ML14091A489

Virgil C. Summer Nuclear Station, License Amendment Request LAR-13-02396, Attachments 1, 2, 3, 4, and 5

ML14091A489
Person / Time
Site:	Summer
Issue date:	03/26/2014
From:	South Carolina Electric & Gas Co
To:	Office of Nuclear Reactor Regulation
Shared Package
ML14091A487	List: ML14091A488 ML14091A489 RC-14-0039, License Amendment Request LAR-13-02396, Attachments 5, 6 and 7 RC-14-0039, Virgil C. Summer Nuclear Station, License Amendment Request LAR-13-02396, Attachments 1, 2, 3, 4, and 5 RC-14-0039, Virgil C. Summer, Unit 1 - License Amendment Request LAR-13-02396, Request for NRC Approval of Radiation Emergency Plan Change
References
LAR-13-02396, RC-14-0039
Download: ML14091A489 (288)

Text

{{#Wiki_filter:Document Control DeskAttachment ILAR-1 3-02396RC-1 4-0039Page 1 of 10VIRGIL C. SUMMER NUCLEAR STATION (VCSNS) Unit 1DOCKET NO. 50-395OPERATING LICENSE NO. NPF-12ATTACHMENT IAnalysis of Proposed Radiation Emergency Plan Change1.0 DESCRIPTION Virgil C. Summer Nuclear Station, Unit 1 (VCSNS) is proposing changes to its Radiation Emergency Plan (EP). The proposed changes include the following: activation time of theEmergency Response Facilities (ERF), including the Emergency Operations Facility (EOF),Technical Support Center (TSC), and Operational Support Center (OSC) within 75 minutes ofan ALERT or higher declaration; relocation of the Technical Support Center to a new locationwithin the basement of the Nuclear Operations Building (NOB); realignment of Emergency Response Organization (ERO) positions, titles, and responsibilities to support a future multi-unit site; transfer of the offsite notification responsibilities directly from the Control Room to the EOF;relocation of the EOF engineering support personnel to the new Technical Support Center; andadministrative changes to support the above changes. The changes have been evaluated under 10 CFR 50.54(q) and reductions in effectiveness have been identified; therefore thechanges require prior NRC approval. 2.0 PROPOSED CHANGE(Note: Attachment II provides a description and correlation to the Licensee's Justification andEvaluation (Attachment III) for each proposed change to the Radiation Emergency Plan).2.1 Activation of the Emergency Response Facilities The activation time requirement for ERFs is proposed to be changed to within 75 minutes withall facilities activating at an Alert classification or higher. The current activation requirement iswithin 60 minutes of the declaration of an Alert or higher for the TSC and OSC, and within 60minutes of the declaration of a Site Area Emergency or higher for the EOF.2.2 Relocation of the Technical Support CenterThe new TSC is proposed to be relocated in the basement of the NOB. This location issouthwest and outside of the Unit 1 Protected Area and is approximately 1900 ft from the Unit 1control room. The separation of the TSC from the control room (CR) will be approximately 10 to15 minutes. This 10 to 15 minute timeframe is based on a person leaving the CR, processing through the Owner Controlled Area and the Protected Area Security Control Points, andentering the NOB to access the TSC. Document Control DeskAttachment ILAR-13-02396 RC-1 4-0039Page 2 of 10The new facility design and layout provides a larger facility with updated audio/visual equipment to establish and maintain command and control of on-site evaluations and mitigation strategydevelopment. Features of the new TSC include a dedicated emergency diesel generator, additional telephones, and computer resources. The TSC phone lines will be increased from 15to 46 and the number of networked personal computers will be increased from 13 to 32. Thisincrease will allow the ERO to access plant data, drawings, procedures, and other computerapplications. The TSC is also designed to meet the protected envelope functional requirements for habitability and ventilation similar to the Control Room.2.3 Realignment of Emergency Response Organization The proposed changes to ERO positions, titles, and responsibilities are to support the new TSCand to align the ERO to support multi-unit emergencies once VCSNS Units 2 & 3 becomeoperational. 2.4 Transfer Offsite Notification Responsibilities Directly to the EOFThe notification responsibilities are proposed to transfer from the control room directly to theEOF. Since the EOF will be activated at an Alert or higher classification, the transfer of offsitecommunications directly from the control room to the EOF removes an interim step to transferfrom the control room to the TSC and then to the EOF.2.5 Relocate EOF Engineering to New Technical Support CenterEngineering Support functions are proposed to be relocated from the EOF to the TSC as part ofthe ERO realignment. As a result, all Engineering evaluation and mitigation functions will bedirected in one location. A limited engineering presence will be maintained within the EOF toprovide technical support to the EOF and offsite agencies. 2.6 Administrative ItemsSeveral Administrative changes are also necessary to support the proposed changes to theRadiation Emergency Plan. The changes include updates to figures, appendices, and annexes;inclusion of references to future Units 2 & 3; correction of reference items such as NationalResponse Framework, Federal Emergency Management Agency; and update regulatory crossreferences. These administrative changes are needed to support the proposed changes to theplan.3.0 BACKGROUND In 2011, the NRC amended 10 CFR 50.54(q) to require the use of the license amendment process in 10 CFR 50.90, "Application for Amendment of License, Construction Permit, or EarlySite Permit," when applying for prior NRC approval of those changes determined to be areduction in effectiveness. A staffing analysis was conducted in October of 2012 to comply with the new EP Rulemaking in2011. This analysis was incorporated by reference into the Radiation Emergency Plan asAppendix

7. Through this analysis, it was determined that during emergency conditions, theminimal on-shift staff could support an emergency response for 90 minutes until the EROaugmentation occurred and ERFs were staffed.

As a result of this determination and with the Document Control DeskAttachment ILAR-13-02396 RC-14-0039 Page 3 of 10activation of the TSC, OSC, and EOF at an Alert, the activation times are being proposed tochange to within 75 minutes from the time of declaration of an Alert or higher classification. Thischange also aligns the Unit 1 emergency plan to the Units 2 & 3 Combined Operating LicenseApplication (COLA) Emergency Plan which was approved by the NRC in the Final SafetyEvaluation Report (FSER) (ML1 10450305, ML1 10310185, and ML1 11320113). VCSNS began evaluating locations for a new central onsite command and control facility whenthe V.C. Summer Nuclear Station Units 2 and 3 COLA, was submitted. Given the proximity toall 3 units, the new NOB was selected for the TSC. Unit 1 initiated the TSC design andconstruction process with the intent to include Units 2 and 3 emergency response personnel once the units become operational. This change is the first step in the process to implement thenew TSC for Unit 1. The VCSNS Units 2 & 3 COLA Emergency Plan includes the use of thenew TSC and was approved by the FSER (ML1 10450305, ML1 10310185, and ML1 11320113) issued by the NRC. Other proposed emergency plan changes improve efficiency and logistics, and align the ERO structure to that approved in the FSER for Units 2 & 3 to support theeventual multi-unit emergency response. 4.0 TECHNICAL ANALYSIS4.1 Activation of the Emergency Response Facilities The activation time requirement for ERFs is proposed to be changed to within 75 minutes withall facilities activating at an Alert classification or higher. The current activation time in theVCSNS Emergency Plan is within 60 minutes of the declaration of an Alert or higher for the TSCand OSC and within 60 minutes of the declaration of a Site Area Emergency or higher for theEOF. This proposed increase in activation time to within 75 minutes of an Alert or higherdeclaration is a reduction in effectiveness from the current emergency plan requirements. TheEOF will be activated at the same time as the TSC. The proposed change is supported by thestaffing analysis that was completed to comply with EP Rulemaking. This analysis determined that during emergency conditions, the minimal on-shift staffing can provide emergency responsefor 90 minutes or until the ERO augmentation occurs.NUREG-0654 Criterion II.A. 4 states that "Each principal organization shall be capable ofcontinuous (24-hr) operations for a protracted period..."; Criterion 11.B.3 states that "eachlicensee shall identify a line of succession for the emergency coordinator position and identifythe specific conditions for higher level utility officials assuming this function." and Criterion 1l.B.5"The licensee must be able to augment on-shift capabilities within a short period afterdeclaration of an emergency...". The term short period is recognized in NUREG-0654 table B-1as 30 and 60 minutes.The on-shift staffing analysis demonstrated that all emergency functions can and will beassigned to and performed by on-shift personnel, until augmented by the ERO. Upondeclaration of an Alert or higher classification, the on-shift staffing is to support the control roompersonnel. This staffing fulfills the NUREG-0654 Criterion ll.B.5 for 30-minute responders andprovides additional support to the on-shift ERO to facilitate the proposed within 75 minuteresponse for on-call ERO personnel. It is VCSNS's intent to expend its best efforts to meet theaugmentation criteria regarding staffing ERF with sufficiently skilled individuals capable of Document Control DeskAttachment ILAR-1 3-02396RC-14-0039 Page 4 of 10responding to an emergency. VCSNS realizes that due to diversity of normal residential patterns for the stations' staff, possible adverse weather conditions and road congestion, thesetime frames may not always be obtainable. Advances in technologies such as computers, plantdata display systems, and the augmentation of the EOF at an Alert or higher classification willallow for a more timely response to emergencies. The new TSC enhances response time sinceit is outside the protected area.All functions of the EOF, TSC, and OSC will be maintained and will continue to meet theguidelines of NUREG-0654, 10 CFR 50.47(b), and 10 CFR 50 Appendix E. The emergency plan will continue to provide requirements for the assignment of responsibilities andaugmentation of the ERO to support the on-shift personnel on a continuous emergency response basis. The emergency plan requirements are supported by the performance andinclusion of the On-Shift Staffing Analysis. The analysis ensures emergency actions andresponsibilities can be supported until the augmented ERO arrives and activates the Emergency Response Facilities. The proposed within 75 minutes response time will align the VCSNS Unit 1 Radiation Emergency Plan with the Units 2 & 3 Emergency Plan approved in the FSER (ML1 10450305, ML110310185, and ML111320113) issued by the NRC.4.2 Relocation of the Technical Support CenterThe proposed change to relocate the TSC is a reduction in effectiveness from the currentemergency plan requirements. Table 1 provides a direct comparison between the capabilities ofthe current TSC facility and proposed new facility. Table 1 TSC Resource Comparison Resource Current Facility Proposed FacilityTSC -32 VCS, 12 NRC with Back-ERO Positions Assigned TSC -13 VCS, 6 NRC up OSC --15 VCSSquare Footage (total) -2,500 -14,300Facilities shared with Control Full men's and women's facilities Rest Rooms Room for men and women with showersKitchenette shared with Break Area with tables and servingBreak/Serving Area Control Room area, ice, water, refrigerator, etc.Work Stations (total) 13 44Telephones (PBX) 13 44Telephones (Satellite) 1 1Telephone (Dedicated Lines) 1 110 desk top for dedicated positions Radios Hand-held only and hand-held Computers/Data Connections 13 32 with 9 in Back-up OSC5 with additional 15 AN displayProjectors (A/V System) 2 capabilities in adjacent work areas Document Control DeskAttachment ILAR-13-02396 RC-14-0039 Page 5 of 10Resource Current Facility Proposed Facility-880 sq ft with 9 work stations andBack-up OSC None command table390 sq ft with 4 work stations andNRC Area 8 x 8 cubicle conference tableThe new TSC will continue to meet the intent and guidelines of NUREG-0696, "Functional Criteria for Emergency Response Facilities" and NUREG-0737 "Clarification of TMI Action PlanRequirements" with the exception of the TSC location. The new TSC will be located within thebasement of the NOB. This location is outside of and southwest of the Unit 1 Protected Areaand is approximately 1900 feet from the Unit 1 control room. The distance between the CR andthe TSC is about a 10 to 15 minute walk. This 10 to 15 minute timeframe is based on a personleaving the CR, processing through Owner Controlled Area and Protected Area Security ControlPoints, and entering the NOB to access the TSC. The proposed TSC location does not lenditself to face-to-face communications with the Unit 1 control room as recommended by NUREG-0696, section 2.2. The location of the TSC is an alternative method to NUREG-0696 requiring the TSC to be within two minutes of the control room and that there be no major securitybarriers between the two facilities. While the proposed location of the new TSC does not allow for direct face-to-face communications between the Shift Supervisor in the CR and the Emergency Director in theTSC, adequate communications lines and designated positions will ensure continued andeffective communication. The site currently demonstrates the effectiveness of thecommunications lines and designated positions as a substitute for face-to-face communications during emergency plan drills with the VCSNS Simulator CR and the current TSC. Therefore, relocation of the TSC to the new NOB will not prevent VCS from meeting the intent of theguidance in NUREG-0696. The new location also provides for improved off-hours staffing capabilities since responders willnot have to process through Owner Controlled or Protected Area Security access locations toreach the TSC. The relocation of the TSC will make activation timelier and improve thecapability for transfer of critical tasks from the Control Room. The relocation of the TSC allowsactivation of and access to the TSC during a security event more practical and timely by notrelocating personnel into an area where the hostile action may be directed. The location of theTSC will also provide managerial and technical support to plant operations personnel via thecommunication links during emergency conditions without congesting the control room. Thenew TSC will also have access to the plant computer and Safety Parameter Display System(SPDS) displays. There is not an anticipated need to traverse from the TSC to the CR therefore the Protected Area security barrier will not create any adverse impact on the function of the newTSC being located outside of the Protected Area. Should the need arise, security personnel areassigned in the TSC to enhance the movement of personnel between the TSC and the controlroom.The working space is considerably larger than the existing facility and will reduce currentcrowded working conditions (reference Table 1). This change will strengthen the TSCcommand and control function by allowing the TSC ERO a larger, better-designed working area. Document Control DeskAttachment ILAR-13-02396 RC-14-0039 Page 6 of 10The TSC is sized to accommodate a minimum of 40 personnel and their supporting equipment. This includes provisions for at least three NRC representatives. The larger work area facilitates additional state of the art equipment for TSC personnel to perform their ERO functions. Thenew facility will strengthen the ERO by creating a centralized onsite command and controlorganization and a single evaluation and mitigation decision structure for the entire site.The TSC was constructed to meet the 2006 International Building Code. The superstructure ofthe facility was designed for IBC site class D, design category C, Business occupancy categoryI1. The TSC and NOB structure are fully equipped with sprinklers and constructed with non-combustible construction. The basement ceiling systems, mechanical

ductwork, plumbing, piping, sprinkler piping, and electrical systems are seismically braced throughout the TSC.Access to the TSC will be controlled through two direct points of ingress/egress, on the northand south ends of the basement (central and south portions of the NOB, respectively).

Thesepoints do not open directly to the exterior of the building, but are accessed through stairways orelevators from the upper floors. Control of personnel entering will be done using access cardreaders connected to site security access control computers. The TSC was designed to meet the protected envelope functional requirements for habitability and ventilation similar to the Control Room as identified in NUREG-0696 and Section II.B.2 ofNUREG-0737. The HVAC system is designed with High Efficiency Particulate Air filters andcharcoal filters with a mixed air capability from both inside the facility and exterior. The systemwhen placed in emergency mode, via a designated button in the TSC command area, closesspecified motorized

dampers, disables EF-1 (rest rooms exhaust fan), and energizes FFU-1(filtered HVAC). Once this takes place, the TSC pressurizes to a minimum of 0.125 inwc. Analarm panel is located within the command area of the TSC that will alert personnel of a changein pressurization which causes the positive pressure to fall below 0.125 inwc.Although these changes are reductions in effectiveness, the changes will continue to meet therequirements of 10 CFR 50.47(b) and 10 CFR 50 Appendix E. The TSC will continue tomaintain adequate facilities and equipment.

The new TSC will ensure the station's emergency response will protect the public health and safety while monitoring, evaluating, and developing mitigation strategies in response to the emergency conditions. The function,

location, staffing requirements, size, equipment, building structure, andenvironmental controls for the new TSC, have been previously reviewed and approved in theFSER for the VCSNS Units 2 & 3 Emergency Plan (ML110450305, ML110310185, andML1 11320113).

4.3 Realignment of Emergency Response Organization VCSNS will operate three nuclear units, once construction of Units 2 & 3 is complete. Thereorganization of the ERO structure will support the future multi-unit site. This reorganization will result in a reduction in effectiveness from the current emergency plan requirements, butmeets the intent and requirements of 10 CFR 50 Appendix E. The organization change alignsUnit 1 ERO and ERO organizational structures to those that have been previously reviewed andapproved in the FSER for the VCSNS Units 2 & 3 Emergency Plan (ML1 10450305, ML110310185, and ML111320113). Document Control DeskAttachment ILAR-1 3-02396RC-14-0039 Page 7 of 10Reductions in effectiveness are caused by the addition and deletion of Emergency ResponseOrganization positions and realignment of responsibilities, both assigned to the individual positions and within the emergency response facilities. The cumulative effect of these changesto the emergency plan contributes to the reduction in effectiveness. These changes willcontinue to meet the requirements of 10 CFR 50.47(b) and 10 CFR 50 Appendix E. Thechanges will continue to ensure the responsibilities of emergency response are assigned andthe response organization has adequate staff to augment the on-shift staff on a continuous emergency response basis. The overall size of the ERO may change with some positions beingadded and some being deleted, but the functions and responsibilities of the ERO will not. Thechanges will allow a modified command and control structure to support a multi-unit site. Therewill also be additional designated expertise for each of the three units. Functions andresponsibilities are being rearranged to support the overall changes to the plan. The ERO willcontinue to be able to provide the evaluation, mitigation, offsite support, and public alert andwarning for each emergency and for any of the four emergency classifications. A table of the responsibility changes for each ERO position is provided in Enclosure B, E-planERO Position Responsibility Change & Comparison of Attachment Ill, VCSNS EP-100 (TSC &ERO) LAR Change Justification/Evaluation. 4.4 Transfer Offsite Notification Responsibilities Directly to the EOFThe initial emergency notification(s) will be completed by the control room and thenresponsibility for subsequent classifications transferred to the ERO in the EOF once the EOF isactivated. This change is a reduction in effectiveness from the current emergency planrequirements. The activation of the EOF at an Alert or higher classification allows the transfer ofthe responsibilities to be completed in a more timely and effective method. The EOF is thefacility responsible for interfacing with offsite emergency management agencies and is the mosteffective location to make the notifications and Protective Action Recommendations. The proposed change removes the requirement to transfer the classification and notification functions from the control room to the TSC and then from the TSC to the EOF. This will makethe transfer a one-time evolution and make the subsequent notifications more efficient since asecond turnover is not required. The removal of responsibilities from the TSC allows theEmergency Director and the TSC to focus their attention on evaluation and mitigation of theemergency conditions within the plant. Turnover and coordination used to transfer thecommunications from the control room to the TSC and eventually to the EOF will be used totransfer it directly to the EOF.The reduction in effectiveness is caused by the removal of notification functions from the TSCand the deletion of communication positions in the TSC. However, the changes will continue tomeet the requirements of 10 CFR 50.47(b) and 10 CFR 50 Appendix E. The changes willcontinue to provide the means and capabilities to notify state, local, federal, and other offsiteresponse agencies in the event of an emergency at an ALERT or higher emergency classification. With the activation of the EOF at an ALERT, the EOF will provide the samefunctions as if they were received from the TSC. The EOF will continue to provide an offsitefocus of responsibilities to ensure public health and safety is protected. Document Control DeskAttachment ILAR-1 3-02396RC-1 4-0039Page 8 of 10The change will not add additional responsibilities to the EOF or the ERO that are not currently being performed as part of an emergency response. 4.5 Relocate EOF Engineerinq Functions to the New Technical Support CenterEmergency response engineering assessment and mitigation functions are being relocated fromthe EOF to the TSC. Relocating the engineering functions to the TSC is a reduction ineffectiveness from the current emergency plan requirements. This change will place alltechnical engineering resources in one emergency facility and under one engineering decisionmaker to focus on the onsite emergency. The removal of engineering responsibilities from the EOF will allow the EOF to focus onmeasures that protect the public health and safety, and to obtain additional resources fromoffsite vendors or agencies to support the emergency. The EOF ERO will maintain an individual with engineering expertise to advise EOF personnel on plant engineering matters. Engineering personnel will report to the TSC Technical Support Manager, who will allocate engineering resources to address priorities established by the TSC. Having all engineering expertise in onelocation improves efficiency by eliminating the need for coordination and communications between the engineering groups.The changes will continue to meet the requirements of 10 CFR 50.47(b) and 10 CFR 50Appendix E. The changes will continue to ensure the responsibilities for emergency responseare assigned and that adequate facilities and equipment are available. This change also addsadditional expertise to support each unit. The changes do alter the methods, equipment, andpersonnel for evaluating and controlling a radiological release; for evaluation of system,structure, or component failures; and for plans with recovery and reentry.

However, thesefunctions will remain in place within the Emergency Response Organization and as arequirement in the emergency plan.4.6 Administrative ItemsSeveral Administrative changes are also necessary to support the proposed changes to theRadiation Emergency Plan. The changes include updates to figures, appendices, and annexes;inclusion of references to future Units 2 & 3, correction of reference items such as NationalResponse Framework and Federal Emergency Management Agency; and update regulatory cross references.

These administrative changes support the other changes to the plan andreduce the effectiveness of the plan.5.0 REGULATORY ANALYSIS5.1 Applicable Regulatory Requirements / Criteria10 CFR 50.47(b) and 10 CFR 50 Appendix E establish emergency planning standards thatrequire 1) adequate staffing;

2) satisfactory performance of key functional areas and criticaltasks; and 3) timely augmentation of the response capability.

The proposed changes have beenevaluated to determine whether applicable regulations and requirements continue to be met.The proposed changes have also been evaluated in accordance with 10 CFR 50.54(q) andresult in a reduction in the effectiveness of the emergency plan and therefore, prior NRC Document Control DeskAttachment ILAR-1 3-02396RC-14-0039 Page 9 of 10approval is required. The proposed changes to the plan, will continue to meet the requirements of 10 CFR 50 Appendix E and the planning standards of 10 CFR 50.47(b). 5.2 No Si-gnificant Hazards Consideration VCSNS has evaluated whether or not a significant hazards consideration is involved with theproposed changes by focusing on the three standards set forth in 10 CFR 50.92, "Issuance ofamendment," as discussed below:1. Does the proposed amendment involve a significant increase in the probability orconsequences of an accident previously evaluated? Response: No. The proposed changes to the VCSNS emergency plan do not impact thephysical function of plant structures,

systems, or components (SSC) or the manner in whichSSCs perform their design function.

The proposed changes neither adversely affect accidentinitiators or precursors, nor alter design assumptions. The proposed changes do not alter orprevent the ability of SSCs to perform their intended function to mitigate the consequences of aninitiating event within assumed acceptance limits. No operating procedures or administrative controls that function to prevent or mitigate accidents are affected by the proposed changes.Therefore, the proposed changes do not involve a significant increase in the probability orconsequences of an accident previously evaluated.

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

Response: No. The proposed changes do not involve a physical alteration of the plant (i.e., nonew or different type of equipment will be installed or removed) or a change in the method ofplant operation. The proposed changes will not introduce failure modes that could result in anew accident, and the change does not alter assumptions made in the safety analysis. Theproposed changes to the location of the TSC, activation times of facilities, and aligning EROstructure are not initiators of any accidents. Therefore, the proposed change does not create thepossibility of a new or different kind of accident from any accident previously evaluated.

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

No. Margin of safety is associated with the ability of the fission product barriers (i.e.,fuel cladding, reactor coolant system pressure

boundary, and containment structure) to limit thelevel of radiation dose to the public. The proposed changes do not impact operation of the plantor its response to transients or accidents.

The changes do not affect the Technical Specifications or the operating license. The proposed changes do not involve a change in themethod of plant operation, and no accident analyses will be affected by the proposed changes.Additionally, the proposed changes will not relax any criteria used to establish safety limits andwill not relax any safety system settings. The safety analysis acceptance criteria are not affectedby these changes. The proposed changes will not result in plant operation in a configuration outside the design basis. The proposed changes do not adversely affect systems that respondto safely shut down the plant and to maintain the plant in a safe shutdown condition. The Document Control DeskAttachment ILAR-13-02396 RC-14-0039 Page 10 of 10emergency plan will continue to activate an emergency response commensurate with the extentof degradation of plant safety.Based on the above, SCE&G concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and accordingly, afinding of "no significant hazards consideration" is justified. 6.0 ENVIRONMENTAL CONSIDERATIONS The proposed changes to the Radiation Emergency Plan maintain the environmental bounds ofthe current environmental assessment associated with the VCSNS Unit 1. The proposedchanges will not affect plant safety and will not have an adverse effect on the probability of anaccident occurring. The proposed change does not involve (i) a significant hazardsconsideration, (ii) a significant change in the types or significant increase in the amounts of anyeffluent that may be released

offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

The construction of the NOB is now complete. The NOB was designed in accordance withState and local Uniform Building Codes. Therefore, proposed changes do not result in changesto land use or water use, or result in changes to the quality of quantity of non-radiological effluents. No changes to the National Pollution Discharge Elimination System permit areneeded. The addition of a diesel generator was reviewed to ensure compliance with the Stateof South Carolina's air regulations and was determined to have no impacts on the air or ambientair quality. There are no impacts to historical and cultural resources. Therefore, no changes toor different types of non-radiological environmental impacts are expected as a result of thesechanges.In conclusion, the proposed changes to the Radiation Emergency Plan will not have an adverseimpact on the environment.

7.0 PRECEDENCE

This request is similar in nature to the other requests authorized by the NRC for Clinton PowerStation [ML061920575, ML063530752, and ML070540270] and Three Mile Island NuclearStation, Unit 1 [ML023460148].

However, the amended rule in 2011 changed the language tospecify that licensees must use the license amendment process in 10 CFR 50.90 for changesevaluated as a potential reduction in effectiveness.

The function,

location, staffing requirements, size, equipment, building structure, and environmental controls for the new TSC, have beenpreviously reviewed and approved in the FSER for VCSNS Units 2 & 3 Emergency Plan(ML110450305, ML110310185, and ML111320113).

Document Control DeskAttachment IILAR-13-02396 RC-14-0039 Page 1 of 4VIRGIL C. SUMMER NUCLEAR STATION (VCSNS) Unit 1DOCKET NO. 50-395OPERATING LICENSE NO. NPF-12ATTACHMENT IICross Reference of Radiation Emergency Plan Changes to Attachment I Section 2.0Cross Reference of Radiation Emergency Plan Changes to Attachment I Section 2.0LAR Item Number Change SummarySection Attachment III2.1 4 Part 2 Section B. 1 -Changed activation of the ERO to reflect the fullERO activation at an Alert, Site Area Emergency, or GeneralEmergency (Alert or higher classification) 2.1 9 Part 2 Section B.5.a -Changed the augmentation time of the EROfrom "within about 60 minutes" to "within 75 minutes"2.1 39 Part 2 Section D.1.b -Changed activation of the ERO to reflect thefull ERO activation at an Alert2.1 40 Part 2 Section D.1.c -Changed activation of the ERO to reflect thefull ERO activation at a Site Area Emergency 2.1 42 Part 2 Section E.2.a -Changed activation of the ERO to reflect thefull ERO activation at an Alert, Site Area Emergency, or GeneralEmergency (Alert or higher classification) and removed reference toactivating the JIC2.1 46 Part 2 Section H.1 .c -Added the OSC guidance to include references to the new Back-up OSC in the new TSC and the Remote OSC in theEOF Building (formally the Back-up), changed reference to the JICBuilding to the EOF Building, added guidance to support a multi-unit ERO, and added guidance on the back-up and remote OSC2.1 47 Part 2 Section H.5 -Changed the augmentation time of the ERO from60 minutes to 75 minutes and changed activation of the ERO to reflectthe full ERO activation at an Alert, Site Area Emergency, or GeneralEmergency (Alert or higher classification) 2.1 50 Part 2 Section 1.8 -Changed activation of the ERO to reflect theactivation of Field Teams at an Alert or higher classification 2.1 54 Annex 1 Section 4.1.B -Changed the augmentation time of the EROfrom "within about 60 minutes" to "within 75 minutes"2.2 45 Part 2 Section H. 1.b -Added guidance and references for therelocation of the TSC into the basement of the Nuclear Operations

Building, noted the addition of the Security Manager to the TSC,updated the accommodations, back-up facilities, and remote facilities, added guidance to support a multi-unit ERO, and added guidance onthe back-up and remote OSC and TSC Document Control DeskAttachment IILAR-13-02396 RC-14-0039 Page 2 of 42.2 53 Old Annex 1 Section 4.1.B -Removed references to the Technical Support Center2.2 46 Part 2 Section H. .c -Added the OSC guidance to include references to the new Back-up OSC in the new TSC and the Remote OSC in theEOF Building (formally the Back-up),

changed reference to the JICBuilding to the EOF Building, added guidance to support a multi-unit ERO, and added guidance on the back-up and remote OSC2.3 2 Part 2 Section A.4 -Added guidance that personnel in unaffected unit(s) may be used to assist with emergencies in other units2.3 6 Part 2 Section B.2 -Added guidance on multi-unit event commandand control2.3 10 Part 2 Section B.5.a.2 -Added the ERO position for Emergency Support Operator and the location and responsibilities for this positionand guidance for the multi-unit ERO2.3 11 Part 2 Section B.5.a.3 -Added guidance for the multi-unit ERO2.3 12 Part 2 Section B.5.a.4 -Added guidance for Technical SupportSupervisors to include personnel from each Protected Area/Technology (multi-unit) 2.3 13 Part 2 Section B.5.a.5 -Added ERO position for Technical SupportCommunicator and the location and responsibilities for this positionand guidance for the multi-unit ERO2.3 14 Part 2 Section B.5.a.6 -Added guidance for Operations Supervisor toinclude personnel from each Protected Area/Technology (multi-unit) 2.3 15 Old Part 2 Section B.5.a.8 -Deleted the State/County Communicator and its responsibilities from the TSC2.3 16 Part 2 Section B.5.a.8 -Added the Emergency Notification System(ENS) Communicator position to the Control Room2.3 18 Part 2 Section B.5.a. 10 -Transferred the duties of the ERO positionfor Security Supervisor (OSC) to the TSC and changed the titles toSecurity Manager and the location and responsibilities for this position2.3 19 Part 2 Section B.5.a.11 -Added reference to the ERO position forChemistry Supervisor and the location and responsibilities for thisposition2.3 20 Part 2 Section B.5.a. 12 -Added reference to the ERO position forMaintenance Supervisor and the location and responsibilities for thisposition2.3 21 Part 2 Section B.5.a. 13- Added guidance for Operational SupportCenter Supervisors to include personnel from each Protected Area/Technology (multi-unit) 2.3 22 Part 2 Section B.5.a.14 -Added guidance for Operational SupportCenter Damage Control Teams to include personnel from eachProtected Area/Technology (multi-unit) 2.3 23 Old Part 2 Section B.5.a. 11 -Transferred the responsibilities of theSecurity Supervisor (OSC) to the TSC and changed the title toSecurity Manager2.3 24 Part 2 Section B.5.b. -Changed activation of the ERO to reflect thefull ERO activation at an Alert, Site Area Emergency, or General Document Control DeskAttachment IILAR-13-02396 RC-14-0039 Page 3 of 4Emergency (Alert or higher classification) and added the discretion toactivate at an Unusual Event2.3 28 Old Part 2 Section B.5.b.8 -Deleted the General Services Coordinator and its responsibilities from the EOF2.3 29 Part 2 Section B.5.b.8 -Revised the title and responsibilities of thePlant Security Advisor (formally Security Coordinator) 2.3 30 Part 2 Section B.5.b.9 -Added reference to the ERO position forHealth Physics Network (HPN) Communicator and the location andresponsibilities for this position2.3 31 Part 2 Section B.5.b.10 -Added the description of the ERO positionfor Field Teams and the location and responsibilities for this position tothe body of the plan2.3 32 Part 2 Section B.5.b. 11 -Added the description of the ERO positionfor Plant Operations Advisor and the location and responsibilities forthis position to the body of the plan2.3 34 Part 2 Figure B-1 b -Updated the organization chart to reflect changesto ERO positions in the plan2.3 35 Part 2 Figure B-Ic -Updated the organization chart to reflect changesto ERO positions in the plan2.3 36 Part 2 Figure B-id -Updated the organization chart to reflect changesto ERO positions in the plan2.3 37 Part 2 Table B-la -Updated the table to include changes affecting ERO positions, augmentation times, and responsibilities 2.3 38 Part 2 Section D. l.a -Added guidance for a multi-unit ERO2.3 41 Part 2 Section D.2 -Added guidance on the Units 2 & 3 EALs2.3 44 Part 2 Section H.1 & l.a -Added guidance to support a multi-unit ERO2.3 49 Part 2 Section H.12 -Revised provisions for KI in the Control Room2.3 51 Part 2 Section J.4.d -Added the lED and ED with the OEM2.3 56 Annex 2 & 3 -Added Unit specific guidance for VCSNS Units 2 & 32.4 7 Part 2 Section B.2 -Transferred responsibilities for notifications directly to the EOF from the Control Room2.4 8 Part 2 Section B.4 -Changed the ED responsibilities to remove theresponsibilities to make notifications and Protective ActionRecommendations 2.4 15 Old Part 2 Section B.5.a.8 -Deleted the State/County Communicator and its responsibilities from the TSC2.4 25 Part 2 Section B.5.b.2 -Changed the responsibility for preparing notification forms to approving 2.4 27 Part 2 Section B.5.b.6 -Added the ERO position for Communications Coordinator and the location and responsibilities for this position to theEOF2.5 10 Part 2 Section B.5.a.2 -Added the ERO position for Emergency Support Operator and the location and responsibilities for this positionand guidance for the multi-unit ERO2.5 13 Part 2 Section B.5.a.5 -Added ERO position for Technical SupportCommunicator and the location and responsibilities for this position Document Control DeskAttachment IILAR-13-02396 RC-14-0039 Page 4 of 4and guidance for the multi-unit ERO2.5 26 Part 2 Section B.5.b.3 -Revised the title and responsibilities of thePlant Engineering Advisor (formally Technical Support Coordinator) 2.5 33 Part 2 Section B.5.c.3 -Transferred the responsibilities of the LeadTechnical Briefer to the position of Plant Engineering Advisor2.6 1 All sections -Updated the grammatical references from a single unitto multi-unit nomenclatures (unit to units, annex to annexes, controlroom to control rooms, etc.)2.6 3 All sections -Added reference for "unaffected unit"/'affected unit"2.6 5 Part 2 Section B.1 -Relocated reference to the specific number ofAuxiliary Operators to the Annexes and added a generic reference 2.6 17 Part 2 Section B.5.a.9 -Added "(Reactor)" and grammatically corrected the title of the Technical Support Staff and added guidanceon a multi-unit ERO2.6 43 Part 2 Section F.1 Changed guidance to be more generic tosupport Units 1, 2, & 32.6 48 Part 2 Section H. 10 -Added guidance that additional supplies may beobtained from other units2.6 52 Part 2 Section N.3 -Added guidance for rotation of drills among Unitspecific facilities and personnel 2.6 55 Annex 1 Section 5.2 -Added guidance for an onsite assembly area Document Control DeskAttachment IIILAR-1 3-02396RC-14-0039 VIRGIL C. SUMMER NUCLEAR STATION (VCSNS) Unit IDOCKET NO. 50-395OPERATING LICENSE NO. NPF-12ATTACHMENT IIIVCSNS EP-100 (TSC & ERO) LAR Change Justification/Evaluation Document Control DeskAttachment IIILAR-13-02396 RC-14-0039 Page 1 of 61VCS EP-100 (TSC & ERO) LAR Change Justification/Evaluation TITLE: EP-100, Radiation Emergency Plan, Rev xx NRC Submittal (TSC & ERO) IDATE: 1/24/2014 DESCRIPTION OF PROPOSED CHANGE:The Emergency Plan is being revised to:* incorporate the new Technical Support Center (TSC)* to revise the activation requirements and times for the Emergency Response Organization andFacilities

• to reorganize the ERO structure to support the new TSC, responsibilities, and assignments

" to add the guidance for multi-units. A 10 CFR 50.54(q) evaluation was performed and recorded by VCS under VCS #: E2012-013 Revision 2.DESCRIPTION AND REVIEW OF LICENSING BASIS AFFECTED BY THE PROPOSED CHANGE:NUREG-0717, SER related to V. C. Summer Nuclear Station Unit 1, Supplements 2 and 3 require and stateVCS has a radiological emergency response plan that includes elements of NUREG-0654, Revision 1 (1979criteria), NUREG-0696, 10 CFR 50.47, and 10 CFR 50 Appendix E and will provide adequate planning basisfor an acceptable state of emergency preparedness and meets these requirements. EP-100 Revision 5 isthe revision in which the latest Safety Evaluation Report (SER) was issued in August 1982. Since thisrevision numerous other revisions have been made under the 10 CFR 50.54(q) process. This revisionmaintains the intent, purpose, and function of the emergency plan as evaluated up to the current Revision63.DESCRIBE HOW THE PROPOSED CHANGE COMPLIES WITH RELEVANT EMERGENCY PREPAREDNESS REGULATION(S) AND PREVIOUS COMMITMENT(S) MADE TO THE NRC:NUREG-0654, 10 CFR 50.47, and 10 CFR 50 Appendix E provide regulatory guidance and requirements fora radiological emergency plan content. One commitment for maintaining a core thermal (reactor) engineer isalso referenced in the plan and will not be affected by this change. This revision does affect how theregulatory or commitment requirements will be met. Changes affecting the requirements of 10 CFR 50.47and 10 CFR 50 Appendix E are evaluated in this evaluation. This revision also changes the means andmethods in which NUREG-0696 requirements will be met due to building a new TSC and relocating thefacility and reassigning ERO personnel and ERO functions. The revision also affects the Security andEmergency Plan interfaces in accordance with 10 CFR 73.58, which was evaluated under site procedure SAP-0163 by site Security personnel and there is no adverse impact on the Security Plan or interface. DESCRIPTION OF IMPACT OF THE PROPOSED CHANGE ON THE EFFECTIVENESS OF EMERGENCY PLAN FUNCTIONS: Enclosure A of this evaluation provides the detailed evaluation of these elements and the revisions affecting them. In many cases, as evaluated in the Enclosure, individual changes may not reduce the effectiveness ofthe emergency plan. However, when combined together and with the change in activation times, EROassignments, and relocation of the TSC, these changes do reduce the effectiveness of the emergency planand require prior approval by the NRC.EVALUATION CONCLUSION: Answer the following questions about the proposed change.1. Does the proposed change comply with the requirements of 10 CFR 50.47(b) and 10 [ YES E NOCFR 50 Appendix E?2. Does the proposed change maintain the effectiveness of the emergency plan (i.e., no E YES 0 NOreduction in effectiveness)? Document Control DeskAttachment IIILAR-13-02396 RC-14-0039 Page 2 of 61Enclosure A -Planning

Standard, Function, and Program Element Evaluation Item Change Summary Affected EP-100 Planning Standard/

Change Justification/Evaluation Rev 63 Section(s) Function/ Element(s)

1. All sections

-updated the Throughout n/a Justification: The grammatical references are administrative grammatical references from supporting the details of this revision and do not affect the plan or itsa single unit to multi-unit requirements. nomenclatures (unit to units,annex to annexes, control Evaluation: As individual

changes, the changes may not reduce theroom to control rooms, etc.) effectiveness of the emergency plan. However, when combinedtogether and with the change in activation times, ERO assignments, and relocation of the TSC, these changes reduce the effectiveness of the emergency plan and require prior approval by the NRC. Thechanges continue to meet the requirements of 10 CFR 50.47(b) and10 CFR 50 Appendix E. See the Technical Evaluation Section 4.6 ofthe LAR ATTACHMENT I.2. Added guidance that Part 2 Section A.4 10 CFR 50.47(b)(1)

Justification: VCS Units 1,2, and 3 are physically located on thepersonnel in unaffected same property site. Each plant has designated minimum staffing, unit(s) may be used to assist including Operations, Health Physics, Chemistry, Mechanical with emergencies in other Maintenance, Electrical Maintenance, and I&C Maintenance units personnel. The personnel from these disciplines on the unaffected unit(s) will be used to augment the affected unit(s) staffing toperform actions they are trained and qualified to perform, such asradiological accident assessment, repair and corrective actions,search and rescue, chemistry/radiochemistry, etc. This staffingaugmentation will fulfill the NUREG-0654 Criterion Il.B.5 for 30-minute responders and provides additional support to the on-shiftERO to permit a 75-minute response for on-call ERO personnel. The time frames for rapid augmentation of nuclear power plant staffin the event of an emergency are not rigid guidance requirements but rather times set by VCSNS. It is VCS's intent to expend its bestefforts to meet the augmentation criteria regarding staffingEmergency Response Facilities with sufficiently skilled individuals capable of handling an emergency. While Unit 3 is under Document Control DeskAttachment IIILAR-13-02396 RC-14-0039 Page 3 of 61Item Change Summary Affected EP-100 Planning Standard/ Change Justification/Evaluation Rev 63 Section(s) Function/ Element(s) construction, Units 1 and 2 will maintain the capability to augmentaffected unit shift personnel. VCS will operate three nuclear units, once construction of Units 2 &3 are completed. Each Unit will have its own Operational SupportCenter (OSC) with full staffing to support an emergency within itsunit. The use of personnel between units from unaffected units willprovide additional resources trained and qualified for immediate response. During an emergency each OSC will maintain itsminimum staffing requirements. Evaluation: The use of unaffected unit personnel for responses inother affected units, by itself does not reduce the effectiveness ofthe emergency plan. However, when combined with an emergency at a unit sharing its staff, response times and availability ofpersonnel may be delayed, thus reducing the overall effectiveness ofan emergency response to another unit. This is a reduction ineffectiveness and requires prior approval by the NRC. The changescontinue to meet the requirements of 10 CFR 50.47(b) and 10 CFR50 Appendix E. See the Technical Evaluation Section 4.3 of theLAR ATTACHMENT I.3. Added reference for Throughout 10 CFR 50.47(b)(1) Justification: The words affected and unaffected refer to VCS"unaffected unit/ "affected Units either in or not in an emergency condition, respectively. Sinceunit" these terms are used to determine which Control Room will be thelead during an emergency, the command and control responsibilities now differ. The change is an administrative identifier to separatewhich personnel or units may or may not be in an emergency requiring activation in accordance with the plan.Evaluation: Since the term affects the command and controlsstructure of the emergency plan, it does reduce the effectiveness ofthe initial response to an emergency and requires prior approval by Document Control DeskAttachment IIILAR-13-02396 RC-14-0039 Page 4 of 61Item Change Summary Affected EP-100 Planning Standard/ Change Justification/Evaluation Rev 63 Section(s) Function/ Element(s) the NRC. The changes continue to meet the requirements of 10CFR 50.47(b) and 10 CFR 50 Appendix E. See the Technical Evaluation Section 4.6 of the LAR ATTACHMENT I.4.Changed activation of theERO to reflect the full EROactivation at an Alert, SiteArea Emergency, or GeneralEmergency (Alert or higherclassification) Part 2 Section B. 110 CFR 50.47(b)(1) 10 CFR 50.47(b)(2) 10 CFR 50.47(b)(6) 10 CFR 50.47(b)(8) Justification: Activation and Essential Staffing designations arebeing placed in the emergency plan to provide guidance onactivating emergency facilities in a timely manner to assume criticalfunctions from the Control Room. These designations in staffinggive facility managers a clear and concise staffing requirement foractivation and allow the facility to be activated without essential staffing and prior to briefing the entire facility. The designation foractivation and essential allow activations based on the ability toassume critical functions before all designated ERF personnel arriveat the facility. In addition, the requirements for when the EOF is tobe activated are also changing. The EOF, TSC, and OSC will be activated at an Alert or higherclassification. The EOF earlier activation is required to ensure otherchanges in staffing and responsibilities are implemented effectively and efficiently. The EOF will be aligned to be the overall responsible facility for SCE&G and SCANA corporate emergency responses. This will be done while coordinating offsite state and local agencycommunications, offsite radiological monitoring, procurement, andmedia and public interfaces. This facility will be directed by amember of the VCS senior management team and supported bySCANA corporate resources, as needed. Changes to the staffing ofthe EOF includes: position title changes, position reporting alignment, and facility responsibility changes. The ERO positions titles changes and responsibility changes are detailed in Enclosure B, Emergency Response Organization Position Responsibility Change & Comparison, of this document. The orcqanization aliqnment of the EOF personnel and Document Control DeskAttachment IIILAR-13-02396 RC-14-0039 Page 5 of 61Item Change Summary Affected EP-100 Planning Standard/ Change Justification/Evaluation Rev 63 Section(s) Function/ Element(s) responsibilities includes a single reporting structure for the entirefacility including the Joint Information Center (JIC) and the EOFproper. The EOF will have a facility manager that reports directly tothe (Emergency Control Officer (ECO)). The CompanySpokesperson for the JIC will also report to the ECO.The function of the EOF remains intact with exception of portions ofits engineering resources. The EOF engineering resources thatsupport mitigation evaluations and development will be relocated tothe TSC. Limited engineering resources will remain in the EOF tosupport offsite notifications, technical assistance for press releases, and to respond to technical questions from offsite agencies andorganizations. Relocation of the engineers to the TSC will placeneeded engineering resources in the same location and under thedirection of a single engineering decision maker, thus enhancing thecapability to respond to, evaluate, and mitigate an emergency. The existing communication functions will not change. However, theEOF will no longer assume state and county communications fromthe TSC, but will activate earlier (at an Alert) in the emergency andwill assume state and local communications directly from the ControlRoom. This function currently is transferred from the Control Roomto the TSC and then to the EOF. The transfer of communications directly from the Control Room to the EOF places thecommunication responsibilities in its final facility in a timelier mannerand improves efficiency by removing an intermediate transfer of theresponsibilities. This allows the EOF to establish communications immediately with the state and county agencies eliminating possibleconfusion for multiple transfers and places the offsite responsibility solely on the EOF.Functions of the EOF will be maintained as described withenhancements and will continue to meet the reauirement of_______ .1 ___________________________ L Document Control DeskAttachment IIILAR-13-02396 RC-14-0039 Page 6 of 61Item Change Summary Affected EP-100 Planning Standard/ Change Justification/Evaluation Rev 63 Section(s) Function/ Element(s) NUREG-0654, 10 CFR 50.47(b), and 10 CFR 50 Appendix E. Dueto advances in technologies such as computers, direct telephone links, plant data display systems, etc. and the augmentation of theemergency facilities at an Alert or higher classification; theseenhancements will allow timelier responses to emergencies and theability to protect public health and safety.Evaluation: As individual

changes, the changes in the activation requirements for the EOF and the change in organization andfunction may not reduce the effectiveness of the emergency plan.However, when combined together and with the change in activation times, ERO assignments, and relocation of the TSC, these changesreduce the effectiveness of the emergency plan and require priorapproval by the NRC. The changes continue to meet therequirements of 10 CFR 50.47(b) and 10 CFR 50 Appendix E. Seethe Technical Evaluation Section 4.1 of the LAR ATTACHMENT I.5. Relocated reference to the Part 2 Section B. 1 10 CFR 50.47(b)(1)

Justification: The specific number of Auxiliary Operators (AO) wasspecific number of Auxiliary increased to five after the staffing study for VCS Unit 1 wasOperators to the Annexes 10 CFR 50.47(b)(2) completed and the emergency plan revised per the regulation. Theand added a generic specific number of AOs in Part 2 Section B.1 is not generic to allreference Units, thus the reference must be general and the specific numberincluded in the applicable Unit Annexes. The Unit 1 Annex has thespecific number, five (5).Evaluation: As an individual change, the change may not reducethe effectiveness of the emergency plan. However, when combinedtogether and with the change in activation times, ERO assignments, and relocation of the TSC, these changes reduce the effectiveness of the emergency plan and require prior approval by the NRC. Thechanges continue to meet the requirements of 10 CFR 50.47(b) and10 CFR 50 Appendix E. See the Technical Evaluation Section 4.6 of Document Control DeskAttachment IIILAR-1 3-02396RC-14-0039 Page 7 of 61Item Change Summary Affected EP-100 Planning Standard/ Change Justification/Evaluation Rev 63 Section(s) Function/ Element(s) the LAR ATTACHMENT I.6. Added guidance on multi-unit Part 2 Section B.2 10 CFR 50.47(b)(1) Justification: The logistics of a multi-unit site adds aspects ofevent command and control command and control which were not previously used and trained or10 CFR 50.47(b)(2) drilled at VCS. The guidance added changes the command andcontrol structure for emergencies to ensure proper response by ERO10 CFR 50.47(b)(10) personnel. The addition is needed to clearly delineate the structure to support a multi-unit site.10 CFR 50.47(b)(14) Evaluation: Since the term affects the command and controlsstructure of the emergency plan, it does reduce the effectiveness ofthe response to an emergency and requires prior approval by theNRC. The changes continue to meet the requirements of 10 CFR50.47(b) and 10 CFR 50 Appendix E. See the Technical Evaluation Section 4.3 of the LAR ATTACHMENT I.7. Transferred responsibilities Part 2 Section B.2 10 CFR 50.47(b)(1) Justification: The notification of and development of PARs for anfor notifications directly to the emergency is critical to protecting public health and safety. This andEOF from the Control Room 10 CFR 50.47(b)(5) other emergency information is provided to offsite agencies for eachclassification made and for follow-up notifications. The initialemergency notification(s) will be completed by the Control Roomand then transferred to the augmented ERO in the EOF. Theactivation of the EOF at an Alert or higher classification allows thetransfer of the responsibilities to be completed in a more timely andeffective method. The EOF is the facility responsible for interfacing with offsite emergency management agencies and is the mosteffective location to make notifications. This change will remove the current requirement to transfer thisresponsibility from the Control Room to the TSC and then from theTSC to the EOF. The change will make the transfer a one-timeevolution. Subsequent notifications will be more efficient since asecond turnover is not required. This removes the responsibilities Document Control DeskAttachment IIILAR-13-02396 RC-14-0039 Page 8 of 61Item Change Summary Affected EP-100 Planning Standard/ Change Justification/Evaluation Rev 63 Section(s) Function/ Element(s) from the TSC and allows the Emergency Director to focus attention on evaluations and mitigations of the emergency conditions withinthe plant. Similar turnover and coordination used to transfer thecommunications from the Control Room to the TSC and eventually to the EOF will be used to transfer them directly to the EOF.The change will not add any responsibilities to the EOF or the EROthat are currently not performed as part of an emergency. Therevision does remove the responsibility from the TSC and deletescommunication positions in the TSC, allowing them to focus ononsite responses. Evaluation: As individual

changes, the changes in the transfer ofemergency communications and Protective ActionRecommendations may not reduce the effectiveness of theemergency plan. However, when combined together and with thechange in activation times, ERO titles, ERO assignments, andrelocation of the TSC, these changes reduce the effectiveness of theemergency plan. Notification of state and local governmental agencies within 15 minutes after declaration of an emergency andproviding follow-up notifications will continue to be made. This willensure systems are established for prompt communication amongprincipal emergency response organizations and systems areestablished for prompt communication to emergency responsepersonnel.

