ML17248A401

Attachments 1 to 8: Palisades Nuclear Plant - License Amendment Request - Emergency Plan Revision to Reflect a Permanently Shut Down and Defueled Reactor Vessel

ML17248A401
Person / Time
Site:	Palisades
Issue date:	08/31/2017
From:	Entergy Nuclear Operations
To:	Office of Nuclear Reactor Regulation
Shared Package
ML17248A389	List: ML17248A401 PNP 2017-034, License Amendment Request - Submittal of Emergency Plan Revision to Reflect a Permanently Shut Down and Defueled Reactor Vessel
References
PNP 2017-034
Download: ML17248A401 (400)

Text

Attachment 1 to PNP 2017-034 Palisades Nuclear Plant Description and Evaluation of the Proposed Changes (35 Pages)

ATTACHMENT 1 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGES 1.0

SUMMARY

DESCRIPTION Pursuant to Title 10 of the Code of Federal Regulations, Part 50, Section 90 (10 CFR 50.90),

Entergy Nuclear Operations, Inc. (ENO) requests U.S. Nuclear Regulatory Commission (NRC) review and approval of a revision to the Palisades Nuclear Plant (PNP) Site Emergency Plan (SEP).

The proposed changes would revise the current PNP SEP and the on-shift and augmented Emergency Response Organization (ERO) staffing to support the pending permanent cessation of power operations at PNP, as certified in Reference 1, and the planned permanent removal of fuel from the PNP reactor vessel. The proposed reduction from current operating on-shift and augmented ERO staffing levels is commensurate with the need to safely store spent fuel at the facility in a manner that is protective of public health and safety.

ENO has reviewed the proposed changes against the planning standards in 10 CFR 50.47(b) and the requirements in 10 CFR Part 50, Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities, and concluded that the standards and requirements would continue to be met. Therefore, no exemption from 10 CFR 50.47 or 10 CFR 50, Appendix E, is requested.

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ATTACHMENT 1 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGES 2.0 DETAILED DESCRIPTION The proposed changes would revise the current PNP SEP and the on-shift staffing and augmented ERO staffing to reflect the pending permanent cessation of power operations (Reference 1) and the planned permanent removal of fuel from the PNP reactor vessel. Specifically, the proposed changes would eliminate the on-shift positions not needed for the safe storage of spent fuel in the spent fuel pool (SFP) during the initial decommissioning period and eliminate the augmented staffing positions not necessary to effectively respond to credible accidents when in a permanently shut down and defueled condition. provides a tabular summary of the proposed changes to the PNP SEP. Attachment 3 provides the revised PNP SEP with the proposed changes shown in markup format. Attachment 4 provides a clean version of the revised PNP SEP. Any additional changes beyond those involving a reduction in staffing in Attachments 2, 3, and 4 are included for informational purposes only and will be dispositioned prior to implementation in accordance with the requirements in 10 CFR 50.54(q), Emergency plans, subparagraph (3), related to emergency preparedness, and specifically to making changes to emergency response plans.

Currently, PNP SEP Figure 5-2, Plant Staffing and Augmentation Requirements, specifies the on-shift and augmented staffing for certain positions in the following Major Functional Areas:

Plant Operations and Assessment of Operational Aspects Emergency Direction Notification and Communication Radiological Accident Assessment and Support of Operational Accident Assessment Radiation Protection Plant System Engineering, Repair and Corrective Actions Field Monitoring Teams Fire Fighting Rescue Operations and First-Aid Site Access Control and Personnel The proposed post-shutdown on-shift and augmented ERO staff will continue to address the Major Functional Areas.

On-Shift Staffing The proposed changes to the PNP SEP will eliminate the following on-shift positions:

One (1) Control Room Supervisor One (1) Shift Engineer/Shift Technical Advisor Two (2) Licensed Nuclear Control Operators Four (4) Non-Licensed Nuclear Plant Operators One (1) Communicator One (1) Radiation Protection Technician One (1) Chemistry Technician The proposed post-shutdown Operations on-shift staff will continue to address the Major Functional Areas and will consist of:

One (1) Shift Manager (qualified as a Certified Fuel Handler (CFH))

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ATTACHMENT 1 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGES Two (2) Non-Certified Operators One (1) Radiation Protection Technician These staffing levels have been considered in the PNP analysis of proposed post-shutdown on-shift staffing in conjunction with the postulated accidents that will be applicable in the permanently shut down and defueled condition. The analysis is provided in Attachment 5 of this submittal.

Use of the title Non-Certified Operator is dependent upon NRC approval of proposed changes to the PNP Renewed Facility Operating License (Reference 2) that revise the minimum shift staffing requirements in the PNP Renewed Facility Operating License by replacing references to licensed and non-licensed operators with references to CFHs and Non-Certified Operators. However, implementation of the changes to the PNP SEP proposed in this submittal is not dependent upon prior NRC approval of the proposed changes to the PNP Renewed Facility Operating License.

An individual qualified as a CFH will supervise fuel handling operations while in the permanently shut down and defueled condition. Shift Managers will be qualified as CFHs. The Shift Manager requires additional qualification beyond the CFH training. Command and Control will remain with the Shift Manager, regardless of location of the individual designated as the Shift Manager.

Non-Certified Operators will perform duties typically associated with those formerly performed by Non-Licensed Nuclear Plant Operators, such as manipulation and monitoring of plant equipment.

Non-Certified Operators will also be assigned to monitor indications and communications in the Control Room. Reference 3 submitted a CFH training program for NRC approval. Reference 13 provided the NRC approval of Reference 3. Dedicated Licensed Nuclear Control Operators will not be utilized while in the permanently shut down and defueled condition.

The Non-Certified Operator position will include the post-shutdown duties of the current Non-Licensed Nuclear Plant Operator. The specific training requirements of the Non-Certified Operator position will be developed by the PNP Training Department and will be reviewed and approved by Operations management. The training program will be designed with an emphasis on systems and processes important to maintaining SFP cooling, and monitoring and controlling SFP parameters, such as SFP water level and temperature. Consequently, the Non-Certified Operators will be trained on pertinent Control Room indications and controls that will be monitored and operated to maintain SFP cooling and SFP water level, in addition to monitoring plant radiological conditions.

The Non-Certified Operator training program will include training on applicable aspects of the PNP SEP-related Non-Certified Operator duties. Non-Certified Operators will be trained and qualified consistent with 10 CFR 50.120, Training and qualification of nuclear power plant personnel, in accordance with ENO training procedures.

Personnel assigned to fill the Non-Certified Operator positions during the post-shutdown period will include both previously licensed and non-licensed operators. Much of the required training for the Non-Certified Operator position will already have been completed by the formerly licensed operators, because they have previously been trained and qualified as Nuclear Control Operators to support power operations. The current Non-Licensed Nuclear Plant Operators have been trained and qualified as non-licensed operators only. Therefore, it is expected that the individuals assigned to fill the Non-Certified Operator positions will require additional training related to Control Room operations.

Once the specific training requirements for the Non-Certified Operator position have been identified, a gap analysis will be completed for all operators identified to fill the Non-Certified Operator position. Individualized training plans will be developed and completed to address Page 3 of 35

ATTACHMENT 1 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGES specific knowledge and skill areas for the selected Non-Certified Operator candidates. This will include training the currently qualified Non-Licensed Nuclear Plant Operators on Control Room indications, controls, and procedures. The initial training for any new Non-Certified Operators will include all training requirements for the Non-Certified Operator position to ensure the personnel are equipped with the required skills and knowledge to perform their required job functions.

The proposed changes to the on-shift organization are identified in the proposed changes to the PNP SEP Figure 5-2, included in Attachments 3 and 4, and are summarized in Attachment 2.

Augmented Emergency Response Organization Staffing The proposed changes to the PNP SEP would eliminate augmented ERO positions currently identified in the PNP SEP, Figure 5-2 and Emergency Plan Implementing Procedures (EPIPs) describing the activation and operation of the Technical Support Center (TSC), Emergency Operations Facility (EOF), Operations Support Center (OSC), and Joint Information Center (JIC).

Specific augmented ERO positions proposed for elimination are identified in Table 1 of this attachment.

Currently, PNP SEP, Figure 5-2 specifies the on-shift and augmented staffing for certain positions in the Major Functional Areas identified above. The proposed changes to the PNP SEP would eliminate the following augmented positions identified in Figure 5-2:

State/County Communicator Chemistry Technician Four (4) Radiation Protection (RP) Technicians Core/Thermal Hydraulic Engineer Electrical Engineer Mechanical Engineer OSC Craft (one Electrical Maintenance Technician and one Instrument and Control (I&C)

Technician)

Radwaste Operator After permanent cessation of power operations and certification of permanent removal of fuel from the reactor vessel, in accordance with 10 CFR 50.82(a)(1)(i) and (ii), and pursuant to 10 CFR 50.82(a)(2), the 10 CFR Part 50 license will no longer authorize reactor operation or emplacement or retention of fuel in the reactor vessel. Thus, the need for augmenting engineers is reduced.

The Engineering Coordinator in the TSC, tasked with performing engineering assessments of plant conditions and actions needed to mitigate damage to the plant, will provide the Major Task of Technical Support in the Major Functional Area of Plant System Engineering, Repair, and Corrective Actions in Figure 5-2. With respect to responding to engineering requests from the Engineering Coordinator, this function will continue to be performed by augmenting qualified engineering resources. The Engineering Coordinator will continue to continuously evaluate the need for engineering resources and coordinate with the EOF Technical Advisor to call in qualified engineering personnel. These individuals may be tasked with activities to be completed at engineering offices external to the TSC, called to report to the TSC, or directed to other facilities.

The OSC Craft (Electrical and Mechanical) functions will continue to be performed by augmenting resources. PNP will maintain trained and qualified I&C personnel to respond to an emergency.

These resources are discussed in more detail in Section 3.2.2.2.

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ATTACHMENT 1 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGES 2.1. Reason for the Proposed Changes The proposed changes reflect the pending permanent cessation of power operations, which is anticipated to occur on October 1, 2018 (Reference 1), and the planned permanent defueling of the PNP reactor. After the reactor is permanently shut down, all fuel assemblies will be removed from the reactor vessel and placed in the SFP. The irradiated fuel will be stored in the SFP and in the Independent Spent Fuel Storage Installation (ISFSI) until it is removed by the Department of Energy (DOE). Upon docketing of the certifications for permanent cessation of power operations (10 CFR 50.82(a)(1)(i)) and permanent removal of fuel from the reactor vessel (10 CFR 50.82(a)(1)(ii)), pursuant to 10 CFR 50.82(a)(2), the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel into the reactor vessel.

The proposed revisions to the PNP SEP are commensurate with the reduction in hazards associated with the permanently shut down and defueled condition, and will allow PNP to transition from an appropriate staffing level required for an operating facility to staffing levels required for a permanently shut down and defueled facility. The proposed changes are required to properly reflect the conditions of the facility while continuing to maintain the effectiveness of the PNP SEP and preserve the PNP Decommissioning Trust Fund.

2.2. Background The on-site emergency plan standards in 10 CFR 50.47(b)(2) state, in part, that on-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, [and]

timely augmentation of response capabilities is available.

NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, (Reference 4),Section II.B, Onsite Emergency Organization, presents guidance for meeting the planning standards and requirements of 10 CFR 50.47(b) and 10 CFR 50, Appendix E, Section IV.A. The guidance describes the onsite emergency organization, including the staffing requirements found in Table B-1, Minimum Staffing Requirements for NRC Licensees for Nuclear Power Plant Emergencies. This table specifies a minimum of ten on-shift responders in four Major Functional Areas. It also specifies seven on-shift response functions where the duties may be performed by shift personnel who are assigned other functions (i.e., there are no dedicated responders to perform these functions). Table B-1 specifies two Major Functional Areas (i.e., firefighting and site access control/personnel accountability) which must be staffed on a site-specific basis.

The on-shift staff must be able to cope with a spectrum of events until augmenting personnel arrive in accordance with the sites emergency plan commitments. The augmenting responders assume managerial, engineering, and administrative duties from the on-shift personnel, allowing on-shift personnel to focus on their assigned functions.

On November 23, 2011, the NRC published a final rule in the Federal Register amending certain emergency preparedness requirements in its regulations that govern domestic licensing of production and utilization facilities (Reference 5). This final rule amended 10 CFR Part 50, Appendix E, Section IV.A, Organization, to address the assignment of tasks or responsibilities to on-shift ERO personnel that could potentially overburden them and prevent the timely performance of their emergency plan functions. Specifically,Section IV.A.9 states that licensees shall perform a detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan.

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ATTACHMENT 1 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGES Coincident with the rule change in 10 CFR Part 50, Appendix E, Section IV.A.9, the NRC issued NSIR/DPR-ISG-01, Interim Staff Guidance - Emergency Planning for Nuclear Power Plants (ISG-

01) (Reference 6). This Interim Staff Guidance (ISG) provides information relevant to performing the on-shift staffing analysis. The ISG states that the NEI developed NEI 10-05, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities, (Reference 7) to establish a standard methodology for a licensee to perform the required staffing analysis, and that the NRC reviewed NEI 10-05 and found it to be an acceptable methodology for this purpose. The ISG also indicates that the completed staffing analyses are required to be part of the emergency plan and the results documented and submitted to the NRC in accordance with 10 CFR 50.54(q)(5) for review.

2.3 PNP Specific Background On-Shift Staffing In August 2015, PNP updated its On-Shift Staffing Analysis in accordance with the NEI 10-05 guidance to satisfy the requirements of 10 CFR 50, Appendix E Section IV.A.9. This analysis examined the capability of the minimum on-shift staff provided in Figure 5-2 of the PNP SEP to perform the key emergency response actions for events described in NSIR/DPR-ISG-01 until augmenting staff arrive. The analysis was conducted by a cross disciplinary team of corporate Emergency Preparedness personnel and station personnel from the Operations, Training, Radiation Protection, Chemistry, Engineering, Regulatory Assurance, and Emergency Planning departments. Additionally, members of the Security staff provided input to the analysis.

The emergency response to each of the events described in NSIR/DPR-ISG-01 was determined by conducting a tabletop of the event using the emergency plan and procedures and the applicable departmental procedures such as emergency and abnormal operating procedures.

Each scenario was reviewed by the cross disciplinary team to determine the required plant actions and emergency plan implementation actions based on plant procedures prior to staff augmentation. These actions were then compared to the minimum on-shift staffing for emergency response implementation as described in Figure 5-2 of the PNP SEP, ensuring that no actions were assigned to staff members that conflicted with either their dedicated emergency response role or their dedicated operational role, as appropriate. In cases where multiple tasks were assigned to an individual, the team evaluated the timing of the tasks to ensure that they could be performed by the individual in series within any specified time requirements. The Design Basis Accident (DBA) scenarios considered in the analysis were the Design Basis Threat (DBT), control rod ejection accident, small line break outside containment, loss of coolant accident (LOCA), fuel handling accident (FHA), main steam line break inside containment (MSLB) accident, waste tank rupture, aircraft probable threat, Control Room fire requiring evacuation and remote shutdown, station blackout, and steam generator tube rupture (SGTR) with concurrent loss of off-site power.

The analysis concluded that an on-shift staff of fifteen (15) is required to respond to the most limiting accident scenario reviewed, which was determined to be the aircraft probable threat.

PNP SEP Figure 5-2 specifies the minimum staffing requirements for the PNP on-shift staff, defines the positions initially responsible for satisfying key ERO functions, and specifies positions that will augment the on-shift staff.

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ATTACHMENT 1 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGES Augmented Emergency Response Organization Staffing The PNP SEP defines four classes of emergency events: Notification of Unusual Event (UE), Alert, Site Area Emergency (SAE) and General Emergency (GE). Because on-shift personnel can normally address an emergency response to UEs without additional support, staff augmentation may not be activated for an UE declaration. The Operations Shift Manager maintains command and control responsibility during UEs, unless the EOF has been activated. An Alert declaration results in the activation of the EOF, TSC, OSC, and discretionary activation of the JIC. All Emergency Response Facilities (ERFs) are activated at a SAE or GE declaration. Overall responsibility for the event is assumed by the Emergency Director in the EOF when the EOF is declared operational. When the ERO is activated, notification is sent to those required to respond to their assigned ERF.

PNP SEP, Section 5.0, Organizational Control of Emergencies, describes how the normal plant operating organization transitions into an ERO to effectively deal with any incident at PNP.

The PNP onsite emergency organization is described in Section 5.3, Palisades Emergency Response Organization, and the operating and engineering organization is described in Section 5.2 of the PNP SEP. If initiating conditions exist that result in the declaration of an emergency, the Shift Manager assumes the role of Emergency Director and is responsible for emergency direction and coordination. The normal operating organization assumes their pre-assigned emergency response roles. This is considered to be a short-term response organization that will be augmented within one hour after call-out by additional plant personnel.

If an Alert, SAE, or GE is declared, or if the minimum shift crew requires assistance during an UE, the onsite emergency organization will be augmented by additional plant personnel as described in Section 5.3 of the PNP SEP, Palisades Emergency Response Organization. The PNP SEP describes the augmented emergency organization that will staff and operate the EOF, TSC, OSC, and JIC within one hour of the request for activation.

Plans and procedures have been put into place to ensure the timely activation of emergency response facilities. PNP SEP Figure 5-1 identifies the interfaces among the various emergency organizations.

3.0 TECHNICAL EVALUATION

3.1 Accident Analysis Chapter 14 of the PNP Final Safety Analysis Report (FSAR) describes safety analyses for postulated DBAs under which the PNP is licensed. Upon docketing of the certifications required by 10 CFR 50.82(a)(1)(i) and (ii), the 10 CFR Part 50 license for PNP will no longer authorize operation of the reactor or emplacement or retention of fuel into the reactor vessel, as specified in 10 CFR 50.82(a)(2). Therefore, most of the accident scenarios postulated in the FSAR will no longer be applicable once PNP is in the permanently shut down and defueled condition.

The postulated DBAs that will remain applicable to PNP in its permanently shut down and defueled condition are the Cask Drop in the SFP (FSAR Section 14.11) and a FHA in the SFP area (FSAR Section 14.19). FSAR Section 14 will be revised to eliminate the DBAs that will not be applicable in the permanently shut down and defueled condition.

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ATTACHMENT 1 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGES It was determined that no emergency declaration would be expected for the FSAR Section 14.11 event. Therefore, the FSAR Section 14.11 event was not considered in the analysis of proposed post-shutdown on-shift staffing. Additionally, the Station Blackout (SBO) event was not considered in the analysis of proposed post-shutdown on-shift staffing. Once the certifications required by 10 CFR 50.82(a)(1)(i) and (ii) are docketed, PNP will no longer be licensed to operate and 10 CFR 50.63 (the SBO rule) will no longer be applicable pursuant to 10 CFR 50.63(a)(1).

An evaluation was performed to determine if sufficient on-shift staffing would be available to implement emergency response actions in response to potential aircraft impacts in accordance with 10 CFR 50.54(hh)(1). In the permanently shut down and defueled condition, the Fire Brigade will relocate away from target areas and prepare for reentry. The task of maintaining communications during this event are transferred to the Non-Certified Operator trained and qualified to perform this function. Therefore, sufficient staffing is available to promptly implement response actions required under 10 CFR 50.54(hh)(1) without impacting the performance of designated emergency plan functions.

In the permanently shut down and defueled condition, the PNP Fire Brigade will be responsible for implementing the SFP inventory makeup strategies required under 10 CFR 50.54(hh)(2). PNP will continue to maintain a trained and qualified Fire Brigade responsible for implementation of the SFP inventory makeup strategies. The Fire Brigade personnel identified in the PNP Post-Shutdown Emergency Plan (PSEP) are separate and distinct from those responsible for implementing the major elements of the emergency plan including command and control, emergency classification, offsite notifications, and dose assessment/protective action recommendation development.

Therefore, sufficient staffing is available to promptly implement SFP inventory makeup strategies required under 10 CFR 50.54(hh)(2) without impacting the performance of designated emergency plan functions.

As described in Section 3.2.2.2, events involving a loss of SFP cooling and/or water inventory can be addressed by implementation of SFP inventory makeup strategies required under 10 CFR 50.54(hh)(2). These strategies will continue to be maintained to satisfy applicable portions of Condition 2.C.(6).b of the PNP Renewed Facility Operating License.

3.2 Analysis of Proposed Changes 3.2.1 On-Shift Staffing To support reduced staffing following permanent cessation of power operations and permanent removal of fuel from the reactor vessel, the proposed post-shutdown on-shift staffing was evaluated in conjunction with the postulated accidents that could occur in the permanently shut down and defueled condition (Attachment 5). The analysis of proposed post-shutdown on-shift staffing considered the cask drop in the SFP (FSAR Section 14.11) and the FHA as the applicable DBAs. The analysis of proposed post-shutdown on-shift staffing concluded that in a permanently shut down and defueled condition one on-shift Shift Manager, two Non-Certified Operators, and one Radiation Protection Technician can perform all required Emergency Plan actions in a timely manner and there are no collateral duties that would prevent the timely performance of emergency plan functions. The Fire Brigade complement considered in the analysis of proposed post-shutdown on-shift staffing was consistent with the requirements from the Fire Hazard Analysis.

Accident Scenarios For the analysis of proposed post-shutdown on-shift staffing, the following accident scenarios were considered:

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ATTACHMENT 1 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGES Design Basis Threat The event evaluated for this analysis assumes a land based threat that is neutralized immediately when inside the protected area fence, no significant damage to equipment or systems that require corrective actions before the augmented ERO is staffed, no radiological release, and no fire that requires firefighting response before the augmented ERO is staffed.

Fuel Handling Accident The DBA FHA is assumed to occur as a consequence of a failure of the fuel assembly lifting mechanism, resulting in the dropping of a raised fuel assembly onto stored fuel bundles. The FHA is assumed to occur in containment two days after shutdown. An Alert emergency declaration was assumed to be declared due to the event.

Aircraft Probable Threat (50.54(hh))

Notification is received from the NRC that a probable aircraft threat exists (>5 minutes, <30 minutes).

Control Room Fire Requiring Evacuation and Maintain SFP Cooling A fire occurs in the Control Room requiring the evacuation and actions implemented to control spent fuel pool cooling from a remote location.

General Emergency (GE) with radioactive release and PAR (assumed for analysis purposes)

This event is based on the same initial conditions as the FHA, but assumes a dose that exceeds the Environmental Protection Agencys (EPA) Protective Action Guides (PAGs) beyond the site boundary, and thus necessitates promulgation of a PAR.

In addition to the events described above, a Cask Drop in the SFP (FSAR Section 14.11) analyzed dropped cask events and determined that no emergency declaration would be expected for this event.

The analysis of proposed post-shutdown on-shift staffing indicates that the proposed on-shift personnel can satisfactorily implement all emergency plan functions as required by regulation without augmented personnel for at least 90 minutes following an emergency declaration. The analysis confirmed that no chemistry job tasks were noted as being required within the first 90 minutes of any of the analyzed events. The 90-minute capability exceeds the PNP SEP requirements that augmented staff respond in 60 minutes. ENO is not requesting an extension to the current 60-minute augmentation capability.

The proposed on-shift staffing changes do not impact the capabilities of the on-shift staff to respond to an emergency and continues to comply with the PNP SEP, site commitments, and applicable regulations.

Additional analysis for each of the proposed on-shift staffing changes associated with PNP SEP Figure 5-2 is provided for each major functional area in Sections 3.2.1.1 through 3.2.1.10.

Additionally, because Figure 5-2 of the PNP SEP includes 60-minute and 90-minute staff Page 9 of 35

ATTACHMENT 1 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGES augmentation capabilities, the proposed revisions to the ERO impacting each major functional area are also addressed in Sections 3.2.1.1 through 3.2.1.10.

3.2.1.1 Major Functional Area: Plant Operations and Assessment of Operational Aspects Current Staffing Requirement During normal operations, the minimum staff on duty at the plant during all shifts to satisfy this Major Functional Area consists of:

One (1) Control Room Supervisor One (1) Shift Engineer/Shift Technical Advisor One (1) Shift Manager Two (2) Licensed Nuclear Control Operators Six (6) Non-Licensed Nuclear Plant Operators Proposed Change The proposed changes to the PNP Emergency Plan will eliminate the following on-shift positions:

One (1) Control Room Supervisor One (1) Shift Engineer/Shift Technical Advisor Two (2) Licensed Nuclear Control Operators Four (4) Non-Licensed Nuclear Plant Operators Credited on-shift personnel will consist of one Shift Manager and two Non-Certified Operators. Use of the titles, CFH and Non-Certified Operator, are dependent upon NRC approval of proposed changes to the PNP Technical Specifications (Reference 2).

Implementation of the PNP PSEP, as proposed for revision in this submittal, is not dependent upon prior NRC approval of the proposed changes to the PNP Technical Specifications.

Analysis Because of the reduced number of possible events requiring mitigating actions in the permanently shut down and defueled condition and the limited number of actions to be performed by the Control Room positions in a permanently shut down and defueled condition, no Licensed Nuclear Control Operators or Shift Engineer/Shift Technical Advisor job tasks were noted as being required for any of the events analyzed in the analysis of proposed post-shutdown on-shift staffing. Therefore, the Licensed Nuclear Control Operator and Shift Engineer/Shift Technical Advisor positions can be eliminated without reducing the effectiveness of the PNP SEP.

The regulatory standard for minimum staffing requirements for NRC licensees is documented in NUREG-0654. The total minimum on-shift staffing expressed in NUREG-0654, Table B-1, is ten personnel. Plant Operations shift staffing, as implemented previously, was based on an operating philosophy that provided defense in depth. The analysis of proposed post-shutdown on-shift staffing concluded that in a permanently shut down and defueled condition, the on-shift Shift Manager and two Non-Certified Operators can perform all required PSEP actions in a timely manner and there are no collateral duties Page 10 of 35

ATTACHMENT 1 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGES that would prevent the timely performance of emergency plan functions. Therefore, this deviation from the guidance presented in NUREG-0654, Table B-1 is acceptable.

3.2.1.2 Major Functional Area: Emergency Director Current Staffing Requirement The minimum staff on duty at the plant during all shifts to satisfy this Major Functional Area consists of the Shift Manager.

Proposed Change No proposed changes in staffing.

Analysis PNP proposes no changes to the Emergency Director staffing.

3.2.1.3 Major Functional Area: Notification/Communication Major Tasks: Notify licensee, State, Local, and Federal personnel and maintain communications Current Staffing Requirement The Shift Manager and an on-shift Communicator perform the function of on-shift notification/communication.

Augmentation of the notification/communication capability is accomplished by the Offsite Communicator and the State/County Communicator in the EOF, and the ENS Communicator in the TSC within 60 minutes.

Proposed Change Replace the On-shift Communicator with a Non-Certified Operator.

Elimination of the augmenting EOF State/County Communicator position.

Analysis This function is currently performed by an on-shift staff position performing emergency plan Communicator requirements. This function is currently augmented by TSC and EOF designated communications positions when those facilities assume communications responsibilities.

Initial notification to offsite authorities are required to occur within 15 minutes of declaration of an emergency and initial NRC notification is required to occur immediately after notification of the appropriate State or County agencies and not later than 60 minutes after the time of the emergency declaration. Subsequent notifications are made, should the event escalate and to provide informational updates. The resource commitment to support the communication function is not full time so there is time to support performance of collateral duties during the first 60 minutes until staff augmentation can occur. The on-shift and offsite Page 11 of 35

ATTACHMENT 1 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGES communicators have advanced communications capabilities available as illustrated in PNP SEP Table 7-1, Palisades SEP Communications Matrix. Communications with the NRC take place over dedicated telephone lines provided for and maintained by the NRC (Emergency Notification System (ENS)). For purposes of the analysis of proposed post-shutdown on-shift staffing, NRC notifications were treated as a continuous action in accordance with 10 CFR 50.72(c)(3), meaning that once the initial NRC communications are established, it was assumed that the NRC will request an open line to be continuously maintained with the NRC Operations Center. The use of dedicated phone circuits and headsets enables these notifications to be performed by the same on-shift communicator who performs the State and County notifications.

The Shift Manager initially approves the content of the communication with the State and Federal agencies until relieved of this function by the EOF. The PNP SEP goal is to activate the EOF within approximately 60 minutes. The EOF assumes the communication responsibility concurrent with activation. Therefore, the current communication protocol may remain within the Control Room for the first 60 minutes, regardless of the presence of any prior ERO augmentation.

The elimination of the State/County Communicator position in the EOF does not impact the capabilities of the on-shift staffing or augmented response. The position can be eliminated without placing an undue burden on the remaining ERO positions in the EOF and without increasing the risk to public health and safety. Attachment 6 contains an analysis of all ERO positions proposed for elimination and evaluates the transfer of tasks currently assigned to the State/County Communicator following permanent cessation of power operations and permanent removal of fuel from the reactor vessel. The EOF will continue to be activated at an Alert or higher declaration. Functional responsibilities of the State/County Communicator position are either currently performed by other positions or will be reassigned to remaining positions. The proposed ERO staffing reductions continue to address the risks to public health and safety, comply with the PNP SEP, site commitments, and applicable regulations.

In the post-shutdown condition, the task of notifying and communicating with offsite authorities will be transferred to the Non-Certified Operators. This change is acceptable because the analysis of proposed post-shutdown on-shift staffing concluded that in a permanently shut down and defueled condition, the Non-Certified Operator can perform this required PNP SEP action in a timely manner and there are no collateral duties that would prevent the timely performance of this emergency plan function.

3.2.1.4 Major Functional Area: Radiological Accident Assessment and Support of Operational Accident Assessment Major Tasks: Emergency Operations Facility (EOF) Director, Offsite Dose Assessment, and Chemistry/Radiochemistry Current Staffing Requirement On-shift Senior Radiation Protection Expertise (provided by shift personnel assigned other functions)

On-shift Chemistry Technician Augmentation with the Senior Manager (EOF Director) within 60 minutes Page 12 of 35

ATTACHMENT 1 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGES Augmentation with Senior Radiation Protection expertise within 60 minutes (Radiological Assessment Coordinator in TSC or Radiological Assessment Coordinator in EOF)

Augmentation with one Chemistry Technician within 60 minutes Proposed Change Elimination of the on-shift Chemistry Technician.

Elimination of the augmenting Chemistry Technician.

Analysis The elimination of the on-shift and augmenting Chemistry Technician positions does not impact the ability of the on-shift or augmented ERO to perform dose assessment. The analysis of proposed post-shutdown on-shift staffing concluded that in a permanently shut down and defueled condition, the on-shift Shift Manager and two Non-Certified Operators can perform all required PNP SEP actions in a timely manner and there are no collateral duties that would prevent the timely performance of emergency plan functions. Control Room personnel can perform initial dose assessment using existing EPIPs.

Currently, the Chemistry Technician is an on-shift position per PNP SEP Figure 5-2 so that a technician is always available to immediately collect and analyze a liquid sample if the applicable radiation monitor is not available during a release, or as directed by the Shift Manager. When the on-shift Chemistry Technician position is eliminated, the on-shift Radiation Protection Technician will be able to perform sampling and analysis, so as not to delay information potentially needed by the Shift Manager to determine if an emergency declaration is required. A gap analysis will be performed to determine any differences between current Radiation Protection Technician training requirements and any new specific knowledge requirements associated with emergency plan sampling and analysis.

Such specific knowledge requirements would include how to obtain specific liquid samples.

For gaseous releases, the only credible scenario for releasing gas would be to mechanically damage spent fuel during handling or by impact of a heavy object. Activities that could cause mechanical damage will require that a Chemistry Technician be on-site or the radiation monitor listed in gaseous effluent Emergency Action Levels (EALs) is in service, thereby alleviating any reliance on a potentially delayed sample analysis to determine EAL applicability. A new regulatory commitment to revise applicable fuel handling procedures to incorporate this prerequisite is included in Attachment 7.

Once the specific training requirements for the Radiation Protection Technician position have been identified using a systems approach to training, as required by 10 CFR 50.120, a formal gap analysis will be completed for all personnel identified to fill the Radiation Protection Technician position. Individualized training plans will be developed and completed to address specific knowledge and skills areas for each of the selected Radiation Protection Technician candidates. The initial training for all incumbent Radiation Protection Technicians will include all training requirements to perform liquid sampling and analysis to support an emergency declaration.

The initial training requirements for any new Radiation Protection Technician will include all training modules to ensure they are equipped with the required skills and knowledge to perform the required liquid sampling and analysis. These training modules will be specifically identified in the training program description for the Radiation Protection Page 13 of 35

ATTACHMENT 1 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGES Technician position. This document will be developed in accordance with the requirements of 10 CFR 50.120.

Based on the above, the proposed change in on-shift operations staffing and elimination of the on-shift Chemistry Technician are appropriate given the cessation of power operations and permanent removal of fuel from the reactor vessel.

3.2.1.5 Major Functional Area: Radiation Protection Major Tasks: Radiation Protection Tasks: a. Offsite Surveys, b. Onsite (Out-of-Plant)

Surveys, c. In-Plant Surveys, d. Access Control, e. RP Coverage, f. Personnel Monitoring,

g. Dosimetry Current Staffing Requirement Two on-shift Radiation Protection Technicians.

Augmentation by three Radiation Protection Technicians within 60 minutes.

Augmentation by an additional three Radiation Protection Technicians within 90 minutes.

Proposed Change Eliminate one on-shift Radiation Protection Technician position.

Eliminate one 60-minute augmenting Radiation Protection Technician position.

Eliminate three 90-minute augmenting Radiation Protection Technician position.

Analysis The function of these resources is to provide radiation protection oversight of the on-shift complement of personnel and augmented personnel who are expected to respond to emergency events for damage repair, corrective actions, search and rescue, first aid, firefighting and personnel monitoring. They can also be expected to provide for access control and the issuance of dosimetry.

PNP will no longer be an operating nuclear power plant. In accordance with 10 CFR 50.82(a)(1), pursuant to 10 CFR 50.82(a)(2), the Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel. With irradiated fuel being stored in the SFP and ISFSI, the spectrum of credible accidents and operational events, and the quantity and complexity of activities required for the safe storage of spent nuclear fuel is reduced as compared to an operating plant. The risk in the permanently shut down and defueled condition is significantly reduced because many of the potential initiating conditions that would lead to an emergency declaration will no longer be possible and the elimination of credible accidents involving an operating reactor provides additional time to plan and execute assessment and mitigation actions. If additional resources are determined to be necessary during an emergency, PNP maintains the necessary staffing to provide sufficient personnel trained in radiation protection to respond and perform the required actions, if necessary, in the post-shutdown condition.

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ATTACHMENT 1 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGES During a declared emergency, RWPs and dose setpoints will change depending on the emergency situation and plant conditions. Both systems have been used by plant workers for several years. Worker dose margins and training qualifications are also automatically verified when the RWP access control system is used. If a worker's dose margin is inadequate or training is expired, the workers access would be precluded and the access control system would not allow issuance of an electronic dosimeter. In an emergency situation, approval to exceed dose margins is required. During the log-in process, workers acknowledge their electronic dosimeter alarm setpoints and that they have read and understand their radiation work permit. The electronic dosimeter provides the worker with a continuous status of dose received and work area dose rates, and will alarm at preset dose and dose rate alarms. Worker use of electronic dosimeters facilitates more efficient use of Radiation Protection (RP) Technicians to provide RP coverage while preserving the ALARA concept. Access control is maintained because the worker must obtain an electronic dosimeter and enter a radiation work permit number into the access control computer system prior to being allowed access into the Radiologically Controlled Area (RCA). No setup is required for the radiation work permit access control computers, which allows RP Technicians to be used for more critical tasks during emergency response. Personnel are required to self-monitor for radioactive contamination whenever they exit the RCA. No RP involvement is necessary for this contamination monitoring activity because workers are trained to perform this task without supervision or oversight. However, contaminated personnel exiting the RCA will require RP oversight.

The analysis of proposed post-shutdown staffing concluded that in a permanently shut down and defueled condition, Non-Certified Operators can perform this required action in a timely manner and there are no collateral duties that would prevent the timely performance of this task.

RP coverage will only be performed if the radiological status of a room is unknown and there is a definitive need for emergency workers to enter the room to perform a task. The decision to provide RP coverage may be based on plant radiological conditions as indicated by installed area radiation monitors (ARMs).

During the initial stages of an accident, not all areas of the plant would be affected by releases of radioactive materials. Therefore, RP coverage would not be required for all areas. Because entry is expected to be limited to those areas where maintenance necessary to maintain SFP cooling is required and the areas potentially affected by an accident involving the SFP are limited, there is a significant decrease in areas potentially requiring RP coverage in a permanently shut down and defueled condition. If RP coverage is deemed necessary, multiple emergency teams can be covered by the on-shift RP Technician. If RP coverage is not provided (for entry into areas with low radiological risk or known radiological status), worker protection is ensured because emergency workers are required to wear electronic dosimeters (which will alarm at preset dose and dose rate setpoints) and because of the installed ARMs (which alarm locally and remotely at preset dose rates) located throughout the plant.

Tasks requiring the issuance of dosimetry are not expected in the initial stages of an event, but during the recovery phase. Prior to self-issuance of dosimetry, workers are assigned a RWP, setpoints are adjusted, and briefings are conducted by RP.

The analysis of proposed post-shutdown on-shift staffing determined there are no time critical RP or chemistry tasks, and that task performance is directed and prioritized by the Shift Manager for the 90-minute time frame used in the analysis. There are no overlapping Page 15 of 35

ATTACHMENT 1 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGES RP or chemistry tasks. RP tasks were able to be performed without augmented personnel in the 90-minute time frame used in the analysis.

Activities related to the conduct of surveys or radiological assessment of the area surrounding PNP are performed by the Field Team Technicians identified in the Field Monitoring Team (FMT) Major Functional Area of Figure 5-2 of the PNP SEP, independent of the augmenting RP Technician positions.

PNP proposes reducing the number of augmenting RP Technicians listed in the Major Functional Area of Radiation Protection in Figure 5-2 of the PNP SEP from six to two. As previously described, the spectrum of credible accidents and operational events, and the quantity and complexity of activities required for the safe storage of spent nuclear fuel is reduced as compared to an operating plant. The risk in the permanently shut down and defueled condition is significantly reduced because many of the potential initiating conditions that would lead to an emergency declaration will no longer be possible and the elimination of credible accidents involving an operating reactor provides additional time to plan and execute assessment and mitigation actions.

3.2.1.6 Major Functional Area: Plant System Engineering, Repair and Corrective Actions Major Tasks: Technical Support, Repair, and Corrective Actions Current Staffing Requirement The on-shift Shift Engineer/Shift Technical Advisor performs the major task of Technical Support.

Augment the on-shift core/thermal hydraulics capability by one within 60 minutes (TSC Reactor Engineer).

Augment the Shift Engineer/Shift Technical Advisor with the Mechanical Engineer and Electrical Engineer within 60 minutes.

OSC staff (Mechanical Maintenance, Radwaste Operator, Electrical Maintenance, I&C Technicians) augmentation within 60 minutes to perform repair and corrective actions.

Proposed Change Eliminate the on-shift Shift Engineer/Shift Technical Advisor position.

Eliminate the TSC Reactor Engineer ERO position.

Replace the Mechanical Engineer and Electrical Engineer ERO positions with the Engineering Coordinator ERO position (augmenting within 60 minutes).

Eliminate the Radwaste Operator, one Electrical Technician, and the I&C Technician from Repair and Corrective Action staffing (augmenting within 60 minutes).

Analysis The Shift Engineer/Shift Technical Advisor performs independent assessments of plant operating concerns, technical support, appropriate corrective actions, analysis of events Page 16 of 35

ATTACHMENT 1 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGES and their effects, effectiveness of response(s) to emergent conditions, classifications of emergencies, protection of the public, and any other actions related to critical safety functions and plant safety during abnormal and emergency situations. The Shift Engineer/Shift Technical Advisor also contributes to operations during normal plant conditions. By routine monitoring of equipment and plant operations, the Shift Engineer/Shift Technical Advisor can focus on preventative actions to mitigate the consequences of an accident.

Because of the permanent cessation of power operations and permanent removal of fuel from the reactor vessel, the Shift Engineer/Shift Technical Advisor position is no longer necessary for technical and analytical assistance. The Technical Support function will be assumed by the remaining Control Room personnel.

The analysis of proposed post-shutdown on-shift staffing concluded that the on-shift Shift Manager and two Non-Certified Operators can perform any required technical analysis, until augmented by the TSC, in a timely manner and there are no collateral duties that would prevent the timely performance of this task.

The function of the TSC Reactor Engineer is to provide confirmation of adequacy of core cooling, maintenance of coolable core geometry, and to verify that actual plant response to the event is as expected. This function is initially performed by the on-shift Shift Engineer/Shift Technical Advisor under the guidance of the Shift Manager. The TSC Reactor Engineer position can be eliminated without increasing the risk to public health and safety because the major task of evaluating core/thermal hydraulics is not necessary in a permanently shut down and defueled condition.

The primary duties of the TSC Engineer positions include: responding to engineering requests from the Engineering Coordinator, evaluating the implementation of Severe Accident Management Guidelines, and assisting the OSC in preparing to send repair teams into the plant. These duties are either no longer necessary in a permanently shut down and defueled condition or will be performed by other members of the post-shutdown ERO.

The Engineering Coordinator is tasked with performing an engineering assessment of plant conditions and/or actions needed to mitigate damage to the plant. With respect to responding to engineering requests from the Engineering Coordinator, this function will continue to be performed by augmenting qualified engineering resources. The Engineering Coordinator will continuously evaluate the need for engineering resources and coordinate with the EOF Technical Advisor to call in additional qualified engineering personnel. These individuals may be tasked with activities to be completed at engineering offices external to the TSC, called to report to the TSC, or directed to other facilities.

Engineering resources will continue to be available as augmented positions with specific training and qualification requirements for assigned personnel in accordance with the site training program. The required training courses and requalification frequencies will be unchanged in the post-shutdown condition. However, these positions will no longer be identified as on-call positions. The elimination of the TSC Engineer positions is justified because the spectrum of credible accidents and operational events, and the quantity and complexity of activities required for the safe storage of spent nuclear fuel is reduced as compared to an operating plant. The set of plant equipment required in the permanently shut down and defueled condition is also greatly reduced, which reduces the assessment and mitigation activities the TSC must perform.

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ATTACHMENT 1 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGES The Radwaste Operator position is no longer required in the post shutdown and permanently shut down and defueled condition. Electrical Maintenance Technician duties include providing repairs and corrective actions for plant electrical equipment, as directed.

I&C Technician duties include providing repairs and corrective actions to plant instrumentation, as directed. The OSC Manager will continuously evaluate the need for resources and coordinate with the EOF Technical Advisor to call in additional qualified personnel. OSC resources will continue to be augmented positions with specific training and qualification requirements for assigned personnel in accordance with the site training program. The required training courses and requalification frequencies will be unchanged in the post-shutdown condition. The elimination of the OSC craft positions described above is justified because the spectrum of credible accidents and operational events, and the quantity and complexity of activities required for the safe storage of spent nuclear fuel is reduced as compared to an operating plant. The set of plant equipment required in the permanently shut down and defueled condition is also greatly reduced, which reduces the assessment and mitigation activities the OSC must perform. Additionally, the elimination of credible accidents involving an operating reactor provides additional time to plan and execute assessment and mitigation actions.

3.2.1.7 Major Functional Area: Field Monitoring Teams (FMTs)

Major Tasks: Onsite FMT, Offsite FMT, and Transportation Current Staffing Requirement Augmentation by two Radiation Protection Technicians within 60 minutes and one additional Radiation Protection Technician within 90 minutes.

Augmentation of two drivers - one within 60 minutes and one within 90 minutes.

Proposed Change No proposed changes in staffing.

Analysis PNP proposes no changes to the FMT staffing.

3.2.1.8 Major Functional Area: Fire Fighting Current Staffing Requirement The Fire Brigade complement currently consists of five (5) responders, one of which acts as the Plant Fire Brigade Leader.

Proposed Change No proposed changes in staffing. The Fire Brigade complement will continue to consist of a minimum of five (5) responders, including a Fire Brigade Leader and a minimum of four (4) trained and qualified Fire Brigade Members in compliance with the PNP fire protection program.

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ATTACHMENT 1 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGES Analysis The Fire Brigade will continue to be staffed in accordance with Technical Specifications. All Fire Brigade training and qualification requirements will be maintained using the Fire Hazards Analysis requirements. The Fire Brigade will continue to perform the task of firefighting in the permanently shut down and defueled condition. The Fire Brigade will be available to promptly implement SFP inventory makeup strategies required under 10 CFR 50.54(hh)(2) without impacting the performance of designated emergency plan functions.

3.2.1.9 Major Functional Area: Rescue Operations and First Aid Current Staffing Requirement The minimum staff on duty at the plant during all shifts to satisfy this Major Functional Area consists of two (2) on-shift personnel assigned other functions.

Proposed Change No proposed changes in staffing.

Analysis PNP proposes no staffing changes to the Rescue Operations and First Aid staffing Major Functional Area.

3.2.1.10 Major Functional Area: Site Access Control and Personnel Major Tasks: Security, fire fighting, communications, personnel accountability Current Staffing Requirement Staffing in accordance with the Security Plan Proposed Change No proposed changes in staffing.

Analysis PNP proposes no staffing changes to the Site Access Control and Personnel Major Functional Area.

3.2.2 Augmented ERO Staffing Prior to an emergency declaration, the normal plant operating organization is in place. The initial classification of an off-normal event and declaration are performed by the Shift Manager. Upon classification and declaration of an emergency, the Shift Manager assumes the role of Emergency Director and retains that role until another designated Emergency Director can assume control.

The onsite emergency organization is activated by personnel notification or when the station alarm is sounded and the emergency is announced over the public address system. Initially, the ERO consists of the normal operating shift personnel who function as the emergency team members.

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ATTACHMENT 1 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGES The normal operating staff is augmented by qualified plant personnel. Those personnel onsite respond when the station alarm is sounded and the announcement is made or when individuals are notified by another means. Personnel not onsite during off-hours operations will be notified via an ERO notification system. A designated on-shift plant employee completes the notifications.

In the permanently shut down and defueled condition, PNP will continue to maintain ERO teams to respond to an emergency declaration. When the Shift Manager directs the activation of the ERO call out system, ERO members are notified to ensure adequate coverage of ERO positions at each ERF. ERO members not on-call are expected to respond unless they are unavailable.

PNP requires ERO personnel to act promptly in reporting to their assigned ERF even when not on duty. During duty periods, procedures further require that team members respond within the required response time for their ERF (unless a longer time frame is specified for their specific ERO position) and that they remain fit for duty throughout the duty assignment. Individuals are trained to respond to their ERF even if they are not on duty. Excess personnel that respond may be assigned support responsibilities or be designated as a relief shift. This conservative policy ensures timely activation because some off-duty personnel may respond sooner than the on-duty personnel.

The proposed revisions to the PNP SEP will not change the requirements described above.

Managements continued expectation is that duty and support ERO members report to their respective ERF as quickly as possible. ERO personnel are expected to respond when notified by the ERO notification system. Current augmented ERO positions are identified, and the associated duties are captured, in the ERO Task Analysis provided in Attachment 6. Each of the positions proposed for elimination were analyzed to identify the key duties associated with the position and the duties were then evaluated against the planning standards in NUREG-0654.

During the development of the proposed changes to the augmented ERO staffing, documented in , PNP initiated a multi-disciplined team review of each aspect of the augmented ERO staffing changes. This team included participants from Operations, Training, Engineering, Chemistry, Radiation Protection, and Emergency Planning. Each proposed change in task alignment was vetted by this group.

The Table provided in Attachment 6 contains columns with headings "Implementing Actions" and "Task Assigned To?". These columns provide the details regarding the disposition of each task.

Some of the duties are identified as being eliminated because they become unnecessary following permanent cessation of power operations and permanent removal of fuel from the reactor vessel.

Other duties are identified as eliminated because the duties are performed redundantly by other positions in the ERO and will continue to be performed by these positions in the post-shutdown ERO.

Procedures and training materials depicting the changes presented in Attachment 6 will be developed to align with the revised task assignments. These procedures will be used to support training of post-shutdown ERO staff and the conduct of drills that will be used to validate the staffing and assignment of tasks.

The proposed changes to the PNP SEP, including the changes made to develop the post-shutdown ERO, have been evaluated for impacts on the ERO and for the ability of offsite response organizations (OROs) to implement their U.S. Federal Emergency Management Agency (FEMA)-

approved Radiological Emergency Preparedness (REP) Plans. Potential impacts on the ability of State and County response organizations to effectively implement their FEMA-approved REPs do Page 20 of 35

ATTACHMENT 1 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGES not exist because no tasks that require interfacing with State and County response organizations are proposed for elimination. PNP has appropriately addressed elimination of augmented ERO positions that interface with offsite representatives by transferring the necessary tasks to remaining post-shutdown augmented ERO positions. In addition, the PNP ERO includes technical support staff that have dedicated responsibilities for interfacing with State and County representatives.

During an emergency, these personnel are dispatched to the State and County EOCs to act as communication and technical liaisons between the EOCs and plant technical staff to provide clarification of emergency response information. These positions will remain as part of the PNP ERO in the post-shutdown period. See Attachment 8 for correspondence from the State and Local agencies.

To validate the results of the proposed changes to the augmented ERO described within, and the analysis presented in Attachment 6, one or more drills will be developed and conducted prior to implementation of the changes described within this LAR. The drills will be conducted to confirm the ability of the post-shutdown augmented ERO to perform the necessary functions of each ERF and will utilize the post-shutdown procedures that will be developed depicting the revised assignment of duties. The drills will be used to train and qualify post-shutdown augmented ERO members, evaluate and validate the ability to accomplish the stated mission of each ERF, and ensure that the planning standard functions are preserved with no degradation in time-sensitive activities or in the ability to communicate with OROs. The drills will also validate that the post-shutdown augmented ERO continues to address the risks to public health and safety and comply with the PNP SEP, site commitments, and applicable regulations. Implementing procedures will be revised to address the permanently shut down and defueled conditions. The revised procedures will be used to support training of augmented ERO staff and the conduct of the drills described above.

Training and draft procedures will be developed and in place prior to performing post-shutdown ERO validation drills. The drill scenarios will include SFP events and will be designed to test the major elements of the PNP Post-Shutdown Emergency Plan (PSEP). Major elements to be tested will include communications and coordination with OROs, including the JIC. State, County, and Federal response organizations will be provided the opportunity to participate in or observe the drills, as applicable. New regulatory commitments for scenario elements and communication with offsite agencies are included in Attachment 7.

PNP has not yet finalized a schedule of drills that will be conducted. When the dates are finalized, the NRC Project Manager will be notified and provided with a schedule. PNP will provide the schedule to the NRC with appropriate advanced notice, thereby allowing the NRC and FEMA an opportunity to observe each drill. A new regulatory commitment to provide the schedule to the NRC Project Manager is included in Attachment 7.

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ATTACHMENT 1 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGES Table 1 - Proposed Post-Shutdown Augmented ERO Staffing Proposed Post-Current PNP Augmented ERO Positions Shutdown Augmented Justification for Elimination2 ERO Positions1 Technical Support Center Emergency Plant Manager Emergency Plant Not Applicable (N/A) - Position Manager Retained TSC Manager -- Tasks transferred Operations Coordinator -- Tasks transferred TSC Reactor Engineer -- No remaining functions Engineering Coordinator Engineering Coordinator N/A - Position Retained TSC Engineers (Electrical, I&C, -- Tasks transferred Mechanical)

TSC Communicator -- Tasks transferred Radiological Assessment Coordinator -- Tasks transferred Security Coordinator Security Coordinator N/A - Position Retained Maintenance Coordinator -- Tasks transferred ENS Communicator ENS Communicator N/A - Position Retained TSC Admin Support -- Tasks transferred TSC Log Keeper -- Tasks transferred Operations Support Center OSC Manager OSC Manager N/A - Position Retained OSC Operations Support -- Tasks transferred Work Control Coordinator -- Tasks transferred Mechanical and I&C/Electrical Coordinators -- Tasks transferred Rad/Chem Coordinator Rad/Chem Coordinator N/A - Position Retained OSC Staff (Electrical, I&C, Mechanical OSC Staff (Electrical, N/A - Positions Retained, tasks Maintenance, RP/HP, Chemistry) Mechanical Maintenance, transferred, or tasks are no RP/HP Technicians) longer necessary OSC Log Keeper -- Tasks transferred OSC Radio Communicator -- Tasks transferred OSC Admin Support -- Tasks transferred Onsite Monitoring Team Onsite Monitoring Teams N/A - Position Retained Offsite Monitoring Teams Offsite Monitoring Teams N/A - Position Retained Emergency Operations Facility Emergency Director Emergency Director N/A - Position Retained EOF Manager -- Tasks transferred EOF Technical Advisor EOF Technical Advisor N/A - Position Retained EOF Log Keeper -- Tasks transferred Radiological Assessment Coordinator Radiological Assessment N/A - Position Retained Coordinator Offsite Communicator Offsite Communicator N/A - Position Retained Lead Offsite Liaison -- Tasks transferred Offsite Team Coordinator Offsite Team Coordinator N/A - Position Retained Administration and Logistics Coordinator -- Tasks transferred IT Specialist -- Tasks transferred Dose Assessor Dose Assessor N/A - Position Retained Offsite Liaisons (1 State/3 County) Offsite Liaisons (1 State/3 N/A - Positions Retained County)

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ATTACHMENT 1 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGES Proposed Post-Current PNP Augmented ERO Positions Shutdown Augmented Justification for Elimination2 ERO Positions1 EOF Communicator -- Tasks transferred State/County Communicator -- Tasks transferred Security Coordinator -- Tasks transferred Security Staff -- Tasks transferred EOF Admin Support -- Tasks transferred Joint Information Center Company Spokesperson Company Spokesperson N/A - Position Retained JIC Manager -- Tasks transferred Technical Advisor -- Tasks transferred JIC Logistics Coordinator -- Tasks transferred Information Coordinator -- Tasks transferred JIC Media Liaison JIC Media Liaison N/A - Position Retained JIC Log Keeper -- Tasks transferred JIC Technical Assistant -- Tasks transferred Press Release Writer -- Tasks transferred Media Monitor Media Monitor N/A - Position Retained Inquiry Response Coordinator -- Tasks transferred Public Inquiry Responders (2) Public Inquiry Responder Reduced responsibilities can be performed by remaining positions JIC Admin Support -- Tasks transferred 1

A dash (--) Indicates the position is proposed for elimination upon implementation of the Post-Shutdown Emergency Plan.

2 Detailed information regarding the proposed elimination of each position is provide in Section 3.2.2.1 through 3.2.2.4 and Attachment 6.

The intent of Table 1 is to compare the current augmented ERO positions against the proposed post-shutdown augmented ERO positions. As an example, the TSC Reactor Engineer is a position that is proposed for elimination in the post-shutdown ERO, because in a permanently shut down and defueled condition the responsibilities associated with a reactor core no longer need to be maintained. The proposed elimination of augmented ERO positions are described in greater detail in the following sections. Those augmented ERO positions identified in procedures as typical minimum staffing positions to declare the ERFs operational are described in greater detail. Other augmented ERO positions proposed for elimination, but not identified in procedure as typical minimum staffing positions to declare the ERFs operational, are also addressed in the following sections.

Additional analysis for each of the augmented ERO staffing changes that impact the content of PNP SEP Figure 5-2 was previously addressed by Major Functional Area in Sections 3.2.1.1 through 3.2.1.10. contains an analysis of all augmented ERO positions proposed for elimination and evaluates the transfer of tasks to remaining augmented ERO positions following permanent cessation of power operations and permanent removal of fuel from the reactor vessel.

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ATTACHMENT 1 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGES 3.2.2.1 Technical Support Center The TSC has been designed to meet the intent of the guidance in NUREG-0696, Functional Criteria for Emergency Response Facilities, and the clarification in NUREG-0737, Supplement 1, Clarification of TMI Action Plan Requirements, as applicable. Following permanent cessation of power operations and permanent removal of fuel from the reactor vessel, the TSC will continue to be located in the area immediately adjacent to the Control Room. The changes proposed to the PNP SEP do not involve any physical modifications to, or layout/configuration changes in, the TSC.

The current PNP SEP is intended to address the risks to public health and safety inherent with an operating reactor. The risk in the permanently shut down and defueled condition is significantly reduced because many of the potential initiating conditions that would lead to an emergency declaration will no longer be possible.

The spectrum of credible accidents and operational events, and the quantity and complexity of activities required for the safe storage of spent nuclear fuel is reduced as compared to an operating plant. The set of plant equipment required in the permanently shut down and defueled condition is also greatly reduced, which reduces the assessment and mitigation activities the TSC must perform. Therefore, the TSC Manager, Operations Coordinator, TSC Reactor Engineer, TSC Engineers, TSC Communicator, Radiological Assessment Coordinator, Maintenance Coordinator, TSC Admin Support, and TSC Log Keeper positions can be eliminated without placing an undue burden on the remaining ERO positions in the TSC and without increasing the risk to public health and safety. Attachment 6 contains an analysis of all augmented ERO positions being eliminated and evaluates the transfer of tasks to remaining augmented ERO positions following permanent cessation of power operations. The proposed augmented ERO staffing reductions continue to address the risks to public health and safety, comply with the PNP SEP, site commitments, and applicable regulations.

The proposed staffing changes eliminate the following ERO positions in the TSC described in procedure as typical minimum staffing that could be considered necessary to declare the TSC operational: the Reactor Engineer (Technical Support - Core/Thermal Hydraulics), TSC Engineers (Electrical, I&C, and Mechanical), and the Radiological Assessment Coordinator.

TSC Reactor Engineer The primary duties of the TSC Reactor Engineer include: monitoring plant conditions for any indication of core damage, assisting in clarifying core parameter information to the Engineering Team, and assisting in the implementation of Severe Accident Management Guidelines. In a permanently shut down and defueled condition, responsibilities associated with a reactor core no longer need to be maintained. Elimination of the TSC Reactor Engineer position will have no effect on emergency response in a permanently shut down and defueled condition because the position is not required to assess the condition of fuel in the SFP during an emergency. The TSC Reactor Engineer position can be eliminated without increasing the risk to public health and safety because the major task of evaluating core/thermal hydraulics is not necessary or possible in a permanently shut down and defueled condition.

TSC Engineers (Electrical, I&C, and Mechanical)

The primary duties of the TSC Engineer positions include responding to engineering requests from the Engineering Coordinator, evaluating the implementation of Severe Accident Management Guidelines, and assisting the OSC in preparing to send repair teams into the plant. These duties are either no longer necessary in a permanently shut down and defueled condition or will be performed by the Engineering Coordinator. The Engineering Coordinator is tasked with performing Page 24 of 35

ATTACHMENT 1 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGES an engineering assessment of plant conditions and/or actions needed to mitigate damage to the plant.

With respect to responding to engineering requests from the Engineering Coordinator, this function will continue to be performed by augmenting qualified engineering resources. The Engineering Coordinator will continuously evaluate the need for engineering resources and coordinate with the EOF Technical Advisor to call in qualified engineering personnel. These individuals may be tasked with activities to be completed at engineering offices external to the TSC, called to report to the TSC, or directed to other facilities.

Engineering resources will continue to be available as augmenting positions with specific training and qualification requirements for assigned personnel in accordance with the site training program.

The required training courses and requalification frequencies will be unchanged in the permanently shut down and defueled condition. However, these positions will no longer be identified as on-call positions. The elimination of the TSC Engineer positions is justified because the spectrum of credible accidents and operational events, and the quantity and complexity of activities required for the safe storage of spent nuclear fuel is reduced as compared to an operating plant. The set of plant equipment required in the permanently shut down and defueled condition is also greatly reduced, which reduces the assessment and mitigation activities the TSC must perform. contains an analysis of the TSC Engineer positions and evaluates the transfer of tasks to remaining ERO positions following permanent cessation of power operations and permanent removal of fuel from the reactor vessel.

Radiological Assessment Coordinator The primary duties of the Radiological Assessment Coordinator is to coordinate Radiation Protection activities, including onsite radiological assessment, personnel exposure control and radiation protection programs. The Radiological Assessment Coordinator functions overlap with those of the Rad/Chem Coordinator in the OSC (position maintained in the post-shutdown ERO).

In an operating plant, the number and type of Radiation Protection activities supports this redundancy and overlap in function. In the permanently shut down and defueled condition, the spectrum of credible accidents and operational events, and the quantity and complexity of activities required for the safe storage of spent nuclear fuel is reduced as compared to an operating plant and redundant functions is no longer necessary to ensure performance. The Radiological Assessment Coordinator position can be eliminated without increasing the risk to public health and safety because the major task of coordinating Radiation Protection activities is provided by the Rad/Chem Coordinator in the OSC.

In addition to the positions described above, the following TSC positions are also proposed for elimination following permanent cessation of power operations and permanent removal of fuel from the reactor vessel:

TSC Manager Operations Coordinator TSC Maintenance Coordinator TSC Communicator TSC Admin Support TSC Log Keeper The TSC Manager is currently responsible for ensuring the TSC is activated in accordance with applicable procedures and ensuring notification of the ERO has been made. This position also advises the Emergency Plant Manager on proposed corrective actions and emergency Page 25 of 35

ATTACHMENT 1 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGES classification from a technical standpoint (i.e., plant system damage, core damage, etc.).

Functional responsibilities of the TSC Manager position that remain applicable in a permanently shut down and defueled condition will be reassigned to remaining positions in the TSC.

The primary duties of the Operations Coordinator are to monitor plant data communications between the Control Room and other ERFs, inform the TSC of the overall plant condition and significant changes to system and equipment status, provide technical assistance to the Shift Manager, monitor fission product barrier and plant status, and coordinate TSC efforts in support of Control Room actions. These duties are either no longer necessary in a permanently shut down and defueled condition, or they will be performed by other members of the post shutdown ERO, including the Emergency Plant Manager and the Engineering Coordinator.

The primary duties of the TSC Maintenance Coordinator are to communicate requests for repair and corrective action teams to the OSC, and assist the OSC in prioritizing the requests. These duties are either no longer necessary in a permanently shut down and defueled condition, or they will be performed by other members of the post shutdown ERO.

The elimination of the TSC Admin Support, TSC Communicator, and TSC Log Keeper positions does not impact the capabilities of the on-shift staffing or augmented response. The TSC will continue to be activated at an Alert or higher declaration. Functional responsibilities of the positions eliminated as a result of the changes will be reassigned to remaining positions, as necessary. The proposed augmented ERO staffing reductions continue to address the risks to public health and safety, comply with the PNP Emergency Plan, site commitments, and applicable regulations.

3.2.2.2 Operations Support Center The OSC has been designed to meet the intent of the guidance in NUREG-0696, Functional Criteria for Emergency Response Facilities, and the clarification in NUREG-0737, Supplement 1, Clarification of TMI Action Plan Requirements, as applicable. Following permanent cessation of power operations and permanent removal of fuel from the reactor vessel, the OSC will continue to be located near the mens locker room in the Service Building. The proposed changes to the PNP SEP do not involve any physical modifications to, or layout/configuration changes in, the OSC.

The OSC Manager is responsible for ensuring adequate staffing of the OSC to support the emergency; working with the Emergency Plant Manager to set priorities for the OSC; and directing the activities of the OSC to support the emergency response. If at any time the OSC Manager determines additional manpower is necessary to accomplish the mission of the OSC, the OSC Manager will contact the EOF Technical Advisor to arrange for augmentation by additional personnel to support the emergency response functions of the OSC.

In the permanently shut down and defueled condition, the primary functions of the OSC will remain dispatching of, and accounting for, Repair and Corrective Action Teams and dispatching of Onsite and Offsite Monitoring Teams. The OSC Craft functions will continue to be performed by augmenting qualified resources. The OSC Manager will continue to continuously evaluate the need for resources and coordinate with the EOF Technical Advisor to call in additional assistance.

OSC resources will continue to be augmented positions with specific training and qualification requirements for assigned personnel in accordance with the site training program. The required training courses and requalification frequencies will be unchanged in the post-shutdown condition.

The proposed staffing changes do not eliminate any ERO positions in the OSC described in procedure as typical minimum staffing that could be considered necessary to declare the OSC Page 26 of 35

ATTACHMENT 1 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGES operational. The following OSC positions are proposed for elimination following permanent cessation of power operations and permanent removal of fuel from the reactor vessel:

OSC Operations Support Work Control Coordinator Mechanical and I&C/Electrical Coordinators OSC Log Keeper OSC Radio Communicator OSC Admin Support Additionally, the proposed staffing changes eliminate the augmenting Radwaste Operator, one augmenting electrical technician, and the augmenting I&C Technician. These positions are included in PNP SEP Figure 5-2 as 60-minute augmenting responders. Electrical Maintenance Technician duties include providing repairs and corrective actions for plant electrical equipment, as directed. I&C Technician duties include providing repairs and corrective actions to plant instrumentation, as directed. The spectrum of credible accidents and operational events, and the quantity and complexity of activities required for the safe storage of spent nuclear fuel is reduced as compared to an operating plant. Therefore, the duties and coverage required for these positions are reduced.

The proposed augmented ERO staffing continues to address the risks to public health and safety, comply with the PNP Emergency Plan, site commitments, and applicable regulations.

In the permanently shut down and defueled condition, the spectrum of credible accidents and operational events, and the quantity and complexity of activities required for the safe storage of spent nuclear fuel is reduced as compared to an operating plant. The primary events of concern in the immediate post-shutdown and defueled condition will be a dropped cask in the SFP, a FHA, and a loss of SFP cooling and/or water inventory. Events involving a loss of SFP cooling and/or water inventory can be addressed by implementation of SFP inventory makeup strategies required under 10 CFR 50.54(hh)(2). These strategies will continue to be maintained as a license condition.

OSC staff is not relied upon to implement SFP inventory makeup.

Restoration of equipment supporting SFP cooling and inventory will be the primary focus of emergency mitigation actions for the TSC and OSC in a permanently shut down and defueled condition. Although ERO activation/response time requirements will be unchanged, the elimination of credible accidents involving an operating reactor provides additional time to plan and execute assessment and mitigation actions. The proposed changes do not impact the capability to assess and monitor actual or potential offsite consequences of a radiological emergency or provide information to offsite authorities in a timely manner. Therefore, the OSC Operations Support, Work Control Coordinator, Mechanical and I&C/Electrical Coordinators, OSC Log Keeper, OSC Radio Communicator, and OSC Admin Support positions can be eliminated without placing an undue burden on the remaining ERO positions in the OSC and without increasing the risk to public health and safety.

3.2.2.3 Emergency Operations Facility The EOF functions to maintain overall management of Entergys emergency response and recovery resources; evaluate, coordinate, and communicate emergency response activities with Federal, State, and County emergency response organizations; evaluate offsite accident conditions; and make recommendations to offsite agencies regarding protective actions. Federal, State, and County representatives are provided space and communications at the EOF and staff this facility at an Alert or higher classification.

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ATTACHMENT 1 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGES The EOF has been designed to meet the intent of the guidance in NUREG-0696, Functional Criteria for Emergency Response Facilities, and the clarification in NUREG-0737, Supplement 1, Clarification of TMI Action Plan Requirements, as applicable. Following permanent cessation of power operations, the EOF will continue to be located in downtown Benton Harbor, approximately 16 miles south southwest from the plant site. The proposed changes to the PNP SEP do not involve any physical modifications to, or layout/configuration changes in, the EOF.

The EOF maintains extensive communications capability with all ERFs and direct links are established between the EOF, the State and County Emergency Operations Centers (EOCs), and the JIC to provide up-to-date emergency status reports. The proposed changes to the PNP SEP do not involve changes to the ability of offsite authorities to report to the EOF or the JIC, and as a result, do not impact the ability of the offsite authorities to mobilize to, or operate from, the EOF and JIC.

When activated, the Emergency Director reports to the EOF and directs the activities of the augmented ERO throughout the emergency and until the recovery activities have been terminated.

The Emergency Director, or a designated alternate, issues periodic status reports of the event to offsite representatives located in the EOF. The Radiological Assessment Coordinator and Technical Advisor will provide and interpret plant information to the offsite representatives in the EOF. Additionally, technical support staff are dispatched to the State and County EOCs when requested and appropriate, or generally, during an Alert or higher declaration to act as a liaison with the plant technical staff so the magnitude of the emergency can be more clearly conveyed to the EOCs staff. The proposed changes do not reduce the ability of PNP to provide the necessary information regarding the status and progression of an event or in the frequency at which event information updates are provided. Nor do the changes impact the ability to dispatch additional technical support to the EOCs. As a result, the proposed changes do not impact the ability of PNP to communicate with the OROs.

Centralized coordination of the offsite radiological assessment effort with all organizations interested in, and/or performing, assessments is necessary to ensure that the data and its interpretation are reviewed by PNP and OROs with monitoring and assessment responsibilities.

The number and type of organizations performing this effort vary with time and following emergency declarations and offsite notification. Initially, plant emergency response personnel are the only organization performing this function and they are directed from, and their results evaluated, at the EOF. State and Federal response agencies would augment plant assessment efforts. The proposed changes to the PNP SEP do not impact the ability of OROs to monitor and assess a potential release and effectively implement their emergency plans.

PNP will continue to maintain the capability to display plant and meteorological data in the EOF, maintain offsite monitoring equipment at the EOF and maintain the current dose assessment capabilities at the EOF. Additionally, PNP will maintain a goal of sixty (60) minutes after declaration of an emergency to activate the EOF.

The proposed staffing changes do not eliminate any ERO positions in the EOF described in procedure as typical minimum staffing that could be considered necessary to declare the EOF operational. The following EOF positions are proposed for elimination following permanent cessation of power operations and permanent removal of fuel from the reactor vessel:

EOF Manager EOF Log Keeper Page 28 of 35

ATTACHMENT 1 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGES Lead Offsite Liaison Administration and Logistics Coordinator IT Specialist EOF Communicator State/County Communicator Security Coordinator Security Staff EOF Admin Support The proposed elimination of the EOF staffing listed above does not impact the capabilities of the on-shift staffing or augmented response. The positions can be eliminated without placing an undue burden on the remaining ERO positions in the EOF and without increasing the risk to public health and safety. The EOF will continue to be activated at an Alert or higher declaration. Functional responsibilities of the positions proposed for elimination will be reassigned to remaining positions.

The proposed augmented ERO staffing continue to address the risks to public health and safety, comply with the PNP SEP, site commitments, and applicable regulations. The proposed changes to the ERO staffing in the EOF do not impact the ability of the State and County response organizations to effectively implement their FEMA-approved REP Plans. Additional discussion of the potential impact on OROs is included in Section 3.2.3.

3.2.2.4 Joint Information Center The PNP JIC is co-located with the EOF in Benton Harbor. The JIC provides a location for the news media to receive information from all involved agencies and companies during an emergency and provide it to the public. The JIC is equipped to accommodate the news media for large briefings and conferences and contains extensive communications systems. Media monitoring and rumor control are also accomplished at the JIC, allowing Entergy and State representatives to address incorrect information or rumors. Responses to media telephone inquiries are also addressed at the JIC.

The JIC meets the intent of the guidance in Planning Standard G of NUREG-0654. Following permanent cessation of operations and permanent removal of fuel from the reactor vessel, the JIC will continue to be located in Benton Harbor. The proposed changes to the PNP SEP do not involve any physical modifications to, or layout/configuration changes in, the JIC.

The following JIC positions are proposed for elimination following permanent cessation of power operations and permanent removal of fuel from the reactor vessel:

JIC Manager Technical Advisor JIC Logistics Coordinator Information Coordinator JIC Log Keeper JIC Technical Assistant Press Release Writer Inquiry Response Coordinator JIC Admin Support In the permanently shut down and defueled condition, media briefings and rumor control will continue to be conducted regularly during an emergency to provide accurate and timely information to the public. The proposed JIC staffing changes described above do not impact the capabilities of Page 29 of 35

ATTACHMENT 1 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGES the on-shift staffing or augmented response. The positions can be eliminated without placing an undue burden on the remaining ERO positions in the JIC and without increasing the risk to public health and safety. Functional responsibilities of the positions proposed for elimination will be reassigned to remaining positions. The proposed augmented ERO staffing reductions continue to address the risks to public health and safety, comply with the PNP SEP, site commitments, and applicable regulations.

3.2.3 Impact on Off-Site Response Organizations Because of the location of PNP, the planning and responsibilities at the State and County level involve coordination with the State of Michigan, Berrien County, Allegan County, and Van Buren County. Table 7-1 of the PNP SEP describes the extensive communications network maintained between PNP, Federal, State, and County agencies as a means of promptly notifying and maintaining communications with appropriate authorities. The coordination effort with offsite authorities is initiated by notifying the State of Michigan and Van Buren County and providing them with key information regarding an emergency. The proposed changes to the PNP SEP do not involve changes to this communications network, and as a result, do not impact the ability of PNP to promptly notify and initiate coordination with the offsite authorities.

Formal offsite REP plans, approved by the FEMA in accordance with 44 CFR 350, are required to be maintained in effect until the NRC approves an exemption from formal offsite emergency preparedness requirements. Because the changes proposed by ENO, specifically in regards to ERO staffing of the EOF and JIC, have the potential to adversely impact the effective implementation of the State and County REP plans, the proposed changes to the PNP SEP were evaluated for impacts on the ability of the State and County response organizations to effectively implement their FEMA-approved REP Plans. This evaluation included a review of the State of Michigan Radiological Emergency Response Plan, the Berrien County Radiological Emergency Response Plan, the Allegan County Radiological Emergency Response Plan, and the Van Buren County Emergency Preparedness Plan. The review of the State and County REPs did not identify any specific references to PNP ERO positions proposed for elimination. Therefore, the conclusion was made that the proposed changes have no effect on the State or counties ability to implement their FEMA-approved REP plans. On June 6, 2017, a meeting with these various Federal, State, and local agencies was conducted to discuss the proposed changes. Feedback from the State and local agencies is provided in Attachment 8.

PNP technical support staff is dispatched to the State and County EOCs when requested and appropriate, or generally, during a SAE or GE to act as a liaison with the plant technical staff to clearly convey the magnitude of the emergency to the EOCs staff. These positions are retained in the Post-Shutdown ERO. The proposed changes do not reduce the ability of PNP to provide the necessary information regarding the status and progression of an event or in the frequency at which event information updates are provided. Nor do the changes impact the ability to dispatch additional technical support to the EOCs. As a result, the proposed changes do not impact the ability of PNP to communicate with the OROs or the ability of the State and County response organizations to effectively implement their FEMA-approved REP Plans.

3.3 Summary ENO performed an analysis to evaluate the ability of the proposed post-shutdown on-shift staffing to implement all regulatory required emergency plan functions in conjunction with the postulated accidents that will be applicable in the permanently shut down and defueled condition. Additionally, an analysis of all augmented ERO positions was performed to analyze the transfer of tasks from Page 30 of 35

ATTACHMENT 1 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGES those positions proposed for elimination to remaining augmented ERO positions following permanent cessation of power operations and permanent removal of fuel from the reactor.

The proposed augmented ERO staffing changes do not impact the capabilities of the on-shift staffing or augmented response. The ERFs will continue to be activated within approximately 60 minutes of an Alert or higher declaration. The remaining post-shutdown functional responsibilities of the positions proposed for elimination are being reassigned to remaining positions. The proposed augmented ERO staffing reductions continue to address the risks to public health and safety and comply with the PNP SEP, site commitments, and applicable regulations.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria On-Shift and Augmented ERO Staffing The specific standards for establishing an onsite emergency organization to respond to emergency events appears in 10 CFR 50.47(b) and 10 CFR 50, Appendix E, Section IV.A. Specifically:

• 10 CFR 50.47(b)(1): Primary responsibilities for emergency response by the nuclear facility licensee and by State and local organizations within the Emergency Planning Zones have been assigned, the emergency responsibilities of the various supporting organizations have been specifically established, and each principal response organization has staff to respond and to augment its initial response on a continuous basis.

• 10 CFR 50.47(b)(2): On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available and the interfaces among various onsite response activities and offsite support and response activities are specified.

• 10 CFR 50, Appendix E Section IV.A.1: [E-Plans must contain] A description of the normal plant operating organization.

• 10 CFR 50, Appendix E Section IV.A.2: [E-Plans must contain] A description of the onsite emergency response organization with a detailed discussion of:

• Authorities, responsibilities, and duties of the individual(s) who will take charge during an emergency;

• Plant staff emergency assignments;

• Authorities, responsibilities, and duties on an onsite emergency coordinator who shall be in charge of the exchange of information with offsite authorities responsible for coordinating and implementing offsite emergency measures; NUREG-0654 (Reference 4),Section II.B, Onsite Emergency Organization, presents guidance for meeting these requirements. The guidance describes the onsite emergency organization, including the staffing requirements found in Table B-1, Minimum Staffing Requirements for NRC Licensees for Nuclear Power Plant Emergencies.

