Text

Emergency Plan Revision 39
	ML18193A461
Person / Time
Site:	Cook
Issue date:	05/31/2018
From:	Tipton-Stone J; American Electric Power, Indiana Michigan Power Co
To:	; Office of Nuclear Reactor Regulation
References
	AEP-NRC-2018-52
	Download: ML18193A461 (214)
	v • d • e

{{#Wiki_filter:Enclosure to AEP-NRC-2018-52 DONALD C. COOK NUCLEAR PLANT EMERGENCY PLAN Revision 39 . ******-**-*-************----,* DONALD C. COOK NUCLEAR PLANT EMERGENCY PLAN REVISION 39 UNITS 1 & 2 DOCKET NOS. 50-315 & 50-316 LICENSE NO$. DPR-58 & DPR-74 Editoria Review -Kris Elliott Reviewed: ""' Emergency Preparedness Manager -Kevin Simpson Plant Operations Review Committee: Date: .f?1?<f ' l Date: s/31/;cF ~, Date: S-~t h'8 J Date: 5 /~, t*'rs Approved: Y .. ~Ch.i / 'f7 51 Date: _l!ij_tf:...=o __ P~ Meeting Number Effective Date: 06/12/2018 CEP Rev39 -' Page 1 of 212 TABLE OF CONTENTS INTRODUCTION A. Purpose ........................................................................................................... _. ............... 9 8. Objective ......................................................................................................................... 9 C. Scope .............................................................................................................................. 9 D. Organization of the Emergency Plan ............................................................................... 9 E. Definitions ..................................................................................................................... 10 PLANNING STANDARDS PAGE 13 A. ORGANIZATIONAL CONTROL A.1 Organizational Control ....................................................................................... 14 A.2 Not Applicable .................................................................................................... 15 [;..3 Agreements ............................................. ., .................................... ,., ..................... 15 A.4 Continuous Protracted Operations ..................................................................... 15 8. EMERGENCY RESPONSE ORGANIZATION 17 8.1 . Normal On-Site Operating Organization ............................................................. 18 8.2 On-Shift Emergency Coordination ...................................................................... 21 8.3 Emergency Coordination Line of Succession ..................................................... 21 8.4 Non~delegable Emergency Coordinator Duties .................................................. 21 8.5 Emergency Response Organization ................................................................... 22 8.5.a Technical Support Center ....................................................................... 22 8.5.b Operations Support Center ..................................................................... 26 8.5.c Emergency Operations Facility ............................................................... 28 8.5.d Emergency News Center/Joint Information Center ................................. 32 8.5.e Liaisons .................................................................................................. 34 8.6 Overall Organization and Communication .......................................................... 34 8.7 Plant Staff Augmentation ................................................................................... 34 8.8 Offsite Agencies and Organizations ................................................................... 35 8.9 Offsite Groups .................................................................................................... 36 C. EMERGENCY RESPONSE SUPPORT AND RESOURCES 51 C.1 Federal Radiological Assistance ........................................................................

52. C.2 Liaisons .............................................................................................................

53 C.3 Radiological Laboratories .............................................................................. -..... 54 C.4 Offsite Agencies and Organizations (non Governmental) ................................... 54 D. EMERGENCY CLASSIFICATION SYSTEM 56 D.1 Emergency Action Levels ................................................................................... 57 D.2 Initiating Conditions ............................................................................................ 58 CEP Rev 39 ! E. F. G. H. NOTIFICATION METHODS AND PROCEDURES Page 2 of 212 70 E.1 Notification of Offsite Response Organizations .................................................. 71 E.2 ERO Alert, Notification and Mobilization ............................................................. 72 E.2.a Onsite (Plant Staff) ................................................................................. 72 E.2.b Offsite (Plant Staff) ................................................................................. 73 E.3 Content of Initial Emergency Messages ............................................................. 7 4 E.4 Content of Follow-up Emergency Messages ...................................................... 74 . E.5 Not Applicable (State and Local Public Information System) .............................. 75 E. 6 Public Notification .............................................................................................. 75 E. 7 Public Information Messages ............................................................................. 76 EMERGENCY COMMUNICATIONS 79 F.1 Licensee, Local, State, and NRC Emergency Communications ......................... 80 F .2 Medical Support Communications ...................................................................... 83 F .3 Communications Systems Testing ..................................................................... 83 PUBLIC EDUCATION AND INFORMATION 85 G .1 Public Information ............................................................................................... 86 G.2 Distribution of Public Information ........................................................................ 86 G.3 Emergency News Center/Joint Information Center ............................................. 87 G.4 ENC/JIC Spokespersons and Public Inquiry ..... , ................................................ 87 G.5 Annual Media Briefing ..................................................... '. .................................. 87 EMERGENCY FACILITIES AND EQUIPMENT 88 H.1 Technical Support Center (TSC) ...............................

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89 H.2 Emergency Operations Facility (EOF) ................................................................ 92 H .3 Operations Support Center (OSC) ..................................................................... 94 H.4 AEP Emergency Organization Staffing and Activation ....................................... 96 H.5 Emergency Detection .......................................................................................... 96 H.6 Offsite Monitoring and Analysis Equipment.. .................................................... 101 H. 7 Radiological Environmental Monitoring ...............

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102 H.8 Meteorological System ......................................................... '. ...........

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102 I. ACCIDENT ASSESSMENT . 106 1.1 Release Identification and Event Classification ................................................ 107 1.2 Radiation Monitoring System ........................................................................... 107 1.3 Release Source Term and Magnitude Determination ....................................... 107 1.4 Dose Assessment Evaluation .......................................................................... 108 1.5 Meteorological Assessment ............................................................................. 109 1.6 Not Addressed ....... : .............................

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109 I. 7 Radiological Field Monitoring ........................................................................... 109 1.8 Liquid and Gaseous Release Assessment ....................................................... 109 1.9 Off-site Radio iodine Monitoring .................................

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109 1.10 Not Addressed ................................................................................................. 109 CEP Rev 39 J. PROTECTIVE RESPONSE Page 3 of 212 110 J.1 Owner Controlled Area Warning and Advisement......................................... 111 J.2 Evacuation Routes ........................................................................................... 111 J.3 Evacuee Monitoring ......................................................................................... 112 J.4 Evacuee Decontamination ............................................................................... 112 J.5 Personnel Accountability .................................................................................. 112 J.6 Protective Measures for Those Remaining, or Reporting to the Site ................ 113 J.7 Off-Site Protective Actions ............................................................................... 114 J.8 Evacuation Times ............................................................................................ 114 J.9 Not Applicable .................................................................................................. 114 J.10 Plume Exposure Pathway Protective Measures Implementation ...................... 115 K. RADIOLOGICAL EXPOSURE CONTROL 117 K.1 Emergency Exposure ....................................................................................... 119 K.2 Emergency Exposure Authorization and Control. ............................................. 119 ~K.3 Emergency Personnel Dosimetry ..........*.....................................*..................... 119 K.4 Not Applicable .................................................................................................. 120 K.5 Decontamination .............................................................................................. 120 K.6 Contamination Control ..................................................................................... 120 K.7 Decontamination of Relocated Onsite Personnel ............................................. 121 L. MEDICAL AND PUBLIC HEAL TH SUPPORT . 123 L.1 Offsite Medical Support .................................................................................... 124 L.2 Onsite Medical Support .................................................................................... 125 L.3 Not Applicable .................................................................................................. 125 L.4 Victim Transport ............................................................................................... 125 M. RECOVERY AND RE-ENTRY PLANNING AND POST ACCIDENT OPERATIONS 126 M.1 Reentry and Recovery ...................................

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127 M.2 Not Addressed ..............................................................................

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128 M.3 Recovery Initiation Notification ......................................................................... 128 M.4 Not Addressed ................................................................................................. 128 N. EXERCISES AND DRILLS 129 N .1 Exercises ......................................................................................................... 130 N.2 Drills ................................................................................................................. 130 N.3 Drill and Exercise Execution ............................................................................ 131 N.4 Official Observation and Critique ...................................................................... 132 N.5 Results Evaluation and Corrective Actions ....................................................... 132 0. RADIOLOGICAL EMERGENCY RESPONSE TRAINING 133 0.1 Organization Training ....................................................................................... 134 0.2 Onsite ERO Training ........................................................................................ 134 0.3 First Aid Team Training .................................................................................... 134 0.4 ERO Training and Qualification ........................................................................ 134 0.5 Initial and Annual Retraining ............................................................................ 136 CEP Rev 39 P. RESPONSIBILITY FOR PLANNING EFFORT Page 4 of 212 137 P.1 Emergency Planner Training ............................................................................ 138 P.2 Emergency Plans Administration Responsibility ............................................... 138 P.3 Emergency Planning Coordinator Designation (Not Addressed) ...................... 138 P.4 Periodic Reviews, Updates, and Audits ............................................................ 138 P.5 Emergency Plan Change Communication ........................................................ 138 P.6 Emergency Response Organization Support Plans .......................................... 139 P. 7 Implementing Procedures ................................................................................ 139 P. 8 Table of Contents & Cross-reference ............................................................... 139 P.9 Independent Emergency Program Review ....................................................... 139 P.10. ERO Telephone Number Updates ................................................................... 139 CEP Rev 39 APPENDICES A. 1. 2. Page 5 of 212 Index of Emergency Plan Implementing Procedures ........................................ 141 Cross Reference CEP and Emergency Plan Implementing Procedures ........... 142 B. Agreements with Off-Site Support Agencies ...................................

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148 C. Emergency Kits and Equipment Locations .................................................................. 166 D. Emergency Preparedness Brochure ............................................................................ 168 E. Description of Federal Radiological Assistance ........................................................... 181 F. Berrien County Road Map ........................................................................................... 189 G. Population Distribution ................................................................................................ 191 H. Radiological Response Support Service Capabilities ............................ ...................... 193 I. Notification of American Nuclear Insurers .................................................................... 195 J. Eight Year Plan Matrix ................................................................................................. 199 K. Agreements with Off-Site Agencies, Hazardous Material Spills ***:***** .......................... 202 CEP Rev 39 Page 6 of 212 LIST OF FIGURES Figure TITLE Section Page 1. Michigan Nuclear Accident Response Organization A 16 2. Management Structure of the Nuclear Generation Group B 42 3. Site Operations B 43 4. On Shift Emergency Response Organization B 44 5. TSC Organization B 45 6. OSC Organization B 46 7. EOF Organization B 47 .. 8. CNP Emergency News Center/ Joint Information Center Organization B 48 9. Nuclear Incident Initial Notification Process E 77 10. CNP Emergency Response Communications flow E 78 11. Locations of Emergency Response Centers H 103 12. CNP Emergency Response Center Locations H 104 13. Primary Evacuation Routes J 116 14. Accident Notification Procedures for ANI Insurers Appendix I 198 CEP Rev 39 LIST OF TABLES 1. Cook Nuclear Plant Minimum Staffing for Nuclear Power Plant Emergencies

2. Fission Product Barrier Matrix -Mode 1-4 3. Initiating Conditions, Mode 1-4 4. Initiating Conditions, Modes 5-6 and Defueled 5. Critical NUREG 0737 Parameters

6. Maximum Allowable Contamination Limits for On Site Facilities Used by the Publif Page 7 of 212 Section Page B 49 D 58 D 61 D 66 H 105 K 122 CEP Rev 39 Page 8 of 212 INTRODUCTION Introduction CEP Rev 39 Page 9 of 212 INTRODUCTION A. B. Purpose The purpose of the Cook Nuclear Plant Emergency Plan is to fulfill the requirements as set forth in 1 O CFR 50,. Appendix E, and the planning objectives set forth in NUREG-0654/FEMA-REP-1 Revision 1. Objective

The Cook Nuclear Plant Emergency Plan has the fundamental objective of protecting the health and safety of the* general public, persons temporarily visiting or assigned to the reactor facility, and employees of the. plant. C. Scope D. _ The specific details for the implementation

_of this emergency plan_are incorporated in the Cook Nuclear Plant Emergency Plan Procedures pursuant to the requirements specified in "Purpose", above. The Cook Nuclear Plant Emergency Plan applies to both .of the nuclear units and the on-site Independent Spent Fuel Storage Installation (ISFSI). The Emergency Plan procedures include or reference procedures developed for plant operating, radiological, security, and administrative functions as necessary to ensure that all requirements are adequately defined. Appendix A to this Plan contains a list of Plant Emergency Plan Procedures. This plan is primarily concerned with an accidental release of radioactive material, but it is also concerned with major non-nuclear accidents which could prove hazardous to the safe operation of the plant. This includes supplementing our procedures for responding to hazardous material spills to meet

Michigan Hazardous Waste Operations and Emergency Response (HAZWOPER) and hazardous waste regulations.

Organization of the Emergency Plan The information describing the D.C. Cook Nuclear Power Plant Emergency Plan follows the numerology of NUREG-0654/FEMA-REP-1, Revision 1. The organization of NUREG-0654/FEMA-REP-1, Revision 1 sequences evaluation criteria by subject. Some criteria apply to licensee only, and some apply to offsite organizations only. The result is that there would be gaps in the Emergency Plan numbering if the licensee only criteria were listed. When this occurs the NUREG numbering is maintained by listing the criteria number and labeling it as Not Applicable. Some criteria in the Emergency Plan are not addressed. Again, to maintain the NUREG numbering the criteria is listed but is labeled as Not Addressed. Introduction CEP Rev 39 Page 10 of 212 E. Definitions

1. Berrien County Emergency Operations Center (BCEOC) This facility provides an area to coordinate efforts of local agencies and organizations involved in the emergency response.

It is a center established and controlled by the Berrien County Sheriffs Department and is located in St. Joseph, Michigan.

2. Civil* Disturbance One or more persons violently protesting plant operations or activities at the site. 3. Confinement Boundary The barrier(s) between areas containing radioactive substances and the environment.

4. Control Rooms Control and monitoring functions for Units 1 and 2 are provided for in separate Control Rooms. Each Control Room has a controlled access entrance located off the turbine building main operating floor at Elevation 633'. Personnel a~signed to the Control Rooin during the emergency will be as indicated in Figure 4 (until the Technical Support Center is activated).

Should conditions require the presence, in the Control Room, of personnel other than those listed in Figure 4, approval must be obtained from the Shift Manager or his alternate.

5. Cook Nuclear Plant Procedures Documents defining the details* necessary to specify manipulation of controls and equipment to place the facility in a safe condition and to prescribe other appropriate protective measures to be taken by employees of the licensee.

6. Emergency Action Levels Radiation dose rates; specific levels of airborne, waterborne,

or surface-deposited concentrations of radioactive materials; or specific instrument indications (including their rates of change) that may be used as thresholds for designating the appropriate class of emergency.

7. Emergency News Center (ENC) The Emergency News Center is located in the Nuclear Generation Group Headquarters Building located approximately 14 miles southeast of the Plant in Buchanan, Michigan:

This facility will provide for dissemination of emergency information to the news media prior to activation of the Joint Information Center. 8. Emergency Operations Facility (EOF) This facility is in the Nuclear Generation Group Headquarters Building located approximately 14 miles southeast of the Plant in Buchanan, Michigan. This facility is activated at the declaration of an

Alert, or higher, emergency classification.

The EOF houses the support personnel whose primary responsibilities are to assist in offsite dose assessment and protective action recommendations, communication with offsite agencies, exposure control, technical support of plant operations and other related activities. Representatives from various support agencies and groups may use this facility as a working space to prepare short and long term plans and procedures to mitigate the incident.

9. Emergency Plan Implementing Procedures (EPIP's) The specific procedures that provide instructions, identify responsibilities, and implement the emergency plan. A list of Emergency Plan Procedures is contained in Appendix A. Introduction CEP Rev 39 Page 11 of 212 10. HAZMAT Team The hazardous material spill response team (HAZMAT Team) is a group of plant personnel designated to respond to emergencies involving hazardous materials.

They are trained as required by Michigan Hazardous Waste Operations and Emergency Response (HAZWOPER) rules and respond to emergencies using spill pre-plan procedures. The Shift Manager, or a qualified Incident Commander, will act as the lnc:ident Commander in charge of the plant spill response. A designated HAZMAT Team Safety Officer will have responsibility for the on-scene safety of response personnel.

11. Hostile Action An act toward a Nuclear Power Plant (NPP) or its personnel that includes the use of violent force to destroy equipment, takes hostages, and/or intimidate 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 or ISF.SI. Non-terrorism-based EALs should be used to address such activities, (e.g., violent acts between individuals in the owner controlled area.) 12. Hostile Force One or more individuals who are engaged in determined assault, overtly. or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.

13. Independent Spent Fuel Storage Installation (ISFSI) A complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage. 14. Joint Information Center (JIC) This facility is operated by AEP personnel for the purpose of disseminating information to the news media, conducting press briefing and as an area where the representatives from various emergency response organizations can meet, review, and release material to the press. The JIC uses the same facilities as the Emergency News Center (ENC). 15. NRC Licensed Personnel Those plant personnel holding current operator's or senior operator's licenses from the United

States Nuclear
Regulatory Commission as defined in 10 CFR Part 55. 16. Off-Site means outside the area which is under the control of Cook Nuclear Plant. 17.. Off-Site Survey Teams These are teams of personnel assigned to monitor radiological parameters anywhere outside of the plant protected area* or the ISFSI protected area. At least one member of the team shall be trained in radiation protection.

18. On-Site defined as the owner controlled area inclusive of the protected area and all property outside the plant protected and ISFSI protected areas but under the control of Cook Nuclear Plant. Introduction CEP Rev 39

19. 20. 21. 22. 23. 24. Page 12 of 212 Operations Support Center (OSC) This area is located in the basement/shelter area of the plant's lakeside office building.

The OSC is the area that will house the operations support personnel for assignment to respond to Control Room and Technical Support Center requests. Communication links are established as needed with the Control Rooms, Technical Support Center and the Emergency Operations Facility.

Protected Area The area encompassed by physical barriers to control access to the plant and to the ISFSI. Protective Action Guides (PAG) The projected dose to an individual from an unplanned release of radioactive material at which a specific protective action to reduce or avoid that dose is recommended.

Protective actions would be warranted provided the reduction in individual dose expected to be achieved by carrying out the protective action is not offset by excessive _risks to individual safety in taking the protective action. The PAG does not include the dose that has unavoidably occurred prior to th.e initiation of a protective action. State Emergency Operations Center (SEOC) This facility provides a central location from which the emergency functions of state government may be carried out in response to emergency conditions. The primary State EOC is located at 7150 Harris Drive, Dimondale, Ml 48821. State Field Team Center (FTC) This facility provides the operational working area for State representatives assigned to coordinate the dispatch of field teams to monitor for radioactive contamination. The facility will be directed by a Field Team Center Coordinator* assigned by the Michigan Department of State Police/Emergency Management and Homeland

Security Division.

A representative of the Department of Environmental Quality/Drinking Water and Radiological Protection Division will be assigned to this facility as the Radiological Monitoring Team Leader. The location for the FTC is the Michigan Department of Transportation's Coloma garage at the intersection of Red Arrow Highway and 1-196. Technical Support Center (TSC) This facility is located adjacent to the Control Rooms at Elevation 644'. This center is physically separated from both Control Rooms. This facility has communication links to each Control Room, to the Emergency Operations Facility, Emergency News* Center/Joint Information Center, Operations Support Center and offsite emergency operations centers established by State/County authorities. This area contains access to instrumentation and necessary reference material for plant management and support personnel. The primary function of the TSC is to provide an area in close proximity to the Control Room from which plant operators can receive technical support and assistance from personnel who have the experience and expertise in nuclear plant operations, maintenance, safety and design. Their function is to mitigate the cause(s) of a nuclear incident and act as a data gathering center for plant parameters. Access to the TSC will typically be limited immediately to those individuals listed in Figure 5, and as the situation demands, those individuals required by the SEO or alternate. Introduction CEP Rev 39 Page 13 of 212 PLANNING STANDARD A ORGANIZATION CONTROL Planning Standard A CEP Rev 39 Page 14 of 212 A. ORGANIZATIONAL CONTROL A.1. Organizational Control In order for any emergency plan to be effective it is necessary to ensure that. every organization that provides support services has prepared in advance an emergency plan and/or procedures. These plans and/or procedures should define the individual responsibilities for coordinating and directing support effort and.the level of response each organization is prepared to make to meet its defined response capability on a continuous basis. Assistance from private organizations having nuclear industry affiliations can also be expected and are identified in Section C.4. A.1.a. Response Organizations Descriptions of the primary response organizations and their operational roles are outlined in S~ction B. The "state" col.1,Jmn of Figure 1 shows j:he Primary Response t,gencies and Support Response Agencies that comprise the State of Michigan's nuclear accident response . organization. The Primary. Response Agencies and their duties are performed at the State Emergency Operations Center (SEOC). The Support Response Agencies are the resources available to the SEOC for implementing actions in response to an emergency. A.1.b. Concept of Operations In the event of an emergency situation, the Shift Manager (or Senior NRC licensed individual) will call upon any additional members of the plant organization as needed. These additional individuals form, along with the on-duty operating shift, the plant Emergency Response Organization. The initiation of any aspects of this emergency plan allows for the use of the total plant organization, at the discretion of the Shift Manager. The major assignments of the on-duty operating shift and the supplemental personnel in the Emergency Plan Organization are delineated .in Table 1. The extent to which the Emergency Response Organization is staffed will be dependent upon the emergency* classification and the discretion of the Site Emergency Director (SEO). For an Unusual Event, only the Control Room will be staffed. For an Alert, Site Area Emergency, and General Emergency the TSC, OSC, ENC/JIC, and EOF will be activated and staffed. Senior plant management and technical personnel representing the licensee and the NRC are located in the TSC. TSC personnel will provide support to the Control Room operating personnel in the management of abnormal conditions and in accident mitigation. During recovery operations the TSC provides plant systems support for the management personnel located in the EOF. The TSC functions as the primary information source to the EOF and to the NRC on plant status. The Operations Support Center (OSC) is. an onsite assembly area separate from the Control Room and the TSC where licensee operations support personnel report in an emergency. This is an assembly area for personnel to report for instructions from the OSC Manager. Communications are provided to the Control Room, TSC, and EOF on bridge lines. Teams are dispatched from the OSC to provide for Damage Control, Rescue, and Surveys. Planning Standard A CEP Rev 39 Page 15 of 212 The EOF will provide current information on conditions potentially affecting the public to the NRC, state and county emergency response agencies. Radiological assessment, determination of recommended public protective actions and coordination of offsite response will be transferred to the EOF once the EOF is activated. EOF personnel coordinate the offsite radiological monitoring during nuclear emergencies and recovery operations. The EOF will function as the post-accident recovery management center for both onsite and offsite activities. The CNP Emergency Public Information Organization is structured to provide a correct and consistent flow of information to the public and the news media throughout an emergency at CNP. During

the initial phases of any emergency, all public information relating to the emergency Will be released via the Emergency News Center: The ENC becomes the .JIC when the State of Michigan declares the JIC activated.

A.1.c. Organization Interrelationships The relationships between Cook Nuclear Plant normal operating and Emergency Response 0Jganizations are presented in numbered Figurea 1 through 8. The figures are referenced throughout this Emergency Plan, and especially in Planning Section B, the Onsite Emergency Organization. A.1.d. Persons in Charge The Emergency Director (ED) is responsible for control and coordination of all Cook Nuclear Plant emergency and recovery operations. A.1.e. 24 Hour Response The.CNP Emergency Response Organization (ERO) is capable of continuous 24.,.hour operations for a protracted period. A.2. Not applicable A.3. Agreements The CNP Emergency Plan provides for agreements with various offsite support organizations that are part of the overall response organization within the Plume Exposure Pathway Emergency Planning Zone. These agreements are listed in Appendix B to this plan. In addition to the offsite support agencies listed in Appendix B, it is assumed that assistance will be provided, as necessary, by those State, County and Federal agencies that are mandated by their charter, public law or regulations to protect the public health and safety, i.e., the NRC and FEMA. It is not expected that letters of agreement are required with these agencies. A.4. Continuous Protracted Operations The CNP Emergency Response Organization (ERO) is capable of continuous 24~hour operations for a protracted period. Planning Standard A CEP Rev 39 Page 16 of 212 FIGURE 1 MICHIGAN NUCLEAR ACCIDENT RESPONSE ORGANIZATION FEDERAL Federal Emergency Management Agency Nuclear Regulatory Commission Department of Energy Federal Coordination Resource Support Technical Advice* PLANT OWNER/OPERATOR Site Emergency Response Organization Notification Onsite Control LOCAL Public Works Fire . Social Services Warning Evacuation Sheltering Blockading Public Information Re-entry Health Berrien County Sheriffs Department STATE PRIMARY RESPONSE AGENCIES State Police Direction, Control & Coordination Evacuation Authority Warning/Notification Security Damage Assessment Public Information In-place Shelter Local Plans T errQrist Activities Federal Liaison Military Weapon Accident Environmental Quality Monitoring & Sampling Technical Advice Decontamination Advice Occupational Health Medical & Health Support Accident & Dose Assessment Radiological Exposure Control PrQtective Actions Ground Water

Municipal Water Supplies SUPPORT RESPONSE AGENCIES Agriculture Food Contamination Food Supply Sampling Corrections Temporary Housing Transportation Assist. Feeding and Clothing Support Community Health Crisis Counseling Temporary Housing Natural Resources Environmental Impact Fish/Game Contamination Sampling Warning Support Meteorological Analysis Surface Water Transportation Licensing and Reg Affairs Public Utilities Liaison Energy Disruption Education Housing Mass Transportation Military Affairs Transportation Security Aerial & Ground Monitoring Support Human Services Housing/Registration Feeding and Clothing Assistance Centers Volunteer Agency Support Transportation

-Railroads -Air Traffic Traffic Regulations Blockade Planning Standard A CEP Rev 39 Page 17 of 212 PLANNING STANDARD B EMERGENCY RESPONSE ORGANIZATION Planning Standard B CEP Rev 39 Page 18 of 212 8. EMERGENCY RESPONSE ORGANIZATION The purpose of this section is to describe the CNP organization during normal operations and during emergencies.

Figure 2 shows the management structure for the Nuclear Generation Group (NGG). The Senior Vice President is the primary interface with local and state officials in matters concerning emergency preparedness.

B.1 Normal On-Site Operating Organization The normal on-site operating organization chart for the CNP is shown in Figure 3. 8.1.a. Vice Presidents The Chief Nuclear Officer (CNO) is responsible for implementing all activities at the CNP in accordance with all applicable laws, regulations, AEP and NGG policies while meeting the business needs of AEPNGG. "" "" "" q,. "" T~e Site Vice President (SVP) has the full authority and responsibility for operating, maintaining, and modifying the plant within established parameters and procedures. These responsibilities include ensuring effective implementation of the radiation protection program, directing the production, safety, work control and outage activities and Site Protective Services, and organizational/administrative activities at the plant. Additionally, the SVP is responsible for oversight of the Security Plan, Emergency Plan, and is responsible for integration of the emergency response and security functions. 8.1.b. Plant Manager The Plant Manager is accountable to the Site Vice President for the operations, maintenance, radiation protection, chemistry and environmental functional areas of plant production. The primary responsibility for the Plant Manager is the safe operation of the nuclear facility in accordance with applicable corporate policies, laws, regulations, licenses, and technical requirements, to ensure that public health and safety, including that of employees, is protected from undue nuclear and industrial safety risks. 8.1.c. Maintenance Manager The Maintenance Manager reports to the Plant Manager and is accountable for managing and . directing the activities related to the maintenance of all site equipment, structures, grounds and yards, and fire protection program. Managers that report to the Maintenance Manager provide the tools and support services necessary to optimize the safe, environmentally sound, cost effective efforts of the plant production organizations. 8.1.d. Emergency Preparedness Manager The Emergency Preparedness Manager ensures that the on-site and off-site emergency preparedness programs can protect the health and safety of the general public and site personnel while minimizing damage to the property and the environment in the event of an emergency. The Emergency Preparedness Manager is accountable to the Site Vice President. 8.1.e. Nuclear Regulatory Compliance and Licensing Director The Nuclear Regulatory Compliance and Licensing Director is accountable to the Site Vice President and is responsible for developing and directing the access authorization and fitness for duty programs. Planning Standard B CEP Rev 39 !~-----Page 19 of 212 B.1.f. Security Manager The Security Manager is accountable to the Site Vice President and is responsible for developing and directing the nuclear security program. 8.1.g. Training Manager The Training Manager reports to the Site Vice President and is accountable for the maintenance of INPO accreditation for eligible training programs, as well as non-accredited programs. This includes managing the development and presentation of training materials; maintenance of training materials, inclusive of the plant simulator and training aids; maintenance of training records and methods for assessing training effectiveness. 8.1.h. Operations Manager The Operations Manager reports to the Plant Manager and is accountable for operating the ~nuclear generating unit§ in a safe, environmerttally sound, cost effectiye, reliable and efficienj:

.. manner in accordance with applicable corporate policies,.

laws,. regulations, licenses, and -technical requirements. The primary responsibility of the Operations Manager is the safe operation of the generation units to ensure that the public health and safety, including those of employees, is protected from undue industrial and nuclear safety risks. B.1.i. Chemistry Manager The Chemistry Manager reports to the Plant Manager and is accountable for all activities related to plant system chemistry sampling, analysis, and control operations at CNP by optimizing fission product barrier effectiveness, maximize the life of plant equipment, and protect the health and safety of the public. 8.1.j. Radiation Protection Manager The Radiation Protection Manager,. who is accountable to the Plant Manager, serves as the regulatory Radiation Protection Manager. The Radiation Protection Manager .is responsible for *the implementation and maintenance of the radiation protection programs."As such, the function of the Radiation Protection Manager is to establish and maintain the highest level of radiological safety attainable for the protection of plant employees, the public, and the environment. 8.1.k. On-Shift Operations Personnel The major assignments of the on-duty operating shift and the supplemental personnel in the Emergency Plan. Organization are delineated in Table 1, CNP Staffing for Radiological Emergencies. Figure 4 is the chart for the On-shift Response Organization.

The Shift Manager, acting as the SEO, has overall responsibility for directing and implementing emergency and abnormal procedures to bring the unit to a safe condition.

The Shift Manager retains the Emergency Direction and Control functions until relieved by a qualified Site Emergency Director (SEO) or Emergency Director (ED). This position is the Table 1 on-shift column Shift Manager position for the Emergency Direction and Control functional area and plant operations functional area. One of the two Unit Supervisors on shift aids and assists the Shift Manager. This position is the Table 1, CNP Staffing for Radiological Emergencies, on-shift plant operations functional area Unit Supervisor. Planning Standard B CEP Rev 39 Page 20 of 212 The Work Control SRO reports to the Control Room in the event of an emergency to assist the Operations shift. The Work Control SRO provides staffing of the Table 1, CNP Staffing for Radiological Emergencies, On-shift plant operations functional area Assistant Shift Manager/WCC-SRO. One of the Reactor Operators provides staffing of the Table 1, CNP Staffing for Radiological Emergencies, Radiological Accident Assessment and Support functional area On-Shift Offsite Dose Assessment until relieved of that responsibility by the EOF. Two of the Auxiliary Equipment Operators (AEOs) provide staffing of the Table 1, CNP Staffing for Radiological Emergencies; Notification/Communication functional area until relieved of that responsibility by the EOF. An additional AEO performs the plant system engineering, repair and corrective actions functional area repair and corrective actions Rad Waste Operator as part of the normal AEO duties. The on-duty Shift Technical Advisor (STA) reports to the Control Room in the event of an ~emergency. The STA Junction is monitoring .the Critical Safety Function Status Trees and recommending necessary procedure transitions. The Core/Thermal Hydraulic conditions are monitored by the Critical Safety Function Status Trees. The STA provides staffing of the Table 1, CNP Staffing for Radiological Emergencies, Plant System Engineering, Repair and Gorrective Actions functional area On-Shift Core/Thermal Hydraulics and STA Technical Support. The STA reports to the SM and acts in an advisory capacity. Other STAs called in will report to the TSC, as needed. B.1.1. On Shift non-Operations (Supplemental) Personnel The major assignments of the on-duty operating shift and the supplemental personnel in the Emergency Plan Organization are delineated in Table 1, CNP Staffing for Radiological Emergencies. Figure 4 is the chart for the On-shift Response Organization. Three RP Technicians (RPT) are assigned to each shift to provide the Table 1, CNP Staffing for Radiological Emergencies, Radiological Accident Assessment and Support functional area Shift Offsite, Onsite, and In-plant surveys. They also provide Protective Actions functional area On-Shift Radiation Protection coverage. The on-shift RP Technician staffing is augmented with an on-shift Chemistry Technician and ten (10) RP Technicians called in for 60 minute supplemental staffing. Two Chemistry Technicians are assigned to each shift to provide the Table 1, CNP Staffing for Radiological Emergencies, Radiological Accident Assessment and Support functional area Shift Chemistry positions making expertise immediately available to address chemistry issues. The on-shift Chemistry staffing is augmented with one (1) Chemistry technician called in for 60 minute supplemental staffing. The Mechanic, Electrician, and I & C Technician assignment ensures the plant system engineering repair and corrective actions functional area On-Shift Repair and Corrective Actions maintenance disciplines expertise are immediately available to address maintenance issues. The on-shift Maintenance staffing is augmented with one Mechanic and Electrician called in for 60 minute supplemental staffing. The Fire Brigade provides the staffing for the On-Shift Fire Protection Functional Area and the Rescue and First Aid functional area. The brigade shift staffing is maintained as specified in the Technical Requirements Manual. Staffing for sixty minute response is provided by supporting local fire departments. Planning Standard B CEP Rev 39 Page21 of212 The Security force provides the staffing for the On-Shift and 60 minute Access Control and Accountability Functional Area. Security staffing is maintained as specified in the Security Plan. B.2. On-Shift Emergency Coordination The Shift Manager, acting as the SEO, has overall responsibility for directing and implementing emergency and abnormal procedures to bring the unit to a safe condition. B.3. Emergency Coordination Line of Succession The authority for initiation of the Emergency Plan is delegated to the senior supervisor of the duty operating shift (e.g., the Shift Manager). Upon the classification of an emergency event, the Shift Manager (SM) assumes the position of Site Emergency Director (SEO). The Shift Manager retains the Emergency Direction and Control functions until relieved by a qualified Site Emergency Director (SEO) or Emergency Director (ED). Upon arrival at the appropriate emergency response facility, the SEO and/or ED reviews the emergency situation with the Shift Manager, assumes the responsibilities for overall management of plant and emergency response functions, and .assures that proper actions are being taken to mitigate the event. The SEO or ED ensures that the proper State/County authorities, NRC and AEP officials are notified. The SEO will function as acting Emergency Director until such responsibilities are assumed at the EOF. Upon activation of the EOF the Emergency Director reviews the emergency situation with the SEO and assumes responsibility for control and co-ordination of all emergency and recovery operations from the SEO. B.4. Non-delegable Emergency Coordinator Duties During the initial phase of a nuclear incident prior to activation of the EOF, the SEO has the delegable responsibility to make Protective Action Recommendations (PARs) to State/County authorities responsible for offsite emergency measures. Upon activation of the EOF the Emergency Director assumes the non-delegable responsibility for making Protective Action Recommendations (PARs) to State/County authorities responsible for offsite emergency measures. Planning Standard B CEP Rev 39 Page 22 of 212 8.5 Emergency Response Organization The CNP Emergency Response Organization is presented in Figures 4 through 8. Every effort is made to match professional skills with those needed in the ERO positions listed on Figures 4 through 8. However, there may be some instances where, in actual assignments, the professionalskill description may not match those listed with their respective position. In such cases, the individual in question has been determined to effectively fulfill the requirements of the position through training and qualification for the ERO staff position or because of similar current, or past professional experiences or duties. All positions are assigned common administrative responsibilities such as event response and maintaining adequate documentation of the event tasks. Individual tasks for each ERO position are as follows: 8.5.a. Technical Support Center (TSC) The TSC Emergency Response Organization is presented in Figure 5. 8.5.a.1. Site Emergency Director (SEO) The SEO is assigned the following responsibilities:

Coordinate response activities with offsite response agencies
Coordinate ERO/facility shift turnover
Assume/maintain command and control
Transfer command and control
Manage all onsite emergency response activities .
Request and coordinate emergency activities with law enforcement agencies
Coordinate information and activities with offsite agency personnel in the facility
Develop requests for external assistance (technical, craft, admin, etc.)
Approve material, personnel and logistics expenditures necessary for response to the event
Classify and declare emergencies
Approve and direct offsite emergency notifications to state and local authorities
Direct notifications and ENS communications with the NRG
Ensure flow of information within and between the emergency response facilities
Perform or direct emergency PA announcements
Direct preparations and brief personnel prior to facility activation
Direct relocation of site emergency response facilities
Establish plant/station response priorities
Determine and direct the actions for mitigation strategies and contingency plans
Coordinate between CR, OSC and TSC to set OSC Team task priorities
Direct site assembly, accountability and search & rescue activities
Direct local and site evacuation
Coordinate site evacuation
Approve use of Kl
Approve Protective Action Recommendations to offsite authorities
Approve emergency exposures
Terminate the emergency event
Develop recovery plans Planning Standard B CEP Rev 39 Page 23 of 212
Authorize and direct extreme measures (FLEX, EDMG, SAMG, §50.54(x) or suspend security controls)
Conduct facility briefs and updates In addition to these immediate.

duties noted above, the SEO also has the authority to make policy decisions and expend funds necessary to cope with the event. B.5.a.2. TSC Manager The TSC Manager is assigned the following responsibilities;

Coordinate ERO/facility shift turnover * . Manage facility emergency response activities
Manage assigned group emergency response activities
.Coordinate information and activities with offsite agency personnel in the facility
Coordinate integration of the NRG site team
Develop reque._sts for external assistan~e (technical, craft, adrnjn, etc.)
Assist with emergency classification
Ensure flow of information within and between the emergency response facilities
Perform or direct emergency PA announcements
Direct preparations and brief personnel prior to facility activation
Ensure minimum staff is available and prepared to activate the facility
Activate the facility
Determine current/projected staff needs
Support coordination of site emergency facility relocation
Establish plant/station response priorities
Coordinate between CR, OSC and TSC to set OSC Team task priorities
Establish and maintain facility accountability
Coordinate site evacuation
Develop recovery plans
Conduct facility briefs and updates B.5.a.3. ENS Communicator The ENS Communicator is assigned the following responsibility;
Provide event data and plant information to the NRG via the ENS B.5.a.4. TSC Communicator The TSC Communicator is assigned the following responsibilities;
Communicate on assigned communication line and provide key information to facility staff
Provide operations or radiological data to ERO members (loss of PPG/PSS)
Maintain status and information boards B.5.a.5. CR Communicator

{located in the CR) The CR Communicator is assigned the following responsibilities;

Communicate on assigned communication line and provide key information to facility staff
Provide operations or radiological data to ERO members (loss of PPG/PSS) Planning Standard B CEP Rev 39 Page 24 of 212 8.5.a.6. Plant Evaluation Team The Plant Evaluation Team (PET) is made up of individuals from;
Engineering

-Nuclear Fuels Group

Engineering

-Electrical or Instrumentation and Control

Engineering

-Mechanical

Operations or Operations Training The PET are assigned the following responsibilities:

Cl) Ctl C .s:! 0 .... Ctl C :.;::::; 0 (.) I ca I ..... I *.: I ca 1--a3 1--g 1--t5 .c 1--(.) w Q.. w Q) w Q) w Q) o...O 0... 0::: o...w o...~ Monitor status of the Emergency Operations Procedures X Assist with emen::iency classification X Support completion of the Emergency Notification Form to state and local authorities X Provide event data and plant information to the NRC via the ENS X Provide operations or radiological data to ERO members (loss of X PPC/PSS) Communicate with ICP to provide information and coordination X Provide support for development of mitigation strategies and X X X X contingency plans Provide support for accident detection, assessment and response X X X X priorities Provide analysis of core damaQe and fission product release potential X X Coordinate between CR, OSC and TSC to set OSC Team task X Priorities Evaluate conditions and provide recommendations for PARs X Analyze and develop extreme measures actions (FLEX, EDMG, X X X X SAMG, §50.54(x)) 8.5.a.7. Maintenance Coordinator The Maintenance Coordinator is assigned the following responsibilities;

Ensure flow of information within and between the emergency response facilities
Provide support for development of mitigation strategies and contingency plans
Coordinate between CR, OSC and TSC to set OSC Team task priorities
Participate with OSC Team dispatch and control 8.5.a.8. Radiological Assessment Coordinator (RAC) The RAC is assigned the following responsibilities:
Manage assigned group emergency response activities
Assist with emergency classification
Provide operations or radiological data to ERO members (loss of PPC/PSS)
Communicate with ICP to provide information and coordination
Determine currenUprojected staff needs
Support coordination of site emergency facility relocation
Provide support for development of mitigation strategies and contingency plans Planning Standard B CEP Rev 39 Page 25 of 212
Provide support for accident detection, assessment and response priorities
Monitor, evaluate and communicate conditions involving any release of radioactivity
Record/review radiological sampling and survey data
Provide support and logistics for site assembly activities
Provide support and logistics for site evacuation activities
Evaluate the need for and ensure proper use of Kl
Evaluate conditions and provide recommendations for PARs
Ensure approved emergency exposure controls are issued
Ensure radiological conditions are known for occupied areas * *
Track emergency worker exposure and evaluate the need for dose extensions
Coordinate the monitoring of site evacuees
Direct personnel monitoring and decontamination activities .
Ensure habitability is established and maintained for occupied onsite areas
Establish contamination controls for occupied areas 8.5.a.9. Security Coordinator The.Security Coordinator is assigned the following responsibilities:
Manage assigned group emergency response activities
Request and coordinate emergency activities with law enforcement agencies
Assist with emergency classification , *
Communicate with ICP to provide information and coordination
Provide support for development of mitigation strategies and contingency plans
Establish and maintain accountability for security personnel
Provide support and logistics for site assembly activities
Participate in search and rescue activities
Coordinate site evacuation
Direct site access controls activities
Provide support and logistics for site evacuation activities
Ensure radiological conditions are known for occupied areas
Coordinate ERO response to a security event B.5.a.10 ICP Liaison The ICP Liaison is staffed during a security or other type event where the offsite agencies establish an incident command post near the station. Additional.

personnel from Security, Radiation Protection, Fire Brigade, and/or Operations may be dispatched to assist. The ICP Liaison is assigned the following responsibility;

Communicate with ICP to provide information and coordination B.5.a.11.

Administrative Coordinator The Administrative Coordinator is assigned the following responsibilities:

Complete facility 24 hour staffing list
Coordinate facility 24 hour staffing lists for the site
Manage assigned group emergency response activities
Provide ad min/logistics needs for facility operation Planning Standard B CEP Rev 39 Page 26 of 212 B.5.a.12.

Administrative Specialist The Administrative Specialist is assigned the following responsibilities:

Provide admin/logistics needs for facility operation
Distribute forms, reports, etc. as needed B.5.a.13 Computer Analyst The Computer Analyst is assigned the following responsibility;
Ensure availability of facility information/communicaUon/display systems 8.5.b. Operations Support Center (OSC) The OSC Emergency Response Organization is presented in Figure 6. 8.5.b.1. Operations Support Center Manager The Operations Support Center Manager is assigned the following responsibilities;
Complete facility 24 hour staffing list
Coordinate ERO/facility shift turnover
Manage facility emergency response activities
Manage assigned group emergency response activities
Coordinate integration of the NRG site team *
Develop requests for external assistance (technical, craft, admin, etc.)
Ensure flow of information within and between the emergency response facilities
Direct preparations and brief personnel prior to facility activation
Ensure minimum staff is available and prepared to activate the facility
Activate the facility
Determine current/projected staff needs
Support coordination of site emergency facility relocation
Coordinate between CR, OSC and TSC to set OSC Team task priorities
Participate with OSC Team dispatch and control
Establish and maintain facility accountability
Provide support and logistics for site evacuation activities .
Coordinate the monitoring of site evacuees
Direct personnel monitoring and decontamination activities
Develop recovery plans
Conduct facility briefs and updates 8.5.b.2. OSC Communicator The OSC Communicator is assigned the following responsibilities;
Communicate on assigned communication line and provide key information to facility staff
Provide operations or radiological data to ERO members (loss of PPG/PSS)
Maintain status and information boards
Distribute forms, reports, etc. as needed Planning Standard 8 CEP Rev 39 I B.5.b.3. Team Coordinator The Team Coordinator is assigned the following responsibilities;
. Maintain status and information boards *
Coordinate between CR, OSC and TSC to set OSC Team task priorities
Participate with OSC Team dispatch and control B.5.b.4. RP Supervisor The RP Supervisor is assigned the following responsibilities;
Manage assigned group emergency response activities
Determine current/projected staff needs
Brief and dispatch the onsite/offsite radiation monitoring teams
Record/review radiological sampling and survey data
Participate with OSC Team dispatch and control
Provide radiation protection coverag~ for emergency teams -* Evaluate the need for and ensure proper use of Kl Page 27 of 212 * *. Ensure use of Personnel Protective Equipment (protective clothing, respirators, etc.)
Ensure approved emergency exposure controls are issued
Ensure radiological conditions are known for occupied areas
Track emergency worker exposure and evaluate the need for dose extensions
Coordinate the monitoring of site evacuees
Direct personnel monitoring and decontamination activities
Ensure habitability is established and maintained for occupied onsite areas
Establish contamination controls for occupied areas B.5.b.5. Mechanical Supervisor The Mechanical Supervisor is assigned the following responsibilities;
Manage assigned group emergency response activities
Determine current/projected staff needs
Participate with OSC Team dispatch and control
Ensure use of Personnel Protective Equipment (protective clothing, respirators, etc.) B.5.b.6. Electrical/l&C Supervisor The Electrical/l&C Supervisor is assigned the following responsibilities;
Manage assigned group emergency response activities
Determine current/projected staff needs
Participate with OSC Team dispatch ahd control
Ensure use of Personnel Protective Equipment (protective clothing, respirators, etc.) B.5.b.7. Chemistry Supervisor The Chemistry Supervisor is assigned the following responsibilities;
Manage assigned group emergency response activities
Determine current/projected staff needs
Record/review chemical sampling and analysis
Participate with OSC Team dispatch and control Planning Standard B CEP Rev 39 Page 28 of 212
Ensure use of Personnel Protective Equipment (protective clothing, respirators, etc.) B.5.b.8. Damage Control Team The Damage Control Team reports directly to the OSC Manager and is responsible for the repair and restoration of damaged plant systems, equipment, or components.