These changes require prior approval by the NRC. Thechanges continue to meet the requirements of 10 CFR 50.47(b) and10 CFR 50 Appendix E. See the Technical Evaluation Section 4.4 ofthe LAR ATTACHMENT I.8. Changed the ED Part 2 Section B.4 10 CFR 50.47(b)(1) Justification: The notification of and development of PARs for anresponsibilities to remove the emergency is critical to protecting public health and safety. This andresponsibilities to make 10 CFR 50.47(b)(5) other emergency information is provided to offsite agencies for eachnotifications and Protective classification made and for follow-up notifications. The initial Document Control DeskAttachment IIILAR-1 3-02396RC-14-0039 Page 9 of 61Item Change Summary Affected EP-100 Planning Standard/ Change Justification/Evaluation Rev 63 Section(s) Function/ Element(s) Action Recommendations 10 CFR 50.47(b)(9) emergency notification(s) will be completed by the Control Roomand then transferred to the augmented ERO in the EOF. Theactivation of the EOF at an Alert or higher classification allows thetransfer of the responsibilities to be completed in a more timely andeffective method. The EOF is the facility responsible for interfacing with offsite emergency management agencies and is the mosteffective location to make these notifications and PARs due to itsfocus being offsite emergency response and support.The change removes the guidance to transfer from the ControlRoom to the TSC and then from the TSC to the EOF. This will makethe transfer a one-time evolution and make the subsequent notifications more efficient since a second turnover is not required. This removes the responsibilities from the TSC and allows theEmergency Director to focus on evaluations and mitigations of theemergency conditions within the plant. Similar turnover andcoordination used to transfer the communications from the ControlRoom to the TSC and eventually to the EOF will be used to transferthem directly to the EOF.The change will not add any responsibilities to the EOF or the EROthat are currently not performed as part of an emergency. Therevision does remove the responsibility from the TSC, allowing TSCpersonnel to focus on onsite response. Evaluation: As individual

changes, the changes in the transfer ofemergency communications and Protective ActionRecommendations may not reduce the effectiveness of theemergency plan. However, when combined together and with thechange in activation times, ERO titles, ERO assignments, andrelocation of the TSC, these changes reduce the effectiveness of theemergency plan. Notification of state and local governmental agencies within 15 minutes after declaration of an emergency or_______ L ____________________________

J _______________________ .1 _______________________ Document Control DeskAttachment IIILAR-13-02396 RC-14-0039 Page 10 of 61Item Change Summary Affected EP-100 Planning Standard/ Change Justification/Evaluation Rev 63 Section(s) Function/ Element(s) PAR approval and providing follow-up notifications will continue tobe made. This will ensure systems are established for promptcommunication among principal emergency response organizations and systems are established for prompt communication toemergency response personnel. These changes require priorapproval by the NRC. The changes continue to meet therequirements of 10 CFR 50.47(b) and 10 CFR 50 Appendix E. Seethe Technical Evaluation Section 4.4 of the LAR ATTACHMENT I.9. Changed the augmentation Part 2 Section B.5.a 10 CFR 50.47(b)(1) The evaluation for the change in activation time is provided intime of the ERO from "within enclosure C of this attachment. about 60 minutes" to "within 10 CFR 50.47(b)(2) 75 minutes"10. Added the ERO position for Part 2 Section B.5.a.2 10 CFR 50.47(b)(1) Justification: The position of Emergency Support Operator is beingEmergency Support Operator added to the ERO to support Operations communications andand the location and 10 CFR 50.47(b)(2) transfer of information from the Control Room to the TSC or viceresponsibilities for this versa. This position is a dedicated phone talker between facilities. position and guidance for the 10 CFR 50.47(b)(10) multi-unit ERO The logistics of a multi-unit site adds aspects of command and10 CFR 50.47(b)(14) control which were not previously used and trained at VCS. Theguidance added changes the command and control structure foremergencies to ensure proper response by personnel. The additionis needed to clearly delineate the structure and reduce the overallpotential confusion for going to a multi-unit site.Evaluation: As an individual change the addition of the Operatordoes not reduce the effectiveness of the emergency plan. However,when combined together and with the change in activation times,relocation of the TSC, and the change to a multi-unit emergency response organization; these changes reduce the effectiveness ofthe emergency plan and require prior approval by the NRC. Thechanges continue to meet the requirements of 10 CFR 50.47(b) and Document Control DeskAttachment IllLAR-13-02396 RC-14-0039 Page 11 of 61Item Change Summary Affected EP-100 Planning Standard/ Change Justification/Evaluation Rev 63 Section(s) Function/ Element(s) 10 CFR 50 Appendix E. See the Technical Evaluation Section 4.3and 4.5 of the LAR ATTACHMENT I.11. Added guidance for the multi- Part 2 Section B.5.a.3 10 CFR 50.47(b)(1) Justification: The Emergency Director position will be responsible unit ERO for overall onsite emergency response for all three Units. Since the10 CFR 50.47(b)(2) classification of emergencies will be a site level classification and theEmergency Response Organization will include response personnel 10 CFR 50.47(b)(10) from each Protected Area (two technologies), overall decisionmaking, evaluation, and mitigation responsibilities will be added to10 CFR 50.47(b)(14) this position. Although the conduct of these responsibilities may bedone in the same manner currently trained and demonstrated indrills, the logistics of managing a multi-unit site during an emergency does change the overall management of command and control. Thelogistics of a multi-unit site adds aspects of command and controlwhich were not previously used and trained at VCS. The guidanceadded, clearly delineates the structure and reduces the overallpotential confusion for going to a multi-unit site. The overallchanges to the plan ensures the Emergency Director will have theneeded support from other ERO positions with specificUnit/technology knowledge to effectively maintain the overallcommand and control and fulfill the responsibilities of the onsitedecision maker.Evaluation: Since the guidance affects the command and controlsstructure of the emergency plan, it reduces the effectiveness of theinitial response to an emergency and requires prior approval by theNRC. The changes continue to meet the requirements of 10 CFR50.47(b) and 10 CFR 50 Appendix E. See the Technical Evaluation Section 4.3 of the LAR ATTACHMENT I.12. Added guidance for Part 2 Section B.5.a.4 10 CFR 50.47(b)(1) See justification and evaluation for item 6Technical SupportSSupervisors to include Document Control DeskAttachment IllLAR-13-02396 RC-14-0039 Page 12 of 61Item Change Summary Affected EP-100 Planning Standard/ Change Justification/Evaluation Rev 63 Section(s) Function/ Element(s) personnel from each 10 CFR 50.47(b)(2) Protected Area/Technology (multi-unit) 10 CFR 50.47(b)(10) 10 CFR 50.47(b)(14)

13. Added the ERO position for Part 2 Section B.5.a.5 10 CFR 50.47(b)(1)

Justification: The position of Technical Support Communicator isTechnical Support being added to the ERO to support Engineering communications Communicator and the 10 CFR 50.47(b)(2) and transfer of technical information from the TSC where decisions location and responsibilities are being evaluated and made to the EOF. The EOF is the facilityfor this position and guidance 10 CFR 50.47(b)(10) where technical information of the response must be developed andfor the multi-unit ERO provided to the public, and to or from the OSC or Control Room,10 CFR 50.47(b)(14) where if needed, technical information can be implemented orgathered and provided to evaluators and decision makers. Thisposition is a dedicated phone talker between facilities. The logistics of a multi-unit site adds aspects of command andcontrol which were not previously used and trained at VCS. Theguidance added changes the command and control structure foremergencies to ensure proper response by personnel. The additionis needed to clearly delineate the structure and reduce the overallpotential confusion for going to a multi-unit site.Evaluation: As an individual change the addition of theCommunicator does not reduce the effectiveness of the emergency plan. However, when combined together and with the change inactivation times, relocation of Engineering resources to the TSC,relocation of the TSC and the change to a multi-unit emergency response organization; these changes reduce the effectiveness ofthe emergency plan and requires prior approval by the NRC. Thechanges continue to meet the requirements of 10 CFR 50.47(b) and10 CFR 50 Appendix E. See the Technical Evaluation Section 4.3 Document Control DeskAttachment IIILAR-13-02396 RC-14-0039 Page 13 of 61Item Change Summary Affected EP-100 Planning Standard/ Change Justification/Evaluation Rev 63 Section(s) Function/ Element(s) and 4.5 of the LAR ATTACHMENT I.14. Added guidance for Part 2 Section B.5.a.6 10 CFR 50.47(b)(1) See justification and evaluation for item 6Operations Supervisors toinclude personnel from each 10 CFR 50.47(b)(2) Protected Area/Technology (multi-unit) 10 CFR 50.47(b)(10) 10 CFR 50.47(b)(14)

15. Deleted the State/County Old Part 2 Section 10 CFR 50.47(b)(1)

Justification: The responsibilities for offsite notifications are beingCommunicator and its B.5.a.8 directly transferred to the EOF from the Control Room as evaluated responsibilities from the TSC 10 CFR 50.47(b)(6) in item 7. The change in responsibilities removes a need to transferthis function from the Control Room to the TSC and then to the EOF.This provides offsite agencies with a direct line of communications with the emergency facility focused on offsite notifications andresponses in a more timely and effective manner.This change removes a need for offsite interface from the TSC.These responsibilities were previously assigned to the TSC due tothe EOF responding and activating the facility within about 60minutes of a Site Area Emergency. The EOF personnel will nowrespond and activate the facility within 75 minutes of the declaration of an Alert or higher classification. Therefore this activation at anearlier classification allows transfer of offsite notifications directly tothe EOF. Additional justification details are in Enclosure B (item 9).Evaluation: As an individual change, the change in responsibilities reduce the effectiveness of the emergency plan. Also, whencombined with the changes in activation times and relocation of theTSC; these changes reduce the effectiveness of the emergency planand require prior approval by the NRC. The changes continue tomeet the requirements of 10 CFR 50.47(b) and 10 CFR 50 Appendix Document Control DeskAttachment IIILAR-13-02396 RC-14-0039 Page 14 of 61Item Change Summary Affected EP-100 Planning Standard/ Change Justification/Evaluation Rev 63 Section(s) Function/ Element(s) E. See the Technical Evaluation Section 4.3 and 4.4 of the LARATTACHMENT I.16. Added reference to the Part 2 Section B.5.a.8 10 CFR 50.47(b)(1) Justification: The position of ENS Communicator has been a partEmergency Notification of the ERO and filled by designated on-shift personnel. TheSystem (ENS) 10 CFR 50.47(b)(6) communicator responds to the Control Room (CR) during anCommunicator position to the emergency to facilitate questions and responses for the counterpart Control Room lines supported by VCS for the NRC. The ENS Communicator in theCR will work directly with the communicator in the TSC, onceactivated, responding to inquiries by the regulator. The reference isbeing added to ensure the VCS emergency response maintains firsthand contact for indication and plant decision discussions inresponse to the emergency, due to relocation of the TSC.Evaluation: As individual

changes, the addition of an ENSCommunicator may not reduce the effectiveness of the emergency plan. However, when combined together and with the change inactivation times, relocation of Engineering resources to the TSC,and relocation of the TSC; these changes reduce the effectiveness of the emergency plan to ensure the responsibility for emergency response is assigned and requires prior approval by the NRC. Thechanges continue to meet the requirements of 10 CFR 50.47(b) and10 CFR 50 Appendix E. See the Technical Evaluation Section 4.3 ofthe LAR ATTACHMENT I.17. Added "(Reactor)"

and Part 2 Section B.5.a.9 10 CFR 50.47(b)(1) Justification: These changes are all administrative changesgrammatically corrected the supporting the implementation of the previously listed changes.title of the Technical Support 10 CFR 50.47(b)(8) Staff and added guidance on The logistics of a multi-unit site adds aspects of command anda multi-unit ERO control which were not previously used and trained at VCS. Theguidance added changes the command and control structure foremergencies to ensure proper response by all personnel. Theaddition is needed to clearly delineate the structure and reduce the Document Control DeskAttachment IIILAR-13-02396 RC-14-0039 Page 15 of 61Item Change Summary Affected EP-100 Planning Standard/ Change Justification/Evaluation Rev 63 Section(s) Function/ Element(s) overall potential confusion for going to a multi-unit site.Evaluation: These changes must be implemented based on thechanges, justifications, and evaluations previously listed in thisdocument. As individual

changes, these may not reduce theeffectiveness of the emergency plan. However, when combinedtogether and with the change in activation times, ERO titles, EROassignments, and relocation of the TSC and the addition of multi-unit

guidance, these changes reduce the effectiveness of the emergency plan and require prior approval by the NRC. The changes continueto meet the requirements of 10 CFR 50.47(b) and 10 CFR 50Appendix E. See the Technical Evaluation Section 4.6 of the LARATTACHMENT I.18. Transferred the duties of the Part 2 Section B.5.a. 10 10 CFR 50.47(b)(1)

Justification: The assignment of the Security Manager to the TSCERO position for Security ensures the proper level of evaluator and decision maker for onsiteSupervisor (OSC) to the TSC 10 CFR 50.47(b)(8) responses to emergencies at a multi-unit site. Placing this positionand changed the titles to in the TSC provides the Security oversight for the entire onsiteSecurity Manager and the response. This position will also interface directly with the Securitylocation and responsibilities Advisor in the EOF and the onsite Security Force to ensure thefor this position safety and security of responders to the facilities. This manager will be able to support the TSC through management of Security resources, providing insight to the TSC for Securitydefensive strategies and actions, and the capability to evaluate theeffects of the emergency on the Security Plan and personnel. TheManager will be directly involved with the emergency evaluation needs and will have the capacity to dispatch or relocate Securityassets to support the response. The addition of this position will not burden the human factorsengineering of the TSC, as this position was factored into the layoutand design of the facility. Document Control DeskAttachment IIILAR-13-02396 RC-14-0039 Page 16 of 61Item Change Summary Affected EP-100 Planning Standard/ Change Justification/Evaluation Rev 63 Section(s) Function/ Element(s) The TSC is being relocated and designed to provide adequate workspace for the Security Manager and access to site procedures,

drawings, and other documents.

The workspace will provide acomputer, a telephone, and other assets to support this position. The functions are being reassigned to the Manager, because theSecurity Manager position is being added to the TSC. The SecurityManager will ensure the Security Plan is maintained and will directthe operations of the Security Force. Thus the functions of securitycommand and control are not being removed from the emergency plan, but are being reassigned and placed in the overall onsiteemergency decision facility. Evaluation: As an individual change, the transfer of the Securityfunctions to the Security Manager in the TSC may not reduce theeffectiveness of the emergency plan. However, when combinedtogether, with the change in activation times and relocation of theTSC and the addition of multi-unit guidance; these changes reducethe effectiveness of the emergency plan and require prior approvalby the NRC. The changes continue to meet the requirements of 10CFR 50.47(b) and 10 CFR 50 Appendix E. See the Technical Evaluation Section 4.3 of the LAR ATTACHMENT I.19. Added reference to the ERO Part 2 Section B.5.a. 11 10 CFR 50.47(b)(1) Justification: The change is an administrative change and doesposition for Chemistry not affect the plan or its requirements. No responsibilities wereSupervisor and the location added or removed based on this change. These positions wereand responsibilities for this already listed either in the emergency position descriptions, theposition tables of ERO positions, or as shift personnel for each Unit.Evaluation: As an individual change, the change may not reducethe effectiveness of the emergency plan. However, when combinedtogether and with the change in activation times, ERO assignments, Document Control DeskAttachment IIILAR-1 3-02396RC-14-0039 Page 17 of 61Item Change Summary Affected EP-100 Planning Standard/ Change Justification/Evaluation Rev 63 Section(s) Function/ Element(s) and relocation of the TSC, these changes reduce the effectiveness of the emergency plan and require prior approval by the NRC. Thechanges continue to meet the requirements of 10 CFR 50.47(b) and10 CFR 50 Appendix E. See the Technical Evaluation Section 4.6 ofthe LAR ATTACHMENT I.20. Added reference to the ERO Part 2 Section B.5.a.12 10 CFR 50.47(b)(1) Justification: The change is an administrative change and doesposition for Maintenance not affect the plan or its requirements. No responsibilities wereSupervisor, the location and added or removed based on this change. These positions wereresponsibilities for this already listed either in the emergency position descriptions, theposition, and multi-unit tables of ERO positions, or as shift personnel for each Unit. Seeguidance also the justification and evaluation for item 6.Evaluation: As individual

changes, the changes may not reduce theeffectiveness of the emergency plan. However, when combinedtogether and with the change in activation times, ERO assignments, and relocation of the TSC, these changes reduce the effectiveness of the emergency plan and require prior approval by the NRC. Thechanges continue to meet the requirements of 10 CFR 50.47(b) and10 CFR 50 Appendix E. See the Technical Evaluation Section 4.3 ofthe LAR ATTACHMENT I.21. Added guidance for Part 2 Section B.5.a.13 10 CFR 50.47(b)(1)

See justification and evaluation for item 6Operational Support CenterSupervisors to include 10 CFR 50.47(b)(2) personnel from eachProtected Area/Technology 10 CFR 50.47(b)(10) (multi-unit) 10 CFR 50.47(b)(14)

22. Added guidance for Part 2 Section B.5.a.14 10 CFR 50.47(b)(1)

See justification and evaluation for item 6Operational Support CenterDamage Control Teams to Document Control DeskAttachment IIILAR-13-02396 RC-14-0039 Page 18 of 61Item Change Summary Affected EP-100 Planning Standard/ Change Justification/Evaluation Rev 63 Section(s) Function/ Element(s) include personnel from each 10 CFR 50.47(b)(2) Protected Area/Technology (multi-unit) 10 CFR 50.47(b)(10) 10 CFR 50.47(b)(14)

23. Transferred the Old Part 2 Section 10 CFR 50.47(b)(1)

Justification: The assignment of the Security Manager to the TSCresponsibilities of the B.5.a.11 ensures the proper level of evaluator and decision maker for onsiteSecurity Supervisor (OSC) to 10 CFR 50.47(b)(8) responses to emergencies at a multi-unit site. Placing this positionthe TSC and changed the in the TSC provides the Security oversight for the entire onsitetitle to Security Manager response. This position will also interface directly with the SecurityAdvisor in the EOF and the onsite Security Force to ensure thesafety and security of responders to the facilities. This manager will be able to support the TSC through management of Security resources, providing insight to the TSC for Securitydefensive strategies and actions, and the capability to evaluate theeffects of the emergency on the Security Plan and personnel. TheManager will be directly involved with the emergency evaluation needs and will have the capacity to dispatch or relocate Securityassets to support the response. The addition of this position will not burden the human factorsengineering of the TSC, as this position was factored into the layoutand design of the facility. The TSC is being relocated and designed to provide adequate workspace for the Security Manager and access to site procedures,

drawings, and other documents.

The workspace will provide acomputer, a telephone, and other assets to support this position. The functions are being reassigned to the Manager, because theSecurity Manager position is being added to the TSC. The Security Document Control DeskAttachment IIILAR-13-02396 RC-14-0039 Page 19 of 61Item Change Summary Affected EP-100 Planning Standard/ Change Justification/Evaluation Rev 63 Section(s) Function/ Element(s) Manager will ensure the Security Plan is maintained and will directthe operations of the Security Force. Thus the functions of securitycommand and control are not being removed from the emergency plan, but are being reassigned and placed in the overall onsiteemergency decision facility. Evaluation: As an individual change, the transfer of the Securityfunctions to the Security Manager in the TSC may not reduce theeffectiveness of the emergency plan. However, when combinedtogether and with the change in activation times, relocation of theTSC and addition of multi-unit guidance; these changes reduce theeffectiveness of the emergency plan and require prior approval bythe NRC. The changes continue to meet the requirements of 10CFR 50.47(b) and 10 CFR 50 Appendix E. See the Technical Evaluation Section 4.3 of the LAR ATTACHMENT I.24. Changed activation of the Part 2 Section B.5.b. 10 CFR 50.47(b)(1) See justification and evaluation for item 4ERO to reflect the full EROactivation at an Alert, Site 10 CFR 50.47(b)(2) Area Emergency, or GeneralEmergency (Alert or higher 10 CFR 50.47(b)(6) classification) and added thediscretion to activate at an 10 CFR 50.47(b)(8) Unusual Event25. Changed the responsibility Part 2 Section B.5.b.2 Justification: The action of preparing is assigned to thefor "preparing" notification Communications Coordinator in the EOF. The OEM is the managerforms to "approving" responsible for reviewing and approving the forms before they aresent to offsite agencies. This allows the OEM to have anindependent review and approval of the form to help ensure it isaccurate. Evaluation: As individual

changes, the changes may not reduce the Document Control DeskAttachment IIILAR-13-02396 RC-14-0039 Page 20 of 61Item Change Summary Affected EP-100 Planning Standard/

Change Justification/Evaluation Rev 63 Section(s) Function/ Element(s) effectiveness of the emergency plan. However, when combinedtogether and with the change in activation times, ERO assignments, and relocation of the TSC, these changes reduce the effectiveness of the emergency plan and require prior approval by the NRC. Thechanges continue to meet the requirements of 10 CFR 50.47(b) and10 CFR 50 Appendix E. See the Technical Evaluation Section 4.4 ofthe LAR ATTACHMENT I.26. Revised the title and Part 2 Section B.5.b.3 10 CFR 50.47(b)(1) Justification: Changing the title of the Plant Engineering Advisorresponsibilities of the Plant will not affect emergency response. This position will support theEngineering Advisor EOF as the Engineering point of contact and advisor to the EOF and(formerly Technical Support JIC for actions being evaluated or taken by personnel in the TSC, forCoordinator) offsite notifications, creating press releases, and preparing for pressconferences. Removing the responsibility of engineering support forthe TSC and adding the responsibility to support VCS State andCounty Liaisons, will permit the Plant Engineering Advisor to focuson the offsite technical support and response needed for theemergency. The revised responsibilities for this position will providea better understanding to the offsite understanding of how theemergency and the actions taken may affect public health andsafety. This will provide offsite agencies with a more dedicated resource for technical information to support Protective ActiveDecisions (PAD).Emergency response Engineering functions are being relocated tothe TSC, with exception of a Plant Engineering Advisor. Relocating the engineering functions will place needed technical engineering resources, focused on the onsite emergency, in one emergency facility and under one engineering decision maker.The change in Engineering responsibilities within the EOF will allowthe EOF to place efforts and emergency evaluations and decisionmakings on protecting the public health and safety. Support of the Document Control DeskAttachment IIILAR-13-02396 RC-14-0039 Page 21 of 61Item Change Summary Affected EP-100 Planning Standard/ Change Justification/Evaluation Rev 63 Section(s) Function/ Element(s) onsite requests will no longer be needed. This will allow the EOF tofocus its technical expertise on the offsite responses and support.This change will provide the TSC with additional engineering resources to evaluate, plan, and implement mitigation strategies andto evaluate resources needed to support the emergency from offsitevendors or agencies. Adding the additional resources to the responsibilities of the TSCTechnical Support Manager does not add additional burden to thisposition, it removes a third party position that took phone request foronsite needs and directed personnel, previously located in the EOF,to support the needs of the TSC. Relocation of engineering resources will not burden the human factors engineering orcapabilities of the TSC. The TSC was designed to support theadditional personnel. The TSC is being relocated and designed to provide adequate workspace for Engineering resources and access to site procedures,

drawings, and other documents.

The workspace will provide morecomputers, telephones, and engineering assets than previously available in the EOF and old TSC.Response times for personnel reassigned from the EOF to the TSCwill be affected. Personnel previously assigned to the EOFresponded and activated the facility within about 60 minutes of a SiteArea Emergency. The reassignment of personnel will beimplemented along with the requirement to respond and activate theTSC within 75 at an Alert or higher classification. Therefore thisactivation is at an earlier classification, providing the ERO with moretimely responders and resources. Evaluation: As an individual change, the title change and thechange in responsibilities for the Plant Engineering Advisor do not Document Control DeskAttachment IIILAR-1 3-02396RC-14-0039 Page 22 of 61Item Change Summary Affected EP-100 Planning Standard/ Change Justification/Evaluation Rev 63 Section(s) Function/ Element(s) reduce the effectiveness of the emergency plan. However, whencombined together and with the change in activation times,relocation of Engineering resources to the TSC, and relocation of theTSC; these changes reduce the effectiveness of the emergency planto ensure the responsibility for emergency response is assigned andrequires prior approval by the NRC. The changes continue to meetthe requirements of 10 CFR 50.47(b) and 10 CFR 50 Appendix E.See the Technical Evaluation Section 4.5 of the LAR ATTACHMENT 1.27. Added the ERO position for Part 2 Section B.5.b.6 10 CFR 50.47(b)(1) Justification: The position of Communications Coordinator wasCommunications Coordinator added to create a single point of contact for completing theand the location and 10 CFR 50.47(b)(5) Emergency Notification Forms and coordinating the contact of state,responsibilities for this local, and federal agencies for information on emergency position to the EOF classifications, protective actions decisions being made, sirenactivations, offsite response

actions, etc. The responsibilities of thisposition are not new, but are being relocated from other positions tosupport the changes addressed in item 7 above, in whichemergency notifications will be made from the EOF and will nolonger be made from the TSC.The Coordinator will maintain a focus on timely and accuratenotifications, thus ensuring the offsite agencies have the means tomake timely and effective decisions to protect public health andsafety. This EOF is sized and configured to support this position.

Evaluation: As an individual change, the change in responsibilities may not reduce the effectiveness of the emergency plan. However,when combined together and with the change in activation times,reassignment of notification responsibilities, and relocation of theTSC; these changes reduce the effectiveness of the emergency planand require prior approval by the NRC. The changes continue tomeet the requirements of 10 CFR 50.47(b) and 10 CFR 50 Appendix Document Control DeskAttachment IIILAR-13-02396 RC-14-0039 Page 23 of 61Item Change Summary Affected EP-100 Planning Standard/ Change Justification/Evaluation Rev 63 Section(s) Function/ Element(s) E. See the Technical Evaluation Section 4.4 of the LARATTACHMENT I.28. Deleted the General Services Old Part 2 Section 10 CFR 50.47(b)(1) Justification: The Coordinator position has been removed from theCoordinator and its B.5.b.8 emergency plan. The Coordinator is a purchasing agent for theresponsibilities from the EOF company and the role may be filled by VCS purchasing agentslocated in the EOF or may be filled by any corporate purchasing agent located at other corporate locations. The process ofpurchasing does not change due to an emergency. On call purchasing personnel will support purchasing needs either atthe corporate offices or at the EOF. The details of the duties arebeing maintained within the emergency plan implementing procedures to ensure the responsibilities are not removed fromsupporting the ERO.Evaluation: The position is an administrative position and notrecommended or required as a minimum staffing position in NUREG0654 or regulations.

However, removal of this position from theEmergency Plan reduces the effectiveness of the plan and requiresprior approval by the NRC. The changes continue to meet therequirements of 10 CFR 50.47(b) and 10 CFR 50 Appendix E. Seethe Technical Evaluation Section 4.3 of the LAR ATTACHMENT I.29. Revised the title and Part 2 Section B.5.b.8 10 CFR 50.47(b)(1)

Justification: The title has been changed to more accurately responsibilities of the Plant identify the role and responsibilities as an Advisor to the ERO in theSecurity Advisor (formerly EOF. The Advisor is not a decision maker for onsite actions, but willSecurity Coordinator) provide the interface with the Security Manager in the Technical Support Center and provide insight as to what actions are beingtaken onsite that may require interface with offsite law enforcement agencies. This Advisor will be responsible for monitoring andcoordinating Security support at the EOF, in coordination with the Document Control DeskAttachment IIILAR-1 3-02396RC-14-0039 Page 24 of 61Item Change Summary Affected EP-100 Planning Standard/ Change Justification/Evaluation Rev 63 Section(s) Function/ Element(s) security decision maker in the TSC.Evaluation: As an individual change, the change in title may notreduce the effectiveness of the emergency plan. However, whencombined together and with the change in activation times,reassignment of Security responsibilities, and relocation of the TSC;these changes reduce the effectiveness of the emergency plan andrequire prior approval by the NRC. The changes continue to meetthe requirements of 10 CFR 50.47(b) and 10 CFR 50 Appendix E.See the Technical Evaluation Section 4.3 of the LAR ATTACHMENT I.30. Added reference to the ERO Part 2 Section B.5.b.9 10 CFR 50.47(b)(1) Justification: The position of the Communicator is a collateral dutyposition for Health Physics for Health Physics personnel but was not identified as a specificNetwork (HPN) 1&CFR 50.47(b)(6) ERO position. This change formalizes the position to ensure properCommunicator and the communications are established and maintained during anlocation and responsibilities emergency. The position keeps the Regulator apprised of thefor this position radiological conditions of the emergency and the mitigation andmonitoring actions being taken for the offsite environs. This positionmay also communicate with SC Department of Health andEnvironmental Control (DHEC) personnel to coordinate field teamand dose projection transfer of information to the regulator. This position already has a designated work location within the EOF.Evaluation: As an individual change, the formal addition of thisposition does not reduce the effectiveness of the emergency plan.However, when combined together and with the change in activation times, relocation of Engineering resources to the TSC, andrelocation of the TSC; these changes reduce the effectiveness of theemergency plan and requires prior approval by the NRC. Thechanges continue to meet the requirements of 10 CFR 50.47(b) and10 CFR 50 Appendix E. See the Technical Evaluation Section 4.3 of Document Control DeskAttachment IIILAR-13-02396 RC-14-0039 Page 25 of 61Item Change Summary Affected EP-100 Planning Standard/ Change Justification/Evaluation Rev 63 Section(s) Function/ Element(s) the LAR ATTACHMENT I.31. Added the description of the Part 2 Section B.5.b.10 10 CFR 50.47(b)(1) Justification: The position of Field Teams has been identified inERO position for Field the Emergency Plan staffing tables but has not had a formalTeams and the location and description of responsibilities in the plan. This change betterresponsibilities for this describes these positions as part of the overall emergency responseposition to the body of the and staffing. planEvaluation: As an individual change, the change may not reducethe effectiveness of the emergency plan. However, when combinedtogether and with the change in activation times and a multi-unit ERO, these changes reduce the effectiveness of the emergency plan and require prior approval by the NRC. The changes continueto meet the requirements of 10 CFR 50.47(b) and 10 CFR 50Appendix E. See the Technical Evaluation Section 4.3 of the LARATTACHMENT I.32. Added the description of the Part 2 Section B.5.b.1 1 10 CFR 50.47(b)(1) Justification: The position of Plant Operations Advisor has beenERO position for Plant identified in the Emergency Plan staffing tables but has not had aOperations Advisor and formal description of responsibilities in the plan. This change betterdescribed the location and describes the position as part of the overall emergency responseresponsibilities for this and staffing. position in the planEvaluation: As an individual change, the change may not reducethe effectiveness of the emergency plan. However, when combinedtogether and with the change in activation times and a multi-unit ERO, these changes reduce the effectiveness of the emergency plan and require prior approval by the NRC. The changes continueto meet the requirements of 10 CFR 50.47(b) and 10 CFR 50Appendix E. See the Technical Evaluation Section 4.3 of the LARATTACHMENT I. Document Control DeskAttachment IIILAR-1 3-02396RC-14-0039 Page 26 of 61Item Change Summary Affected EP-100 Planning Standard/ Change Justification/Evaluation Rev 63 Section(s) Function/ Element(s)

33. Transferred the Part 2 Section B.5.c.3 10 CFR 50.47(b)(1)

Justification: The Plant Engineering Advisor will assume the dutiesresponsibilities of the Lead of reviewing and assisting in the development of press releases andTechnical Briefer to the if needed, support media press conferences that were performed byposition of Plant Engineering the Lead Technical Briefer. The relocation of the Engineering staffAdvisor from the EOF to the TSC will remove many of the oversight responsibilities from the Plant Engineering

Advisor, thus allowingthis position to take on an engineering advisory role in the EOF.Evaluation:

The additional responsibilities as a whole may notreduce the effectiveness of the emergency plan. However, whencombined together and with the changes in relocating engineering resources and a multi-unit ERO, this change reduces theeffectiveness of the emergency plan and require prior approval bythe NRC. The change continues to meet the requirements of 10CFR 50.47(b) and 10 CFR 50 Appendix E. See the Technical Evaluation Section 4.5 of the LAR ATTACHMENT I.34. Updated the organization Part 2 Figure B-lb 10 CFR 50.47(b)(1) Justification: These changes support implementation of otherchart to reflect changes to listed emergency plan changes.ERO positions in the planThe logistics of a multi-unit site adds aspects of command andcontrol which were not previously used and trained or drilled at VCS.The guidance added, changes the command and control structure for emergencies to ensure proper response by personnel. Theaddition is needed to clearly delineate the structure and reduce theoverall potential confusion for transitioning to a multi-unit site.Evaluation: These changes must be implemented based on thechanges, justifications, and evaluations previously listed in thisdocument. As individual

changes, these may not reduce theeffectiveness of the emergency plan. However, when combinedtogether and with the change in activation times, ERO titles, EROassignments, and relocation of the TSC, these changes reduce the Document Control DeskAttachment IIILAR-13-02396 RC-14-0039 Page 27 of 61Item Change Summary Affected EP-100 Planning Standard/

Change Justification/Evaluation Rev 63 Section(s) Function/ Element(s) effectiveness of the emergency plan and require prior approval bythe NRC. The changes continue to meet the requirements of 10CFR 50.47(b) and 10 CFR 50 Appendix E. See the Technical Evaluation Section 4.3 of the LAR ATTACHMENT I.35. Updated the organization Part 2 Figure B-ic 10 CFR 50.47(b)(1) Justification: These changes support implementation of otherchart to reflect changes to listed emergency plan changes.ERO positions in the plan 10 CFR 50.47(b)(2) The logistics of a multi-unit site adds aspects of command and10 CFR 50.47(b)(6) control which were not previously used and trained or drilled at VCS.The guidance added, changes the command and control structure 10 CFR 50.47(b)(8) for emergencies to ensure proper response by personnel. Theaddition is needed to clearly delineate the structure and reduce theoverall potential confusion for transitioning to a multi-unit site.Evaluation: These changes must be implemented based on thechanges, justifications, and evaluations previously listed in thisdocument. As individual

changes, these may not reduce theeffectiveness of the emergency plan. However, when combinedtogether and with the change in activation times, ERO titles, EROassignments, and relocation of the TSC, these changes reduce theeffectiveness of the emergency plan and require prior approval bythe NRC. The changes continue to meet the requirements of 10CFR 50.47(b) and 10 CFR 50 Appendix E. See the Technical Evaluation Section 4.3 of the LAR ATTACHMENT I.36. Updated the organization Part 2 Figure B-id 10 CFR 50.47(b)(1)

Justification: These changes support implementation of otherchart to reflect changes to listed emergency plan changes.ERO positions in the plan 10 CFR 50.47(b)(2) The logistics of a multi-unit site adds aspects of command and10 CFR 50.47(b)(6) control which were not previously used and trained or drilled at VCS.The guidance added, changes the command and control structure for emergencies to ensure proper response by personnel. The Document Control DeskAttachment IIILAR-13-02396 RC-14-0039 Page 28 of 61Item Change Summary Affected EP-100 Planning Standard/ Change Justification/Evaluation Rev 63 Section(s) Function/ Element(s) 10 CFR 50.47(b)(8) addition is needed to clearly delineate the structure and reduce theoverall potential confusion for transitioning to a multi-unit site.Evaluation: These changes must be implemented based on thechanges, justifications, and evaluations previously listed in thisdocument. As individual

changes, these may not reduce theeffectiveness of the emergency plan. However, when combinedtogether and with the change in activation times, ERO titles, EROassignments, and relocation of the TSC, these changes reduce theeffectiveness of the emergency plan and require prior approval bythe NRC. The changes continue to meet the requirements of 10CFR 50.47(b) and 10 CFR 50 Appendix E. See the Technical Evaluation Section 4.3 of the LAR ATTACHMENT I.37. Updated the table to include Part 2 Table B-i a 10 CFR 50.47(b)(1)

Justification: These changes support implementation of otherchanges affecting ERO listed emergency plan changes.positions, augmentation 10 CFR 50.47(b)(2) times, and responsibilities The logistics of a multi-unit site adds aspects of command and10 CFR 50.47(b)(6) control which were not previously used and trained or drilled at VCS.The guidance added, changes the command and control structure 10 CFR 50.47(b)(8) for emergencies to ensure proper response by personnel. Theaddition is needed to clearly delineate the structure and reduce theoverall potential confusion for transitioning to a multi-unit site.Evaluation: These changes must be implemented based on thechanges, justifications, and evaluations previously listed in thisdocument. As individual

changes, these may not reduce theeffectiveness of the emergency plan. However, when combinedtogether and with the change in activation times, ERO titles, EROassignments, and relocation of the TSC, these changes reduce theeffectiveness of the emergency plan and require prior approval bythe NRC. The changes continue to meet the requirements of 10CFR 50.47(b) and 10 CFR 50 Appendix E. See the Technical Document Control DeskAttachment IIILAR-13-02396 RC-14-0039 Page 29 of 61Item Change Summary Affected EP-100 Planning Standard/

Change Justification/Evaluation Rev 63 Section(s) Function/ Element(s) Evaluation Section 4.3 of the LAR ATTACHMENT I.38. Added guidance for a multi- Part 2 Section D. 1.a 10 CFR 50.47(b)(1) See justification and evaluation for item 6unit ERO10 CFR 50.47(b)(2) 10 CFR 50.47(b)(10) 10 CFR 50.47(b)(14)

39. Changed activation of the Part 2 Section D.1.b 10 CFR 50.47(b)(1)

See justification and evaluation on item 4ERO to reflect the full EROactivation at an Alert 10 CFR 50.47(b)(2) 10 CFR 50.47(b)(6) 10 CFR 50.47(b)(8)

40. Changed activation of the Part 2 Section D. 1.c 10 CFR 50.47(b)(1)

See justification and evaluation on item 4ERO to reflect the full EROactivation at a Site Area 10 CFR 50.47(b)(2) Emergency 10 CFR 50.47(b)(6) 10 CFR 50.47(b)(8))

41. Added guidance on the Units Part 2 Section D.2 10 CFR 50.47(b)(4)

Justification: Emergency Action Levels (EAL) are required in2 & 3 EALs accordance with 10 CFR 50.47(b)(4) to ensure the site is adequately evaluating plant conditions to determine if an emergency classification is required. The addition of the Units 2 & 3 EALsensure these action levels developed in accordance with NEI 07-01,which was endorsed by the NRC, are maintained as a part of theEmergency Plan. The EALs are maintained under a separate Document Control DeskAttachment IIILAR-1 3-02396RC-14-0039 Page 30 of 61Item Change Summary Affected EP-100 Planning Standard/ Change Justification/Evaluation Rev 63 Section(s) Function/ Element(s) controlled

document, but required the same evaluations and reviewsas an emergency plan change.Evaluation:

As individual

changes, the changes may not reduce theeffectiveness of the emergency plan. However, when combinedtogether and with the change in multi-unit responses, activation times, ERO assignments, and relocation of the TSC, these changesreduce the effectiveness of the emergency plan and require priorapproval by the NRC. The changes continue to meet therequirements of 10 CFR 50.47(b) and 10 CFR 50 Appendix E. Seethe Technical Evaluation Section 4.3 of the LAR ATTACHMENT I.42. Changed activation of the Part 2 Section E.2.a 10 CFR 50.47(b)(1)

See justification and evaluation on item 4ERO to reflect the full EROactivation at an Alert, Site 10 CFR 50.47(b)(2) Area Emergency, or GeneralEmergency (Alert or higher 10 CFR 50.47(b)(6) classification) and removedreference to activating the 10 CFR 50.47(b)(8) JIC43. Changed guidance to be Part 2 Section F.1 -4 10 CFR 50.47(b)(6) Justification: This is an administrative change to transfer Unitmore generic to support specific information/guidance from the generic sections of theUnits 1, 2, & 3 10 CFR 50.47(b)(8) emergency plan into the annex specific to Units. No unit specificguidance was removed from the plan. The alarms and public10 CFR 50.57(b)(10) address systems are used to provide notification of emergencies and protective actions to site personnel. Evaluation: As individual

changes, the changes may not reduce theeffectiveness of the emergency plan. However, when combinedtogether and with the change in activation times, ERO assignments, and relocation of the TSC, these changes reduce the effectiveness of the emergency plan and require prior approval by the NRC. The Document Control DeskAttachment IIILAR-13-02396 RC-14-0039 Page 31 of 61Item Change Summary Affected EP-100 Planning Standard/

Change Justification/Evaluation Rev 63 Section(s) Function/ Element(s) changes continue to meet the requirements of 10 CFR 50.47(b) and10 CFR 50 Appendix E. See the Technical Evaluation Section 4.6 ofthe LAR ATTACHMENT I.44. Added guidance to support a Part 2 Section H. 1 & 10 CFR 50.47(b)(1) Justification: The logistics of a multi-unit site adds aspects ofmulti-unit ERO l.a command and control which were not previously used and trained at10 CFR 50.47(b)(2) VCS. The guidance added, changes the command and controlstructure for emergencies to ensure proper response by ERO10 CFR 50.47(b)(10) personnel. The addition is needed to clearly delineate the structure to support a multi-unit site.10 CFR 50.47(b)(14) Evaluation: Since the term affects the command and controlsstructure of the emergency plan, it does reduce the effectiveness ofthe initial response to an emergency and requires prior approval bythe NRC. The changes continue to meet the requirements of 10CFR 50.47(b) and 10 CFR 50 Appendix E. See the Technical Evaluation Section 4.3 of the LAR ATTACHMENT I.45. Added guidance and Part 2 Section H.1 .b 10 CFR 50.47(b)(1) The evaluation of the TSC is in Enclosure D to this attachment. Thereferences for the relocation evaluation on the transfer of the Security Manager is discussed inof the TSC into the basement 10 CFR 50.47(b)(8) item 18 above. The evaluation of the guidance to support a multi-of the Nuclear Operations unit ERO is discussed in item 11 above. The back-up OSC is aBuilding, noted the transfer of portion of the designated work space within the new TSC. Thethe Security Manager to the additional guidance for the remote TSC and OSC is added toTSC, updated the capture emergency facilities to be used in the event the site accessaccommodations, back-up is impeded or inaccessible due to an emergency. These changesfacilities, and remote ensure the plan has guidance for all emergency facilities. facilities, added guidance tosupport a multi-unit ERO,and added guidance on theback-up and remote OSCand TSC Document Control DeskAttachment IIILAR-13-02396 RC-14-0039 Page 32 of 61Item Change Summary Affected EP-100 Planning Standard/ Change Justification/Evaluation Rev 63 Section(s) Function/ Element(s)

46. Added the OSC guidance to Part 2 Section H. 1 .c 10 CFR 50.47(b)(8)

Justification: The description change is an administrative changeinclude references to the new based on relocation of the TSC into the new NOB.Back-up OSC in the newTSC and the Remote OSC in The Remote OSC and the Remote TSC have been located at thethe EOF Building (formerly Joint Information Center (JIC) Building since it was incorporated intothe Back-up), changed the emergency plan in 2009 under 10 CFR 50.54(q). The EOF isreference to the JIC Building located in the JIC Building. The description was updated to reflectto the EOF Building, added this.guidance to support a multi-unit ERO, and added The logistics of a multi-unit site adds aspects of command andguidance on the back-up and control which were not previously used and trained at VCS. Theremote OSC guidance added changes the command and control structure foremergencies to ensure proper response by personnel. The additionis needed to clearly delineate the structure and reduce the overallpotential confusion for going to a multi-unit site.Evaluation: As individual

changes, the change to include reference to the Back-up OSC in the TSC, the description of the Remote TSCin the JIC Building, and multi-unit guidance may not reduce theeffectiveness of the emergency plan. However, when combinedtogether and with the change in activation times, ERO titles, EROassignments, and relocation of the TSC, these changes reduce theeffectiveness of the emergency plan and require prior approval bythe NRC. The changes continue to meet the requirements of 10CFR 50.47(b) and 10 CFR 50 Appendix E. See the Technical Evaluation Section 4.1 and 4.2 of the LAR ATTACHMENT I.47. Changed the augmentation Part 2 Section H.5 10 CFR 50.47(b)(1)

See justification and evaluation for item 4 and Enclosure Ctime of the ERO from 60 (item 9)minutes to 75 minutes and 10 CFR 50.47(b)(2) changed activation of theERO to reflect the full EROactivation at an Alert, Site Document Control DeskAttachment IIILAR-13-02396 RC-14-0039 Page 33 of 61Item Change Summary Affected EP-100 Planning Standard/ Change Justification/Evaluation Rev 63 Section(s) Function/ Element(s) Area Emergency, or GeneralEmergency (Alert or higherclassification)

48. Added guidance that Part 2 Section H.10 10 CFR 50.47(b)(8)

Justification: VCS will operate three nuclear units, onceadditional supplies may be construction of Units 2 & 3 are completed. Each Unit will have itsobtained from other units own Operational Support Center (OSC) with full staffing to supportan emergency within its unit. The use of supplies between unitsfrom unaffected units will provide more resources for immediate response. Evaluation: The use of unaffected unit supplies for responses inother affected units, by itself does not reduce the effectiveness ofthe emergency plan. However, when combined with an emergency at a unit sharing its staff, response times and availability ofpersonnel may be delayed, thus reducing the overall effectiveness ofan emergency response to another unit. This is a reduction ineffectiveness and requires prior approval by the NRC. The changescontinue to meet the requirements of 10 CFR 50.47(b) and 10 CFR50 Appendix E. See the Technical Evaluation Section 4.6 of theLAR ATTACHMENT I.49. Revised provisions for KI in Part 2 Section H.12 10 CFR 50.47(b)(10) Justification: The TSC will maintain the responsibility to make thethe Control Room decision to offer Potassium Iodide (KI) to onsite personnel.

