergency Management (KDEM) and Kansas Department of Health and Environment (KDHE) go to the EOF. They act as the interface between WCGS, the County, and the State .

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• AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN 48 Kansas Division of Emergency Management (KDEM) 1. The KDEM provides the following assistance:

a. Evaluates information presented by WCGS to decide off-site protective actions b. Coordinates nuclear incident response

planning, training, and notification.

Activities include:

o Notification of KDHE o Notification of Key federal and state agencies o Notification of the Governor's Office o Provides radiological monitoring coordination o Requests federal assistance and coordinates federal and state support on behalf of affected areas o Provides 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day point of contact to receive notification o Activates the State EOC o Activates the Kansas Emergency Alert System of 93 Revision:

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• AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN ' Page Kansas Department of Health and Environment (KDHE) 49 of 1. The KDHE provides assistance as described below: o Acts as the lead state agency for operational radiological emergency response o Conducts radiological monitoring in affected areas o Provides radiological advice to hospitals o Develops and establishes State PAGs o Provides information and guidance to the public about protective

actions, via the KDEM o Assesses off-site contamination of the environment o Provides technical guidance and coordination in recovery activities o Supports the development and conduct of radiological response training o Reviews, evaluates, and maintains dosimetry records for non-licensee emergency workers and other affected individuals Kansas Highway Patrol (KHP) 1. The KHP provides communications and notification support including backup notification means for the following:

o Coffey County Sheriff's Office o KDEM, Technological Hazards Section o The Governor's Office 2. The KHP augments local law enforcement in securing the area and establishing evacuation routes and providing traffic control.

3. The KHP provides self-support radiological monitoring.

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18A Information Use 6.11.6 6.11.7 AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN 50 4 . The KHP maintains emergency communications systems 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day. Kansas National Guard of 1. The Kansas National Guard may be directed by the Governor to provide assistance as needed such as the following:

o Evacuation of communities o Area security o Media Security Kansas Department of Transportation (KDOT) 1. KDOT provides assistance as follows:

o Provides emergency traffic barriers and signs o Supplements emergency traffic control o Supplies construction equipment o Provides communications support 93 6.12 Federal Organizations 6.12.1 6.12.2 6.12.3 Should an emergency situation or accident occur at WCGS, notification and reports must be made to various federal agencies and organizations, and requests for assistance may also be made. Federal Emergency Management Agency (FEMA) 1. FEMA is the lead agency supporting implementation of the state and local emergency plans. Region VII FEMA response time is estimated to be four hours. Department of Energy (DOE) 1. The DOE Radiological Assistance Program provides monitoring assistance and radiological consultation to the KDHE. The DOE provides assistance under the Nuclear/Radiological Incident Annex to the National Response Framework and responds to authorized requests for assistance by the KDHE. It is expected that initial responders, to assist with off-site radiological monitoring, will arrive within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

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• AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Page 51 of Nuclear Regulatory Commission (NRC) 1. The NRC provides advice to other federal, state, and local agencies on the radiological health consequences of various emergency protective actions.

The NRC requires notification and reports as indicated in ATTACHMENT H, REPORTING OF INCIDENTS PER 10CFR20 and as specified in the WCGS Technical Specifications.

NRC Region IV response time is estimated to be 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Licensee resources available to support the federal response include the following:

o Space and equipment in the TSC and EOF provided for key federal personnel o Telecommunications equipment at these centers is available to federal personnel for use o Parking space adjacent to the EOF provides an area for the location of federal response

vehicles, with power and sanitary services available at the EOF o Open fields west of the parking lot at the EOF provide access for helicopters o Coffey County Airport is available for air traffic Federal Radiological Monitoring and Assessment Center (FRMAC) 1. FRMAC is a federal asset available on request by the Department of Homeland Security (DHS) and state and local agencies to respond to a nuclear or radiological incident.

The FRMAC is an interagency organization with representation from the NNSA, the Department of Defense (DOD), the Environmental Protection Agency (EPA), the Department of Health and Human Services (HHS), Federal Bureau of Investigations (FBI), and other federal agencies.

Full Federal response (FRMAC) is expected within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> . 93

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18A AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Information Use Page 52 of 93 6.13 Additional Support Agencies 6.13.1 6.13.2 Vendor and Architect/Engineers (A/E) 1. NSSS supplier, Westinghouse, is the chief vendor who may be involved with emergency response for WCGS. Westinghouse has emergency response plans which are activated upon notice and is expected to provide the following services:

o Personnel with expertise in various areas o Technical analysis o Operational analysis o Accident/transient analysis o Recommendations Regional Utility Support 1. WCGS shares the Standardized Nuclear Unit Power Plant System (SNUPPS) power-block design with the Union Electric Callaway Plant. Because of this design concept and similarity with the WCGS layout, assistance from Union Electric is possible.

A specific mutual aid agreement between WCGS and Callaway Energy Center, Ameren Missouri d/b/a Union Electric has been established.

While this assistance may be available within a short period of time, it shows greatest promise in the case of a prolonged emergency where extended, around the clock coverage is required.

The Site Emergency Manager may authorize the temporary use of this resource, should staff augmentation be necessary.

Union Electric Company is a signatory of the INPO FIXED FACILITY EMERGENCY RESPONSE VOLUNTARY ASSISTANCE AGREEMENT

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18A Information Use 6.13.3 6.13.4 AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN 53 of Institute of Nuclear Power Operations (INPO) 1. WCGS has signed the INPO FIXED FACILITY EMERGENCY RESPONSE VOLUNTARY ASSISTANCE AGREEMENT.

This agreement is by and among electric utilities which have responsibility for the construction and operation of commercial U.S. nuclear power plants. Assistance may be requested from any of the signatory companies in the form of technical and administrative aid or personnel,

facility, or equipment resources.

Requested assistance is rendered according to the agreement.

American Nuclear Insurers (ANI) 1. ANI is notified at emergency classifications of Alert or higher. ANI is available to provide insurance services as necessary.

93 6.14 Plant Monitoring 6.14.1 Nuclear Plant Information System (NPIS) 1. The integration and display of selected and critical data is performed by NPIS which is a non-safety, non-Class lE system. Isolation is provided to ensure that NPIS does not degrade the performance of safety system equipment or displays.

2. NPIS provides data storage and recall capability.

3. Certain parameters are also transmitted to the NRC Operations Center via the Emergency Response Data System (ERDS) link of NPIS. ERDS is activated through NPIS within 60 minutes of an Alert or higher classification.

4. The NPIS computer feeds key plant parameters to individual terminals in the Control Room, TSC, and via *RTime Viewer to the EOF which display data identical in accuracy, resolution, and reliability.

Support personnel may assist the Control Room staff to analyze and diagnose plant abnormalities so that mitigative action may be taken and then monitored.

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• AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Page 54 of 93 5. The Safety Parameter Display System (SPDS) provides for continuous indication of plant parameters or derived variables representative of the safety status of the plant. The primary function of the SPDS is to aid the user in the rapid detection of abnormal operating conditions.

As a plant safety information and diagnostic tool, SPDS concentrates on a minimum set of plant parameters from which the plant safety status can be assessed.

On-Site Radiological Monitors

1. Process monitors monitor the radiation intensity of materials within plant systems.

These monitors continuously

measure, indicate and record the radioactive material concentrations located within systems being monitored.

Each monitor includes an adjustable alarm to provide indication of a significant change or the existence of a concentration of radioactive material above pre-selected values. The USAR, Chapter 11.5, includes a listing and range of plant monitors.

2. The Area Radiation Monitoring System monitors provide information about radiation intensity at specific plant locations.