Members of the Damage Control Team will be selected based on the type of damage that must be dealt with at the time. B.5.b.9. Rescue Team Rescue Teams are used for rescue of injured and trapped personnel. Rescue Teams shall .be made .up of at least two people, orie person qualified in radiation protection and at least one other person. --B.5.b.10. In-Plant/On-Site Survey Team In-Plant/On-Site Survey Teams are used for radiological survey during reentry of site facilities as well as support of other emergency teams which must gain access for decontamination, repair, and other activities that support event mitigation or recovery operations. B.5.c. Emergency Operations Facility (EOF) The EOF Emergency Response Organization is presented in Figure 7. B.5.c.1. Emergency Director The Emergency Director is assigned the following responsibilities:

Coordinate response activities with offsite response agencies
Coordinate ERO/facility shift turnover
Assume/maintain command and control
Transfer command and control
Request and coordinate emergency activities with law enforcement agencies.
Coordinate information and activities with offsite agency personnel in the facility
Coordinate information with government officials/agencies and EOCs
Prioritize and authorize requests for external assistance (technical, craft, admin, etc.)
Approve material, personnel and logistics expenditures necessary for response to the event
Request Federal support and resources
Classify and declare emergencies
Approve and direct offsite emergency notifications to state and local authorities
Direct notifications and ENS communications with the NRC
Ensure flow of information within and between the emergency response facilities
Maintain communications with AEP corporate and coordinate activities
Review news releases
Direct preparations and brief personnel prior to facility activation
Support coordination of site emergency facility relocation
Approve Protective Action Recommendations to offsite authorities
Terminate the emergency event
Develop recovery plans Planning Standard B CEP Rev 39 Page 29 of 212
Authorize and direct extreme measures (FLEX, EDMG, SAMG, §50.54(x) or suspend security controls)
Conduct facility briefs and updates B.5.c.2. EOF ManagerJ The EOF Manager is assigned the following responsibilities:
Coordinate response activities with offsite response agencies (EM, ICP, Field Mon, etc.)
Coordinate ERO/facility shift turnover
Manage facility emergency response activities
Manage assigned group emergency response activities
Coordinate information and activities with offsite agency personnel in the facility
Coordinate integration of the NRC site team
Develop requests for external assistance (technical, craft, admin, etc.)
Assist with emergency classification
Ensure flow.of information within am:I between the emergem;y response facilities
Direct preparations and brief personnel prior to facility activation
Ensure minimum staff is available and prepared to activate the facility.
Activate the facility
Determine current/projected staff needs
Develop recovery plans
Conduct facility briefs and updates B.5.c.3. Operations Advisor The Operations Advisor is assigned the following responsibilities:
Monitor status of the Emergency Operations Procedures
Assist with emergency classification
Support completion of the Emergency Notification Form to state and local authorities
Provide support for development of mitigation strategies and contingency plans
Evaluate conditions and provide recommendations for PARs
Analyze and develop extreme measures actions (FLEX, EDMG, SAMG, §50.54(x))

B.5.c.4. State Communicator The State & County Communicators are assigned the following responsibility:

Perform offsite emergency notifications to state and local authorities
Distribute forms, reports, etc. as needed B.5.c.5. County Communicator The State & County Communicators are assigned the following responsibility:
*Perform offsite emergency notifications to state and local authorities B.5.c.6. HPN Communicator The HPN Communicators are assigned the foll?wing responsibility:
Provide event data and plant information to the NRC via the HPN B.5.c.7. EOF Communicator Planning Standard B CEP Rev 39 Page 30 of 212 The EOF Communicator is assigned the following responsibilities:
Communicate on assigned communication line and provide key information to facility staff *
Provide operations or radiological data to ERO members (loss of PPC/PSS)
Maintain status and information boards B.5.c.8. Public Information Communicator The Public Information is assigned the following responsibilities:
Provide emergency response information to the ENC
Provide technical assistance for the development of news releases and statements B.5.c.9. Offsite Liaison Coordinator Offsite Liaison Coordinator is assigned the following responsibilities:
Manage assigned group emergency response activities
Support State/County EOC Liaisons
Coordinate information with government officials/agencies and EOCs B.5.c.10.

Offsite Liaison The Offsite Liaison is assigned the following responsibilities:

Coordinate information with government officials/agencies and EOCs
Report status of state and county emergency response activities to EOF B.5.c.11.

Industry & Reg Affairs Liaison The Industry & Reg Affairs Liaison is assigned the following responsibilities:

Coordinate information and activities with offsite agency personnel in the facility
Coordinate integration of the NRC site team
Coordinate external assistance (industry, commercial, contractor)
Provide event notification/information to industry groups (INPO, ANI, etc.)
Provide guidance for licensed-based decisions B.5.c.12.

Environmental Assessment Coordinator The EOF the Environmental Assessment Coordinator is assigned the following responsibilities:

Coordinate response activities with offsite response agencies (EM, ICP, Field Mon, etc.)
Manage assigned group emergency response activities
Assist with emergency classification
Support completion of the Emergency Notification Form to state and local authorities
Determine current/projected staff needs
Monitor, evaluate and communicate conditions involving a,ny release of radioactivity
Review and analyze dose assessment results
Direct/perform dose assessment
Record/review radiological sampling and survey data
Evaluate the need for and ensure proper use of Kl
Evaluate conditions and provide recommendations for PARs
Ensure approved emergency exposure controls are issued Planning Standard B CEP Rev 39 Page 31 of 212
Track emergency worker exposure and evaluate the need for dose extensions
Coordinate the monitoring of site evacuees
Direct personnel monitoring and decontamination activities
Direct post-accident environmental sampling and exposure activities B.5.c.13.

Dose Assessor The Dose Assessors are assigned the following responsibilities:

Support completion of the Emergency Notification Form to state and local authorities
Monitor, evaluate and communicate conditions involving any release of radioactivity
Review and analyze dose assessment results *
Direct/perform dose assessment
Record/review radiological sampling and survey data B.5.c.14.

Field Monitoring Team Communicator -The Field Monitoring Team Communicator is assigned the* following responsibiliti~s:

. Communicate on assigned*

communication line and provide key information to facility staff *

Brief and dispatch the onsite/offsite radiation monitoring teams
Record/review radiological sampling and survey data * * . Track emergency worker exposure and evaluate the need for dose extensions B.5.c.15.

Field Monitoring Team Member The Field Monitoring Team Members are assigned the following responsibilities:

Perform radiological sampling and surveys
Record/review radiological sampling and survey data Offsite Radiation Monitoring is performed by survey teams assembled in the OSC. Upon leaving the OSC the Offsite Survey Team(s) report to the Environmental Assessment Coordinator in the . EOFvia the Field Monitoring Team Communicator to receive briefing and instructions.

The off-site Survey Team Driver is normally filled by non-RPT personnel.

Qualified RP Technicians fill the position for persons performing the survey. B.5.c.16.

Logistics Coordinator The Logistics Coordinator is assigned the following responsibilities:

Manage assigned group emergency response activities
Coordinate external assistance (industry, commercial, contractor)
Arrange logistics support for event response
Support coordination of site emergency facility relocation
Serve as primary point of contact for SAFER and FLEX support B.5.c.17.

IT Specialist The IT Specialist is assigned the following responsibility:

Ensure availability of facility information/communication/display systems Planning Standard B CEP Rev 39 Page 32 of 212 B.5.c.18.

Administrative Coordinator The Administrative Coordinator is assigned the following responsibilities:

Complete facility 24 hour staffing list
Manage assigned group emergency response activities
Provide ad min/logistics needs for facility operation B.5.c.19.

Administrative Specialist

The Administrative Specialist is assigned the following responsibilities:
Provide ad min/logistics needs for facility operation
Distribute forms, reports, etc. as needed B.5.d. Emergency News Center/Joint Information Center (ENC/JIC)

The ENC, located-at the Nuclear Generation Group Headquarters Building, approximately 14 miles southeast of CNP in Buchanan, Michigan, will be staffed by individuals from the Energy Information Center, CNP, and Corporate Communications -Generation .. The ENC will be under the direction of the Emergency News Center Manager. Throughout the operation of the ENC, the Emergency News Center Manager maintains constant .communication with AEP Corporate Communications -Generation. See Figure 8 for an organization chart illustrating staffing and information flow for the ENC/JIC. Figure 5 illustrates EN.C/JIC functional relationship to the remainder of the Emergency Response Organization. When the Governor of the State of Michigan declares a "State of Disaster or Emergency" the ENC becomes the Joint Information Center at the governor's declaration. See Figure 8 for an organization chart illustrating staffing and information flow for the ENC/JIC. B.5.d.1. Utility Spokesperson The Utility Spokesperson is the "single utility spokesperson" when dealing with the news media. The Utility Spokesperson is assigned the following responsibilities:

Coordinate information and activities with offsite agency personnel in the facility
Approve/review news releases
Direct the development of news releases
Ensure press releases are prepared and issued prior to JIC activation
Perform media briefings and interviews
Address rumors in media briefings
Develop recovery plans 8.5.d.2. Technical Communicator The Technical Communicator is assigned the following responsibilities:
Communicate on assigned communication line and provide key information to facility staff
Provide operations or radiological data to ERO members (loss of PPC/PSS)
Provide emergency response information to the ENC
Provide technical assistance for the development of news releases and statements
Assist the Spokesperson in gathering technical information for media briefings and interviews Planning Standard B CEP Rev 39 Page 33 of 212 B.5.d.3. Emergency News Center Manager The Emergency News Center Manager is assigned the following responsibilities:
Complete facility 24 hour staffing list
Coordinate ERO/facility shift turnover
Manage facility emergency response activities
Manage assigned group emergency response activities
Coordinate information and activities with offsite agency personnel in the facility
Develop requests for external assistance (technical, craft, admin, etc.)
Ensure flow of information within and between the emergency response facilities
Maintain communications with AEP corporate and coordinate activities
Direct the development of news releases
Ensure press releases are prepared and issued prior to JIC activation
Coordinate the conduct of media briefings
Direct preparations and brief personnel prior to facility activation
Ensure minimum staff is available -and prepared to activate the facility
Activate the facility *
Determine currenUprojected staff needs
Conduct facility briefs and updates B.5.d.4. Media Area Coordinator The Media Area Coordinator is assigned the following responsibilities:
Manage assigned group emergency response activities
Maintain status and information boards
Coordinate the conduct of media briefings
Coordinate accommodation of news media personnel
Provide media with prepared media information and media briefing start times
Provide admin/logistics needs for facility operation
Distribute forms, reports, etc. as needed B.5.d.5. AudioNisual Specialist The AudioNisual Specialist is assigned the following responsibilities:
Support the setup of electronics and communications equipment
Ensure availability of facility information/communication/display systems B.5.d.6. Receptionist The Receptionist is assigned the following responsibilities:
Coordinate ENC security and media badging
Register personnel at the assigned location
Provide admin/logistics needs for facility operation B.5.d.7. Briefing Statement Writer The Briefing Statement Writer is assigned the following responsibilities:

Planning Standard B CEP Rev 39 I ! Page 34 of 212

Develop technical news releases
Coordinate distribution of news releases 8.5.d.8. Rumor Control/Media Monitoring Coordinator
The Rumor Control/Media Monitoring Coordinator is assigned the following responsibilities:
Manage assigned group emergency response activities
Monitor media outlets for event related information
Perform rumor control activities
Set up the facility
Determine current/projected staff needs 8.5.d.9. Rumor Control/Media Monitoring Specialist
The Rumor Control/Media Monitoring Specialist is assigned the following responsibilities:
Monitor media outlets for event related information
Perform rumor control activities 8.5.d.10.

Support Office Coordinator The Support Office Coordinator is assigned the following responsibilities:

Provide admin/logistics needs for facility-operation
Manage assigned group emergency response activities
Determine current/projected staff needs 8.5.d.11.

Support Office Admin Specialist The Support Office Admin Specialist is assigned the following responsibility:

Complete facility 24 hour staffing list
Provide admin/logistics needs for facility operation 8.6. Overall Organization and Communication The communication links between various emergency centers established as a result of implementing the Emergency Plan are delineated by Functional Organization Charts in Figures 9 and 10.
Initial notification flow sequence is shown in Figure 9. Figure 10 shows the relationship between various emergency centers and organizations after the incident has occurred and all channels of communication have been established.

8.7. Plant Staff Augmentation 8.7.a. Logistics Support Emergency Director directs the development of recovery plans and procedures. The Administrative Coordinator serves as a support resource for the ED in the areas of planning, scheduling and expediting of recovery operations. The Administrative Coordinator is assigned to the EOF and reports to the EOF Manager. Planning Standard 8 CEP Rev 39 Page 35 of 212 8.7.b. Reentry/Recovery Technical Support The Plant Evaluation Team (PET), operating out of the TSC develops corrective action recommendations. When the corrective action plans are decided upon, the TSC Manager coordinates the design and construction activities of the utility, NSSS supplier, and other outside vendors to support the corrective actions for recovery. 8.7.c. Management Level Interface with Government During an event the Emergency Director is responsible for control and coordination of all emergency and recovery operations including communications with offsite organizations, and interface with governmental authorities. 8.7.d. Releases to Media The Emergency News Center Manager coordinates all information at the ENC/JIC with counterparts fronJ the county, state, feder,al agencies, and others.,involved with the emerg,ency. The Utility Spokesperson is the "single utility spokesperson" when dealing with the news media. 8.8. Offsite Agencies and Organizations Appendix B, Agreements with Off-Site Support Agencies, identifies the primary response agencies that can be relied upon in an emergency to provide assistance. In addition various nuclear industry organizations can be called upon to provide technical assistance as needed. Procedures have been developed and are in place that assures the ability to notify and request assistance from those agencies identified in Appendix B. These procedures also provide the ability to notify and request assistance from other nuclear industry organizations. These include, but are not limited to: 1. NSSS Supplier.

2. Consultants on radiological and radwaste requirements.

3. Nuclear Fuel Supplier.

8.8.a. Notification of American Nuclear Insurers The American Nuclear Insurers notification criteria for nuclear emergencies has been brought into alignment with the emergency classification (EAL) system described in Section D and also identifies methods for follow-up communications. American Nuclear Insurers requires notification in the event of an Alert, Site Area Emergency or General Emergency. A representative of the NGG shall notify American Nuclear Insurers via the American Nuclear ln~urers emergency notification number. American Nuclear Insurers requires that periodic updates be supplied of releases of radioactive material from the plant, plant status and impending protective action for members of the public. These updates are the responsibility of the Industry Support Communicator in the EOF. Appendix I, Notification of American Nuclear Insurers, and Figure 13 show the ANI notification procedure. Planning Standard B CEP Rev 39 Page 36 of 212 8.9. Offsite Groups Although many offsite groups may be used in the event of an emergency, there are three offsite groups that have agreed to serve in the capacities outlined in this plan should an incident occur. These groups are the Berrien County Sheriff's Department, the State of Michigan, and the Federal Government. The responsibilities and authorities of the County, State. and Federal Governments and their interrelationship with this emergency plan are outlined in the following paragraphs. Written agreements with various offsite agencies that are part of the overall response organization within the Plume Exposure Pathway Emergency Planning Zone are listed in Appendix B of this plan. 8.9.a. Berrien County Sheriff's Department The Berrien County Sheriff's Department, which is the lead agency in implementing the Berrien County Radiological . Emergency Plan, has established an Emergency Operating Center (BCEOC) in accordance with the Berrien County Emergency Plan.* This center is located in Benton Harbor, .Michigan about 14 miles from the plant. It is~equipped with the appropriate communications equipment to coordinate all the local offsite protective actions. The Berrien County Sheriff has the responsibility and authority for coordination of all local .* resources in the event of a hostile threat or a radiological emergency, including establishing an Incident Command Post when applicable. The Sheriff's Department also has a marine division within its organization for the control of water traffic should it be necessary. Although the Sheriff's Department is primarily responsible for coping with an emergency using its own resources, the County Sheriff will call upon state resources to supplement the local resources when the local resources are clearly insufficient to cope with the emergency. Once the Governor of Michigan has declared a State of Disaster under Act 390, the Berrien County Sheriff's. Department will implement the Governor's Orders and will perform the following:

1. Contact other local agencies as needed for assistance.

2. Control offsite vehicular traffic. 3. Initiate the warning system and issue clear instructions of what protective action is required for the populace.

4. Take other appropriate action, if so advised by the Michigan State Department of Environmental Quality (DEQ) or upon notification by the SEO or ED that conditions . requiring immediate offsite protective action have been reached. (For further details see the Berrien County Plan -Warning Annex.) 8.9.b. State of Michigan The State of Michigan has developed the Michigan Emergency Management Plan. In the event that offsite protective action is required due to a hostile threat or a radiological emergency at CNP, this Michigan Emergency Management Plan can also be placed into effect to assist the Berrien County Sheriff's Department.

A brief outline follows of the plan's provisions for nuclear facility emergencies. Planning Standard B CEP Rev 39 Page 37 of 212 Under the Michigan Emergency Management Plan, the Department of State Police will provide guidance for the development of state and local nuclear incident emergency plans for dealing with peacetime radiological incidents. These are defined as situations in which normal control over radioactive materials is accidentally lost, with resulting hazard to the health and safety of the general public. The State Director of Emergency Management and Homeland Security is responsible for planning and coordinating the Disaster Relief Forces and their activities for the state. The Nuclear Power Plant Project Coordinator, Emergency Management and Homeland Security Division, State Police is designated as the Emergency Planning Coordinator for the State's radiological emergency response planning portion of the plan. The State Police, Emergency Management and Homeland Security Division, at the direction of the Governor, will coordinate all organizations in* the State for nuclear incident activities, maintaining liaison with all levels of government. The primary State Emergency Operations Center (SEOC), acting in support of the BCEOC, will perform all state governmental functions. This SEOC is located at 7150

Harris Drive, Dimondale, Ml 48821.
Alternate sites to the primary State EOC will be located in one of the State Police District Headquarters as indicated in the Michigan Emergency Management Plan. The basic responsibilities and .duties of the State Government agencies that provide support* during a nuclear incident are outlined below. B.9.b.1. are: B.9.b.1.a.

The Primary State Response Agencies and a summary of their responsibilities The Department of Michigan State Police (MSP)

Receives notification of nuclear incidents from the utility and alerts state agencies and warns affected local governments (adjacent states and adjacent counties are also alerted);
Operates the State Emergency Operations Center, . and the field team centers;
Provides overall direction and control of all activated state and local disaster relief forces;
Provides notificc!tion to local jurisdictions based on technical advice by the DEQ to evacuate and/or shelter in-place.
Assists local jurisdictions to establish security around restricted area;
Collects and compiles damage assessment information;
Prepares and coordinates emergency public information releases and advises the news media;
Assists local jurisdictions with any transportation accidents;
Establishes procedures to handle terrorist activities at nuclear power plants; and
Provides liaison to various federal organizations and agencies.

Planning Standard B CEP Rev 39 8.9.b.1.b. 8.9.b.2. B.9.b.2.a. 8.9.b.2.b. B.9.b.2.c. 8.9.b.2.d. Page 38 of 212 The Department of Environmental Quality {DEQ)

Monitors the environment, personnel, .and equipment in support of emergency operations;
Evaluates the public health and medical aspects of radiological effects;
Recommends measures and establishes limits to mitigate radiological effects on public health;
Recommends measures to control the spread of radioactivity;
Establishes radiological safety criteria for recovery, re-occupancy, and rehabilitation of affected areas;
Provides technical advice and assistance for offsite decontamination activities and support.
Sample surface water. .
Condi.Jct other monitoring as requested.
Monitor areas for contamination of the environment and recommend suitable countermeasures to reduce the impact of contamination of the environment.
Provide meteorological support and technical advice for use in analyzing or projecting radiological release hazards. The State Support Response Agencies and a summary of their responsibilities are: Department of Agriculture
Responsible for sampling agriculture areas for food contamination and recommending appropriate counter measures in conjunction with the Department of Public Health.
Responsible for taking appropriate actions to prohibit contaminated foods from entering the market. Licensing and Regulatory Affairs
Provide liaison to the public utility companies.
Provide recommendations for handling energy disruptions resulting from a shutdown due to a nuclear incident.
Provide advice and guidance to affected persons regarding insurance claims and adjustments.

Department of Corrections

Provide for mass care, feeding, clothing and sheltering.
Provide mass transportation assistance for affected persons and disaster relief workers. Department of Education
Provide support for mass care, feeding and housing.
Provide mass transportation assistance.

Planning Standard B CEP Rev 39 8.9.b.2.e. 8.9.b.2.f. 8.9.b.2.g. 8.9.b.2.h. 8.9.b.2.i. Page 39 of 212 Department of Community Health

Provide crisis counseling and intervention center assistance to affected persons.
Provides coordination of medical and emergency medical services to affected areas. Department of Military Affairs
Provide transportation and manpower support for evacuation counter measures.
Provide security support to local law enforcement operations, including control of access to restricted or evacuated are.as within the Emergency Planning Zone (EPZ). Department of Natural Resources

Monitor areas accessible by fish and game. *

Take action to prevent or minimize contamination of fish and game. * *
Take samples of fish and game, which may have been exposed or contaminated.
Assist local authorities to warn and evacuate occupants of state parks, beaches, and other recreational areas if necessary.

Human Services

Assist with sheltering and housing evacuated population;
Provide feeding and clothing if required to persons affected.
Establish assistance centers for affected individuals and families.

to receive advice and assistance.

Coordinate assistance made available by volunteer relief agencies and the American Red Cross.
Department of Transportation
Provide for mass transportation assistance to local jurisdictions if required.
Provide advice and assistance
support regarding barricades and security measures around an evacuated or restricted area.
Provide advice on traffic regulation and control for the evacuation of designated areas.
Provide assistance for the rescue of entrapped workers and persons.
Planning Standard B CEP Rev 39 Page 40 of 212 The Michigan Department of State Police is notified of an emergency condition in the manner described in Section E by the SEO or designee.

The State Police will set up a command post at the SEOC at 7150 Harris Drive, Dimondale, Ml 48821. The State Police will also set up a Field Team Center (FTC) to coordinate the dispatch of field teams to monitor for radiological contamination. The FTC will be established at the Michigan Department of Transportation Coloma Service Garage on Red Arrow Highway at 1-196. The State Police will coordinate their efforts with the BCEOC and with the EOF, as needed. After notification has been given, the Michigan Department of State Police will assist Berrien County and perform the actions listed in Section B.9.b. B.9.c. Federal Government The Federal Government has established the Nuclear/Radiological Incident Annex under the National Response Plan to coordinate Federal radiological assistance. The Nuclear/Radiological Incident Annex establishes: . * . A means of requesting and providing Federal* radiological assistance from existing . Federarresources, and

An operational framework for coordinating the radiological monitoring and assessment activities of Federal agencies during radiological emergencies occurring within the United States and its territories.

The Nuclear Regulatory Commission (NRC) as the Coordinating Agency is responsible for coordinating the response of all other federal agencies in accordance with the National Response Plan. The Department of Energy (DOE) Chicago Operations Office, located at Argonne National Laboratory, has radiation monitoring. capability available. It will, as requested by NGG Management or any of the indicated offsite groups (Sheriff, State Police or DEQ), assist in the offsite emergency program. The Chicago Operations Office will, upon request by NGG Management or any of the indicated offsite groups, participate in the monitoring of the offsite areas affected and in the analysis of field data and will recommend measures to be taken offsite for protecting the public. It will also advise the ED of the recommendations. The DOE Operations Office will, to the extent they are available during the protection and recovery stage, continue to advise the Emergency Management and Homeland Security Division of the Michigan Department of State Police and provide monitoring and analytical capability as requested. B.9.d. Fire Department CNP maintains an onsite fire fighting brigade; this capability is expected to be sufficient for all fires onsite. In the event offsite assistance is desired or needed, local fire departments may be called upon. The Fire Protection Shift Supervisor is responsible for fire fighting activity onsite as well as notifying offsite departments when assistance is needed. -The primary fire departments that will respond to a fire emergency at CNP are:

Lake Township Fire Department
Bridgman Fire Department Planning Standard B CEP Rev 39 Page 41 of 212 Letters of agreement to provide firefighting assistance to CNP can be found in Appendix B of * . this Plan. 8.9.e. HAZMAT Team CNP maintains an onsite hazardous material spill response team that is capable of responding to most emergency spill events. If there is insufficient manpower or material available, assistance from the Berrien County HAZMAT Team will be requested.

A letter of agreement offering their services can be found in Appendix K of this plan. AEP has also contracted with environmental firms to provide emergency spill response assistance. These contractors are listed in the Spill Prevention Control and Countermeasures (SPCC) Plan and Pollution Incident Prevention (PIP) Plan, copies of which are* located in the Shift Manager's office. Planning Standard B CEP Rev 39 ' I Director Nuclear Oversight Page 42 of 212 Figure 2 Management Structure of the Nuclear Generation Group I Director Nuclear Business Services Plant Manager Emergency Preparedness Manager ' Chief Nuclear Officer Site Vice President Director Nuclear Regulatory Compliance and Liceensing <-----Training Manager Security Manager 1----~ Planning Standard B I Manager Employee Concerns ' Nuclepr Projects Director Vice President Engineering I Manager Policy Communication Plant Enginee'ring Director Design Engineering l--_j_---1 Nuclear IT Manager Director CEP Rev 39 Page 43 of 212 Figure 3 I Site Operations Site Vice President ... ' '-Plant Manager *ll I Operations Maintenance Nuclear Outage Work Control Director Director Manager Manager ... I l ' Site Procedure Chemistry Radiation Protection Safety Group/Nuclear Manager Manager Manager Document Management Manager Planning Standard B CEP Rev 39 I Shift Technical Advisor I Fire Brigade 1/1.fX SRO I Auxiliary Operator U-1 Supervisor and Control Room Operators I I I Auxiliary I Operator Figure 4 On Shift Response Organization Site Emergency Director (Shift Manager) I **-*-*-*-*-*, G FederaVState/ I j Local Agencies 1 *-*-*-*-*-* .. Radiation Protection Technicians U-2 Supervisor and Control Room Operators I I Auxiliary I I Auxiliary Operator Operator I Chemistry Technicians I 2AEO ., Phone Talkers Planning Standard B Page 44 of 212 ' I I Instrument and Security Shift Control Technician -Supervisor I I ' lv1 aintenance Security Electrician Force l lv1 aintenance Mechanic ,--------.d I ' I lnc1 ent Command I I Post Liaison I I _______ I CEP Rev 39 Figure 5 -TSC Organization Plant Evaluation Team Maintenance Coordinator Planning Standard B Security Coord i nator ICP Lia i son [event based] Page 45 of 212 Administrative Coordinator TSC Admin Specialist Computer Analyst CEP Rev 39 Figure 6 -OSC Organization RP Supervisor 3x: RPT (from shift) OSC Communicator Team Coordinator Mechanical Supervisor Mechanic (from shift) Elect/l&C Supervisor Electrician (from shift) l&C Tech (from shift) Electrician OR l&C Tech (from shift) Planning Standard B Chemistry Supervisor (60 min) 2x: Chemistry Technician (from shift) Page 46 of 212 OPs Spervisor (from shift) 5x: Fire Brigade Member (from shift) 6x: AEO (from shift) CEP Rev 39 Figure 7 -EOF Organization HPN Communicator Dose Assessor FMT Communicator Operations Advisor 2x: Offsite Liaison Industry & Reg Affairs Liaison Public Information Communicator EOF Communicator Logistics Coordinator IT Specialist Planning Standard B Page 47 of 212 Administrative Coordinator EOFAdmin Special i st CEP Rev 39 Page 48 of 212 Figure 8 -CNP ENC/JIC Organization Techn i cal Communicator <<,. "'* _ ~IJ,:_"::,.,(:* '* I " I I Briefing Statement Writer -I I I Media Area Coordinator Rumor Control / Media Support Office Coordinator Monitoring Coordinator .::* -Receptionist -4x: Rumor Control / Media '----Support Office Adm i n Monitoring Specialist Specialist I -AV Special i st Plann i ng Standard B CEP Rev 39

1. Plant Ops and Assessment of Operational Aspects 2. Direction and Control 3. Notification

& Comm. 4. Radiological Assessment and Support of Operational Accident Assessment Page 49 of 212 Table 1 CNP Staffing for Nuclear Power Plant Emergencies Response and Accident Mitigation Shift Manager (CR) Assistant Shift Manager/WCC-SRO (CR) Unit Supervisor (CR) Control Room Operator (CR) Auxiliar E ui ment O erator CR Command and Shift Manager (CR) Control ....... *******-******** Site ... Emergencypirector .. (TSC) Facility and Group TSC Manager (TSC) Control OSC Manager (OSC) EOF Manager (EOF) ENC Mana er ENC Emergency Licensee -Reactor Operator (CR) Communications Local/State -Qualified Operator (CR) Federal -Qualified Operator (CR) State & County Communicator (EOF) ENS Communicator (TSC) ----** .......................................... HPNComm.unicator (EO.F) ... __ Plant Status & Technical Activities CR Communicator (CR) TSC Communicator (TSC) OSC Communicator (OSC) EOF Communicator (EOF) 1 a 1 1 1 1 1<d) 1 a 1 1 2 1 --*-----********-----******-*-Public.Info Communicator (EOF) ______ ...............

- -*-*-**

-*****-*** 1 1 1 1 1 1 1 2 Governmental Offsite Liaison Coordinator (EOF) Offsite Liaison (EOF) ICP Liaison (TSC) lndust & Re Affairs Liaison (EOF) EOF Director Emergency Director (EOF) 1 *****-*-***** -1{a)*. Dose Assessment Reactor Operator(CR) ____ **-***--*---- ...... . --* ****-* ****-**---************-*************-- -*-Dose_ Assessor .. (EOF) Offsite Surveys RP Technician (OSC) FMT Communicator (EOF) ......... .. -*********- ................... FMT Member(EOF)__ _ __ _ Onsite Surveys RP Technician (OSC) . --**** _ ............. RP Technician(OSC) In-plant Surveys RP Technician (OSC) 1 4 1 1 1 2 1 1 1 .........

- -***-***-*******-

RP ... Technician .. (OSCL. ............ _. *-............... -..... ... .. . ........................... -*************** RP Supervisory Rad .. Assessme.nt .. Coordinator .. (TSC) -****** 1 Envimnmental.Assmt .. Coord.inator.(EOFt_ .. . 1 *****************************************************************-***************** 11 RP Supervisor (OSCL .....................

- - - - -********-

............................ . Chemistry/ Chemistry .. Techn.ician.(OSC)............ ... . --***********- ... 2 Radiochemistry _ ChemistryTechnician.(OSC)_ .................. ---********** .. 1 Chemistry Supervisor Chemistry Supervisor (OSC) Planning Standard B 1 CEP Rev 39

!i);*,f) 3'.: '.;;;1::£,::1'.}i" :t<* liU:ni;tjbn;1.I. ,Are.a 5. Plant System Engineering, Repair, and Corrective Actions 6. In-Plant PAs 7. Fire Protection

8. Rescue / 1 s Aid Technical Support / Accident Analysis Shift Technical Advisor (CR) Core Damage: PET -Reactor (TSC) Thermal Hydraulics:

PET -Ops (TSC) Electrical: PET -Electrical/l&C (TSC) Mechanical: PET -Mechanical (TSC) ...................... Operations .. Advisor(EOF) Repair and Mechanic (OSC) Corrective Actions Electrician (OSC) Radiation Protection l&C Technician (OSC) Electrician OR l&C Technician (OSC) Maintenance Coordinator (TSC) Team Coordinator (OSC) Mechanical Supervisor (OSC) Mechanic (OSC) Radwaste Operator (OSC)

Elect/l&C Supervisor (OSC) Electrician (OSC) RP Technician (OSC) RP Technician (OSC) 9. Access Control Security & Accountability Shift Security Supervisor (Plant) Security Personnel (Plant) Securit Coordinator (TSC) 10. Resource Allocation and Admin Administration Administrative Coordinator (TSC) TSC Administrative Specialist (TSC) Administrative Coordinator (EOF) EOF Administrative Specialist (EOF) Media Area Coordinator (ENC) Receptionist (ENC) 1 1 1 1 5 1 (c) Page 50 of 212 1 1 1 1 1 1 1 4 1 1 1 1 Local Support Local Support 1 Facility Operations Comp}-Jler Analyst. (TSCL ...........

_______ . ******---- ---***-** -*** 1 1 1 1 1 1 1 1 1 1 1 1 .11. Public Information Logistics Coordinator (EOF) IT Specialist (EOF) AV Specialist (ENC) Support Office Coordinator (ENC) Support Office Adm in Specialist (ENC) Public Information Utility Spokesperson (ENC) Technical Communicator (ENC) Briefing Statement Writer (ENC) Rumor Control/Media Mon Coord (ENC) Rumor Control/Media Mon 30 29 1 1 1 1 4 41 1 The augmentation times presented in this table are goals developed from the guidance of Table B-1 in NUREG-0654, FEMA-REP-1, Rev. 1 "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants." a. May be provided by shift or other personnel assigned from other functions. Not included in the total. b. The ICP Liaison is a situational position. For all HAB events a 2nd TSC Security Coordinator assumes the position of ICP Liaison and responds to the ICP. c. Per Security Plan d. Utility Spokesperson and Emergency News Center Manager are minimum staffing positions required for facility activation, but they do not have a required response time. Planning Standard B CEP Rev 39 Page 51 of 212 PLANNING STANDARD C EMERGENCY RESPONSE SUPPORT AND RESOURCES Planning Standard C CEP Rev 39 Page 52 of 212 C. EMERGENCY RESPONSE SUPPORT AND RESOURCES C.1. Federal Radiological Assistance C.1.a. Requesting Federal Assistance The Emergency Director (ED) or the Site Emergency Director (SEO) has the authority to request federal radiological assistance. A request for federal radiological assistance should be made through the Department of Energy's (DOE) Chicago Operations Office located at 9800 S. Cass Avenue, Argonne, Illinois *60439. The Chicago: Operations Office is designated to provide the primary assistance following .a radiological incident in the Radiological Assessment Program (RAP) Region 5. When a requestfor RAP assistance is niade, the following information should be provided:

1. N~ture of the incident.

2. Name, title, location and telephone number of person requesting assistance.

3. Time of the incident.

4. Location of the incident.

5. Accessibility of location.

6. Whether a fire is involved.

7. Relative seriousness of incident.

8. Weather conditions.

9. Personnel involved (injuries, contamination, etc.). 10. Local/state/federal agencies that have been notified.

11. Whether the news media is aware of the incident; whether false or exaggerated reports are known to have circulated.

C.1.b. Federal Resources The immediate objective of the DOE's Chicago Operations Office is to dispatch a team of specialists to the incident site where the team will: 1. Evaluate the hazard. 2. Take or recommend action to counteract and control any acute hazard offsite from the licensee's site. 3. Establish communication with State and local authorities and the press. If the Chicago Operations Office determines a need for additional assistance beyond its own capabilities, it may initiate the Nuclear/Radiological Incident Annex. Planning Standard C CEP Rev 39 Page53of212 The Nuclear/Radiological Incident Annex has been established by the federal government to coordinate federal radiological assistance. The Nuclear/Radiological Incident Annex establishes:

A means of requesting and providing Federal radiological assistance from existing federal resources, and
An operational framework for coordinating the radiological monitoring and assessment activities of Federal agencies during radiological emergencies occurring within the United States and its territories.

Through the Nuclear/Radiological Incident Annex the DO E's Chicago Operations Office has the capability to call upon resources located throughout the United States and will provide this assistance where necessary or when requested. Some of the immediate resources that can be provided are (but not limited to): 1.

Prov.ide team(s) of RAP personnel to assist in offsite monitoring.

2.,

Provide portable direct reading radiological measuring instruments.

3. Provide counting equipment..

4. Provide aerial surveillance and measurement.

5. Provide analytical capability to augment the licensee and state's capability.

6. Provide resources as may be available at the Argonne National Laboratory.

7. Provide health physics assistance.

8. Provide environmental control assistance.

9. Provide remote handling equipment on an as needed basis. Additional information pertaining to federal radiological assistance can be found in Appendix E, Description of Federal Radiological Assistance, to this plan. Appendix E is divided into three .sections.

Section I is a brief introduction to the federal radiological assistance. Section II describes typical capabilities and expected mobilization and travel times for some of the Region 5 radiological assistance resources available within Region 5 of the DOE's radiological assistance program. Section Ill describes additional DOE capabilities that can be activated dependent on the assistance needed and how it is activated. C.1.c. Federal Response Support Resources Appendix E contains information on the local resources required to support the RAP. C.2. Liaisons C.2.a. Liaisons to CNP Not applicable Planning Standard C CEP Rev 39 Page 54 of 212 C.2.b. Liaisons from CNP Sections 8.5.a.1 O and 8.5.c.10. detail the liaisons provided to the Berrien County EOC, Incident Command Post and the Michigan SEOC. C.3. Radiological Laboratories . ,Section H.6.c Offsite Laboratory Facilities discusses offsite laboratory avqilability. C.4. Offsite Agencies and Organizations

Appendix B identifies the primary response agencies that. can be relied upon in an emergency to provide assistance.

In addition various nuclear industry organizations can be called upon to *provide technical assistance as needed. Procedures have been developed arn;:I are in place that

assures the ability to notify and request assistance from those agencies identified in Appendix B. These procedures also provide the ability to notify and request assistance from other nuclear industry grgariizations.

These inqJude, but are not limitedJo:

1. NSSS Supplier.

2. Consultants on radiological and radwaste requirements.

3. Nuclear Fuel Supplier.

C.4.a. American Nuclear Insurers The American Nuclear Insurers notification criteria for nuclear emergencies has been brought into alignment with the emergency classification (EAL) system described in Section D and also identifies methods for follow-up communications. American Nuclear Insurers requires notification in the event of an Alert, Site Area Emergency or General Emergency. A representative of the NGG shall notify American Nuclear Insurers via the American Nuclear Insurers emergency notification number. American Nuclear Insurers requires that periodic updates be supplied of releases of radi.oactive material from the plant, plant status and impending prote<;:tive action for members of the public. These updates are the responsibility of the Industry Support Communicator in the EOF. Appendix I and Figure 13 show the ANI notification procedure. C.4.b. Nuclear Transportation Accidents A Voluntary Assistance Agreement has been entered into between electric utilities involved in the transportation of source material; special nuclear material and by-product material received, possessed, used or transferred. This agreement sets forth the understanding and agreement with respect to the mutual undertaking to each other in the situation where an emergency occurs by reason of a nuclear materials transportation accident and assistance is provided by one utility to another. A copy of this agreement can be found in Appendix B. Planning Standard C CEP Rev 39 Page 55 of 212 C.4.c. Nuclear Power Plant Accidents A voluntary assistance agreement has been entered into*between electric utilities involved in the operation of nuclear power plants. This agreement sets forth the understanding and agreement with respect to their mutual undertaking to each other in a situation where an emergency occurs at a nuclear power plant and assistance is provided by. one utility to another. A copy of this agreement can be found in Appendix B, and contact information is contain_ed in the Emergency Plan Procedures. Planning Standard C CEP Rev 39 Page 56 of 212 PLANNING STANDARD D EMERGENCY CLASSIFICATION SYSTEM Planning Standard D CEP Rev 39 Page 57 of 212 D. . EMERGENCY CLASSIFICATION SYSTEM In general, Initiating Conditions (ICs) describe conditions that require implementation of emergency actions. Emergency Action Levels (EALs) are, where possible, pre-designated, subjective thresholds for entry into a particular Emergency Classification Level (ECL). The action to be taken by the operating shift depends on the severity of the incident, its effects and type.

The SEO or ED will exercise subjective judgment to ensure all incidents are classified at the highest appropriate ECL based on the following criteria:
Conditions warrant a declaration of an Unusual Event when 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 offsite response or monitoring are expected unless further degradation of safety systems occurs. * . Conditions warrant a declaration of an Alert when events are in process or have occurred wbich involve an actual or potential substantial degradation of the level of safety of the plant or a s.ecurity event that involves probable life threatening risk to site personnel or damage to site equipment because of Hostile Action. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels. *

Conditions warrant a declaration of a Site Area Emergency when events are in process or have occurred which involve an actual or likely major failures of plant functions needed for protection of the public or Hostile Action that results in intentional damage or malicious acts; (1) toward site personnel or equipment that could lead to the likely failure of or, (2) that prevent 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.
Conditions warrant a declaration of a General Emergency when events are in process or have occurred which involve actual or imminent substantial core degradation or melting with potential for loss of containment integrity or Hostile Action that results in an actual loss of physical control of the facility.

Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels beyond the site boundary. The ICs/EALs were created following the methodology of NUMARC/NESP-007, Rev. 2. The ICs/EALs will classify an event or condition into one of four Emergency Classification Levels (ECLs) if an emergency classification is appropriate. D.1. Emergency Action Levels Emergency Action Levels are pre-determined, site specific, observable thresholds for plant Initiating Conditions that place the plant in a given emergency class. An EAL can be an instrument reading; an equipment status indicator, a measurable parameter (onsite or offsite); a discrete, observable event; results of analyses; entry into specific emergency operating procedure; or another phenomenon which, if it occurs, indicates entry into a particular emergency class. Planning Standard D CEP Rev 39 Page 58 of 212 The severity of the emergency classification may change over time with the emergency being upgraded from one classification level to another. Incidents will typically be classified in a lower emergency classification at first and then escalated to a higher classification if the situation deteriorates. Each of the four emergency classification levels has characteristic Emergency Action Levels for various parameters. Table 2 is the Fission Product Barriers matrix for modes 1 through 4 used. to determine EALs . . Table 3 describes the EAL Initiating Conditions for the various Emergency Condition Categories (ECCs) for Modes 1 through 4. Table 4 describes the Initiating Conditions for Modes 5 and 6 and defueled condition (shutdown).

D.2. . Initiating Conditions Initiating Condition

-One of a predetermined subset of nuclear power plant conditions where either the potential exists for a radiological emergency or such an emergency has occurred. Some of the initiating conditions and events are directly identifiable by their eiistence, such as operation of a safety system or a. fire, while others require observation of process or radiation monitoring instrumentation. ' ' ' Station procedures contain the specific instrumentation, equipment status, and . non-process conditions and events that are used to establish the emergency classification. Table 2 is the Fission Product Barriers matrix for modes 1 through 4 used to determine EALs. Table 3 describes the EAL Initiating Conditions for the various Emergency Condition Categories (ECCs) for Modes 1 through 4. Table 4 describes the Initiating Conditions for Modes. 5 and 6 and defueled condition (shutdown). D.2.1 Emergency Declaration Timeliness Station procedures contain instructions to declare an emergency within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded and shall promptly declare the emergency condition as soon as possible following identification ' ' of the appropriate emergency classification level. Planning Standard D CEP Rev 39 Page 59 of 212 Table 2 FISSION PRODUCT BARRIER MATRIX-Mode 1-4 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Loss of1WO Fission Product Any 1WO of the FoUowing: Loss or Potential Loss .of Either F1,1el Clad Loss or Potential Loss of Containment Barriers AND Potential Loss of Third 1. Loss or Potential Loss of Fuel Clad. or RCS Barrier. Barrier. Barrier. 2. Loss or Potential Loss of RCS. 3. Loss of Containment Barrier. 1. FUEL CLAD BARRIER .LOSS (L) POTENTIAL LOSS (P) .1 Core Cooling CSFST Core Cooling CSFST -RED Core Exit Thermocouples > 757° OR RVLIS Level< 46% (Narrow Range) OR Heat Sink CSFST -RED .2 Containment Radiation > 200 R/hr . ' None ! .3 Primary Coolant Activity >300 uCi/cc 1-131 dose equivalent None OR Core Damaae > 5.0% clad failure .4 SED Judgment Any condition in the opinion of the SED that indicates loss of the Any condition in the opinion of the SED that indicates potential Fuel Clad barrier. :E loss of the Fuel Clad barrier. :E 2. RCS BARRIER LOSS (L) POTENTIAL LOSS (P) .1 RCS Leak Rate (unisolable) > available makeup capacity as indicated by complete loss of > capacity of one centrifugal charging pump in normal charging RCS subcooling. line up. .2 Steam Generator Leakage Entry into OHP 4023.E-3, SGTR Ruptured SG with leak > capacity of one charging pump in AND normal cl1arging line up. A Non-isolable secondary line break or a prolonged release (>30 minutes) of contaminated secondary coolant resulting in a radioactive release to the environment from the affected SG. 1 .3 Containment Radiation > 10 R/hr None .4 RCS lntearitv CSFST None RCS lntearitv CSFST -RED .5 Heat Sink CSFST None Heat Sink CSFST -RED .6 SED Judgment Any condition in the opinion of the SED that indicates loss of the Any condition in the opinion of the SED that indicates potential RCS barrier. :E loss of the RCS barrier. :E 1 Does not include a release through the condenser air ejectors, or ttie gland steam condenser vents for the purpose of declaration of a SITE AREA EMERGENCY.