However, with the relocation of the TSC to the new NuclearOperations

Building, the TSC is no longer adjacent to the ControlRoom and the distribution of KI will be more effective and timelyfrom the OSC.Evaluation:

As individual

changes, the change to provide KI to theControl Room from the OSC may not reduce the effectiveness of theemergency plan. However, when combined together and with thechange in ERO titles, ERO assignments, and relocation of the TSC, Document Control DeskAttachment IIILAR-1 3-02396RC-14-0039 Page 34 of 61Item Change Summary Affected EP-100 Planning Standard/

Change Justification/Evaluation Rev 63 Section(s) Function/ Element(s) these changes reduce the effectiveness of the emergency plan andrequire prior approval by the NRC. The changes continue to meetthe requirements of 10 CFR 50.47(b) and 10 CFR 50 Appendix E.See the Technical Evaluation Section 4.3 of the LAR ATTACHMENT 1.50. Changed activation of the Part 2 Section 1.8 10 CFR 50.47(b)(1) The evaluation for the change in activation time is provided inERO to reflect the activation enclosure C of this attachment. of Field Teams at an Alert or 10 CFR 50.47(b)(9) higher classification

51. Added the lED and ED with Part 2 Section J.4.d 10 CFR 50.47(b)(1)

Justification: These changes are administrative changesthe OEM supporting and complete the implementation of the previously listedchanges.Evaluation: These changes must be implemented based on thechanges, justifications, and evaluations previously listed in thisdocument. As individual

changes, these may not reduce theeffectiveness of the emergency plan. However, when combinedtogether and with the change in activation times, ERO titles, EROassignments, and relocation of the TSC, these changes reduce theeffectiveness of the emergency plan and require prior approval bythe NRC. The changes continue to meet the requirements of 10CFR 50.47(b) and 10 CFR 50 Appendix E. See the Technical Evaluation Section 4.3 of the LAR ATTACHMENT I.52. Added guidance for rotation Part 2 Section N.3 10 CFR 50.47(b)(1)

Justification: The need to rotate drills among all Units andof drills among the Unit personnel ensures that emergency responders are trained andspecific facilities and 10 CFR 50.47(b)(2) drilled in simulated conditions to make them more proficient inpersonnel protecting public health and safety for either Unit/Technology 10 CFR 50.47(b)(14) experiencing an emergency. The VCS ERO is a single organization with only the Control Rooms and Operational Support Centers beingspecifically assigned to each Unit. These facilities may not be Document Control DeskAttachment IIILAR-13-02396 RC-14-0039 Page 35 of 61Item Change Summary Affected EP-100 Planning Standard/ Change Justification/Evaluation Rev 63 Section(s) Function/ Element(s) directly involved in an emergency condition but may provide supportto the affected Unit.Evaluation: As individual

changes, the changes may not reduce theeffectiveness of the emergency plan. However, when combined withthe change in ERO assignments and relocation of the TSC, thesechanges reduce the effectiveness of the emergency plan and requireprior approval by the NRC. The changes continue to meet therequirements of 10 CFR 50.47(b) and 10 CFR 50 Appendix E. Seethe Technical Evaluation Section 4.6 of the LAR ATTACHMENT I.53. Removed references to the Old Annex 1 Section 10 CFR 50.47(b)(8)

Justification: This is an administrative change supporting changesTechnical Support Center 4.1. B listed in this revision. The description of the TSC was relocated fromthe Annex to Part 2 of the plan due to the facility being relocated andbecoming an overall emergency response facility for the site and nota unit specific facility. The Annex contains information that isspecific to VCS Unit 1.Evaluation: As an individual change, the change in the location ofthe TSC word description may not reduce the effectiveness of theemergency plan. However, when combined together and with thechange in activation times, ERO titles, ERO assignments, andrelocation of the TSC, these changes reduce the effectiveness of theemergency plan and require prior approval by the NRC. Thechanges continue to meet the requirements of 10 CFR 50.47(b) and10 CFR 50 Appendix E. See the Technical Evaluation Section 4.2 ofthe LAR ATTACHMENT I.54. Changed the augmentation Annex 1 Section 4.1.3 10 CFR 50.47(b)(1) See justification and evaluation for item 9time of the ERO from "withinabout 60 minutes" to "within 10 CFR 50.47(b)(2) 75 minutes" Document Control DeskAttachment IIILAR-13-02396 RC-14-0039 Page 36 of 61Item Change Summary Affected EP-100 Planning Standard/ Change Justification/Evaluation Rev 63 Section(s) Function/ Element(s)

55. Added guidance for an onsite Annex 1 Section 5.2 10 CFR 50.47(b)(10)

Justification: The addition of the onsite assembly area will allowassembly area VCS a designated location to assemble personnel onsite that are notdirectly involved in the response to an emergency. This will allowthe ERO to provide a briefing and release information to personnel before dismissing them. The location chosen is outside of the Unit 1Protected Area and outside the proposed Units 2 & 3 Protected Area, thus the designated location will not affect the ability tocomplete accountability during an emergency. The ERO alreadyhas designated assembly/holding area leaders assigned and thesepersonnel will be responsible for managing,

briefing, and dismissing non-essential personnel under direction of the Emergency Directorin the TSC.Evaluation:

As an individual change, the change to include anassembly area may not reduce the effectiveness of the emergency plan. However, when combined together and with the change inactivation times, ERO titles, ERO assignments, and relocation of theTSC, these changes reduce the effectiveness of the emergency planand require prior approval by the NRC. The changes continue tomeet the requirements of 10 CFR 50.47(b) and 10 CFR 50 AppendixE. See the Technical Evaluation Section 4.6 of the LARATTACHMENT I.56. Added Unit specific guidance Annex 2 & 3 10 CFR 50.47(b)(1) Justification: The logistics of a multi-unit site adds aspects offor VCS Units 2 & 3 command and control which were not previously used and trained atVCS. The guidance added changes the command and controlstructure for emergencies to ensure proper response by personnel. The addition is needed to clearly delineate the structure and reducethe overall potential confusion for going to a multi-unit site.Evaluation: Since the term affects the command and controlsstructure of the emergency plan, it reduces the effectiveness of theinitial response to an emergency and requires prior approval by the Document Control DeskAttachment IIILAR-13-02396 RC-14-0039 Page 37 of 61Item Change Summary Affected EP-100 Planning Standard/ Change Justification/Evaluation Rev 63 Section(s) Function/ Element(s) NRC. The changes continue to meet the requirements of 10 CFR50.47(b) and 10 CFR 50 Appendix E. See the Technical Evaluation Section 4.3 of the LAR ATTACHMENT I. Document Control DeskAttachment IIILAR-1 3-02396RC-14-0039 Page 38 of 61Enclosure B, Emergency Response Organization Position Responsibility Change & Comparison Rev 63 ERO Rev 63 Rev 63 Submittal ERO Submittal Submittal CommentsPosition Titles' Facility Responsibilities Position Titles1 Facility Responsibilities Shift Supervisor Control

• Evaluate conditions and Shift Supervisor Control
• Evaluate conditions and Duties and responsibilities do notRoom declare an emergency Room declare an emergency change. The wording of these* Act in the capacity of the
• Act in the capacity of the duties may differ from previousInterim Emergency Director Interim Emergency Director revisions, but are maintained in the* Manage the emergency and
• Manage the emergency and plan and implementing procedures.

initial emergency responses initial emergency responses and actions and actions* Maintain reactor and

• Maintain reactor andsystems control systems control* Activate ERO
• Activate ERO* Initiate ERDS
• Initiate ERDS* Perform the duties outlined
• Perform the duties outlinedfor the ED, OEC, and ECO. for the ED, OEC, and ECO.* NUREG 0654 Table B-1
• NUREG 0654 Table B-1Functional Area -Plant Functional Area -PlantOperations and Assessment of Operations and Assessment ofOperations Aspects (Room Operations Aspects (RoomStaff) Staff)% NUREG 0654 Table B-1
• NUREG 0654 Table B-1Functional Area -Emergency Functional Area -Emergency Direction and Control Direction and Control(Command and Control)

(Command and Control)* NUREG 0654 Table B-1

• NUREG 0654 Table B-1Functional Area -Notification Functional Area -Notification and Communications and Communications (Emergency Communications)

(Emergency Communications) Shift Engineer Control 9 Technical advisor for core Shift Engineer Control 9 Technical advisor for core Duties and responsibilities do notRoom cooling and containment Room cooling and containment change. The wording of theseintegrity integrity duties may differ from previous* NUREG 0654 Table B-1

• NUREG 0654 Table B-1 revisions, but are maintained in theFunctional Area -Plant System Functional Area -Plant System plan and implementing procedures.

Engineering, Repair, and Engineering, Repair, andCorrective Actions (Technical Corrective Actions (Technical Support) Support) Document Control DeskAttachment IIILAR-13-02396 RC-14-0039 Page 39 of 61Rev 63 ERO Rev 63 Rev 63 Submittal ERO Submittal Submittal CommentsPosition Titles1 Facility Responsibilities Position Titles1 Facility Responsibilities

• Perform accident
• Perform accidentassessments and evaluate assessments and evaluateoperating conditions as the Shift operating conditions as the ShiftTechnical Advisor Technical Advisor* Diagnose off-normal events
• Diagnose off-normal eventsControl Room Control 0 Operating plant equipment Control Room Control 0 Operating plant equipment Duties and responsibilities do notOperators Room from the Control Room Operators Room from the Control Room change. The wording of these* NUREG 0654 Table B-1
• NUREG 0654 Table B-1 duties may differ from previousFunctional Area -Plant Functional Area -Plant revisions, but are maintained in theOperations and Assessment of Operations and Assessment of plan and implementing procedures.

Operations Aspects Operations AspectsAuxiliary Control 0 Operating plant equipment Auxiliary Control

• Operating plant equipment Duties and responsibilities do notOperators Room outside of the Control Room Operators Room outside of the Control Room change. The wording of theseduties may differ from previousrevisions, but are maintained in theplan and implementing procedures.

State/County Control

• Notification of station State/County Control
• Notification of station Duties and responsibilities do notCommunicator Room/TSC personnel, state agencies, Communicator Room personnel, state agencies, change. The wording of thesecounty agencies, and the NRC county agencies, and the NRC duties may differ from previous% NUREG 0654 Table B-1
• NUREG 0654 Table B-1 revisions, but are maintained in theFunctional Area -Notification Functional Area -Notification plan and implementing procedures.

and Communications and Communications (Emergency Communications) (Emergency Communications) None N/A N/A ENS Control 0 Provide updates and Added this position to formalize theCommunicator Room respond to inquiries from the support of the NRC telephone line.NRCEmergency TSC

• Supervises and directs the Emergency TSC 9 Supervises and directs the Duties and responsibilities do notDirector Onsite ERO Director Onsite ERO change. The wording of these0 Provides for control and
• Provides for control and duties may differ from previousoperation of the plant, mitigation operation of the plant, mitigation revisions, but are maintained in theof the emergency, protection of of the emergency, protection of plan and implementing procedures.

station personnel, and station personnel, and Additional details of theseemergency support emergency support responsibilities were added toe Organizes and coordinates 9 Organizes and coordinates properly identify the position's onsite efforts onsite efforts emergency role. No additional 0 Implement in-plant recovery e Implement in-plant recovery duties have been added.operations operations 9 Classifying emergencies 9 Classifying emergencies Document Control DeskAttachment IIILAR-13-02396 RC-14-0039 Page 40 of 61Rev 63 ERO Rev 63 Rev 63 Submittal ERO Submittal Submittal CommentsPosition Titles1 Facility Responsibilities Position Titles1 Facility Responsibilities

• NUREG 0654 Table B-1
• NUREG 0654 Table B-1Functional Area -Emergency Functional Area -Emergency Direction and Control Direction and Control(Command and Control)

(Command and Control)0 SAMG decision maker

• SAMG decision makerTechnical TSC e SAMG evaluator Technical TSC
• SAMG evaluator Duties and responsibilities do notSupport 9 Directs the engineering staff Support
• Directs the engineering staff change. The wording of theseSupervisor in the performance of technical Supervisor in the performance of technical duties may differ from previousassessments of the emergency assessments of the emergency revisions, but are maintained in theand the assistance in recovery and the assistance in recovery plan and implementing procedures.

% NUREG 0654 Table B-1

• NUREG 0654 Table B-1 Additional details of theseFunctional Area -Plant System Functional Area -Plant System responsibilities were added toEngineering, Repair, and Engineering, Repair, and properly identify the position's Corrective Actions (Technical Corrective Actions (Technical emergency role. No additional Support)

Support) duties have been added.None N/A N/A Technical TSC 9 Transmits and receives This position has been added toSupport technical information or the ERO to ensure engineering Communicator engineering decisions or resources are available forrequest to the EOF, OSC, or assessment and evaluation, but notJIC delayed by communicating with* NUREG 0654 Table B-1 other facilities. Functional Area -Notification and Communications (PlantStatus)None N/A N/A Security TSC

• Manages the Security The Supervisor's title was changedManager Force actions and support and the position was relocated to0 Physical Security and the TSC. This provides a securityaccess control decision maker with all otheremergency response decisionmakers.None N/A N/A Maintenance TSC
• Supervises Maintenance The Supervisor position was addedSupervisor personnel to the emergency plan to ensure* Assist in mitigation proper oversight and commandevaluations and repairs for and control were in place formechanical, electrical, and I&C maintenance activities.

None N/A N/A Chemistry TSC

• Supervises chemistry The Supervisor position was addedSupervisor sampling and analyses to the emergency plan to ensure* Directs extent and nature of proper oversight and commandand control were in place for Document Control DeskAttachment IIILAR-13-02396 RC-14-0039 Page 41 of 61Rev 63 ERO Rev 63 Rev 63 Submittal ERO Submittal Submittal CommentsPosition Titles' Facility Responsibilities Position Titles1 Facility Responsibilities radiological and chemistry chemistry activities actionsOperations TSC
• Determines the extent of Operations TSC 0 Determines the extent of Duties and responsibilities do notSupervisor the emergency and Supervisor the emergency and change. The wording of theserecommends corrective actions recommends corrective actions duties may differ from previous* Provide technical 0 Provide technical revisions, but are maintained in theassistance to the Shift assistance to the Shift plan and implementing procedures.

Supervisor Supervisor

• NUREG 0654 Table B-1
• NUREG 0654 Table B-1Functional Area -Plant System Functional Area -Plant SystemEngineering, Repair, and Engineering, Repair, andCorrective Actions (Technical Corrective Actions (Technical Support)

Support)Radiological TSC

• NUREG 0654 Table B-1 Radiological TSC 9 NUREG 0654 Table B-1 Duties and responsibilities do notAssessment Functional Area -Radiological Assessment Functional Area -Radiological change. The wording of theseSupervisor Assessment and Support Of Supervisor Assessment and Support Of duties may differ from previousOperational Accident Operational Accident revisions, but are maintained in theAssessment; HP Supervisor Assessment; HP Supervisor plan and implementing procedures.
• Supervises activities for Additional details of theseonsite radiological responsibilities were added toassessments.

properly identify the position's emergency role. No additional duties have been added.None N/A N/A ENS TSC

• Provide updates and Added this position to formalize theCommunicator respond to inquiries from the support of the NRC telephone line.NRC* NUREG 0654 Table B-1Functional Area -Notification and Communications (PlantStatus)Core Thermal TSC
• Evaluate damage Core Thermal TSC
• Evaluate damage Duties and responsibilities do notEngineer assessment reports Engineer assessment reports change. The wording of these* Support mitigation 0 Support mitigation duties may differ from previousrecommendations, strategies, recommendations, strategies, revisions, but are maintained in theand procedure development and procedure development plan and implementing procedures.

% NUREG 0654 Table B-1

• NUREG 0654 Table B-1 Additional details of theseFunctional Area -Plant System Functional Area -Plant System responsibilities were added toEngineering, Repair, and Engineering, Repair, and properly identify the position's Corrective Actions (Technical Corrective Actions (Technical emergency role. No additional Document Control DeskAttachment IIILAR-1 3-02396RC-14-0039 Page 42 of 61Rev 63 ERO Rev 63 Rev 63 Submittal ERO Submittal Submittal CommentsPosition Titles1 Facility Responsibilities Position Titles' Facility Responsibilities Support)

Support) duties have been added.Electrical TSC 0 Evaluate damage Electrical TSC 0 Evaluate damage Duties and responsibilities do notEngineer assessment reports Engineer assessment reports change. The wording of these* Support mitigation

• Support mitigation duties may differ from previousrecommendations, strategies, recommendations, strategies, revisions, but are maintained in theand procedure development and procedure development plan and implementing procedures.
• NUREG 0654 Table B-1 a NUREG 0654 Table B-1 Additional details of theseFunctional Area -Plant System Functional Area -Plant System responsibilities were added toEngineering, Repair, and Engineering, Repair, and properly identify the position's Corrective Actions (Technical Corrective Actions (Technical emergency role. No additional Support)

Support) duties have been added.Mechanical TSC

• Evaluate damage Mechanical TSC
• Evaluate damage Duties and responsibilities do notEngineer assessment reports Engineer assessment reports change. The wording of these* Support mitigation
• Support mitigation duties may differ from previousrecommendations, strategies, recommendations, strategies, revisions, but are maintained in theand procedure development and procedure development plan and implementing procedures.

% NUREG 0654 Table B-1

• NUREG 0654 Table B-1 Additional details of theseFunctional Area -Plant System Functional Area -Plant System responsibilities were added toEngineering, Repair, and Engineering, Repair, and properly identify the position's Corrective Actions (Technical Corrective Actions (Technical emergency role. No additional Support)

Support) duties have been added.State/County TSC

• Notification of station None N/A N/A Communications will no longer beCommunicator personnel, state agencies, transferred to the TSC.county agencies, and the NRC Communications will transfer from* NUREG 0654 Table B-1 the Control Room directly to theFunctional Area -Notification

& EOF.Communication; Emergency Communications OSC Supervisor OSC 0 Manages the activities of OSC Supervisor OSC

• Manages the activities of Duties and responsibilities do notthe OSC the OSC change. The wording of these0 Implements mitigation
• Implements mitigation duties may differ from previousstrategies and procedures strategies and procedures revisions, but are maintained in the* NUREG 0654 Table B-1
• NUREG 0654 Table B-1 plan and implementing procedures.

Functional Area -Plant System Functional Area -Plant SystemEngineering, Repair, and Engineering, Repair, and Document Control DeskAttachment IIILAR-1 3-02396RC-14-0039 Page 43 of 61Rev 63 ERO Rev 63 Rev 63 Submittal ERO Submittal Submittal CommentsPosition Titles' Facility Responsibilities Position Titles' Facility Responsibilities Corrective Actions (Repair and Corrective Actions (Repair andCorrective Actions) Corrective Actions)Damage Control OSC

• Implements mitigation Damage Control OSC
• Implements mitigation Duties and responsibilities do not-Health strategies and procedures

-Health Physics strategies and procedures change. The wording of thesePhysics

• Performs plant radiological
• Performs plant radiological duties may differ from previousevaluations evaluations revisions, but are maintained in the* Post radiological conditions
• Post radiological conditions plan and implementing procedures.
• NUREG 0654 Table B-1
• NUREG 0654 Table B-1Functional Area -Radiological Functional Area -Radiological Assessment and Support of Assessment and Support ofOperational Accident Operational AccidentAssessment (Offsite Dose Assessment (Offsite DoseAssessment)

Assessment)

• NUREG 0654 Table B-1 0 NUREG 0654 Table B-1Functional Area -Radiological Functional Area -Radiological Assessment and Support of Assessment and Support ofOperational Accident Operational AccidentAssessment (Onsite Assessment (OnsiteRadiological Monitoring)

Radiological Monitoring) % NUREG 0654 Table B-1

• NUREG 0654 Table B-1Functional Area -Radiological Functional Area -Radiological Assessment and Support of Assessment and Support ofOperational Accident Operational AccidentAssessment (In-plant Surveys)

Assessment (In-plant Surveys)* NUREG 0654 Table B-1 0 NUREG 0654 Table B-1Functional Area -Plant System Functional Area -Plant SystemEngineering, Repair, and Engineering, Repair, andCorrective Actions (Repair and Corrective Actions (Repair andCorrective Actions) Corrective Actions)* NUREG 0654 Table B-1

• NUREG 0654 Table B-1Functional Area -In-plant Functional Area -In-plantProtective Actions (Radiation Protective Actions (Radiation Protection)

Protection) Damage Control OSC

• Implements mitigation Damage Control OSC 0 Implements mitigation Duties and responsibilities do not-Mechanical strategies and procedures

-Mechanical strategies and procedures change. The wording of these* NUREG 0654 Table B-1 0 NUREG 0654 Table B-1 duties may differ from previousFunctional Area -Plant System Functional Area -Plant System revisions, but are maintained in theEngineering, Repair, and Engineering, Repair, and plan and implementing procedures. Corrective Actions (Repair and Corrective Actions (Repair and Document Control DeskAttachment IIILAR-13-02396 RC-14-0039 Page 44 of 61Rev 63 ERO Rev 63 Rev 63 Submittal ERO Submittal Submittal CommentsPosition Titles1 Facility Responsibilities Position Titles' Facility Responsibilities Corrective Actions) Corrective Actions)Damage Control OSC 0 Implements mitigation Damage Control OSC 0 Implements mitigation Duties and responsibilities do not-Electrical strategies and procedures -Electrical strategies and procedures change. The wording of these* NUREG 0654 Table B-1 0 NUREG 0654 Table B-1 duties may differ from previousFunctional Area -Plant System Functional Area -Plant System revisions, but are maintained in theEngineering, Repair, and Engineering, Repair, and plan and implementing procedures. Corrective Actions (Repair and Corrective Actions (Repair andCorrective Actions) Corrective Actions)Damage Control OSC

• Implements mitigation Damage Control OSC 0 Implements mitigation Duties and responsibilities do not-I&C strategies and procedures

-I&C strategies and procedures change. The wording of these% NUREG 0654 Table B-1

• NUREG 0654 Table B-1 duties may differ from previousFunctional Area -Plant System Functional Area -Plant System revisions, but are maintained in theEngineering, Repair, and Engineering, Repair, and plan and implementing procedures.

Corrective Actions (Repair and Corrective Actions (Repair andCorrective Actions) Corrective Actions)Damage Control OSC

• Implements mitigation Damage Control OSC 0 Implements mitigation Duties and responsibilities do not-Chemistry strategies and procedures

-Chemistry strategies and procedures change. The wording of these* NUREG 0654 Table B-1

• NUREG 0654 Table B-1 duties may differ from previousFunctional Area -Radiological Functional Area -Radiological revisions, but are maintained in theAssessment and Support of Assessment and Support of plan and implementing procedures.

Operational Accident Operational AccidentAssessment (Chemistry) Assessment (Chemistry) Damage Control OSC 0 Implements mitigation Damage Control OSC 0 Implements mitigation Duties and responsibilities do not-Operations strategies and procedures -Operations strategies and procedures change. The wording of theseduties may differ from previousrevisions, but are maintained in theplan and implementing procedures. Security OSC

• Physical security of the Security TSC
• Physical security of the Overall control of the SecuritySupervisor plant Manager plant Force was transferred to the* Access control of the plant 0 Access control of the plant Security Manager in the TSC. Seeprotected area and vital areas protected area and vital areas the Security Manager position formore details.Plant OSC
• Manage OSC radiological Health Physics OSC
• Manage OSC radiological The title was changed, but dutiesRadiological response and monitoring Specialist response and monitoring and responsibilities do not change.Monitoring
• NUREG 0654 Table B-1
• NUREG 0654 Table B-1 The wording of these duties mayDirector Functional Area -Radiological Functional Area -Radiological differ from previous revisions, butAssessment and Support of Assessment and Support of are maintained in the plan andOperational Accident Operational Accident implementing procedures.

ThisAssessment (HP Supervisory) Assessment (HP Supervisory) position is a shift position or may Document Control DeskAttachment IIILAR-13-02396 RC-14-0039 Page 45 of 61Rev 63 ERO Rev 63 Rev 63 Submittal ERO Submittal Submittal CommentsPosition Titles1 Facility Responsibilities Position Titles' Facility Responsibilities be filled by qualified personnel fromthe augmented ERO.Emergency EOF

• Overall command and Emergency EOF
• Overall command and Duties and responsibilities do notControl Officer control Control Officer control change. The wording of these* Company Spokesperson
• Company Spokesperson duties may differ from previous* Approve press releases
• Approve press releases revisions, but are maintained in the* Update and inform offsite e Update and inform offsite plan and implementing procedures.

agencies agencies* Manage requests for

• Manage requests forassistance from offsite assistance from offsiteorganizations/vendors organizations/vendors
• NUREG 0654 Table B-1
• NUREG 0654 Table B-1Functional Area -Emergency Functional Area -Emergency Direction and Control Direction and Control(Command and Control)

(Command and Control)Offsite EOF 9 Direct and coordinate Offsite EOF

• Direct and coordinate The title was changed, but dutiesEmergency activation and response of the Emergency activation and response of the and responsibilities do not change.Coordinator EOF Manager EOF The wording of these duties may; PAR assessment,
• PAR assessment, differ from previous revisions, butdetermination, and notification determination, and notification are maintained in the plan and* Preparing state and county 9 Preparing state and county implementing procedures.

notification forms notification forms* Communicate with offsite

• Communicate with offsiteagencies on emergency agencies on emergency updates updates* NUREG 0654 Table B-1
• NUREG 0654 Table B-1Functional Area -Emergency Functional Area -Emergency Direction and Control Direction and Control(Command and Control)

(Command and Control)* NUREG 0654 Table B-1

• NUREG 0654 Table B-1Functional Area -Notification Functional Area -Notification and Communications and Communications (Emergency Communications)

(Emergency Communications) Technical EOF 0 Provides technical Plant EOF 0 Provides technical support The Title has changed andSupport information and engineering Engineering and communications for the responsibilities changed to PlantCoordinator support regarding the Advisor EOF and technical support for Engineering

Advisor, who will noemergency to the EOF staff press release development and longer manage Engineering or* NUREG 0654 Table B-1 State and County Liaisons support personnel in the EOF. The Document Control DeskAttachment IIILAR-1 3-02396RC-14-0039 Page 46 of 61Rev 63 ERO Rev 63 Rev 63 Submittal ERO Submittal Submittal CommentsPosition Titles1 Facility Responsibilities Position Titles' Facility Responsibilities Functional Area -Notification

• NUREG 0654 Table B-1 Advisor will provide engineering and Communication (Plant Functional Area -Notification assistance to the EOF decisionStatus) and Communications (Plant makers and offsite agencies.

Status) These responsibilities will berelocated to the TSC.Offsite EOF

• Directs radiological Offsite EOF
• Directs radiological Duties and responsibilities do notRadiological assessment for offsite environs Radiological assessment for offsite environs change. The wording of theseMonitoring
• Directs radiological dose Monitoring 0 Directs radiological dose duties may differ from previousCoordinator projections Coordinator projections revisions, but are maintained in the* Recommends PARs 0 Recommends PARs plan and implementing procedures.
• NUREG 0654 Table B-1
• NUREG 0654 Table B-1Functional Area -Radiological Functional Area -Radiological Assessment and Support of Assessment and Support ofOperational Accident Operational AccidentAssessment (Offsite Dose Assessment (Offsite DoseAssessment)

Assessment) Dose Assessor EOF & Develops radiological dose Dose Assessor EOF a Develops radiological dose Duties and responsibilities do notassessments assessments change. The wording of these* NUREG 0654 Table B-1

• NUREG 0654 Table B-1 duties may differ from previousFunctional Area -Radiological Functional Area -Radiological revisions, but are maintained in theAssessment and Support of Assessment and Support of plan and implementing procedures.

Operational Accident Operational AccidentAssessment (Offsite Dose Assessment (Offsite DoseAssessment) Assessment) None n/a n/a Communications EOF 0 Creates ENFs New position to coordinate allCoordinator

• Ensures notifications of the offsite emergency notifications.

emergency are made to offsiteagencies by S/CCommunicators 0 Provides updates for offsiteresponses to the ECO and OECState/County EOF

• Make and receive phone State/County EOF 0 Make and receive phone Duties and responsibilities do notCommunicators calls to and from offsite Communicators calls to and from offsite change. The wording of theseemergency agencies emergency agencies duties may differ from previous* Support activation of the
• Support activation of the revisions, but are maintained in theANS ANS plan and implementing procedures.
• Monitor offsite agency 0 Monitor offsite agencyactions actions Document Control DeskAttachment IIILAR-13-02396 RC-14-0039 Page 47 of 61Rev 63 ERO Rev 63 Rev 63 Submittal ERO Submittal Submittal CommentsPosition Titles1 Facility Responsibilities Position Titles' Facility Responsibilities

NUREG 0654 Table B-1

• NUREG 0654 Table B-1Functional Area -Notification Functional Area -Notification and Communications and Communications (Emergency Communications)

(Emergency Communications) Security EOF 0 Maintaining EOF security Plant Security EOF 0 Maintaining EOF security The title was changed, but dutiesCoordinator 0 Interact with local law Advisor 0 Interact with local law and responsibilities do not change.enforcement officials enforcement officials The wording of these duties may* Badging and screening 0 Badging and screening differ from previous revisions, butactivities activities are maintained in the plan andimplementing procedures. None n/a n/a HPN EOF

• Provide updates and Added this position to formalize theCommunicator respond to inquiries from the support of the NRC telephone line.NRC* NUREG 0654 Table B-1Functional Area -Notification and Communications (PlantStatus)Field Teams EOF
• Survey and sample Field Teams EOF 0 Survey and sample The positions of Field Teams haveradiological conditions within radiological conditions within always been identified in thethe EPZ the EPZ Emergency Plan staffing tables butNUREG 0654 Table B-1
• NUREG 0654 Table B-1 has not had a formal description ofFunctional Area -Radiological Functional Area -Radiological responsibilities.

This changeAssessment and Support of Assessment and Support of formalizes these as part of theOperational Accident Operational Accident overall emergency response andAssessment (Offsite Assessment (Offsite staffing. Radiological Monitoring) Radiological Monitoring) General EOF

• Procurement and receipt of None N/A N/A Removed from the Emergency Services items Plan, but the function is beingCoordinator 0 Support services such as maintained in the implementing typing and reproduction procedures.

services, supplies, personnel accommodations, temporary offsite facilities, communications, and mealsCompany JIC

• Manages the development, Company JIC
• Manages the development, The title was changed to allowSpokesperson review, and approval of media Spokesperson review, and approval of media designated manager within SCANA(ECO) related messages related messages or SCE&G to act in behalf of the* Directs the public
• Directs the public company.information emergency information emergency Document Control DeskAttachment IIILAR-1 3-02396RC-14-0039 Page 48 of 61Rev 63 ERO Rev 63 Rev 63 Submittal ERO Submittal Submittal CommentsPosition Titles1 Facility Responsibilities Position Titles1 Facility Responsibilities response personnel response personnel JIC Coordinator JIC 0 Manages the operability of JIC Coordinator JIC 0 Manages the operability of Duties and responsibilities do notthe JIC the JIC change. The wording of theseduties may differ from previousrevisions, but are maintained in theplan and implementing procedures.

Media JIC

• Interfaces and monitors the Media JIC
• Interfaces and monitors the Duties and responsibilities do notCoordinator media while the JIC is Coordinator media while the JIC is change. The wording of theseoperational operational duties may differ from previousrevisions, but are maintained in theplan and implementing procedures.

Lead Technical JIC

• Assists in the technical None N/A N/A This responsibility is beingBriefer development of media reassigned to the Technical messages Support Advisor in the EOF.

Document Control DeskAttachment IIILAR-13-02396 RC-14-0039 Page 49 of 61Required Staffing Summary Tables (VCS Unit I ONLY)SER Revision 5Position On-shift 30 Min 60 MinShift Supervisor (SRO) 1Shift Foreman (SRO) 1Control Room Operators 2Auxiliary Operators 2Communicator 1 1 2General Manager Nuclear Operations 1Health Physics & Environmental 1Coordinator HP Specialist 1,1(**) 3 4HP Specialist -offsite surveys 2(*) 2Chemistry 1(* 1Shift Technical Advisor 1Core Thermal Engineer 1Electrical Engineer 1Mechanical Engineer 1Mechanical Maintenance 1 1Electrical Maintenance 1 2I&C Technician 1 1(*) 1* -For each unaffected nuclear unit in operation, maintain at least one shift foreman, one control room operator and one auxiliary operator except that units sharinga control room may share a shift foreman if all functions are covered** -Performed by shift personnel indicated under In-plant surveys Document Control DeskAttachment IIILAR-13-02396 RC-14-0039 Page 50 of 61Current -Rev 63 ProposedPosition On-shift 30 Min 60 Min of 60 Min of SAE or Position On-shift 75 Min of Alert, SAE,Alert, SAE, GE (EOF) or GEor GE (TSC (TSC, OSC, & EOF)& OSC)Shift Supervisor/Interim 1 Shift Supervisor/Interim 1Emergency Director Emergency DirectorControl Room Supervisor 1 Control Room Supervisor 1Reactor Operators 2 Reactor Operators 2Auxiliary Operators 5 Auxiliary Operators 5Emergency Director 1 Emergency Director 1Offsite Emergency Coordinator 1 Offsite Emergency Manager 1State/County Communicator (CR, 1 1 1 State/County Communicator (CR, 1 1TSC, EOF) EOF)ENS Communicator (CR/TSC) 1 ENS Communicator (CR, TSC) 1HP Specialist 1 5 5 HP Specialist 1 10Offsite Radiological Mon. Coor. 1 Offsite Radiological Mon. Coor. 1Dose Assessor/HP Specialist 1 1 Dose Assessor/HP Specialist 1 1Field Teams (Driver & HP) 1(h) 1 Field Teams (Driver & HP) 2Chemistry 1 1 Chemistry 1 1Plant Radiological Monitoring Dir. 1 HP Specialist 1Radiological Assessment 1 Radiological Assessment 1Supervisor Supervisor Shift Engineer I Shift Engineer 1Operations Supervisor 1 Operations Supervisor 1Technical Support Supervisor 1 Technical Support Supervisor 1Core Thermal Engineer 1(e) 1 Core Thermal Engineer (Shift Eng.) 1Electrical Engineer 1 Electrical Engineer 1Mechanical Engineer 1 Mechanical Engineer 1Mechanical Maint. 2 1 Mechanical Maint. 2 1Electrical Maint. 1 1 1 Electrical Maint. 2 1I&C Maint. 1 1(h) 1 I&C Maint. 2 1OSC Supervisor 1 OSC Supervisor 1N/A N/A N/A N/A N/A Technical Support Communicator 1N/A N/A N/A N/A N/A Emergency Support Operator 1N/A N/A N/A N/A N/A Maintenance Supervisor 1N/A N/A N/A N/A N/A Chemistry Supervisor 1 Document Control DeskAttachment IIILAR-13-02396 RC-14-0039 Page 51 of 61Current -Rev 63 ProposedPosition On-shift 30 Min 60 Min of 60 Min of SAE or Position On-shift 75 Min of Alert, SAE,Alert, SAE, GE (EOF) or GEor GE (TSC (TSC, OSC, & EOF)& OSC)Damage Control -Op (Aux Ops) Damage Control -Op (Aux Ops)Security Supervisor 1 (OSC) Security Manager 1 (TSC)Emergency Control Officer 1 Emergency Control Officer 1Technical Support Coordinator 1 Plant Engineering Advisor 1N/A N/A N/A N/A N/A Plant Operations Advisor 1N/A N/A N/A N/A N/A Communications Coordinator 1Security Coordinator 1 Plant Security Advisor 1Security Force Per Security Plan Security Force Per Security PlanN/A N/A N/A N/A N/A HPN Communicator 1General Services Coor. 1 N/A N/A N/ACompany Spokesperson 1 (*when activated) Company Spokesperson 1*JIC Coordinator 1* JIC Coordinator 1*Media Coordinator 1* Media Coordinator 1*Lead Technical Briefer 1* N/A N/A N/Ae- May be provided by shift personnel assigned other functions h- Actual response time is 40 mins Document Control DeskAttachment IllLAR-13-02396 RC-14-0039 Page 52 of 61Enclosure C, Activation Time Change Justification/Evaluation Justification: NUREG-0654 Part II Section A states that "Each principal organization shall be capable ofcontinuous (24-hr) operations for a protracted period..."; Section B states that "each licensee shall identifya line of succession for the emergency coordinator position and identify the specific conditions for higherlevel utility officials assuming this function." and "...The licensee must be able to augment on-shiftcapabilities within a short period after declaration of an emergency...". It further defines that short periodas 30 and 60 minutes.VCS Unit 1 has conducted an On-shift Staffing Analysis to demonstrate and confirm all emergency functions will and can be assigned and maintained by on-shift personnel, until augmented by the ERO.The Staffing Analysis evaluated personnel and response for the first 90 minutes of an emergency, withexception of 30 (40) minute responding positions. VCS has adequately staffed its on-shift personnel tosupport the Control Room personnel upon declaration of an Alert or higher classification. This staffing willfulfill the NUREG-0654 Criterion ll.B.5 for most 30-minute responders and provides additional support tothe on-shift ERO. Additional support is provided to the on-shift ERO within a 75 minute response timewith on-call ERO personnel. The time frames for rapid augmentation of a nuclear power plant staff in theevent of an emergency are not regulatory requirements but rather commitments to times set by VCS.VCS will expend its best efforts to meet the augmentation criteria times regarding staffing Emergency Response Facilities with sufficiently skilled individuals capable of handling an emergency. Due to diversity of normal residential patterns for the stations' staff, possible adverse weather conditions, and roadcongestion, these time frames might be exceeded. All functions of the EOF, TSC, and OSC will bemaintained as described with enhancements and continues to meet the requirement of NUREG-0654, 10CFR 50.47(b), and 10 CFR 50 Appendix E. Due to advances in technologies such as computers, directtelephone links, plant data display systems, etc. and the augmentation of the emergency facilities at anAlert or higher classification, these enhancements will allow timelier responses to emergencies and theability to protect public health and safety.The change in activation times and at what classification the facilities will be activated support a timelyresponse of personnel. This will allow the EOF to activate in a timelier manner to remove criticalfunctions from the Control Room and to establish the overall emergency response leadership and supportteam along with activation of the TSC and OSC. The change in activation time will allow the TSC toactivate with its enhanced staffing and in its new location to remove critical functions from the ControlRoom and to establish the overall emergency response leadership and support team along with activation of the EOF and OSC.In addition to the proposed response time changes from 60 to 75 minutes, VCS is proposing a change tothe 30 minute response time for several ERO Health Physics Specialists and Field Monitoring Teampositions to a 75 minute response time. As referenced in Part 2 Section A.4, Continuous

Coverage, VCSwill rely on shift personnel from the unaffected Unit(s) to be available to support the coverage required forthese positions, until such time the augmented ERO can respond to take these duties. Part 2, SectionH.5, Activation, states the ERO augmentation process identified individuals who are capable of fulfilling the specific response function that are listed in Table B-la. This table was developed based on functions that are listed in Table B-1 of NUREG-0654/FEMA-REP-1.

VCS will use unaffected unit on-shiftpersonnel to augment the affected unit on-shift personnel upon declaration of an Alert or higherclassification. The staffing augmentation will fulfill the NUREG-0654/FEMA-REP-1, Criterion lI.B.5 for 30-minute responders and provides additional support to the on-shift ERO to permit a 75-minute responsefor on-call ERO personnel. Although the response time will vary due to factors such as weather andtraffic conditions, a time of 75 minutes for activation

staffing, following the notification of an Alert or higheremergency classification, has been established for the ERO personnel responding to the stationemergency facilities and the EOF ERO personnel.

VCS Units 1, 2, and 3 are physically located on the same property site. Each plant has designated minimum staffing, including Operations, Health Physics, Chemistry, Mechanical Maintenance, Electrical Maintenance, and I&C Maintenance personnel. The personnel from these disciplines on the unaffected unit(s) will be used to augment the affected unit(s) staffing to perform actions they are trained and Document Control DeskAttachment IIILAR-13-02396 RC-14-0039 Page 53 of 61qualified to perform, such as radiological accident assessment, repair and corrective

actions, search andrescue, chemistry/radiochemistry, etc. This staffing augmentation will fulfill the NUREG-0654 Criterion lI.B.5 for 30-minute responders and provides additional support to the on-shift ERO to permit a 75-minute response for on-call ERO personnel.

The time frames for rapid augmentation of nuclear power plant staffin the event of an emergency are not rigid regulatory requirements but rather administrative times set byVCSNS. It is VCS's intent to expend its best efforts to meet the augmentation criteria regarding staffingEmergency Response Facilities with sufficiently skilled individuals capable of handling an emergency. While Unit 3 is under construction, Units 1 and 2 will maintain the capability to augment affected unit shiftpersonnel. As VCS and the area around it continue to grow, increases in residential and transient populations at orimmediately adjacent to the site and within its EPZ have resulted in travel times increasing. Any increasein travel times without the corresponding relaxation in facility activation time increases the perceived pressure to achieve timeliness, with a potential for reduction in driving safety for individuals responding toan emergency. The change in response times also aligns the VCS Unit 1 emergency plan with the Units 2 & 3 COLemergency plan.Evaluation: The augmentation time of the ERO reduces the effectiveness of the emergency planand require prior approval by the NRC. The changes continue to meet the requirements of 10 CFR50.47 (b) and 10 CFR 50 Appendix E, see the Technical Evaluation Section 4.1 of the LARATTACHMENT I. Document Control DeskAttachment IIILAR-13-02396 RC-14-0039 Page 54 of 61Enclosure D, Technical Support Center Relocation Justification/Evaluation Justification: Function: Changes to the Emergency Response Organization are being proposed to alignfunctions with facilities. The Technical Support Center (TSC) will be aligned to be the overall responsible facility for onsite evaluations and mitigation strategy development and implementation. Changes to thestaffing of the TSC includes: position title changes, position reporting alignment, and position and facilityresponsibility changes. The ERO positions title changes and responsibility changes are detailed inEnclosure B, E-plan ERO Position Responsibility Change & Comparison, of this evaluation. The proposed TSC organization will continue to report to the Emergency Director. The function of theTSC will remain intact with exception of its state and county emergency communications staff. Thisfunction will be removed from the TSC and transferred directly from the Control Room to the EOF.Personnel affected by this change will be reassigned other positions within the ERO. This removes theoffsite interface function and allows the TSC to focus on onsite responses. The TSC will also bereorganized to include engineering functions supporting evaluation and mitigation of the emergency atVCS. A portion of the current EOF engineering staff used to support the TSC staff will be relocated intothe TSC creating one engineering organization focused on onsite evaluations and mitigation. Thisorganization will report to one Technical Support Supervisor. The new TSC facility is designed to meet the intent and requirements of NUREG-0696 "Functional Criteria for Emergency Response Facilities" and NUREG-0737 "Clarification of TMI [Three Mile Island]Action Plan Requirements". This location departs from the guidance in NUREG-0696 in three areas:1) that the TSC be located near the Control Room, 2) that the walking time from the TSC to the ControlRoom not exceed 2 minutes, and 3) that there be no major security barriers between the TSC and theControl Room. However, with vastly improved electronic communication capabilities and technologies, face to face interactions between TSC and Control Room personnel are no longer necessary to meet theintent of NUREG-0696 guidance. VCS drills are currently conducted in a manner that does not afford theface to face interactions, due to the Simulator being in the training

building, outside the Protected Area.Therefore, relocation of the TSC to the new NOB will not prevent VCS from meeting the intent of theguidance in NUREG-0696.