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ATTACHMENT 1 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGES 10 CFR Part 50, Appendix E, Section IV.A.9 states that licensees shall perform a detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan.

NSIR/DPR-ISG-01, Interim Staff Guidance - Emergency Planning for Nuclear Power Plants (Reference 6) provides information relevant to performing the on-shift staffing analysis. The ISG states that NEI 10-05, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities, is an acceptable methodology for performing the staffing analysis. The ISG also indicates that the completed staffing analyses are required to be part of the emergency plan and the results documented and submitted to the NRC in accordance with 10 CFR 50.54(q)(5).

NRC Regulatory Guide 1.101, Emergency Response Planning and Preparedness for Nuclear Power Reactors, (Reference 8) Section C, states in part "The criteria and recommendations in Revision 1 of NUREG-0654/FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants (November 1980), are methods acceptable to the NRC staff for complying with the standards in 10 CFR 50.47 that must be met in onsite and offsite emergency response plans. These criteria provide a basis for NRC licensees and State and local governments to develop acceptable radiological emergency plans and improve emergency preparedness."

Regulatory Guide 1.219, Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors, November 2011 (Reference 9), describes a method that the NRC considers to be acceptable to implement the requirements in 10 CFR 50.54(q). In Section 2.a.(1), the NRC encourages licensees to arrange a conference call with the NRC staff to clarify 10 CFR 50.54(q) requirements and guidance within this regulatory guide for EP changes that increase the activation time of emergency response facilities.

Regulatory Issue Summary 2005-02, "Clarifying the Process for Making Emergency Plan Changes," Revision 1 (Reference 10) was issued by the NRC to clarify the meaning of "decrease in effectiveness" and the process for making changes to emergency plans, and to provide some examples of changes that are considered to be a decrease in effectiveness.

4.2 Precedent The requested changes to the on-shift staffing and augmented ERO staffing are similar in nature to the post-shutdown changes approved by the NRC and implemented by Vermont Yankee Nuclear Power Station (Reference 11) and Ft. Calhoun Station (Reference 12).

4.3 No Significant Hazards Consideration Pursuant to 10 CFR 50.92, Entergy Nuclear Operations, Inc. (ENO) has reviewed the proposed changes and concludes that the changes do not involve a significant hazards consideration because the proposed changes satisfy the criteria in 10 CFR 50.92(c). These criteria require that operation of the facility in accordance with the proposed amendment would not (1) involve a significant increase in the probability or consequences of an accident previously evaluated; (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.

The proposed changes would revise the Palisades Nuclear Plant (PNP) Site Emergency Plan (SEP) to reduce the number of on-shift and augmented emergency response organization (ERO)

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ATTACHMENT 1 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGES positions commensurate with the hazards associated with a permanently shut down and defueled facility.

The discussion below addresses each of these criteria and demonstrates that the proposed amendment does not constitute a significant hazard.

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed changes to the PNP SEP do not impact the function of plant structures, systems, or components (SSCs). The proposed changes do not affect accident initiators or precursors, nor does it alter design assumptions. The proposed changes do not prevent the ability of the on-shift staff and augmented ERO to perform their intended functions to mitigate the consequences of any accident or event that will be credible in the permanently shut down and defueled condition. The proposed changes only remove positions that will no longer be credited in the PNP SEP.

Therefore, the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed changes reduce the number of on-shift and augmented ERO positions commensurate with the hazards associated with a permanently shut down and defueled facility. The proposed changes do not involve installation of new equipment or modification of existing equipment, so that no new equipment failure modes are introduced. Also, the proposed changes do not result in a change to the way that the equipment or facility is operated so that no new accident initiators are created.

Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

Margin of safety is associated with confidence in the ability of the fission product barriers (i.e., fuel cladding, reactor coolant system pressure boundary, and containment structure) to limit the level of radiation dose to the public. The proposed changes are associated with the PNP SEP and do not impact operation of the plant or its response to transients or accidents. The change does not affect the Technical Specifications. The proposed changes do not involve a change in the method of plant operation, and no accident analyses will be affected by the proposed changes. Safety analysis acceptance criteria are not affected by the proposed changes. The revised PNP SEP will continue to provide the necessary response staff with the proposed changes.

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ATTACHMENT 1 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGES Therefore, the proposed amendment does not involve a significant reduction in a margin of safety.

4.4 Conclusion Based on the above, ENO concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.

5.0 ENVIRONMENTAL CONSIDERATION

This amendment request meets the eligibility criteria for categorical exclusion from environmental review set forth in 10 CFR 51.22(c)(9) as follows:

(i) The amendment involves no significant hazards consideration.

As described in Section 4.3 of this evaluation, the proposed changes involve no significant hazards consideration.

(ii) There is no significant change in the types or significant increase in the amounts of any effluent that may be released offsite.

The proposed changes do not involve any physical alterations to the plant configuration or any changes to the operation of the facility that could lead to a change in the type or amount of effluent release offsite.

(iii) There is no significant increase in individual or cumulative occupational radiation exposure.

The proposed changes do not involve any physical alterations to the plant configuration or any changes to the operation of the facility that could lead to a significant increase in individual or cumulative occupational radiation exposure.

Based on the above, ENO concludes that the proposed change meets the eligibility criteria for categorical exclusion as set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.

6.0 REFERENCES

1. Letter, ENO to USNRC, PNP 2017-001, Certification of Permanent Cessation of Power Operations, dated January 4, 2017 (ADAMS Accession Number ML17004A062)

2. Letter, ENO to USNRC, License Amendment Request - Administrative Controls for a Permanently Defueled Condition, dated July 27, 2017 (PNP 2017-035), ADAMS Accession Number ML17208A428)

3. Letter, ENO to USNRC, PNP 2017-010, Program Approval - Certified Fuel Handler Training and Retraining Program, dated March 28, 2017 (ADAMS Accession Number ML17087A016)

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ATTACHMENT 1 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGES

4. NUREG-0654, FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 1, published November 1980.

5. Federal Register Volume 76, Number 226, Wednesday, November 23, 2011, Rules and Regulations, Enhancements to Emergency Preparedness Regulations; Final Rule.

6. NSIR/DPR-ISG-01, Interim Staff Guidance - Emergency Planning for Nuclear Power Plants, Revision 0, November 2011 (ADAMS Accession Number ML113010523)

7. NEI 10-05, Rev. 0, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities (ADAMS Accession Number ML111751698)

8. NRC Regulatory Guide 1.101, Emergency Response Planning and Preparedness for Nuclear Power Reactors, Revision 4, July 2003

9. Regulatory Guide 1.219, Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors, November 2011 (ADAMS Accession Number ML102510626)

10. Regulatory Issue Summary 2005-02, "Clarifying the Process for Making Emergency Plan Changes," Revision 1, April 19, 2011 (ADAMS Accession Number ML100340545)

11. Letter, USNRC to Entergy Nuclear Operations, Inc., Vermont Yankee Nuclear Power Station - Issuance of Amendment to Renewed Facility Operating License Re: Changes to the Emergency Plan (TAC No. MF3668), dated February 4, 2015 (ADAMS Accession Number ML14346A065)

12. Letter, USNRC to Omaha Public Power District, Fort Calhoun Station - Unit 1 -

Issuance of Amendment Re: Revise Emergency Plan to Address the Permanently Defueled Condition (CAC No. MF8326), dated July 27, 2017 (ADAMS Accession Number ML17123A348)

13. Letter, USNRC to ENO, Palisades Nuclear Plant - Approval of Certified Fuel Handler Training and Retraining Program (CAC No. MF9500), dated August 21, 2017 (ADAMS Accession Number ML17151A350)

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Attachment 2 To Entergy Letter PNP 2017-034 Palisades Nuclear Plant Tabular Summary of Proposed Changes to the Palisades Nuclear Plant Site Emergency Plan (41 Pages)

PNP Emergency Plan Change Summary After (Pending Revision Emergency Plan Section Before (Rev. 29) Reason for Change Number)

Cover page/Header Palisades Nuclear Plant Site Palisades Nuclear Plant Post Reflect the change to Post Emergency Plan Shutdown Emergency Plan Shutdown.

Procedure No SEP Procedure No SEP Revision 29 Revision TBD New Procedure/Revision Summary List of latest changes made for Rev. Full revision to address Reflect the change to Post 29 implementation of the Post Shutdown.

Shutdown Emergency Plan Table of Contents, 2.4.3 Objectives of the Palisades Site Objectives of the Palisades Post Reflect the change to Post Emergency Plan Shutdown Emergency Plan Shutdown.

Table of Contents, 2.5.1 Site Emergency Plan Supplement 1 PostShutdown Emergency Plan Reflect the change to Post Supplement 1 Shutdown.

Table of Contents, 2.5.2 Site Emergency Plan Supplement 2 PostShutdown Emergency Plan Reflect the change to Post Supplement 2 Shutdown.

Table of Contents, 3.0 Site Emergency Plan Summary PostShutdown Emergency Plan Reflect the change to Post Summary Shutdown.

Table of Contents, 3.1 Emergency Plan Steps PostShutdown Emergency Plan Reflect the change to Post Steps Shutdown.

Table of Contents, 4.0 Emergency Conditions PostShutdown Emergency Reflect the change to Post Conditions Shutdown.

Table of Contents, 5.2.7 Shift Engineers/Shift Technical DELETED The Shift Engineer/Shift Technical Advisors (SE/STA) Advisor will not exist in the post shutdown onshift staff.

Table of Contents, 8.3 Review and Updating of the Review and Updating of the Post Reflect the change to Post Emergency Plan and Implementing Shutdown Emergency Plan and Shutdown.

Procedures Implementing Procedures Table of Contents, Supp 1 SEP, Supp 1, Site Emergency Plan PSEP, Supp 1, PostShutdown Reflect the change to Post Supplement 1 - EAL Wall Charts Emergency Plan Supplement 1 - EAL Shutdown.

(Note: SEP Supp 1 is under separate Wall Charts (Note: PSEP Supp 1 is 1

PNP Emergency Plan Change Summary After (Pending Revision Emergency Plan Section Before (Rev. 29) Reason for Change Number) cover with its own revision number.) under separate cover with its own revision number.)

Table of Contents, Supp 2 SEP Supp 2, Evacuation Time PSEP Supp 2, Evacuation Time Reflect the change to Post Estimates, Revision 1, August 2012 Estimates, Revision 1, August 2012 Shutdown.

(Note: SEP Supp 2 will be maintained (Note: PSEP Supp 2 will be in the same binder as the Site maintained in the same binder as Emergency Plan with its own the PostShutdown Emergency Plan revisions number.) with its own revisions number.)

Source Documents, 3 Entergy Procedure ENHU106, PENHU106, Procedure and Work Fleet procedure revised to be site Procedure and Work Instruction Instruction Use and Adherence specific following shutdown.

Use and Adherence Source Documents, 11 Entergy Procedure ENTQ110, PENTQ110, Emergency Response Fleet procedure revised to be site Emergency Response Organization Organization Training specific following shutdown.

Training Reference Documents, 15 Entergy Procedure ENOM119, On PENOM119, OnSite Safety Fleet procedure revised to be site Site Safety Review Committee Review Committee specific following shutdown.

Reference Documents, 58 Entergy Procedure ENIT103, PENIT103, Nuclear Cyber Security Fleet procedure revised to be site Nuclear Cyber Security Program Program specific following shutdown.

Reference Documents, 62 SEP, Supp 1, Site Emergency Plan PSEP, Supp 1, PostShutdown Reflect the change to Post Supplement 1 - EAL Wall Charts Emergency Plan Supplement 1 - EAL Shutdown.

(Note: SEP Supp 1 is under separate Wall Charts (Note: PSEP Supp 1 is cover with its own revision number.) under separate cover with its own revision number.)

Reference Documents, 63 SEP Supp 2, Evacuation Time PSEP Supp 2, Evacuation Time Reflect the change to Post Estimates, Revision 1, August 2012 Estimates, Revision 1, August 2012 Shutdown.

(Note: SEP Supp 2 will be maintained (Note: PSEP Supp 2 will be in the same binder as the Site maintained in the same binder as Emergency Plan with its own the PostShutdown Emergency Plan revisions number.) with its own revisions number.)

Reference Documents, 65 Entergy Procedure ENTQ110, PENTQ110, Emergency Response Fleet procedure revised to be site 2

PNP Emergency Plan Change Summary After (Pending Revision Emergency Plan Section Before (Rev. 29) Reason for Change Number)

Emergency Response Organization Organization Training specific following shutdown.

Training Reference Documents, 66 Entergy Procedure ENTQ201, PENTQ201, Systematic Approach Fleet procedure revised to be site Systematic Approach to Training to Training Process specific following shutdown.

Process Reference Documents, 67 Entergy Procedure ENEP308, PENEP308, Emergency Planning Fleet procedure revised to be site Emergency Planning Critiques Critiques specific following shutdown.

Reference Documents, 68 Entergy Procedure ENEP306, Drills PENEP306, Drills and Exercises Fleet procedure revised to be site and Exercises specific following shutdown.

Reference Documents, 69 Palisades Nuclear Station OnShift Palisades Nuclear Plant Analysis of Updated for PostShutdown Staffing Analysis, Revision 4, dated Proposed PostShutdown OnShift Analysis.

July 28, 2017 conducted in Staffing, Revision 0, dated August, accordance with NEI 1005 and 2017 conducted as required by required by 10CFR50, Appendix E, 10CFR50, Appendix E, Section IV.A Section IV.A 1.0, Introduction, 1st paragraph The purpose of the Palisades Site The purpose of the Palisades Post Reflect the change to Post Emergency Plan (SEP) is to aid in Shutdown Emergency Plan (PSEP) is Shutdown.

protecting members of the general to aid in protecting members of the public, persons temporarily visiting general public, persons temporarily the site, and site employees. visiting the site, and site employees.

1.0, Introduction, last paragraph Detailed procedures concerning the Detailed procedures concerning the Reflect the change to PostShutdown implementation of the Site implementation of the Post and conversion of Entergy Fleet Emergency Plan are not included Shutdown Emergency Plan are not procedures to sitespecific here, but are included in the included here, but are included in procedures.

Palisades Nuclear Plant Emergency the Palisades Nuclear Plant Implementing Procedures and Emergency Implementing Entergy Fleet Emergency Procedures. These procedures Preparedness Procedures. These describe the duties and actions of procedures describe the duties and individuals and groups in the event actions of individuals and groups in of an emergency and also serve as the event of an emergency and also an interface of the PostShutdown 3

PNP Emergency Plan Change Summary After (Pending Revision Emergency Plan Section Before (Rev. 29) Reason for Change Number) serve as an interface of the Site Emergency Plan with Plant Emergency Plan with Plant operations, security, and radiological operations, security, and radiological controls procedures. Selected controls procedures. Selected elements of the Quality Program are elements of the Quality Program are applied to the PostShutdown applied to the Site Emergency Emergency Planning Function for the Planning Function for the Palisades Palisades Plant.

Plant.

1.1.9, Control Room The location at Palisades Plant from The location at Palisades Plant from After permanent cessation of power which the Reactor and its auxiliary which systems are controlled. The operations and certification of systems are controlled. The assembly area for Control Room permanent removal of fuel from the assembly area for Control Room personnel. reactor vessel, in accordance with 10 personnel. CFR 50.82(a)(1)(i) and (ii), and pursuant to 10 CFR 50.82(a)(2), the 10 CFR 50 license will no longer authorize reactor operation or emplacement or retention of fuel in the reactor vessel.

1.1.10, Control Room Personnel Shift Manager, Nuclear Control The credited onshift complement Palisades will no longer be an Operators, Nuclear Plant Operators, consists of a Shift Manager (qualified operating nuclear power plant. The Shift Engineer/Shift Technical as a Certified Fuel Handler (CFH)) following Control Room onshift Advisor, and Control Room and two (2) NonCertified Operators. positions will be eliminated:

Supervisor.

Shift Engineer/Shift Technical Advisor Nuclear Control Operators Following permanent cessation of power operations and removal of fuel from the reactor vessel, Operations onshift personnel will consist of one (1) Shift Manager and two (2) NonCertified Operators.

Use of the title, NonCertified 4

PNP Emergency Plan Change Summary After (Pending Revision Emergency Plan Section Before (Rev. 29) Reason for Change Number)

Operator, is dependent upon NRC approval of proposed changes to the PNP Technical Specifications that replace references to licensed and nonlicensed operators with references to CFHs and Non Certified Operators. Implementation of the Emergency Plan as revised in this LAR is not dependent upon prior NRC approval of the proposed changes to the PNP Technical Specifications.

1.1.16 Specific procedures providing Specific procedures providing Reflect the change to Post specific actions to implement the specific actions to implement the Shutdown.

Site Emergency Plan in order to PostShutdown Emergency Plan in mitigate or terminate an emergency order to mitigate or terminate an situation. emergency situation.

2.1, General Information and Site The design of the Palisades Nuclear The Palisades Nuclear Power Plant Palisades will no longer be an Description, 2nd paragraph Plant is that of a pressurized water (PNP) ceased power operations and operating nuclear power plant. The type nuclear steam supply system is permanently defueled in Site description has been revised to supplied and manufactured by accordance with 10 CFR indicate the permanently shut down Combustion Engineering. The 50.82(a)(1)(i) and (ii). On January 4, and defueled condition.

system uses chemical shims and 2017, Entergy Nuclear Operations control rods for reactivity control (ENO) submitted a certification of and Utube steam generators. Maps permanent cessation of power identifying Palisades Plant facilities operations pursuant to 10 CFR are provided in Figures 22 and 23. 50.82(a)(1)(i). ENO has submitted written certification to the NRC in accordance with 10 CFR 50.82(1)(ii) that meets the requirements of 10 CFR 50.4(b)(9) certifying that fuel has been permanently removed from the reactor vessel. Upon 5

PNP Emergency Plan Change Summary After (Pending Revision Emergency Plan Section Before (Rev. 29) Reason for Change Number) docketing of these certifications, the 10 CFR Part 50 license for PNP no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel, as specified in 10 CFR 50.82(a)(2).

Maps identifying Palisades Plant facilities are provided in Figures 22 and 23.

2.1, General Information and Site With irradiated fuel being stored in Palisades will no longer be an Description, 3rd paragraph (new) the Spent Fuel Pool and the operating nuclear power plant. The Independent Spent Fuel Storage Site description has been revised to Installation (ISFSI), the reactor indicate the permanently shut down coolant system and secondary and defueled condition.

systems have no function related to the storage of the irradiated fuel. Therefore, the postulated accidents involving failure or malfunction of the reactor and reactor coolant system or secondary systems are no longer applicable.

2.2, Population Distribution and The area within a 10mile radius The area within a 10mile radius Reflect the change to Post Evacuation Times surrounding the Palisades Plant is surrounding the Palisades Plant is Shutdown.

designated as the plume exposure designated as the plume exposure Emergency Planning Zone (EPZ). A Emergency Planning Zone (EPZ). A comprehensive population study comprehensive population study was prepared in August 2012 by KLD was prepared in August 2012 by KLD Engineering. The Evacuation Time Engineering. The Evacuation Time Estimates for the plume EPZ are Estimates for the plume EPZ are adopted as a progeny procedure to adopted as a progeny procedure to Palisades Site Emergency Plan. See Palisades PostShutdown Emergency 6

PNP Emergency Plan Change Summary After (Pending Revision Emergency Plan Section Before (Rev. 29) Reason for Change Number)

SEP Supp 2, "Evacuation Time Plan. See PSEP Supp 2, "Evacuation Estimates." Time Estimates."

2.4.3 Objectives of the Palisades Site Objectives of the Palisades Post Reflect the change to Post Emergency Plan Shutdown Emergency Plan Shutdown.

The objectives of the Site Emergency The objectives of the PostShutdown Plan are to: Emergency Plan are to:

2.5.1 Site Emergency Plan Supplement 1 PostShutdown Emergency Plan Reflect the change to Post Supplement 1 Shutdown.

The "Site Emergency Plan Supplement 1 EAL Wall Charts" The "PostShutdown Emergency Plan contains the Palisades Emergency Supplement 1 EAL Wall Charts" Action Levels in a wall chart format. contains the Palisades Emergency It is part of the Site Emergency Plan. Action Levels in a wall chart format.

Changes to the supplement require It is part of the PostShutdown all the same types of reviews and Emergency Plan. Changes to the approvals as required for the Site supplement require all the same Emergency Plan. Revisions to the types of reviews and approvals as supplement will be tracked by its required for the PostShutdown own revision number, not the SEP's Emergency Plan. Revisions to the revision number. supplement will be tracked by its own revision number, not the PSEP's The "Site Emergency Plan revision number.

Supplement 1 EAL Wall Charts" will be maintained in the same binder as The "PostShutdown Emergency Plan the Site Emergency Plan. Supplement 1 EAL Wall Charts" will be maintained in the same binder as the PostShutdown Emergency Plan.

2.5.2 Site Emergency Plan Supplement 2 PostShutdown Emergency Plan Reflect the change to Post Supplement 2 Shutdown.

The Site Emergency Plan Supplement 2 "Evacuation Time The PostShutdown Emergency Plan Estimates (Revision 1, August 2012)" Supplement 2 "Evacuation Time 7

PNP Emergency Plan Change Summary After (Pending Revision Emergency Plan Section Before (Rev. 29) Reason for Change Number) contains the Palisades updated Estimates (Revision 1, August 2012)"

Evacuation Time Estimates study contains the Palisades updated (Revision 1, August 2012). It is part Evacuation Time Estimates study of the Site Emergency Plan. Changes (Revision 1, August 2012). It is part to the supplement require all the of the PostShutdown Emergency same types of reviews and approvals Plan. Changes to the supplement as required for the Site Emergency require all the same types of reviews Plan. Revisions to the supplement and approvals as required for the will be tracked by its own revision PostShutdown Emergency Plan.

number, not the SEPs revision Revisions to the supplement will be number. tracked by its own revision number, not the PSEPs revision number.

The Site Emergency Plan Supplement 2 "Evacuation Time The PostShutdown Emergency Plan Estimates" will be maintained in the Supplement 2 "Evacuation Time same binder as the Site Emergency Estimates" will be maintained in the Plan. same binder as the PostShutdown Emergency Plan.

2.5.4, Related Plans, Programs, and Several plans, programs, and Several plans, programs, and Reflect the change to Post Procedures, 1st paragraph procedures have been developed to procedures have been developed to Shutdown.

assure the safe operation of the assure the safe operation of the Plant. The Site Emergency Plan and Plant. The PostShutdown Emergency Implementing Emergency Plan and Emergency Procedures have been written to Implementing Procedures have been coordinate these plans with other written to coordinate these plans programs and procedures. During with other programs and emergency situations, the procedures. During emergency coordination and utilization of all situations, the coordination and plans and procedures are essential. utilization of all plans and procedures are essential.

2.5.4, Related Plans, Programs, and The Safeguards Contingency The Safeguards Contingency Reflect the change to Post Procedures, 2nd paragraph Procedures have been coordinated Procedures have been coordinated Shutdown.

8

PNP Emergency Plan Change Summary After (Pending Revision Emergency Plan Section Before (Rev. 29) Reason for Change Number) with the Site Emergency Plan and with the PostShutdown Emergency Emergency Implementing Plan and Emergency Implementing Procedures to minimize the Procedures to minimize the consequences of an emergency consequences of an emergency situation. Security procedures situation. Security procedures contain an explanation of the duties contain an explanation of the duties and responsibilities for security and responsibilities for security personnel in the event of personnel in the event of an emergency. an emergency.

2.5.4, Related Plans, Programs, and The Palisades Emergency Operating DELETED EOPs are not applicable in the Procedures, 4th paragraph Procedures have been developed to permanently shut down and control Plant operation during defueled condition.

emergency situations. These emergency procedures work in conjunction with the Emergency Plan Implementing Procedures.

3.0, title and 1st paragraph SITE EMERGENCY PLAN

SUMMARY

POSTSHUTDOWN EMERGENCY Reflect the change to Post PLAN

SUMMARY

Shutdown.

The Emergency Plan establishes the basic steps that will be used to The PostShutdown Emergency Plan determine the response of the establishes the basic steps that will emergency organization for each of be used to determine the response four emergency classes. The of the emergency organization for emergency classes are as follows: each of four emergency classes. The Unusual Event, Alert, Site Area emergency classes are as follows:

Emergency, and General Emergency. Unusual Event, Alert, Site Area The conditions that must exist for Emergency, and General Emergency.

the declaration of a specific The conditions that must exist for emergency class are presented in the declaration of a specific the Site Emergency Plan, emergency class are presented in Supplement 1 EAL Wall Charts. the PostShutdown Emergency Plan, Supplement 1 EAL Wall Charts.

9

PNP Emergency Plan Change Summary After (Pending Revision Emergency Plan Section Before (Rev. 29) Reason for Change Number) 3.0, 2nd paragraph The declaration of each class will The declaration of each class will Reflect the change to Post lead to specific notification of offsite lead to specific notification of offsite Shutdown.

authorities. Emergency facilities authorities. Emergency facilities shall be activated as described in shall be activated as described in Table 31, "Emergency Classifications Table 31, "Emergency Classifications and the Level of Response by and the Level of Response by Participating Groups," and staffed as Participating Groups," and staffed as presented in Section 5 of the presented in Section 5 of the Palisades Site Emergency Plan. In Palisades PostShutdown Emergency response to a particular event, Plan. In response to a particular certain protective actions may be event, certain protective actions may initiated or certain offsite agencies be initiated or certain offsite may be activated. These actions are agencies may be activated. These detailed in Section 6 of the Palisades actions are detailed in Section 6 of Site Emergency Plan. Palisades the Palisades PostShutdown maintains the capability to assess, Emergency Plan. Palisades classify, and declare an emergency maintains the capability to assess, condition within 15 minutes after classify, and declare an emergency the availability of indications to plant condition within 15 minutes after operators that an emergency action the availability of indications to plant level has been exceeded and operators that an emergency action promptly declares the emergency level has been exceeded and condition as soon as possible promptly declares the emergency following identification of the condition as soon as possible appropriate emergency classification following identification of the level. appropriate emergency classification level.

3.0, 3rd paragraph For emergencies that result in (1) the For emergencies that result in (1) the Reflect the change to Post release of radioactive materials release of radioactive materials Shutdown.

greater than specified levels, or (2) greater than specified levels, or (2) the degradation of barriers to the the degradation of barriers to the release of radioactive materials, release of radioactive materials, assessments of the offsite assessments of the offsite consequences or the projected consequences or the projected 10

PNP Emergency Plan Change Summary After (Pending Revision Emergency Plan Section Before (Rev. 29) Reason for Change Number) offsite consequences shall be made. offsite consequences shall be made.

These assessments will be These assessments will be transmitted to the offsite authorities transmitted to the offsite authorities responsible for taking protective responsible for taking protective actions on behalf of the general actions on behalf of the general public. Recommendations to these public. Recommendations to these offsite authorities will be based on offsite authorities will be based on the protective actions identified in the protective actions identified in Table 62 from the Palisades Site Table 62 from the Palisades Post Emergency Plan. Shutdown Emergency Plan.

3.1 EMERGENCY PLAN STEPS POSTSHUTDOWN EMERGENCY Reflect the change to Post PLAN STEPS Shutdown.

In general, the Emergency Plan encompasses the following basic In general, the PostShutdown steps: Emergency Plan encompasses the following basic steps:

3.2, Entergy Corporation Emergency This Emergency Plan establishes an This PostShutdown Emergency Plan Reflect the change to Post Organization, 1st paragraph organization capable of responding establishes an organization capable Shutdown.

to the complete spectrum of of responding to the complete incidents covered by this Emergency spectrum of incidents covered by Plan. Provisions are made for rapid this PostShutdown Emergency Plan.

notification of appropriate portions Provisions are made for rapid of the response organization, and for notification of appropriate portions expanding the response organization of the response organization, and for if the situation dictates. expanding the response organization if the situation dictates.

3.2, Entergy Corporation Emergency An individual having the authority An individual having the authority Reflect the change to Post Organization, 2nd paragraph and responsibility to initiate any and responsibility to initiate any Shutdown.

emergency actions within the emergency actions within the provisions of this Emergency Plan, provisions of this PostShutdown including the exchange of Emergency Plan, including the information with authorities exchange of information with responsible for coordinating offsite authorities responsible for 11

PNP Emergency Plan Change Summary After (Pending Revision Emergency Plan Section Before (Rev. 29) Reason for Change Number) emergency measures, is onsite at all coordinating offsite emergency times. This individual is the Shift measures, is onsite at all times. This Manager until relieved by the individual is the Shift Manager until Emergency Director. relieved by the Emergency Director.

3.3, Emergency Classifications, last Section 4 from the Palisades Nuclear Section 4 from the Palisades Nuclear Reflect the change to Post paragraph Plant Site Emergency Plan contains a Plant PostShutdown Emergency Shutdown.

more detailed discussion of the Plan contains a more detailed classifications of emergencies. Table discussion of the classifications of 31, "Emergency Classifications and emergencies. Table 31, "Emergency the Level of Response by Classifications and the Level of Participating Groups," shows, in Response by Participating Groups,"

column form, the emergency shows, in column form, the classifications, and the degrees of emergency classifications, and the involvement of onsite and offsite degrees of involvement of onsite organizations. and offsite organizations.

3.4, Emergency Actions, 1st In all instances, when one of the In all instances, when one of the Reflect the change to Post paragraph classifications of the above classifications of the above Shutdown.

emergencies occurs in the Plant, the emergencies occurs in the Plant, the Shift Manager is responsible for Shift Manager is responsible for taking immediate action to taking immediate action to safeguard personnel and equipment. safeguard personnel and equipment.

Utilizing the Palisades Nuclear Plant Utilizing the Palisades Nuclear Plant Emergency Implementing Emergency Implementing Procedures, the Shift Manager shall Procedures, the Shift Manager shall activate the necessary portions of activate the necessary portions of the Site Emergency Plan. The basic the PostShutdown Emergency Plan.

considerations for safe operation of The basic considerations for safe the Plant, and for action in the event operation of the Plant, and for action of an emergency in the Plant, are in the event of an emergency in the summarized as follows: Plant, are summarized as follows:

3.4.a In any event, protection of Plant In any event, protection of Plant Palisades will no longer be an personnel and the public is the personnel and the public is the operating nuclear power plant.

highest priority. A range of highest priority. A range of 12

PNP Emergency Plan Change Summary After (Pending Revision Emergency Plan Section Before (Rev. 29) Reason for Change Number) protective actions to protect onsite protective actions to protect onsite personnel during hostile action is personnel during hostile action is provided to ensure the continued provided to ensure the continued ability to safely shut down the ability to perform the functions of reactor and perform the functions of the emergency plan. Plant system the emergency plan. Plant system and equipment protection is and equipment protection is secondary.

secondary.

4.1, Emergency Classification This Site Emergency Plan provides This PostShutdown Emergency Plan Reflect the change to Post System, 1st paragraph four mutually exclusive provides four mutually exclusive Shutdown.

classifications covering the classifications covering the postulated spectrum of emergency postulated spectrum of emergency situations. For each classification, a situations. For each classification, a particular set of immediate actions particular set of immediate actions to be taken is established as to be taken is established as described in Section 6, of the Site described in Section 6, of the Post Emergency Plan. Actions for each of Shutdown Emergency Plan. Actions the four mutually exclusive for each of the four mutually classifications are defined in exclusive classifications are defined Emergency Implementing in Emergency Implementing Procedure EI1, "Emergency Procedure EI1, "Emergency Classification and Actions," Classification and Actions,"

Attachment 1, "Emergency Actions." Attachment 1, "Emergency Actions."

4.1, Emergency Classification Palisades Emergency Action Levels Palisades Emergency Action Levels Reflect the change to Post System, last paragraph can be found in the "Site Emergency can be found in the "PostShutdown Shutdown.

Plan Supplement 1 EAL Wall Emergency Plan Supplement 1 EAL Charts." Wall Charts."

4.1.3, Site Area Emergency, 1st A Site Area Emergency is defined as A Site Area Emergency is defined as Editorial - added closing quotation paragraph that situation where, "Events are in that situation where, "Events are in mark process or have occurred which process or have occurred which involve an actual or likely major involve an actual or likely major failures of plant functions needed for failures of plant functions needed for protection of the public or HOSTILE protection of the public or HOSTILE 13

PNP Emergency Plan Change Summary After (Pending Revision Emergency Plan Section Before (Rev. 29) Reason for Change Number)

ACTION that results in intentional ACTION that results in intentional damage or malicious acts; (1) toward damage or malicious acts; (1) toward site personnel or equipment that site personnel or equipment that could lead to the likely failure of or; could lead to the likely failure of or; (2) that prevent effective access to (2) that prevent effective access to equipment needed for the equipment needed for the protection of the public. Any protection of the public. Any releases are not expected to result in releases are not expected to result in exposure levels which exceed EPA exposure levels which exceed EPA Protective Action Guideline exposure Protective Action Guideline exposure levels beyond the site boundary. levels beyond the site boundary.

4.1.4, General Emergency, last Guidelines for Plant, State, and local Guidelines for Plant, State, and local Editorial - corrected punctuation paragraph actions are listed in Table 41. Some actions are listed in Table 41. Some and capitalization protective actions may be protective actions may be recommended upon declaration of recommended upon declaration of the General Emergency since the the General Emergency since the lower limits of the EPA PAGs are lower limits of the EPA PAGs are likely to be exceeded. Emergency likely to be exceeded. Emergency Action Levels (EAL) have been Action Levels (EAL) have been selected so that time should be selected so that time should be available to make some available to make some confirmatory measurements in the confirmatory measurements in the field prior to implementation of the field prior to implementation of the more extensive (i.e., evacuation) more extensive (i.e., evacuation) protective action. Some of the protective action. Some of the General Emergency action levels General Emergency action levels require a dose projection calculation require a dose projection calculation using actual meteorology. This using actual meteorology. This differs from the adverse differs from the adverse meteorology assumptions used in meteorology assumptions used in the Site Emergency action levels in the Site Emergency Action Levels in order to remove this builtin order to remove this builtin conservatism and to preclude conservatism and to preclude declaring a General Emergency when declaring a General Emergency when 14

PNP Emergency Plan Change Summary After (Pending Revision Emergency Plan Section Before (Rev. 29) Reason for Change Number) actual conditions do not warrant the actual conditions do not warrant the higher classification. Declaration of higher classification. Declaration of a General Emergency requires a a General Emergency requires a recommendation to the State for recommendation to the State for protective actions for the local protective actions for the local population. population.

5.0, Organizational Control of Emergency planning must consider Emergency planning must consider Palisades will no longer be an Emergencies, 1st paragraph the capabilities of the normally the capabilities of the normally operating nuclear power plant.

present operating staff, augmented present operating staff, augmented by support from other utility by support from other utility personnel and local and distant personnel and local and distant support. The initial phases of an support. The initial phases of an emergency situation at an operating emergency situation at a nuclear power plant will involve a permanently shutdown and defueled relatively small number of nuclear power plant will involve a individuals. These individuals must relatively small number of be capable of: (1) determining that individuals. These individuals must an emergency exists, (2) providing be capable of: (1) determining that initial classification and assessment, an emergency exists, (2) providing and (3) promptly notifying other initial classification and assessment, groups and individuals in the and (3) promptly notifying other emergency organization. groups and individuals in the emergency organization.

5.0, Organizational Control of This section of the Site Emergency This section of the PostShutdown Reflect the change to Post Emergencies, 3rd paragraph Plan addresses the assignment of Emergency Plan addresses the Shutdown.

personnel and the establishment of assignment of personnel and the responsibilities and authority for the: establishment of responsibilities and authority for the:

5.1, Palisades Plant Organization The Palisades Nuclear Plant The Palisades Nuclear Plant shift Palisades will no longer be an operating and shift engineering activities are under the control of operating nuclear power plant.

activities are under the control of the General Manager, Plant the General Manager, Plant Operations. The shift activities at Operations. The operating and shift the Plant are conducted by 15

PNP Emergency Plan Change Summary After (Pending Revision Emergency Plan Section Before (Rev. 29) Reason for Change Number) engineering activities at the Plant operating crews on twelvehour are conducted by operating crews shifts. Each twelvehour shift is on twelvehour shifts. Each twelve responsible for continuous operation hour shift is responsible for of the Plant.

continuous operation of the Plant.

5.2, Operating and Engineering The Palisades Plant organization The Palisades Plant organization After permanent cessation of power Organization includes personnel encompassing includes personnel encompassing operations and certification of both the management and both the management and permanent removal of fuel from the operation of the unit. The minimum operations staff. The minimum on reactor vessel, in accordance with 10 onshift staffing is indicated in Figure shift staffing is indicated in Figure 5 CFR 50.82(a)(1)(i) and (ii), and

52. 2. pursuant to 10 CFR 50.82(a)(2), the 10 CFR 50 license will no longer authorize reactor operation or emplacement or retention of fuel in the reactor vessel.

5.2.6, Shift Manager The Shift Manager, one of whom is The Shift Manager, one of whom is Following permanent cessation of on duty at all times, is responsible on duty at all times, is responsible power operations and certification for the safe and efficient operation for the safe and efficient operation of permanent removal of fuel from of the Plant during his assigned shift. of the Plant during his assigned shift. the reactor vessel, Operations on He maintains control over Plant The Shift Manager maintains control shift personnel will consist of one (1) operations as the Senior Licensed over Plant operations as the Shift Manager, who will be a Operator unless he is properly Certified Fuel Handler (CFH) unless qualified Certified Fuel Handler relieved by another member of the properly relieved by another Shift (CFH). Use of the title, CFH, is Plant staff who holds a valid Senior Manager. In an emergency dependent upon NRC approval of Operator's License. In an emergency condition, the Shift Manager initially proposed changes to the PNP condition, the Shift Manager initially assumes the role of Emergency Technical Specifications that replace assumes the role of Emergency Director. references to licensed and non Director. licensed operators with references to CFHs and NonCertified Operators. Implementation of the Emergency plan as revised in this LAR is not dependent upon prior NRC approval of the proposed 16

PNP Emergency Plan Change Summary After (Pending Revision Emergency Plan Section Before (Rev. 29) Reason for Change Number) changes to the PNP Technical Specifications.

5.2.7 Shift Engineers/Shift Technical DELETED Palisades will no longer be an Advisors (SE/STA) operating nuclear power plant. The SE/STA position will be eliminated.

Shift Engineers/Shift Technical Advisors function in an oversight The proposed elimination of the role for accident assessment and SE/STA position has been evaluated evaluation of operating conditions. in the PNP analysis of proposed While on duty, SE/STAs diagnose postshutdown onshift staffing in abnormal events and report to the conjunction with the postulated Shift Manager. In an emergency accidents that will be applicable in condition, the SE/STA provides SEP the permanently defueled condition.

oversight and may assist the Shift Manager in his role as Emergency Director.

5.3, Palisades Emergency Response In the event of an emergency in In the event of an emergency in Reflect the change to Post Organization, 1st paragraph which one of the classification levels which one of the classification levels Shutdown.

is declared (Unusual Event, Alert, is declared (Unusual Event, Alert, Site Area Emergency, or General Site Area Emergency, or General Emergency), all or a portion of the Emergency), all or a portion of the Site Emergency Plan will be PostShutdown Emergency Plan will activated. The assignment of be activated. The assignment of responsibilities in the Emergency responsibilities in the Emergency Response Organization (ERO) is Response Organization (ERO) is ultimately the responsibility of the ultimately the responsibility of the General Manager, Plant Operations. General Manager, Plant Operations.

However, the ERO is predefined and However, the ERO is predefined and alternate assignments to various alternate assignments to various positions are specified to provide for positions are specified to provide for automatic, unambiguous manning of automatic, unambiguous staffing of the emergency organization within the emergency organization within the time necessary to respond to the the time necessary to respond to the 17

PNP Emergency Plan Change Summary After (Pending Revision Emergency Plan Section Before (Rev. 29) Reason for Change Number) emergency. emergency.

5.3.1, Control Room The Control Room is designed to be The Control Room is designed to be Palisades will no longer be an habitable under accident conditions habitable under accident conditions operating nuclear power plant.

and shall serve as the onsite and shall serve as the onsite Emergency Control Center. Emergency Control Center.

Emergency lighting, power, air Emergency lighting, power, air filtrationventilation system, and filtrationventilation system, and shielded walls enable the operators shielded walls enable the operators to remain in the Control Room to to remain in the Control Room to ensure that the reactor remains in a ensure that the plant remains in a safe condition. The minimum on safe condition. The minimum on shift staffing is indicated in Figure 5 shift staffing is indicated in Figure 5

2. 2.

5.3.4, Emergency Operations Facility, The design features of the EOF are The design features of the EOF are Reflect the change to Post last paragraph discussed in Palisades Site discussed in Palisades Post Shutdown.

Emergency Plan, Section 7.0, Shutdown Emergency Plan, "Emergency Facilities and Section 7.0, "Emergency Facilities Equipment." and Equipment."

5.3.5, Joint Information Center The plant Communications The plant Communications Editorial - grammatical correction personnel shall be responsible for personnel shall be responsible for maintenance of the Palisades maintenance of the Palisades Nuclear Plant Public Information Nuclear Plant Public Information Policies and Procedures. These Policies and Procedures. These provide for disseminating provide for disseminating information to the public via the information to the public via the media and establishing a system for media and establishing a system for rumor control during an emergency. rumor control during an emergency.

Public Affairs personnel shall Public Affairs personnel shall coordinate the activation and coordinate the activation and management of the Joint management of the Joint Information Center (JIC) in Information Center (JIC) in cooperation with the Corporate cooperation with the Corporate Public Affairs Department. He shall Public Affairs Department. Public 18

PNP Emergency Plan Change Summary After (Pending Revision Emergency Plan Section Before (Rev. 29) Reason for Change Number) prepare and issue press releases in Affairs personnel shall prepare and cooperation with state and local issue press releases in cooperation agencies. Reference Palisades with state and local agencies.

Nuclear Plant Emergency Public Reference Palisades Nuclear Plant Information Policies and Procedures Emergency Public Information for details. Policies and Procedures for details.

5.4.1, Shift Manager/EOF Emergency The Shift Manager/EOF Emergency The Shift Manager/EOF Emergency Reflect the change to Post Director Director is responsible for the overall Director is responsible for the overall Shutdown.

assessment of emergency assessment of emergency Editorial - grammatical correction conditions, especially where conditions, especially where emergency conditions present a real emergency conditions present a real or potential hazard to offsite or potential hazard to offsite persons or property. The Shift persons or property. The Shift Manager/EOF Emergency Director Manager/EOF Emergency Director will have the overall responsibility will have the overall responsibility for operational decisions involving for operational decisions involving the safety of the Plant and its the safety of the Plant and its personnel, and for making personnel, and for making recommendations based on recommendations based on technical information supplied by technical information supplied by support personnel regarding the support personnel regarding the general public during an emergency general public during an emergency situation. He will also implement situation. The Shift Manager/EOF the Palisades Site Emergency Plan Emergency Director will also through the use of specific implement the Palisades Post Emergency Plan Implementing Shutdown Emergency Plan through Procedures. The Shift Manager/EOF the use of specific Emergency Plan Emergency Director is responsible Implementing Procedures. The Shift for ensuring the capability for Manager/EOF Emergency Director is continuous operation of emergency responsible for ensuring the response centers, including capability for continuous operation personnel and material resources. In of emergency response centers, addition, the Shift Manager/EOF including personnel and material Emergency Director is responsible resources. In addition, the Shift 19

PNP Emergency Plan Change Summary After (Pending Revision Emergency Plan Section Before (Rev. 29) Reason for Change Number) for providing offsite officials with Manager/EOF Emergency Director is pertinent information regarding the responsible for providing offsite conditions at the Plant. officials with pertinent information regarding the conditions at the Plant.

5.4.2 NOTE The Shift Manager assumes the The Shift Manager assumes the Reflect the change to Post responsibilities of the Site responsibilities of the Post Shutdown.

Emergency Plan until relieved by the Shutdown Emergency Plan until EOF Director. relieved by the EOF Director.

5.5, Recovery Organization, 1st Recovery after an emergency Recovery after an emergency Reflect the change to Post paragraph condition will be handled by the condition will be handled by the Shutdown.

emergency organization unless emergency organization unless conditions indicate that recovery will conditions indicate that recovery will be complicated or will take a long be complicated or will take a long period of time. At the discretion of period of time. At the discretion of the EOF Emergency Director, the the EOF Emergency Director, the Plant will shift from an emergency Plant will shift from an emergency organization structure to a Recovery organization structure to a Recovery Organization. Guidelines that will be Organization. Guidelines that will be employed for determining this shift employed for determining this shift are explained in Palisades Site are explained in Palisades Post Emergency Plan, Section 9.0, Shutdown Emergency Plan, "Recovery." Section 9.0, "Recovery."

5.5, Recovery Organization, last The TSC Engineering Coordinator will The TSC Engineering Coordinator will After permanent cessation of power paragraph also support the EOF Rad also support the EOF Rad operations and certification of Assessment Coordinator in Assessment Coordinator in permanent removal of fuel from the determining how much radioactivity determining how much radioactivity reactor vessel, in accordance with 10 potentially can be released to the potentially can be released to the CFR 50.82(a)(1)(i) and (ii), and atmosphere based on the nature atmosphere based on the nature pursuant to 10 CFR 50.82(a)(2), the and extent of core damage. and extent of spent fuel damage. 10 CFR 50 license will no longer authorize reactor operation or emplacement or retention of fuel in the reactor vessel. As a result, the 20

PNP Emergency Plan Change Summary After (Pending Revision Emergency Plan Section Before (Rev. 29) Reason for Change Number) extent of core damage is no longer applicable. With irradiated fuel being stored in the Spent Fuel Pool, it becomes the focus of the assessment.

5.6 OffSite Emergency Response In those cases where agency In those cases where agency Editorial - correct punctuation and Services assistance is mandated by law (ie, assistance is mandated by law (i.e., capitalization.

the State of Michigan), a letter of the State of Michigan), a letter of agreement may be excluded from agreement may be excluded from the plan. The services provided by the Plan. The services provided by local support groups are listed in the local support groups are listed in the following sections. following sections.

5.6.5, Berrien County Emergency Site Emergency Plan, Section 7.0, PostShutdown Emergency Plan, Reflect the change to Post Management, 1st paragraph, last "Emergency Facilities and Section 7.0, "Emergency Facilities Shutdown.

sentence Equipment," summarizes and Equipment," summarizes communications. communications.

5.6.5, Berrien County Emergency The Chief of Staff (Director of The Chief of Staff (Director of Editorial - grammatical correction Management, 2nd paragraph Emergency Management) is Emergency Management) is responsible for initiating the responsible for initiating the staffing manning of the EOC. By prior of the EOC. By prior agreement agreement between counties, between counties, communications communications between the Plant between the Plant and Berrien and Berrien County will normally be County will normally be directed directed through Van Buren County. through Van Buren County.

5.6.6, Allegan County Office of Palisades Site Emergency Plan, Palisades PostShutdown Emergency Reflect the change to Post Emergency Preparedness, 1st Section 7.0, "Emergency Facilities Plan, Section 7.0, "Emergency Shutdown.

paragraph, last sentence and Equipment," summarizes Facilities and Equipment,"

communications. summarizes communications.

5.7, Coordination with The coordination between the state, The coordination between the state, Reflect the change to Post Governmental Authorities, 1st county, and federal emergency plans county, and federal emergency plans Shutdown.

21

PNP Emergency Plan Change Summary After (Pending Revision Emergency Plan Section Before (Rev. 29) Reason for Change Number) sentence and the Palisades Site Emergency and the Palisades PostShutdown Plan serves to ensure the safety and Emergency Plan serves to ensure the health of the public. safety and health of the public.

5.7.1.b, Michigan State Police - Paw Communications are detailed in Communications are detailed in Reflect the change to Post Paw Post, last sentence Palisades Site Emergency Plan, Palisades PostShutdown Emergency Shutdown.

Section 7.0, "Emergency Facilities Plan, Section 7.0, "Emergency and Equipment." Facilities and Equipment."

5.7.2.a, Nuclear Regulatory The NRC shall be notified within an The NRC shall be notified within an Reflect the change to Post Commission (NRC), 1st paragraph, hour, anytime all or part of the Site hour, anytime all or part of the Post Shutdown.

last 2 sentences Emergency Plan is activated. Means Shutdown Emergency Plan is of communications are described in activated. Means of the Site Emergency Plan, Section 7.0, communications are described in the "Emergency Facilities PostShutdown Emergency Plan, and Equipment." Section 7.0, "Emergency Facilities and Equipment."

Figure 52, Title Plant Staffing and Augmentation PostShutdown Plant Staffing and Reflect the change to Post Requirements Augmentation Requirements Shutdown.

Figure 52, Major Functional Area - Shift Engineer/Shift Technical Shift Manager 1 Palisades will no longer be an Plant Operations and Assessment of Advisor (SRO) 1 NonCertified Operator 2 operating nuclear power plant. The Operational Aspects Shift Manager (SRO) 1 following onshift positions will be Control Room Supervisor (SRO) 1 eliminated:

Nuclear Control Operators 2 Shift Engineer/Shift Nuclear Plant Operators** 6 Technical Advisor Two (2) Nuclear Control Operators One (1) Nuclear Plant Operators Following permanent cessation of power operations and certification of permanent removal of fuel from 22

PNP Emergency Plan Change Summary After (Pending Revision Emergency Plan Section Before (Rev. 29) Reason for Change Number) the reactor vessel, Operations on shift personnel will consist of one (1)

Shift Manager and two (2) Non Certified Operators. Use of the titles, CFH and NonCertified Operator, are dependent upon NRC approval of proposed changes to the PNP Technical Specifications that replace references to licensed and non licensed operators with references to CFHs and NonCertified Operators. Implementation of the Emergency plan as revised in this LAR is not dependent upon prior NRC approval of the proposed changes to the PNP Technical Specifications.

These staffing levels have been evaluated in the PNP analysis of proposed postshutdown onshift staffing in conjunction with the postulated accidents that will be applicable in the permanently defueled condition.

Figure 52, Major Functional Area - OnShift 1 OnShift 1* Palisades will no longer be an Notification/Communication operating nuclear power plant. On 60 Min. Augmentation 3 60 Min, Augmentation 2 Shift Notification/Communication tasks will be transferred to the Non Certified Operator.

This transfer of duties has been evaluated in the PNP analysis of proposed postshutdown onshift staffing in conjunction with the 23

PNP Emergency Plan Change Summary After (Pending Revision Emergency Plan Section Before (Rev. 29) Reason for Change Number) postulated accidents that will be applicable in the permanently defueled condition.

60 minute augmentation staff will consist of the ENS Communicator and the Offsite Communicator. The redundant position of State/County Communicator will be eliminated.

The proposed elimination of the redundant State and County Communicator position has been evaluated in the PNP analysis of postshutdown ERO staffing.

Figure 52, Major Functional Area - Chem Technician Onshift 1 RP Technician Onshift 1* Palisades will no longer be an Radiological Accident Assessment operating nuclear power plant. The 60 Min Augmentation 1 60 Min Augmentation and Support of Operational Accident onshift Chemistry Technician Assessment position will be eliminated.

Removal of the onshift Chemistry Technician has been evaluated in the PNP analysis of proposed post shutdown onshift staffing in conjunction with the postulated accidents that will be applicable in the permanently defueled condition.

Removal of the augmenting Chemistry Technician position does not impact the ability of the onshift or ERO staff to perform dose assessment.

Figure 52, Major Functional Area - RP Technician - OnShift 2 RP Technician - OnShift 1 Palisades will no longer be an Radiation Protection operating nuclear power plant.

24

PNP Emergency Plan Change Summary After (Pending Revision Emergency Plan Section Before (Rev. 29) Reason for Change Number) 60 Min Augmentation 3 60 Min Augmentation 2 Removal of the onshift RP Technician has been evaluated in the 90 Min Augmentation 3 90 Min Augmentation PNP analysis of proposed post shutdown onshift staffing in conjunction with the postulated accidents that will be applicable in the permanently defueled condition.

Reduction in the number of augmenting RP Technicians has been evaluated in the PNP analysis of postshutdown ERO staffing.

Figure 52, Major Functional Area - Core/Thermal Hydraulics (Shift) 1* Electrical/Mechanical Palisades will no longer be an Plant System Engineering, Repair, Core/Thermal (60 Min Aug) 1 (60 Min Aug) 1 operating nuclear power plant.

and Corrective Actions - Technical Electrical (60 Min Aug) 1 After permanent cessation of power Support Mechanical (60 Min Aug) 1 operations and certification of permanent removal of fuel from the reactor vessel, the 10 CFR 50 license will no longer authorize reactor operation or emplacement or retention of fuel in the reactor vessel. As a result the Core/Thermal Hydraulic Engineer is no longer needed.

The Engineering Coordinator will perform Engineering functions in the TSC. The spectrum of credible and operational events, and the quantity and complexity of activities required for the safe storage of spent nuclear fuel is reduced as compared to an operating plant. The set of plant equipment required in the 25

PNP Emergency Plan Change Summary After (Pending Revision Emergency Plan Section Before (Rev. 29) Reason for Change Number) permanently defueled condition is also greatly reduced, which reduces the assessment and mitigation activities the TSC must perform.

Reduction in the number of augmenting Engineers has been evaluated in the PNP analysis of postshutdown ERO staffing.

Figure 52, Major Functional Area - Mechanical Maintenance 60 Min Mechanical Maintenance 60 Min Palisades will no longer be an Plant System Engineering, Repair, Augmentation 1 Augmentation 1 operating nuclear power plant.

and Corrective Actions - Repair and Radwaste Operator - 60 Min Electrical Maintenance - 60 Min After permanent cessation of power Corrective Actions Augmentation 1 Augmentation 1 operations and certification of Electrical Maintenance - 60 Min permanent removal of fuel from the Augmentation 2 reactor vessel, the 10 CFR 50 license Instrument and Control will no longer authorize reactor (I&C) Technician - 60 Min operation or emplacement or Augmentation 1 retention of fuel in the reactor vessel.

The spectrum of credible and operational events, and the quantity and complexity of activities required for the safe storage of spent nuclear fuel is reduced as compared to an operating plant. The set of plant equipment required in the permanently defueled condition is also greatly reduced, which reduces the repair and corrective action activities the OSC must perform.

Figure 52 Total (OnShift) 15 4 Reduction in the number of onshift staff has been evaluated in the PNP analysis of proposed postshutdown 26

PNP Emergency Plan Change Summary After (Pending Revision Emergency Plan Section Before (Rev. 29) Reason for Change Number) onshift staffing in conjunction with the postulated accidents that will be applicable in the permanently defueled condition.

Figure 52 Total (60 Min 20 12 Reduction in the number of 60 Augmentation) minute augmenting ERO staff has been evaluated in the PNP analysis of postshutdown ERO staffing.

Figure 52 Total (90 Min 5 2 Reduction in the number of 90 Augmentation) minute augmenting ERO staff has been evaluated in the PNP analysis of postshutdown ERO staffing.

Figure 52, Note ** Each of up to 2 of the 6 onshift NPO Deleted Following permanent cessation of positions may be filled by a fire power operations and certification brigade qualified person who is also of permanent removal of fuel from minor maintenance qualified; or the reactor vessel, Operations on alternately by 2 persons per required shift personnel will consist of one (1)

NPO, one fire brigade qualified and Shift Manager and two (2) Non the other minor maintenance Certified Operators. Because the qualified. note is in reference to the Nuclear Plant Operator position, it becomes unnecessary.

6.1, Activation of Emergency If it appears that an incident or If it appears that an incident or Reflect the change to Post Organization, 1st paragraph condition may meet or exceed a condition may meet or exceed a Shutdown.

predetermined value or condition predetermined value or condition specified as an Emergency Action specified as an Emergency Action Level in Emergency Implementing Level in Emergency Implementing Procedure EI1, "Emergency Procedure EI1, "Emergency Classification and Actions," and SEP Classification and Actions," and PSEP Supplement 1 "SITE EMERGENCY Supplement 1 "POSTSHUTDOWN PLAN Supplement 1 EAL Wall EMERGENCY PLAN Supplement 1 Charts" then certain portions of this EAL Wall Charts" then certain 27

PNP Emergency Plan Change Summary After (Pending Revision Emergency Plan Section Before (Rev. 29) Reason for Change Number) plan and specific procedures shall portions of this plan and specific require implementation. procedures shall require implementation.

6.1, Activation of Emergency The Shift Manager will initially The Shift Manager will initially Palisades will no longer be an Organization, last paragraph classify the emergency and ensure classify the emergency and ensure operating nuclear power plant. The required notifications are made. The required notifications are made. The SE/STA position will be eliminated.

Shift Manager shall ensure that an Shift Manager shall ensure that an The proposed elimination of the overall assessment of the emergency overall assessment of the emergency SE/STA position has been evaluated is performed in order to determine is performed in order to determine in the PNP analysis of proposed the most appropriate classification the most appropriate classification postshutdown onshift staffing in and, based on this determination, and, based on this determination, conjunction with the postulated activate portions of the emergency activate portions of the emergency accidents that will be applicable in organization as necessary. The Shift organization as necessary. The the permanently defueled condition.

Engineer/Shift Technical Advisor may methodology used in activating the assist the Shift Manager in emergency organizations during performing these functions. The each class of emergency is provided methodology used in activating the in the following sections:

emergency organizations during each class of emergency is provided in the following sections:

6.1.1.a, Control Room Personnel Should emergency conditions, either Should emergency conditions, either Palisades will no longer be an real or potential, arise, it is expected real or potential, arise, it is expected operating nuclear power plant. The that the Nuclear Control Operators that the Shift Manager will initially Nuclear Control Operator positions and the Shift Manager will initially be made aware of the situation by will be eliminated.

be made aware of the situation by alarms, instrument readings, reports, These staffing levels have been alarms, instrument readings, etc. The Shift Manager shall ensure evaluated in the PNP analysis of reports, etc. The Shift Manager shall that the General Manager, Plant proposed postshutdown onshift ensure that the General Manager, Operations or Duty Station Manager staffing in conjunction with the Plant Operations or Duty Station on backshift and weekends is postulated accidents that will be Manager on backshift and weekends immediately informed of any applicable in the permanently is immediately informed of any possible emergency situation.

defueled condition.

possible emergency situation.

6.1.1.b The Shift Manager is responsible for The Shift Manager is responsible for After permanent cessation of power ensuring the performance of the ensuring the performance of the operations and certification of 28

PNP Emergency Plan Change Summary After (Pending Revision Emergency Plan Section Before (Rev. 29) Reason for Change Number) initial assessment of the emergency initial assessment of the emergency permanent removal of fuel from the (eg, Plant and reactor status, (e.g., Plant and spent fuel pool reactor vessel, in accordance with 10 radiological conditions, etc) in the status, radiological conditions, etc.) CFR 50.82(a)(1)(i) and (ii), and following manner: in the following manner: pursuant to 10 CFR 50.82(a)(2), the 10 CFR 50 license will no longer authorize reactor operation or emplacement or retention of fuel in the reactor vessel. As a result, reactor status is no longer applicable. With irradiated fuel being stored in the Spent Fuel Pool, it becomes the focus of the assessment.

Editorial - punctuation corrections.

6.1.1.b.1 Determine the immediate actions Determine the immediate actions Palisades will no longer be an necessary to be taken to ensure the necessary to be taken to ensure the operating nuclear power plant. The safe and proper operation of the safe and proper operation of the SE/STA position will be eliminated.

Plant. The Shift Engineer will advise Plant.

The proposed elimination of the and assist the Shift Manager on SE/STA position has been evaluated matters pertaining to the safe and in the PNP analysis of proposed proper operations of the station postshutdown onshift staffing in with regard to nuclear safety.

conjunction with the postulated accidents that will be applicable in the permanently defueled condition.

6.1.2, Emergency Plant Manager, 1st The Shift Manager will continue to The Shift Manager will continue to Reflect the change to Post sentence perform the Command and Control perform the Command and Control Shutdown.

actions of the Site Emergency Plan actions of the PostShutdown until relieved by the EOF Director. Emergency Plan until relieved by the EOF Director.

6.1.2.h Advise the ED on core damage and Advise the ED on plant conditions for After permanent cessation of power plant conditions for classification classification and PAR determination operations and certification of and PAR determination permanent removal of fuel from the 29

PNP Emergency Plan Change Summary After (Pending Revision Emergency Plan Section Before (Rev. 29) Reason for Change Number) reactor vessel, in accordance with 10 CFR 50.82(a)(1)(i) and (ii), and pursuant to 10 CFR 50.82(a)(2), the 10 CFR 50 license will no longer authorize reactor operation or emplacement or retention of fuel in the reactor vessel. As a result, core damage is no longer applicable.

6.1.2.n Implement severe accident DELETED (subsequent steps Palisades will no longer be an management procedure strategies. renumbered) operating nuclear power plant. The severe accident management procedures are entered from the EOPs. The EOPs are no longer applicable in the permanently shutdown and defueled condition; therefore the severe accident management procedure strategies are no longer applicable.

6.2.3.a An increased amount of Plant An increased amount of Plant Palisades will no longer be an instrumentation shall be monitored, instrumentation shall be monitored. operating nuclear power plant.

in particular, indications of core After permanent cessation of power status (eg, in core thermocouple operations and certification of readings, etc) shall be monitored. permanent removal of fuel from the reactor vessel, in accordance with 10 CFR 50.82(a)(1)(i) and (ii), and pursuant to 10 CFR 50.82(a)(2), the 10 CFR 50 license will no longer authorize reactor operation or emplacement or retention of fuel in the reactor vessel. As a result, core status is no longer applicable.

6.3.3, System Control System design is aimed at automatic System design is aimed at automatic Palisades will be permanently shut corrective actions, such as Plant corrective actions, such as system 30

PNP Emergency Plan Change Summary After (Pending Revision Emergency Plan Section Before (Rev. 29) Reason for Change Number) shutdown and system isolation, isolation, whenever operating down.

whenever operating parameters parameters become abnormal.

become abnormal. Operating Operating procedures are written for procedures are written for manual manual control of these same control of these same situations, situations, should automatic should automatic features fail. features fail.

7.1.3, Operations Support Center, The function of the OSC is to The function of the OSC is to Title change of NPO to NonCertified 2nd paragraph assemble and coordinate necessary assemble and coordinate necessary Operator is dependent upon NRC personnel from Chemistry, Radiation personnel from Chemistry, Radiation approval of proposed changes to the Protection, Operations (NPOs), I&C, Protection, Operations (Non PNP Technical Specifications that Electrical, and Mechanical. These Certified Operators), I&C, Electrical, replace references to licensed and groups will be dispatched for specific and Mechanical. These groups will nonlicensed operators with jobs as directed by the TSC. be dispatched for specific jobs as references to CFHs and Non directed by the TSC. Certified Operators. Implementation of the Emergency plan as revised in this LAR is not dependent upon prior NRC approval of the proposed changes to the PNP Technical Specifications.

7.2 Emergency Operations Facility, Palisades Technical Specifications Palisades Technical Specifications Reflect the change to Post list following 4th paragraph Palisades Operating Procedures Palisades Operating Procedures Shutdown.

Palisades Final Safety Analysis Palisades Final Safety Analysis EOPs are not applicable in the Report Report permanently shutdown condition.

Palisades Abnormal Operating Palisades Abnormal Operating Procedures Procedures Palisades Emergency Operating Palisades PostShutdown Emergency Procedures Plan Palisades Site Emergency Plan Palisades Emergency Implementing Palisades Emergency Implementing Procedures Procedures Michigan Emergency Management Michigan Emergency Management Plan Plan Van Buren County Emergency Plan 31

PNP Emergency Plan Change Summary After (Pending Revision Emergency Plan Section Before (Rev. 29) Reason for Change Number)

Van Buren County Emergency Plan Berrien County Emergency Plan Berrien County Emergency Plan Allegan County Emergency Plan Allegan County Emergency Plan Palisades Piping and Instrument Palisades Piping and Instrument Diagrams Diagrams 7.7.2, Laboratory Facilities, 3rd GEL Laboratory maintains a GEL Laboratory maintains a Editorial - correct spelling paragraph, last sentence laboratory in Charlseton, South laboratory in Charleston, South Carolina which has the capability to Carolina which has the capability to perform chemical and radiological perform chemical and radiological analyses. analyses.

7.8.6.a, last sentence In addition to breathing apparatus, In addition to breathing apparatus, Editorial - correct punctuation thyroidblocking agents thyroidblocking agents (ie, potassium iodide) will be (i.e., potassium iodide) will be dispensed for onsite personnel in dispensed for onsite personnel in accordance with Emergency accordance with Emergency Implementing Procedures. Implementing Procedures.

Table 71 Palisades SEP Communications Palisades PSEP Communications Reflect the change to Post Matrix Matrix Shutdown.

8.0, Maintaining Emergency Palisades Plant shall maintain the Palisades Plant shall maintain the Reflect the change to Post Preparedness, 1st paragraph Site Emergency Plan and the PostShutdown Emergency Plan and Shutdown.

Palisades Nuclear Plant Emergency the Palisades Nuclear Plant Implementing Procedures as two Emergency Implementing separate documents. It is intended Procedures as two separate that this Emergency Plan, although documents. It is intended that this considered part of Palisades Nuclear PostShutdown Emergency Plan, Power Plant's Final Safety Analysis although considered part of Report (FSAR), be maintained as a Palisades Nuclear Power Plant's Final separate document. Safety Analysis Report (FSAR), be maintained as a separate document.

8.0, Maintaining Emergency In order to meet the constantly In order to meet the constantly Reflect the change to Post changing conditions, methods have changing conditions, methods have 32

PNP Emergency Plan Change Summary After (Pending Revision Emergency Plan Section Before (Rev. 29) Reason for Change Number)

Preparedness, 3rd paragraph been implemented to ensure that been implemented to ensure that Shutdown.

the Site Emergency Plan and the PostShutdown Emergency Plan Implementing Procedures remain and Implementing Procedures effective over the life of the Plant. remain effective over the life of the Efforts shall be made to assure Plant. Efforts shall be made to continuous emergency preparedness assure continuous emergency and operational readiness among preparedness and operational Entergy personnel and the offsite readiness among Entergy personnel response agencies and and the offsite response agencies organizations. and organizations.

8.1.1, Training Palisades Plant personnel, including Palisades Plant personnel, including Reflect the change to Post nonpermanent personnel, will nonpermanent personnel, will Shutdown.

receive training pertinent to the Site receive training pertinent to the Fleet procedure changed to site Emergency Plan and Implementing PostShutdown Emergency Plan and specific procedure.

Procedures. Persons assigned Implementing Procedures. Persons specific responsibilities during an assigned specific responsibilities emergency will receive additional during an emergency will receive training appropriate to their additional training appropriate to respective assignments. The their respective assignments. The responsibility for training is that of responsibility for training is that of the Training Manager. He may the Training Manager. He may delegate specialtytraining delegate specialtytraining responsibilities to personnel responsibilities to personnel qualified to perform such training, qualified to perform such training, for example, State or County training for example, State or County training personnel. Governance of personnel. Governance of Emergency Response Organization Emergency Response Organization Training for Entergy personnel is Training for Entergy personnel is provided by Entergy Procedure provided by Procedure PENTQ110, ENTQ110, "Emergency Response "Emergency Response Organization Organization Training." This Training." This procedure describes procedure describes the the responsibilities for conducting responsibilities for conducting and and administering initial and administering initial and continuing continuing emergency preparedness 33

PNP Emergency Plan Change Summary After (Pending Revision Emergency Plan Section Before (Rev. 29) Reason for Change Number) emergency preparedness training; training; provides clarification and provides clarification and details to details to implement a remediation implement a remediation process; process; and follows the guidance of and follows the guidance of ENTQ PENTQ201,"Systematic Approach 201,"Systematic Approach to to Training Process," and P Training Process," and ENEP308, ENEP308, "Emergency Planning "Emergency Planning Critiques." Critiques."

8.1.2.b, Drills and Exercises Verify the adequacy of the Palisades Verify the adequacy of the Palisades Reflect the change to Post Plant Site Emergency Plan and the Plant PostShutdown Emergency Shutdown.

methods used in the Implementing Plan and the methods used in the Procedures. Implementing Procedures.

8.1.2, Drills and Exercises, last Recommendations for revisions to Recommendations for revisions to Reflect the change to Post paragraph the Palisades Nuclear Power Plant the Palisades Nuclear Power Plant Shutdown.

Site Emergency Plan and/or PostShutdown Emergency Plan Implementing Procedures and/or and/or Implementing Procedures upgrading of emergency equipment and/or upgrading of emergency and supplies as a result of a drill or equipment and supplies as a result exercise will be forwarded to of a drill or exercise will be Emergency Planning by observers forwarded to Emergency Planning by and participants for inclusion in a observers and participants for formal critique. After review, inclusion in a formal critique. After recommendations will be forwarded review, recommendations will be to the Manager, Emergency forwarded to the Manager, Preparedness for comments. Emergency Preparedness for Recommended changes that are comments. Recommended changes approved by the Regulatory and that are approved by the Regulatory Performance Improvement Director and Performance Improvement will be incorporated into the Site Director will be incorporated into Emergency Plan and Implementing the PostShutdown Emergency Plan Procedures. Records shall be and Implementing Procedures.

maintained on drills and exercises Records shall be maintained on drills conducted at the Palisades Plant. and exercises conducted at the Palisades Plant.

34

PNP Emergency Plan Change Summary After (Pending Revision Emergency Plan Section Before (Rev. 29) Reason for Change Number) 8.1.3.e, Radiological Emergency A critique shall be scheduled at the A critique shall be scheduled at the Editorial - correct capitalization Preparedness Exercise, 3rd conclusion of the exercise to conclusion of the exercise to paragraph, 2nd sentence evaluate the ability of organizations evaluate the ability of organizations to respond as called for in the plan. to respond as called for in the Plan.

8.1.4.a Ensure offsite county, state, and Ensure offsite county, state, and Reflect the change to Post supporting emergency plans are supporting emergency plans are Shutdown.

compatible with the Palisades Site compatible with the Palisades Post Emergency Plan. Shutdown Emergency Plan.

8.1.4.c Ensure that the information, data, Ensure that the information, data, Reflect the change to Post and procedures detailed in the and procedures detailed in the Shutdown.

Palisades Nuclear Plant Emergency Palisades Nuclear Plant Emergency Implementing Procedures are Implementing Procedures are consistent with the Palisades Site consistent with the Palisades Post Emergency Plan. Shutdown Emergency Plan.

8.1.4.d Ensure that the Emergency Plan Ensure that the Emergency Plan Editorial - correct punctuation Implementing Procedures are Implementing Procedures are coordinated and interface properly coordinated and interface properly with other procedures with other procedures (eg, Administrative Procedures, (e.g., Administrative Procedures, Security Procedures, Radiation Security Procedures, Radiation Protection Procedures, and Training Protection Procedures, and Training Procedures, etc). Procedures, etc.).

8.1.4.f Coordinate the onsite review and Coordinate the onsite review and Reflect the change to Post updating of the Palisades Site updating of the Palisades Post Shutdown.

Emergency Plan and Implementing Shutdown Emergency Plan and Procedures. Implementing Procedures.

8.3 REVIEW AND UPDATING OF THE REVIEW AND UPDATING OF THE Reflect the change to Post EMERGENCY PLAN AND POSTSHUTDOWN EMERGENCY Shutdown.

IMPLEMENTING PROCEDURES PLAN AND IMPLEMENTING PROCEDURES 8.3, 1st paragraph The Palisades Plant Site Emergency The Palisades Plant PostShutdown Reflect the change to Post 35

PNP Emergency Plan Change Summary After (Pending Revision Emergency Plan Section Before (Rev. 29) Reason for Change Number)

Plan involves the coordination of Emergency Plan involves the Shutdown.

Entergy personnel and offsite coordination of Entergy personnel support agencies. To achieve and and offsite support agencies.

maintain the most efficient course of To achieve and maintain the most emergency actions, the Palisades efficient course of emergency Plant Site Emergency Plan and actions, the Palisades Plant Post Implementing Procedures, including Shutdown Emergency Plan and appended letters of agreement, will Implementing Procedures, including be reviewed on an annual basis and appended letters of agreement, will updated as needed. These reviews be reviewed on an annual basis and are conducted to comply with the updated as needed. These reviews Entergy procedures, federal are conducted to comply with the regulations, and operation license Entergy procedures, federal provisions. regulations, and operation license provisions.

8.3, 2nd paragraph Proposed revisions to the Site Proposed revisions to the Post Reflect the change to Post Emergency Plan, Emergency Shutdown Emergency Plan, Shutdown.

Implementing Procedures and Emergency Implementing appended Letters of Agreement shall Procedures and appended Letters of receive an effectiveness review in Agreement shall receive an accordance with 10 CFR 50.54(q). If effectiveness review in accordance the change to the Site Emergency with 10 CFR 50.54(q). If the change Plan reduces the effectiveness of the to the PostShutdown Emergency Plan, the Nuclear Regulatory Plan reduces the effectiveness of the Commission (NRC) shall review and Plan, the Nuclear Regulatory approve the change prior to Commission (NRC) shall review and implementation. The proposed approve the change prior to change shall be reviewed by the implementation. The proposed Management and Safety Review change shall be reviewed by the Committee (MSRC) prior to Plant Management and Safety Review Licensing submitting the proposed Committee (MSRC) prior to Plant change to the NRC. Licensing submitting the proposed change to the NRC.

36

PNP Emergency Plan Change Summary After (Pending Revision Emergency Plan Section Before (Rev. 29) Reason for Change Number) 8.3, 3rd paragraph Proposed revisions to the Site Proposed revisions to the Post Reflect the change to Post Emergency Plan shall be reviewed Shutdown Emergency Plan shall be Shutdown.

and approved in accordance with reviewed and approved in Fleet procedure changed to site the Entergy Procedure ENOM119, accordance with the Procedure P specific procedure.

"OnSite Safety Review Committee." ENOM119, "OnSite Safety Review Committee."

8.3, 4th paragraph When revisions to the Site When revisions to the Post Reflect the change to Post Emergency Plan affect offsite Shutdown Emergency Plan affect Shutdown.

support agencies, they shall be offsite support agencies, they shall notified as the changes occur. be notified as the changes occur.

8.3, 5th paragraph Editorial changes to the Site Editorial changes to the Post Reflect the change to Post Emergency Plan or Emergency Shutdown Emergency Plan or Shutdown.

Implementing Procedures such as Emergency Implementing titles and telephone lists are not Procedures such as titles and subject to the review process telephone lists are not subject to the described above. review process described above.

8.3, 7th paragraph, 1st sentence The review shall include the Site The review shall include the Post Reflect the change to Post Emergency Plan, Emergency Shutdown Emergency Plan, Shutdown.

Implementing Procedures, training, Emergency Implementing drills and exercises, equipment, and Procedures, training, drills and interfaces with state and local exercises, equipment, and interfaces governments. with state and local governments.

8.3, 8th paragraph As the Site Emergency Plan is As the PostShutdown Emergency Reflect the change to Post reviewed, the emergency Plan is reviewed, the emergency Shutdown.

organization or procedures may be organization or procedures may be changed as a result of the following: changed as a result of the following:

8.5.2, Dose Assessment Compute The Dose Assessment Computer The Dose Assessment Computer Fleet procedure changed to site Programs Programs are in accordance with Programs are in accordance with specific procedure.

Entergy Procedure ENIT103, Procedure PENIT103, "Nuclear "Nuclear Cyber Security Program." Cyber Security Program."

37

PNP Emergency Plan Change Summary After (Pending Revision Emergency Plan Section Before (Rev. 29) Reason for Change Number) 9.0, Recovery, 2nd paragraph A recovery plan, from a practical A recovery plan, from a practical Reflect the change to Post standpoint, must be flexible enough standpoint, must be flexible enough Shutdown.

to adapt to existing, rather than to adapt to existing, rather than theoretical, conditions. It is not theoretical, conditions. It is not possible to anticipate in advance all possible to anticipate in advance all of the conditions that may be of the conditions that may be encountered in an emergency encountered in an emergency situation; therefore, the Palisades situation; therefore, the Palisades Site Emergency Plan is addressed to PostShutdown Emergency Plan is general principles that will serve as a addressed to general principles that guide for developing a flexible plan will serve as a guide for developing a of action. flexible plan of action.