E EAL's in these tables are NOT complete.

Refer to referenced basis page (PMP-2080-EPP-101, Attachment 3)for complete description. Planning Standard D CEP Rev 39 Page 60 of 212 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Loss of TWO Fission Product Any TWO of the Following: Loss or Potential Loss of Either Fuel Clad Loss or Potential Loss of Containment Barriers AND Potential Loss of Third 4. Loss or Potential Loss of Fuel Clad. or RCS Barrier. Barrier. Barrier. 5. Loss or Potential Loss of RCS. 6. Loss of Containment Barrier. ' 3. CONTAINMENT BARRIER LOSS (L) POTENTIAL LOSS (P) .1 Containment Radiation None > 1000 R/hr. OR Core damaae > 20% clad failure. .2 Containment Integrity Unisolable breach of containment. None OR Rapid unexplained containment pressure or sump level drop following pressure rise caused by a LOCA. OR

Containment pressure/sump level NOT performing as expected for conditions.

OR Entrv into ECA-1.2, LOCA Outside Containment. .3 SG Secondary Side Release Primary to secondary leak rate> Tech. Spec. limit. None AND Release of secondary coolant from the associated steam aenerator to the environment is occurrinQ. 1 .4 Containment CSFST None Containment CSFST -RED .5 Containment Hydrogen None >4.0% ' OR Containment Hydrogen >0.5% AND any Hydrogen Control eauipment inoperable. .6 Containment Pressure Control None BOTH CTS trains OR BOTH containment air recirc fans inoperable OR fail to auto start on their containment pressure setnoint OR containment pressure >12Psia. . 7 Core Exit Thermocouples None Core Cooling CSFST-R.ED AND Restoration orocedures not effective within 15 minutes. .8 SED Judgment Any condition in the opinion of the SED that indicates loss of the Any condition in the opinion of the SED that indicates potential Containment barrier. 5" loss of the Containment barrier. > 1 Does not include a release through the condenser air ejectors, or the gland steam condenser vents for the purpose of declaration of a SITE AREA EMERGENCY. Planning Standard D CEP Rev 39 !GENERAL EMERGENCY H-1 SEO Judgment Conditions indicate actual or imminent substantial core damage with potential loss of containment or the potential exists for an uncontrolled radioactive release that may exceed EPA limits at the site boundary. Table 3 INITATING CONDITIONS -Mode 1 -4 H-1 SEO Judgment Conditions indicate likely or actual major failures of plant functions needed to protect the public. H-1 SEO Judgment Conditions indicate that plant safety systems may be degraded and additional personnel are needed for additional monitoring. Page 61 of 212 H-1 SEO Judgment Conditions indicate a potential degradation of the level of safety of the plant. H-2 Security H-2 Security H-2 Security H-2 Security HOSTILE ACTION resulting in Loss of HOSTILE ACTION within the HOSTILE ACTION within the OWNER Confirmed Security Condition which Physical Control of the Facility. PROTECTED AREA CONTROLLED AREA or airborne attack indicates a potential degradation in the 1. A HOSTILE ACTION has occurred 1. A HOSTILE ACTION is occurring or threat. level of safety of the plant. such that plant personnel are unable has occurred within the 1. A HOSTILE ACTION is occurring or 1. SECURITY CONDITION that does to operate equipment required to PROTECTED AREA as reported by has occurred within the OWNER not involve a HOSTILE ACTION as maintain safety functions listed the Security Shift Supervisor. CONTROLLED AREA as reported by reported by Security Shift below: :E the Security Shift Supervisor. Supervision.

Reactivity Control (ability to shut OR OR down the reactor and keep it 2. A validated notification from the NRC 2. A credible site-specific security threat shutdown) of a LARGE AIRCRAFT attack threat notification.
RCS Inventory (ability to cool the within 30 minutes of the site. OR core) :E 3. A validated notification from NRC .. Secondary Heat Removal (ability e providing information of an aircraft to maintain heat sink) threat. OR 2. A HOSTILE ACTION has caused
failure of spent fuel cooling systems and IMMINENT fuel damage is likely. :E H-3 CR Evacuation H-3 CR Evacuation Control Room evacuated AND control not Control Room evacuation initiated.

established in 15 minutes. :E H-4 Fire Fire OR explosion affecting plant operations. H-5 Toxic Gas Toxic OR flammable gas release that threatens lives OR affects ability to achieve and maintain Mode 5. Planning Standard D H-4 Fire Fire in Protected Area NOT extinguished

E within 15 minutes of detection.

H-5 Toxic Gas Toxic OR flammable gas release affecting plant operation. H-8 ISFSI Damage to a loaded cask CONFINEMENT BOUNDARY. CEP Rev 39 Page 62 of 212 I GENERAL EMERGENCY I SITE AREA EMERGENCY I ALERT I UNUSUAL EVENT ' 1, ',_}\. 'cJ{,,~ ;: !? '. , 1":., ,, ** *. ;, . i,, .,;*.,;;e ,:if:c*,,r',;,;:; '. "' . ' ,, 4 < ~,, <~* .... ' ,~* ~*; 'v~" ; -:,S ,,,;f~,,*.;:,.

'*' *~' '< ::s,.,v-~,* :"', "' -~ "',:,.>*"'" *"" *,~ -i \".{,, W:lj *: ,;(',~,, 'CJ:i~" 1" :.-</*'.{'

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Jv5-':: >5<;:~ N-1 Seismic N-1 Seismic Seismic event indicated by: . ' Seismic.event indicated by: 1. Seismic instrument activated

1. Seismic instrument activated OR OR 2. Ground motion detected by Control 2. Ground motion detected by Control Room crew Room crew AND I: 1. Visible major damage in vital / area. OR 2. Plant Trip. I: N-2 Tornado/wind

' N-2 Tornado/wind

1. Tornado strike in Vital Area 1. Tornado strike within Protected Area. OR 2. >90 moh wind for >15 minutes. N-3 Structural Visible damage to a structure containing systems required to achieve and maintain Mode 5. N-4 Vehicle Collision N-4 Vehicle Collision Vehicle collision affecting Vital Area. Vehicle collision affecting systems or structures within the Protected Area. N-5 MT Failure ' N-5 MT Failure Main turbine generated missile Main turbine rotating component failure penetrates Vital Area. causes visible damage or damages aenerafor seals. N-6 Flooding Flooding in Vital Area affects safety related eauioment.

N-7 Explosion Unanticipated explosion within Protected Area causes visible damage to oermanent structures or enuioment. Planning Standard D CEP Rev 39 Page 63 of 212 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT -/ IABl\l0RMA*LRAD1AT10N ,LEVEL;S11;1;fl:;UEI\IJ"S: . , ;:, , , ,c'" . ii;': 5 .* ": ;! *: ' *' I~*--, . cc;:: I~-. ,_ ,* .. '-'**; '" \ 'h /' t-' -'.\:;,>:*_

I ., ' *--;, .-R-1 Effluent release R-1 Effluent release R-1 Effluent release R-1 Effluent release Site boundary dose > 1 REM TEDE or 5 Site boundary dose> 100 mrem TEDE or Unplanned Rad release >200X ODCM Unplanned Rad release >2X ODCM limits REM CDE to thyroid based on: 500 mrem CDE to thyroid based on: limits for >15 minutes based on: for> 60 minutes based on: 1. Survey results 1. Survey results 1. Effluent Rad monitor 200X high 1. Effluent Rad monitor 2X high alarm 0R OR alarm setpoint.

setpoint.

2. Dose assessment

2. Dose assessment OR OR OR OR 2. Release Rad monitor 200X high 2. Release Rad monitor 2X high alarm 3. Effluent monitor readings >15 3. Effluent monitor readings >15 alarm setpoint.

setpoint. minutes minutes. OR OR L L 3. Gas or liquid sample results 200X 3. Gas or liquid sample results 2X ODCM release limit. ODCM release limit. L L R-2 Plant Rad level R-2 Plant Rad level Rad levels that impede plant operations Unexpected reading on Area Monitor based on: 1 OOOX the 24 hr average. 1. >15 mR/hr in Control Rm(s) /CAS OR 2. >100 mR/hr at remote S/D areas. L R-3 Loss of level R-3 Loss of level Major damage to irradiated fuel or loss of Uncontrolled lowering in refueling cavity, level that has or will uncover fuel outside SFP or Transfer Canal indicated by: of the reactor vessel based on; 1. Inability to maintain > 643'4" in SFP 1. Visual observation of levels. or Transfer Canal with irradiated fuel OR present 2. Rad monitor alarms OR OR 2. Inability to maintain > 643'4" in the 3. Level < 632'4" SFP or Transfer refueling cavity with irradiated fuel in Canal. containment. L Planning Standard D CEP Rev 39 Page 64 of 212 !GENERAL EMERGENCY !ALERT : 1! 7,i t ' C {,,,~ -.~; <>".!:,S'.,;.-,_;;Vfc. .;,:; *,}. :f~,~\-->>,> t,*~ 1 ,T--L.<./>'.'*~*t"'

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C **""'"-k'<l,' ,\". \ ,,;_ . .,.,,~ .. ,, c, ,,,,,. S-1 RPS failure S-1 RPS failure S-1 RPS failure 1. Auto and manual Reactor Trip fails Auto and manual Reactor Trip fails from Auto Reactor Trip fails AND manual trip from Control Room AND Control Room. successful from Control Room. Subcriticality and Core Cooling CSFSTs are RED OR 2. Subcriticality and Heat Sink CSFSTs are RED. S-2 Loss of AC S-2 Loss of AC S-2 Loss of AC S-2 Loss of AC 1. Prolonged loss of all AC (A and D -T Loss of all AC (A and D -T buses) for AC power supply to T buses reduced to a Loss of ALL OFF-SITE power (Auxiliary, buses) AND. Core Cooling CSFST ->15 minutes. single source for> 15 minutes. Reserve and 69kv Transformers) to the T ORANGE. Buses for> 15 minutes. OR e 2. Loss of all AC (A and D -T buses) L L expected to last for> 4 hrs. S-3Loss of DC power Loss of ALL vital DC buses AB AND CD
for > 15 minutes (bus volts < 220v) S-5Loss of Hot SD sys. Loss of apility to achieve or maintain hot shutdown based on entry into: I / 1. OHP 4023.FR-H.1, Response to Loss of Secondary Heat Sink OR e 2. OHP 4023.FR-C.1, Response to Inadequate Core Coolina. Planning Standard D CEP Rev 39 GENERAL EMERGENCY S-6 Loss of Alarms Loss of ability to monitor alarms during a transient indicated by: 1. Loss of Safety System annunciator panel(s) for> 15 minutes. AND 2. A known loss of Attachment 2 Critical Parameters indications for> 15 minutes. AND 3. Compensatory indications NOT available (PPC, SPDS). AND 4. A significant transient is in progress.

L S-6 Loss of Alarms 1. Loss of either: a. Safety system annunciator panels in a unit for > 15 minutes OR b. A known loss*ot Attachment 2 Critical Parameters indications for> 15 minutes AND 2. Additional monitoring is required. AND 3. Annunciator/Indicator loss does not result from PLANNED action. AND 4. Either a. A significant transient is in progress, OR b. Compensatory Indications NOT available L Planning Standard D Page 65 of 212 S-6 Loss of Alarms 1. Loss of either: a. Safety system annunciator panels in a unit for > 15 minutes OR b. A known loss of Attachment 2 Critical Parameters indications for> 15 minutes AND 2. Additional monitoring is required. AND 3. Annunciator/Indicator loss does not result from PLANNED action. AND 4. Compensatory Indications are available. S-7 Degraded Clad 1. RCS activity> 1.0 µCi/gram 1-131 dose equivalent for> 48 hrs. OR 2. RCS activity> 215.1 µCi/gram Xe-133 dose e uivalent. S-8 RCS Leakage 1. RCS leakage exceeds 10 gpm pressure boundary leakage, SG tube leakage or unidentified leakage OR 2. > 25 m identified leaka e. S-9 Tech Spec Unit not in required mode within LCO time limits. S-10 Loss of Comm. Unplanned loss of all on or off-site communications CEP Rev 39 !GENERAL EMERGENCY 1seo Jl.JDGMEN:r . *

H-1 SEO Judgment Conditions indicate actual or imminent substantial core damage with potential loss of containment or the potential exists for an uncontrolled radioactive release that may exceed EPA limits at the site
bounda tHAZARDS AND OTHJ;R CONDITION~
H-2 Security HOSTILE ACTION resulting in Loss of Physical Control of the Facility.

1. A HOSTILE ACTION has occurred such that plant personnel are unable to operate equipment required to maintain safety functions listed below:

Reactivity Control (ability to shut down the reactor and keep it shutdown)
RCS Inventory (ability to cool the core)
Secondary Heat Removal (ability to maintain heat sink) OR 2. A HOSTILE ACTION has caused failure of spent fuel cooling systems and IMMINENT fuel damage is likely. L Table 4 INITIATING.

CONDITIONS-Mode 5 & 6 and Defueled I SITE AREA EMERGENCY I ALERT H-1 SEO Judgment Conditions indicate likely or actual major failures of plant functions needed to protect the public. : ;', . H-2 Security HOSTILE ACTION within the PROTECTED AREA 1. A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA as reported by the Security Shift Supervisor. H-3 CR Evacuation L Control Room evacuated AND control not established in 15 minutes. L H-1 SEO Judgment Conditions indicate that plant safety systems may be degraded and additional personnel are needed for additional monitoring. C '" 0 H-2 Security HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat. 1. A HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED AREA as reported by the Security Shift Supervisor. OR 2. A validated notification from the NRC of a LARGE AIRCRAFT attack threat within 30 minutes of the site. e L H-3 CR Evacuation Control Room evacuation initiated. H-4 Fire ' Fire OR explosion affecting plant operations. L H-5 Toxic Gas Toxic OR flammable gas release that threatens lives OR affects ability to achieve and maintain Mode 5. L Planning Standard D Page 66 of 212 I UNUSUAL EVENT H-1 SEO Judgment Conditions indicate a potential degradation of the level of safety of the plant. -e H-2 Security Confirmed Security Condition which indicates a potential degradation in the level of safety of the plant. 1. SECURITY CONDITION that does not involve a HOSTILE ACTION as reported by Security Shift Supervision. OR l 2. A credible site-specific security threat notification. OR 3. A validated notification from NRC providing information of an aircraft threat. L H-4 Fire Fire in Protected Area NOT extinguished within 15 minutes of detection. H-5 Toxic Gas Toxic OR flammable gas release affecting plant operation. L H-8 ISFSI Damage to a loaded cask CONFINEMENT BOUNDARY. CEP Rev 39 I GENERAL EMERGENCY I SITE AREA EMERGENCY I ALERT N-1 Seismic Seismic event indicated by: 1. Seismic instrument activated OR 2. Ground motion detected by Control Room crew AND 1. Visible major damage in vital area. OR 2. Plant Trip. N-2 Tornado/wind

1. Tornado strike in Vital Area OR 2. >90 moh wind for >15 minutes. N-3 Structural Visible damage to a structure containing systems required to achieve and maintain Mode 5. N-4 Vehicle Collision Vehicle collision affecting Vital Area. N-5 MT Failure Main turbine generated missile penetrates Vital Area. N-6 Flooding Flooding in Vital Area affects safety related eauioment.

Planning Standard D Page 67 of 212 I UNUSUAL EVENT N-1 Seismic Seismic event indicated by: 1. Seismic instrument activated OR 2. Ground motion detected by Control Room crew N-2 Tornado/wind

1. Tornado strike within Protected Area. N-4 Vehicle Collision Vehicle collision affecting systems or structures within the Protected Area. N-5 MT Failure Main turbine rotating component failure causes visible damage or damages generator .seals. N-7 Explosion Unanticipated explosion within Protected Area causes visible damage to permanent structures or equipment.

CEP Rev 39 Page 68 of 212 I GENERAL EMERGENCY I SITE AREA EMERGENCY R-1 Effluent release R-1 Effluent release R-1 Effluent release , R-1 Effluent release Site boundary dose> 1 REM TEDE or 5 Site boundary dose> 100 mrem TEDE or Unplanned Rad release >200X ODCM Unplanned Rad release >2X ODCM limits REM CDE to thyroid based on: 500 mrem CDE to thyroid based on: 1. Survey results 1. Survey results 2. 3. OR OR Dose assessment OR Effluent monitor readings >15 minutes 2. 3. Dose assessment .OR Effluent monitor readings >15 minutes.

limits for >15 minutes based on: for> 60 minutes based on: 1. Effluent Rad monitor 200X high 1. Effluent Rad monitor 2X high alarm alarm setpoint.

setpoint.

2. OR Release Rad monitor 200X high alarm setpoint.

OR L 3. Gas or liquid sample results 200X ODCM release limit. R-2 Plant Rad level Rad levels that impede plant operations based on: 1. >15 mR/hr in Control Rm(s) /CAS OR 2. >100 mR/hr at remote SID areas. R-3 Loss of level L Major damage to irradiated fuel or loss of level that has or will uncover fuel outside of the reactor vessel based on! 1. Visual observation of levels. OR 2. Rad monitor alarms OR 3. Level < 6324" SFP or Transfer Canal. 2. OR Release Rad monitor 2X high alarm setpoint. OR 3. Gas or liquid sample results 2X ODCM release limit. R-2 Plant Rad level Unexpected reading on Area Monitor 1 OOOX the 24 hr average. R-3 Loss of level Uncontrolled lowering in refueling cavity, SFP or Transfer Canal indicated by: 1. Inability to maintain > 643'4" in SFP or Transfer Canal with irradiated fuel present OR 2. Inability to maintain > 643'4" in the refueling cavity with irradiated fuel in containment. Planning Standard D CEP Rev 39 Page 69 of 212 \GENERAL EMERGENCY \ SITE AREA EMERGENCY \ALERT \ UNUSUAL EVENT [ C:!!)1:.p;:5 l;:ll!JJ00WN/~.!:f UEl!1NG1SYS1];M 'il\ll;l\Uf;UNC:]IONS:s, ,. :;J, ii:,;::,.::;:~;,{::

2;;*;.1::t:i:.:::.;t**

' t <'-',-_.f:::d;;;

1fft*c* 1-**: ;-"';\?<(}"'Tr,,:

.. :r*/\r1-{i '.ij.~ ,,;:.i:~*t} .. (~--E\:~-',?,'!>,,,~*:;., .. ,., 1'i":i':fftrr~i:::*.\.*?::"~'.;i1t0::; 11£(tr::~\:1r:::*!Jf'!%, C-3 Loss of AC C-3 Loss of AC Loss of ALL AC power to A and D T-Loss of ALL OFF-SITE power (Auxiliary, buses for> 15 minutes. Reserve and 69kv transformers) to the T buses for> 15 minutes. Mode 5,6 and defueled Mode 5,6 C-4 Loss of Water Level in the Reactor C-4 Inability to Maintain a Unit in Cold Vessel that has or will Uncover Fuel in Shutdown the Reactor Vessel 1. Loss of shutdown cooling as 1. Loss of shutdown cooling as evidenced by entry into OHP evidenced by entry into OHP 4022.017.001, "Loss of RHR 4022.017.001, "Loss of RHR Cooling" e Cooling" AND AND 2. Temperature rise that either: 2. Core uncovery as indicated by: a. Exceeds TIS cold shutdown limit a. RVLIS NR <46% -0 RCPs of 200°F OR OR b. Reactor Vessel Water Level b. Results in an UNCONTROLLED <614 feet. RCS temperature rise approaching the cold shutdown T/S limit of 200°F Mode 5,6 Mode 5,6 ' C-5 Degraded Clad 1. RCS activity> 1.0 µCi/gram 1-131 dose equivalent for > 48 hrs. OR 2. RCS activity> 215.1 µCi/gram Xe-133 dose equivalent. Mode 5,6 C-6 Loss of Comm. Unplanned loss of all on or off-site communications. Mode 5,6 ' C-7 Loss of DC power Unplanned loss of ALL vital DC buses AB AND CD for >15 minutes (bus volts ,920v) Modes 5,6 Planning Standard D CEP Rev 39 Page 70 of 212 PLANNING STANDARD E NOTIFICATION METHODS AND PROCEDURES Planning Standard E CEP Rev 39 Page 71 of 212 E. NOTIFICATION OF EMERGENCY RESPONSE PERSONNEL AND ORGANIZATIONS E.1. Notification of Offsite Response Organizations During an emergency condition, control of offsite actions rests with the appropriate government authorities with technical assistance provided by various members of the plant staff. This technical assistance is provided through the use of the plant's communication system. A current list of all key support agencies with their telephone numbers is maintained in the Shift Manager's office so that they may be notified of any emergency condition. This call list is incorporated into the plant Emergency Plan P_rocedures and is checked quarterly to verify that all phone numbers on the list are correct. It is the responsibility of the SM, acting as the SED early in an event, the SED; or the ED, once the EOF is operational, to ensure that these offsite response organizations are notified. Notification shall include the message authentication in order to permit further action by the Sheriff's Department. Notification is given to the B~rrien County Sheriff's D~partment and to the Mifhigan State Police Operations Office in Lansing, Michigan within 15 minutes following the recognition and

verification of an Unusual Event, Alert, Site Area Emergency, or General Emergency condition.

Any incident that requires initiation of the Nuclear Emergency Alarm requires notification of the NRC and notification of the appropriate offsite groups. Upon notification with authentication, the Berrien County Emergency Operations Plan will be implemented. The Berrien County Sheriff's Department has established a county Emergency Operating Center (EOC) in Benton Harbor, Michigan, which will be the focal point for immediate offsite county agency actions when notified of an emergency condition. The Berrien County Sheriff is the Berrien County Administrator of the Office of Emergency Management/Homeland Security and is responsible for coordinating all local resources when notified of an emergency condition.

An offsite liaison is sent to the Berrien County EOC at the emergency classification of Alert or higher classification.

The liaison assists in the interpretation of incoming plant reports, and acts

as the liaison between the Plant and the Berrien County Sheriff's Department.

The organization of the Department of State Police is such that initial notification is made to the Michigan Intelligence Operations Center (MIOC) in Lansing, Michigan. The Michigan State Police will then set up an EOC at 7150 Harris Drive; Dimondale, Ml 48821\: An offsite liaison will also be sent to the State EOC upon activation by the State Police to perform a function similar to that of the person at the Berrien County EOC. Plant status updates will be provided to the State and County using separate lines. All communications, where practical, to the State and County will be via the offsite liaison at their respective EOCs. Immediately following the initial notification of the Berrien County Sheriff's Department and the Michigan State Police, the SM/SEO/ED shall also notify the Nuclear Regulatory Commission's Operations Center, and the appropriate senior AEPNGG management. The decision to evacuate offsite individuals or to take other protective action rests with the appropriate civil authorities. The SEO or ED is responsible for notifying the appropriate State/County authorities that the conditions for offsite protective actions have been reached. Figure 8 shows the initial notification process for nuclear incidents. A current list of all appropriate company officials and county, state and federal a\_lthorities with their telephone numbers is maintained as part of the plant ERO Phone Directory. A listing of offsite support groups is attached as Appendix B. Planning Standard E CEP Rev 39 Page 72 of 212 E.1.a Notification of Nuclear Transportation Accidents Incidents involving nuclear material that result from transportation accidents offsite as specified in Section C.4.b and within the service territory of AEP shall be reported to the applicable state government. The appropriate information required in Sections E.3 and E.4 and other pertinent information shall be provided as necessary. If the Plant has been requested to respond to a transportation accident involving nuclear material by another utility under the Voluntary Assistance Agreement, the Plant shall inform the state and Berrien County government of the request; nature and location of the accident, expected response and recommended precautions to be taken by the responsible offsite authorities. The response team shall keep the on-scene government representatives and the Plant informed on the status of the accident.

E.2 ERO Alert, Notification and Mobilization E.2.a Onsite (Plant Staff) If art emergency condition sbould arise that would affect individuals on or of(,site, this emergency plan will be initiated; There are two plant emergency alarms: A Fire Alarm and a Nuclear Emergency Alarm. Each audible signal is unique and easily distinguishable so that no confusion as to its purpose will develop. If the incident or condition is a fire, the Fire Alarm is sounded . . The Nuclear Emergency Alarm is a horn designed to produce a distinct sound different from any other alarms in the plant. It may be activated manually from either the Unit 1 Control Room or Unit 2 Control Room. The senior supervisor of the on-duty shift (e.g., the Shift Manager) has the authority to activate the Nuclear Emergency Alarm. In the absence of the Shift Manager, the
senior NRC licensed operator assigned in the Control Room has the authority to activate the Nuclear Emergency Alarm. An announcement over the Plant Public Address System (PA) identifying the incident will be made including a brief description of the incident, and the . appropriate alarm for the determined condition will be sounded throughout the plant and at the switchyard.

In addition, in certain areas where the PA system and/or the Nuclear Emergency Alarm are not audible, strobe lights are installed to provide a visual warning signal. In the case of some Security events, the Nuclear Emergency Alarm would not be sounded. Persons responding to the NEA could become targets of opportunity. Instructions to onsite personnel would be made using the Plant PA system. Immediate sounding of the Nuclear Emergency Alarm is required for incidents which, in the judgment ofthe Shift Manager, result in:

release of radioactivity that could cause conditions for excessive exposure to plant personnel, or
plant conditions that could cause conditions for excessive exposure to plant personnel, or
a Site Area Emergency, or General Emergency, except where harm to personnel is possible (e.g. Security event driving the SAE or GE). Planning Standard E CEP Rev39 Page 73 of 212 The sounding of the Nuclear Emergency Alarm dictates an immediate evacuation of all plant personnel and plant visitors to the onsite assembly areas identified in Section J.1. with the exceptions that: 1. The operators on duty for each unit report to their respective Control Room. 2. Personnel designated as part of the plant Emergency Response Organization report to their assigned facilities. (i.e. TSC, OSC, EOF, ENC/JIC) 3. Individuals in outlying areas of the plant are informed by Site Protective Services of the emergency classification in effect and the action to be taken .. 4. Security personnel will remain on post unless otherwise directed.

5. Initiation of the procedures for evacuation of all employees and visitors within the Cook Energy Information Center. * .

Immediately after initiation of the Nuclear Emergency Alarm, the emergency call list is initiated, if not already initiated, and measures are taken by the Shift Manager and Shift Technical Advisor to evaluate conditions on the site. The decision to take onsite protective actions, beyond sounding of the Nuclear Emergency Alarm is the responsibility of the SEO. Any Emergency Plan incident other than routine tests that requires initiation
of the Nuclear Emergency Alarm requires notification of the NRC by the SEO or ED and notification of appropriate offsite groups as determined by the SEO or ED. E.2.b Offsite (Plant Staff) An Emergency Plan Procedure for notification of plant personnel and an ERO Phone Directory have been developed to provide the information that is necessary to summon plant personnel during emergency conditions to staff the Emergency Response Facilities.

This procedure may be implemented anytime the SEO determines that it is necessary to augment on duty emergency personnel with off-duty plant personnel. A current list of all key personnel with their telephone numbers is maintained in the Shift Manager's office so that they may be notified. This call list is incorporated into the ERO Phone Directory and is checked quarterly to verify that all phone numbers on the list are correct. When the Nuclear Emergency Alarm is sounded, notification of the Site Vice President (or Alternate), and Operations Director is the responsibility of the Shift Manager or designee. Calls mar,e by on-shift personnel initiate the ERO call out to staff the Emergency Response Facilities. If the automated ERO Notification System (ERONS) fails, a backup manual call out procedure is initiated. Personnel that are called out, or are on call, report to their assigned Emergency Response Facility immediately upon receiving notification to respond at an Alert or higher emergency classification. In the event of security related event the notification alerts the emergency response personnel, who normally report to on-site facilities, to report to an alternate location such as the Buchanan Office Building. Planning Standard E CEP Rev 39 ./ Page 74 of 212 Once the Nuclear Emergency Alarm has sounded, only authorized personnel are permitted to enter the Owner Controlled Area. This access control is a function of the Plant Security Force which may be further augmented by the Berrien County Sheriff and/or the Michigan State Police.

E.3. Content of Initial Emergency Messages Initial emergency messages sent from the Plant to appropriate offsite response organizations shall contain the information listed below, as it becomes available.

1. Class of Emergency.

2. Date and time of classification.

3. Indicate if a release is occurring or has occurred .. 4. Wind directiori and wind speed . . 5. Protective Measures recommended (if known) based on magnitude or severity of an actual release and current meteorological conditions, or the condition of the core/containment.

6. Potentially affected population areas. 7. Plant name 8. Verification to confirm authenticity of call. E.4 Content of Follow-up Emergency Messages Follow-up messages sent from the Plant to appropriate offsite. response organizations should contain the following information, as it becomes available:

1. Location of incident, name and telephone number (or communication channel identification) of caller. 2. Type and description

of release (airborne, waterborne, surface spill) and estimated duration/impact times (actual or projected).

3. An estimate of the quantity of radioactive material released or being released and the release point. 4. Physical form of released material, including estimates of the relative quantities of noble gases, iodines and particulates.

5. Meteorological conditions (wind speed, direction,*

atmospheric stability, or precipitation, if any). 6. Projected dose rate at site boundary, integrated dose from time of message to projected end of release at site boundary.

7. Projected dose rate and integrated dose for 2, 5 and 10 miles. 8. Prognosis for worsening or terminating the event based on plant information.

Planning Standard E CEP Rev 39

~

Page 75 of 212 E.5 Not Applicable E.6. Public Notification The Berrien County Sheriff is responsible for overall supervision of the warning function for offsite actions. The Berrien County Emergency Operations Plan-Nuclear Power Plant Incident Procedures contain the time estimated for adverse and favorable conditions for various sectors in the 10 mile EPZ for 2 mile, 5 mile, and 1 O mile radii. The time estimates include the times required for:

Notification
Public Preparation
Movement
Total Evacuation
Confirmation
Evacuation

& Confirmation

Special Considerations to include or consider in each sector The Berrien County Plan includes provisions for: 1. Alerting local radio, television stations and, local news media to be prepared to transmit Emergency Public Information.

This initial notification will be accomplished via a radio receiver/transmitter that will record the emergency information transmitted by the Sheriffs Department to designated locations simultaneously. Additional information will be provided as described in Section G. 2. Coordination with other law enforcement and fire services to extend public notification of the appropriate Emergency Plan areas utilizing public address systems on emergency vehicles.

3. Warning of the Warren Dunes park (recreation) area populace of the emergency and action to be ta'5en. 4. Activation and use of the emergency warning system consisting of sirens located throughout the 10 mile EPZ. Activation of this system is controlled solely by the Berrien County Sheriff* and is based upon recommendations made by the appropriate authority.

The D. C. Cook Plant Emergency Preparedness Department has overall responsibility for testing, maintenance, and repair of the Alert and Notification System (ANS) Sirens. The ANS is the primary method for alerting and notifying the population within the plume exposure EPZ. Backup ANS for the EPZ is achieved through Route Alerting which is contained within the Alert and Notification System (ANS) Design Report and the State of Michigan and Berrien County Radiological Emergency Response Plans. Refer to Appendix B for FEMA letter describing the provisions for ANS. Planning Standard E CEP Rev 39 Page 76 of 212 A description of the warning system is in the emergency preparedness brochure/calendar provided in Appendix D, Emergency Preparedness Brochure. E.7. Public Information Messages * . The State of Michigan and Berrien County have developed and incorporated in their respective emergency plans sample messages for release of information to the public. These messages Will utilize supporting information obtained directly from the Plant or from the plant liaison persons located at the Berrien County EOC, State EOC and at the JIC (when activated). Using the information gathered from various sources, the message(s) will contain pertinent information to the public for the declared emergency classification. The message(s) describe the* warning, sheltering, evacuation and other protective measures deemed necessary by the appropriate County and/or State officials. -* Additionally, Berrien County has prepared sample Public Information Bulletins to provide pertinent information on protective actions that may be taken in the event of a nuclear incident. These bulletins are shown in the Berrien County Emergency Plan. Planning Standard E CEP Rev 39 "-.' Berrien County State Police NRC Figure 9 Nuclear Incident Initial Notification Process Control Room Alternate Planning Standard E Nuclear Emergency or Fire Alarm Senior Vice Nuclear Generation Emergency PreJ)ilredness Coordinators Page 77 of 212 CEP Rev 39 I Page 78 of 212 Figure 10 CNP Emergency Response Communications Flow I I I I I L.:..._ I I 1--1 CONTROL ROOM OPERATIONS SUPPORT CENTER NRC EMERGENCY NEWS CENTER!,, JOINTINFORMATION ,,/ CENTER ,,,,,, / / / / / / EMERGENCY OPERATIONS FACILITY ,,,,,,,,STATE ,, ,, ,,COMMUNICATIONS ,,,,,, COORDINATOR NEWS '-----.. MEDIA & PUBLIC GOVERNOR . NSSS/FUEL PROVIDER(S) CONSULTANTS i+--~ AMERICAN NUCLEAR '--ICP STATEEOC BERRIEN COUNTYEOC ~------.i INSURERS COOK NUCLEAR PLANT EMERGENCY RESPONSE COMMUNICATIONS FLOW SHORT-TERM FLOW LONG-TERM FLOW OTHER LOCAL/STATE/ '+--~ FEDERAL GOVERNMENT AGENCIES Planning Standard E CEP Rev 39 Page 79 of 212 PLANNING STANDARD F EMERGENCY COMMUNICATIONS Planning Standard F CEP Rev 39 Page 80 of 212 F. EMERGENCY COMMUNICATIONS F.1. Licensee, Local. State. and NRC Emergency Communications Implementation procedures for the use of communication networks to notify all parts of the emergency organization are outlined in the CNP Emergency Plan Procedures that are available in each of the emergency response facilities. The communications network consists of communications systems that are available on a 24 hours per day basis to communicate with

AEP personnel, *State, County, and the NRC during emergency conditions.

F.1.a. State and Local Communications The Berrien County Sheriff's Department and the Michigan State Police dispatch are continuously staffed so capability exists for 24-hour radio and telephone communication with the Plant. The telephone and radio links to the Berrien County Sheriff's Department dispatchers also accesses the county emergency response organizations. The 911 system is. an alternate m~thod to access the cou(lty emergency respons~ organizations. The primary means of notification to the Sheriff's Department is by telephone. As an alternate, notification of an emergency to the Sheriff's Department in Berrien County is made with a transmitter and receiver combination device from the Unit 1 Control Room. This device is operated with a frequency and a license maintained by the State of Michigan. Controls for the device are also available on the Plant Security consoles. This establishes a communication link between the Control Room and the Sheriff's Department in Berrien County'. The primary means

of notification to the State Police Operations Center in Lansing is by telephone.

A back-up radio system is maintained between CNP and the Michigan Department of State Police in Niles, Michigan. In this system, a radio transceiver maintained at the CNP is set at a frequency used by the State Police. These radios are equipped such that the State Police are assured that any transmissions to them originated at the Cook Plant. Communications between CNP and the local fire departments are by means of telephone calls. The fire departments would respond immediately upon notification of an emergency at CNP. Radio communication capability is provided to contact the Berrien County Sheriff's* Department and the Michigan Department of State Police Post 53 (in Niles) from the Unit 1 Control Room, Central Alarm Station (CAS), and the Secondary Alarm Station (SAS) in the event of failure of telephone company circuits. Suitable normal and back-up power supplies are also provided. Bridgman Local Telephone Service Local commercial telephone service provides circuits between Bridgman and the CNP. F.1.b. Communications with Contiguous Governments in the EPZ's Notifying the State of Indiana and the Michigan counties within a 50 mile radius of CNP of the incident classification, protective actions recommended, etc. is the responsibility of the Berrien County Sheriff's Department and the Michigan. Department of State Police. Berrien County and Michigan is the only county and state within a 10 mile radius of CNP. Planning Standard F CEP Rev 39 Page 81 of 212 F.1.c. Communications with Federal Emergency Response Organizations The "Communications" section of Appendix E, Description of Federal Radiological Assistance, outlines communication with the DOE Radiological Assistance Plan responders. F.1.d Offsite Communications The communications system at CNP provides the versatility required in the event of a nuclear incident. The system operation utilizes private telephone lines,* dedicated microwave links (OPX), 2-way* radio, the normal in-plant communication system (PABX), and the capability to reach outside extensions through various system company switchboards. The emergency response centers will have the following communications capability: PABX/ OPX Private Fire/Erner. Offsite ENS *HPN Microwave Lines Radio Radios Control Room X X' X X X TSC (SS) X X X X X X .. .. "' osc X X X EOF X' X X X X X Plant Mgr's Office X ENC/JIG X X 1 The EOF utilizes the Buchanan Office Building PABX and has access to a local commercial provider and AEP microwave capability. 2 Two telephone lines in each Control Room automatically bypass the plant PABX if it fails. Communications between CNP and the Offsite Survey Team(s) are made by portable radios. These radios are maintained in the dedicated survey vehicles, emergency facilities, and are assigned for use to plant operating departments. AEP Microwave/Fiber Optics System This system allows direct communication to major media stations and AEP offices. It provides fast and reliable support for the plant in the event of an emergency. The CNP switchboard has "tie trunks" to Buchanan, Michigan and Fort Wayne, Indiana. Direct, dedicated microwave channels are established 24 hours per day between Cook Plant, and both Fort Wayne, Indiana and Buchanan, Michigan. The microwave facilities at CNP are powered by their own battery that is constantly serviced by a trickle charger, powered from an AC station auxiliary. In the event of a failure in this AC line, an emergency generator automatically takes over the supply of power to the charger. The battery alone is capable of operating the microwave facilities for approximately 8 hours. F.1.e. Alerting and Activating Emergency Response Organization and Personnel Plant Public Address System The Plant Public Address (PA) System is powered by the Critical Control Room Power Supply and is automatically switched to a backup supply from the diesel generator in the event that the normal power supply is lost. Planning Standard F CEP Rev 39 Page 82 of 212 The Plant PA System provides paging to all major buildings of the plant including the office and service building. This system includes a five-party channel system for two-way communications. It should be noted that this system cannot be used to notify offsite persons of an incident. Other systems are available for this use. Plant Private Automatic Branch Exchange Plant Telephone System The Private Automatic Branch Exchange Plant Telephone System (PABX) is powered by its own battery on a trickle charger. PABX System installations are located in areas most frequently occupied by plant personnel, including the plant's emergency response organization. Security Radio A portable radio sy§tem is installed for secwity communications. T.bis system uses dual *. transmitters to provide a dual frequency capability. Radio coverage includes all general areas onsite. If necessary, this system can be used .as a back-up means of communication onsite in the event of an emergency. Fire and Emergency Radio A portable radio system is installed for fire and emergency communications. This system is powered from a non-emergency bus and provided with backup battery power. The fire and emergency radio coverage includes all general areas onsite, excluding containment. This system is also utilized for medical emergencies, field team communications, etc. F.1.f Emergency Communications with the NRC Communications with the NRC Headquarters is by dedicated telephone lines from the Control Rooms, TSC, and EOF. The Federal Telecommunications System (FTS) is used to communicate with NRC Headquarters, in White Flint, Maryland. Communications with Region Ill headquarters, located in Lisle, Illinois, is by commercial tefephone lines and the FTS. Health Physics Network (HPN) A FTS telephone line has been installed between the Plant and the NRC, which is primarily intended for use during an emergency and will function as the Health Physics Network (HPN) dedicated line. A total of three extensions are located at AEP facilities in:

NRC Resident Inspector's Office
TSC
EOF This line will be utilized to provide specific information to the NRC regarding significant radiological events at the Plant. Information transmitted to the NRC, excluding that originating from the Resident Inspector's Office, must be approved by the appropriate emergency response management personnel prior to its transmittal.

The HPN telephones will be staffed by the licensee. Planning Standard F CEP Rev 39 F.2 Page 83 of 212 Emergency Notification System (ENS) The Emergency Notification System (ENS) is intended for use as the primary means for the Plant to report emergencies and other significant events to the NRG. This FTS line will serve as a dedicated line to provide operational data to the NRG during a declared emergency. A total of five extensions are located at AEP facilities in:

TSC
Control Rooms
NRC Resident Inspector's Office
EOF Communications over the ENS telephone will be initiated by Control Room personnel if a nuclear emergency occurs at CNP. Licensee personnel will staff the ENS telephones at the EOF when the EOF is activated.

Emergency Response Data System (EROS) The Emergency Response Data System (EROS) is a direct electronic data link between CNP computer systems and the NRG Operations Center. Types of data transmitted include information on the plant's primary and secondary coolant systems, safety injection system, and radiation monitoring systems. Data is updated at approximately 5-second intervals. Medical Support Communications Communications between CNP and the offsite medical facilities are made by telephone calls and are authenticated for contaminated patients only. F.3 Communications Systems Testing Communication links between the NRG Operations Centers and the CNP TSC and EOF via the Emergency Notification System (red phone) are tested monthly for operability. In addition, the Control Room communication link with the NRG Operations Centers is tested for operability on a daily basis. Communication links between the Plant and Berrien County Sheriffs Department, and the Michigan Department of State Police have been established and are tested monthly at a minimum. Communications with Offsite Survey Teams will be tested at least annually to ensure an understanding of the content of the messages in the drills. Planning Standard F CEP Rev 39 Page 84 of 212 The majority of the communications systems are tested ori a daily basis through normal use. The radio communications to the Berrien County Sheriffs Department and Michigan Department of State Police are tested daily. An annual drill is conducted with the offsite emergency response personnel including those of State and County agencies if these authorities desire to participate. As a minimum, each annual drill (~xercise) tests the communication links and notification procedures with State and County agencies to ensure the proper flow of information in the event of a nuclear incident. Planning Standard F CEP Rev 39 Page 85 of 212 PLANNING STANDARD G PUBLIC EDUCATION AND INFORMATION Planning Standard G CEP Rev 39 Page 86 of 212 G. PUBLIC EDUCATION AND INFORMATION The utility industry's experience has consistently shown that offsite public reaction is more . favorable when information originates with the utility, and that notification of appropriate county, state and federal agencies is made prior to any public announcement to ensure that the information presented is fully understood by all parties and does not conflict with news reports and information transmitted to any agencies by other sources. Press briefings will be arranged in conjunction with appropriate agency officials to permit a consistent and timely exchange of information. The ENC/JIC personnel manage information release on the incident by: * . Gathering information on the incident, preparing, and approving information releases to the media. *

providing a single location for use by the media for obtaining information about the incident.
Monitoring the broadcast media for discrepancies between approved media releases and broadcast information.
Answering questions posed by callers to the Public Inquiry telephone lines. The ENC/JIC facility shall.be activated for any Alert, Site Area Emergency, or General Emergency.

The goal is to have ENC/JIC staffed approximately 90 minutes after declaration of an Alert, Site Area Emergency, or General Emergency.

G.1. Public Information American Electric Power (AEP) annually distributes emergency educational information to the public within the Emergency Planning Zone (EPZ) in conjunction with Berrien County and the Michigan Department of State Police -Emergency Management and Homeland Security Division.

Such information includes the warning methodology used in notification of the public, educational information on radiation, personnel or agencies to contact for additional information, and sheltering and evacuation procedures used in the event of a nuclear incident. Appendix D is an example of the emergency educational information material that is distributed annually. G.2 Distribution of Public Information The above emergency educational information was distributed to the public initially and is updated annually. This information is sent to all Berrien County residences and businesses, as well as Niles and other locations served by municipal power. This mailing includes those living and working both inside and near the 1 O mile EPZ. New electric service customers are sent a

copy of the emergency educational information and are added to the annual mailing.
The brochure is also distributed to Warren Dunes State Park, local motels, hotels, nursing homes, marinas, and apartment complexes.