When activated, the TSC functions include:" Support for the affected Control Room's emergency response efforts" Continued evaluation of event classification

• Assessment of the plant status and potential offsite impact* Coordination of emergency response actions within the Protected Area (PA)* Communication with the NRC via ENS* Activation of the Emergency Response Data System (ERDS) or ensuring that it is activated Location:

VC Summer (VCS) has constructed a new Nuclear Operations Building (NOB) and within itsbasement is a proposed new Technical Support Center (TSC). The NOB and proposed TSC. will belocated outside of and southwest of the Unit 1 Protected Area and north of the Units 2 & 3 Protected Area. This location is approximately 1900 ft. from the Unit 1 Control Room located within the Protected Area. The separation of the TSC from the Control Room will be approximately 9 to 13 minutes (undernormal walking conditions and with normal plant populations) and includes processing time throughOwner Controlled Area and Protected Area Security Control Points.The VCS Emergency Plan describes extensive communications capabilities between the TSC and therespective unit control rooms, OSCs, EOF, and offsite EROs. These communications capabilities providea variety of methods to ensure reliable communications and compensate for the TSC being locatedoutside of the Protected Area. NUREG-0800 includes a statement that advanced communication capabilities may be used to satisfy the 2-minute travel time. In addition, having a common TSC that Document Control DeskAttachment IIILAR-13-02396 RC-14-0039 Page 55 of 61supports multiple reactor units and is located a moderate distance (i.e., more than 2 minutes) from theControl Room presents distinct advantages. These include the increased efficiency of a centralized pointof support for the entire site, the elimination of confusion regarding which TSC on a multiple-unit sitewould be staffed in an emergency, not having to staff multiple TSCs if an incident involved more than oneunit, and consideration of security-related events.During a radiological emergency requiring an emergency declaration, Security procedures and actionswill not inhibit access through the Owner Controlled or Protected Area hardware and access systems.Thus during travel, these systems have a negligible impact on access to the Control Room or otherportions of the plant. In the event of a hostile action, plant procedures provide guidance for theEmergency Response Organization (ERO) to activate utilizing alternate facilities, outside of potential hostile action areas, and provide procedure guidance for moving personnel under protective measures. Management interaction and technical information exchange will be done using plant computer andcommunications (telephone, radio, etc.) systems that provide means to directly contact the Control Roomand significantly minimizes the need to physically relocate a member of the TSC into the Control Room.The capabilities to review and evaluate technical data, such as plant parameter display information, procedural information, or plant drawings, are provided in the TSC from real-time systems which receivetheir inputs from the same sources as the Control Room, but communicate them on a different network.Relocation of the TSC will not change this configuration from its current set-up. The use of technology toaccess and evaluate these parameters significantly reduces the need for face-to-face interactions, asexpected in NUREG-0696. In the event that TSC personnel are to travel to the Control Room during a radiological release or if arelease is imminent, the TSC has storage capabilities for maintaining protective clothing and surveyinstruments that will be needed to ensure dose received during travel is ALARA. The location of the TSCalso affords the opportunity to use multiple routes to reach the Control Room and will be selected tominimize exposure to a potential plume or release path.Staffing and Training: The TSC will be designed to support an emergency for VCS Unit 1 and in thefuture Units 2 and 3 or any combination thereof. Fully staffed with required personnel, the TSC will hostthirty-two ERO positions, including three NRC Residents. The new facility will strengthen the ERO bycreating a centralized onsite command and control organization and a single evaluation and mitigation decision structure for the entire site. This organization will have access to and can evaluate emergency conditions for Unit 1, Unit 2, or Unit 3 using plant computer systems to provide operational parameters and meteorological data. The centralized organization structure can maintain communications with theControl Room(s), the Operational Support Center(s), and the Emergency Operations Facility. Thischange will also strengthen the TSC command and control function by allowing the TSC Emergency Response Organization (ERO) a larger, better designed working area.The Nuclear Operations Building upper floors house Engineering, Site Management, and other plantorganizations and personnel assigned to the ERO to augment Shift Staffing in an emergency. This isexpected to facilitate the activation of the TSC, thus improving the timeliness of taking critical tasks fromthe Control Room staff and having the staff in place to initiate evaluations and mitigation development. This location also provides for improved off-hours staffing capabilities since responders will not have toprocess through Owner Controlled or Protected Area Security access locations to reach the TSC. Therelocation of the TSC will make activation timelier and improve the capability for transfer of critical tasksfrom the Control Room. The relocation of the TSC allows activation of and access to the TSC during asecurity event more practical and timely by not relocating personnel into an area where the hostile actionmay be directed. The TSC being located in the basement provides structural security and access to thefacility is controlled by security measures. Overall the staffing of the TSC will change from its current roles and responsibilities. The staffing of theTSC will be changed to include most ERO engineering functions and to remove offsite communication responsibilities. The engineering staff currently reporting to the EOF will be relocated to provide direct Document Control DeskAttachment IIILAR-13-02396 RC-14-0039 Page 56 of 61support to the Reactor, Mechanical, and Electrical disciplines. The offsite communications will betransferred directly from the control room to the EOF and no longer be a responsibility of the TSC.ERO Training will be maintained as it is currently required by the emergency plan and implementing procedures. Currently the training provided during participation in emergency drills is conducted with theTSC in the Unit 1 Control Building (adjacent to the actual Control Room) and the Control Room Simulator located in the Nuclear Learning Center. Personnel training specific to their task will be modified toincorporate changes based on the relocation of the TSC and the new work station arrangements andchanged responsibilities. Size: The TSC work space will increase from the current Unit 1 TSC space of approximately 2,500 sq ftto approximately 14,300 total sq ft, supporting all three units. The command area and adjacent workareas total approximately 7,000 sq ft of working space. This provides more than adequate spacing,versus the 75 sq ft/person required in NUREG-0696. The TSC will be designed around a centralcommand center with partitioned work spaces on its perimeter for designated support groups. Each workspace has full viewing of the command area through glass store front partition walls. The facility(basement) also includes restrooms with shower facilities, a break room (refrigeration, ice and beverage, and serving areas), storage areas, and communications/network, A/V, copier/printer, electrical, andmechanical rooms supporting only the TSC area. A designated boundary has been established to helpensure the TSC portions of the basement are protected within the HVAC/Recirculation-Filtration envelop.The new facility will provide more and larger individual work spaces and designated areas for workdisciplines and conferences as compared to the existing TSC. The command area will increase from ninework stations to twenty-two work stations. The engineering area will expand from two shared workspaces to eleven work stations. The facility will also include two separate work areas that will supportthree work stations, each. The TSC will also include a designated NRC support area which expands fromone work space to five and a conference area, both directly adjacent to the command area and separated by a glass partition wall. The TSC will include a back-up Operational Support Center (OSC), if needed, inan adjacent work area with twelve work stations and a large command style table in the center. This areais separated from the command area by glass partition walls. If not needed for an OSC; it can be utilizedby the TSC staff in the response to an emergency. With larger work areas, more technology (computers and telephones) will be available to the TSCpersonnel to perform their duties. Telephone and computer availability will be increased to allow morecapability of information management and evaluation. The new TSC will allow the personnel to accessplant data, drawings, procedures, and other computer applications more timely and effectively from eachwork station. Technology in the new TSC will also include multiple overhead projection

systems, largescreen displays, teleconferencing, real time system monitoring through plant computer

networks, andradio, Public Branch Exchange, and satellite phone communications.

Structure: The TSC will be located in the basement of the Nuclear Operations

Building, below two upperstructural floors which are designed and constructed to the 2006 International Building Code. Access tothe TSC will be controlled through two direct points of ingress/egress, on the north and south ends of thebasement (central and south portions of the NOB, respectively).

These points do not open directly to theexterior of the building, but are accessed through stairways or elevators from the upper floors. Control ofpersonnel entering will be done using access card readers connected to site security access controlcomputers. The NOB is located within the Exclusion Area of the site which is patrolled and controlled byonsite security forces.The basement of the NOB, where the TSC will be housed, is constructed of 10-12 inch thick concreteretaining walls and is submerged 16' below finished exterior grade. The floor structure of the NOB aboveforms a cap above the space. This cap is constructed of a composite beam and concrete slabconstruction. The TSC as well as the NOB structure above are fully sprinklered and constructed withnon-combustible construction. The superstructure of the facility is designed for IBC site class D, designcategory C, Business occupancy category I1. The basement ceiling systems, mechanical

ductwork, plumbing piping, sprinkler piping, and electrical systems are seismically braced throughout the TSC.

Document Control DeskAttachment IIILAR-13-02396 RC-14-0039 Page 57 of 61Habitability: The TSC is designed to meet the protected envelope functional requirements for habitability and ventilation similar to the Control Room as identified in NUREG-0696 and Section ll.B.2 of NUREG-0737. The HVAC system is designed with High Efficiency Particulate Air filters and charcoal filters with amixed air capability from both inside the facility and exterior. The system when placed in emergency mode, via a designated button in the TSC command area, closes specified motorized

dampers, disablesEF-1 (rest rooms exhaust fan), and energizes FFU-1 (filtered HVAC). Once this takes place the TSCpressurizes to a minimum of 0.125 inwc. An alarm panel is located within the command area of the TSCthat will alert personnel of a change in pressurization which causes the positive pressure to fall below0.125 in.The HVAC design includes the following:

The mechanical ventilation for the TSC area is currently designed to provide 4000 cfm of outside air priorto isolation and during isolation to achieve a 0.125" positive pressure. A total of 4000 cfm will be filteredwith charcoal and HEPA filtration during isolation. 3200 cfm of the 4000 cfm will be outside air and theremaining 800 cfm of the 4000 cfm filtered air will be recirculated from the TSC area.During the normal mode of operation, the system will provide conditioned airflow to the terminal boxesserving the spaces. As the space temperatures are satisfied, the dampers on the boxes will start to closetherefore causing the supply fan on AHU-0-1 to slow down. The speed of the supply fan (on AHU-0-1)will vary depending on the building load. The return air damper shall modulate to maintain a positivepressure differential between the TSC boundary area and the outdoors. A pressure monitor is located inthe TSC to provide positive pressure verification. The TSC area will enter into emergency mode upon activation from a push button located in the TSC dueto a radiological release or imminent release. When the system is in emergency mode, the dampers inthe 26 x 16 outside air duct will close and the damper in the 18 x 18 outside air duct and 14" return willopen. These two ducts (18 x 18 and 14" diameter) feed into the back of FFU-1. FFU-1 will energize andprovide 4000 cfm of filtered fresh air into the back of AHU-0-1. The sequence of AHU-0-1 will be thesame as if the unit were in normal mode of operation. The return damper in the TSC will modulate tomaintain a positive pressure differential between the TSC boundary area and the outdoors. FFU-1 hasMERV 8 pre-filters, MERV 15 charcoal

filters, and MERV 16 final filters.1. TSC ventilation air inlet and recirculation flow rates -The system design provides 3200 cfm ofoutside air make-up (unfiltered) to the TSC prior to isolation, after isolation 3200 cfm (filtered).

Anadditional 800 cfm of air is recirculated through the charcoal cleanup unit.2. HEPA filter and charcoal absorber fission product removal efficiencies -The system provides99% removal efficiency for particulates and 90% decontamination efficiency for radioiodine.

3. TSC unfiltered air in-leakage rate -The in-leakage assumed for the TSC dose calculation is 500cfm of unfiltered air after isolation.

4. Atmospheric dispersion factors (X/Q values) at TSC air intake -The X/Q values at the TSC airintake are as follows, with the release assumed at ground level from the location of the plant vent.These values which bound the containment shell ground level release are calculated usingARCON96 based on two years of meteorological data:0-2 hr 2.33E-05 sec/m32 -8 hr 1.84E-05 sec/m38 -24 hr 7.65E-06 sec/m324 -96 hr 6.00E-06 sec/m396 -720 hr 4.58E-06 sec/m35. TSC occupancy factors -The standard Control Room occupancy factors from Section 4.2.6 ofRegulatory Guide 1.183, July 2000, are assumed for the TSC:0-24 hr 1.0 (100%)24 -96 hr0.6 (60%)

Document Control DeskAttachment IIILAR-1 3-02396RC-14-0039 Page 58 of 6196 -720 hr 0.4 (40%)6. TSC free air volume -The TSC design is approximately 72' by 130', with an additional 14' by 40'area provided as a potential eating area. The floor area does not include those vestibule areasthat function as air locks between stairways and the TSC, but do include areas that contain theventilation system fans and filter plenums. The floor to ceiling height is 14.5'. These dimensions provide a volume of 143,840 ft3 for the dose evaluation of the facility. The TSC free air volumewill be no greater than 143,840 ft3.7. Occupant breathing rate -The breathing rate of 3.5E-4 m3/sec for the TSC occupant is assumedfor the duration of the accident. This rate is consistent with that for the control room operator inSection 4.2.6 of Regulatory Guide 1.183, July 2000.8. Description of the ventilation design -The ventilation design for the TSC is modeled after Figure 1of Regulatory Guide 1.52, Revision 3, June 2001, with minor deviations. Neither the moistureseparators nor the heater are expected to be required in the charcoal unit. The ventilation equipment will be located within the TSC ventilation

envelop, within a mechanical room.During normal operation the system functions as a normal ventilation system providing temperature

control, filtration, and some amount of outside air make-up.

During emergency recirculation conditions acharcoal absorber unit is placed in service. This unit is intended to provide filtration of part of the air beingrecirculated in the TSC as well as the outside air make-up for the TSC. During the emergency recirculation mode of operation the system maintains a 1/8" wc positive pressure in the TSC relative tooutside, by admitting 3000 cfm of outside air. This flow of 3000 cfm provides enough ventilation (filtered fresh air) for at least 100 people. The charcoal absorber unit filters an additional 800 cfm of air that isrecirculated from the TSC. There is also an unfiltered recirculation rate of 15,000 cfm, but this has nobearing on the radiological analysis. The HVAC system is not designed as Seismic Category I and is not provided with redundant fans, filters,or power supplies, as allowed by the NUREG-0696 requirements for the TSC. Each TSC entrance isprovided with a weather sealed doorway between stairways and the TSC.Exposure to direct radiation from a radiological release is negligible due to the TSC being located in thebasement and beneath the two upper floors of the NOB. Based on current Unit 1 TSC dose calculations and taking the conservative approach that the new TSC will be further away from the plant and in thebasement of the Nuclear Operations

Building, the expected dose rates and TEDE accumulated dose isexpected to be less than 5 Rem.Radiological monitoring will be provided using a portable Beta Continuous Air Monitor (CAM). Themonitor will be mounted on a portable cart and rolled into the hallway immediately adjacent to the TSCCommand Area and within the HVAC envelop.

The monitor will meet the follow specifications: Microprocessor-based central readout device, mated to a detection head with real timegamma background subtraction using two detectors 2 in. diameter sealed proportional Window: 2 to 3mg/cm2 micaRadial Sampling Head: 8.5% 6OCo, 17% 90Sr/90Y (nominal) Inline Sampling Head: 6.4% 85Kr, 4.4% 133Xe (nominal) Noble Gas Sampling Head: 5.75% 60Co, 12% 90Sr/90Y (nominal) Display Unit: 8.5 to 113L/min., 0.5 to 6.8 cfh (0.3 to 4.0 cfm)Pump: 56L/min. (2.0 cfm) nominal at STP with clean filterTwo rows x 20 characters high visibility vacuum fluorescent, percentage of Alarm 40-element LED bar graphFront panel lights display READY and MALFUNCTION conditions, red alarm strobe lightvisual warning, and sonalert audible warning Document Control DeskAttachment IIILAR-13-02396 RC-14-0039 Page 59 of 61Communications: The communication racks give the facility an independence from the remainder of thebuilding, but still maintain the capability to reroute, these functions through other servers or racks withinthe company to help ensure their availability. Additionally, the TSC will have radio and fiber opticcapabilities that can communicate with the Control Room, OSC, EOF, and offsite emergency

agencies, ifneeded.Network Transport (feeds to the building):

Two Network Transport feeds come to the TSC from AccessAuthorization Portal currently, which is also dual, redundantly fed from the corporate network. The systemwill be upgraded in the future to provide for two 10gig feeds, one from Fiber Hut (FH) 2 and the otherfrom FH5. FH2 and FH5 will have separate and diverse path 1Ogig feeds one to 1401 Main St (Columbia, SC) and the other to 24x7 data center (West Columbia, SC).Dual Independent Distribution switches (Transport connections and uplinks from Access switches): The 2transport feeds are connected to two distribution switches (DistSNOBA and DistSNOBB). Networkaccess switches (PC, printers, building security

systems, AV systems, building management

systems, IPphones, and IP radios connected to access switches) in the building have two uplinks to the distribution switches.

One uplink to the DistSNOBA and the other DistSNOBB .These are also linked together foradditional redundancy. Each distribution switch has dual power supplies. One power supply can run the switch. Both powersupplies are powered up and running at half capacity and are configured to take over should one of themfail or lose power. For each switch one power supply is connected to emergency power source and the2nd power supply is connected the building UPS system.Dual Access Switches: PC, printers, building security

systems, AV systems, building management

systems, IP Phones, and IP radios connected to access switches.

Due to the number of connection forecasted for the TSC, there are two access switches in the MTR. Every access switch in the buildinghas two uplinks that are directly fed to the distribution switches. In the MTR, there is a pair of accessswitches (SW1SNOBB and SW2SNOBB). Note: Devices (PC, printers. Etc.) have single connection toone or the other switch.Each access switch has two supervisor modules that hold the switches configuration and a single 10giguplink to a NOB distribution switch. One is active and the 2nd one is in standby mode. Should the activeone fail or have a problem, the second supervisor module takes over the management and operation ofthe switch.Each access switch has dual power supplies. One power supply can run the switch. Both powersupplies are powered up and running at half capacity and are configured to take over should one of themfail or lose power. For each switch one power supply is connected to emergency power source and the2nd power supply is connected the building UPS system.Note: Devices (PC, printers. Etc.) have single connection to one or the other switch. However as long asthe switch is powered up and running, one uplink to the distribution switch is lost there is still a paththrough the other distribution switch for continued connectivity. Instrumentation, Data System Equipment, and Power Supplies: A description of data systems isdescribed in the above section for Communications. The HVAC system is controlled by the Building Management system which provides system diagnosis and alarms to site facilities maintenance personnel. The facility has normal and emergency 480 volt power distribution equipment on the ground floorelevation which feed an automatic transfer switch (ATS) that supplies power to the building emergency power distribution panels. The main emergency power distribution panel feeds a 480 volt panel in thebasement (TSC) electrical room that feeds additional panels that supply power for lighting, HVACequipment, the uninterruptible power system (UPS) system, and other 480 volt loads. Step down Document Control DeskAttachment IIILAR-1 3-02396RC-14-0039 Page 60 of 61transformers are located in the basement to supply panels that feed receptacles and other 120 volt and208 volt loads.In the event of a loss of normal power the ATS will transfer to the emergency diesel generator. Thegenerator feeding the emergency power system is a 550 KW diesel engine generator with adequatecapacity to supply emergency power loads in the TSC as well as the other emergency loads in thebuilding. Lighting and HVAC systems in the TSC will be fed from the emergency power. 120 voltreceptacles are fed from emergency power panels and receptacles for critical equipment and computers are fed from the UPS system. The TSC emergency generator powers TSC loads and limited loads withinthe remaining Nuclear Operations Building (NOB) to allow access safely into the TSC. These loadsinclude, but are not limited to, emergency

lighting, elevator power, and security systems.Technical Data and Data System: A description of data systems is described in the above section forCommunications.

TSC Resource Comparison TableResource Current Facility Proposed FacilityERO Positions Assigned TSC -13 VCS, 6 NRC S -32V ,12N C wt BakTSC -32 VCS, 12 NRC with Back-up OSC --15 VCSSquare Footage (total) -2,500 -14,300Rest Rooms Facilities shared with Control Full men's and women's facilities Room for men and women with showersKitchenette shared with Break Area with tables and servingBreak/Serving Area Coto omarea, ice, water,' refrig, etc.aControl Room (cafeteria on 1st Floor NOB)Work Stations (total) 13 44Telephones (PBX) 13 44Telephones (Satellite) 1 1Telephone (Dedicated Lines) 1 1Radios Hand-helds only 10 desk top for dedicated positions and hand-helds Computers/Data Connections 13 32 with 9 in Back-up OSCProjctos (/V Sste) 25 with additional 15 A/V displayProjectors (A/V System) 2 capabilities in adjacent work areas-880 sq ft with 9 work stations andCk OC Ne xcommand tableNRC Area 8 x 8 cubicle 390 sq ft with 4 work stations andconference table Document Control DeskAttachment IIILAR-13-02396 RC-14-0039 Page 61 of 61Evaluation: Relocation of the Technical Support Center does result in a reduction in effectiveness of theEmergency Plan and requires prior NRC approval. Document Control DeskAttachment IVLAR-13-02396 RC-14-0039 Page 1 of 61VIRGIL C. SUMMER NUCLEAR STATION (VCSNS) Unit 1DOCKET NO. 50-395OPERATING LICENSE NO. NPF-12ATTACHMENT IVLicensee's Staffing Analysis Conducted in October of 2012 NUCLEAR OPERATIONS COPY NO.A CWMPAV. C. Summer Unit #1 (VCS)ERO On-Shift StaffingAnalysisRevision 0Appendix Initially Prepared By:Operations Support Services, Inc.1716 White Pond LaneWaxhaw, NC 28173October, 2012 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX 7EP-100 APPENDIX 7Page 2 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX 7TABLE OF CONTENTSI IN T R O D U C T IO N ......................................................................................................... 32 ON-SHIFT STAFFING COMPLEMENT .................................................................. 52.1 Shift Staffing Licensing Basis Comparison ............................................. 52.2 On-Shift Staffing Complement Used in the Analysis .............................. 73 ANALYZED EVENTS .................................................................................................. 93.1 List of Potential Events to be Analyzed ................................................. 93.2 Disposition of Events ............................................................................ 93.3 NEI 10-05 Appendix A Table, Analyzed Events and Accidents ............ 153.4 Scope/Sequence of Events ................................................................. 164 ON-SHIFT STAFFING TASK ANALYSIS ............................................................ 214.1 Non-Validated Task Analysis Results ................................................. 214.2 Potential Task Overlap Analysis Results (by position) ........................ 214.3 Potential Task Overlap Requiring Time Motion Study .......................... 225 ON-SHIFT STAFFING TIME MOTION STUDY ................................................... 245.1 Analysis Summary .............................................................................. 245.2 Recommendations .............................................................................. 246 R E FE R E N C E S ......................................................................................................... 256.1 Regulatory and Guidance References ................................................. 256.2 Event Analysis References ................................................................. 26Attachment 1: NEI 10-05 Table 5 Controlling Method Correlation .......................... 28Attachment 2: NEI 10-05 Appendix B On-Shift Staffing Analysis Results Tables ........ 29Attachment 3: NEI 10-05 Appendix D & E On-Shift Staffing Analysis Results Tables. 58Page 3 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX

71. INTRODUCTION The specific requirement for establishing a shift emergency organization to respond toemergency events appears in 10 CFR 50.47(b)(2) which states, in part, the following:

On-shift facility licensee responsibilities for emergency response are unambiguously

defined, adequate staffing to provide initial facility accident response in key functional areasis maintained at all times...As part of the overall Emergency Preparedness rulemaking the NRC amended 10 CFR Part 50,Appendix E, Section IV.A, "Organization,"

to address concerns regarding the assignment oftasks or responsibilities to on-shift emergency response organization (ERO) personnel thatwould potentially overburden them and prevent the timely performance of their emergency planfunctions. Licensees must have enough on-shift staff to perform specified tasks in variousfunctional areas of emergency response. All shifts must have the capability to perform theseemergency functions 24 hours a day, 7 days a week, to minimize the impact of radiological emergencies and to provide for the protection of public health and safety.Previous NRC regulations stated that on-shift staffing levels must be adequate but gave noclear definition of "adequate." This provided some leeway in how licensees assignedemergency plan implementation duties to on-shift personnel. The supporting NRC guidanceused for the approval of emergency plans attempted to define the measure of adequacy, butstakeholders found the guidance to be unclear. The NRC believes the final rule better ensuressufficient on-shift staff in the post-September 11, 2001, threat environment by limiting theassignment of responsibilities which on-shift ERO members would likely perform concurrently with their emergency plan functions In November 2011 the NRC formally published rule changes related to emergency preparedness in 10CFR50.47 and Appendix E. 10CFR50 Appendix E.IV states:A. Organization -The organization for coping with radiological emergencies shall bedescribed, including definition of authorities, responsibilities, and duties of individuals assigned to the licensee's ERO and the means for notification of such individuals in theevent of an emergency. The new rule added the following under Section A to read:9. By December 24, 2012, for nuclear power reactor licensees, a detailed analysisdemonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance oftheir assigned functions as specified in the emergency plan.The NRC staff also provided a revision to NSIR/DPR-ISG-01, Interim Staff Guidance (ISG),"Emergency Planning for Nuclear Power Plants", in November 2011. The ISG Section IV.Cprovides much greater detail on acceptable methods for licensees to implement therequirements of the new rule. The ISG specifically endorsed NEI 10-05 "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities". Page 4 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX 7The NEI methodology for developing the new Emergency Plan on-shift staffing licensing basis iscomposed of the following:

• Define the on-shift ERO staffing and response time requirements.

" Define the site specific event scenarios described in the ISG.* Perform an On-shift Staffing Analysis (OSA) for each event scenario.

• Perform a Time Motion Study (TMS) to analyze the results of the OSA, if deemednecessary.

The ISG requires that the results of the assessment be incorporated into the licensee's Emergency Plan and be considered a part of the licensee licensing bases.Page 5 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX

72. ON-SHIFT STAFFING COMPLEMENT 2.1. Shift Staffing Licensing Basis Comparison The current minimum shift staffing level specified in the current Emergency Plan meets andexceeds the minimum shift staffing level approved by NRC SER.SER E-Plan Shift Staffing a Current E-Plan Shift Staffing a Minimum Shift Staffing aShift Supervisor (1) Shift Supervisor (1) Shift Supervisor (1)Shift Forman (1) CR Supervisor (1) CR Supervisor (1)CR Operators (2) CR Operators (2) CR Operators (2)Auxiliary Operators (2) Auxiliary Operators (2) Auxiliary Operators (2)dShift Technical Advisor (1) Shift Engineer (1) Shift Engineer (1)Communications (1) Communicator (1) Communicator (1)Health Physics Specialist (1) Health Physics Specialist (1) Health Physics Specialist (1)Health Physics Specialist (1) b Health Physics Specialist (2)b Health Physics Specialist (1)eChemistry Specialist (0) Chemistry Specialist (1) Chemistry Specialist (1)Mechanical Maintenance (1) Mechanical Maintenance (1) Mechanical Maintenance (1)Electrical Maintenance (1) b Electrical Maintenance (1) b Electrical Maintenance (1) bI&C Technician (1) I&C Technician (1) I&C Technician (1)Fire Brigade per Tech. Spec. b Fire Brigade (Per Fire Prot. Fire Brigade (5)b, cProgram)b Rescue Operations and First Aid Rescue Operations and First Aid Rescue Operations and First Aid(2)b (2)b (2)bSecurity

-Site Access Control Site Access Control and Site Access Control andand Accountability (per Security Accountability (per Security Plan) Accountability (per Security Plan)Plant)Total = 11Total = 12Total = 13fPage 6 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX 7a. Shift staffing levels are specified in the following documents:

• SER E-Plan Shift Staffing* Current E-Plan Shift Staffing" Minimum Shift StaffingSCE&G VC Summer Nuclear Station, Nuclear Operations, Radiation Emergency Plan, Rev. 4 April 1981 Table 5-1Staffing Requirements for Emergency Conditions SCE&G VC Summer Nuclear Station, Nuclear Operations, Radiation Emergency Plan, EP-1 00, Revision 60 StaffingRequirements for Emergency Conditions FPP-026, Fire Response, Rev. 2 Enclosure 6.7 FPER FireBrigade Minimum Shift Compliment SAP-200, Conduct of Operations, Rev. 8 Enclosure ANormal Shift Complement OAP-100.6 Control Room Conduct and Control of ShiftActivities, Rev. 3, Attachment VIIA FEP Manning SheetSAP-0127, Emergency Preparedness, Rev. 3 Enclosure 6.2 ERO Responsibility Assignment Matrixb. These positions may be covered by on-shift personnel assigned other functions.

Staff positions with "b" designation are not included in the staffing total.c. The Fire Brigade is comprised of (3) on-shift Auxiliary Operators, one of which serves as FireBrigade Leader and 2 on-shift Maintenance Services personnel.

d. Normal shift complement for Auxiliary Operators is 5 per SAP-200 Enclosure A and OAP 100.6Attachment VlIA, however, Emergency Plan Table 5-1 and Technical Specifications only require2.e. Per SAP-0127 Enclosure 6.2, a minimum of 2 HP Specialists are on shift, one of which supportsboth in-plant surveys and in-plant protective actionsf. OAP-1 00.6 Control Room Conduct and Control of Shift Activities, Section 12.1 refers to an "11man minimum shift, including the STS"Page 7 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX 72.2. On-Shift Staffing Complement Used in the Analysis1. Only personnel required to be on-shift are credited in the staffing analysis.

The on-shift personnel complement is limited to the minimum required number andcomposition as described in the VCS1 emergency plan, Table 5-1, and asaugmented per SAP-0127 Enclosure 6.2.2. The on-shift staffing utilized for the analysis, based on the current emergency planand SAP-01 27, was specifically defined with the following considerations:

• The Shift Supervisor initially assumes the position of Interim Emergency Director(lED) until relieved by the Emergency Director in the TSC." The lED:o announces the emergency condition and site evacuation (if applicable) to allplant personnel over the plant paging systemo determines appropriate off-site protective action recommendations o directs the Shift Communicator to complete the initial notifications inaccordance with EPP-002o notifies Security of call-ino assigns a person (Maintenance) to record names and badge numbers of allessential shift workerso requests offsite emergency services (Fire, Medical, Law Enforcement, etc.), ifrequiredo ensures the Emergency Log Book or Control Room AutoLog is established and maintained o ensures TSC, Operations Support Center (OSC), and EOF are beingactivated o determines if a site or Protected Area evacuation is requiredo ensures updated follow-up notifications are made in accordance with EPP-002 hourly, and when conditions changeo ensures plant page announcements are made periodically to update plantpersonnel on emergency conditions
• Shift essential personnel report to the Control Room.* The Shift Communicator performs ERO activation and off-site notifications inaccordance with EPP-002." The STA function is performed by the Shift Engineer.
• On-shift dose assessment is performed by an on-shift HP Specialist in the CountRoom, if required.

" Fire brigade minimum number of 5, which consists of a team leader and four firebrigade members.Page 8 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX 70)Functional Area Major Tasks Emergency Positions > ):E1. Plant Operations and Control Room Staff Shift Supervisor 1Assessment of CR Supervisor Operational AspectsReactor Operator (NRO, BOP) 2Auxiliary Operator (CB, TB, IB, 5aABU, ABL)2. Emergency Direction Command and Control Shift Supervisor (lED) band Control3. Notification & State/County/NRC Shift Communicator (STS) 1Communication .... ...di.o..g....l. ................ ~ ...e .. ..A s .......e.s.s .e. n ... ......... ..... ................................................. H...l.............. .S ..e .. a.................................C .u.n .t...R. o.o..m.... ....I............ ........... .................... ................ Assessment Offsite/Onsite/ln-plant HP Specialist (Shift Lead) 1SurveysChemistry Chemistry Specialist

15. Plant System Accident Analysis

& Shift Engineer (STA) 1Engineering, Repair, Technical Support ...... (STA) .1and Corrective Actions Mech. Maintenance (FPER) 2cRepair and Corrective Elec. Maintenance (FPER) 1 dActions I&C Tech 16. In-Plant PAs Radiation Protection HP Specialist b7. Fire Suppression -- Fire Brigade e8. 1st Aid and Rescue -- Medical Emergency Response bOps Team (MERT)9. Site Access Controland Accountability Security&Accountability Plant Protection fTOTAL: 18(a) Normal shift complement for Auxiliary Operators is 5 per SAP-200 Enclosure A and OAP 100.6Attachment VIIA, however, Emergency Plan Table 5-1 and Technical Specifications only require 2.(b) May be filled by someone filling another position having functional qualifications. (c) Normal shift complement for Mechanical Maintenance is 2 per OAP 100.6 Attachment VIIA, however,Emergency Plan Table 5-1 only requires 1.(d) Normal shift complement for Electrical Maintenance is 1 per OAP 100.6 Attachment VIIA, however,Emergency Plan Table 5-1 allows this function to be performed by other positions on shift.(e) Fire Brigade per FPP-026, Fire Response, Rev. 2 Enclosure 6.7 FPER Fire Brigade Minimum ShiftCompliment; composed of five on-shift individuals, some of which may be assigned other duties.(f) Per Security Plan.Page 9 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX

73. ANALYZED EVENTS3.1. List of Potential Events to be AnalyzedVCS Unit 1 UFSAR updated through 11/28/11 Section 15.4 identifies the following asCondition IV -Limiting Faults:1. Major rupture of pipes containing reactor coolant up to and including double endedrupture of the largest pipe in the Reactor Coolant System (RCS), i.e., loss-of-coolant accident (LOCA) -15.4.12. Major secondary system pipe ruptures

-15.4.23. Steam generator tube rupture -15.4.34. Single reactor coolant pump locked rotor -15.4.45. Fuel handling accident-15.4.56. Rupture of a control rod drive mechanism housing (rod cluster control assemblyejection) -15.4.6Note: At least one of the DBA scenarios must result in a General Emergency with offsiteradiological doses that exceed the EPA PAGs and necessitate PARs.Additionally, the following events must be analyzed to comply with the Interim StaffGuidance (ISG) for the new on-shift staffing rule in 10 CFR 50 Appendix E.* Design Basis Threat (DBT)* Aircraft probable threat -50.54(hh)(1) response actions* Control room fire leading to evacuation and remote shutdown* Station blackout* Appendix R fire response* SAMG3.2. Disposition of EventsVCS1 Emergency Plan Section 4 and EPP-001, Activation and Implementation ofEmergency Plan, Rev. 30, were used to determine the UFSAR Section 15 Condition IVevents that would result in an event declaration. 3.2.1. Maior rupture of pipes containing reactor coolant up to and including double endedrupture of the largest pipe in the Reactor Coolant System (RCS), i.e., loss-of-coolant accident (LOCA) -15.4.1Page 10 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX 7For the purpose of ECCS analyses, Westinghouse defines a large break loss-of-coolant accident (LOCA) as a rupture 1.0 ft2 or larger of the reactor coolant system pipingincluding the double ended rupture of the largest pipe in the reactor coolant system or ofany line connected to that system.Should a major break occur, rapid depressurization of the Reactor Coolant System(RCS) to a pressure nearly equal to the containment pressure occurs in approximately 40 seconds, with a nearly complete loss of system inventory. Rapid voiding in the coreshuts down reactor power. A safety injection system signal is actuated when the lowpressurizer pressure setpoint is reached. These countermeasures will limit theconsequences of the accident in two ways:" Borated water injection complements void formation in causing rapid reduction of power to a residual level corresponding to fission product decay heat. Anaverage RCS / sump mixed boron concentration is calculated to ensure thatthe post-LOCA core remains subcritical.

However, no credit is taken for theinsertion of control rods to shut down the reactor in the large break analysis.

• Injection of borated water provides heat transfer from the core and preventsexcessive cladding temperatures.

Before the break occurs, the reactor is assumed to be in a full power equilibrium condition, i.e., the heat generated in the core is being removed through the steamgenerator secondary system. At the beginning of the blowdown phase, the entire RCScontains sub-cooled liquid which transfers heat from the core by forced convection withsome fully developed nucleate boiling. During blowdown, heat from fission productdecay, hot internals and the vessel, continues to be transferred to the reactor coolant.After the break develops, the time to departure from nucleate boiling is calculated. Thereafter, the core heat transfer is unstable, with both nucleate boiling and film boilingoccurring. As the core becomes voided, both transition boiling and forced convection areconsidered as the dominant core heat transfer mechanisms. Heat transfer due toradiation is also considered. The heat transfer between the RCS and the secondary system may be in eitherdirection, depending on the relative temperatures. In the case of the large break LOCA,the primary pressure rapidly decreases below the secondary system pressure and thesteam generators are an additional heat source. In this analysis using theWCOBRA/TRAC methodology, the steam generator secondary is conservatively assumed to be isolated (main feedwater and steam line) at the initiation of the event tomaximize the secondary side heat load.This event results in an ECL of an Alert under FA1.1 (Loss or potential loss of either thefuel clad RCS) due to:1. RCS Loss (RCS leak rate > available makeup capacity as indicated by a loss ofRCS subcooling) Therefore, this event is analyzed in this appendix. Page 11 VCSI On-Shift Staffing AnalysisEP-100 APPENDIX 73.2.2. Major secondary system pipe ruptures -15.4.2: Two events are evaluated -rupture of amain steam line and rupture of a main feedwater line." Major Rupture of a Main Steam Line: This event is evaluated to occur in hotshutdown and assumes one RCCA is stuck in the fully withdrawn position. The resulting cooldown does return the reactor to critical for a brief period oftime but is quickly shutdown again by the operation of SI. RCS Integrity remains Green, and no fuel failure results. This event does not reach anyECL. Therefore, it is not analyzed in this appendix.

• Rupture of a Main Feedwater Line: This event is evaluated to occur at 102%reactor power. RCS integrity is not challenged and no fuel damage occurs.This event does not reach any ECL. Therefore, it is not analyzed in thisappendix.

3.2.3. Steam generator tube rupture -15.4.3: Assuming normal operation of the various plantcontrol systems, the following sequence of events is initiated by a tube rupture resulting from the complete severance of a single steam generator tube:" Pressurizer low pressure and low level alarms are actuated and chargingpump flow increases in an attempt to maintain pressurizer level. On thesecondary side there is a steam flow/feedwater flow mismatch before trip asfeedwater flow to the affected steam generator is reduced due to theadditional break flow which is now being supplied to that unit.* Continued loss of reactor coolant inventory leads to a reactor trip signalgenerated by low pressurizer pressure. Resultant plant cooldown following reactor trip leads to a rapid change of pressurizer level, and the safetyinjection signal, initiated by low pressurizer

pressure, follows soon after thereactor trip. The safety injection signal automatically terminates normalfeedwater supply and initiates emergency feedwater addition.

• The steam generator blowdown liquid radiation monitor and the condenser airremoval system radiation monitor will alarm, indicating a sharp increase inradioactivity in the secondary system and will automatically divert the steamgenerator blowdown flow to the Nuclear Blowdown Processing System." The reactor trip automatically trips the turbine and if offsite power is available the steam dump valves open permitting steam dump to the condenser.

In theevent of a coincident loss of offsite power, the condenser steam dump valveswould automatically close to protect the condenser. The steam generator pressure would rapidly increase resulting in steam discharge to theatmosphere through the main steam safety and/or power operated reliefvalves." Following reactor trip, the continued action of emergency feedwater supplyand borated high head injection flow (supplied from the refueling waterstorage tank) provide a heat sink which absorbs some of the decay heat.Thus, steam bypass to the condenser, or in the case of loss of offsite power,steam relief to atmosphere, is attenuated during the 30 minutes in which therecovery procedure leading to isolation is being carried out.Page 12 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX 7High head injection flow results in increasing pressurizer water level. The timeafter trip at which the operator can clearly see returning level in the pressurizer is dependent upon the amount of operating auxiliary equipment. Based on these conditions, an Alert ECL would result from FA1.1 based on an RCSLoss (Ruptured SG results in an ECCS (SI) actuation). A realistic and a conservative radiological analysis is performed for this event. Therealistic analysis does not result in offsite doses great enough to reach a higher ECL.The conservative analysis results in a Thyroid dose of 40 Rem and a whole body TEDEdose of approximately 15 Rem. This would result in an ECL of General Emergency based on RG1.2 (Dose assessment using actual meteorology indicates doses > 1,000mRem TEDE or 5,000 mRem thyroid CDE at or beyond the site boundary). This resultwill be utilized to have this event reach a General Emergency ECL and is includedin the analysis. 3.2.4. Singqle reactor coolant pump locked rotor -15.4.4: Based on the Realistic Analysisperformed, this event results in no fuel failure and no challenge to the RCPB, and doesnot reach any ECL. Therefore, it is not analyzed in this appendix. 3.2.5. Fuel Handlingq Accident -15.4.5: A fuel handling accident (FHA) during refueling couldrelease a fraction of the fission product inventory in the plant to the environment. Two (2)accident scenarios are considered: (1) a refueling accident occurring inside containment and (2) a refueling accident occurring outside containment. The postulated fuel handling accident inside containment is the dropping of a spent fuelassembly onto the core during refueling which results in damage to the fuel assemblies. It is postulated that a spent fuel assembly is dropped onto the core during refueling resulting in breaching of the fuel rod cladding. As a result of the damage, a portion of thevolatile fission gases are released to the water pool covering the core. Subsequently, afraction of the water soluble gases are absorbed in the pool with the remainder beingtransported through the water and into the Reactor Building atmosphere. The escapedgases are assumed to be released instantaneously to the environment via the ReactorBuilding Purge System and dispersed into the atmosphere.

However, since there willnot be a time during refueling activities when only the minimum on-shift ERO is presentfor this event, the fuel handling accident inside the Containment is not included in theon-shift staffing analysis.

The fuel handling accident outside containment is postulated as the dropping of a spentfuel assembly into the Spent Fuel Pool which results in damage to the fuel assemblies and the release of the volatile gaseous fission products. Realistic and conservative analyses were performed for both of these events. Thewhole body TEDE dose at the EAB resulting from the fuel handling accident in theContainment or FHB is approximately 0.25 Rem and 4.75 Rem Thyroid.The fuel handling accident results in a Site Area Emergency classification under RS1.2(Dose assessment using actual meteorology indicates doses > 100 mRem TEDE or 500mRem thyroid CDE at or beyond the site boundary). A fuel handling accident in the FuelHandling Building spent fuel pool is included in the analysis. Page 13 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX 73.2.6. Rupture of a control rod drive mechanism housing (rod cluster control assembly eiection) -15.4.6: This accident is defined as the mechanical failure of a control rod mechanism pressure housing resulting in the ejection of a rod cluster control assembly (RCCA) anddrive shaft. The consequence of this mechanical failure is a rapid positive reactivity insertion together with an adverse core power distribution, possibly leading to localized fuel rod damage.The realistic analysis for this event does not result in any RCL due to radiological release and resulting offsite dose (the resulting whole body TEDE at the EAB is1.1 x 10-7 Rem). The loss of coolant that results is bounded by the large break LOCAresults. Therefore, this event is not included in the analysis. 3.2.7. Design Basis Threat (DBT): This event results in a Site Area Emergency ECL based onHS4.1 (A hostile action is occurring or has occurred within the Protected Area asreported by the security Team Leader) Therefore, this event is analyzed in thisappendix. 3.2.8. Aircraft Probable Threat -50.54(hh)(1) Response Actions: This event results in an AlertECL based HA4.1 (A validated notification from NRC of an airliner attack threat within 30minutes of the site). Therefore, this event is analyzed in this appendix. 3.2.9. Control Room Fire Leading to Evacuation and Remote Shutdown: This event results inan Alert ECL based on HA5.1 (AOP-600.1, Control Room Evacuation, or FEP-4.0,Control Room Evacuation Due To Fire, requires Control Room evacuation). Therefore, this event is analyzed in this appendix. 3.2.10. Station Blackout: This event results in a Site Area Emergency ECL based on SS1.1(Loss of all offsite and all onsite AC power to 7.2 KV ESF buses 1 DA and 1DB for -> 15min.). Therefore, this event is analyzed in this appendix. 3.2.11. Appendix R Fire Response: The on-shift staff responds to a fire alarm or the report of afire at VC Summer by entering procedure FEP-1I.0 FIRE EMERGENCY PROCEDURE SELECTION. In addition to monitoring the plant and coordinating communication, theoperating shift staffs the Fire Brigade.If the fire is in the control room, FEP-4.0, Control Room Evacuation Due To Fire isutilized and the plant must be shut down and controlled from outside the control room.The Control Room fire requiring evacuation and plant shutdown from remote locations isclearly the most serious Appendix R fire with regard to operator actions as prescribed inthese procedures. Since the Control Room fire is addressed in Section 1.2.9, anadditional Appendix R fire is not included in the analysis. Page 14 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX 73.2.12. SAMG: Before the TSC is staffed and functional, VC Summer SAMGs require theControl Room to enter SACRG-1, Severe Accident Control Room Guideline InitialResponse, pending arrival of the TSC. SACRG-1 entry conditions are any of thefollowing:

1) EOP-6.0, LOSS OF ALL ESF AC POWER, when core exit TCs are greater than1200OF and actions to cool the core are not successful.

2) EOP-13.0, RESPONSE TO ABNORMAL NUCLEAR POWER GENERATION, when core exit TCs are greater than 1200OF and actions to cool the core are notsuccessful.

3) EOP-14.0, RESPONSE TO INADEQUATE CORE COOLING, when core exitTCs are greater than 1200°F and actions to cool the core are not successful.

4) EOP-2.6, RHR SUMP BLOCKAGE, when core exit TCs are greater than 1200OFand actions to cool the core are not successful None of these conditions are reached in any of the accidents that are required to beevaluated, so SAMG is not included in this analysis.