Appendix C, Population Distribution The contents of Appendix C have The contents of Appendix C have Reflect the change to Post and Evacuation Time Estimates been relocated to a progeny been relocated to a progeny Shutdown.

procedure to the Site Emergency procedure to the PostShutdown Plan. See SEP Supp 2, "Evacuation Emergency Plan. See PSEP Supp 2, Time Estimates," Revision 1, August "Evacuation Time Estimates,"

2012. Revision 1, August 2012.

Appendix D Entergy Procedures Additional Procedures Fleet procedures changed to site specific procedures.

Appendix D, Additional Procedures ENEP306 Drills and Exercises PENEP306 Drills and Exercises Fleet procedure changed to site specific procedure.

Appendix D, Additional Procedures, This procedure establishes a process This procedure provides guidance for Fleet procedure changed to site PENEP306 to standardize fleet drill and exercise the planning, preparation, specific procedure.

programs and provides guidance for scheduling, conduct, evaluation, and the planning, preparation, documentation of Emergency scheduling, conduct, evaluation, and Planning drills and exercises.

documentation of Emergency Planning drills and exercises.

Appendix D, Additional Procedures ENEP307 Hostile Action Based PENEP307 Hostile Action Based Fleet procedure changed to site Drills and Exercises Drills and Exercises specific procedure.

38

PNP Emergency Plan Change Summary After (Pending Revision Emergency Plan Section Before (Rev. 29) Reason for Change Number)

Appendix D, Additional Procedures, This procedure establishes a process This procedure provides guidance for Fleet procedure changed to site PENEP307 to standardize the fleet hostile the preparation and conduct of specific procedure.

action based drill program and integrated Emergency Planning (EP) processes; provides guidance for the and Security exercises using hostile preparation and conduct of action based scenarios; and, integrated Emergency Planning (EP) provides guidance for the and Security exercises using hostile preparation and conduct of a action based scenarios; and, preexercise hostile actionbased provides guidance for the tabletop.

preparation and conduct of a preexercise hostile actionbased tabletop.

Appendix D, Additional Procedures ENEP308 Emergency Planning PENEP308 Emergency Planning Fleet procedure changed to site Critiques Critiques specific procedure.

Appendix D, Additional Procedures, This procedure establishes a process This procedure describes the means Fleet procedure changed to site PENEP308 to standardize fleet drill and exercise for tracking and correcting specific procedure.

critiques, and describes the means deficiencies identified in drills.

for tracking and correcting deficiencies identified in drills.

Appendix D, Additional Procedures ENEP310 Emergency Response PENEP310 Emergency Response Fleet procedure changed to site Organization Notification System Organization Notification System specific procedure.

Appendix D, Additional Procedures ENEP311 Emergency Response PENEP311 Emergency Response Fleet procedure changed to site Data System (ERDS) Activation via Data System (ERDS) Activation via specific procedure.

the Virtual Private Network (VPN) the Virtual Private Network (VPN)

Appendix D, Additional Procedures ENEP313 Offsite Dose Assessment PENEP313 Offsite Dose Fleet procedure changed to site using the Unified RASCAL Interface Assessment using the Unified specific procedure.

RASCAL Interface Appendix D, Additional Procedures ENEP609 Emergency Operations PENEP609 Emergency Operations Fleet procedure changed to site Facility (EOF) Operations Facility (EOF) Operations specific procedure.

Appendix D, Additional Procedures ENEP610 Technical Support Center PENEP610 Technical Support Fleet procedure changed to site 39

PNP Emergency Plan Change Summary After (Pending Revision Emergency Plan Section Before (Rev. 29) Reason for Change Number)

(TSC) Operations Center (TSC) Operations specific procedure.

Appendix D, Additional Procedures ENEP611 Operations Support PENEP611 Operations Support Fleet procedure changed to site Center (OSC) Operations Center (OSC) Operations specific procedure.

Appendix D, Additional Procedures ENEP801 Emergency Response PENEP801 Emergency Response Fleet procedure changed to site Organization Organization specific procedure.

Appendix D, Additional Procedures ENTQ110 Emergency Response PENTQ110 Emergency Response Fleet procedure changed to site Organization Training Organization Training specific procedure.

Appendix D, Additional Procedures ENTQ11001 Fleet EPlan Training PENTQ11001 EPlan Training Fleet procedure changed to site Course Summary Course Summary specific procedure.

Appendix D, Additional Procedures, This procedure lists the Fleet specific This procedure lists the specific Fleet procedure changed to site PENTQ11001 curricula and learning items required curricula and learning items required specific procedure.

for each of the standard Emergency for each of the Emergency Response Response Organization (ERO) Organization (ERO) positions positions specified in ENEP801, specified in PENEP801, Emergency Emergency Response Organization. Response Organization.

Appendix I, NUREG0654 Cross *The referenced section of the Site *The referenced section of the Post Reflect the change to Post Reference, footnote Emergency Plan represents the Shutdown Emergency Plan Shutdown.

principal location where the NUREG represents the principal location is addressed. where the NUREG is addressed.

Appendix I, NUREG0654 Cross Site Emergency Plan PostShutdown Emergency Plan Reflect the change to Post Reference, 2nd column title Shutdown.

Appendix I, NUREG0654 Cross Table 41 and SITE EMERGENCY Table 41 and POSTSHUTDOWN Reflect the change to Post Reference, D.1 PLAN Supplement 1 EAL Wall EMERGENCY PLAN Supplement Shutdown.

Charts 1 EAL Wall Charts Appendix I, NUREG0654 Cross SITE EMERGENCY PLAN Supplement POSTSHUTDOWN EMERGENCY Reflect the change to Post Reference, D.2 1 EAL Wall Charts PLAN Supplement 1 EAL Wall Shutdown.

Charts Appendix I, NUREG0654 Cross SITE EMERGENCY PLAN Supplement POSTSHUTDOWN EMERGENCY Reflect the change to Post 40

PNP Emergency Plan Change Summary After (Pending Revision Emergency Plan Section Before (Rev. 29) Reason for Change Number)

Reference, I.1 1 EAL Wall Charts PLAN Supplement 1 EAL Wall Shutdown.

Charts Appendix I, NUREG0654 Cross SITE EMERGENCY PLAN Supplement POSTSHUTDOWN EMERGENCY Reflect the change to Post Reference, J.8 2 Evacuation Time Estimates PLAN Supplement 2 Evacuation Shutdown.

Time Estimates 41

Attachment 3 To Entergy Letter PNP 2017-034 Palisades Nuclear Plant Proposed Revision to the Palisades Nuclear Plant Site Emergency Plan (mark-up)

(130 Pages)

Procedure No SEP Revision 29TBD Effective Date PALISADES NUCLEAR PLANT SITE POST-SHUTDOWN EMERGENCY PLAN TITLE: SITE EMERGENCY PLAN Approved: DGMalone /

Procedure Sponsor Date Process Applicability Exclusion Revision 29 TBD FULL REVISION TO ADDRESS IMPLEMENTATION OF THE POST-SHUTDOWN EMERGENCY PLAN Specific Changes The Site Emergency Plan (SEP) Revision 28 and the On-shift Staffing Analysis (OSA) Revision 3, considered part of the SEP, are being revised. The SEP changes consist of:

1. Adding a note to Figure 5-2, Plant Staffing and Augmentation Requirements, to allow use of task-qualified personnel in substitution of Nuclear Plant Operators (NPOs) as part of the required on-shift complement.

2. Changing Reference Document 69, Palisades Nuclear Station On-Shift Staffing Analysis from Revision 3 to Revision 4.

The OSA is being updated to Revision 4 to align with the Revision 29 update to Figure 5-2 of the SEP.

Specifically, updates include:

3. Updating the text in Section I, Introduction, to allow for up to 2 of the 6 on-shift NPO positions' functional responsibilities be performed by a person or persons who singularly or collectively possess the Fire Brigade qualification and task-qualification to perform minor maintenance actions to mitigate an event (e.g. a FB qualified person and a minor maintenance task qualified person may collectively fill the NPO #5 position) as directed by the Control Room Supervisor.

4. Adding parenthetical reference to other Fire Brigade and/or task-qualified personnel to NPO #5 and NPO #6 in the table included in Section II.A.

5. Adding parenthetical reference to Fire Brigade and/or other task-qualified personnel in Section II.D.1.

6. Adding Revision 4 to the second paragraph of Section III.A.

7. Updating the Revision 4 report date in Section I, Introduction.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page i TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN Table of Contents SOURCES AND REFERENCES .................................................................................................... 1 SOURCE DOCUMENTS ................................................................................................ 1 REFERENCE DOCUMENTS ......................................................................................... 1

1.0 INTRODUCTION

.......................................................................................................... 66 1.1 DEFINITIONS ............................................................................................... 66 1.1.1 Accident ................................................................................. 66 1.1.2 Activation............................................................................... 66 1.1.3 Affected Persons .................................................................. 77 1.1.4 Alarm ...................................................................................... 77 1.1.5 Alert ........................................................................................ 77 1.1.6 Annunciation ......................................................................... 77 1.1.7 Assessment Actions ............................................................. 77 1.1.8 Command and Control ......................................................... 77 1.1.9 Control Room ........................................................................ 77 1.1.10 Control Room Personnel ...................................................... 77 1.1.11 Corrective Actions ................................................................ 88 1.1.12 Decontamination ................................................................... 88 1.1.13 Emergency ............................................................................. 88 1.1.14 Emergency Action Levels (EAL) .......................................... 88 1.1.15 Emergency Operations Facility (EOF) ................................. 88 1.1.16 Emergency Implementing Procedures ................................ 88 1.1.17 Emergency Planning Zones (EPZ) ....................................... 99 1.1.18 Fitness For Duty .................................................................... 99 1.1.19 Fully Operational ................................................................... 99 1.1.20 General Emergency .............................................................. 99 1.1.21 Hostile Action ........................................................................ 99 1.1.22 Hostile Force ..................................................................... 1010 1.1.23 Ingestion Exposure Pathway ........................................... 1010 1.1.24 Initiating Condition (IC) .................................................... 1010 1.1.25 Offsite................................................................................. 1010

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page ii TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN Table of Contents 1.1.26 Onsite ................................................................................. 1010 1.1.27 Operational ........................................................................ 1010 1.1.28 Operations Support Center (OSC) ................................... 1111 1.1.29 Owner Controlled Area ..................................................... 1111 1.1.30 Plume Exposure Pathway ................................................ 1111 1.1.31 Population at Risk ............................................................. 1111 1.1.32 Protective Actions............................................................. 1111 1.1.33 Protective Action Guides (PAG) ...................................... 1111 1.1.34 Protected Area .................................................................. 1212 1.1.35 Radiological Emergency .................................................. 1212 1.1.36 Recovery Actions .............................................................. 1212 1.1.37 Site Area Emergency ........................................................ 1212 1.1.38 Emergency Plant Manager ............................................... 1212 1.1.39 State ................................................................................... 1212 1.1.40 Technical Support Center (TSC) ...................................... 1212 1.1.41 Unusual Event ................................................................... 1313 2.0 SCOPE AND APPLICABILITY ................................................................................ 1313 2.1 GENERAL INFORMATION AND SITE DESCRIPTION........................... 1313 2.2 POPULATION DISTRIBUTION AND EVACUATION TIMES .................. 1413 2.3 EMERGENCY PLANNING ZONES ......................................................... 1414 2.4 PURPOSES AND OBJECTIVES ............................................................. 1414 2.4.1 Regulatory Requirements ................................................ 1515 2.4.2 Purpose of Emergency Preparedness ............................ 1515 2.4.3 Objectives of the Palisades Site Post-Shutdown Emergency Plan .................................................................................... 1515 2.5

SUMMARY

OF EMERGENCY PLAN INTERRELATIONSHIPS ............. 1616 2.5.1 Site Post-Shutdown Emergency Plan Supplement 1 ..... 1616 2.5.2 Site Post-Shutdown Emergency Plan Supplement 2 ..... 1717 2.5.3 Emergency Implementing Procedures ............................ 1717 2.5.4 Related Plans, Programs, and Procedures ..................... 1717

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page iii TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN Table of Contents 3.0 SITE POST-SHUTDOWN EMERGENCY PLAN

SUMMARY

.................................. 2222 3.1 POST-SHUTDOWN EMERGENCY PLAN STEPS .................................. 2222 3.2 ENTERGY CORPORATION EMERGENCY ORGANIZATION ................ 2323 3.3 EMERGENCY CLASSIFICATIONS ......................................................... 2323 3.4 EMERGENCY ACTIONS ......................................................................... 2525 4.0 POST-SHUTDOWN EMERGENCY CONDITIONS .................................................. 2727 4.1 EMERGENCY CLASSIFICATION SYSTEM ............................................ 2727 4.1.1 Unusual Event ................................................................... 2828 4.1.2 Alert .................................................................................... 2929 4.1.3 Site Area Emergency ........................................................ 3030 4.1.4 General Emergency .......................................................... 3131 4.2 CLASSIFICATION OF POSTULATED ACCIDENTS .............................. 3131 5.0 ORGANIZATIONAL CONTROL OF EMERGENCIES ............................................. 3838 5.1 PALISADES PLANT ORGANIZATION ................................................... 3838 5.2 OPERATING AND ENGINEERING ORGANIZATION ............................. 3838 5.2.1 GENERAL MANAGER, PLANT OPERATIONS ................ 3939 5.2.2 Director - Emergency Programs ...................................... 3939 5.2.3 Director - Engineering ...................................................... 3939 5.2.4 Regulatory and Performance Improvement Director ..... 3939 5.2.5 Duty Station Manager ....................................................... 3939 5.2.6 Shift Manager .................................................................... 3939 5.2.7 Shift Engineers/Shift Technical Advisors (SE/STA)DELETED ............................................................ 4040 5.3 PALISADES EMERGENCY RESPONSE ORGANIZATION ................... 4040 5.3.1 Control Room .................................................................... 4040 5.3.2 Technical Support Center ................................................ 4141 5.3.3 Operations Support Center .............................................. 4141 5.3.4 Emergency Operations Facility (EOF) ............................. 4141 5.3.5 Joint Information Center (JIC) ......................................... 4242

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page iv TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN Table of Contents 5.4 EMERGENCY STAFFING ....................................................................... 4242 5.4.1 Shift Manager/EOF Emergency Director ......................... 4242 5.4.2 Shift Manager/Emergency Plant Manager ....................... 4343 5.5 RECOVERY ORGANIZATION ................................................................. 4343 5.6 OFF-SITE EMERGENCY RESPONSE SERVICES ................................. 4444 5.6.1 Medical Services ............................................................... 4444 5.6.2 Fire-Fighting Services ...................................................... 4545 5.6.3 Law Enforcement Agencies ............................................. 4545 5.6.4 Van Buren County Office of Domestic Preparedness.... 4545 5.6.5 Berrien County Emergency Management ....................... 4646 5.6.6 Allegan County Office of Emergency Preparedness ..... 4646 5.7 COORDINATION WITH GOVERNMENTAL AGENCIES ........................ 4747 5.7.1 State of Michigan Agencies ............................................. 4747 5.7.2 Federal Agencies .............................................................. 4949 5.8 INSTITUTE OF NUCLEAR POWER OPERATIONS (INPO) ................... 5050 6.0 EMERGENCY MEASURES ..................................................................................... 5756 6.1 ACTIVATION OF THE EMERGENCY ORGANIZATION ......................... 5756 6.1.1 Control Room Personnel .................................................. 5857 6.1.2 Emergency Plant Manager ............................................... 6160 6.1.3 Emergency Director .......................................................... 6261 6.1.4 Emergency Management and Homeland Security Division -

Michigan State Police ....................................................... 6362 6.1.5 Michigan Department of Environmental Quality, Radiological Protection Section ...................................... 6362 6.1.6 Affected Counties: Van Buren County, Berrien County, and Allegan County .................................................................. 6463 6.2 ASSESSMENT ACTIONS ........................................................................ 6463 6.2.1 Assessment Actions for Unusual Events ....................... 6463 6.2.2 Assessment Actions for Alerts ........................................ 6463 6.2.3 Assessment Actions for Site Area Emergencies ........... 6564 6.2.4 Assessment Actions for General Emergencies ............. 6665

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page v TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN Table of Contents 6.2.5 Estimation of Offsite Dose ............................................... 6665 6.2.6 Data Reporting, Recording, and Analysis ....................... 6766 6.2.7 Interviewing Evacuees or Other Witnesses .................... 6766 6.2.8 Assessment Results Communications ........................... 6766 6.3 CORRECTIVE ACTIONS ......................................................................... 6766 6.3.1 Fire Control ........................................................................ 6867 6.3.2 Repair and Damage Control ............................................. 6867 6.3.3 System Control ................................................................. 6867 6.4 PROTECTIVE ACTIONS ......................................................................... 6968 6.4.1 Sheltering, Evacuation, Personnel Accountability......... 6968 6.4.2 Contamination Control Measures .................................... 7372 6.5 AID TO AFFECTED PERSONNEL .......................................................... 7473 6.5.1 Emergency Personnel Exposure Criteria........................ 7473 6.5.2 Decontamination and First Aid ........................................ 7574 6.5.3 Medical Treatment............................................................. 7574 7.0 EMERGENCY FACILITIES AND EQUIPMENT ....................................................... 8079 7.1 ONSITE EMERGENCY FACILITIES........................................................ 8079 7.1.1 Control Room .................................................................... 8079 7.1.2 Technical Support Center ................................................ 8180 7.1.3 Operations Support Center (OSC) ................................... 8281 7.2 EMERGENCY OPERATIONS FACILITY (EOF) ...................................... 8281 7.3 COUNTY AND STATE EMERGENCY CENTERS ................................... 8382 7.3.1 County Emergency Operations Centers ......................... 8382 7.3.2 State Emergency Operations Center ............................... 8483 7.4 JOINT INFORMATION CENTER (JIC) .................................................... 8483 7.5 COMMUNICATIONS EQUIPMENT.......................................................... 8483 7.5.1 Routine Communications System ................................... 8483

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page vi TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN Table of Contents 7.6 ASSESSMENT EQUIPMENT SYSTEMS ................................................ 8584 7.6.1 Radiation Monitoring System .......................................... 8584 7.6.2 Meteorology....................................................................... 8786 7.6.3 Fire Protection System ..................................................... 8786 7.7 OFFSITE MONITORING .......................................................................... 8887 7.7.1 Radiological Monitoring ................................................... 8887 7.7.2 Laboratory Facilities ......................................................... 8887 7.8 FIRST AID AND MEDICAL CARE ........................................................... 8988 7.8.1 First Aid and Medical Care ............................................... 8988 7.8.2 First Aid Equipment .......................................................... 8988 7.8.3 Decontamination and First Aid ........................................ 8988 7.8.4 Medical Transportation..................................................... 8988 7.8.5 Medical Treatment............................................................. 8988 7.8.6 Use of Protective Equipment and Supplies .................... 9089 8.0 MAINTAINING EMERGENCY PREPAREDNESS ................................................... 9493 8.1 ORGANIZATION PREPAREDNESS ....................................................... 9493 8.1.1 Training .............................................................................. 9493 8.1.2 Drills and Exercises .......................................................... 9594 8.1.3 Major Drills and Exercises ............................................... 9695 8.1.4 Emergency Planning......................................................... 9897 8.2 EDUCATIONAL INFORMATION FOR THE PUBLIC .............................. 9998 8.3 REVIEW AND UPDATING OF THE POST-SHUTDOWN EMERGENCY PLAN AND IMPLEMENTING PROCEDURES ........................................ 9998 8.4 MAINTENANCE AND INVENTORY OF EMERGENCY EQUIPMENT AND SUPPLIES ............................................................................................ 101100 8.5 EMERGENCY EQUIPMENT NUCLEAR PERFORMANCE ASSESSMENT DEPARTMENT CONTROLS ............................................................... 101100 8.5.1 Meteorological Monitoring Program............................ 101100 8.5.2 Dose Assessment Computer Programs...................... 101100 9.0 RECOVERY ......................................................................................................... 101100

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page vii TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN Table of Contents Appendix A, "Agreements with Off-Site Individuals, Agencies, and Organizations" Appendix B, "Basis for Deletion of Appendix B of the Palisades Site Emergency Plan" Appendix C, "Evacuation Time Estimates," Revision 1, August 2012 prepared by KLD Engineering. (This document is relocated to SEP Supp 2, See below.)

Appendix D, "Emergency Implementing Procedures" Appendix E, "General Equipment in Emergency Kits" Appendix I, "NUREG-0654 Cross Reference" PSEP Supp 1, "SITE POST-SHUTDOWN EMERGENCY PLAN Supplement 1 - EAL Wall Charts" (Note: PSEP Supp 1 is under separate cover with its own revision number.)

PSEP Supp 2, "Evacuation Time Estimates," Revision 1, August 2012 (Note: PSEP Supp 2 will be maintained in the same binder as the Site Post-Shutdown Emergency Plan with its own revision number.)

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 1 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN SOURCES AND REFERENCES SOURCE DOCUMENTS

1. NUREG-0654, Revision 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Procedures in Support of Nuclear Power Plants" (November 1980)

2. Title 10 of the Code of Federal Regulations, Part 50

3. Entergy ProcedureP- EN-HU-106, "Procedure and Work Instruction Use and Adherence"

4. NUREG-0737 Supplement 1, "Clarification of TMI Action Plan Requirements"

5. Palisades Administrative Procedure 4.00, "Operations Organization, Responsibilities, and Conduct"

6. Abnormal Operating Procedure AOP-23, "Primary Coolant Leak"

7. Abnormal Operating Procedure AOP-24, "Steam Generator Tube Leak"

8. NEI 99-01 Revision 5, "Methodology for Development of Emergency Action Levels"

9. NRC Bulletin 2005-02: Emergency Preparedness and Response Actions for Security Based Events

10. Engineering Analysis, EA-JBB-01-04, "Failed Fuel Dose Rates on NSSS Piping"

11. Entergy Procedure P-EN-TQ-110, "Emergency Response Organization Training" REFERENCE DOCUMENTS

1. Regulatory Guide 1.70, Revision 2, "Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants"

2. Palisades Nuclear Plant Emergency Implementing Procedures

3. 10 CFR 50, "Domestic Licensing of Production and Utilization Facilities"

4. 10 CFR 100, "Reactor Site Criteria"

5. Palisades Final Safety Analysis Report

6. NUREG-0696, "Functional Criteria for Emergency Response Facilities" (February 1981)

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 2 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN

7. Palisades Safeguards Contingency Procedures

8. Palisades Health Physics Procedures

9. Palisades Abnormal Operating Procedures

10. Palisades Emergency Operating Procedures

11. Palisades Nuclear Plant Public Information Policies and Procedures

12. Palisades Fire Protection Plan

13. EPA 400-R-92-001, "Manual of Protective Action Guides and Protective Actions for Nuclear Incidents"

14. Palisades Administrative Procedure 4.00, "Operations Organization, Responsibilities and Conduct"

15. Entergy Procedure P-EN-OM-119, "On-Site Safety Review Committee"

16. Emergency Implementing Procedure EI-1, "Emergency Classification and Actions"

17. Emergency Implementing Procedure EI-2.2, "Emergency Staff Augmentation"

18. Emergency Implementing Procedure EI-3, "Communications and Notifications"

19. Emergency Implementing Procedure EI-4.1, "Technical Support Center Activation"

20. Emergency Implementing Procedure EI-4.2, "Operations Support Center Activation"

21. Emergency Implementing Procedure EI-4.3, "Emergency Operations Facility Activation"

22. Emergency Implementing Procedure EI-5.0, "Reentry"

23. Emergency Implementing Procedure EI-5.1, "Recovery"

24. Emergency Implementing Procedure EI-6, "Rapid Dose Calculation"

25. Emergency Implementing Procedure EI-6.1, "Release Rate Determination from Stack Gas Monitors"

26. Emergency Implementing Procedure EI-6.2, "Release Rate Determination from Steam Line Monitors RIA-2323 and RIA-2324 for Steam Releases through Atmospheric Dump Valves"

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 3 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN

27. Emergency Implementing Procedure EI-6.3, "Release Rate Determination from High-Range Effluent Monitors"

28. Emergency Implementing Procedure EI-6.4, "Release/Potential Release Determination from Containment High-Range Monitors"

29. Emergency Implementing Procedure EI-6.6, "Gamma E-Bar Determinations"

30. Emergency Implementing Procedure EI-6.7, "Plant Site Meterological System"

31. Emergency Implementing Procedure EI-6.8, "Backup and Supplemental Meteorology"

32. Emergency Implementing Procedure EI-6.9, "Automated Dose Assessment Program"

33. Emergency Implementing Procedure EI-6.10, "Offsite Dose Calculation - Straight Line Gaussian (Manual Method)

34. Emergency Implementing Procedure EI-6.13, "Protective Action Recommendations for Offsite Population"

35. Emergency Implementing Procedure EI-7.0, "Emergency Post Accident Sampling and Determination of Fuel Failure Using Dose Rates"

36. Emergency Implementing Procedure EI-7.10, "Post Accident Sampling, Radioactive Gaseous Effluent Monitoring"

37. Emergency Implementing Procedure EI-8, "Onsite Radiological Monitoring"

38. Emergency Implementing Procedure EI-9, "Offsite Radiological Monitoring"

39. Emergency Implementing Procedure EI-10, "Accident Environmental Assessment"

40. Emergency Implementing Procedure EI-11, "Determination of Extent of Core Damage"

41. Emergency Implementing Procedure EI-12.1, "Personnel Accountability and Assembly"

42. Emergency Implementing Procedure EI-12.3, "Search and Rescue Team Responsibilities"

43. Emergency Implementing Procedure EI-13, "Evacuation/Reassembly"

44. Emergency Implementing Procedure EI-14, "Medical Care/Treatment of Contaminated, Injured Personnel"

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 4 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN

45. Emergency Implementing Procedure EI-15.2, "Communications Tests"

46. Emergency Implementing Procedure EI-16.1, "Maintenance of Emergency Equipment"

47. Emergency Implementing Procedure EI-17, "Compensating Measures for OOS EAL Equipment and Listing of Non-EAL Equipment Important for Emergency Preparedness"

48. 10 CFR 20, "Standards for Protection Against Radiation"

49. Oil and Hazardous Materials Spill Prevention Plan

50. Palisades Technical Specifications

51. Act 390, Michigan Public Acts of 1976

52. Act 368, Michigan Public Acts of 1978

53. Michigan Emergency Management Plan

54. Van Buren County Emergency Plan

55. Allegan County Emergency Plan

56. Berrien County Emergency Plan

57. Palisades Administrative Procedure 1.14, "Meteorological Monitoring Program"

58. Entergy Procedure P-EN-IT-103, "Nuclear Cyber Security Program"

59. NEI 99-01 Revisions 5, "Methodology for Development of Emergency Action Levels"

60. NRC Bulletin 2005-02: Emergency Preparedness and Response Actions for Security Based Events

61. NEI White Paper dated November 18th, 2005, "Enhancements to Emergency Preparedness Programs for Hostile Action" (Endorsed by NRC RIS 2006-12)

62. SITE POST-SHUTDOWN EMERGENCY PLAN Supplement 1 - "EAL Wall Charts" (Note: PSEP Supp 1 is under separate cover with its own revision number.)

63. SITE POST-SHUTDOWN EMERGENCY PLAN Supplement 2 - "Evacuation Time Estimates" (Revision 1, August 2012) (Note: PSEP Supp 2 will be maintained in the same binder as the Site Emergency Plan.)

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 5 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN

64. Engineering Analysis, EA-JBB-01-04, "Failed Fuel Dose Rates on NSSS Piping"

65. Entergy Procedure P-EN-TQ-110, "Emergency Response Organization Training"

66. Entergy ProcedureP-EN-TQ-201, "Systematic Approach to Training Process"

67. Entergy ProcedureP-EN-EP-308, "Emergency Planning Critiques"

68. Entergy Procedure P-EN-EP-306, "Drills and Exercises"

69. Palisades Nuclear Station Plant Analysis of Proposed Post-Shutdown On-Shift Staffing Analysis, Revision 4 0 dated July 28August, 2017 conducted in accordance with NEI 10-05 andas required by 10CFR50, Appendix E, Section IV.A

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 6 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN INFORMATIONAL USE Procedure is available and referenced for review, but not necessarily at the work location.

Procedure may be performed from memory or referred to as needed.

User remains responsible for procedure adherence.

1.0 INTRODUCTION

The purpose of the Palisades Site Post-Shutdown Emergency Plan (PSEP) is to aid in protecting members of the general public, persons temporarily visiting the site, and site employees.

Information submitted in this plan was developed using the guidance provided in NUREG-0654, Revision 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Procedures in Support of Nuclear Power Plants,"

published in November 1980 and with Regulatory Guide 1.70, Revision 2, "Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants," dated September 1975.

Detailed procedures concerning the implementation of the Site Post-Shutdown Emergency Plan are not included here, but are included in the Palisades Nuclear Plant Emergency Implementing Procedures and Entergy Fleet Emergency Preparedness Procedures. These procedures describe the duties and actions of individuals and groups in the event of an emergency and also serve as an interface of the Site Post-Shutdown Emergency Plan with Plant operations, security, and radiological controls procedures. Selected elements of the Quality Program are applied to the Site Post-Shutdown Emergency Planning Function for the Palisades Plant.

1.1 DEFINITIONS 1.1.1 Accident Any unexpected or unintentional event resulting in radiological exposure, contamination, or physical injury to individuals requiring offsite medical treatment, and/or physical damage to safety-related components.

1.1.2 Activation Actions taken to staff and setup an emergency response facility to make it operational. Actions include, but are not limited to, notification of emergency personnel, equipment setup, and equipment operability testing.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 7 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN 1.1.3 Affected Persons Individuals who have been radiologically exposed or physically injured as a result of an accident to a degree requiring special attention, e.g., decontamination, first aid, or medical services.

1.1.4 Alarm An indication of abnormal Plant conditions and/or equipment status.

1.1.5 Alert Events are in process or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.

1.1.6 Annunciation An alarm or indication of normal or abnormal conditions.

1.1.7 Assessment Actions Those actions taken during or after an accident to provide data to make decisions.

1.1.8 Command and Control Resides with the Shift Manager or EOF Emergency Director following assumption of overall authority for Entergy Corporation emergency response. At minimum, this individual will assume responsibility for event classification, dose assessment, protective action recommendations, and notification of offsite authorities.

1.1.9 Control Room The location at Palisades Plant from which the Reactor and its auxiliary systems are controlled. The assembly area for Control Room personnel.

1.1.10 Control Room Personnel The credited on shift complement consists of a Shift Manager (qualified as a Certified Fuel Handler (CFH)), and two (2) Non-Certified Operators.Nuclear Control

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 8 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN Operators, Nuclear Plant Operators, Shift Engineer/Shift Technical Advisor, and Control Room Supervisor.

1.1.11 Corrective Actions Those emergency measures taken to lessen or terminate an emergency situation at, or near, the source of the problem.

1.1.12 Decontamination The removal of radioactive material from individuals, equipment, surfaces, foodstuffs, etc.

1.1.13 Emergency Any occurrence at the Palisades Nuclear Power Plant that may result in undue risk to the health and safety of the onsite personnel or the public.

1.1.14 Emergency Action Levels (EAL)

A predetermined, site-specific, observable threshold for a plant Initiating Condition that places 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 procedures; or another phenomenon which, if it occurs, indicates entry into a particular emergency class.

There are times when an EAL will be a threshold point on a measurable continuous function, such as a primary system coolant leak that has exceeded technical specifications.

At other times, the EAL lists a discrete event that places the plant in a particular emergency class.

1.1.15 Emergency Operations Facility (EOF)

An offsite emergency center from which the offsite emergency support actions of Entergy Corporation are controlled and coordinated with state, local, and federal authorities to mitigate the consequences of an emergency.

1.1.16 Emergency Implementing Procedures Specific procedures providing specific actions to implement the Site Post-Shutdown Emergency Plan in order to mitigate or terminate an emergency situation.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 9 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN 1.1.17 Emergency Planning Zones (EPZ)

Two zones that encircle the Palisades Plant. The primary EPZ plume exposure pathway, with a radius of 10 miles, has been established to prevent excessive airborne exposure, and the secondary EPZ, ingestion exposure pathway, with a radius of 50 miles, has been established to prevent excessive ingestion of contaminated food. Within these two zones, protective actions are described for the protection of the public.

1.1.18 Fitness For Duty Provide reasonable assurance that personnel who maintain unescorted access will perform their tasks in a reliable and trustworthy manner and are not under the influence of any substance, legal or illegal, or mentally or physically impaired from any cause, which in any way adversely affects their ability to safely and competently perform their duties.

1.1.19 Fully Operational Status of an Emergency Response Facility following assumption of all responsibilities.

1.1.20 General Emergency 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 offsite for more than the immediate site area.

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

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 10 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN 1.1.22 Hostile Force One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.

1.1.23 Ingestion Exposure Pathway The path affected by fallout from a radioactive plume. Of major concern is the contamination of food and water within the emergency planning zones.

1.1.24 Initiating Condition (IC): One of a predetermined subset of nuclear power plant conditions when either the potential exists for a radiological emergency, or such an emergency has occurred.

An IC is an emergency condition, which sets it apart from the broad class of conditions that may or may not have the potential to escalate into a radiological emergency.

It can be a continuous, measurable function that is outside technical specifications, such as elevated PCS temperature or falling reactor coolant level (a symptom).

1.1.25 Offsite All land and water areas outside the owner-controlled area.

1.1.26 Onsite All land and water areas within the owner-controlled area, use of which must be authorized by Entergy Corporation.

1.1.27 Operational Status of an emergency facility, declared by the appropriate facility manager upon determining that the facility is adequately staffed and equipment is setup and available to assume/perform the emergency functions assigned to that facility.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 11 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN 1.1.28 Operations Support Center (OSC)

The onsite area in which onsite support personnel can assemble for subsequent assignment to duties in support of emergency operations. Support personnel assigned to the OSC normally consist of Chemistry, Radiation Protection, and repairpersons from I&C, Electrical, and Mechanical Maintenance.

1.1.29 Owner Controlled Area The area surrounding the Plant in which the reactor licensee has the authority to determine all activities including exclusion or removal of persons and property from the area during accident conditions.

1.1.30 Plume Exposure Pathway The path by which a radioactive cloud (plume) can expose the population-at-risk and/or onsite personnel to radiation. The principle exposure sources for this pathway are:

a. Whole body external exposure to gamma radiation from the radioactive plume and from deposited material.

b. Inhalation exposure from the passing radioactive plume.

1.1.31 Population at Risk Those persons for whom protective actions are or would be taken.

1.1.32 Protective Actions Those emergency measures taken for the purpose of preventing or minimizing radiological exposures to individuals that would be likely to occur if the actions were not taken.

1.1.33 Protective Action Guides (PAG)

Projected radiological dose or dose commitment values to individuals in the general population that warrant protective action following a release of radioactive material.

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.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 12 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN 1.1.34 Protected Area The fenced area immediately surrounding the nuclear Plant, access to which is controlled in accordance with the Safeguards Contingency Procedures.

1.1.35 Radiological Emergency An emergency involving radioactive material.

1.1.36 Recovery Actions Those actions taken after the emergency to restore the Plant as nearly as possible to its pre-emergency condition.

1.1.37 Site Area Emergency 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 effective access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.

1.1.38 Emergency Plant Manager The person designated as responsible for all onsite actions during an emergency condition.

1.1.39 State The State of Michigan.

1.1.40 Technical Support Center (TSC)

An area which accommodates personnel which will provide management and technical support to Plant Operations personnel during emergency conditions from a location outside the Control Room.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 13 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN 1.1.41 Unusual Event 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.

2.0 SCOPE AND APPLICABILITY 2.1 GENERAL INFORMATION AND SITE DESCRIPTION The Palisades Nuclear Power Plant is owned by Entergy Corporation. An area map showing the location of the facility is provided in Figure 2-1.

The design of the Palisades Nuclear Plant is that of a pressurized water-type nuclear steam supply system supplied and manufactured by Combustion Engineering. The system uses chemical shim and control rods for reactivity control and U-tube steam generators. Maps identifying Palisades Plant facilities are provided in Figures 2-2 and 2-3. The Palisades Nuclear Power Plant (PNP) ceased power operations and is permanently defueled in accordance with 10 CFR 50.82(a)(1)(i) and (ii). On January 4, 2017, Entergy Nuclear Operations (ENO) submitted a certification of permanent cessation of power operations pursuant to 10 CFR 50.82(a)(1)(i). ENO has submitted written certification to the NRC in accordance with 10 CFR 50.82(1)(ii) that meets the requirements of 10 CFR 50.4(b)(9) certifying that fuel has been permanently removed from the reactor vessel. Upon docketing of these certifications, the 10 CFR Part 50 license for PNP no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel, as specified in 10 CFR 50.82(a)(2).

With irradiated fuel being stored in the Spent Fuel Pool and the Independent Spent Fuel Storage Installation (ISFSI), the reactor coolant system and secondary systems have no function related to the storage of the irradiated fuel. Therefore, the postulated accidents involving failure or malfunction of the reactor and reactor coolant system or secondary systems are no longer applicable.

The Palisades Plant is located in Covert Township, Van Buren County, Michigan.

The Plant is bordered to the north by the Van Buren State Park and to the west by Lake Michigan. The south and east are sparsely populated, underdeveloped, or used for farming. Interstate 196 and the Blue Star Highway lie within one mile east of the site. Much of the area around the site is devoted to recreation and tourism, which produces a fluctuating and seasonal population.

Highway access to the Plant is provided from the Blue Star Highway (A-2) via the Plant access road.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 14 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN 2.2 POPULATION DISTRIBUTION AND EVACUATION TIMES The area within a 10-mile radius surrounding the Palisades Plant is designated as the plume exposure Emergency Planning Zone (EPZ). A comprehensive population study was prepared in August 2012 by KLD Engineering. The Evacuation Time Estimates for the plume EPZ are adopted as a progeny procedure to Palisades Site Post-Shutdown Emergency Plan. See PSEP Supp 2, "Evacuation Time Estimates."

2.3 EMERGENCY PLANNING ZONES EPZs are areas designated for which planning is recommended to assure that prompt and effective actions are taken to protect the public in the event of an accident.

Two EPZs have been identified for the purpose of development and implementation of emergency planning. The plume exposure emergency planning zone has a 10 mile radius. Within this zone, shelter and/or evacuation is the immediate protective action to be recommended for the general public. The principal concern with the plume exposure pathway is that of Total Effective Dose Equivalent (TEDE) exposure and/or exposure to the adult thyroid Committed Dose Equivalent (CDE) due to inhalation and ingestion.

The ingestion exposure EPZ extends to a 50-mile radius. Once exceeding the 10-mile radius, the plume exposure pathway is no longer of significant concern.

At this point, the ingestion pathway is of greatest concern.

2.4 PURPOSES AND OBJECTIVES Effective emergency preparedness needs to incorporate not only the emergency response for systems, but must also include response for people. Engineering safety systems at the Plant are designed to ensure that the consequences of a major malfunction will be mitigated prior to any adverse effect to the general public or facility. The basis for emergency planning is to provide human emergency response in much the same way as safety systems do for design.

It is imperative that all plans, programs, and procedures be well coordinated with the Emergency Plan. Only when they are well coordinated can the response to emergencies be initiated in a timely and effective manner.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 15 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN 2.4.1 Regulatory Requirements 10 CFR 50, "Domestic Licensing Of Production and Utilization Facilities" Section 50.34, "Contents of Applications; Technical Information", requires that each application for a license to operate a facility include in a Final Safety Analysis Report (FSAR), along with other information, the applicant's plans for coping with emergencies, including the items specified in Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities," 10 CFR 50. Section 100.3, 10 CFR 100, "Reactor Site Criteria," in the definitions of exclusion area and low population zone, establishes additional criteria for plans to cope with emergencies and serious accidents. 10 CFR 50.47, "Emergency Plans," requires that adequate protective measures can and will be taken in the event of a radiological emergency.

Supplemental guidance has been provided by the Nuclear Regulatory Commission (NRC) by the following documents:

a. NUREG-0654, Revision 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plant" (November 1980).

b. NUREG-0696, "Functional Criteria for Emergency Response Facilities" (February 1981).

These documents describe methods acceptable to the NRC staff for compliance with the Commission's regulations in regard to the content of emergency plans for nuclear power plants including provisions for the periodic review and revision of the Emergency Plans.

2.4.2 Purpose of Emergency Preparedness The purpose of emergency preparedness is to provide a mechanism that would be used in making decisions in the event of an emergency, and to assure that the necessary equipment, supplies, and essential services are available to protect the health and safety of the public.

2.4.3 Objectives of the Palisades Site Post-Shutdown Emergency Plan The objectives of the Site Post-Shutdown Emergency Plan are to:

a. Establish criteria for classifying emergencies, performing notifications, activating emergency facilities, and activating portions of the emergency organization.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 16 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN

b. Establish an emergency organization and assign responsibilities in the emergency organization for classifying emergencies, performing notifications, performing onsite protective actions, performing dose assessments, and making recommendations to offsite authorities.

c. Identify the support that will be provided to the onsite emergency organization by the Entergy Corporation headquarters and offsite organizations (ie, fire, ambulance, medical).

d. Identify the offsite authorities that are responsible for taking protective actions on behalf of members of the general public or that interface with this Emergency Plan.

e. Identify emergency facilities and available communication systems to be used by the emergency organization.

f. Identify training for personnel in the emergency organization.

g. Provide for drills and exercises of the emergency organization.

h. Provide for periodic review and update of the plan.

2.5

SUMMARY

OF EMERGENCY PLAN INTERRELATIONSHIPS This Emergency Plan should not, in itself, be considered the sole working document to be used during an emergency. The purpose of the Emergency Plan is to classify emergencies according to their severity, to assign responsibilities for actions, and to clearly outline the most effective course of action required to safeguard the public and Plant personnel in the event of an emergency. Detailed instructions and guidelines for emergency actions are included in other plans, programs, and procedures as described below.

2.5.1 Site Post-Shutdown Emergency Plan Supplement 1 The "Site Post-Shutdown Emergency Plan Supplement 1 - EAL Wall Charts" contains the Palisades Emergency Action Levels in a wall chart format. It is part of the Site Post-Shutdown Emergency Plan. Changes to the supplement require all the same types of reviews and approvals as required for the Site Post-Shutdown Emergency Plan. Revisions to the supplement will be tracked by its own revision number, not the PSEP's revision number.

The "Site Post-Shutdown Emergency Plan Supplement 1 - EAL Wall Charts" will be maintained in the same binder as the Site Post-Shutdown Emergency Plan.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 17 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN 2.5.2 Site Post-Shutdown Emergency Plan Supplement 2 The Site Post-Shutdown Emergency Plan Supplement 2 - "Evacuation Time Estimates (Revision 1, August 2012)" contains the Palisades updated Evacuation Time Estimates study (Revision 1, August 2012). It is part of the Site Post-Shhutdown Emergency Plan. Changes to the supplement require all the same types of reviews and approvals as required for the Site Post-Shutdown Emergency Plan.

Revisions to the supplement will be tracked by its own revision number, not the PSEPs revision number.

The Site Post-Shutdown Emergency Plan Supplement 2 - "Evacuation Time Estimates" will be maintained in the same binder as the Site Post-Shutdown Emergency Plan.

2.5.3 Emergency Implementing Procedures Detailed Emergency Implementing Procedures required to implement the plan have been developed. An index of the Emergency Implementing Procedures is included in Appendix D.

Detailed implementing procedures for emergencies considered to be special events, such as civil disturbances, bomb threats, and breaches in security are included as part of the Safeguards Contingency Procedures.

Separate emergency procedures are not provided for activities already covered by Plant or section Operating Procedures (ie, calibration of survey instruments). The plan relies on certain aspects of the Plant's operating procedures, radiation protection procedures, and security procedures, where they are required for clarification.

2.5.4 Related Plans, Programs, and Procedures Several plans, programs, and procedures have been developed to assure the safe operation of the Plant. The Site Post-Shutdown Emergency Plan and Emergency Implementing Procedures have been written to coordinate these plans with other programs and procedures. During emergency situations, the coordination and utilization of all plans and procedures are essential.

The Safeguards Contingency Procedures have been coordinated with the Site Post-Shutdown Emergency Plan and Emergency Implementing Procedures to minimize the consequences of an emergency situation. Security procedures contain an explanation of the duties and responsibilities for security personnel in the event of an emergency.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 18 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN Provisions for radiological control at the Plant have been covered in Radiation Protection Procedures. These procedures establish controls and protective measures to be placed on work being conducted in radiation areas. Inclusive within the area of radiation control are the procedures that Radiation Protection establishes for determining exposure through surveys, analysis, and various other avenues.

The Palisades Emergency Operating Procedures have been developed to control Plant operation during emergency situations. These emergency procedures work in conjunction with the Emergency Plan Implementing Procedures.

The Palisades Nuclear Plant Public Information Policies and Procedures contain the information necessary to establish a flow of emergency information to the public.

The Palisades Fire Protection Plan has been developed to assure the safe operation of the Plant during a fire.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 19 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN FIGURE 2-1 PALISADES PLANT GENERAL LOCATION

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 20 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN FIGURE 2-2 PALISADES FACILITIES

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 21 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN FIGURE 2-3 PALISADES NUCLEAR PLANT SITE

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 22 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN 3.0 SITE POST-SHUTDOWN EMERGENCY PLAN

SUMMARY

The Post-Shutdown Emergency Plan establishes the basic steps that will be used to determine the response of the emergency organization for each of four emergency classes. The emergency classes are as follows: Unusual Event, Alert, Site Area Emergency, and General Emergency. The conditions that must exist for the declaration of a specific emergency class are presented in the Site Post-Shutdown Emergency Plan, Supplement 1 - EAL Wall Charts.

The declaration of each class will lead to specific notification of offsite authorities.

Emergency facilities shall be activated as described in Table 3-1, "Emergency Classifications and the Level of Response by Participating Groups," and staffed as presented in Section 5 of the Palisades Site Post-Shutdown Emergency Plan. In response to a particular event, certain protective actions may be initiated or certain offsite agencies may be activated. These actions are detailed in Section 6 of the Palisades Site Post-Shutdown Emergency Plan. Palisades maintains the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded and promptly declares the emergency condition as soon as possible following identification of the appropriate emergency classification level.

For emergencies that result in (1) the release of radioactive materials greater than specified levels, or (2) the degradation of barriers to the release of radioactive materials, assessments of the offsite consequences or the projected offsite consequences shall be made. These assessments will be transmitted to the offsite authorities responsible for taking protective actions on behalf of the general public.

Recommendations to these offsite authorities will be based on the protective actions identified in Table 6-2 from the Palisades Site Post-Shutdown Emergency Plan.

3.1 POST-SHUTDOWN EMERGENCY PLAN STEPS In general, the Post-shutdown Emergency Plan encompasses the following basic steps:

a. Detection of the emergency

b. Classification of the emergency

c. Notification of offsite agencies

d. Activation of the responding organization(s)

e. Assessment of the situation

f. Initiation of protective actions

g. Initiation of corrective actions

h. Aid to affected persons

i. Reentry and recovery

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 23 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN 3.2 ENTERGY CORPORATION EMERGENCY ORGANIZATION This Post-Shutdown Emergency Plan establishes an organization capable of responding to the complete spectrum of incidents covered by this Post-Shutdown Emergency Plan. Provisions are made for rapid notification of appropriate portions of the response organization, and for expanding the response organization if the situation dictates.

An individual having the authority and responsibility to initiate any emergency actions within the provisions of this Post-Shutdown Emergency Plan, including the exchange of information with authorities responsible for coordinating offsite emergency measures, is onsite at all times. This individual is the Shift Manager until relieved by the Emergency Director.

The operating shift crew is responsible for implementing emergency action(s) in accordance with assigned response functions. Emergency response functions are also assigned to additional Plant staff personnel who are rapidly alerted and mobilized to augment or relieve the operating shift personnel of emergency duties as deemed appropriate by the Emergency Plant Manager, and in accordance with the implementing procedures of this Plan.

In addition, this Plan includes offsite agencies and organizations who have signed letters of agreement with Palisades Nuclear Power Plant (see Appendix A). Their designated response functions include implementation of offsite protective actions, transportation and treatment of personnel requiring medical treatment, control of access to the station, fire-fighting support, radiological sampling and assessment, technical consultation, and testing.

3.3 EMERGENCY CLASSIFICATIONS Emergencies are grouped into four classifications listed below in order of severity:

a. Unusual Event 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.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 24 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN

b. Alert Events are in process or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.

c. Site Area Emergency 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 effective access to equipment needed for the protection of the public.

Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.

d. General Emergency 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 offsite for more than the immediate site area.

Section 4 from the Palisades Nuclear Plant Site Post-Shutdown Emergency Plan contains a more detailed discussion of the classifications of emergencies. Table 3-1, "Emergency Classifications and the Level of Response by Participating Groups,"

shows, in column form, the emergency classifications, and the degrees of involvement of onsite and offsite organizations.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 25 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN 3.4 EMERGENCY ACTIONS In all instances, when one of the classifications of the above emergencies occurs in the Plant, the Shift Manager is responsible for taking immediate action to safeguard personnel and equipment. Utilizing the Palisades Nuclear Plant Emergency Implementing Procedures, the Shift Manager shall activate the necessary portions of the Site Post-Shutdown Emergency Plan. The basic considerations for safe operation of the Plant, and for action in the event of an emergency in the Plant, are summarized as follows:

a. In any event, protection of Plant personnel and the public is the highest priority. A range of protective actions to protect onsite personnel during hostile action is provided to ensure the continued ability to safely shut down the reactor and perform the functions of the emergency plan. Plant system and equipment protection is secondary.

b. When there is doubt as to the classification of the emergency condition, the more conservative case is considered.

c. The instrumentation is assumed to be providing correct information unless it is clearly identified that an instrument is erroneous or out of service.

d. All alarms are promptly acknowledged, any required response action is taken, and an immediate investigation of the cause that initiated the alarm is made.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 26 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN TABLE 3-1 EMERGENCY CLASSIFICATIONS AND THE LEVEL OF RESPONSE BY PARTICIPATING GROUPS SHIFT PLANT STAFF SUPPORT EMERGENCY RESPONSE NOTIFICATION RESPONSE RESPONSE Unusual Investigate. Shift Duty Station Supplement on-shift None Event Manager activates Manager, resources as needed.

appropriate Van Buren County, emergency team(s). State, and NRC.

Alert Investigate. Shift Duty Station TSC/OSC/EOF activation. Emergency Plant Manager activates Manager, Discretionary News Manager appropriate Van Buren County, Center activation. determines need emergency teams. State, NRC, and Supplement activated for offsite Required in-plant staff augmentation. emergency teams. support. Acquire protective actions Investigate event, assist offsite support as performed. shift personnel in required.

controlling Plant response. Assess radiological consequences.

Site Area Investigate. Shift Duty Station TSC/OSC/EOF/JIC Determine need Emergency Manager activates Manager, activation. Supplement for further offsite appropriate teams. Van Buren County, activated emergency support. Acquire Required in-plant State, NRC, and teams. Investigate event, offsite support as protective actions staff augmentation. assist shift personnel in required.

performed. controlling Plant response. Assess radiological consequences.

General Investigate. Shift Duty Station TSC/OSC/EOF/JIC Determine need Emergency Manager activates Manager, activation. Supplement for further offsite appropriate teams. Van Buren County, activated emergency support. Acquire Required Plant State, NRC, and teams. Investigate event, offsite support as protective actions staff augmentation. assist shift personnel in required.

performed. controlling Plant response. Assess radiological consequences. EOF Director provides protective action recommendations to offsite authorities.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 27 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN 4.0 POST-SHUTDOWN EMERGENCY CONDITIONS 4.1 EMERGENCY CLASSIFICATION SYSTEM This Site Post-Shutdown Emergency Plan provides four mutually exclusive classifications covering the postulated spectrum of emergency situations. For each classification, a particular set of immediate actions to be taken is established as described in Section 6, of the Site Post-Shutdown Emergency Plan. Actions for each of the four mutually exclusive classifications are defined in Emergency Implementing Procedure EI-1, "Emergency Classification and Actions,"

Attachment 1, "Emergency Actions."

The various classifications of accidents represent a hierarchy of accidents based on potential or actual hazards presented to the general public. Accidents may be classified in a lower category at first and then escalated to another higher classification if the situation deteriorates. Accident classification may be downgraded as conditions improve. The four classes that comprise the Emergency Classification System are:

a. Unusual Event

b. Alert

c. Site Area Emergency

d. General Emergency All emergency measures begin with the notification of the Shift Manager that a situation exists which presents a real or potential hazard. This is followed by assessment and evaluation by the Shift Manager, classification of the emergency, notifications, and activation and/or mobilization of the applicable emergency organizations. Section 6 summarizes the emergency measures to be taken by both the onsite and offsite emergency organizations.

Emergency Action Levels (EALs) are used to describe each of the four emergency classes. These levels are composed of a combination of Plant parameters (such as instrument readings and system status) that can be used to give relatively quick indication to the Plant operating staff of the severity of the accident situation.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 28 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN The purpose of the EAL is to provide the earliest possible identification of actual or potential accident situations. In most cases, further assessment action will be conducted both onsite and offsite before actual protective actions are initiated.

EALs associated with radioactive releases are related to the Environmental Protection Agency's Protective Actions Guides (PAG) summarized in EPA 400-R-92-001, "Manual of Protective Action Guides and Protective Actions for Nuclear Incidents." An assessment by the Plant emergency organization along with state support agencies of the potential of reaching or exceeding the PAG will be performed following the declaration of an emergency class.

When EALs are observed in conjunction with Plant or equipment status due to planned maintenance or testing activities, an emergency condition does not exist.

A conservative philosophy for classification shall be used to declare the highest classification for which an EAL has been exceeded. For example, a Site Area Emergency would be declared directly if a Site Area Emergency level is exceeded without having previously been declared in a lower Alert classification.

The Emergency Action Levels are not necessarily all inclusive. The Shift Manager/EOF Emergency Director shall declare an appropriate emergency classification whenever, in their personal judgment, the Plant status warrants such a declaration.

Palisades Emergency Action Levels can be found in the "Site Post-Shutdown Emergency Plan Supplement 1 - EAL Wall Charts."

4.1.1 Unusual Event The Unusual Event is the least severe of the four emergency classifications. For the purposes of this plan, an Unusual Event is defined as that situation where, "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."

The purpose of the Unusual Event declaration is to:

a. Assure that the first step in any response later found to be necessary has been carried out.

b. Bring the Plant operations staff to a state of readiness.

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c. Provide systematic handling of Unusual Events information and decision-making.

Guidelines for Plant, State, and local actions are listed in Table 4-1.

An incident shall be classified as an Unusual Event if the event is minor in nature, involves no releases of radioactive material requiring offsite response or monitoring, and presents no immediate hazard to the public. Events in this classification are selected based upon a potential to degenerate to a more severe situation rather than an actual public hazard.

4.1.2 Alert An Alert is defined as that situation where, "Events are in process or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels." The Alert class involves relatively minor emergency situations that have a direct effect on the Plant safety-related systems. The Alert shall set into motion personnel onsite and offsite who would be required to perform actions up to and including the evacuation of near-site areas. The Alert class also addresses limited releases of radioactive material and, therefore, might require some assessment actions by the emergency organizations.

The purpose of the Alert declaration is to:

a. Assure that emergency personnel are readily available to respond if the situation becomes more serious or to perform confirmatory radiation monitoring if required.

b. Provide offsite authorities current status information.

Guidelines for Plant, State, and local actions are listed in Table 4-1.

An incident shall be classified as an Alert if there is real or potential limited releases of radioactive material to the environment. A situation shall be classified at the Alert level only if EALs for higher classification have not been exceeded or are not expected to be exceeded in the near term.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 30 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN 4.1.3 Site Area Emergency A Site Area Emergency is defined as that situation where, "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 effective access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.

The purpose of the Site Area Emergency declaration is to:

a. Assure that emergency response facilities are manned.

b. Assure that radiation-monitoring teams are dispatched both onsite and offsite.

c. Assure that personnel required for evacuation of near-site areas are at their duty stations if the situation becomes more serious.

d. Provide consultation with offsite authorities.

e. Provide updates for the public through offsite authorities.

Guidelines for Plant, State, and local actions are listed in Table 4-1. Although immediate protective actions are not automatically required, declaration of a Site Area Emergency shall set into motion all personnel onsite and offsite who would be required to perform actions up to and including the evacuation of near-site areas.

Dispatched radiation monitoring teams will make continuing assessments to provide officials with information to decide protective actions. The Site Area Emergency classification includes accidents that have significant radiation release potential.

Unlike the Unusual Event and Alert classifications of emergencies, the Site Area Emergency classification may involve some radiation exposure to the near-site public. Many of the accidents included in this classification have the potential for degradation to the General Emergency classification. Although the EALs for this classification have been selected at values well below the EPA PAGs, offsite monitoring team reports and continuing assessment actions shall lead to any final decision on protective actions to be taken.

Accidents that have significant potential for the release of radioactive material shall be classified as a Site Area Emergency.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 31 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN 4.1.4 General Emergency The General Emergency is the most severe classification of emergency. The General Emergency classification is defined as that situation where, "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 offsite for more than the immediate site area."

The purpose of the General Emergency declaration is to:

a. Initiate predetermined protective actions for the public.

b. Provide continuous assessment of information from Palisades Plant, and offsite monitoring groups.

c. Initiate additional measures as indicated by event releases or potential releases.

d. Provide consultation with offsite authorities.

e. Provide updates for the public through offsite authorities.

Guidelines for Plant, State, and local actions are listed in Table 4-1. Some protective actions may be recommended upon declaration of the General Emergency since the lower limits of the EPA PAGs are likely to be exceeded.

Emergency Action Levels (EAL) have been selected so that time should be available to make some confirmatory measurements in the field prior to implementation of the more extensive (i.e., evacuation) protective action. Some of the General Emergency action levels require a dose projection calculation using actual meteorology. This differs from the adverse meteorology assumptions used in the Site Emergency action Action levels Levels in order to remove this built-in conservatism and to preclude declaring a General Emergency when actual conditions do not warrant the higher classification. Declaration of a General Emergency requires a recommendation to the State for protective actions for the local population.

4.2 CLASSIFICATION OF POSTULATED ACCIDENTS The events postulated in Section 14, Palisades Plant Final Safety Analysis Report (FSAR), may be categorized into one or more of the four emergency classifications. A complete discussion of these events may be found in the FSAR.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 32 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN TABLE 4-1 GUIDELINES FOR PLANT, STATE AND LOCAL ACTIONS STATE AND/OR LOCAL OFFSITE CLASS LICENSEE ACTIONS AUTHORITY ACTIONS UNUSUAL EVENT Class Description Events are in process or have 1. Promptly inform state and local offsite 1. Provide fire or security occurred which indicate a authorities of nature of unusual assistance if requested.

potential degradation of the level condition as soon as discovered.

of safety of the plant or indicate 2. Escalate to a more severe a security threat to facility 2. Augment on-shift resources as class, if appropriate.

protection has been initiated. needed.

No releases of radioactive 3. Stand by until verbal closeout.

material requiring offsite 3. Assess and respond.

response or monitoring are expected unless further 4. Escalate to a more severe class, if degradation of safety systems appropriate, occurs.

or Purpose

5. Close out with verbal summary to Purpose of offsite notification is offsite authorities; followed by written to: (1) assure that the first step summary.

in any response later found to be necessary has been carried out, (2) bring the operating staff to a state of readiness, and (3) provide systematic handling of Unusual Events information and decision making.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 33 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN TABLE 4-1 GUIDELINES FOR PLANT, STATE AND LOCAL ACTIONS STATE AND/OR LOCAL OFFSITE CLASS LICENSEE ACTIONS AUTHORITY ACTIONS ALERT Class Description Events are in process or have 1. Promptly inform state and local offsite 1. Provide fire or security occurred which involve an actual authorities of Alert status and reason assistance if requested.

or potential substantial for emergency as soon as discovered.

degradation of the level of safety 2. Augment resources and bring of the plant or a security event 2. Augment resources by activating primary response centers and that involves probable life onsite Technical Support Center, Emergency Alert System to threatening risk to site personnel onsite Operations Support Center, and standby status.

or damage to site equipment near-site Emergency Operations because of HOSTILE ACTION. Facility (EOF). 3. Alert to standby status key Any releases are expected to be emergency personnel limited to small fractions of the 3. Assess and respond. including monitoring teams EPA Protective Action Guideline and associated exposure levels. 4. Dispatch onsite monitoring teams and communications.

associated communications.

Purpose 4. Provide confirmatory off-site

5. Designate an individual for Plant status radiation monitoring and Purpose of the Alert is to updates to offsite authorities. ingestion pathway dose (1) assure that emergency projections if actual releases personnel are readily available 6. Provide meteorological data to off site substantially exceed Technical to respond if situation becomes authorities and if any releases are Specification limits.

more serious or to perform occurring, dose estimates for actual confirmatory radiation releases. 5. Escalate to a more severe monitoring if required, and class, if appropriate.

(2) provide offsite authorities 7. Escalate to a more severe class, if current status information. appropriate 6. Maintain Alert status until verbal closeout or reduction of or emergency class.

8. Close out or recommend reduction in emergency class by briefing of offsite authorities and by phone followed by written summary.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 34 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN TABLE 4-1 GUIDELINES FOR PLANT, STATE AND LOCAL ACTIONS STATE AND/OR LOCAL OFFSITE CLASS LICENSEE ACTIONS AUTHORITY ACTIONS SITE AREA EMERGENCY Class Description Events are in process or have 1. Promptly inform state and local offsite 1. Provide any assistance occurred which involve an actual authorities of Site Area Emergency requested.

or likely major failures of plant status and reason for emergency as functions needed for protection soon as discovered. 2. If sheltering near the site is of the public or HOSTILE desirable, activate public ACTION that results in 2. Augment resources by activating notification system within at intentional damage or malicious onsite Technical Support Center, least two miles of the Plant.

acts; (1) toward site personnel onsite Operations Support Center, and or equipment that could lead to near-site Emergency Operations 3. Provide public within at least the likely failure of or; (2) that Facility (EOF). about 10 miles periodic prevent effective access to updates on emergency status.

equipment needed for the 3. Assess and respond.

protection of the public. Any 4. Augment resources by releases are not expected to 4. Dispatch onsite and offsite monitoring activating primary response result in exposure levels which teams and associated centers.

exceed EPA Protective Action communications.

Guideline exposure levels 5. Dispatch key emergency beyond the site boundary. 5. Designate an individual for Plant status personnel including monitoring updates to offsite authorities and teams and associated Purpose periodic press briefings (perhaps joint communications.

with offsite authorities).

Purpose of the Site Area 6. Alert to standby status other Emergency declaration is to: 6. Make senior technical and emergency personnel (1) assure that response centers management staff onsite available for (eg, those needed for are manned, (2) assure that consultation with NRC and state on a evacuation) and dispatch monitoring teams are periodic basis. personnel to near-site duty dispatched, (3) assure that stations.

personnel required for 7. Provide meteorological and dose evacuation of near-site areas estimates to offsite authorities for 7. Provide off-site monitoring are at duty stations if situation actual releases via a designated results to licensee, DOE, and becomes more serious, individual or automated data others and jointly assess (4) provide consultation with transmission. them.

offsite authorities, and (5) provide updates for the Cont'd on next page. Cont'd on next page.

public through offsite authorities.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 35 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN TABLE 4-1 GUIDELINES FOR PLANT, STATE AND LOCAL ACTIONS STATE AND/OR LOCAL OFFSITE CLASS LICENSEE ACTIONS AUTHORITY ACTIONS SITE AREA EMERGENCY (cont)

8. Provide release and dose projections 8. Continuously assess based on available Plant condition information from licensee and information and foreseeable offsite monitoring with regard contingencies. to changes to protective actions already initiated for

9. Escalate to a General Emergency public and mobilizing class, if appropriate. evacuation resources.

or 9. Recommend placing milk animals within 10 miles on stored feed and assess need

10. Close out or recommend reduction in to extend distance.

emergency class by briefing of offsite authorities and by phone followed by 10. Provide press briefings with written summary licensee.

11. Escalate to General Emergency class, if appropriate.

12. Maintain General Emergency status until closeout or reduction of emergency class.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 36 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN TABLE 4-1 GUIDELINES FOR PLANT, STATE AND LOCAL ACTIONS STATE AND/OR LOCAL OFFSITE CLASS LICENSEE ACTIONS AUTHORITY ACTIONS GENERAL EMERGENCY Class Description Events are in process or have 1. Promptly inform state and 1. Provide any assistance occurred which involve actual or local offsite authorities of requested.

imminent substantial core General Emergency status degradation or melting with and reason for emergency 2. Activate immediate public potential for loss of containment as soon as discovered notification of Emergency integrity or HOSTILE ACTION (parallel notification of status and provide public that results in an actual loss of state/local). periodic updates.

physical control of the facility.

Releases can be reasonably 2. Augment resources by 3. For actual or projected expected to exceed EPA activating onsite Technical severe core damage Protective Action Guideline Support Center, and onsite accidents or loss of control exposure levels offsite for more Operations Support Center of facility, recommend than the immediate site area. and near-site Emergency evacuation for 2 mile radius Operations Facility (EOF). and 5 miles downwind Purpose (unless conditions make

3. Assess and respond. evacuation dangerous) and Purpose of the General assess need to extend

4. Dispatch onsite and offsite distances. Advise the Emergency declaration is to: monitoring teams and (1) initiate predetermined remainder of plume EPZ to associated go indoors and listen to protective actions for the public, communications.

(2) provide continuous Emergency Alert assessment of information from 5. System (EAS) messages.

Designate an individual for licensee and offsite organization Plant status updates to 4. Augment resources by measurement, (3) initiate offsite authorities and activating primary response additional measures as periodic press briefings centers.

indicated by actual or potential (perhaps joint offsite releases, (4) provide authorities). 5. Dispatch key emergency consultation with offsite personnel including authorities, and (5) provide 6. Make senior technical and monitoring teams and updates for the public through management staff onsite associated communications.

offsite authorities. available for consultation with NRC and state on a 6. Dispatch other emergency periodic basis. personnel to duty stations within five-mile radius and

7. Provide meteorological and alert all others to standby dose estimates to offsite status.

authorities for actual releases via a designated 7. Provide offsite monitoring individual or automated results to licensee, DOE, data transmission. and others and jointly assess them.

Cont'd on next page.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 37 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN TABLE 4-1 GUIDELINES FOR PLANT, STATE AND LOCAL ACTIONS STATE AND/OR LOCAL OFFSITE CLASS LICENSEE ACTIONS AUTHORITY ACTIONS GENERAL EMERGENCY (cont)

8. Provide release and dose 8. Continuously assess projections based on information from licensee available Plant condition and offsite monitoring with information and foreseeable regard to changes to contingencies. protective actions already initiated for public and

9. Close out or recommend mobilizing evacuation reduction in emergency resources.

class by briefing of offsite authorities at EOF and by 9. Recommend placing milk phone followed by written animals within 10 miles on summary. stored feed and assess need to extend distance.

10. Provide press briefings with licensee.

11. Maintain General Emergency status until closeout or reduction of emergency class.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 38 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN 5.0 ORGANIZATIONAL CONTROL OF EMERGENCIES Emergency planning must consider the capabilities of the normally present operating staff, augmented by support from other utility personnel and local and distant support. The initial phases of an emergency situation at an operatinga permanently shutdown and defueled nuclear power plant will involve a relatively small number of individuals. These individuals must be capable of: (1) determining that an emergency exists, (2) providing initial classification and assessment, and (3) promptly notifying other groups and individuals in the emergency organization.

The Palisades Plant Organization has complete capability, at all times, to perform the detection, classification, and notification functions required in the early phases of an emergency. These capabilities are augmented, as required, by the Palisades Emergency Response Organization (ERO).

This section of the Site Post-Shutdown Emergency Plan addresses the assignment of personnel and the establishment of responsibilities and authority for the:

a. Palisades Plant Organization

b. Palisades Emergency Response Organization Figure 5-1 shows the interfaces between these organizations, governmental agencies, and the general public.

5.1 PALISADES PLANT ORGANIZATION The Palisades Nuclear Plant operating and shift engineering activities are under the control of the General Manager, Plant Operations. The operating and shift engineering activities at the Plant are conducted by operating crews on twelve-hour shifts. Each twelve-hour shift is responsible for continuous operation of the Plant.

5.2 OPERATING AND ENGINEERING ORGANIZATION The Palisades Plant organization includes personnel encompassing both the management and operations of the unitstaff. The minimum on-shift staffing is indicated in Figure 5-2.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 39 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN 5.2.1 GENERAL MANAGER, PLANT OPERATIONS The General Manager, Plant Operations is responsible for the technical and administrative management of the day-to-day physical operation of the Plant; this includes Operations, Chemistry and Radiological Services, Maintenance, and Planning and Scheduling.

5.2.2 Director - Emergency Programs The Director, Emergency Programs, is directly responsible for Entergy Emergency Preparedness, including: company-wide projects, National emergency interfaces, and regulatory issues.

5.2.3 Director - Engineering The Director - Engineering is responsible for system and design engineering, nuclear engineering, engineering programs, dry fuel services, and nuclear fuel supply.

5.2.4 Regulatory and Performance Improvement Director The Regulatory and Performance Improvement Director provides onsite oversight/supervision for emergency planning.

5.2.5 Duty Station Manager This is a rotating position among qualified Plant upper management (as defined by the General Manager, Plant Operations). The Duty Station Manager functions as the General Manager, Plant Operations on backshifts and weekends.

5.2.6 Shift Manager The Shift Manager, one of whom is on duty at all times, is responsible for the safe and efficient operation of the Plant during his assigned shift. He The Shift Manager maintains control over Plant operations as the Senior Licensed OperatorCertified Fuel Handler (CFH) unless he is properly relieved by another member of the Plant staff who holds a valid Senior Operator's LicenseShift Manager. In an emergency condition, the Shift Manager initially assumes the role of Emergency Director.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 40 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN 5.2.7 Shift Engineers/Shift Technical Advisors (SE/STA)DELETED Shift Engineers/Shift Technical Advisors function in an oversight role for accident assessment and evaluation of operating conditions. While on duty, SE/STAs diagnose abnormal events and report to the Shift Manager. In an emergency condition, the SE/STA provides SEP oversight and may assist the Shift Manager in his role as Emergency Director.

5.3 PALISADES EMERGENCY RESPONSE ORGANIZATION In the event of an emergency in which one of the classification levels is declared (Unusual Event, Alert, Site Area Emergency, or General Emergency), all or a portion of the Site Post-Shutdown Emergency Plan will be activated. The assignment of responsibilities in the Emergency Response Organization (ERO) is ultimately the responsibility of the General Manager, Plant Operations. However, the ERO is predefined and alternate assignments to various positions are specified to provide for automatic, unambiguous manning staffing of the emergency organization within the time necessary to respond to the emergency.

In general, the emergency organization will be housed in five emergency response centers:

a. Control Room

b. Technical Support Center

c. Operations Support Center

d. Emergency Operations Facility

e. Joint Information Center 5.3.1 Control Room The Control Room is designed to be habitable under accident conditions and shall serve as the on-site Emergency Control Center. Emergency lighting, power, air filtration-ventilation system, and shielded walls enable the operators to remain in the Control Room to ensure that the reactor plant remains in a safe condition. The minimum on-shift staffing is indicated in Figure 5-2.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 41 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN 5.3.2 Technical Support Center The Technical Support Center (TSC) will provide Plant management and technical support to Operations personnel during emergency conditions and guidance to Control Room operating personnel to mitigate the effects of the emergency condition.

The TSC organization can be found in Emergency Implementing Procedure EI-4.1, "Technical Support Center Activation."

5.3.3 Operations Support Center The Operations Support Center (OSC) will coordinate Emergency Maintenance, Radiation Protection, and Chemistry activities of Plant personnel. The Control Room or TSC (when activated) will direct the priorities for the OSC. The OSC organization can be found in Emergency Implementing Procedure EI-4.2, "Operations Support Center Activation."

5.3.4 Emergency Operations Facility (EOF)

The Emergency Operations Facility (EOF) is located in downtown Benton Harbor, approximately 16 miles South Southwest from the Plant. The EOF staff is responsible for overall management of an emergency and for communicating with external agencies upon transfer of responsibility from the Control Room.

Activation of the EOF is mandatory at the Alert, Site Area, and General Emergency Classifications. Activation of the EOF at an Unusual Event will be at the request of the Shift Manager. The EOF will be staffed by Plant personnel. The initial staff may be supplemented by federal, state, and local officials.

Once activated and operational, the EOF Emergency Director will be responsible for management of overall emergency response. The EOF will coordinate emergency response activities with federal, state, and local agencies to mitigate the consequences of an emergency. The EOF organization can be found in Emergency Implementing Procedure EI-4.3, "Emergency Operations Facility Activation."

The EOF provides an alternative facility, with communications capabilities for contacting the Control Room and plant security, to serve as a staging area for augmented emergency response staff if the site is under threat of, or experiencing hostile action.

The design features of the EOF are discussed in Palisades Site Post-Shutdown Emergency Plan, Section 7.0, "Emergency Facilities and Equipment."

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 42 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN 5.3.5 Joint Information Center (JIC)

The plant Communications personnel shall be responsible for maintenance of the Palisades Nuclear Plant Public Information Policies and Procedures. These provide for disseminating information to the public via the media and establishing a system for rumor control during an emergency. Public Affairs personnel shall coordinate the activation and management of the Joint Information Center (JIC) in cooperation with the Corporate Public Affairs Department. He Public Affairs personnel shall prepare and issue press releases in cooperation with state and local agencies. Reference Palisades Nuclear Plant Emergency Public Information Policies and Procedures for details.

5.4 EMERGENCY STAFFING Normal Plant staffing provides sufficient personnel for continuous protracted emergency operation. The extent to which the emergency organization is activated is dependent upon the classification of the emergency. A method for emergency staff augmentation is available to the Shift Manager. Figure 5-2 provides requirements for minimum additional staffing and required arrival times. Details of emergency staff augmentation are available in Emergency Implementing Procedure EI-2.2, "Emergency Staff Augmentation."

5.4.1 Shift Manager/EOF Emergency Director The Shift Manager/EOF Emergency Director is responsible for the overall assessment of emergency conditions, especially where emergency conditions present a real or potential hazard to off-site persons or property. The Shift Manager/EOF Emergency Director will have the overall responsibility for operational decisions involving the safety of the Plant and its personnel, and for making recommendations based on technical information supplied by support personnel regarding the general public during an emergency situation. He The Shift Manager/EOF Emergency Director will also implement the Palisades Site Post-Shutdown Emergency Plan through the use of specific Emergency Plan Implementing Procedures. The Shift Manager/EOF Emergency Director is responsible for ensuring the capability for continuous operation of emergency response centers, including personnel and material resources. In addition, the Shift Manager/EOF Emergency Director is responsible for providing off-site officials with pertinent information regarding the conditions at the Plant.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 43 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN Any conflicts that should arise between the Emergency Plant Manager and the NOTE:

EOF Emergency Director will be resolved by the Site Vice President.

5.4.2 Shift Manager/Emergency Plant Manager The Shift Manager/Emergency Plant Manager may not delegate the decision to evacuate the site or the decision to authorize exposures that exceed the 10 CFR 20 regulatory exposure limits for emergency workers.

Prior to activation of the EOF, the decision to recommend protective actions to off-site organizations also cannot be delegated. The EOF Director, in consultation with the Shift Manager, will assume this responsibility after the EOF is activated.

For backshifts and weekends, the Duty Station Manager assumes the role of the Plant General Manager.

The Shift Manager assumes the responsibilities of the Site Post-Shutdown NOTE:

Emergency Plan until relieved by the EOF Director.

The Emergency Plant Manager shall be assigned to the Technical Support Center once it is activated.

5.5 RECOVERY ORGANIZATION Recovery after an emergency condition will be handled by the emergency organization unless conditions indicate that recovery will be complicated or will take a long period of time. At the discretion of the EOF Emergency Director, the Plant will shift from an emergency organization structure to a Recovery Organization.

Guidelines that will be employed for determining this shift are explained in Palisades Site Post-Shutdown Emergency Plan, Section 9.0, "Recovery."

The Recovery Organization will depend upon the nature of the accident and the situations preceding the accident.