Selected camping and recreational areas that are part of the 10 mile EPZ most frequently used by large segments of the transient population will also be provided with similar information. The Cook Energy Information Center Manager is responsible for the annual distribution of emergency educational information to the public within the 10 mile EPZ. Planning Standard G CEP Rev 39 Page 87 of 212 G.3. Emergency News Center/Joint Information Center (ENC/JIC) The Emergency News Center/Joint Information Center (ENC/JIC) provides a single location for issuing information on incidents and Company response about incidents to the news media. The Emergency News Center/Joint Information Center (ENC/JIC) is located in the. Nuclear Generation Group Headquarters Building located approximately 14 miles southeast of the plant site in Buchanan, Michigan. The ENC/JIC shares the first floor of the building with the EOF. Media access is allowed to an auditorium area, media work area, and lobby* area of the building through a guarded main entranceway. Access to all other areas and entrances to the building are locked, barricaded, or guarded to prevent media intrusion into the EOF, corporate offices, or the ERO staffed portion of the ENC/JIC. The auditorium provides the location for briefings by the utility Spokesperson and representatives of any other agencies responding to the incident. Space and electrical power are provided for media c.1;1meras to be set up for ~broadcasting briefings. An area adjacent to but separate from the auditorium is set up as a media work area with desks, chairs, and phones for media use, as well as distribution of press kits and copies of releases. A Support Staff area is set up adjacent to, but separate from the auditorium and areas accessible to the media, for communicators, statement writers and others. working to support ENC/JIC operation. Fax machines, telephone lines and computers are set up to support obtaining current information and preparing press statements. G.4. ENC/JIC Spokespersons and Public Inquiry G.4.a. Spokesperson Information Later in the event as off-site agencies activate, the ENC/JIC. becomes th~ single location for *

coordinated response to the* news media by the spokespersons of the Company, local and state government, the NRC, and any other agencies responding to the incident.

The ENC/JIC does not become a Joint Information Center until after the declaration of a Site Area Emergency and when a representative from the state is present and declares the JIC activated. G.4.b Spokesperson Information Exchange The ENC/JIC is staffed; to provide for media release preparation and presentation, media monitoring, and public inquiry. The ENC/JIC staff also provides for support of off-site agency responders to the facility as well as support for the media representatives that use the facility. G.4.c. Public Inquiry A Media Monitoring and Public Inquiry area is set up with radios, televisions, and telephones. Media Monitors watch releases televised by the local media and listen to radio reports for any inaccurate information. Public Inquiry Communicators record and respond to any questions called in to the Public Inquiry extensions. G.5 Annual Media Briefing Information is sent annually to the local news media to explain the emergency preparedness plans of the State, County, and utility. This is sent just prior to the annual Cook Emergency Plan exercise and invites the media to participate in the exercise. The role of the media in providing emergency information to the public is also explained. Planning Standard G CEP Rev 39 Page 88 of 212 PLANNING STANDARD H EMERGENCY FACILITIES AND EQUIPMENT Planning Standard H CEP Rev 39 Page 89 of 212 H. EMERGENCY FACILITIES AND EQUIPMENT Plant personnel who are needed and are not onsite will be notified of the existing plant condition and will be directed to report to one of the following locations: 1 TSC 2 EOF 3 osc 4 Or an alternate location in the event of unsafe plant conditions. H.1. Technical Support Center H.1.a. TSC Functions 1he onsite Technical Support Center (TSC) provides plant management and technical support to plant operations personnel during emergency conditions from a location outside the Control Room. During the short-term emergency conditions, the TSC is capable of serving the following purposes until all required response centers both on and offsite have been activated.

Providing technical support to operations personnel as requested.
Directing the activities of site personnel.
Evaluating offsite agency requests and recommendations to ensure compatibility with emergency response objectives.

The TSC shall be activated for any Alert, Site Area Emergency or General Emergency. The TSC, combined with the Control Room, can perform the functions of the EOF until the EOF is activated. Sufficient data to determine the plant steady state and dynamic behavior prior to and throughout the course of an accident is available for analysis in the TSC. TSC personnel shall have ready access to plant records and procedures to support detailed technical analysis and evaluation of plant conditions. The TSC facilities may be used by plant personnel for normal daily operations as well as for training and emergency drills provided that these activities do not interfere with the immediate activation of the TSC or the continuing TSC operations in the event of an accident. The primary NRC role in the TSC will be supportive, advisory, and observational. H.1.b. TSC Location The TSC is located adjacent to the Control Room to readily allow face-to-face interaction between Control Room personnel and the senior plant management working in the TSC. (See Figures 10 and 11) Planning Standard H CEP Rev 39 Page 90 of 212 An alternate location for the TSC is the Buchanan Office Building in the event of unsafe conditions at the plant. H.1.c. TSC Staffing The TSC is staffed to provide technical support to the Control Room operating staff during accidents. The number and type of personnel assigned to the TSC and their time of arrival in

the TSC may vary according to the emergency class. The TSC staff assignments are contained in Section B. The SEO, or in the absence of the SEO, the TSC Manager shall coordinate activities in the TSC and interface with the Control Room and the EOF. H.1.d. TSC Design The CNP TSC is. located in the Turbine Building adjacent to the two Control Rooms. This . location readily allows for face-to-face interaction between the Control Room personnel and TSC personnel.

Because of the proximity of the TSC to the Control Room, it will normally take *. Jess than 2 minutes to travel from one facility to., the other. The lower leyel of the TSC (elevatioo 634') is comprised primarily of the Shift Manager's Office and the TSC computer room. The upper level (elevation 643') houses the Plant Evaluation Team area which contains the computer consoles, communications area, and a separate office with sufficient working space for five NRC representatives. The staffing and use of the TSC has been tested in emergency exercises with the result that there is sufficient space for plant emergency personnel to perform their assigned functions.

The TSC has been constructed to provide the same degree of radiological habitability as the Control Room under accident conditions.

Concrete shielding has been provided to significantly reduce the effects of containment building radiation shine during an accident. Radiation monitoring is provided to indicate radiation dose rates as well as airborne radioactivity levels. The CNP TSC has been designed to: 1. Provide technical support to plant operations personnel during emergency conditions.

2. Relieve the reactor operators of peripheral duties not directly related to reactor system manipulation.

3. Prevent congestion in the Control Room. 4. If necessary, perform EOF functions for an Alert,* Site Area Emergency or General Emergency until the EOF is fully functional.

The following communication systems have been provided in the TSC:

Offsite emergency radio to communicate with the Offsite Survey Teams as well as with in-plant teams, and EOF.
Dedicated line on the NRC Health Physics Network (HPN) and two dedicated lines on the NRC Emergency Notification System (ENS).
Plant intercom/PA System.
Dedicated communication circuit to the Control Room, OSC and EOF.
Fax capability.

Planning Standard H CEP Rev 39 I . i Page 91 of 212

2 private lines off the CNP PBX are dedicated for NRG use with outside capability.
Additional telephones to be used as needed. The TSC will not contain, but will have ready access to plant records, drawings and other documentation as required.

The concept of operation of the AEP Emergency Response Organization is described in Section A.1.b. H.1.e. TSC Data Availability Personal Computers and printers are available in the TSC that allow access to the plant LAN, .stand-alone programs, and access to Plant Process Computer information. H.1.e.1. Plant Process Computer (PPG) The CNP Plant Process Computer (PPG) System has been developed and designed using the ~guidelines of NUREG-0696 and NUREG-0737,.,Supplement 1 to provid.e the plant operating an..d

technical support personnel with the pertinent plant information to facilitate the emergency response to an accident in a timely manner and to assess the status of the critical safety functions.

This system can also be used during normal plant operations for other functions such as plant performance analysis and personnel training. The PPG network is a data gathering, analysis, and display system that interfaces with multiple computer . systems. This system consists of two similar computerized data acquisition, processing and display systems, one for each unit. The Unit 1 and Unit 2 PPCs acquire, validate, and convert analog, digital, pulse, and sequence of events inputs from process instruments into engineering units. In addition, data is acquired from the RMS, MIDAS, and from various recorders .located throughout the plant. The Unit 1, Unit 2, and Simulator PPCs and the Plant System Server (PSS) computers are part of a computer network. The PPG network is used to send emergency response data to the NRG via EROS. The Safety Parameter Display System (SPDS) is also a function that is performed by the PPG network. The PPG system inf9rmation is accessed with personal computers that access the PPG through , the Plant System Server (PSS) system and the information so obtained is usually referred to as PPG data. PCs that have access to the PPG in this fashion are available in the Control Rooms, TSC, OSC, ENC/JIG, and the EOF. H.1.e.2. Emergency Response Data System Emergency Response Data System (EROS) is-a direct electronic data link between CNP PPG system and the NRG Operations Center. Types of data transmitted include information on the plant primary and secondary coolant systems, safety injection system, and radiation monitoring systems. H.1.e.3. Dose Assessment Program {OAP) A Dose Assessment Program (OAP) is available in the TSC, EOF, and the Control Room. OAP is discussed in section 1.4. Planning Standard H CEP Rev 39 Page 92 of 212 H.1.e.4. MIDAS Access to meteorological information via the Meteorological Information and Dispersion Assessment (MIDAS) System display is available on any of the computers in the Control Rooms, OSC, TSC, and EOF that have access to the PPC. The meteorological information is used for offsite dose assessment purposes. H.1.e.5. Radiation Monitoring System RMS data is available on any of the computers located in the Control Room, OSC, TSC, ENC/JIC and EOF facilities that have access to the PPC. H.2. Emergency Operations Facility H.2.a. EOF Functions The EOF provides COQrdination and evaluatioQ of licensee activities d~uring an emergency. TIJe

EOF shall be activated during an Alert, Site Area Emergency and General Emergency.

Once fully activated and staffed, the function of the EOF shall provide for: * *.*

Management of overall licensee emergency response, * *. Coordination of radiological and environmental assessment, ** * . Determination of recommended public protective actions,
Coordination of emergency response activities with federal, state, and local agencies, and
Recovery functions.

To accomplish these functions, personnel shall be provided in the EOF for communications with offsite agencies and the evaluation of pertinent radiological, meteorological, and plant system data. Once the Emergency Response Organization (ERO) has been established in the EOF, the TSC Manager will work with the Logistics Coordinator to coordinate communications with the engineering support personnel as needed to respond to the emergency. The EOF personnel shall coordinate the emergency response activities with those of county, state and federal emergency response organizations, including the NRC and FEMA. H.2.b. EOF Location The EOF is located on the first floor in the NGG Headquarters building in Buchanan, Michigan, which is approximately 14 miles from CNP. The EOF shares the first floor of the building with the ENC/JIC, but the media is segregated from all but a lobby area and auditorium where briefings occur and do not have access to the EOF or the EOF staff. (See Figure 11) Planning Standard H CEP Rev 39 Page 93 of 212 H.2.c. EOF Staffing The EOF shall be staffed to provide overall management of the plant resources and evaluation and coordination of plant activities during and after an accident. The EOF staff will include personnel to perform radiological evaluations, interface with offsite, and manage offsite resources. The EOF staff assignments are contained in Section B. The ED shall be in charge of all activities in the EOF. H.2.d. EOF Design The EOF is located in . the NGG Headquarters building in Buchanan, Michigan, which is approximately 14 miles from CNP. It occupies approximately 6400 square feet of the first floor of the building, approximately 2500 square feet of which is reserved for use by NRC personnel. The EOF contains an operations room which includes the crisis management team, communicators, the NRC office, the dose assessors and the data display terminals. The ., communications are tQ the:

ENC/JIC
State and local representatives in their respective Emergency Operation Centers
NRC Emergency Operations Center (ENS and HPN telephones have been installed)
TSC and Control Room
Licensee Offsite Survey Teams The EOF Manager will be in charge of all the Emergency Operations Facility communicators and status displays.

The following communication systems have been provided in the EOF: *

Offsite emergency radio to communicate with the Offsite Survey Teams, TSC, and OSC.
Dedicated line on the NRC Health Physics Network (HPN) and on the NRC Emergency Notification System (ENS).
Dedicated communication circuit to the Control Room, TSC, and OSC.
Fax capability.
3 private lines dedicated for NRC use with outside capability.
Additional telephones to be used as needed. The design of the EOF structure and organization ensures its ability to perform the following functions:
Management of overall licensee emergency response.
Coordination of radiological and environmental assessment.

Planning Standard H CEP Rev 39 ,---Page 94 of 212

Determination of recommended public protective actions.
Coordination of emergency response activities with federal, state and local agencies.

The EOF was designed for occupancy by approximately 70 persons. The approximate occupancy, by function, is as follows: ERO Managers and Coordinators .6 NRC Personnel 23 FEMA, State and County Personnel 3 Communicators 6 Clerical and Extra Staff 5 Assessment Staff 2 45 Ample parking spaces exist outside the EOF in the NGG Headquarters Building parking lot for the number of vehicles that can be expected during an emergency as well as space for mobile vans that will be brought in by. offsite support agencies. In addition, space exists near the building that can be used for landing a helicopter should the need arise. H.2.e. EOF Data Availability The same computer capability (PC, PPC, LAN, OAP, etc.) described for the TSC in H.1.e. is available in the EOF. H.3. Operations Support Center (OSC) H.3.a OSC Functions The Operations Support Center (OSC) is an onsite assembly area separate from the Control Room and the TSC where licensee operations support personnel report in an emergency. The OSC:

Provides a location . where plant logistic support can be coordinated during an emergency, and
Restricts Control Room access to those support personnel specifically requested by the shift manager. The OSC shall be activated for any Alert, Site Area Emergency, or General Emergency.

This is an assembly area for personnel to report for instructions from the OSC Manager. Communications are provided to the Control Room, TSC, and EOF on bridge lines. Communications are provided to Damage Control, Rescue, and Survey Teams with portable radios. Planning Standard H CEP Rev 39 Page 95 of 212 H.3.b. OSC Location The OSC is located in the basement of the Lakeside Office Building on the plant site. The classrooms, storage rooms, and offices on the north end of the basement comprise the area where the staff assigned to the OSC stage and perform their function. The remainder of the office building complex is used for assembly of the remainder of the plant staff when accountability is performed. (See Figures 10 and 11) The OSC will normally be located in the basement area of the Lakeside Office Building; however,. this area is not intended to be "fixed" and may be re-located to other areas of the plant that will permit the orderly progression of work to restore the plant/unit to operational status. Any area that is used as an OSC shall be approved by the SEO after the RP Department surveys the area and it is found to be radiologically acceptable. An alternate location for the OSC is the Buchanan Office Building in the event of unsafe conditions at the plant H.3.c, OSC Staffing The OSC staff assignments are contained in Section B. The OSC Manager shall be in charge of all activities in the OSC. H.3.d. OSC Design The OSC is located in the basement of the plant's lakeside office building. Classroom space is available for assembling, briefing, and de-briefing response teams, as well as storage space for emergency response equipment such as anti-contamination clothing and survey equipment. There shall be direct communications between the OSC and the Control Room and between the OSC and the TSC so that the personnel reporting to the OSC can be assigned to duties in support of emergency operations. Means for analyzing air samples and environmental samples are located in the OSC. Offsite Survey Teams can return samples to the OSC for analysis. If the OSC is unavailable or inaccessible samples can be counted at Palisades Nuclear Plant (about 25 miles from CNP) or other of the contingency Offsite Laboratory Facilities. The following communication systems have been provided in the OSC:

Offsite emergency radio to communicate with the Offsite Survey Teams, TSC, and EOF.
Dedicated communication circuits to the Control Room, TSC, and EOF.
Fax capability.
Additional telephones to be used as needed. H.3.e. OSC Data Availability The same computer capability (PC, PPC, LAN, etc.) described for the TSC, with the exception of OAP, is available in the OSC. In addition the OSC has access capability to the Radiation Protection Dose Tracking and Control System. Planning Standard H CEP Rev 39 Page 96 of 212 H.4. AEP Emergency Organization Staffing and Activation The concept employed by AEP is to support the plant operating staff in an emergency by
activating all of the Emergency Response Facilities when the operating shift determines that additional resources are necessary to respond to an event. At the plant, the TSC would be activated upon an Alert, or higher emergency classification and would perform its functions to support Control Room operation within the goal of 60 minutes. These functions are to provide plant management and technical support to operations personnel; relieve the Control Room personnel of peripheral duties not directly related to plant operation; prevent congestion in the Control Room, and perform EOF functions until the EOF is activated.

The EOF will be activated for any Alert, Site Area Emergency or General Emergency and for any lesser classification. as determined by the SEO. The goal is to activate the EOF within 60 minutes of an Alert, or higher emergency classification. Pre..:designated members of the NGG staff will report to the EOF to provide management and operations support. When ERO members arrive at the EOF, the EOF functions are transferred from the TSC or the Control Room to the EOF. These functions are: management of overall licensee emergency response, coordination_ of radiological and environmental assessment, including determination of protective action recommendations for the public (when the Emergency Director position is activated), and *coordination of emergency response activities with federal, state and local agencies. During this time, the EOF is in communication with the TSC. The ENC/JIC facility will be activated at the Alert level, and becomes the JIC at a Site Area Emergency and when declared as the JIC by the State of Michigan. The goal is to activate the ENC/JIC within 90 minutes of an Alert, or higher emergency classification. The EOF will be in communication with the ENC/JIC as well as with the state* and county emergency operations center. Press releases will be coordinated with the NRC, state, local and AEP ERO. Long Term Recovery. At the plant, the TSC is providing support to the Control Room and plant operations staff. The ED is responsible for the entire recovery operation and is located in the EOF. The EOF staff obtains its information on the plant status from the PPC terminals located in the* EOF, The dose assessment and communication with the licensee's Offsite Survey Teams and all other communications with offsite parties continues. to be performed at the EOF. The Engineering, Design .and Site Services Manager is responsible for obtaining supplementary assistance, if needed, from the other NGG personnel.

H.5. Emergency Detection CNP has nuclear and process instrumentation to detect abnormal situations.

This instrumentation will provide warning to the operators so that action can be taken to avoid or mitigate the consequences of plant incidents. Detection capability is provided in the following areas: 1. Instrumentation for detecting seismic activity on the plant site and meteorological towers for monitoring and recording weather data. 2. A system for monitoring of radiation levels in selected areas of the plant, radioactivity of process streams in the plant, and liquid and gaseous discharges from the plant. 3. Instrumentation to measure tank levels in various plant systems and the pressures, temperatures, and flows of process streams. Planning Standard H CEP Rev 39 Page 97 of 212 4. Instrumentation for detecting fires in the plant and security events. Specifically the instrumentation available to assist in determining th.e severity of a nuclear incident inside the containment is listed in Table 5, "Critical NUREG-0737 Parameters". Events that do not have a potential for radiological releases but which may have a public -interest are detected through the plant's monitoring instrumentation, the plant computer system, audio-visual, alarm/trip indications, fire protection system, and seismic monitoring system. H.5.a. Seismic Monitoring The seismic monitoring system consists of two forms of monitoring instrumentation, the strong motion triaxial accelerometers and the peak recording accelerometers. The.strong motion triaxial system is composed of seismic triggers, control panel, recorder, panels, accelerometers, and power supply. These components provide a means of recording the time history of a seismic event. The power~supply to the system, e,2ecluding the playback . instrument, is designed to. provide power from a battery backup source should the AC input supply be lost. The seismic monitoring system includes a digital computer with an uninterruptable power supply. The system has real-time analysis capability. The accelerometers for these two systems

have been placed in various locations throughout the plant .in such positio11s as to minimize inadvertent system activations.
H.5.b Radiation Monitoring System The instrumentation for determining
the extent and magnitude of accidental releases of radioactive materials offsite includes the Radiation Monitoring System and meteorological instrumentation.

Information from each of these sources is available in the Unit 1 and Unit 2 Control.Rooms, as well as any PC with access to the Plant System Server (PSS). The RMS and Meteorological System data is available to the EOF, TSC, ENC/JIC and OSC from the PPC through the Plant System Server. Alarms are provided for high radiation, RMS malfunctions and, where applicable, loss of sample flow on the local indication and control panel, and at the main Control Room display console via the RMS communications system. A release can be determined from either in-plant RMS, or portable radiation instrumentation dispatched from the plant when it is possible that there has been an accidental gas release which could not be monitored by the plant RMS. Information from readings of this portable instrumentation may then be used to determine the extent of the release.

For accidents where there has been no significant release to the environs, but readings on Control Room instruments indicate a release within the containment, samples can be taken to determine the level of radioactivity therein. Tables relating*

the radiation levels in the containment for various accident conditions as a function of time and power history are used for comparison with actual data as an aid in determining the possible type of and severity of the accident and are contained in the Emergency Plan Procedures. The major source of liquid effluent from the plant is through the circulating water discharge. Identified potential sources of radioactive releases to the circulating water system are monitored by the process monitors of the Radiation Monitoring System. Planning Standard H CEP Rev 39 r------------~~- Page 98 of 212 For long-term events which may have some impact on the environment, additional REMP sampling stations may be provided as necessary. The Radiation Monitoring System instrumentation is divided into analog and digital systems.

Additional information on the monitor functions and range can be found in the UFSAR, Offsite Dose Calculation Manual, "OP Drawings", and Technical Specifications Bases sections.

H.5.b.1. Analog System 1.

The Process Radiation Monitoring Systems monitor various fluid streams for indication of radiation levels. The radiation levels are indicated by meter, recorded by a multipoint recorder, and high radiation level alarms are annunciated in the Control Room. *2. The Area Radiation Monitoring System monitors radiation levels in various areas of the plant. The radiation level -is. indicated locally and in the Control Room where it is -recorded.

A Rredetermined increase.,in the radiation level qetected by this system., is alarmed both locally and in the Control Room. H.5.b.2. Digital System 1.

The Process Radiation Monitoring Systems monitor various fluid streams for indication of radiation levels. This data is processed by a local microprocessor.

Display of the data . is available upon operator request via terminals in the Control Rooms. A common high radiation alarm is annunciated and the initiating device(s) identity is printed or logged at the control terminals.

The Eberline digital RMS consists of a series of radiation detectors, monitor controllers or local processors, and control terminals together with appropriate ancillary GOmponents . including display devices. The local processor
gathers data, performs routine calculations, retains channel parameter information, and a history file for all detectors
served by that processor.

It also determines operation and alarm status and communicates with the central control terminals.* A digital display provides status and alarm outputs and a display of selected channel data. 0 Alarms are provided for high radiation, RMS malfunctions and, where applicable, loss of sample flow on the local indication and control panel, and at the main Control Room display console via the RMS communications system. Each reactor unit at CNP has an RMS control terminal. The two central control terminals are functionally identical. One control terminal performs the functions of polling each -local processor for operational status and data, logging any changes in status and associated data, logging history files, annunciating status conditions, communication error messages and, upon keyboard request, performing calculations on data in the history files. One control terminal performs system operating functions while the other is in standby ready to take over system functions. In the event of control terminal failure or outage, the standby system controller is capable of controlling RMS in both units to provide updated data. The control terminal is the operator interface with the rest of the system. 2. . Area Radiation Monitors monitor radiation levels in most rooms and passageways of the Auxiliary Building and each containment. This data is processed by the local microprocessor and transmitted to the redundant control terminals. Planning Standard H CEP Rev 39 Page 99 of 212 A complete listing of the RMS monitors, their identification number, type of monitor, location, and range is available via computer or in the Reference Section of facility binders containing the Emergency Plan Implementing Procedures issued for use. H.5.b.3. Release Assessment Dose Assessment software is available in each Control Room, the TSC, and the EOF that calculates:

1. The site boundary dose as a function of time, meteorological conditions and release rate, . 2. The.dose rate as a function of distance from the plant for site boundary and beyond, and meteorological conditions.

The above OAP software is only applicable to gaseous releases which are directly measurable

. from plant effluent afld containment area moQitors, or Offsite Survey Jeam measurements of.. plume dose rate. In addition to the instrumentation which is immediately used by the plant personnel in detecting a radiation release from the plant, a Radiological Environmental Monitoring Program is available from which samples can be taken and analyzed.
The Radiological Environmental.

Monitoring Program (REMP) monitors the environment surrounding the plant. The stations from which sampling of airborne particulate, airborne 1-131, lake water, well water, external radiation, etc. are located in the Plant's surrounding environs and are identified in appropriate plant procedures. With the existing instrumentation available to plant personnel, the evaluation of the release and the estimation of the resultant radiation levels at distances from the site boundary can be made without the need to use the Radiological Environmental Monitoring Program sample stations. For long-term events which may have some impact on the environment, additional REMP sampling stations may be established. H.5.c. Process Monitoring . Plant operating parameters including pressures, temperatures, volumes, and flowrates for systems, as well as RMS and meteorology are available throughout the ERO facilities on PCs that access the PPC information through the Plant System Server (PSS). H.5.d Fire Protection The fire protection detection system is comprised of two general types of detectors. They are thermal detectors and products of combustion detectors. The thermal detectors are designed to detect thermal energy output (i.e., heat from a fire). The products of combustion detectors are designed to detect particles, smoke, or infrared radiation. The fire detection systems provide an alarm and/or actuate fire suppression systems. Alarm functions generally include:

Annunciation in the Control Rooms, Planning Standard H CEP Rev 39 Page 100 of 212
Audible overall plant fire horns for those suppression systems which are actuated by detection systems,
Audible and/or visual alarms for gaseous suppression systems actuated by detection systems. H.5.d.1. Types of thermal detectors in use at the plant are as follow: Thermistor A thermistor is a continuous line heat detector.

When an over heat condition occurs anywhere along the thermistor, the resistance drops which is sensed by the control panel. The control panel activates an alarm and/or automatic fire suppression systems. Fusible Entity Detector/Actuators Fusible Entity., Detectors are used~ to activate sprinkler

. systems by melting ~at predetermined temperatures allowing water to be released from the sprinkler heads. The types of plant sprinkler systems employing this type of detector/actuators are:
Wet Pipe Sprinkler System The piping is always full of water under pressure, so that, if exposed to fire, the sprinkler head is activated and water will instantly flow from the open head onto the fire, and at the same time provides an alarm of such activation and water flow.
Preaction Sprinkler System Thes~ systems are used in areas subject to freezing temperatures or where there is a possibility of water damage from accidental operation or a break in the piping system. In these systems, there are two piping systems one for air (pilot) and one for water. Sprinklers (pilot heads) with a lower temperature rating are installed in the air (pilot) piping system as compared to those installed in the water piping system. The air pressure in the pilot piping keeps a control valve closed. When the pilot heads operate from a fire, the air in the pilot piping is vented and the control valve opens allowing water to fill the water piping. At this point, the system operates the same as a wet pipe sprinkler system. H.5.d.2. Types of products of combustion detectors in use at the plant are as follow: Ionization Type Responds to an abnormally high concentration of invisible particles of combustion products that are ionized by a radioactive source located in the detector chamber. Photoelectric Type Responds to visible smoke in the detector chamber which causes a light source in the detector to be refracted and reflected into a photoelectric_

cell. Infrared Flame Detector Responds directly to the presence of the infrared radiation emanating from flames, which flicker between the frequencies of 5 to 30 C.P.S. Planning Standard H CEP Rev 39 Page 101 of 212 H.6 Offsite Monitoring and Analysis Equipment H.6.a. Geophysical (Meteorological, hydrologic, seismic) A contract is maintained with a commercial weather service for meteorological forecast services, and for an alternate source of meteorological data if the plant site meteorological system is unavailable. As a back-up for the contract service the NOAA Weather Service Forecast broadcasts are accessed through a plant phone extension, as well as being available from weather radios. Phone numbers for the National Earthquake Information Center are maintained PMP-2080-EPP-101, "Emergency Classification". The center can be contacted for confirmation of, or information on seismic events. H.6.b. Radiological Monitoring Emergency Plan PrQcedures establish the *. means of assuring tbat adequate emerger1.cy equipment is stocked at designated points for use in emergencies dealing with radiological hazards. The emergency equipment includes, but is not limited to:

Air samplers with assorted cartridges
Ion chambers
Geiger counters
Respirators
Personal dosimetry Plant procedures identify the requirement for emergency equipment to be inv~ntoried and checked at specified times to ensure that the supplies and equipment are properly maintained and available for use. Emergency equipment is kept at some offsite locations see Appendix C, Emergency Kits and Equipment Locations, for locations.

Appendix B contains agreements with offsite support agencies including agreements with other utilities for assistance during emergencies at nuclear power stations. Appendix E contains information about assistance and resources, including instrumentation, available through the DOE Radiological Assistance Plan. H.6.c Offsite Laboratory Facilities In the event that it becomes necessary to use offsite laboratories for analysis of samples the following facilities may be contacted and the analysis performed depending on the type of samples (See Appendix H, Radiological Response Support Service Capabilities):

Teledyne Isotopes Inc.
Argonne Laboratory (DOE)
There is also a Reciprocal Laboratory Use Agreement with Palisades Nuclear Plant (see Appendix B). Planning Standard H CEP Rev 39 Page 102 of 212 H.7. Radiological Environmental Monitoring The CNP uses a pressurized water reactor with a radwaste holdup and treatment system that has been designed to keep radioactive releases to as low as practical levels. However, small quantities of noble gases and other radionuclides that are released to the environment are expected to be minuscule and insignificant as a source of potential exposure to flora and fauna in the area. However, direct radiation exposure to the public and radionuclide accumulations in various components of food chains to man is carefully monitored through the REMP. Further information on the REMP can be found in the Offsite Dose Calculation Manual (ODCM). H.8 Meteorological System The system's meteorological towers are located inside the thermal internal boundary layer and have the ability to measure unmodified onshore airflow to detect the presence of a lake breeze. The meteorological*

system consists of monitoring information located on three towers. The .. primary and backup tpwers are located abo11t 1-mile inland from ttie plant site to provide .. a representative determination of the meteorological conditions for emergency planning purposes. The primary tower has instruments at the 10 and 60-meter elevations. Each elevation has a measurement of wind speed and direction. Temperature is measured at both elevations and is used to determine a delta temperature (delta T). This delta T is used in dose assessment to determine atmospheric stability. A precipitation gauge is located near the primary tower site. The backup tower has wind speed and wind direction instrumentation located at the 10-meter elevation. Separate communication lines are provided for the main and backup towers. The shoreline tower also has wind speed and wind direction instrumentation at the 10-meter elevation. Temperature detectors are located at the 2-meter and 10 meter elevations of the tower. The shoreline tower is located just northwest of the plant on the shore of Lake Michigan. The three towers are controlled by a central computer located at CNP site. The towers are polled every 15 minutes for meteorological data. The data are stored in the central computer. Meteorological data are available from any PC with access to the PPC data. Daily checks of the digital data are performed to ensure reliability. Erroneous data are flagged on these displays and triggers the issuance of a Work Order (WO). The WO system is used to notify the appropriate department of the problem and provides notification of the resolution to the problem. An adequate spare parts inventory is maintained at the primary tower site. Calibration of the system is performed semi-annually and is . documented by the plant Instrumentation and Control Section. Meteorological information can be obtained directly from the primary tower site using a keypad if communications with the central computer are lost. Backup meteorological information can also be obtained from a consulting firm. Forecasting information is available from the consulting firm as well as a plant extension that continuously plays NOAA weather information, and Weather Service radio. Planning Standard H CEP Rev 39 Page 103 of 212 Figure 11 LOCATIONS OF EMERGENCY RESPONSE CENTERS North Access Btilding . .. ******* ... . .. *** ... .. ** ... .. .. . . . . .. Visitors Center Operations Support Center ...... . . . . . . . . . . ....................................................... ......... Auxiliary Building Control Rooms Technical Support Center Turbine Buharng Screen House D . . : Office Building _ *******************************"********

..........

.. *****-* ... Emergency News Center/Joint Information Center in the Nuclear Generation Group Headquarters Building in Buchanan Planning Standard H Emergency Operations Facility in the Nuclear Generation Group Headquarters Building in Buchanan CEP Rev 39 Page 104 of 212 FIGURE 12 CNP EMERGENCY RESPONSE CENTER LOCATIONS Control Room Entry at Elev. 633' Turbine Building Technical Support Center (TSC) Above SM's Office Complex Adjacent to Units 1 and 2 Control Rooms Operations Support Center (OSC) Plant Offices -Basem~nt Shelter Elev. 587' Emergency Operations Facility (EOF) In Nuclear Generation Group Headquarters Buchanan -Approximately 14 miles Southeast of CNP Emergency News Center/Joint Information Center (ENC/JIC) In Nuclear Generation Group Headquarters Buchanan -Approximately 14 miles Southeast of CNP Planning Standard H CEP Rev 39 Page 105 of 212 TABLE 5 CRITICAL NUREG 0737 PARAMETERS PARAMETER INSTRUMENTATION Neutron Flux (Gammametrics) NRl-21, NRl-23 Reactor Coolant Pressure (Wide Ranqe) NPS-110, NPS-111, MR-13 Reactor Coolant Outlet Temperature Thot (Wide Ranae) NTR-110, 120, 130 140 Reactor Coolant Inlet Temperature Tcold (Wide Ranae) NTR-210, 220, 230 240 lncore Thermocouples (Core Exit Thermocouples) TIC 1-65 Reactor Coolant Svstem Subcoolinq Marqin Monitor QR-110-3 Reactor Coolant Inventory System (Reactor Vessel Level Indication) NLl-110, 111,120,121,130,131' Pressurizer Water Level NLP-151, 152, 153 Charqinq Pump Flow IFl-51, 52, 53, 54 Charqinq Pump Breaker Status 1E, 1W, 2E, 2W Control Room Position lndicatina Liahts for Breakers Safetv Injection Pumo Breaker Status 1 N, 1 S, 2N, 2S Control Room Position lndicatina Liahts for Breakers Safetv Injection Flow IFl-260, 266 Refuelinq Water Storaqe Tank Water Level ILS-950, 951 Containment Water Level NLl-320, 321,330,331,340,341 Containment Recirculation Sump Water Level NLl-300, NLl-301 Containment Pressure (Wide Ranqe) PPA-310, 312 Containment Pressure (Narrow Ranqe) PPP-300, 301, 302, 303 Containment Hvdroqen Monitorinq ESR-1 thru 9, PAS-H2-A-CR1, PAS-H2-B-CR1 Containment Isolation Valve Position Monitorinq Control Room Position Indicating Lights Containment Area Radiation Monitors (Hiqh Ranqe) Unit 1 VRA-1310, 1410, Unit 2 VRA-2310,2410 Steam Line Pressure MPP-210,211,212, 220,221,222,230,231,232,240,241,242 Steam Generator Water Level (Wide Ranqe) BLl-110, 120, 130, 140 Steam Generator Water Level (Narrow Ranqe) BLP-110, 111,'112, 120,121,122,130,131,132,140,141,142 Auxiliarv Feedwater Flow Rate FFl-210, 220, 230, 240 CCW Flow to ESF Svstem, CCW Pump Breaker Status PP-10E, PP-10W Reactivity Control, Control Rod Position CA1-8(U1), CB1-4(U1), CA1-4(U2), CB1-8(U2), CC1-8, CD1-9, SA1-8, SB1-8, SC1-4, SD1-4 Condensate Storaqe Tank Level CLl-113, CLl-114 Planning*standard H CEP Rev 39 Page 106 of 212 PLANNING STANDARD I . ACCIDENT ASSESSMENT

.. Planning Standard I CEP Rev 39 Page 107 of 212 I. ACCIDENT ASSESSMENT The purpose of this section is to describe the systems, equipment, and methods for monitoring and assessing offsite consequences of actual or potential radiological emergencies.

1.1. Release Identification and Event Classification

The Emergency Plan Procedures contain the information used to establish the emergency classification category based on plant system and effluent parameter values. Those initiating conditions are identified in NUMARC/NESP-007.

Section D contains the plant specific EALs and initiating conditions in the Emergency Classification System tables. 1.2. Radiation Monitoring System The RMS monitors area radiation levels in most rooms and passageways of the Auxiliary , *. Building and each containment. Effluent and process flows are monitored for radioactive material. The monitors and channels of most interest for monitoring and evaluating events for radiological impact are: S> S> S> ,, Containment Radio Gas monitors ....................................................................... 2 per unit Condenser Air Ejector Radio Gas monitors ........................................................ 1 per unit Unit Vent Radio Gas Monitors ............................................................................ 1 per unit Gland Steam Leak Off Monitors .......................................................................... 1 per unit Steam Generator Power Operated Relief Valve (PORV) Monitors ...................... 4 per unit Containment High Range Area Radiation Monitors ............................................. 2 per unit Process Monitors Component Cooling Loops A and B Liquid Waste Disposal Steam Generator Slowdown Sampling Essential Service Water Waste Gas Decay Tanks Waste Liquid Off-Gas Steam Generator Slowdown Treatment

A complete listing of the RMS monitors, their identification number, type of monitor, location, and range is available via computer or in the Reference Section of facility binders, containing the Emergency . Plan Implementing Procedures issued for use. Section H.5.b
contains the description of the RMS system. 1.3. Release Source Term and Magnitude Determination 1.3.a. Release Source Term Calculations correcting containment dose rates as a function of time and reactor power history are contained in the plant core damage assessment procedure.

Tables use the corrected containment dose rate results to provide estimates of core damage. Estimates of core damage are used to select the source term used in the Dose Assessment Program for assessing releases. Planning Standard I CEP Rev 39 Page 108 of 212 The Dose Assessment Program for assessing releases of radioactive material can use the source term for a release after core damage, a release of a waste gas decay tank (WGDT), a release from the spent fuel pit (SFP) or a release from the Independent Spent Fuel Storage Installation (ISFSI) to estimate dose rates. 1.3.b. Release Magnitude Effluent monitor radiation readings and effluent pathway flow rates are used to calculate the magnitude of releases. ' When it is possible that there has been an accidental gas release which could ~ot be monitored by the plant RMS survey teams dispatched from the plant perform surveys offsite with portable

radiation instrumentation.

Information from readings of this portable instrumentation may be used to determine the extent of the release. 1.4 Dose Assessment Evaluation

A dose assessment program to quickly relate measured release rates and containment dose rates to dose and dose rates at the site boundary and beyond are maintained in the Control Rooms, TSC, and the EOF. The determination of the meteorological stability class to perform . offsite dose calculations is described in the Plant Emergency Plan Procedures.

Once. the meteorological stability class is determined, the offsite radiation dose and dose rates at the site boundary can be estimated using the information. obtained from the plant radiation monitoring instruments and/or measured offsite radiation dose rates and the dose assessment program. A dose assessment computer program, OAP, provides a method of calculating conservative estimates of dose and dose rates at the offsite area most probably affected by a gaseous release to assist in emergency classification and Protective Action Recommendations (PAR). The Dose Assessment Program allows evaluation of several types of release scenarios with the flexibility for meteorological and radiological inputs to perform alternate evaluations to best characterize an event and the resulting protective measures. The program also allows calculations based on offsite survey results for cross comparison purposes,* or a means for evaluating unmonitored releases. In order to calculate a dose/dose rate, the program requires data on:

the radiological effluent.
containment area monitor dose rates, or
offsite dose rate measurement results. This information can be obtained from the plant's RMS or from Offsite Survey Teams. Other features included in the program are as follows:
Variable Trajectory Plume Segment Model
Radioactive decay after reactor shutdown
Decay and daughter in-growth during transit*
Ground level release
Finite cloud correction
Option to input offsite field survey data.
NuReg -1228 Event Tree Modeling for Source Term
Multi Accident Assessment Capability The program is run on personal computers.

Planning Standard I CEP Rev 39 Page 1 Q9 of 212 The OAP program will be used as the primary means of performing a dose assessment. Dose Assessment Program (OAP) is a PC computer program that calculates*conservative estimates of Total Effective Dose Equivalent (TEDE) and Thyroid Committed Dose Equivalent (COE) dose rates and total projected dose, based on a radiological release, at the plant boundary and at 2, 5, and 1 O mile distances. The program also uses the information to determine the Emergency Classification Level (ECL) associated with the release. 1.5 Meteorological Assessment The system's meteorological towers are located inside the thermal internal boundary layer and have the ability to measure unmodified onshore airflow to detect the presence of a lake breeze. Meteorological data are available from any PPC capable computer. Section H.8 contains a description of the Meteorological System. * . Meteorological data from the onsite meteorological tower. is input into the dose assessm_ent

. program. The data is ~used to calculate the .~tmospheric diffusion f'1ctor, X/Q, to determin..e atmospheric dispersion of radioactive material as part of the Dose Assessment Program for calculating off site doses and dose rates. Weather forecast information is also used to project changes in plume dispersion and location, which can cause changes to Protective Action Recommendations.

1.6. 1.7 Not Addressed. Radiological Field Monitoring As part of the response to any Alert, Site Area Emergency or General Emergency, one or more offsite survey teams are formed, as* per plant procedures, and dispatched for sampling under radio contact. The off-site survey team driver position is normally filled by non-RPT personnel. Qualified RP Technicians fill the position for persons performing the survey. If adequate RP and other personnel are not available onsite, personnel to staff offsite survey team(s) would be summoned per Emergency Plan procedures. 1.8. Liquid and Gaseous Release Assessment A minimum of two vehicles dedicated to Emergency Plan offsite surveys is available 24 hours a day. Additionally, keys for all normally available plant vehicles are available. in the OSC in the

Office Building Basement.

Offsite survey team(s) deployed from onsite would have such vehicles available for use. Each of the two dedicated offsite survey vehicles, the office building basement, and the EOF have air sampling equipment, dose rate, and count rate instrumentation in addition to radio equipment for communication with the plant. Previous experience indicates that deployment of personnel from onsite to offsite .areas takes approximately 30 minutes from the time of notification. 1.9. Off-site Radioiodine Monitoring Measurements of radio-iodine yielding sensitivity to the range of 1 o-a µCi/cc can be obtained by returning the sample to the regular counting facility or to the counting area independent of the regular counting facility located in the basement area of the Office Building. 1.10. Not Addressed. Planning Standard I CEP Rev 39

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Page 110 of 212 PLANNING STANDARD J PROTECTIVE RESPONSE Planning Standard J CEP Rev 39 Page 111 of 212 J. PROTECTIVE RESPONSE J.1. Owner Controlled Area Warning and Advisement Since the PA system within the plant is extensive, an announcement of the nature of the emergency can be made to most personnel immediately. Upon sounding of the Nuclear Emergency Alarm personnel in the outlying areas of the plant site are notified using the methods described in section E.2.a of this plan. J.1.a. Non ERO Employees Plant employees without ERO duties and personnel temporarily assigned to the plant for training or other purposes, are required to know the location and routes to the assembly areas and be familiar with the emergency alarm procedure. Personnel already onsite immediately proceed to their appropriate assembly area upon sounding of the Nuclear Emergency Alarm. J.1.b. Visitors Groups on tour are escorted to

an assembly area by their tour guide, should the Nuclear Emergency Alarm be sounded. Personnel already onsite immediately proceed to their appropriate assembly area upon sounding of the Nuclear Emergency Alarm. J.1.c. Contractors and Construction Contractors, .supervisors, and/or foremen (i.e., outside labor) are provided with instructions, prior to beginning work as to the emergency alarm procedure and as to their responsibility for assembling the people under their supervision in the area designated by the SEO or designated alternate.

Personnel already onsite immediately proceed to their appropriate assembly area upon sounding of the Nuclear Emergency Alarm. J.1.d Others The decision to commence evacuation of the Cook Energy Information Center is made by the SEO on the basis of the evaluation of the condition of the plant and the extent of the emergency. The Manager of the Cook Energy Information Center or designee is responsible for the accountability of all Energy Information Center employees and all visitors of the Center should the Nuclear Emergency Alarm be sounded. When State Police and National Guard are assigned to the plant their disposition will be determined by the nature of the emergency. If the plant is under attack the MSP and National Guard are considered essential personnel and become Emergency Workers for the event. If the emergency does not involve attack of the plant the MSP and National Guard are considered non-essential personnel and evacuated from site upon evacuation of non-essential personnel. J.2. Evacuation Routes If the SEO deems evacuation of personnel from the plant site necessary, the evacuation route to be taken is determined by the nature of the incident. Personnel evacuate the plant and site as directed by the SEO. Evacuation of individuals shall not commence until it is determined that personnel exposure for such evacuation is within the limits of 1 O CFR Part 20, or if this is not practical due to the nature of the emergency, the most expeditious and non-hazardous evacuation route shall be used. Planning Standard J CEP Rev 39 Page 112 of 212. The SEO designates the evacuation route. One of the below designated routes is utilized (see Figure 12) 1. North East along main access road to the Red Arrow Highway.

2.
North along Lake Michigan beach area to Rosemary Road. 3. South along Lake Michigan beach area to Livingston Road. 4.. North East (for Energy Information Center only) to the Red Arrow Highway. The Security Coordinator (or* alternate) is responsible for the accountability of evacuated
personnel from the plant site and reports any missing persons to the SEO.
J.3. Evacuee Monitoring

~* . If evacuation is initiat~d a personnel monitori[lg station is establishect for those evacuated b~ a person trained in radiation protection. The Radiation Protection Plan specifies the acceptable limits for contamination to the body and clothing for exiting the plant. Suitable equipment intended for such personnel monitoring stations will be stored in both the OSC *and the Training Center.

Other equipment is available from the Radiation Protection Access Control (RPAC), if access to that area is feasible.