These monitors provide the following:

a. Warnings of excessive gamma radiation levels in areas where nuclear fuel is stored or handled b. Control Room personnel with a continuous indication of gamma radiation levels at selected locations within the various plant buildings

c. Assistance in detecting unauthorized or inadvertent movement of radioactive material in the plant, including the radwaste area d. Supplementation of other systems, such as process radiation monitoring or leak detection, in detecting abnormal migrations of radioactive material

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• 6.14.4 6.14.5 6 .14. 6

• AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Page 55 of 3. Effluent monitors provide information about the concentration of radioactive material in plant effluent pathways.

Each significant effluent pathway from the plant includes an effluent monitor to enable the quantification of the radioactive material concentration exiting the plant. Meteorological Monitoring System 1. The Meteorological Monitoring System is composed of a 90-meter instrument tower and a temperature controlled shelter at the base of the tower housing associated instrumentation and equipment.

2. The function of the meteorological system is to monitor and record meteorological conditions.

3. Information provided by instruments at the meteorological tower is available from the NPIS computer system . 4. Time interval measurements are used in calculating 15-minute averages for all parameters.

5. When needed, Meteorological data can be obtained from the National Weather Service.

Seismic Monitoring System 1. The seismic warning panel in the Control Room provides local visual and audible indication when a seismic event has occurred.

Hydrologic Monitoring

1. Hydrologic monitoring is not required as WCGS is a "dry site" as defined by Regulatory Guide 1.102. The plant site is located above the design basis flood level. Fire Protection

1. WCGS is protected by an independent fire protection system consisting of two subsystems, a detection/alarm system and a suppression system. 2. Activation of the fire systems results in an audible alarm throughout the plant. Alarms are also displayed in the Control Room. 93

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18A Information Use 6.14.7 AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Page 56 of Laboratory Facilities

1. A radiochemistry (hot) laboratory, radwaste laboratory, and turbine building chemistry laboratory are located in the power block. The chemistry shop laboratory is located in the Walter P. Chrysler Building.

Further information on on-site laboratory equipment can be found in USAR, Chapter 12.5. 2. The chemistry shop laboratory on site may be used for processing of routine and emergency field samples.

The Kansas Health and Environmental Laboratory in Topeka, KS, is available to further augment the processing of emergency samples.

3. Private laboratories under contract to WCGS or laboratories of neighboring utilities who are signatories of the INPO Voluntary Assistance Agreement may be considered for use. 93 6.15 Emergency Supplies 6.15.1 6.15.2 6.15.3 Emergency supplies include protective, communications, and radiological monitoring equipment, check sources, and other supplies.

The EPPs list emergency supplies and their' locations.

Emergency supplies are maintained, inventoried, and inspected on a quarterly basis in accordance with EPPs. The EPPs contain an inventory list of WCGS equipment for emergency supplies.

This equipment may be augmented by other on-site equipment.

Instruments are calibrated in accordance with WCGS Radiation Protection Procedures.

For any items removed from the emergency supplies for calibration or repair, an operable equivalent instrument is used to replace it. Sufficient quantities of spare instruments/equipment are on site to provide replacements

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18A AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Information Use age 57 of 93 6.16 Communications 6.16.1 6.16.2 Communication Equipment

1. Telephones provide primary communications contact with the State and County EOCs. The on-site system in the Olive Beech Building and the off-site system in EOF are powered by their own battery and charger.

The battery will supply the system if the charger fails. a. The Emergency Telecommunications System (ETS) is used for NRC communications.

b. Trunk lines are available for communications with outside agencies.

c. Cell phones or other comparable equipment are used as a backup means of communications with joint radiological monitoring teams. 2. Radio communications provide backup communications with the State and County EOCs. Fixed AC-powered transmitter/receiver units and a number of portable and hand-held units are also capable of providing fixed and mobile communications to joint radiological monitoring teams. a. Radio communication is the primary communication method for the joint radiological monitoring teams. 3. A paging system is used for initial notification of key personnel.

Pager coverage is provided in and around the cities of Burlington,

Emporia, Topeka, Ottawa and Lawrence.

Communication Dissemination

1. The methods of employee communications may be employee

meetings, announcements, or literature handouts.

2. The Public Information Organization is responsible for interfacing with the media. Communication between WCGS and media organizations are performed in accordance with EPPs.

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• AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN 58 of 3. Annually, WCGS offers the news media with the following information:

o Information concerning the emergency plan o Information concerning radiation o Facilities available for media o Points of contact for statements of public information o Differences between normal and emergency plant operations

4. Standardized public announcements for broadcast during an emergency have been written by the state, county, and WCGS and are found in the State Plan. 5. WCGS, state, and local emergency organizations provide members of the public, including transients, public education information on how they are notified and what their initial actions should be during an emergency.

a. Emergency planning information is provided within local telephone directories.

The information, developed jointly by WCGS, Coffey County and the State of Kansas, is distributed to residences of the EPZ. b. Information includes educational facts on radiation, protective

measures, special needs of the handicapped and the points of contact for additional information.

c. An annual mail-out to the public provides information regarding operation of Tone Alert Radios. 6. Emergency planning information, displayed on information boards, is provided for transients in the public use areas of John Redmond Reservoir (JRR), Coffey County Lake (CCL), and other WCGS controlled areas. Transients have access to emergency plan information within motel rooms and telephone books. 93

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18A AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Information Use Page 59 of 93 6.17 Emergency Plan Training 6.17.1 6.17.2 6.17.3 6.17.4 6.17.5 WCGS has developed an emergency preparedness training program which meets the requirements of 10CFR50, Appendix E, Section IV. F. The Superintendent Emergency Planning ensures required training is provided for ERO personnel in accordance with plant procedures.

The Superintendent Emergency Planning ensures corrective actions for any Emergency Planning weakness or deficiencies identified are in{tiated and corrected using the WCGS corrective action process.

Personnel receive general RERP training as a portion of Plant Access Training prior to receiving unescorted access to WCGS. Initial and re-qualification training is provided for personnel on the ERO. This training may be in the form of self study, class room training, drills, tabletops, or any combination of these. 1. Position specific training is provided for personnel filling positions in the following areas: o Managers/Coordinators of the emergency o Personnel responsible for accident assessment o Radiological monitoring teams o Fire brigade members o Emergency response teams o Medical support personnel o Security personnel o Support personnel

2. Critiques are performed after each training class to identify weak or deficient areas .

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18A Information Use 6.17.6 6.17.7 AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN 60 of Where Letters of Agreement exist between WCGS and local agencies and for each off-site response organization's emergency support role, training is offered annually.

Training is also offered to the participants in the Interlocal Agreement between Coffey County and host county Lyon. 1. This training consists of an orientation to plant operations and site access procedures, basic radiation protection and monitoring information, procedures for notification, an overview of the ERO duties and activities, and training materials associated with performance of their expected roles. Drills are considered part of the Emergency Plan Training Program.

Periodic drills conducted between the biennial exercise ensure that the ERO is capable of executing the principal functional areas of emergency response including activities such as management and coordination of emergency

response, accident assessment, event classification, notification of off-site authorities, assessment of the on-site and off-site impact of radiological

releases, protective action decision making, plant system repair and mitigative action implementation.

1. State and County participation in drills will be allowed if they so desire. 93 6.18 Emergency Plan Drills 6.18.1 6.18.2 6.18.3 Annual communication drills between WCGS, State and County EOCs, and field assessment teams ensure that contact can be made and that messages are comprehended.