Page 15 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX 73.3. NEI 10-05 AtDendix A Table. Analyzed Events and Accidents Analysis Summary Description of Event or Accident Plant Reference Document(s) ECL Analysis# Mode Required? 1 Major rupture of pipes containing reactor coolant up to and 1 UFSAR 15.4.1 Alert Yesincluding double ended rupture of the largest pipe in the ReactorCoolant System (RCS), i.e., loss-of-coolant accident (LOCA)2 Major secondary system pipe ruptures 1 UFSAR 15.4.2 None No3 Steam generator tube rupture 1 UFSAR 15.4.3 GE Yes4 Single reactor coolant pump locked rotor 1 UFSAR 15.4.4 None No5 Fuel handling accident outside containment 1 UFSAR 15.4.5 SAE Yes6 Rupture of a control rod drive mechanism housing (rod cluster 1 UFSAR 15.4.6 Alert No'control assembly ejection) 7 Design Basis Threat (DBT) 1 EPP-027 SAE Yes8 Aircraft Probable Threat -50.54(hh)(1) Response Actions 1 EPP-027 Alert Yes9 Control Room Fire Leading to Evacuation and Remote Shutdown 1 FEP-4.0 Alert Yes10 Station Blackout 1 EOP 6.0 SAE Yes11 Appendix R Fire Response 1 FEP-1.0 Alert Noz12 SAMG 1 SACRG-1 GE No'Notes:1.2.3.The resulting loss of coolant that results is bounded by Analysis

1. 1.The control room fire and evacuation is the limiting Appendix R fire response scenario with regard to complex actions by the on-shift ERO.The entry conditions for SACRG-1 do not occur for any of the FSAR limiting fault events or other scenarios performed within this analysis.

Page 16 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX 73.4. Scope/Sequence of Events3.4.11. General Assumptions and Limitations

1. On-shift personnel can report to their assigned response locations within timeframes sufficient to allow for performance of assigned actions.

The following are the typicallocations of the on-shift personnel:

• S hift S upervisor (1) ..........................................................................

C ontrol R oom* C R S upervisor (1) ............................................................................ C ontrol R oom* Control Room Operator (NRO) ........................................................ Control Room* Control Room Operator (BOP) ......................................................... Control Room* Auxiliary Operator (CBAO) ............................................................ Control Building" Auxiliary Operator (TBAO) ........................................................... Turbine Building* Auxiliary Operator (IBAO) ..................................................... Intermediate Building* Auxiliary Operator (ABUAO) ....................................................... Auxiliary Building* Auxiliary Operator (ABLAO) ........................................................ Auxiliary Building* S hift C om m unicator (STS) ......................................................................... In Plant* Shift Engineer (STA) ......... ................................... Control Room* H P S h ift Le a d ............................................................................................ In P la nt* HP Count Room .......................................................................... HP Count Room* C hem istry S pecialist .................................................................................. In P lant* M echanical M aintenance 1 ........................................................................ In Plant* M echanical M aintenance 2 ........................................................................ In Plant" I& C M a inte na nce ....................................................................................... In P la nt* E lectrical M aintenance ............................................................................... In P lant* Fire Brigade (5) ...................................... (See Auxiliary Operators & Mech. Maint.)* Security Force Supervisor ........................................................... Per Security Plan2. The on-shift staff possesses the necessary Radiation Worker qualifications to obtainnormal dosimetry and to enter Radiologically Controlled Areas (but not high, lockedhigh, or very high radiation areas) without the aid of a Radiation Protection (RP)Technician.

3. It is assumed that personnel assigned to the major response area of PlantOperations

& Safe Shutdown meet the requirements and guidance established byNRC regulations and are able to satisfactorily perform the functions and tasksnecessary to achieve and maintain safe shutdown. Staff performance within this areais not evaluated as part of this assessment, unless a role/function/task from anothermajor response area is assigned as a collateral duty.Page 17 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX

74. It is assumed that personnel assigned to the major response area of Firefighting meet the requirements and guidance established by NRC regulations and are able tosatisfactorily perform the functions and tasks necessary to fight a fire. Staffperformance within this area is regularly analyzed through other station programs(e.g., fire drills) and will not be evaluated as part of this assessment, unless arole/function/task from another major response area is assigned as a collateral duty.While it is VCS1 practice is to assign the CBAO, TBAO, ABLAO, and two Mechanical Maintenance personnel to the Fire Brigade, the other AOs could be assigned inplace of these brigade members as event-specific response activities require.5. Individuals holding the position of Health Physics Specialist or Chemistry Specialist are qualified to perform the range of tasks expected of their position.

6. The analyzed events occur during off-normal work hours at a time when augmented ERO responders are not at the site (e.g., during a backshift, weekend or holiday).

The ERO augmentation time is based on the time of event declaration until the timeof turnover of the function/responsibility. Specifically, any time needed by theaugmenting ERO to acquire materials or prepare for turnover is accounted for.Section 6.1 of the VCS1 Emergency Plan requires notification of the stationEmergency Response Organization (ERO) following event declaration. Theemergency plan does not specify a time requirement for relief of the emergency response functions from the on-shift staff; however, the emergency procedures directrelief to occur in the steps following facility activation. Relief of the on-shift ERO isassumed to occur no sooner than 90 minutes from the time of the classifiable event.For purposes of this analysis, 90 minutes is used as the time period for theconduct of on-shift ERO response actions.3.4.12. Event Specific Information

1. Major rupture of pipes containing reactor coolant up to and including double endedrupture of the largest pipe in the Reactor Coolant System (RCS), i.e., loss-of-coolant accident (LOCA) -15.4.1Initial Conditions:

The unit is operating normally at 100% power in an equilibrium condition. Abnormal Conditions: NoneScenario Events: Double-ended severance of an RCS cold leg pipe.One ECCS train, including one HHSI pump and one LHSI pump,starts and delivers flow through the injection lines. Theaccumulator and safety injection flows from the broken loop wereassumed to spill to containment. Both emergency dieselgenerators (EDGs) are assumed to start.Continued operation of the ECCS pumps supplies water duringlong-term cooling. Core temperatures have been reduced to long-term steady state levels associated with dissipation of residualheat generation. After the water level of the refueling waterstorage tank (RWST) reaches a minimum allowable value, coolantfor long-term cooling of the core is obtained by switching from theinjection mode to the sump recirculation mode of ECCS operation. Page 18 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX 7Spilled borated water is drawn from the engineered safety features(ESF) containment sumps by the LHSI pumps (also called theResidual Heat Removal pumps, or RHR pumps) and returned tothe RCS cold legs.It is assumed that the entire inventory of fission product activitycontained in the primary coolant was released to containment. No off-site release resulting in significant offsite dose above theAlert threshold (FSAR Table 15.4-16). Notes: FSAR Section 15.4.1 Realistic Analysis2. Steam generator tube rupture -15.4.3 (as modified to result in a GeneralEmergency) Initial Conditions: Abnormal Conditions: Scenario Events:The unit is operating normally at 100% power in an equilibrium condition. Coolant activity (gap failure) is sufficient to result in an offsite dosethat exceeds the EPA PAGs beyond the site boundary. Complete severance of a single steam generator tube withconcurrent loss of off-site AC power (LOOP).The accident is assumed to take place at power (100%) with thereactor coolant contaminated with fission products corresponding to a level necessary to support the offsite radiological conditions, thus a non-realistic damage source term input is necessary. Theaccident leads to an significant increase in fission products in thesecondary system due to leakage of radioactive coolant from thereactor coolant system. A coincident loss of offsite power, resultsin the discharge of activity to the atmosphere via the steamgenerator safety which subsequently sticks open.The operator is expected to determine that a steam generator tuberupture has occurred, and to identify and attempt to isolate thefaulty steam generator in order to terminate radioactive release tothe atmosphere from the faulty unit.Recovery procedures are not successful on a time scale whichensures that break flow to the secondary system is terminated before water level in the affected steam generator rises into themain steam pipe. RCS depressurization results in a reactor tripand pressure decrease in the pressurizer. Safety injection occurswhen the applicable SI setpoint is reached.Notes: This DBA scenario is to result in a General Emergency with offsiteradiological doses that exceed the EPA PAGs and necessitate PARs.3. Fuel Handling Accident Outside Containment -15.4.5Page 19 VCSI On-Shift Staffing AnalysisEP-100 APPENDIX 7Initial Conditions: The unit is operating normally at 100% power in an equilibrium condition. Plant at minimum staffing with the exception of ONEadditional SRO supervising the crew in the Spent Fuel Pool area.Abnormal Conditions: NoneScenario Events:A spent fuel assembly is dropped into the Spent Fuel Pool whichresults in damage to the fuel assemblies and the release of thevolatile gaseous fission products. Following the dropped fuel assembly gaseous fission products arereleased to the spent fuel pool and subsequently to the FuelHandling Building. These gases are released to the environment via the fuel handling building charcoal exhaust system.Notes: Dose assessment using actual meteorology indicates doses > 100mRem TEDE or 500 mRem thyroid CDE at or beyond the siteboundary4. Design Basis Threat (DBT)Initial Conditions: The unit is operating normally at 100% power in an equilibrium condition. Abnormal Conditions: NoneScenario Events: VCS1 Security Team Leader notifies the Shift Supervisor that aHOSTILE FORCE is engaged in an attack at the Protected Areafence. Security Force Officers inside the PA fence are underfire.Notes: No abnormal radiological conditions exist during this event.5. Aircraft Probable Threat -50.54(hh)(1) Response ActionsInitial Conditions: The unit is operating normally at 100% power in an equilibrium condition. Abnormal Conditions: NoneScenario Events:A valid notification from the NRC Headquarters Operations Officer(HOO) is received detailing an aircraft identified as a potential threat to VCS1. ETA at VCS is 28 minutes.Notes: No abnormal radiological conditions exist during this event.Page 20 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX

76. Control Room Fire Leading to Evacuation and Remote ShutdownInitial Conditions:

The unit is operating normally at 100% power in an equilibrium condition. Abnormal Conditions: No major evolutions planned or in progress. Scenario Events: A fire ignites inside the Unit 1 Control Room.Smoke and gases necessitate the evacuation of the Control RoomNotes: No abnormal radiological conditions exist during this event.7. Station BlackoutThe event consists of a loss of offsite power and a failure of all emergency AC powersources resulting in a Station Blackout (Loss of all AC power).Initial Conditions: The unit is operating normally at 100% power in an equilibrium condition. Abnormal Conditions: No major evolutions planned or in progress. Scenario Events: Loss of all offsite power occurs.Reactor trips, both diesels fail to start, all AC buses are de-energized. No emergency diesel generators will synchronize toany bus.Notes: No abnormal radiological conditions exist during this event.Page 21 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX

74. ON-SHIFT STAFFING ANALYSISRefer to Attachment 2, NEI 10-05 Appendix B On-Shift Staffing Analysis Results Tables,for additional documentation of the on-shift staffing task analysis results.4.1 Non-Validated Task Analysis ResultsNEI 10-05 Table 5 -Emergency Plan Implementation task analysis controlling methodsare correlated with the EP Drill Program in Attachment 1.The task analysis identified no tasks performed by the on-shift ERO that have not beenpreviously validated for performance capabilities.

4.2 Potential Task Overlap Analysis Results (by position) Table 4-1 summarizes the results of the potential overlaps and un-validated tasksidentified in the analysis. The task analysis identified one position that may experience task overlap (refer to Table4-1 for a listing of potential task overlaps):

1) The HP Count Room specialist experiences potential task overlap of Offsiteradiological assessment in the following:

• Analysis Event #3 -Steam Generator Tube Rupture" Analysis Event #5 -Fuel Handling Accident Outside Containment The results of the task analysis indicate that the following events require time motionstudy evaluation:

1) Analysis Event #3 -Steam Generator Tube Rupture2) Analysis Event #5 -Fuel Handling Accident Outside Containment Per NEI 10-05 Table 3.1, the results of the task analysis indicate that five of the sevenevents do not require time motion study evaluation:

Table 4-1: Task Analysis SummaryPsen113. HP Count Room 4/5 Offsite radiolo ical assessment 103. HPP CCount Room 1415 Omfit. radlological assessment Refer to Attachment 2, NEI 10-05 Appendix B On-Shift Staffing Analysis Results Tablesfor additional documentation of the on-shift staffing analysis table top results.Page 22 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX 74.3 Potential Task Overlap Requiring Time Motion StudyFor combinations of tasks that resulted in the same potential overlap in multiple events,demonstration and evaluation of those task combinations may be conducted in one ormore time motion studies, provided procedure, environment and task timing are similar.Table 4-2 provides a comparison of potential overlapping tasks by position for each ofthe analyzed events.Analysis Event #1 -LOCABased on the results of the task analysis, no tasks were identified as meeting therequirements for further analysis under the NEI 10-05 time motion study.Analysis Event #3 -Steam Generator Tube RuptureBased on the results of the task analysis, the following were identified as meeting therequirements for further analysis under the NEI 10-05 time motion study:The HP Count Room specialist performs the EP task of Offsite radiological assessment. ERO shift positions that perform table 4 tasks and this EP task are required to have thecollective performance of those tasks analyzed and validated by a time motion study.Analysis Event #5 -Fuel Handling Accident Outside Containment Based on the results of the task analysis, the following were identified as meeting therequirements for further analysis under the NEI 10-05 time motion study:The HP Count Room specialist performs the EP task of Offsite radiological assessment. ERO shift positions that perform table 4 tasks and this EP task are required to have thecollective performance of those tasks analyzed and validated by a time motion study.Analysis Event #7 -Design Basis Threat (DBT)Based on the results of the task analysis, no tasks were identified as meeting therequirements for further analysis under the NEI 10-05 time motion study.Analysis Event #8 -Aircraft Probable ThreatBased on the results of the task analysis, no tasks were identified as meeting therequirements for further analysis under the NEI 10-05 time motion studyAnalysis Event #9 -Control Room Fire Leading to Evacuation Based on the results of the task analysis, no tasks were identified as meeting therequirements for further analysis under the NEI 10-05 time motion study.Analysis Event #10 -Station Blackout (SBO)Based on the results of the task analysis, no tasks were identified as meeting therequirements for further analysis under the NEI 10-05 time motion study.Page 23 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX 7Table 4-2: Task Overlap Summary02,020cWT)02%21)0Z.ccr_.d002020(UZf24)01ccHP Count Room N/A 4/5 415 N/A N/A N/A N/APage 24 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX

75. ON-SHIFT STAFFING TIME MOTION STUDY5.1 Analysis SummaryThe time motion studies identified no overlap that would preclude or unacceptably delayassigned responsibilities for the HP-Count Room on-shift position.

The potential for overlap identified in the staffing analysis in Section 4; the performance of off-site radiological assessment (dose assessment) by the HP-Count Room relative toother assigned tasks (counting either SG or SFP samples), was the sole task requiring analysis in the time motion study per NEI 10-05. The determination that this overlapwould not preclude or unacceptably delay assigned HP-Count Room responsibilities isbased on the following:

1. The tasks of counting SG samples (analysis

1. 3 SGTR) or SFP samples (analysis
2. 5 FHA) are not time critical.

That is, neither sample results are required toperform a time critical EOP, AOP, or Emergency Plan actions nor do they affectEOP, AOP, or Emergency Plan decision making within the analysis time periodof 90 minutes.2. Procedure EPP-005 Attachment XXII "Guidance For Performing DoseProjections By Shift Personnel" states that "If the Count Room Specialist isperforming other essential work, the lED must determine the priority for theCount Room Specialist'. This provides the Shift Manager (Interim Emergency Director) the procedural latitude to prioritize the HP-Count Room activities andpreclude any potential overlap.Refer to Attachment 3, NEI 10-05 Appendix D & E On-Shift Staffing Analysis ResultsTables, for additional documentation details of the on-shift staffing time motion studyevaluation results.5.2 Recommendations NonePage 25 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX

76. REFERENCES 6.1 Regulatory and Guidance References 6.1.1 10 CFR 50.47(b)(2) 6.1.2 10 CFR 50 Appendix E Section IV.A.96.1.3 NSIR/DPR-ISG-01, Interim Staff Guidance

-Emergency Planning for Nuclear PowerPlants6.1.4 NEI 10-05, Assessment of On-Shift Emergency Response Organization Staffing andCapabilities, Rev 0Page 26 VCSI On-Shift Staffing AnalysisEP-100 APPENDIX 76.2 Event Analysis References AnalvsisProcedure Rev. Title #1 #3 #5 #7 #8 #9 #10No. LOCA SGTR FHA DBT APT CREF SBOAOP-123.3 3 Potential Fuel Assembly Damage While Handling Fuel xAOP-304.3 3 Loss of Balance of Plant Buses xCP-1 11 7 Boron Determination x xCP-902 14 Chemistry Sampling Point List xCP-903 20 Operation of Nuclear Sampling System x xEOP-1.0 26 Reactor Trip/Safety Injection Actuation x xEOP-1.1 17 Reactor Trip Recovery x xEOP-2.0 15 Loss of Reactor or Secondary Coolant xEOP-2.2 16 Transfer to Cold Leg Recirculation x xEOP-3.0 11 Faulted SG Isolation xEOP-4.0 20 Steam Generator Tube Rupture xSGTR with Loss of Reactor Coolant: Subcooled EOP-4.2 16 Recovery Desired xEOP-6.0 25 Loss of All ESF AC Power xEPP-001 30 Activation and Implementation of Emergency Plan x x x x x x xEPP-001.2 8 Alert x xEPP-001.3 8 Site Area Emergency x x x xEPP-001.4 8 General Emergency xEPP-002 35 Communication & Notification x x x x x xEPP-005 20 Offsite Dose Calculation x xEPP-013 13 Fire Emergency xPage 27 VCSI On-Shift Staffing AnalysisEP-100 APPENDIX 7AnalysisProcedure

1. 1 #3 #5 #7 #8 #9 #10No. LOCA SGTR FHA DBT APT CREF SBOEPP-021 22 Activation of the Early warning System x x x xEPP-027 4 Hostile Action x xFEP-4.0 4 Control Room Evacuation Due to Fire xGOP-4C 1 Rapid Power Reduction xHPP-245 1 Radiological Controls for Failed Fuel xHPP-302 10 Radiation and Contamination Survey Techniques xHPP-403 11 Radiological Controls for Nuclear Work Activities xHPP-808 13 Sample Analysis x xSOP-118 17 Component Cooling Water xSOP-220 17 Station and Backup Instrument Air Systems x x xSOP-505 10 Control Building Ventilation System x x xSPP-114 16H Security Force Responsibilities During Emergencies x x x xPage 28 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX 7Attachment 1: NEI 10-05 Table 5 Controlling Method Correlation Line Function/Task OPs Training Program and EP Drill Program TaskAnalysis Controlling MethodOPs Training Program1. Declare the Emergency Classification Level EP Drill Program(ECL)EPP-105 (CR-2).Approve Offsite Protective Action OPs Training Program2. Recommendations EP Drill ProgramEPP-105 (CR-6) & EPP-106OPs Training Program3. Approve content of State/local notifications EP Drill ProgramEPP-105 (CR-3) & EPP-1064. Approve extension to allowable dose limits N/AOPs Training ProgramNotification and direction to on-shift staff EP Dri Program5. (e.g., to assemble,

evacuate, etc.) EP Drill ProgramEPP-105 (CR-6)OPs Training Program6. ERO notification EP Drill ProgramEPP-105 (CR-4)OPs Training Program7. Abbreviated NRC notification for DBT event EP Drill ProgramEPP-105 (CR-3)OPs Training Program8. Complete State/local notification form EP Drill ProgramEPP-105 (CR-3) & EPP-106OPs Training Program9. Perform State/local notifications EP Drill ProgramEPP-105 (CR-3)OPs Training Program10. Complete NRC event notification form EP Drill ProgramEPP-105 (CR-3) & EPP-106OPs Training Program11. Activate ERDS EP Drill ProgramEPT-08, EPP-105 Att. 13HP Training Program12. Offsite radiological assessment EP Drill ProgramC-517-016-01-10 in Q-HP-MIDAS (required for EPT-42)I&C Training Program13. Perform NRC notifications EP Drill ProgramEPP-105 (CR-3) & EPP-10614. Perform other site-specific event N/Anotifications (e.g., INPO, ANI, etc.)OPs Training Program15. Personnel accountability EP Drill ProgramTPE-17Page 29 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX 7'Attachment-2:

'NEI 10-05 Appendix B On-Shift Staffing Analysis Results Tables .Analysis Event #1 -LOCATABLE I -On-Shift Positions Line On-shift Position Emergency Plan Reference Augmentation Role in Unanalyzed TMSElapsed Time (min) Table#/Line# Task? Required?

1. Shift Supervisor Table 2-1 2/15/1No No5/55/85/102. CR Supervisor Table 2-1 2/2 No No3. Shift Engineer (STA) Table 2-1 2/3 No No4. Control Room Operator (NRO) Table 2-1 2/4 No No5. Control Room Operator (BOP) Table 2-1 2/5 No No6. Auxiliary Operator (CBAO) Table 2-1 2/6 No No7. Auxiliary Operator (TBAO) Table 2-1 2/7 No No8. Auxiliary Operator (IBAO) Table 2-1 2/8 No No9. Auxiliary Operator (ABUAO) Table 2-1 2/9 No No10. Auxiliary Operator (ABLAO) Table 2-1 2/10 No No11. Shift Communicator (STS) Table 2-1 5/65/9 No No5/1112. HP Shift Lead Table 2-1 90 4/1__ __ __ __ __ __ _ __ __ __ __ 44No No4/413. HP Count Room Table 2-1 90 4/7 No No14. Chemistry Specialist Table 2-1 90 4/7 No No15. Mechanical Maintenance 1 Table 2-1 N/A N/A N/A16. Mechanical Maintenance 2 Table 2-1 N/A N/A N/A17. I&C Maintenance Table 2-1 5/13 No No18. Electrical Maintenance Table 2-1 N/A N/A N/A19. Security Force Supervisor Table 2-1 N/A N/A N/APage 30 VCSI On-Shift Staffing AnalysisEP-100 APPENDIX 7Attachment 2: NEI 10-05 Appendix B On-Shift Staffing Analysis Results TablesAnalysis Event #1 -LOCATABLE 2 -Plant Operations

& Safe ShutdownMinimum Operations Crew (One Unit -One Control Room)Line Generic Title/Role On-Shift Position Task Description Controlling Method1. Shift Manager Shift Supervisor Plant and crew oversight OPs Training Program2. Unit Supervisor CR Supervisor Direct EOP/SOP actions OPs Training Program3. Shift Technical Advisor Shift Engineer (STA) STA tasks OPs Training Program4. Reactor Operator

1. 1 Control Room Operator (NRO) Perform EOP/SOP actions OPs Training Program5. Reactor Operator
2. 2 Control Room Operator (BOP) Perform EOP/SOP actions OPs Training Program6. Auxiliary Operator
3. 1 Auxiliary Operator (CBAO) Perform in-plant actions OPs Training Program7. Auxiliary Operator
4. 2 Auxiliary Operator (TBAO) Perform in-plant actions OPs Training Program8. Other Auxiliary Operator (IBAO) Perform in-plant actions OPs Training Program9. Other Auxiliary Operator (ABUAO) Perform in-plant actions OPs Training Program10. Other Auxiliary Operator (ABLAO) Perform in-plant actions OPs Training ProgramOther (non-Operations)

Personnel Line Generic Title/Role On-Shift Position Task Description Controlling Method15. Mechanic Mechanical Maintenance 1 N/A N/A16. Mechanic Mechanical Maintenance 2 N/A N/A17. I&C Technician I&C Maintenance N/A N/A18. Electrician Electrical Maintenance N/A N/AAnalysis Event #1 -LOCATABLE 3 -Firefighting Line Performed By -Task Description Controlling Method1. Fire Brigade Leader (AO) N/A N/A2. Fire Brigade Member #1 (AO) N/A N/A3. Fire Brigade Member #2 (AO) N/A N/A4. Fire Brigade Member #3 (Mechanical Maintenance

1) N/A N/A5. Fire Brigade Member #4 (Mechanical Maintenance

1) N/A N/APage 31 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX 7Attachment 2: NEI 10-05 Appendix B On-Shift Staffing Analysis Results TablesAnalysis Event #1 -LOCATABLE 4 -Radiation Protection and Chemistry

1. Position Performing Function/Task Performance Time Period After Emerg ency Declaration (minutes) 0-10 10-20 20-30 30-40 40-50 50-60 60-70 70-80 80-90In-Plant Radiological Survey1. On-Shift Position:

HP Shift Lead X X XOn-Site Radiological Survey2. On-Shift Position: Personnel Monitoring

3. On-Shift Position:

Job Coverage4. On-Shift Position: HP Shift Lead X XOffsite Radiological Assessment

5. On-Shift Position:

Center Set-Up6. On-Shift Position: Sampling Activities On-Shift Position: Chemistry Specialist X X X XHP Count Room X X X X XChemistry function/task

1. 2 -Describe:

8. On-Shift Position:

Note: The basis for the selected performance time period was established by the subject matter experts during the task analysistime periods for concurrent tasks will be analyzed as part of the time motion study.review. Specific performance Page 32 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX 7.Attacment2: NEI i0-05 Appendix B On-Shift Staffing Analysis Results TablesAnalysis Event #1 -LOCATABLE 5 -Emergency Plan Implementation , .* ,Task AnalysisLine Function/Task On-Shift PositionControlling MethodOPs Training Program1. Declare the Emergency Classification Level (ECL) Shift Supervisor EP Drill Program2. Approve Offsite Protective Action Recommendations N/A EP Drill Program3. Approve content of State/local notifications Shift Supervisor EP Drill Program4. Approve extension to allowable dose limits N/A N/A5. Notification and direction to on-shift staff (e.g., to assemble,

evacuate, etc.) Shift Supervisor EP Drill Program6. ERO notification Communicator (STS) EP Drill Program7. Abbreviated NRC notification for DBT event N/A N/A8. Complete State/local notification form Shift Supervisor OPs Training ProgramEP Drill ProgramOPs Training Program9. Perform State/local notifications Communicator (STS) EP Drill Program10. Complete NRC event notification form Shift Supervisor EP Drill Program11. Activate ERDS Communicator (STS) EP Drill Program12. Offsite radiological assessment N/A N/A13. Perform NRC notifications I&C Maintenance EP Drill Program14. Perform other site-specific event notifications (e.g., INPO, ANI, etc.) N/A N/A15. Personnel accountability N/A N/ANote: Lines #3, #8 and #9 include initial and follow-up State/local notifications.

Page 33 VCSI On-Shift Staffing AnalysisEP-100 APPENDIX 7Attachment 2: NEl 10-05 Appendix B On-Shift Staffing Analysis ResUlts Tables ..Analysis Event #3 -Steam Generator Tube RuptureTABLE I -On-Shift Positions Augmentation Role in Unanalyzed TMSLineEmergecy Plan Reference Elapsed Time (min) Table#/Line# Task? Required?

1. Shift Supervisor Table 2-1 2/15/15/25/3 No No5/55/85/102. CR Supervisor Table 2-1 2/2 No No3. Shift Engineer (STA) Table 2-1 2/3 No No4. Control Room Operator (NRO) Table 2-1 2/4 No No5. Control Room Operator (BOP) Table 2-1 2/5 No No6. Auxiliary Operator (CBAO) Table 2-1 2/6 No No7. Auxiliary Operator (TBAO) Table 2-1 2/7 No No8. Auxiliary Operator (IBAO) Table 2-1 2/8 No No9. Auxiliary Operator (ABUAO) Table 2-1 N/A N/A N/A10. Auxiliary Operator (ABLAO) Table 2-1 2/10 No No11. Shift Communicator (STS) Table 2-1 5/65/9 No No5/1112. HP Shift Lead Table 2-1 90 4/144No No4/413. HP Count Room Table 2-1 90 4/547No Yes4/714. Chemistry Specialist Table 2-1 90 4/7 No No15. Mechanical Maintenance 1 Table 2-1 N/A N/A N/A16. Mechanical Maintenance 2 Table 2-1 N/A N/A N/A17. I&C Maintenance Table 2-1 5/13 No No18. Electrical Maintenance Table 2-1 5/15 No No19 Security Force Supervisor Table 2-1 5/15 No NoPage 34 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX 7Attachment 2: -NEI 10-05AppendixB On-Shift Staffing Analysis Results TablesAnalysis Event #3 -Steam Generator Tube RuptureTABLE 2 -Plant Operations

& Safe ShutdownMinimum Operations Crew (One Unit -One Control Room)Line Generic Title/Role On-Shift Position Task Description Controlling Method1. Shift Manager Shift Supervisor Plant and crew oversight OPs Training Program2. Unit Supervisor CR Supervisor Direct EOP/SOP actions OPs Training Program3. Shift Technical Advisor Shift Engineer (STA) STA tasks OPs Training Program4. Reactor Operator

1. 1 Control Room Operator (NRO) Perform EOP/SOP actions OPs Training Program5. Reactor Operator
2. 2 Control Room Operator (BOP) Perform EOP/SOP actions OPs Training Program6. Auxiliary Operator
3. 1 Auxiliary Operator (CBAO) Perform in-plant actions OPs Training Program7. Auxiliary Operator
4. 2 Auxiliary Operator (TBAO) Perform in-plant actions OPs Training Program8. Other Auxiliary Operator (IBAO) Perform in-plant actions OPs Training Program9. Other Auxiliary Operator (ABUAO) N/A N/A10. Other Auxiliary Operator (ABLAO) Perform in-plant actions OPs Training ProgramOther (non-Operations)

Personnel Line Generic Title/Role On-Shift Position Task Description Controlling Method15. Mechanic Mechanical Maintenance 1 N/A N/A16. Mechanic Mechanical Maintenance 2 N/A N/A17. I&C Technician I&C Maintenance N/A N/A18. Electrician Electrical Maintenance N/A N/AAnalysis Event #3 -Steam Generator Tube RuptureTABLE 3 -Firefighting Line Performed By Task Description Controlling Method1. Fire Brigade Leader (AO) N/A N/A2. Fire Brigade Member #1 (AO) N/A N/A3. Fire Brigade Member #2 (AO) N/A N/A4. Fire Brigade Member #3 (Mechanical Maintenance

1) N/A N/A5. Fire Brigade Member #4 (Mechanical Maintenance

1) N/A N/APage 35 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX 7Attachfmen_2:

NE!-10-05 Appendix B On-Shift Staffing Analysis Results TablesAnalysis Event #3 -Steam Generator Tube RuptureTABLE 4 -Radiation Protection and Chemistry SPos ition Performing Fun ctionlTask Performance Time Period After Emergency Declaration (minutes) P o o F n0-10 10-20 20-30 30-40 40-50 50-60 60-70 70-80 80-90In-Plant Radiological Survey1. On-Shift Position: HP Shift Lead X X X X X X X X XOn-Site Radiological Survey2. On-Shift Position: Personnel Monitoring

3. On-Shift Position:

Job Coverage4. On-Shift Position: HP Shift Lead XOffsite Radiological Assessment

5. On-Shift Position:

HP Count Room XCenter Set-Up6. On-Shift Position: Sampling Activities On-Shift Position: Chemistry Specialist X X XHP Count Room X X XChemistry function/task

1. 2 -Describe:

8. On-Shift Position:

Note: The basis for the selected performance time period was established by the subject matter experts during the task analysis review. Specific performance time periods for concurrent tasks will be analyzed as part of the time motion study.Page 36 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX 7Attachment 2: NEI 10-05 Appendix B On-Shift Staffing Analysis Results TablesAnalysis Event #3 -Steam Generator Tube RuptureTABLE 5 -Emergency Plan Implementation Line- Function/Task

OnShift Position Task AnalysisSFus O f P n Controlling MethodOPs Training Program1. Declare the Emergency Classification Level (ECL) Shift Supervisor EP Drill Program2. Approve Offsite Protective Action Recommendations Shift Supervisor EP Drill Program3. Approve content of State/local notifications Shift Supervisor EP Drill Program4. Approve extension to allowable dose limits N/A N/A5. Notification and direction to on-shift staff (e.g., to assemble,

evacuate, etc.) Shift Supervisor EP Drill Program6. ERO notification Communicator (STS) EP Drill Program7. Abbreviated NRC notification for DBT event N/A N/A8. Complete State/local notification form Shift Supervisor OPs Training ProgramEP Drill Program9. Perform State/local notifications Communicator (STS) OPs Training ProgramEP Drill Program10. Complete NRC event notification form Shift Supervisor EP Drill Program11. Activate ERDS Communicator (STS) EP Drill Program12. Offsite radiological assessment N/A N/A13. Perform NRC notifications I&C Maintenance EP Drill Program14. Perform other site-specific event notifications (e.g., INPO, ANI, etc.) N/A N/A15. Personnel accountability Security Maintenance Note:Lins_3,8nd#9incudeinitilandfoow-uStae/localntificatiElectrical MaintenanceEDlo Note: Lines #3, #8 and #9 include initial and follow-up State/local notifications.

Page 37 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX 7.Attachment 2-: H-NEI 0O-05 Appendix B On-ShiiftStaffing-Analysis Results TablesAnalysis Event #5 -Fuel HandlingTABLE 1 -On-Shift Positions Accident Outside Containment Line On-shift Position Emergency Plan Reference Augmentation Role in Unanalyzed TMSElapsed Time (min) Table#/Line# Task? Required?

1. Shift Supervisor Table 2-1 2/15/15/35/3 No No5/55/85/102. CR Supervisor Table 2-1 2/2 No No3. Shift Engineer (STA) Table 2-1 2/3 No No4. Control Room Operator (NRO) Table 2-1 2/4 No No5. Control Room Operator (BOP) Table 2-1 2/5 No No6. Auxiliary Operator (CBAO) Table 2-1 2/6 No No7. Auxiliary Operator (TBAO) Table 2-1 N/A No No8. Auxiliary Operator (IBAO) Table 2-1 N/A No No9. Auxiliary Operator (ABUAO) Table 2-1 N/A N/A N/A10. Auxiliary Operator (ABLAO) Table 2-1 N/A No No11. Shift Communicator (STS) Table 2-1 5/65/9 No No5/1112. HP Shift Lead Table 2-1 90 4/1 No No13. HP Count Room Table 2-1 90 4/547No Yes4/714. Chemistry Specialist Table 2-1 90 4/7 No No15. Mechanical Maintenance 1 Table 2-1 N/A N/A N/A16. Mechanical Maintenance 2 Table 2-1 N/A N/A N/A17. I&C Maintenance Table 2-1 5/13 No No18. Electrical Maintenance Table 2-1 5/15 No No19. Security Force Supervisor Table 2-1 5/15 No NoPage 38 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX 7Attachment 2: -NEI 10-05 Appendix B On-Shift Staffing Analysis Results TablesAnalysis Event #5 -Fuel Handling Accident Outside Containment TABLE 2 -Plant Operations

& Safe ShutdownMinimum Operations Crew (One Unit -One Control Room)Line Generic Title/Role On-Shift Position Task Description Controlling Method1. Shift Manager Shift Supervisor Plant and crew oversight OPs Training Program2. Unit Supervisor CR Supervisor Direct AOP actions OPs Training Program3. Shift Technical Advisor Shift Engineer (STA) STA tasks OPs Training Program4. Reactor Operator

1. 1 Control Room Operator (NRO) Perform GOP actions OPs Training Program5. Reactor Operator
2. 2 Control Room Operator (BOP) Perform GOP actions OPs Training Program6. Auxiliary Operator
3. 1 Auxiliary Operator (CBAO) Perform in-plant actions OPs Training Program7. Auxiliary Operator
4. 2 Auxiliary Operator (TBAO) N/A N/A8. Other Auxiliary Operator (IBAO) N/A N/A9. Other Auxiliary Operator (ABUAO) N/A N/A10. Other Auxiliary Operator (ABLAO) N/A N/AOther (non-Operations)

Personnel Line Generic Title/Role

• On-Shift Position Task Description Controlling Method15. Mechanic Mechanical Maintenance 1 N/A N/A16. Mechanic Mechanical Maintenance 2 N/A N/A17. I&C Technician I&C Maintenance N/A N/A18. Electrician Electrical Maintenance N/A N/AAnalysis Event #5 -Fuel Handling Accident Outside Containment TABLE 3 -Firefighting Line Performed By Task Description Controlling Method1. Fire Brigade Leader (AO) N/A N/A2. Fire Brigade Member #1 (AO) N/A N/A3. Fire Brigade Member #2 (AO) N/A N/A4. Fire Brigade Member #3 (Mechanical Maintenance

1) N/A N/A5. Fire Brigade Member #4 (Mechanical Maintenance

1) N/A N/APage 39 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX 7Attachment-2:

-NEI.10-05 Appendix B On-Shift Staffing Analysis Results TablesAnalysis Event #5 -Fuel Handling Accident Outside Containment TABLE 4 -Radiation Protection and Chemistry

1. .Position Performing Function/Task Performance Time Period After Emerg ency Declaration (minutes) 0-10 10-20 20-30 30-40 40-50 50-60 60-70 70-80 80-90In-Plant Radiological Survey1. On-Shift Position:

HP Shift Lead X XOn-Site Radiological Survey2. On-Shift Position: Personnel Monitoring

3. On-Shift Position:

Job Coverage4. On-Shift Position: Offsite Radiological Assessment

5. On-Shift Position:

HP Count Room X XCenter Set-Up6. On-Shift Position: Sampling Activities On-Shift Position: Chemistry Specialist X XHP Count Room X X X XChemistry function/task

1. 2 -Describe:

8. On-Shift Position:

Note: The basis for the selected performance time period was established by the subject matter experts during the task analysis review. Specific performance time periods for concurrent tasks will be analyzed as part of the time motion study.Page 40 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX 7Attachment 2: NEI 10-05 Appendix B On-Shift Staffing Analysis Results Tables -Analysis Event #5 -Fuel Handling Accident Outside Containment TABLE 5 -Emergency Plan Implementation -f Task AnalysisLine- Function/Task' On-Shift Position Controlling MethodOPs Training Program1. Declare the Emergency Classification Level (ECL) Shift Supervisor EP Drill Program2. Approve Offsite Protective Action Recommendations N/A EP Drill Program3. Approve content of State/local notifications Shift Supervisor EP Drill Program4. Approve extension to allowable dose limits N/A N/A5. Notification and direction to on-shift staff (e.g., to assemble,

evacuate, etc.) Shift Supervisor EP Drill Program6. ERO notification Communicator (STS) EP Drill Program7. Abbreviated NRC notification for DBT event N/A N/A8. Complete State/local notification form Shift Supervisor OPs Training ProgramEP Drill Program9. Perform State/local notifications Communicator (STS) OPs Training ProgramEP Drill Program10. Complete NRC event notification form Shift Supervisor EP Drill Program11. Activate ERDS Communicator (STS) EP Drill Program12. Offsite radiological assessment N/A N/A13. Perform NRC notifications I&C Maintenance EP Drill Program14. Perform other site-specific event notifications (e.g., INPO, ANI, etc.) N/A N/APersonnel accountability Security N/A15. PrnlcElectrical Maintenance Note: Lines #3, #8 and #9 include initial and follow-up State/local notifications.

Page 41 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX 7Attachment 2: NEI 10-05 Appendix B On-Shift Staffing Analysis Results TablesAnalysis Event #7 -Design Basis Threat (DBT)TABLE I -On-Shift Positions Line On-shift Position Emergency Plan Reference Augmentation Role in Unanalyzed TMSElapsed Time (min) Table#/Line# Task? Required?

1. Shift Supervisor Table 2-1 2/15/15/35/5 No No5/75/85/102. CR Supervisor Table 2-1 2/2 No No3. Shift Engineer (STA) Table 2-1 2/3 No No4. Control Room Operator (NRO) Table 2-1 2/4 No No5. Control Room Operator (BOP) Table 2-1 2/5 No No6. Auxiliary Operator (CBAO) Table 2-1 2/6 No No7. Auxiliary Operator (TBAO) Table 2-1 2/7 No No8. Auxiliary Operator (IBAO) Table 2-1 2/8 No No9. Auxiliary Operator (ABUAO) Table 2-1 N/A No No10. Auxiliary Operator (ABLAO) Table 2-1 N/A No No11. Shift Communicator (STS) Table 2-1 5/65/9 No No5/1112. HP Shift Lead Table 2-1 90 N/A No No13. HP Count Room Table 2-1 90 N/A No No14. Chemistry Specialist Table 2-1 90 N/A No No15. Mechanical Maintenance 1 Table 2-1 N/A No No16. Mechanical Maintenance 2 Table 2-1 N/A No No17. I&C Maintenance Table 2-1 5/13 No No18. Electrical Maintenance Table 2-1 N/A No No19 Security Force Supervisor Table 2-1 N/A No NoPage 42 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX 7Attachment 2: --N-l-0-l(5-AO-iAppendixB-On-Shli-ft-S-taffi-g-Analysis-Result-s Tables ------Analysis Event #7 -Design Basis Threat (DBT)TABLE 2 -Plant Operations

& Safe ShutdownMinimum Operations Crew (One Unit -One Control Room)Line Generic Title/Role On-Shift Position Task Description Controlling Method1. Shift Manager Shift Supervisor Plant and crew oversight OPs Training Program2. Unit Supervisor CR Supervisor Direct EOP and EPP-027 actions OPs Training ProgramEP Drill Program3. Shift Technical Advisor Shift Engineer (STA) STA tasks OPs Training Program4. Reactor Operator

1. 1 Control Room Operator (NRO) Perform CR EOP and EPP-027 OPs Training Programactions EP Drill Program5. Reactor Operator
2. 2 Control Room Operator (BOP) Perform CR EOP and EPP-027 OPs Training Programactions EP Drill Program6. Auxiliary Operator
3. 1 Auxiliary Operator (CBAO) Perform In-plant EOP actions OPs Training Program7. Auxiliary Operator
4. 2 Auxiliary Operator (TBAO) Perform EPP-027 actions EP Drill Program8. Other Auxiliary Operator (IBAO) Perform In-plant EOP actions OPs Training Program9. Other Auxiliary Operator (ABUAO) N/A N/A10. Other Auxiliary Operator (ABLAO) N/A N/AOther (non-Operations)

Personnel .Line-

• Generic Title/Role On-Shift Position Task Description

..Controlling Method15. Mechanic Mechanical Maintenance 1 N/A N/A16. Mechanic Mechanical Maintenance 2 N/A N/A17. I&C Technician I&C Maintenance N/A N/A18. Electrician Electrical Maintenance N/A N/APage 43 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX 7Attachment 2:---NEI10-05-Appendix B On-Shift Staffing Analysis Results TablesAnalysis Event #7 -Design Basis Threat (DBT)TABLE 3 -Firefighting Line Performed By Task Description Controlling Method1. Fire Brigade Leader (AO) N/A N/A2. Fire Brigade Member #1 (AO) N/A N/A3. Fire Brigade Member #2 (AO) N/A N/A4. Fire Brigade Member #3 (Mechanical Maintenance

1) N/A N/A5. Fire Brigade Member #4 (Mechanical Maintenance

1) N/A N/APage 44 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX 7i Attachment 2:-NEI 10-05 Appendix B On-Shift StaffingqAnalysis Results TablesAnalysis Event #7 -Design Basis Threat (DBT)TABLE 4 -Radiation Protection and Chemistry SPosition Performing Function/Task Performance Time Period After Emergency Declaration (minutes) 0-10 10-20 20-30 30-40 40-50 50-60 60-70 70-80 80-90In-Plant Radiological Survey1. On-Shift Position:

N/A N/A N/A N/A N/A N/A N/A N/A N/AOn-Site Radiological Survey2. On-Shift Position: N/A N/A N/A N/A N/A N/A N/A N/A N/APersonnel Monitoring

3. On-Shift Position:

N/A N/A N/A N/A N/A N/A N/A N/A N/AJob Coverage4. On-Shift Position: N/A N/A N/A N/A N/A N/A N/A N/A N/AOffsite Radiological Assessment

5. On-Shift Position:

N/A N/A N/A N/A N/A N/A N/A N/A N/ACenter Set-Up6. On-Shift Position: N/A N/A N/A N/A N/A N/A N/A N/A N/AChemistry function/task

1. 1 -Describe:

7. On-Shift Position:

N/A N/A N/A N/A N/A N/A N/A N/A N/AChemistry function/task

1. 2 -Describe:

8. On-Shift Position:

N/A N/A N/A N/A N/A N/A N/A N/A N/ANote: The basis for the selected performance time period was established by the subject matter experts during the task analysis review. Specific performance time periods for concurrent tasks will be analyzed as part of the time motion study.Page 45 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX 7Attachment 2: NEI 10-05 Appendix B On-Shift Staffing Analysis Results Tables,Analysis Event #7 -Design Basis Threat (DBT)TABLE 5 -Emergency Plan Implementation Line Function/Task On-Shift Position Task AnalysisControlling MethodPg1 Declare the Emergency Classification Level (ECL) Shift Supervisor OPs Training Program* EP Drill Program2. Approve Offsite Protective Action Recommendations N/A EP Drill Program3. Approve content of State/local notifications Shift Supervisor EP Drill Program4. Approve extension to allowable dose limits N/A N/A5. Notification and direction to on-shift staff (e.g., to assemble,

evacuate, etc.) Shift Supervisor EP Drill Program6. ERO notification Communicator (STS) EP Drill Program7. Abbreviated NRC notification for DBT event Shift Supervisor EP Drill program8. Complete State/local notification form Shift Supervisor OPs Training ProgramEP Drill Program9. Perform State/local notifications Communicator (STS) OPs Training ProgramEP Drill Program10. Complete NRC event notification form Shift Supervisor EP Drill Program11. Activate ERDS Communicator EP Drill Program12. Offsite radiological assessment N/A N/A13. Perform NRC notifications I&C Maintenance EP Drill Program14. Perform other site-specific event notifications (e.g., INPO, ANI, etc.) N/A N/A15. Personnel accountability N/A N/ANote: Lines #3, #8 and #9 include initial and follow-up State/local notifications.

Page 46 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX 7Attachment 2: NEI 10-05 Appendix B On-Shift Staffing Analysis Results Tables -.. -..Analysis Event #8 -Aircraft Probable ThreatTABLE I -On-Shift Positions ...Augmentation .Role in Unanalyzed TMSLine On-shift Position Emergency Plan -Reference Apsed time mole# in Task? Re urd.......Elapsed Time (min) Table#/Line# Task? Required?