J.4 Evacuee Decontamination If any of the evacuated personnel are contaminated; the OSC Manager will institute the necessary steps for movement of these personnel to decontamination facilities and initiate surveys of the surrounding areas. J.5 Personnel Accountability

Control of all personnel entering, leaving and at various locations throughout the plant is a function of the plant security force. The accountability of all personnel in the protected area of the plant is maintained via the security computer system. The security computer records provide the primary means of assuring the accountability of all persons of the site. Use of this computer will enable the accountability to be performed rapidly with a stated goal of achieving completion of personnel accountability within 30 minutes.
During some postulated events, assembly and accountability may pose a greater danger to plant personnel than directing a rapid egress of personnel from the Protected Area, or directing personnel to remain at their work areas. SM/SEO discretion, with input from the Security Coordinator (or Security if facilities are not yet activated) should be used when deciding to perform accountability and/or evacuation under these conditions.

Once the Nuclear Emergency Alarm has been sounded all personnel onsite shall report to their pre-assigned assembly areas. The SEO will notify personnel via the PA system of any changes in the areas to be used due to the release or expected release of radiological effluents fro!TI the plant. Planning Standard J CEP Rev 39 Page 113 of 212 Personnel reporting to their assembly area onsite will be accounted for using the plant security access list and security computer. This list provides an up-to-date listing of all personnel onsite by area location. The results of the accountability process will be transmitted to the individual in charge of personnel accountability. If personnel are unaccounted for, the security computer will be queried to determine the individuals last known location. The individual(s) will_ be paged on the PA system, the individuaFs supervisor will be notified and if required, the SEO will initiate search and rescue operations. J.6 Protective Measures for Those Remaining, or Reporting to the Site Personnel reniaining onsite after the sounding of the Nuclear Emergency Alarm will be required to assemble in an area that is free from ionizing radiation and contamination, or presents the minimum exposure to personnel engaged in emergency operations. Surveys of the assembly area(s) will be conducted to ensure continued habitability. Personnel remaining onsite who are engaged in emergency operations where there is an actual or potential radiological hazard, shall upon the direction of the RP Director, wear the required protective clothing and respiratory protection. The RP Department shall perform the required . surveys and establish the type and quantity of clothing, and other protective measures required. The Plant Security Force will control access to the Owner Controlled Area at the 1-94 Gatehouse as directed by the SEO. Personnel arriving at the plant to assist in the emergency will be allowed access to the plant via minimal exposure routes as identified by the Plant RP Department and approved by the SEO. The RP Department will establish a Controlled Area Access Point for personnel arriving at (and departing from) the plant from offsite if the access route exceeds the criteria for "Clean Areas" as identified in the Radiation Protection Plan. The amount of exposure personnel receive in reporting to the plant will be included in the individual's dose records. Additionally, other precautions, such as decontamination, will be taken as necessary prior to entering the plant and reporting to the assigned assembly area.* Equipment decontamination . and controls are described in detail in the Radiation Protection Plan. *

J.6.a. Respiratory Protection The Radiation Protection Plan and Radiation Protection Procedures identify the instructions and requirements pertainir:ig to respiratory protection requirements and respiratory protection equipment usage. J.6.b. Protective Clothing The Radiation Protection Plan and Radiation Protection Procedures identify the instructions and requirements pertaining to protective clothing requirements and protective clothing usage. J.6.c. Radio-protective Drugs The procedures and precautions for the issuance and use of thyroid prophylaxis, e.g., individual thyroid protection, by emergency workers will be based on existing conditions.

The provisions for stockpiling, inventory, storage and use are included in Emergency Plan Procedures. However, since the medical aftereffects of the agent cannot be determined, wholesale (wide) distribution cannot be incorporated as a responsible protective measure for personnel onsite. Planning Standard J CEP Rev 39 Page 114 of 212 J. 7 Off-site Protective Actions For incidents thatfall under the ECLs as defined herein, the SEO or ED will notify the Michigan State Police, the Berrien County Sheriffs. Department, the NRC, and the AEP Emergency Response Organization described in this plan that such an incident has occurred. It is the responsibility of the Governor of Michigan, or authorized representative, to issue Protective* Action. Orders (PAOs) such as sheltering, evacuation, administration of thyroid !:>locking agents, etc. These decisions are based upon the protective action guides in Annex S of the Michigan Emergency Management Plan (MEMP). Since copies of the MEMP are maintained and readily available at the various Emergency Response Facilities, the protective action guides and their bases will not be reproduced here. For incidents involving actual or imminent releases of radioactive material to the atmosphere the

Control Room or EOF protective action recommendation procedures, as appropriate, will be used as the .basis for recommendations for protective actions to the public. These procedures
. are based on the cur;rent issue of the "Manual for Protective Action Guides and Protection Action for Nuclear Incidents" (EPA 400-R-92-001

). The *EPA Guide provides Protective Action Guides (PAGs) for whole body external gamma radiation and for inhalation of* radioactive material in an airborne plume.

The most effective actions to be recommended to the public are evacuation, sheltering, and access control. Evacuation potentially provides the greatest margin of protection.

On the other hand, because sheltering may be implemented in less time than evacuation, it may be the protective action of choice if rapid evacuation is impeded for any reason. Also, since sheltering is less .disruptive than evacuation, it may be the protective action of choice when the dose reduction factor associated with shelter is adequate to reduce the projected dose to less than . PAG *levels .. Access control is an effective action to avoid exposure of personnel who might otherwise enter areas of high exposure unnecessarily. Emergency Plan Procedures have been established to provide the mechanism and criteria for recommending protective actions to state and local government. Additionally the protective action guides for emergency workers and those engaged in lifesaving activities exposed to airborne radioactive materials are listed in Section K.1., Emergency Exposure, and in the Plant Radiation Protection Plan.

J.8. Evacuation Times Evacuation time estimates and informational county maps are contained in the Berrien County Emergency Operations Plan submitted to the Nuclear Regulatory Commission (NRC). Evacuation time estimates are performed within 365 days after the availability of the most recent decennial census data. Yearly revieyvs of the Evacuation time estimates are performed to estimate the Emergency Planning Zone permanent resident population changes. J.9. Not Applicable Planning Stanqard J CEP Rev 39

/ J.10 Plume Exposure Pathway Protective Measures Implementation I J.10.a. Route and Facility Location Maps Page 115 of 212 Maps for the 1 O and 50 mile EPZ, developed by the Michigan State Police are provided for use at the following locations:

Control Rooms
TSC
osc
EOF
ENC/JIC
Berrien County EOC
Cook Energy Information Center These maps show information such as sector designations, emergency center locations
- topographical information, and when used in conjunction with Berrren County plan indicates preferred evacuation routes.
J.1 O.b. Population Distribution Maps Evacuation time estimates and informational county maps are contained in the Berri_en County Emergency Operations Plan submitted to the Nuclear Regulatory Commission (NRC).
J.1 O.c. Population Notification The Berrien County Plan includes provisions for alerting local radio and television stations and, local news media to be prepared to transmit Emergency Public Information.

Section E~6 addresses Public Notification J.1 O.d. Protective Action Basis The Dose Assessment Program and off-site survey team results, as well as plant system and equipment status, are the basis for Protective Action Recommendations. OAP and* off-site surveys are addressed in sections 1.4 and 1.5. Planning Standard J CEP Rev 39 Figure 13 Cook Nuclear Plant Primary Evacuation Routes Evacuation Route B V i sitors Center Roa d Page 116 of 212 A Northeast along Main Access /, Road to Red Arrow Highway B South along Lake Michigan Beach area to Livingston Road c North Along Lake Michigan Beach area to Rosemary Road D (For Energy Information Center) Northeast on Visitor Center Road to Red Arrow Highway Planning Standard J CEP Rev 39 Page 117 of 212 PLANNING STANDARD K RADIOLOGICAL EXPOSURE CONTROL Planning Standard K CEP Rev 39 Page 118 of 212 K. RADIOLOGICAL EXPOSURE CONTROL The CNP Radiation Protection Plan (PMl-6010) specifies the base criteria for the implementation of the Radiation Protection (RP) program and the methods to be used to control the exposure to radiation and radioactive materials. The standards listed in PMl-601 O and the programs to be followed consist of: 1. RP Training and Qualifications

2. ALARA Program 3. Radiation Work Permits 4. Dosimetry Program 5. Area Postings 6. Contaminatio'n Control 7. Internal Exposure Control 8. Radioactive Material Control Program 9. Survey Program 10. Instrumentation Program 11. Radiological Environmental Monitoring Program 12. Offsite Dose Calculation Manual 13. Review and Surveillance Program Related sub-tier RP procedures have been developed to provide a detail~d and comprehensive method of performing the daily and emergency assignments.

The procedures cover the following areas: 1. Exposure Monitoring and Control 2. Respiratory Protection

3. Contamination Control 4. Radiological Controls 5. Instrumentation

6. Instrumentation Calibration

7. Radioactive Effluent Control 8. Abnormal Condition Response 9. RMS Instrumentation Planning Standard K CEP Rev 39 Page 119 of 212 10. RMS Instrumentation Calibration

11. RMS Alarm Response K.1. Emergency Exposure I It is possible that emergency situations may arise which transcend the normal requirements for limiting dose. Dose to penetrating radiation during emergency response or response to accidents may be up to 10 rem Total Effective Dose Equivalent (TEDE), 100 rem Committed Dose Equivalent (COE) to the thyroid for non-life-saving actions. Life saving doses may be up to 25 rem T~DE or 250 rem COE to the thyroid. However, in all situations, every reasonable effort shall be made to minimize dose. In .no case shall thisJype of dose be permitted unless rescue persor,m~I are wearing monitoJing devices capable of monitoring these doses. Situations may also rarely occur in which a dose in excess of 25 rem, for emergency exposure, would be unavoidable in order to carry out a lifesaving operation, to avoid extensive exposure of large populations, to perform assessment actions, provide first* aid or other medical treatment services, to perform personnel decontamination or provide ambulance services for personnel onsite. (Onsite medical support is described in Planning Standard L, L.2) However, persons undertaking any emergency operation in which the dose will exceed 25 rem to the whole body should do so only on a voluntary basis and with full awareness of the risks involved, including the numerical levels of dose at which acute effects of radiation will be incurred and numerical estimates of the risk of delayed effects. K.2. Emergency Exposure Authorization and Control Doses in excess of 1 O CFR 20 limits may be authorized by the SEO in order to prevent serious property damage, serious b9dily injury, or for life saving measures .. The assessment and recording of radiation exposures will be the assigned duty and responsibility of the person so designated by the RP Director.

The SEO shall be made aware of any changes in cumulative exposures which would affect emergency team assignments. The exposure of personnel who were in the immediate area of a radiation incident must be determined before they are assigned to any emergency or recovery team. Self-reading dosimeters, electronic dosimeters, area monitor records, or thermoluminescent dosimeters will. be used to establish accumulated exposure for each individual. K.3. Emergency Personnel Dosimetry K.3.a Dose Determination Radiation Exposure Records for exposed personnel will be maintained by the plant and will be available for review by the State of Michigan Department of Environmental Quality (DEQ). K.3.b. Dosimetry Use and Dose Records RMT-2080-0SC-001 identifies criteria and methods for reading, recording and maintaining dose records. Planning Standard K CEP Rev 39 Page 120 of 212 K.4. State and Local Emergency Exposure Authorization Not Applicable. K.5. Decontamination K.5.a. Decontamination Criteria RMT-'2080-0SC-001 identifies the criteria for decontamination of personnel, personnel wounds, and equipment. Survey data and records of data taken by the licensee resulting from a nuclear incident at the licensee's plant will be made available to the State for review upon written request to plant management by the Michigan DEQ or other designated State agency. K.5.b. Decontamination Methods RMT-2080-0SC-001 identify the means and methods for decontamination of personnel, personnel wounds, and equipment. There are two separate decontamination facilities which may be used during an emergency. The main facility is located in the Radiation Protection Access Control (RPAC) on the 609' elevation east of the auxiliary building. The other facility is located in the Auxiliary Building aQcess at the Turbine Radiation Protection Access Control (TRPAC) on the 609'* elevation of the Unit 1Turbine Building. The decontamination facility associated with the RPAC consists of a decontamination area and a personnel shower. Additional space available in the area may also be used. Personnel protective clothing and equipment are also available in the RPAC.

Both decontamination facilities have adequate water supplies for both showers and wash basins. All* floor and sink drains in the adjoining areas drain either into the laundry and hot *shower drain* tank or other contaminated liquid tanks for complete control of potentially contaminated wastes. Information on equipment and inventory of supplies as well as detailed written procedures and standing orders, are found in the Administrative Procedures and the Emergency Plan Procedures; as well as the RP Plan and the RP Procedures.

A list of Emergency Kit Locations is shown in Appendix C. Inventory procedures are specified in *the RP procedure indicated in the plant procedure column in Appendix A. K.6. Contamination Control K.6.a. Area Access Control RMT-2080-0SC-001 and RMT-2080-TSC-001 identifies the means and methods for area access for control of contamination. K.6.b. Water and Food Contamination Control Not addressed. Planning Standard K CEP Rev 39 Page 121 of 212 K.6.c. Returning Items and Areas to Normal Use RMT-2080-EPl-109 identify the means and methods for decontaminating and returning areas and items to normal use. The public will be restricted from areas within the Owner Controlled Area normally open to the public (i.e., Energy Information Center) which have been contaminated with radioactive material in excess of the limits defined in Table 6, Maximum Allowable Contamination Limits for On-Site Facilities Used by the Public. Prior to the release of these areas for public use, the plant will notify the DEQ and provide the required data for review at least 24 h.ours in advance of release of these areas to the public. K.7. Decontamination of Relocated Onsite Personnel Personnel evacuated from onsite will be decontaminated as required by the plant RP procedures and Emergency Plan Procedures. If necessary and where possible, suitable protective clothing wijl be used during the evacuation. Planning Standard K CEP Rev 39 Page 122 of 212 Table 6 MAXIMUM ALLOWABLE CONTAMINATION LIMITS FOR ON-SITE FACILITIES USED BY THE PUBLIC* Beta-Gamma Skin, Personal Clothing, and Items Directly Associated With the Human Body Material or Facilities Not Directly Associated With the Human Body Counts per Minute (cpm)1 < 2 X Background 2 < 2 X Background 2 1 Measured with GM and side window probe with beta shield opened or with thin window pancake probe. 2 Use background readings in cpm as measured pursuant to footnote 1. Gamma background must be 0.2 mR/hr, or less, as measured with a GM and a side window probe with the beta shield closed.

Ref. Michigan Emergency Management Plan Planning Standard K CEP Rev 39 Page 123 of 212 PLANNING STANDARD L MEDICAL AND PUBLIC HEAL TH SUPPORT Planning Standard L CEP Rev 39 Page 124 of 212 L. MEDICAL AND PUBLIC HEAL TH SUPPORT L.1. Offsite Medical Support Lakeland Regional Medical Center, Saint Joseph, in St. Joseph, Michigan has an emergency room which is open 24 hours a day year round and arrangements have been made with them for the care of contaminated persons. There is a physician constantly on duty at the hospital.

Lakeland Regional Medical Center, St. Joseph is the primary site for the handling of contaminated patients from CNP. The hospital is approximately 9.5 miles from the plant site. In addition, Niles Community Hospital, Niles located in Niles, Michigan, about 19 miles from the plant site, has facilities and staff for the handling of contaminated patients from CNP. This facility is the back-up site for Lakeland Regional Medical Center, St. Joseph . . The Radiation Emergency Area (REA) at Lakeland Regional Medical Center, St. Joseph, lends itself well to controlling the access of non-essential personnel. The REA at bpth St. Joseph and Niles is located in ~a section of the hospjtal remote from any qther treatment facilitiel?,. A contaminated or potentially contaminated patient is wrapped and placed on a clean gurney when

taken from the ambulance before being taken into the facility to avoid the spread of contamination.

The REA facility in both hospitals consists of a room designed for easy decontamination, should this be required. Adequate water. is supplied for any necessary personnel or equipment decontamination. The facilities include a fiberglass table with a special drain to allow control of liquids for later removal from the hospital. If the injury does not require special handling because of contamination levels or high radiation levels, the facilities of the emergency room and other parts of the hospital are available. In addition to that equipment normally found in hospital emergency facilities for routine nuclear emergencies, other specialized equipment includes such items as plastic and absorbent . paper for contamination control, protective clothing, equipment for the control of liquid and solid

wastes and their removal from the hospital to the plant for treatment and/or disposal, and assorted signs, barriers, and supplies.

Also available at the hospital are such items as survey instruments, dosimeters, samplers, and associated equipment.

There are no limitations with regard to duration of admissions of casualties or contaminated patients.

Special rooms have been arranged so the patients can be kept as long as necessary before being transferred to a different facility or until released. Onsite decontamination of the injured person, as well as the design of the REA with respect to the rest of the hospital, negates any limitations on the availability of the offsite medical facilities with respect to contamination levels. The only limitation due to direct radiation levels from a contaminated injured person

is to the people directly concerned with treatment of the contaminated injured person because the REA is located in a part of the building remote from the patients and staff in most conditions.

The limitation on the exposure of the physician or hospital staff remains a medical judgment made by the physician for individual cases. This judgment will be made using data obtained from portable radiation monitoring equipment. Planning Standard L CEP Rev 39 Page 125 of 212 Detailed procedures have been developed for activation of the hospital assistance plan. A comprehensive training program has been conducted for the hospital staff and employees who would be involved as a part of the offsite medical support. This program includes training in the principles of radiation protection, basic radiation protection procedures, applicable parts of the emergency plan and emergency procedures, and an exercise simulating radiological and physical injury. This training program shall be periodically reviewed and repeated at least once each year. Plant personnel will monitor all persons leaving the treatment room after removal of protective clothing. The treatment room, all equipment used in the room and during patient treatment is surveyed by plant personnel for contamination. Any contaminated equipment or areas will be decontaminated by plant personnel to the Plant RP Protection Plan "Clean Area" specifications. All radioactive waste is sealed and .transported to the plant for disposal in accordance with current DOT and State regulations. Subsequent therapy for individuals who have been exposed or contaminated is provided in the kind and extent which . is required under the direction of the hospital phy~ician. Additionally, consultation service is available from the Department of Energy's Radiation Emergency Assistance Center/Training Site on radiation related injuries. L.2. Onsite Medical Support In the event of serious injury, medical treatment must always take precedence over decontamination of the individual. First Aid training is provided within. several plant departments, providing emergency medical expertise within the plant. All plant personnel are trained in the proper response to a medical emergency. No physicians or nurses are located on-site. The CNP has the necessary facilities and supplies at the site for decontamination and monitoring of personnel as well as the facilities and necessary medical supplies for appropriate emergency first aid treatment. L.3. State Medical Support Listing Not Applicable. . L.4. Victim Transport Medic-1 Ambulance Service is located approximately 4 miles from the plant and provides the primary emergency medical services for the Plant. As a back up a plant emergency vehicle is available. Planning Standard L CEP Rev 39 PLANNING STANDARD M RECOVERY AND RE-ENTY PLANNING AND , POST ACCIDENT OPERATIONS* Planning Standard M Page 126 of 212 CEP Rev 39 Page 127 of 212 M. RECOVERY AND RE-ENTRY PLANNING AND POST ACCIDENT OPERATIONS M.1. Reentry and Recovery The exact nature and details of a specific emergency determine the procedures that are used for the resumption of normal plant activities. The procedures formulated to regain the services of plant systems lost through such an incident follow the practices of good engineering judgment.

After the Emergency Plan has been activated, the plant personnel initiate a survey of plant damage and contamination.

The plant systems or components involved in the incident are evaluated by any number of the following methods: 1. Radiation Surveys 2. Process instrumentation

3. Visual inspe~tions (where possible)

. 4. Reactor Protection System Instrumentation

5. Reactor Control System Instrumentation

6. Out of core and in core nuclear instrumentation

7. Engineering safety features instrumentation

8. Radiation monitoring system 9. Post Accident Sampling Capability (where possible)

Re-Entry Survey or personnel monitoring teams are sent out to gather information prior to re-entry and report such findings to the individuals designated in the Emergency Plan Procedures in the TSC and/or the EOF. The Radiation Protection Director (RPO) is responsible for protecting plant personnel entering the plant. The RPO is responsible for ensuring that radiation doses are under Federal limits for a radiation worker involved in plant re-entry before resuming normal plant operation. Survey teams will measure radiation levels on and around the site and re-entry will be made when radiation hazards are reduced to permissible levels. The SEO will approve re-entry procedures based on existing and potential conditions of the plant. Recovery Operations Where control of the incident has been attained and there is no further danger to personnel, the emergency phase shall be at ah end. Restoration and recovery operations shall continue, but not under the same criteria as the emergency operation. During restoration and recovery operations, activity levels and personnel exposures will be based on 1 O CFR 20 limits. Planning Standard M CEP Rev 39 i I Page 128 of 212 The recovery procedures that must be developed following a radiological incident will vary, but in general they will include the following activities:

1. Damage evaluation

2. Decontamination measures 3. Repair procedures

4. Disposal procedures

5. Ensure adequate offsite response readiness

6. Test and start-up procedures

'M.2. Recovery Organization The Recovery Organization is addressed in~ the Emergency Plan Procedures. See Appendix A for cross-reference. M.3. Recovery Initiation Notification Normal -communications channels will be utilized to notify State,. County and other response organizations of the start of recovery operations and any changes occurring within the plans, procedures and response organization. Recovery operations affecting or interfacing with offsite responsibilities will be reviewed and approved by the appropriate response manager. M.4. Estimating Population Total Exposure Not addressed. Planning Standard M CEP Rev 39 Page 129 of 212 PLANNING STANDARD N EXERCISES AND DRILLS Planning Standard N CEP Rev 39

~

Page 130 of 212 N. EXERCISES AND DRILLS -N .1. Exercises N.1.a. Exercise Content Each exercise. will be conducted in accordance with a unique scenario developed for that exercise. Each exercise tests portions of emergency preparedness plans within the AEP system, State and County. The plant will also participate in joint exercises initiated anc;J coordinated by the NRG and FEMA to test the effectiveness of the emergency plan(s) at all levels.

The ultimate criteria against which the results of exercises are to be measured will be effective implementation of the plant's and participating response organization emergency response plans to a simulated event, and the manner in which all agencies, public and private, interface their plans to assure that the public health and safety is protected.

N .. 1.b. Exercise Scheduling An annual emergency exercise is conducted at CNP to test various basic elements of the emergency preparedness program. Biennially, this exercise is conducted with participation of offsite emergency personnel, including those of State and County agencies. Off-hours shift augmentation drills ensure that the goals of Table 1, CNP Staffing for Radiological Emergencies, are being met. These drills are to be conducted semi-annually. One of these drills per calendar year will include the contacted personnel reporting to their assigned .emergency facilities and activating the facility. Credit can be taken for normal shift personnel

above that indicated for "On-shift" to meet the augmentation goals. Scenarios will be varied from year to year such that all major elements of the Emergency Plan, Emergency Plan Procedures and Emergency Response Organizations are tested within an 8 year period (see Appendix J, Eight Year Plan Matrix, for 8 year plan). N.2. Drills N.2.a. Communication Drills Communications is a part of each drill and exercise.

Links are established between the off-site agencies and the Cook ERO, or plant personnel playing the part of the off-site agencies communicate with the ERO communicators.

Communication links between the plant emergency facilities are established as a part of each drill or exercise.

Anytime Offsite Survey Teams are dispatched for drill or exercises communication and control with the teams is established. N.2.b. Fire Drills Quarterly fire drills are conducted to ensure participation biannually by si_te fire brigade members. An annual fire drill is held that includes participation of an offsite fire department. N.2.c. Medical Emergency Drills An exercise simulating radiological and physical injury shall be conducted with the offsite medical personnel annually. Planning Standard N CEP Rev39 Page 131 of 212 N.2.d. Radiological Monitoring Drills Drills involving response to, and analysis of, simulated airborne, liquid, and environmental (vegetation, snow, soil, etc.) samples and direct radiation measurements in the environment shall be conducted semi-annually. N.2.e. Health Physics Drills N.2.e.1. Environmental Monitoring Drills involving response to, and analysis of, simulated airborne, liquid, and environmental. (vegetation, snow, soil, etc.) samples and direct radiation measurements in the environment shall be conducted semi-annually. N.2.e.2. Plant Liquid Monitoring PASS removed by Qperating Ucense chanm=~ #261 and 244 for Ul and 2 respectively del~te requirements for Post Accident Sampling System. N.2.f. Other drills N.2.f.1. Hostile Action Based Drills Drills involving response to the use of violent force to destroy equipment, take hostages, and/or intimidate the licensee to achieve an end. This incluqes attack by air, land, or water using guns, explosives, projectiles, vehicles, or other devices used to deliver destructive force. (NRC Commitment 8373.) N.2.f.2.Fast Breaking Drills Drills involving an initial classification of, or rapid escalation to, a Site Area Emergency or General Emergency. N.2.f.3.No radiological release or minimal release. Drills involving declaration of a Site Area Emergency but not a General Emergency that involve no radiological release or an unplanned minimal radiological release. N.3. Drill and Exercise Execution Each scenario shall be jointly developed by appropriate response agencies participating in the exercise and shall include: i N.3.a. Basic objective(s) of the exercise N.3.b. Date, time and place and participating response agencies, and the extent to which participating agencies will respond. N.3.c. Simulated events, which may include offsite radiological releases. N.3.d. Time Line of real. and simulated events. N.3.e. Narrative summary describing the conduct of the exercise. Planning Standard N CEP Rev 39 Page 132 of 212 N.3.f. Arrangements for official observers, and advance materials to official observers. N.4. Official Observation and Critique After the drill or exercise, a critique shall be conducted involving participants, controllers and observers. The critique should be held as soon as practicable after completion of the drill or exercise. N.5. Results Evaluation and Corrective Actions A formal evaluation of exercises, with lessons learned, shall be prepared and submitted through the Corrective Action Program. The Emergency Preparedness Manager (or alternate) shall review and assign action items to upgrade those areas where deficiencies were noted. These

action items will be assigned, tracked and closed using the plant corrective action program. ~. Planning Standard N CEP Rev 39 Page 133 of 212 PLANNING STANDARD 0 .RADIOLOGICAL EMERGENCY RESPONSE TRAINING Planning Standard 0 CEP Rev 39

0. 0.1 RADIOLOGICAL EMERGENCY RESPONSE TRAINING Organization Training Page 134 of 212 Cook Nuclear Plant provides training to agencies or organizations that provide onsite assistance to the plant. Types of organizations provided this training are as follows:

Local Law Enforcement
Ambulance Service
Fire Departments
Hospitals Training should be offered annually.

Should any of these agencies request additional training, either in scope or schedule, every possible action should be taken to facilitate the request. The training of Berrien County and State ot Michigan emergency [esponse personnel is the responsibility of the Michigan State Police Emergency Management and Homeland Security Division. The Cook Nuclear Plant is committed to assist in the endeavor upon request. 0.2. Onsite ERO Training The plant training program is the responsibility of the Training Manager. A general employee training program provides initial orientation training and annual (every 12 months) retraining to CNP employees in the general emergency plan response. They are familiarized with the sounding of the Nuclear Emergency Alarm, assembly areas and routes to take to these assembly areas. This training also includes general aspects of the Emergency Plan. ERO position specific training and qualification is administered through TPD-600-EPT Emergency Preparedness Training Program Description. Position specific Job Familiarization Guides are used for on-the-job training and qualification of the ERO responders. 0.3. First Aid Team Training Personnel who respond to medical emergencies at the Cook Nuclear Plant receive either aid training or are qualified as Medical Emergency Response Team members (MERT). 0.4 ERO Training and Qualification To the maximum extent practicable, emergency plan training and qualification should be incorporated into functional training and qualification programs. Specialized initial training and retraining programs will be provided as outlined below for the following categories of emergency personnel. 0.4.a. Directors and Key Personnel Initial specialized training in emergency plan and procedures implementation is provided to the directors and coordinators of the response organizations including emergency plan drill participation and annual reviews of the same. Training for execution of the emergency plan is provided by completion of senior licensed operator training, or equivalent training that applies to emergency plan execution. Planning Standard O CEP Rev 39 Page 135 of 212 0.4.b. Personnel Responsible for Accident Assessment Initial specialized training in emergency plant operations, emergency plan and procedures implementation is provided including an annual review of the same. Further training includes participation in emergency plan drills.

0.4.c. Radiological Monitoring Teams Radiation Protection personnel receive Emergency Plan training as part of their Initial RP Technici.an training.

Continuing Training and drill participation requirements addressed in TPD-600-EPT, Emergency Preparedness Training Program Description.* 0.4.d. Security & Fire Brigade Fire*Brigade staff receive Initial and annual retraining in fire fighting techniques and first aid. ,, The Plant Security Fprce is considered the~Emergency Security T~am. All .actions requirgd during emergencies are included in security officer training., 0.4.e. Onsite Repair & Damage Control The Damage Control Team is responsible for the repair and restoration of damaged plant systems, equipment, or components. Training, exercises and drills involving the Pamage Control Team will be conducted in a manner consistent with established Emergency Plan Procedures. 0.4.f. First Aid & Rescue Teams The first-aid training program is administered by the Training Department. The MERT program is administered by an accredited offsite institution. 0.4.g.

Local Service Personnel (Offsite Fire Department Personnel and Local Sheriffi The local Fire
Departments receive familiarization in specific, plant acce$S and control procedures and participate annually in plant fire drills. Sheriffs department receives annual Emergency Alert System (EAS) training and participates in the annual plant emergency exercise.

0.4.h.

Medical Support Personnel An exercise simulating radiological and physical injury . shall be conducted with the offsite m~dical personnel annually.

0.4.i. Licensee Headquarters Support Not addressed. 0.4.j. Personnel Transmitting Emergency Information and Instructions ERO Communicators receive ERO initial training and position specific Job Familiarization Guides for their specific communication duties. Planning Standard 0 CEP Rev 39 Page 136 of 212 0.5. Initial and Annual Retraining Initial training and qualification, as well as continuing training requirements addressed in TPD-600-EPT, Emergency Preparedness Training Program Description . . Initial training and job familiarization completed prior to assignment to the ERO. Continuing training consists of the following (as minimum):

Drill participation at least once every two years.
ERO Facility training.
Annual ERO Classroom training or a requalification challenge exam. Planning Standard 0 CEP Rev 39 Page 137 of 212 PLANNING STANDARD P RESPONSIBILITY FOR PLANNING EFFORT Planning Standard P CEP Rev 39 P. P.1 RESPONSIBILITY FOR PLANNING EFFORT Emergency Planner Training Page 138 of 212 Emergency Preparedness Coordinator position specific training and qualification is administered through TPD-600-EPC Emergency Preparedness Coordinator Training Program Description.

Position specific training and qualification card are used for training and qualification of Emergency Preparedness Coordinators. P.2 Emergency Plan Administration Responsibility The . Chief

Nuclear Officer shall have overall authority and responsibility for radiological emergency response planning.

In this effort he has the authority to delegate responsibility in the planning effort

to .enhance the overall readiness and ensure that the plan is updated as . necessary.

Normally plan updating and review will be the responsibility of the Site Vice President. The training of individuals in the CNP Emergency Response Organization (ERO) in ~the Emergency Plan s~,all be the responsibility .9f the Training Manage~ P.3 Emergency Planning Coordinator Designation Not addressed. P.4. Periodic Reviews Updates and Audits The responsibilities of. the individuals, groups, agencies, the Emergency Plan, and implementation procedures to be followed during an emergency condition are reviewed at a

minimum, on an annual basis and updated as required.

All written agreements with offsite support groups are reviewed and updated if necessary, on a two year basis. This review will take into account changes identified by drills and exercises. The plant maintains up-to-date approved emergency response plans from the state and county. Changes to these offsite plans are reviewed to maintain an effective interface with the Cook Emergency Plan. The Plant Operations Review Committee is responsible for the review of changes to the Emergency Plan. The Plant Operations Review*committee is also responsible for the review of changes, other than editorial corrections, to the Emergency Plan Implementing Procedures. The Senior Vice President -Nuclear Generation Group, or designee, shall approve changes to the Emergency Plan. All reviews shall be documented. The Senior Vice President-Nuclear Generation Group shall be sent copies of the changes. NRG approval shall be obtained as appropriate. P.5. Emergency Plan Change Communication Approved Emergency Plan revisions and/or applicable procedural changes will be promptly forwarded to appropriate offsite emergency support organizations. A list of changes to the Emergency Plan shall be submitted with each plan revision. Changes to the Plant's Emergency Plan Procedures shall be made in accordance with plant practice for revising procedures. Planning Standard P CEP Rev 39 P.6 Emergency Response Organization Support Plans Plan Emergency Operations Plan Source Berrien County Sheriffs Office State of Michigan Page 139 of 212 Michigan Emergency Management Plan Regional Plan Handbook -RAP INPO Emergency Response Manual National Response Plan, _Nuclear/Radiological Incident Annex Department of Energy Region V Institute of Nuclear Power Operations* Department of Homeland Security with NRC as Coordinating Agency P.7. Implementing Procedures Detailed procedures for implementing and providing additional information on the Emergency Plan are available in the Emergency Plan Procedures._ The written_ procedures indicated in Appendix A cover the following but are not limited to: 1. Authority and responsibility for completing specific tasks. 2. Action levels requiring implementation of protective measures outlined.

3. Medical treatment procedures and handling of contaminated individuals.

4. Necessary equipment for medical treatment, radiation detection, and rescue operations.

5. Identification of emergency communications equipment.

6. Emergency center description and operation.

7.-Restoration procedures from emergency to normal conditions.

8. Communications P.8 Table of Contents & Cross-reference Table of Contents and Appendix A fulfill this requirement.

P.9. Independent Emergency _Program Review Audits of the Emergency Plan and implementing procedures are performed as delineated in 10 CFR 50.54(t)(1). These audits shall be performed by the Plant Performance* Assurance Department and may include items relating to training, readiness testing, equipment, State/local plant interfaces, medical arrangements, etc. I Audit findings shall be reported, evaluated and recommendations completed as described in the Audit Program Policy. The results of the audit, along with the recommendations for improvements shall be documented and reported to plant management and retained for a period of five years. Reviews involving the adequacy of interface with State/local agencies shall be available to the appropriate agency. P.10. ERO Telephone Number Updates Appendix J fulfils this requirement. Planning Standard P CEP Rev 39 *.! 1 Page 140 of 212 APPENDIX A 1. INDEX OF Ery'IERGENCY PLAN IMPLEMENTING DOCLtMENTS

2. CROSS REFERENCE CEP AND EMERGENCY PLAN IMPLEMENTING DOCUMENTS Appendix A CEP Rev 39 Page 141 of 212 DONALD C. COOK NUCLEAR PLANT EMERGENCY PLAN IMPLEMENTING DOCUMENTS IDENTIFICATION NUMBER

RMA-2080-EPA-008 PMP-2080-EPP-100 PMP-2080-EPP-101 PMP-2080-EPP-108 RMT-2080-EPl-109 PMP 2080-EPP-200 PMP-2081-EPP-105 RMT-2080-EPP-500 RMT-2080-EOF-001 RMT-2080:-JI C-001 RMT-2080-0SC-OO 1 RMT-2080-TSC-OO 1 SPP-2060-SFl-216 EPP-2080-ER0-001 RMT-2080-PPA-OO 1 TPD-600-EPC
TPD-600-EPT TITLE EMERGENCY PLAN MANAGEMENT , EMERGENCY RESPONSE EMERGENCY CLASSIFICATION INITIAL DOSE ASSESSMENT TERMINATION AND RECOVERY INITIATING CHANGES TO THE EMERGENCY PLAN OR EMERGENCY PLAN IMPLEMENTING PROCEGURES . . . . *. . CORE DAMAGE ASSESSMENT DRILL & EXERCISE SCHEDULING, DEVELOPMENT, CONDUCT &EVALUATION ACTIVATION AND OPERATION-OF THE EOF ACTIVATION AND OPERATION OF THE ENC/JIC ACTIVATION AND OPERATION OF THE OSC ACTIVATION AND OPERATION OF THE TSC PLANT RESPONSE TOA VALIDATED SECURITY THREAT EMERGENCY RESPONSE RESOURCE READINESS EMERGENCY PREPAREDNESS PERIODIC PROGRAM ACTIVITIES EMERGENCY PREPAREDNESS COORDINATOR TRAINING PROGRAM DESCRIPTION EMERGENCY PREPAREDNESS TRAINING PROGRAM DESCRIPTION DECONTAMINATION AND TREATMENT OF THE RADIOACTIVELY CONTAMINATED PATIENT(S)

AT LAKELAND REGIONAL MEDICAL CENTER ERO ON-SHIFT STAFFING ANALYSIS REPORT Appendix A CEP Rev 39 Page 142 of 212 NUREG-0654 -EMERGENCY PLAN -PROCEDURE CROSS REFERENCE At Cook Nuclear Plant, NUREG-0654 is applied as guidance in plan and procedure development with consideration to plant organization, administrative policies and operating procedures. NUREG-0654 EMERGENCY (Sect II Planning Standards PLAN SECTION PLANT PROCEDURE and Evaluation Criteria) A.1.a A.1.a Not applicable 8.8 8.9 A.1.b A.1.b Not applicable A.1.c .. A.1.c ,. Not applicable Figure 1 Figure 2 Figure 3 Figure 4 Figure 5 Figure 6 Figure 7 Figure 8 Figure 9 FiQure 10 A.1.d A.1.d PMP-2080-EPP-100 RMT-2080-EOF-001 A.1.e A.1.e RMT-2080-EOF-001 Table 1 A.2. Not applicable Not applicable A.3 A.3 RMA-2080-EPA-008 Appendix 8 A.4 A.4 RMT-2080-EOF-001 RMT-2080-0SC-OO 1 RMT-2080-TSC-001 8.1 8.1 Not applicable Figure 3 Figure 4 8.2 8.2 PMP-2080-EPP-100 8.1.j. ' 8.5.a.1 8.5.c.1 8.3 8.3 PMP-2080-EPP-100 RMT-2080-TSC-OO 1 RMT-2080-EOF-OO 1 8.4 8.4 PMP-2080-EPP-100 RMT-2080-EOF-001 " Appendix A CEP Rev 39 Page 143 of 212 NUREG-0654 EMERGENCY (Sect II Planning Standards PLAN SECTION PLANT PROCEDURE and Evaluation Criteria) B.5 B,5 RMT-2080-0SC-OO 1 Table 1 RMT-2080-TSC-OO 1 Figure 5 RMT-2080-EOF-001 Figure 6 RMT-2080-JIC-001 Figure 7 ERO On-Shift Staffing Analysis Fk1ure 8 Report B.6 B.6 Not ap.plicable . Fiqure 8 B.7 B.5 ERO On-Shift Staffing Analysis Table 1 Report B.7.a B.7.a RMT-2080-EOF-OO 1 B.5.c.9 B.7.b B.7.b RMT-2080-TSC-OO 1 ,, B.5.c.8 ., . , . B.7.c B.7.c RMT-2080-EOF-001 B.5.c.1 B.7.d B.7.d RMT-2080-J IC-001 B.5.d.1 B.8 B.8 Not applicable C.4 Appendix B B.9 B.9 Not applicable L.1 Appendix B C.1.a C.1.a Not applicable C.1.b C.1.b Not applicable Appendix E C.1.c Appendix E Not applicable C.2.a Not applicable Not applicable C.2.b B.5.e.1 RMT-2080-EOF-001 C.3 H.6.c RMT-2080-EOF-001 Appendix B Appendix H C.4 C.4 RMT-2080-EOF-001 B.8 Appendix B Appendix H D.1 D.1 PMP-2080-EPP-101 Table 2 Table 3 Table 4 D.2 D.2 PMP-2080-EPP-101 Table 2 Table 3 Table 4 D.3 Not applicable Not applicable D.4 Not applicable Not applicable Appendix A CEP Rev 39 Page 144 of 212 NUREG-0654 EMERGENCY (Sect II Planning Standards PLAN SECTION PLANT PROCEDURE and Evaluation Criteria) E.1 E.1 PMP-2080-EPP-100 E.2 E.2 PMP-2080-EPP-100 SPP-2060-SFl-216 E.3 E.3 PMP-2080-EPP-100 E.4 E.4 PMP-2080-EPP-100 RMT-2080-EOF-001 E.5 Not applicable Not applicable E.6 E.6 Not applicable Appendix D E.7 E.7 PMP-2080-EPP-100 RMT-2080-EOF-001 F.1.a F.1.a PMP-2080-EPP-100 F.1.b F.1.b RMT-2080-EOF-001 'F.1.c .. F.1.c. .. RMT,.2080-EOF-001 . Appendix E F.1.d F.1.d RMT-2080-EOF-001 F.1.e F.1.e PMP 2080-EPP-100 F.1.f F.1.f RMT-2080-EOF-001 F.2 F.2 Not applicable F.3 F.3 EPP-2080-ERO-OO 1 G.1 G.1 Not applicable Appendix D G.2 G.2 Not applicable G.3.a G.3. RMT-2080-JIC-001 G.3.b Not addressed Not applicable G.4.a G.4.a RMT-2080-JIC-001 G.4.b G.4.b. RMT-2080-JIC-001 G.4.c G.4.c. RMT-2080-JIC-001 G.5 G.5. Not aoplicable H.1 H.1 (TSC) RMT-2080-TSC-OO 1 H.3 (OSC) RMT-2080-0SC-001 H.2 H.2 RMT-2080-EOF-001 H.3 Not applicable Not applicable (SEOC/CEOC) H.4 H.4. PM P-2080-EPP-100 H.5 H.5 RMT-2080-TSC-001 H.5.a H.5.a RMT-2080-EOF-001 RMT-2080-0SC-OO 1 H.5.b -. H.5.b RMT-2080-TSC-OO 1 H.5.c H.5.c RMT-2080-TSC-OO 1 H.5.d H.5.d Not applicable H.6 H.6 RMT-2080-EOF-OO 1 H.6.a H.6.a RMT-2080-EOF-001 H.6.b H.6.b RMT-2080-EOF-001 EPP-2080-ER0-001 H.6.c H.6.c RMT-2080-EOF-001 H.7 H.7 EPP-2080-ERO-OO 1 Appendix A CEP Rev 39 I I Page 145 of 212 NUREG-0654 EMERGENCY (Sect II Planning Standards PLAN SECTION PLANT PROCEDURE and Evaluation Criteria) H.8 H.8. RMT-2080-EOF-OO 1 H.9 H.3 RMT-2080-0SC-OO 1 H.10 Appendix J EPP-2080-ER0-001 H.11 Appendix C EPP-2080-ERO-OO 1 H.12 H.3.d. RMT-2080-EOF-001 1.1 1.1. PMP-2080-EPP-101 Table 2 Table 3 Table 4 1.2 1.2 RMT-2080-EOF-001 1.3.a 1.3.a. RMT-2080-EOF-OO 1 1.3.b 1.3.b. RMT-2080-EOF-OO 1 1.4 1.4 RMT-2080-EOF-001 1.5 ,, 1.5 ,, RMT-2080-EOF-001 ,, 1.6 Not addressed Not applicable 1.7 1.7 RMT-2080-EOF-001 1.8 1.8 RMT-2080-EOF-001 1.9 1.9 RMT-2080-EOF-001 1.10 Not addressed RMT-2080-EOF-001 1.11 Not applicable RMT-2080-EOF-001 J.1.a J.1.a RMT-2080-TSC-001 J.1.b. J.1.b. RMT-2080-TSC-001 J.1.c. J.1.c. RMT-2080-TSC-001 J.1.d. J.1.d. RMT-2080-TSC-OO 1 J.2 J.2 RMT-2080-TSC-OO 1 Fiaure 14 J.3 J.3 RMT-2080-TSC-OO 1 J.4 J.4 RMT-2080-TSC-001 J.5 J.5 RMT-2080-TSC-001 J.6.a J.6.a. RMT-2080-EOF-001 J.6.b J.6.b. RMT-2080-EOF-001 J.6.c J.6.c. RMT-2080-EOF-OO 1 J.7 J.7 RMT-2080-EOF-OO 1 J.8. J.8, PMP-2080-EPP-100 Berrien County Emergency RMT-2080-EOF-001 Operations Plan J.9. Not Applicable Not Aoolicable J.10.a. J.10.a. Not applicable J.10.b J.10.b. Not Applicable J.10.c. J.10.c. Not Applicable E.6. J.10.m. J.10.d. PMP-2080-EPP-100 1.4. RMT-2080-EOF-001 1.5. K.1 a -q K.1 RMT-2080-0SC-OO 1 K.2 K.2 RMT-2080-TSC-OO 1 RMT-2080-0SC-OO 1 Appendix A CEP Rev 39 Page 146 of 212 NUREG-0654 EMERGENCY (Sect'II Planning Standards. PLANT PROCEDURE and Evaluation Criteria) PLAN 'SECTION K.3.a K.3.a. RMT-2080-TSC-001 RMT-2080-0SC-OO 1 K.3.b K.3.b. RMT-2080-0SC-OO 1 K.4 Not Applicable Not Applicable K.5.a K.5.a. RMT-2080-0SC-OO 1 K.5.b K.5.b RMT-2080-0SC-OO 1 K.6.a. K.6.a. RMT-2080-TSC-001 RMT-2080-0SC-OO 1 K.6.b. Not Addressed K.6.c. K.6.c. RMT-2080-EPl-109 K.7 K.7 RMT-2080-0SC-OO 1 L.1 L.1. Lakeland Hospital Contaminated Injured Person .. ** Protocol ** L.2 L.2. Not applicable L.3. Not Applicable Not applicable L.4 L.4 Not applicable M.1 M.1 RMT-2080-0SC-001 M.2 M.2 RMT-2080-EPl-109 M.3 M.3 RMT-2080-EPl-109 M.4 Not addressed Not aoolicable N.1.a N.1.a RMT-2080-EPP-500 RMT-2080-PPA-001 N.1.b. N.1.b. RMT-2080-EPP-500 AppendixJ RMT-2080-PPA-OO 1 N.2.a N.2.a. RMT-2080-EPP-500 RMT-2080-PPA-001 N.2.b

Tech. Spec. RMT-2080-EPP-500 RMT-2080-PPA-001 N.2.c N.2.c. RMT-2080-EPP-500 Appendix J RMT-2080-PPA-001 N.2.d N.2.d. RMT-2080.:.EPP-500 N.2.e N.2.e RMT-2080-EPP-500 N.3 N.3 RMT-2080-EPP-500 N.4 N.4 RMT-2080-EPP-500 N.5 N.5 RMT-2080-EPP-500 0.1 0.1 TPD-600-EPT 0.1.a. 0.1 TPD-600-EPT 0.1.b. Not applicable Not applicable 0.2 0.2 TPD-600-EPT 0.3 0.3 RMT-2080-PPA-OO 1 0.4.a 0.4.a. TPD-600-EPT 0.4.b 0.4.b. TPD-600-EPT 0.4.c. 0.4.c. TPD-600-EPT 0.4.d. 0.4.d. Not addressed 0.4.e. 0.4.e. TPD-600-EPT 0.4.f. 0.4.f. Not addressed Appendix A CEP Rev 39 Page 147 of 212 NUREG-0654 EMERGENCY (Sect II Planning Standards PLAN SECTION PLANT PROCEDURE and Evaluation Criteria) 0.4.Q. 0.4.g. Not addressed 0.4.h. 0.4.h. Not addressed 0.4.i. Not addressed Not addressed 0.4.i. 0.4.i. TPD-600-EPT 0.5 0.5. TPD-600-EPT P.1 P.1 TPD-600-EPC P.2 P.2 PMl-2080 P.3 Not addressed PMl-2080 P.4 P.4. PMl-2080 P.5 P.5 RMA-2080-EPA-008 P.6 P.6 ,. Not applicable P.7 Appendix A Not applicable P.8 Table of Contents Not apf21icable

.. .. . Appendix A .. ** P.9 P.9 Not applicable P.10 APoendix J RMT-2080-PPA-001 Appendix A CEP Rev 39 Page 148 of 212 APPENDIX B AGREEMENTS WITH OFF-SITE SUPPORT AGENCIES Appendix B CEP Rev 39 Page 149 of 212 APPENDIX B Agreements with Off-Site Support Agencies 1. Sheriff Department, Berrien County, Michigan 1 page January 5, 2018 2. , Lakeland Health 1 page January 18, 2018 (', 3. Lake Township Fire Department 1 page January 5,'2018 4. City of Bridgman Fire Department 1 page January 16, 2018 5. Medic 1 Community Emergency Service 2 pages December 20, 2017 6. Reciprocal Laboratory Use Agreement 2 pages August 28, 2017 7. Mutual Assistance Agreement Between Detroit Edison 6 pages September 25, 2017 Company, Entergy Nuclear Palisades ana Indiana Michigan Power Co. 8. Institute of Nuclear Power Operations Emergency 1 page November 2, 2017 Resources .9. FEMA Alert and Notification (ANS) Design Report letter 1 page September 11, 2017 Appendix B CEP Rev 39 Sheriff Department, Berrien County, Michigan 1/5/2018 BERRIEN COUNTY EMERGENCY MANAGEMENT DIVISION OF BERRIEN COUNTY SHERIFF'S OFFICE 2100 E. Empire Avenue, Benton Harbor, Michigan 49022 Telephone (269) 983-7141

Fax: (269) 983-5726 Mr. Ronald J. Sieber Cook Nuclear Plant One Cook Place Bridgman, Ml 49106

Dear Mr. Sieber:

Page 150 of 212 1 page JON HINI(ELMAN CHAIRMAN BOARD OF COMMISSIONERS L. PAUL BAILEY SHERIFF CAPT. ROCKEY ADAMS COORDINATOR We wish to reaffirm the willingness of the Berrien County Sheriff's Department to respond upon request to any emergency which could occur at the D.C. Cook facility. Berrien County Emergency Management/Office of Homeland Security has the obligation to respond upon notification that an emergency exists. Berrien County will implement their Nuclear Accident Proced__ures (Appendix

1) of the Emergency Operations Plan and take appropriate actions as outlined therein. In addition, the Sheriff's Department has basic patrol and investigative services and currently has a fourteen member Hazardous Materials Response Team who are trained to Technician Level. Four of the fourteen Haz-Mat team members are cross-trained as bomb technicians, and of whom have successfully completed the FBI Hazardous Device School at Redstone Arsenal in Redstone, Alabama. Our Tactical Unit consists of 20 personnel who conduct training monthly. The Berrien <;:aunty Sheriff's Department will be available to you upon request, in any area within the jurisdiction of this agency. Sincerely, Sheriff/Director, Emergency Management

\ Appendix B CEP Rev 39 Lakeland Health Page 151 of 212 1 page Lakeland Health January 18, 2018 :Mr. Joel Gebbie Sr. Vice President & ChiefNuclear Officer Cook Nuclear Plant One Cook Place Bridgman, MI 49106

Dear Mr. Gebbie:

This letter is to confom that Lakeland tJ:ealth remains able .to 1)l*ovide care for the injured radioactively-contaminated patients at the St. Joseph and Niles Emergency Department sites. This would include Donald C. Cook personnel exposed on-site and members of the pub1ic exposed off-site who may l'equire services.