1. Monthly communication tests verify communications with the local County and State authorities.

Communications tests are made with the NRC Headquarters via the Emergency Telecommunications System (ETS). These tests are performed in accordance with EPPs. Fire drills are conducted in accordance with plant administrative procedures

. Annual medical emergency drills include transportation and treatment of simulated contaminated individuals by ambulance and off-site medical treatment facilities.

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18A Information Use 6.18.4 6.18.5 6.18.6 6.18.7 6.18.8 AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN 61 Annual radiological monitoring drills include collection and analysis of sample media, field activities, and provisions for communications and record keeping.

of 93 Semi-annual Health Physics drills involve response to and analysis of simulated elevated airborne and liquid samples and direct radiation measurements in the environment.

Each calendar

quarter, a callout drill is conducted to verify the operability of the notification system. Critiques are conducted following each drill to identify and correct noted weaknesses and deficiencies.

Terrorist-based-event drills will be conducted as directed by FEMA and the NRC. [Commitment Step 3.2.4] 6.19 Emergency Planning Exercises 6.19.1 6.19.2 6.19.3 In accordance with 10CFR50 Appendix E, Section IV.F, emergency exercises will test the adequacy of timing and content of implementing procedures and methods, test emergency equipment and communication

networks, test the public notification system, and ensure that ERO personnel are familiar with their duties. Exercises will be conducted biennially to test the on-site and off-site emergency plans. Exercises ensure that the ERO is capable of executing the principal functional areas of emergency response including activities such as management and coordination of emergency

response, accident assessment, event classification, notification of off-site authorities, assessment of the on-site and off-site impact of radiological

releases, protective action decision making, plant system repair and mitigative action implementation.

To meet NRC and FEMA requirements, the exercises are varied so as to test, at least once every eight years, all major components of the WCGS, State, and County plans and response organizations.

The State and County actively participate in these exercises.

Revision:

18A Information Use

• 6.19.4

• 6.19.5 6 .19. 6

• AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Page 62 of Each scenario variation shall be demonstrated at last once during the eight year exercise cycle and shall include, but not be limited to, the following:

1. Exercises should be conducted under various weather conditions.

2. Hostile action directed at the plant site involving the integration of off-site resources with on-site response.

3. An initial classification of or rapid escalation to a Site Area Emergency or General Emergency.

4. No radiological release or an unplanned minimal radiological release that requires the site to declare a Site Area Emergency, but does not require declaration of a General Emergency.

5. Implementation of strategies, procedures and guidance developed under 10 CFR 5 0 . 5 4 ( hh) ( 2 ) . 6. Start a drill or exercise between 6:00 p.m. and 4:00 a.m. Some drills or exercises should be unannounced.

7. Large radiological release requiring ingestion pathway protective actions beyond the 10 mile EPZ. Terrorist-based-event exercises will be conducted as directed by FEMA and the NRC. [Commitment Step 3.2.4] Designated observers from federal, state, local governments, and WCGS observe the required exercises.

Certain of these observers also evaluate the exercise.

1. The Superintendent Emergency Planning has the lead responsibility for ensuring corrective actions associated with emergency planning are initiated.

2. Critiques are conducted following each exercise to identify and correct noted weaknesses and deficiencies.

93

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18A Information Use 6.19.7 6.19.8 6.19.9 6.19.10 AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Page Prior to an exercise a scenario package is prepared which contains the following:

63 o Basic objective of each exercise and appropriate evaluation criteria that support demonstration of key skills in principle functional areas o Simulated events of o Dates, time periods, places, and participating organizations o Time schedule of all initiating events o Descriptive scenario addressing the conduct of the exercise which should include public information activities, off-site fire department assistance, simulated casualties, rescue of personnel, use of protective clothing and radiological monitoring teams o Description of the arrangements for, and advance materials to be provided to official observers Records of exercises conducted during the eight year cycle shall be maintained that document the content of scenarios used to comply with scenario variation requirements.

The exercise scenario shall be submitted to the NRC under 10 CFR 50.4 at least 60 days prior to the evaluated exercise.

Remedial exercises will be conducted for exercises which do not satisfactorily test the emergency response plan as determined by FEMA and the NRC. 93 6.20 Emergency Plan and Procedures Administrative Controls 6.20.1 The Quality Assurance Organization is responsible for assuring that a review of the WCGS Emergency Planning and Preparedness Program will be performed, at least once every twelve months, in accordance with lOCFR 50.54(t).

1. Personnel performing this review will have no direct responsibility for implementation of the Emergency Planning and Preparedness Program.

Revision:

18A Information Use

• 6.20.2

• 6.20.3 6.20.4 6.21 Recovery 6.21.1 6.21.2

• AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Page 64 2. The review shall evaluate interfaces with state and local governments, licensee drills, exercises, capabilities, procedures and emergency facilities.

3. The results of the review are reported to owner representatives and WCGS Senior Management and shall be retained for at least five years. 4. Correction of review findings are evaluated and implemented using normal WCGS procedures.

5. The applicable portions of the review shall be made available to the State and local governments.

of The Superintendent Emergency Planning ensures the coordination and documentation of RERP reviews and revisions and the RERP distribution.

The RERP is revised annually to incorporate changes identified during drills, exercises and the lOCFR 50.54(t) review . 1. The RERP and approved changes are distributed to all organizations and individuals with responsibility for implementation of the RERP. The Superintendent Emergency Planning ensures emergency planning personnel are properly trained.

Action period period Plan items required to be performed in a time are allowed a 1.25 times frequency grace to complete the item. The Recovery Plan is activated in a progressive manner when the Site, if EOF not activated, or Off-Site Emergency Manager determines stabilized plant conditions warrant the transition of the emergency response efforts to the recovery phase. IF a General Emergency has been reached, THEN NRC and KDEM concurrence shall be obtained prior to downgrading

. 93

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18A Information Use 6.21.3 6.21.4 6.21.5 7.0 RECORDS 7.1 None 8.0 FORMS AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Page 65 The EPPs provide the general plans for reentry and recovery and describe the means by which decisions to relax protective measures are reached.

1. Evaluation of the status of the three fission product barriers is used for de-escalation.

As the situation improves and barriers are restored, the next lower level of event may be declared.

2. De-escalation may also occur if conditions have stabilized such that the potential for re-escalation to a higher level has been removed and a controlled situation exists. A declaration of de-escalation is provided by the Emergency Manager based on known information and recommendations of the ERO. of 3. Guidelines are provided for Reentry Team(s) to perform surveys and monitoring activities to be employed for initial reentry.

During the recovery process the normal procedures employed for configuration

control, reporting, interfaces with regulatory agencies and support groups, exposure

control, environmental monitoring, and procurement of supplies and services shall be utilized.

The Recovery Plan utilizes the necessary technical, administrative, managerial and support personnel that may be required for the recovery phase of emergency

response, as determined by Site or Off-site Emergency Managers.

The responsibilities and functions of the Emergency Managers and staff are detailed in the EPPs. 93 8.1 APF-06-002-01, EMERGENCY ACTION LEVELS Revision:

18A AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Information Use !Page 66 of 93

• ATTACHMENT A (Page 1 of 1) *EFFECTIVE 10-MILE EPZ POPULATION Distance (miles) And Significant Approximate Direction From The Site Population Centers Population Sub zone To Population Center Burlington, KS 2,674 SW-1 3.5 Southwest New Strawn, KS 394 W-1 3.4 West-Northwest

Waverly, KS 592 NE-2 11. 5 North-Northeast LeRoy, KS 561 SE-3 11.1 South-Southeast Aliceville, KS 40 SE-2 9.3 Southeast

• Ottumwa, KS 20 NW-1 6.8 West-Northwest Sharpe, KS 10 N-1 2.4 North Jacob's Creek 70 W-2 10.0 West The city population numbers were taken from the 2010 census. --I -END-* 11

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18A AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Information Use age 67 of 93 ATTACHMENT B (Page 1 of 2) SUBZONE EVACUATION TIMES B.1 Table B.1 lists each subzone and the population in that subzone.