The TSC Engineering Coordinator will also support the EOF Rad Assessment Coordinator in determining how much radioactivity potentially can be released to the atmosphere based on the nature and extent of core damagespent fuel damage.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 44 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN 5.6 OFF-SITE EMERGENCY RESPONSE SERVICES The potential consequences of some emergencies may require the support services of off-site individuals, organizations, and agencies. As a result, local support service arrangements have been made with offsite groups to provide onsite aid in the event of an emergency situation, including those resulting from hostile actions. Support services encompass such areas as medical assistance, fire control, evacuation, ambulance services, and law enforcement. Written agreements are entered into to assure these individuals'/agencies'/organizations' availability and capabilities. In the written agreements, the agencies have outlined their responsibilities or have agreed to their responsibilities as outlined in this section. A listing of the letters of agreement, contracts, or signature pages has been included in Appendix A. In those cases where agency assistance is mandated by law (i.e., the State of Michigan), a letter of agreement may be excluded from the pPlan. The services provided by local support groups are listed in the following sections.

5.6.1 Medical Services The primary hospital facility for the treatment of serious medical emergencies occurring at the Plant is South Haven Community Hospital, located in South Haven, Michigan, approximately 6 miles from the Plant. South Haven Community Hospital is equipped to receive and treat all types of accident victims, including those with radioactive contamination. The backup medical facility is Lakeland Regional Medical Center, located approximately 20 miles from the Plant in St Joseph, Michigan.

The hospital shall be notified of incoming accident victims at the direction of the Emergency Director. The hospital may contact the Plant by telephone in the event information is required in the treatment of a victim.

Ambulance service for the transportation of accident victims, including radioactively contaminated victims, is provided by the Covert Fire Department, with backup services provided by South Haven Ambulance Service and Medic I of Benton Harbor.

The ambulance units and Emergency Medical Technicians are trained and equipped to respond to a medical emergency at the Plant. The Shift Manager is responsible for the decision to request off-site medical support. The ambulance service shall be notified at the direction of the Shift Manager. Contact with the ambulance may be maintained through the respective medical service dispatcher.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 45 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN 5.6.2 Fire-Fighting Services When it is determined by the Emergency Director that off-site fire support is necessary, fire protection response will be by the Covert Fire Department with mutual aid provided by the Van Buren County Mutual Aid Pact. Contact may be made using the telephone system. Fire Department personnel will be trained in handling emergency situations for nuclear facilities.

In addition to their fire suppression capabilities, the fire departments will provide specially equipped vehicles and personnel trained for emergency rescue and other contingencies.

5.6.3 Law Enforcement Agencies In the event of a civil disturbance or criminal act, the Michigan State Police, Van Buren County Sheriff Department, and the Covert Township Police Department may provide law enforcement assistance.

An Auto-Dial line exists to the Michigan State Police Operations in Lansing, Michigan and the Van Buren County Sheriff Department in Paw Paw, Michigan.

5.6.4 Van Buren County Office of Domestic Preparedness The Van Buren County Office of Domestic Preparedness is located in the County Sheriff's Courthouse Annex, Paw Paw, Michigan. In the event of an emergency, Van Buren County Sheriff's Department will disseminate information and recommendations initially supplied by Entergy Corporation to the Chairman of the Van Buren County Board of Commissioners, Van Buren County Domestic Preparedness Director, and the Emergency Operations Center (EOC), if activated.

Section 7.0, "Emergency Facilities and Equipment," summarizes communications.

The Chairman of the Van Buren County Board of Commissioners is responsible for activation of the county's Emergency Operations Plan. The Van Buren County Domestic Preparedness Director is responsible for overall coordination and planning of emergency response activities within the county. The Director will implement the activation and operational aspects of the EOC and alert key officials and agencies.

The Director will coordinate efforts with other agencies to inform the public in affected portions of the county to take protective actions when conditions warrant.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 46 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN 5.6.5 Berrien County Emergency Management The Berrien County Emergency Operations Center (EOC) is located in Benton Harbor, Michigan. The Chief of Staff (Director of Emergency Management) is responsible for overall coordination of emergency operations in Berrien County in the event of an emergency. The Chief of Staff operates under the direction of the Chief Executive (Chair, Berrien County Board of Commissioners). Berrien County Sheriff's Department will disseminate information and recommendations initially supplied by Entergy Corporation to the Chief of Staff and/or the Emergency Management Coordinator and the Emergency Operations Center (EOC), if activated. Site Post-Shutdown Emergency Plan, Section 7.0, "Emergency Facilities and Equipment," summarizes communications.

The Chief Executive (Chair, Berrien County Board of Commissioners) is responsible for activation of the County's Emergency Operations Plan and for overall coordination and planning of emergency operations with Van Buren County until this information and direction is provided by the State of Michigan. The Chief of Staff (Director of Emergency Management) is responsible for initiating the manning staffing of the EOC. By prior agreement between counties, communications between the Plant and Berrien County will normally be directed through Van Buren County.

5.6.6 Allegan County Office of Emergency Preparedness The Allegan County Office of Emergency Management is located at the Allegan County Office Complex, Allegan, Michigan. In the event of an emergency, Allegan County Sheriff's Department will disseminate information and recommendations initially supplied by Entergy Corporation to the Chairperson of the Allegan County Board of Commissioners, Allegan County Emergency Management Director, and the Emergency Operations Center (EOC), if activated. By prior agreement between the counties, communications between the Plant and Allegan County will normally be directed through Van Buren County. Palisades Site Post-Shutdown Emergency Plan, Section 7.0, "Emergency Facilities and Equipment," summarizes communications.

The Chairperson of the Allegan County Board of Commissioners is responsible for the activation of the County's Emergency Operations Plan. The Allegan County Emergency Management Director is responsible for overall coordination and planning of emergency response activities within the county. The Emergency Management Director will implement activation of the EOC and alert key officials and agencies.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 47 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN 5.7 COORDINATION WITH GOVERNMENTAL AGENCIES The coordination between the state, county, and federal emergency plans and the Palisades Site Post-Shutdown Emergency Plan serves to ensure the safety and health of the public. The coordination of the emergency plans enables all organizations to participate without confusion or hesitation in regard to their responsibilities. All participating agencies should have a clear picture of the roles they play during an emergency situation. As a part of the coordination effort, each participating agency is assigned specific responsibilities and authority in regard to both emergency planning and emergency response. Written agreements with governmental agencies are included in Appendix A, "Agreement With Offsite Individuals, Agencies, and Organizations."

5.7.1 State of Michigan Agencies State agencies are under the direction of the Governor of the State of Michigan.

a. Michigan State Police Emergency Management and Homeland Security Division (MSP/EMHSD)

The State Police Emergency Management and Homeland Security Division is the leading state agency for emergency response planning and operations.

This agency is under the direction of the State Director of Emergency Management. Responsibilities of this group include:

1. Development and maintenance of the Michigan Emergency Management Plan and assistance to the counties in developing their individual emergency operations plans.

2. Recommendations to the Governor of the State of Michigan regarding emergency measures.

3. Arranging training programs for state and local agencies designed to promote effective response to radiological incidents.

4. Providing communications, radiological monitoring, and other available support to affected local governments.

5. Coordinating the support of other state agencies or political subdivisions near the affected area and obtaining the assistance of federal agencies as required.

The normal point of contact for the Palisades Plant is through the Operations Division of the Michigan State Police in Lansing.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 48 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN The Palisades Plant will support the State Police by providing specific information pertaining to the nature of the incident, recommendations on protective actions, and other available information and technical guidance.

b. Michigan State Police - Paw Paw Post Michigan State Police (MSP) is responsible for providing emergency traffic control and other available assistance. The MSPs nearest post is located in Paw Paw, Michigan with direct radio communications to Van Buren, Allegan, and Berrien Counties. Communications are detailed in Palisades Site Post-Shutdown Emergency Plan, Section 7.0, "Emergency Facilities and Equipment."

c. Michigan Department of Transportation Michigan Department of Transportation (MDOT) assists in emergency traffic regulation coordination with the Michigan State Police, the Sheriff, and the County Road Commission of the affected county.

d. Michigan Department of Environmental Quality (DEQ)

The Michigan Department of Environmental Quality, Radiological Protection Section located in Lansing is responsible for administering and directing radiation control programs and activities within the state. Their Radcon Field Team provides direct radiological emergency response capability during emergency conditions. The team's responsibilities include:

1. Moving immediately to the affected area and performing radiological monitoring, as appropriate.

2. Determining and reporting the nature and scope of the hazard.

3. Providing state government with technical guidance, recommending appropriate emergency countermeasures and recovery actions, and otherwise assisting the affected community.

The Department of Environmental Quality, Radiological Protection Section is responsible for providing the public with health hazard evaluation, guidance, or protective actions and other pertinent information concerning radiological incidents.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 49 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN

e. Michigan Department of Health and Human Service The Michigan Department of Health and Human Services is responsible for coordinating emergency medical support of radiological incidents, as requested by DEQ, Radiological Protection Section, or local health authorities.

f. Michigan Department of Agriculture and Rural Development The Michigan Department of Agriculture and Rural Development acts on advice from the State Health Director for controlling agricultural products and production for the purpose of radiation health hazard abatement. Protective actions initiated by the Department of Agriculture and Rural Development may include any or all of the protective actions recommended by the Environmental Protection Agency.

5.7.2 Federal Agencies

a. Nuclear Regulatory Commission (NRC)

Nuclear Regulatory Commission for the State of Michigan may request the Federal Department of Energy dispatch Federal Radiological Monitoring and Assessment Center (FRMAC) personnel to the scene in the event of an emergency who could perform radiological monitoring and dose assessment.

The Emergency Director has the authority to request NRC assistance.

The office may also furnish advice and assistance to the Plant as deemed necessary. The NRC shall be notified within an hour, anytime all or part of the Site Post-Shutdown Emergency Plan is activated. Means of communications are described in the Site Post-Shutdown Emergency Plan, Section 7.0, "Emergency Facilities and Equipment."

Facilities for the NRC are available in the Technical Support Center and the Emergency Operations Facility, including work space and telephones.

The Emergency Operations Facility provides space for trailers for long term support capabilities.

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b. US Department of Energy (DOE)

The Department of Energy will assist during radiological emergencies by furnishing advice, consultation, and assistance regarding the protection of personnel, treatment of injured and/or exposed persons, minimization of further exposure and contamination, and the determination of existence and extent of contamination. The DOE will respond to the FRMAC in support of the state and local monitoring operations, but may receive requests for assistance directly from the Plant as authorized by the Emergency Director.

Contact with the DOE may be established using telephone lines. The Emergency Operations Facility provides space for trailers in support of DOE activities.

c. Federal Emergency Management Agency (FEMA)

The Federal Emergency Management Agency will assist the utility in real events with consultation and expertise in controlling an actual emergency.

FEMA also evaluates Local and State Emergency Plans to ensure adequacy.

d. Federal Radiological Monitoring and Assessment Center The Federal Radiological Monitoring and Assessment Center is a joint facility for all federal agencies involved in evaluating and mitigating radiological events. The NRC is the Lead Federal Agency (LFA) for the FRMAC and will coordinate the efforts of all federal agencies involved. The FRMAC will supply information and support to state and local governments concerning radiological conditions.

5.8 INSTITUTE OF NUCLEAR POWER OPERATIONS (INPO)

The Institute of Nuclear Power Operations will provide emergency response as requested by Entergy Corporation. INPO can provide assistance locating sources of emergency manpower and equipment, analyzing operational aspects of the event, and organizing industrial experts who could advise Entergy Corporation on technical matters. INPO will be contacted by means of its 24-hour telephone number in the event of a radiological emergency. The EOF Emergency Director shall be responsible for requesting assistance from INPO.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 51 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN FIGURE 5-1 EMERGENCY RESPONSE INTERFACES

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 52 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN FIGURE 5-2 POST-SHUTDOWN PLANT STAFFING AND AUGMENTATION REQUIREMENTS STAFF AUGMENTATION MAJOR FUNCTIONAL POSITION TITLE ON CAPABILITY AND MAJOR TASKS RESPONSE TIME AREA OR EXPERTISE SHIFT 60 Min 90 Min Plant Operations and Shift Engineer/Shift 1 -- --

Assessment of Technical Advisor (SRO) -- -- --

Operational Shift Manager (SRO) 1 -- --

Aspects Control Room Supervisor 1 -- --

(SRO)

Nuclear Control Operators 2 -- --

Nuclear Plant Operators**Non- 62 -- --

Certified Operators Emergency Director Shift Manager 1* -- --

Notification/ Notify licensee, state, 1* 32 --

Communication local, and federal personnel and maintain communication Radiological Accident Emergency Operations Senior Manager -- 1 --

Assessment and Support Facility (EOF) Director of Operational Accident Offsite Dose Senior Radiation Protection Assessment Assessment (RP) Expertise 1* 1 --

Chemistry/Radiochemistry Chem RP Technicians 1* 1-- --

Radiation Protection Radiation Protection Tasks: RP Technicians 21 3 2 3--

a. Offsite Surveys

b. Onsite (Out-of-Plant) Surveys

c. In-Plant Surveys

d. Access Control

e. RP Coverage

f. Personnel Monitoring NOTES:

• May be provided by shift personnel assigned other functions.

• • Each of up to 2 of the 6 on-shift NPO positions may be filled by a fire brigade qualified person who is also minor maintenance qualified; or alternately by 2 persons per required NPO, one fire brigade qualified and the other minor maintenance qualified.

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g. Dosimetry

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 54 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN FIGURE 5-2 POST-SHUTDOWN PLANT STAFFING AND AUGMENTATION REQUIREMENTS STAFF AUGMENTATION MAJOR FUNCTIONAL POSITION TITLE ON CAPABILITY AND MAJOR TASKS RESPONSE TIME AREA OR EXPERTISE SHIFT 60 Min 90 Min Plant System Technical Support Core/Thermal Hydraulics 1* 1 --

Engineering, Repair, Electrical/ -- 1 --

and Corrective Actions Mechanical -- 1 --

Repair and Corrective Mechanical Maintenance 1* 1 --

Actions Radwaste Operator -- 1 --

Electrical Maintenance 1* 21 --

Instrument and Control (I&C) Technician -- 1 --

NOTES:

• May be provided by shift personnel assigned other functions.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 55 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN FIGURE 5-2 POST-SHUTDOWN PLANT STAFFING AND AUGMENTATION REQUIREMENTS STAFF AUGMENTATION MAJOR FUNCTIONAL POSITION TITLE ON CAPABILITY AND MAJOR TASKS RESPONSE TIME AREA OR EXPERTISE SHIFT 60 Min 90 Min Field Monitoring Teams Onsite FMT - Radiation monitor to RP Technician -- 1 --

(FMTs) assess environmental radiation/contamination and provide input to Senior Radiation Protection Expertise. Also provide RP coverage for FMT.

Offsite FMT - Perform RP Technicians -- 1 1 environmental radiation/contamination assessments and radioactive plume tracking. Communicate and coordinate with applicable ERO supervision. Responsible for the radiation protection of the FMT.

Transportation Drivers -- 1 1 Fire Fighting -- -- Fire Brigade Local Support per Technical Specifications

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 56 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN FIGURE 5-2 PLANT STAFFING AND AUGMENTATION REQUIREMENTS STAFF AUGMENTATION POSITION TITLE ON CAPABILITY AND MAJOR FUNCTIONAL AREA MAJOR TASKS OR EXPERTISE SHIFT RESPONSE TIME 60 Min 90 Min Rescue Operations -- -- 2* Local Support and First-Aid Site Access Control Security, fire fighting Security Personnel All per and Personnel communications, personnel Security accountability Plan TOTAL 154 2012 52 NOTES: 1. Staff augmentation personnel are required to respond as quickly as possible, within the required response time.

2. The Shift Manager may call out additional designated ERO members, or the full ERO complement, at any time in an emergency event regardless of classification.

3. Even when they are not on duty, staff augmentation personnel are to respond to an emergency call out when they are fit for duty and otherwise available for timely response.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 57 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN 6.0 EMERGENCY MEASURES

a. This section identifies the measure to be used for each type of emergency previously classified in Section 4. The logic presented in this section is used as the basis for the detailed Palisades Nuclear Plant Emergency Implementing Procedures which define the emergency actions to be taken for each emergency classification. Emergency measures begin with the following:

1. Recognition, classification, and declaration of an emergency condition.

2. Notification of the applicable agencies and personnel (Figure 6-1).

3. Mobilization of the appropriate portions of the emergency organization.

b. Emergency measures are additionally organized into the following categories:

1. Assessment actions

2. Corrective actions

3. Protective actions These measures are described in the following sections for each emergency classification.

6.1 ACTIVATION OF THE EMERGENCY ORGANIZATION If it appears that an incident or condition may meet or exceed a predetermined value or condition specified as an Emergency Action Level in Emergency Implementing Procedure EI-1, "Emergency Classification and Actions," and PSEP Supplement 1 "SITE POST-SHUTDOWN EMERGENCY PLAN Supplement 1 - EAL Wall Charts" then certain portions of this plan and specific procedures shall require implementation.

The Shift Manager will initially classify the emergency and ensure required notifications are made. The Shift Manager shall ensure that an overall assessment of the emergency is performed in order to determine the most appropriate classification and, based on this determination, activate portions of the emergency organization as necessary. The Shift Engineer/Shift Technical Advisor may assist the Shift Manager in performing these functions. The methodology used in activating the emergency organizations during each class of emergency is provided in the following sections:

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 58 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN 6.1.1 Control Room Personnel

a. Should emergency conditions, either real or potential, arise, it is expected that the Nuclear Control Operators and the Shift Manager will initially be made aware of the situation by alarms, instrument readings, reports, etc. The Shift Manager shall ensure that the General Manager, Plant Operations or Duty Station Manager on backshift and weekends is immediately informed of any possible emergency situation.

b. The Shift Manager is responsible for ensuring the performance of the initial assessment of the emergency (e.g., Plant and reactor spent fuel pool status, radiological conditions, etc.) in the following manner:

1. Determine the immediate actions necessary to be taken to ensure the safe and proper operation of the Plant. The Shift Engineer will advise and assist the Shift Manager on matters pertaining to the safe and proper operation of the station with regard to nuclear safety.

2. If the situation requires activation of all or part of the Site Emergency Plan, the Shift Manager shall:

(a) Initiate the applicable Emergency Implementing Procedures.

(b) Initially classify the emergency.

(c) Ensure the appropriate alarm is sounded.

(d) Announce the location, type and classification of the emergency on the Plant public address system.

(e) Notify the following personnel and agencies of the emergency condition(s): (Reference Emergency Implementing Procedure EI-3, "Communications and Notifications.").

Message authentication may be used as deemed necessary.

(1) Van Buren County (2) State of Michigan (3) NRC (4) The General Manager, Plant Operations or designated alternate (Duty Station Manager)

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 59 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN While both pages of the notification form are not necessary for every notification, NOTE:

the two pages together include the elements listed in the following sections.

(f) Initial notification should consist of the following as appropriate:

(1) Name and telephone number (if needed).

(2) Location of incident.

(3) Date and time of incident.

(4) Emergency classification (Emergency Implementing Procedure EI-1, "Emergency Classification and Actions").

(5) Whether a release is taking/has taken place.

(6) The affected/potentially affected population.

(7) Recommended protective actions.

(g) Follow-up notification should consist of the following as appropriate:

(1) Name and telephone number (if needed).

(2) Location of incident.

(3) Date and time of incident.

(4) Emergency classification (EI-1).

(5) Type of actual or projected release (liquid or gaseous) and estimated duration/impact times.

(6) Estimate of amount or radioactive material released, points of release, and height of release (Emergency Implementing Procedure EI-6, "Offsite Dose Calculation and Recommendations for Protective Actions").

(7) Chemical and physical form of released material. Include estimates of the relative quantities and concentration of noble gas, iodine, and particulates (EI-6).

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 60 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN (8) Prevailing meteorological conditions (EI-6).

(9) Actual or projected dose rates of at the site boundary and the integrated dose rate at the site boundary (Emergency Implementing Procedures EI-6 and EI-9, "Offsite Radiological Monitoring").

(10) Projected dose rates and integrated dose rates at the projected peak and at 2, 5, and 10 miles from the site and the sectors affected.

(11) Estimate of surface contamination in Plant, onsite and offsite.

(12) Entergy Corporation emergency response actions underway.

(13) Recommended emergency actions, including protective measures.

(14) Requests for support from organizations.

(15) Prognosis for worsening or termination of event.

3. Due to the additional responsibilities assigned to the Shift Manager at the beginning of an emergency, the following actions are to be performed in the priority listed below:

(a) Ensure the safe operation of the Plant.

(b) Ensure that immediate notification requirements are met.

(c) Dispatch, in the event of radiological emergencies, Radiation Monitoring Teams, to designated analysis locations onsite and offsite.

(d) Perform additional emergency actions as time and conditions permit including accident assessment beyond that required for emergency classification.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 61 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN 6.1.2 Emergency Plant Manager The Shift Manager will continue to perform the Command and Control actions of the Site Post-Shutdown Emergency Plan until relieved by the EOF Director. The Emergency Plant Manager reports to the EOF Emergency Director. When the EOF Director has taken Command and Control of the event and the TSC is Operational the Shift Manager and Control Room will report to the EPM. The EPM has the responsibility for command of all accident mitigation actions at the site and performs these duties from the Technical Support Center (TSC). Responsibilities include:

a. Assume command of the TSC and OSC and the onsite mitigation efforts

b. Provide information and recommendations to the ED regarding the classification of an emergency

c. Ensure timely ENS notifications

d. Perform accident assessment to prioritize mitigation actions.

e. Coordinate the activities of the CR, TSC and OSC

f. Direct personnel evacuation, assembly and accountability of non-essential personnel

g. Provide information and recommendations to the ED regarding plant activities

h. Advise the ED on core damage and plant conditions for classification and PAR determination

i. Direct the organization and coordination of repair corrective action teams

j. Direct onsite protective actions

k. Authorize emergency radiation exposure and issuance of KI to recommended personnel in the CR, TSC or OSC or to Security personnel

l. Make operational decisions involving the safety of the plant and its personnel and make recommendations to the Control Room Personnel

m. Initiate immediate corrective actions to limit or contain the emergency invoking the provisions of 10 CFR 50.54(x) if appropriate1

n. Implement severe accident management procedure strategies

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o. Direct relocation to an alternate location

p. Integrate offsite responders with on-site response efforts when required

q. Perform emergency termination

r. Maintain Plant security 6.1.3 Emergency Director The Emergency Director provides overall command and control of the emergency response. Responsibilities include:

a. Receive turnover from the SM/ED and assume command/control of EOF and activities outside the area controlled by the TSC

b. Direct the activation, operation and deactivation of the EOF

c. Determine to what extent the offsite and onsite emergency organization shall be activated

d. Upgrade the emergency classification level (cannot delegate)

e. Make Protective Action Recommendations (PAR) to offsite agencies (cannot delegate)

f. Direct and approve offsite notification to State and local agencies (cannot delegate)

g. Communicate within and between the emergency response facilities.

h. Ensure event information is communicated to other organizations (NRC, Entergy Corp, etc) to keep them informed of the emergency situation

i. Direct the activities of the EOF organization in support of the TSC and offsite response agencies (Counties, and the State of Michigan)

j. Direct protective actions for offsite monitoring teams, EOF ERO and offsite resources

k. Request assistance from offsite agencies, excluding requests for offsite medical/fire, security assistance (Coordinate request for Federal assistance through the State)

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l. Authorize issuance of KI and radiation exposure in excess of 10CFR 20 limits for ERO members outside of the protected area

m. Conduct turnover of command and control to relief ED

n. Dispatch Palisades Plant liaisons to principal offsite emergency operations centers

o. Maintain adherence to the fitness for duty policy 6.1.4 Emergency Management and Homeland Security Division - Michigan State Police In emergency situations, the Emergency Management and Homeland Security Division is responsible for coordinating the support of other state agencies and political subdivisions and obtaining the assistance of federal agencies as required.

The Emergency Management Division will provide the following emergency support:

a. Activation of the State Emergency Operations Center, as necessary

b. Communications, radiological monitoring, and other available support to the affected local government

c. Liaison with local, state, and federal agencies 6.1.5 Michigan Department of Environmental Quality, Radiological Protection Section The Michigan Department of Environmental Quality, Radiological Protection Section is responsible for administering and directing radiation control programs and activities within the State of Michigan.

The Radiological Protection Section has the direct responsibility to provide the technical assistance necessary to evaluate the offsite consequences of a radiological incident, to provide protective action guidance to state and local authorities responsible for public safety, and to oversee offsite decontamination and reentry operations.

The Michigan Department of Community Health is responsible for coordinating emergency medical support as requested by the Michigan Department of Environmental Quality, Radiological Protection Section, or local health authorities.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 64 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN 6.1.6 Affected Counties: Van Buren County, Berrien County, and Allegan County Emergency responsibilities of County Emergency Management include communication support to the responding county departments, providing warning and notification to the public, and assuring the continuation of vital services during the emergency.

6.2 ASSESSMENT ACTIONS Effective coordination and direction of all portions of the emergency organization require almost continuous accident assessment during the course of the emergency.

Each emergency class will require similar accident assessment methods; however, each classification imposes a different magnitude of assessment effort. In the following steps, the assessment actions to be taken for each emergency classification are outlined.

6.2.1 Assessment Actions for Unusual Events The detection of an Unusual Event shall arise from exceeding a specific Emergency Action Level for this class. Detection of the event will come as a result of alarms, instrument readings, recognition through experience, or any combination thereof.

The continuing assessment actions to be performed for this classification of emergency shall be in accordance with the Emergency Implementing Procedures and shall consist of the normal monitoring of Control Room and other Plant instrumentation and status indication until the situation is resolved. If a fire is the reason for the declaration of an Unusual Event, the Shift Manager will make continuing assessments based on his knowledge and experience on whether offsite firefighting assistance is needed.

6.2.2 Assessment Actions for Alerts When an accident has been classified as an Alert by the Shift Manager, assessment actions shall be performed in accordance with the Emergency Implementing Procedures for an Alert.

These actions include:

a. Accountability of onsite personnel.

b. Staff augmentation, as needed.

c. Increased surveillance of in-plant instrumentation.

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d. Activation of appropriate emergency facilities.

e. Dispatch of shift personnel, if possible, to the identified problem area for confirmation and visual assessment.

f. Dispatch of onsite Radiation Monitoring Teams to monitor for possible release and to provide confirmation of correct accident classification.

g. If a radiological accident is occurring, surveillance of the in-plant instrumentation is necessary to obtain meteorological and radiological data required for calculating or estimating projected doses. This dose assessment activity shall continue until termination of the emergency in order that the updating of initial assessments may be provided to all concerned offsite agencies, the Shift Manager, and EOF Emergency Director. Emergency Implementing Procedures are provided to aid in a rapid, consistent projection of doses.

6.2.3 Assessment Actions for Site Area Emergencies The assessment actions for the Site Area Emergency classification are similar to the actions for an Alert; however, due to the increased magnitude of the possible release of radioactive material, a significantly larger assessment will occur. The necessary personnel for this assessment effort shall be provided by mobilization of the onsite and offsite emergency organizations.

Specifically:

a. An increased amount of Plant instrumentation shall be monitored, in particular, indications of core status (eg, in-core thermocouple readings, etc) shall be monitored.

b. Radiological monitoring efforts shall be increased. Onsite and offsite radiological monitoring teams will be dispatched. In addition to beta-gamma field measurements, change out of environmental thermoluminescent dosimeters (TLD), air sampling, and collection of the environmental media for assessment of radioactive material transport and deposition may also be performed.

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c. Dose assessment activities will be conducted more frequently with an increased emphasis on dose projections for use as a factor in determining the necessity for protective actions for the public. Radiological (eg, TLDs) and meteorological instrumentation readings shall be used to project the dose rate at predetermined distances from the Plant, and to determine the integrated dose received. In reporting the dose projections to offsite agencies, the dose rate, dose, and the basis for the time used for the dose estimate shall always be provided. Any confirmation of dose rates by offsite Radiation Monitoring Teams shall be reflected in reporting and/or revising the dose estimate information provided to offsite agencies.

Dose projections shall be considered with respect to the Environmental Protection Agency Protective Action Guides (Table 6-1). Reporting of assessments to offsite authorities shall include the relationship of the dose to these guidelines. Emergency Implementing Procedures will be provided for recording all pertinent information.

6.2.4 Assessment Actions for General Emergencies Assessment actions for the General Emergency classification shall be the same as for the Site Area Emergency with some possible shift of emphasis to greater offsite radiation monitoring and dose projections extending to distances farther from the site.

6.2.5 Estimation of Offsite Dose The Emergency Implementing Procedures (reference Emergency Implementing Procedure EI-6, "Offsite Dose Calculation and Recommendations for Protective Actions") contain several methods for calculating offsite dose to population from accidental releases. These methods include:

a. Computer Method - Implements the above method using a personal computer to speed the process.

b. Manual Method - A pencil and paper method for calculating offsite dose using precalculated diffusion factors and a straight line Gaussian methodology.

c. Segmented Gaussian - Variable trajectory Plume model.

The above methods have been developed in cooperation with state agencies and provide methods for rapid, accurate dose estimates.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 67 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN 6.2.6 Data Reporting, Recording, and Analysis Specially assigned personnel at all designated emergency centers have the responsibility for collecting, recording, and analyzing data transmitted to them.

Preplanned emergency logs and procedures are provided to ensure that all necessary information is received and recorded. Included will be:

a. Data from emergency survey teams as available. This will be recorded to define the affected environs.

b. Evacuated Plant personnel will be questioned to gather all possible information on observed conditions.

c. In addition to incoming data, a log of events occurring at the emergency centers (TSC, OSC, EOF) and Control Room will be kept. Individual sections of this log will record such items as personnel exposure, contamination levels, communications, and check-off lists.

6.2.7 Interviewing Evacuees or Other Witnesses Information from personnel evacuating the site may be collected at the evacuation control point as directed by the Emergency Plant Manager. This information shall be reported to the TSC when possible.

6.2.8 Assessment Results Communications The EOF Emergency Director is notified of assessment results from the site and from offsite support agencies. The EOF Emergency Director, in turn, is responsible for communication back to those groups so that emergency measures may be modified as necessary.

6.3 CORRECTIVE ACTIONS Detailed operating procedures are available to the operators for use during emergencies as well as during normal operations. Specific emergency procedures are provided to assist the operators in placing the Plant in a safe condition and taking the necessary supplemental corrective actions. In addition, operations personnel are trained in the operation of the Plant systems and their associated procedures and are, therefore, capable of taking appropriate corrective actions based on their training, knowledge, and experience.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 68 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN Corrective actions shall be planned events that are taken to lessen or terminate the emergency situation. Planned radioactive releases or corrective actions that may result in a radioactive release shall be evaluated by the EOF Emergency Director, and his staff, as far in advance of the event as is possible. Such events and data pertaining to the release shall be reported to the appropriate offsite emergency response organization and/or agencies.

6.3.1 Fire Control Provisions for firefighting and control are described in the Fire Protection Implementing Procedures. The Covert Township Fire Department and the South Haven Fire Department provide Offsite backup firefighting support.

In-plant firefighting equipment ranges from portable extinguishers to automatic sprinkler control. The Plant emergency organization includes a trained fire brigade for immediate response to any fire situation.

The Van Buren Dispatch, via 911, is first to be called. They are required to dispatch both Covert and South Haven Fire Departments. These departments consist of personnel trained for firefighting, including situations involving radioactive contamination. Additional support is available from fire departments in nearby Allegan and Berrien Counties through mutual aid agreements. These fire departments are also trained and equipped for rescue work and control of hazardous gas leaks, including chlorine gas.

6.3.2 Repair and Damage Control The Palisades Plant staff is comprised of technically and vocationally trained personnel capable of improvising necessary repair and control measures for correction of an emergency situation. Wherever possible, corrective measures are anticipated and included in emergency and operating procedures.

6.3.3 System Control System design is aimed at automatic corrective actions, such as Plant shutdown and system isolation, whenever operating parameters become abnormal. Operating procedures are written for manual control of these same situations, should automatic features fail.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 69 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN 6.4 PROTECTIVE ACTIONS Protective actions are emergency measures taken during or after an emergency situation that are intended to minimize or eliminate the hazard to the health and safety of the general public and/or Plant personnel. Such actions taken onsite are the responsibility of the Entergy Corporation, while those offsite actions are the responsibility of the State of Michigan and local political jurisdictions. Protective Action Guides for the Environmental Protection Agency and the State of Michigan are shown on Tables 6-1 and 6-2. All visitors to the site protected area shall be either escorted by an employee knowledgeable as to the Emergency Plan response actions or shall receive training on actions required by them during an emergency.

6.4.1 Sheltering, Evacuation, Personnel Accountability During an emergency, the relocation of personnel may be required in order to prevent or minimize exposure to radiation and radioactive materials. The following steps present information on policies applicable to such situations:

a. Plant Site

1. Notification All persons onsite at the time of an Alert, Site Area, or General Emergency shall be notified of the emergency by a two-minute steady siren and an announcement over the public address system in the assembly areas. Notification of an Unusual Event should be over the Plant public address system. For the Alert and above, personnel shall be instructed to report to assembly areas for accountability, monitoring, and possible evacuation. Personnel accountability shall be completed in approximately 30 minutes. Specific assembly areas are designated in the Emergency Implementing Procedures. All personnel shall be trained in the locations of the assembly areas, or be escorted by an employee who is so trained. At the assembly area, members of the emergency organization shall direct efforts per the applicable Emergency Implementing Procedure. These procedures shall provide contingency plans for weather, traffic, and radiological impediments to evacuation.

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2. Site Access Control Provisions for control of access to the Palisades site have been included in the Safeguards Contingency Procedures to take care of personnel entering for business purposes and for those who might inadvertently enter. Access to the exclusion areas of the Plant is controlled by the Plant security force. Offsite support is provided by local and/or state law enforcement personnel.

3. Monitoring of Evacuees A combination of checking electronic dosimeters and questioning of evacuees will be used to initially determine if there were any high external exposures involved in the emergency. For any known or suspected high exposures, the permanent dosimeters will be read as soon as possible and further investigation will be conducted to determine the amount of exposure or necessary actions to be taken.

Monitoring for contamination and internal ingestion at the assembly areas will be accomplished by using portable instrumentation and questioning. Priority for decontamination will be given persons found with the highest levels of contamination. Any persons suspected or known to have ingested radioactivity will be whole-body counted, as soon as conditions permit, to assess their internal exposure.

Decontamination supplies for evacuees shall be available.

4. Egress Routes Three potential routes are available: Plant access road to the east and the beach to the north or south. Unless conditions dictate otherwise, the Plant access road to the east will be the primary evacuation route.

An evacuation procedure shall require a personnel accountability check at the appropriate control point/monitoring station. Security officers shall be dispatched by the Emergency Plant Manager to stop ingress from the access roads and to assist Plant personnel evacuating the site. A control point/monitoring station shall be established along the egress route in an area expected to be outside the path of possible radioactive releases.

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b. Offsite Areas

1. Agency Responsibilities The Palisades Nuclear Plant is located in Van Buren County (Covert Township), and the 10-mile emergency planning zone includes portions of Allegan and Berrien counties, including the city of South Haven. In a radiological emergency, operational control will be from the State Emergency Operations Center (SEOC) in Lansing, with local operation control from the county EOCs. Each county has an Emergency Preparedness Plan which is a legal document in compliance with Act 390 of the Michigan Public Acts of 1976.

The Michigan Department of Environmental Quality is responsible for directing radiation control programs and emergency responses within the state as stated in Act 368, Michigan Public Acts of 1978 and the Michigan Emergency Management Plan (MEMP), and the Governor's Executive Order 1996-1.

The Deputy State Director of Emergency Management of the Michigan State Police provides overall coordination of emergency operations, including the use of all state government resources upon proclamation of a State of Disaster, or State of Emergency by the Governor. The Michigan State Police will coordinate the disaster response activities of all departments of State Government.

2. Notification and Response The local government will provide notification of the general public involved and define and identify this population. The state government will give detailed directions for protection of this population, including provisions for evacuation of personnel from affected sectors of the environs if necessary.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 72 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN

3. Protective Actions Protective action procedures are covered in the Michigan Emergency Preparedness Plan and the Van Buren, Allegan, and Berrien County Emergency Plans. In summary, these plans contain the following:

(a) A public warning system composed of two components, alert and notification.

(1) The alert component is comprised of a siren system which provides coverage for a 10 mile radius around the plant, and allows the resident and transient populations to be warned within 15 minutes of the issuance of a protective action.

(2) The notification component consists of several local radio stations that broadcast appropriate initial and follow-up messages on protective actions to be taken.

(3) If a backup means of notification is necessary, other television/radio communications, vehicles with mobile public address systems (Route Alerting) and other means as necessary can be utilized.

(b) Predesignated areas are based on continuous mile circles from the Palisades Plant. These areas will be used by the responsible authorities in ordering protective actions.

(c) A communication system has been established for emergency notification of offsite agencies having protective response assignments.

(d) Emergency response and evacuation plans for offsite areas have been formulated by state and local agencies. Evacuation clear times for areas near Palisades are shown in Appendix C.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 73 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN 6.4.2 Contamination Control Measures This section describes the provisions for preventing or minimizing direct or subsequent ingestion exposure to radioactive materials deposited on the ground or other contaminable surfaces.

a. Plant Area Access to the owner-controlled area shall be controlled. In addition, within the owner-controlled area, there are no areas for producing agricultural products. In-plant contamination control shall be exercised in accordance with approved radiation protection procedures.

b. Offsite Areas Criteria for preventing or minimizing ingestion of, or exposure to, contaminated materials or areas is contained in the Michigan Emergency Management Plan.

Included are:

1. Isolation or quarantine and area access control.

2. Control of the distribution of affected commercial agricultural crops.

3. Control of public water supplies.

4. Means for providing advisory information regarding the use of affected home food and water supplies.

5. Criteria for permitting return to normal use.

Action levels and responsibilities for execution of these measures are included. Contaminated areas will be barricaded and posted to control access until time allows for decontamination activities. Michigan Department of Environmental Quality representatives will be responsible for these actions and will be assisted by other Michigan State Departments and/or Entergy Corporation upon request.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 74 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN 6.5 AID TO AFFECTED PERSONNEL 6.5.1 Emergency Personnel Exposure Criteria Although an emergency situation transcends the normal requirements for limiting exposure, there are suggested levels of exposure acceptable in emergencies. Even under these conditions, every reasonable effort to minimize exposure must be made and personnel must be provided with appropriate monitoring devices. Three categories of risk versus benefit must be considered:

a. Saving of human life and reduction of injury.

b. Protection of health and safety of the public.

c. Protection of property.

In order to avoid restricting actions that may be necessary to save lives, it shall be left to the judgment of the individual to determine the amount of exposure that he will accept to perform an emergency action that will result in the saving of human life.

Emergency team members are instructed in radiation effects and the risks involved for emergency doses. Basic guidelines provided to emergency team members are the EPA recommendations contained in Table 6-3. These exposures must be authorized by the Emergency Plant Manager based on the recommendation of the TSC Rad Coordinator.

The Radiation Protection Procedures shall be followed. In the event emergency exposure limits are approved, the same administrative methods for dose control shall be used with the higher emergency exposure limits.

Once the emergency condition has been mitigated, steps shall be taken to recover from the incident. All actions from this point shall be preplanned in order to limit exposures. Normal exposure limits will be used, areas will be controlled, and exposure of personnel documented.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 75 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN 6.5.2 Decontamination and First Aid Onsite personnel decontamination facilities for emergency conditions are fully equipped with decontamination material. The decontamination facility at Palisades Plant is located at the access control area of the auxiliary building.

The decontamination facility consists of a shower, sink, and first-aid kits.

Decontamination supplies such as various decontamination solutions and surgical brushes will be stored in the decontamination facility. Emergency equipment located around the site is available and includes personnel monitoring equipment. There are also additional personnel monitoring equipment located at the access control area including dosimeters, and high and low-range survey instruments. A comprehensive list of materials and equipment available for use can be found in Appendix E.

In an emergency situation, decontamination is the responsibility of the Radiation Monitoring Team. When decontamination of an area or equipment is required, personnel from Operations, Maintenance, and Radiation Protection will work jointly.

Medical first-aid training is provided to designated members of the Plant emergency organization that, as a minimum, includes the Red Cross Multimedia course or equivalent, combined with the American Heart Association Cardiopulmonary Resuscitation course. This training for members of the Plant staff also includes methods of handling contaminated patients and/or injuries. At least one person on each operating shift is required to have this first-aid training.

The Covert Township Fire Department ambulance personnel and the South Haven Area Emergency Services ambulance staff are trained in caring for radiologically contaminated victims.

6.5.3 Medical Treatment In the event of a serious accident at Palisades Plant requiring medical treatment, agreements have been made with the area hospitals. These hospitals are:

a. South Haven Community Hospital, South Haven, Michigan.

b. Lakeland Regional Medical Center, St Joseph, Michigan.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 76 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN TABLE 6-1 ENVIRONMENTAL PROTECTION AGENCY - PROTECTIVE ACTION GUIDES PAG Protective Action Projected Dose Whichever is more limiting Intervention Level

• 0.5 rem (CEDE)

Whole body or any set of organs OR 5 rem (CDE) any single organ Specific PAs are not provided due to the wide variety of actions that could be NOTE:

taken.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 77 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN TABLE 6-2 PROTECTIVE ACTION GUIDES (PAGs) & OBJECTIVES Early Plume PAGs (Source - EPA 400-R-92-001)

PAG Protective Action Comments Projected Dose Evacuation 1-5 rem TEDE Evacuating (or for some (or sheltering) 5-25 rem thyroid situations, sheltering) 50-500 rem skin should normally be initiated at the lower limits.

Administration of stable 25 rem thyroid Requires approval of State iodine Medical Officials Relocation PAGs (Source - EPA 400-R-92-001)

PAG Protective Action Comments Projected 1st Year Dose Relocate the general 2 rem TEDE population > 100 rem beta skin dose Apply simple dose < 2 rem TEDE These protective actions reduction techniques should be taken to reduce doses to as low as practicable levels Long Term Objectives (Source - EPA 400-R-92-001)

Long Term Objectives Period Objective Any single year 0.5 rem TEDE (2 through 50) 50 Years 5 rem TEDE

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 78 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN TABLE 6-3 GUIDANCE ON DOSE LIMITS FOR WORKERS PERFORMING EMERGENCY SERVICES Dose Limita Activity Condition (rem) 5 all 10 protecting valuable lower dose not practicable property 25 lifesaving or protection of lower dose not practicable large populations

>25 lifesaving or protection of only on a voluntary basis large populations to persons fully aware of the risks involved a

Sum of external effective dose equivalent and committed effective dose equivalent to nonpregnant adults from exposure and intake during an emergency situation. Workers performing services during emergencies should limit dose to the lens of the eye to three times the listed value and doses to any other organ (including skin and body extremities) to ten times the listed value. These limits apply to all doses from an incident, except those received in unrestricted areas by members of the public during the intermediate phase of the incident.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 79 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN FIGURE 6-1 PALISADES PLANT NORMAL NOTIFICATION CHAIN Control Room or Emergency Operations Facility Communicator If Needed Notifications Required Notifications Covert Fire Department Van Buren County Sheriff*

Michigan State Police Ambulance Services Emergency Management Division NRC Hospitals (Note: Communicator located in TSC)

Van Buren State Park Duty Station Manager Superintendent Palisades Park Superintendent Federal Aviation Administration Department of Energy US Coast Guard South Haven Water Department Berrien County Sheriff Allegan County Sheriff Entergy Public Affairs

• Not a required notification if the State Emergency Operations Center is activated.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 80 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN 7.0 EMERGENCY FACILITIES AND EQUIPMENT This section describes the equipment and facilities that are utilized to:

a. Assess the extent of accident hazards.

b. Mobilize the resources required to mitigate the consequences of an accident.

c. Provide protection to Plant personnel.

d. Support accident mitigation operations.

e. Provide immediate care for injured/contaminated personnel.

f. Effect damage control.

7.1 ONSITE EMERGENCY FACILITIES Onsite emergency support centers include the Control Room and two other areas at Palisades. These areas are designated as the Technical Support Center and the Operations Support Center as described below.

7.1.1 Control Room The principal emergency control center is the Plant's Control Room. Operations personnel will report to the Control Room and control all evolutions from this central location. Self-Contained Breathing Apparatuses are located in or near the Control Room for personnel protection from inhalation.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 81 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN 7.1.2 Technical Support Center The Technical Support Center is located in the area immediately adjacent to the Control Room and includes the Shift Manager's office, the viewing gallery hallway, and the adjacent open work area. The TSC will accommodate personnel who will provide technical support to Operations and Control Room personnel during emergency conditions. Complete record keeping and communications capabilities have been installed. All necessary equipment, furnishings, and documents are stored in the immediate area and are readily available for use. The TSC may be activated for Unusual Events, and will be activated for Alert, Site Area Emergency, and General Emergency conditions.

Further details concerning staffing, equipment, furnishings, procedures, and activation are outlined in the Emergency Implementing Procedures.

Habitability of the Control Room and the TSC is assured by the filtered ventilation system that serves this area. In addition, Self-Contained Breathing Apparatus (SCBA) is provided for up to eight individuals. An area radiation monitor in the viewing gallery area reads out in the Control Room to provide external dose rate data. Air sampling and analysis equipment are provided in the emergency equipment kits to monitor airborne radioactivity levels. Personal radiation dosimetry issued to some site personnel and visitors will provide individual radiation dose assessment data. In the event that the Technical Support Center is not habitable, an alternate center may be established at the OSC, Mechanical Maintenance Shop, or other site buildings.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 82 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN 7.1.3 Operations Support Center (OSC)

The Operations Support Center (OSC) is located near the men's locker room in the Service Building that is connected to the rest of the Plant by hallways.

The function of the OSC is to assemble and coordinate necessary personnel from Chemistry, Radiation Protection, Operations (NPOsNon-Certified Operators), I&C, Electrical, and Mechanical. These groups will be dispatched for specific jobs as directed by the TSC.

Additional details concerning staffing, equipment, furnishings, procedures, and activation are outlined in the Emergency Implementing Procedures.

Habitability of the OSC is verified using available emergency kit equipment.

Equipment is provided for measuring external dose rates and airborne radioactive levels. The OSC ventilation system is independent of the Auxiliary Building system.

This minimizes airborne contamination as a result of events in the Auxiliary Building.

In the event the OSC should not be habitable, alternate locations such as the Mechanical Maintenance Shop or permanent construction buildings are available for use.

A maintenance kit containing only maintenance supplies is kept in the men's locker room.

7.2 EMERGENCY OPERATIONS FACILITY (EOF)

The Palisades Emergency Operations Facility (EOF) is located in downtown Benton Harbor, approximately 16 miles South Southwest from the Plant. The EOF assumes overall responsibility for Entergy Corporation emergency response. The EOF is designed to provide assistance in the decision-making process to protect the public health and safety, and to control radiological monitoring teams offsite. The EOF may be activated for the Unusual Event, and shall be fully activated for the Alert, Site Area Emergency, and General Emergency categories.

To assure the safety of the staff, equipment is provided for measuring external dose rates, and airborne radioactivity levels.

The staff is comprised of personnel from the Plant. In addition, liaison personnel from the county, state, and federal governments will also be present in the EOF.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 83 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN The EOF has ready access to up-to-date Plant records, procedures, and emergency plans needed to exercise overall utility resources management and for recovery management. Hard copy records stored and maintained at the EOF include, but are not limited to:

Palisades Technical Specifications Palisades Operating Procedures Palisades Final Safety Analysis Report Palisades Abnormal Operating Procedures Palisades Emergency Operating Procedures Palisades Site Post-Shutdown Emergency Plan Palisades Emergency Implementing Procedures Michigan Emergency Management Plan Van Buren County Emergency Plan Berrien County Emergency Plan Allegan County Emergency Plan Palisades Piping and Instrument Diagrams Other up-to-date records including radiological records, procedures, drawings, schematics, and diagrams are readily available via transmittal to the EOF.

The EOF shall provide analysis of field monitoring data, and coordination for the collection sample media.

7.3 COUNTY AND STATE EMERGENCY CENTERS 7.3.1 County Emergency Operations Centers Potential emergencies could directly impact those individuals living within the 10-Mile Emergency Planning Zone, and indirectly affect property within the 50-Mile Emergency Planning Zone. Therefore, emergency planning efforts have been initiated by those affected counties within the 10-Mile Emergency Planning Zone.

The affected counties are: Van Buren, Berrien, and Allegan Counties.

Each of these counties has established and maintains an Emergency Operations Center (EOC). These centers are located as follows:

a. Van Buren County Courthouse Annex Paw Paw, Michigan

b. Berrien County Sheriff's Department Benton Harbor, Michigan

c. Allegan Central Dispatch Allegan, Michigan

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 84 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN 7.3.2 State Emergency Operations Center When it is determined that personnel and resources of state government are needed to support disaster operations of affected local governments, the State Emergency Operations Center (SEOC) is staffed in Lansing. This facility is staffed at any level of emergency depending on potential for required state response.

The Michigan State Field Team Center location will be determined at the time of the incident by personnel at the State EOC. That facility is equipped with the necessary communications control capabilities (when staffed), from which the State will dispatch offsite-monitoring teams. All decision makers remain in Lansing.

7.4 JOINT INFORMATION CENTER (JIC)

A Joint Information Center (JIC) will be established at the combined EOF/JIC located at 330 W Main, Benton Harbor. The JIC will be staffed by public information representatives of the utility, state, county, and federal governments. The Plant Communications Specialist will be located in this facility upon its activation.

7.5 COMMUNICATIONS EQUIPMENT The members of the emergency organizations require correct and up-to-date information relevant to the potential or real emergency condition. Therefore, the communications systems that will be used by the emergency organizations must meet the following basic criteria:

a. Provide for prompt initial notification.

b. Maintain reliability.

c. Provide for alternate methods of communications.

7.5.1 Routine Communications System Communications equipment available for offsite use include:

a. Commercial telephones - separate outside lines.

b. Intracompany telephone system.

c. State Police Radio - through Security Department.

d. Emergency Network System telephone to NRC.

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e. Commercial telephone to Van Buren County Sheriff's Department, Paw Paw.

f. Commercial telephone to State Police Operation Center, Lansing.

g. Power failure phones in major onsite response centers (Control Room, TSC, OSC).

h. Satellite phones in major onsite response centers (Control Room, TSC, OSC, EOF).

Table 7-1 summarizes communications resources.

7.6 ASSESSMENT EQUIPMENT SYSTEMS 7.6.1 Radiation Monitoring System The Radiation Monitoring System measures, indicates, and records the presence and level of radiation, and alerts Plant personnel to abnormal levels of radioactivity, thereby contributing to personnel protection and proper operation of Plant equipment.

The system consists of permanently installed, continuous monitoring devices together with a program and provisions for specific sample collections and laboratory analyses. The system is designed to provide information for use in evaluating the radiological consequences of normal Plant operation, anticipated operational occurrences, and accidents. Control actions are initiated on the required systems when radiation levels exceed predetermined amounts.

These monitoring functions are performed by the following subsystems and programs:

a. Area Radiation Monitoring

b. Liquid Radiation Monitoring

c. Airborne Radiation Monitoring

1. Gas

2. Particulate

3. Iodine

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 86 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN Data from these subsystems are displayed by readouts, annunciators, and recorders located in the Control Room. (Portable airborne and area monitors are capable of being plugged into receptacles throughout the Plant.) Instrumentation power for the Radiation Monitoring System will be supplied from a reliable source.

d. Area Radiation Monitors Area radiation monitors are primarily for the purpose of measuring radiation dose rates for protection of Plant personnel and providing supporting data to the surveillance of Plant radiation levels.

Monitor alarm setpoints depend on the normal background radiation at the detector location and the calculated levels for abnormal conditions. The monitors will operate within the range of normal environmental conditions applicable to their locations.

Monitored points within the Plant are in areas where personnel exposure to radiation is most likely, and at appropriate access control boundaries.

Readouts and alarms are provided both locally and in the Control Room.

e. Airborne Radiation Monitors The radiation monitors located in the gaseous release paths monitor radioactivity with sufficient sensitivity to demonstrate compliance with 10 CFR 20 limits. They also provide sampling capability, ie, removable filters and/or gas sample stop valves. Samples analyzed with laboratory equipment permit evaluation of compliance to more restrictive regulations and provide data required.

f. Liquid Radiation Monitors The monitoring systems consist of fixed detectors that display radiation levels in the Control Room.

Testing and maintenance features, such as remotely operated check sources, flushing connections, and cutoff valves are included for periodic system check and/or calibration. The liquid radiation monitors are designed to ensure that liquid effluent releases are maintained below the DAC values of 10 CFR 20 by the use of alarms and automatic shutoff features.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 87 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN 7.6.2 Meteorology Onsite meteorological data is provided by a meteorological tower located in the northeast sector of the site. This system is primarily concerned with providing data for estimating the actual or potential effects of an accidental, airborne release of radioactivity.

The following data is available:

a. Wind direction and speed at 10 and 60 meters.

b. Stability class.

This data is transmitted to the Control Room at 15-minute averages. A remote interrogation capability is available. Details of the system as it applies to emergency offsite dose calculation are provided in Emergency Implementing Procedure EI-6.7, "Plant Site Meteorological System." Details on the system in general are provided in "Palisades Meteorological Monitoring Project Plan."

Backup meteorological data can be obtained through use of Emergency Implementing Procedure EI-6.8, "Backup and Supplemental Meteorology."

Severe weather warnings are provided to the Plant by a private consultant.

Predictions of sky to ground lightening, tornados, and wind speeds in excess of 40 mph are reported to the Control Room.

7.6.3 Fire Protection System The Fire Protection System, including monitoring devices and fire suppression equipment, is completely detailed in the Fire Protection Implementing Procedures.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 88 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN 7.7 OFFSITE MONITORING 7.7.1 Radiological Monitoring Radiological Monitoring Teams shall be activated at the direction of the Shift Manager or OSC Manager. If the OSC has not been activated, notification should be made directly to the Radiation Protection Office. Monitoring teams should consist of two Radiation Protection members. The emergency vehicle shall provide transportation and be equipped with radio communications and equipment suitable for monitoring and/or sampling gaseous or liquid releases. The equipment and procedures supplied to the offsite team(s) provide the capability to sample for radioiodine in concentration as low as 10-7 micro-curies per cubic centimeter.

Following staff augmentation, the estimated deployment time for a monitoring team is 30 minutes.

a. The Environmental Monitoring Program provides a number of TLDs and airborne particulate sampling stations that are valuable for long-term appraisal of integrated dose.

b. The Michigan Department of Environmental Quality provides offsite field monitoring capability within approximately three hours.

c. The State Police Emergency Management Division can request aerial and field monitoring through the Department of Energy.

7.7.2 Laboratory Facilities The Plant laboratory and counting rooms have the capability to perform the analyses required under emergency conditions. The Michigan Department of Environmental Quality, Radiological Protection Section operates a radiological laboratory in Lansing.

Palisades Plant, and the DC Cook Nuclear Plant, may exchange services for radiological laboratory analyses, laboratory boron analyses, and backup dispersion meteorology information.

GEL Laboratory has agreed to provide the following services: collecting, analyzing, evaluating, and reporting on appropriate samples as needed for protective action information. GEL Laboratory maintains a laboratory in CharlsetonCharleston, South Carolina which has the capability to perform chemical and radiological analyses.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 89 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN 7.8 FIRST AID AND MEDICAL CARE 7.8.1 First Aid and Medical Care At least one person having American Red Cross Multimedia First Aid or equivalent will be available onsite at all times.

Specialized training is given for the treatment and handling of contaminated personnel and injuries.

Emergency call lists for ambulance service and medical facilities are kept current in the Emergency Implementing Procedures.

7.8.2 First Aid Equipment There are first aid kits in appropriate areas of the Plant. Accountability and inventory checks are performed quarterly and after use.

7.8.3 Decontamination and First Aid Personnel decontamination facilities for emergency conditions include showers, sinks, cleaning agents, and first aid kits, which are maintained near the Radiation Protection access control area. These supplies include special materials and Personnel Decontamination Procedures. Additional personnel decontamination equipment and facilities shall be available for decontamination of evacuees.

7.8.4 Medical Transportation Company vehicles maintained onsite and/or private vehicles can be used to transport injured and/or contaminated personnel for medical treatment. In addition, ambulances are available from the Covert and South Haven Fire Departments, depending on the severity of the situation.

7.8.5 Medical Treatment South Haven Community Hospital and Lakeland Regional Medical Center/St Joseph, have agreed to accept contaminated, injured patients.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 90 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN 7.8.6 Use of Protective Equipment and Supplies Listings by general category of typical emergency protective equipment and supplies that are stored and maintained for emergency purposes are contained in Appendix E of the Plan. Additional protective actions considered as measures for minimizing radiological exposure and contamination of Plant personnel include use of protective equipment and clothing as described below:

a. Individual Respiratory Protection Respiratory protection devices will be issued when necessary to significantly reduce the internal exposure to radionuclides. Self-Contained Breathing Apparatus will also be used in emergencies involving smoke, gases, oxygen deficient atmospheres, or unknown conditions. Both Self-Contained Breathing Apparatus and air-purifying type full-face respirators are maintained in or near the Control Room, and a larger supply of this equipment is available at the Radiation Protection area in access control. Respiratory protection devices will be issued to survey teams, rescue teams, and other personnel required to be in areas of suspected or known high airborne radioactivity. A reserve breathing air supply that is of a rate sufficient to support Control Room personnel for an extended period of time is available.

In addition to breathing apparatus, thyroid-blocking agents (i.e., potassium iodide) will be dispensed for onsite personnel in accordance with Emergency Implementing Procedures.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 91 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN

b. Protective Clothing Supplies of this apparel include coveralls, rubber gloves, shoe covers and boots, caps and hoods, and plastic suits. Inventories are maintained for normal Plant use in access control and in the stockroom.

Additional supplies of protective clothing are in the emergency kits. This clothing will be issued to survey teams, rescue teams, and other personnel required to enter known or suspect areas of radioactive contamination. It will also be issued to persons required to work in or occupy contaminated areas.

For emergency conditions, normal street clothing is considered as protective apparel, which is supplemented as necessary to protect skin surfaces, and which can be cleaned or discarded later. Protective clothing is distributed offsite only to members of those support agencies required to occupy contaminated areas for some purpose. In this event, Entergy Corporation will provide supplies to those people as available.

c. Breathing Air A local supplier of compressed air is capable of providing emergency air cylinders on a 24-hour basis.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 92 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN TABLE 7-1 PALISADES PSEP COMMUNICATIONS MATRIX Control Room TSC OSC EOF State EOC Van Buren EOC NRC Offsite Teams Control 1. Intp Phone 1. Intp Phone 1. Intp Phone 1. Com Phone 1. Com Phone 1. ENS NR Room 2. SP Phone 2. Co Network 2. Radio1 2. Radio2 2. Radio2 2. Com Phone TSC 1. Intp Phone 1. Ded Circuit 1. Satellite 1. Com Phone 1. Com Phone 1. ENS NR

2. SP Phone 2. Intp Phone Phone 2. Radio2 2. Radio2 2. Com Phone

3. Satellite 3. Satellite 3. Satellite Phone Phone Phone OSC 1. Intp Phone 1. SP Phone 1. Intp Phone NR NR NR 1. Radio3

2. Co Network 2. Intp Phone 2. Radio3 2. Com Phone EOF 1. Intp Phone 1. Ded Circuit 1. Intp Phone 1. Com Phone 1. Com Phone 1. ENS 1. Radio3

2. Radio1 2. Com Phone 2. Radio3 2. Co Network 2. Co Network 2. Com Phone 2. Com Phone State EOC 1. Com Phone 1. Com Phone NR 1. Com Phone 1. Com Phone NR NR

2. Radio2 2. Radio2 2. Co Network 2. LEIN Van Buren 1. Com Phone 1. Com Phone NR 1. Com Phone 1. Com Phone NR NR EOC 2. Radio2 2. Radio2 2. Co Network 2. LEIN NRC 1. ENS 1. ENS NR 1. ENS NR NR NR

2. Com Phone 2. Com Phone 2. Com Phone Offsite NR NR 1. Radio3 1. Radio3 NR NR NR Teams 2. Com Phone 2. Com Phone Radio - 1Control Room/EOF (Located in Control Room)

- 2Plant Security Radio (in CAS & SAS/ Paw Paw State Police (backshifts & weekends))

- 3Radiation Protection Radio Network ENS - Emergency Notification System Com Phone - Commercial Telephone Intp Phone - Intraplant Telephone System Co Network - Palisades Telephone Network SP Phone - Sound Powered Phone LEIN - Michigan State Police Communication System Ded Circuit - Dedicated Telephone Circuit (Digital/VOIP) NR - Not Required

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 93 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN TABLE 7-1 PALISADES SEP COMMUNICATIONS MATRIX BACKUP PHONE NUMBERS AND METHODS

1. State of Michigan

a. 517-241-8000

b. 517-332-2521

c. Security Radio

2. Van Buren County Sheriff

a. 269-657-2058

b. 269-657-3101

3. NRC

a. 301-816-5100

b. 301-951-0550

c. 301-415-0550

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 94 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN 8.0 MAINTAINING EMERGENCY PREPAREDNESS Palisades Plant shall maintain the Site Post-Shutdown Emergency Plan and the Palisades Nuclear Plant Emergency Implementing Procedures as two separate documents. It is intended that this Post-Shutdown Emergency Plan, although considered part of Palisades Nuclear Power Plant's Final Safety Analysis Report (FSAR), be maintained as a separate document.

The Site Vice President is the individual with overall authority and responsibility for the Site Emergency Preparedness.

In order to meet the constantly changing conditions, methods have been implemented to ensure that the Site Post-Shutdown Emergency Plan and Implementing Procedures remain effective over the life of the Plant. Efforts shall be made to assure continuous emergency preparedness and operational readiness among Entergy personnel and the offsite response agencies and organizations.

8.1 ORGANIZATION PREPAREDNESS 8.1.1 Training Palisades Plant personnel, including non-permanent personnel, will receive training pertinent to the Site Post-Shutdown Emergency Plan and Implementing Procedures.

Persons assigned specific responsibilities during an emergency will receive additional training appropriate to their respective assignments. The responsibility for training is that of the Training Manager. He may delegate specialty-training responsibilities to personnel qualified to perform such training, for example, State or County training personnel. Governance of Emergency Response Organization Training for Entergy personnel is provided by Entergy Procedure P-EN-TQ-110, "Emergency Response Organization Training." This procedure describes the responsibilities for conducting and administering initial and continuing emergency preparedness training; provides clarification and details to implement a remediation process; and follows the guidance of P-EN-TQ-201,"Systematic Approach to Training Process," and P-EN-EP-308, "Emergency Planning Critiques."

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 95 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN 8.1.2 Drills and Exercises Members of the operating staff need to be familiar with their specific duties and responsibilities in the event of an accident at the Palisades Plant. To accomplish this, periodic drills and exercises will be conducted to test the state of emergency preparedness. The prime objective of the drills and exercise is to verify emergency preparedness of participating personnel, organizations, and agencies.

Each drill and exercise will be conducted to meet the following objectives:

a. Ensure that the participants are familiar with their respective duties and responsibilities.

b. Verify the adequacy of the Palisades Plant Site Post-Shutdown Emergency Plan and the methods used in the Implementing Procedures.

c. Test communication networks and systems.

d. Check the adequacy of emergency supplies and equipment.

e. Verify the operability of emergency equipment.

f. Designed to allow for freeplay for decision making.

Emergency Planning will ensure that drills and exercises are conducted as specified in this Plan.

Scheduled drills and exercises will be held involving appropriate offsite as well as onsite emergency personnel, organizations, and agencies. These drills and exercises will be conducted to simulate actual emergency conditions. Drill scenarios will be prepared that involve participation of several emergency teams and will include specific parts of the onsite and offsite emergency organizations such as state, county, and federal organizations, and local services support personnel and organizations. Offsite emergency planning personnel will be given advance notice of the schedule date of the drill or exercise, although the actual details shall be kept confidential from Offsite Response Players. Official observers will be provided with materials in accordance with their requirements.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 96 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN Recommendations for revisions to the Palisades Nuclear Power Plant Site Post-Shutdown Emergency Plan and/or Implementing Procedures and/or upgrading of emergency equipment and supplies as a result of a drill or exercise will be forwarded to Emergency Planning by observers and participants for inclusion in a formal critique. After review, recommendations will be forwarded to the Manager, Emergency Preparedness for comments. Recommended changes that are approved by the Regulatory and Performance Improvement Director will be incorporated into the Site Post-Shutdown Emergency Plan and Implementing Procedures. Records shall be maintained on drills and exercises conducted at the Palisades Plant.

8.1.3 Major Drills and Exercises will include the following:

a. Medical Drill A Medical drill shall be conducted at least once per calendar year. The drill shall involve the participation of local medical support personnel and organizations (eg, physicians, ambulance services, hospital, etc). Scenarios may include cases of radiation overexposure, contaminated personnel and/or contaminated/injured personnel.

b. Fire Emergency Drill Drills will be conducted in accordance with the Palisades Fire Plan which has been reviewed and approved by the NRC.

c. Radiological Monitoring Drills A radiological monitoring drill (onsite and/or offsite) shall be conducted annually. This drill shall include the collection and analysis of various materials. These may include grass, water, soil, and air samples.

d. Health Physics Drills Health Physics drills shall be conducted semi-annually which involve response to, and analysis of, simulated elevated airborne and liquid samples, and direct radiation measurements.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 97 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN

e. Radiological Emergency Preparedness Exercise An exercise which tests the Emergency Preparedness Plan and organization shall be conducted at least once per calendar year. These exercises shall be varied such that plans and preparedness organizations are tested completely within an eight-year exercise cycle. Provisions should be made to start exercises between 6:00 PM and 4:00 AM once every eight year exercise cycle, and to develop scenarios that reach Site Area and/or General Emergency levels every two years to assist the state and counties in maintaining their Emergency Preparedness requirements.

Annual exercises may involve the local, county, and state government emergency planning agencies depending on their past participation and schedule in accordance with federal regulations. Federal emergency response agencies shall be involved in a major exercise at least once every five years. Specific items tested are: public warning, adequacy of Emergency Implementing Procedures, communications, accident assessment, radiological monitoring, use of the Protective Action Guidelines, evacuation methodology, direction and control, public information, recovery and reentry operations, and emergency equipment.

Official observers from federal, state, or local governments will be encouraged to observe, evaluate, and critique the required exercises. A critique shall be scheduled at the conclusion of the exercise to evaluate the ability of organizations to respond as called for in the Pplan. The critique shall be conducted as soon as practicable after the exercise, and a formal evaluation or report shall result from the critique. Deficiencies identified in this evaluation shall be assigned to appropriate Entergy staff.

f. Communication Tests Communications shall be tested monthly with NRC headquarters from the Control Room, Technical Support Center and near-site Emergency Operations Facility. Communications shall be tested monthly with state and local governments within the plume exposure pathway of the Emergency Planning Zones. Communication shall be tested quarterly with those federal and state emergency response organizations within the ingestion pathway.

Communication links with state emergency operations center and field assessment teams from the Plant shall be tested annually. Communication links with the county emergency operations centers shall be tested annually by calling the respective Sheriff's Department. Communications between the Control Room, Technical Support Center, and Emergency Operations Facility shall be tested annually.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 98 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN 8.1.4 Emergency Planning Emergency Planning has been delegated responsibilities related to emergency planning that include, but are not limited to, the following:

a. Ensure offsite county, state, and supporting emergency plans are compatible with the Palisades Site Post-Shutdown Emergency Plan.

b. Conduct offsite agency training.

c. Ensure that the information, data, and procedures detailed in the Palisades Nuclear Plant Emergency Implementing Procedures are consistent with the Palisades Site Post-Shutdown Emergency Plan.

d. Ensure that the Emergency Plan Implementing Procedures are coordinated and interface properly with other procedures (e.g., Administrative Procedures, Security Procedures, Radiation Protection Procedures, and Training Procedures, etc.).

e. Coordinate the onsite emergency planning drill and exercise activities.

f. Coordinate the onsite review and updating of the Palisades Site Post-Shutdown Emergency Plan and Implementing Procedures.

g. Assist the Palisades Training Department, in coordinating and/or providing emergency planning related specialty training.

h. Ensure the maintenance and inventory of emergency equipment and supplies.

i. Be familiar with current changes in the federal regulations and guidance which impact emergency planning activities.

j. Document all corrective actions resulting from Plant-related Emergency Planning critiques and audits.

k. Initiate appropriate Plant-related corrective actions, if any, resulting from the critiques of each integrated practice drill conducted at the Plant.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 99 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN 8.2 EDUCATIONAL INFORMATION FOR THE PUBLIC For resident and transient members of the public within the 10-Mile Emergency Planning Zone, Entergy Corporation, and the local and state governments will provide written information pertaining to topics associated with emergency planning.

Information provided may include the following topics:

• Notification methods, time required for notification.

• Public initial actions.

• Educational information on radiation.

• Contact points and locations for additional information, including news media or local broadcast stations.

• Protective measures.

• Special needs of the handicapped.

This information can be disseminated to the public via varying methods. These methods may include direct mail of literature, information brochures contained in billing statements, telephone book inserts, and posting information documents in public areas.

At least annually, Entergy Corporation and the local and state governments will update the information, if necessary, for members of the public within the 10-Mile Emergency Planning Zone.

8.3 REVIEW AND UPDATING OF THE POST-SHUTDOWN EMERGENCY PLAN AND IMPLEMENTING PROCEDURES The Palisades Plant Site Post-Shutdown Emergency Plan involves the coordination of Entergy personnel and offsite support agencies. To achieve and maintain the most efficient course of emergency actions, the Palisades Plant Post-ShutdownSite Emergency Plan and Implementing Procedures, including appended letters of agreement, will be reviewed on an annual basis and updated as needed. These reviews are conducted to comply with the Entergy procedures, federal regulations, and operation license provisions.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 100 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN Proposed revisions to the Post-ShutdownSite Emergency Plan, Emergency Implementing Procedures and appended Letters of Agreement shall receive an effectiveness review in accordance with 10 CFR 50.54(q). If the change to the Post-ShutdownSite Emergency Plan reduces the effectiveness of the Plan, the Nuclear Regulatory Commission (NRC) shall review and approve the change prior to implementation. The proposed change shall be reviewed by the Management and Safety Review Committee (MSRC) prior to Plant Licensing submitting the proposed change to the NRC.

Proposed revisions to the Post-ShutdownSite Emergency Plan shall be reviewed and approved in accordance with the Entergy Procedure P-EN-OM-119, "On-Site Safety Review Committee."

When revisions to the Post-ShutdownSite Emergency Plan affect offsite support agencies, they shall be notified as the changes occur.

Editorial changes to the Post-ShutdownSite Emergency Plan or Emergency Implementing Procedures such as titles and telephone lists are not subject to the review process described above.

An independent review of the Emergency Preparedness Program shall be conducted in accordance with 10CFR50.54(t).

The review shall include the Post-ShutdownSite Emergency Plan, Emergency Implementing Procedures, training, drills and exercises, equipment, and interfaces with state and local governments. Records of the review shall be maintained for at least 5 years. Emergency Planning shall ensure state and local governments have access to appropriate findings.

As the Post-ShutdownSite Emergency Plan is reviewed, the emergency organization or procedures may be changed as a result of the following:

a. Drills may detect deficiencies and may indicate a more desirable organization or procedure.

b. Changes in key personnel involved in the organization or procedure.

c. Changes in the Plant's organizational structure.

d. Changes in the functions of supporting agencies, resulting from reorganization, personnel changes, and equipment requirements.

e. Changes in state or federal regulations.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 101 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN

f. Modifications to the Plant.

g. Recommendations received from other organizations, such as the state and federal agencies or other nuclear facilities.

8.4 MAINTENANCE AND INVENTORY OF EMERGENCY EQUIPMENT AND SUPPLIES Emergency Planning is responsible for ensuring the quarterly inventory and/or seal inspection is completed for designated emergency supplies and equipment.

Designated emergency equipment and supplies and their storage locations will be listed in the Implementing Procedures. Equipment, supplies, and parts having shelf lives shall be checked and replaced as necessary. Operational readiness of emergency equipment and supplies can be assured by conducting surveillance testing, maintenance checks, calibration, or inventory of all supplies and conducting an annual review of the list of equipment important to Emergency Planning.

8.5 EMERGENCY EQUIPMENT NUCLEAR PERFORMANCE ASSESSMENT DEPARTMENT CONTROLS 8.5.1 Meteorological Monitoring Program The Emergency Preparedness Section controls for the Palisades Plant Meteorological Monitoring Program are defined in Palisades Administrative Procedure 1.14, "Meteorological Monitoring Program."

8.5.2 Dose Assessment Computer Programs The Dose Assessment Computer Programs are in accordance with Entergy Procedure P-EN-IT-103, "Nuclear Cyber Security Program."

9.0 RECOVERY In any emergency, the immediate action is directed to limiting the consequences of the incident in a manner that will afford maximum protection of the Plant personnel and the public. Once the immediate corrective and protective actions have established an effective control over the incident situation, the emergency actions will shift into the recovery phase.

A recovery plan, from a practical standpoint, must be flexible enough to adapt to existing, rather than theoretical, conditions. It is not possible to anticipate in advance all of the conditions that may be encountered in an emergency situation; therefore, the Palisades Post-ShutdownSite Emergency Plan is addressed to general principles that will serve as a guide for developing a flexible plan of action.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 102 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN In the period immediately following an incident, initial radiation monitoring functions will involve only gross hazard evaluations and isolation and definition of radiological problem areas. This immediate radiation surveillance activity is intended to provide the basic information for the second stage of reentry and recovery.

9.1 The following is a brief description of actions that will be examined as required prior to authorizing reentry by the emergency staff.

9.1.1 Review available radiation surveillance data. Determine Plant areas potentially affected by radiation and contamination.

9.1.2 Review radiation exposures of personnel to participate in recovery operations.

Determine need for additional personnel.

9.1.3 Review adequacy of radiation survey instrumentation and equipment (type, ranges, number, calibration, etc).

9.1.4 Preplan survey team activities:

a. Areas to be surveyed

b. Anticipated radiation and contamination levels

c. Radiation survey equipment required

d. Shielding requirements and availability

e. Protective clothing and equipment required

f. Access control procedures (issuance of RWP)

g. Exposure control limits and personnel dosimetry required

h. Decontamination requirements

i. Communications required 9.2 The initial reentry into the Plant areas should encompass the following (in order of priority):

9.2.1 Determine initial recovery operations.

9.2.2 Identify hazards or potential hazards associated with the recovery operations.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 103 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN 9.2.3 Conduct comprehensive radiation surveillance of Plant facilities and define radiological problem areas.

9.2.4 Isolate and post areas in the Plant with appropriate warning signs and rope barriers, as Radiation Areas, High Radiation Areas, and Contaminated Areas, as appropriate.

9.3 The nature and extent of the emergency situation will determine what recovery operations are required. The Recovery Organization described in Section 5 will be established as directed by the Recovery Manager.

9.3.1 In order for the recovery phase of the emergency to commence, the conditions which caused the incident must no longer exist. It is the responsibility of the EOF Emergency Director to determine that the facility and/or surroundings are safe.

9.3.2 The following criteria must be met before the recovery and reentry phase can begin:

a. The Plant is in a controlled and stable condition,

b. The release of radioactive materials to the environment is under control or has ceased.

c. In-plant radiation levels are stable or decreasing.

d. Fire, flood, etc, is under control or has ceased.

e. At least one level of redundancy in plant systems should be available to prevent reinitiation of the event.

f. Consensus has been reached among the SED, EOF Director, NRC, and the State.

9.4 The initial objectives of the recovery program are the determination of the damage to equipment, the installation of shielding, rope barriers and signs, the application of clearance tags, decontamination, and cleanup as required to place the Plant in an acceptable long-term condition. Other recovery operations will not be initiated until the area affected by the emergency has been defined. Particular attention will be directed toward isolating and tagging out components and systems as required to control or minimize hazards. A systematic investigation will be conducted to determine the equipment damaged and the extent of the damage.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 104 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN 9.5 Once the initial objectives are completed, a detailed investigation of the accident causes and consequences both to the Plant and to the environment will be conducted. Determination will be made as to the equipment repair work required as well as the need to modify Plant operating procedures. Repair work and approved modifications shall be carried out as authorized. Test programs to confirm fitness for return to service will be developed and executed.

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

9.7 The State EOC will be advised when the Plant deems it safe to begin the reentry phase of the offsite recovery operation. If the Governor has ordered an evacuation, it is legally required for the Governor to officially rescind the order. The Michigan Department of Environmental Quality is responsible for coordinating reentry procedures for the offsite population.