Mutually agreed upon annual training and drills will be conducted to assure staff competency fa. caring for. this patient population, with evaluation by FEMA when required.

A policy and procedure manual is available at each site and updated regularly to mcorporate changes in patient management. An identified Radiation Emergency Area '(REA) is available at each site that allows for stabilization, treatment, and management of the radioactive eomponent of the *emergency. I understand that the training for hospital personnel, equipment, and stocking of the dlsaster cart will continue to be provided by Donald C. Cook Nuclear Plant. This agreement shall remain in effect from the date of signing until either party, upon ninety (90) days prior written notice to the other party, terminates the agreement. Please contact Kathy Effa, Manager of Emergency Services, at 269.983.8670 for any assistance that you require. /-* Sincerely, *'1-// ,,,// /--"-.. .. /':)-/ / . / // " .... .. ,../" ,' ,/ ...... ..,.,~*. < \ * /,' * ' *,'*v,/;:-;, * . -~ I ,,/~* / ---. . . . l_...,.,-,Loren B. Hamel, MI> President & CEO Lakeland Health LBH: sd Legal Review Completed HfrP I \1~ji':B 1234 Napier Avenue, St. Joseph, Ml 4908S (269) 983-8300 Appendix B w ww. I a ke I a I) d h ea Ith .o rg CEP Rev 39 Lake Township Fire Department Page 152 of 212 1 page LAI(E TOWNSI-IIP FIRE AND RESCUE P.O. BOX 818 3169 SHAWNEE ROAD BRJDGIVIAN, MICHIGAN 49106 269-465-6351 Emergency Preparedness Agreement Between Lake Charter Township Fire Department and Donald C. Cook Nuclear Plant Upon receipt of a request for assistance from the Cook Nuclear Plant, Lake Charter Township Fire Department agrees to respond by sending personnel and an NFPA 1901 compliant Pumper Fire Apparatus with the required minimum equipment to the Cook nuclear Plant Site. The Cook Nuclear Plant agrees to lead Lake Charter Township Fire Department responders from

the Security Control Center to the scene and agr~es to provide escorts.for Lake Ch!);rter Township Fire Fighting vehicles and personnel while in the Protected Area, or other owner controlled areas. The Cook Nuclear Plant and Lake Charter Township Fire Department agree that for all fires in the Plant Protected Areas, the Plant Fire Brigade Leader will be responsible for fire extinguishment with the assistance of Lake Charter Township Fire Department personnel and advice and counsel of the Lake Charter Township Fire Chief or his designee.

For fires outside the Plant Protected Area, the Lake Charter Township Fire Chief shall be responsible for fire extinguishment with the advice and counsel of the Plant Fire Brigade Leader or designee if they are present. The Cook Nuclear Plant agrees to provide and Lake Charter Township Fire Department agrees to participate in annual site specific training and drills conducted at the Cook Nuclear Plant site. This agreement shall remain in effect from the date of signing unless the agreement is terminated. Any party upon ninety (90) days prior written notice to the other party may terminate this agreement. As an indication of your agreement to the above statements . concerning our mutual responsibilities, please sign below. Sincerely, ~~ce President /okNU<;:lear Plant Accepted and agreed to this S dayof .,ddddh11f .c,2018 (;/ffe4~ John ast Supervisor Lake Charter Township / //7 ~<?~/ ,~.* Harold Heyn

7 Fire Chief Lake Charter Township Fire Department Appendix B CEP Rev 39 City of Bridgman Fire Department BRIDGMAN FIRE RESCUE P.O. BOX 366 4234 VINE STREET BRIDGMAN MICHIGAN 49106 (269) 465-3803 (269) 465-5144 FAX (269) 465-4269 . EMERGENCY 911 Page 153 of 212 1 page Emergency Pfeparedness Agreement between Bridgman City Fire Department and Donald C. Cook Nuclear Plant. Upon receipt of a request for assistance from the Cook Nuclear Plant, Bridgman City Fire Department agrees to respond by .;lending personnel, apparatus,,and equipment to the Cook Ngclear Plant site.
The Cook Nuclear Plant agrees to lead Bridgman City Fire Department responders from the Security Control Center.to the scene and agrees to provide escorts for Bridgman City Fire Department Apparatus and personnel while in the protected area, or other owner controlled areas. The Cook Nuclear Plant and Bridgman City Fire Department agree that for all fires in the Plant Protected Areas, the Plant Fire Brigade Leader will be responsible for the fire extinguishment with the assistance of Bridgman City Fire Department personnel and the advice and counsel of the Bridgman City Fire Chief or his des/gnee.

For fires outside the Plant Protected Area, the Lake Charter Township Fire Chief shall be responsible for fire extinguishment with the assistance ofBridgman City Fire Department personnel and advice of the Bridgman City Fire Chiefor designee and counsel of the Plant Fire Brigade Leader or designee if they are present. The Cook Nuclear Plant agrees to provide and Bridgman City Fire Department agrees to participate in annual site specific training and drills conducted at the Cook Nuclear Plant site. This agreement shall remain in effect from the date of signing unless the agreement is terminated. Any party upon ninety (90) days prior written notice to the other party may terminate this agreement. As anindication of your agreement to the above statements concerning our mutual responsibilities, please sign below. Sincerely, Cook Nuclear Plant Accepted and agreed to this I b 1-1,.. Day of J;...., vo, 1-) ~~--Joel Buist Fire Chief , 2018 Bridgman City Fire Department Appendix B CEP Rev 39 Page 154 of 212 Medic 1 Community Emergency Service *MEDI£1 E11ierge11cy Pl111111i1ig Agree111e11/ 1Jehvee1i Metlic J A111b11la11ce q111/ Do11altl C. Cool, Nuclear P/mtt The purpose of this letter is to establish an agreement between Indiana and Michigan Electric Company's Donald C. Cook Nuclear Plant and Medic I Ambulance. In the event of an emergency at the Cook Nuclear Plant involving an injury, Medic 1 Ambulance agrees to*provide medical care whether the victim has been htjured as the result of an accident involving radioactive contamination, hazardous waste, or a regular work accident. Upon receipt ofa request for an EMS vehicle from the Cook Nuclear Plant Control Room, Medic 1 Ambulance agrees lo respond by sending personnel, apparatus, and equipment to the Plant site. Cook Nuclear Plant agrees to provide an escort for EMS vehicles and personnel while in the protected area. Cook Nuclear Plant agrees to provide the necessary health physics support to Medic 1 Ambulance staff duririg the treatment of victims who are injured in an accident involving radioactive contamination. In the event ofan injury involving a hazardous waste, specific chemical information will be provided to Medic I Ambulance staff. The communication link between Medic 1 Ambulance and Cook Nuclear Plant will be provided via telephone communication through the Ben*icn County dispatch radio. Cook Nuclear Plant agrees to provide training for emergency room and EMS personnel in order to prepare them for handling of radiologically contarninated victims. Such training will consist of, but not be limited lo, a discussion of types of radiation, types of contamination, methods of decontamination, and methods of controlling the spread of conta1nination. Cook Nuclear Plant agrees to conduct and Medic I Ambulance agrees to participate in joint drills that include plant personnel, EMS personnel, and emergency room personnel. These drills will meet Joint Commission on Accredited Hospitals (JCAH) requirements. Cook Nuclear Plant agrees le;> decontaminate all Medic I Ambulance equipment and facilities including EMS vehicles. that have become contaminated as a result of treatment of a victim in a timely fashion and to dispose of the associated waste. Cook Nuclear Plant agrees to provide emergency kits for the emergency room and the ambulance. Appendix B 2 pages CEP Rev 39 Page 155 of 212 Medic l Ambulance agrees that medical care provided under this agreement includes any assist,mce rendered through existing mutual aid agreements entered into by Medic 1 Ainbulance. Any party, upon ninety (90) days prior notice to the other party, may te1minate this agreement.* As indication of your agreement to the above statement concerning our mutual responsibility, please sign below. J,Mbif-MM1 Site Vice President Cook Nuclear Plant Dated: \ 1.._/ Z.o / [ 7 Q~ JaclcJSherJr. Executive Director Medic I Ambulance Dated: ---"D'""e""'ce"'"m"'b"-'c"-r..,_1""'9.~2'"'0..,_l.,_7 __ P.O. Box 1563 / Benton Harbor, MI 49023 / Phone (269) 925-2141 Appendix B CEP Rev 39 Reciprocal Laboratory Use Agreement Page 156 of 212 2 pages RECIPROCAL LABORATORY USE AGREEMENT WITNESS ETH THAT WHEREAS, INDIANA MICHIGAN POWER, (hereinafter called IMP) and ENTERGY NUCLEAR PALISADES, L.L.C., (hereinafter called "ENTERGY) have chemical and radiochemical analytical laboratories at their Donald C Cook"Nuclear Plant and Palisades Nuclear Plant, respectively, which laboratory facilities are suitable for performing chemical analyses following a nuclear-related accident (NRA), and WHEREAS, IMP and Entergy each desire to provide the temporary use of their respective existing laboratory facilities and personnel to perform chemical analyses for the other in the event the other has lost use of its laboratory facilities due to a NRA, NOW, THEREFORE, the parties hereto do hereby mutually agree as follows: 1. In the event either party hereto is unable to use its laboratory facilities due to a NRA, the other party agrees to temporarily use its existing laboratory facilities and personnel, to the extent practical, to analyze without charge, samples delivered to it by the party which suffered the NRA .. Each party agrees, in connection with such sampling, handling and analyses, to comply with the requirements of NUREG-0578 and NUREG.-073i and such other requirements as may be specified by the Nuclear Regulatory Commission in regard to past-accident sample analysis.

2. Each party agrees, in performing analyses for the other, to provide a high standard of professional service, provided, however, that neither party shall have any obligation or liability for damages, including, but not limited to, consequential pamages, arising out of or in connection with the others use of, or reliance on, the results of such analyses.

3. This agreement shall be effective on the date hereof and shall continue until

terminated as hereinafter set forth. Either party hereto may terminate this agreement at any time hereafter upon sixty (60) days written notice of termination to the other party. Appendix B ( CEP Rev 39 Page 157 of 212 INDIANA MICHIGAN POWER BY: 0~) La c;J/i:?/17

~ane Lies Date /1e Vice President -Cook Nuclear Plant ENTERGY NUG,LEAR PALISADES, L.L.C. BY: i-\\-\1 Charles F. Arnone Date Site Vice President -Palisades Appendix B CEP Rev 39 Page 158 of 212 Mutual Assistance Agreement Between Detroit Edison Company, Entergy Nuclear Palisades and Indiana Michigan Power Co. MUTUAL ASSISTANCE AGREEMENT BETWEEN DTE ENERGY ELECTRIC COMPANY, ENTERGY NUCLEAR PALISADES, L.L.C. AND INDIANA MICHIGAN POWER Appendix B 6 pages CEP Rev 39 r-------Page 159 of 212 0.1 Enterny Nuclear Palisades, L.L.C., DTE Energy Electric Company and Indiana Michigan Power, WITNESS ETH 0.2 WHEREAS, Entergy Nuclear Palisades, (LLC), DTE Energy Electric Company and Indiana Michigan Power own electric facilities, including nuclear generation stations and are engaged in the generation of electric power in Michigan; and 0.3

WHEREAS, the parties desire to help assure the availability of adequately trained and . experienced emergency personnel in the event of an emergency situation at any of their nuclear generating stations; 0.4 NOW, THEREFORE, in consideration of the promises and mutual covenants herein set forth, the parties agree as follows: ARTICLE I DEFINITIONS 1.1 "Alert" shall be defined as a situation in which events are in process or have occurred which involves an actual or potential substantial degradation of the level of safety of the plant. 1.2 "Emergency" shall be defined consistent with the definition of Osite area emergency as set forth in NU REG 0654 as a situation in which events are in process or have occurred which involve actual or likely major failures of plant functions needed for protection of the public. 1.3 "Requesting party" shall be defined as any party to this Agreement who, upon the occurrence of an emergency at one of its nuclear generating stations, seeks emergency assistance, pursuant to this Agreement, from one or more of the parties hereto. 1.4 "Responding party" or responding parties shall be defined as any party or parties to this Agreement who are presented with a request for emergency assistance pursuant to this Agreement.

Appendix B CEP Rev 39 Page 160 of 212 ARTICLE II REQUESTS FOR EMERGENCY ASSISTANCE 2.1 In the event of an Alert at one of its nuclear generating stations, any party to this Agreement may notify any or all of the other parties that an Alert exists and that their emergency assistance may be required. 2.2 In the event of an emergency at one of its nuclear generating stations, any party to the Agreement may request emergency assistance from any or all of the other parties. 2.3 Requests for emergency assistance shall be made between and among the following party personnel:

Entergy Nuclear Palisades, L.L.C. Site Vice President

-Palisades Nuclear Plant .. DTE Energy Electric Company Site Vice President-Fermi Nuclear Plant Indiana Michigan Power Site :Vice President -Cook Nuclear Plant ARTICLE Ill EXCUSED FAILURE TO RESPOND 3.1 Failure to respond to a request for emergency assistance pursuant to this Agreement shall be excused if, in order to respond, the requested party or parties would be forced in its or their sole judgment or judgments to: 3.1.1 Violate its duties relating to the care and staffing at its own nuclear generating stations; or 3.1.2 Jeopardize the public health or safety at a location other than the location of the requesting party emergency. ARTICLE IV SCOPE OF ASSISTANCE 4.1 If requested under this Agreement, the responding party or parties will provide trained and experienced personnel to perform off-site radiation protection activities to the requesting party. All equipment intended for use by the responding personnel, except personal dosimeters and certification documents (such as certifications of Health Physics training, instrument training and dose exposure records), shall be the responsibility of the requesting party to provide. The responding party or parties may use their own equipment if agreeable to the requesting party. However, use by the responding party or parties of their own equipment shall in no way alter the duties and obligations Imposed upon the parties by this Agreement. 4.2 Emergency assistance provided by the responding party or parties shall continue until their personnel are dismissed by the requesting party, or are recalled by the responding party to support operations at its own facilities. Appendix B CEP Rev 39

Page 161 of 212 4.3 Responding party or parties' personnel exposure shall be limited to off-site radiation, and such exposure shall not exceed federal requirements as set forth in 1 OCFR20. 4.4 Wages, hours and other terms and conditions of employment applicable to loaned personnel shall be those of the party providing such personnel. 4.5 Personnel provided by responding party or parties shall, at all time during the period in which emergency assistance is being provided, continue to be employees of the responding party or parties. The responding party, and not the requesting party, shall be liable to loaned personnel for any wages, salaries, cost and expenses associated with the provision of emergency assistance. ARTICLEV REIMBURSEME!',IT FOR EMERGENCY ASSIST.ANGE RENDERED 5.1 The requesting party shall reimburse each responding party for all costs and expenses incurred by each responding party in providing emergency assistance hereunder. Such costs and expenses shall include: 5.1.1 Salaries and wages paid to loaned personnel (including supervisors) for paid time spent in the requesting party service area, and paid time for travel to and from such service area; 5.1.2 A percentage of the total of such wages and salaries, as determined by the responding party, reflecting expenses incurred for: 5.1.2.1 Compliance with Worker Compensation laws; 5.1.2.2 Payroll taxes; 5.1.2.3 Hospitalization, surgical and medical coverage; 5.1.2.4 Pensions and life insurance; 5.1.2.5 Vacation, holiday and sick pay; 5.1.2.6 Travel accident insurance; 5.1.3 Transportation to and from the requesting party service area, including the cost of travel accident insurance purchased expressly for coverage during such transportation; 5.1.4 Food and lodging; 5.1.5 Persona! expenses specifically agreed to between the requesting and responding parties; 5.1.6 Charges, at the rates internally used by the responding party, for the use of transportation equipment and other equipment requested; and 5.1. 7 Any further costs specifically agreed to between the requesting and responding parties. Appendix B CEP Rev 39 Page 162 of 212 5.2 All time sheets and work records pertaining to loaned personnel shall be maintained by the responding party. 5.3 All charges shall be paid by the requesting party to each responding party within ten (10) days after receipt of an invoice, itemized to the satisfaction of the requesting party. ARTICLE VI INDEMNIFICATION 6.1 The requesting party shall indemnify and hold harmless each responding party from and against any.and all liability for loss, damage, cost or expense which the responding party shall incur by reason of bodily injury, including death, to any person or persons, or by reason of damage to or destruction of any property, including the loss of use thereof, arising out bf or in any manner connected with the giving of emergency assistance to the . . 6.2 In the event of bodily injury, including death, to any employee of the responding party, or in the event of damage to or destruction of any property of the responding party, the requesting party shall indemnify the responding party for such loss in the following manner: 6.2.1 If such loss is covered by an insurance policy purchased by the responding party from a third party carrier, the requesting party shall make reimbursement to the extent such losses increase the responding party insurance costs; 6.2.2 If such loss is not covered by an insurance policy purchased by the responding party or exceeds such coverage, the requesting party shall make

reimbursement to the extent of the claims or benefits actually paid or the losses sustained by the responding party. ARTICLE VII MODIFICATION 7.1 At any time after the date of this Agreement any party, by giving not less than thirty days written notice to the other parties, may from time to time call for reconsideration of the terms and conditions of this Agreement.

If such reconsideration is called for, the authorized representatives of the parties shall meet as promptly as convenient and discuss any of the terms and conditions of the Agreement. No party shall be ur,der any obligation to agree to any modification or supplement not satisfactory to it. Any agreement modifying or supplementing such terms and conditions shall be in writing, signed by all parties, and shall specify the date such modification or supplement shall become effective. ARTICLE VIII PLAN EXERCISING 8.1 The parties agree to provide, at their own expense, personnel to observe or assist in demonstrating the effectiveness of a nuclear generating station emergency plan as may be required by that nuclear generating station NRC approved emergency plan. Appendix B CEP Rev 39 Page 163 of 212 ARTICLE IX TERM OF AGREEMENT 9.1 This Agreement shall continue indefinitely from the date of signing unless and until terminated as provided for in-Section 9.2 below. 9.2 Any party, upon sixty (60) days prior written notice to all other parties, may terminate this Agreement. IN WITNESS WHEREOF, the parties hereto cause this Agreement to be executed by their duly authorized officers on duplicate original pages attached hereto and made a part hereof .. ENT~cii=DES, L~~\\-1 1 Charles.Arnone Date Site Vice President -Palisades DTE ENERGY ELECTRIC COMPANY Keith~ Site Vice President -Fermi INDIANA MICHIGAN POWER 'i~2s=-17 Date l:lane Lies Date Vice President -D. C. Cook Nuclear Plant Appendix B CEP Rev 39 Institute of Nuclear Power Operations Emergency Resources Page 164 of 212 1 page INPO

Dear Ladies and Gent_lemen:

inslitu/e oi Nuclear Power Operations November 2, 2017 Suite 100 100 Galleria Parkwar_, SE Atlanta, (iA 30339-5943 770-644-8000 FAX 770-644-8549 This letter C!;lqifies that the Nuclear Power Pl{lnt Emergency Response Assistance Agreement dated November 8, 2013 remains in effect. INPO will .assist you as described in the agreeme11t and i_n revision 1 of the United States Ind.us.try Event Response -Framework A copy of the agreement and. the col!nterpart signatures can be found on the INPO integrated response member website. This agreement will remain in effect until amended or terminated in accordance with the guidance desc:ribed in paragraphs 14 and 1. 5 of the agreement. Should you have any questions, please call me at (770) 644-8882 or ~mail at Williamsdr@inpo.org DRW:qa Sincerely, JJ~/J/~ Dane *R. \Villianis Mµiager, Emergency Managament Appendix B CEP Rev 39 ,-------------------- ---FEMA ANS Design Report Letter Page 165 of 212 1 page September ll , 2017 To~yll Nob~Ctl . . . . Manag~r. Radlok>gi~al J3metgeney '.Ptepareµnesi; Unit Mkhig.'ln Stat11 Pofr;e

_ * * **
Emergency

!l.*f1magcri1cnt &. Hon¥:'lhmd Security llivision P.O. Bo:i1 30634 Lansing_. Mk;lugan 4&910*5883 Dcar'Ms. Nolmch: US, 1k JlllrlJIU!tt! uCllrtitielnrid S<<ll1ily -. . . fti-t:IUII V . S>& Srutb aa,1:-St,ett, 1>1<>:r 7 t:hioago. iillnr,i,; (,miti5 FEMA On July J 2, 201:7 DHS/Ffil.1ARegion V J'eceived fromth.e State of.Michigan, 11 pr<>puscd Ak:rt andNot1ficu!ion Systeµi (Ai"!Sj De.~ign Basis Report Rtnii.slort*i

d~ted May 1.9, 20l'/, by AEP that would amend the DC Coo~ Nuclear Power Plllnt'!:, c1dsting AN$ Dcsig1Hfasis Report. iippmvc:9 on P,..~mhcr 10, 2012. * . Afti:r t.-umplt:ling til'3 mvi.iw, DHSIFBMJ\

Region V <.-oncu1-s wllh tile proposed changes and . ap-pr_ovcsthe auicndhtents to the ~xistlng ANS Design Ba.,;is RcporUhal a~ rioted in the rcv.ision ~mnuu-y -of the ,-ep4rt. lfyou should have any questions, plctiSC call me al 312-408~5389 or contact DWnine Warren at 312-40~5342. . . . Seai1 O'Leary, Chair Rcgiorinl Assi:stanc-e Corrumtlcc Appendix B CEP Rev 39 Page 166 of 212 APPENDIX C EMERGENCY KITS AND EQUIPMENT LOCATION Appendix C CEP Rev 39 Page 167 of 212 Emergency Kits and Equipment Location KIT Radiation Protection Emergency Kit First Aid -Decon Equipment Anti-C Equipment for Ambulance In-Plant/On-Site Driver to Hospital . Emergency Anti-C Equipment

Hospital Emergency Cabinet Shift Supervisor Office Radiation Protection Emergency Locker SCBAs Stretcher Lockers LOCATION Operations Support Center (OSC) Emergency Operations Facility (EOF) Survey Vehicles (1 in each of the 2 dedicated Survey Vehicles)

Radiation Protection Access Control (RPAC) Security Control Center Vehicle Search Portal Technical Support Center (TSC). Operations Support Center Area Training Center Emergency Operations Facility (EOF) Both Control Rooms Control Room Emergency Cabinet Survey Vehicle Lakeland Regional Medical Center, St. Joseph Niles Community Hospital, Niles 633' Turbine Deck at TSC stairs 17 -Auxiliary Building 10-RPAC 1 O -Basement Assembly Area (OSC) 10 -633' Turbine Deck by TSC 2 -Each Control Room 10 -609' Turbine Bldg. (for Turbine Building use only) 1 O -Locations in Plant Appendix C CEP Rev 39 APPENDIX D EMERGENCY PREPAREDNESS BROCHURE Appendix D CEP Rev 39 Page 168 of 212 i I Applicable Portions from the Annual Emergency Information Calendar fo r Be rr ien C ounty W HA T TOO O IFY OU HE AR E M ERGENCY WA RNING SI REN S In : Berrlen County , w,,useeio~ning sirens and cellphone texts ID alertyouofaserious emergency.Sucbemergendeslndud@a , nudearacdd1>11t,chemlal , splll.se...re-herorother possftile dangerous cooditi'on i n our county. .,. Htha e nef'9111cywarnlng siren sound, far OrM t o tve mlautel, 1ln8 toa19"tale..t.l on wtian or raodlomdon l ilted In this SKtlol\. or dlec:kyou r ml !'I-or alhw wlintlHa mmrnualcllltlo* devke for-9ffl(Y mHADH-Berrien County uses a nitlonaf alert ,ind wa ming ~m to send , e m ergency me5sagestoyou .* , &ne!gency Alert S,stern (EAS)mes!ilge1 are sent lhroughTV and , radlo!lation..AllortheTV and radio st a tions l fsts:I *here a re p a rt o(the , Joc,jl Eineigency Alert Syrtem ([AS). Some oft be statlonsmayerperienceadelayingettlngemergencylnforrrationoutduetoCDmpUlerlzd progl'.imming

orllmited broadast !idledullng

,.Checkallofthe fl51led !latfonumtil ',,a u find one that is broadcasting emergency inforrnatfon.

CeU* phone1 , and <Xherwlrelm deviCl!s recelw! Wlreles1 'frnetgene:y Alerts (WfA~ lryourw!reless carrier 1)11rt1 d pates i n theW fA 1 ystemy,ouwlll 1eCeille erneigencyalerts automatlcaly

WEA messages arenotchaigedtoyourwlrelessdat2 pla,11 )I,, Hyou hu r an _,,,.-acy lh* that IHb for !Ha du** mlnulll or*** that Np8ab la IHHllan-a-inlnur.

latflYIII.,

Ill proba~ allng * ,,.,.._t,-

~lt inallt. To be sure.tune to any , radio ortele'Vlslon statkln listed here orcheckyourc:eH phoneforeme,gency messages. )I,, Hyo u noUc* t llatan HMrven<"f siren*~ dlnapd or notwotklng. ml 2119-9l6-26fl ~lat,oly. The Berrien County Emergency Ma n~g-Offi Cl!-ma1ntains , the sirens. For your protectlol\

report non-waklng , s i rens right away. Vacat l one rs and Vis ltors Hyau hea r ane,gancy alrwlS wh11tvxatlor,jng or vbltlng lntln aNNt, ...tshtlharlndoon or In yowwhlde. Tune1X> one oft h eteleYls[on or radio stations (fisted at ilg'h1J.follow all' directions glwn by parlcoffidals, !herlff an d police officers.

During a ~8Mf9111CY , do Mt :sta,yln ya,a whld& It Is not safe! Boaters and Campers Hyou hHr aM f9"'K'Y slrwu whlabaatlng. do nat wait for furtha'wamlng. Tune to the marine channel 1 6 (156.8 MH:z) orto an all!ll radio station Hsll!dto t1,e iightfor emeigency informatfon. Millrlne patrol boats wtn* also-,n boaters on Lab Midl[gan If there isa,serlousernergency. 'lbu will be told the .loration of safe waterway.; and docking areas. tryau hu r anttgancy alrwlS whlecampmg. hldng. swnnlng orvhlllng In MN pakt. follow al errwvaneylmcru::11-fron pwk'Oflc:llh. At W.r ren I DuMs and Grand Mere state park,, offidals wi ll u se the pu b Kc a d d ress system or m o bile alert unftUo let you ltnoww , hat )OU' should do. At other klal paoo,immediatl!l)I tune t o an.arearadfo st!tlon nsled at r lghlandfollowlnstruct[ons. Ap p end i x D THE SIRENS AA:E lESTED ONJTHE FIRST SATIJROAY Of THE MONTH AT 1 l'.M. All , rronth ly tests, eXCl!ptfor Aprl~ ronsist oh shprt siren mund last l ng , lesstban a mlnute . On the first Saturdayof April,wetestall ernergencywarn in9 sirens i>r three minutes at 1 , p.m , as part , of cur comprehensi'.e safety plan.At other times, )IOU may;hear l e...e!,tests also lasting 1eSl5 than a minute. Tune to on e of these radio or TV stations for emergency Information NI, WNIL*l.290 WiJM-1400 fflo!OU -NBC 1 6 'M'IOU

NBC 16.1 WNOl/-16.2 FM WNJS-9017

--95.9 ws.M-!M:.9 WYTZ-f115 'IIO',()R-95.7 WCXT-98.1 Television W59T -CBS,22 W59T

CBS 22.1 WSIJT -FOXlll WQI.Q-9911 WC5'f -101.7 W,Rl(-!07.1 WBND-ABc:57

'191D-ABC57 , 1

All calll~eJSare accurateatthetlme of print lng1.AII statfon~are on the air 24 hours. Check yoor cable or sate! lite prw l derforyou r channel lineup. FClll.DW ALL BROADCAST INSTRUCTIONS PAOMPnY. TM radio o r teJnfllo*

_,,._ wll tal you wbt actions )IOUdwdd ~.lfany. C EP Re v 39 Page 169 of 2 1 2 WHA T TO DO IF YOU ARE TOLD TO SEEK SHELTER OR STAY INDOO RS for most emeigeooes. it is s.afer ID stay mdOOB. wind l'iirt l:Jlow any tmic ix pjsooou s f1:11J1e sam dig ases aWily im a. shon time. Dui ing a seYere weather emergency. ruldin gs cffer tlile be5t protection. especially basem etTts. Whife i'ndDU5 , dothefo Ucwi ng: 1111' Ki!!e?alm. Panic.i s y our worst e n emy in any emergeocy. IJ,, Close.allw l ndows.anddoo~.indbrlngpets lns:ld'e.

Turn , ofhD .el'-'lntalresystems 51llchas rans and alrcoociitioners..

Tum down fumoce lhermo:strt. C lose fi~l ace dampers.. jl\> lfyourbulldtnghau b.uemen"ub!a radlo,mdgothere. II-Do not go OUblde to 5ee what i s h apperu ng um ii you are t ord it is sale to go out o.r are told to evacuate. If you must go ootdoors-briefly to wam so~duriin-g a nuclea r emergeocy, t:orer yo ur no 1e aitid rnolllh wiilh a p ie<le ct doth sud!, as a towel or scarf. iJi, Do not use 1he telephone or-lnternM unless. it is absolu b!ly necessary. !t's importallf to li'.eep tel'.ephone lines open f o r , emergeocyuse.

SU,OUl>of:,our , caror\'l!hlde1n.aweatfleremergency.

Seek shelt er in Ille basement of a nearby ooildi n g Of U!I a ditch until the weather emergency passes; IMPORTANT: Do not pld: up mldrm fram sdiocJkor da, QM'!! CMb!rs. Sdloofmff .and dald caregtven wtl lreep dlRclmi III Kllool ~1t h ar.i., goaurapin. fU NCTIONAL NEEDS: If you need spec:ial help in an emergency, fill out tl,,e card to the right and mall it right BW!rf, In an emagency, a peson wilha.functiooal need may iil dude illl)'Ollewitfl ..t.sion or he a lin g impairments. phy.sicil << mental disabil ities , or so-Mio has no means of iransportatm If yoo: migh t need in .n emergency, pls'.se fill out the* Functioo.a l Ne.eds ard on1fle next page and mall it in today.I t lslmpOrtant .tonotethn,oo should update-and~ i n yoor Function.al 'Needs cml eacfl Y'Nf. T he Berrien Coo;ity Health Departm~t wil l J:ee p your functional needs infoon.alioo on file for yeat'!'oorinfurmation will be ~t <confide ntial. P!e ase*fill out a new Clild a11d mail ii' in a~ soon as )'OU r e.eerie ycur new calenda.r , if needed. ff youknaw someone wrth fundional neec:lswflo .llves wl1l'tJn th~ 10-ffllle Emergency Pla nning Zone , [Seepage t6L pleasevolun~ tD h@lp diem In an em~. If this is not practical or possible, ple.ase discus.s an d/or assist ttlem im filling oot this emergency Glfd_ Appendix D .2.018 FU NCTIONA l NEEDS CARD BUSINESS REPLY MAIL FlHT-CUSUl,1,11. FE RiliT N0-1 Q ~DC-<<11 ,I U II l'(lgn\B E \ITU &El'.r.D lo Y AOOnE:l!EE O JVtsCON OF B ERR I EN COUNTY Stt:ERJ.Ff'S OfFJCE BERR!EJl , COUITTY EMERGE!l(CY IA1'4AGl:MENT 2100 E EMPIRE AVE BEN T ON HAR B OR Ml 49ll22-!l69'5 1111m*1*1 11 111 f i h11*11*1*11 1*1 .. *11*11*Plllll1l*1rl1111 1** If you h ave funrtlo n a I needs , fm out the , o,ther s ~de o f t h I s ca rc:i. Cut tibl , s tard out, fo l d and seal It , then p uU t Into the mall. CEP Rev 39 Page 170 of 212 WHAT TO DO IFYOU ARE TOLD TO EVA CUA TE Cook Nuclear Publk l nquiry Line: 866-362-3105 "" Ustm to the radio orte1e.¥153on tsee page 15J for lnmuctlons. They will give )ll>U ea.-acuation routes and directions to open receptio.n , centers. Ito Go dlrec:tl7 toil recepi1on , c-enter and! reglstel'. Folkl'Nthe broadcasted evacua!ioo route instructions to*the near,est open r.ec:eption center. Ple;ise registetr when *yoo amve so Jamily and friends wil'I :l:J1owwhefe you .are. Afte-)Oil have. registered yoo ma,y go to stay with friemdsor family woo live oot5ide the dang.er afl!il. Or, itF youi p;refef.. )'OU wil l beassigmedl lo a safe , l'!l'a r by gathemg place. .,.. Stay cillm, You and otflers wi:th you shoo'ld have lime to g!!t read)' to !leave S3fely. .,.. Taite onlJ*essentla1 items. Packasif )'OIII weregoingonatripforon l yafewda)'S. U'se. the list below as a guide. ... Do nm take fireanm,. alrobolk beftrages or 1D egal drugs. .. lfyouh.wefunction.ilneeds .andlmre:sentl na posttanf.you

wi ll r~ r:u!cessary

.ass.titance. If :,ou need help , ili sten ID a, focaHVo r ra<flO :st.mo n (See page 15) fOf the telephone, numberyou

can call .,.. Have-a plan for :,our pets. C u i:mntly , r eception centl!JS will onJy accept pets if they are sesvice .a llimats. Make arrangements to stay with relatives, friends or at a pet-ml!fllily hotel ootside of the area. Bring an em!!fgency pet kit (see the ched list bebw). For more iinformati<Hl\

go ID ready.govlcruing-anima/J , PrtfrowLcom and .Jlet.sWeJa:imerom. "" Turn off smal appliances. fights and Willer faucets. Howl!'i,er, l l!i!Vl! y our refrigera tor .a nd f r: e.ezer m. ... Tur n , off art ~r-lntalce .s:,stems .ll!lch as tan.sand ai:r ronditiooiBg. Turn cfOlln f u moce dlermos.rat. Close liir:e.placedampers. ... Close and lock.allwtndows andi doofs. The evac.uatedl area w;rJ be securad and you wi1l not be a Hawed to r eturn until it is safe. "" Cbeclc., onnelgbbo~Makesurelru!ylinowhowtoevacuateandlhatt~have transportati!m. IIIPORTAHT:J)o nat pldtup JOUI' chldrenftmn Kboalsor chld care mnhft. lfnec:e515ilfJ, tlleJwll bet.Mell toshelms oufsidethe da'9f zm,e. Ll5tl!n for dlll!CtionsOII TY or radloflllliom (see !Mge Hh boutWMft*illidwhen they can be pldledup. Do IIOtWOi"1 lf,ouwfa11111J

menibe!;5 , a'l!ln a hospiiaJ o,rotber speclilkare faclltt:y , ;is tbef also haveeffll!!l'gfflq procedur1!5.

Appendix D ' 2018 FUNCTIONAL NEE:DS fNFORMATION lt)OOhml'maimalD!Ms , pl~fillin , t bis m ,, b l d , s e;af ih!it h , tJpe.;md*m;ilt:odil'j f Yoo mn li!fl<I in a am sad! )l!'i!I ro l:fep oor f!IB~-.tn-Di!IE. l'ilill!: IHhlR are !j!<<i.l cfl!Nti:>M to )'-"tlf ~. p,me Clllltad Belli!n fnun l)' Emeigency Management al 2-6~ 1111, Ell 49 15. ZP: &'ftllAlllPUT*DIIEIBIIIUIJ,PlElSl:<IfflJilllll)tmlS'IOISTBDIIHlllftfl .{Olffl: m w n n E m 'l'MllfllfKTIDIUUIHD (ORGHIL TlllllPPLn: 'NHEB.IBl!t l!E D!JI OO,i ml.ff: _________ _ TIIIISNlllllOII IIIJOUIIIIOII: Page 171 of 212 ~d L a filmi l 1 roonbff or me!irl giJe Jl!U transpO!lat i: m, if you Wlfl! asked I D emmte

a emergecncy

!' YIS __ NO __ ,n IIIOIIIIIIOII: Doyouh.mpm.t~tmtwnuldll<t

~nti."tlif J Ot.1wereasll!d1D
l.'r..:mteinan
i:m;,rgl!Q(f J -If~. roilatt~number , ot lll1li lUOOBll: Ifill] OM.511 * ~KE 111.J\TIIJII.III. CEP Rev 39 L What to Bring With You C Bastes: this ca lend at c..uh, pottible radio. flashlicjlt extra bffleries.

keys, tool kit credit/debit cards. chedcbook. wal@, purse C Bedding: blanken. pin~ sleeping bag:s C Totletrtes: soap. towels, toothpaste. toothbrusht!$, ramn. s:aniUry supp[ies C Sp<<lll lhnls: speciakiiet f~ baby fonnula and bo~ di~, favorite toys°' games C HHlth su119*es: medicines. glasses , dentures. heamg aids, first aid kit. jlfescriplion infunnaoon C ldenttfiaaon: driver's lice nse, credit c.a:rds. importam papen C Pet su119*es: f ood. water; medicines. le;uhes. tags ONCE YOU AREINYOUAVEHICLE

Drift~. There IS no need ID speed. Fdlow directions or all sheritl police .net iTaffic officers.
Close~ wtndoal and ftlltS. Shut of:f and air cordtioning.
Ustmtolhe~(sH.,.15).Follow emergeocy instructJons broadcast on rourcaror pomble mo. You wil l be told when it is safe to return. Reception Center locations The locations d the fwr reception centers are listed below. Lil.ten to an area radioorTVstJ!ion (see page 151 to learn which reception centers a.re open. ~MIGHKHOOL 1700 W lluct Nies l5oudi ol181sA &st*ol >>-51) CIILOIU MIGHSOIOOL JOOW. St. jcxoeplt s..-. c--(led An-Migi..,I NEW IIS'FALOHIGH SCNOOL I I 12 £. 0., Snet. ._ lliftalo (5oulh ol ~12t 16 Appendix D Cook Nuclear Plant Emergency Planning Zone The circled aiH in !he map is a 1 o-mile radius surrol.nding Cook t .Jdea r Plant in Bridgman known as the Eme<gency Planning Zone (EPZJ. The early-w.mmig siren system for Beme-n County i:s within the EPZ. When nece.1sary , arN 1V and r.tdio mtions (-page 15) will. alert people l iving iruiide the EPZ when the r e i~ an emergency.