TABLE B.1 POPULATION BY SUB ZONE Evacuation Sub zone Evacuation Zone Population Center (CTR) 0 -2 132 North-1 (N-1) 2 -5 27 Northeast-1 (NE-1) 2 -5 48 East-1 (E-1) 2 -5 62 Southeast-1 (SE-1) 2 -5 57 South-1 (S-1) 2 -5 45 Southwest-1 (SW-1) 2 -5 2,854 West-1 (W-1) 2 -5 480 Northwest-1 (NW-1) 2 -5 112 North-2 (N-2) 5 -10 163 Northeast-2 (NE-2) 5 -10 682 Northeast-3 (NE-3) 5 -10 115 East-2 (E-2) 5 -10 54 Southeast-2 (SE-2) 5 -10 124 Southeast-3 (SE-3) 5 -10 662 Southeast-4 (SE-4) 5 -10 45 South-2 (S-2) 5 -10 81 Southwest-2 (SW-2) 5 -10 137 West-2 (W-2) 5 -10 167 Northwest-2 (NW-2) 5 -10 149 B.2 Total Coffey County population equals 8,601 persons (2010 census).

• Effective 10-Mile Emergency Planning Zone Subtotals are as follows:

0 Effective 0 mile zone = 8 persons 0 Effective 2 mile zone = 3,345 persons 0 Effective 5 10-mile zone 2,843 persons 0 Effective 0 mile zone = 6,196 persons B.3 Table B.2 lists evacuation confirmation time parameters.

TABLE B.2 EVACUATION CONFIRMATION TIME PARAMETERS Speed Vehicles EPZ Miles Number of Between Effort in Assumed Confirmation Location Traveled Houses Houses Vehicle Available Time Burlington 36 1,183 5 mph 105 Hrs 11 9.5 Hrs New Strawn 3 229 5 mph 20 Hrs 3 6.6 Hrs LeRoy 9 289 5 mph 43 Hrs 5 8.6 Hrs Waverly 7 280 5 mph 33 Hrs 4 8.3 Hrs Remaining EPZ* 289 649 30 mph 80.5 Hrs 8 10.3 Hrs

• Includes the evacuation confirmation of the U.S. Army Corps of Engineers areas at John Redmond Reservoir, Coffey County Lake, and the U.S. Fish and Wildlife Service area north of the Neosho River.

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18A AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Information Use IP age 68 of 93 ATTACHMENT B (Page 2 of 2) SUBZONE EVACUATION TIMES B.4 Coffey County has Letters of Agreement or Mutual Aid Agreements with surrounding medical transport groups and the Coffey County Public Transportation to assist with transportation for ambulatory persons.

For all transportation-dependent people, including the non-ambulatory occupants of the Burlington Life Care Center, Sunset Manor Nursing Home, and the Coffey County Hospital, an evacuation time of 2.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> is estimated using area resources.

B.5 Tables B.3 and B.4 list the 10-mile evacuation times for average and adverse weather conditions.

TABLE B.3 TABLE B.4 10-MILE EVACUATION TIMES 10-MILE EVACUATION TIMES FOR AVERAGE WEATHER FOR ADVERSE WEATHER CONDITIONS (HOURS) CONDITIONS (HOURS) Sub zone Effective 10-mile Sub zone Effective 10-mile CTR 1:20 CTR 2:00 CCL 1:20 CCL 2:00 JRR 1:20 JRR 2:00 N-1 1:30 N-1 2:15 NE-1 1:20 NE-1 2:00 E-1 1:25 E-1 2:00 SE-1 1:25 SE-1 2:00 S-1 1:30 S-1 2:15 SW-1 1:45 SW-1 2:25 W-1 1:45 W-1 2:25 NW-1 1:45 NW-1 2:25 N-2 1:45 N-2 2:20 NE-2 1:40 NE-2 2:20 NE-3 1:30 NE-3 2:05 E-2 1:35 E-2 2:10 SE-2 1:35 SE-2 2:10 SE-3 1:45 SE-3 2:25 SE-4 1:40 SE-4 2:20 S-2 1:45 S-2 2:25 SW-2 1:50 SW-2 2:30 W-2 1:50 W-2 2:25 NW-2 1:40 NW-2 2:25 -END-Revision:

18A AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Information Use Page 69 of 93

• ATTACHMENT c (Page 1 of 8) CROSS REFERENCE BETWEEN NUREG 0654, RERP, & WCGS PROCEDURES 0654 RERP Comments Procedure Section Section A. -ASSIGNMENT OF RESPONSIBILITY (Organization Control) 1.a 6.5, 6.6, WCGS on-site and off-EPP 06-002, TECHNICAL SUPPORT 6.8, 6.9 site organizations CENTER OPERATIONS EPP 06-003, EMERGENCY OPERATION FACILITY OPERATIONS EPP 06-004, PUBLIC INFORMATION ORGANIZATION 1.a 6.10, Outside organizations 6.11, 6.12, 6.13 1.b 6.5 -6.13 1.c FIGURE 6 1.d 6.5, 6. 6, EPP 06-001, CONTROL ROOM 6

• 8 f 6.9 OPERATIONS EPP 06-002, TECHNICAL SUPPORT CENTER OPERATIONS

• EPP 06-003, EMERGENCY OPERATION FACILITY OPERATIONS 1.e 6.5.2 Notifications are made from the contr'ol room, at the direction of the Site Emergency Manager.

2.a & 2.b N/A 3. ATTACH. G 4. 6. 8. 2 Off-site Emergency EPP 06-003, EMERGENCY OPERATION Manager FACILITY OPERATIONS 6.6.11, Administrative EPP 06-002, TECHNICAL SUPPORT 6.8.10 Coordinators CENTER OPERATIONS EPP 06-003, EMERGENCY OPERATION FACILITY OPERATIONS B. -ON-SITE EMERGENCY ORGANIZATION

1. 6.5, EPP 06-001, CONTROL ROOM Figure 2 OPERATIONS

2. 6.5.2 Site Emergency EPP 06-001, CONTROL ROOM Manager OPERATIONS

3. 5.1.1, Transfer of control EPP 06-001, CONTROL ROOM 5. 2 .1, from the Shift OPERATIONS 6.5.2, Manager to the Site EPP 06-002, TECHNICAL SUPPORT 6.6.5, Emergency Manager.