1. Shift Supervisor Table 2-1 2/15/15/35/3 No No5/55/85/102. CR Supervisor Table 2-1 2/2 No No3. Shift Engineer (STA) Table 2-1 2/3 No No4. Control Room Operator (NRO) Table 2-1 2/4 No No5. Control Room Operator (BOP) Table 2-1 2/5 No No6. Auxiliary Operator (CBAO) Table 2-1 2/6 No No7. Auxiliary Operator (TBAO) Table 2-1 2/7 No No8. Auxiliary Operator (IBAO) Table 2-1 2/8 No No9. Auxiliary Operator (ABUAO) Table 2-1 2/9 No No10. Auxiliary Operator (ABLAO) Table 2-1 2/10 No No11. Shift Communicator (STS) Table 2-1 5/65/9 No No5/1112. HP Shift Lead Table 2-1 90 N/A N/A N/A13. HP Count Room Table 2-1 90 N/A N/A N/A14. Chemistry Specialist Table 2-1 90 N/A N/A N/A15. Mechanical Maintenance 1 Table 2-1 2/12 No No16. Mechanical Maintenance 2 Table 2-1 2/13 No No17. I&C Maintenance Table 2-1 5/13 No No18. Electrical Maintenance Table 2-1 N/A N/A N/A19 Security Force Supervisor Table 2-1 N/A N/A N/APage 47 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX 7Attachment.2:

NEI 10-05 Appendix B On-Shift Staffing Analysis Results TablesAnalysis Event #8 -Aircraft Probable ThreatTABLE 2 -Plant Operations & Safe ShutdownMinimum Operations Crew (One Unit -One Control Room)Line Generic Title/Role On-Shift Position Task Description Controlling Method1. Shift Manager Shift Supervisor Plant and crew oversight OPs Training Program2. Unit Supervisor CR Supervisor Direct GOP/EPP actions OPs Training Program3. Shift Technical Advisor Shift Engineer (STA) STA tasks OPs Training Program4. Reactor Operator

1. 1 Control Room Operator (NRO) Perform GOP actions OPs Training Program5. Reactor Operator
2. 2 Control Room Operator (BOP) Perform GOP actions OPs Training Program6. Auxiliary Operator
3. 1 Auxiliary Operator (CBAO) Perform EPP-27 actions OPs Training Program7. Auxiliary Operator
4. 2 Auxiliary Operator (TBAO) Perform EPP-27 actions OPs Training Program8. Other Auxiliary Operator (IBAO) Perform EPP-27 actions OPs Training Program9. Other Auxiliary Operator (ABUAO) EPP-27 ENC B actions OPs Training Program10. Other Auxiliary Operator (ABLAO) Perform EPP-27 actions OPs Training ProgramOther (non-Operations)

Personnel Line Generic Title/Role On-Shift Position Task Description Controlling Method15. Mechanic Mechanical Maintenance 1 N/A N/A16. Mechanic Mechanical Maintenance 2 N/A N/A17. I&C Technician I&C Maintenance N/A* N/A18. Electrician Electrical Maintenance N/A N/A* Reports to Control Room to support EP function of NRC Communicator Analysis Event #8 -Aircraft Probable ThreatTABLE 3 -Firefighting Line Performed By Task Description Controlling Method1. Fire Brigade Leader (AO) N/A N/A2. Fire Brigade Member #1 (AO) N/A N/A3. Fire Brigade Member #2 (AO) N/A N/A4. Fire Brigade Member #3 (Mechanical Maintenance

1) N/A N/A5. Fire Brigade Member #4 (Mechanical Maintenance

1) N/A N/APage 48 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX 7Attachment 2: NEI 10-05 Appendix BOn-Shift Analysis Event #8 -Aircraft Probable ThreatTABLE 4- Radiation Protection and Chemistry Staffing Analysis Results Tables# Position Performing Function/Task

_Performance Time Period After Emergency Declaration (minutes) 0-10 10-20 20-30 30-40 40-50 50-60 60-70 70-80 80-90In-Plant Radiological Survey1. On-Shift Position: N/A N/A N/A N/A N/A N/A N/A N/A N/AOn-Site Radiological Survey2. On-Shift Position: N/A N/A N/A N/A N/A N/A N/A N/A N/APersonnel Monitoring

3. On-Shift Position:

N/A N/A N/A N/A N/A N/A N/A N/A N/AJob Coverage4. On-Shift Position: N/A N/A N/A N/A N/A N/A N/A N/A N/AOffsite Radiological Assessment

5. On-Shift Position:

N/A N/A N/A N/A N/A N/A N/A N/A N/ACenter Set-Up6. On-Shift Position: N/A N/A N/A N/A N/A N/A N/A N/A N/AChemistry function/task

1. 1 -Describe:

7. On-Shift Position:

N/A N/A N/A N/A N/A N/A N/A N/A N/AChemistry function/task

1. 2 -Describe:

8. On-Shift Position:

N/A N/A N/A N/A N/A N/A N/A N/A N/ANote: The basis for the selected performance time period was established by the subject matter experts during the task analysis review. Specific performance time periods for concurrent tasks will be analyzed as part of the time motion study.Page 49 VCSI On-Shift Staffing AnalysisEP-100 APPENDIX 7Attachment 2: NEI 10-05 Appendix B On-Shift Staffing Analysis Results TablesAnalysis Event #8 -Aircraft Probable ThreatTABLE 5- Emergency Plan Implementation Line Function/Task On-Shift Position Task AnalysisControlling MethodOPs Training Program1. Declare the Emergency Classification Level (ECL) Shift Supervisor EP Drill Program2. Approve Offsite Protective Action Recommendations N/A N/A3. Approve content of State/local notifications Shift Supervisor EP Drill Program4. Approve extension to allowable dose limits N/A N/A5. Notification and direction to on-shift staff (e.g., to assemble,

evacuate, etc.) Shift Supervisor EP Drill Program6. ERO notification Communicator (STS) EP Drill Program7. Abbreviated NRC notification for DBT event N/A N/A8. Complete State/local notification form Shift Supervisor OPs Training ProgramEP Drill Program9. Perform State/local notifications Communicator (STS) OPs Training ProgramEP Drill Program10. Complete NRC event notification form Shift Supervisor EP Drill Program11. Activate ERDS Communicator (STS) EP Drill Program12. Offsite radiological assessment N/A N/A13. Perform NRC notifications I&C Maintenance EP Drill Program14. Perform other site-specific event notifications (e.g., INPO, ANI, etc.) N/A N/A15. Personnel accountability N/A N/ANote: Lines #3, #8 and #9 include initial and follow-up State/local notifications.

Page 50 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX 7'Attachment 2:l NE .l10-05-Appendix B- On-Shift Staffing Analysis ResultsTables Analysis Event #9 -Control RoomTABLE I -On-Shift Positions Fire Leading to Evacuation

• Augmentations...

Role in Unanalyzed TMVSLine On-shift Position Emergency Plan Reference augmentain. Role#in UnTask?nalyzedired Elapsed Time (min) Table#ILine# Ts? Required? 1 Shift Supervisor Table 2-1 2/15/15/3 No No5/55/85/102. CR Supervisor Table 2-1 2/2 No No3. Shift Engineer (STA) Table 2-1 2/3 No No4. Control Room Operator (NRO) Table 2-1 2/4 No No5. Control Room Operator (BOP) Table 2-1 2/5 No No6. Auxiliary Operator (CBAO) Table 2-1 3/1 No No7. Auxiliary Operator (TBAO) Table 2-1 3/2 No No8. Auxiliary Operator (IBAO) Table 2-1 2/8 No No9. Auxiliary Operator (ABUAO) Table 2-1 2/9 No No10. Auxiliary Operator (ABLAO) Table 2-1 3/3 No No11. Shift Communicator (STS) Table 2-1 2/11 No No12. HP Shift Lead Table 2-1 90 N/A N/A N/A13. HP Count Room Table 2-1 90 N/A N/A N/A14. Chemistry Specialist Table 2-1 90 N/A N/A N/A15. Mechanical Maintenance 1 Table 2-1 3/4 No No16. Mechanical Maintenance 2 Table 2-1 3/5 No No17. I&C Maintenance Table 2-1 5/65/9 No No5/1318. Electrical Maintenance Table 2-1 2/18 No No19 Security Force Supervisor Table 2-1 N/A N/A N/APage 51 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX 7Attachment 2: NEI 10-05 Appendix B On-Shift Staffing Analysis Results TablesAnalysis Event #9 -Control Room Fire Leading to Evacuation TABLE 2 -Plant Operations & Safe ShutdownMinimum Operations Crew (One Unit -One Control Room)Line Generic Title/Role On-Shift Position Task Description Controlling Method1. Shift Manager Shift Supervisor Plant and crew oversight OPs Training Program2. Unit Supervisor CR Supervisor Perform FEP-4.0 actions OPs Training Program3. Shift Technical Advisor Shift Engineer (STA) STA tasks OPs Training Program4. Reactor Operator

1. 1 Control Room Operator (NRO) Perform FEP-4.0 actions OPs Training Program5. Reactor Operator
2. 2 Control Room Operator (BOP) Perform FEP-4.0 actions OPs Training Program6. Auxiliary Operator
3. 1 Auxiliary Operator (CBAO) N/A N/A7. Auxiliary Operator
4. 2 Auxiliary Operator (TBAO) N/A N/A8. Other Auxiliary Operator (IBAO) Perform FEP-4.0 actions OPs Training Program9. Other Auxiliary Operator (ABUAO) Perform FEP-4.0 actions OPs Training Program10. Other Auxiliary Operator (ABLAO) N/A N/AOther (non-Operations)

Personnel Line Generic Title/Role On-Shift Position Task Description Controlling Method11. Other Shift Communicator (STS) Perform FEP-4.0 actions Fire Protection Program15. Mechanic Mechanical Maintenance 1 N/A N/A16. Mechanic Mechanical Maintenance 2 N/A N/A17. I&C Technician I&C Maintenance N/A N/A18. Electrician Electrical Maintenance Perform FEP-4.0 actions Fire Protection ProgramAnalysis Event #9 -Control Room Fire Leading to Evacuation TABLE 3 -Firefighting Line Performed By Task Description Controlling Method1. Fire Brigade Leader (CBAO) Firefighting Activities Fire Protection Program2. Fire Brigade Member #1 (TBAO) Firefighting Activities Fire Protection Program3. Fire Brigade Member #2 (ABLAO) Firefighting Activities Fire Protection Program4. Fire Brigade Member #3 (Mechanical Maintenance

1) Firefighting Activities Fire Protection Program5. Fire Brigade Member #4 (Mechanical Maintenance

1) Firefighting Activities Fire Protection ProgramPage 52 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX 7Attachment 2: NEI10-05 Appendix B On-Shift Staffing Analysis Results TablesAnalysis Event #9 -Control Room Fire Leading to Evacuation TABLE 4 -Radiation Protection and Chemistry

1. Position Performing Function/Task Performance Time Period After Emer ency Declaration (minutes) 0-10 10-20 20-30 30-40 40-50 50-60 60-70 70-80 80-90In-Plant Radiological Survey1. On-Shift Position:

N/A N/A N/A N/A N/A N/A N/A N/A N/AOn-Site Radiological Survey2. On-Shift Position: N/A N/A N/A N/A N/A N/A N/A N/A N/APersonnel Monitoring

3. On-Shift Position:

N/A N/A N/A N/A N/A N/A N/A N/A N/AJob Coverage4. On-Shift Position: N/A N/A N/A N/A N/A N/A N/A N/A N/AOffsite Radiological Assessment

5. On-Shift Position:

N/A N/A N/A N/A N/A N/A N/A N/A N/ACenter Set-Up6. On-Shift Position: N/A N/A N/A N/A N/A N/A N/A N/A N/AChemistry function/task

1. 1 -Describe:

7. On-Shift Position:

N/A N/A N/A N/A N/A N/A N/A N/A N/AChemistry function/task

1. 2 -Describe:

8. On-Shift Position:

N/A N/A N/A N/A N/A N/A N/A N/A N/ANote: The basis for the selected performance time period was established by the subject matter experts during the task analysis review. Specific performance time periods for concurrent tasks will be analyzed as part of the time motion study.Page 53 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX 7Attachment 2:_ NEI 10-05 Appendix B On--Shift Staffing Analysis Results TablesAnalysis Event #9 -Control Room Fire Leading to Evacuation TABLE 5 -Emergency Plan Implementation Line Function/Task On-Shift Position Task AnalysisControlling Method1. Declare the Emergency Classification Level (ECL) Shift Supervisor OPs Training ProgramEP Drill Program2. Approve Offsite Protective Action Recommendations N/A EP Drill Program3. Approve content of State/local notifications Shift Supervisor EP Drill Program4. Approve extension to allowable dose limits N/A N/A5. Notification and direction to on-shift staff (e.g., to assemble,

evacuate, etc.) Shift Supervisor EP Drill Program6. ERO notification I&C Maintenance EP Drill Program7. Abbreviated NRC notification for DBT event N/A N/A8. Complete State/local notification form Shift Supervisor OPs Training ProgramEP Drill Program9. Perform State/local notifications I&C Maintenance OPs Training ProgramEP Drill Program10. Complete NRC event notification form Shift Supervisor EP Drill Program11. Activate ERDS None None12. Offsite radiological assessment N/A EP Drill Program13. Perform NRC notifications I&C Maintenance EP Drill Program14. Perform other site-specific event notifications (e.g., INPO, ANI, etc.) N/A N/A15. Personnel accountability N/A N/ANote: Lines #3, #8 and #9 include initial and follow-up State/local notifications.

Line #11: capability to activate ERDS when Control Room is not habitable does not exist at this time.Page 54 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX 7,Attachment 2:, _NEI10-05 Appendix B On-Shift Staffing Analysis Results TablesAnalysis Event #10 -Station Blackout (SBO)TABLE I -On-Shift Positions,"Augmentation " Role in Unanalyzed TMVSLine -On-shift Position Emergency-Plan Reference augmentain Role#in Unaalye TMSElapsed Time (min) Table#ILine# Task? Required?

1. Shift Supervisor Table 2-1 2/15/15/35/5 No No5/55/85/102. CR Supervisor Table 2-1 2/2 No No3. Shift Engineer (STA) Table 2-1 2/3 No No4. Control Room Operator (NRO) Table 2-1 2/4 No No5. Control Room Operator (BOP) Table 2-1 2/5 No No6. Auxiliary Operator (CBAO) Table 2-1 N/A N/A N/A7. Auxiliary Operator (TBAO) Table 2-1 2/7 No No8. Auxiliary Operator (IBAO) Table 2-1 N/A N/A N/A9. Auxiliary Operator (ABUAO) Table 2-1 2/9 N/A N/A10. Auxiliary Operator (ABLAO) Table 2-1 N/A N/A N/A11. Shift Communicator (STS) Table 2-1 5/65/9 No No5/1112. HP Shift Lead Table 2-1 90 4/1 No No13. HP Count Room Table 2-1 90 N/A N/A N/A14. Chemistry Specialist Table 2-1 90 N/A N/A N/A15. Mechanical Maintenance 1 Table 2-1 N/A N/A N/A16. Mechanical Maintenance 2 Table 2-1 N/A N/A N/A17. I&C Maintenance Table 2-1 5/13___ _ ___ __ __ ___ __ __ ___ _ ___ __ __ ___ __ __ ___ _ ___ __ __ ___ 515No No5/1518. 1Electrical Maintenance Table 2-1 N/A N/A N/A19 Security Force Supervisor Table 2-15/15NoNoPage 55 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX 7Attachmenti2:

NE11-0-05 Appendix B On-Shift Staffing Analysis Results TablesAnalysis Event #10 -Station Blackout (SBO)TABLE 2 -Plant Operations & Safe ShutdownMinimum Operations Crew (On Units -One Control Room)Line Generic Title/Role On-Shift Position Task Description Controlling Method1. Shift Manager Shift Supervisor Plant and crew oversight OPs Training Program2. Unit Supervisor CR Supervisor Directs EOP actions OPs Training Program3. Shift Technical Advisor Shift Engineer (STA) STA tasks OPs Training Program4. Reactor Operator

1. 1 Control Room Operator (NRO) Performs EOP actions OPs Training Program5. Reactor Operator
2. 2 Control Room Operator (BOP) Perform s EOP actions OPs Training Program6. Auxiliary Operator
3. 1 Auxiliary Operator (CBAO) N/A N/A7. Auxiliary Operator
4. 2 Auxiliary Operator (TBAO) Performs in-plant actions OPs Training Program8. Other Auxiliary Operator (IBAO) N/A N/A9. Other Auxiliary Operator (ABUAO) Performs in-plant actions Ops Training Program10. Other Auxiliary Operator (ABLAO) N/A N/AOther (non-Operations)

Personnel Line Generic Title/Role On-Shift Position Task Description Controlling Method15. Mechanic Mechanical Maintenance 1 N/A N/A16. Mechanic Mechanical Maintenance 2 N/A N/A17. I&C Technician I&C Maintenance N/A N/A18. Electrician Electrical Maintenance N/A N/AAnalysis Event #10 -Station Blackout (SBO)TABLE 3 -Firefighting Line Performed By Task Description Controlling Method1. Fire Brigade Leader (AO) N/A N/A2. Fire Brigade Member #1 (AO) N/A N/A3. Fire Brigade Member #2 (AO) N/A N/A4. Fire Brigade Member #3 (Mechanical Maintenance

1) N/A N/A5. Fire Brigade Member #4 (Mechanical Maintenance

1) N/A N/APage 56 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX 7Attachment-2:_

N-EIl 10-_05- Appendix B On-Shift Staffing Analysis Results TablesAnalysis Event #10 -Station Blackout (SBO)TABLE 4 -Radiation Protection and Chemistry SPosition Performing Function/Task Performance Time Period After Emergency Declaration (minutes) 0-10 10-20 20-30 30-40 40-50 50-60 60-70 70-80 80-90In-Plant Radiological Survey1. On-Shift Position: HP Shift Lead XOn-Site Radiological Survey2. On-Shift Position: Personnel Monitoring

3. On-Shift Position:

Job Coverage4. On-Shift Position: Offsite Radiological Assessment

5. On-Shift Position:

Center Set-Up6. On-Shift Position: Chemistry function/task

1. 1 -Describe:

7. On-Shift Position:

Chemistry function/task

1. 2 -Describe:

8. On-Shift Position:

Note: The basis for the selected performance time period was established by the subject matter experts during the task analysis review. Specific performance time periods for concurrent tasks will be analyzed as part of the time motion study.Page 57 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX 7Attachment2: NEI 10-05 Appendix B On-Shift Staffing Analysis Results TablesAnalysis Event #10 -Station Blackout (SBO)TABLE 5 -Emergency Plan Implementation Line Function/Task On-Shift Position Task AnalysisControlling Method1 Declare the Emergency Classification Level (ECL) Shift Supervisor OPs Training Program* EP Drill Program2. Approve Offsite Protective Action Recommendations N/A EP Drill Program3. Approve content of State/local notifications Shift Supervisor EP Drill Program4. Approve extension to allowable dose limits N/A N/A5. Notification and direction to on-shift staff (e.g., to assemble,

evacuate, etc.) Shift Supervisor EP Drill Program6. ERO notification Communicator (STS) EP Drill Program7. Abbreviated NRC notification for DBT event N/A N/A8. Complete State/local notification form Shift Supervisor OPs Training ProgramEP Drill Program9. Perform State/local notifications Communicator (STS) OPs Training ProgramEP Drill Program10. Complete NRC event notification form Shift Supervisor EP Drill Program11. Activate ERDS Communicator (STS) EP Drill Program12. Offsite radiological assessment N/A N/A13. Perform NRC notifications I&C Maintenance EP Drill Program14. Perform other site-specific event notifications (e.g., INPO, ANI, etc.) N/A N/A15. Personnel accountability Security N/ANote: _Lies_3,

_and_9includenitialadfoll_-upStat/localntificat&C Maintenance N/ANote: Lines #3, #8 and #9 include initial and follow-up State/local notifications. Page 58 VCS1 On-Shift Staffing AnalysisEP-100 APPENDIX 7Attachme-nt-3:--- NEi_10-05 Appendix D&E On-Shift Staffing Analysis Results TablesAn~lv~i~ EvAnt ~2 -5~tA~m C~~n~r~tnr t.ih~ PlintlirA 1~TR~Pn~itinn HP (~n.mnt RnnmI ind= Analvsis Event #2 -Steam Generator tube Rupture IS TRI Position: HP Count Room I ina fim 1 -11Appendix D: Function / Responsibility (Task) AnalysisI Function Responsibility (Task) Action Step Duration1. Radiological Assessment 1.1 Perform Dose Assessment (4/5) EPP-005 Step 4.2 & Attachment XXII Step B 12Appendix E: Work Activities AnalysisTime Plant/equipmentlenvironmental events and conditions Task / Action Step description applicable to the functions and tasks (start & stop)Actions completed in the HP Count Room. Refer to section Receive call to perform dose assessment 3.4.8.2 for event and conditions description. (0955 -0956)Actions completed in the HP Count Room. Refer to section Read procedure 3.4.8.2 for event and conditions description. (0956 -0958)1003 Actions completed in the HP Count Room. Refer to section Adjust printer3.4.8.2 for event and conditions description. (1003 -1003.5)1004 Actions completed in the HP Count Room. Refer to section Start MIDAS Program3.4.8.2 for event and conditions description. (1004 -1005)1005 Actions completed in the HP Count Room. Refer to section Entered data3.4.8.2 for event and conditions description. (1005 -1005.5)1024 Actions completed in the HP Count Room. Refer to section Call lED with results3.4.8.2 for event and conditions description. (1006 -1007)Page 59 VCSI On-Shift Staffing AnalysisEP-100 APPENDIX 7Attachiment 3: NEIl10-05 Appendix D&E On-Shift Staffing Analysis Results TablesAnalysis Event #3 -Fuel Handlina Accident (FHAIPosition: HP Count RoomLine#: 1-13Appendix D: Function / Responsibility (Task) AnalysisSFunction Responsibility (Task) Iction Step Duration1. Radiological Assessment 1.1 Perform Dose Assessment (4/5) EPP-005 Step 4.2 & Attachment XXII Step B 12Appendix E: Work Activities AnalysisTime Plant/equipment/environmental events and conditions Task I Action Step description applicable to the functions and tasks (start & stop)Actions completed in the HP Count Room. Refer to section Receive call to perform dose assessment 354.8.2 for event and conditions description. (1035 -1036)Actions completed in the HP Count Room. Refer to section Read procedure 374.8.2 for event and conditions description. (1037 -1038)1038 Actions completed in the HP Count Room. Refer to section Adjust printer3,4.8.2 for event and conditions description. (1038 -1038.5)Actions completed in the HP Count Room. Refer to section Start MIDAS Program3,4.8.2 for event and conditions description. (1038 -1038.5)Actions completed in the HP Count Room. Refer to section Entered data3,4.8.2 for event and conditions description. (1038.5 -1046)1046 Actions completed in the HP Count Room. Refer to section Call lED with results3.4.8.2 for event and conditions description. (1046- 1047)Page 60 Document Control DeskAttachment VLAR-13-02396 RC-14-0039 Page 1 of 247VIRGIL C. SUMMER NUCLEAR STATION (VCSNS) Unit IDOCKET NO. 50-395OPERATING LICENSE NO. NPF-12ATTACHMENT VProposed Radiation Emergency Plan (EP-100 Revision

63) (Mark-Up)

SOUTH CAROLINA ELECTRIC & GAS COMPANYVIRGIL C. SUMMER NUCLEAR STATIONNUCLEAR OPERATIONS NUCLEAR OPERATIONS COPY NO.RADIATION EMERGENCY PLANEP-100REVISION xxThis text box is administrative and must be removed priorto effectiveness. Revision to this procedure is being donein preparation to support submittal to the NRC. Thisprocedure must be validated and additional revisions beyond what is referenced here, Revision 63 of the Unit 1plan, and performed under 50.54(q) or made afterSeptember 13, 2013 need to be evaluated forincorporation into this procedure before implementation. SAFETY RELATED Table of ContentsV. C. Summer Nuclear StationTable of Contents V. C. Summer Nuclear StationPart 1: Introduction .................................................................................................................. 1Section A : Purpose .......................................................................................................... 1Section B: Background ............................................................................................. IF a c ility D e s crip tio n .............................................................................................. ... ....... 1Emergency Planning Zones ........................................ 1....Section C: Scope ......................................................................................................... ISection D: Planning Basis .............................................................................................. 1Section E: Contiguous-Jurisdiction Emergency Planning ........................................... 1Section F: Integrated Guidance and Criteria ............................................................ ISection G: Funding and Technical Assistance ........................................................ ISection H: Emergency Response Organization ............................................................ 1Section 1: Federal Response ................................................................................... ISection J: Form and Content of Plan ........................................................................ IFigure 1-2: V. C. Summer Site Layout .................................... 3Figure 1-4: 50-Mile Emergency Planning Zone (Ingestion Pathway) ......................... 5Part 2: Planning Standards and Criteria ............................................................................. 6Section A: Assignment of Responsibility .................................................................

61. C oncept of O perations

................................................................................... .62. State and County Functions and Responsibilities ......................... 123. Agreem ents in Planning Effort ...................................................................... 124. Continuous Coverage ........................................... 12Figure A-i: Agency Response Organization Interrelationships .............................. 13Figure A-2: VCSNS Augmented Emergency Response Organization Interrelationships1, Section B: Emergency Response Organization ..................................................... 151. On-Shift Emergency Response Organization Assignments ............................ 152. Authority over the Emergency Response Organization .................... 173. Criteria for Assuming Command and Control (Succession) ............................ 184. N on-D elegable D uties .................................................................................. ..185. Emergency Response Organization Position Responsibilities ........................... 196. Emergency Response Organization Block Diagram ........................ 297. Industry/Private Support Organizations ............................ .............................. 29Figure B-la: Overall ERO Command Structure ....................................................... 32Figure B-lb: Onsite Emergency Response Organization ........................ 33Figure B-ic: Offsite Emergency Response Organization ............................................ 34Figure B-ld: Emergency Public Information Organization ....................................... 35Table B-la: Staffing Requirements for the VCSNS ERO ......................................... 36Section C: Emergency Response Support and Resources ................................... 401. Federal Response Support and Resources ........................................................ 40iiRev 0 Table of Contents V. C. Summer Nuclear Station2 .L ia is o n s ............... .......... ....................................................................... 4 13. Radiological Laboratories ............................................................................. 414. Other Assistance ............................................................................... 41Section D: Emergency Classification System ....................................................... 421. Emergency Classification System .................................................... 422. Emergency Action Level Technical Basis .............................. 483. Offsite Classification Systems ...................................................................... 484. Offsite Emergency Procedures ......... 4.............................................................. 49Section E: Notification Methods and Procedures ................................................... 501. Bases for Emergency Response Organization Notification .............................. 502. Notification and Mobilization of Emergency Response Personnel ................. 503. Initial Notification Messages ................ ........ ................................................. 524. Follow-Up Messages ...................................... 535. State and County Information Dissemination ................................................... 536. Notification of the Public ................................................................................ 537. Messages to the Public .................................................................................. 54Section F: Emergency Communications ..................................................................... 551. Communications/Notifications ........................................................................ 552. Medical Communications ............................................................................... 583. Communications Testing ........................ ..................................................... 584. P la nt A la rm s ............................................................................................... ..6 0Figure F-1: Notification Scheme (After Full Augmentation) .......................................... 61Figure F-2: ERF Communications Matrix ................................................................. 62Figure F-3: NRC Communications for Nuclear Response ............................................. 63Section G: Public Education and Information ........................................................ 641. Public Information Publication 6........................................................................... 642. Public Education Materials .......................................................................... 643. Media Accommodations ...................... ............ .................................... 654. Coordination of Public Information ................................................................. 665. Media Orientation ......................................................................................... 66Section H: Emergency Facilities and Equipment ................................................... 671. Control Rooms, Technical Support Center, and Operational Support Centers ...672. Emergency Operations Facility ..................................................................... 703. Joint Information Center ............................................ 724. Emergency Operations Centers ................................................................... 725. Activation ................... ..................................................... 736. Monitoring Equipment Onsite ........................................................................ 757. Monitoring Equipment Offsite .................... ......................................... 778. Offsite Monitoring Equipment Storage ................................. 789. Meteorological Monitoring ............................................................................ 79iii Rev 0 Table of Contents V. C. Summer Nuclear Station10. O S C C apabilities ......................................................................................... ..7911. Facility and Equipment Readiness .................................. 7912. Emergency Equipment and Supplies .................................. 8013. General Use Emergency Equipment ................... ......... ................... 8114. Collection Point for Field Samples ................................................................. 81Section 1: Accident Assessment ........................................................ .821. Plant Parameters and Corresponding Emergency Classification ................... 822. Onsite Accident Assessment Capabilities ............................ ........................... 823. Source Term Determ ination ......................................... ................................. 824. Effluent Monitor Data and Dose Projection .................................................. 845. M eteorologica l Inform ation .................. ........................................................... 856. Unm onitored Release ................................................................................... 857. Field Monitoring .......................................... 858. Field Teams ............................................ 869. Iodine Monitoring .......... ................ ................. 8610 .D ose E stim ates ............................................................................................. .8611. State Monitoring Capabilities .......................................... 86Section J: Protective Response ............................................................................. 871. Notification of Onsite Personnel ................................................................... 872. Evacuation Locations .............................................................. 873. Radiological Monitoring of Evacuees ............................................................... 874. Protective Actions for Onsite Personnel ......................................................... 885. Accountability .................................................. 896. Provisions for Onsite Personnel ..................................... 897. Mechanism for Implementing Protective Action Recommendations .............. 908. Evacuation Tim e Estim ate ..... ............ ............ .. ........................................ 909. Capability of Implementing Protective Action Recommendations ............... 9010. Implementation of Protective Action Recommendations ........................ 9111. Ingestion Pathway Protective Measures ....................................................... 9212. M onitoring of Evacuees................ ................. .............................................. 92Figure J-1: Sector Population Distribution ............................................................... 93Figure J-2: PA R Flow chart .............................. ............. ....................................... 94Section K: Radiological Exposure Control ............................................................ 951. Emergency Exposure Guidelines ................................................................. 952. Emergency Radiation Protection Program ..................................................... 953. Personnel M onitoring .................................................................................... 964. Non-V. C. Summer Personnel Exposure Authorization ..................................... 965. Contamination and Decontamination ............................................................ 976. Contamination Control Measures .................................... 977. Decontamination of Relocated Personnel ............. ....... ......... ..... 98iv Rev 0 Table of Contents V. C. Summer Nuclear StationSection L: Medical and Public Health Support ...................................................... 991. Offsite Hospital and Medical Service Facilities ................................................... 992, O nsite First A id C apability ..... ....................................................................... 993. M ed ica l T ransportation ..................................................................................... 10 1Section M: Reentry and Recovery Planning ............................................................... 1021. Reentry and Recovery .................................. ... 1022. R ecovery O rganization .................................................................................... 1053. Recovery Phase Notifications ...................................... .............. ....... ..... 1084. Total Population Exposure.................................. 108Section N: Drill and Exercise Program ....................................................................... 1091 .E xe rc ise s .....1............................................................................... .......... 10 92. Drills ................................................ 1113. C onduct of D rills and Exercises ....................................................................... 1124. Critique and Evaluation ............. .... ............. ....1135. Resolution of Drill and Exercise Findings ......................................................... 113Section 0: Emergency Response Training ................................................................ 1141. A ssu ra nce of T rain ing ...................................................................................... 1142. Functional Training of the ERO ....................................... 1153 .F irst A id R espo nse ........................................................................................... 1154. Emergency Response Organization Training Program .................... 1155. General,

Initial, and Annual Training Program Maintenance

.................. 120Section P: Responsibility for the Maintenance of the Planning Effort. .................... 1221. Emergency Preparedness Staff Training ......................................................... 1222. Authority for the Emergency Preparedness Effort ........................ 1223. Responsibility for Development and Maintenance of the Plan ............... 1224. Emergency Plan and Agreement Revisions ..................................................... 1265. Em ergency Plan Distribution ....................... .................................. 1266. Supporting Emergency Response Plans .......................................................... 1277. Implementing and Supporting Procedures ............................. 1278. Cross-Reference to Planning Criteria ........................................................... 1279. Audit/Assessment of the Emergency Preparedness Program ................ 12810. Maintenance of Emergency Telephone Numbers ........................ 128A nnex 1: Unit I ..................................................................................................................... 129Section 1: Introduction ............................................................................................... 1291.1 U n it I D e scriptio n ............................................................................................ 12 9Figure Al-1: Unit I Facility Layout (specimen) ..... .......................... 130Section 2: Organizational Control of Emergencies .................................................. 1312.1 Norm al Shift Staffi ng ....................................................................... ....... 1312.2 Shift Emergency Response Positional Responsibilities .................................... 131vRev 0 Table of Contents V. C. Summer Nuclear StationTable 2-1: V. C. Summer On-Shift Staffing and ERO Positions ................................. 132Section 3: Classification of Emergencies .................................................................. 133Section 4: Emergency Facilities and Equipment ...................................................... 1334.1 Unit-Specific Emergency Facilities ......................................................... ... 1334.2 Assessment Resources .................................................. 135Table 4-1: Radiation Monitoring System Description ................................................. 1364.3 Communications ........................................ 1414 .4 P la nt A la rm s .................................................................................................. 14 1Section 5: Emergency Measures ............................................................................... 1425.1 Unit Protective Actions ........................................... 1425.2 Unit Assembly Areas .......................................... 1425.3 U nit Evacuation R outes ................................................................................... 143Annex 2: Unit 2 ..................................................................................................................... 144Section 1: Introduction ............................................................................................... 1441.1 U nit 2 D escriptio n ...................................................... ..................................... 144Figure B1-1 Units 2 and 3 Facility Layout (specimen) ............................................ 145Section 2: Organizational Control of Emergencies .................................................. 1462.1 N orm al S hift Staffi ng ........................................................................................ 1462.2 Shift Emergency Response Positional Responsibilities ........................ 147Table 2-1: V. C. Summer On-Shift Staffing and ERO Positions ......... 148Section 3: Classification of Emergencies .................................................................. 149Section 4: Emergency Facilities and Equipment ...................................................... 1494.1 Unit-Specific Emergency Facilities .................................................................. 1494.2 A ssessm ent Resources ...... ................................... .................................... 151Table 4-1 Radiation Monitoring Detectors ............................. ............... ............. 152Section 5: Emergency Measures ............................................................................... 1575.1 U nit P rotective A ctions ........................................................................ ......... 1575 .2 U nit A ssem bly A reas ....................................................................................... 1575.3 Unit Evacuation Routes ........................................ 157Annex 3: Unit 3 ..................................................................................................................... 159Section 1: Introduction ............................................................................................... 1591.1 Unit 3 Description ........................................ 159Figure C1-1 Units 2 and 3 Facility Layout (specimen) ................................................ 160Section 2: Organizational Control of Emergencies .................................................. 1612.1 N orm al S hift Sta ffi ng ............................................................................. ... 16 12.2 Shift Emergency Response Positional Responsibilities .................................... 162Table 2-1: V. C. Summer On-Shift Staffing and ERO Positions ............ ... 163vi Rev 0 Table of ContentsV. C. Summer Nuclear StationSection 3: Classification of Emergencies .................................................................. 164Section 4: Emergency Facilities and Equipment ................................................ 1654.1 Unit-Specific Em ergency Facilities ................................................................ 1654.2 A ssessm ent Resources ............................................ .................................... 166Table 4-1 Radiation Monitoring Detectors ................................................................... 167Section 5: Emergency Measures ............................................................................... 1725.1 Unit Protective Actions .................................... 1725.2 U nit A ssem bly A reas ...................................................................................... 1725.3 U nit Evacuation R outes .................................................................................... 172Appendix I -References ...................................................................................................... 173Appendix 2 -Letters of Agreement .................................................................................. 175Appendix 3 -List of Emergency Plan Procedures ............................................................. 176Appendix 4 -Abbreviations, Acronyms and Definitions .................................................... 178Appendix 5 -Evacuation Time Estimate Study ................................................................... 186Appendix 6 -Regulatory Requirements Cross Reference Document ............................... 187Table 1 -10 CFR 50 Appendix E -Emergency Planning and Preparedness forProduction and Utilization Facilities ................................... 188Table 2 -10 CFR 50.47 Emergency Plans ................................................................ 199Table 3 -NUREG-0654 Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear PowerP lants ......................... ................................... 202Appendix 7 -On-shift Staffing Analysis ............................................................................. 229*4 i .4 4. 4m" ; .................................................................................................................. .A,Soction A; -Purpo .o... ..... ........ ...... ..... ..... ........... .,3Ge n R--^ ^,4a~ ....... 1mocti-on 2: s_ 9R ..nd ...................................... ........... .... 1J=FiFrrgeon~ Planning Z-one6.. .............. 66 .... ........... 6.................. 6........ --....1:IFormatted: Indent: Left: 0", Hanging: 0.81",Tab stops: 0.81', Left + Not at 1.2"r-ormated: Default Paragraph Font, Font:Bold, Check spelling and grammarBold, Check spelling and grammarFormatted: Default Paragraph Font, Font:P aragrap Font, Font:Bold, Check spelling and grammarFo1 mat : Default Paragraph Font, Font:\\Bold, Check spelling and grammarFormatted: Default Paragraph Font, Font:S Bold, Check spelling and grammarI Formattbd: Default Paragraph Font, Checkspelling and grammarI Formatted: Default Paragraph Font, Checkspelling and grammarvii Rev 0 Table of ContentsV. C. Summer Nuclear StationSction -. ...... ............................................... S .Pla..ningAna ... ... ISocGtionFI E; -lnt ig UtoG uI -igdoanc and M F 0 G CPtri ... ... ...... ...... .......,Seet n ,IL .-;~e --, lnn an -" -"^--n ... n r. .i : .t ......... ............. ... .......................... ,S .. v v R .v .....-R -T a iq n l A a ' t e ......,38 v.v., .W " r~ v- -.O .vvRGY .ROS OR ........... ~ .............. o......................................................

1. ..ti .n esp o nse .........................................................................................

ep,sooin. rm Plan ....... .......................... F-l :9;4-r 12 V. C RSmme S^te ..yo ........ I .......... .......... ................. .... .......... Figwe 14; 50 Mile Evmegncy Zne (ngetion PathWy) .........Par.t 2: Planning Standardl and Criter. ia. ............................... 6.3otio A rt: : .e.s-'-monto Coepoeiblit ... -^, ... ^S r Ap!c: Omens in olaRn spnngEff rt.y ........ ......... .. .............. 12'. o t e e r .......... .. ....................................... ............. -.,Stte athr2 CS NS asAnd E rugp ......... ... .......................................... ..... c 1:21 On .. Shif .... .o......... .. .. .....o. ......... ....... ............ ,4 -re i~uushor y9'evcr thc .mr~ c .... ... ....... ...... ............. ...15~w- Emer4geny Response O gani-zation Po.ition...................... ...... 10Aj*jýFe goncy RenqnOrganiationaWR cPiDiagramt282 7.GGR0 Industr"PriOate RSuPOR Orgapization ..826-_QuRShla: O~neqa sy ERerO 6 Command ai Strutur....... .................... 120..,Fguo I:Onit mo~nc RsoneOranztin....... ............ ...3230...4- ,3.re Pic: OFit Em Asorigoc Roommnd ~ GORVOzaI (SGn...GI...................3331.. Tabljei B DeleSablen DutesJem for the..........................3532.. Setin :E-M9Fge4;y Ro6GAeponcoaký upport an Reuros..................36 jm. ~ qeio y Rýcal La Oratories..............IFF1......... ........ ........06f4A -B1e *Other Asctnco..........................91 ................... 10363_oTabio9n

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Initial, and ARRual Prgr.am MainteRnane

..... -4......... 117109,6 o.tin .. 12 f Rsp.eviibiwity for the Maintenance- -of the Plan.ning E.ffort................ 11 111fm e an P" w dn6"c Staff T ainin.g -1.0.......1.....1.................................. ...,2. AUthoFARi for the EMorg nc'; PrF paredness Effort ..... ............. 1.1.........1..0..... 14 !!14.m.. Pan and Agement ReVisio..s............................ 123115S....................................................................... 1 2 11J6. ShEupperting E=merge.cy R Pcponse Plans..... ............................. 124116,T ..... !: .c to Pla ni t ri...... ....... w. ... ............. ........ 121J9. 26,udit'A scoccmonA-t of the Emrgnece;y Proparcdnccc Prora 125117...... ,40. j'AaintenAnce ofEmergeny TeAlephoeR N-umb-ers........................157 Annx : nit ..... ................................. ............. 12611.!ection

jntroducrtion E ..........

................................. 12611514. -Unit 44)eccrFppo... ......... W.w.........__.....................................1426118 Figure All: UitW 1 Faciliy Layout (specimen) .......................... W 12711 9,Sectien 2: prga~zatiOnal Conrol1 Of EmoRgOnc0ioc...................... 12820 _'2.2 .Shift Emer9genc~y-Response Pocitional Rsoiblte ............... 1210._,Table 2 1: V. G. SummorW On; Shift Staffinig and ERO Petitions6 1.......... ...29121*Soction 3: -_bes8ifatien ofram~rgonrciot...-. ................................... 112Al~e .-Unit SecFgec Emegitlenc FacilEqities.. ... ................................. 13-20122-Formatted Formatted -Form.tted Formatted Formatted Formatted zACFormtted 7Formatted 7.'Formatted e P.FFormdatted sFormatted Formatted -fForm atted -------------Formatted Formatted FormattedI {o atted 1{Formatted Formatte: Default Paragraph Font, Font:dCekspelling and grammarFormatted F rrmatted ...I{Formatted Formatted: Default Paragraph Font, ContkBlCekspelling and grammarFormatted Formatted xiRev 0 Table of ContentsV. C. Summer Nuclear Station,4.2 iAssmnt RAeAourcs .... , 12 1.1 : 4,Table 4 1; _Radiation hMGonitorin System DoSciPtGIo ...... ............. I....131. .G iQ2fi A A, I.. I-.....,A !a FFn s ... 4 ................. 4.4 ....................... 4_ 4 ......... ......................... ...71 _ antr 4 1I.1,4+1f M OaSUFOc .................................... 12913Formatted Formatted: Default Paragraph Font, Checkspelling and grammarrFormatted Formatted Formatted Formatted Formatted Formatted Formatted: Default Paragraph Font, Font: anei nrnrmr rI,iAvan 'I 1I*5. 2IUn A66 eb,5.3 UnWFit Evacuaitip r-eas............ ............... n Rou tes........... ................................ A AAA- Q.130131.... ......... .... .......... ........... .... .... ........ 00Section..

................... ............... 14133144 kUn 2 Dec riptio n..... ........ .. ... ........... .......... 1.113....figure 1B. 1 ..it .2 and 3 Facility Layout7 ........ ...... .......... ............ 113Soctin2: qanizatina' Control of Em.o....n.... .1432.2 JRom, ShiftStaffing_ .......................... 35,Ta be 2 1: V. C. 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U 47L=.octio , : .,n"ro" uction........................................................................... , ,-4 n 2 eW cr p M , .............. ....... ............... ............................................. Ii^4 4 ..-:I- I I~ .: ........d~ ~ -'~l Pd~niz~lef9efmiee ................................ Formatted Formatted -Formatted Formatte: Default Paragraph Font, Fnt:Bold, Check spelling and grammarspelling and grammarFormatteda u r hFormatted Formatted 7..ForFattedtChc Formatted Formatted Formatted ..Formatted Formatted ....................... .............. 1!58110,2.2_ ShA-EFA9rGe,, Respensp Positienal Reponsbties................ .4594&*i~a. :V, G. Swurnmmor O nRt Sh taffiln and ERGt Posi9an ... -......S..t*.n 3: .Class.n of Em.ernc .. ...................................... 245ýqn 4;A 1 1-;. c........................................... qieg+"A ..MGAn0tdff, AlF I. ..... ...... ........ ......... 162153............. I ..... ........................ ... 1 63151i R.......... .16115xii Rev 0 Table of Contents V. C. Summer Nuclear Station1 U rtGcti.e ctio.n................. ........... ....169160JS 5 6 U; ÷ -... ....... ."564 ._ Unit "\ccembtl I. ..s..... ............ .. ...................... 1691, .2 -_- .Wi4 As.~ -- .. .......... ................................ ........... ........... ............. .....4 ;..3Unt...u.to...te.......... .......... ........ 1 ... 1A ppondix 1 Raforancoc.... .. ............... .............. ........ 1701-61Appendix 2 of* AGm--nt .............. ,,....... .-. ................. 17116jkppondix 3 -LostoGf Emergoncy Plan PFOco0du'rocA. ............. ................ ..... 172Appndi *4 a"ronym and Definitions .. ........... 17.166Appendix Timo Estimato study .... .. 1...........7.3... 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Plans and Prooarednees in SU-D 1.t of N'uclear Powtrý -A -2~i!Rb ... ........................................- .......-.- -APpendix 7- On shift Staffing Analyq* .............. .. .......... ........ 225216C,Appendix 8- Akart A-nd Notification System Design Report ............- ---2-26-21-7 Formatted: Default Paragraph Font, Font:Bold, Check spelling and grammarFormatted: Default Paragraph Font, Font:Bold, Check spelling and grammarFormatted: Default Paragraph Font, Font:Bold, Check spelling and grammar\ Formatted: Default Paragraph Font, Font:Bold, Check spelling and grammarFormatted: Default Paragraph Font, Font:oBld, Check spelling and grammarFormatted: Default Paragraph Font, FontCsplln an gramaFrmattd. DealPaarpFotFn:Nt Bold, Check spelling and grammarI Formatted: Default Paragraph Font, Check.spelling and grammar\ Formatted: Default Paragraph Font, Font: Not4 Bold, Check spelling and grammarFormatted Default Paragraph Font, Check1\,spelling and grammarForated Default Paragraph Font, F;7t\Bold, Check spelling and grammarFormatted: Default Paragraph Font, Font:Bold, Check spelling and grammarxiiiRev 0 Part 1: Introduction V. C. Summer Nuclear StationPart 1: Introduction Section A: PurposeAs required in the conditions set forth by the Nuclear Regulatory Commission (NRC) for theoperating licenses for the Virgil C. Summer Nuclear Station (VCSNS) Units 1, 2 and 3 themanagement of South Carolina Electric & Gas Company (SCE&G) recognizes its responsibility and authority to operate and maintain the nuclear power station in such a manner as to providefor the safety of the general public. This document describes the VCSNS Radiation Emergency Preparedness Program. The philosophy that guides the development and maintenance of thisprogram is the protection of the health and safety of the general public in the communities around the nuclear power station and the personnel who work at VCSNS.This Radiation Emergency Plan (Emergency Plan) establishes the concepts, evaluation andassessment

criteria, and protective actions that are necessary in order to limit and mitigate theconsequences of potential or actual radiological emergencies.