Inside the EPZ are the ProCecti11e Action Area.s for the Cook Nucleilr Pli!nL During an emergency , these aren will be identified by the numbers shown in the rNp. f.or enmple. the TV orradio sl.ltion may say, 'Protective Action Area 1 mustevacuate:ot

~otecti11e Action Alea2 m1m. t1ke s.helter:KnowwhichProtective Actionhe,i

)'OU lr,e, work or arP boating in so you can respond Pfallptly to instructions. During .i emergency, isten to are.11 lV or radio sta ions <1nd follow the offici al e¥acu a rion instructions to the re<:e ption a!Oter you aR' to we. ' ,r .;-.-..... __ --] CEP Rev 39 Page 172 of 212 IMPORTAN T NUCLEAR EMERGENCY TERMS AND RADIATION FACTS Nuclear !Emergency Terms. 11n ttie uniffl;-efr;' elll: nt llilat lhe'le is .. an emergency.a t the Cook. Nudear Plant, foor tenru will be us~ todescribe each sitluatioo _ Thosefourterms are explained below. lheyare listed iJII ordernf least serious f l) to most serioos {4). Because af lhl!' many s:afeguards and highly sli:illed people operating tM{ook. Nudea,: llt\mt,.it is very u nli fa!lytha t .a seriouseventwi'II ever OCC1Jr tflen!,.Chanc:esofyoo haYing 1n seek she,lteror evaa:ra t e becalase ofa nudear , emffQency are rery rer:oot.e. In most casE!!, *l!'tacuation ~ordead as a safety measure before any danger can~ to )'OIi or )'O'lllf f.imi!)'. Federal law. however , requir , es that fue. public be iokl ~t todo in case-of a significant releilise cti radioactive-materialfrcrn the Coak Nude a r Plant.:Pfease keepthii E mergency lnfmmalion Calendar handy: and become[amilianvith incootents. 'Sometimes )'O U wiU hear new:t aboota dliD or .an exerme irwolving ~C~Hudear J!fant Tha t is because fedenl, C019Y and pbn t officials are re<JJired by law ro pamcipate regul'art,, in drills .and exercises so they .ire pcepared in ase af a.n emergency. Recmember, you will hNr earfy-wamlng sirens if shelter or evaruation is necesgry. See page 15. lflhe sirens sound. rtstm ro.an araalVor radio-station for emergency i r:ifom1aoo11 t see fut on page i S) andfollow instructions. U.INUSUAI. EVENT: a m i nOf problem at the-Godk Nuclea. Plant !hat varies from OOIIJlalor rootme operations. No re lea.le dradioadi'o1e materia l is expected. Cook Pllmt offici als wi lf notify federal state and , coonfy <ffioials. You will not have , to clo.anythi119.

2. ALERT: ilJl abnorma l plant CIJf'ldition 1mt cowl iesl!llt in a small release of rac:limdivl!

material inside-IN!" plaml This is stilll considereda miflDf e"6li. Cook Plant offitiars willi ootifyfedent state and county officiads. to stand by. Jt is not'lilcel)' that )'OU will have toi do anything.

3. .SITE AREA EMEIIGEJliCY~

a more serious sitwbO!l iflat CDtJlct result in a release cf radioactiire material around the plant site.. All feclera P,.rtate.andoount)' ctfficiafs wiD I be ,eacfy to help it needed Protediw me.aSUfl!S ll\3Y be required to ensure the sat:ely of the public in .a limited area near the pl.id. site-boundary. If so, lhe sirens may sound Time in imm,ediatelyto an a~a TV Of radio station 1 see page 15) to learn wlhetberyou will need to seek shelter or ewcuate. Appendix D 4. *GENERAL EMERGUICY: the most senoos siru a ti<m possible at tlrie Cool; ti!Jcfeair Plant tt coolct result in 'tfue re lease ct .i la:rg e amount of 1acf1Xli!dli'e m3terial ool:siide the pin boondary. All federal , rute and coo11t:, offrills will provide l'le1p as needed. Protl!ClM! measures may be required to enwre ttie safely of the-public.as tar a.s 1 0 mires from lf1e plant The silen:s l'lill sound arn:!'you willl be tdd by a:rea TV <ind radiQ stations (See page 1 S) if sheher Dri;vacualion i snecessall)'. TWO-OTHER KEYTEJ!l:MS: RAD.IAHOtl AINDCONTAMtNlmON II> Radtltlon refer.s to the pa rtid es and wa*,oe,s given , off by radioactive ma te r ial. It .is: a form oli enef'Q il' that oooirs na l urallit and .artif:K:ial:ty .*We aree:i:posedl to [t ew.ry d;J/1'. Howe-{ff. radiation could be h armful to )l'Olllr flea[th :ancf safety* if the l;e,,re ls are higl\ enough .a:nd the exposure lasts long emough. ... Contamination is when rao:ioadive ma t erial is where it~ not supposed to be. fuod.. water or air is consid~ ,cooraminate.d if it coma ins more or 'Cliffi!rellt types ofracftaacti*re material lhan woo:id be oomially P're!.el'lt.Our !bodies, for example, contain wry* 51111aJ l .imounts of Ifie r.ad"10actiilre elem!!tlls potassi u m-40. cam,Ql;J-J.4 and tritium. We are not considered t o be conramin.ated because lhei;e, , elEf!lents. exist within m natur:al(y. However , tlhe !ffi!Senc.e of :Strooli m-ro (a po~sible bproduct of a nudearpower pt.a nt emergemcYj i n fuoo. air or water can 'indicate conumination. Facts About Radlatl on RADIATION ISANAlURALiFACTOF l.!IFE RadialKlfl is.afurmof enNg:, like*light.ms u nshime. Theireiis radiationa Ti a10tJ;Jdt1 s..We. ate exposed to small amotJnts of radioactive mal'e!iiils evEf)' mornent cf our~ HOWWEMEAS UR.f.RAD IATlON 'l'ou cannot :see , tls1e, hear oc smell ionizin g l'ildiat.ioJL Bert we can m easure it *A~ specia l instrmlents. We use a u111 it ol!l!'d a mi'llirem (mRf:m) to mea sure~ radialion. On average, a pe-rson living in the U.S. i:eceives aflou

620 mRern per yea:r from a ll radiation snm:es. A person liv ing witflm 1 0 miles a the Cook. Nude-M Plan I rece'ives about'485 mRem because we l ive a.ti bN *elev..li on that is 111ot neiacr an y radioactive rod fomlatian:s , About l 10 mRem of the total we 1ecei~-e comes from ma1n-r;11ade-s:o..r=~

primaril'j medical testing. Cmly a tiw/ fm:oom of a11e percent of lhe rnan,rn.d!! radia!ioo 1'11:N!lld

come from llile< Cook Plant. CEP Rev 39 Page 173 of 212 NATUIIAlWICKGROIJNDR'.ADIATIOM IS I N T HEAIRWESREATHE The sun coven our planet with oosmic racfiation.

Some rocks and mi~ QM! cdr smill a1110t1nts of radiation. One s:oorce ;IOU 111,1)' befammar with is radon gas. Many buildmg. mall!'.rials contain radiation. In fact radioactive particll!'s .re i n the ;ur we braa~ food we e.atand the w.aterwedrink. E...en Olli' bodies,are slightly ra~. Thes-.e* sources of r adialion are ca.lied natur.a l badigroond radratiOfl. WE MA1<£ ANO USE R'.ADIOACTIV , E SO U Rra EVERY DAY l!esides naru~ ocairring. radiatiion , thl!fe is. aloo artificial {tl\3n-madf!t racfJation. Radicxactive mamrials are med in medkal and denta l X-raY!.-'lhey are used to h~p diagOOSE and treat diseases such as cancer: Science and incfustry use rad"IOilctive mall:.rials ror researoh and to do su:h things 3:S X,;n, welds. Other sources r:J radioactive rnall!'lials are color TV!;. smoke detectM. some luminous.-cfral watches <1nddocks. Vert smal l amocmts d radialioo mme from generating ,electricitywilh nudearpower. Types. of Radla ll on Radiation i ocll.ldes such thirlgs-as light. heat and radio W3V1!S. However:. when we speak d. radiatioo weusu.i[Jy mean "ioniziDg" racfiation ."fNs radialioci an produce highenl!fgy. charged partid!!s called1ans" in th,e materials it strikM. THE~ TYPESOFIONIZJKGIIADIAilONARE:

Alpba pa rticles , 1A'IDChcanbe-stopped bt a sheet of paper:
Beta partide5, wli!:h ran be rtopped tr, a thin ~etof metal..
Gamma rays. whkh .an be stopped almart completely by tnree [eet of a:naete.
tieutron particl~ which can be stopped by water. mncrete and mm l 17 Appendix D Effects , of RadlatJon Just as too much exposure to Ifie suo ca:n cause pail:IFUI sunburn. 1Do much ex;po:sure to certain leve ls and , types of radiatio n can ha,oe-ha rmful effects. You wou ld, hem ever; have 1o be exposed to radiation~

a\'er 20,000 mRem vmni n a day to produce, effects meJS"urable b;va trained:doctor. Very larg e dosl!'.I of 5 Q.(OO to 1 00,ooorniR>arnaie ll!qUirEd befo..-e :,,xi woolii feel arl)' ill effects. The amount of exposure from radi a!ion depends on:

lerr,J!h cftimeyou .ue eqi,osed
How faryou = frooi lheSlOOn:e ofradiatim
Whidt part of)'OO( body is exposed. '
How much material )'00 inhale or tlke inl o )'OOrboof.

Your heifth orphy.sia! cooditioo .can .affect your reaction to radratioo expo<.:ure. For exa.mple , shcold be awa:rl' thatuobom b.Jbtesand very young m!ldren are more l*ilytobe harmed by racbtloo exposure. The less r.diatioo you are exposed tQ, the-less cha.oce you hal*e al rece iving any rurmful efracts. That iswh)* it is so impo rtant to h~.ve an emergency plat1 in pl:llCE near a n udea r power plant We need to treat rad iation with ootb GWtiort and commo n sense. Cm.Hudear Plant workers reg r Jl a.11,y check radialion levashoth [ris ide aoo oom:ie the plant I n lhe ur:ilike-)v event cf.a serious. nuclear :accident a l the pt.. t,;state amllfedera. 1 health experts "Mltlld be c:a!IE<f m to takP radi3 ti on readings beyo nd fl>.!!. pl21il t ~e boindary. These rea<fmg s would det.ermime wha steps. if any , you , )'Oll r family and ,r;woders woutd need to take t o pr otect yo u rsell!E!.. State ofM i chlgan Potassium Iodide D strlbutlon Radioactive-iodineo cradioiodine)ts one c,f the prafocts that col.id be rele.ased in the unftkezy event ofa serious nuch!a! pcw!!r pla11 t ao:idf!nt Potass i um iodide t Kl l is. a radioactive form ofiod i!M! thal maybetalc:.en to redoce 1:1,e a moun of radioac tive iodine ~bso!bed bytheo body's thyroid gl and. Kl offer:s protection o nly to th.e t!hy.r.c.'ii gl a.oo and its ~woofd be to su,ppl ement e'latuation and in-place melll!;ring. E\oac wtion and iplace .shettering are thi! primary mea!ls of prot-ection in a radiologica l emergency. StatE and co1Ety officials will use tile Emergency Ak;rt System till) *o II012!y ti:11! pubrx:: ri the need to evacua~ to seek.sflelter i n place, orto tlke Kl. 'KJ is a,'2 il able to persons l\tthm 10 miles of Cook. Nudi!ar Plant thrOll,llil the MichrJan Department of H ealth and Human SeroMES (MDHH5~ Dmlle.d Instructions on the MDHHS dlstrlbu:tlon of Kl can be foondon p;igie , 19 oflh~calend~r or www.mlc:hlgan.gcwml. It is nec~s:a ry* to pic1 yoor Kl prior to an emerg,encymuatio l\ at t he pla nt. Com plete )'DUI \-olrller aod pick U!}YoUr IO' at a participa tin g j!Xlamlac) ' at ~'O li ff ea iii est CCf1*,1enience. You win NOT be able to gl!t Kl from lhe pharmacy .dlm.ng ii nudRr plant emergency. People who a.re-a ll'ergic to iodi ne should Ml~ IO. ln the eorent d an a llergic r eaction , contact a doctor. CEP Rev 39 Page 174 of 212 I I I I I I I I I I I NOTICE TO FARMERS, FOOD PROCESSORS AND msTRIBUTORS HOWYOUWIL L BE.NOl'lFIEDINAHUClEARfMERGEKCY The Sta t e a* Michigan wlll evalua~ the serious,ness cl a nudear accident l twil order action s ID protect the publk .md the food sappfy.

If you llvewlthln 1omlleso(theCookNoclsrPlam , yaurmtwaming may be the soundin,g d emergeocy sirens.. If you he a r a siren for three to fi'R minu tes, tune to a radio orlV sta tion f isted on page 15 for emergency rmormatrcn.

.. If you !Mhrther tha 10 mllesfrom the plant )'OU will be notified by area rad lio and TV s.titions {'see page 1 S]. The nev.rs repat will let you le.now ifyoo need to take* p rot ective action. or a Cooperative Extension Service official vwll .conbct you. Pleasefdllow the e~ncy inst ru ctio ns right awa y. .. If you b.rve questlOm about a rsl or potl!flt~I emergency, please contact the M ichi ga n Department of Agriculture and Rural O!!'o'elopment a eoo-2g2.39 3 9_ Aft.el' ooun. call 517*.3H-0440. WHAT TO 00 JF YOU ARE TOLD TO SEEX SHEUEA Du m11g a nutilear emergency , it is Vl!fY im portan t to limit Your owloor adMties as mlrlt as poss:ilile. Piease stay indoors .a nd follow the inS1ructions provided in racftoand 1V messages [see page 1 5). WHAT TO DO I F YOU ARE OllDERED TO EVACUAl'HOUR FARM If )'OUM withm 1 o mi les cl the Cook Nudear Ptanl. yo u may be told to evaaia te. 'l'ou miFf be permrtted, witf1 direc.1ions frorn the state, to reenll!r Ifi e eVilCWted ar:ea temporarily to tend to Ifie lil!eds ofYoUrf.mn. Yoo " ill r eceiYe im m rdions Of.I .what routes t o us e. s afety prEGutions and decootamination procedures.. '(our Cooperative .~ion Service aqentc.an provide ari ma l he.11th .and t eeomg guidelines. HOW CAM A NUClEAR EMERGENCY COt.TAMINATE fOOOl Du ring a nudear emageocy , dusHized; , adioacti'r'e materials QR tail ont.o fruits. 1/e9ft'ilbles or grains; This food coufd enterlhe-food .and be eaten by the public. For example; Cowscould ea t grass ro'll!'fed wilh ra<flOiictive iodine--131. Traces of the iodine could be i:wsedlthroogh to the milk and lhento people who drin\it lodine-131 has the potentia l , ID cona mtrate in the human th)'T oid9la111 d whe~ it cnuld cause tll,>roid cancer_ Appendix D PROTECTING THE FOOD SUP:Pl Y D UR ING A NUC L E AR'. E ME RGEN CY Fo11owin g* a nudearemergency, the !)lablic could be exposed to radi:Oild:ive matecial in several ways. At lim, and gases rele a sed i nto

air c,ould be ingested or mh!led direct!)'. Mditiooal exrxisure cotid result from ea ii ng or drinki ng food or mill <Dntlminated bf ITilc:es rJ rad"IO.acti'le ma IE-rial. farmers. food processors an d disttiootors will be required to lal(e steps to pro tect the foo:! supply. EYE{)' step will be taken to minimize or al/O idic ont!m ination. Pleil<Se read thi s paqe* a F1dthe na 1.to learn howtoprotect

~food ~plyin;tfu e ,eve nt dia nucl eooem.erge ncy. S A MPLES WlU BE C-OU:ECTID TO O ETEll MIHE PROTE CTIVE A CTfON ln 1'1e e\leliltof an accidenta l rel.ease of radimctivemateri31.,Stat.eofM.imigan emergency worke'ls "Ylill d etemune what ptotectiNe steps )'OU wi ll n eed to~ Emergeocy workers wil l coflect rnnple.;of a:i~ w-.ter and SO(lto seewhetherthere is radioactive wntamiflatioo. whe r e , it is ootl!d .and the a m!Ml t. 5.lmptes cl mi lk. foraqe , crops and proa!ssed f ood s also may be taken. Fie ld dara and ctfierf.actor; w il!'be used by~ state todetEmlinethe best ro urs e of aai,:m to praect !he p ublic and th efocd wpply. Samples ma be taken from as.far a1~ as so m il es f rom he plant siCe. SOte of Michigan emergencyworkers ~Nill give fo~rs_ food proc.essoo and distributors outs i de of the l o-mil e radius of the Coo k Nude Plan specific mstructions oo haw to cdBeci and test :samples. SAMPlES ARE BE! G T.ftlKEN N.QW TO G IVE U S :A MSEUH:E P.adioac.tive materialls ocaJr na nurally i n the e nvironme nt. So r noia na M idiiga:n Power and Sla te of Michig ildl emer ge ncy wort.er~ con tinual fy tlke samples of the ai r, wata-, mill:.. 'o'eQetlOOII iilld animal l'ifenea r the Coo k. N ocileai: P la~t This g ives them a " na lo ra r baseli11e ro r comparisCll in Ifi e event of a nuclea r emerg ency: HOW TO PROTECT YOUR WATER SUPPLY I N JI. u acAA EM6RGEiN CY 51D re a smuchwa.terasyco C!n foryoor l ivestock Co11e1ope11vrell,. tanksillldcther .storage coo~ Oase off the intakes from con tam in~&I poods. sm;:miscf' cistem t I n ger:ieral , wa er from wells a:n,d water hE)iltel"S should safe tu use. P.adioactro'e ccntaminants deposited on the , groa.id asua ll ywitt travel ve ry dowly into lfle soil H cootaminarrts fall ooto the surface dl a lr.!3 and! ri'..ers, the rad iooci:ile materials m a y get intolhe groundwater s upp lies. l ttalce.s j ustai fe'w hrurs fulr strelms and lakes locarry he CDflbmi nants m a ny mk CEP Rev 39 Page 175 of 212 HOW TO !PROTECT VOUA UVESTOCK OR POUi.TRY , IN A NUClEAA EMElRGiENCY Tue first priority is to proh!c:tdairy animak because radioactive materia ls can quil::kh' enter the foodl ch.i.111 through m il k an::11 ome,.r dairy products. If sheltering is required , shelte r 'OUI' da1I)' anim.alsfi& Shefter IM!stook m awered bams << sheds 111less the wealhl!il' i's exlll!:mefy hot or other factDGmab! sheltering impos!iofe . .Ptovide yoor.an im a ts with sn>t-e,d Eeed such as hay , si lage and bagged grain. v.,ier,e...e r pos~:ible, draw wall!f &Ir :,our animals iR:im .a weff. Avoid using water from ponds , ffi'e[> ilJld oreeli:s. This wJI hel p to m ini mize the amoo111 t ct radioactive-materia l ingested by :,oor a nimals. Po ultry are more resistan t to radioactiYe cootamiaaiioo tha111 atherfarm.animats. Keep tftem in yourendos.ed racility an d contiMI!! to gi\le them slDredlfeed and w,;l'J water. If yoor poultf)' a r:e normally kept outdoors; bring them inside if possible. EggshreH's provide natural protection from conlamination. Genera[b<; \lli'II be-safe lo*eat after !he sheik are washed ID rem~ st1ri.ace caitamina!ion. IMPORTMff: Do notife5truy amu~ dapi.*mltarleed supplies unless dlrecb!d bf ilutllclrtfles.to do so.

DO NOT DESH!OY YOUR' ANIMALS Destrov:youranim<Lls only if )'OU get orders from stile orfederal'authoribes. liJo not slaughrer any animal's for immediate food needs. Generally , anim a ls that a~ exp05E!d to 0010active cootlmin a nts and radioactive rainwater will 5.\IIViY!!.

Milll'f wil l lb!! marb!lableand safe for hum ans to eat. However , do oot ..now animals to,gra~e in open lield~ unlels Stile of Midiigan , your(ooper .a ii'te Extem ion .ServiCI! a,ge111t or anotherg!M!rnment officia l gives you pamissicn WHATlO DO IF FEED 5 RADJOACTIIIELY CONTAMINAJ'ED Qnfv in extreme emergencies ma:, :,oofeed your live srockcnntaminated

grain or hay. Ir }'OU m u st use the amt am ina~l feed , you mart ooable to reduce~ 1-i of mntam ina lion. For example*, if tlie feed is stored Oll!:Side, the contamination m a:, be gll!iter at<< near the surface ofihe feed pifec You may be.ablie to reduce the CIK1tami na lion *11!'1-el s:ig,,liflcantfy brf removing the top portion. Do not dispose of coorami na ted feed or hi3)' 1 1.11[es5 spoilage-has made it i!M!d ib te. GerM!r.llfy, contaminated prod1.1rn ma)' be, salvage a life after:adeqtate time passes and lfley are~ ~:seci Please li:eep contaminated feed Sl.lJ)plie.i.

separate frcni dherteedsothecontaminalicndoesnotspread.'t'ourC~E.x.tensiooServic.e agent c.an provide yoo ll'mil specific i nfoonation. 18 Appendix D WHO , PAYS FOR: LOST OR DESTROYED FARM POODIJCTS 1 Fa11111ers; , food processors md o:istributan c.ould race seriow.fi:naooa l lo= fal l owifMJ a nuclea.r emergency: Unde r federal law , youwtll lbe rEimbursed tor arr,, oft~e rosse.s. The Price-Ander5on Act. enacli!d er, Congress in *1957 , ~ires the operators of nudear power plants.and certain other nudleariaciliiie.s to pwdilase midear liability iiru urance policies fo~the p rntl!c:.tion of lfleptJblk:. As.a.result. oo-faultins1Jra11c:e pods are in pl.ice to pay daims. prom plty without length)' COtJrt hearings. O'aim ants lll!!ed oo~ prove that the injury or property dilm ag e resulted from lhe nuoor emei,gemcy. Commen:ial insurance policies exclude awerage for nuclear emergencies becaU5e .1\nderson lv::t makes cmoerage Uflfl ece-ssary. WHIU TO !JO WITH fOOO .AND PRODUCTS COfflAMJNAlED 1H A NU<llAR EMERGENCY Crops in die field let your st.md'mg crop~ 91Ž' to ma~urity. The 1,eve;J c( radialion l!Xpmure-they w ill receil'e* moofdl not affect theirgrowth. Mort ro:ntamma.nb wilt be washed aff in the rain. Or. '0\11.'r lime.. 1he*orcps Vi\ill retur n lo safe levels as they grow. I f special h nve.sling procedures are required, your Cooper:ati\e Exteruion Service agent mll g.wyou instructions. .lloob aad*babers Potatoe5,. carrots an d plants !!hat m a ll.Jre under llile grou nd ,gEfle.ra ll y a re sa f e to eax. Make sur.e to thor ol.l.Jlify wash and peel these prodtJCts , to remO!Je soi l pattide.s and mntaminafn. ........ w,egetal,les inth iefie ldl Unprotected plants may ha11e partidf'..s o<radioacthoe comminaliOl!I on fu1!ir smface1. Before eamig.tbem , w.is h thDIO!!J9hly.lhen brush, scru b ,or peel w., outer layers. Some leafy vegetmles may be eaten after'j'OU rema*,e Ifie c>.JW layers. .If )'CU' crops oo not need lo be harvestt>d immedi3tely , l eve them i n tihe i'ield or oo Ille *IJeei. lhey should Ire able to be harvl!S'tedionce )'OI.Jr .area is. declared safe again; You may klse SOOll! ripe fruilS a,n,d Yl!getables to spoilage.. Cootamination le.--els in yoor .a ng may be toohigl:i.forfieltlwom.ers to ha 1Yest*yo r Jc cmpina .timEfy m a nner. Thu l\\iU be IBimborsed for crop tosses.. Hooey and apiary pntducu Following a, nuclea r emergemcy, State of Midiigan emer~cy worl,;e r s w ill need to t.l.!! samples aad a~ hon ey and i.eaiives rn llh.e Proteclrre -Action llraas. font.ct your Goqperam*e Extension Service agm for; guidance. CEP Rev 39 Page 176 of 212 NOTICE.TO FARMERS, FOOD PROCESSORS AND DISTRIBUTORS CO.NnNUED IMPORTANT: Do not<ClestJooJ my Mlnlak. a:aps.:mlkor sppplll!5 unleB di<<tl!d!JJ autlla!rttk5 to lfo so. . Farm_prodm:b If rad ioactive particles a; material! are p resent in '3rgeamounts. )'Oil may be adlrised not to use,, eat or se<< garden prodoce or a.n.imal products unti l samples are t.aken and aralyzed State cl Micihig311 emerg,encywcrt.er:s will! conduct the sample tests and aru:lysis:. Please fdJJowtheir O(ders t o protect me p<tiirx: 's a.lid roor ~-Mi* M ilkcoota mmailed at ICJW IEvEl's cl: iodine-ll 1 ITid)' be c.onwrted to poNden!d milk or cheese. Then i tv.iill be.stored 1 mti! lhe iodin e\ r.acf~tydiminishes to sal!i! IP\ll!ls. It mayalsa be used in:animalfeed w;1c1;r,. and plants After a nlJCile.ar emergency, wild game ~uch as dee r, rab bit.5(Jtliael. pheasant and partridge may st food :and water cootamiAared with r adioadive partides ,.SGII! d Michigan emergency work:er:s may advise Yllll oot to eat wifd game until it-!11as been sampledland assessed , to be safe. Wild ecfrb'le , plan ts, such :as. natiYeb&bs, mushroom~ dandelion greens.. spearm.iM, ~nnint O(win,tergreen mav have particles cit COf'ltaminalion on ifleirsurface,s, too. Sef<<e eating. be* rure to wa sh, brush,. saub Of peEI to m:inimize cnnbmination. HOW SOON. WlLL TRE RADIOACTIVITY REACH SAFElEVELS7 The speed itla.t radioacti'ltty diminishes depends oo se...eral things. Inert gases refeased from a nudearpowe<r plan t kmi the<ir rad'ioactivity within mi nute-s. \/Md or heavY iair;i tend to remove ra.cftooctive material lrom pbnts lll!f)' quidly. In some cases, hawe'l'er, a ha.rd rain attar a nucleari!'mergenq llllo)' splash rontmlillall!d soil onto plant surfaces , This will increase lhe amount of radioactiw material on low-starxliag plants. WlfAT STEPS CAM BE.TA.KEN TO REST.ORE COHTAMINATEO 50CLS1 There .ue.ieVeral steps th.it can be lllltl!ll to res'tore soos oontammated in a nudear emergency. One is oot to use the soi l for a period of time. !n a woot-a.se situation. hean)' cootrminatl!d soil ma y need robe rMl!M!dJ and sentto an appt!)Yl!d radioadi111: waste di~! facilil:,. 5rJch drastic action mar not. be possible tor latge"!'ie.ldt but may be used for small plots or are,.as such as walkways ne ar buildings whet"e people come in dosecon ta dwnltiit Appendix D ------**-----* In 18s se'tl!re s.ittations.. libercrops m a r be planted inst.!ad i offruitt and V2getablM. ~owing m.lfbe used to Jr.!~ fue ra dioa ai.Ye coottminan ts ibe[ow tlhe rootzonoe* until theradioadiveydecar,sto safe le\oel.s O'l'er time. liming maw aloo be used t o limit the.absorption d .specific radioactive elemeots by crops. Farmers "'511 receiw* guidarice tmm the U nit ed St.ates Dep:a!lmel1lt of Agocul:ture

s Natural Resowces: Conservatiro Service on how to re-store va:'lt.iable SOJl. ID productiiloe use. wmr S"HOULD FOOD PROCESSORS ANO DISTAlBtITOAS 00 1H A Nll<l.!EAR EMHI.G;l:NCY7 After :a 11uc~aremerge11cy.

IJIIM!ffimffit officials ma:, restr i ct the m(uementof contaminated food prodoctrnrwiThhold them tram the ma rketpla ce. These products shooldnotbe released until ttiey arce coosidered safe for oons,Jmptioo a; a decision is made*to dispose of them. Sta t e o r Mic:h iga m em~encyw:irli:e~

wlJ I i r:is t ruct )'O U on how to safely haoole an dl dispose of coo ta mmated food pr odl!\ct:s.

The environmental damage c aused by a 11uclea r re action ma.y be .~'hat-liv ed. S teps can be laien to m a lte a ful l recarer1-For more Information, contact: MSIHIERRIEKCOONTYCOOPERATIYE ElCTffiSION ~IMCE 269-944-'41.2.6 1 7371-uRanda'le .R: oad Bentoo Harbor, Ml 49022 hrtp-//mme.anr.snru.edufcounty /i nfo l B-erriBJ If you haw qu~stlons about a real or potential eme9ncy, you may also contact the, Mlchlga n Department of Agrtcultura , and Rural Development: .MICHIGAN IXPIUI.TMENTOo AGIIIClJUUl!E AND IIURAI. DEVEIDPMEKr B00-292-3939 1vwwmichigan.gov f mda!dl CEP Rev 39 Page 177 of 212 Potassium fodide (Kl) Fads ,P_, lod!<lalK!Jllo .......... ftQ <<itl Ii> Pl!*~** ........ . 1 0!llt*i!i-CODicNu!iler~iin -*Ul)lir,aiy~,:' ... -h Pllrlt. 'lllit!np IQ wlb lwlp p,,aqty,,ur ~ldirom --........,_ ID(lna. 'II<>"""""' IC)~ p1eaa .-111e 'l n l'orlllrian in llwre>alandir, i;,arnplell U.,~and'*ltll;I-G I~-~-.._~. ~"" t"""'.._._ .. :,,;>11_ ~lrJ!ll<T .. -.-. .. lltalaka~ ~will N~li,.lblt 1i0'111i't IJCI fro,,, 11w!*l*!lllll!Y<Uli9* ..... pia,,f *~ n,....~-Kl

.._hm._ [PIOl!l'lffl, a'-* -mpa--.-Gl'l -box.it 11 **** ~.!Jlllto""'
, cil -~-~an911!"""1:P"1!" .:ta~, ,....i(i , wlll,a..w~ What is Kl? Kl(ihellh~lllm1'1\Jr1Md11J!i"?Jll!Sllllll llldii!j IS :i, nan~5171 p lm lidne ~l l odl'E L!i an~.ltw1Sl1DJl1ncmlure:i,ndl&i!1Scoan lqlllltri plrl:Ol'Jllurdl!t Ba'311!1! kllllni!'llilln txyour newtn. rt *t;. lm!d tn tl!O! wr. l'IDllll#l!r, Ille lilllne .n fne.KJ p(I !L!i mui:n slronger bni ne~lnlll:il!Mli. TalileBIIIICllDltlll! El!iKl as a rejllaa'm!l1 ! ror Kl, 1 9 The ft11Chlgan Department af Health and Human Servla!!i (MOHHS) ru!IS the I(] program. For more tnformatloo, contact: Phon£s 517-:BS-8350 (8 a.m. to 5 (l}.m ,) Emal!: mdhm~~lchlgan.gov 0nl'ln£s www.mlchtgan .gov00 How does Kl work? !i1 lte LDll'.ely IM!llt d 11 Sima! lllddl!cll .at ll! !D:'1?31 power plan1, ndbatlltfe lbllne OlUIJ re rell'll3ll(I rntn 1ne :ilr. l.Jke regi::eir loclile , ra!l03!llVe IO!lrn! ,cart be!lnred , }!JUI ltrjrold ms CS) ame inlrntd cm:erot"idner' ll!Jl1llll Jllll{emS llll!f llime. Clllill!II arel110'st a t 11M <11 ttr)mil ~fllll1l l!JjHISml to rdmcllYI! IDllD!. f:.I prtl!dls)'JU'lt!frr.111
tlf11~ lrup \111111ia&leb:m<llfOOIJE,1D1l:lltlt(211.'tmlll!
111 ~IO!lile. 12 IS lmpo!ml lllr)llll 1D lemWbi:!l'IG.iloesJJOI l'.fflle:t ~ocrWl!dl! ba:tf1rom ll'doadhl! .llllill!llll ti;I ~mly yuE it¥1*1 gl:!ml. How cm I gqtl<B? 01.:,lne 11'.lOCIU ID -DI 1he partldpaltq ptnrrmd'es llm!litm!. Tlll! pllllmlil'J W11 i;r.rffll!' jW llilmirl! a:muni Of IQ imt !'=II 'lll!elt lbr.e ltl! XI In a Sllle, lllf'hl,"llilm
i,nU illl!p II In 11s i!lll pai:.lll!l
'fro 8h:ad 111!£1) rt ll!l 'lllm as p:irt Dfyour llffBgl!'JCJ 11!Wfr kit :Ill? IIJ:!! b lffllrro row. V*oo WII mt tie Ible 1D get It mm the~ l!U111lg a, nut1ear-ix-jilJlt! Wlum shGJuld I tat& IC.I? "hilt , IO odJ If a "Gllllnl 8inllJNlcJ" Ila 111B1!11 iledlfl!d atll18C-llb:IBU Pllft. I Ille l!l11ff9BllY stms.;SOUn:! tit 11111!1! mnutes ar rmra. ttu ID )'Dtl' !real rn!lil mtl!lel<si lll .!As!:m R!ltw lll,!o lnslrur:!imS gtt'l!n l!rf~ Append ix D Use the Information In this chart to talu! 1he coned amount llor one dose. AGE: WBQR' 005E ls+y eor.s* ArrJ-'igtai. Twa 12) 65, mg t>ble~ (.i.nckcl't!l 'Jl'tJ;flOM!lr , br:rasrl~Vlll' warnml l.2*1Syear.; 1 50 lbs.or ml!i1'! Two 12} 6S mg !ablet, l:Z-ll!y e,r,; le,ath,n 1 SD lbs. *One rn fili_ mg ab t 3*12 ye.ors AnyYt~i,t ' O:ic Cl) ~5 m911:>blet l'l.>'.lf(T/116:Smg t,,hle:t,cru.ito:firrl!!io l iquid. 1 moo, 1h*l~,,. Any .. ,ejgl>t /l~flifcrum1r.g imdmirir.o wi'l.brrJI<1tkk:llllt l h.=,.m\l'.umcq] Quarter [l l4) 65 mg ll:i b'.let: crumec in.to,, liq uid. Birth*l mor;liil Anywe:g t:.t mlltfalS. Yoo illl&J Ill! l'nmlchli ti T~l!f'h-p ia,-e ar-."Ua!e. 'lllU Slltad my t em Kl n n m tld'o*IJ' TVn:ouncemmuy h1t n; pmilBi' pt!nt l'l:!.5 declaml a 0 Gemal £me:gm:y; 1he rmst~ *tp. D I p'tlni efll!!!l!!T.)'. n*)ffllar di ld'!nf!l~allllirAl/tnm!'l!l
!',I *rea:t!J IMlflilll?
, IIQl'i 11111511! lime SBln::tlln; t:, d. £'I!£~ DI Sllelh!nng " b-plle1! 'IS :Ille t:J5sl 'Ml}' in~ 'too rmn twm 1n 13l!Ul!on. H'.ow mud! .Kl shnuld I rake ,? ra lllllll! t'l)!Eetll tne ltrJl1llll 1tlr 2:t M.n:. Y ie .SIJOUI! .bl! sall<!y i!l/3CUlB:<h..Uttn Ille 24-1:Du r ttm penDll. See the dlu'i lmfl!!> ror 12l<.i!' lr-fd!!llnas. Wha:t side elf.eels could I ha.ve l'rom la1cln9*Kl? *m., l!!IEC.ts 31e Unlklt/ wll!'£I Kl IS !l5e:l at Im rerommeMell <lllllll! mi: ror a. 1tmt'tllll!!. Mlmr !Ide< effl<!di can : tcl:lll! 81 upse t.sloimi:n. sk.ll' ra m or a ITlrtaBc b!BII!. An l't1K!Jl:cmlill211 t3ll lia'l:'ll!llre~ ~ln.w llakl!.'I:. !iit.lµiln, 5!M!llilg ,o1 i ret.lc!! 04' OOlly or !muti~ brestnt:~ Sefflie !llaltneSs ar bre!!lllll!qµl'm ln1nl@dl8il! aHllilkMl r CEP Rev 39 (1'rutnKlioru fufCJ!tlS.luil,:i a.9i:lmirir.Q w~J fa: t)RJV , i;l'"d'!:rt tlr /YIJalmfXY) WbD s'hooro: rf!JT rnke IK I? l'DII : SIK!Ud!IIO I ilalle* Kl If:
Yau am a\i,,1110 to l!dne.11 Sh!{l!l:11, a!ergy may nrn Ere11 n 1nal ]'!HJ are ru~.gt 1D l (U!tl!. Talk>>l'!'J'!DJSIClrnm,l~r~Jf)'IJU Ill.II!< \'15he911i!l:1:i1l!l1;1J.

YCiJ ila're tEip!llroim:s (ett) Cf .ll}jlrolmp!Err.errl!m'c

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I.I ill! pID!Jram, *1t.1:1. J'E!lpCfl~ rer t:!Mng s Clsjlell!lo~ p1a11 in s lrompc:e!r.w lill inel.e m1ill.dmls. 'P bl.5b!oall~ .attoJl3!1f~IB. ')t1UC311 prm1oea c~ er ltfll T'..o.:ll!lr1a
)'1111' e~ .rednat tlle'Jom ottl3tl ltelrll£'.illel13l SU1{(y c< KL Page 178 of 212 Read ttiis i nfonnal io n before signing Hle Kl voucher. SQJ'ling tlunoucher maans lhatyou agn!a to and understand the fallowing:
I UNDERSTAND THAl:
Kl IS an ~Clllll!!; non-pma!Jftlll

Kl IS ID bl! bDll my Whl!n , a GIHllnl 6l'lllfgl!llq'ilm been dt!Clmd al Ille CUO.k Ntdllr Jllllll

Kl Ii NOT Ii ldl&llui!
I IHIIICllsbl or ab!lhmg pla:e.. , ... IOlloll 1111tructbns or Bll1!lgl!E1 ora:...
Kl onlfjllliec:ls Ille lh),dl ,glllnd 1lllm 131D11:1111!

lllcb. II d DB!. nd pola:t lb!< rwl:llfille bady. In a nld!lr i-pllnt l!IIIIIJIIIICY,.
lnl!II could bf tlllllll 11111:11 , nom atner nund radlllaJn.
AlibJuOl llilllng kl .. UIIU8lly ... It call CIIIII! ?!upie 'IIIIO Ille 11i¥n*! IIRBII! or in lll!rglt ID lldh8. P!opl!o 11111D i-d!!ll1liill
~11181 er~ ll1leallal 'IIICllllils (IIINS .. 111n , ¥1!1J f1A! ata1 illleBB, ltllUtl not laka Kl wllllld lht bldliJ In 1ntt-Oldor. I AGRE! THAT:
1 11111 fDIOIIII all llUUcblns on hOW' to llll! pcl:mlu m rixn (ll l-* 1111 1 tdd tile phlm18J:y hal1nl!!IB 1111m 1111 lllllliy.
Clllml. allbarai:tlJIIS retaim D tile '1151!, dl!lhl!IJ, lllbelng and pa::<<IIJng << Kl Addtional agrNmllllts for husioa,ssu
1 01111 or , ll!plllll!ll!
Ill! 111111mBl"lmlllullon 111111111!11 on. Ille 'IUUdll!r.
TI1IS .a .Pronle r nninllln OG d06lng and llll!IICII oonlJaalk::illam 1D d Bf1'*""81Mm pnor ID sll:blllng Kl. {NOTE: Yau d nn11111111
lallltm8ilon In elldl bm: Ill Kl and on lhe llilHIIS Wltlllie at wn:.111l:ltgan.plll.J To qtralify to r llCffill Kl tablets for your household o rbosi119SS, yoo must:
LNe crlllllk lllililn 1 o mnee Clock lb:1!111 1'111111.