PALISADES NUCLEAR PLANT PSEP SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 105 of 105 TITLE: SITE POST-SHUTDOWN EMERGENCY PLAN FIGURE 9-1 LONG TERM RECOVERY ORGANIZATION SITE VICE PRESIDENT PLANT COMMUNICATIONS PUBLIC AFFAIRS RECOVERY ADMINISTRATION SPECIALIST DIRECTOR MANAGER AND LOGISTICS PLANNING AND LOGISTICS PLANT PLANT RADIATION PLANT ENGINEERING OPERATIONS PROTECTION MAINTENANCE

PALISADES NUCLEAR PLANT APPENDIX A SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 1 of 2 AGREEMENTS WITH OFF-SITE INDIVIDUALS, AGENCIES, AND ORGANIZATIONS Criteria for agreements with off-site individuals, agencies, and organizations.

Letters of agreement, contracts, or signature pages may be used to verify agreements made with offsite individuals, agencies, and organizations. The use of signature pages is appropriate for use with organizations or agencies where response functions are covered by laws, regulations, or executive orders.

Letters of agreement contain the following as appropriate:

1. Concepts of operations,

2. Emergency measures or services to be provided,

3. Mutually acceptable criteria for implementation,

4. Arrangements for exchange of information,

5. Authorities,

6. Responsibilities,

7. And Limits of actions.

Contracts or contract excerpts may be used in place of letters of agreement and should address the above criteria as appropriate.

As specified in Section 8 of this plan, letters of agreement, contracts, and signature pages will be reviewed annually. The following agreements will be reviewed annually and updated as needed.

1. Covert Fire Department

2. South Haven Area Emergency Services Authority

3. Lakeland Regional Medical Center

4. South Haven Community Hospital

5. Medic 1 Community Emergency Service

6. GEL Laboratories

PALISADES NUCLEAR PLANT APPENDIX A SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 2 of 2 AGREEMENTS WITH OFF-SITE INDIVIDUALS, AGENCIES, AND ORGANIZATIONS

7. Memo on Agreement with NSSS Vendor

8. Memo on Agreement with Nuclear Fuel Supplier

9. Reciprocal Laboratory Use Agreement

10. Institute of Nuclear Power Operations

11. Mutual Assistance Agreement

12. Hostile Action Memorandum of Understanding All letters of agreement, contracts, and signature pages are kept with the master file for this appendix in Document Control.

PALISADES NUCLEAR PLANT APPENDIX B SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 1 of 1 BASIS FOR DELETION OF APPENDIX B OF THE PALISADES SITE POST-SHUTDOWN EMERGENCY PLAN

PALISADES NUCLEAR PLANT APPENDIX C SITE POST-SHUTDOWN EMERGENCY PLAN Attachment A Revision 29TBD Page 1 of 1 POPULATION DISTRIBUTION AND EVACUATION TIME ESTIMATES The contents of Appendix C have been relocated to a progeny procedure to the Post-ShutdownSite Emergency Plan. See PSEP Supp 2, "Evacuation Time Estimates," Revision 1, August 2012.

PALISADES NUCLEAR PLANT APPENDIX D SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 1 of 8 EMERGENCY IMPLEMENTING PROCEDURES Palisades Site Specific Procedures EI-1 Emergency Classification and Actions (SEP Section 4)

Upon recognition that abnormal Plant or site conditions exist, this procedure will be used in conjunction with SEP Sup 1 "SITE EMERGENCY PLAN Supplement 1 - EAL Wall Charts" to determine the appropriate Emergency Action Level(s) and to assure that all mandatory and subsequent actions are carried out.

EI-1.1 Emergency Response to Credible Security Threats (Canceled) (SEP Section 4)

This procedure provides guidance for declaring and responding to an Unusual Event or an Alert based on a credible security threat. (This procedure was canceled following the implementation of the NEI 99-01 Revision 4 EALs as this version of EALs incorporated the security threat EALs.)

EI-2.1 Emergency Plant Manager (Canceled) (SEP Section 5)

This procedure defines the responsibilities of the Emergency Plant Manager.

EI-2.2 Emergency Staff Augmentation (SEP Section 5)

This procedure establishes a method for augmenting onsite staffing under emergency conditions.

EI-3 Communications and Notifications (SEP Section 6)

This procedure details the notification format and provides call lists of offsite agencies. The primary and alternate communications lines are also described.

EI-4.1 Technical Support Center Activation (SEP Section 5)

This procedure describes the activation, staffing, physical facilities, equipment, and operations of the TSC.

EI-4.2 Operations Support Center Activation (SEP Section 5)

This procedure describes the activation, staffing, physical facilities, equipment, and operations of the OSC.

EI-4.3 Emergency Operations Facility Activation (SEP Section 5)

This procedure describes the activation, staffing, physical facilities, equipment, and operations of the EOF.

PALISADES NUCLEAR PLANT APPENDIX D SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 2 of 8 EMERGENCY IMPLEMENTING PROCEDURES EI-5.0 Reentry (SEP Section 9)

This procedure provides guidelines for entry into the affected area of the Plant after the emergency condition has been stabilized. It also provides guidelines for the initial recovery operation prior to the establishment of the Long-Term Recovery Organization.

EI-5.1 Recovery (SEP Section 9)

This procedure describes the recovery phase of emergency response at Palisades, and provides guidelines for restoring the plant to its preemergency condition.

EI-6 Rapid Dose Calculation (SEP Section 6)

This procedure provides a method to determine the appropriate steps required to calculate offsite dose and recommend offsite protective actions.

EI-6.1 Release Rate Determination from Stack Gas Monitors (SEP Section 6)

This procedure provides a manual calculation of a release rate for radioactive effluents from the Plant stack.

EI-6.2 Release Rate Determination from Steam Line Monitors RIA-2323 and RIA-2324 for Steam Releases Through Atmospheric Dump Valves (SEP Section 6)

This procedure provides a manual calculation of a release rate for radioactive effluents from the atmospheric dump valves.

EI-6.3 Release Rate Determination from High-Range Effluent Monitors (SEP Section 6)

This procedure provides a release rate calculation for radioactive effluents from the Plant stack or steam dumps.

EI-6.4 Release/Potential Release Determination from Containment High-Range Monitors (SEP Section 6)

This procedure provides a release/potential release rate from radioactive material released into containment.

EI-6.6 Gamma E-Bar Determinations (SEP Section 6)

This procedure provides a Gamma E-Bar (Average Gamma Energy Per Disintegration) for input into offsite dose calculations.

PALISADES NUCLEAR PLANT APPENDIX D SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 3 of 8 EMERGENCY IMPLEMENTING PROCEDURES EI-6.7 Plant Site Meteorological System (SEP Section 7)

This procedure provides a means to access the Plant site meteorological system for meteorological data required in the offsite dose calculations.

EI-6.8 Backup and Supplemental Meteorology (SEP Section 7)

This procedure provides a means to access the Weather Services International (WSI) meteorological system and obtain meteorological data required in the offsite dose calculations when onsite meteorological data is not available.

EI-6.9 Automated Dose Assessment Program (SEP Section 6)

This procedure provides basic instruction on how to initiate and operate the IBM PC Automated Dose Assessment Program "Offsite."

EI-6.10 Offsite Dose Calculation - Straight Line Gaussian (Manual Method)

(SEP Section 6)

This procedure provides a manual backup to the automated dose assessment program to calculate whole body and thyroid dose rates.

EI-6.13 Protective Action Recommendations for Offsite Population (SEP Section 6)

This procedure provides guidelines for determining protection actions for the general public to be recommended to the appropriate state and local authorities in the event of a radiological emergency.

EI-7.0 Emergency Post Accident Sampling and Determination of Fuel Failure Using Dose Rates (SEP Section 6)

This procedure provides the decision process necessary to implement sampling under emergency conditions.

EI-7.1 Emergency Sampling - PCS Liquid/Gas and Containment Air (Canceled)

This procedure describes the sequential method of sampling the Primary Coolant System (PCS) and/or the containment atmosphere during a post-accident condition using the PASM panel. (This procedure was canceled following elimination of the PASM panel.)

PALISADES NUCLEAR PLANT APPENDIX D SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 4 of 8 EMERGENCY IMPLEMENTING PROCEDURES EI-7.2 Emergency Post Accident Analysis (Canceled)

This procedure describes the sequential method of analyzing the PCS samples obtained during an accident condition. (This procedure was canceled following elimination of the PASM panel.)

EI-7.3 Hydrogen and Oxygen Gas Analysis of Post-Accident Samples (Canceled)

This procedure describes the steps necessary to determine the hydrogen concentration from a PCS gas sample collected at the PASM panel, as well as the hydrogen and oxygen concentration from containment atmospheric gas samples.

(This procedure was canceled following elimination of the PASM panel.)

EI-7.4 Post Accident Gas and Liquid Activity Analysis (Canceled)

This procedure describes the steps necessary to analyze samples for gamma activity during a post-accident condition. (This procedure was canceled following elimination of the PASM panel.)

EI-7.5 Boron: Chloride Ion Chromatography Method Post Accident (Canceled)

This procedure describes the steps necessary to analyze and determine the boron concentration in a diluted PCS sample during a post-accident condition. (This procedure was canceled following elimination of the PASM panel.)

EI-7.8 pH: Hydrogen Specific Ion Electrode (Canceled 10/95)

This procedure describes the steps necessary to determine the pH of an undiluted PCS sample during a post-accident condition. (This procedure was canceled 10/95).

EI-7.10 Post Accident Sampling, Radioactive Gaseous Effluent Monitoring (SEP Section 6)

This procedure describes the steps necessary to obtain a post-accident sample of the stack effluent utilizing the radioactive gaseous effluent monitor.

EI-8 Onsite Radiological Monitoring (SEP Section 6)

This procedure provides guidelines for post-accident radiological monitoring on site.

EI-9 Offsite Radiological Monitoring (SEP Section 6)

This procedure provides guidelines for post-accident radiological monitoring off site.

PALISADES NUCLEAR PLANT APPENDIX D SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 5 of 8 EMERGENCY IMPLEMENTING PROCEDURES EI-10 Accident Environmental Assessment (SEP Section 6)

This procedure provides guidelines for post-accident collection and replacement of accident TLDs, obtaining data from air monitoring stations, collection and assessment of waterborne effluents, and obtaining water/milk/vegetation samples.

EI-11 Determination of Extent of Core Damage (SEP Section 6)

This procedure provides a method of estimating the degree of core damage during accident conditions.

EI-11.2 Core Damage Assessment from Post Accident Sampling (Canceled)

This procedure provides a method of determining extent of core damage via gamma isotopic analysis at the PASM panel. (This procedure was canceled following elimination of the PASM panel.)

EI-12.1 Personnel Accountability and Assembly (SEP Section 6)

To provide guidelines and assign responsibility for personnel assembly and accountability.

EI-12.2 Assembly Area Personnel Lists (Canceled 10/95)

Provides updates for assembly area lists. (This procedure was canceled 10/95).

EI-12.3 Search and Rescue Team Responsibilities (SEP Section 6)

Provides guidelines for search and rescue teams during an emergency.

EI-13 Evacuation/Reassembly (SEP Section 6)

This procedure provides site evacuation procedures and the subsequent reassembly of personnel.

EI-14 Medical Care/Treatment of Contaminated, Injured Personnel (SEP Section 6)

This procedure provides guidelines on personnel emergency radiation exposure limits, personnel decontamination procedures, the use of thyroid blocking agents, and the methods of transporting contaminated/injured victims to hospitals.

PALISADES NUCLEAR PLANT APPENDIX D SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 6 of 8 EMERGENCY IMPLEMENTING PROCEDURES EI-15.1 Drills and Exercises (Cancelled)

This procedure details the requirements for drills and exercises which test the efficiency of the Site Emergency Plan. (This procedure was canceled following the implementation of Entergy Procedure EN-EP-306, Drills and Exercises.)

EI-15.2 Communications Tests (SEP Section 8)

This procedure establishes requirements for testing the emergency communications systems.

EI-15.3 Post Accident Sample Monitoring System Operator Training (Canceled)

This procedure provides training guidelines for the post-accident sample panel.

(This procedure was canceled following elimination of the PASM panel.)

EI-16.1 Maintenance of Emergency Equipment (SEP Section 7)

This procedure establishes a method for the regular inventory and testing of emergency equipment and supplies.

EI-16.2 Post Accident Sample Monitoring System Supplies and Associated Equipment Checks (Canceled)

This procedure establishes a method for the regular inventory and operability checks of the Post Accident Sample Monitoring Panel supply cabinets and associated equipment. (This procedure was canceled following elimination of the PASM panel.)

EI-17 Compensating Measures For OOS EAL Equipment And Listing Of Non-EAL Equipment Important For Emergency Preparedness This procedure lists equipment important to Emergency Preparedness. It provides time restrictions for the length of time the equipment may be out of service.

Entergy Additional Procedures P-EN-EP-306 Drills and Exercises This procedure establishes a process to standardize fleet drill and exercise programs and provides guidance for the planning, preparation, scheduling, conduct, evaluation, and documentation of Emergency Planning drills and exercises.

PALISADES NUCLEAR PLANT APPENDIX D SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 7 of 8 EMERGENCY IMPLEMENTING PROCEDURES P-EN-EP-307 Hostile Action Based Drills and Exercises This procedure establishes a process to standardize the fleet hostile action based drill program and processes; provides guidance for the preparation and conduct of integrated Emergency Planning (EP) and Security exercises using hostile action based scenarios; and, provides guidance for the preparation and conduct of a pre-exercise hostile action-based tabletop.

P-EN-EP-308 Emergency Planning Critiques This procedure establishes a process to standardize fleet drill and exercise critiques, and describes the means for tracking and correcting deficiencies identified in drills.

P-EN-EP-310 Emergency Response Organization Notification System This procedure provides guidance to maintain the ERO notification system in a state of readiness.

P-EN-EP-311 Emergency Response Data System (ERDS) Activation via the Virtual Private Network (VPN)

This procedure provides for a secure network communications connection supporting the transmission of station parameters to the Nuclear Regulatory Commission (NRC) in the event of a declared emergency; and provides instructions for verification of connections for those plants which maintain 24/7 connectivity.

P-EN-EP-313 Offsite Dose Assessment using the Unified RASCAL Interface This procedure provides the methods and instructions for performing offsite dose assessment using the Unified RASCAL Interface (URI).

P-EN-EP-609 Emergency Operations Facility (EOF) Operations This procedure provides guidance to activate and operate the EOF focusing on classification, notification, dose assessment and protective action recommendations.

P-EN-EP-610 Technical Support Center (TSC) Operations This procedure provides guidance to activate and operate the TSC; and, contains guidelines regarding personnel emergency radiation exposure limits and issuance of thyroid blocking agents.

PALISADES NUCLEAR PLANT APPENDIX D SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 8 of 8 EMERGENCY IMPLEMENTING PROCEDURES P-EN-EP-611 Operations Support Center (OSC) Operations This procedure provides guidance to activate and operate the OSC.

P-EN-EP-801 Emergency Response Organization This procedure outlines expectations and responsibilities for Emergency Response Organization (ERO) members, Site Management and the Emergency Planning staff; and, outlines responsibilities for personnel assigned to an ERO position and for other company personnel who may be called upon to support an emergency response effort, but are not directly assigned to an ERO position.

P-EN-TQ-110 Emergency Response Organization Training This procedure establishes the training and qualification requirements for personnel assigned to the Emergency Response Organization (ERO); and establishes the training offered to off-site emergency response organizations.

P-EN-TQ-110-01 Fleet EPlan Training Course Summary This procedure lists the Fleet specific curricula and learning items required for each of the standard Emergency Response Organization (ERO) positions specified in P-EN-EP-801, Emergency Response Organization.

PALISADES NUCLEAR PLANT APPENDIX E SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 1 of 1 GENERAL EQUIPMENT IN EMERGENCY KITS Emergency kits will be maintained and inspected at least quarterly and readily accessible. Kits are typically maintained in the following locations: Technical Support Center (TSC),

Operations Support Center (OSC), Emergency Operations Facility (EOF), Emergency Vehicles, Health Physics Office and support hospitals. Specific kit locations are specified in the Emergency Implementing Procedures. Specific equipment inventories are contained in the Emergency Implementing Procedures.

Emergency kits consist of the following generic equipment classifications:

a. Monitoring instrumentation and equipment including: dose rate and count rate meters, air sampling equipment, personnel dosimetry equipment.

b. Protective equipment including: protective clothing, respiratory equipment, thyroid blocking agent.

c. Communications equipment including: radios, telephones, microphones.

d. Reference material including: Emergency plans and procedures, maps, equipment lists, spare forms.

e. Miscellaneous equipment including: survey, posting and boundary equipment, plastic bags, flashlights, office supplies, decontamination equipment.

f. Maintenance equipment.

g. Medical Emergency equipment including: monitoring instrumentation and equipment, protective equipment, survey, posting and boundary equipment, decontamination and first aid supplies.

h. Medical Emergency First Aid equipment including: Medical First Aid supplies for use in responding to contaminated or noncontaminated injuries.

PALISADES NUCLEAR PLANT APPENDIX I SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 1 of 4 NUREG-0654 CROSS REFERENCE NUREG-0654 FEMA-REP-1 REV 1 SITE POST-SHUTDOWN EMERGENCY PLAN*

A.1.a Section 5 A.1.b 5.1 through 5.5 A.1.c Figure 5.1 A.1.d 3.2 A.1.e 3.2, Table 7-1 A.3 5.6, 5.7, 5.8, Appendix A A.4 5.1 B.1 5.2 B.2 5.2.5 B.3 5.4.1 B.4 5.4.1 B.5 Figure 5-2 B.6 5.3 through 5.8, Figure 5-1 B.7.a 5.4 B.7.b 5.5 B.7.c Figure 5-1 B.7.d 5.3.5 B.8 5.8, Appendix A B.9 5.6.1 through 5.6.3, Appendix A C.1.a 5.7.2 C.1.b 7.1, 7.2 C.1.c 5.7.2.a C.2.b 6.1.3.n C.3 7.7.2 C.4 Appendix A D.1 Table 4-1 and SITE POST-SHUTDOWN EMERGENCY PLAN Supplement 1 - EAL Wall Charts D.2 SITE POST-SHUTDOWN EMERGENCY PLAN Supplement 1

- EAL Wall Charts E.1 6.1.3.f, 6.1.3.h, Figure 6-1 E.2 5.4 E.3 6.1.1.b.2(f)

• The referenced section of the Site Post-Shutdown Emergency Plan represents the principal location where the NUREG is addressed.

PALISADES NUCLEAR PLANT APPENDIX I SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 2 of 4 NUREG-0654 CROSS REFERENCE NUREG-0654 FEMA-REP-1 REV 1 SITE POST-SHUTDOWN EMERGENCY PLAN*

E.4 6.1.1.b.2(g)

E.6 6.4.1.b.3(a)

E.7 6.4.1.b F.1 3.2, Table 7-1, 6.1.1, 6.1.2 F.2 7.8.1 F.3 8.1.2 G.1 8.2 G.2 8.2 G.3 5.3.5, 7.4 G.4.a 5.3.5 G.4.b 5.3.5 G.4.c 5.3.5 G.5 8.2 H.1 5.3.2 H.2 5.3.4 H.4 5.4 H.5 7.6 H.6 7.6.2, 7.7 H.7 7.7.1 H.8 7.6.2 H.9 5.3.3 H.10 8.4 H.11 Appendix E H.12 7.2 I.1 SITE POST-SHUTDOWN EMERGENCY PLAN Supplement 1

- EAL Wall Charts I.2 7.6 I.3 6.2.5 I.4 7.6, 7.7 I.5 7.6.2 I.6 6.2.5 I.7 7.7.1

• The referenced section of the Site Post-Shutdown Emergency Plan represents the principal location where the NUREG is addressed.

PALISADES NUCLEAR PLANT APPENDIX I SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 3 of 4 NUREG-0654 CROSS REFERENCE NUREG-0654 FEMA-REP-1 REV 1 SITE POST-SHUTDOWN EMERGENCY PLAN*

I.8 6.2.5 I.9 7.7.1 I.10 6.2.5 J.1 6.4.1.a.1 J.2 6.4.1 J.3 6.4.1.a.4 J.4 6.4.1 J.5 6.4.1.a.1 J.6 7.8.6 J.7 6.1.1 J.8 SITE POST-SHUTDOWN EMERGENCY PLAN Supplement 2

- Evacuation Time Estimates J.10 6.4.1.b, 7.7 K.1 6.5 K.2 6.5.1 K.3 6.5.1 K.5 6.4.2, 6.5.2 K.6 6.4.2 K.7 6.5.2 L.1 5.6.1 L.2 6.5.2 L.4 5.6.1 M.1 9.0 M.2 Figure 9-1 M.3 9.0 M.4 6.2.5 N.1 8.1.2 N.2 8.1.2 N.3 8.1.2 N.4 8.1.2 N.5 8.1.2 O.1 8.1.1

• The referenced section of the Site Post-Shutdown Emergency Plan represents the principal location where the NUREG is addressed.

PALISADES NUCLEAR PLANT APPENDIX I SITE POST-SHUTDOWN EMERGENCY PLAN Revision 29TBD Page 4 of 4 NUREG-0654 CROSS REFERENCE NUREG-0654 FEMA-REP-1 REV 1 SITE POST-SHUTDOWN EMERGENCY PLAN*

O.2 8.1.1, 8.1.2 O.3 6.5.2 O.4 8.1.1 O.5 8.1.1 P.1 8.1 P.2 5.1 P.3 8.1.3 P.4 8.3 P.5 8.3 P.6 2.5.3 P.7 Appendix D P.8 Table of Contents P.9 8.3 P.10 8.1.3f

• The referenced section of the Site Post-Shutdown Emergency Plan represents the principal location where the NUREG is addressed.

Attachment 4 To Entergy Letter PNP 2017-034 Palisades Nuclear Plant Proposed Revision to the Palisades Nuclear Plant Site Emergency Plan (clean)

(129 Pages)

Procedure No SEP Revision TBD Effective Date PALISADES NUCLEAR PLANT POST-SHUTDOWN EMERGENCY PLAN TITLE: SITE EMERGENCY PLAN Approved: /

Procedure Sponsor Date Process Applicability Exclusion Revision TBD FULL REVISION TO ADDRESS IMPLEMENTATION OF THE POST-SHUTDOWN EMERGENCY PLAN

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page i TITLE: POST-SHUTDOWN EMERGENCY PLAN Table of Contents SOURCES AND REFERENCES .................................................................................................... 1 SOURCE DOCUMENTS ................................................................................................ 1 REFERENCE DOCUMENTS ......................................................................................... 1

1.0 INTRODUCTION

............................................................................................................ 6 1.1 DEFINITIONS ................................................................................................. 6 1.1.1 Accident ................................................................................... 6 1.1.2 Activation................................................................................. 6 1.1.3 Affected Persons .................................................................... 7 1.1.4 Alarm ........................................................................................ 7 1.1.5 Alert .......................................................................................... 7 1.1.6 Annunciation ........................................................................... 7 1.1.7 Assessment Actions ............................................................... 7 1.1.8 Command and Control ........................................................... 7 1.1.9 Control Room .......................................................................... 7 1.1.10 Control Room Personnel ........................................................ 7 1.1.11 Corrective Actions .................................................................. 8 1.1.12 Decontamination ..................................................................... 8 1.1.13 Emergency ............................................................................... 8 1.1.14 Emergency Action Levels (EAL) ............................................ 8 1.1.15 Emergency Operations Facility (EOF) ................................... 8 1.1.16 Emergency Implementing Procedures .................................. 8 1.1.17 Emergency Planning Zones (EPZ) ......................................... 9 1.1.18 Fitness For Duty ...................................................................... 9 1.1.19 Fully Operational ..................................................................... 9 1.1.20 General Emergency ................................................................ 9 1.1.21 Hostile Action .......................................................................... 9 1.1.22 Hostile Force ......................................................................... 10 1.1.23 Ingestion Exposure Pathway ............................................... 10 1.1.24 Initiating Condition (IC) ........................................................ 10

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page ii TITLE: POST-SHUTDOWN EMERGENCY PLAN Table of Contents 1.1.25 Offsite..................................................................................... 10 1.1.26 Onsite ..................................................................................... 10 1.1.27 Operational ............................................................................ 10 1.1.28 Operations Support Center (OSC) ....................................... 11 1.1.29 Owner Controlled Area ......................................................... 11 1.1.30 Plume Exposure Pathway .................................................... 11 1.1.31 Population at Risk ................................................................. 11 1.1.32 Protective Actions................................................................. 11 1.1.33 Protective Action Guides (PAG) .......................................... 11 1.1.34 Protected Area ...................................................................... 12 1.1.35 Radiological Emergency ...................................................... 12 1.1.36 Recovery Actions .................................................................. 12 1.1.37 Site Area Emergency ............................................................ 12 1.1.38 Emergency Plant Manager ................................................... 12 1.1.39 State ....................................................................................... 12 1.1.40 Technical Support Center (TSC) .......................................... 12 1.1.41 Unusual Event ....................................................................... 13 2.0 SCOPE AND APPLICABILITY .................................................................................... 13 2.1 GENERAL INFORMATION AND SITE DESCRIPTION............................... 13 2.2 POPULATION DISTRIBUTION AND EVACUATION TIMES ...................... 13 2.3 EMERGENCY PLANNING ZONES ............................................................. 14 2.4 PURPOSES AND OBJECTIVES ................................................................. 14 2.4.1 Regulatory Requirements .................................................... 15 2.4.2 Purpose of Emergency Preparedness ................................ 15 2.4.3 Objectives of the Palisades Post-Shutdown Emergency Plan ........................................................................................ 15 2.5

SUMMARY

OF EMERGENCY PLAN INTERRELATIONSHIPS ................. 16 2.5.1 Post-Shutdown Emergency Plan Supplement 1 ................ 16 2.5.2 Post-Shutdown Emergency Plan Supplement 2 ................ 17 2.5.3 Emergency Implementing Procedures ................................ 17

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page iii TITLE: POST-SHUTDOWN EMERGENCY PLAN Table of Contents 2.5.4 Related Plans, Programs, and Procedures ......................... 17 3.0 POST-SHUTDOWN EMERGENCY PLAN

SUMMARY

............................................... 22 3.1 POST-SHUTDOWN EMERGENCY PLAN STEPS ...................................... 22 3.2 ENTERGY CORPORATION EMERGENCY ORGANIZATION .................... 23 3.3 EMERGENCY CLASSIFICATIONS ............................................................. 23 3.4 EMERGENCY ACTIONS ............................................................................. 25 4.0 POST-SHUTDOWN EMERGENCY CONDITIONS ...................................................... 27 4.1 EMERGENCY CLASSIFICATION SYSTEM ................................................ 27 4.1.1 Unusual Event ....................................................................... 28 4.1.2 Alert ........................................................................................ 29 4.1.3 Site Area Emergency ............................................................ 30 4.1.4 General Emergency .............................................................. 31 4.2 CLASSIFICATION OF POSTULATED ACCIDENTS .................................. 31 5.0 ORGANIZATIONAL CONTROL OF EMERGENCIES ................................................. 38 5.1 PALISADES PLANT ORGANIZATION ....................................................... 38 5.2 OPERATING AND ENGINEERING ORGANIZATION ................................. 38 5.2.1 GENERAL MANAGER, PLANT OPERATIONS .................... 39 5.2.2 Director - Emergency Programs .......................................... 39 5.2.3 Director - Engineering .......................................................... 39 5.2.4 Regulatory and Performance Improvement Director ......... 39 5.2.5 Duty Station Manager ........................................................... 39 5.2.6 Shift Manager ........................................................................ 39 5.2.7 DELETED ............................................................................... 39 5.3 PALISADES EMERGENCY RESPONSE ORGANIZATION ....................... 39 5.3.1 Control Room ........................................................................ 40 5.3.2 Technical Support Center .................................................... 40 5.3.3 Operations Support Center .................................................. 40 5.3.4 Emergency Operations Facility (EOF) ................................. 41 5.3.5 Joint Information Center (JIC) ............................................. 41

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page iv TITLE: POST-SHUTDOWN EMERGENCY PLAN Table of Contents 5.4 EMERGENCY STAFFING ........................................................................... 41 5.4.1 Shift Manager/EOF Emergency Director ............................. 42 5.4.2 Shift Manager/Emergency Plant Manager ........................... 42 5.5 RECOVERY ORGANIZATION ..................................................................... 43 5.6 OFF-SITE EMERGENCY RESPONSE SERVICES ..................................... 43 5.6.1 Medical Services ................................................................... 43 5.6.2 Fire-Fighting Services .......................................................... 44 5.6.3 Law Enforcement Agencies ................................................. 44 5.6.4 Van Buren County Office of Domestic Preparedness........ 45 5.6.5 Berrien County Emergency Management ........................... 46 5.6.6 Allegan County Office of Emergency Preparedness ......... 46 5.7 COORDINATION WITH GOVERNMENTAL AGENCIES ............................ 47 5.7.1 State of Michigan Agencies ................................................. 47 5.7.2 Federal Agencies .................................................................. 49 5.8 INSTITUTE OF NUCLEAR POWER OPERATIONS (INPO) ....................... 50 6.0 EMERGENCY MEASURES ......................................................................................... 56 6.1 ACTIVATION OF THE EMERGENCY ORGANIZATION ............................. 56 6.1.1 Control Room Personnel ...................................................... 57 6.1.2 Emergency Plant Manager ................................................... 60 6.1.3 Emergency Director .............................................................. 61 6.1.4 Emergency Management and Homeland Security Division -

Michigan State Police ........................................................... 62 6.1.5 Michigan Department of Environmental Quality, Radiological Protection Section .......................................... 62 6.1.6 Affected Counties: Van Buren County, Berrien County, and Allegan County ...................................................................... 63 6.2 ASSESSMENT ACTIONS ............................................................................ 63 6.2.1 Assessment Actions for Unusual Events ........................... 63 6.2.2 Assessment Actions for Alerts ............................................ 63 6.2.3 Assessment Actions for Site Area Emergencies ............... 64 6.2.4 Assessment Actions for General Emergencies ................. 65

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page v TITLE: POST-SHUTDOWN EMERGENCY PLAN Table of Contents 6.2.5 Estimation of Offsite Dose ................................................... 65 6.2.6 Data Reporting, Recording, and Analysis ........................... 66 6.2.7 Interviewing Evacuees or Other Witnesses ........................ 66 6.2.8 Assessment Results Communications ............................... 66 6.3 CORRECTIVE ACTIONS ............................................................................. 66 6.3.1 Fire Control ............................................................................ 67 6.3.2 Repair and Damage Control ................................................. 67 6.3.3 System Control ..................................................................... 67 6.4 PROTECTIVE ACTIONS ............................................................................. 68 6.4.1 Sheltering, Evacuation, Personnel Accountability............. 68 6.4.2 Contamination Control Measures ........................................ 72 6.5 AID TO AFFECTED PERSONNEL .............................................................. 73 6.5.1 Emergency Personnel Exposure Criteria............................ 73 6.5.2 Decontamination and First Aid ............................................ 74 6.5.3 Medical Treatment................................................................. 74 7.0 EMERGENCY FACILITIES AND EQUIPMENT ........................................................... 79 7.1 ONSITE EMERGENCY FACILITIES............................................................ 79 7.1.1 Control Room ........................................................................ 79 7.1.2 Technical Support Center .................................................... 80 7.1.3 Operations Support Center (OSC) ....................................... 81 7.2 EMERGENCY OPERATIONS FACILITY (EOF) .......................................... 81 7.3 COUNTY AND STATE EMERGENCY CENTERS ....................................... 82 7.3.1 County Emergency Operations Centers ............................. 82 7.3.2 State Emergency Operations Center ................................... 82 7.4 JOINT INFORMATION CENTER (JIC) ........................................................ 83 7.5 COMMUNICATIONS EQUIPMENT.............................................................. 83 7.5.1 Routine Communications System ....................................... 83

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page vi TITLE: POST-SHUTDOWN EMERGENCY PLAN Table of Contents 7.6 ASSESSMENT EQUIPMENT SYSTEMS .................................................... 84 7.6.1 Radiation Monitoring System .............................................. 84 7.6.2 Meteorology........................................................................... 86 7.6.3 Fire Protection System ......................................................... 86 7.7 OFFSITE MONITORING .............................................................................. 87 7.7.1 Radiological Monitoring ....................................................... 87 7.7.2 Laboratory Facilities ............................................................. 87 7.8 FIRST AID AND MEDICAL CARE ............................................................... 88 7.8.1 First Aid and Medical Care ................................................... 88 7.8.2 First Aid Equipment .............................................................. 88 7.8.3 Decontamination and First Aid ............................................ 88 7.8.4 Medical Transportation......................................................... 88 7.8.5 Medical Treatment................................................................. 88 7.8.6 Use of Protective Equipment and Supplies ........................ 89 8.0 MAINTAINING EMERGENCY PREPAREDNESS ....................................................... 93 8.1 ORGANIZATION PREPAREDNESS ........................................................... 93 8.1.1 Training .................................................................................. 93 8.1.2 Drills and Exercises .............................................................. 94 8.1.3 Major Drills and Exercises ................................................... 95 8.1.4 Emergency Planning............................................................. 97 8.2 EDUCATIONAL INFORMATION FOR THE PUBLIC .................................. 98 8.3 REVIEW AND UPDATING OF THE POST-SHUTDOWN EMERGENCY PLAN AND IMPLEMENTING PROCEDURES ............................................ 98 8.4 MAINTENANCE AND INVENTORY OF EMERGENCY EQUIPMENT AND SUPPLIES .................................................................................................. 100 8.5 EMERGENCY EQUIPMENT NUCLEAR PERFORMANCE ASSESSMENT DEPARTMENT CONTROLS ..................................................................... 100 8.5.1 Meteorological Monitoring Program.................................. 100 8.5.2 Dose Assessment Computer Programs............................ 100 9.0 RECOVERY ............................................................................................................... 100

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page vii TITLE: POST-SHUTDOWN EMERGENCY PLAN Table of Contents Appendix A, "Agreements with Off-Site Individuals, Agencies, and Organizations" Appendix B, "Basis for Deletion of Appendix B of the Palisades Site Emergency Plan" Appendix C, "Evacuation Time Estimates," Revision 1, August 2012 prepared by KLD Engineering. (This document is relocated to SEP Supp 2, See below.)

Appendix D, "Emergency Implementing Procedures" Appendix E, "General Equipment in Emergency Kits" Appendix I, "NUREG-0654 Cross Reference" PSEP Supp 1, "POST-SHUTDOWN EMERGENCY PLAN Supplement 1 - EAL Wall Charts" (Note: PSEP Supp 1 is under separate cover with its own revision number.)

PSEP Supp 2, "Evacuation Time Estimates," Revision 1, August 2012 (Note: PSEP Supp 2 will be maintained in the same binder as the Post-Shutdown Emergency Plan with its own revision number.)

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 1 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN SOURCES AND REFERENCES SOURCE DOCUMENTS

1. NUREG-0654, Revision 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Procedures in Support of Nuclear Power Plants" (November 1980)

2. Title 10 of the Code of Federal Regulations, Part 50

3. P- EN-HU-106, "Procedure and Work Instruction Use and Adherence"

4. NUREG-0737 Supplement 1, "Clarification of TMI Action Plan Requirements"

5. Palisades Administrative Procedure 4.00, "Operations Organization, Responsibilities, and Conduct"

6. Abnormal Operating Procedure AOP-23, "Primary Coolant Leak"

7. Abnormal Operating Procedure AOP-24, "Steam Generator Tube Leak"

8. NEI 99-01 Revision 5, "Methodology for Development of Emergency Action Levels"

9. NRC Bulletin 2005-02: Emergency Preparedness and Response Actions for Security Based Events

10. Engineering Analysis, EA-JBB-01-04, "Failed Fuel Dose Rates on NSSS Piping"

11. P-EN-TQ-110, "Emergency Response Organization Training" REFERENCE DOCUMENTS

1. Regulatory Guide 1.70, Revision 2, "Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants"

2. Palisades Nuclear Plant Emergency Implementing Procedures

3. 10 CFR 50, "Domestic Licensing of Production and Utilization Facilities"

4. 10 CFR 100, "Reactor Site Criteria"

5. Palisades Final Safety Analysis Report

6. NUREG-0696, "Functional Criteria for Emergency Response Facilities" (February 1981)

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 2 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN

7. Palisades Safeguards Contingency Procedures

8. Palisades Health Physics Procedures

9. Palisades Abnormal Operating Procedures

10. Palisades Emergency Operating Procedures

11. Palisades Nuclear Plant Public Information Policies and Procedures

12. Palisades Fire Protection Plan

13. EPA 400-R-92-001, "Manual of Protective Action Guides and Protective Actions for Nuclear Incidents"

14. Palisades Administrative Procedure 4.00, "Operations Organization, Responsibilities and Conduct"

15. P-EN-OM-119, "On-Site Safety Review Committee"

16. Emergency Implementing Procedure EI-1, "Emergency Classification and Actions"

17. Emergency Implementing Procedure EI-2.2, "Emergency Staff Augmentation"

18. Emergency Implementing Procedure EI-3, "Communications and Notifications"

19. Emergency Implementing Procedure EI-4.1, "Technical Support Center Activation"

20. Emergency Implementing Procedure EI-4.2, "Operations Support Center Activation"

21. Emergency Implementing Procedure EI-4.3, "Emergency Operations Facility Activation"

22. Emergency Implementing Procedure EI-5.0, "Reentry"

23. Emergency Implementing Procedure EI-5.1, "Recovery"

24. Emergency Implementing Procedure EI-6, "Rapid Dose Calculation"

25. Emergency Implementing Procedure EI-6.1, "Release Rate Determination from Stack Gas Monitors"

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 3 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN

26. Emergency Implementing Procedure EI-6.2, "Release Rate Determination from Steam Line Monitors RIA-2323 and RIA-2324 for Steam Releases through Atmospheric Dump Valves"

27. Emergency Implementing Procedure EI-6.3, "Release Rate Determination from High-Range Effluent Monitors"

28. Emergency Implementing Procedure EI-6.4, "Release/Potential Release Determination from Containment High-Range Monitors"

29. Emergency Implementing Procedure EI-6.6, "Gamma E-Bar Determinations"

30. Emergency Implementing Procedure EI-6.7, "Plant Site Meterological System"

31. Emergency Implementing Procedure EI-6.8, "Backup and Supplemental Meteorology"

32. Emergency Implementing Procedure EI-6.9, "Automated Dose Assessment Program"

33. Emergency Implementing Procedure EI-6.10, "Offsite Dose Calculation - Straight Line Gaussian (Manual Method)

34. Emergency Implementing Procedure EI-6.13, "Protective Action Recommendations for Offsite Population"

35. Emergency Implementing Procedure EI-7.0, "Emergency Post Accident Sampling and Determination of Fuel Failure Using Dose Rates"

36. Emergency Implementing Procedure EI-7.10, "Post Accident Sampling, Radioactive Gaseous Effluent Monitoring"

37. Emergency Implementing Procedure EI-8, "Onsite Radiological Monitoring"

38. Emergency Implementing Procedure EI-9, "Offsite Radiological Monitoring"

39. Emergency Implementing Procedure EI-10, "Accident Environmental Assessment"

40. Emergency Implementing Procedure EI-11, "Determination of Extent of Core Damage"

41. Emergency Implementing Procedure EI-12.1, "Personnel Accountability and Assembly"

42. Emergency Implementing Procedure EI-12.3, "Search and Rescue Team Responsibilities"

43. Emergency Implementing Procedure EI-13, "Evacuation/Reassembly"

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 4 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN

44. Emergency Implementing Procedure EI-14, "Medical Care/Treatment of Contaminated, Injured Personnel"

45. Emergency Implementing Procedure EI-15.2, "Communications Tests"

46. Emergency Implementing Procedure EI-16.1, "Maintenance of Emergency Equipment"

47. Emergency Implementing Procedure EI-17, "Compensating Measures for OOS EAL Equipment and Listing of Non-EAL Equipment Important for Emergency Preparedness"

48. 10 CFR 20, "Standards for Protection Against Radiation"

49. Oil and Hazardous Materials Spill Prevention Plan

50. Palisades Technical Specifications

51. Act 390, Michigan Public Acts of 1976

52. Act 368, Michigan Public Acts of 1978

53. Michigan Emergency Management Plan

54. Van Buren County Emergency Plan

55. Allegan County Emergency Plan

56. Berrien County Emergency Plan

57. Palisades Administrative Procedure 1.14, "Meteorological Monitoring Program"

58. P-EN-IT-103, "Nuclear Cyber Security Program"

59. NEI 99-01 Revisions 5, "Methodology for Development of Emergency Action Levels"

60. NRC Bulletin 2005-02: Emergency Preparedness and Response Actions for Security Based Events

61. NEI White Paper dated November 18th, 2005, "Enhancements to Emergency Preparedness Programs for Hostile Action" (Endorsed by NRC RIS 2006-12)

62. POST-SHUTDOWN EMERGENCY PLAN Supplement 1 - "EAL Wall Charts" (Note:

PSEP Supp 1 is under separate cover with its own revision number.)

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 5 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN

63. POST-SHUTDOWN EMERGENCY PLAN Supplement 2 - "Evacuation Time Estimates" (Revision 1, August 2012) (Note: PSEP Supp 2 will be maintained in the same binder as the Site Emergency Plan.)

64. Engineering Analysis, EA-JBB-01-04, "Failed Fuel Dose Rates on NSSS Piping"

65. P-EN-TQ-110, "Emergency Response Organization Training"

66. P-EN-TQ-201, "Systematic Approach to Training Process"

67. P-EN-EP-308, "Emergency Planning Critiques"

68. P-EN-EP-306, "Drills and Exercises"

69. Palisades Nuclear Plant Analysis of Proposed Post-Shutdown On-Shift Staffing, Revision 0 dated August, 2017 conducted as required by 10CFR50, Appendix E, Section IV.A

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 6 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN INFORMATIONAL USE Procedure is available and referenced for review, but not necessarily at the work location.

Procedure may be performed from memory or referred to as needed.

User remains responsible for procedure adherence.

1.0 INTRODUCTION

The purpose of the Palisades Post-Shutdown Emergency Plan (PSEP) is to aid in protecting members of the general public, persons temporarily visiting the site, and site employees.

Information submitted in this plan was developed using the guidance provided in NUREG-0654, Revision 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Procedures in Support of Nuclear Power Plants,"

published in November 1980 and with Regulatory Guide 1.70, Revision 2, "Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants," dated September 1975.

Detailed procedures concerning the implementation of the Post-Shutdown Emergency Plan are not included here, but are included in the Palisades Nuclear Plant Emergency Implementing Procedures. These procedures describe the duties and actions of individuals and groups in the event of an emergency and also serve as an interface of the Post-Shutdown Emergency Plan with Plant operations, security, and radiological controls procedures. Selected elements of the Quality Program are applied to the Post-Shutdown Emergency Planning Function for the Palisades Plant.

1.1 DEFINITIONS 1.1.1 Accident Any unexpected or unintentional event resulting in radiological exposure, contamination, or physical injury to individuals requiring offsite medical treatment, and/or physical damage to safety-related components.

1.1.2 Activation Actions taken to staff and setup an emergency response facility to make it operational. Actions include, but are not limited to, notification of emergency personnel, equipment setup, and equipment operability testing.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 7 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN 1.1.3 Affected Persons Individuals who have been radiologically exposed or physically injured as a result of an accident to a degree requiring special attention, e.g., decontamination, first aid, or medical services.

1.1.4 Alarm An indication of abnormal Plant conditions and/or equipment status.

1.1.5 Alert Events are in process or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.

1.1.6 Annunciation An alarm or indication of normal or abnormal conditions.

1.1.7 Assessment Actions Those actions taken during or after an accident to provide data to make decisions.

1.1.8 Command and Control Resides with the Shift Manager or EOF Emergency Director following assumption of overall authority for Entergy Corporation emergency response. At minimum, this individual will assume responsibility for event classification, dose assessment, protective action recommendations, and notification of offsite authorities.

1.1.9 Control Room The location at Palisades Plant from which systems are controlled. The assembly area for Control Room personnel.

1.1.10 Control Room Personnel The credited on shift complement consists of a Shift Manager (qualified as a Certified Fuel Handler (CFH)) and two (2) Non-Certified Operators.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 8 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN 1.1.11 Corrective Actions Those emergency measures taken to lessen or terminate an emergency situation at, or near, the source of the problem.

1.1.12 Decontamination The removal of radioactive material from individuals, equipment, surfaces, foodstuffs, etc.

1.1.13 Emergency Any occurrence at the Palisades Nuclear Power Plant that may result in undue risk to the health and safety of the onsite personnel or the public.

1.1.14 Emergency Action Levels (EAL)

A predetermined, site-specific, observable threshold for a plant Initiating Condition that places 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 procedures; or another phenomenon which, if it occurs, indicates entry into a particular emergency class.

There are times when an EAL will be a threshold point on a measurable continuous function, such as a primary system coolant leak that has exceeded technical specifications.

At other times, the EAL lists a discrete event that places the plant in a particular emergency class.

1.1.15 Emergency Operations Facility (EOF)

An offsite emergency center from which the offsite emergency support actions of Entergy Corporation are controlled and coordinated with state, local, and federal authorities to mitigate the consequences of an emergency.

1.1.16 Emergency Implementing Procedures Specific procedures providing specific actions to implement the Post-Shutdown Emergency Plan in order to mitigate or terminate an emergency situation.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 9 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN 1.1.17 Emergency Planning Zones (EPZ)

Two zones that encircle the Palisades Plant. The primary EPZ plume exposure pathway, with a radius of 10 miles, has been established to prevent excessive airborne exposure, and the secondary EPZ, ingestion exposure pathway, with a radius of 50 miles, has been established to prevent excessive ingestion of contaminated food. Within these two zones, protective actions are described for the protection of the public.

1.1.18 Fitness For Duty Provide reasonable assurance that personnel who maintain unescorted access will perform their tasks in a reliable and trustworthy manner and are not under the influence of any substance, legal or illegal, or mentally or physically impaired from any cause, which in any way adversely affects their ability to safely and competently perform their duties.

1.1.19 Fully Operational Status of an Emergency Response Facility following assumption of all responsibilities.

1.1.20 General Emergency 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 offsite for more than the immediate site area.

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

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 10 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN 1.1.22 Hostile Force One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.

1.1.23 Ingestion Exposure Pathway The path affected by fallout from a radioactive plume. Of major concern is the contamination of food and water within the emergency planning zones.

1.1.24 Initiating Condition (IC): One of a predetermined subset of nuclear power plant conditions when either the potential exists for a radiological emergency, or such an emergency has occurred.

An IC is an emergency condition, which sets it apart from the broad class of conditions that may or may not have the potential to escalate into a radiological emergency.

It can be a continuous, measurable function that is outside technical specifications, such as elevated PCS temperature or falling reactor coolant level (a symptom).

1.1.25 Offsite All land and water areas outside the owner-controlled area.

1.1.26 Onsite All land and water areas within the owner-controlled area, use of which must be authorized by Entergy Corporation.

1.1.27 Operational Status of an emergency facility, declared by the appropriate facility manager upon determining that the facility is adequately staffed and equipment is setup and available to assume/perform the emergency functions assigned to that facility.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 11 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN 1.1.28 Operations Support Center (OSC)

The onsite area in which onsite support personnel can assemble for subsequent assignment to duties in support of emergency operations. Support personnel assigned to the OSC normally consist of Chemistry, Radiation Protection, and repairpersons from I&C, Electrical, and Mechanical Maintenance.

1.1.29 Owner Controlled Area The area surrounding the Plant in which the reactor licensee has the authority to determine all activities including exclusion or removal of persons and property from the area during accident conditions.

1.1.30 Plume Exposure Pathway The path by which a radioactive cloud (plume) can expose the population-at-risk and/or onsite personnel to radiation. The principle exposure sources for this pathway are:

a. Whole body external exposure to gamma radiation from the radioactive plume and from deposited material.

b. Inhalation exposure from the passing radioactive plume.

1.1.31 Population at Risk Those persons for whom protective actions are or would be taken.

1.1.32 Protective Actions Those emergency measures taken for the purpose of preventing or minimizing radiological exposures to individuals that would be likely to occur if the actions were not taken.

1.1.33 Protective Action Guides (PAG)

Projected radiological dose or dose commitment values to individuals in the general population that warrant protective action following a release of radioactive material.

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.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 12 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN 1.1.34 Protected Area The fenced area immediately surrounding the nuclear Plant, access to which is controlled in accordance with the Safeguards Contingency Procedures.

1.1.35 Radiological Emergency An emergency involving radioactive material.

1.1.36 Recovery Actions Those actions taken after the emergency to restore the Plant as nearly as possible to its pre-emergency condition.

1.1.37 Site Area Emergency 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 effective access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.

1.1.38 Emergency Plant Manager The person designated as responsible for all onsite actions during an emergency condition.

1.1.39 State The State of Michigan.

1.1.40 Technical Support Center (TSC)

An area which accommodates personnel which will provide management and technical support to Plant Operations personnel during emergency conditions from a location outside the Control Room.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 13 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN 1.1.41 Unusual Event 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.

2.0 SCOPE AND APPLICABILITY 2.1 GENERAL INFORMATION AND SITE DESCRIPTION The Palisades Nuclear Power Plant is owned by Entergy Corporation. An area map showing the location of the facility is provided in Figure 2-1.

The Palisades Nuclear Power Plant (PNP) ceased power operations and is permanently defueled in accordance with 10 CFR 50.82(a)(1)(i) and (ii). On January 4, 2017, Entergy Nuclear Operations (ENO) submitted a certification of permanent cessation of power operations pursuant to 10 CFR 50.82(a)(1)(i). ENO has submitted written certification to the NRC in accordance with 10 CFR 50.82(1)(ii) that meets the requirements of 10 CFR 50.4(b)(9) certifying that fuel has been permanently removed from the reactor vessel. Upon docketing of these certifications, the 10 CFR Part 50 license for PNP no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel, as specified in 10 CFR 50.82(a)(2).

With irradiated fuel being stored in the Spent Fuel Pool and the Independent Spent Fuel Storage Installation (ISFSI), the reactor coolant system and secondary systems have no function related to the storage of the irradiated fuel. Therefore, the postulated accidents involving failure or malfunction of the reactor and reactor coolant system or secondary systems are no longer applicable.

The Palisades Plant is located in Covert Township, Van Buren County, Michigan.

The Plant is bordered to the north by the Van Buren State Park and to the west by Lake Michigan. The south and east are sparsely populated, underdeveloped, or used for farming. Interstate 196 and the Blue Star Highway lie within one mile east of the site. Much of the area around the site is devoted to recreation and tourism, which produces a fluctuating and seasonal population.

Highway access to the Plant is provided from the Blue Star Highway (A-2) via the Plant access road.

2.2 POPULATION DISTRIBUTION AND EVACUATION TIMES

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 14 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN The area within a 10-mile radius surrounding the Palisades Plant is designated as the plume exposure Emergency Planning Zone (EPZ). A comprehensive population study was prepared in August 2012 by KLD Engineering. The Evacuation Time Estimates for the plume EPZ are adopted as a progeny procedure to Palisades Post-Shutdown Emergency Plan. See PSEP Supp 2, "Evacuation Time Estimates."

2.3 EMERGENCY PLANNING ZONES EPZs are areas designated for which planning is recommended to assure that prompt and effective actions are taken to protect the public in the event of an accident.

Two EPZs have been identified for the purpose of development and implementation of emergency planning. The plume exposure emergency planning zone has a 10 mile radius. Within this zone, shelter and/or evacuation is the immediate protective action to be recommended for the general public. The principal concern with the plume exposure pathway is that of Total Effective Dose Equivalent (TEDE) exposure and/or exposure to the adult thyroid Committed Dose Equivalent (CDE) due to inhalation and ingestion.

The ingestion exposure EPZ extends to a 50-mile radius. Once exceeding the 10-mile radius, the plume exposure pathway is no longer of significant concern.

At this point, the ingestion pathway is of greatest concern.

2.4 PURPOSES AND OBJECTIVES Effective emergency preparedness needs to incorporate not only the emergency response for systems, but must also include response for people. Engineering safety systems at the Plant are designed to ensure that the consequences of a major malfunction will be mitigated prior to any adverse effect to the general public or facility. The basis for emergency planning is to provide human emergency response in much the same way as safety systems do for design.

It is imperative that all plans, programs, and procedures be well coordinated with the Emergency Plan. Only when they are well coordinated can the response to emergencies be initiated in a timely and effective manner.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 15 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN 2.4.1 Regulatory Requirements 10 CFR 50, "Domestic Licensing Of Production and Utilization Facilities" Section 50.34, "Contents of Applications; Technical Information", requires that each application for a license to operate a facility include in a Final Safety Analysis Report (FSAR), along with other information, the applicant's plans for coping with emergencies, including the items specified in Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities," 10 CFR 50. Section 100.3, 10 CFR 100, "Reactor Site Criteria," in the definitions of exclusion area and low population zone, establishes additional criteria for plans to cope with emergencies and serious accidents. 10 CFR 50.47, "Emergency Plans," requires that adequate protective measures can and will be taken in the event of a radiological emergency.

Supplemental guidance has been provided by the Nuclear Regulatory Commission (NRC) by the following documents:

a. NUREG-0654, Revision 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plant" (November 1980).

b. NUREG-0696, "Functional Criteria for Emergency Response Facilities" (February 1981).

These documents describe methods acceptable to the NRC staff for compliance with the Commission's regulations in regard to the content of emergency plans for nuclear power plants including provisions for the periodic review and revision of the Emergency Plans.

2.4.2 Purpose of Emergency Preparedness The purpose of emergency preparedness is to provide a mechanism that would be used in making decisions in the event of an emergency, and to assure that the necessary equipment, supplies, and essential services are available to protect the health and safety of the public.

2.4.3 Objectives of the Palisades Post-Shutdown Emergency Plan The objectives of the Post-Shutdown Emergency Plan are to:

a. Establish criteria for classifying emergencies, performing notifications, activating emergency facilities, and activating portions of the emergency organization.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 16 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN

b. Establish an emergency organization and assign responsibilities in the emergency organization for classifying emergencies, performing notifications, performing onsite protective actions, performing dose assessments, and making recommendations to offsite authorities.

c. Identify the support that will be provided to the onsite emergency organization by the Entergy Corporation headquarters and offsite organizations (ie, fire, ambulance, medical).

d. Identify the offsite authorities that are responsible for taking protective actions on behalf of members of the general public or that interface with this Emergency Plan.

e. Identify emergency facilities and available communication systems to be used by the emergency organization.

f. Identify training for personnel in the emergency organization.

g. Provide for drills and exercises of the emergency organization.

h. Provide for periodic review and update of the plan.

2.5

SUMMARY

OF EMERGENCY PLAN INTERRELATIONSHIPS This Emergency Plan should not, in itself, be considered the sole working document to be used during an emergency. The purpose of the Emergency Plan is to classify emergencies according to their severity, to assign responsibilities for actions, and to clearly outline the most effective course of action required to safeguard the public and Plant personnel in the event of an emergency. Detailed instructions and guidelines for emergency actions are included in other plans, programs, and procedures as described below.

2.5.1 Post-Shutdown Emergency Plan Supplement 1 The "Post-Shutdown Emergency Plan Supplement 1 - EAL Wall Charts" contains the Palisades Emergency Action Levels in a wall chart format. It is part of the Post-Shutdown Emergency Plan. Changes to the supplement require all the same types of reviews and approvals as required for the Post-Shutdown Emergency Plan.

Revisions to the supplement will be tracked by its own revision number, not the PSEP's revision number.

The "Post-Shutdown Emergency Plan Supplement 1 - EAL Wall Charts" will be maintained in the same binder as the Post-Shutdown Emergency Plan.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 17 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN 2.5.2 Post-Shutdown Emergency Plan Supplement 2 The Post-Shutdown Emergency Plan Supplement 2 - "Evacuation Time Estimates (Revision 1, August 2012)" contains the Palisades updated Evacuation Time Estimates study (Revision 1, August 2012). It is part of the Post-Shhutdown Emergency Plan. Changes to the supplement require all the same types of reviews and approvals as required for the Post-Shutdown Emergency Plan. Revisions to the supplement will be tracked by its own revision number, not the PSEPs revision number.

The Post-Shutdown Emergency Plan Supplement 2 - "Evacuation Time Estimates" will be maintained in the same binder as the Post-Shutdown Emergency Plan.

2.5.3 Emergency Implementing Procedures Detailed Emergency Implementing Procedures required to implement the plan have been developed. An index of the Emergency Implementing Procedures is included in Appendix D.

Detailed implementing procedures for emergencies considered to be special events, such as civil disturbances, bomb threats, and breaches in security are included as part of the Safeguards Contingency Procedures.

Separate emergency procedures are not provided for activities already covered by Plant or section Operating Procedures (ie, calibration of survey instruments). The plan relies on certain aspects of the Plant's operating procedures, radiation protection procedures, and security procedures, where they are required for clarification.

2.5.4 Related Plans, Programs, and Procedures Several plans, programs, and procedures have been developed to assure the safe operation of the Plant. The Post-Shutdown Emergency Plan and Emergency Implementing Procedures have been written to coordinate these plans with other programs and procedures. During emergency situations, the coordination and utilization of all plans and procedures are essential.

The Safeguards Contingency Procedures have been coordinated with the Post-Shutdown Emergency Plan and Emergency Implementing Procedures to minimize the consequences of an emergency situation. Security procedures contain an explanation of the duties and responsibilities for security personnel in the event of an emergency.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 18 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN Provisions for radiological control at the Plant have been covered in Radiation Protection Procedures. These procedures establish controls and protective measures to be placed on work being conducted in radiation areas. Inclusive within the area of radiation control are the procedures that Radiation Protection establishes for determining exposure through surveys, analysis, and various other avenues.

The Palisades Nuclear Plant Public Information Policies and Procedures contain the information necessary to establish a flow of emergency information to the public.

The Palisades Fire Protection Plan has been developed to assure the safe operation of the Plant during a fire.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 19 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN FIGURE 2-1 PALISADES PLANT GENERAL LOCATION

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 20 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN FIGURE 2-2 PALISADES FACILITIES

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 21 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN FIGURE 2-3 PALISADES NUCLEAR PLANT SITE

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 22 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN 3.0 POST-SHUTDOWN EMERGENCY PLAN

SUMMARY

The Post-Shutdown Emergency Plan establishes the basic steps that will be used to determine the response of the emergency organization for each of four emergency classes. The emergency classes are as follows: Unusual Event, Alert, Site Area Emergency, and General Emergency. The conditions that must exist for the declaration of a specific emergency class are presented in the Post-Shutdown Emergency Plan, Supplement 1 - EAL Wall Charts.

The declaration of each class will lead to specific notification of offsite authorities.

Emergency facilities shall be activated as described in Table 3-1, "Emergency Classifications and the Level of Response by Participating Groups," and staffed as presented in Section 5 of the Palisades Post-Shutdown Emergency Plan. In response to a particular event, certain protective actions may be initiated or certain offsite agencies may be activated. These actions are detailed in Section 6 of the Palisades Post-Shutdown Emergency Plan. Palisades maintains the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded and promptly declares the emergency condition as soon as possible following identification of the appropriate emergency classification level.

For emergencies that result in (1) the release of radioactive materials greater than specified levels, or (2) the degradation of barriers to the release of radioactive materials, assessments of the offsite consequences or the projected offsite consequences shall be made. These assessments will be transmitted to the offsite authorities responsible for taking protective actions on behalf of the general public.

Recommendations to these offsite authorities will be based on the protective actions identified in Table 6-2 from the Palisades Post-Shutdown Emergency Plan.

3.1 POST-SHUTDOWN EMERGENCY PLAN STEPS In general, the Post-shutdown Emergency Plan encompasses the following basic steps:

a. Detection of the emergency

b. Classification of the emergency

c. Notification of offsite agencies

d. Activation of the responding organization(s)

e. Assessment of the situation

f. Initiation of protective actions

g. Initiation of corrective actions

h. Aid to affected persons

i. Reentry and recovery

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 23 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN 3.2 ENTERGY CORPORATION EMERGENCY ORGANIZATION This Post-Shutdown Emergency Plan establishes an organization capable of responding to the complete spectrum of incidents covered by this Post-Shutdown Emergency Plan. Provisions are made for rapid notification of appropriate portions of the response organization, and for expanding the response organization if the situation dictates.

An individual having the authority and responsibility to initiate any emergency actions within the provisions of this Post-Shutdown Emergency Plan, including the exchange of information with authorities responsible for coordinating offsite emergency measures, is onsite at all times. This individual is the Shift Manager until relieved by the Emergency Director.

The operating shift crew is responsible for implementing emergency action(s) in accordance with assigned response functions. Emergency response functions are also assigned to additional Plant staff personnel who are rapidly alerted and mobilized to augment or relieve the operating shift personnel of emergency duties as deemed appropriate by the Emergency Plant Manager, and in accordance with the implementing procedures of this Plan.

In addition, this Plan includes offsite agencies and organizations who have signed letters of agreement with Palisades Nuclear Power Plant (see Appendix A). Their designated response functions include implementation of offsite protective actions, transportation and treatment of personnel requiring medical treatment, control of access to the station, fire-fighting support, radiological sampling and assessment, technical consultation, and testing.

3.3 EMERGENCY CLASSIFICATIONS Emergencies are grouped into four classifications listed below in order of severity:

a. Unusual Event 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.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 24 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN

b. Alert Events are in process or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.

c. Site Area Emergency 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 effective access to equipment needed for the protection of the public.

Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.

d. General Emergency 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 offsite for more than the immediate site area.

Section 4 from the Palisades Nuclear Plant Post-Shutdown Emergency Plan contains a more detailed discussion of the classifications of emergencies. Table 3-1, "Emergency Classifications and the Level of Response by Participating Groups,"

shows, in column form, the emergency classifications, and the degrees of involvement of onsite and offsite organizations.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 25 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN 3.4 EMERGENCY ACTIONS In all instances, when one of the classifications of the above emergencies occurs in the Plant, the Shift Manager is responsible for taking immediate action to safeguard personnel and equipment. Utilizing the Palisades Nuclear Plant Emergency Implementing Procedures, the Shift Manager shall activate the necessary portions of the Post-Shutdown Emergency Plan. The basic considerations for safe operation of the Plant, and for action in the event of an emergency in the Plant, are summarized as follows:

a. In any event, protection of Plant personnel and the public is the highest priority. A range of protective actions to protect onsite personnel during hostile action is provided to ensure the continued ability to perform the functions of the emergency plan. Plant system and equipment protection is secondary.

b. When there is doubt as to the classification of the emergency condition, the more conservative case is considered.

c. The instrumentation is assumed to be providing correct information unless it is clearly identified that an instrument is erroneous or out of service.

d. All alarms are promptly acknowledged, any required response action is taken, and an immediate investigation of the cause that initiated the alarm is made.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 26 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN TABLE 3-1 EMERGENCY CLASSIFICATIONS AND THE LEVEL OF RESPONSE BY PARTICIPATING GROUPS SHIFT PLANT STAFF SUPPORT EMERGENCY RESPONSE NOTIFICATION RESPONSE RESPONSE Unusual Investigate. Shift Duty Station Supplement on-shift None Event Manager activates Manager, resources as needed.

appropriate Van Buren County, emergency team(s). State, and NRC.

Alert Investigate. Shift Duty Station TSC/OSC/EOF activation. Emergency Plant Manager activates Manager, Discretionary News Manager appropriate Van Buren County, Center activation. determines need emergency teams. State, NRC, and Supplement activated for offsite Required in-plant staff augmentation. emergency teams. support. Acquire protective actions Investigate event, assist offsite support as performed. shift personnel in required.

controlling Plant response. Assess radiological consequences.

Site Area Investigate. Shift Duty Station TSC/OSC/EOF/JIC Determine need Emergency Manager activates Manager, activation. Supplement for further offsite appropriate teams. Van Buren County, activated emergency support. Acquire Required in-plant State, NRC, and teams. Investigate event, offsite support as protective actions staff augmentation. assist shift personnel in required.

performed. controlling Plant response. Assess radiological consequences.

General Investigate. Shift Duty Station TSC/OSC/EOF/JIC Determine need Emergency Manager activates Manager, activation. Supplement for further offsite appropriate teams. Van Buren County, activated emergency support. Acquire Required Plant State, NRC, and teams. Investigate event, offsite support as protective actions staff augmentation. assist shift personnel in required.

performed. controlling Plant response. Assess radiological consequences. EOF Director provides protective action recommendations to offsite authorities.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 27 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN 4.0 POST-SHUTDOWN EMERGENCY CONDITIONS 4.1 EMERGENCY CLASSIFICATION SYSTEM This Post-Shutdown Emergency Plan provides four mutually exclusive classifications covering the postulated spectrum of emergency situations. For each classification, a particular set of immediate actions to be taken is established as described in Section 6, of the Post-Shutdown Emergency Plan. Actions for each of the four mutually exclusive classifications are defined in Emergency Implementing Procedure EI-1, "Emergency Classification and Actions," Attachment 1, "Emergency Actions."

The various classifications of accidents represent a hierarchy of accidents based on potential or actual hazards presented to the general public. Accidents may be classified in a lower category at first and then escalated to another higher classification if the situation deteriorates. Accident classification may be downgraded as conditions improve. The four classes that comprise the Emergency Classification System are:

a. Unusual Event

b. Alert

c. Site Area Emergency

d. General Emergency All emergency measures begin with the notification of the Shift Manager that a situation exists which presents a real or potential hazard. This is followed by assessment and evaluation by the Shift Manager, classification of the emergency, notifications, and activation and/or mobilization of the applicable emergency organizations. Section 6 summarizes the emergency measures to be taken by both the onsite and offsite emergency organizations.

Emergency Action Levels (EALs) are used to describe each of the four emergency classes. These levels are composed of a combination of Plant parameters (such as instrument readings and system status) that can be used to give relatively quick indication to the Plant operating staff of the severity of the accident situation.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 28 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN The purpose of the EAL is to provide the earliest possible identification of actual or potential accident situations. In most cases, further assessment action will be conducted both onsite and offsite before actual protective actions are initiated.

EALs associated with radioactive releases are related to the Environmental Protection Agency's Protective Actions Guides (PAG) summarized in EPA 400-R-92-001, "Manual of Protective Action Guides and Protective Actions for Nuclear Incidents." An assessment by the Plant emergency organization along with state support agencies of the potential of reaching or exceeding the PAG will be performed following the declaration of an emergency class.

When EALs are observed in conjunction with Plant or equipment status due to planned maintenance or testing activities, an emergency condition does not exist.

A conservative philosophy for classification shall be used to declare the highest classification for which an EAL has been exceeded. For example, a Site Area Emergency would be declared directly if a Site Area Emergency level is exceeded without having previously been declared in a lower Alert classification.

The Emergency Action Levels are not necessarily all inclusive. The Shift Manager/EOF Emergency Director shall declare an appropriate emergency classification whenever, in their personal judgment, the Plant status warrants such a declaration.

Palisades Emergency Action Levels can be found in the "Post-Shutdown Emergency Plan Supplement 1 - EAL Wall Charts."

4.1.1 Unusual Event The Unusual Event is the least severe of the four emergency classifications. For the purposes of this plan, an Unusual Event is defined as that situation where, "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."

The purpose of the Unusual Event declaration is to:

a. Assure that the first step in any response later found to be necessary has been carried out.

b. Bring the Plant operations staff to a state of readiness.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 29 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN

c. Provide systematic handling of Unusual Events information and decision-making.

Guidelines for Plant, State, and local actions are listed in Table 4-1.

An incident shall be classified as an Unusual Event if the event is minor in nature, involves no releases of radioactive material requiring offsite response or monitoring, and presents no immediate hazard to the public. Events in this classification are selected based upon a potential to degenerate to a more severe situation rather than an actual public hazard.

4.1.2 Alert An Alert is defined as that situation where, "Events are in process or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels." The Alert class involves relatively minor emergency situations that have a direct effect on the Plant safety-related systems. The Alert shall set into motion personnel onsite and offsite who would be required to perform actions up to and including the evacuation of near-site areas. The Alert class also addresses limited releases of radioactive material and, therefore, might require some assessment actions by the emergency organizations.

The purpose of the Alert declaration is to:

a. Assure that emergency personnel are readily available to respond if the situation becomes more serious or to perform confirmatory radiation monitoring if required.

b. Provide offsite authorities current status information.

Guidelines for Plant, State, and local actions are listed in Table 4-1.

An incident shall be classified as an Alert if there is real or potential limited releases of radioactive material to the environment. A situation shall be classified at the Alert level only if EALs for higher classification have not been exceeded or are not expected to be exceeded in the near term.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 30 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN 4.1.3 Site Area Emergency A Site Area Emergency is defined as that situation where, "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 effective access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.

The purpose of the Site Area Emergency declaration is to:

a. Assure that emergency response facilities are manned.

b. Assure that radiation-monitoring teams are dispatched both onsite and offsite.

c. Assure that personnel required for evacuation of near-site areas are at their duty stations if the situation becomes more serious.

d. Provide consultation with offsite authorities.

e. Provide updates for the public through offsite authorities.

Guidelines for Plant, State, and local actions are listed in Table 4-1. Although immediate protective actions are not automatically required, declaration of a Site Area Emergency shall set into motion all personnel onsite and offsite who would be required to perform actions up to and including the evacuation of near-site areas.

Dispatched radiation monitoring teams will make continuing assessments to provide officials with information to decide protective actions. The Site Area Emergency classification includes accidents that have significant radiation release potential.

Unlike the Unusual Event and Alert classifications of emergencies, the Site Area Emergency classification may involve some radiation exposure to the near-site public. Many of the accidents included in this classification have the potential for degradation to the General Emergency classification. Although the EALs for this classification have been selected at values well below the EPA PAGs, offsite monitoring team reports and continuing assessment actions shall lead to any final decision on protective actions to be taken.

Accidents that have significant potential for the release of radioactive material shall be classified as a Site Area Emergency.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 31 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN 4.1.4 General Emergency The General Emergency is the most severe classification of emergency. The General Emergency classification is defined as that situation where, "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 offsite for more than the immediate site area."

The purpose of the General Emergency declaration is to:

a. Initiate predetermined protective actions for the public.

b. Provide continuous assessment of information from Palisades Plant, and offsite monitoring groups.

c. Initiate additional measures as indicated by event releases or potential releases.

d. Provide consultation with offsite authorities.

e. Provide updates for the public through offsite authorities.

Guidelines for Plant, State, and local actions are listed in Table 4-1. Some protective actions may be recommended upon declaration of the General Emergency since the lower limits of the EPA PAGs are likely to be exceeded.

Emergency Action Levels (EAL) have been selected so that time should be available to make some confirmatory measurements in the field prior to implementation of the more extensive (i.e., evacuation) protective action. Some of the General Emergency action levels require a dose projection calculation using actual meteorology. This differs from the adverse meteorology assumptions used in the Site Emergency Action Levels in order to remove this built-in conservatism and to preclude declaring a General Emergency when actual conditions do not warrant the higher classification. Declaration of a General Emergency requires a recommendation to the State for protective actions for the local population.

4.2 CLASSIFICATION OF POSTULATED ACCIDENTS The events postulated in Section 14, Palisades Plant Final Safety Analysis Report (FSAR), may be categorized into one or more of the four emergency classifications. A complete discussion of these events may be found in the FSAR.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 32 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN TABLE 4-1 GUIDELINES FOR PLANT, STATE AND LOCAL ACTIONS STATE AND/OR LOCAL OFFSITE CLASS LICENSEE ACTIONS AUTHORITY ACTIONS UNUSUAL EVENT Class Description Events are in process or have 1. Promptly inform state and local offsite 1. Provide fire or security occurred which indicate a authorities of nature of unusual assistance if requested.

potential degradation of the level condition as soon as discovered.

of safety of the plant or indicate 2. Escalate to a more severe a security threat to facility 2. Augment on-shift resources as class, if appropriate.

protection has been initiated. needed.

No releases of radioactive 3. Stand by until verbal closeout.

material requiring offsite 3. Assess and respond.

response or monitoring are expected unless further 4. Escalate to a more severe class, if degradation of safety systems appropriate, occurs.

or Purpose

5. Close out with verbal summary to Purpose of offsite notification is offsite authorities; followed by written to: (1) assure that the first step summary.

in any response later found to be necessary has been carried out, (2) bring the operating staff to a state of readiness, and (3) provide systematic handling of Unusual Events information and decision making.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 33 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN TABLE 4-1 GUIDELINES FOR PLANT, STATE AND LOCAL ACTIONS STATE AND/OR LOCAL OFFSITE CLASS LICENSEE ACTIONS AUTHORITY ACTIONS ALERT Class Description Events are in process or have 1. Promptly inform state and local offsite 1. Provide fire or security occurred which involve an actual authorities of Alert status and reason assistance if requested.

or potential substantial for emergency as soon as discovered.

degradation of the level of safety 2. Augment resources and bring of the plant or a security event 2. Augment resources by activating primary response centers and that involves probable life onsite Technical Support Center, Emergency Alert System to threatening risk to site personnel onsite Operations Support Center, and standby status.

or damage to site equipment near-site Emergency Operations because of HOSTILE ACTION. Facility (EOF). 3. Alert to standby status key Any releases are expected to be emergency personnel limited to small fractions of the 3. Assess and respond. including monitoring teams EPA Protective Action Guideline and associated exposure levels. 4. Dispatch onsite monitoring teams and communications.

associated communications.

Purpose 4. Provide confirmatory off-site

5. Designate an individual for Plant status radiation monitoring and Purpose of the Alert is to updates to offsite authorities. ingestion pathway dose (1) assure that emergency projections if actual releases personnel are readily available 6. Provide meteorological data to off site substantially exceed Technical to respond if situation becomes authorities and if any releases are Specification limits.

more serious or to perform occurring, dose estimates for actual confirmatory radiation releases. 5. Escalate to a more severe monitoring if required, and class, if appropriate.

(2) provide offsite authorities 7. Escalate to a more severe class, if current status information. appropriate 6. Maintain Alert status until verbal closeout or reduction of or emergency class.

8. Close out or recommend reduction in emergency class by briefing of offsite authorities and by phone followed by written summary.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 34 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN TABLE 4-1 GUIDELINES FOR PLANT, STATE AND LOCAL ACTIONS STATE AND/OR LOCAL OFFSITE CLASS LICENSEE ACTIONS AUTHORITY ACTIONS SITE AREA EMERGENCY Class Description Events are in process or have 1. Promptly inform state and local offsite 1. Provide any assistance occurred which involve an actual authorities of Site Area Emergency requested.

or likely major failures of plant status and reason for emergency as functions needed for protection soon as discovered. 2. If sheltering near the site is of the public or HOSTILE desirable, activate public ACTION that results in 2. Augment resources by activating notification system within at intentional damage or malicious onsite Technical Support Center, least two miles of the Plant.

acts; (1) toward site personnel onsite Operations Support Center, and or equipment that could lead to near-site Emergency Operations 3. Provide public within at least the likely failure of or; (2) that Facility (EOF). about 10 miles periodic prevent effective access to updates on emergency status.

equipment needed for the 3. Assess and respond.

protection of the public. Any 4. Augment resources by releases are not expected to 4. Dispatch onsite and offsite monitoring activating primary response result in exposure levels which teams and associated centers.

exceed EPA Protective Action communications.

Guideline exposure levels 5. Dispatch key emergency beyond the site boundary. 5. Designate an individual for Plant status personnel including monitoring updates to offsite authorities and teams and associated Purpose periodic press briefings (perhaps joint communications.

with offsite authorities).

Purpose of the Site Area 6. Alert to standby status other Emergency declaration is to: 6. Make senior technical and emergency personnel (1) assure that response centers management staff onsite available for (eg, those needed for are manned, (2) assure that consultation with NRC and state on a evacuation) and dispatch monitoring teams are periodic basis. personnel to near-site duty dispatched, (3) assure that stations.

personnel required for 7. Provide meteorological and dose evacuation of near-site areas estimates to offsite authorities for 7. Provide off-site monitoring are at duty stations if situation actual releases via a designated results to licensee, DOE, and becomes more serious, individual or automated data others and jointly assess (4) provide consultation with transmission. them.

offsite authorities, and (5) provide updates for the Cont'd on next page. Cont'd on next page.

public through offsite authorities.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 35 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN TABLE 4-1 GUIDELINES FOR PLANT, STATE AND LOCAL ACTIONS STATE AND/OR LOCAL OFFSITE CLASS LICENSEE ACTIONS AUTHORITY ACTIONS SITE AREA EMERGENCY (cont)

8. Provide release and dose projections 8. Continuously assess based on available Plant condition information from licensee and information and foreseeable offsite monitoring with regard contingencies. to changes to protective actions already initiated for

9. Escalate to a General Emergency public and mobilizing class, if appropriate. evacuation resources.

or 9. Recommend placing milk animals within 10 miles on stored feed and assess need

10. Close out or recommend reduction in to extend distance.

emergency class by briefing of offsite authorities and by phone followed by 10. Provide press briefings with written summary licensee.