It has been prepared to establish the procedures and practices for management control over unplanned or emergency events thatmay occur at VCSNS. It also provides the necessary prearrangements, directions, andorganization so that all nuclear emergencies can be effectively and efficiently resolved. The VCSNS Emergency Preparedness Program consists of the Emergency Plan, Unit Annexes,Emergency Plan Implementing Procedures (EPIPs), and associated program administrative documents. The VCSNS Emergency Plan outlines the basis for response actions that would beimplemented in an emergency. This document is not intended to be used as a procedure. The Unit Annexes are parts of the Emergency Plan and are subject to the same review andaudit requirements as the Emergency Plan. In the areas where the Unit Annexes deviate fromthe general requirements of the Emergency Plan, the Unit Annex shall serve as the controlling document. The information that is in the Plan need not be restated in the Unit Annexes. The Annexes shalladdress any differences between co-located units operated by SCE&G.Annex Format and Specific Content: As a minimum, the Unit Annexes shall address the areasdescribed as follows:Section 1: Introduction The unit description is provided along with the inclusion of maps, drawings, and/ordiagrams. It describes the specifics of each unit and its location. A summary statement describes the Annex's interface with the Emergency Plan.Section 2: Organizational Control of Emergencies Unit-specific on-shift staffing is outlined in the Unit Annexes to the Emergency Plan. The on-call Emergency Response Organization (ERO) positions are outlined in Section B of theEmergency Plan.Page 1 of 4-9219EP- 100 Rev Gxx Part 1: Introduction V. C. Summer Nuclear StationSection 3: Classification of Emergencies Emergency Action Levels (EALs) are developed for all emergency classes for the purposeof event classification. The EALs are incorporated into the implementing procedures forActivation and Implementation of Emergency Plan for each technology. Section 4: Emer-gency Facilities and Equipment A description of unit-specific facilities and equipment available for use during an emergency response or to support the remainder of the site is included in each Unit Annex.Section 5: Emergency MeasuresA description of unit-specific personnel protective

actions, assembly areas, and evacuation routes are discussed.

Detailed EPIPs are maintained separately and are used to guide those responsible forimplementing emergency response actions.Section B: Background Facility Description The VCSNS site is on the east side of the Broad River in western Fairfield County. The Unit 1power block area (generating facilities and switchyard) is on the south shore of the Monticello Reservoir. Units 2 and 3 are approximately 1 mile south-southwest of Unit 1. An exclusion area,defined as the area within approximately 1 mile of Unit 1 combined with the area 3,390 feet fromthe center of Units 2 and 3 (the Exclusion Area Boundary), is posted and access to landportions of this area is controlled. The Exclusion Area Boundary encompasses approximately 2,560 acres. It includes the southern portion of the Monticello Reservoir and parts of theFairfield Pumped Storage Facility. The largest industrial center nearest to the site is Columbia, which is approximately 26 milessoutheast of the site. The nearest community is Jenkinsville, approximately three milessoutheast of the site. The closest primary public road is SC 215 which lies approximately 6,800feet east of the Unit 1 reactor building centerline and is outside the exclusion area. Highwayaccess to the station is via SC 215 from Columbia or by Interstate 26 to US 176, and then to SC213 and SC 215.Figure 1-1 shows the general location of VCSNS.Figure 1-2 shows the Exclusion Area Boundary (EAB) for Units 1, 2, and 3.Within the EAB, ownership is divided between SCE&G and Santee Cooper. Pursuant to theVCSNS owner's agreement authorizing the development, construction, licensing, and operation of generating units, SCE&G, for itself and as agent for the co-owner, retains complete authority to regulate any and all access and activity within the entire exclusion area.Page 41-2 of 4.-93219EIP- 100 Rev 0xx Part 1: Introduction V. C. Summer Nuclear StationEmergency Planning ZonesThe Exposure Pathway Emergency Planning Zone (EPZ) for the VCSNS is an area surrounding the VCSNS site with Unit 1 at the center and having a radius of about ten (10) miles (exactboundaries are determined in concurrence with state and county authorities). Figure 1-3 showsthe EPZ and PAZ. Principal exposure sources from the plume exposure pathway are (a)external exposure to gamma and beta radiation from the plume and from deposition materials and (b) exposure of the internal organs to gamma and beta radiation from inhaled radioactive gases and/or radioactive particles. The time of potential exposure can range from hours todays.The Ingestion Pathway Emergency Planning Zone (IPZ) is an area surrounding the station withUnit 1 as the center and having a radius of about fifty (50) miles. The primary exposure sourcefrom the ingestion exposure pathway is the ingestion of contaminated fresh vegetables andmilk. The time of potential exposure can range from hours to months. Figure 1-4 shows theIngestion Pathway EPZ.In the context of this Emergency Plan, including the Unit Annexes and Emergency PlanProcedures (EPP), SCE&G manages the operations of the VCSNS.The primary hazard consideration at the nuclear power station is the potential unplanned release of radioactive material resulting from an accident. The probability of such a release isconsidered very low due to the design of the units and strict operational guidelines enforced bythe NRC. Notwithstanding, federal regulations require that a solid Emergency Preparedness Program exist for each commercial nuclear power station. A detailed description of the stationis provided in each units' Final Safety Analysis Report (FSAR).To minimize the number of ad hoc decisions made during an emergency and to ensure thatnecessary equipment,

supplies, and essential services are available to meet the needs of anemergency, SCE&G has developed this Emergency Plan. This Emergency Plan is applicable toVCSNS and considers the consequences of radiological emergencies, as required by 10 CFR50.47 and 10 CFR 50 Appendix E.In addition, this plan addresses guidance and adheres to the intent of the criteria established and provided within NUREG-0654/FEMA-REP-1 Rev. 1 (NUREG-0654),

which is a joint NRCand Federal Emergency Management Agency (FEMA) document. Regulatory Guide 1.101,"Emergency Planning and Preparedness for Nuclear Power Reactors," endorses the criteria andrecommendations in NUREG-0654, as methods acceptable to the NRC staff for complying withthe standards in 10 CFR 50.47.The Emergency Plan also considers the consequences of nonradiological emergencies. Page 41-3 of 1-93219EP-IO00 Rev Oxx Part 1: Introduction V. C. Summer Nuclear StationSection C: ScopeThis document describes actions to be taken in the event of a radiological accident at theVCSNS that may impact the health and safety of the general public or station employees. It alsoserves to limit the damage to facilities and property, and provides for the restoration of suchfacilities in the event of an emergency. If such an accident were to occur, the ERO would be putin place and maintained until such time when the plant is returned to a stable condition and thethreat to the general public or station personnel no longer exists. This plan describes thefunctions and operation of the ERO, including assignments of authority and responsibility. It doesnot, nor is it intended to, provide guidance for actual plant equipment manipulations. Theseinstructions are contained in site-specific normal and Emergency Operating Procedures (EOP)as required by Technical Specifications and other regulatory guidance. The Emergency Planprovides for: identification and evaluation of emergency situations, protective

measures, communications, coordination and notification of govemmental authorities, document review andcontrol, emergency preparedness assessment, and training of all emergency response personnel.

A method for recovering from a declared emergency is also described in this plan.Section D: Planninq BasisThe Emergency Plan, in conjunction with the Unit Annexes and the emergency plan procedures and administrative procedures, documents the methods by which the VCSNS Emergency Preparedness Program meets the planning standards set forth in 10 CFR 50.47(b) and therequirements of 10 CFR 50 Appendix E. Development of the Emergency Plan was based onNUREG-0654. Acceptable alternate

methods, which deviate from NUREG-0654, are allowed under Regulatory Guide 1.101, "Emergency Planning and Preparedness for Nuclear Power Reactors."

However,any and all deviations will be documented in the Unit Annexes and evaluated as continuing tomeet the Planning Standards of 10 CFR 50.47(b) and 10 CFR 50 Appendix E under the 10 CFR50.54(q) process. This evaluation process is employed to ensure the continued effectiveness ofthe Emergency Plan and respective Unit Annexes.Other applicable regulations, publications, and guidance were used (see Appendix 1,"References") along with site-specific documents to ensure consistency in the planning effort.Section E: Contiguous-Jurisdiction Emergency PlanningThe Emergency Plan recognizes the state of South Carolina, in cooperation with the EPZcounties (Fairfield, Lexington,

Newberry,

& Richland), as the overall authority responsible forProtective Action Directives (PADs) in order to protect the health and safety of the generalpublic.Section F: Integrated Guidance and CriteriaThis plan was developed in conjunction with federal, state, and county emergency responseplans to ensure a consistent and integrated response to a classified event.Page 4 of 4-4219EP-100 Rev Oxx Part 1: Introduction V. C. Summer Nuclear StationSection G: Funding and Technical Assistance SCE&G is dedicated to providing the level of support necessary, as dictated by federalregulation, to ensure appropriate integration of the state, county, and VCSNS radiological emergency preparedness programs. Section H: Emergency Response Organization SCE&G acknowledges its primary responsibility for planning and implementing emergency measures within the EAB and for overall plant accident assessment. These emergency measures include corrective

actions, protective

measures, and aid for personnel onsite. Toaccomplish these responsibilities, SCE&G has established an augmented ERO that will bemobilized to provide the initial response to an event classified as an Alert, Site Area Emergency, or General Emergency.

The ERO may be partially or fully activated during an Unusual Event, ifthe Interim Emergency Director (lED) determines their assistance is needed to mitigate theevent. In addition, advance arrangements have been made with offsite organizations for specialemergency assistance such as ambulance,

medical, hospital, fire, and police services.

In the longer time frame, a framework for a Recovery Organization is set forth in this plan. It isrecognized that the normal station organization will be used for much of the recovery effort, withadditional resources identified at the time of the event.Section I: Federal ResponseProvisions are made within the Emergency Plan for the integration of appropriate elements offederal assistance activities. Arrangements have been made to accommodate a federalresponse organization presence in the VCSNS emergency response facilities as well as supportcommunications between VCSNS and federal emergency facilities. Section J: Form and Content of PlanIn accordance with regulatory guidance provided in NUREG-0800, the Emergency Plan isreferenced in Chapter 13 of the VCSNS FSAR. The Emergency Plan is administratively maintained as a separate document. Appendix 3, List of Emergency Plan Procedures, provides a subject matter cross-reference between the NUREG-0654 evaluation criteria and the EPIPs and applicable administrative documents. Appendix 6 is a specific requirements cross-reference between the Emergency Plan and 1OCFR50 Appendix E, 10CFR50.47, NUREG-0654. Page 4-5 of 49-219EP-1 00 Rev Gxx Part 1: Introduction V. C. Summer Nuclear StationPart 1: IntroductIon V. C. Summer Nuclear StationFigure 1-1: General Location of the Site and Surrounding AreaPage 4-6 of 4-9-219EP-IO00 Rev Oxx Part 1: Introduction V. C. Summer Nuclear StationIS. //I\0IILegendWaterRoadState RouteRailroadL -Site Boundary/Exclusion Area Boundary (EAB)0 0.25 0.5 0.75 1I JMMM ý TMineFigure 1-2: V. C. Summer Site LayoutPage 41-7 of 493219EP-1 00 Rev 0xx Part 1: Introduction V. C. Summer Nuclear StationFigure 1-3: 10-Mile Emergency Planning Zone (Exposure Pathway)Page 4-8 of4-93219 EP- 100 Rev xxO Part 1: Introduction V. C. Summer Nuclear StationFigure 1-4: 50-Mile Emergency Planning Zone (Ingestion Pathway)Page 6-9 of 4-93219EP-100 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear StationPart 2: Planning Standards and CriteriaSection A: Assignment of Responsibility This section describes the primary responsibilities and organizational control of SCE&G, federal,state, county, and other EROs within the plume exposure pathway and the ingestion pathwayzones. Various supporting organizations are also described as well as staffing for initial andcontinuous response.

1. Concept of Operations The relationships and the concept of operations for the organizations and agencies that area part of the overall ERO are as follows:aA. Identified below are federal, state, and county organizations (and other localgovernmental agencies) that are involved in a response to an emergency at VCSNS(Figure A-i).1) Federal Agencies:

The National Response Framework (NRF) outlines federalstatutory and regulatory responsibilities during incidents requiring a coordinated federal response. The primary federal response for supporting an emergency atVCSNS includes: a) Nuclear Regulatory Commission (NRC): The NRC Regional Office has theresponsibility for the auditing of nuclear power stations. It is responsible forensuring that such activities are conducted in accordance with the terms andconditions of such NRC licenses and that as a result of such operations, there is no undue risk to the health and safety of the public.The NRC Office of Nuclear Reactor Regulation, established by the EnergyReorganization Act of 1974, as amended, performs licensing functions associated with the construction and operation of nuclear reactors and with thereceipt, possession, ownership, and use of special nuclear and byproduct materials used at reactor facilities. With regard to emergency preparedness, the NRC shall:" Assess licensee emergency plans for adequacy" Review the FEMA findings and determinations on the adequacy andcapability of implementation of state and local plans* Make decisions with regard to the overall state of emergency preparedness and issuance of operating licensesPage 5-10 of 4-9,220EP-1 00 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear StationThe NRC shall respond to incidents at licensed facilities or vehicular accidents involving licensed materials, in transit. Within the sphere of the NRF, the NRCshall act as a Coordinating Agency. In this role the NRC:" Performs an independent assessment of the incident and potential offsiteconsequences and, as appropriate, provides recommendations concerning any protective measures" Performs oversight of the licensee, to include monitoring, evaluation ofprotective action recommendations (PARs), advice, assistance, and, asappropriate, direction

• Dispatches, when appropriate, an NRC site team of technical experts to thelicensee's facilityUnder certain situations involving the protection of public health/safety ornational

security, the NRC may take possession of special nuclear materials and/or operate certain facilities regulated by the NRC. FEMA shall act as thelead federal agency for offsite, nontechnical concerns.

During an incident, the Chairman of the Commission is the senior NRCauthority for all aspects of a response. The Chairman shall transfer control ofemergency response activities to the Director of Site Operations when deemedappropriate by the Chairman. All NRC Regions as well as Headquarters are prepared to respond to potential emergencies. All Regions and Headquarters have developed plans andprocedures for responding to radiological incidents involving NRC licensees. Headquarters has developed the NRC Incident Response Plans andImplementing Procedures. Each NRC Region has developed RegionalSupplements that detail how the Region will fulfill all of the responsibilities assigned in the NRC Incident Response Plan. All NRC organizations areresponsible for maintaining an effective state of preparedness through periodictraining, drills, and exercises. Each Region and Headquarters has established and maintains an IncidentResponse Center designed to centralize and coordinate the emergency response function. Adequate communications are established to link thelicensee, Headquarters, and the Region. The NRC has established lines ofcommunications with local government, state government, other federalagencies, Congress and the White House. Public information will bedisseminated in a timely manner and periodically. Each Region is prepared to send a team of qualified specialists to the sceneexpeditiously. All of the necessary supplies and equipment needed foremergency response will be provided and maintained by the NRC.The NRC Incident Response Plan objectives are to provide for protection of thepublic health and safety, property, and the environment, from the effects ofradiological incidents that may occur at licensed facilities or which involvelicensed materials, including radionuclides in transit.Page 5-13 of 493220EP- 100 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear StationThe objectives of the agency plan set forth the organizational and management concepts and responsibilities needed to ensure that NRC has an effective emergency response program.The NRC Incident Response Plan is intended to ensure NRC preparedness: " To receive and evaluate notification information of incidents, accidents, andunusual events and determine the extent of NRC response necessary tomeet NRC responsibilities for mitigating the consequences of these events" To determine the cause of incidents, accidents, and unusual events in orderto ensure that appropriate corrective actions are taken by the licensee tominimize the consequences of these events" To provide onsite expertise in a timely manner, to evaluate the nature andextent of the incident, ascertain plant status (for reactors and fuel facilities), monitor licensee activities, determine compliance, make recommendations, and, if necessary, issue orders relative to the event" To inform the public and others of plant status and technical detailsconcerning the incident" To recommend adequate protective actions to the responsible local and/orstate agencies" To provide technical assistance " To ensure the plant is returned to a safe condition " To return the NRC Headquarters and Regional office to normal operations b) Federal Emergency Management Agency (FEMA): Per the NationalResponse Framework (NRF), FEMA, a division of the Department ofHomeland Security (DHS) is responsible for the overall coordination of amultiagency federal response to a significant radiological incident. Theprimary role of FEMA is to support the state by coordinating the delivery offederal nontechnical assistance. FEMA coordinates state requests for federalassistance, identifying which federal agency can best address specific needs.If deemed necessary by FEMA, it will establish a Homeland SecurityOperations Center (HSOC) from which it will manage its assistance activities. c) U.S. Department of Energy (DOE): The DOE has extensive radiological monitoring equipment and personnel resources that it can assemble anddispatch to the scene of a radiological incident. The DOE local operations office at Savannah River Site can assist VCSNS following a radiological incident as outlined in the Federal Radiological Monitoring and Assessment Plan (FRMAP). If VCSNS or the affected states deem that assistance fromDOE is necessary or desirable, they will request that assistance using theproper channels. VCSNS will contact the U.S. NRC Headquarters and theaffected state(s) will make contact through DHS.Page 6-13 of 1-49220EP-100 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Stationd) Environmental Protection Agency (EPA): Assists with field radiological monitoring/sampling and non-plant related recovery and reentry guidance. e) Federal Bureau of Investigation (FBI): Support from the FBI is available through its statutory responsibility based in Public Law and the US Code, andthrough a memorandum of understanding for cooperation with the NRC.Notification to the FBI will be through provisions of the VCSNS Security Plan,or by the NRC.f) National Weather Service (NWS): Provides meteorological information duringemergency situations, if required. Data available will include existing andforecasted wind directions, wind speed, and ambient air temperature.

2) State Agenciesa) The State of South Carolina:

The state of South Carolina has the statutory responsibility and authority for protecting the health and safety of the public inSouth Carolina. The state has developed a "South Carolina Operational Radiological Emergency Response Plan." This plan was developed inaccordance with NUREG 0654. The Plan has received 44 CFR 350unconditional approvals from DHS for all nuclear generating station(s) withinthe state boundaries. Basic descriptions for the South Carolina stateagencies responsible for actions in the event of a nuclear power station areas follows:* Governor of South Carolina: The governor of the state has overallcommand authority for both the radiological and nonradiological aspects ofa nuclear incident. The governor shall make the final recommendation forprotective actions and shall serve as the state's primary spokesperson.

• South Carolina Emergency Management Division (SCEMD):

Coordinates the operational response and recovery functions of all state agencies. TheSCEMD proposes PARs to the govemor. It also coordinates theimplementation of the govemor's Protective Action Directives (PAD).The SCEMD response action to a nuclear incident will fall into one of thefollowing functional areas:-Command for all (state-related) radiological aspects of a nuclearincident. -Field radiological functions (state-related) of confirmatory accidentassessments during a nuclear emergency. This may include a MobileCommand Center, a Mobile Nuclear Laboratory, and monitoring andsampling teams.The SCEMD has the responsibility to inform and coordinate technical information with the North Carolina Emergency Management Agencies withrespect to an emergency that impacts the 50-mile ingestion pathway zone.Page 5-13 of Q220EP-1 00 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear StationThe SCEMD has both the command authority for radiological aspects of anuclear incident and the responsibility for performing various radiological functions. These functions include milk, water and food control, radiation exposure control for state emergency

workers, and confirmatory accidentassessment.

" Department of Health and Environmental Control (DHEC): DHEC maintains a radiological hazard assessment capability and provides radiological technical

support, coordination and guidance for the state and localgovemments; conducts and/or coordinates offsite radiological surveillance and monitoring in coordination with the VCSNS offsite environmental monitoring group; and makes recommendations to SCEMD for protective actions as well as recovery and reentry guidelines.

• South Carolina Law Enforcement Division (SLED): SLED provides supportduring security related events at the station.* The South Carolina Department of Natural Resources (SCDNR):

TheSCDNR patrols and ensures the safety of waterways in South Carolina. The SCDNR is promptly notified of any oil or hazardous substance discharges into rivers or lakes or radioactive contamination of rivers orlakes under its jurisdiction at levels requiring assistance to effect protective actions. The SCDNR is contacted by the appropriate state agencies in theevent of an incident at an applicable nuclear power plant. The UnitedStates Coast Guard (USCG) is responsible for officially closing thewaterways to all boating traffic.b) The State of North Carolina: A portion of the 50-mile ingestion pathway EPZfor VCSNS lies within the state of North Carolina. The state of North Carolinahas developed a Radiological Emergency Response Plan to respond tocommercial nuclear power stations within the state of North Carolina and forthose nuclear stations outside of the state that are within 50 miles of NorthCarolina.

3) County Government AgenciesVCSNS and the surrounding counties of Fairfield,

Newberry, Lexington, and Richlandthat comprise the plume exposure pathway EPZ have developed integrated emergency response programs that call upon the resources of their county. Thecounty organizations are responsible for implementing and coordinating the countyresponse to an emergency.

Each of the county Emergency Operations Centers (EOCs) serve as the primarycoordinating center for local govemment response within the county's jurisdiction andfor coordination between counties. Page 5-13 of 4-9-220EP-100 Rev Gxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Station4) Private AgenciesThere are various private agencies that VCSNS has acquired Letters of Agreement regarding support during an emergency. These agencies have agreed to providefirefighting,

medical, resource, and lodging support as needed during an emergency.

These Letters of Agreement are listed in Appendix 2 and are reviewed and updatedas necessary. bB. During an emergency condition classified as an Alert, Site Area Emergency, or GeneralEmergency, the station's augmented ERO is notified and responds to augment the normalplant organization under the direction of the lED.The augmented ERO consists of three major response suborganizations with inter-relationships as illustrated in Figure A-2:1) The Onsite ERO, directed by the Emergency Director (ED), provides for:* Control and operation of the plant* Mitigation of the emergency condition

• Protection of station personnel inside the Protected Area* Emergency support for Operations, Engineering, Maintenance, firefighting,

Security, and first aidThe onsite ERO is made up primarily of personnel from the station's day-to-day management team, Operations, Health Physics, Chemistry, Engineering, Maintenance,

Security, and other site support personnel.

2) The Offsite ERO, directed by the Offsto Emorge,,cY CordinatorOffsite Emergency Manager (QE-GOEM),

provides for:" Offsite radiological accident assessment " Protection of station personnel outside the Protected Area* Emergency support for acquisition of material and support personnel

• The primary interface between VCSNS and outside organizations responsible forthe protection of the publicThe Offsite ERO is made up primarily of personnel from the station's high levelmanagement team, Security, Health Physics, and Training with support from otherstations departments as necessary.

3) The Emergency Public Information Organization (EPIO), directed by theEmergency Control Officer/Company Spokesperson, coordinates with PublicInformation Officers (PIO) from other organizations to provide information to thepublic through the news media.Page 5-13 of 493220EP-1 00 Rev Oxx Part 2: Planning Standards and CriteriaV_ C_ Summar Nuclaar StationGC.The Emergency Control Officer (ECO) is a senior VCSNS employee with overallresponsibility for coordinating emergency response actions of the station, and the EPIOwith the affected state(s) and county agencies.

dD. Procedures for training and maintenance of the emergency organization are in place toensure 24-hour-per-day staffing for emergency

response, including established communication links.2. State and County Functions and Responsibilities The state and counties have emergency response plans that specify the responsibilities andfunctions for the major agencies, departments, and key individuals of their organizations.

This information is located in their respective plans.3. Agreements in Planning EffortWritten agreements establishing the concept of operations developed between VCSNS andother support organizations having an emergency response role have been developed. These agreements identify the emergency measures to be provided, the mutually acceptedcriteria for implementation, and the arrangements for exchange of information. Agreement letters are not necessary with federal agencies that are legally required to respond based onfederal law. However, agreements are necessary if the agency was expected to provideassistance not required by law. Letters of Agreement shall be obtained with privatecontractors and others who provide services in support of the station during a declaredemergency. A list of Letters of Agreement is provided in Appendix 2 of this Plan, the actualletters are maintained on file at the station. Letters of Agreement, as a minimum, state thatthe cooperating organization will provide their normal services in support of an emergency atthe VCSNS site. A contract/purchase order with a private contractor is considered acceptable in lieu of a Letter of Agreement for the specified duration of the contract.

4. Continuous CoverageVCSNS maintains 24-hour emergency response capability.

The normal on-shift complement provides the initial response to an emergency. This group is trained to handle emergency situations (e.g., initiate implementation of the Emergency Plan, make initial accidentassessment, emergency classification, notifications, communications, and PARs until theaugmented ERO arrives. Personnel from the unaffected unit(s) are available and respondwhen notified. Minimum staffing will be maintained in the unaffected units in accordance withguidance in NUREG-0654 Table B-I. The ERO is composed of a broad spectrum ofpersonnel with specialties in Operations, Maintenance, Engineering, Radiochemistry, HealthPhysics, Fire Protection,

Security, comr-'n,.atocPublic

Affairs, and Emergency IPreparedness who are available and trained to augment on-shift personnel in anemergency.

Procedures for training and maintenance of the emergency organization are inplace to provide the capability of continuous (24-hour) operations. The ED, located in the Technical Support Center (TSC), has the authority and responsibility for assuring continuity of resources (technical, administrative, and material) in the event ofthe activation of the ERO.Page 5-13 of 493220EP-100 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear StationFigure A-I: Agency Response Organization Interrelationships Page &-13 of 493220 EP-100 Rev 0xx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear StationOnsite Emergency Response Organization Technical Affected UnitSupport Center Control(TSC) RoomAffected UnitOperations Support Center(OSC)Offsite Emergency Response Organization Field Monitoring Emergency Teams Operations (FMTs) Facility (EOF)Emergency PublicInformation Organization Joint Information Center (JIC)Figure A-2: VCSNS Augmented Emergency Response Organization Interrelationships Page 6-13 of 4-3220EP-100 Rev gxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear StationSection B: Emeraency Response Oraanization This section describes the ERO, its key positions, and associated responsibilities. It outlines thestaffing requirements that provide initial emergency response actions and provisions for timelyaugmentation of on-shift personnel when required. The below-listed ERO positions form the basis of VCSNS emergency response. If needed, anycompany personnel and resources can and will be used to ensure the safety of offsitepopulations, station personnel, and protection of station equipment needed to maintain nuclearsafety.1. On-Shift Emergency Response Organization Assignments The normal plant personnel complement is established with the Vice President, NuclearOperations having overall authority for station operations. The Vice President, NuclearOperations directs the unit organization in the management of the various departments while the Shift Supervisor retains the responsibility for actual operation of plant systems.Emergency Preparedness must consider the capabilities of the normal plant organization and the ERO. The initial phases of an emergency situation at VCSNS will most likely involvea relatively small number of individuals. These individuals must be capable of (1)determining that an emergency exists, (2) providing initial classification and assessment, (3)promptly notifying offsite authorities and individuals in the emergency organization, and (4)making PARs as needed. The subsequent phases of the emergency situation may requirean increasing augmentation of the emergency organization. The station has personnel on-shift at all times that can provide an initial response to anEmergency Event. The Unit Annexes' Table 2-1 outlines the unit on-shift emergency organization and its relation to the normal staff complement. Members of the on-shiftorganization are trained on their responsibilities and duties in the event of an emergency and are capable of performing all response actions in an Unusual Event and the initialactions of higher classifications. The epeit-full ERO will be activated at an Alert, a.44heontiro ERO Will ba acti'ated at A Site Area Emergency, or General Emergency. On-Shift Personnel: Shift personnel have the capability at all times to perform detection, mitigation, classification, and notification functions required in the early phases of anemergency. Shift augmentation and further ERO involvement will be determined by theextent and magnitude of the event. When a transition to Severe Accident Management Guidelines (SAMGs) is initiated, the eG-hift-,- ewControl Room Staff assumes the dutiesand responsibilities of the SAMG implementers. A set of guidelines, Beyond Design BasisMitigation Guidelines (BDMG), in support of events that are beyond VCSNS design basishas been developed and maintained to provide guidance on evaluations and actions takento mitigate an event of this nature.Shift Supervisor: Has the responsibility and the authority to declare an emergency andbecomes the Interim Emergency Director (lED). In that role, the lED will initiate theappropriate immediate action in accordance with written procedures, mitigate theconsequences of the emergency, activate the eqsite-full ERO at an Alert and the entire ERat a Site Area Emorgec,'; or Foneral higher classification, and notify offsitesupport and government

agencies, as appropriate.

In the Shift Supervisor's absence orincapacitation, the line of succession is defined by unit's Operations and Emergency PlanProcedures. Page 5-13 of 1-94220EP-1 00 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear StationShift Engineer/Shift Technical Advisor (STA): A qualified individual assumes an overviewrole as the technical advisor with the specific responsibility of monitoring the maintenance ofcore cooling and containment integrity. An individual assigned the duty as the ShiftEngineer/STA shall be available to the unit Control Room at all times.Control Room Operators: One qualified Control Room Supervisor and at least two qualified Reactor Operators are assigned to each shift during normal operations. They areresponsible for operating plant equipment from the Control Room.Auxiliary Operators: At-least-fiveAuxiliary (non-licensed) operators are assigned to eachshift. They are responsible for operating plant equipment throughout the plant.Radiation Protection: The station Health Physics personnel are responsible for the handlingand monitoring of radioactive materials. Included in this organization are Health PhysicsSupervisors, Staff, and Specialists. Chemistry: The station Chemistry personnel are responsible for sampling of systemeffluents, and the chemical and radio-analytical analysis of those samples. Included in thisorganization are Chemistry Supervisors, Staff, and Specialists. Security: The station Security personnel are responsible for the physical security of the site.Included in this organization are Security management, staff, and Security Officers. A Fire Brigade for the Protected Area has been established by designating trainedindividuals as brigade members. The Fire Brigade Leader will be designated as per theFSAR and FPER.A Medical Emergency Response Team (MERT) for each Protected Area has beenestablished by designating trained individuals from the above listed groups as teammembers.An individual (or group of individuals) on each shift is trained and made available to act asthe State/County Communicator for the Protected Area. This individual can notify stationpersonnel, state agencies, county agencies, and the NRC. The State/County Communicator will maintain communications as necessary until relieved by a qualified member from theaugmented ERO.Page 5-13 of 1-93220EP-1 00 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Station2. Authority over the Emergency Response Organization The lED, ED, Offsite Emergency Manager (OEM), and Emergency Control Officer (ECO)are the designated VCSNS individuals who have overall authority and responsibility, management

ability, and technical knowledge for coordinating all emergency responseactivities at the VCSNS. The lED is the Shift Supervisor from the lead unit. In the event thatthere are multiple units entering in an emergency condition simultaneously, either the Unit 1or Unit 2 Shift Supervisor, depending on the affected Protected Area, will be the lED. In theevent the site as a whole is in an emergency due to natural phenomena, a security event, oran event affecting both Protected Areas, the Unit 1 Shift Supervisor will be designated asthe lED. If the event only affects a single Unit, then that Unit's Shift Supervisor is the lED.The lED is the Shift Supe.-sor.

The ED, OEM, and ECO are members of site management. Control Room: lED (Shift Supervisor), initially in command and control until relieved by theEmergency Director (ED) in the TSC. Once relieved by the ED, the ShiftSupervisor will maintain reactor and systems control.TSC: ED, when the TSC has attained minimum staffing levels, assumes theresponsibilities for classification and declaration, and otific;tion. ofemergencies, evaluations of operational events, and mitigation development. These duties may only be turned over to another qualified ED, with 9XceptioA o-f tho Antific-tion, WhiGh may be turned overeto thp DECEOF: ECO, when the EOF has attained minimum staffing levels, assumes overallcommand and control of VCSNS emergency response and approval ofpress releases, unless a designated Company Spokesperson is assigned. These duties may only be turned over to another qualified ECO/Company Spokesperson. OEM, when the EOF has attained minimum staffing levels, assumescommand and control of the EOF, notification of local, state, and federalagencies, and development and notification of Protective ActionRecommendations. These duties may only be turned over to anotherqualified OEM.Page 6-13 of 4-"220EP-IO00 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Station3. Criteria for Assuming Command and Control (Succession) Emergency personnel assume responsibility for their positions upon receiving notification toactivate. The responsibility for initial assessment of, and response to, an emergency restswith the Shift Supervisor. The Shift Supervisor is the lED and has the ED's responsibilities and authority until relieved by a qualified ED. The ED will relieve the Shift Supervisor of theresponsibility for continued assessment of the severity of the emergency and functions aspart of the ERO as appropriate in accordance with the guidance provided in the Emergency Plan, the Unit Annexes, and the emergency plan procedures. Final succession is achievedwhen the ED, OEM, and ECO assume overall command and control, and directs VCSNS'semergency response activities. The Control Room is to be relieved of command and control as soon as possible after thedeclaration of an Alert or higher classification. The overall command and control of theemergency is transferred directly to the ECO, as soon as possible. Command and controldoes not transfer to the TSC and EOF until the following criteria have been met:" Adequate staff levels are present in support of the non-delegable responsibilities " The status of the plant is well understood by the relieving individual " The staff has been fully briefed as to the status of the event and the current proposed planof action" A formal turnover between the lED relinquishing command and control and the ED, OEM,and ECO assuming command and control has been madeAlthough the ERO fulfills all regulatory requirements for emergency

response, it may bealtered at the discretion of the ECO. This type of alteration will be based on identified needswithin the ERO, event dependent

criteria, and identified needs of the company as a whole.4. Non-Delegable DutiesNon-delegable duties include the following functions:

" Event classification " Development of PARs for the general public" Notification of offsite authorities (approval of state, county, and NRC notifications) " Approving company press releases pertaining to the emergency The Shift Supervisor is responsible for the initial classification of an event and assumes theposition as lED. In this capacity, the Shift Supervisor has responsibility for performing thenon-delegable responsibilities until relieved. The ED (in the TSC) will relieve the lED of the command and control and eventclassification, notification, and Protoctiv, AcG-tionP Rc .mm +ndatin duti,,+. The OEM (in theEOF) will relieve the lED of emergency notifications and PAR development; and the ECO (inthe EOF) will relieve the ED of overall command and control.Page 6-13 of 493220EP-1 00 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Station5. Emergency Response Organization Position Responsibilities Each Annexes' Table 2-1 and Part 2 Section B-1 and Table B-la outline ERO positions required to meet minimum staffing and augmentation of the on-shift complement uponactivation of the Emergency Response Organization (ERO), and the major tasks assigned toeach position. The augmentation staffing levels are used as a planning basis to cover a widerange of possible events. For extended events (one that is expected to continue for morethan 24 hours), actual staffing will be established by the ED, OEM, and ECO based on theevent and personnel availability.

However, reduced staffing will only occur after discussion concerning the impact on plant operations and emergency response with the ED, OEM, andECO.As shown on Figure B-la, the overall ERO is made up of three suborganizations:

" The first is called the Onsite ERO. It is responsible for onsite emergency responseactivities. These activities include protecting plant personnel, mitigating the results of theevent, classifications, and keeping the Offsite ERO informed of onsite events and actionsbeing taken.* The second is called the Offsite ERO, which is responsible for offsite emergency responseactivities. These activities include providing information to and interface with offsiteauthorities, monitoring offsite results of the event, protecting plant personnel outside theProtected Area, supporting the onsite organization, notifications, Protective ActionRecommendations (PAR), and coordinating public information.

• The third is called the Emergency Public Information Organization and is responsible forproviding accurate information to the public about the event through the news media.Specific responsibilities for each sub-organization and related positions are as follows:a. Onsite ERO (Figure B-lb): The Onsite ERO is activated during an emergency classified as an Alert or higher. It can also be activated by the lED at his discretion during anUnusual Event. It functions under the direction of the ED, who is responsible fororganizing and coordinating the emergency efforts at and within the Protected Area ofthe affected unit(s).The Onsite ERO consists of station personnel who are involved with emergency response efforts necessary to control the plant during an incident.

This organization operates out of the Control Room, the Technical Support Center (TSC), and the affectedUnit's Operational Support Center (OSC). Collectively, members of the Onsite EROprovide for the following activities during an emergency:

• Plant systems operations and monitoring
• Radiological survey and monitoring (including Environmental Monitoring)

" Firefighting

• Rescue operations and first aid* Decontamination
• Security of plant and access controlPage 6-13 of 93220EP-100 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Station* Repair and damage control* Personnel protection including

assembly, accountability, and evacuation

• Communications When plant conditions warrant entry into the SAMGs, the ED assumes the role ofdecision-maker.

The Technical Support Supervisor or another qualified individual(s) assume the role of evaluator and assistant evaluator, and the Control Room staffassumes the role of implementers. Control Room personnel will perform mitigating actions for severe accidents per SAMGs before TSC activation. A set of guidelines, Beyond Design Basis Mitigation Guidelines (BDMG), in support of events that arebeyond VCSNS design basis has been developed and maintained to provide guidanceon evaluations and actions taken to mitigate an event of this nature.Those personnel identified to augment the on-shift personnel within about-6075 minutes Iof the declaration of an Alert or higher classification are part of the on-call ERO. Thesepersonnel are immediately available during normal working hours and are contacted bya call out system during nonworking hours.For security-related events that would prevent the emergency responders from reachingthe site, the augmented TSC, OSC, and Control Room responders would be directed torespond to the EOF or another designated offsite location. TSC/OSC/Control Roomstaffs will provide any possible assistance from this offsite staging area until such timeas site access is restored. Due to the configuration of the site and the presence of two separate and different technologies, there are selected positions in the ERO that have expertise in a specifictechnology and will be used as position leads during an emergency affecting thattechnology. All Onsite ERO personnel shall have the authority to perform assigned duties in amanner consistent with the objectives of this plan. In addition to maintaining adequatedocumentation of the event, position responsibilities include:1) Shift Supervisor (Interim Emergency Director) CRA Shift Supervisor is on duty 24 hours a day and is the lED in a declaredemergency until relieved of this function. While serving in this capacity, the ShiftSupervisor is responsible for:* Activating the ERO (as deemed appropriate or as procedurally required)

• Initiating the NRC Emergency Response Data System (ERDS)* Performing those duties outlined for the ED, OEM, and ECOPage 5-13 of 492R220EP-1 00 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear StationThe on-duty Shift Supervisor directs the activities of the operating crew and isresponsible for the safe operation of the plant in compliance with the unit NRC operating license and the unit operating procedures.

The Shift Supervisor, after relinquishing command and control, functionally reports to the ED in the TSC.The Shift Supervisor's responsibilities, when not in command and control, are described below:" The authority and responsibility to shutdown the reactor when determined thatthe safety of the reactor is in jeopardy or when operating parameters exceed anyof the reactor protection circuit setpoints and automatic shutdown does not occur* To ensure a review has been completed to determine the circumstance, cause,and limits under which operations can safely proceed before the reactor isreturned to power following a trip or an unscheduled or unexplained powerreduction

• The responsibility to be present at the plant and to provide direction for returning the reactor to power following a trip or an unscheduled or unexplained powerreduction
• The responsibility to adhere to the unit Technical Specifications and to reviewroutine operating data to assure safe operation
• The responsibility to identify applicable EALs and emergency classifications

" The responsibility to adhere to unit operating procedures and the requirements for their use. During an emergency, authorize operations personnel to departfrom approved procedures where necessary to prevent injury to personnel, including the public, or damage to the facility consistent with the requirements of10 CFR 50.54(x) and (y)." Initiate immediate corrective actions to limit or contain the emergency invokingthe provisions of 10 CFR 50.54(x) if appropriate, and specifically whenaddressing SAMGs or BDMGs" Approve emergency special procedures, and implement as required under theprovisions of 10 CFR 50.54(x)" Supervise the activities of the Control Room crew and the Communicators " Initiate onsite protective

actions, including authorization of exposure limits foremergency workers in excess of normal station limits2) Emergency Supoort Operator CRThe Operator reports to the Shift Supervisor.

Major functions include assisting inthe determination of the extent of station emergencies and recommending corrective actions. There is one Operator assigned to each Control Room. Each ofthese individuals report to their respective Control Rooms and communicates withtheir respective Operations Supervisor(s) in the TSC.Tho Operator repots to theShift Suoorwicor. ýMaio~r fu-nctio~ng include Aggictina n the dcte~rmination Af the extentPage 5-13 of 1-93220EP-100 Rev 0xx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Station3)4)5)of Station. 9oM9F@8ncie and recommonBding coerrecntive ac-tio-ns. There if; oneOperator as640Red-to eAch- Control Room. Emach of thero individuals report to thouFrespetive Control RoomA and coaemmunic-ates with the Operations Supervisor in theTSC for their respective ProteGted Arealechnoogy. Emeraency Director (ED) TSCThe ED supervises and directs the Onsite ERO. The ED's responsibilities includeorganizing and coordinating the onsite emergency efforts. Additionally, the ED hasthe requisite authority, plant operating experience, and qualifications to implement in-plant recovery operations. The ED is responsible for relieving the lED ofclassifying emergencies and onsite command and control. EDs are assigned fromeach Protected Area/Technology (Unit 1 and Units 2 & 3). The ED from affectedUnit(s) assumes the position of lead ED for the ERO.The ED supepi-oes anddirFectS the Onsito ERO. The ED'S rospontbilitic

,include organi.ing andcoordinating the ensite em~Fe;rgny effots. Addkitinally, the ED has the requiesite authority, plant operating eXP9ionc9.

, and q.alifitations to implement in platnrecover'; operatios.. The ED is responsib;le for. relieving the lED of cWAssi.ng Technical Support Supervisor TSCThe Technical Support Supervisor reports to the ED and directs a staff of engineers in performing technical assessments of station emergencies and assists in recoveryplanning. Supervisors are assigned from each Protected Area/Technology (Unit 1and Units 2 & 3). The Supervisor from affected Unit(s) assumes the position oflead Supervisor for the ERO.Tho Tec.hnical.. Support Supe. w.iso reports to the EDand directs a staff of engincors in perf49Formig technical assessmenAt6 Of station;emergencies and assists i~ngrcver,' planning. Technical Suoport Communicator TSCThe Technical Support Communicator reports to the Technical Support Supervisor. The Communicator is responsible for transmitting/receiving technical information orengineering decisions and support requests to and from the EOF, TSC, OSC, andControl Room(s).The TIenh.nial Support iator is ftransM!ittig~reco*ivi technica~l informatfion or engineering deAsionsQ and supportrcqUacts to an~d from the EFG=, TSCG, OSC, and Cenr#9l RoomR(s)-. Operations Supervisor TSCThe Operations Supervisor reports to the ED. Major functions include determining the extent of station emergencies and recommending corrective actions.Supervisors are assigned from each Protected Area/Technology (Unit 1 and Units 2& 3). The Supervisor from affected Unit(s) assumes the position of lead Supervisor for the ERO.The Operat!ins reports to the ED. Major fu';ncion ,inludsdetermining the extcnt -of station emorgencis and recommending corrective actons There- ark uevsro efrm each established Protected Area/Technology (Unit 1 ad Uof these individuals report to theT9C. The affected un~it Superio sue the position of load Supervisrw for, theFRO~Radiological Assessment Supervisor TSCThe Radiological Assessment Supervisor reports to the ED and supervises the6)7)Page 6-13 of 4-3220EP-100 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Stationactivities of the onsite radiological assessments. The supervisor directs the staff indetermining the extent and nature of radiological hazardous and conditions onsite.8) Emergency Notification System (ENS) Communicator TSC/CRThe Emergency Notification System Communicators report to the ED. TheCommunicator provides updates and responds to inquiries from the NRC for plantstatus, emergency classifications, and mitigation assessments, strategies, andactions.T-ho EmFergency Notification SyStom Communicators report to theEmer9gency Diroctlor. All coGMMUnicatem provide updates and respond to nurofromn the NIRC for plant status, emergoncY clasificationadmtgto RaFsscmonts and Actions.Page 5-13 of 220EP-100 Rev 0xx Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station409) Technical Support Staff TSCCore Thermal (Reactor), Electrical, Mechanical, and I&C (Units 2 & 3 only)Engineers make up the Technical Support Staff. These Engineers evaluatedamage assessment reports and support the development of mitigation recommendations, strategies, and procedures to recover the plant and return it to asafe and operational state. Each discipline will provide personnel to support eachProtected Area/Technology.Coro

Thormal, E=loGrical, Engineers makeup the Technical Support Staff. These Engineers evaluate damage assessment roports and 6upport the development of mnitigatfion~

rocoFmmondations, Strategies, Gand oroceduree toG- i rocever: the plant and return it to an eporational state.8) 6tateiGGURtY GOMMUR"GatOF Tsc:The Stato/CountY CommuAnicator roperts to the ED and enure.s that initialnotifirtcation gr om uiae to the nffsitA offirials within 15i minutes afte thechaRnge n classification or a change 4n PARs and that fol1ow.9 up notgifications arema;de withdin about 60 minut4196esf the proevious noiiain.This pocitiGn WilleXchange nomto with aIppropriate state and county aece oadnemergency notification f,-oms (green sheets) or ether questions that may arise.Uecn activation of the ESC, communications l trancfcrrd to the EOFSecurity Manager TSC10)The Security Manager reports to the ED and supervises the activities and defensive strategy of the Security Force, the site access control, and the Protected Area andVital Area access controls. The Manager also provides updates and information tothe Security Advisor in the EOF.11) Chemistry Supervisor TSCThe Supervisor reports to the ED and supervises the activities of the chemistry sampling and analyses. The supervisor directs the staff in determining the extentand nature of radiological and chemistry problems onsite.12) Maintenance Supervisor TSCThe Supervisor reports to the ED and supervises the activities of the Maintenance organization and assist with mitigation evaluations and repairs. The supervisor directs the staff in determining the extent and nature of mechanical, electrical, andI&C problems. Supervisors are assigned from each Protected Area/Technology (Unit 1 and Units 2 & 3). The Supervisor from affected Unit(s) assumes theposition of lead Supervisor for the ERO.13) Operational Support Center Supervisors OSCThe OSC Supervisors reports to the ED and supervises the activities of OSCpersonnel while implementing the mitigation strategies and procedures. Each OSC(Units 1, 2, & 3) will have separate Supervisors.The Supervisor reperts to theED and supep..ses the activities of 08G personnel while implementing themnitigation stratlegies and procedures. 154) Operational Support Center Damage Control Teams OSCSpecialists and Operators make-up the OSC Damage Control Teams. These teamsperform emergency mitigation tasks throughout the station. Individuals from HealthPhysics, Mechanical, Electrical, and I&C Maintenance, Chemistry, and Operations are always available as part of the OSC Damage Control Teams. Individuals fromPage 5-13 of 494220EP-1 00 Rev 0xx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Stationother plant organizations may also be called to assist in emergency mitigation efrorts. Eacn UOu will nave separate teams.p9cGa'ists a:n upeorato make upthe asp- -Damage Control ToaMs. Those toams performA omoF~rgonY mitigation tasks throughout the stationP. Individuas fo olhPyis ohnclEloctrical, and I&C Manenn e, hmistry, and Operations aro always avaiboas pa- i of the asp Damagoe Contro Toa ... Individuals from other plantorganizations m.ay also be called to assist in emergoncy mitigation offt.A)r----The SeGu* Supcrvwrer will 6uppeot the emorgoncy by providing er.Ge~ Or accossas roguostod to areas scUrod bDy the Socurity Force9 and not nOr~alY accer.sed. The SupeM'iso is responsible forF the physical security of the plant, access controlto the plant Pro-tectoid Aroa and access coentrol to plant vital aroas. In the event of AecUr ro-- latod' e Ye...t. the 6u VANii .. ll 9. to th. :TSPPage 6-13 of 4-9220EP-100 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Stationb. Offsite ERO (Figure B-lc): The Offsite ERO is activated during an emergency classified as -a Site Arop Emergencyan Alert or higher. It can also be activated by the lED at hisdiscretion during an Unusual Event. It functions under the direction of the OffsiteEmergency CoordinetefManager, and is responsible for offsite emergency responseactivities. These activities include providing information to and interface with offsiteauthorities; monitoring offsite results of the event; protecting plant personnel outside theProtected Area who are sheltered or evacuated, supporting the onsite organization, andcoordinating the flow of information to the EPIO.1) Emergency Control Officer (ECO) EOFWhen the ECO has command and control, the ongoing responsibilities include:* Assumes overall command and control of emergency response activities

• Ensure that federal, state, and county authorities and industry supportagencies remain cognizant of the status of the emergency situation.