CENTER OPERATIONS

• 6.6.5.1, EPP 06-003, EMERGENCY OPERATION 6.8.2 FACILITY OPERATIONS

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18A AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Information Use ATTACHMENT C (Page 2 of 8) Page 70 of 93 CROSS REFERENCE BETWEEN NUREG 0654, RERP, & WCGS PROCEDURES 0654 RERP Comments Procedure Section Section B. -ON-SITE EMERGENCY ORGANIZATION

4. 6.5.2, Responsibilities of EPP 06-001, CONTROL ROOM 6. 6. 5, the Shift Manager, OPERATIONS 6.8.2 Site Emergency EPP 06-002, TECHNICAL SUPPORT Manager, Off-site CENTER OPERATIONS Emergency Manager EPP 06-003, EMERGENCY OPERATION FACILITY OPERATIONS 5 6.5, 6.6, Major ERO positions EPP 06-001, CONTROL ROOM 6.7, 6.8, and their functions OPERATIONS 6.9 EPP 06-002, TECHNICAL SUPPORT CENTER OPERATIONS EPP 06-003, EMERGENCY OPERATION FACILITY OPERATIONS

6. 6.5, 6

• 6 t Interfaces between 6.7, 6.8, WCGS and outside 6.9, Fig. organizations 5 & 6 7a. 6. 8 .11 Administrative EPP 06-003, EMERGENCY OPERATION Coordinator FACILITY OPERATIONS 7b. 6.21 Recovery Plan EPP 06-003, EMERGENCY OPERATION FACILITY OPERATIONS 7c. 6.8.2 Duty Emergency Manager EPP 06-003, EMERGENCY OPERATION FACILITY OPERATIONS 7 .d 6.9 On-site & Off-site EPP 06-002, TECHNICAL SUPPORT Public Information CENTER OPERATIONS Coordinator

& Wolf EPP 06-003, EMERGENCY OPERATION Creek Public FACILITY OPERATIONS Information Officer EPP 06-004, PUBLIC INFORMATION ORGANIZATION

8. 6.13 Specify contractors I organizations available on request 9. 6.10 Identify local support agencies

c. -EMERGENCY RESPONSE SUPPORT AND RESOURCES 1.a 6.8.2 Persons authorized to request assistance l.b 6.12 Expected Federal resources

1. c 6.4.1, Space is provided for 6.4.2, NRC personnel in the 6.4.4, Control Room, TSC, and 6.12.5 EOF. The EOF also has limited space for state and local personnel.

2a. N/A Revision:

18A AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Information Use !Page 71 of 93

• ATTACHMENT C (Page 3 of 8) CROSS REFERENCE BETWEEN NUREG 0654, RERP, & WCGS PROCEDURES 0654 RERP Comments Procedure Section Section 2.b 6.8.12 0654 RERP Comments Procedure Section Section c. -EMERGENCY RESPONSE SUPPORT AND RESOURCES

3. 6.14.7 Identify radiological laboratories

4. 6.13 and Identify other ATTACH G facilities and organizations which could assist .D. -EMERGENCY CLASSIFICATION SYSTEM 1. 6.2 Emergency EPP 06-005, EMERGENCY Classifications CLASSIFICATION

2. 6.2 Initiating conditions EPP 06-005, EMERGENCY CLASSIFICATION

3. & 4. N/A

• E . -NOTIFICATION METHODS AND PROCEDURES

1. 6.3.3, Notifications EPP 06-007, EMERGENCY 6.5.2, NOTIFICATIONS 6.6.5, 6.8.2 2. 6.16.1, Notification of EPP 06-015, EMERGENCY RESPONSE 6.5.3 responding personnel ORGANIZATION CALLOUT 3. 6.3.3, Initial notifications EPP 06-007, EMERGENCY 6.5.2, NOTIFICATIONS 6.6.5, 6.8.2 ', 4.a thru 6.5.2, Follow-up Notifications EPP 06-007, EMERGENCY 4 .n 6.6.5, NOTIFICATIONS 6.8.2 5. N/A 6. 6.10.3, Evacuation times 6.3.4.3, Attach B 7. 6.16.2.4 F. -EMERGENCY COMMUNICATIONS 1.a 6.5 1.b 6.5.2 1.c 6.5.2, 6.5.4, 6.6.5,

• 6.6.9, 6.8.2 1.d 6.4.4, 6.16 1.e 6.5.3, ERO Callout EPP 06-015, EMERGENCY RESPONSE 6.16.1 ORGANIZATION CALLOUT

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18A AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Information Use ATTACHMENT C (Page 4 of 8) !Page 72 of 93 CROSS REFERENCE BETWEEN NUREG 0654, RERP, & WCGS PROCEDURES 0654 RERP Comments Procedure Section Section F. -EMERGENCY COMMUNICATIONS

1. f 6.4.4, EPP 06-001, CONTROL ROOM 6.5.2, OPERATIONS 6.5.4, EPP 06-002, TECHNICAL SUPPORT 6.6.9, CENTER OPERATIONS 6.16.1 EPP 06-003, EMERGENCY OPERATION FACILITY OPERATIONS

2. 6.10.6 3. 6.15, EPP 06-018, MAINTENANCE OF 6.18.1, EMERGENCY FACILITIES AND 6.18.6 EQUIPMENT/COMMUNICATION CHECKS G. -PUBLIC EDUCATION AND INFORMATION

1. 6.16.2 2. 6.17.5, 6.17.6 3.a 6.4.5, EPP 06-004, PUBLIC INFORMATION 6.16.2 ORGANIZATION 3 .b 6.4.5 4.a 6.9.2 EPP 06-004, PUBLIC INFORMATION ORGANIZATION 4 .b 6.9.2, EPP 06-004, PUBLIC INFORMATION

6. 9.11 ORGANIZATION 4.c 6.4.5, EPP 06-004, PUBLIC INFORMATION 6.9.10 ORGANIZATION

5. 6.16.2 H. -EMERGENCY FACILITIES AND EQUIPMENT

1. 6.4.2, EPP 06-002, TECHNICAL SUPPORT 6.4.3, CENTER OPERATIONS

6. 6, 6.7 2. 6.4.4, EPP 06-003, EMERGENCY OPERATION 6.8 FACILITY OPERATIONS

3. 6.8 Establish EOF. 4. 6. 6 .1, 6.8.1, Fig.2,3,4 ATTACH. D 5.a 6.14.3, 6.14.4, 6.14.5 5.b 6.4.1, EPP 06-011, EMERGENCY TEAM 6.4.2, FORMATION AND CONTROL 6.14.2 5.c 6.2.2, 6.14.2 5 .d 6.14.6 6.a 6.14.1 ,\

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18A AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Information Use ATTACHMENT C (Page 5 of 8) Page 73 of 93 CROSS REFERENCE BETWEEN NUREG 0654, RERP, & WCGS PROCEDURES 0654 RERP I Comments Procedure Section Section H. -EMERGENCY FACILITIES AND EQUIPMENT 6.b 6.14.1, EPP 06-011, EMERGENCY TEAM Figure 8 & FORMATION AND CONTROL Figure 9 6.c 6.14.7 7. 6.15 EPP 06-011, EMERGENCY TEAM FORMATION AND CONTROL 8. 6.14.3 9. 6.4.3 EPP 06-002, TECHNICAL SUPPORT CENTER OPERATIONS

10. 6.15 EPP 06-018, MAINTENANCE OF EMERGENCY FACILITIES AND EQUIPMENT/COMMUNICATION CHECKS 11. 6.15 12. 6.14.7 EPP 06-011, EMERGENCY TEAM FORMATION AND CONTROL I . -ACCIDENT ASSESSMENT

1. 6.2 APF 06-002-01, EMERGENCY ACTION LEVELS 2. 6. 3. 8' EPP 06-017, CORE DAMAGE 6.14.2 ASSESSMENT METHODOLOGY 3.a 6.3.7 EPP 06-012, DOSE ASSESSMENT 3 .b 6. 3. 7 EPP 06-012, DOSE ASSESSMENT

4. 6.3.7 EPP 06-012, DOSE ASSESSMENT

5. 6.14.3 6. 6.3.7 EPP 06-012, DOSE ASSESSMENT

7. 6.3.8, EPP 06-011, EMERGENCY TEAM 6.8.4 FORMATION AND CONTROL 8. 6.3.7, 6.5.2, 6.6.5, 6.8.2 9. 6.4.2, Lower bound for 6.4.4 iodine measurement capability is 1. OE-7uCi/cc.