11. Escalate to General Emergency class, if appropriate.

12. Maintain General Emergency status until closeout or reduction of emergency class.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 36 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN TABLE 4-1 GUIDELINES FOR PLANT, STATE AND LOCAL ACTIONS STATE AND/OR LOCAL OFFSITE CLASS LICENSEE ACTIONS AUTHORITY ACTIONS GENERAL EMERGENCY Class Description Events are in process or have 1. Promptly inform state and 1. Provide any assistance occurred which involve actual or local offsite authorities of requested.

imminent substantial core General Emergency status degradation or melting with and reason for emergency 2. Activate immediate public potential for loss of containment as soon as discovered notification of Emergency integrity or HOSTILE ACTION (parallel notification of status and provide public that results in an actual loss of state/local). periodic updates.

physical control of the facility.

Releases can be reasonably 2. Augment resources by 3. For actual or projected expected to exceed EPA activating onsite Technical severe core damage Protective Action Guideline Support Center, and onsite accidents or loss of control exposure levels offsite for more Operations Support Center of facility, recommend than the immediate site area. and near-site Emergency evacuation for 2 mile radius Operations Facility (EOF). and 5 miles downwind Purpose (unless conditions make

3. Assess and respond. evacuation dangerous) and Purpose of the General assess need to extend

4. Dispatch onsite and offsite distances. Advise the Emergency declaration is to: monitoring teams and (1) initiate predetermined remainder of plume EPZ to associated go indoors and listen to protective actions for the public, communications.

(2) provide continuous Emergency Alert assessment of information from 5. System (EAS) messages.

Designate an individual for licensee and offsite organization Plant status updates to 4. Augment resources by measurement, (3) initiate offsite authorities and activating primary response additional measures as periodic press briefings centers.

indicated by actual or potential (perhaps joint offsite releases, (4) provide authorities). 5. Dispatch key emergency consultation with offsite personnel including authorities, and (5) provide 6. Make senior technical and monitoring teams and updates for the public through management staff onsite associated communications.

offsite authorities. available for consultation with NRC and state on a 6. Dispatch other emergency periodic basis. personnel to duty stations within five-mile radius and

7. Provide meteorological and alert all others to standby dose estimates to offsite status.

authorities for actual releases via a designated 7. Provide offsite monitoring individual or automated results to licensee, DOE, data transmission. and others and jointly assess them.

Cont'd on next page.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 37 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN TABLE 4-1 GUIDELINES FOR PLANT, STATE AND LOCAL ACTIONS STATE AND/OR LOCAL OFFSITE CLASS LICENSEE ACTIONS AUTHORITY ACTIONS GENERAL EMERGENCY (cont)

8. Provide release and dose 8. Continuously assess projections based on information from licensee available Plant condition and offsite monitoring with information and foreseeable regard to changes to contingencies. protective actions already initiated for public and

9. Close out or recommend mobilizing evacuation reduction in emergency resources.

class by briefing of offsite authorities at EOF and by 9. Recommend placing milk phone followed by written animals within 10 miles on summary. stored feed and assess need to extend distance.

10. Provide press briefings with licensee.

11. Maintain General Emergency status until closeout or reduction of emergency class.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 38 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN 5.0 ORGANIZATIONAL CONTROL OF EMERGENCIES Emergency planning must consider the capabilities of the normally present operating staff, augmented by support from other utility personnel and local and distant support. The initial phases of an emergency situation at a permanently shutdown and defueled nuclear power plant will involve a relatively small number of individuals. These individuals must be capable of: (1) determining that an emergency exists, (2) providing initial classification and assessment, and (3) promptly notifying other groups and individuals in the emergency organization.

The Palisades Plant Organization has complete capability, at all times, to perform the detection, classification, and notification functions required in the early phases of an emergency. These capabilities are augmented, as required, by the Palisades Emergency Response Organization (ERO).

This section of the Post-Shutdown Emergency Plan addresses the assignment of personnel and the establishment of responsibilities and authority for the:

a. Palisades Plant Organization

b. Palisades Emergency Response Organization Figure 5-1 shows the interfaces between these organizations, governmental agencies, and the general public.

5.1 PALISADES PLANT ORGANIZATION The Palisades Nuclear Plant shift activities are under the control of the General Manager, Plant Operations. The shift activities at the Plant are conducted by operating crews on twelve-hour shifts. Each twelve-hour shift is responsible for continuous operation of the Plant.

5.2 OPERATING AND ENGINEERING ORGANIZATION The Palisades Plant organization includes personnel encompassing both the management and operations staff. The minimum on-shift staffing is indicated in Figure 5-2.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 39 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN 5.2.1 GENERAL MANAGER, PLANT OPERATIONS The General Manager, Plant Operations is responsible for the technical and administrative management of the day-to-day physical operation of the Plant; this includes Operations, Chemistry and Radiological Services, Maintenance, and Planning and Scheduling.

5.2.2 Director - Emergency Programs The Director, Emergency Programs, is directly responsible for Entergy Emergency Preparedness, including: company-wide projects, National emergency interfaces, and regulatory issues.

5.2.3 Director - Engineering The Director - Engineering is responsible for system and design engineering, nuclear engineering, engineering programs, dry fuel services, and nuclear fuel supply.

5.2.4 Regulatory and Performance Improvement Director The Regulatory and Performance Improvement Director provides onsite oversight/supervision for emergency planning.

5.2.5 Duty Station Manager This is a rotating position among qualified Plant upper management (as defined by the General Manager, Plant Operations). The Duty Station Manager functions as the General Manager, Plant Operations on backshifts and weekends.

5.2.6 Shift Manager The Shift Manager, one of whom is on duty at all times, is responsible for the safe and efficient operation of the Plant during his assigned shift. The Shift Manager maintains control over Plant operations as the Certified Fuel Handler (CFH) unless properly relieved by another Shift Manager. In an emergency condition, the Shift Manager initially assumes the role of Emergency Director.

5.2.7 DELETED 5.3 PALISADES EMERGENCY RESPONSE ORGANIZATION In the event of an emergency in which one of the classification levels is declared (Unusual Event, Alert, Site Area Emergency, or General Emergency), all or a portion

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 40 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN of the Post-Shutdown Emergency Plan will be activated. The assignment of responsibilities in the Emergency Response Organization (ERO) is ultimately the responsibility of the General Manager, Plant Operations. However, the ERO is predefined and alternate assignments to various positions are specified to provide for automatic, unambiguous staffing of the emergency organization within the time necessary to respond to the emergency.

In general, the emergency organization will be housed in five emergency response centers:

a. Control Room

b. Technical Support Center

c. Operations Support Center

d. Emergency Operations Facility

e. Joint Information Center 5.3.1 Control Room The Control Room is designed to be habitable under accident conditions and shall serve as the on-site Emergency Control Center. Emergency lighting, power, air filtration-ventilation system, and shielded walls enable the operators to remain in the Control Room to ensure that the plant remains in a safe condition. The minimum on-shift staffing is indicated in Figure 5-2.

5.3.2 Technical Support Center The Technical Support Center (TSC) will provide Plant management and technical support to Operations personnel during emergency conditions and guidance to Control Room operating personnel to mitigate the effects of the emergency condition.

The TSC organization can be found in Emergency Implementing Procedure EI-4.1, "Technical Support Center Activation."

5.3.3 Operations Support Center The Operations Support Center (OSC) will coordinate Emergency Maintenance, Radiation Protection, and Chemistry activities of Plant personnel. The Control Room or TSC (when activated) will direct the priorities for the OSC. The OSC organization

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 41 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN can be found in Emergency Implementing Procedure EI-4.2, "Operations Support Center Activation."

5.3.4 Emergency Operations Facility (EOF)

The Emergency Operations Facility (EOF) is located in downtown Benton Harbor, approximately 16 miles South Southwest from the Plant. The EOF staff is responsible for overall management of an emergency and for communicating with external agencies upon transfer of responsibility from the Control Room.

Activation of the EOF is mandatory at the Alert, Site Area, and General Emergency Classifications. Activation of the EOF at an Unusual Event will be at the request of the Shift Manager. The EOF will be staffed by Plant personnel. The initial staff may be supplemented by federal, state, and local officials.

Once activated and operational, the EOF Emergency Director will be responsible for management of overall emergency response. The EOF will coordinate emergency response activities with federal, state, and local agencies to mitigate the consequences of an emergency. The EOF organization can be found in Emergency Implementing Procedure EI-4.3, "Emergency Operations Facility Activation."

The EOF provides an alternative facility, with communications capabilities for contacting the Control Room and plant security, to serve as a staging area for augmented emergency response staff if the site is under threat of, or experiencing hostile action.

The design features of the EOF are discussed in Palisades Post-Shutdown Emergency Plan, Section 7.0, "Emergency Facilities and Equipment."

5.3.5 Joint Information Center (JIC)

The plant Communications personnel shall be responsible for maintenance of the Palisades Nuclear Plant Public Information Policies and Procedures. These provide for disseminating information to the public via the media and establishing a system for rumor control during an emergency. Public Affairs personnel shall coordinate the activation and management of the Joint Information Center (JIC) in cooperation with the Corporate Public Affairs Department. Public Affairs personnel shall prepare and issue press releases in cooperation with state and local agencies. Reference Palisades Nuclear Plant Emergency Public Information Policies and Procedures for details.

5.4 EMERGENCY STAFFING

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 42 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN Normal Plant staffing provides sufficient personnel for continuous protracted emergency operation. The extent to which the emergency organization is activated is dependent upon the classification of the emergency. A method for emergency staff augmentation is available to the Shift Manager. Figure 5-2 provides requirements for minimum additional staffing and required arrival times. Details of emergency staff augmentation are available in Emergency Implementing Procedure EI-2.2, "Emergency Staff Augmentation."

5.4.1 Shift Manager/EOF Emergency Director The Shift Manager/EOF Emergency Director is responsible for the overall assessment of emergency conditions, especially where emergency conditions present a real or potential hazard to off-site persons or property. The Shift Manager/EOF Emergency Director will have the overall responsibility for operational decisions involving the safety of the Plant and its personnel, and for making recommendations based on technical information supplied by support personnel regarding the general public during an emergency situation. The Shift Manager/EOF Emergency Director will also implement the Palisades Post-Shutdown Emergency Plan through the use of specific Emergency Plan Implementing Procedures. The Shift Manager/EOF Emergency Director is responsible for ensuring the capability for continuous operation of emergency response centers, including personnel and material resources. In addition, the Shift Manager/EOF Emergency Director is responsible for providing off-site officials with pertinent information regarding the conditions at the Plant.

Any conflicts that should arise between the Emergency Plant Manager and the NOTE:

EOF Emergency Director will be resolved by the Site Vice President.

5.4.2 Shift Manager/Emergency Plant Manager The Shift Manager/Emergency Plant Manager may not delegate the decision to evacuate the site or the decision to authorize exposures that exceed the 10 CFR 20 regulatory exposure limits for emergency workers.

Prior to activation of the EOF, the decision to recommend protective actions to off-site organizations also cannot be delegated. The EOF Director, in consultation with the Shift Manager, will assume this responsibility after the EOF is activated.

For backshifts and weekends, the Duty Station Manager assumes the role of the Plant General Manager.

The Shift Manager assumes the responsibilities of the Post-Shutdown Emergency NOTE:

Plan until relieved by the EOF Director.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 43 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN The Emergency Plant Manager shall be assigned to the Technical Support Center once it is activated.

5.5 RECOVERY ORGANIZATION Recovery after an emergency condition will be handled by the emergency organization unless conditions indicate that recovery will be complicated or will take a long period of time. At the discretion of the EOF Emergency Director, the Plant will shift from an emergency organization structure to a Recovery Organization.

Guidelines that will be employed for determining this shift are explained in Palisades Post-Shutdown Emergency Plan, Section 9.0, "Recovery."

The Recovery Organization will depend upon the nature of the accident and the situations preceding the accident.

The TSC Engineering Coordinator will also support the EOF Rad Assessment Coordinator in determining how much radioactivity potentially can be released to the atmosphere based on the nature and extent of spent fuel damage.

5.6 OFF-SITE EMERGENCY RESPONSE SERVICES The potential consequences of some emergencies may require the support services of off-site individuals, organizations, and agencies. As a result, local support service arrangements have been made with offsite groups to provide onsite aid in the event of an emergency situation, including those resulting from hostile actions. Support services encompass such areas as medical assistance, fire control, evacuation, ambulance services, and law enforcement. Written agreements are entered into to assure these individuals'/agencies'/organizations' availability and capabilities. In the written agreements, the agencies have outlined their responsibilities or have agreed to their responsibilities as outlined in this section. A listing of the letters of agreement, contracts, or signature pages has been included in Appendix A. In those cases where agency assistance is mandated by law (i.e., the State of Michigan), a letter of agreement may be excluded from the Plan. The services provided by local support groups are listed in the following sections.

5.6.1 Medical Services The primary hospital facility for the treatment of serious medical emergencies occurring at the Plant is South Haven Community Hospital, located in South Haven, Michigan, approximately 6 miles from the Plant. South Haven Community Hospital is equipped to receive and treat all types of accident victims, including those with radioactive contamination. The backup medical facility is Lakeland Regional Medical Center, located approximately 20 miles from the Plant in St Joseph, Michigan.

The hospital shall be notified of incoming accident victims at the direction of the

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 44 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN Emergency Director. The hospital may contact the Plant by telephone in the event information is required in the treatment of a victim.

Ambulance service for the transportation of accident victims, including radioactively contaminated victims, is provided by the Covert Fire Department, with backup services provided by South Haven Ambulance Service and Medic I of Benton Harbor.

The ambulance units and Emergency Medical Technicians are trained and equipped to respond to a medical emergency at the Plant. The Shift Manager is responsible for the decision to request off-site medical support. The ambulance service shall be notified at the direction of the Shift Manager. Contact with the ambulance may be maintained through the respective medical service dispatcher.

5.6.2 Fire-Fighting Services When it is determined by the Emergency Director that off-site fire support is necessary, fire protection response will be by the Covert Fire Department with mutual aid provided by the Van Buren County Mutual Aid Pact. Contact may be made using the telephone system. Fire Department personnel will be trained in handling emergency situations for nuclear facilities.

In addition to their fire suppression capabilities, the fire departments will provide specially equipped vehicles and personnel trained for emergency rescue and other contingencies.

5.6.3 Law Enforcement Agencies In the event of a civil disturbance or criminal act, the Michigan State Police, Van Buren County Sheriff Department, and the Covert Township Police Department may provide law enforcement assistance.

An Auto-Dial line exists to the Michigan State Police Operations in Lansing, Michigan and the Van Buren County Sheriff Department in Paw Paw, Michigan.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 45 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN 5.6.4 Van Buren County Office of Domestic Preparedness The Van Buren County Office of Domestic Preparedness is located in the County Sheriff's Courthouse Annex, Paw Paw, Michigan. In the event of an emergency, Van Buren County Sheriff's Department will disseminate information and recommendations initially supplied by Entergy Corporation to the Chairman of the Van Buren County Board of Commissioners, Van Buren County Domestic Preparedness Director, and the Emergency Operations Center (EOC), if activated.

Section 7.0, "Emergency Facilities and Equipment," summarizes communications.

The Chairman of the Van Buren County Board of Commissioners is responsible for activation of the county's Emergency Operations Plan. The Van Buren County Domestic Preparedness Director is responsible for overall coordination and planning of emergency response activities within the county. The Director will implement the activation and operational aspects of the EOC and alert key officials and agencies.

The Director will coordinate efforts with other agencies to inform the public in affected portions of the county to take protective actions when conditions warrant.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 46 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN 5.6.5 Berrien County Emergency Management The Berrien County Emergency Operations Center (EOC) is located in Benton Harbor, Michigan. The Chief of Staff (Director of Emergency Management) is responsible for overall coordination of emergency operations in Berrien County in the event of an emergency. The Chief of Staff operates under the direction of the Chief Executive (Chair, Berrien County Board of Commissioners). Berrien County Sheriff's Department will disseminate information and recommendations initially supplied by Entergy Corporation to the Chief of Staff and/or the Emergency Management Coordinator and the Emergency Operations Center (EOC), if activated. Post-Shutdown Emergency Plan, Section 7.0, "Emergency Facilities and Equipment," summarizes communications.

The Chief Executive (Chair, Berrien County Board of Commissioners) is responsible for activation of the County's Emergency Operations Plan and for overall coordination and planning of emergency operations with Van Buren County until this information and direction is provided by the State of Michigan. The Chief of Staff (Director of Emergency Management) is responsible for initiating the staffing of the EOC. By prior agreement between counties, communications between the Plant and Berrien County will normally be directed through Van Buren County.

5.6.6 Allegan County Office of Emergency Preparedness The Allegan County Office of Emergency Management is located at the Allegan County Office Complex, Allegan, Michigan. In the event of an emergency, Allegan County Sheriff's Department will disseminate information and recommendations initially supplied by Entergy Corporation to the Chairperson of the Allegan County Board of Commissioners, Allegan County Emergency Management Director, and the Emergency Operations Center (EOC), if activated. By prior agreement between the counties, communications between the Plant and Allegan County will normally be directed through Van Buren County. Palisades Post-Shutdown Emergency Plan, Section 7.0, "Emergency Facilities and Equipment," summarizes communications.

The Chairperson of the Allegan County Board of Commissioners is responsible for the activation of the County's Emergency Operations Plan. The Allegan County Emergency Management Director is responsible for overall coordination and planning of emergency response activities within the county. The Emergency Management Director will implement activation of the EOC and alert key officials and agencies.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 47 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN 5.7 COORDINATION WITH GOVERNMENTAL AGENCIES The coordination between the state, county, and federal emergency plans and the Palisades Post-Shutdown Emergency Plan serves to ensure the safety and health of the public. The coordination of the emergency plans enables all organizations to participate without confusion or hesitation in regard to their responsibilities. All participating agencies should have a clear picture of the roles they play during an emergency situation. As a part of the coordination effort, each participating agency is assigned specific responsibilities and authority in regard to both emergency planning and emergency response. Written agreements with governmental agencies are included in Appendix A, "Agreement With Offsite Individuals, Agencies, and Organizations."

5.7.1 State of Michigan Agencies State agencies are under the direction of the Governor of the State of Michigan.

a. Michigan State Police Emergency Management and Homeland Security Division (MSP/EMHSD)

The State Police Emergency Management and Homeland Security Division is the leading state agency for emergency response planning and operations.

This agency is under the direction of the State Director of Emergency Management. Responsibilities of this group include:

1. Development and maintenance of the Michigan Emergency Management Plan and assistance to the counties in developing their individual emergency operations plans.

2. Recommendations to the Governor of the State of Michigan regarding emergency measures.

3. Arranging training programs for state and local agencies designed to promote effective response to radiological incidents.

4. Providing communications, radiological monitoring, and other available support to affected local governments.

5. Coordinating the support of other state agencies or political subdivisions near the affected area and obtaining the assistance of federal agencies as required.

The normal point of contact for the Palisades Plant is through the Operations Division of the Michigan State Police in Lansing.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 48 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN The Palisades Plant will support the State Police by providing specific information pertaining to the nature of the incident, recommendations on protective actions, and other available information and technical guidance.

b. Michigan State Police - Paw Paw Post Michigan State Police (MSP) is responsible for providing emergency traffic control and other available assistance. The MSPs nearest post is located in Paw Paw, Michigan with direct radio communications to Van Buren, Allegan, and Berrien Counties. Communications are detailed in Palisades Post-Shutdown Emergency Plan, Section 7.0, "Emergency Facilities and Equipment."

c. Michigan Department of Transportation Michigan Department of Transportation (MDOT) assists in emergency traffic regulation coordination with the Michigan State Police, the Sheriff, and the County Road Commission of the affected county.

d. Michigan Department of Environmental Quality (DEQ)

The Michigan Department of Environmental Quality, Radiological Protection Section located in Lansing is responsible for administering and directing radiation control programs and activities within the state. Their Radcon Field Team provides direct radiological emergency response capability during emergency conditions. The team's responsibilities include:

1. Moving immediately to the affected area and performing radiological monitoring, as appropriate.

2. Determining and reporting the nature and scope of the hazard.

3. Providing state government with technical guidance, recommending appropriate emergency countermeasures and recovery actions, and otherwise assisting the affected community.

The Department of Environmental Quality, Radiological Protection Section is responsible for providing the public with health hazard evaluation, guidance, or protective actions and other pertinent information concerning radiological incidents.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 49 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN

e. Michigan Department of Health and Human Service The Michigan Department of Health and Human Services is responsible for coordinating emergency medical support of radiological incidents, as requested by DEQ, Radiological Protection Section, or local health authorities.

f. Michigan Department of Agriculture and Rural Development The Michigan Department of Agriculture and Rural Development acts on advice from the State Health Director for controlling agricultural products and production for the purpose of radiation health hazard abatement. Protective actions initiated by the Department of Agriculture and Rural Development may include any or all of the protective actions recommended by the Environmental Protection Agency.

5.7.2 Federal Agencies

a. Nuclear Regulatory Commission (NRC)

Nuclear Regulatory Commission for the State of Michigan may request the Federal Department of Energy dispatch Federal Radiological Monitoring and Assessment Center (FRMAC) personnel to the scene in the event of an emergency who could perform radiological monitoring and dose assessment.

The Emergency Director has the authority to request NRC assistance.

The office may also furnish advice and assistance to the Plant as deemed necessary. The NRC shall be notified within an hour, anytime all or part of the Post-Shutdown Emergency Plan is activated. Means of communications are described in the Post-Shutdown Emergency Plan, Section 7.0, "Emergency Facilities and Equipment."

Facilities for the NRC are available in the Technical Support Center and the Emergency Operations Facility, including work space and telephones.

The Emergency Operations Facility provides space for trailers for long term support capabilities.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 50 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN

b. US Department of Energy (DOE)

The Department of Energy will assist during radiological emergencies by furnishing advice, consultation, and assistance regarding the protection of personnel, treatment of injured and/or exposed persons, minimization of further exposure and contamination, and the determination of existence and extent of contamination. The DOE will respond to the FRMAC in support of the state and local monitoring operations, but may receive requests for assistance directly from the Plant as authorized by the Emergency Director.

Contact with the DOE may be established using telephone lines. The Emergency Operations Facility provides space for trailers in support of DOE activities.

c. Federal Emergency Management Agency (FEMA)

The Federal Emergency Management Agency will assist the utility in real events with consultation and expertise in controlling an actual emergency.

FEMA also evaluates Local and State Emergency Plans to ensure adequacy.

d. Federal Radiological Monitoring and Assessment Center The Federal Radiological Monitoring and Assessment Center is a joint facility for all federal agencies involved in evaluating and mitigating radiological events. The NRC is the Lead Federal Agency (LFA) for the FRMAC and will coordinate the efforts of all federal agencies involved. The FRMAC will supply information and support to state and local governments concerning radiological conditions.

5.8 INSTITUTE OF NUCLEAR POWER OPERATIONS (INPO)

The Institute of Nuclear Power Operations will provide emergency response as requested by Entergy Corporation. INPO can provide assistance locating sources of emergency manpower and equipment, analyzing operational aspects of the event, and organizing industrial experts who could advise Entergy Corporation on technical matters. INPO will be contacted by means of its 24-hour telephone number in the event of a radiological emergency. The EOF Emergency Director shall be responsible for requesting assistance from INPO.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 51 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN FIGURE 5-1 EMERGENCY RESPONSE INTERFACES

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 52 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN FIGURE 5-2 POST-SHUTDOWN PLANT STAFFING AND AUGMENTATION REQUIREMENTS STAFF AUGMENTATION MAJOR FUNCTIONAL POSITION TITLE ON CAPABILITY AND MAJOR TASKS RESPONSE TIME AREA OR EXPERTISE SHIFT 60 Min 90 Min Plant Operations and Shift Manager 1 -- --

Assessment of Operational Non-Certified Operators 2 -- --

Aspects Emergency Director Shift Manager 1* -- --

Notification/ Notify licensee, state, 1* 2 --

Communication local, and federal personnel and maintain communication Radiological Accident Emergency Operations Senior Manager -- 1 --

Assessment and Support Facility (EOF) Director of Operational Accident Offsite Dose Senior Radiation Protection Assessment Assessment (RP) Expertise 1* 1 --

Chemistry/Radiochemistry RP Technicians 1* -- --

Radiation Protection Radiation Protection Tasks: RP Technicians 1 2 --

a. Offsite Surveys

b. Onsite (Out-of-Plant) Surveys

c. In-Plant Surveys

d. Access Control

e. RP Coverage

f. Personnel Monitoring

g. Dosimetry NOTES:

• May be provided by shift personnel assigned other functions.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 53 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN FIGURE 5-2 POST-SHUTDOWN PLANT STAFFING AND AUGMENTATION REQUIREMENTS STAFF AUGMENTATION MAJOR FUNCTIONAL POSITION TITLE ON CAPABILITY AND MAJOR TASKS RESPONSE TIME AREA OR EXPERTISE SHIFT 60 Min 90 Min Plant System Technical Support Electrical/Mechanical -- 1 --

Engineering, Repair, and Corrective Actions Repair and Corrective Mechanical Maintenance 1* 1 --

Actions Electrical Maintenance 1* 1 --

Field Monitoring Teams Onsite FMT - Radiation monitor to RP Technician -- 1 --

(FMTs) assess environmental radiation/contamination and provide input to Senior Radiation Protection Expertise. Also provide RP coverage for FMT.

Offsite FMT - Perform RP Technicians -- 1 1 environmental radiation/contamination assessments and radioactive plume tracking. Communicate and coordinate with applicable ERO supervision. Responsible for the radiation protection of the FMT.

Transportation Drivers -- 1 1

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 54 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN FIGURE 5-2 POST-SHUTDOWN PLANT STAFFING AND AUGMENTATION REQUIREMENTS STAFF AUGMENTATION MAJOR FUNCTIONAL POSITION TITLE ON CAPABILITY AND MAJOR TASKS RESPONSE TIME AREA OR EXPERTISE SHIFT 60 Min 90 Min Fire Fighting -- -- Fire Brigade Local Support per Technical Specifications

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 55 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN FIGURE 5-2 PLANT STAFFING AND AUGMENTATION REQUIREMENTS STAFF AUGMENTATION POSITION TITLE ON CAPABILITY AND MAJOR FUNCTIONAL AREA MAJOR TASKS OR EXPERTISE SHIFT RESPONSE TIME 60 Min 90 Min Rescue Operations -- -- 2* Local Support and First-Aid Site Access Control Security, fire fighting Security Personnel All per and Personnel communications, personnel Security accountability Plan TOTAL 4 12 2 NOTES: 1. Staff augmentation personnel are required to respond as quickly as possible, within the required response time.

2. The Shift Manager may call out additional designated ERO members, or the full ERO complement, at any time in an emergency event regardless of classification.

3. Even when they are not on duty, staff augmentation personnel are to respond to an emergency call out when they are fit for duty and otherwise available for timely response.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 56 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN 6.0 EMERGENCY MEASURES

a. This section identifies the measure to be used for each type of emergency previously classified in Section 4. The logic presented in this section is used as the basis for the detailed Palisades Nuclear Plant Emergency Implementing Procedures which define the emergency actions to be taken for each emergency classification. Emergency measures begin with the following:

1. Recognition, classification, and declaration of an emergency condition.

2. Notification of the applicable agencies and personnel (Figure 6-1).

3. Mobilization of the appropriate portions of the emergency organization.

b. Emergency measures are additionally organized into the following categories:

1. Assessment actions

2. Corrective actions

3. Protective actions These measures are described in the following sections for each emergency classification.

6.1 ACTIVATION OF THE EMERGENCY ORGANIZATION If it appears that an incident or condition may meet or exceed a predetermined value or condition specified as an Emergency Action Level in Emergency Implementing Procedure EI-1, "Emergency Classification and Actions," and PSEP Supplement 1 "POST-SHUTDOWN EMERGENCY PLAN Supplement 1 - EAL Wall Charts" then certain portions of this plan and specific procedures shall require implementation.

The Shift Manager will initially classify the emergency and ensure required notifications are made. The Shift Manager shall ensure that an overall assessment of the emergency is performed in order to determine the most appropriate classification and, based on this determination, activate portions of the emergency organization as necessary. The methodology used in activating the emergency organizations during each class of emergency is provided in the following sections:

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 57 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN 6.1.1 Control Room Personnel

a. Should emergency conditions, either real or potential, arise, it is expected that the Shift Manager will initially be made aware of the situation by alarms, instrument readings, reports, etc. The Shift Manager shall ensure that the General Manager, Plant Operations or Duty Station Manager on backshift and weekends is immediately informed of any possible emergency situation.

b. The Shift Manager is responsible for ensuring the performance of the initial assessment of the emergency (e.g., Plant and spent fuel pool status, radiological conditions, etc.) in the following manner:

1. Determine the immediate actions necessary to be taken to ensure the safe and proper operation of the Plant.

2. If the situation requires activation of all or part of the Site Emergency Plan, the Shift Manager shall:

(a) Initiate the applicable Emergency Implementing Procedures.

(b) Initially classify the emergency.

(c) Ensure the appropriate alarm is sounded.

(d) Announce the location, type and classification of the emergency on the Plant public address system.

(e) Notify the following personnel and agencies of the emergency condition(s): (Reference Emergency Implementing Procedure EI-3, "Communications and Notifications.").

Message authentication may be used as deemed necessary.

(1) Van Buren County (2) State of Michigan (3) NRC (4) The General Manager, Plant Operations or designated alternate (Duty Station Manager)

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 58 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN While both pages of the notification form are not necessary for every notification, NOTE:

the two pages together include the elements listed in the following sections.

(f) Initial notification should consist of the following as appropriate:

(1) Name and telephone number (if needed).

(2) Location of incident.

(3) Date and time of incident.

(4) Emergency classification (Emergency Implementing Procedure EI-1, "Emergency Classification and Actions").

(5) Whether a release is taking/has taken place.

(6) The affected/potentially affected population.

(7) Recommended protective actions.

(g) Follow-up notification should consist of the following as appropriate:

(1) Name and telephone number (if needed).

(2) Location of incident.

(3) Date and time of incident.

(4) Emergency classification (EI-1).

(5) Type of actual or projected release (liquid or gaseous) and estimated duration/impact times.

(6) Estimate of amount or radioactive material released, points of release, and height of release (Emergency Implementing Procedure EI-6, "Offsite Dose Calculation and Recommendations for Protective Actions").

(7) Chemical and physical form of released material. Include estimates of the relative quantities and concentration of noble gas, iodine, and particulates (EI-6).

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 59 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN (8) Prevailing meteorological conditions (EI-6).

(9) Actual or projected dose rates of at the site boundary and the integrated dose rate at the site boundary (Emergency Implementing Procedures EI-6 and EI-9, "Offsite Radiological Monitoring").

(10) Projected dose rates and integrated dose rates at the projected peak and at 2, 5, and 10 miles from the site and the sectors affected.

(11) Estimate of surface contamination in Plant, onsite and offsite.

(12) Entergy Corporation emergency response actions underway.

(13) Recommended emergency actions, including protective measures.

(14) Requests for support from organizations.

(15) Prognosis for worsening or termination of event.

3. Due to the additional responsibilities assigned to the Shift Manager at the beginning of an emergency, the following actions are to be performed in the priority listed below:

(a) Ensure the safe operation of the Plant.

(b) Ensure that immediate notification requirements are met.

(c) Dispatch, in the event of radiological emergencies, Radiation Monitoring Teams, to designated analysis locations onsite and offsite.

(d) Perform additional emergency actions as time and conditions permit including accident assessment beyond that required for emergency classification.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 60 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN 6.1.2 Emergency Plant Manager The Shift Manager will continue to perform the Command and Control actions of the Post-Shutdown Emergency Plan until relieved by the EOF Director. The Emergency Plant Manager reports to the EOF Emergency Director. When the EOF Director has taken Command and Control of the event and the TSC is Operational the Shift Manager and Control Room will report to the EPM. The EPM has the responsibility for command of all accident mitigation actions at the site and performs these duties from the Technical Support Center (TSC). Responsibilities include:

a. Assume command of the TSC and OSC and the onsite mitigation efforts

b. Provide information and recommendations to the ED regarding the classification of an emergency

c. Ensure timely ENS notifications

d. Perform accident assessment to prioritize mitigation actions.

e. Coordinate the activities of the CR, TSC and OSC

f. Direct personnel evacuation, assembly and accountability of non-essential personnel

g. Provide information and recommendations to the ED regarding plant activities

h. Advise the ED on plant conditions for classification and PAR determination

i. Direct the organization and coordination of repair corrective action teams

j. Direct onsite protective actions

k. Authorize emergency radiation exposure and issuance of KI to recommended personnel in the CR, TSC or OSC or to Security personnel

l. Make operational decisions involving the safety of the plant and its personnel and make recommendations to the Control Room Personnel

m. Initiate immediate corrective actions to limit or contain the emergency invoking the provisions of 10 CFR 50.54(x) if appropriate1

o. Direct relocation to an alternate location

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 61 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN

p. Integrate offsite responders with on-site response efforts when required

q. Perform emergency termination

r. Maintain Plant security 6.1.3 Emergency Director The Emergency Director provides overall command and control of the emergency response. Responsibilities include:

a. Receive turnover from the SM/ED and assume command/control of EOF and activities outside the area controlled by the TSC

b. Direct the activation, operation and deactivation of the EOF

c. Determine to what extent the offsite and onsite emergency organization shall be activated

d. Upgrade the emergency classification level (cannot delegate)

e. Make Protective Action Recommendations (PAR) to offsite agencies (cannot delegate)

f. Direct and approve offsite notification to State and local agencies (cannot delegate)

g. Communicate within and between the emergency response facilities.

h. Ensure event information is communicated to other organizations (NRC, Entergy Corp, etc) to keep them informed of the emergency situation

i. Direct the activities of the EOF organization in support of the TSC and offsite response agencies (Counties, and the State of Michigan)

j. Direct protective actions for offsite monitoring teams, EOF ERO and offsite resources

k. Request assistance from offsite agencies, excluding requests for offsite medical/fire, security assistance (Coordinate request for Federal assistance through the State)

l. Authorize issuance of KI and radiation exposure in excess of 10CFR 20 limits for ERO members outside of the protected area

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m. Conduct turnover of command and control to relief ED

n. Dispatch Palisades Plant liaisons to principal offsite emergency operations centers

o. Maintain adherence to the fitness for duty policy 6.1.4 Emergency Management and Homeland Security Division - Michigan State Police In emergency situations, the Emergency Management and Homeland Security Division is responsible for coordinating the support of other state agencies and political subdivisions and obtaining the assistance of federal agencies as required.

The Emergency Management Division will provide the following emergency support:

a. Activation of the State Emergency Operations Center, as necessary

b. Communications, radiological monitoring, and other available support to the affected local government

c. Liaison with local, state, and federal agencies 6.1.5 Michigan Department of Environmental Quality, Radiological Protection Section The Michigan Department of Environmental Quality, Radiological Protection Section is responsible for administering and directing radiation control programs and activities within the State of Michigan.

The Radiological Protection Section has the direct responsibility to provide the technical assistance necessary to evaluate the offsite consequences of a radiological incident, to provide protective action guidance to state and local authorities responsible for public safety, and to oversee offsite decontamination and reentry operations.

The Michigan Department of Community Health is responsible for coordinating emergency medical support as requested by the Michigan Department of Environmental Quality, Radiological Protection Section, or local health authorities.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 63 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN 6.1.6 Affected Counties: Van Buren County, Berrien County, and Allegan County Emergency responsibilities of County Emergency Management include communication support to the responding county departments, providing warning and notification to the public, and assuring the continuation of vital services during the emergency.

6.2 ASSESSMENT ACTIONS Effective coordination and direction of all portions of the emergency organization require almost continuous accident assessment during the course of the emergency.

Each emergency class will require similar accident assessment methods; however, each classification imposes a different magnitude of assessment effort. In the following steps, the assessment actions to be taken for each emergency classification are outlined.

6.2.1 Assessment Actions for Unusual Events The detection of an Unusual Event shall arise from exceeding a specific Emergency Action Level for this class. Detection of the event will come as a result of alarms, instrument readings, recognition through experience, or any combination thereof.

The continuing assessment actions to be performed for this classification of emergency shall be in accordance with the Emergency Implementing Procedures and shall consist of the normal monitoring of Control Room and other Plant instrumentation and status indication until the situation is resolved. If a fire is the reason for the declaration of an Unusual Event, the Shift Manager will make continuing assessments based on his knowledge and experience on whether offsite firefighting assistance is needed.

6.2.2 Assessment Actions for Alerts When an accident has been classified as an Alert by the Shift Manager, assessment actions shall be performed in accordance with the Emergency Implementing Procedures for an Alert.

These actions include:

a. Accountability of onsite personnel.

b. Staff augmentation, as needed.

c. Increased surveillance of in-plant instrumentation.

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d. Activation of appropriate emergency facilities.

e. Dispatch of shift personnel, if possible, to the identified problem area for confirmation and visual assessment.

f. Dispatch of onsite Radiation Monitoring Teams to monitor for possible release and to provide confirmation of correct accident classification.

g. If a radiological accident is occurring, surveillance of the in-plant instrumentation is necessary to obtain meteorological and radiological data required for calculating or estimating projected doses. This dose assessment activity shall continue until termination of the emergency in order that the updating of initial assessments may be provided to all concerned offsite agencies, the Shift Manager, and EOF Emergency Director. Emergency Implementing Procedures are provided to aid in a rapid, consistent projection of doses.

6.2.3 Assessment Actions for Site Area Emergencies The assessment actions for the Site Area Emergency classification are similar to the actions for an Alert; however, due to the increased magnitude of the possible release of radioactive material, a significantly larger assessment will occur. The necessary personnel for this assessment effort shall be provided by mobilization of the onsite and offsite emergency organizations.

Specifically:

a. An increased amount of Plant instrumentation shall be monitored.

b. Radiological monitoring efforts shall be increased. Onsite and offsite radiological monitoring teams will be dispatched. In addition to beta-gamma field measurements, change out of environmental thermoluminescent dosimeters (TLD), air sampling, and collection of the environmental media for assessment of radioactive material transport and deposition may also be performed.

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c. Dose assessment activities will be conducted more frequently with an increased emphasis on dose projections for use as a factor in determining the necessity for protective actions for the public. Radiological (eg, TLDs) and meteorological instrumentation readings shall be used to project the dose rate at predetermined distances from the Plant, and to determine the integrated dose received. In reporting the dose projections to offsite agencies, the dose rate, dose, and the basis for the time used for the dose estimate shall always be provided. Any confirmation of dose rates by offsite Radiation Monitoring Teams shall be reflected in reporting and/or revising the dose estimate information provided to offsite agencies.

Dose projections shall be considered with respect to the Environmental Protection Agency Protective Action Guides (Table 6-1). Reporting of assessments to offsite authorities shall include the relationship of the dose to these guidelines. Emergency Implementing Procedures will be provided for recording all pertinent information.

6.2.4 Assessment Actions for General Emergencies Assessment actions for the General Emergency classification shall be the same as for the Site Area Emergency with some possible shift of emphasis to greater offsite radiation monitoring and dose projections extending to distances farther from the site.

6.2.5 Estimation of Offsite Dose The Emergency Implementing Procedures (reference Emergency Implementing Procedure EI-6, "Offsite Dose Calculation and Recommendations for Protective Actions") contain several methods for calculating offsite dose to population from accidental releases. These methods include:

a. Computer Method - Implements the above method using a personal computer to speed the process.

b. Manual Method - A pencil and paper method for calculating offsite dose using precalculated diffusion factors and a straight line Gaussian methodology.

c. Segmented Gaussian - Variable trajectory Plume model.

The above methods have been developed in cooperation with state agencies and provide methods for rapid, accurate dose estimates.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 66 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN 6.2.6 Data Reporting, Recording, and Analysis Specially assigned personnel at all designated emergency centers have the responsibility for collecting, recording, and analyzing data transmitted to them.

Preplanned emergency logs and procedures are provided to ensure that all necessary information is received and recorded. Included will be:

a. Data from emergency survey teams as available. This will be recorded to define the affected environs.

b. Evacuated Plant personnel will be questioned to gather all possible information on observed conditions.

c. In addition to incoming data, a log of events occurring at the emergency centers (TSC, OSC, EOF) and Control Room will be kept. Individual sections of this log will record such items as personnel exposure, contamination levels, communications, and check-off lists.

6.2.7 Interviewing Evacuees or Other Witnesses Information from personnel evacuating the site may be collected at the evacuation control point as directed by the Emergency Plant Manager. This information shall be reported to the TSC when possible.

6.2.8 Assessment Results Communications The EOF Emergency Director is notified of assessment results from the site and from offsite support agencies. The EOF Emergency Director, in turn, is responsible for communication back to those groups so that emergency measures may be modified as necessary.

6.3 CORRECTIVE ACTIONS Detailed operating procedures are available to the operators for use during emergencies as well as during normal operations. Specific emergency procedures are provided to assist the operators in placing the Plant in a safe condition and taking the necessary supplemental corrective actions. In addition, operations personnel are trained in the operation of the Plant systems and their associated procedures and are, therefore, capable of taking appropriate corrective actions based on their training, knowledge, and experience.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 67 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN Corrective actions shall be planned events that are taken to lessen or terminate the emergency situation. Planned radioactive releases or corrective actions that may result in a radioactive release shall be evaluated by the EOF Emergency Director, and his staff, as far in advance of the event as is possible. Such events and data pertaining to the release shall be reported to the appropriate offsite emergency response organization and/or agencies.

6.3.1 Fire Control Provisions for firefighting and control are described in the Fire Protection Implementing Procedures. The Covert Township Fire Department and the South Haven Fire Department provide Offsite backup firefighting support.

In-plant firefighting equipment ranges from portable extinguishers to automatic sprinkler control. The Plant emergency organization includes a trained fire brigade for immediate response to any fire situation.

The Van Buren Dispatch, via 911, is first to be called. They are required to dispatch both Covert and South Haven Fire Departments. These departments consist of personnel trained for firefighting, including situations involving radioactive contamination. Additional support is available from fire departments in nearby Allegan and Berrien Counties through mutual aid agreements. These fire departments are also trained and equipped for rescue work and control of hazardous gas leaks, including chlorine gas.

6.3.2 Repair and Damage Control The Palisades Plant staff is comprised of technically and vocationally trained personnel capable of improvising necessary repair and control measures for correction of an emergency situation. Wherever possible, corrective measures are anticipated and included in emergency and operating procedures.

6.3.3 System Control System design is aimed at automatic corrective actions, such as system isolation, whenever operating parameters become abnormal. Operating procedures are written for manual control of these same situations, should automatic features fail.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 68 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN 6.4 PROTECTIVE ACTIONS Protective actions are emergency measures taken during or after an emergency situation that are intended to minimize or eliminate the hazard to the health and safety of the general public and/or Plant personnel. Such actions taken onsite are the responsibility of the Entergy Corporation, while those offsite actions are the responsibility of the State of Michigan and local political jurisdictions. Protective Action Guides for the Environmental Protection Agency and the State of Michigan are shown on Tables 6-1 and 6-2. All visitors to the site protected area shall be either escorted by an employee knowledgeable as to the Emergency Plan response actions or shall receive training on actions required by them during an emergency.

6.4.1 Sheltering, Evacuation, Personnel Accountability During an emergency, the relocation of personnel may be required in order to prevent or minimize exposure to radiation and radioactive materials. The following steps present information on policies applicable to such situations:

a. Plant Site

1. Notification All persons onsite at the time of an Alert, Site Area, or General Emergency shall be notified of the emergency by a two-minute steady siren and an announcement over the public address system in the assembly areas. Notification of an Unusual Event should be over the Plant public address system. For the Alert and above, personnel shall be instructed to report to assembly areas for accountability, monitoring, and possible evacuation. Personnel accountability shall be completed in approximately 30 minutes. Specific assembly areas are designated in the Emergency Implementing Procedures. All personnel shall be trained in the locations of the assembly areas, or be escorted by an employee who is so trained. At the assembly area, members of the emergency organization shall direct efforts per the applicable Emergency Implementing Procedure. These procedures shall provide contingency plans for weather, traffic, and radiological impediments to evacuation.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 69 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN

2. Site Access Control Provisions for control of access to the Palisades site have been included in the Safeguards Contingency Procedures to take care of personnel entering for business purposes and for those who might inadvertently enter. Access to the exclusion areas of the Plant is controlled by the Plant security force. Offsite support is provided by local and/or state law enforcement personnel.

3. Monitoring of Evacuees A combination of checking electronic dosimeters and questioning of evacuees will be used to initially determine if there were any high external exposures involved in the emergency. For any known or suspected high exposures, the permanent dosimeters will be read as soon as possible and further investigation will be conducted to determine the amount of exposure or necessary actions to be taken.

Monitoring for contamination and internal ingestion at the assembly areas will be accomplished by using portable instrumentation and questioning. Priority for decontamination will be given persons found with the highest levels of contamination. Any persons suspected or known to have ingested radioactivity will be whole-body counted, as soon as conditions permit, to assess their internal exposure.

Decontamination supplies for evacuees shall be available.

4. Egress Routes Three potential routes are available: Plant access road to the east and the beach to the north or south. Unless conditions dictate otherwise, the Plant access road to the east will be the primary evacuation route.

An evacuation procedure shall require a personnel accountability check at the appropriate control point/monitoring station. Security officers shall be dispatched by the Emergency Plant Manager to stop ingress from the access roads and to assist Plant personnel evacuating the site. A control point/monitoring station shall be established along the egress route in an area expected to be outside the path of possible radioactive releases.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 70 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN

b. Offsite Areas

1. Agency Responsibilities The Palisades Nuclear Plant is located in Van Buren County (Covert Township), and the 10-mile emergency planning zone includes portions of Allegan and Berrien counties, including the city of South Haven. In a radiological emergency, operational control will be from the State Emergency Operations Center (SEOC) in Lansing, with local operation control from the county EOCs. Each county has an Emergency Preparedness Plan which is a legal document in compliance with Act 390 of the Michigan Public Acts of 1976.

The Michigan Department of Environmental Quality is responsible for directing radiation control programs and emergency responses within the state as stated in Act 368, Michigan Public Acts of 1978 and the Michigan Emergency Management Plan (MEMP), and the Governor's Executive Order 1996-1.

The Deputy State Director of Emergency Management of the Michigan State Police provides overall coordination of emergency operations, including the use of all state government resources upon proclamation of a State of Disaster, or State of Emergency by the Governor. The Michigan State Police will coordinate the disaster response activities of all departments of State Government.

2. Notification and Response The local government will provide notification of the general public involved and define and identify this population. The state government will give detailed directions for protection of this population, including provisions for evacuation of personnel from affected sectors of the environs if necessary.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 71 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN

3. Protective Actions Protective action procedures are covered in the Michigan Emergency Preparedness Plan and the Van Buren, Allegan, and Berrien County Emergency Plans. In summary, these plans contain the following:

(a) A public warning system composed of two components, alert and notification.

(1) The alert component is comprised of a siren system which provides coverage for a 10 mile radius around the plant, and allows the resident and transient populations to be warned within 15 minutes of the issuance of a protective action.

(2) The notification component consists of several local radio stations that broadcast appropriate initial and follow-up messages on protective actions to be taken.

(3) If a backup means of notification is necessary, other television/radio communications, vehicles with mobile public address systems (Route Alerting) and other means as necessary can be utilized.

(b) Predesignated areas are based on continuous mile circles from the Palisades Plant. These areas will be used by the responsible authorities in ordering protective actions.

(c) A communication system has been established for emergency notification of offsite agencies having protective response assignments.

(d) Emergency response and evacuation plans for offsite areas have been formulated by state and local agencies. Evacuation clear times for areas near Palisades are shown in Appendix C.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 72 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN 6.4.2 Contamination Control Measures This section describes the provisions for preventing or minimizing direct or subsequent ingestion exposure to radioactive materials deposited on the ground or other contaminable surfaces.

a. Plant Area Access to the owner-controlled area shall be controlled. In addition, within the owner-controlled area, there are no areas for producing agricultural products. In-plant contamination control shall be exercised in accordance with approved radiation protection procedures.

b. Offsite Areas Criteria for preventing or minimizing ingestion of, or exposure to, contaminated materials or areas is contained in the Michigan Emergency Management Plan.

Included are:

1. Isolation or quarantine and area access control.

2. Control of the distribution of affected commercial agricultural crops.

3. Control of public water supplies.

4. Means for providing advisory information regarding the use of affected home food and water supplies.

5. Criteria for permitting return to normal use.

Action levels and responsibilities for execution of these measures are included. Contaminated areas will be barricaded and posted to control access until time allows for decontamination activities. Michigan Department of Environmental Quality representatives will be responsible for these actions and will be assisted by other Michigan State Departments and/or Entergy Corporation upon request.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 73 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN 6.5 AID TO AFFECTED PERSONNEL 6.5.1 Emergency Personnel Exposure Criteria Although an emergency situation transcends the normal requirements for limiting exposure, there are suggested levels of exposure acceptable in emergencies. Even under these conditions, every reasonable effort to minimize exposure must be made and personnel must be provided with appropriate monitoring devices. Three categories of risk versus benefit must be considered:

a. Saving of human life and reduction of injury.

b. Protection of health and safety of the public.

c. Protection of property.

In order to avoid restricting actions that may be necessary to save lives, it shall be left to the judgment of the individual to determine the amount of exposure that he will accept to perform an emergency action that will result in the saving of human life.

Emergency team members are instructed in radiation effects and the risks involved for emergency doses. Basic guidelines provided to emergency team members are the EPA recommendations contained in Table 6-3. These exposures must be authorized by the Emergency Plant Manager based on the recommendation of the TSC Rad Coordinator.

The Radiation Protection Procedures shall be followed. In the event emergency exposure limits are approved, the same administrative methods for dose control shall be used with the higher emergency exposure limits.

Once the emergency condition has been mitigated, steps shall be taken to recover from the incident. All actions from this point shall be preplanned in order to limit exposures. Normal exposure limits will be used, areas will be controlled, and exposure of personnel documented.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 74 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN 6.5.2 Decontamination and First Aid Onsite personnel decontamination facilities for emergency conditions are fully equipped with decontamination material. The decontamination facility at Palisades Plant is located at the access control area of the auxiliary building.

The decontamination facility consists of a shower, sink, and first-aid kits.

Decontamination supplies such as various decontamination solutions and surgical brushes will be stored in the decontamination facility. Emergency equipment located around the site is available and includes personnel monitoring equipment. There are also additional personnel monitoring equipment located at the access control area including dosimeters, and high and low-range survey instruments. A comprehensive list of materials and equipment available for use can be found in Appendix E.

In an emergency situation, decontamination is the responsibility of the Radiation Monitoring Team. When decontamination of an area or equipment is required, personnel from Operations, Maintenance, and Radiation Protection will work jointly.

Medical first-aid training is provided to designated members of the Plant emergency organization that, as a minimum, includes the Red Cross Multimedia course or equivalent, combined with the American Heart Association Cardiopulmonary Resuscitation course. This training for members of the Plant staff also includes methods of handling contaminated patients and/or injuries. At least one person on each operating shift is required to have this first-aid training.

The Covert Township Fire Department ambulance personnel and the South Haven Area Emergency Services ambulance staff are trained in caring for radiologically contaminated victims.

6.5.3 Medical Treatment In the event of a serious accident at Palisades Plant requiring medical treatment, agreements have been made with the area hospitals. These hospitals are:

a. South Haven Community Hospital, South Haven, Michigan.

b. Lakeland Regional Medical Center, St Joseph, Michigan.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 75 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN TABLE 6-1 ENVIRONMENTAL PROTECTION AGENCY - PROTECTIVE ACTION GUIDES PAG Protective Action Projected Dose Whichever is more limiting Intervention Level

• 0.5 rem (CEDE)

Whole body or any set of organs OR 5 rem (CDE) any single organ Specific PAs are not provided due to the wide variety of actions that could be NOTE:

taken.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 76 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN TABLE 6-2 PROTECTIVE ACTION GUIDES (PAGs) & OBJECTIVES Early Plume PAGs (Source - EPA 400-R-92-001)

PAG Protective Action Comments Projected Dose Evacuation 1-5 rem TEDE Evacuating (or for some (or sheltering) 5-25 rem thyroid situations, sheltering) 50-500 rem skin should normally be initiated at the lower limits.

Administration of stable 25 rem thyroid Requires approval of State iodine Medical Officials Relocation PAGs (Source - EPA 400-R-92-001)

PAG Protective Action Comments Projected 1st Year Dose Relocate the general 2 rem TEDE population > 100 rem beta skin dose Apply simple dose < 2 rem TEDE These protective actions reduction techniques should be taken to reduce doses to as low as practicable levels Long Term Objectives (Source - EPA 400-R-92-001)

Long Term Objectives Period Objective Any single year 0.5 rem TEDE (2 through 50) 50 Years 5 rem TEDE

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 77 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN TABLE 6-3 GUIDANCE ON DOSE LIMITS FOR WORKERS PERFORMING EMERGENCY SERVICES Dose Limita Activity Condition (rem) 5 all 10 protecting valuable lower dose not practicable property 25 lifesaving or protection of lower dose not practicable large populations

>25 lifesaving or protection of only on a voluntary basis large populations to persons fully aware of the risks involved a

Sum of external effective dose equivalent and committed effective dose equivalent to nonpregnant adults from exposure and intake during an emergency situation. Workers performing services during emergencies should limit dose to the lens of the eye to three times the listed value and doses to any other organ (including skin and body extremities) to ten times the listed value. These limits apply to all doses from an incident, except those received in unrestricted areas by members of the public during the intermediate phase of the incident.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 78 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN FIGURE 6-1 PALISADES PLANT NORMAL NOTIFICATION CHAIN Control Room or Emergency Operations Facility Communicator If Needed Notifications Required Notifications Covert Fire Department Van Buren County Sheriff*

Michigan State Police Ambulance Services Emergency Management Division NRC Hospitals (Note: Communicator located in TSC)

Van Buren State Park Duty Station Manager Superintendent Palisades Park Superintendent Federal Aviation Administration Department of Energy US Coast Guard South Haven Water Department Berrien County Sheriff Allegan County Sheriff Entergy Public Affairs

• Not a required notification if the State Emergency Operations Center is activated.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 79 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN 7.0 EMERGENCY FACILITIES AND EQUIPMENT This section describes the equipment and facilities that are utilized to:

a. Assess the extent of accident hazards.

b. Mobilize the resources required to mitigate the consequences of an accident.

c. Provide protection to Plant personnel.

d. Support accident mitigation operations.

e. Provide immediate care for injured/contaminated personnel.

f. Effect damage control.

7.1 ONSITE EMERGENCY FACILITIES Onsite emergency support centers include the Control Room and two other areas at Palisades. These areas are designated as the Technical Support Center and the Operations Support Center as described below.

7.1.1 Control Room The principal emergency control center is the Plant's Control Room. Operations personnel will report to the Control Room and control all evolutions from this central location. Self-Contained Breathing Apparatuses are located in or near the Control Room for personnel protection from inhalation.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 80 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN 7.1.2 Technical Support Center The Technical Support Center is located in the area immediately adjacent to the Control Room and includes the Shift Manager's office, the viewing gallery hallway, and the adjacent open work area. The TSC will accommodate personnel who will provide technical support to Operations and Control Room personnel during emergency conditions. Complete record keeping and communications capabilities have been installed. All necessary equipment, furnishings, and documents are stored in the immediate area and are readily available for use. The TSC may be activated for Unusual Events, and will be activated for Alert, Site Area Emergency, and General Emergency conditions.

Further details concerning staffing, equipment, furnishings, procedures, and activation are outlined in the Emergency Implementing Procedures.

Habitability of the Control Room and the TSC is assured by the filtered ventilation system that serves this area. In addition, Self-Contained Breathing Apparatus (SCBA) is provided for up to eight individuals. An area radiation monitor in the viewing gallery area reads out in the Control Room to provide external dose rate data. Air sampling and analysis equipment are provided in the emergency equipment kits to monitor airborne radioactivity levels. Personal radiation dosimetry issued to some site personnel and visitors will provide individual radiation dose assessment data. In the event that the Technical Support Center is not habitable, an alternate center may be established at the OSC, Mechanical Maintenance Shop, or other site buildings.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 81 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN 7.1.3 Operations Support Center (OSC)

The Operations Support Center (OSC) is located near the men's locker room in the Service Building that is connected to the rest of the Plant by hallways.

The function of the OSC is to assemble and coordinate necessary personnel from Chemistry, Radiation Protection, Operations (Non-Certified Operators), I&C, Electrical, and Mechanical. These groups will be dispatched for specific jobs as directed by the TSC.

Additional details concerning staffing, equipment, furnishings, procedures, and activation are outlined in the Emergency Implementing Procedures.

Habitability of the OSC is verified using available emergency kit equipment.

Equipment is provided for measuring external dose rates and airborne radioactive levels. The OSC ventilation system is independent of the Auxiliary Building system.

This minimizes airborne contamination as a result of events in the Auxiliary Building.

In the event the OSC should not be habitable, alternate locations such as the Mechanical Maintenance Shop or permanent construction buildings are available for use.

A maintenance kit containing only maintenance supplies is kept in the men's locker room.

7.2 EMERGENCY OPERATIONS FACILITY (EOF)

The Palisades Emergency Operations Facility (EOF) is located in downtown Benton Harbor, approximately 16 miles South Southwest from the Plant. The EOF assumes overall responsibility for Entergy Corporation emergency response. The EOF is designed to provide assistance in the decision-making process to protect the public health and safety, and to control radiological monitoring teams offsite. The EOF may be activated for the Unusual Event, and shall be fully activated for the Alert, Site Area Emergency, and General Emergency categories.

To assure the safety of the staff, equipment is provided for measuring external dose rates, and airborne radioactivity levels.

The staff is comprised of personnel from the Plant. In addition, liaison personnel from the county, state, and federal governments will also be present in the EOF.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 82 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN The EOF has ready access to up-to-date Plant records, procedures, and emergency plans needed to exercise overall utility resources management and for recovery management. Hard copy records stored and maintained at the EOF include, but are not limited to:

Palisades Technical Specifications Palisades Operating Procedures Palisades Final Safety Analysis Report Palisades Abnormal Operating Procedures Palisades Post-Shutdown Emergency Plan Palisades Emergency Implementing Procedures Michigan Emergency Management Plan Van Buren County Emergency Plan Berrien County Emergency Plan Allegan County Emergency Plan Palisades Piping and Instrument Diagrams Other up-to-date records including radiological records, procedures, drawings, schematics, and diagrams are readily available via transmittal to the EOF.

The EOF shall provide analysis of field monitoring data, and coordination for the collection sample media.

7.3 COUNTY AND STATE EMERGENCY CENTERS 7.3.1 County Emergency Operations Centers Potential emergencies could directly impact those individuals living within the 10-Mile Emergency Planning Zone, and indirectly affect property within the 50-Mile Emergency Planning Zone. Therefore, emergency planning efforts have been initiated by those affected counties within the 10-Mile Emergency Planning Zone.

The affected counties are: Van Buren, Berrien, and Allegan Counties.

Each of these counties has established and maintains an Emergency Operations Center (EOC). These centers are located as follows:

a. Van Buren County Courthouse Annex Paw Paw, Michigan

b. Berrien County Sheriff's Department Benton Harbor, Michigan

c. Allegan Central Dispatch Allegan, Michigan 7.3.2 State Emergency Operations Center

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 83 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN When it is determined that personnel and resources of state government are needed to support disaster operations of affected local governments, the State Emergency Operations Center (SEOC) is staffed in Lansing. This facility is staffed at any level of emergency depending on potential for required state response.

The Michigan State Field Team Center location will be determined at the time of the incident by personnel at the State EOC. That facility is equipped with the necessary communications control capabilities (when staffed), from which the State will dispatch offsite-monitoring teams. All decision makers remain in Lansing.

7.4 JOINT INFORMATION CENTER (JIC)

A Joint Information Center (JIC) will be established at the combined EOF/JIC located at 330 W Main, Benton Harbor. The JIC will be staffed by public information representatives of the utility, state, county, and federal governments. The Plant Communications Specialist will be located in this facility upon its activation.

7.5 COMMUNICATIONS EQUIPMENT The members of the emergency organizations require correct and up-to-date information relevant to the potential or real emergency condition. Therefore, the communications systems that will be used by the emergency organizations must meet the following basic criteria:

a. Provide for prompt initial notification.

b. Maintain reliability.

c. Provide for alternate methods of communications.

7.5.1 Routine Communications System Communications equipment available for offsite use include:

a. Commercial telephones - separate outside lines.

b. Intracompany telephone system.

c. State Police Radio - through Security Department.

d. Emergency Network System telephone to NRC.

e. Commercial telephone to Van Buren County Sheriff's Department, Paw Paw.

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f. Commercial telephone to State Police Operation Center, Lansing.

g. Power failure phones in major onsite response centers (Control Room, TSC, OSC).

h. Satellite phones in major onsite response centers (Control Room, TSC, OSC, EOF).

Table 7-1 summarizes communications resources.

7.6 ASSESSMENT EQUIPMENT SYSTEMS 7.6.1 Radiation Monitoring System The Radiation Monitoring System measures, indicates, and records the presence and level of radiation, and alerts Plant personnel to abnormal levels of radioactivity, thereby contributing to personnel protection and proper operation of Plant equipment.

The system consists of permanently installed, continuous monitoring devices together with a program and provisions for specific sample collections and laboratory analyses. The system is designed to provide information for use in evaluating the radiological consequences of normal Plant operation, anticipated operational occurrences, and accidents. Control actions are initiated on the required systems when radiation levels exceed predetermined amounts.

These monitoring functions are performed by the following subsystems and programs:

a. Area Radiation Monitoring

b. Liquid Radiation Monitoring

c. Airborne Radiation Monitoring

1. Gas

2. Particulate

3. Iodine

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 85 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN Data from these subsystems are displayed by readouts, annunciators, and recorders located in the Control Room. (Portable airborne and area monitors are capable of being plugged into receptacles throughout the Plant.) Instrumentation power for the Radiation Monitoring System will be supplied from a reliable source.

d. Area Radiation Monitors Area radiation monitors are primarily for the purpose of measuring radiation dose rates for protection of Plant personnel and providing supporting data to the surveillance of Plant radiation levels.

Monitor alarm setpoints depend on the normal background radiation at the detector location and the calculated levels for abnormal conditions. The monitors will operate within the range of normal environmental conditions applicable to their locations.

Monitored points within the Plant are in areas where personnel exposure to radiation is most likely, and at appropriate access control boundaries.

Readouts and alarms are provided both locally and in the Control Room.

e. Airborne Radiation Monitors The radiation monitors located in the gaseous release paths monitor radioactivity with sufficient sensitivity to demonstrate compliance with 10 CFR 20 limits. They also provide sampling capability, ie, removable filters and/or gas sample stop valves. Samples analyzed with laboratory equipment permit evaluation of compliance to more restrictive regulations and provide data required.

f. Liquid Radiation Monitors The monitoring systems consist of fixed detectors that display radiation levels in the Control Room.

Testing and maintenance features, such as remotely operated check sources, flushing connections, and cutoff valves are included for periodic system check and/or calibration. The liquid radiation monitors are designed to ensure that liquid effluent releases are maintained below the DAC values of 10 CFR 20 by the use of alarms and automatic shutoff features.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 86 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN 7.6.2 Meteorology Onsite meteorological data is provided by a meteorological tower located in the northeast sector of the site. This system is primarily concerned with providing data for estimating the actual or potential effects of an accidental, airborne release of radioactivity.

The following data is available:

a. Wind direction and speed at 10 and 60 meters.

b. Stability class.

This data is transmitted to the Control Room at 15-minute averages. A remote interrogation capability is available. Details of the system as it applies to emergency offsite dose calculation are provided in Emergency Implementing Procedure EI-6.7, "Plant Site Meteorological System." Details on the system in general are provided in "Palisades Meteorological Monitoring Project Plan."

Backup meteorological data can be obtained through use of Emergency Implementing Procedure EI-6.8, "Backup and Supplemental Meteorology."

Severe weather warnings are provided to the Plant by a private consultant.

Predictions of sky to ground lightening, tornados, and wind speeds in excess of 40 mph are reported to the Control Room.

7.6.3 Fire Protection System The Fire Protection System, including monitoring devices and fire suppression equipment, is completely detailed in the Fire Protection Implementing Procedures.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 87 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN 7.7 OFFSITE MONITORING 7.7.1 Radiological Monitoring Radiological Monitoring Teams shall be activated at the direction of the Shift Manager or OSC Manager. If the OSC has not been activated, notification should be made directly to the Radiation Protection Office. Monitoring teams should consist of two Radiation Protection members. The emergency vehicle shall provide transportation and be equipped with radio communications and equipment suitable for monitoring and/or sampling gaseous or liquid releases. The equipment and procedures supplied to the offsite team(s) provide the capability to sample for radioiodine in concentration as low as 10-7 micro-curies per cubic centimeter.

Following staff augmentation, the estimated deployment time for a monitoring team is 30 minutes.

a. The Environmental Monitoring Program provides a number of TLDs and airborne particulate sampling stations that are valuable for long-term appraisal of integrated dose.

b. The Michigan Department of Environmental Quality provides offsite field monitoring capability within approximately three hours.

c. The State Police Emergency Management Division can request aerial and field monitoring through the Department of Energy.

7.7.2 Laboratory Facilities The Plant laboratory and counting rooms have the capability to perform the analyses required under emergency conditions. The Michigan Department of Environmental Quality, Radiological Protection Section operates a radiological laboratory in Lansing.

Palisades Plant, and the DC Cook Nuclear Plant, may exchange services for radiological laboratory analyses, laboratory boron analyses, and backup dispersion meteorology information.

GEL Laboratory has agreed to provide the following services: collecting, analyzing, evaluating, and reporting on appropriate samples as needed for protective action information. GEL Laboratory maintains a laboratory in Charleston, South Carolina which has the capability to perform chemical and radiological analyses.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 88 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN 7.8 FIRST AID AND MEDICAL CARE 7.8.1 First Aid and Medical Care At least one person having American Red Cross Multimedia First Aid or equivalent will be available onsite at all times.

Specialized training is given for the treatment and handling of contaminated personnel and injuries.

Emergency call lists for ambulance service and medical facilities are kept current in the Emergency Implementing Procedures.

7.8.2 First Aid Equipment There are first aid kits in appropriate areas of the Plant. Accountability and inventory checks are performed quarterly and after use.

7.8.3 Decontamination and First Aid Personnel decontamination facilities for emergency conditions include showers, sinks, cleaning agents, and first aid kits, which are maintained near the Radiation Protection access control area. These supplies include special materials and Personnel Decontamination Procedures. Additional personnel decontamination equipment and facilities shall be available for decontamination of evacuees.

7.8.4 Medical Transportation Company vehicles maintained onsite and/or private vehicles can be used to transport injured and/or contaminated personnel for medical treatment. In addition, ambulances are available from the Covert and South Haven Fire Departments, depending on the severity of the situation.

7.8.5 Medical Treatment South Haven Community Hospital and Lakeland Regional Medical Center/St Joseph, have agreed to accept contaminated, injured patients.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 89 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN 7.8.6 Use of Protective Equipment and Supplies Listings by general category of typical emergency protective equipment and supplies that are stored and maintained for emergency purposes are contained in Appendix E of the Plan. Additional protective actions considered as measures for minimizing radiological exposure and contamination of Plant personnel include use of protective equipment and clothing as described below:

a. Individual Respiratory Protection Respiratory protection devices will be issued when necessary to significantly reduce the internal exposure to radionuclides. Self-Contained Breathing Apparatus will also be used in emergencies involving smoke, gases, oxygen deficient atmospheres, or unknown conditions. Both Self-Contained Breathing Apparatus and air-purifying type full-face respirators are maintained in or near the Control Room, and a larger supply of this equipment is available at the Radiation Protection area in access control. Respiratory protection devices will be issued to survey teams, rescue teams, and other personnel required to be in areas of suspected or known high airborne radioactivity. A reserve breathing air supply that is of a rate sufficient to support Control Room personnel for an extended period of time is available.

In addition to breathing apparatus, thyroid-blocking agents (i.e., potassium iodide) will be dispensed for onsite personnel in accordance with Emergency Implementing Procedures.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 90 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN

b. Protective Clothing Supplies of this apparel include coveralls, rubber gloves, shoe covers and boots, caps and hoods, and plastic suits. Inventories are maintained for normal Plant use in access control and in the stockroom.

Additional supplies of protective clothing are in the emergency kits. This clothing will be issued to survey teams, rescue teams, and other personnel required to enter known or suspect areas of radioactive contamination. It will also be issued to persons required to work in or occupy contaminated areas.

For emergency conditions, normal street clothing is considered as protective apparel, which is supplemented as necessary to protect skin surfaces, and which can be cleaned or discarded later. Protective clothing is distributed offsite only to members of those support agencies required to occupy contaminated areas for some purpose. In this event, Entergy Corporation will provide supplies to those people as available.

c. Breathing Air A local supplier of compressed air is capable of providing emergency air cylinders on a 24-hour basis.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 91 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN TABLE 7-1 PALISADES PSEP COMMUNICATIONS MATRIX Control Room TSC OSC EOF State EOC Van Buren EOC NRC Offsite Teams Control 1. Intp Phone 1. Intp Phone 1. Intp Phone 1. Com Phone 1. Com Phone 1. ENS NR Room 2. SP Phone 2. Co Network 2. Radio1 2. Radio2 2. Radio2 2. Com Phone TSC 1. Intp Phone 1. Ded Circuit 1. Satellite 1. Com Phone 1. Com Phone 1. ENS NR

2. SP Phone 2. Intp Phone Phone 2. Radio2 2. Radio2 2. Com Phone

3. Satellite 3. Satellite 3. Satellite Phone Phone Phone OSC 1. Intp Phone 1. SP Phone 1. Intp Phone NR NR NR 1. Radio3

2. Co Network 2. Intp Phone 2. Radio3 2. Com Phone EOF 1. Intp Phone 1. Ded Circuit 1. Intp Phone 1. Com Phone 1. Com Phone 1. ENS 1. Radio3

2. Radio1 2. Com Phone 2. Radio3 2. Co Network 2. Co Network 2. Com Phone 2. Com Phone State EOC 1. Com Phone 1. Com Phone NR 1. Com Phone 1. Com Phone NR NR

2. Radio2 2. Radio2 2. Co Network 2. LEIN Van Buren 1. Com Phone 1. Com Phone NR 1. Com Phone 1. Com Phone NR NR EOC 2. Radio2 2. Radio2 2. Co Network 2. LEIN NRC 1. ENS 1. ENS NR 1. ENS NR NR NR

2. Com Phone 2. Com Phone 2. Com Phone Offsite NR NR 1. Radio3 1. Radio3 NR NR NR Teams 2. Com Phone 2. Com Phone 1

Radio - Control Room/EOF (Located in Control Room) 2

- Plant Security Radio (in CAS & SAS/ Paw Paw State Police (backshifts & weekends))

- 3Radiation Protection Radio Network ENS - Emergency Notification System Com Phone - Commercial Telephone Intp Phone - Intraplant Telephone System Co Network - Palisades Telephone Network SP Phone - Sound Powered Phone LEIN - Michigan State Police Communication System Ded Circuit - Dedicated Telephone Circuit (Digital/VOIP) NR - Not Required

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 92 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN TABLE 7-1 PALISADES SEP COMMUNICATIONS MATRIX BACKUP PHONE NUMBERS AND METHODS

1. State of Michigan

a. 517-241-8000

b. 517-332-2521

c. Security Radio

2. Van Buren County Sheriff

a. 269-657-2058

b. 269-657-3101

3. NRC

a. 301-816-5100

b. 301-951-0550

c. 301-415-0550

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 93 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN 8.0 MAINTAINING EMERGENCY PREPAREDNESS Palisades Plant shall maintain the Post-Shutdown Emergency Plan and the Palisades Nuclear Plant Emergency Implementing Procedures as two separate documents. It is intended that this Post-Shutdown Emergency Plan, although considered part of Palisades Nuclear Power Plant's Final Safety Analysis Report (FSAR), be maintained as a separate document.

The Site Vice President is the individual with overall authority and responsibility for the Site Emergency Preparedness.

In order to meet the constantly changing conditions, methods have been implemented to ensure that the Post-Shutdown Emergency Plan and Implementing Procedures remain effective over the life of the Plant. Efforts shall be made to assure continuous emergency preparedness and operational readiness among Entergy personnel and the offsite response agencies and organizations.

8.1 ORGANIZATION PREPAREDNESS 8.1.1 Training Palisades Plant personnel, including non-permanent personnel, will receive training pertinent to the Post-Shutdown Emergency Plan and Implementing Procedures.

Persons assigned specific responsibilities during an emergency will receive additional training appropriate to their respective assignments. The responsibility for training is that of the Training Manager. He may delegate specialty-training responsibilities to personnel qualified to perform such training, for example, State or County training personnel. Governance of Emergency Response Organization Training for Entergy personnel is provided by Procedure P-EN-TQ-110, "Emergency Response Organization Training." This procedure describes the responsibilities for conducting and administering initial and continuing emergency preparedness training; provides clarification and details to implement a remediation process; and follows the guidance of P-EN-TQ-201,"Systematic Approach to Training Process,"

and P-EN-EP-308, "Emergency Planning Critiques."

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 94 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN 8.1.2 Drills and Exercises Members of the operating staff need to be familiar with their specific duties and responsibilities in the event of an accident at the Palisades Plant. To accomplish this, periodic drills and exercises will be conducted to test the state of emergency preparedness. The prime objective of the drills and exercise is to verify emergency preparedness of participating personnel, organizations, and agencies.

Each drill and exercise will be conducted to meet the following objectives:

a. Ensure that the participants are familiar with their respective duties and responsibilities.

b. Verify the adequacy of the Palisades Plant Post-Shutdown Emergency Plan and the methods used in the Implementing Procedures.

c. Test communication networks and systems.

d. Check the adequacy of emergency supplies and equipment.

e. Verify the operability of emergency equipment.

f. Designed to allow for freeplay for decision making.

Emergency Planning will ensure that drills and exercises are conducted as specified in this Plan.

Scheduled drills and exercises will be held involving appropriate offsite as well as onsite emergency personnel, organizations, and agencies. These drills and exercises will be conducted to simulate actual emergency conditions. Drill scenarios will be prepared that involve participation of several emergency teams and will include specific parts of the onsite and offsite emergency organizations such as state, county, and federal organizations, and local services support personnel and organizations. Offsite emergency planning personnel will be given advance notice of the schedule date of the drill or exercise, although the actual details shall be kept confidential from Offsite Response Players. Official observers will be provided with materials in accordance with their requirements.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 95 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN Recommendations for revisions to the Palisades Nuclear Power Plant Post-Shutdown Emergency Plan and/or Implementing Procedures and/or upgrading of emergency equipment and supplies as a result of a drill or exercise will be forwarded to Emergency Planning by observers and participants for inclusion in a formal critique. After review, recommendations will be forwarded to the Manager, Emergency Preparedness for comments. Recommended changes that are approved by the Regulatory and Performance Improvement Director will be incorporated into the Post-Shutdown Emergency Plan and Implementing Procedures. Records shall be maintained on drills and exercises conducted at the Palisades Plant.

8.1.3 Major Drills and Exercises will include the following:

a. Medical Drill A Medical drill shall be conducted at least once per calendar year. The drill shall involve the participation of local medical support personnel and organizations (eg, physicians, ambulance services, hospital, etc). Scenarios may include cases of radiation overexposure, contaminated personnel and/or contaminated/injured personnel.

b. Fire Emergency Drill Drills will be conducted in accordance with the Palisades Fire Plan which has been reviewed and approved by the NRC.

c. Radiological Monitoring Drills A radiological monitoring drill (onsite and/or offsite) shall be conducted annually. This drill shall include the collection and analysis of various materials. These may include grass, water, soil, and air samples.

d. Health Physics Drills Health Physics drills shall be conducted semi-annually which involve response to, and analysis of, simulated elevated airborne and liquid samples, and direct radiation measurements.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 96 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN

e. Radiological Emergency Preparedness Exercise An exercise which tests the Emergency Preparedness Plan and organization shall be conducted at least once per calendar year. These exercises shall be varied such that plans and preparedness organizations are tested completely within an eight-year exercise cycle. Provisions should be made to start exercises between 6:00 PM and 4:00 AM once every eight year exercise cycle, and to develop scenarios that reach Site Area and/or General Emergency levels every two years to assist the state and counties in maintaining their Emergency Preparedness requirements.