BetBJl!ll'BOI'~

PIM!ll 11 ;Olll!mrrKIHi!l!IJBS D. Participating Phannacies YD1J MAY PICK IP YOm Kl TABLITS AT THE FOLLOWl:NG PHARMACIE&

Meijer Pharmacy 1920 ?ipestone Rd .. Benton H.-bor , Ml

Meijer Ptwmacy 5019 Red Arrow Hwy., Stevensville, Ml

Meijer Phllrmacy 5150 S. frar13din Sl, Micfl:igmi City, IN

Meijer Pharmacy 1223 Phoenix st., Sooth Haven, Ml Appendix D Page 179 of 212 ,-____________
Cl!.*~tl,o-~~11~ _ ________ _ 2017*2018 Potassium Iodide (KU Voucher By irgrq trA6 fOOn, I &gll!e ltl!l I hme real !ti? Kl 111ltllll3tl m p~ lDl tnst I am olrt aJ;mg 1!11 ilr ll!Ofie 'litla 'lW> or llfflC wttn o m e~ llftlrn coo~ Nu di!m-rtn Pl.EASE COMPI.ErE SECTION l O"R 2 1.,.aamw, II FOIIIOISUOU II lllOO:: SIIIETMORm: 2..IQllfflll, 11 f'GRIISDIESS.USE N.UIEDf B1JS1f6S: cama KI.IIE CClJKlY: PIWIIAC'f ISi ONIJ PWIIICT UII: IDTI: ~HE I l l Pc 19J K EI PJIBUCrt: L-------------------=-r---------- QJI along!ho clashed llna. -., CEP Rev 39 PREPARIN I G FOR AN EMERGENCY EVENT Emergency !iitualic:moften catch people ctr gu w A good Wil'/ to stay safe m an emergenc y is to mow \Wat'lodo ahe.ad of time. Here are five steps )'OU a.n ilalie maw t o m alle Sl!l!E)'O(J. yow family amdyourro-wcd;ers
are*prepated to handle anyeml!'llJeocy
-1. After you: read 1h15 Emergency lnfomwlon Calendar , plNse wie ltwtth*)'IIU' family ar <IHftllltBs. Then disp lay it where )'00 can find i t qwd;lywben you need it 2. Keep the folllllllling HMIStogetber tn ii safe , 95}'-to-,get-to
place: iJ Emergeac y , ca:Sh D Ched:book C Pet supplies '.] lmponan1 papers [i Deb it cards C Credit cares First aid ki t C Por ta ble radio D Persooal identification D Extra treys c; Ex tra batt f'ii es. C Potassium iolflde* (f<I J 0 Pla::rip tion m edic ine s D Ra sh lig h if obtained in adVilllce 3.. Make a 11st of personal 111sbucnom that y ou, yoo r family or co-worlam will need ID f ollow [n an eme,gen()t Keep.a list of ~ies )'Oil may need with the it:lstructiom.
Incl ude on*yoia supply list Ifi e items in s mp 1 aoore and the EYacuation sl!lpplie , isted on page 115. 4. IKeep your l'ehkle In good na1ning ordef", Ifil l yoor gas tankwtiene...erit gets below half: If yoo do Aat have a Gil' oroo not ha\11! .someone 10 dme you in an emergency , li ll! out the Functional Needs cardon pages l.S and 16. Md tbeanl , rtghtaiwny , You oo not need a snmp , s. llf you know peclflle who h*e tmcuonaf nl!l!ds.111.1kl! sure they mad In a.Junrttooal .Needs card.This may include an,one with mien or hearing impairml!tilh. physical , orrne n t.l disabilitie ~ QI/someone who has no means d tr.msportatioo. Piease lilelp them fill out lfle functiooa.1 H eeds card and return it right ~Y (see pages 15 ilfld 16). Wi: have member.. on oor ffllergl!IIIC)' team to he\p people with fum::t io!la l needs get to safely. Also. if )'OU lmoN someone who is blim l or G111aot r.t!ad welf , please read this Emergency fnformanoo Cak!ndarto him or he r: Then display i t where fam il y orme11ds can fin d i t fast forilddltklllid l!lllergen<y
pn!p!lrednesS
ttpsand~ cfmrn1-t , Bt!!rrie111County's free~nc, Prl!pa,eclnns Gulde! Co tom.bciberiltarg and dkkon the Dnk WI thenght<<Jluimr.
20 Ap p e nd ix D IMPORTANT PHONE NUMBERS AND EMERGENCY l 1 NFORMATfON fat 3111 fuephol'll!' numbe15. an d emergency infoorution )'011 IX .i member o f' )oor hottsehold a, bu 5ID!!!5 m il/I' need m a pe!lona i emer gl!ncy. lltease includ e name5 .anil numbers fee yoor: NAME O F P E RSO N O R SEIIV'ICE l'EtEPHON:E HUMBER *C-l Nude* Public lnqui'7 Line ,866-)62-3 '105 Use lhe space below to also li~t a:ny speci al he ahb or medical infcmution t l\a t an , emer;ge:ncy teammembef may need t o lmcm aboul)'OU. your fam ily m em b er, or m-WOlt en. SPEOAL lf EA ffil N EEDS OR EiMERG~N'CY 'llf f ORMATIO.N: CEP R e v 39 Page 180 of 212 APPENDIX E DESCRIPTION OF FEDERAL RADIOLOGICAL ASSIST ANGE Appendix E Page 181 of 212 CEP Rev 39 Page 182 of 212 FEDERAL RADIOLOGICAL ASSISTANCE DESCRIPTION . I. Introduction II. This document summarizes the DOE radiological assistance capabilities that can be provided to the Donald C. Cook Nuclear Plant (CNP). Section II describes typical capabilities and expected mobilization and travel times for some of the Region 5 of the DO E's radiological assistance program. Section Ill describes additional DOE capabilities that can be activated dependent on the assistance needed and how it is activated. Based on its extensive capabilities, the Chicago Operations Office (CH) will augment the resources of CNP. CH typical capabilities and mobilization and travel times are based on discussions with the CH Regional Coordinating Office representative on the Region 5 *. Radiological Assistanc~ Plan (Reference 1). .,
The mobilization time, which is defined as the time required to load equipment and initiate travel, is usually about one hour. Travel times in this attachment are specific to CNP and pertain to arrival at some appropriate location near the station. These are best estimate mobilization and travel based on a normal situation.
Region 5 Typical Capabilities and Mobilization and Travel Times The DOE radiological assistance resources are drawn from the major DOE contractor laboratories and facilities. The personnel involved with these response have routine radiological-related duties on a daily basis at leading nuclear facilities thereby ensuring not only continuing experience and training, but also providing the conditions. for keeping equipment operable and calibrated. The Radiological Assistance Plan (RAP) provides assistance only. Although this is a federal government agency with highly developed expertise, this agency will not assume the responsibility of the Utility or State for protection of the health and welfare of Michigan citizens and plant personnel. CNP would request DOE-RAP assistance only if it was determined that the plant radiological resources needed augmentation. If requested, a RAP representative from the CH will report to the plant/EOF and the CNP ERO in accident assessment and radiological exposure control function. CH can provide support to CNP to accomplish the following goals:
Alpha, beta, gamma radiation surveys

Radiation monitoring of air, food, water, milk, and personnel

Gamma spectrometry and radionuclide identification of air, food, water, milk, soil and vegetation

Airborne radioiodine sampling and analysis of concentrations as low as 5E-07 µCi/cc

Radiological control advice

Laboratory analysis

Mobile laboratories

Communications Appendix E CEP Rev 39 111. Page 183 of 212 Mobile laboratories from RAP contain high and low-range alpha, beta, and gamma radiation survey equipment as well as alpha-gamma spectrometry analysis equipment.
Estimated times of arrival for the CH resources within the region will vary depending on where the resources are drawn from. The number of personnel and equipment dispatched will also vary depending on the accident conditions and the requests presented by the Utility and/or State. Table F-1 lists the DOE manpower located at Argonne National Laboratory (ANL) that could be provided in response to an incident. The table also provides ari estimate for time of arrival to CNP area assuming a half hour to a 1.5 hour assemble or mobilization time. It should be noted that ANL team is a major team and therefore has a larger spectrum of monitoring equipment and number of personnel to respond to an accident. The available resources include a mobile laboratory equipped with a multichannel analyzer. The other teams listed in the table would complement this ANL resource capability. .All of the above resources can be activated ... with one phone call to CH. That phone number is given in Appendix H. If the call comes in to the off-hours duty officer, arrangements will be made for 3-way communication or re contact with a radiological expert. The phone call may be made from the Technical Support Center by the Radiological Assessment Coordinator (RAC). The RAC would be able to describe the suspected radiological consequences of the accident and the resources and assistance which might be required of DOE RAP. Additional DOE RAP Capabilities Specialized and unique resources exist for various other DOE activities. These
resources can be activated and mobilized when needed: Included in this capability are resources available throughout all the other DOE radiological assistance regions as well as the resources of the Nuclear Emergency Search Team (NEST), Aerial Measuring System (AMS), and the Atmospheric Release Advisory Capability (ARAC). Response Equipment The DOE response network is organized to include the deployment of those personnel and equipment that are immediately required.
If the situation is of major proportion, equipment in the following categories may be needed and available. Airborne Systems Helicopters and fixed-wing aircraft are equipped with gamma and neutron detection
equipment.
Gamma spectral data is recorded with position information derived from measurements of several exposure rates and principal isotope identification on the ground. This is plotted as isopleths on maps or aerial photographs for immediate use by the responsible authorities. Aerial photography is performed with large format cameras. A twelve channel Daedalus Scanner is available for very sensitive thermal mapping, assessment applications or similar diagnostic. Appendix E CEP Rev 39 Page 184 of 212 Standard Health Physics Instruments Packages of standard health physics instruments are available with current calibrations. Team scientists select the appropriate instruments for the predominant isotopes. A TLD reader and 250 TLD's are included. A variety of alarming dosimeters are carried by . personnel working close to the incident site. Also, included are air samplers, portable counting equipment, battery powered analyzers, arid source handling equipment. contamination clothing and breathing apparatus are also available. Communications An extensive communications system is deployed with the special
team. A memorandum of understanding between DOE at AT&T assures rapid telephone response for the communications system connection.
The switching hardware for a twelve line telephone system and radios for HF and VHFtransmissions are installed in an airline cargo pod. In addition, the system contains a portable microwave system to provide. video, data, audio, telephone, and control communication between a field ~command post and an.incident site which may.. be up to 50 miles apar.t. Telephone with HF backup is the primary longer distance communication* system.
On-scene communication is assured with VHF radio, repeaters.
and. pagers. Included. in the communication array are all the basic support elements to establish a field command post. This includes typewriters, telecopiers, copy machines, . status boards, etc. All of the equipment and systems described above are packaged for deployment within two hours of a request. Existing airlift agreements between DOE and the Military Airlift Command assure rapid response. Most of the equipment can also* be flown on commercial body aircraft and trucked the final distance to a site if time so dictates. Backup Support There are many specialized systems located throughout DOE National Laboratories., which, .could be made available for specialized needs or extreme emergency* situations.
The members of the special DOE field team and the DOE Headquarters Emergency Action Coordinating Team are prepared to locate special equipment, arrange transportation and logistically support the equipment on site if risk to the public and . national priorities so require. * .ARAC The ARAC system located at LLL, is a system for computer based atmospheric modeling system which is real-time linked to the National Weather Service and the USAF Global Weather System. To insure accurate modeling for small areas around a fixed site meteorological data from the site is required.
In addition, topographic data is added for the site environs. Many calculational models are available to the field team. Source terms may be discrete (explosion), continuous plume, or patterns if particulates are present. Software is available to make dose assessments and to accumulate these if the release is continuing over a period of time. ARAC can also predict plume patterns which may be extremely valuable for evacuation planning, locations where air monitoring should be emphasized, or planning releases which are under limited control. Finally, aerial teams can continuously compare and update ARAC data with actual in-plume measurements to assist in improving source term estimates. Communication with ARAC is via telecopier. Because of its relatively long deployment time of approximately 48 hours, ARAC could only be sued as a backup to offsite dose projection calculations done by the utility state and local agencies. Appendix E CEP Rev 39 Page 185 of 212 . The request for the above resources is made to CH who will request their activation by calling the DOE Headquarters at the Emergency Operation Center in Germantown, Maryland. If CH decides resources other than those within DOE RAP, are needed, CH would activate the appropriate Federal agencies within the lnteragency Radiological Assistance Program by calling the appropriate agency, or agencies, directly. Additional Monitoring Teams
Ames, Iowa

Miamisburg, Ohio

Cincinnati, Ohio Monitoring teams from the above locations are available for assistance.
Deployment time is eight (8) hours or longer. Appendix E CEP Rev 39 A. Page 186 of 212 . Resource Information Required by RAP Comma*nd Centers State of Michigan Berrien County Donald C. Cook Nuclear Plant
State of Michigan EOC 7150 Harris Drive Dimondale, Ml 48821 517-284-3862

Field Team Center Michigan Department of Transportation Coloma Garage Red Arrow Highway Benton Harbor, Ml 269-840-2811

BC EOC 2100 East Empire Ave. Benton Harbor, Ml 269-934-9023

EOF B.

Nearest Airport C. D. Primary -Benton Harbor Telephone:
Frequency: Services:
Tower Hours of Operation:
Alternate -South Bend Telephone: Frequency: Services: Tower Hours of Operation: Lodging Holiday. Inn Express -Benton Harbor Ramada Inn -Benton Harbor Southwest Michigan Regional Airport 269-927-3194 Standard FAA frequency Fixed Base Operator; AVGAS and Jet A fuel available; Major engine and repair capability Tower closed; South Bend controls Michiana Regional Airport 57 4-233-2185 Standard FAA frequency Refueling: 2 fixed based operators; AVGAS and Jet A fuel available; Major engine and avionics repair capability 7:00 am to midnight 269-927 -4599 269-927-1172 Courtyard by Marriott -Benton Harbor 269-925-3000 Transportation Avis 269-926-2151 E. Police Escorts If required Coordinate requirement with County and/or State Police Appendix E CEP Rev 39 F. G. H. I. Page 187 of 212 Police Vehicles for Communication Augmentation* Coordinate specific requirements and request with Berrien County and/or State Police as available. State Police Frequency 800 MHz County Sheriff 800 MHz Travel Routes (From Chicago Operations Office) Take 1-294 South for 23.0 miles At 1-80 Toll Exit 160B, continue (east) on 1-294 [1-80] for 0.6 mile Continue (East) on 1-80/1-94 for 52 miles At 1-94 Exit 4, turn Right (East) onto US-12 for 18.2 miles toward Niles At Red Bud Trail turn Left (North) onto Red Bud Trail for about 2 miles to Elizabeth Street. At Buchanan, turn Left (West) onto Elizabeth Street for% mile to 500 Circle Drive Medical Facility Location Lakeland Regional Medical Center St. Joseph, Ml Niles Community Hospital Niles, Ml Maps of Sampling Points 1234 Napier Avenue Saint Joseph, Ml 269-983-8300 3100 N. St. Joseph Niles, Ml 269-683-5510 Provide as required. REFERENCES
1. Radiological Assistant Plan -Region 5, August 25, 1978, U.S. Department of Energy, Chicago Operations Office, Argonne, Illinois.
Appendix E CEP Rev 39 Mobilization** Laboratory Location Argonne National Lab Argonne, Illinois DOE Radiological Assistance Laboratories at ANL Number of Radiologically trained persons for first response a. Response by private charter aircraft 5-6* b. Mobile Laboratory 5-6~* Page 188 of 212 And travel time to the CNP Area Hours 3 ..*. 4 This number includes one or two DOE personnel to coordinate the Federal radiological monitoring effort with the Utility and/or State. * * * ** This includes 30-90 minutes mobilization time based on motor vehicle/land transportation under ideal weather and traffic conditions. Appendix E CEP Rev 39 Page 189 of 212 APPENDIX F BERRIEN COUNTY ROAD MAP Appendix F CEP Rev 39 Page 190 of 212 Berrien County Geographical Information System (GIS) Follow web browser link: https://www.berriencounty.org/406/Municipality-Maps . . Appendix F CEP Rev 39 Page 191 of 212 APPENDIX G POPULATION DISTRIBUTION Appendix G CEP Rev 39 Page 192 of 212 2010 POPULATION DISTRIBUTION Sector Direction 0-10 Miles A N 0 B NNE 12,425 C NE 26,677 D ENE 5;852 E E 7,674 F ESE 4,728 G-SE 1,485 H SSE 2,418 J s 3,340 K SSW 2,993 L SW 266 M WSW 0 N ., w " 0 p *WNW 0 Q NW 0 R NNW 0 Total 67,858 Appendix G CEP Rev 39 Page 193 of 212 APPENDIX H RADIOLOGICAL RESPONSE SUPPORT SERVICES CAPABILITIES Appendix H CEP Rev 39 --~~----~-

-Page 194 of 212 ARGONNE LABORATORY (DOE) The following is a description of resources available from the Department of Energy (DOE) per the regional implementation of DOE Radiological Assistance Program (RAP). This description of available resources is taken from the DOE Region V Radiological Assistance Plan, Section Ill, dated January 1984. This description of available resources is consistent with the DOE Letter of Agreement found in Appendix B to the Donald C. Cook Plan. DOE Region V radiological assistance resources are drawn from the major DOE contractor laboratories and facilities located in the geographical region. The personnel involved with these responses have routine radiological related duties on a daily basis at leading nuclear facilities, thereby, ensuring not only continuing experience and training, but also providing the conditions for keeping state-of-the-art equipment operable and calibrated. It should be noted that Argonne National Laboratories is a major resource and, therefore, has a larger spectrum of monitoring equipment and personnel for emergency response than the other laboratories in the region. DOE provides assistance only. Although this is a Federal agency with highly developed expertise, this agency will not assume the responsibility of the utility, the State, or local resource group for protection of the health and welfare of the local population and nuclear station p~rsonnel. A request for DOE assistance would be made only if it was concluded that utility and State radiological resources needed augmentation. If requested, a RAP representative from DOE Chicago Operations Office (CH) will report to the utility's emergency operations facility * (EOF) and/or the State EOC and assist the emergency organization in the accident assessment and radiological exposure control functions. CH can provide support to accomplish the following goa~: *
Alpha, beta, and gamma radiation surveys; * -_ Radiation monitoring of air, food, water, milk, and personnel;

Gamma spectrometry and radionuclide identification of air, food, water, milk, soil, and vegetation samples;

Airborne radioiodine sampling and analysis of concentrations as low as 1 E-08 microcuries per cubic centimeter;

Radiological control advice;

Laboratory analysis;

Mobile laboratories; and

Communications Mobile laboratories from CH contain high and low range alpha, beta, and gamma radiation survey equipment as well as sodium iodine scintillation spectrometry analysis equipment.
Estimated times of arrival for the CH resources within the region will vary depending on where -the resources are drawn from. The number of personnel and equipment dispatched will also vary depending on the accident conditions and the nature of the request. The request for any of the DOE resources listed in this section can be activated by a single incoming telephone call. Once the CH Duty Officer receives the request for assistance, he will make the necessary calls to activate the specific resources requested. That incoming number is (630) 252-4800 (24 hrs.). Appendix H CEP Rev 39 Page 195 of 212 APPENDIX I NOTIFICATION OF AMERICAN NUCLEAR INSURERS Appendix I CEP Rev 39 Page 196 of 212 NUCLEAR EMERGENCIES ANI/MAELU EMERGENCY ASSISTANCE (GENERAL) The provisions of the Price-Anderson Law facilitate ANI and MAELU (the pools) providing prompt assistance to members of the public who may be adversely affected in the event a nuclear incident were to occur at an ANI/MAELU/NRC indemnified facility. This arrangement is intended to alleviate the immediate financial burden which may be incurred by members of the public due, for example, to evacuation and relocation activities initiated as a consequence of a nuclear occurrence. In providing emergency assistance to members of the public, the pools will promptly dispatch their representatives to commence the distribution of emergency assistance funds. ANI/MAELU EMERGENCY ASSISTANCE (CLAIMS HANDLING PROCEDURES) The pools' emergency assistance arrangements contemplate the mobilization and dispatch of emergency claims teams to directly dispense emergency assistance funds to affected members of the public. Following notification of a nuclear incident potentially involving bodily injury, evacuation of offsite personnel or damage to offsite property, the ANI staff will alert claims personnel of member companies. The information provided to us by the insured will be utilized to recommend appropriate emergency response actions. If the magnitude of the incident requires immediate financial assistance to members of the general population, pool representatives will be directed to establish an emergency assistance office at a convenient location. It is contemplated that establishment of such an, office would be coordinated with the insured and local or state government authorities. Applicants for emergency assistance will be required to fill out a simple form giving their name, address, and names of additional persons to be assisted. The application contains two basic
provisions:
1. That the disbursement of emergency assistance funds does not constitute an admission of liability on the part of the insured; and 2. That the acceptance of emergency funds does not constitute a release on the part of the applicant.
The procedures outlined above. are specifically directed towards immediate payment to members of the public for out-of pocket transportation, living and other reasonable expenses incurred shortly after a nuclear incident. Subsequent to such immediate relief being provided, the pools will service bodily injury and property damage claims which may be presented. Should the incident be declared an "extraordinary nuclear occurrence" by the NRC, virtually all legal defenses are waived by the insured and the pools which makes adjusting the claims much simpler. CRITERIA FOR EMERGENCY NOTIFICATION Under what circumstances should the pools be notified in order to activate the type of emergency assistance response described above? Appendix I CEP Rev 39 Page 197 of 212 Condition 5, "Notice of Occurrence, Claim or Suit", of the Nuclear Energy Liability Policy (facility form) delineates the notification commitment of the insured to the insurer; however, the provisions of Condition 5 do not specifically describe the type of immediate financial assistance discussed above. Almost by definition, emergency financial assistance must be provided in a timely fashion. Timely assistance of course, implies timely notification: "The pools should be* notified in the event of a nuclear emergency requiring notification of State or Federal governmental agencies, or if the insured believes that offsite persons may be affected and financial assistance of a nature discussed (under Emergency Assistance above) may be required. In these instances we would expect notification as soon as possible after the initiation of the emergency." Recent efforts by the Nuclear* Regulatory Commission have led to the standardization .of the syste'11 used by power reactor licensees to categorize emergencies as published in NUREG 0654 (Rev; 1'), "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans ... " Other types of nuclear facilities are using similar terms to describe emergency conditions which could develop at. their sites. To be consistent with industry classification systems, the insured's emergency plans and/or emergency plan implementing procedures should be written to require notification of the pools in the event of an ALERT, SITE AREA EMERGENCY, or GENERAL EMERGENCY as soon as possible. Even if it appears to be remote that offsite persons will be affected, the pool should be notified in order that response plans can be initiated to the point of alerting teams of adjusters to stand by. Response activity can be discontinued if it proves less severe and does not require pool response. Naturally, all nuclear; occurrences of an emergency or non-emergency nature which may fall under the nuclear liability policy should be reported formally in writing as specified in Condition 5 of the facility form policy. EMERGENCY NOTIFICATION AND FOLLOW-UP PROCEDURES In the event of an emergency, it is important to establish clear lines of communication between your facility and ANI in order to exchange all required information during a developing emergency situation. ANI maintains 24 hour coverage of our emergency notification number. This number is 860-682-1301. During normal office hours (8:00 am -4:00 p.m.) this number will be answered by our receptionist who will transfer an incoming emergency call to an appropriate individual in the office. Outside of normal office hours this phone line is covered by an automated phone answering service. The answering service can be used to leave a message, including the affiliation and phone number of the caller. A designated ANI staff will in turn call back the facility to obtain appropriate information regarding the nuclear accident. The TMI incident, as well as other incidents, clearly demonstrated the need for follow-up communication.since the information transmitted in the initial notification may be incomplete. As discussed above, an important purpose of emergency notification to the pools is to allow them to gauge financial assistance to member of the public as they did during the TMI incident. Additionally, members companies with assets at risk require accurate and timely information from the ANI staff when nuclear incidents occur, whether or not such incidents ultimately lead to the actuation of emergency financial assistance by the pools. In order to carry out these mandated responsibilities, it is essential that ANI receive up-to-date information from reliable technical sources regarding radioactive releases from the site, plant status, and impending protective action for members of the public. Appendix I CEP Rev 39 Page 198 of 212 FIGURE 14 ACCIDENT NOTIFICATION PROCEDURES FOR ANI INSURERS THE FACILITY'S COMMUNICATIONS DUTY OFFICER.EACH SHIFT ' .... *NUCLEAR or **NON-NUCLEAR ACCIDENT ; .... 860-682-1301 AMERICAN NUCLEAR ANI HO:ME OFFICE INSURERS FARMINGTON, CT NOTIFICATION NOTES ---24 HOUR TELEPHONE COVERAGE PROVIDED FOR IMMEDIATE NOTIFICATION AND OTHER SERIOUS ACCIDENTS ---IN ADDITION TO NOTIFICATION TO ANIR.OMPTL Y NOTIFY YOUR COMPAN'!S INSURANCE DEPARTMENT .
NUCLEAR ---NOTIFY AN! AS SOON AS POSSIBLE AFTER DECLARATION OF A NUCLEAR ALEBJITE AREA EMERGENCY OR GENERAL EMERGENCY
---REFER TO AN! INFORMATION BULLETIJSJA (81) FOR DESCRIPTION OF EMERGENCY CLAIMS ASSISTANCE AND ACCIDENT REPORTING INFORMATION REQIBREMENTS
NON-NUCLEAR
---REFER TO AN! INFORMATION BULLETIJSJA (81). NOTIFY AN! IMMEDIATELY IN THE EVENT OF A SERIOUS ACCIDENT INVOL YING l;IIRllBHTINQ EXPLOSION OPERATION OF FIXED FIRE PROTECTION EQIBPMEl'fW]NDSTORM, VEHICULAR DAMAGE TO PLAN;IDROPPING OF EQUIPMENTEMERGENCY OR UNPLANNED IMPAIRMENT TO FIRE PROTECTION EQUIPMEN'.('ETC, AND SERIOUS ACCIDENTS THAT INVOLVE ELECTRICAL AND MECHANICAL EQUIPMENT A~ PRESSURE SYSTEMS COMPONENTS ---REPORT ALL PROPERTY ACCIDENTS REGARDLESS OF DEDUCTIBLR'RIVIAL ACCIDENTS NEED ONLY BE REPORTED TO YOUR COMP AllruNSURANCE DEPARTMENT FOR PROMPT WRITTEN NOTIFICATION OF AN! VIA AGEl'll!ROKER . Appendix I Page 1 of 1 Revision 30 Appendix I CEP Rev 39 Page 199 of 212 APPENDIX J EIGHT YEAR PLAN MATRIX Appendix J CEP Rev 39 Page 200 of 212 EIGHT YEAR PLAN FOR EMERGENCY PREPAREDNESS ACTIVITIES . Eight Year Items. 2018 2019 2020 2021 2022 1. Exercise with full State and County participation involving the ingestion X exposure pathway. 2. Exercise with State and County participation X X (HAB) 3. Exercise with full State. and County participation X 4. Biennial Evaluated Exercise X X (HAB) 5. Annual Exercise (Satisfied by Biennial Evaluated Exercise) X X X Notes: The plan presented above ensures compliance with both the NRC and FEMA periodic exercise requirements Annual Items 1. Annual Exercise (Performance date dependent on outside agency schedule) ' 1a. I Train controllers/evaluators 1b. I Conduct the exercise 2. Annual Media Mailing 3. Review Emergency Action Levels with State and County authorities
4. Verify dates of letter of agreement in the Emergency Plan 2023 2024 2025 X X X X X 5. Review documentation to ensure Emergency Response Organization personnel have received required training in the past year. 6. Test of communications between Cook Plant, State and County EOCs and Field Assessment Teams. 7. Review of Emergency Preparedness Program pursuant to 1 O CFR 50.54(t) (PA Audit) ' 8. Letter to State and County making interface evaluation portion of 50.54(t) review available

9. Distribution of Emergency Preparedness Public Information Brochure 10. Fire drill with off-site support participation (conducted per Fire Protection Program Manual (FPPM)) 11. Training for plant, hospital, and ambulance personnel on the handling and treatment of contaminated/injured personnel

12. Medical emergency drill involving a contaminated individual (Performance date dependent on outside agency schedule)

13. Radiological.
Monitoring Drill (both on-site and off-site). Drill to include collection and analysis of water, vegetation, soil and air samples. Coordinated with the annual exercise.
14. Test of the Public Notification System ' The scheduling for the performance of annual items is dependent on the outside agency schedule.
Appendix J CEP Rev 39 '* Page 201 of 212 EIGHT YEAR PLAN FOR EMERGENCY PREPAREDNESS ACTIVITIES Semi-Annual Items 1. Semi-annual backshift augmentation drill* 2. Semi-annual Radiological Monitoring and Health Physics Drills involving the response to and analysis of simulated airborne and liquid samples and direct radiation measurements in the environment.*
Quarterly Items** 1. Verification of plant personnel Notification Telephone Numbers 2. Verification of Initial Notification Telephone Numbers 3. Fire Emergency Drill 4. Operability checks, per Radiation Protection Procedures

5. Inventories Monthly Items 1. State and County EC (within EPZ) communication tests 2. NRC Headquarters and Regional office communications test (CR, TSC, EOF) *The semi-annual items are conducted during any month January through June and any month during July through December.
The quarterly items are conducted during any month within the quarter. Appendix J CEP Rev 39
\ \ APPENDIX K AGREEMENTS WITH OFFSITE AGENCIES FOR HAZARDOUS MATERIALS SPILLS Appendix K Page 202 of 212 CEP Rev 39
1. 2. Page 203 of 212 APPENDIXK Agreements With Offsite Agencies For Hazardous Materials Spills Berrien County Emergency Management 1 page January 5, 2018 Lakeland Regional Health System 1 page January 18, 2018 Appendix K CEP Rev 39 Berrien County Emergency Management 1/5/2018 BERRIEN COUNTY EMERGENCY MANAGEMENT DIVISION OF BERRIEN COUNTY SHERIFF'S OFFICE 2100 E. Empire Avenue, Benton Harbor, Michigan 49022 Telephone (269) 983-7141
Fax: (269) 983-5726 Mr. Ronald J. Sieber Cook Nuclear Plant One Cook Place Bridgman, Ml 49106
Dear Mr. Sieber:
Page 204 of 212 JON HINKELMAN CHAIRMAN BOARD OF COMMISSIONERS L. PAUL BAILEY SHERIFF CAPT. ROCKEY ADAMS COORDINATOR We wish to reaffirm the willingness of the Berrien County Sheriff's Department to respond upon request to any emergency which could occur at the D.C. Cook facility. Berrien County Emergency Management/Office of Homeland Security has the obligation to respond upon notification that an emergency exists. Berrien County will implement their Nuclear Accident Proced..ures (Appendix
1) of the Emergency Operations Plan and take appropriate actions as outlined therein. In addition, the Sheriff's Department has basic patrol and investigative services and currently has a fourteen member Hazardous Materials Response Team who are trained to Technician Level. Four of the fourteen Haz-Mat team members are cross-trained as bomb technicians, and of whom have successfully completed the FBI Hazardous Device School at Redstone Arsenal in Redstone, Alabama. Our Tactical Unit consists of 20 personnel who conduct training monthly. . The Berrien County Sheriffs Department will be available to you upon request, in any area within the jurisdiction of this agency. Sincerely, Sheriff/Director, Emergency Management Appendix K CEP Rev 39 Page 205 of 212 Lakeland Regional Health System Lakeland Health January 18,.2018 Mr. Joel Gebbie Sr. Vice President
& ChiefNuclear Officer CookNuclear Plant One Cook Place Bridwnan, MI 49106
Dear Mr. Gebbie:
This letter is to confinn tlmt Lakeland Health remains able to provide care for the iryured : radioactively-contaminated patients at the St. Joseph and Niles Emergency Department sites. This would include Donald C. Cook personnel exposed on-site and members of the public exposed off-site who may reql!ire Services. Mutually agreed upon annual training and drills will be conducted to assure staff competency in caring for this patient population, with evaiuation by FEMA when required. A policy and procedure manual is available at each site and updated regularly to incorp()rate changes in patient management. An identified Radiation Emergency Area (REA) is available at each site that allows*for stabilization, treatment, and management ofthe radioactive component of the emergency. I understimq that the training for hospital pe1'sonnel, equipment, and stocking of the disaster cart will continue to be provided by Donald C; Cook Nuclear Plant. 1bis agreement shall remain in effect from the date of signing until either party, upon ninety (90) days prior written notice to the other party, terminates the agreement. Please contact Kathy Effa, Manager of Emergency Services, at269.983.8670 for any assistance that. you require. . / / Sincerely, *)l-/ ./7 ,/*--\ ?_,;:::o* -.. *<,~*_,... .... / , **7/>* ._,.,,. ; //... . l_----*lliren B. ilamel, MD President & CEO Lakeland Health LBH: sd Legal Review Completed H/l"P 1\r8l1~ 12~4 Napier Avenue, St. Joseph, Ml 49085 (269) 983-8300 ww w. I a ke I and h ea Ith .. o rg Appendix K CEP Rev 39 Page 206 of 212 REVISION
SUMMARY
Procedure No.: CEP Rev. No.: 039 ------------------ Tit I e: D.C. COOK NUCLEAR PLANT EMERGENCY PLAN Alteration Justification The Cook Emergency Plan is wholly controlled under 10 CFR 50.54(q) and plant procedure RMA-2080-EPA-008, Emergency Plan Management, therefore a 50.59 review is nof required. 10 CFR 50.54(q) review was performed and is referenced in the workflow for this revision . . The conclusion was that the changes in this revision do continue fo comply with the requirements of §50.47(b) and §50 Appendix E and the changes do not constitute a reduction in effectiveness. Therefore, this Cook Emergency Plan Implementing Procedure can be implemented without prior approval. Change .1: Front Matter -Page 1 of the CEP is the Table of Contents to match the ~tandard format of Cook's procedures and plans. -This moved the revision summary to the end of the document. -The 1 OCFR50.54(q) is not part of the front matter. It is now only by reference on the coversheet. . Change 2 [Page 1-7]: Table of Contents -Corrected formatting issues with the positions of page numberingthroughout. ,.Replaced Figure 5 'CNP ERO at an Alert Classification' with 'TSC Organization'. -Added 'Figure 6 'OSC Organization'. -Renamed Figure 7 from 'Organization of the Emergency Directors Staff at the EOP to 'EOF Organization'.
-Due to adding Figure 6, shifted remaining Figure numbers one number higher. Change 3 [Page 12]: Definitions -Updated SEOC address in SEOC definition.

-Changed title of SEC to SEO in TSC definition.
Change 4 [Page 14]: A.1.b, Concept of Ops -Changed title of SEC to SEO. -Removed '(via EOF)' at the end of the fourth paragraph after 'NRG'. -Removed 'on the Board Writers and Managers bridges' in favor of simply stating 'bridge lines'. These changes.are EDITORIAL in nature and recommended b.y Cook Emergency
. Preparedness (EP) Supervisor to enhance readability by third parties. These changes have not impacted content. There is no requirement to include 50.54(q) within the CEP. Related 50.54(q) evaluations of this revision #17-50 and 18-02 are available upon requestand retained by Nuclear Document Management.
_ No margin marks used. All changes to the Table of Contents are EDITORIAL in nature. These editorial changes were either to fix formatting issues from the previous E-Plan revision or required based on succeeding changes in the body of the CEP. No margin mark's used. No change to the content of the definitions was made. Therefore these changes are ADMINISTRATIVE due to an updated State address and title for the SEO per Change 12. ADMINISTRATIVE changes to align SEO title with Change 12 and ensure clarification that the TSC performs NRG notification per Change 12. Third sub-change is ADMINISTRATIVE in -that names of specific phone bridge lines are an unnecessary level of specificity and do not change intent of the CEP. CEP Rev 39 Page 207 of 212 Alteration Justification Change 5 [Page 15]: A.1.c, Organization EDITORIAL change necessary to figure Interrelationships numbering due to adding Figure 6 per -Updated numbering of 'Figures 1 through 1 a Change 27. to 'Fiaures 1 throuqh 8'. Chijnge 6 [Page 18-19]: ADMINISTRATIVE change due to B.1.a, Vice Presidents reorganization where the Director of N.uclear . -Updated title of 'Vice President-Nuclear Site Services position was removed from the Generation Group' to 'CNO'; Updated P.2 on Cook organization. pg 138 as we.II. -Updated title of 'Senior Vice President' to All originally reporting to this Director now Site Vice President; Updated P.2 on pg 138 directly report to the Site Vice President. as well. -DELETED 'The Vice President--:Site Support ADMINISTRATIVE changes to Figure 2 and 3 Services is responsible for personnel training for non-emergency chain of command to and qualification'. This responsibility already reflect changes in organizational structure. aligns with the T'faining Manager. ** This is a routine**update to keep these fi§ures B.1.d, Director Nuclear Site Services was reflective of the current plant (non-DELETED emergency) organization. -Then ADDED these responsibilities to B.1.a for the SVP. B.1.d&e, EP and Security Manager -Changed accountability of these positions to the SVP. B.1.e, Nuclear Regulato[Y Comi;iliance and Licensing Director -Added new title between EP and Security Manager. Moved Access and FFD responsibilities from Security Manager to this position. Page 42 and 43: Updated Figure 2 and 3 due to these orQanizational chanQes. Change 7 [Page 20]: B.1.k, On-Shift ADMINISTRATIVE change due to a related Operations Personnel acronym/title change in Change 12. -Chanoed title of SEC to SEO. Change 8 [Page 21]: B.2, On-Shift ADMINISTRATIVE change dueto a related Emergency Coordination acronym/title change in Change 12. -Chanoed title of SEC to SEO. Change 9 [Page 21]: B.3, Emergency ADMINISTRATIVE change due to a related Coordination Line of Succession acronym/title change in Change 12. -Changed title of SEC to SEO in four places. Change 10 [Page 21]: B.4, Non-delegable ADMINISTRATIVE change du~ to a related Emergency Coordinator Duties acronym/title change in Change 12. -ChanQed title of SEC to SEO. CEP Rev 39 Page 208 of 212 Alteration Justification Change 11 [Page 22]: B.5, Emergency EDITORIAL change necessary to figure Response Organization numbering due to adding Figure 6 per . -Updated numbering of 'Figures 4 through 7 Change 27. to 'Figures 4 through 8' in two places. -Added third paragraph stating 'All positions Second sub-change is ADMINISTRATIVE in are assigned common administrative that it provides clarification: responsibilities such as event response and Administrative/office tasking [not required to
maintaining adequate documentation of the be included by regulatory guidance]
was not *event tasks. Individual tasks for each ERO included in the descriptions of positions/tasks . position are as follows:' in the sections that follow. Change 12 [Page 22-26]: B.5.a.1 through MAJOR change to the TSC organization.
13, TSC Organization Positions These changes were the result of an overhaul ""Revised all position titles (aligned with Figure to the ERO designed to improve overall 5) and provided a new complete list of efficiency and effectiveness.
These changes responsibilities. were approved by PORC via 50:54(q) #17-50 .. on 1/12/2018. .. .. Change 13 [Page 26]: B.5.b, OSC EDITORIAL change necessary to figure * :-Updated numbering of 'Figure 5' to 'Figure 6' numbering due to adding Figure 6 per ChanQe 27. Change 14 [Page 26-28]: B.5.b.1 through 7, MAJOR change to the OSC organization. OSC Organization Positions These changes Were the result of an overhaul -Revised all position titles .(aligned with Figure to the ERO designed to improve overall 6) and provided a new complete list of efficiency and effectiveness. These changes responsibilities. were approved by PORC via 50.54(q) #17-50 on 1/12/2018. Change 15 [Page 28]: B.5.c, EOF EDITORIAL change necessary to figure -Updated numbering of 'Figure 5 and Figure numbering due to adding Figure 6 per 6' to 'Fiaure 7. Chanae 27. Change 16 [Page 28-32]: B.5.c.1 through MAJOR change to the EOF organization. 19, EOF Organization Positions These changes were the result of ari overhaul -Revised all position titles (aligned with Figure to the ERO designed to improve overall 7) and provided a new complete list of efficiency and effectiveness. These changes responsibilities. were approved by PORC via 50.54(q) #17-50 on 1/12/2018. . Change 17 [Page 32]: B.5.d, ENC/JIC EDITORIAL change necessary to figure -Updated numbering of 'Figure 1' to 'Figure 8' n.umbering due to adding Figure 6 per Chahae 27. Change 18 [Pag~ 32-34]: B.5.d.1 through 11 MAJOR change to the ENC/JIC organization. -Revised all position titles (aligned with Figure These changes were the result of an overhaul 8) *and provided a new complete list of to the ERO designed to improve overall responsibilities. efficiency and effectiveness. These changes were approved by PORC via 50.54(q) #17-50 on 1/12/2018. Change 19 [Page 34]: B.5.e, Liaisons ADMINISTRATIVE change by relocating -DELETED this section and placed Liaison in Liaisons to the respective ERO facility they with section B.5.a.1 O (TSC ICP Liaison) and ultimately report to during an emergency. sections B.5.c.9 and 1 O (EOF Offsite Liaison and Liaison Coordinator). No marain mark used. Change 20 [Page 34]: B.6, Overall EDITORIAL change necessary to figure Organization and Communication numbering due to adding Figure 6 per -Updated Figure numbering for Figures 9 and Change 27. 10. CEP Rev 39 Alteration Change 21 [Page 34]: 8.7.a, Logistics Support -Updated title only from 'Scheduling and Planning Manager' to 'Administrative Coordinator'. Change 22 [Page 35]: 8.7.b,
Reentry/Recover Tech Support -Updated reporting chain for TSC Plant Evaluation Team from 'EOF EDS Manager' to 'TSC Manaaer'.
Change 23 [Page 35]: 8.7.d, Releases to Media -Updated position coordinating this task from 'Media Center Manager' to 'ENC Manager'. Change 24 [Page 36]: 8.9.a.4, Berrien County Sheriffs Bepartment -Chanaed title of SEC to SEO. Change 25 [Page 37]: 8.9.b, State of Michigan -Updated address of State Emergency Operations Facility (EOC). Change 26 [Page*40]: 8.9.b.2.i, Department of Transportation -Changed title of SEC to SEO. -Updated address of State Emergency Operations Facilitv. Change 27 [Page 45-48]: Figures 5 through 9, Organization Charts for TSC, OSC, EOF and ENC/JIC -Redesigned the four organization charts for Cook's four Emergency Response Facilities. Change 28 [Page 49-50]: Table 1, CNP Staffing for Nuclear Power Plant Emergencies -Completely updated with new titles, as needed, based on responsibilities found in Section 8.5, Emergency Response Organization -Added 'Full Staffing' component. -Added footnotes b (/GP Liaison info), c ('per Security Plan) and d (ENC/JIG clarifications). Page 209 of 212 Justification ADMINISTRATIVE change to title resulting from Change 16. ADMINISTRATIVE change to title resulting from Change 12. ADMINISTRATIVE change to title resulting from Change 18. ADMINISTRATIVE change to title resulting from Change 12:-** ADMINISTRATIVE change due to a change in State EOC address. ADMINISTRATIVE change to title resulting from Change 12. ADMINISTRATIVE change due to a change in State EOC address. ADMINISTRATIVE change to align the positions design from Changes 12, 14, 16 and 18 with a complete organization chart representing each facility. This resulted in the addition of a Figure 6. No marQin marks used. MAJOR change to Table 1 (NUREG-0654 Table 8-1). -The on-shift staffing was not impacted. -Augmenting ERO was changed to align the positions design from Changes 12, 14, 16 and 18. -The full staffing component was added to give a complete picture to the reader for how minimum staffing is supplemented by full staffing to support the various required functions. -Footnotes were added as clarifications from Changes 12, 14, 16 and 18. This Table 1 was provided as part of 50.54(q) #17-50 and approved by PORC on 1/12/2018. No marain marks used. CEP Rev 39 ./ Page 210 of 212 Alteration Justification Change 29 [Page 52]: C.1.a, Requesting ADMINISTRATIVE change to title resulting Federal Assistance from Change 12. -Chanqed title of SEC to SEO. Change 30 [Page 54]: C.2.b, Liaisons from . EDITORIAL change to section numbering CNP due to other changes. No change to details in -Updated section numberinq only. this section were made.
Change 31 [Page 57]: D, Emergency ADMINISTRATIVE change to title resulting Classification System from Change 12. -Chanqed title of SEC to SEO. Change 32 [Page 59]: Table 2, Fission ADMINISTRATIVE change to title resulting Product Barrier Matrix from Change 12. -Changed title of SEC to SEO in 1.4, 2.6 and 3.8 EAL's. No margin marks used.

Change 33 [Page 61]: Table 3, Initiating ADMINISTRATIVE change to title resulting Conditions Mode 1-4 from Change 12. -Chanqed title of SEC to SEO in H-1 EAL. ** No marQin marks used. .. Change 34 [Page 66]: Table 4, Initiating ADMINISTRATIVE change to title resulting Conditions Mode 5-6 and Defueled from Change 12. ..,Chanqed title of SEC to SEO in H-1 EAL. No margin marks used . Change 35 [Page 71]: E.1 Notification of ADMINISTRATIVE change to title resulting Offsite Response Organizations from Change 12. -Changed title of SEC to SEO in three paraqraphs.
Change 36 [Page 73]: E.2.a and b, Onsite ADMINISTRATIVE change to title resulting and Offsite Staff from Change 12. -Chanqed title of SEC to SEO. Change 37 [Page 77-78]: Figures 10 and 11 EDITORIAL change necessary to figure -Updated figure numbering only. numbering due to adding Figure 6 per Change 27. No marqin marks used. Change 38 [Page 90]: H.1.c, TSC Staffing ADMINISTRATIVE change to title resulting -ChanQed title of SEC to SEO. from Change 12. Change 39 [Page 92]: H.2.a, EOF Functions ADMINISTRATIVE changes to titles resulting -Changed titles from 'EOF EDS Manager to from Changes 12 and 16. communicate with Engineering Personnef to 'TSC Manager will work with Logistics ADMINISTRATIVE change to who completes Coordinator to communicate with Engineering this task per Change-12 and' 16. Personnef. Change 40 [Page 93-94]: H.2.d, EOF Design ADMINISTRATIVE change to title resulting -Changed title from 'Communications from Change 16. Director to 'EOF Manager' for who is in charge of communicators and displays. ADMINISTRATIVE change to occupancy -Updated EOF occupancy charting based on chart resulting from Change 16. new ERO desiqn. Change 41 [Page 94]: H.3.a, OSC Functions ADMINISTRATIVE in that names of specific -Removed specific phone bridge names in phone bridge lines are an unnecessary level favor of generically referring to them as of specificity and do not change intent of the 'bridqe lines'. CEP. Change 42 [Page 95]: H.3.b, OSC Location ADMINISTRATIVE change to title resulting -Chanqed title of SEC to SEO. from ChanQe 12. CEP Rev 39 Page 211 of 212 Alteration Justification Change 43 [Page 96]: H.4, AEP ERO ADMINISTRATIVE change to title resulting Staffing and Activation from Change 12. -Chanqed title of SEC to SEO. Change 44 [Page 103]: Figure 11, Locations EDITORIAL charige necessary to figure of Emergency Response Centers numbering due to adding Figure 6 per -Updated figure numbering. Change 27. -Updated map due to change in location of -* North Access Building. ADMINSTRATIVE change to map to update a newly implemented Security North Access Building at the, perimeter of the Protected Area. No margin marks used. Change 45 [Page 104]: Figure 12, CNP EDITORIAL change necessary to figure Emergency Response Center Locations numbering due to adding Figure 6 per -Updated figure numbering. ., Change-27. ., '" No margin marks used. Change 46 [Page 111-114]: J, .Protective ADMINISTRATIVE change to title resulting Response from Change 12. .. -Changed title of SEC to SEO in eleven locations. Change 47 [Page 116]: Figure 13, CNP EDITORIAL change necessary to figure . Primary Evacuation Routes numbering. due to adding Figure 6 per -Updated figure numbering only. Change 27. \ No margin marks used. Change 48 [Page 119]: K.2, Emergency ADMINISTRATIVE change to title resulting Exposure Authorization and Control from Change 12. -Changed title of SEC to SEO in two locations. Change 49 [Page 127]: M.1, Reentry ADMINISTRATIVE change to title resulting* -Changed title of SEC to SEO. from Change 12. Change 50 [Page 141 & 146]: Appendix 'A' ADMINISTRATIVE: EOF-002 is being
NUREG-0654 to E-Plan Cross Reference deactivated in favor of using EPl-109 for the -Removed RMT-2080-EOF-002 and replaced same function.
with RMT-2080-EPl-109 for K.6.c, M.2 and M.3. Hospital procedure title updated necessary -Updated Lakeland Hospital procedure title. per AR 2018-2018-4. Change 51 [Page 149-165]: Appendix 'B' Required ADMINIS_TRATIVE routine updates Agreements with Offsite Support Agencies [per Cook procedure PMP-2080-EPP-200 -Updated all letters of agreement. No Step 3.2 and GT 2017-8321-1]. changes to agreement content were made. Change 52 [Page 169-180]: Appendix 'D' ADMINISTRATIVE change recommended by Emergency Preparedness Brochure EP Supervisor. This change is to include only -Removed reference to the physical Annual the credited brochure information in the CEP Calendar in favor of adding all of the vice an entire copy of the Annual Cook applicable portions from the calendar that Calendar with every controlled copy of th_e meet this Planning Standard requirement. CEP. No marqin marks used. CEP Rev 39 Alteration Change 53 [Page 186]: Appendix 'E' Description of Federal Assistance -Updated State EOC Address. Change 54 [Page 190]: Appendix 'F' Berrien County Road Map -Removed reference to a physical map within the E-Plan in favor of directing reader to the Berrien County electronic GIS. -Change 55 [Page 200]: Appendix 'J' Eight Year Plan Matrix -Updated 'Eight Year Items' by one year from '2017 to 2024' to '2018 to 2025'. Change 56 [Page 203-205]: Appendix 'K' Agreements with Offsite Agencies for Hazardous Materials Spills -Updated all letters of agreement. No chanqes to aqreement content were made. Change 57 [Page 112]: J.2, Evacuation Routes -Added the fourth evacuation route found on Figure 13 [Page 116]. -Aligned verbiage of all four evacuation routes to that in the NRC Safety Evaluated Cook Emergency Plan (Revision 3). --, Page 212 of 212 Justification ADMINISTRATIVE change due to an update to a State address. ADMINISTRATIVE change in removing a physical map from the CEP and replacing with the Berrien County GIS webpage. Recommended per EP Supervisor to ensure the reader has most accurate Berrien County mapping information. This was also recommended by Berrien County Emergency Management. _ Regulation does not require a physical map to be located in Licensee Emergency Plans*: ADMINISTRATIVE change necessary to ensure the most up-to-date 8-year range is available for planning purposes. No margin marks used. Required ADMINISTRATIVE routine updates [per Cook pro'cedure PMP-2080-EPP-200 Step 3.2 and GT 2017-8321-1]. ADMINISTRATIVE in that this change mostly consisted of aligning verbiage to the license basis emergency plan. -In practice, Cook has always had four possible evacuation routes. -No change to any of the fou-r evacuation routes has been made. -No change to Figure 13 was necessary. CEP Rev 39}}

ML18193A461

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Dear Mr. Sieber:

Dear Mr. Gebbie:

Dear Ladies and Gent_lemen:

Dear Mr. Sieber:

Dear Mr. Gebbie:

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