10. 6. 3. 7 EPP 06-012, DOSE ASSESSMENT

11. 6. 3. 8 EPP 06-011, EMERGENCY TEAM FORMATION AND CONTROL J. -PROTECTIVE RESPONSE 1.a thru 6.3.10, EPP 06-010, PERSONNEL 1.d 6.3.11, ACCOUNTABILITY AND EVACUATION 6.6.5 2. 6.3.10, 6.3.11, Figure 1

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18A AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Information Use ATTACHMENT C (Page 6 of 8) IP age 74 of 93 CROSS REFERENCE BETWEEN NUREG 0654, RERP, & WCGS PROCEDURES 0654 RERP Comments Procedure Section Section J. -PROTECTIVE RESPONSE

3. 6. 3. 9, 6.3.12, 6. 4. 8' 4. 6. 3. 9, 6.3.12 5. 6.3.10, EPP 06-010, PERSONNEL 6.3.11, ACCOUNTABILITY AND EVACUATION 6.6.5 6.a thru 6.3.13, EPP 06-013, EXPOSURE CONTROL AND 6.c 6.3.14 PERSONNEL PROTECTION EPP 06-011, EMERENCY TEAM FORMATION AND CONTROL 7. 6.3.3 EPP 06-006, PROTECTIVE ACTION RECOMMENDATION

8. Attach. B 9 . N/A 10.a & Fig. 1 10.b 10.c 6.1.6, 6.1.7, 6.10.2 10.d & N/A 10.1 10 .m 6.3.4.2 EPP 06-006, PROTECTIVE ACTION RECOMMENDATION

11. & 12. N/A K. -RADIOLOGICAL EXPOSURE CONTROL 1. a thru 6.3, l.g 6. 4. 6, 6.10.5, 6.10.6 2. 6.3.15, EPP 06-001, CONTROL ROOM 6. 3 .16, OPERATIONS 6.5.2, EPP 06-002, TECHNICAL SUPPORT 6.6.5, CENTER OPERATIONS 6.8.2 EPP 06-003, EMERGENCY OPERATION FACILITY OPERATIONS 3.a & 3.b 6. 3 .16, 6.3.17, 6.3.18, 6.4.2, 6.15.1 4. N/A 5.a & 5.b 6.3.20, 6.3.21

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18A AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Information Use ATTACHMENT C (Page 7 of 8) Page 75 of 93 CROSS REFERENCE BETWEEN NUREG 0654, RERP, & WCGS PROCEDURES 0654 RERP Comments Procedure Section Section 6.a thru 6.3.21, 6.c 6.3.22, ATTACH. E 7. 6.3.13, 6. 4. 6 L. -MEDICAL AND PUBLIC HEALTH SUPPORT 1. 6.10.5 2. 6. 4. 6 3. N/A 4. 6.10.6 M. -RECOVERY AND REENTRY PLANNING AND POST-ACCIDENT OPERATIONS

1. 0 6.21 2. 6.21 EPP 06-008, RE-ENTRY,

RECOVERY,

3. 6.21 AND TERMINATION OPERATIONS

4. 6.3.7 This is not specifically identified as a post-accident function N. -EXERCISES AND DRILLS 1. a & 1.b 4.17, 6.19 2.a 6.18 2.b 6.18.2 2.c 6.18.3 2.d 6.18.4 EPP 06-009, DRILL AND EXERCISE 2.e(l) 6.18.5 REQUIREMENTS 2.e(2) 6.18.5 3.a thru 6.19.5 3.f 4. 6.19.4 5. 6.19.4 0. -RADIOLOGICAL EMERGENCY RESPONSE TRAINING 1.a 6.17 1.b N/A 2. 6.17.2, EPP 06-021, TRAINING PROGRAMS 6.17.4 3. 6.4.6 4. 6.17.4 5 . 6.17

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18A Information Use RADIOLOGICAL EMERGENCY RESPONSE PLAN ATTACHMENT C (Page 8 of 8) AP 06-002 !Page 76 of 93 CROSS REFERENCE BETWEEN NUREG 0654, RERP, & WCGS PROCEDURES P. -RESPONSIBILITY FOR THE PLANNING EFFORT: DEVELOPMENT, PERIODIC REVIEW AND DISTRIBUTION OF EMERGENCY PLANS 1. 6.17 2. 5.3, 6.17.2 3. 6.20.2 4. 6.20.2 5. 6.20.2 6. 6.10, 6.11 7. AITACH.C

8. Table of Contents and ATTACH. C 9. 6.20.1 10. 6.20.2 -END-

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18A AP 06-002

• RADIOLOGICAL EMERGENCY RESPONSE PLAN Information Use ATTACHMENT D (Page 1 of 1) WCGS MINIMUM STAFFING FOR EMERGENCIES (Reference Step 3.1.10/Step 3.1.11/)

FUNCTIONAL AREA (l) POSITION TITLE OR EXPERTISE ON SHIFT Plant Operations

& Shift Manager (SRO) 1 Assessment of Control Room Supervisor (CRS) 1 Operational Aspects Reactor Operator (RO) 2 Nuclear Station Operator 5*** Emergency Direction Site Emergency Manager 1* and Control Notification/

Emergency Communicator 2 Communication Radiological Accident Off-Site Emergency Manager and Assessment

& Support staff -of Operational Accident Assessment Sr. Health Physics Expertise

-HP Personnel 3 Chemistry Personnel 2 Plant System Shift Technical Advisor 1**** Engineering, Repair & Mitigative Actions Core/Thermal Hydraulics Eng. -Electrical Eng. -Mechanical Eng. -Radwaste Operator 1* Mechanical Maint. -Electrical Maint. 1* I&C Technician

-Protective Actions HP Personnel 1* (In-Plant)

Fire fighting

= Fire --FB per TRM Brigade(FB)

( TR5 . 2 . 1 .

b) Rescue Operations and --2* First Aid Site Access Control Security Personnel All per and Accountability Security Plan TOTAL 17 Page 77 of 93 Capability For Additions:

• • 60 mins 90 mins ----------3 --5 1 1 ---1 1 ---2 1 Local Local Support Support Local Local Support Support 25 5 May be provided by shift personnel assigned to other functions.

• • It is a goal to add, in accordance with this table, to the on-shift capabilities when determined necessary after a declared Emergency.

• • • **** May be provided by a Reactor Operator (RO) . STA is required in Modes 1-4. An SRO capable of performing STA functions required in Modes 5, 6 and defueled

. <1> Discipline-specific skills training for personnel in the above table are contained in discipline-specific training documents such as AP 30D-006, CHEMISTRY TRAINING PROGRAM and AP 30D-100, RADIATION PROTECTION TRAINING PROGRAMS.

[Commitment Step 3.2.5] -END-is Revision:

18A AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Information Use Page 78 of 93

• ATTACHMENT E (Page 1 of 2) EPA/KANSAS PROTECTIVE ACTION GUIDES E.1 Population Protective Action Guides (PAG) For Exposure To A Plume -Early Phase Protective Action PAG (Projected Dose) Comments Evacuation 1-5 rem (Note 1) Evacuation (or sheltering should normally be initiated at 1 rem. Administration of stable 5 rem (Note 3) Special Populations iodine (Note 2) (1) Dose is TEDE, which includes effective dose equivalent from external and internal sources and committed effective dose equivalent from inhalation.

Committed dose equivalents to the thyroid and to the skin may be 5 and 50 times larger, respectively.

(2) Use of KI is not planned for general population in Kansas. The State considers prompt evacuation of the public to be a more effective protective measure than administration of KI. (3) Committed dose equivalent to be thyroid from radioiodine.