Annual exercises may involve the local, county, and state government emergency planning agencies depending on their past participation and schedule in accordance with federal regulations. Federal emergency response agencies shall be involved in a major exercise at least once every five years. Specific items tested are: public warning, adequacy of Emergency Implementing Procedures, communications, accident assessment, radiological monitoring, use of the Protective Action Guidelines, evacuation methodology, direction and control, public information, recovery and reentry operations, and emergency equipment.

Official observers from federal, state, or local governments will be encouraged to observe, evaluate, and critique the required exercises. A critique shall be scheduled at the conclusion of the exercise to evaluate the ability of organizations to respond as called for in the Plan. The critique shall be conducted as soon as practicable after the exercise, and a formal evaluation or report shall result from the critique. Deficiencies identified in this evaluation shall be assigned to appropriate Entergy staff.

f. Communication Tests Communications shall be tested monthly with NRC headquarters from the Control Room, Technical Support Center and near-site Emergency Operations Facility. Communications shall be tested monthly with state and local governments within the plume exposure pathway of the Emergency Planning Zones. Communication shall be tested quarterly with those federal and state emergency response organizations within the ingestion pathway.

Communication links with state emergency operations center and field assessment teams from the Plant shall be tested annually. Communication links with the county emergency operations centers shall be tested annually by calling the respective Sheriff's Department. Communications between the Control Room, Technical Support Center, and Emergency Operations Facility shall be tested annually.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 97 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN 8.1.4 Emergency Planning Emergency Planning has been delegated responsibilities related to emergency planning that include, but are not limited to, the following:

a. Ensure offsite county, state, and supporting emergency plans are compatible with the Palisades Post-Shutdown Emergency Plan.

b. Conduct offsite agency training.

c. Ensure that the information, data, and procedures detailed in the Palisades Nuclear Plant Emergency Implementing Procedures are consistent with the Palisades Post-Shutdown Emergency Plan.

d. Ensure that the Emergency Plan Implementing Procedures are coordinated and interface properly with other procedures (e.g., Administrative Procedures, Security Procedures, Radiation Protection Procedures, and Training Procedures, etc.).

e. Coordinate the onsite emergency planning drill and exercise activities.

f. Coordinate the onsite review and updating of the Palisades Post-Shutdown Emergency Plan and Implementing Procedures.

g. Assist the Palisades Training Department, in coordinating and/or providing emergency planning related specialty training.

h. Ensure the maintenance and inventory of emergency equipment and supplies.

i. Be familiar with current changes in the federal regulations and guidance which impact emergency planning activities.

j. Document all corrective actions resulting from Plant-related Emergency Planning critiques and audits.

k. Initiate appropriate Plant-related corrective actions, if any, resulting from the critiques of each integrated practice drill conducted at the Plant.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 98 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN 8.2 EDUCATIONAL INFORMATION FOR THE PUBLIC For resident and transient members of the public within the 10-Mile Emergency Planning Zone, Entergy Corporation, and the local and state governments will provide written information pertaining to topics associated with emergency planning.

Information provided may include the following topics:

• Notification methods, time required for notification.

• Public initial actions.

• Educational information on radiation.

• Contact points and locations for additional information, including news media or local broadcast stations.

• Protective measures.

• Special needs of the handicapped.

This information can be disseminated to the public via varying methods. These methods may include direct mail of literature, information brochures contained in billing statements, telephone book inserts, and posting information documents in public areas.

At least annually, Entergy Corporation and the local and state governments will update the information, if necessary, for members of the public within the 10-Mile Emergency Planning Zone.

8.3 REVIEW AND UPDATING OF THE POST-SHUTDOWN EMERGENCY PLAN AND IMPLEMENTING PROCEDURES The Palisades Plant Post-Shutdown Emergency Plan involves the coordination of Entergy personnel and offsite support agencies. To achieve and maintain the most efficient course of emergency actions, the Palisades Plant Post-Shutdown Emergency Plan and Implementing Procedures, including appended letters of agreement, will be reviewed on an annual basis and updated as needed. These reviews are conducted to comply with the Entergy procedures, federal regulations, and operation license provisions.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 99 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN Proposed revisions to the Post-Shutdown Emergency Plan, Emergency Implementing Procedures and appended Letters of Agreement shall receive an effectiveness review in accordance with 10 CFR 50.54(q). If the change to the Post-Shutdown Emergency Plan reduces the effectiveness of the Plan, the Nuclear Regulatory Commission (NRC) shall review and approve the change prior to implementation. The proposed change shall be reviewed by the Management and Safety Review Committee (MSRC) prior to Plant Licensing submitting the proposed change to the NRC.

Proposed revisions to the Post-Shutdown Emergency Plan shall be reviewed and approved in accordance with the Procedure P-EN-OM-119, "On-Site Safety Review Committee."

When revisions to the Post-Shutdown Emergency Plan affect offsite support agencies, they shall be notified as the changes occur.

Editorial changes to the Post-Shutdown Emergency Plan or Emergency Implementing Procedures such as titles and telephone lists are not subject to the review process described above.

An independent review of the Emergency Preparedness Program shall be conducted in accordance with 10CFR50.54(t).

The review shall include the Post-Shutdown Emergency Plan, Emergency Implementing Procedures, training, drills and exercises, equipment, and interfaces with state and local governments. Records of the review shall be maintained for at least 5 years. Emergency Planning shall ensure state and local governments have access to appropriate findings.

As the Post-Shutdown Emergency Plan is reviewed, the emergency organization or procedures may be changed as a result of the following:

a. Drills may detect deficiencies and may indicate a more desirable organization or procedure.

b. Changes in key personnel involved in the organization or procedure.

c. Changes in the Plant's organizational structure.

d. Changes in the functions of supporting agencies, resulting from reorganization, personnel changes, and equipment requirements.

e. Changes in state or federal regulations.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 100 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN

f. Modifications to the Plant.

g. Recommendations received from other organizations, such as the state and federal agencies or other nuclear facilities.

8.4 MAINTENANCE AND INVENTORY OF EMERGENCY EQUIPMENT AND SUPPLIES Emergency Planning is responsible for ensuring the quarterly inventory and/or seal inspection is completed for designated emergency supplies and equipment.

Designated emergency equipment and supplies and their storage locations will be listed in the Implementing Procedures. Equipment, supplies, and parts having shelf lives shall be checked and replaced as necessary. Operational readiness of emergency equipment and supplies can be assured by conducting surveillance testing, maintenance checks, calibration, or inventory of all supplies and conducting an annual review of the list of equipment important to Emergency Planning.

8.5 EMERGENCY EQUIPMENT NUCLEAR PERFORMANCE ASSESSMENT DEPARTMENT CONTROLS 8.5.1 Meteorological Monitoring Program The Emergency Preparedness Section controls for the Palisades Plant Meteorological Monitoring Program are defined in Palisades Administrative Procedure 1.14, "Meteorological Monitoring Program."

8.5.2 Dose Assessment Computer Programs The Dose Assessment Computer Programs are in accordance with Procedure P-EN-IT-103, "Nuclear Cyber Security Program."

9.0 RECOVERY In any emergency, the immediate action is directed to limiting the consequences of the incident in a manner that will afford maximum protection of the Plant personnel and the public. Once the immediate corrective and protective actions have established an effective control over the incident situation, the emergency actions will shift into the recovery phase.

A recovery plan, from a practical standpoint, must be flexible enough to adapt to existing, rather than theoretical, conditions. It is not possible to anticipate in advance all of the conditions that may be encountered in an emergency situation; therefore, the Palisades Post-Shutdown Emergency Plan is addressed to general principles that will serve as a guide for developing a flexible plan of action.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 101 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN In the period immediately following an incident, initial radiation monitoring functions will involve only gross hazard evaluations and isolation and definition of radiological problem areas. This immediate radiation surveillance activity is intended to provide the basic information for the second stage of reentry and recovery.

9.1 The following is a brief description of actions that will be examined as required prior to authorizing reentry by the emergency staff.

9.1.1 Review available radiation surveillance data. Determine Plant areas potentially affected by radiation and contamination.

9.1.2 Review radiation exposures of personnel to participate in recovery operations.

Determine need for additional personnel.

9.1.3 Review adequacy of radiation survey instrumentation and equipment (type, ranges, number, calibration, etc).

9.1.4 Preplan survey team activities:

a. Areas to be surveyed

b. Anticipated radiation and contamination levels

c. Radiation survey equipment required

d. Shielding requirements and availability

e. Protective clothing and equipment required

f. Access control procedures (issuance of RWP)

g. Exposure control limits and personnel dosimetry required

h. Decontamination requirements

i. Communications required 9.2 The initial reentry into the Plant areas should encompass the following (in order of priority):

9.2.1 Determine initial recovery operations.

9.2.2 Identify hazards or potential hazards associated with the recovery operations.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 102 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN 9.2.3 Conduct comprehensive radiation surveillance of Plant facilities and define radiological problem areas.

9.2.4 Isolate and post areas in the Plant with appropriate warning signs and rope barriers, as Radiation Areas, High Radiation Areas, and Contaminated Areas, as appropriate.

9.3 The nature and extent of the emergency situation will determine what recovery operations are required. The Recovery Organization described in Section 5 will be established as directed by the Recovery Manager.

9.3.1 In order for the recovery phase of the emergency to commence, the conditions which caused the incident must no longer exist. It is the responsibility of the EOF Emergency Director to determine that the facility and/or surroundings are safe.

9.3.2 The following criteria must be met before the recovery and reentry phase can begin:

a. The Plant is in a controlled and stable condition,

b. The release of radioactive materials to the environment is under control or has ceased.

c. In-plant radiation levels are stable or decreasing.

d. Fire, flood, etc, is under control or has ceased.

e. At least one level of redundancy in plant systems should be available to prevent reinitiation of the event.

f. Consensus has been reached among the SED, EOF Director, NRC, and the State.

9.4 The initial objectives of the recovery program are the determination of the damage to equipment, the installation of shielding, rope barriers and signs, the application of clearance tags, decontamination, and cleanup as required to place the Plant in an acceptable long-term condition. Other recovery operations will not be initiated until the area affected by the emergency has been defined. Particular attention will be directed toward isolating and tagging out components and systems as required to control or minimize hazards. A systematic investigation will be conducted to determine the equipment damaged and the extent of the damage.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 103 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN 9.5 Once the initial objectives are completed, a detailed investigation of the accident causes and consequences both to the Plant and to the environment will be conducted. Determination will be made as to the equipment repair work required as well as the need to modify Plant operating procedures. Repair work and approved modifications shall be carried out as authorized. Test programs to confirm fitness for return to service will be developed and executed.

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

9.7 The State EOC will be advised when the Plant deems it safe to begin the reentry phase of the offsite recovery operation. If the Governor has ordered an evacuation, it is legally required for the Governor to officially rescind the order. The Michigan Department of Environmental Quality is responsible for coordinating reentry procedures for the offsite population.

PALISADES NUCLEAR PLANT PSEP POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 104 of 104 TITLE: POST-SHUTDOWN EMERGENCY PLAN FIGURE 9-1 LONG TERM RECOVERY ORGANIZATION SITE VICE PRESIDENT PLANT COMMUNICATIONS PUBLIC AFFAIRS RECOVERY ADMINISTRATION SPECIALIST DIRECTOR MANAGER AND LOGISTICS PLANNING AND LOGISTICS PLANT PLANT RADIATION PLANT ENGINEERING OPERATIONS PROTECTION MAINTENANCE

PALISADES NUCLEAR PLANT APPENDIX A POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 1 of 2 AGREEMENTS WITH OFF-SITE INDIVIDUALS, AGENCIES, AND ORGANIZATIONS Criteria for agreements with off-site individuals, agencies, and organizations.

Letters of agreement, contracts, or signature pages may be used to verify agreements made with offsite individuals, agencies, and organizations. The use of signature pages is appropriate for use with organizations or agencies where response functions are covered by laws, regulations, or executive orders.

Letters of agreement contain the following as appropriate:

1. Concepts of operations,

2. Emergency measures or services to be provided,

3. Mutually acceptable criteria for implementation,

4. Arrangements for exchange of information,

5. Authorities,

6. Responsibilities,

7. And Limits of actions.

Contracts or contract excerpts may be used in place of letters of agreement and should address the above criteria as appropriate.

As specified in Section 8 of this plan, letters of agreement, contracts, and signature pages will be reviewed annually. The following agreements will be reviewed annually and updated as needed.

1. Covert Fire Department

2. South Haven Area Emergency Services Authority

3. Lakeland Regional Medical Center

4. South Haven Community Hospital

5. Medic 1 Community Emergency Service

6. GEL Laboratories

PALISADES NUCLEAR PLANT APPENDIX A POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 2 of 2 AGREEMENTS WITH OFF-SITE INDIVIDUALS, AGENCIES, AND ORGANIZATIONS

7. Memo on Agreement with NSSS Vendor

8. Memo on Agreement with Nuclear Fuel Supplier

9. Reciprocal Laboratory Use Agreement

10. Institute of Nuclear Power Operations

11. Mutual Assistance Agreement

12. Hostile Action Memorandum of Understanding All letters of agreement, contracts, and signature pages are kept with the master file for this appendix in Document Control.

PALISADES NUCLEAR PLANT APPENDIX B POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 1 of 1 BASIS FOR DELETION OF APPENDIX B OF THE PALISADES POST-SHUTDOWN EMERGENCY PLAN

PALISADES NUCLEAR PLANT APPENDIX C POST-SHUTDOWN EMERGENCY PLAN Attachment A Revision TBD Page 1 of 1 POPULATION DISTRIBUTION AND EVACUATION TIME ESTIMATES The contents of Appendix C have been relocated to a progeny procedure to the Post-Shutdown Emergency Plan. See PSEP Supp 2, "Evacuation Time Estimates,"

Revision 1, August 2012.

PALISADES NUCLEAR PLANT APPENDIX D POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 1 of 8 EMERGENCY IMPLEMENTING PROCEDURES Palisades Site Specific Procedures EI-1 Emergency Classification and Actions (SEP Section 4)

Upon recognition that abnormal Plant or site conditions exist, this procedure will be used in conjunction with SEP Sup 1 "SITE EMERGENCY PLAN Supplement 1 - EAL Wall Charts" to determine the appropriate Emergency Action Level(s) and to assure that all mandatory and subsequent actions are carried out.

EI-1.1 Emergency Response to Credible Security Threats (Canceled) (SEP Section 4)

This procedure provides guidance for declaring and responding to an Unusual Event or an Alert based on a credible security threat. (This procedure was canceled following the implementation of the NEI 99-01 Revision 4 EALs as this version of EALs incorporated the security threat EALs.)

EI-2.1 Emergency Plant Manager (Canceled) (SEP Section 5)

This procedure defines the responsibilities of the Emergency Plant Manager.

EI-2.2 Emergency Staff Augmentation (SEP Section 5)

This procedure establishes a method for augmenting onsite staffing under emergency conditions.

EI-3 Communications and Notifications (SEP Section 6)

This procedure details the notification format and provides call lists of offsite agencies. The primary and alternate communications lines are also described.

EI-4.1 Technical Support Center Activation (SEP Section 5)

This procedure describes the activation, staffing, physical facilities, equipment, and operations of the TSC.

EI-4.2 Operations Support Center Activation (SEP Section 5)

This procedure describes the activation, staffing, physical facilities, equipment, and operations of the OSC.

EI-4.3 Emergency Operations Facility Activation (SEP Section 5)

This procedure describes the activation, staffing, physical facilities, equipment, and operations of the EOF.

PALISADES NUCLEAR PLANT APPENDIX D POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 2 of 8 EMERGENCY IMPLEMENTING PROCEDURES EI-5.0 Reentry (SEP Section 9)

This procedure provides guidelines for entry into the affected area of the Plant after the emergency condition has been stabilized. It also provides guidelines for the initial recovery operation prior to the establishment of the Long-Term Recovery Organization.

EI-5.1 Recovery (SEP Section 9)

This procedure describes the recovery phase of emergency response at Palisades, and provides guidelines for restoring the plant to its preemergency condition.

EI-6 Rapid Dose Calculation (SEP Section 6)

This procedure provides a method to determine the appropriate steps required to calculate offsite dose and recommend offsite protective actions.

EI-6.1 Release Rate Determination from Stack Gas Monitors (SEP Section 6)

This procedure provides a manual calculation of a release rate for radioactive effluents from the Plant stack.

EI-6.2 Release Rate Determination from Steam Line Monitors RIA-2323 and RIA-2324 for Steam Releases Through Atmospheric Dump Valves (SEP Section 6)

This procedure provides a manual calculation of a release rate for radioactive effluents from the atmospheric dump valves.

EI-6.3 Release Rate Determination from High-Range Effluent Monitors (SEP Section 6)

This procedure provides a release rate calculation for radioactive effluents from the Plant stack or steam dumps.

EI-6.4 Release/Potential Release Determination from Containment High-Range Monitors (SEP Section 6)

This procedure provides a release/potential release rate from radioactive material released into containment.

EI-6.6 Gamma E-Bar Determinations (SEP Section 6)

This procedure provides a Gamma E-Bar (Average Gamma Energy Per Disintegration) for input into offsite dose calculations.

PALISADES NUCLEAR PLANT APPENDIX D POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 3 of 8 EMERGENCY IMPLEMENTING PROCEDURES EI-6.7 Plant Site Meteorological System (SEP Section 7)

This procedure provides a means to access the Plant site meteorological system for meteorological data required in the offsite dose calculations.

EI-6.8 Backup and Supplemental Meteorology (SEP Section 7)

This procedure provides a means to access the Weather Services International (WSI) meteorological system and obtain meteorological data required in the offsite dose calculations when onsite meteorological data is not available.

EI-6.9 Automated Dose Assessment Program (SEP Section 6)

This procedure provides basic instruction on how to initiate and operate the IBM PC Automated Dose Assessment Program "Offsite."

EI-6.10 Offsite Dose Calculation - Straight Line Gaussian (Manual Method)

(SEP Section 6)

This procedure provides a manual backup to the automated dose assessment program to calculate whole body and thyroid dose rates.

EI-6.13 Protective Action Recommendations for Offsite Population (SEP Section 6)

This procedure provides guidelines for determining protection actions for the general public to be recommended to the appropriate state and local authorities in the event of a radiological emergency.

EI-7.0 Emergency Post Accident Sampling and Determination of Fuel Failure Using Dose Rates (SEP Section 6)

This procedure provides the decision process necessary to implement sampling under emergency conditions.

EI-7.1 Emergency Sampling - PCS Liquid/Gas and Containment Air (Canceled)

This procedure describes the sequential method of sampling the Primary Coolant System (PCS) and/or the containment atmosphere during a post-accident condition using the PASM panel. (This procedure was canceled following elimination of the PASM panel.)

PALISADES NUCLEAR PLANT APPENDIX D POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 4 of 8 EMERGENCY IMPLEMENTING PROCEDURES EI-7.2 Emergency Post Accident Analysis (Canceled)

This procedure describes the sequential method of analyzing the PCS samples obtained during an accident condition. (This procedure was canceled following elimination of the PASM panel.)

EI-7.3 Hydrogen and Oxygen Gas Analysis of Post-Accident Samples (Canceled)

This procedure describes the steps necessary to determine the hydrogen concentration from a PCS gas sample collected at the PASM panel, as well as the hydrogen and oxygen concentration from containment atmospheric gas samples.

(This procedure was canceled following elimination of the PASM panel.)

EI-7.4 Post Accident Gas and Liquid Activity Analysis (Canceled)

This procedure describes the steps necessary to analyze samples for gamma activity during a post-accident condition. (This procedure was canceled following elimination of the PASM panel.)

EI-7.5 Boron: Chloride Ion Chromatography Method Post Accident (Canceled)

This procedure describes the steps necessary to analyze and determine the boron concentration in a diluted PCS sample during a post-accident condition. (This procedure was canceled following elimination of the PASM panel.)

EI-7.8 pH: Hydrogen Specific Ion Electrode (Canceled 10/95)

This procedure describes the steps necessary to determine the pH of an undiluted PCS sample during a post-accident condition. (This procedure was canceled 10/95).

EI-7.10 Post Accident Sampling, Radioactive Gaseous Effluent Monitoring (SEP Section 6)

This procedure describes the steps necessary to obtain a post-accident sample of the stack effluent utilizing the radioactive gaseous effluent monitor.

EI-8 Onsite Radiological Monitoring (SEP Section 6)

This procedure provides guidelines for post-accident radiological monitoring on site.

EI-9 Offsite Radiological Monitoring (SEP Section 6)

This procedure provides guidelines for post-accident radiological monitoring off site.

PALISADES NUCLEAR PLANT APPENDIX D POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 5 of 8 EMERGENCY IMPLEMENTING PROCEDURES EI-10 Accident Environmental Assessment (SEP Section 6)

This procedure provides guidelines for post-accident collection and replacement of accident TLDs, obtaining data from air monitoring stations, collection and assessment of waterborne effluents, and obtaining water/milk/vegetation samples.

EI-11 Determination of Extent of Core Damage (SEP Section 6)

This procedure provides a method of estimating the degree of core damage during accident conditions.

EI-11.2 Core Damage Assessment from Post Accident Sampling (Canceled)

This procedure provides a method of determining extent of core damage via gamma isotopic analysis at the PASM panel. (This procedure was canceled following elimination of the PASM panel.)

EI-12.1 Personnel Accountability and Assembly (SEP Section 6)

To provide guidelines and assign responsibility for personnel assembly and accountability.

EI-12.2 Assembly Area Personnel Lists (Canceled 10/95)

Provides updates for assembly area lists. (This procedure was canceled 10/95).

EI-12.3 Search and Rescue Team Responsibilities (SEP Section 6)

Provides guidelines for search and rescue teams during an emergency.

EI-13 Evacuation/Reassembly (SEP Section 6)

This procedure provides site evacuation procedures and the subsequent reassembly of personnel.

EI-14 Medical Care/Treatment of Contaminated, Injured Personnel (SEP Section 6)

This procedure provides guidelines on personnel emergency radiation exposure limits, personnel decontamination procedures, the use of thyroid blocking agents, and the methods of transporting contaminated/injured victims to hospitals.

PALISADES NUCLEAR PLANT APPENDIX D POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 6 of 8 EMERGENCY IMPLEMENTING PROCEDURES EI-15.1 Drills and Exercises (Cancelled)

This procedure details the requirements for drills and exercises which test the efficiency of the Site Emergency Plan. (This procedure was canceled following the implementation of Entergy Procedure EN-EP-306, Drills and Exercises.)

EI-15.2 Communications Tests (SEP Section 8)

This procedure establishes requirements for testing the emergency communications systems.

EI-15.3 Post Accident Sample Monitoring System Operator Training (Canceled)

This procedure provides training guidelines for the post-accident sample panel.

(This procedure was canceled following elimination of the PASM panel.)

EI-16.1 Maintenance of Emergency Equipment (SEP Section 7)

This procedure establishes a method for the regular inventory and testing of emergency equipment and supplies.

EI-16.2 Post Accident Sample Monitoring System Supplies and Associated Equipment Checks (Canceled)

This procedure establishes a method for the regular inventory and operability checks of the Post Accident Sample Monitoring Panel supply cabinets and associated equipment. (This procedure was canceled following elimination of the PASM panel.)

EI-17 Compensating Measures For OOS EAL Equipment And Listing Of Non-EAL Equipment Important For Emergency Preparedness This procedure lists equipment important to Emergency Preparedness. It provides time restrictions for the length of time the equipment may be out of service.

Additional Procedures P-EN-EP-306 Drills and Exercises This procedure provides guidance for the planning, preparation, scheduling, conduct, evaluation, and documentation of Emergency Planning drills and exercises.

PALISADES NUCLEAR PLANT APPENDIX D POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 7 of 8 EMERGENCY IMPLEMENTING PROCEDURES P-EN-EP-307 Hostile Action Based Drills and Exercises This procedure provides guidance for the preparation and conduct of integrated Emergency Planning (EP) and Security exercises using hostile action based scenarios; and, provides guidance for the preparation and conduct of a pre-exercise hostile action-based tabletop.

P-EN-EP-308 Emergency Planning Critiques This procedure describes the means for tracking and correcting deficiencies identified in drills.

P-EN-EP-310 Emergency Response Organization Notification System This procedure provides guidance to maintain the ERO notification system in a state of readiness.

P-EN-EP-311 Emergency Response Data System (ERDS) Activation via the Virtual Private Network (VPN)

This procedure provides for a secure network communications connection supporting the transmission of station parameters to the Nuclear Regulatory Commission (NRC) in the event of a declared emergency; and provides instructions for verification of connections for those plants which maintain 24/7 connectivity.

P-EN-EP-313 Offsite Dose Assessment using the Unified RASCAL Interface This procedure provides the methods and instructions for performing offsite dose assessment using the Unified RASCAL Interface (URI).

P-EN-EP-609 Emergency Operations Facility (EOF) Operations This procedure provides guidance to activate and operate the EOF focusing on classification, notification, dose assessment and protective action recommendations.

P-EN-EP-610 Technical Support Center (TSC) Operations This procedure provides guidance to activate and operate the TSC; and, contains guidelines regarding personnel emergency radiation exposure limits and issuance of thyroid blocking agents.

PALISADES NUCLEAR PLANT APPENDIX D POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 8 of 8 EMERGENCY IMPLEMENTING PROCEDURES P-EN-EP-611 Operations Support Center (OSC) Operations This procedure provides guidance to activate and operate the OSC.

P-EN-EP-801 Emergency Response Organization This procedure outlines expectations and responsibilities for Emergency Response Organization (ERO) members, Site Management and the Emergency Planning staff; and, outlines responsibilities for personnel assigned to an ERO position and for other company personnel who may be called upon to support an emergency response effort, but are not directly assigned to an ERO position.

P-EN-TQ-110 Emergency Response Organization Training This procedure establishes the training and qualification requirements for personnel assigned to the Emergency Response Organization (ERO); and establishes the training offered to off-site emergency response organizations.

P-EN-TQ-110-01 EPlan Training Course Summary This procedure lists the specific curricula and learning items required for each of the Emergency Response Organization (ERO) positions specified in P-EN-EP-801, Emergency Response Organization.

PALISADES NUCLEAR PLANT APPENDIX E POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 1 of 1 GENERAL EQUIPMENT IN EMERGENCY KITS Emergency kits will be maintained and inspected at least quarterly and readily accessible. Kits are typically maintained in the following locations: Technical Support Center (TSC),

Operations Support Center (OSC), Emergency Operations Facility (EOF), Emergency Vehicles, Health Physics Office and support hospitals. Specific kit locations are specified in the Emergency Implementing Procedures. Specific equipment inventories are contained in the Emergency Implementing Procedures.

Emergency kits consist of the following generic equipment classifications:

a. Monitoring instrumentation and equipment including: dose rate and count rate meters, air sampling equipment, personnel dosimetry equipment.

b. Protective equipment including: protective clothing, respiratory equipment, thyroid blocking agent.

c. Communications equipment including: radios, telephones, microphones.

d. Reference material including: Emergency plans and procedures, maps, equipment lists, spare forms.

e. Miscellaneous equipment including: survey, posting and boundary equipment, plastic bags, flashlights, office supplies, decontamination equipment.

f. Maintenance equipment.

g. Medical Emergency equipment including: monitoring instrumentation and equipment, protective equipment, survey, posting and boundary equipment, decontamination and first aid supplies.

h. Medical Emergency First Aid equipment including: Medical First Aid supplies for use in responding to contaminated or noncontaminated injuries.

PALISADES NUCLEAR PLANT APPENDIX I POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 1 of 4 NUREG-0654 CROSS REFERENCE NUREG-0654 FEMA-REP-1 REV 1 POST-SHUTDOWN EMERGENCY PLAN*

A.1.a Section 5 A.1.b 5.1 through 5.5 A.1.c Figure 5.1 A.1.d 3.2 A.1.e 3.2, Table 7-1 A.3 5.6, 5.7, 5.8, Appendix A A.4 5.1 B.1 5.2 B.2 5.2.5 B.3 5.4.1 B.4 5.4.1 B.5 Figure 5-2 B.6 5.3 through 5.8, Figure 5-1 B.7.a 5.4 B.7.b 5.5 B.7.c Figure 5-1 B.7.d 5.3.5 B.8 5.8, Appendix A B.9 5.6.1 through 5.6.3, Appendix A C.1.a 5.7.2 C.1.b 7.1, 7.2 C.1.c 5.7.2.a C.2.b 6.1.3.n C.3 7.7.2 C.4 Appendix A D.1 Table 4-1 and POST-SHUTDOWN EMERGENCY PLAN Supplement 1 - EAL Wall Charts D.2 POST-SHUTDOWN EMERGENCY PLAN Supplement 1 -

EAL Wall Charts E.1 6.1.3.f, 6.1.3.h, Figure 6-1 E.2 5.4 E.3 6.1.1.b.2(f)

• The referenced section of the Post-Shutdown Emergency Plan represents the principal location where the NUREG is addressed.

PALISADES NUCLEAR PLANT APPENDIX I POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 2 of 4 NUREG-0654 CROSS REFERENCE NUREG-0654 FEMA-REP-1 REV 1 POST-SHUTDOWN EMERGENCY PLAN*

E.4 6.1.1.b.2(g)

E.6 6.4.1.b.3(a)

E.7 6.4.1.b F.1 3.2, Table 7-1, 6.1.1, 6.1.2 F.2 7.8.1 F.3 8.1.2 G.1 8.2 G.2 8.2 G.3 5.3.5, 7.4 G.4.a 5.3.5 G.4.b 5.3.5 G.4.c 5.3.5 G.5 8.2 H.1 5.3.2 H.2 5.3.4 H.4 5.4 H.5 7.6 H.6 7.6.2, 7.7 H.7 7.7.1 H.8 7.6.2 H.9 5.3.3 H.10 8.4 H.11 Appendix E H.12 7.2 I.1 POST-SHUTDOWN EMERGENCY PLAN Supplement 1 -

EAL Wall Charts I.2 7.6 I.3 6.2.5 I.4 7.6, 7.7 I.5 7.6.2 I.6 6.2.5 I.7 7.7.1

• The referenced section of the Post-Shutdown Emergency Plan represents the principal location where the NUREG is addressed.

PALISADES NUCLEAR PLANT APPENDIX I POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 3 of 4 NUREG-0654 CROSS REFERENCE NUREG-0654 FEMA-REP-1 REV 1 POST-SHUTDOWN EMERGENCY PLAN*

I.8 6.2.5 I.9 7.7.1 I.10 6.2.5 J.1 6.4.1.a.1 J.2 6.4.1 J.3 6.4.1.a.4 J.4 6.4.1 J.5 6.4.1.a.1 J.6 7.8.6 J.7 6.1.1 J.8 POST-SHUTDOWN EMERGENCY PLAN Supplement 2 -

Evacuation Time Estimates J.10 6.4.1.b, 7.7 K.1 6.5 K.2 6.5.1 K.3 6.5.1 K.5 6.4.2, 6.5.2 K.6 6.4.2 K.7 6.5.2 L.1 5.6.1 L.2 6.5.2 L.4 5.6.1 M.1 9.0 M.2 Figure 9-1 M.3 9.0 M.4 6.2.5 N.1 8.1.2 N.2 8.1.2 N.3 8.1.2 N.4 8.1.2 N.5 8.1.2 O.1 8.1.1

• The referenced section of the Post-Shutdown Emergency Plan represents the principal location where the NUREG is addressed.

PALISADES NUCLEAR PLANT APPENDIX I POST-SHUTDOWN EMERGENCY PLAN Revision TBD Page 4 of 4 NUREG-0654 CROSS REFERENCE NUREG-0654 FEMA-REP-1 REV 1 POST-SHUTDOWN EMERGENCY PLAN*

O.2 8.1.1, 8.1.2 O.3 6.5.2 O.4 8.1.1 O.5 8.1.1 P.1 8.1 P.2 5.1 P.3 8.1.3 P.4 8.3 P.5 8.3 P.6 2.5.3 P.7 Appendix D P.8 Table of Contents P.9 8.3 P.10 8.1.3f

• The referenced section of the Post-Shutdown Emergency Plan represents the principal location where the NUREG is addressed.

Attachment 5 To Entergy Letter PNP 2017-034 Palisades Nuclear Plant Analysis of Proposed Post-Shutdown On-Shift Staffing (44 Pages)

PNP ANALYSIS OF PROPOSED POSTSHUTDOWN ONSHIFT STAFFING PALISADES NUCLEAR PLANT ANALYSIS OF PROPOSED POST-SHUTDOWN ON-SHIFT STAFFING August 2017 Palisades Nuclear Plant Page 1 Rev. 0

PNP ANALYSIS OF PROPOSED POSTSHUTDOWN ONSHIFT STAFFING TABLE OF CONTENTS I. INTRODUCTION ................................................................................................................................. 3 II. ANALYSIS

SUMMARY

....................................................................................................................... 3 A. Emergency Plan Minimum Staffing ...................................................................................... 5 B. Other Commitments to Shift Staffing ................................................................................... 7 C. Staffing Exceptions and Time Motion Studies (TMS) ....................................................... 7 D. Emergency Plan Tasks Not Analyzed ................................................................................. 9 III. ANALYSIS PROCESS ........................................................................................................................ 9 IV. ACCIDENT SCENARIOS ................................................................................................................. 10 A. Accident Selection ................................................................................................................ 10 B. Accident Scenarios included in the Analysis .................................................................... 10 C. Accident Scenarios not included in the Analysis ............................................................. 11 V. GENERAL ASSUMPTIONS AND LIMITATIONS ......................................................................... 12 A. Notes and Assumptions applicable to all accidents in PNP Staffing Analysis: ........... 12 B. Additional Assumptions ....................................................................................................... 12 VI. APPENDIX A - ANALYZED EVENTS AND ACCIDENTS ........................................................... 15 VII. APPENDIX B - ON-SHIFT STAFFING ANALYSIS ..................................................................... 16 A. Accident Analysis #1 - Design Basis Threat .................................................................... 16 B. Accident Analysis #2 - Fuel Handling Accident ............................................................... 21 C. Accident Analysis #3 - Aircraft Probable Threat ............................................................. 26 D. Accident Analysis #4 - Control Room Fire Requiring Evacuation and Maintain SFP Cooling ................................................................................................................................... 31 E. Accident Analysis #5 -General Emergency with Radioactive Release and PAR ...... 36 VIII. APPENDIX C - TIME MOTION STUDIES SUPPORTING THE STAFFING ANALYSIS ...... 41 A. Multiple Scenarios (Bounding for all Analyses)................................................................ 41 IX. OVERLAP OF TASKS ACTIVITIES OR OTHER CONFLICTS IDENTIFIED .......................... 44 A. Overlap Requiring Compensatory Measures ................................................................... 44 X. REFERENCES ................................................................................................................................... 44 Palisades Nuclear Plant Page 2 Rev. 0

PNP ANALYSIS OF PROPOSED POSTSHUTDOWN ONSHIFT STAFFING I. INTRODUCTION On January 4, 2017, Entergy Nuclear Operations, Inc. (ENO) informed the Nuclear Regulatory Commission (NRC) that the Palisades Nuclear Plant (PNP) will permanently cease power operations on October 1, 2018. ENO will supplement the January 4, 2017 letter certifying the cessation date in accordance with 10 CFR 50.82(a)(1)(i) and 10 CFR 50.4(b)(9). Once fuel has been permanently removed from the reactor vessel, ENO will submit a written certification to the NRC, in accordance with 10 CFR 50.82(a)(1)(ii) that meets the requirements of 10 CFR 50.4(b)(9). Upon docketing of these certifications, the 10 CFR Part 50 license for PNP will no longer authorize operation of the reactor or emplacement or retention of fuel into the reactor vessel, as specified in 10 CFR 50.82(a)(2). In the permanently defueled condition, the Final Safety Analysis Report (FSAR) credible accidents (postulated accidents) are reduced via the 50.59 process. In order to address the transition from an operating facility to a permanently defueled facility, changes are required to preserve the effectiveness of the PNP Site Emergency Plan (SEP) to properly reflect the conditions of the facility.

This report details the preliminary analysis of the proposed post-shutdown on-shift staffing for PNP, incorporating anticipated changes to the on-shift staffing and postulated accidents to address the post-shutdown and permanently defueled conditions. Specifically, it reassigns some on-shift tasks to align with proposed changes to on-shift staffing and the resulting changes to PNP Emergency Plan Implementing Procedures (EPIPs). This analysis will be updated and formal Time Motion Studies (TMS) will be conducted, as necessary, following development and validation of procedures that address PNPs permanently shut down and defueled conditions.

This analysis evaluates the ability of the proposed post-shutdown minimum on-shift staff to implement all emergency tasks, as applicable to the permanently shut down and defueled conditions.

This analysis satisfies the requirements of 10 CFR Part 50, Appendix E Section IV.A.9, which states that nuclear power licensees shall perform a detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan. To support reduced staffing following permanent cessation of power operations and permanent removal of fuel from the reactor vessel, the proposed post-shutdown on-shift staffing was evaluated in conjunction with the postulated accidents that will be applicable in the permanently defueled condition and assumed corresponding changes to procedures. This analysis examined the capability of the proposed post-shutdown minimum staff to perform the actions for the key functional areas for events applicable in the permanently defueled condition until augmenting Emergency Response Organization (ERO) staff arrives in accordance with the PNP SEP.

II. ANALYSIS

SUMMARY

This analysis determined that a proposed post-shutdown on-shift staff of eight (8) (including the required Fire Brigade) can cope with the spectrum of analyzed events, as described in Section IV of this report, until Palisades Nuclear Plant Page 3 Rev. 0

PNP ANALYSIS OF PROPOSED POSTSHUTDOWN ONSHIFT STAFFING augmenting ERO staff arrives. The on-shift staff consists of individuals necessary to support each of the following emergency plan functional areas or tasks:

Emergency Direction and Control Plant Operations and SFP Cooling Fire Fighting (Fire Brigade)

Accident/Dose Assessment Radiation Protection and Chemistry Notification/Communication Access Control and Accountability It is acceptable for certain functions to be assigned to personnel already assigned other functions/tasks. These include Repair and Corrective Action, Rescue Operations, and First Aid.

PNP intends to enter the post-shutdown and permanently defueled condition with a 5-person Fire Brigade.

However, 10 CFR 50.48(f) states, Licensees that have submitted the certifications required under § 50.82(a)(1) shall maintain a fire protection program to address the potential for fires that could cause the release or spread of radioactive materials (i.e., that could result in a radiological hazard). 10 CFR 50.48(f)(1)(ii) requires the plant to rapidly detect, control, and extinguish fires that do occur. The NRC has provided guidance in Regulatory Guide 1.191, Fire protection Program for Nuclear Plants During Decommissioning and Permanent Shutdown.

Subsection 4.3.4 Onsite Fire Brigade and Offsite Fire Emergency Response, provides guidance with regards to maintenance of a fire brigade during the post-shutdown period. The following factors should be considered in determining the manual firefighting capability:

The magnitude and complexity of potential fires in and around plant areas where radioactive materials or contamination are present The availability of onsite staffing for a fire brigade at any time.

The availability of offsite emergency services, the capability of their staff and equipment, the response time, the staffs training, and access to the plant.

The compatibility of the plants fire system connections and fittings with the fire apparatus and equipment of the offsite responders.

Considering the guidance in RG 1.191, PNP could elect to evaluate the possibility of making changes to the fire protection program, considering system abandonments and the reduction of hazards. This analysis could potentially include an evaluation of the feasibility of a smaller fire brigade. However, this analysis of proposed post-shutdown on-shift staffing considers the current 5-person fire brigade.

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PNP ANALYSIS OF PROPOSED POSTSHUTDOWN ONSHIFT STAFFING A. Emergency Plan Minimum Staffing Per 10 CFR 50.54(q)(1)(iii), Emergency planning function means a capability or resource necessary to prepare for and respond to a radiological emergency, as set forth in the elements of section IV of Appendix E and, for nuclear power reactor licensees, the planning standards of § 50.47(b).

Only personnel proposed to be on-shift are credited in this analysis. This proposed staffing consists of a Shift Manager; two Non-Certified Operators; and one Radiation Protection Technician. An individual qualified as a CFH will supervise fuel handling operations in the permanently shut down and defueled condition. Shift Managers will be qualified as CFHs. The Shift Manager requires additional qualification beyond the CFH training. Command and Control will remain with the Shift Manager, regardless of location.

Additionally, four additional Fire Brigade positions and shift Security personnel are assigned. The on-shift staffing utilized for this analysis was defined with the following considerations:

The Shift Manager performs as Emergency Director until properly relieved by a qualified position.

After being relieved by another Command and Control position, the Shift Manager will provide assistance and direction to the Control Room staff as necessary.

Non-Certified Operator duties include providing technical support for plant systems, providing input on repair and corrective actions, and notifications as directed by the Shift Manager. These notifications include the following: 1) required notifications to the states and counties; 2) required notifications to the NRC; and 3) notifications to the Emergency Response Organization. A Non-Certified Operator will also serve as the Fire Brigade Leader in compliance with the PNP fire protection program implementation with requisite plant knowledge to fill this role.

Non-Certified Operator duties include making repairs and corrective actions on plant equipment until augmented plant maintenance staff arrives, participating as an active member of the Fire Brigade, or as Fire Brigade Leader when assigned by the Shift Manager.

Shift Radiation Protection (RP) Technician duties include conducting radiological accident assessment and support, offsite dose assessment as requested by the Shift Manager, onsite in plant surveys, and chemistry and radiochemistry analysis.

The proposed Fire Brigade minimum complement is 5, consisting of a Non-Certified Operator (Fire Brigade Leader) and four (4) other Fire Brigade qualified staff members assigned other functions.

The following table contains the proposed post-shutdown on-shift positions expected to be in place following shutdown and permanent removal of fuel from the reactor vessel.

This analysis will be updated and formal TMSs will be conducted, as necessary, following development and validation of procedures that address PNPs permanently shutdown and defueled conditions to verify the proposed post-shutdown on-shift staffing is appropriate.

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PNP ANALYSIS OF PROPOSED POSTSHUTDOWN ONSHIFT STAFFING Proposed On-Licensing Basis Shift Staffing Position E-Plan Functional Area Requirement Analysis Results Shift Manager (SM) Emergency Direction E-Plan Figure 5-2 1 (Certified Fuel Handler (CFH1)) and Control Non-Certified Operator #11 E-Plan Figure 5-2 Notifications/Communications 1 Non-Certified Operator #21 E-Plan Figure 5-2 Fire Brigade Leader 13 Fire Brigade #2 (FB #2) E-Plan Figure 5-2 Fire Brigade 13, 4 Fire Brigade Fire Brigade #3 (FB #3) E-Plan Figure 5-2 13, 4 Fire Brigade #4 (FB #4) E-Plan Figure 5-2 Fire Brigade 13, 4 Fire Brigade #5 (FB #5) E-Plan Figure 5-2 Fire Brigade 13, 4 Radiation Protection (RP) Radiation Protection E-Plan Figure 5-2 1 Technician Accident/Dose Assessment2 Security Contingency Access Control and Per Security Security Plan/E-Plan Figure 5-2 Accountability Contingency Plan TOTAL 8 1

Use of the titles, CFH and Non-Certified Operator, are dependent upon NRC approval of proposed changes to Technical Specifications.

Individuals qualified as CFHs will supervise fuel handling operations in the permanently defueled condition. Shift Managers will be qualified as CFHs. The Shift Manager requires additional qualification beyond the CFH training. Non-Certified Operators will perform duties typically associated with those formerly performed by Non-Licensed Nuclear Plant Operators, such as manipulation and monitoring of plant equipment.

2 The Radiation Protection Technician is assigned Accident/Dose Assessment responsibilities in the Fuel Handling Accident analyses (Analyses #2 and #5). However, the Shift Manager and Non-Certified Operators are trained and qualified to perform accident/dose assessment and could be perform the task at the direction of the Shift Manager. There are no Accident/Dose Assessment tasks identified as being required during the remaining analyses.

3 The Fire Brigade consists of a minimum of 5 responders, the Fire Brigade Leader and a minimum of four (4) trained and qualified Fire Brigade Members. These positions do not have any actions or tasks that would conflict with Fire Brigade responsibilities in the events analyzed. The on-shift member is available to support the Shift Manager, where qualified, in non-fire events.

4 Provided by Fire Brigade qualified staff assigned other functions.

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PNP ANALYSIS OF PROPOSED POSTSHUTDOWN ONSHIFT STAFFING B. Other Commitments to Shift Staffing None C. Staffing Exceptions and Time Motion Studies (TMS)

1. No chemistry job tasks were noted as being required within the first 90 minutes of any of the analyzed events. Because the Chemistry Technician was not identified as having any specific Chemistry/Radiochemistry-related emergency tasks, and because the on-shift Radiation Protection Technician will be trained to perform sampling and analysis, the Chemistry Technician position is unnecessary and is not included in the proposed post-shutdown on-shift staffing complement.

2. During fuel movement, additional Operations and Radiation Protection personnel that are not part of the on-shift staff will be on site that, were a fuel handling accident to occur, will be able to respond to the event. Consequently, there are an adequate number of qualified personnel to perform plant surveys and dose assessment in the event of a fuel handling accident as discussed in Events 2 and 5. The task of accident/dose assessment will be performed as directed by the Shift Manager. It is acceptable to assign the Radiation Protection Technician the emergency plan function of dose assessment. No further analysis or TMS is required.

3. Because PNP will no longer be authorized to operate the reactor or place fuel into the reactor vessel, the Shift Engineer/Shift Technical Advisor position is unnecessary and is not included in the proposed post-shutdown on-shift staffing complement.

4. Because PNP will no longer be authorized to operate the reactor or place fuel into the reactor vessel, the Safe Shutdown (SSD) task is not necessary and is not considered in this analysis.

5. Because of the reduced actions necessary to mitigate an emergency in the permanently shut down and defueled condition and the minimal actions of the Control Room positions in this condition, no Licensed Nuclear Control Operator job tasks were noted as being required for any of the analyzed events. Because the Licensed Nuclear Control Operators were not identified as having any specific emergency tasks during the scenarios evaluated for this analysis, the position is not included in the proposed post-shutdown on-shift staffing complement.

6. The Shift Manager is assigned the responsibility to make some site specific event notifications such as to the Duty Plant Manager, Operations Manager, and Resident Inspector. These notifications by phone are considered communications that are approximately one minute in length and are deemed acceptable due to the short duration of the notifications. Additionally, these notifications are collectively evaluated in conjunction with other Shift Manager duties and responsibilities during Operations simulator training evaluations and Emergency Plan drills and are not deemed as impacting the Shift Managers ability to maintain oversight of the event or perform other required emergency plan tasks. Line 14 of Table 5 contained in Section VII of this Palisades Nuclear Plant Page 7 Rev. 0

PNP ANALYSIS OF PROPOSED POSTSHUTDOWN ONSHIFT STAFFING report does not reflect the performance of these short duration notifications. No further analysis or TMS is required.

7. A TMS was performed to verify the capability of the Non-Certified Operator to perform the Notification/Communication responsibilities assigned in each analysis. The PNP process for completing state and local emergency notification forms and performing the off-site notifications is automated and requires minimal manual actions. A TMS was conducted and demonstrated that these tasks could be performed by the on-shift Non-Certified Operator without impacting the ability of the Non-Certified Operator to remain in role providing support and oversight during the emergency. The TMS demonstrated the Notification/Communication responsibilities could be performed individually or in series without impacting the Non-Certified Operator function. The results are documented in Section VIII of this analysis.

The TMS is considered bounding for all scenarios considered in this analysis and demonstrated the Notification/Communication responsibilities could be performed individually or in series without impacting the Non-Certified Operator function. The results are documented in Section VIII of this analysis.

8. Station staff are required to maintain continuous communications with the notification source during an aircraft threat in accordance with 10 CFR 50.54(hh) and Reg. Guide 1.214. There are no specific qualifications required to perform this task and the function is not required to be assigned in advance. The analysis of this event identified there are sufficient personnel on-shift to perform this task during the event. No further analysis or TMS is required.

9. The Shift Manager is assigned the task of notifying the off-shift ERO of the emergency. A TMS was conducted during development of the initial Palisades Nuclear Station On-Shift Staffing Analysis Report to determine if the Shift Manager could perform the task of notifying the ERO of the emergency while continuing to maintain emergency direction and control. The TMS demonstrated the Shift Manager was able to maintain Emergency Direction and Control during the approximate 2 minutes it took to notify the ERO. Additionally, the task of ERO notification is routinely evaluated in conjunction with other Shift Manager duties and responsibilities during Operations simulator training evaluations and Emergency Plan drills. No further analysis or TMS is required.

10. NRC event notifications required due to the declaration of an Emergency Classification in accordance with 10 CFR 50.72 is made verbally using the Emergency Notification System. A written event notification form is not generated by on-shift staff for this notification. Formal written notifications to the NRC as may be required by 10 CFR 50.72 resulting from any of the analyzed events may be generated by the augmented staff. The task of completing the NRC event notification form is therefore not included as an on-shift task requiring evaluation as part of this staffing analysis.

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PNP ANALYSIS OF PROPOSED POSTSHUTDOWN ONSHIFT STAFFING D. Emergency Plan Tasks Not Analyzed

1. Repair and Corrective Action - Per the guidance of NUREG-0654, Table B-1, repair and corrective action tasks may be performed by shift personnel assigned other functions. Repair and corrective action is defined as:

An action that can be performed promptly to restore a non-functional component to functional status (e.g., resetting a breaker), or to place a component in a desired configuration (e.g.,

open a valve), and which does not require work planning or implementation of lockout/tagout controls to complete.

The analysis included a review of repair and corrective action tasks. For the purpose of this analysis, the tasks were considered to fall into two broad categories:

Unplanned/unexpected actions that address equipment failures. These actions are contingent in nature and cannot be specified in advance.

Planned/expected actions performed in support of operating procedure implementation, including severe accident management guidelines.

Non-Certified Operators are trained to perform the actions associated with this functional area.

Actions (e.g., reset breakers, valve manipulation) directed by the Shift Manager to mitigate the event per procedures were performed by the Non-Certified Operators in this analysis. Repair and Corrective Action is an acceptable collateral duty and was not analyzed.

2. Rescue Operations and First Aid: The analysis also included a review of rescue operations and first aid response although neither task was required during the evaluated scenarios. Per the guidance of NUREG-0654, Table B-1, rescue operations and first aid may be performed by shift personnel assigned other functions. The on-shift Radiation Projection staff is trained and available to perform first aid and the site Fire Brigade staff are trained and available to perform rescue operations if required. First aid and rescue operations are acceptable collateral duties .

III. ANALYSIS PROCESS The initial staffing analysis report, Rev. 0, was conducted by a joint team of corporate Emergency Preparedness (EP) personnel and station personnel from the Operations, Training, Licensing, Radiation Protection, Chemistry and Emergency Preparedness (EP) departments. Additionally, members of the Security staff provided input to the analysis. Revision 1 of the initial report was developed based on input, reviews and concurrence from station personnel from the same departments as those participating in the original analysis. The review process for the administrative changes included in Revisions 2, 3, and 4 was limited to an independent peer review and final review and concurrence by the PNP EP Manager.

The current analysis was developed by reviewing each scenario from Revision 4 to determine its applicability in a permanently shut down and defueled condition and what plant actions and emergency plan implementation Palisades Nuclear Plant Page 9 Rev. 0

PNP ANALYSIS OF PROPOSED POSTSHUTDOWN ONSHIFT STAFFING actions were required based on plant procedures prior to staff augmentation. These actions were then compared to the proposed post-shutdown on-shift staff positions expected to be in place following shutdown and permanent removal of fuel from the reactor vessel, ensuring that no actions were assigned to staff members that conflicted with either their proposed emergency plan role or operational role as appropriate. In cases where multiple tasks were assigned to an individual in their role, an evaluation of the timing of the tasks was conducted to ensure that they could be performed by the individual in series within any specified time requirements.

The results of the analysis for each of the scenarios are included in Section VII, APPENDIX B - ON-SHIFT STAFFING ANALYSIS. Note that NSIR DPR-ISG-01 states that only Design Basis Accidents (DBA) which would result in an emergency declaration should be evaluated in the staffing assessment. In a permanently shut down and defueled condition FSAR Chapter 14 will be revised to eliminate the DBAs that will not be applicable in the permanently defueled condition.

IV. ACCIDENT SCENARIOS A. Accident Selection

1. The scenarios were chosen using the guidance of NSIR/DPR-ISG-01, based on the applicability in a permanently shut down and defueled condition. The evaluation considered the station DBAs described in the FSAR along with additional scenarios specified by the guidance documents. The following scenarios were considered for inclusion in this analysis:

1. Design Basis Threat (DBT) ground assault

2. DBA Fuel Handling Accident (FHA)

3. Aircraft Probable Threat as described in 10 CFR 50.54(hh)

4. Fire requiring evacuation of the Control Room and control of Spent Fuel Pool cooling

5. General Emergency with Radioactive Release and PAR

6. Station Blackout (SBO) as described in ISG-01

7. DBA Cask drop in the SFP B. Accident Scenarios included in the Analysis

1. Design Basis Threat The event evaluated for this analysis assumes a land based threat that is neutralized immediately when inside the protected area fence, no significant damage to equipment or systems that require corrective actions before the ERO is staffed, no radiological release, and no fire that requires firefighting response before the ERO is staffed.

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PNP ANALYSIS OF PROPOSED POSTSHUTDOWN ONSHIFT STAFFING

2. Fuel Handling Accident (FHA)

The postulated design basis accident that will remain applicable to PNP in its permanently shut down and defueled condition is the FHA. This accident analysis assumes the drop of a spent fuel assembly onto the spent fuel racks within the SFP resulting in breaking the fuel rods.

3. Aircraft Probable Threat (50.54(hh))

Notification is received from the NRC that a probable aircraft threat exists (>5 minutes, <30 minutes).

4. Fire requiring evacuation of the Control Room and control of spent fuel pool (SFP) cooling A fire occurs requiring the evacuation of the Control Room and procedures implemented to control SFP cooling from a remote location.

5. General Emergency with Radioactive Release and PAR The FHA assumes the drop of a spent fuel assembly onto the spent fuel racks within the SFP resulting in breaking the fuel rods. A General Emergency is declared when the Shift Manager is given a dose assessment update that projects >1 Rem TEDE dose at the site boundary.

C. Accident Scenarios not included in the Analysis

1. Station Blackout ISG-01 provides guidance associated with the staffing analysis for a Station Blackout (SBO). ISG-01 states, in part:

Station blackouts are beyond the plants design basis and may not need to be addressed in the staffing analysis. The blackout coping analyses performed by licensees pursuant to 10 CFR 50.63 establish blackout coping times that exceed the required on-shift staff augmentation time. Also, since the control room fire scenario leading to evacuation and remote shutdown may adequately address the considerations involved with an Appendix R safe shutdown fire, licensees may not need to consider this scenario in the staffing analysis.

10 CFR 50.63(a)(1) states, in part:

Each light-water-cooled nuclear power plant licensed to operate under this part, each light-water-cooled nuclear power plant licensed under subpart C of 10 CFR part 52 after the Commission makes the finding under § 52.103(g) of this chapter, and each design for a light-water-cooled nuclear power plant approved under a standard design approval, standard design certification, and manufacturing license under part 52 of this chapter must be able to withstand for a specified duration and recover from a station blackout as defined in § 50.2.

Upon docketing of the certification of permanent removal of fuel in accordance with 10 CFR 50.82(a)(1)(ii), per 10 CFR 50.82(a)(2), the Part 50 license will no longer authorize operation of Palisades Nuclear Plant Page 11 Rev. 0

PNP ANALYSIS OF PROPOSED POSTSHUTDOWN ONSHIFT STAFFING the reactor or emplacement of fuel in the reactor vessel. PNP will no longer be a nuclear power plant licensed to operate under 10 CFR Part 50 and 10 CFR 50.63 will no longer be applicable.

The SBO scenario is no longer considered an appropriate gauge by which to measure whether an event presents on-shift staff with responsibilities that would prevent the timely performance of assigned functions in the E-Plan. Therefore, this scenario is not considered in this analysis.

2. Dropped Cask as Described in FSAR 14.11 Analyzed dropped cask events were identified as events that would only occur with the availability of additional station staff above and beyond those represented by station minimum staff and are outside the bounds of this analysis. Additionally, it was determined that no emergency declaration would be expected for this event.

V. GENERAL ASSUMPTIONS AND LIMITATIONS A. Notes and Assumptions applicable to all accidents in PNP Staffing Analysis:

1. The RP and Chemistry tasks reviewed were those directed by the Shift Manager to support actions in Operations procedures for Off-Normal Procedures (ONP), Emergency operating Procedures (EOP), and Emergency Plan Implementing Procedures (EI). Any additional tasks directed by the Technical Support Center (TSC), Operations Support Center (OSC), or Emergency Operations Facility (EOF) procedures were not reviewed.

2. PNP has 60 minute emergency responders when augmenting while the ERO is offsite. This analysis was conducted assuming a 90 minute response of the augmented ERO. There were no specific emergency response tasks assigned to the augmented ERO prior to the 90 minute response.

3. There are no time critical RP or Chemistry tasks and task performance is directed and prioritized by the Shift Manager. The time RP is directed to perform a task and the amount of time taken to complete tasks are estimated. No Chemistry samples are required by Tech Specs within the 90 minute period after a declaration. Because the Shift Manager directs when the tasks are performed, there are no overlapping RP or chemistry tasks.

B. Additional Assumptions

1. Response time used for this analysis was the maximum acceptable number of minutes elapsed between emergency declaration and the augmented ERO position holder at a location necessary to relieve an on-shift position of the emergency response task. As noted above, this analysis assumed a 90 minute augmentation time although the times noted in the Table 1 accident analysis tables reflects the PNP SEP required staffing time of 60 minutes.

2. On-shift personnel complement was based on the proposed post-shutdown on-shift positions expected to be in place following shutdown and permanent removal of fuel from the reactor vessel.

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PNP ANALYSIS OF PROPOSED POSTSHUTDOWN ONSHIFT STAFFING

3. Although the temporary absence of a position may be allowed by Tech Specs, the analysis was performed assuming that all required on-shift positions are filled.

4. Each analyzed event occurred during off-normal work hours where the ERO was offsite and all required minimum on-shift positions were filled.

5. On-shift personnel reported to their assigned response locations within timeframes sufficient to allow for performance of assigned actions.

6. On-shift staff had necessary Radiation Worker qualifications to obtain normal dosimetry and enter the radiological control area (RCA) (but not locked high or very high radiation areas) without the aid of an RP technician.

7. Personnel assigned plant operations met the requirements and guidance (analyzed through other programs such as operator training) and were not evaluated as part of this assessment unless a role/function/task from another major response area was assigned as a collateral duty.

8. In-plant (manual) safety related operator actions to manipulate components and equipment from locations outside the control room to achieve and maintain SFP cooling was done by a member of the on-shift staff as defined in the units Tech Specs.

9. Fire brigade (FB) staff performance is analyzed through other station programs (e.g., fire drills) and was not evaluated as part of this assessment unless a role/function/task from another major response area was assigned as a collateral duty.

10. Security was not evaluated unless a role or function from another major response area was assigned as a collateral duty.

11. Communications, briefings, and peer checks are acceptable collateral duties.

12. All on-shift staff positions were evaluated, even if they had no known collateral duties, to ensure they can perform the tasks assigned to them. [Ref NSIR/DPR-ISG-01]

13. The analysis specified the resources available to perform Repair and Corrective Actions and Rescue Operations and First Aid but these may be assigned as collateral duty to a designated on-shift responder.

14. For assessment purposes, NRC notifications were treated as a continuous action per 10CFR50.72(c)(3) and 73.71(b)(1). This means once the initial NRC communications are established, the NRC will request an open line be maintained with the NRC Operations Center.

15. DBA (postulated accident, Condition IV event, or limiting fault) is considered as Unanticipated occurrences that are postulated for accident analysis purposes but not expected to occur during the life of the plant. A postulated accident could result in sufficient damage to preclude resumption of plant operation. As a result, a greater number and variety of actions would need to be implemented by plant personnel.

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PNP ANALYSIS OF PROPOSED POSTSHUTDOWN ONSHIFT STAFFING

16. DBT assumed a hostile force breached the protected area fence but was neutralized with no adverse consequences to plant safety. Damage inflicted on plant systems, structures and components was not sufficient to interrupt SFP cooling or cause a radiological release. There was no fire significant enough to warrant firefighting efforts prior to arrival of offsite resources and/or the augmented ERO.

17. The analysis used DBA analysis assumptions, inputs, timing of events, plant protective response, and specified manual operator actions and their timing, as documented in the FSAR.

18. In cases where a DBA analysis included a radiological release, and the starting point of the release was not clearly defined, the staffing analysis assumed that the release began 15-minutes after the initiating event.

Palisades Nuclear Plant Page 14 Rev. 0

PNP ANALYSIS OF PROPOSED POSTSHUTDOWN ONSHIFT STAFFING VI. APPENDIX A - ANALYZED EVENTS AND ACCIDENTS Summary Event Event Reference Analysis Description of Plant Mode1 Event ECL

1. Type Document(s) Required?

Event 1 DBT Land and/or Permanently NEI 10-05 Site Area Yes waterborne Defueled Emergency HOSTILE ACTION directed against the Protected Area by a HOSTILE FORCE. Assume adversary characteristics defined by the Design Basis Threat (DBT).

2 DBA Fuel Handling Permanently FSAR Chapter Alert Yes Accident Defueled 14.19 (as revised to address permanently defueled conditions) 3 Assumed Aircraft Probable Permanently 10CFR50.54hh(1) Alert Yes for Threat Defueled Analysis RG 1.214 Purpose 4 Assumed Control Room Permanently 10 CFR Part 50.48 Alert Yes for Evacuation and Defueled Analysis maintain SFP Purpose cooling 5 Assumed General Permanently NEI 10-05 General Yes for Emergency with Defueled Emergency Analysis Radioactive Purpose Release and PAR 2

6 Assumed Station Blackout Permanently 10CFR50.63 Site Area No for Defueled Emergency Analysis Purpose 7 DBA Dropped Cask Permanently FSAR 14.11 None No3 Defueled 1

Once PNP submits the certification of permanent removal of fuel in accordance with 10 CFR 50.82(a)(1)(ii), per 10 CFR 50.82(a)(2) the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement of fuel in the reactor vessel. PNP will no longer be a nuclear power plant licensed to operate under Part 50.

2 Once PNP submits the certification of permanent removal of fuel in accordance with 10 CFR 50.82(a)(1)(ii), per 10 CFR 50.82(a)(2) the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement of fuel in the reactor vessel and 10 CFR 50.63 will no longer be applicable.

3 No emergency declaration is expected for this event.

Palisades Nuclear Plant Page 15 Rev. 0

PNP ANALYSIS OF PROPOSED POSTSHUTDOWN ONSHIFT STAFFING VII. APPENDIX B - ON-SHIFT STAFFING ANALYSIS A. Accident Analysis #1 - Design Basis Threat

1. Accident Summary Land and/or waterborne HOSTILE ACTION directed against the Protected Area by a HOSTILE FORCE. Assume adversary characteristics defined by the Design Basis Threat (DBT).

This analysis concluded that sufficient staff was available to simultaneously implement both the Emergency Plan and the Security Plan. The conclusion that sufficient staff was available to implement the Security Plan was based on Security staff personnel not being assigned collateral duties that would prevent the timely performance of their assigned functions. As noted in the analysis assumptions detailed in Section V.B. 10 of this report, the Security organization is assumed to be able to satisfactorily perform all tasks related to Site and Protected Area Access Controls under all event or accident conditions.

2. Accident Specific Assumptions Made The PNP DBT for this analysis assumes a land based threat although a waterborne threat as also considered to determine if it was a more manpower limiting event. This analysis identified that a change to the mode of attack did not impact the staffing analysis or identify the assignment of any additional collateral duties for on-shift personnel which would prevent the timely performance of their assigned functions as specified in the Emergency Plan.

This event assumes the threat is neutralized immediately when inside the protected area fence, no significant damage to equipment or systems that require corrective actions before the ERO is staffed, no radiological release, and no fire that requires firefighting response before the ERO is staffed.

Assume Spent Fuel Pool Temperature of 125ºF.

Security notifies the Shift Manager of condition of hostile action occurring within the protected area (Security code RED)

Assume all non-security staff is located inside the protected area at their normal work station when the event occurs.

Assume all systems function and the spent fuel remains covered. No fuel damage and no release.

3. Procedures for Accident Response AOP-44, Rev. 0, Response to Attack on Palisades EOP-1.0, Rev. 19, Standard Post Trip Actions EI-1, Rev. 57, Emergency Classifications and Actions EI-3, Rev. 33, Communications and Notifications EI-2.2, Rev. 16, Emergency Staff Augmentation EI-12.1, Rev, 19, Personnel Accountability and Assembly ADMIN-4, Rev. 59, Operations Organization, Responsibilities and Conduct Palisades Nuclear Plant Page 16 Rev. 0

PNP ANALYSIS OF PROPOSED POSTSHUTDOWN ONSHIFT STAFFING

4. Tables PNP TABLE 1 - ON-SHIFT POSITIONS Analysis # 1 DBT Security Threat Augmentation Role in Line Unanalyzed TMS On-shift Position E-Plan Reference Elapsed Time Table # /

1. Task? Required?

(min)* Line #

T2/L1 T5/L1 Shift Manager Emergency Plan 1 60 T5/L3 No Yes1 (SM) Figure 5-2 T5/L5 T5/L6 T2/L2 T5/L7*

Non-Certified Emergency Plan 2 N/A T5/L8 No Yes2 Operator #1 Figure 5-2 T5/L9 T5/L13 Non-Certified Emergency Plan 3 N/A N/A No No Operator #2 Figure 5-2 Emergency Plan N/A N/A 4 FB #2 No No Figure 5-2 Emergency Plan N/A 5 FB #3 N/A No No Figure 5-2 Emergency Plan N/A N/A 6 FB #4 No No Figure 5-2 Emergency Plan N/A N/A 7 FB #5 No No Figure 5-2 Emergency Plan N/A 8 RP Technician 60 No No Figure 5-2 Security Contingency Plan /

9 Security N/A T5/L15 No No Emergency Plan Figure 5-2 1

The Shift Manager is assigned the responsibility to make ERO notifications. A TMS was conducted during development of the initial OSA and demonstrated that the Shift Manager was able to maintain Emergency Direction and Control during the approximate 2 minutes it took to notify the ERO. No further analysis or TMS is required to verify timely and effective implementation.

2 See Section VIII.A

• Expected duration of less than 1 minute. Therefore, Task not included in the TMS included in Section VIII.A.

Palisades Nuclear Plant Page 17 Rev. 0

PNP ANALYSIS OF PROPOSED POSTSHUTDOWN ONSHIFT STAFFING PNP TABLE 2 - PLANT OPERATIONS One Unit - One Control Room ANALYSIS # 1 DBT Security Threat Minimum Operations Crew Necessary to Implement AOPs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis Controlling Method SM Licensed Operator Training 1 Shift Manager Program Non-Certified Operator #1 Licensed Operator Training 2 Unit Supervisor Program Other (non-Operations) Personnel Necessary to Implement AOPs if Applicable Task Analysis Line # Generic Title/Role On-Shift Position Controlling Method 3 Mechanic N/A N/A 4 Electrician N/A N/A 5 I&C Technician N/A N/A 6 Other N/A N/A 7 Other N/A N/A Fire Brigade PNP TABLE 3 - FIREFIGHTING ANALYSIS # 1 DBT Security Threat Line Performed by Task Analysis Controlling Method

1 N/A N/A 2 N/A N/A 3 N/A N/A 4 N/A N/A 5 N/A N/A This accident does not include the need for firefighting, first aid or search & rescue.

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PNP ANALYSIS OF PROPOSED POSTSHUTDOWN ONSHIFT STAFFING PNP TABLE 4 - RADIATION PROTECTION AND CHEMISTRY Analysis # 1 DBT Security Threat L Position Performing Performance Time Period After Emergency Declaration (minutes)

I Function / Task N 0-5 5-10 10 20 30 40 50 60 70 80 E 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 1 In-Plant Survey: N/A 2 On-site Survey: N/A 3 Personnel Monitoring: N/A 4 Job Coverage: N/A 5 Offsite Rad Assessment: N/A 6 Other site specific RP (describe): N/A 7 Chemistry Function task #1 (describe)

N/A 8 Chemistry Function task #2 (describe)

N/A No chemistry or RP job function tasks for the conditions described in the DBT assumptions. RP takes cover as directed.

Palisades Nuclear Plant Page 19 Rev. 0

PNP ANALYSIS OF PROPOSED POSTSHUTDOWN ONSHIFT STAFFING PNP TABLE 5 - EMERGENCY PLAN IMPLEMENTATION Analysis # 1 DBT Security Threat Function / Task On-Shift Task Analysis Controlling Method Line#

Position Declare the emergency classification level Emergency Planning Training 1 SM (ECL) Program / EP Drills Approve Offsite Protective Action 2 N/A N/A Recommendations Emergency Planning Training 3 Approve content of State/local notifications SM Program 4 Approve extension to allowable dose N/A N/A Licensed Operator Training Program Notification and direction to on-shift staff 5 SM / Emergency Planning Training (e.g., to assemble, evacuate, etc.)

Program Emergency Planning Training 6 ERO notification SM Program Non-Certified 7 Abbreviated NRC notification for DBT event Licensed Operator Training Program Operator #1 Non-Certified Emergency Planning Training 8 Complete State/local notification form Operator #1 Program Non-Certified Emergency Planning Training 9 Perform State/local notifications Operator #1 Program 10 Complete NRC event notification form N/A N/A 11 Activate ERDS N/A N/A 12 Offsite radiological assessment N/A N/A Non-Certified 13 Perform NRC notifications Operator #1 Licensed Operator Training Program Perform other site-specific event notifications 14 (e.g., Duty Plant Manager, INPO, ANI, etc.) N/A N/A 15 Personnel Accountability Security Security Training Program / EP Drills Palisades Nuclear Plant Page 20 Rev. 0

PNP ANALYSIS OF PROPOSED POSTSHUTDOWN ONSHIFT STAFFING B. Accident Analysis #2 - Fuel Handling Accident

1. Accident Summary The FHA assumes the drop of a spent fuel assembly onto the spent fuel racks within the SFP resulting in breaking the fuel rods.

2. Accident Specific Assumptions Made This analysis assumes an ALERT declaration based on area radiation monitors reaching levels to prompt an emergency declaration.

Additional station personnel, including Operations, Chemistry, and Radiation Protection Technicians, would be on-site during fuel assembly movement. The presence of additional plant personnel would free the on-shift RP Technician to perform dose assessment.

3. Procedures for Accident Response AOP-34, Rev. 0, Fuel Handling Accident EI-1, Rev. 57, Emergency Classification and Actions EI-3, Rev. 33, Communications and Notifications EI-2,2, Rev. 16, Emergency Staff Augmentation EI-12.1, Rev. 19, Personnel Accountability and Assembly ADMIN-4, Rev, 59, Operations Organization, Responsibilities and Conduct Palisades Nuclear Plant Page 21 Rev. 0

PNP ANALYSIS OF PROPOSED POSTSHUTDOWN ONSHIFT STAFFING

4. Tables PNP TABLE 1 - ON-SHIFT POSITIONS Analysis #2 - Fuel Handling Accident Augmentation Role in Table #

Line Unanalyzed TMS On-shift Position E-Plan Reference Elapsed Time / Line #

1. Task? Required?

(min)

T2/L1 T5/L1 Emergency Plan 1 SM 60 T5/L3 No Yes1 Figure 5-2 T5/L5 T5/L6 T2/L2 Non-Certified Emergency Plan T5/L8 2 N/A No Yes2 Operator #1 Figure 5-2 T5/L9 T5/L13 Non-Certified Emergency Plan 3 N/A N/A No No Operator #2 Figure 5-2 Emergency Plan N/A N/A 4 FB #2 No No Figure 5-2 Emergency Plan N/A N/A 5 FB #3 No No Figure 5-2 Emergency Plan N/A N/A 6 FB #4 No No Figure 5-2 Emergency Plan N/A N/A 7 FB #5 No No Figure 5-2 Emergency Plan T4/L2 8 RP Technician 60 No Yes3 Figure 5-2 T5/L12 Security Contingency 9 Security Plan / Emergency N/A T5/L15 No No Plan Figure 5-2 1

The Shift Manager is assigned the responsibility to make ERO notifications. A TMS was conducted during development of the initial OSA and demonstrated that the Shift Manager was able to maintain Emergency Direction and Control during the approximate 2 minutes it took to notify the ERO. No further analysis or TMS is required to verify timely and effective implementation.

2 See Section VIII.A 3

See Section II.C.2 for the exception taken for the Radiation Protection Technician to perform dose assessment. No Time Motion Study or corrective action required.

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PNP ANALYSIS OF PROPOSED POSTSHUTDOWN ONSHIFT STAFFING PNP TABLE 2 - PLANT OPERATIONS One Unit - One Control Room ANALYSIS # 2 - Fuel Handling Accident Minimum Operations Crew Necessary to Implement AOPs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis Controlling Method SM Licensed Operator 1 Shift Manager Training Program Non-Certified Operator #1 Licensed Operator 2 Unit Supervisor Training Program Other (non-Operations) Personnel Necessary to Implement AOPs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis Controlling Method 3 Mechanic N/A N/A 4 Electrician N/A N/A 5 I&C Technician N/A N/A 6 Other N/A N/A 7 Other N/A N/A Fire Brigade PNP TABLE 3 - FIREFIGHTING ANALYSIS # 2 - Fuel Handling Accident Line Performed by Task Analysis Controlling Method

1 N/A N/A 2 N/A N/A 3 N/A N/A 4 N/A N/A 5 N/A N/A This accident does not include the need for firefighting, first aid or search & rescue.

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PNP ANALYSIS OF PROPOSED POSTSHUTDOWN ONSHIFT STAFFING PNP TABLE 4 - RADIATION PROTECTION AND CHEMISTRY Analysis #2 - Fuel Handling Accident L Position Performing Performance Time Period After Emergency Declaration (minutes)*

I Function / Task N 10 20 30 40 50 60 70 80 E 0-5 5-10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 1 In-Plant Survey: N/A (Rad Monitors in use) 2 On-site Survey: RP X XXXX X XXXX X X X X X 3 Personnel Monitoring: N/A 4 Job Coverage: N/A 5 Offsite Rad Assessment:

(Included in Table 5 6 Other site specific RP (describe): N/A 7 Chemistry Function task #1 (describe)

N/A 8 Chemistry Function task #2 (describe)

N/A The time* to commence and complete the task is estimated.

The on-shift RP Technician will perform the above task as directed by the Shift Manager. Tasks are not time critical. The on-shift RP Technician is available for dose assessment if a release occurs.

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PNP ANALYSIS OF PROPOSED POSTSHUTDOWN ONSHIFT STAFFING PNP TABLE 5 - EMERGENCY PLAN IMPLEMENTATION Analysis #2 - Fuel Handling Accident Line Function / Task On-Shift Task Analysis Controlling

1. Position Method Declare the emergency classification level Emergency Planning Training 1 SM (ECL) Program / EP Drills Approve Offsite Protective Action N/A 2 N/A Recommendations Emergency Planning Training 3 Approve content of State/local notifications SM Program 4 Approve extension to allowable dose N/A N/A Licensed Operator Training Notification and direction to on-shift staff (e.g.,

5 SM Program / Emergency Planning to assemble, evacuate, etc.)

Training Program Emergency Planning Training 6 ERO notification SM Program 7 Abbreviated NRC notification for DBT event N/A N/A Non-Certified Emergency Planning Training 8 Complete State/local notification form Operator #1 Program Non-Certified Emergency Planning Training 9 Perform State/local notifications Operator #1 Program 10 Complete NRC event notification form N/A N/A 11 Activate ERDS N/A N/A Emergency Planning Training 12 Offsite radiological assessment RP Technician Program Non-Certified Licensed Operator Training 13 Perform NRC notifications Operator #1 Program Perform other site-specific event notifications 14 N/A N/A (e.g., Duty Plant Manager, INPO, ANI, etc.)