E.2 Emergency Worker Dose Limits (for all types of radiological

• incidents)

E.2.1 Keep all doses ALARA and limit doses to the following TEDE levels: Dose Limit* (Rem) Activity Condition 5 All 10 Protecting valuable Lower dose not practicable property 25 Life saving or protection Lower dose not practicable of large populations

>25 Life saving or protection Only on a voluntary basis to of large populations persons fully aware of the risks involved E.3 Emergency Worker Iodine Dose Limits E.3.1 Keep all doses ALARA and limit iodine doses to the following committed dose equivalent through use of KI and/or respiratory protection:

Dose Limit (Rem) Activity 10 Any worker, any phase No Limit -Life saving No specific upper limit is given for thyroid dose activities or since in life saving activities, complete thyroid loss

• protection OI large might be an acceptable sacrifice if a life can be populations saved. However, this should not be necessary if respirators and/or thyroid protections for rescue personnel are available as.a result of adequate planning.

ll

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18A AP 06-002 Information Use RADIOLOGICAL EMERGENCY RESPONSE PLAN ATTACHMENT E (Page 2 of 2) EPA/KANSAS PROTECTIVE ACTION GUIDES lPage 79 of E.4 Protective Action Guides For Exposure To Deposited Radioactivity During the Intermediate Phase of a Nuclear Incident Protective Action PAG (Projected Comments Dose) (1) 93 Relocate the general Beta dose to skin may be up to population (2) 50 times higher. Doses in any 2 single year after the first will > rem -not exceed 0.5 rem, and the cumulative dose over 50 years will not exceed 5 rem. Apply simple dose These protective actions should reduction techniques (3) <2 rem be taken to reduce doses to as low as practicable levels (1) The projected sum of effective dose equivalent from external gamma radiation and committed effective dose equivalent from inhalation suspended materials, from exposure or intake during the first year. Projected dose refers to the dose that would be received in the absence of shielding from structures of the application or dose reduction techniques.

These PAGs may not provide adequate protection for some long-live radionuclides.

(2) Persons previously evacuated from areas outside the relocation zone defined by this PAG may return to occupy their residences.

Cases involving relocation of persons at high risk from such action (e.g. patients under intensive care) should be evaluated individually.

(3) Simple dose reduction techniques include scrubbing and/or flushing hard surfaces, soaking or plowing soil, minor removal of soil from spots where radioactive materials have concentrated, and spending more time than usual indoors or in other low exposure rate areas. -END-

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18A AP 06-002 Information Use RADIOLOGICAL EMERGENCY RESPONSE PLAN ATTACHMENT F (Page 1 of 1) USAR CHAPTER 15 POSTULATED EVENTS USAR CHAPER 15 POSTULATED EVENTS Page Feed water system malfunctions that result in decrease of feed water temperature Feed water system malfunctions that result in increase of feed water system flow Excessive increase in secondary steam flow Inadvertent opening and failure to close of SG ARV or safety vlv Steam system piping failure (inside containment)

Steam system piping failure (outside containment)

Loss of external load (Main Generator trip) Turbine Trip Inadvertent closure of MSIVs Loss of condenser vacuum & other events resulting in turbine trip Loss of non-emergency AC power to station auxiliaries Loss of normal feedwater Feedwater system pipe break Partial loss of forced RCS flow Complete loss of forced RCS flow RCP shaft seizure (locked rotor) RCP shaft break 80 of Uncontrolled RCCA bank withdrawal from a subcritical of low-power startup condition Uncontrolled RCCA withdrawal at power RCCA misalignment Startup of inactive RCP at an incorrect temperature CVCS malfunction resulting in a decrease in the boron concentration in the RCS Inadvertent loading and operation of a fuel assembly in improper position RCCA ejection accidents Inadvertent ECCS operation at power CVCS malfunction that increases RCS inventory Inadvertent

opening, with failure to close, of pressurizer safety or relief valve 93 Break in instrument line or other lines from RCS pressure boundary that penetrate containment SG tube rupture LOCA spectrum Radioactive waste gas decay tank failure Postulated radioactive releases due to liquid tank failure Fuel handling accident (inside containment)

Fuel handling accident (Fuel Building)

Spent fuel cask drop Anticipated transients without scram -END-

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• Revision:

18A AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Information Use Page 81 of 93 ATTACHMENT G (Page 1 of 1) LETTERS OF AGREEMENT Party:

• The Coffey County Sheriff's Office Board of Trustees Fire District No. 1, Coffey County, KS Newman Memorial Hospital Coffey County Hospital and EMS Topeka Air Ambulance Inc. (d.b.a. Life Star) AirMD, LLC d/b/a Life Team Wolf Creek Nuclear Operating Corporation/Callaway Energy Center, Ameren Missouri d/b/a Union Electric Co. Emergency Mutual Assistance Agreement INPO (Support During an Emergency)

Department of Energy**

Nuclear Regulatory Commission**

National Weather Service***

EPRI/INPO/NEI/Member Utilities Coordination Agreement on Emergency Information****

Westinghouse Law Enforcement*****

As of January 1, 1987, the Letters of Agreement in this Supplement are transferred from Kansas Gas and Electric Company to the Wolf Creek Nuclear Operating Corporation.

These Letters of Agreement are maintained on file and may be reviewed upon request.

• • These LOAs will not be updated.

They have been superseded by the publication of the "Federal Radiological Emergency Response Plan" in the Federal Register on 11/8/85.

• • • As of 8/25/93, the National Weather Service stated in writing that a Letter of Agreement with WCGS is unnecessary.

Their "National Plan for Radiological Emergencies at Commercial Nuclear Power Plants,"

November 1982, remains in effect. **** INPO 03-001, INPO Letter of Agreement, is maintained on the INPO web page. ***** Agreements with Law Enforcement are safeguards information and, therefore, are controlled by Security.

-END-Revision:

18A AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Information Use Page 82 of 93

• ATTACHMENT H (Page 1 of 1) REPORTING OF INCIDENTS PER 10 CFR 20 .2202 I Telephone

& Telegraph

.2203 Written Immediate 24 Hour 30 Day Notification Notification Notification RADIATION INCIDENTS VALUES WCGS NRC KDEM WCGS NRC KDEM WCGS NRC KDEM TEDE 25 REM x x x x x x (. 25 Sv) 5 REM x x x x x x (. 05 Sv) MPE .1201 x x x x Shallow dose 250 Rad x x x x x x to skin or 50 REM x x x x x x extremities in excess of MPE .1201 x x x x

• Lens dose 75 REM x x (. 75 Sv) equivalent 15 REM x x x ( .15 Sv) MPE .1201 x x x The release of 5 ALI x x x x x x radioactive 1 ALI x x x x x x material MPE .1201 x x x x inside or outside of a restricted area x = Indicates notification is required MPE = Maximum Permissible Exposure DAC = Derived Air Concentration WCGS = Wolf Creek Generating Station NRC = Nuclear Regulatory Commission KDEM = Kansas Division of Emergency Management ALI = Annual Limit on Intake -END-*

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• Revision: 18A AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Information Use Page 83 of 93 To Pff.osho Rapids Registration Center \ i FIGURE 1 EFFECTIVE 10-MILE EPZ, SUBZONES AND EVACUATION ROUTES " // / " " " " l Q " I l Q / ... .s-I T J' ,!' ,........_

I

".... _. ___ ._.. ........