Security Security Training Program 15 Personnel Accountability Officer Palisades Nuclear Plant Page 25 Rev. 0

PNP ANALYSIS OF PROPOSED POSTSHUTDOWN ONSHIFT STAFFING C. Accident Analysis #3 - Aircraft Probable Threat

1. Accident Summary The analysis includes all emergency response actions taken prior to an aircraft impact in accordance with RG 1.214 for an aircraft threat that is greater than 5 minutes, but less than 30 minutes from the site, and considers the dispersal of the site fire brigade away from target areas for firefighting.

The analysis does not include a scenario or response actions taken during or after a crash.

2. Accident Specific Assumptions Made The Shift Manager receives the call from the NRC of probable aircraft threat.

All non-security on-shift personnel are inside the protected area fence at their normal workstation.

3. Procedures for Accident Response AOP-44, Rev. 0, Response to Security Threats EOP-1.0, Rev. 19, Standard Post Trip Actions EI-1, Rev. 57, Emergency Classification and Actions EI-3, Rev. 33, Communications and Notifications EI-2,2, Rev. 16, Emergency Staff Augmentation EI-12.1, Rev. 19, Personnel Accountability and Assembly ADMIN-4, Rev, 59, Operations Organization, Responsibilities and Conduct Palisades Nuclear Plant Page 26 Rev. 0

PNP ANALYSIS OF PROPOSED POSTSHUTDOWN ONSHIFT STAFFING

4. Tables PNP TABLE 1 - ON-SHIFT POSITIONS Analysis #3 - Aircraft Potential Threat Augmentation Role in Table Unanalyzed TMS Line E-Plan On-shift Position Elapsed Time # / Line # Task? Required?

1. Reference (min)

T2/L1 T5/L1 Emergency Plan 1 SM 60 T5/L3 No Yes1 Table 8.4 T5/L5 T5/L6 T2/L2 Non-Certified Emergency Plan 2 N/A T5/L9 No Yes2 Operator #1 Table 8.4 T5/L13 Non-Certified Emergency Plan 3 N/A N/A No No Operator #2 Table 8.4 Emergency Plan N/A 4 FB #2 N/A No No Table 8.4 Emergency Plan N/A 5 FB #3 N/A No No Table 8.4 Emergency Plan N/A N/A 6 FB #4 No No Table 8.4 Emergency Plan N/A N/A 7 FB #5 No No Table 8.4 Emergency Plan N/A 8 RP Technician 60 No No Table 8.4 Security Contingency Plan 9 Security N/A T5/L15 No No

/ Emergency Plan Table 8.4 1

The Shift Manager is assigned the responsibility to make ERO notifications. A TMS was conducted during development of the initial OSA and demonstrated that the Shift Manager was able to maintain Emergency Direction and Control during the approximate 2 minutes it took to notify the ERO. No further analysis or TMS is required to verify timely and effective implementation.

2 See bounding analysis in Section VIII.A Palisades Nuclear Plant Page 27 Rev. 0

PNP ANALYSIS OF PROPOSED POSTSHUTDOWN ONSHIFT STAFFING PNP TABLE 2 - PLANT OPERATIONS & SAFE SHUTDOWN One Unit - One Control Room Analysis #3 - Aircraft Potential Threat Minimum Operations Crew Necessary to Implement AOPs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis Controlling Method SM Licensed Operator 1 Shift Manager Training Program Non-Certified Operator #1 Licensed Operator 2 Unit Supervisor Training Program Other (non-Operations) Personnel Necessary to Implement AOPs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis Controlling Method 3 Mechanic N/A N/A 4 Electrician N/A N/A 5 I&C Technician N/A N/A 6 Other N/A N/A 7 Other N/A N/A Fire Brigade PNP TABLE 3 - FIREFIGHTING Analysis #3 - Aircraft Probable Threat Line Performed by Task Analysis Controlling Method

1 N/A N/A 2 N/A N/A 3 N/A N/A 4 N/A N/A 5 N/A N/A This accident does not include the need for firefighting, first aid or search & rescue. The Fire Brigade relocates to the Training Center.

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PNP ANALYSIS OF PROPOSED POST SHUTDOWN ONSHIFT STAFFING PNP TABLE 4 - RADIATION PROTECTION AND CHEMISTRY Analysis #3 - Aircraft Probable Threat L Position Performing Performance Time Period After Emergency Declaration (minutes)*

I Function / Task N 10 20 30 40 50 60 70 80 E 0-5 5-10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 1 In-Plant Survey: N/A 2 On-site Survey: N/A 3 Personnel Monitoring: N/A 4 Job Coverage: N/A 5 Offsite Rad Assessment:

(Included in Table 5

- N/A 6 Other site specific RP (describe): N/A**

7 Chemistry Function task #1 (describe) -

N/A 8 Chemistry Function task #2 (describe) -

N/A

• Times are estimated.

• • The Radiation Protection Technician has assigned no tasks in response to this event and would be available, if needed, to maintain continuous communications with the NRC during the event.

Palisades Nuclear Plant Page 29 Rev. 0

PNP ANALYSIS OF PROPOSED POST SHUTDOWN ONSHIFT STAFFING PNP TABLE 5 - EMERGENCY PLAN IMPLEMENTATION Analysis #3 - Aircraft Probable Threat Line Function / Task On-Shift Position Task Analysis Controlling

1. Method Declare the emergency classification level Emergency Planning 1 SM (ECL) Training Program / EP Drills Approve Offsite Protective Action N/A 2 N/A Recommendations Emergency Planning 3 Approve content of State/local notifications SM Training Program 4 Approve extension to allowable dose N/A N/A Licensed Operator Training Notification and direction to on-shift staff (e.g.,

5 SM Program / Emergency to assemble, evacuate, etc.)

Planning Training Program Emergency Planning 6 ERO notification SM Training Program 7 Abbreviated NRC notification for DBT event N/A N/A 8 Complete State/local notification form N/A N/A Emergency Planning 9 Perform State/local notifications Non-Certified Operator #1 Training Program 10 Complete NRC event notification form N/A N/A 11 Activate ERDS N/A N/A 12 Offsite radiological assessment N/A N/A Licensed Operator Training 13 Perform NRC notifications Non-Certified Operator #1 Program Perform other site-specific event notifications 14 N/A N/A (e.g., Duty Plant Manager, INPO, ANI, etc.)

15 Personnel Accountability Security Security Training Program Note: Lines 8 and 10 are not performed during an aircraft threat.

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PNP ANALYSIS OF PROPOSED POST SHUTDOWN ONSHIFT STAFFING D. Accident Analysis #4 - Control Room Fire Requiring Evacuation and Maintain SFP Cooling

1. Accident Summary This event involves a large transient fire requiring evacuation of the Control Room. The event has the potential to include shorts and/or spurious signals producing potential to lose SFP cooling capabilities.

2. Accident Specific Assumptions Made Assumed control room staff does not have time to perform any procedural actions other than declare the Alert and make the plant announcement before leaving the control room.

3. Procedures for Accident Response AOP-40, Rev. 2, Fire Which Threatens Safety Related Equipment AOP-41, Rev. 3, Alternate Safe Shutdown Procedure EI-1, Rev. 57, Emergency Classification and Actions EI-3, Rev. 33, Communications and Notifications EI-2,2, Rev. 16, Emergency Staff Augmentation EI-12.1, Rev. 19, Personnel Accountability and Assembly ADMIN-4, Rev, 59, Operations Organization, Responsibilities and Conduct Palisades Nuclear Plant Page 31 Rev. 0

PNP ANALYSIS OF PROPOSED POST SHUTDOWN ONSHIFT STAFFING

4. Tables PNP TABLE 1 - ON-SHIFT POSITIONS Analysis #4 - CR Evacuation & SFP Cooling Augmentation Role in Table Unanalyzed TMS Line E-Plan On-shift Position Elapsed Time # / Line # Task? Required?

1. Reference (min)

T2/L1 T5/L1 Emergency Plan 1 SM 60 T5/L3 No Yes1 Figure 5-2 T5/L5 T5/L6 T2/L2 Non-Certified Emergency Plan T5/L8 2 N/A No Yes2 Operator #1 Figure 5-2 T5/L9 T5/L13 Non-Certified Emergency Plan 3 N/A T3/L1 No No Operator #2 Figure 5-2 Emergency Plan N/A T3/L2 4 FB #2 No No Figure 5-2 Emergency Plan N/A T3/L3 5 FB #3 No No Figure 5-2 Emergency Plan N/A T3/L4 6 FB #4 No No Figure 5-2 Emergency Plan N/A T3/L5 7 FB #5 No No Figure 5-2 Emergency Plan N/A 8 RP Technician 60 No No Figure 5-2 Security Contingency Plan 9 Security N/A N/A No No

/ Emergency Plan Figure 5-2 1

The Shift Manager is assigned the responsibility to make ERO notifications. A TMS was conducted during development of the initial OSA and demonstrated that the Shift Manager was able to maintain Emergency Direction and Control during the approximate 2 minutes it took to notify the ERO. No further analysis or TMS is required to verify timely and effective implementation.

2 See Section VIII.A Palisades Nuclear Plant Page 32 Rev. 0

PNP ANALYSIS OF PROPOSED POST SHUTDOWN ONSHIFT STAFFING PNP TABLE 2 - PLANT OPERATIONS One Unit - One Control Room Analysis #4 - CR Evacuation & SFP Cooling Minimum Operations Crew Necessary to Implement AOPs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis Controlling Method SM Licensed Operator 1 Shift Manager Training Program Non-Certified Operator #1 Licensed Operator 2 Unit Supervisor Training Program Other (non-Operations) Personnel Necessary to Implement AOPs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis Controlling Method 3 Mechanic N/A N/A 4 Electrician N/A N/A 5 I&C Technician N/A N/A 6 Other N/A N/A 7 Other N/A N/A Fire Brigade PNP TABLE 3 - FIREFIGHTING Analysis #4 - CR Evacuation & SFP Cooling Line Performed by Task Analysis Controlling Method

1 Non-Certified Operator Fire Protection Program 2 FB #2 Fire Protection Program 3 FB #3 Fire Protection Program 4 FB#4 Fire Protection Program 5 FB#5 Fire Protection Program Palisades Nuclear Plant Page 33 Rev. 0

PNP ANALYSIS OF PROPOSED POST SHUTDOWN ONSHIFT STAFFING PNP TABLE 4 - RADIATION PROTECTION AND CHEMISTRY Analysis #4 - CR Evacuation & SFP Cooling L Position Performing Performance Time Period After Emergency Declaration (minutes)*

I Function / Task N 10 20 30 40 50 60 70 80 E 0-5 5-10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 1 In-Plant Survey: N/A 2 On-site Survey: N/A 3 Personnel Monitoring: N/A 4 Job Coverage: N/A 5 Offsite Rad Assessment:

(Included in Table 5 6 Other site specific RP (describe): N/A 7 Chemistry Function task #1 (describe) -

N/A 8 Chemistry Function task #2 (describe) -

N/A No specific time critical tasks were identified for RP or Chemistry for this event.

Palisades Nuclear Plant Page 34 Rev. 0

PNP ANALYSIS OF PROPOSED POST SHUTDOWN ONSHIFT STAFFING PNP TABLE 5 - EMERGENCY PLAN IMPLEMENTATION Analysis #4 - CR Evacuation & SFP Cooling Line Function / Task On-Shift Position Task Analysis

1. Controlling Method Emergency Planning Declare the emergency classification level 1 Shift Manager Training Program / EP (ECL)

Drills Approve Offsite Protective Action N/A 2 N/A Recommendations Emergency Planning 3 Approve content of State/local notifications Shift Manager Training Program 4 Approve extension to allowable dose N/A N/A Licensed Operator Notification and direction to on-shift staff Training Program /

5 Shift Manager (e.g., to assemble, evacuate, etc.) Emergency Planning Training Program Emergency Planning 6 ERO notification Shift Manager Training Program 7 Abbreviated NRC notification for DBT event N/A N/A Non-Certified Operator Emergency Planning 8 Complete State/local notification form

1. 1 Training Program Non-Certified Operator Emergency Planning 9 Perform State/local notifications

1. 1 Training Program 10 Complete NRC event notification form N/A N/A 11 Activate ERDS N/A N/A 12 Offsite radiological assessment N/A N/A Non-Certified Operator Licensed Operator 13 Perform NRC notifications

1. 1 Training Program Perform other site-specific event notifications 14 N/A N/A (e.g., Duty Plant Manager, INPO, ANI, etc.)

15 Personnel Accountability N/A N/A Palisades Nuclear Plant Page 35 Rev. 0

PNP ANALYSIS OF PROPOSED POST SHUTDOWN ONSHIFT STAFFING E. Accident Analysis #5 -General Emergency with Radioactive Release and PAR

1. Accident Summary (Assumed for Staffing Analysis Purpose)

The FHA assumes the drop of a spent fuel assembly onto the spent fuel racks within the SFP resulting in breaking the fuel rods.

A General Emergency is declared when the Shift Manager is given a dose assessment update that projects >1 Rem TEDE dose at the site boundary.

2. Accident Specific Assumptions Made The FSAR does not contain detailed radiological conditions or release rates to determine an EAL classification. This analysis, therefore, assumed a General Emergency declaration based on area radiation monitors reaching levels to prompt an emergency declaration.

Additional plant personnel, including Operations, Chemistry, and Radiation Protection Specialists, would be on-site during fuel assembly movement. The presence of additional plant personnel would free the on-shift RP Technician to perform dose assessment.

3. Procedures for Accident Response AOP-34, Rev. 0, Fuel Handling Accident EI-1, Rev. 57, Emergency Classification and Actions EI-3, Rev. 33, Communications and Notifications EI-2,2, Rev. 16, Emergency Staff Augmentation EI-12.1, Rev. 19, Personnel Accountability and Assembly ADMIN-4, Rev, 59, Operations Organization, Responsibilities and Conduct Palisades Nuclear Plant Page 36 Rev. 0

PNP ANALYSIS OF PROPOSED POST SHUTDOWN ONSHIFT STAFFING

4. Tables PNP TABLE 1 - ON-SHIFT POSITIONS Analysis #5 -GE with PAR Augmentation Role in Table Unanalyzed TMS Required?

Line E-Plan On-shift Position Elapsed Time # / Line # Task?

1. Reference (min)

T2/L1 T5/L1 T5/L2 Emergency Plan 1 SM 60 T5/L3 No Yes1 Figure 5-2 T5/L4 T5/L5 T5/L6 T2/L2 Non-Certified Emergency Plan T5/L8 2 N/A No Yes2 Operator #1 Figure 5-2 T5/L9 T5/L13 Non-Certified Emergency Plan 3 N/A N/A No No Operator #2 Figure 5-2 Emergency Plan N/A 4 FB #2 N/A No No Figure 5-2 Emergency Plan N/A N/A 5 FB #3 No No Figure 5-2 Emergency Plan N/A N/A 6 FB #4 No No Figure 5-2 Emergency Plan N/A N/A 7 FB #5 No No Figure 5-2 Emergency Plan T4/L4 8 RP Technician 60 No Yes3 Figure 5-2 T5/L12 Security Contingency 9 Security Plan / N/A T5/L15 No No Emergency Plan Figure 5-2 1

The Shift Manager is assigned the responsibility to make ERO notifications. A TMS was conducted during development of the initial OSA and demonstrated that the Shift Manager was able to maintain Emergency Direction and Control during the approximate 2 minutes it took to notify the ERO. No further analysis or TMS is required to verify timely and effective implementation.

2 See Section VIII.A 3

See Section II.C.2 for the exception taken for the Radiation Protection Specialist to perform dose assessment. No Time Motion Study or corrective action required.

Palisades Nuclear Plant Page 37 Rev. 0

PNP ANALYSIS OF PROPOSED POST SHUTDOWN ONSHIFT STAFFING PNP TABLE 2 - PLANT OPERATIONS & SAFE SHUTDOWN One Unit - One Control Room Analysis #5 - GE with PAR Minimum Operations Crew Necessary to Implement AOPs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis Controlling Method SM Licensed Operator 1 Shift Manager Training Program Non-Certified Operator #1 Licensed Operator 2 Unit Supervisor Training Program Other (non-Operations) Personnel Necessary to Implement AOPs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis Controlling Method 5 Mechanic N/A N/A 6 Electrician N/A N/A 7 I&C Technician N/A N/A 8 Other N/A N/A 9 Other N/A N/A Fire Brigade PNP TABLE 3 - FIREFIGHTING Analysis #5 - GE with PAR Line Performed by Task Analysis Controlling Method

1 N/A N/A 2 N/A N/A 3 N/A N/A 4 N/A N/A 5 N/A N/A This accident does not include the need for firefighting, first aid or search & rescue.

Palisades Nuclear Plant Page 38 Rev. 0

PNP ANALYSIS OF PROPOSED POST SHUTDOWN ONSHIFT STAFFING PNP TABLE 4 - RADIATION PROTECTION AND CHEMISTRY Analysis #5 - GE with PAR L Position Performing Performance Time Period After Emergency Declaration (minutes)*

I Function / Task N 10 20 30 40 50 60 70 80 E 0-5 5-10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 1 In-Plant Survey: RP 2 On-site Survey: RP 3 Personnel Monitoring: N/A 4 Job Coverage: As directed by the SM X XXXX X XXXX X X X X X 5 Offsite Rad Assessment: See Table 5 6 Other site specific RP (describe): N/A 7 Chemistry Function task #1 (describe)

N/A 8 Chemistry Function task #2 (describe)

N/A The on-shift Radiation Protection Specialist will perform the above task as directed by the Shift Manager. Tasks are not time critical.

• Times indicated above are estimated.

Palisades Nuclear Plant Page 39 Rev. 0

PNP ANALYSIS OF PROPOSED POST SHUTDOWN ONSHIFT STAFFING PNP TABLE 5 - EMERGENCY PLAN IMPLEMENTATION Analysis #5 - GE with PAR Line Function / Task* On-Shift Position Task Analysis

1. Controlling Method Emergency Planning Declare the emergency classification level 1 Shift Manager Training Program / EP (ECL)

Drills Approve Offsite Protective Action Emergency Planning 2 Shift Manager Recommendations Training Program Emergency Planning 3 Approve content of State/local notifications Shift Manager Training Program Emergency Planning 4 Approve extension to allowable dose Shift Manager Training Program Licensed Operator Notification and direction to on-shift staff Training Program /

5 Shift Manager (e.g., to assemble, evacuate, etc.) Emergency Planning Training Program Emergency Planning 6 ERO notification Shift Manager Training Program 7 Abbreviated NRC notification for DBT event N/A N/A Emergency Planning 8 Complete State/local notification form Non-Certified Operator #1 Training Program Emergency Planning 9 Perform State/local notifications Non-Certified Operator #1 Training Program 10 Complete NRC event notification form N/A N/A 11 Activate ERDS N/A N/A Emergency Planning 12 Offsite radiological assessment RP Technician Training Program Licensed Operator 13 Perform NRC notifications Non-Certified Operator #1 Training Program Perform other site-specific event 14 notifications (e.g., Duty Plant Manager, N/A N/A INPO, ANI, etc.)

15 Personnel Accountability Security Security Training Program

.

Palisades Nuclear Plant Page 40 Rev. 0

PNP ANALYSIS OF PROPOSED POST SHUTDOWN ONSHIFT STAFFING VIII. APPENDIX C - TIME MOTION STUDIES SUPPORTING THE STAFFING ANALYSIS A. Multiple Scenarios (Bounding for all Analyses)

TIME MOTION STUDY OF OVERLAPPING TASKS Multiple Scenarios TASK 1: Complete the State/Local Notification Form JOB: Non-Certified Operator TASK 2: Perform NRC Notification JOB: Non-Certified Operator TASK 3: Perform Event Mitigation JOB: Non-Certified Operator Palisades Nuclear Plant Page 41 Rev. 0

PNP ANALYSIS OF PROPOSED POST SHUTDOWN ONSHIFT STAFFING PURPOSE:

Perform a Time Motion S tudy to evaluate wheth er the performance of a ctions assigned to the No n-Certified Operator #1 are acceptable task overlaps to the primary emergency plan function of event mitigation.

This analysis is considered bounding for all events.

NOTE:

Times for the activities performed are based o n operating experience (e.g., drills, real events, etc.) and/or informed judgment with consideration given to the limited actions in a permanently shut down and defueled condition. Validation of actual times will be performed with updated procedures.

CONCLUSION:

The Time Motion Study d emonstrated the Non-Certified Operator could perform the tasks of completing State, local and NRC notifications successfully, individually or in series, without impacting the ability of the Non-Certified Operator to remain in role providing support to the Shift Manager during the emergency.

LOCATION:

The response to this event was determined by conducting a discussion of the event with the applicable department personnel.

REQUIRED TOOLS/EQUIPMENT:

A. AOP-34, Rev. 0, Fuel Handling Accident B. EI-1, Rev. 57, Emergency Classification and Actions C. EI-3, Rev. 33, Communications and Notifications D. EI-2,2, Rev. 16, Emergency Staff Augmentation E. EI-12.1, Rev. 189 Personnel Accountability and Assembly F. ADMIN-4, Rev, 59, Operations Organization, Responsibilities and Conduct Palisades Nuclear Plant Page 42 Rev. 0

PNP ANALYSIS OF PROPOSED POST SHUTDOWN ONSHIFT STAFFING Function / Responsibility (Task) Analysis Template Event: # 5 Site: Palisades Position: Non-Certified Operator_ Line #: 8, 9, 13 Function Responsibility (Task) Action Step Duration

1. Off-Site Notification 1.1 Complete the notification 1.1.1 form. Retrieve Procedure EI-3, Communications and 2 min Notifications.

1.1.2 5 min Enter required information.

1.1.3 Performed Shift Manager approval of notification form. by Shift Manager 2 min TASK duration for complete notification form 9 min 1.2 Transmit the notification form 1.2.1 2 min Perform state/local notification.

TASK duration for state/local notification 2 min

2. NRC Notification 2.1 Complete NRC event 2.1.1 0 min notification Prepare Event Notification Worksheet. (performed above) 2.1.2 0 min Complete the NRC Notification Worksheet (performed immediately after state notifications and not later than one hour after the declaration of an emergency. above) 2.1.3 2 min Perform NRC Notification.

TASK duration to complete NRC notification 2 min

3. Event Mitigation 3.1 Assess and respond to plant 3.1.1 conditions Provide assistance to the Shift Manager in mitigating 10 min the event as directed.

TASK duration for event mitigation 10 min TOTAL DURATION 23 min Task Performer: Bret Baker Position: Assistant Ops Manager Date: 7/12/2017 Evaluator: Dan Malone Position: EP Manager Date: 7/12/2017 Palisades Nuclear Plant Page 43 Rev. 0

PNP ANALYSIS OF PROPOSED POST SHUTDOWN ONSHIFT STAFFING IX. OVERLAP OF TASKS ACTIVITIES OR OTHER CONFLICTS IDENTIFIED A. Overlap Requiring Compensatory Measures None X. REFERENCES Letter, Entergy Nuclear Operations, Inc. to USNRC, Certification of Permanent Cessation of Power Operations, PNP 2017-001, dated January 4, 2017 (ML17004A062)

NEI 10-05, Rev 0, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities NSIR DPR-ISG-01, Interim Staff Guidance - Emergency Planning for Nuclear Power Plants NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants Palisades Emergency Plan, Rev 29 Palisades On-Shift Staffing Analysis Report, Rev. 3, August 28, 2015 Palisades Nuclear Plant Page 44 Rev. 0

Attachment 6 To Entergy Letter PNP 2017-034 Palisades Nuclear Plant Emergency Response Organization Task Analysis (8 Pages)

ERO POSITION MATRIX Position Key Procedure(s) Regulatory Current ERO Position ENEP801 Tasks (F#) Other Procedural Tasks (ENEP6XX(P#), EI4.X(E#)) Implementing Actions eliminated? Task Assigned to? Min Staffing? NRC PI? EPlan section Requirement EMERGENCY OPERATIONS FACILITY Emergency Director F1. Receive turnover from the ED and assume command/control of EOF and activities outside the area P1. Fill vacant positions if needed F3 task from EOF Manager No N/A Yes Yes ENEP609, Att. 9.1 F1. NUREG 0654 II.A.1.d/II.B.3/II.B.5 controlled by the TSC P2. Maintain a log Eplan, 5.4.1 F11. NUREG 0654 II.A.4 F2. Direct the activation, operation and deactivation of the EOF. P3. De escalation to the Recovery Phase Eplan 6.1.3 F4. NUREG 0654 II.B.4 F3. Prepare and facilitate facility briefings Eplan Figure 52 F5. NUREG 0654 II.B.4/II.J.7 F4. Upgrade the emergency classification level. (cannot delegate)

F6. NUREG 0654 II.B.4 F5. Make protective action recommendations (PAR) to offsite agencies (cannot delegate)

F5./F8. NUREG 0654 II.B.7.c F6. Direct and approve offsite notification to State and local agencies (cannot delegate)

F11. NUREG 0654 II.B.7.a/II.C.1.a F7. Communicate within and between the emergency response facilities F8. Ensure event information is communicated to other organizations (NRC, Entergy Corp, etc.) to keep F13. NUREG 0654 II.K.2 them informed of the emergency situation. F14. NUREG 0654 II.B.4/II.B.7.d F9. Direct the activities of the EOF organization in support of the TSC and offsite response agencies. F18. NUREG 0654 II.B.4 (County, Parish and State) F19. NUREG 0654 II.B.7.b/II.K.6.c/II.M.2 F10. Direct protective actions for offsite monitoring teams, EOF ERO and offsite resources.

F11. Request assistance from offsite agencies, excluding requests for offsite medical/fire, security assistance. (Coordinate request for Federal assistance through the State)

F12. Integrate offsite responders with site response efforts when required.

F13. Authorize issuance of KI and radiation exposure in excess of 10CFR 20 limits for ERO members outside of the protected area.

F14. Authorize press releases (cannot delegate)

F15. Direct facility relocation to the alternate EOF (where applicable)

F16. Determine reportability actions for nonemergency reportable events during an emergency (hazardous material spills, contaminated injured personnel, and so forth).

F17. Conduct turnover of command and control to relief ED.

F18. Terminate the event in accordance with procedures (cannot delegate)

F19. Establish and direct recovery actions Radiological Assessment Coord F1. Direct the activities of the dose assessor and radiological offsite monitoring teams. P1. Maintain a log F1 task from Lead Offsite Liaison No N/A Yes Yes ENEP609, Att. 9.5 F9. NUREG 0654 II.A.1.e F2. Evaluate dose assessment results and recommendations. P2. Assist ED in conduct of briefings P1 task from EOF Log Keeper F3. Determine dose consequences P3. Assist the ED with termination to recovery phase F4. Communicate dose projection results to the ED to determine classification or PAR.

F5. Keep the ED appraised of offsite radiological conditions.

F6. Maintain awareness of dose projections generated by NRC, state and utility models and recognize differences.

F7. Provide overall liaison and coordination of efforts in the area of field team data with State Radiological Personnel.

F8. Brief offsite authorities responding to the EOF on radiological information.

F9. Contact the NRC on Health Physics Network (HPN) Line.(Can be designated to another staff member)

F10. Direct possible predictive and worstcase dose projections.

F11. Monitor or direct monitoring of ERF habitability.

F12. Ensure facility emergency ventilation in service (where applicable)

F13. Recommend EOF relocation based on environmental conditions and provide radiological guidance for the EOF evacuation, where applicable.

F14. Monitor information from displays or reports to detect changes that affect dose assessment.

F15. Establish radiological controls for supplemental and relief personnel responding to the station.

F16. Recommend emergency exposure limits and KI for EOF ERO or offsite monitoring teams F17. Coordinate the administration of KI.

Offsite Communicator F1. Ensure the Emergency Director approves all notifications forms to State/Local agencies. N/A N/A No N/A Yes Yes ENEP609, Att. 9.6 F2. NUREG 0654 II.A.1.e F2. Make notification to the State and local agencies as required by regulations using primary and backup notification system.

F3. Verify State and local agencies received and understand the notification F4. Make followup notifications F5. Maintain records of all notifications and communications 1 OF 8

ERO POSITION MATRIX Position Key Procedure(s) Regulatory Current ERO Position ENEP801 Tasks (F#) Other Procedural Tasks (ENEP6XX(P#), EI4.X(E#)) Implementing Actions eliminated? Task Assigned to? Min Staffing? NRC PI? EPlan section Requirement Technical Advisor F1. Maintain contact with the TSC and Control Room to obtain current plant and emergency P1. Provide the Offsite Communicator the completed, "Emergency Notification F1 task from Admin & Logistics Coord No N/A No No ENEP609, Att. 9.3 N/A status Form" following ED's approval. F2 task from Admin & Logistics Coord F2. Monitor plant computer system parameters. P2. Assist Emergency Director in conduct of briefings. F3 task from Admin & Logisitcs Coord F3. Recommend actions on classification of emergencies P3. Request TSC to fax plant parameter sheets to the EOF if PDS is unavailable F4 task from Admin & Logistics Coord F4. Support PAR decision making/determination. F1 task from EOF Communicator F8 task from EOF Manager P2 task from EOF Manager P3 task from EOF Manager P7 task from TSC Manager P2 task from EOF Logkeeper E8 task from the EOF Security Coord E9 task from the EOF Security Coord F1 task from JIC Technical Advisor F2 task from JIC Tech Advisor (change Inquiry Resp Coord to Inquiry Responder)

F3 task from JIC Tech Advisor (change Press Release Writer to Company Spokesperson and remove reference to Technical Assistant)

EOF Manager F1. Direct activities of the EOF personnel P1. Ensure communication is available to the offsite agencies via primary or alternate Eliminate Position Yes F3 Emergency Director No No ENEP609, Att. 9.2 N/A F2. Assure staffing and timely activation of the EOF notification method via verbal concurrence by the Offsite Communicator F1 eliminate task (ED task F2) F8 EOF Tech Advisor P2. Ensure communication is available to the Control Room via verbal concurrence by the EOF F2 eliminate task (ED task F2)

F3. Obtain additional resources through the Admin/Logistics Coordinator when necessary Technical Advisor P2 EOF Tech Advisor F4. Brief and assist offsite authorities responding to the EOF F4 eliminate task (done by EOF RAC) P3 EOF Tech Advisor P3. Ensure approporiate personnel staff the EOF entrance and screens incoming personnel for F5 eliminate task F5. Assist Rad Assessment Coordinator with facility habitability FFD P4. Ensure Radiological monitoring and dose assessment capabilities are available in the EOF via F6 eliminate task (OffSite Comm doing)

F6. Ensure correct and timely State and local notifications are made within regulatory verbal concurrence by the Radiological Assessment Coordinator F7 eliminate task requirements P5. Provide notifications that EOF is operational P1 eliminate task (OffSite Comm doing)

F7. Ensure WebEOC or status boards are maintained P6. Direct the Radiological Assessment Coordinator to assess on site and off site radiological P4 eliminate task (RAC doing)

F8. Notify Entergy Corporate Office and Corporate Emergency Center conditions P5 eliminate task (ED doing)

P7. Coordinate with the Radiological Assessment Coordinator and Offsite Team Coordinator to P6 eliminate task ensure the needs of the States' offsite communicators are met P7 eliminate task P8. Notify the Administration and Logistics Coordinator upon arrival of security contractor P8 eliminate task P9. Keep the Emergency Director informed of changing conditions that may cause a change in P9 eliminate task (TA doing) the Emergency Classification P10. Assist the ED in determining the appropriate Protective Action Recommendations to P10 eliminate task Offsite Authorities P11 eliminate task (OffSite Comm doing)

P11. Ensure periodic updates are communicated to offsite authorities P12 eliminate task (ED doing)

P12. Assist the ED in the review of news releases P13 eliminate task (ED doing)

P13. Assist the ED in periodic facility briefings P14 eliminate task (RAC doing)

P14. Assist the RAC with KI P15 eliminate task P15. Obtain Control Room official time (time on their clock) and coordinate the synchronization P16 eliminate task of the EOF time with the Control Room P17 eliminate task P16. Ensure current classification level is posted throughout the facility P 18 eliminate task (TA doing)

P17. Activate ERDS P18. Coordinate with Administration and Logistics Coordinator to obtain needed resources P19 eliminate task (ED doing)

P19. Assist in termination to Recovery Phase EOF Communicator F1. Transmit and receive information from onsite ERFs. N/A Eliminate Position Yes F1 EOF Tech Adv No No ENEP609, Att. 9.14 N/A F2. Ensure EOF is notified of information received of significant changes in plant conditions F2 eliminate task (EOF TA doing)

(e.g., start of a release, LOCA, EAL conditions) F3 eliminate task F3. Document information on the required forms or WebEOC F4 eliminate task F4. Assist the EOF Manager with other nonregulatory notifications or communications EOF Log Keeper F1. Maintain a chronological log of emergency status and EOF activities on WebEOC or other P1. Distribute Emergency Notification Forms received from the Offsite Eliminate position Yes P1 Radiological Assessment Coord No No ENEP609, Att. 9.4 N/A acceptable method Communicator F1 eliminate task (ED does this (P2)) P2 Tech Advisor F2. Ensure timeliness of facility briefs by prompting the Emergency Director of the briefing P2. Display the repair and corrective action team status via WebEOC, if F2 eliminate task schedule if necessary available F3 eliminate task F3. Support the EOF Manager / ED as requested Lead Offsite Liaison F1. Obtain plant information and ensure the offsite agencies located in the EOF and the offsite N/A Eliminate position Yes F1 Radiological Assessment Coord No No ENEP609, Att. 9.8 N/A liaisons are briefed on the plant conditions.

Admin & Logistics Coord F1. Manage 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> staffing of the emergency response facilities. N/A Eliminate Position Yes F1 EOF Technical Advisor No No ENEP609, Att. 9.10 F1. NUREG 0654 II.A.1.e F2. Manage logistics for supporting the onsite and offsite emergency response such as F2 EOF Technical Advisor F1./F2. NUREG 0654 II.A.4 additional support personnel or equipment, meals, lodging, etc. F3 EOF Technical Advisor F2. NUREG 0654 II.B.7.a F3. Coordinate access security measures in the EOF if applicable F4 EOF Technical Advisor F4. Align emergency ventilation/isolation when directed (where applicable).

2 OF 8

ERO POSITION MATRIX Position Key Procedure(s) Regulatory Current ERO Position ENEP801 Tasks (F#) Other Procedural Tasks (ENEP6XX(P#), EI4.X(E#)) Implementing Actions eliminated? Task Assigned to? Min Staffing? NRC PI? EPlan section Requirement IT Specialist F1. Monitor facility equipment (computer related and communications) to ensure adequate N/A Eliminate position Yes F1 IT Helpdesk No No ENEP609, Att. 9.11 N/A operation F3 eliminate task F2 IT Helpdesk F2. Resolve any IT related malfunctions F4 IT Helpdesk F3. Verify or perform ERDS activation.

F4. Assist with issues related to WebEOC, if available Dose Assessor F1. Support the radiological activities of the EOF N/A N/A No N/A Yes No ENEP609, Att. 9.12 N/A F2. Obtain data from offsite monitoring team reports, meteorological and radiological data, and plant data F3. Perform dose projection calculations using plant data and offsite monitoring team data.

F4. Perform possible predictive (whatif) and worst case dose projections when directed F5. Provide offsite dose projection information to the RAC F6. Monitor available parameter indications to detect changes that affect dose assessment.

F7. Perform dose projections using primary and backup methods Offsite Team Coordinator F1. Maintain communications with offsite monitoring teams (OMT). N/A N/A No N/A No No ENEP609, Att. 9.9 F1. NUREG 0654 II.A.1.e F2. Employ and direct OMT based on radiological /met information.

F3. Supervise/develop a plume tracking strategy.

F4. Log communications with OMT to include dose /air sample survey results, dosimeter reading, etc.

F5. Ensure radiological information is communicated to the RAC for possible modifications to the dose calculations F6. Support coordination of efforts in the area of offsite monitoring team data with State radiological personnel F7. Ensure team is aware of changing plant / meteorological conditions F8. Ensure team is notified on KI requirements Offsite Liaisons F1. Obtain plant information and ensure the offsite agencies located in the EOC are briefed on N/A N/A No N/A No No ENEP609, Att. 9.13 F1./F2. NUREG 0654 II.C.2.b (1 State/3 County) the plant conditions.

F2. Clarify plant conditions, respond to questions, etc. for the offsite agencies.

Monitoring Team No. 1 (2) F1. Perform activities directed by the OTC to support plume tracking and measurements E1. Log important information and activities. N/A No N/A No No ENEP609, Att. 9.18 F1. NUREG 0654 II.B.5, Table B1 (includes driver) F2. Monitor self reading dosimeters and report results back to the OTC Eplan Figure 52 (considered part of OSC) F3. Implement KI protective measures when notified by the OTC EI4.2 Attachment 13 Monitoring Team No.2 (2) F1. Perform activities directed by the OTC to support plume tracking and measurements E1. Log important information and activities. N/A No N/A No No ENEP609, Att. 9.18 F1. NUREG 0654 II.B.5, Table B1 (includes driver) F2. Monitor self reading dosimeters and report results back to the OTC Eplan Figure 52 (considered part of OSC) F3. Implement KI protective measures when notified by the OTC EI4.2 Attachment 13 State/County Communicator Sitespecific position E1. Ensure communication is available to the states and locals via primary or Eliminate Position Yes N/A No No EI4.3 Attachment 1 F2. NUREG 0654 II.A.1.e alternate notification method by conducting a test of the system. E1 eliminate task (OffSite Comm E2. Maintain a log. does)

E3. Transmit Emergency Notification Form to offsite agencies. E2 eliminate task E4. Provide a copy of Emergency Notification Form to Admin Support for E3 eliminate task (OffSite Comm distribution. does)

E5. Maintain records of all notifications and communications. E4 eliminate task (OffSite Comm E6. Provide periodic updates (Technical Data Sheets) to offsite agencies. does)

E7. Assist the Offsite Communicator with requests for additional information E5 eliminate task (OffSite Comm from NRC, State and County Liaisons. does)

E8. Complete additional notifications per Attachment 4. E6 eliminate task (OffSite Comm E9. Contact noncompany emergency support as requested. does)

E10. Document requests for noncompany support. E7 eliminate task (OffSite Comm does)

E8 eliminate task (OffSite Comm does)

E9 eliminate task E10 eliminate task (ED does)

Security Coordinator Sitespecific position E1. Maintain a log. Eliminate Position Yes E2 TSC Security Coord No No EI4.3 Attachment 3 N/A E2. Record Security Team activities undertaken. E1 eliminate task E3 TSC Security Coord E3. Record all communications outside the Protected Area Fence. E4 eliminate task (TSC Security Coord E8 EOF Tech Advisor E4. Record Accountabilitiy Team activities undertaken and completed. does) E9 EOF Tech Advisor E5. Review radiological conditions and any protective actions for Security Force E5 eliminate task (TSC Security Coord movements. does)

E6. Establish and maintain communications with the Security Force. E6 eliminate task (TSC Security Coord E7. Coordinate Security response to any emergency conditions with other does) emergency response organizations and act as NIMS Liaison. E7 eliminate task (TSC Security Coord E8. Maintain access control to the EOF/JIC. does)

E9. Establish and maintain continuous accountability in the EOF.

Security Staff (2) Sitespecific position E1. Maintain access control at designated points for the EOF/JIC. Eliminate Position Yes N/A No No EI4.3 Attachment 3 N/A E1 eliminate task (Tech Advisor does) 3 OF 8

ERO POSITION MATRIX Position Key Procedure(s) Regulatory Current ERO Position ENEP801 Tasks (F#) Other Procedural Tasks (ENEP6XX(P#), EI4.X(E#)) Implementing Actions eliminated? Task Assigned to? Min Staffing? NRC PI? EPlan section Requirement EOF Admin Support Sitespecific position E1. Maintain a log. Eliminate Position Yes N/A No No EI4.3 Attachment 2 N/A E2. Ensure equipment readiness. E1 eliminate task E3. Make copies and distribute documents received as necessary. E2 eliminate task (each position ensures equipment readiness for their needs)

E3 eliminate task each position takes care of own copying/distribution as needed TECHNICAL SUPPORT CENTER Emergency Plant Manager F1. Direct the activation, operation and deactivation of the TSC P1. Maintain a log F1 task from Ops Coord No N/A Yes Yes ENEP610, Att. 9.1 F2. NUREG 0654 II.A.1.d/II.B.3 F2. Assume command and control of the TSC and OSC and the onsite mitigation efforts P2. Maintain adequate staffing, access control, and 24hour functional F4 task from Ops Coord Eplan 5.4.2 F14. NUREG 0654 II.K.2 F3. Provide information and recommendations to the ED regarding the classification of an continuity of the CR, TSC, and OSC F5 task from Ops Coord Eplan 6.1.2 emergency F7 task from Ops Coord (delete F4. Prepare and facilitate facility briefings reference to Maint Coord)

F5. Verify event classifications F8 task from Ops Coord F6. Ensure timely ENS notifications F13 task from Ops Coord F7. Perform accident assessment to prioritize mitigation actions. F14 task from Ops Coord F8. Coordinate the activities of the CR, TSC and OSC F15 task from Ops Coord F9. Direct personnel evacuation, assembly and accountability of nonessential personnel F17 eliminate task F10. Provide information and recommendations to the ED regarding plant activities P3 task from Ops Coord F11. Advise the ED on core damage and plant conditions for classification and PAR F5 task from TSC Manager determination. F7 task from TSC Manager F12. Direct the organization, coordination, and prioritization of repair corrective action teams F8 task from TSC Manager F13. Direct onsite protective actions E6 task from TSC Admin Support F14. Authorize emergency radiation exposure and issuance of KI to recommended personnel in F1 task from Maint Coord the CR, TSC or OSC or to Security personnel. P2 task from Maint Coord F15. Make operational decisions involving the safety of the plant and its personnel and make recommendations to the Control Room Personnel F16. Initiate immediate corrective actions to limit or contain the emergency invoking the provisions of 10 CFR 50.54(x) if appropriate F17. Implement severe accident management procedure strategies F18. Direct relocation to an alternate location.

F19. Integrate offsite responders with onsite response efforts when required F20. Perform emergency termination duties TSC Manager F1. Assure staffing/timely activation of the TSC. P1. Synchronize the TSC time with CR time Eliminate position Yes F5 EPM No No ENEP610, Att. 9.2 N/A F2. Notify EPM when operational conditions exist. P2. Maintain log P1 eliminate task F7 EPM F3. Recognize and implement all technical aspects of accident mitigation for the emergency. P3. Verify ERDS is activated P2 eliminate task (done by EPM) F8 EPM F4. Perform technical assessments and communicate the conclusions to the EPM. P4. Particpate in periodic briefings with EPM F1 eliminate task (EPM does) P7 EOF Tech Advisor F5. Set priorities for the TSC personnel/OSC Teams. P5. Direct EOP questions to the Operations Coordinator F2 eliminate task F6. Assist the EPM to make operational decisions concerning the safety of the plant. P6. Establish communications as needed with the Entergy Engineering Groups F3 eliminate task (Eng Coord does)

F7. Oversee the activities for relocation to an alternate location. for engineering support functions F4 eliminate task (Eng Coord does)

F8. Direct the tracking of plant configuration changes. P7. Notify NSSS vendor and other vendors of emergency conditions, as F6 eliminate task F9. Deactivate the TSC when the emergency is terminated. required F9 eliminate task (EPM does)

P3 eliminate task P4 eliminate task P5 eliminate task P6 eliminate task Operations Coordinator 1. Coordinate TSC efforts in determining the nature and extent of emergencies pertaining to equipment P1. Monitor fission product barrier and plant status Eliminate position Yes F1 EPM No Yes ENEP610, Att. 9.3 N/A and plant facilities in support of Control Room actions. P2.Complete the Essential Information Form to support periodic briefs as F2 eliminate task (EPM does) F4 EPM

2. Perform accident assessment activities. requested by the EPM F3 eliminate task (EPM does) F5 EPM

3. Provide assistance to initiate immediate corrective actions to limit or contain the emergency P3. Provide technical support to OSC teams F6 eliminate task (EPM does) F7 EPM invoking the provisions of 10 CFR 50.54(x)1 if appropriate, and specifically when addressing Severe F9 eliminate task (EPM does) F8 EPM Accident Management Guidelines (SAMG/SAG).

F10 eliminate task (EPM does) F13 EPM

4. Recommend equipment operations checks and miscellaneous actions to the Control Room in support F11 eliminate task F14 EPM of restoration and accident mitigation.

5. Approve emergency special procedures, and implement as required under the provisions of 10 CFR F12 eliminate task (EPM does) F15 EPM 50.54(x)1 if qualified. F16 eliminate task P3 EPM

6. Recommend changes in plant priorities. P1 eliminate task

7. Assist the Maintenance Coordinator in determining the priority assigned to OSC activities. P2 eliminate task (EPM does)

8. Coordinate additional staffing for the Control Room if requested by the SM.

9. Provide input on event classification.

10. Assist the EPM in evaluating changes in event classification.

11. At the direction of the EPM, assume the duties and responsibilities of the Evaluator, or Decision Maker if qualified, when transition to Severe Accident Management Guidelines (SAMG/SAG) is initiated.

12. Inform the TSC of the overall plant condition and significant changes to system and equipment status.

13. Ensure the Control Room, TSC, and EOF is informed of significant changes in event status (e.g.

changes in classification, command and control, initiation of station assembly, accountability, evacuation, etc.).

14. Coordinate CR request for operations activities outside of the Control Room

15. Provide technical assistance to the Shift Manager.

16. Recommend strategies and actions to prevent severe core damage and containment failure and reduce radiological release.

4 OF 8

ERO POSITION MATRIX Position Key Procedure(s) Regulatory Current ERO Position ENEP801 Tasks (F#) Other Procedural Tasks (ENEP6XX(P#), EI4.X(E#)) Implementing Actions eliminated? Task Assigned to? Min Staffing? NRC PI? EPlan section Requirement Radiological Coordinator F1. Assess radiological conditions to develop radiological plans. P1. Establish and maintain radiological habitability. Eliminate position Yes F1 Rad/Chem Coord Yes Yes ENEP610, Att. 9.9 F9. NUREG II.K.1.a F2. Keep the TSC Manager informed of the radiological conditions. P2. Maintain a log F9 eliminate task (Rad/Chem Coord F2 Rad/Chem Coord F3. Obtain and evaluate data on plant conditions such as meteorological and radiological P3. Direct decontamination efforts of personnel, equipment, and onsite areas does) F3 Rad/Chem Coord monitoring readings, and other pertinent data. as appropriate F12 eliminate task F4 Rad/Chem Coord F4. Ensure that appropriate bioassay procedures have been implemented for onsite personnel P4. Suspend normal RWP requirements for performing work in radiological P1 eliminate task (Rad/Chem Coord F5 Rad/Chem Coord when a radioactivity incident has occurred. controlled areas if necessary. does) F6 Rad/Chem Coord (change TSC Mgr to F5. Recommend authorization of personnel emergency exposure limits. P5. Document radiological readings taken by RP Technicians or other meter P2 eliminate task EPM)

F6. Advise the TSC Manager when use of KI should be considered and coordinate the issuance qualified individuals in the field on survey maps. P3 eliminate task (Rad/Chem Coord F7 Rad/Chem Coord if approved. P6. Establish and maintain dosimetry, protective clothing, and other protective does) F8 Rad/Chem Coord (change TSC Mgr to F7. Recommend evacuation based on environmental conditions equipment requirements for onsite ERO personnel P6 eliminate task (Rad/Chem Coord EPM)

F8. Advise the TSC Manager and EOF Radiological Assessment Coordinator of changes in P7. Control the issuance of KI to onsite emergency workers. does) F10 Rad/Chem Coord radiological release status. P8. Evaluate iodine uptakes for persons issued KI, informing contracted F11 Rad/Chem Coord F9. Assist in planning rescue operations and provide monitoring services as required, including medical representatives of KI issuance. P4 Rad/Chem Coord the transfer of injured and/or contaminated personnel. P5 Rad/Chem Coord F10. Coordinate with the Security Coordinator to determine the routes to be used for P7 Rad/Chem Coord evacuation of nonessential personnel and BREs. P8 Rad/Chem Coord F11. Evaluate and request additional radiation protection personnel and/or equipment.

F12. Advise the Rad Chem Coordinator in the OSC of changes in plant conditions or equipment that may change radiological conditions onsite.

Engineering Coordinator F1. Provide technical guidance to support repair activities. P1. Maintain a log F4 change TSC Manager to EPM No N/A No No ENEP610, Att. 9.5 N/A F2. Recommend strategies and actions to prevent severe core damage and containment failure P2. Coordinate with Non Entergy engineering support (INPO, Mutual F5 eliminate task SAMG no longer and reduce radiological releases. Assistance, Westinghouse, Equipment Vendors and/or NRC Engineers) required F3. Coordinate Engineering work requests with the Engineering support team. P3. Confirm any sample requests for chemistry sampling contain details on the P1 task from TSC Comm F4. Provide results back to the TSC Manager. type of information that is necessary F5. Support SAMG activities and strategies. P4. Provide engineering support for OSC activities as requested F6. Direct tracking and trending of parameters.

F7. Direct the development of emergency repair procedures to support emergency teams.

F8. Track plant configuration changes.

Maintenance Coordinator F1. Communicate the request for repair and corrective teams to the OSC Work Control P1. Provide operational guidance and recommendations on equipment Eliminate position Yes F1 EPM No No ENEP610, Att. 9.11 N/A Coordinator. operations F1 change Work Control Coord to OSC P2 EPM F2. Prioritizes the requests with the TSC Manager. P2. Identify emergency repairs that can be undertaken to restore and maintain Manager equipment operability and plant safety F2 eliminate task (EPM does)

P3. Assist in developing emergency procedures if needed P1 eliminate task (EPM does)

P4. Assist the OSC Coordinators in preparing to send repair teams into the P3 eliminate task (Eng Coord does) plant P4 eliminate task P5. Maintain manpower status to ensure OSC is adequately staffed to support P5 eliminate task (OSC Mgr does) mitigation activities. P6 eliminate task P6. Maintain a log/list and status of OSC work assignments.

TSC Communicator F1. Maintain facility log on WebEOC or other acceptable method. P1. Maintain communications as necessary with satellite Entergy response Eliminate position Yes P1 Eng Coord No No ENEP610, Att. 9.8 N/A F2. Ensure timeliness of facility briefs by prompting EPM to develop and adhere to briefing groups outside the ERFs schedule P2. Keep aware of Control Room personnel actions and procedures being F1 eliminate task (EPM does)

F3. Communicate between the ERFs if necessary regarding plant status or WebEOC entries. implemented. Notify TSC Engneers if appropriate. F2 eliminate task F4. Support the EPM/TSC Manager as requested. P3. Work with other members of the TSC staff to provide support to the F3 eliminate task Control Room to mitigate the effects of the event and return the plant to a F4 eliminate task safe condition. P2 eliminate task (EPM does)

P3 eliminate task (EPM does)

ENS Communicator F1. Prepare the NRC notification worksheet. P1. Maintain a log N/A No N/A Yes No ENEP610, Att. 9.12 F2. NUREG 0654 II.A.1.e F2. Establish and maintain communications with the NRC via the ENS phone. P2. Assist the Engineering Coordinator as necessary in obtaining plant data ENEP610, Att. 9.13 F3. Prepare followup notifications F4. Monitor plant computer parameters and provide plant status to the NRC.

F5. Use backup NRC notification method if ENS line fails.

Reactor Engineer 1. Determine and provide estimation of core damage. N/A Eliminate position no Reactor Eng. Yes N/A Yes No ENEP610, Att. 9.4 F1. NUREG 0654 II.B.5 (Table B1)

2. Assist in Severe Accident Management Guideline implementation. responsibilities to transfer

3. Provide core parameter information results back to the TSC Manager.

TSC Engineer Mechanical F1. Respond to engineering requests from the Engineering Coordinator. P1. Assist the OSC Mechanical and I&C/Electrical Coordinators in preparing to Eliminate position eliminate tasks Yes N/A Yes No ENEP610, Att. 9.6 F1. NUREG 0654 II.B.5 (Table B1)

F2. Evaluate SAM/SAG strategy implementation when designated send repair teams into the plant TSC Engineer Electrical/I&C F1. Respond to engineering requests from the Engineering Coordinator. P1. Assist the OSC Mechanical and I&C/Electrical Coordinators in preparing to Eliminate position eliminate tasks Yes N/A Yes No ENEP610, Att. 9.6 F1. NUREG 0654 II.B.5 (Table B1)

F2. Evaluate SAM/SAG strategy implementation when designated send repair teams into the plant IT Specialist N/A N/A N/A N/A N/A N/A N/A N/A N/A (in the EOF) 5 OF 8

ERO POSITION MATRIX Position Key Procedure(s) Regulatory Current ERO Position ENEP801 Tasks (F#) Other Procedural Tasks (ENEP6XX(P#), EI4.X(E#)) Implementing Actions eliminated? Task Assigned to? Min Staffing? NRC PI? EPlan section Requirement Security Coordinator F1. Overall coordination of the offsite assistance for the security related response. P1. Provide assistance in evaluating plant equipment/system(s) to determine if E2 task from EOF Security Coord No N/A No Yes ENEP610, Att. 9.10 N/A F2. Designated National Incident Management System (NIMS) Liaison between the Incident malfunctionsare related to sabotage. E3 task from EOF Security Coord Command Post (ICP) and Site Organization. P2. Coordinate assistance to monitoring teams by permitting access to owner F3. Coordinate accountability controlled areas normally gated off.

F4. Keep security force advised of emergency status F5. Coordinate with Radiological Coordinator regarding protective actions for the security force.

F6. Keep the ED/EPM informed of any security contingency event which may be occurring and response in progress F7. Coordinate the dispatch of security officers to evacuation assembly areas and keep the ED/EPM informed of evacuation accountability.

TSC Log Keeper Sitespecific position E1. Assist the TSC Manager as necessary. Eliminate Position Yes N/A No No EI4.1 Attachment 2 N/A E2. Prompt the TSC Manager to maintain regular briefs. E1 eliminate task E3. Maintain a chronological log of emergency status and TSC activities. E2 eliminate task E4. Display the repair and corrective action team status. E3 eliminate task E5. Provide other clerical functions as needed. E4 eliminate task E6. Support conduct of briefings. E5 eliminate task E6 li i t t k TSC Admin Support Sitespecific position E1. Maintain a log. Eliminate Position Yes E6 EPM No No EI4.1 Attachment 1 N/A E2. Ensure equipment readiness. E1 eliminate task E3. Coordinate with EOF for arrangments for food and drink for onsite ERO. E2 eliminate task E4. Ensure ENS Communicator immediately receives all incoming Event E3 eliminate task (Tech Advisor does)

Notification Forms and Event Technical Data Sheets. E4 eliminate task E5. Make copies and distribute documents received as necessary. E5 eliminate task E6. Facilitate integration of NRC personnel.

OPERATIONS SUPPORT CENTER OSC Manager F1. Direct the activation, operation and deactivation activities of the OSC. P1. Maintain adequate OSC Staffing F1 task from OSC Log Keeper No N/A Yes Yes ENEP611, Att.9.1 N/A F2. Coordinate and/or prioritize assessment and corrective actions with the TSC. F2 task from Work Control Coord F3. Provide periodic briefings to the OSC personnel. F3 task from Work Coords F4. Support the formation, briefing and debriefing of teams. F4 task from Work Coords F5. Maintain communications with the CR and/or the TSC to inform of OSC teams activities.

F6. Ensure timely dispatch of the teams and mobilize other required support personnel.

F7. Ensure work task priorities are being maintained.

F8. Maintain OSC accountability.

F9. Coordinate movement of OSC personnel to a habitable location or alternate OSC if conditions degrade.

F10. Identify and request resources, equipment and supplies to support the OSC.

Work Control Coordinator F1. Coordinate the formation, briefing and debriefing of repair and corrective action teams and N/A Eliminate position Yes F2 OSC Manager No No ENEP611, Att. 9.3 N/A onsite monitoring teams F1 eliminate task (done by OSCM)

F2. Maintain communications with the Maintenance Coordinator in the TSC F3 eliminate task (done by OSCM)

F3. Ensure timely dispatch of repair/corrective action teams, search/rescue teams, onsite monitoring teams and mobilize other required support personnel.

OSC Log Keeper F1. Maintain facility log N/A Eliminate position Yes F1 OSC Manager No No ENEP611, Att. 9.6 N/A F2. Ensure timeliness of facility briefs by prompting the OSC Manager of the briefing schedule if F2 eliminate task necessary. F3 eliminate task F3. Support the OSC Manager as requested Rad/Chem Coordinator F1. Coordinate RP activities, including onsite radiological assessment, personnel exposure E1. Organize and direct Search and Rescue teams, as needed. F1 task from RP Coord No N/A Yes No ENEP611, Att. 9.5 F5. NUREG 0654 II.K.1.e (RPC has this task) control, and radiation protection programs. E2. Organize and direct first aid teams. F2 task from RP Coord EI4.2 5.3.1 F2. Ensure use of protective clothing, respiratory protection, and access control within the E3. Organize and direct offsite monitoring teams prior to EOF activation, as F3 task from RP Coord plant is deemed appropriate to control personnel exposures. needed. F4 task from RP Coord F3. Deploy onsite radiation monitoring teams to survey radiation levels and sample for F5 task from RP Coord contamination. F6 task from RP Coord (change TSC F4. Ensure habitability of the TSC and/or OSC and habitability of Control Room (where Mgr to EPM) applicable) F7 task from RP Coord F5. Ensure that personnel are decontaminated, if necessary. F8 task from RP Coord (change TSC F6. Conduct/provide assistance for the rad briefings to support the dispatch of the Mgr to EPM) repair/corrective action teams and chemistry/ RP sampling. F10 task from RP Coord F7. Communicate rad/chemistry sample results to the TSC and/or CR. F11 task from RP Coord F8. Coordinate the transport of potentially contaminated or highly exposed personnel to off P4 task from RP Coord site medical facilities. P5 task from RP Coord F9. Determine the necessity for emergency exposure limits and KI issuance and communicate P7 task from RP Coord conditions to the TSC. P8 task from RP Coord F10. Provide radiological support for evacuations, medical response, fire response and search E1 task from OSC Radio Comm and rescue. E2 task from OSC Radio Comm F11. Ensure emergency ventilation filtration system is started per procedures (site specific). E3 task from OSC Radio Comm F12. Establish chemistry sampling priorities. E4 task from OSC Radio Comm F13. Debrief returning emergency teams.

Mechanical Coordinator F1. Assign team members to the repair and corrective action teams N/A Eliminate Position Yes F3 OSC Manager No No ENEP611, Att. 9.4 N/A F2. Conduct/participate in prejob briefing for the assigned tasks. F1 eliminate task (OSCM does) F4 OSC Manager F3. Ensure repair and corrective action teams are tracked. F2 eliminate task (OSCM does)

F4. Ensure communication with the teams is maintained. F5 eliminate task (OSCM does)

F5. Participate in debriefing of returning emergency teams.

6 OF 8

ERO POSITION MATRIX Position Key Procedure(s) Regulatory Current ERO Position ENEP801 Tasks (F#) Other Procedural Tasks (ENEP6XX(P#), EI4.X(E#)) Implementing Actions eliminated? Task Assigned to? Min Staffing? NRC PI? EPlan section Requirement I&C / Electrical Coordinator F1. Assign team members to the repair and corrective action teams. N/A Eliminate Position Yes F3 OSC Manager No No ENEP611, Att. 9.4 N/A F2. Conduct/participate in prejob briefings F1 eliminate task (OSCM does) F4 OSC Manager F3. Ensure repair and corrective action teams are tracked. F2 eliminate task (OSCM does)

F4. Ensure communication with the teams is maintained. F5 eliminate task (OSCM does)

F5. Participate in debriefing of returning emergency teams.

Operations Support F1. Support the OSC as needed. N/A Eliminate Position Yes F2 OSC Manager No No ENEP611, Att. 9.2 N/A F2. Ensure the SM is informed of OSC teams and activities, as applicable. F1 Eliminate task F3. Identify potential operational support needs. F2 eliminate task (OSCM does)

F3 Eliminate task OSC Teams/Technicians F1. Perform initial actions per procedure upon arrival in the OSC. E1. RP Log important information and activities. N/A Yes The augmenting I&C N/A Yes No EI4.2 Attachment 6 F1. NUREG 0654 II.B.5 (Table B1)

(Electrical, I&C, Mechanical, F2. Attend prejob briefing prior to performing emergency maintenance. E2. Maintain equipment control throughout the emergency. Technician and Chemistry EI4.2 Attachment 7 Maintenance, RP/HP, F3. Ensure status boards and/or WebEOC reflect the correct status. Technician are eliminated. EI4.2 Attachment 10 Chemistry) F4. Perform inplant activities as directed by the OSC Coordinator(s). Number of augmenting EI4.2 Attachment 11 F5. Debrief team activity upon return to the OSC. Electrical and RP/HP EI4.2 Attachment 14 F6. RP performs habitability of ERFs where applicable. Technicians reduced.

OSC Radio Communicator Sitespecific position E1. Establish radio communications. Eliminate Position Yes E1 Rad/Chem Coordinator No No EI4.2 Attachment 8 N/A E2. Ensure efficient and timely information flow and documentation of E2 Rad/Chem Coordinator messages. E3 Rad/Chem Coordinator E3. Ensure 10mile EPZ map is updated with meteorological data. E4 Rad/Chem Coordinator E4. Upon EOF activation, turnover information to the EOF Offsite Team Coordinator.

OSC Admin Support Sitespecific position E1. Maintain a log. Eliminate Position Yes N/A No No EI4.2 Attachment 9 N/A E2. Maintain personnel accountability in the OSC. E1 eliminate task E2 eliminate task (OSCM does)

JOINT INFORMATION PIPP06(P#)

CENTER Company Spokesperson F1. Obtain briefing from the ED to ensure timely development of news releases. P1. Ensure prompt and accurate dissemination of information about the emergency F1 task from JIC Manager No N/A Yes No PIPP06, 3.2 F3. NUREG 0654 II.B.7.d/ II.G.3.a/II.G.4.a F2. Ensure that news media briefings are held regularly during the course of the emergency. to the news media and public via ENC News Releases and News Conferences. F2 task from JIC Manager PIPP06, Attachment 2 F5. NUREG 0654 II.G.4.c F3. Serve as spokesperson at media briefings. P2. Ensure orderly and timely transition to the JIC once State personnel arrive and are F3 task from JIC Manager F4. Keep the Entergy Vice President of Communications, or designee, informed throughout the ready to activate. F4 task from JIC Manager P3. Ensure liaison with offsite agencies (Federal, State and local) for the release of emergency. F5 task from JIC Manager public information.

F5. Resolve any known rumors or misinformation to the Media. F6 task from JIC Manager P4. Review and approve all Entergy news bulletins related to the emergency.

F8 task from JIC Manager P1 task from JIC Manager P2 task from JIC Manager F1 task from Info Coord F2 task from Info Coord F3 task from Info Coord P1 task from Info Coord F1 task from Log Keeper F3 task from Logistics Coord F1 task from Press Release Writer F2 task from Press Release Writer F3 task from Press Release Writer P1 task from Press Release Writer F1 task from Inquiry Response Coord JIC Manager F1. Direct the activation, operation and deactivation of the JIC. P1. Ensure establishment of security for ENC/JIC operations. Eliminate position Yes F1 Company Spokesperson Yes No PIPP06, 3.3 N/A F2. Obtain ED approval for the developed news releases and revise accordingly. P2. Prepare list of personnel available to support extended ENC/JIC operations. F7 eliminate task (CS doing) F2 Company Spokesperson PIPP06, Attachment 3 F3. Ensure press release information is communicated to the offsite agencies. F3 Company Spokesperson F4. Ensure press releases are coordinated with the offsite agencies. F4 Company Spokesperson F5. Ensure appropriate timing, content and distribution of news releases. F5 Company Spokesperson F6. Ensure activation of rumor control/public inquiry activities for response to questions from F6 Company Spokesperson the general public. F8 Company Spokesperson F7. Establish or ensure media briefing schedule. P1 Company Spokesperson F8. Notify the Corporate Emergency Center (CEC). P2 Company Spokesperson Technical Advisor F1. Answer technical questions from the news media regarding the emergency situation. N/A Eliminate position Yes F1 EOF Technical Advisor Yes No PIPP06, 3.7 N/A F2. Advise the Inquiry Response Coordinator on questions about radiation or nuclear F2 EOF Technical Advisor PIPP06, Attachment 7 technology to respond to phone questions from the public or media. F3 EOF Technical Advisor F3. Assists the press release writer for technical accuracy, if JIC Technical Assistant position is not staffed.

Technical Assistant F1. Assists the press release writer for technical accuracy. P1. Assume the role of JIC Manager when assigned by either the JIC Manager Eliminate position Yes N/A Yes No PIPP06, 3.8 N/A (Optional in ENEP801) F2. Assist with other JIC activities as needed (e.g., assist with offsite agencies in the JIC). or the Company Spokesperson. F1 eliminate task (Tech Adv does) PIPP06, Attachment 8 F2 eliminate task P1 eliminate task 7 OF 8

ERO POSITION MATRIX Position Key Procedure(s) Regulatory Current ERO Position ENEP801 Tasks (F#) Other Procedural Tasks (ENEP6XX(P#), EI4.X(E#)) Implementing Actions eliminated? Task Assigned to? Min Staffing? NRC PI? EPlan section Requirement Media Liaison F1. Verify the readiness of the JIC briefing area. N/A F2 task from Logistics Coord No N/A Yes No PIPP06, 3.6 N/A F2. Ensures media is informed of protocol and schedules established for media briefings. P1 task from Logistics Coord PIPP06, Attachment 6 F3. Receive and distribute press release information to the media in the JIC briefing area. P1 from JIC Security Information Coordinator F1. Provide news bulletins / press releases for distribution P1. Act as liaison between ENC/JIC personnel and other organizations Eliminate position Yes F1 Company Spokesperson Yes No PIPP06, 3.5 N/A F2. Supervise media monitoring and response activities. operating in the ENC/JIC. F4 eliminate task (CS does) F2 Company Spokesperson PIPP06, Attachment 5 F3. Supervise public response activities. F3 Company Spokesperson F4. Establish and maintain frequent contact with the communications personnel in the P1 Company Spokesperson corporate office or CEC.

Press Release Writer F1. Generate press releases as directed by the JIC Manager. P1. Coordinate with the Technical Advisor/Technical Assistant to obtain up to Eliminate position Yes F1 Company Spokesperson Yes No PIPP06, 3.4 N/A F2. Coordinate with the JIC Manager and transmit generated press releases to ED for approval. date and accurate information for press releases. F2 Company Spokesperson PIPP06, Attachment 4 F3. Transmit copies of approved press releases to the CEC/Corporate Communications. F3 Company Spokesperson P1 Company Spokesperson Logistics Coordinator F1. Activate facility security and briefing center. P1. Ensures the operation of Audio/Visual and the Media Briefing Room facility.Eliminate position Yes F2 Media Liaison Yes No PIPP06, 3.12 N/A F2. Maintain access control to the JIC. F1 eliminate task (CS does) F3 Company Spokesperson PIPP06, Attachment 11 F3. Ensure distribution of all press releases to the offsite agencies, JIC/EOF facilities and to the P1 Media Liaison Media Liaison.

Inquiry Response Coordinator F1. Ensure activation of rumor control activities for response to questions from the general P1. Provide the ENC/JIC Manager with identified trends and information Eliminate position Yes F1 Company Spokesperson Yes No PIPP06, 3.9 N/A public and media. related to the emergency. F2 Company Spokesperson PIPP07 F2. Monitor and respond to the public/media inquiry calls and track trends. P2. Maintain a positionspecific log for Plant Mode Changes, Plant Emergency F3 Company Spokesperson F3. Refer questions on radiation or nuclear technology from Rumor Control Center to the Classification Levels, agricultural advisories, and rumor trends. P1 Company Spokesperson Technical Advisor F2 Inquiry Responder Media Monitor F1. Monitor TV, radio broadcasts and other media sources for inaccuracies. N/A N/A No N/A Yes No PIPP06, 3.11 N/A F2. Report all inaccuracies to the Information Coordinator or JIC Manager to ensure they are PIPP06, Attachment 10 addressed in the media briefings.

JIC Log Keeper F1. Maintain facility log on WebEOC or other acceptable method. N/A Eliminate position Yes F1 JIC Manager Yes No PIPP06, Attachment 13 N/A F2. Support the JIC Manager as requested. F2 Eliminate task Inquiry Responders (2) F1. Log questions that require a callback N/A Change F2 to Company Spokesperson No N/A Yes No PIPP06, 3.10 N/A (Public Inquiry Staff) F2. Log rumors and provide to the Inquiry Response Coordinator F2 task from Inquiry Response Coord PIPP07 F3 task from Inquiry Response Coord JIC Admin Support Sitespecific position P1. Provide clerical support for facility personnel as requested. Eliminate position Yes N/A Yes No PIPP06, 3.13 N/A P2. Process incoming faxes. P1 eliminate task PIPP06, Attachment 12 P3. Process draft press releases. P2 eliminate task P4. Process approved press releases. P3 eliminate task P4 eliminate task 8 OF 8

Attachment 7 To Entergy Letter PNP 2017-034 Palisades Nuclear Plant List of Regulatory Commitments (1 Page)

ATTACHMENT 7 List of Regulatory Commitments This table identifies actions discussed in this letter for which Entergy Nuclear Operations, Inc.

(ENO) commits to perform. Any other actions discussed in this submittal are described for the NRC's information and are not commitments.

TYPE (Check one) SCHEDULED ONE-TIME CONTINUING COMPLETION DATE COMMITMENT ACTION COMPLIANCE (If Required)

ENO has not yet finalized a schedule of x Appropriate drills that will be conducted. Provide the advanced notice to NRC Project Manager a schedule of drills allow the NRC and that will be conducted in preparation for U.S. Federal implementation of the Post-Shutdown Emergency Emergency Plan (PSEP). Management Agency (FEMA) an opportunity to observe each drill.

Revise applicable fuel handling procedures x Prior to permanent to require that a Chemistry Technician be removal of fuel from on-site or the radiation monitors listed in the the PN P reactor gaseous effluent Emergency Action Levels vessel.

are in service as a prerequisite to handling or moving spent fuel.

Training and procedures will be developed x Prior to and in place prior to performing post- implementation of shutdown Emergency Response ERO changes.

Organization (ERO) validation drills. The drill scenarios will include spent fuel pool events and be designed to test the major elements of the PNP PSEP. Major elements to be tested will include communications and coordination with offsite response organizations, including the Joint Information Center.

State, County and Federal response x Appropriate organizations will be provided the advanced notice to opportunity to participate in or observe the allow the NRC and drills conducted in preparation for FEMAan implementation of the PNP PSEP. opportunity to observe each drill and to allow the State/County organizations to participate.

Attachment 8 To Entergy Letter PNP 2017-034 Palisades Nuclear Plant State and Local Agency Correspondence on Post-Shutdown Emergency Plan License Amendment Request Meeting (4 Pages)

BEwuEN COUNTY EM]RGENcY MANAGEMENT DIvIsION OF BERIUEN CouNTY SHE1UFFs OFFICE 2100 E. Empire Avenue, Benton Harbor, Michigan 49022 Telephone (269) 983-7141

• Fax: (269) 934-9023 j0N14 BOARD OF COMMISSIONERS L. PAUL BAILEY SHERIFF CAPT. ROCKEY ADAMS COORDTNATOR July 25, 2017 Mr. Daniel G. Malone Emergency Planning Manager Entergy Palisades Nuclear Plant

27780 Blue Star Memorial Highway Covert, Michigan 49043

SUBJECT:

Palisades Nuclear Plant Post-Shutdown Emergency Plan

Dear Mr. Malone,

We appreciated the invitation to learn more about the Palisades Post-Shutdown Plan License Amendment Request (LAR) and participate in discussion regarding this LAR on June 6, 2017.

Based upon all conversations about this Plan and LAR, leading up to and during the June 6 meeting, we understand the proposed changes. We see no indication that these changes would impact our ability to effectively implement our FEMA-approved REP plans nor do we see any evidence that the safety of the public in Berrien County is negatively affected by this proposed plan.

We will commit any requisite resources needed when it becomes appropriate, for any validation drills or exercises that are scheduled and we will continue to support the NRC and FEMA in executing their respective radiological preparedness missions during the decommissioning process.

We thank you again for explaining the proposed plan and allowing for an open discussion on the proposed changes to the E-Plan. Feel free to contact me if you have any future questions or needs at (269) 983-7111 ext. 4916.

Respectfully, Capt. Rockey Adams Emergency Management Coordinator, Berrien County Sheriffs Office Emergency Management and Homeland Security Division

VAN BUREN COUNTY OFFICE OF DOMESTIC PREPAREDNESS DIVISION OF VAN BUREN COUNTY SHERIFFS OFFICE 205 South Kalamazoo Street

• Paw Paw, Michigan, 49079 - 1594 TELEPHONE (269) 657-7786. FAX (269) 657-7787 Lt. Robert A. Kirk Daniel E. Abbott Director Sheriff kirkrvbco.org abbottd(12vbco.org July20, 2017 Mr. Daniel G. Malone Emergency Planning Manager Entergy Palisades Nuclear Plant

27780 Blue Star Memorial Highway Covert, Michigan 49043

SUBJECT:

Palisades Nuclear Plant Post-Shutdown Emergency Plan

Dear Mr. Malone,

Based on discussions during our meeting on June 6, 2017, concerning Entergys Post-Shutdown Emergency Plan License Amendment Request for Palisades Nuclear Plant, we are satisfied we understand the changes proposed and we are satisfied that these changes will not impact the ability of Van Buren County Sheriffs Office and the VBC Office of Domestic Preparedness to effectively implement our FEMA-approved REP plans.

Lt. Robert Kirk Director/Emergency Manager Office of Domestic Preparedness Van Buren County Sheriffs Office Emergency 911

• Domestic Preparedness Assistant (269) 657-2006 ext. 3998

• Sheriffs Office (269) 657-3101

Allegan County Sheriffs Office EMERGENCY MANAGEMENT DEPARTMENT Homeland Security / Local Emergency Planning Committee 3271 - 122nd Avenue, Allegan, Michigan 49010 Telephone: (269) 673-0571 Fax: (269) 673-0566 Monday, August 14, 2017 Sheriff

Dear Mr. Malone,

Frank Baker Undersheriff Thank you for the invitation to the June 6, 2017 presentation concerning the License Amendment Request for Palisades Nuclear Mike Larsen Plant. Based on this meeting and the discussions that followed after, we feel satisfied that we fully understand the proposed changes and Director do not feel that these changes will in any way impact our ability to Scott Corbin effectively implement our FEMA-approved REP plans.

LEPC Information Sincerely, Coordinator Brett Apelgren LEPC Chairperson Dean Kapenga Scott Corbin Allegan County Emergency Management Director OXCOM Coordinator Jason Veenstra Cert Coordinator Bryan Walker Cadets Connor Mendell Meghan Wood Web site: http://www.allegancounty.org/EOC

STATE OF MICHIGAN RICK SNYDER DEPARTMENT OF STATE POLICE CCL. KRISTE KIBBEY ETUE GOVERNOR LANsnG DIRECTOR July 24, 2017 Mr. Daniel G. Malone Emergency Planning Manager Entergy Palisades Nuclear Plant

27780 Blue Star Memorial Highway Covert, Michigan 49043

Dear Mr. Malone:

Thank you for your presentation on June 6 concerning Entergys Post-Shutdown Emergency Plan License Amendment Request for Palisades Nuclear Plant. Based on this and the discussions that followed, I am satisfied and fully understand the plants licensing amendment request and what can be expected before, during, and after the plants anticipated shutdown.

The Michigan State Police, Emergency Management and Homeland Security Division is confident these proposed changes will not impact our ability to effectively implement the states FE MA-approved Radiological Emergency Preparedness (REP) Plans.

I am fully supportive of the process and will do everything necessary to ensure the safety and protection of the public, as identified in the FEMA REP Manual.

Please contact me directly if you require further assistance in this matter.

Sincerely, Capt. Chris A. Kelenske, Commander Deputy State Director of Emergency Management and Homeland Security EMERGENCY MANAGEMENT AND HOMELAND SECURITY DIVISION

• P.O. BOX 30634

• LANSING, MICHIGAN 48909 www.michigan.gov/msp

• 517-284-3745