\ i NW-2 N-2 -T"-1 I I I \ \ i NE-1 \ i \ i \ .,, " I " I .. NE-3 \ i " " l " I I 4'

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• Revision: 18A AP 06-002 Information Use RADIOLOGICAL EMERGENCY RESPONSE FIGURE 2 MINIMUM SHIFT STAFFING NOTE PLAN Page 84 of STA is required in Modes 1-4. An SRO capable of performing STA functions is required in Modes 5, 6 and defueled. SHIFT MANAGER (SM) (1 SRO) ENS COMMUNICATOR

( 1) OFFSITE COMMUNICATOR

( 1) , ._ _______ I I I I I I SHIFT TECHNICAL ADVISOR (STA) (1) CONTROL ROOM SUPERVISOR (CRS) (1 SRO) I I I I I I I I I f.-----_I REACTOR OPERATORS (RO) (2) CHEMISTRY TECHNICIAN (2) HEAL TH PHYSICS TECHNICIAN (3) Direction Technical Guidance SRO = Senior Reactor Operator STA= Shift Technical Advisor STATION OPERATORS (5) 1\ 93

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• Revision: 18A AP 06-002 RADIOLOGICA L EMERGENCY RESPONSE PLAN Information Use RADIOLOGICAL COORDINATOR FACILITY

-TECHNICIAN TEAM -DIRECTOR TEAM COMMUNICATOR EMERGENCY

..... RESPONSE TEAM FIGURE 3 TSC/OSC ORGANIZATION SITE EMERGENCY MANAGER MAINTENANCE ADMINISTRATIVE COORDINATOR COORDINATOR MAINTENANCE ADMINISTRATIVE

-PLANNER ASSISTANT WAREHOUSE SECURITY SUPPORT COORDINATOR MAINTENANCE

-*** ASSISTANT IP age 85 of 93 OPERATIONS COORDINATOR ENS >---COMMUNICATOR OPERATIONS

,_____ >---RECORDER ENGINEERING

... ***** ....... ....____

COORDINATOR LOCATED IN CONTROL ROOM I .........

. OPERATIONS ENGINEERING COMMUNICATOR TEAM

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• Revision: 18A AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Information Use OPERATIONS COORDINATOR OPERATIONS RECORDER LOCATED AT COUNTY EOC REPRESENTAT IVE AT COUNTY FIGURE 4 EOF ORGANIZATION OFF-SITE EMERGENCY MANAGER HPN COMMUNICATOR DOSE ASSESSMENT COORDINATOR I DOSE ASSESSMENT TECHNICIAN RADIOLOGICAL COORDINATOR FACILITY TECHNICIAN TEAM DIRECTOR

-TEAM COMMUNICA TOR !Page EMERGENCY RESPONSE TEAM 86 of 93 ADMINISTRATIVE COORDINATOR ADMINISTRATIVE ASSISTANT

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• Revision: 18A AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Information Use Page FIGURE 5 PUBLIC INFORMATION ORGANIZATION KGE/KCPU KEPCo REPRESENTATI VE (JIC) COFFEY COUNTY PUBLIC INFORMATION OFFICER (JIC) I REPRESENTATIVE TO THE STATE (SEOC) I WOLF CREEK PUBLIC INFORMATION OFFICER (JIC) STATE OF KANSAS PUBLIC INFORMATION OFFICER (JIC) WOLF CREEK PUBLIC INFORMATION MANAGER (JIC) I FEMA PUBLIC INFORMATION OFFICER (JIC) I TECHNICAL SUPPORT (JIC) NEWS WRITER (JIC) INFORMATION MESSENGER (JIC) ONSITE PUBLIC INFORMATION COORDINATOR PHONE TEAM MANAGER (JIC) PHONE TEAM (JIC) MEDIA MONITORING TEAM MEDIA CENTER MANAGER (MC) MEDIA LIAISON (MC) I MEDIA REGISTRAR (MC) I AUDIO VISUAL SUPPORT (MC) I OFFSITE PUBLIC INFORMATION COORDINATOR (EOF) (TSC) 87 of 93 NRC PUBLIC INFORMATION OFFICER (JIC)

• EMERGENCY ORGANIZATIONS INTERFACES (AT UNUSUAL EVENT LEVEL) CONTROL ROOM . . . . . . . " * * * * * * * * * * * * * * * * *

• I COUNTY EMERGENCY OPERATIONS CENTER * * * * *

• ON SITE OFFSITE (AT ALERT OR HIGHER CLASSIFICATION)

TECHNICAL/OPERATIONS

• * ' SUPPORT CENTER EMERGENCY OPERATIONS FACILITY (EOF) I STATE EMERGENCY OPERATIONS CENTER I OTHER SUPPORT STATE AGENCIES USN RC FEMA NORMAL INTERFACE TEMPORARY INTERFACE ONSITE OFFSITE

• Any of these functions may be activated at any emergency classification level. MEDIA MONITORING TEAM* I PHONE TEAM* I INFORMATION CLEARINGHOUSE

• MEDIA CENTER

• I OTHER LOCAL SUPPORT I I OFFSITE SUPPORT

• H ::0 ::l (1) Hi 0 !--'-H (/J 8 I-'-PJ 0 rt ::l I-'-.. 0 ::l f-' CXl c::: (/J (1) M 3: M ::0 G) M z () r< 5Z 0 H 0 t-< 0 G) H () 0 t-< ::0 G) 1-rj z H G) H c::: N ::0 t-,3 M H O'\ 0 M 3: M ::0 G) M z () r< z ::0 H z t-,3 M ::0 1-rj M (fJ t"rj 0 z (fJ M () M (fJ t"rj t-< z t"rj PJ (1) t"rj CXl CXl 0 O'\ 0 I Hi 0 0 I..() N w Revision: 18A AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Information Use Page 89 of 93

• FIGURE 7 WCGS EMERGENCY RESPONSE FACILITIES 0 I-w ca c: @:8 LL CJ 6.lY'IVl\>NV1 0 § 1I01nl w.., ID 1 HI

• o<> ii

---

Revision: 18A AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Information Use !Page 90 of 93

• FIGURE 8 AIRBORNE PATHWAY SAMPLING LOCATIONS Q D N E *

• FIXED SAMPLING LOCATIONS

• 1\

Revision: 18A AP 06-002 RADIOLOGICA L EMERGENCY RESPONSE PLAN Information Use Page 91 of 93

• FIGURE 9 DIRECT RADIATION PATHWAY SAMPLING LOCATIONS Q

• E

• DOSIMETER LOCATIONS

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• Revision:

18A AP 06-002 RADIOLOGICAL EMERGENCY RESPONSE PLAN Information Use IP age 92 FIGURE 10 WATERBORNE PATHWAY SAMPLING LOCATIONS Q c N WATERBORNE PATHWAY SAMPLING LOCATIONS e = DRINKING WATER * = GROUND WATER A = SURFACE WATER * = SHORELINE SEDIMENT of 93 D E

• *

• Revision: 18A Information Use 25TH RD 24TH AD 23AD AD 22No no 16TH AD ISTH AD 14TH AO 13TH AO 12TH RD 11TH AD 10TH RO 9TH RD 8TH RD 7TH RD TO MADISON -= HWY 58 4TH RD 3RD RD 2NO AD 1ST AO r \ RADIOLOGICAL EMERGENCY RESPONSE PLAN FIGURE 11 FIXED SIREN SITING SIREN LOCATIONS \ \ } f* I-' -! / -FEr1 PA.Jl(,E

.i.r / "><irtt, 1"',,*1'".fl rT ' ' \ \ \ 1 t.l*t.I" "L .!*_.r ll'L I 1:<*.*L I /I .F[H F't.J ,[ AT ,,.-,.it.

--on rr AP 06-002 Page 93 of 17TH AD 18 7s TO C3:AANETT loi;-f,D 15TH AD: E } 14TH AD -13TH RO 710125' TO -GARNETT 11TH RD F 6TH AD 5TH AD HWY 58 3AO AD 2NU AD 1$T RO 93