Ifrequested, dispatch informed individuals to offsite govemmental EOCs" Serve as the Company Spokesperson for press conferences " Approve the technical content of VCSNS press releases before they arereleased to the media (non-delegable duty)* Coordinate all VCSNS activities involved with the emergency response* Ensure offsite agency updates are periodically communicated asrequired/requested

• Request assistance from non-VCSNS emergency response organizations, as necessary
• Provide status, assessment information, and recommended protective actions to offsite emergency response agencies" Request state or federal assistance

2) Offsite Emergency Manager (OEM) EOFThe OEM reports to the ECO. The OEM has the authority, management ability,and technical knowledge to assist the ECO in the management of VCSNS's offsiteERO by directing and coordinating the activation and response efforts of the EOFstaff, determining PARs (non-delegable duty) when necessary, andapproving state and county notification forms (non-delegable duty) with theassistance of the Offsite Radiological Assessment Manag..Radiologia

.Monitoring Coordinator and the Communications Coordinator.

3) Tochnicýal Supp,-, G.oo.r.dinato

.Plant Engineering Advisor EOFThe Techniral Support Coordi-natorPlant Engineering Advisor reports to the OEM.The Celrdmi,,trAdvisor supports the OEM and ECO with technical information aRd,ng:..ccri.ng cppe.t regarding the affected unit.Page 6-13 of 493220EP-100 Rev 0xx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Station4) Offsite Radiological Monitoring Coordinator (ORMC) EOFThe ORMC reports to the OEM and directs the activities of the EOF radiological assessment staff. These duties include specific responsibilities: recommending changes in the event classification and PARs based on effluent releases or doseprojections, assisting the OEM in the evaluation of the significance of anemergency with respect to the public, and advising the OEM on the need foremergency exposures or for issuance of Potassium Iodide (KI) to the Field Teams.5) Dose Assessor EOFThe Dose Assessor reports to the Offsite Radiological Monitoring Coordinator andoperates the dose assessment

program, interprets radiological data from the fieldmonitoring teams, and provides PARs based on dose projections to the OffsiteRadiological

.A.c=sosm.-.nt Mz.n=gorRadielegiclMonitoring Coordinator.

6) Communications Coordinator EOFThe Communications Coordinator reports to the OEM and creates the Emergency Notification Form (ENF). The Coordinator ensures initial notifications arecommunicated to the offsite officials within 15 minutes after the declaration of anemergency classification or change in Protective Action Recommendation (PAR)and follow-up notifications are made within 60 minutes of the previous notification.

The position will coordinate the exchange of information with appropriate state andcounty agencies regarding the emergency, siren activation, offsite Protective ActionDecisions (PAD), or other questions that may arise. This position is the lead for theState/County Communicator in the EOF.7) State/County Communicator EOFThe State/County Communicator reports to the Q0EM-Communications Coordinator and ensures that initial notifications are communicated to the offsite officials within15 minutes after the change in classification or a change in PARs and that follow-up notifications are made within about 60 minutes of the previous notification-. Thisposition will exchange information with appropriate state and county agenciesregarding emergency notification forms (9FeeR sheets) or other questions that mayarise.8) SeoUFitY Security Advisor EOFThe G9rd4.,atet-rAdvisor reports to the OEM and will be responsible for maintaining EOF security, coordinating EOF security with site security, and interfacing with locallaw enforcement, as needed.9) Health Physics Network (HPN) Communicator EOFThe Health Physics Network Communicators report to the Offsite Radiological Monitoring Coordinator in the EOF. The EOF communicator provides updates andresponds to inquiries from the NRC on offsite environmental data, release status,dose projections, and changes to PARS for the general public.10) Field Teams EOFThe Field Teams report to the ORMC and are responsible for conducting radiological monitoring surveys and sampling for areas outside of the OwnerControlled Area, within the EPZPage 5-13 of 4-.93220EP-IO00 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Station11) Plant Operations Advisor EOFThe Plant Operations Advisor reports to the OEM. The Advisor supports the OEMand ECO with operational and technical information regarding the affected unit.8) General Seo.'-ces Coordinator EOFThe Coordinato rFrop.ts to tho OE .and will be r .sponsibl. for mairtaining Andcoor~dinating documonAt sorvNices, transportation, poF9Rsonnlacomdtn, temporary off-sie fa-ilitie

and- coemmunic-ations, meals, and procurem~ent anddeliv

4r; Of it8ems requested by; the ERO.c. Emergency Public Information Organization (EPIO) (Figure B-ld): The EPIO is part ofthe overall ERO that is activated during an emergency.

It functions under the ECO(Company Spokesperson) and gets support from the OEC.The EPIO consists of corporate, and station personnel who are involved with emergency response efforts necessary to coordinate VCSNS public notices with offsite agencypublic information updates. This organization operates out of the Joint Information Center (JIC). Collectively, members of the EPIO provide for the following activities duringan emergency:

• Development and issuance of news releases* Coordination and conduct of media briefings

" Rumor control* Media monitoring and correction of misinformation All EPIO personnel shall have the authority to perform assigned duties in a mannerconsistent with the objectives of this plan. In addition to maintaining adequatedocumentation of the event, position responsibilities include:1) Comoanv Sookesoerson (Emergency Control Officer) JIC/EOFThe Company Spokesperson reports is responsible for directing the VCSNS EPIO,coordinating with the other responders, and providing news information to themedia.2) Joint Information Center Coordinator JICThe JIC Coordinator reports to the Company Spokesperson and is responsible forensuring the operability of the JIC and supervision of monitoring activities in theJIC.3) Lead Technical Brifr JICThe, Anod Tochnica Brie fr reports to the Company Speksper.. n and assists inobtaining technical and Alant status information for --s in news roloases and meedi4)-Media Coordinator liPCThe Media Monitoring Coordinator reports to the JIC Coordinator and ensures thatthe media is being monitored and that VCSNS personnel review the information detailed or contained in media releases. Page 5-13 of 4-9-220EP-1 00 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Station6. Emergency Response Organization Block DiagramEach Annex Table 2-1 and Part 2 Section B-1 and Table B-la, list the basis for the EROand the supporting positions assigned to interface with federal, state, and county authorities. Section B.5 discusses specific responsibilities and the interrelationships for these positions.

7. IndustrylPrivate Support Organizations VCSNS retains contractors to provide supporting services.

A contract/purchase order with aprivate contractor is acceptable in lieu of an agreement letter for the specified duration of thecontract. Institute of Nuclear Power Organization (INPO), Electric Power Research Institute (EPRI), and Nuclear Energy Institute (NEI) maintain a coordination agreement on emergency information with their member utilities. Among services currently provided are the following:

a. Institute of Nuclear Power Operations (INPO): Experience has shown that a utilitymay need resources beyond in-house capabilities for the recovery from a nuclear plantemergency.

One of the roles of INPO is to assist affected utilities by quickly applying theresources of the nuclear industry to meet the needs of an emergency. INPO has anemergency response plan that enables it to provide the following emergency supportfunctions: " Assistance to the affected utility in locating sources of emergency personnel, equipment, and operational analysis" INPO provides the "Nuclear Network," or its replacement, electronic communications system to its members, participants, NEI, and EPRI to coordinate the flow of mediaand technical information about the emergency " VCSNS may obtain utility industry information and assistance from any party to thisagreement through the coordination of INPOTo support these functions, INPO maintains the following emergency supportcapabilities: " A dedicated emergency call number" Designated INPO representative(s) who can be quickly dispatched to the VCSNS EROto coordinate INPO support activities and information flow* The 24-hour-per-day operation of an Emergency Response Center at INPOheadquarters INPO will be notified (via the designated emergency call number) for all situations involving an Alert, Site Area Emergency, or General Emergency declaration. INPO hascoordinated the preparation of a Voluntary Assistance Agreement for Transportation Accidents. SCE&G has signed this agreement which establishes the rights andresponsibilities of electric utilities in requesting or providing assistance for response to atransportation accident involving nuclear materials. Page 5-13 of 4-93220EP- 100 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Stationb. American Nuclear Insurers (ANI): In early 1982, ANI issued Bulletin

1. 5B (1981)"Accident Notification Procedures for Liability Insured" which provides revised criteria forthe notification of the pools in the event of a nuclear emergency at one of the liability insured nuclear power reactor sites. This revision brings the ANI/MAELU (Mutual AtomicEnergy Liability Underwriters) notification criteria into alignment with the standardemergency classification system adopted by the nuclear industry.

This document alsoidentifies a suitable channel for follow-up communication by ANI after initial notification.

c. DOE Radiation Emergency Assistance Center/Training Site (REAC/TS):

DOEREAC/TS provides services of medical and health physics support. REAC/TS adviseson the health physics aspects of situations requiring medical assistance. Page 6-13 of 4-93220EP- 100 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Stationd. Manufacturer Design and Engineering Support: Under established contracts, theunit(s) design engineering company provides design engineering expertise, specialized equipment, and other services identified as needed and deemed appropriate to assist inan emergency situation.

8. Supplemental Emergency Assistance to the EROAgreements are maintained with outside support agencies who do not take part in theorganizational control of the emergency.

They provide assistance when called on during anemergency or during the recovery phase. These agreements identify the emergency measures to be provided, the mutually accepted criteria for implementation, and thearrangements for exchange of information. These support agencies (named in Appendix 2)provide services of:a. Law enforcement

b. Fire protection

c. Ambulance servicesd. Medical and hospital supportSupport groups providing transportation and treatment of injured station personnel aredescribed in Section L of this Plan.Page &13 of 4-93220EP- 100 Rev 0xx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear StationPart 2: Planning Standards and Criteria V. C. Summer Nuclear StationEmergency Control Officer(Company Spokesperson) 4-- -'4----.///I II II II II II II I\/\ --------Onsite Emergency ResponseOrganization

\ --------Offsite Emergency ResponseOrganization \ ---Emergency Public Information Organization Figure B-la: Overall ERO Command Structure Page 32 of 1-93220EP-100 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear StationFigure B-lb: Onsite Emergency Response Organization Page 33 of 4-1.220EP-100 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear StationFigure B-Ic: Offsite Emergency Response Organization Page 34 of 4-2R220EP-1 00 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear StationFigure B-Id: Emergency Public Information Organization Page 35 of 4-93220EP-100 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear StationTable B-la: Staffing Requirements for the VCSNS EROStaffing -Shift/ERO (75 Minute Response Time*)3 nut. Minute ERO Facility ERO FacilityUnit Shift Activation Essential Functional Area Major Tasks Emergency Positions (Facility) Staffing Staffing" Staffing-"

1. Plant Operations and Control Room Shift Supervisor/Interim ED (CR) 4-(h)Assessment of Staff Control Room Supervisor (CR) (h)Operational Aspects Reactor Operator (CR) (h)Auxiliary Operator (CR/OSC)

(h)Emergency Support Operator (CR) ----4 1(i)22. Emergency Direction Command and Interim Emergency Director (CR) (h)and Control Control Emergency Director (TSC) 1a} 1(a)Emergency Control Officer (EOF) 1 (a) 1 (a)Offsite Emergency Goedin4atorManager (EOF) 1(a) 1 (a)3. Notification & Emergency Interim Emergency Director (CR) (h)Communication Communications State/County Communicator (CR) (h) 4State/County Com-mun incatow (TSCG) wa --Offsite Emergency Geor14i4aeteManager (EOF) 119 1(g)State/County Communicator (EOF) --- 1 (ga) 1(g)Communications Coordinator (EOF) 1(g)1Plant Status ENS Communicator (TSC) 1Technical Support Communicator (TSC) 41HPN Communicator (EOF) 1TeohniGcl SuppGrt CoordinatorPlant Engineering 1Advisor (EOF) 1Plant Operations Advisor (EOF)Page 36 of 4-W220EP-1 00 Rev 0xx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear StationStaffing -Shift/ERO (75 Minute Response fim.)3~ -60Minute ERO Facility ERO FacilityUnit Shift Activation Essential Functional Area Major Tasks Emergency Positions (Facility) Staffing Staffing* Staffing**

4. Radiological Offsite Dose Health Physics Specialist (OSC) --1Assessment and Support of Assessment Offsite Rad Monitoring Coordinator (EOF) 1Operational Accident Dose Assessor/Health Physics (EOF) (h) 1Assessment Offsite Field Monitoring Teams (EOF)Radiological Health Physics Specialist (m qualfied pesonnel) l(- 1Monitoring Drivers 1(h) 1Onsite Field M.onitoing TeamsDamage Control(OSC)

Radiological Health Physics Specialist (M uqwed pmonnr) 1 1Monitoring Radiological Assessment Supervisor (TSC) 1In-plant Surveys Health Physics Specialist (OSC) -1(h)Chemistry Chemistry Specialist (OSC) 44e) -1Chemistry Supervisor (TSC) 1(h)HP Supervisory Health Physics Specialist(OSC)Plant Radioelogicl 11-tSupe Y Monting Director (OSC) ---Formatted: Indent: Left: 0", First line: 0",Space After: 0 pt, Don't keep lines together, Tab stops: Not at 1.25"Page 37 of 4-,3220EP-100 Rev 0xx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear StationStaffing -Shift/ERO (75 Minute Response Time')30 ..utG Minute ERO Facility ERO FacilityUnit Shift Activation Essential Functional Area Major Tasks Emergency Positions (Facility) Staffing Staffing" Staffing**

5. Plant System Technical Support Shift Engineer (CR) (h)Engineering, Repair, and Operations Supervisor (GIwTSC) 4-I 1(i)Corrective Actions Technical Support Supervisor (TSC) -1(i)Core Thermal Engineer (TSC) 1 (i)(eOMechanical Engineer (TSC) 1(i)Electrical Engineer (TSC) ....... 1(i)I&C Engineer (TSC) 1(i)Repair and Mechanical Maintenance Mechanic (OSC) 1Corrective Actions Electrical Maintenance Electrician (OSC) 1 1I&C Maintenance Mechanic (OSC) (h) 1(h-) 1Health Physics Specialist (Rad Waste) (OSC) (h) 1OSC Supervisor (OSC) (h) 1Maintenance Supervisor (TSC) 2 1(i)446. In-Plant Protective Radiation Health Physics Specialists (OSC) (h) 2 2(b)Actions Protection (w-7. Fire Fighting Fire Brigade (h) (f) (r,) (4)8. Rescue Operations and Medical Emergency Response Team (h) (f) (4fFirst Aid (b)-9. Site Access Control and Security

& Security Team PeorconnlForce (h)Personnel Accountability Accountability Security Manager (TSC) 1Plant Security Advisor (EOF) 1Page 38 of 4-14220EP-100 Rev 0xx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear StationStaffing -Shift/ERO (75 Minute Response T1me*)3OIlnute- -60 MintERO Facility ERO FacilityUnit Shift Activation Essential Functional Area Major Tasks Emergency Positions (Facility) Staffing Staffing* Staffing**

10. Public Information Media Interface, Company Spokesperson (JIC) 1Information JIC Coordinator (JIC) 1Development, Media and RumorControl Monitoring, and FacilityOperations andControl(a) The Shift Supervisor shall function as the lED until relieved by the Emergency Director and Offsite Emergency Manager(b) May be provided by personnel assigned other functions (G) Fire Brigade9 per FSARi4echn*GaI SpecificationS, as applicable (d) Por Secrwity Plan;(9) May be provided by rhift porsonnel assigned other8 fnctdinRS, (f) Supported by Offsite Response Organizations (ORO)(g) Telephone Communicator Only(h) Actual rosponco time is 40 minutes-h)

Shift personnel are listed in each Unit's Annex Table 2-1(i) Per Unit/Technology (with exception of I&C Eng, Units 2 & 3 only)* Response time is based on optimum travel conditions liigheFacility Activation Staffing also includes Shift Staffing Personnel assigned to the respective facilities. These personnel must beavailable, but are not required to be in the facility to activate. Page 39 of 4-Wg220EP-100 Rev gxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear StationSection C: Emergency Response Support and Resources This section describes the provisions for requesting and effectively using support resources andfor accommodating offsite officials at the VCSNS emergency response facilities.

1. Federal Response Support and Resources Assistance is available from federal agencies through the NRF. The lead federal agencywho provides direct assistance to VCSNS during an emergency is the NRC. Other federalagencies, such as the DHS and the DOE provide assistance to the state throughimplementation of the NRF.a. Sections A and B of this plan identify the specific individuals by title who are authorized to request federal assistance.

b. Federal agencies that may provide assistance in direct support of VCSNS in the event ofan accident are identified in Section A of this plan. If needed, federal resources aremade available to VCSNS in an expeditious and timely manner.c. Each emergency response facility has the equipment and communications capability necessary for a continuous high level of response, interaction, and communication among key personnel during emergency conditions.

The emergency facilities are able toaccommodate federal representatives with working areas provided for their use. Basedon the NRC Response Coordination Manual 1996 (RCM-96) or NUREG-0728, accommodations for the initial site response team assume the following approximate numbers for each facility: Facility Accommodations EOF 12TSC 6CR 1JIC 2d. Communication pathways provided in each of these facilities include access todedicated landline telephones, wireless telephones, and FTS telephones as provided bythe NRC and include the Reactor Safety Counterpart Link (RSCL), Management Counterpart Link (MCL), the Protective Measures Counterpart Link ( PMCL), and theLocal Area Network (LAN). These FTS lines are available in the appropriate VCSNSemergency response facilities and are for use by the NRC Response Team upon theirarrival. The VCSNS ERO does not normally utilize these communication links.Page 40 of 41-9220EP-100 Rev Gxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Station2. Liaisonsa. The NRC and FEMA and the state and counties may dispatch representatives to theEOF where accommodations have been provided.

b. At the Site Area Emergency level and above, VCSNS personnel may be assigned asliaisons to the state of South Carolina, Lexington County, Richland County, NewberryCounty, and Fairfield County EOCs, after they are activated.

These representatives actas technical liaisons to interpret emergency action levels, explain accident conditions, and provide technical information regarding actions by the station's ERO.3. Radiological Laboratories Support of the radiation monitoring and analysis effort is provided by an onsite laboratory. The onsite laboratory is the central point for receipt and analysis of all onsite samples andincludes equipment for chemical analyses and for the analysis of radioactivity. A, aAdditional laboratory facilityies are-4s available at t#e-DHEC, other nuclear facilities, or Iprivate labs. DHEC also has a mobile laboratory for analyzing environmental samples. Theresponse time for efficient activation of the mobile laboratory is approximately 2 to 3 hours.4. Other Assistance Through INPO, other companies' operating nuclear facilities are available to provide certaintypes of assistance and support, including technicians, engineering, design, consultation, Iwhole body counting, and dosimetry evaluation and equipment. Additional facilities, organizations, and individuals, as listed in the Emergency Planning Telephone Directory, areavailable and may be used in support of emergency response. In addition, ANI providesinsurance to cover VCSNS legal liability up to the limits imposed by the Price-Anderson Act,for bodily injury and/or property damage caused by the nuclear energy hazard resulting froman incident at the plant. Written agreements that describe the level of assistance andresources provided to VCSNS by external sources listed in Appendix 2 as applicable. Page 41 of 49Q220EP-IO00 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear StationSection D: Emeraency Classification SystemThis section describes the classification and emergency action level scheme used to determine the minimum response to an abnormal event at the station. This scheme is based on plantsystems, effluent parameters, and operating procedures for each unit The initial response offederal, state, and county agencies depends on information provided by the ERO. The station's Emergency Preparedness Staff works closely with the state of South Carolina and countyagencies to ensure consistency in classification schemes and procedural interfaces.

1. Emergency Classification SystemThe Emergency Plan provides for classification of emergencies into four (4) categories orconditions, covering the postulated spectrum of emergency situations.

They are:* Unusual Event" Alert* Site Area Emergency

• General Emergency Each classification is characterized by EALs or event Initiating Conditions (IC) andaddresses emergencies of increasing severity.

a. Unusual Event Events are in progress or have occurred that indicate a potential degradation of the level of safety of the plant or indicate a security threat to facilityprotection has been initiated.

No releases of radioactive material requiring offsiteresponse or monitoring are expected unless further degradation of safety systemsoccurs.This is the least severe of the four levels. The purpose of this classification is to bringresponse personnel and offsite agencies to a state of readiness in the event the situation degrades and to provide systematic handling of information and decision making. TheJI-itI4ead Unit's Shift Supervisor will classify an Unusual Event and become the lED.Required actions at this classification include:* Notifications to station and company management " Notification, within 15 minutes, of the state and counties" At the discretion of the lED, or the station management, full or selective staffing of anyone or more of the emergency response facilities may be initiated

• Notification of the NRC as soon as possible but within 60 minutes of classification

" Assessment of the situation and response as necessary, which may include escalating to a higher classification when and if conditions warrantPage 42 of 4N220EP-IO00 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Station" When the event is terminated, dose-out is performed over communication links tooffsite authorities (i.e., NRC, state, county), participating in the response by providing asummary of the event" Provide a formal written summary transmitted to the state and counties within 24hours-.b. Events are in progress or have occurred that involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involvesprobable life-threatening risk to site personnel or damage to site equipment because ofHOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPAProtective Action Guideline (PAG) exposure levels.The purpose of this classification is to ensure that emergency response personnel arereadily available and to provide offsite authorities with current status information. AnAlert will be classified as the initiating event or as escalation from an Unusual Event Ineither case, the classification will most likely be made by the lead Unit's Shift Supervisor (lED) before the transfer of command and control.Required actions at this classification include:" Notifications to station management

• Notification, within 15 minutes, of the state and counties* Activation of the Oneita-iRQTSC, OSC(s), EOF, and JIC* Transfer of command and control" Notification of the NRC as soon as possible but within 60 minutes of classification
• Notification of INPO and ANI* Assessment of the situation and response as necessary, which may include escalating to a higher classification if and when conditions warrant" Onsite and offsite field teams are sent to staging areas or dispatched to monitor forreleases of radiation to the environment

" Keeping offsite authorities informed of plant status by providing periodic updates toinclude meteorological and radiological data" When the event is terminated, close-out is performed over communication links tooffsite authorities participating in the response by providing a verbal summary of theevent (i.e., NRC, state, county), followed by formal written summary transmitted to thestate and counties within 8 hoursPage 43 of 449220EP-100 Rev Oxx Part 2: Planning Standards and Criteria V. C. Summer Nuclear Stationc. Site Area Emergency: Events are in progress or have occurred that involve actual orlikely major failures of plant functions needed for protection of the public or HOSTILEACTIONS that result in intentional damage or malicious acts 1) toward site personnel orequipment 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 toresult in exposure levels which exceed EPA PAG exposure levels beyond the siteboundary. This classification will most likely be made by the ED following activation of the TSC withnotifications being developed in the EOF.Required actions at this classification, in addition to those listed under the Alert level,include:" ActivatiFoRnf the Of.eito ERO and Emergency Pub!ic InforPmation OrFganzation " If not previously performed, assembly/accountability shall be performed and siteevacuation of nonessential personnel shall be initiated

• Dispatch of plant technical liaisons to the county and state EOCs when they areactivated to provide a plant-knowledgeable individual to explain plant communications regarding the emergency and support the interaction with the offsite authorities duringthe emergency

" Koeping offeite authorFities informed of plant status by providing periodic updates. to-GincldeA meteorolo91gical data and projected or -actual dosesA for any releases that have" W.Ahen the event is, terminated, close out iS performed over.cmuicto links toofsita participating in the "eponse by providing a verbal summary of theevent (i.e., NRC, state, county), folloWed by formE4 aVFAl wriftonsumary tranemiftod-to thst;at and counties within R hoursPage 44 of 4-93220EP-IO00 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Stationd. General Emergency: Events are in progress or have occurred that involve actual orIMMINENT 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 thefacility. Releases can be reasonably expected to exceed EPA PAG exposure levelsoffsite for more than the immediate site area.The purpose of this classification, in addition to those of the Site Area Emergency level,is to initiate predetermined protective actions for the public and provide continuous assessment of information from monitoring groups. The classification will most likely bemade by the ED following activation of the TSC with notifications and PARs beingdeveloped in the EOF, following activation. Required actions at this classification, in addition to those listed under the Alert and SiteArea Emergency, include:* A PAR will be determined and issued* Assessment of the situation and response as necessary " Whon the ovo~nt is termin'ated, eloco out is porformod ovo-r communic-ation links to911649c authoritfies participating in the rasponse by providing a verbal rcuMMa' oYf theevent (iae, NIRC, state, county), followod by foermalywritten summary tr~ansnmittd to thostate and counties-w..ithin 8-hue. Classification Down-grading: VCSNS's policy is that emergency classifications shall notbe downgraded to a lower classification. Once declared, the event shall remain in effectuntil no classification is warranted, a highor classification is required, -or until such time Ias conditions warrant entry into the Recovery Phase.Page 45 of 4-.3220EP-1 00 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Stationf. Guidance for Termination of an Emergency: The purpose of terminating an emergency is to provide an orderly turnover of plant control from the EROs to the normal VCSNSplant organization. Termination of the emergency is authorized by the ECO in commandand control. If the emergency is classified as an Alert or higher, the lED must await theactivation of the emergency response facilities and turn over command and control tothe ECO before initiating the Recovery/Termination Checklist. The considerations provided in the Recovery/Termination Checklist in the emergency plan procedures mustbe performed before exiting the emergency event. Consultation with governmental agencies and other parties should be conducted before termination of an event classified as Site Area Emergency or General Emergency. Notifications shall be transmitted toappropriate agencies to terminate an event. When a classified event is terminated aRecovery Phase will be entered.g. Recovery Phase: That period when the emergency phase is over and activities are beingtaken to return the situation to a normal state (acceptable condition). The plant is undercontrol and no potential for further degradation to the plant or the environment isbelieved to exist.Entry into the Recovery Phase will be authorized by the ECO after consultation with theED and OEM at an Alert or higher classification and the offsite authorities if a Site AreaEmergency or General Emergency was declared. The lED may enter theRecovery/Termination Phase after the Unusual Event when conditions warrant.Required actions at this phase include:* The state and the NRC shall be consulted prior to entry into recovery from a Site AreaEmergency or a General Emergency.

• Notifications will be made to station management, state, counties, and NRC.* A Recovery organization will be established to manage repairs to return the unit to anacceptable condition, and support environmental monitoring activities as requested incoordination with federal and state efforts." INPO and ANI are notified of Recovery classification.

Page 46 of 4-93220EP-100 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Stationh. VCSNS Security Plan: VCSNS has a Security Plan that complies with the requirements of 10 CFR 73. The interface between the Radiological Emergency Plan and the SecurityPlan is one of parallel operation. The plans are compatible. The Radiation Emergency Plan response

measures, once initiated, are executed in parallel with measures taken inaccordance with the Security Plan. During a classified event, the individual in overallcommand and control has responsibility for implementing both plans.Threats made to VCSNS facilities are evaluated in accordance with established threatassessment procedures and the Security Plan. The Security Plan, Appendix C,Safeguards Contingency Plan, identifies situations that could be ICs for EALclassifications.

Contingency events include bomb threats, attack threats, civildisturbances, Protected Area intrusions, loss of guard/post

contact, vital area intrusions, bomb devices discovered, loss of guard force, hostages, extortion, fire/explosions, internal disturbances, security communications

failure, and obvious attempts oftampering.

The Safeguards Contingency Plan provides guidance for decisions andactions to be taken for each security contingency event. As guidance, the Safeguards Contingency Plan allows for differing responses depending upon the assessment of theactual situation within each contingency event classification. The assessment of any security contingency event and the decision to initiate, or not toimplement the Radiation Emergency Plan, will be the responsibility of the ShiftSupervisor or ECO. All identified security contingency events have the potential of beingassessed as ICs for a radiological emergency declaration. Page 47 of 4-93220EP- 100 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Station2. Emergency Action Level Technical BasisEmergency Plan Implementing Procedures include an EAL Technical Basis Documentwhich includes Unit-Specific EALs consistent with the emergency classification descriptions from NEI 99-01 and NEI 07-01. The EALs are consistent with NEI guidance documentation in accordance with Regulatory Guide 1.101, "Emergency Planning and Preparedness forNuclear Power Reactors." Where possible, these EALs will be related to plantinstrumentation readings.EPP

001, and Impleme.n.ttation of Em=.rgcY Plao,i-AncludeAs Un~it Sp199G& EAI-s consistont with the gonoral class doscriptions and providedi NEI guidance in cnord nce with Rogulato; Guide 1.10,, "Emergenc.y P!anning ard Preparednees for Nhcloar Pe:ower Reactrs."

Whore possible, these --A.Ls wil-be related-to plant instrumon~tation roadings. Emergency classifications are characterized by EALs. The Threshold Values are referenced whenever an Initiating Condition is reached. An Initiating Condition is one of apredetermined subset of unit conditions, where either the potential exists for a radiological emergency, or such an emergency has occurred. Defined in this manner, an Initiating Condition 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. ICs arearranged in one of the Recognition Categories. EALs are for unplanned events. A planned evolution involves preplanning to address thelimitations imposed by the condition, the performance of required surveillance

testing, andthe implementation of specific controls before knowingly entering the condition.

Plannedevolutions to test, manipulate, repair, perform maintenance or modifications to systems andequipment that result in an EAL Threshold Value being met or exceeded are not subject toclassification and activation requirements as long as the evolution proceeds as planned.However, these conditions may be subject to the reporting requirements of 10 CFR 50.72.An emergency is classified after assessing abnormal plant conditions and comparing themto EAL Threshold Values for the appropriate ICs. Classifications are based on the evaluation of VCSNS. EAL matrix tables organized by recognition categories are used to facilitate thecomparison. The EAL matrix for Unit 1 is used when the unit is in the Technical Specification defined modes of Power Operations as: Power Operations,

Startup, Hot Standby, HotShutdown, Cold Shutdown, Refueling, or the Defueled mode. The EAL matrix for Units 2 &3 is used when either unit is in the Technical Specification defined modes of PowerOperations as: Power Operations,

Startup, Hot Standby, Safe Shutdown, Cold Shutdown, Refueling, or Defueled.

All recognition categories should be reviewed for applicability prior to classification. TheEALs are coded with a letter and number designator. All ICs, which describe the severity ofa common condition (series), are located above the EALs.3. Offsite Classification SystemsVCSNS works with the state and counties to ensure consistency between classification schemes. The content of the EALs is reviewed with the state and county authorities on anannual basis. The state and counties are informed regarding any EAL changes thatsignificantly impact the ICs or Ttechnical Bbasis.Page 48 of 1-93220EP-1 00 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Station4. Offsite Emergency Procedures VCSNS works with the state and county authorities to ensure that procedures are in placethat provide for emergency actions to be taken which are consistent with the protective actions recommended by the station, accounting for local offsite conditions that exist at thetime of the emergency. Page 49 of 1-93220EP-IO00 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear StationSection E: Notification Methods and Procedures This section describes the notification of state and county response organizations, federalagencies, and VCSNS emergency response personnel. It outlines the content of initial andfollow-up messages to response organizations within the plume exposure pathway EPZ.1. Bases for Emergency Response Organization Notification VCSNS, in cooperation with state and county authorities, has established mutuallyagreeable methods and procedures for notification of offsite response organizations consistent with the emergency classification and action level scheme. Notifications to offsiteagencies include a means of verification or authentication such as the use of dedicated communications

networks, verification code words, or providing call-back verification phonenumbers.Notification for Transportation Accidents:

A Transportation Accident is defined in 49 CFR171.15 and 49 CFR 171.16. If a Transportation Accident involving material in the custody ofa VCSNS facility occurs, the appropriate internal and offsite agencies will be notified inaccordance with VCSNS procedures.

2. Notification and Mobilization of Emergency Response Personnel Emergency implementing procedures are established for notification and mobilization ofemergency response personnel as follows:a. Onsite: When an emergency is declared, reclassified, or terminated, an announcement is made (over the plant public address system or by other means) that includes theemergency classification declared and response actions to be taken by site personnel.

At the Unusual Event classification, select ERO augmentation personnel may be notifiedand requested to remain available to respond. At an Alert classification or higher, EROaugmentation personnel are notified for activation of the TSC, ari- OSC, and at a Si4Area Emcrgency or highot augmontation perconnol are notificd for actk-ation of the andEOF and JIC using an ERO notification system and/or manual call-outs via commercial telephone as backup.Page 50 of 493220EP-1 00 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Stationb. Offsite: Notifications are promptly made to offsite EROs as follows:1) State/County Agencies: A notification shall be made within 15 minutes of:* The initial emergency classification

• Classification escalation

" The issuance of, or change to a PAR for the general public" Changes in radiological release status, occurring outside of an eventclassification or PAR notification, based on an agreement with the state/county authorities The emergency warning points are simultaneously notified using a dedicated notification system. Commercial telephone lines and/or radios are available asbackup notification methods.A notification will also be initiated to cognizant state/county government agencies assoon as possible but within one hour of the termination of an event classification, orentry into Recovery Phase.2) NRC: An event will be reported to the NRC Operations Center immediately afternotification of the appropriate state and county agencies but not later than one hourafter the time of initial classification, escalation, termination, or entry into theRecovery Phase. The NRC is notified by a dedicated telephone system called theEmergency Notification System (ENS). If the ENS is inoperative, the requirednotifications are made via commercial telephone

service, other dedicated telephone

service, or any other method that shall ensure that a report is made as soon aspractical.

The Emergency Notification Form (ENF) may be used as a guide toprovide initial information to the NRC. If continuous communication is requested and established, a log is used in lieu of the ENF.Specific requirements for the notifications to the NRC for classified emergency events are detailed in 10 CFR 50.72 with guidance provided in the station's notification procedures. The computerized data link to the NRC, referred to as the ERDS, will be initiated within one hour of the declaration of an Alert classification or higher.Mobilization of federal, state, and county response organizations is performed inaccordance with their applicable emergency plan and procedures. At a minimum,mobilization of federal response organizations and activation of state and countyEOCs is expected to occur at the declaration of a Site Area Emergency. The stateand county authorities are responsible for the process of notification of the generalpublic.Page 51 of 1-9,220EP-IO00 Rev Gxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Stationc. Support Oraanizations: When an emergency is initially classified, escalated, orterminated, notifications are promptly made to the following support organizations: " Medical, rescue, and firefighting support services are notified for assistance as thesituation dictates" INPO is notified at an Alert or higher classification with requests for assistance asnecessary " ANI is notified at an Alert or higher classification with requests for assistance asnecessary " Vendor and contractor support services are notified for assistance as the situation dictates3. Initial Notification MessagesVCSNS, in conjunction with state and county authorities, has established the contents of theinitial notification message form, the ENF, transmitted during a classified emergency. Thecontents of the form include, as a minimum:* Designation ('Drill" or "Actual Event")* Identity of site and unit" Event classification

• EAL number (as agreed upon with state authorities)
• Nontechnical event description (as agreed upon with state authorities)
• Date and time of declaration (or entry into Recovery Phase or Termination)

" Whether a release is taking or has taken place (Note: "Release" means a radiological release attributable to the emergency event.)" Wind direction and speed" Whether offsite protective measures may be necessary " Potentially affected EPZ zones subareas-when a General Emergency is declaredNotification

approval, transmittal date and time, and offsite agencies contacted are recordedeither on the notification form or in an event logbook.Page 52 of 4-1220EP- 100 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Station4. Follow-Up MessagesFor all emergency classifications, update messages to state and county authorities will beprovided on a prearranged frequency.

The facility in control of notifications nemmand andcent-rl-is responsible for ensuring that the updates are completed. State and countyupdates contain the prearranged information plus any additional information requested atthe time of the notification. Follow-up notifications are provided to the NRC Operations Center as soon as possible, butnot later than one hour after significant new information is available involving:

a. The results of evaluations or assessments of plant conditions

b. The effectiveness of response or protective measures takenc. Information related to plant behavior that is not understood If requested by the NRC, an open, continuous communications channel will be maintained with the NRC Operations Center over the ENS and/or HPN circuits.

5. State and County Information Dissemination The state and county emergency response plans describe procedures for state and countyofficials to make a public notification decision promptly on being informed by the plant of anemergency.

The system for disseminating information to the public includes notification bypre-scripted messages through appropriate broadcast media such as the Emergency AlertSystem (EAS).6. Notification of the PublicThe capability for the prompt notification of the general public within the 10-mile plumeexposure pathway EPZ around the VCSNS is covered under this plan.This notification capability consists of two principal elements: (1) the Alert and Notification Systems (ANS) and (2) the EAS radio or television stations. " The ANS consists of fixed sirens. Activation of the ANS sirens when directed by the civilauthorities will alert the public to turn on their radios or television to a local EAS station fordetailed information on the emergency situation.

• The EAS is a network of local radio and television stations prepared to transmit or relayemergency information and instructions from the civil authorities to the general public.This notification is directed and controlled by civil authorities, not VCSNS.Activation of the ANS will be initiated by VCSNS personnel upon direction by state or localauthorities as specified in existing agreements concerning activation of the system. Thesiren system is designed in such a fashion that it can be operationally segregated by countyboundary within the 10-mile emergency zone radius. The ANS signal will be a three-minute steady signal. Upon determination of the need for public notification, the ANS can beactivated within 15 minutes.

Upon failure of part or all of the system, the State of SC willdirect notification methods in accordance with their plan.Page 53 of 1-93220EP-1 00 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear StationThe locations of the sirens were determined by a comprehensive engineering study thataddressed population

density, geographical

features, siren output, and mounting heights ofsirens, to ensure coverage of the EPZ.To ensure the ANS is maintained in an operational readiness

posture, the local agencieshave agreed to a testing frequency for the system (by sounding the sirens) periodically thatmeets or exceeds FEMA guidance.

Reports of inoperable equipment are provided to EP-designated maintenance personnel. The goal of the testing and maintenance program is toidentify inoperable equipment in a timely manner and to restore equipment to a functional status commensurate with FEMA operability requirements as referenced in FEMA-REP-10, "Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants"Section E.6.2.1. In addition to this routine test and repair program, preventive maintenance of the ANS will be performed on an annual basis.7. Messages to the PublicThe state has developed EAS messages for the public consistent with the classification scheme. These draft messages are included as part of the South Carolina Operational Radiological Emergency Response Plan and contain instructions with regard to specificprotective actions to be taken by occupants and visitors of affected areas. Messages mayinclude instructions such as: take shelter and go indoors, close windows and doors, turn offventilation systems; directions given for evacuation; directions to stay tuned to specificstations for further information, ad hoc respiratory protection, (e.g., handkerchief overmouth, etc.). VCSNS will provide support for the content of these messages whenrequested. The state and/or the counties control the distribution of radio-protective drugs tothe general public.Page 54 of-4-93220 EP- 100 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear StationSection F: Emergency Communications This section describes the provisions used for prompt communications among principal EROs,communications with the ERO, and communications with the general public.1. Comm unicationslNotifications SCE&G has extensive and reliable communication systems installed at VCSNS. Examplesof the communications network include systems such as normal and dedicated telephone lines on landlines, fiber-optic voice channels, cell phones, satellite phones, mobile radiounits, portable radios, and computer peripherals. This network provides: " Voice communication through normal telephone, dedicated line, and automatic ring-down between selected facilities, conference call capability, speaker phones, and operatorassistance, where required. In addition, there are satellite phone and cell phonecapabilities to maintain communication links to the emergency response facilities andoffsite authorities. " Communications between emergency vehicles and appropriate fixed locations, as well aswith state mobile units and fixed locations

• Facsimile, computer

network, and modem transmission Figure F-1 depicts the initial notification paths and the organizational titles from the VCSNSEmergency Response Facilities (ERFs) to federal, state, and county EROs, and industrysupport agencies.

The primary and alternate methods of communication, and the NRCcommunications

network, are illustrated on Figures F-2 and F-3.a. VCSNS maintains the capability to make initial notifications to the designated offsiteagencies on a 24-hour-per-day basis. The offsite notification system, referred to as theElectric Switch System Exchange (ESSX), provides communications to state and countywarning points and EOCs from the Control Room, TSC, and the EOF. Backup methodsinclude facsimile, commercial telephone lines, radios, and internet.

State and countywarning points are continuously staffed.b-d. VCSNS has established several communication systems that ensure reliable and timelyexchange of information necessary to provide effective command and control over anyemergency response (1) between the station and state and county agencies within theEPZs, (2) with federal EROs, (3) between the station, the EOF, and the state and countyEOCs, and (4) between ERFs and Field Monitoring Teams. A general description of thesystems is as follows:1) Private Branch Exchange (PBX) Telephone System: The PBX telephone systemprovides communication capability between telephones located within the VCSNSfacilities through direct dialing. The PBX is used to connect the Control Room, TSC,OSC, and the EOF. The PBX telephone system also provides for outsidecommunications through interconnections with the corporate fiber optic telephone communications system and commercial telephone systems.Page 55 of 1-93220EP-1 00 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Station2) ESSX: The ESSX is a dedicated commercial communications system that hasbeen installed for the purpose of notifying state and county authorities of declaredemergencies at VCSNS. This system links together the VCSNS Control Room,EOF, TSC, and state and county authorities as appropriate.

3) Local Commercial Telephone System: This system provides standard commercial telephone service through the public infrastructure, consisting of central offices andthe wire line carrier.

The commercial telephone system includes connections toPBX, emergency telephone system, dedicated lines to emergency facilities, andlines to the JIC. The commercial vendor provides primary and secondary power fortheir lines at their central office.4) ERDS: As prescribed by 10 CFR 50 Appendix E.VI, ERDS will supply the NRC withselected plant data points on a near real time basis. ERDS is activated by the EROas soon as possible but not later than one hour after declaration of an Alert, SiteArea Emergency, or General Emergency. The selected data points are transmitted via modem or a Virtual Private Network (VPN) to the NRC at approximately 1-minute intervals. The ERO has backup methods available to provide requiredinformation to the NRC in the event that ERDS is inoperable during the declaredemergency.

5) Field Monitoring Team Communications:

A separate radio communications channelhas been installed to allow coordinated environmental monitoring and assessment during an emergency. This system consists of the necessary hardware to allowradio communication between the Control Room, EOF, and mobile units in VCSNSvehicles. Commercial cell phones, satellite phones, or other means are available asbackup to the primary field team communications system.6) Satellite Telephones: Satellite telephones are provided to the Control Room, theTSC, and the EOF providing a backup communication link in the event that thelandlines are rendered inoperative. These units are equipped with outside antennaeto permit the use of the communications device inside the facilities.

7) 800 MHz Radio: This radio system is an 800 MHz SCANA Corporation system thatis divided into trunks which are used by corporation subsidiaries.

The trunk systemat VCSNS is comprised of channels for Maintenance, Operations, Health Physics,Field Monitoring Teams, etc to allow a means of communications between facilitypersonnel and field personnel for routine work and emergency conditions. Thesystem utilizes both base stations and remote units in conjunction with associated

cabling, repeaters, and antennas to provide optimum coverage for two-waycontinuous transmission.

8) SCE&G Fiber Optic System: The fiber optic system connects South CarolinaElectric and Gas Company's main office in Cayce, South Carolina with the SummerComplex which includes V.C. Summer Nuclear Station, Fairfield Pump StorageUnit, Parr Steam and Hydro Unit and the New Nuclear Deployment Building.

Summer Station is the hub for this system. The system contains 72 fiber opticchannels. Page 56 of 4-9Q220EP-100 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Station-- A .R..U) Main & Fuel Handlina Page System (Ga tron Gs!: This 6Y6tem of Retwekod ohenostations and speakers stat.gically loaedG the statioA R Eh phonestatin con.tains a telephone type roeiver transmitter

handset, and chaFnnelseco aswitches.

The sytem is equipped 44ith an. alarm enrodehr for aledtingpersonnel through a songs of designated tonees. The Fuo HAn 4 dling Page Systemis Lin 5OR the Main Page System is on;ly availRAbl in A resWith Me' handling9) In addition, station communication links exist to ensure appropriate information transfer capabilities during an emergency. The station may also use its videoconferencing

systems, computer network connections, wireless telephones, orstation radios to augment its emergency communications.

10) ReduNdant Paging System: This independent system of Ret,,ked phone stations, and speakcrs stratcgically located-in a-reas of the station inyolyed in the proessF ofEng.ner..d Safety Features hutdo.n.

The system contains its own phonestatiens, power supplies, line balance equ..ipent, and cable system. The system isdistinguished by its Fed color.e. ) MaeNtenanca Jack System: TVhS uAIetcanc Cuomau niatien system a onsists ef angtAot::erk of stra-tegically located jackrstations.. E~achjack station has fourseparatel wired recoptac-los mounted on it, providing fou nepnet omniainchannelsI9. SeverMal

headsets, each consisting of a padded earphon~e type recivean~d -a boom. mounted-no-ise canceling m~icrophone are proVided for ha;nds froceperation of the system. Each headset is equipped with a belt clop amplifer and 30P eufre sable.12) In addition, station cOMMu-nic-atienA links exist to ensure appropriateinrmtn tranSfor capabilitics during an emnergency.

The station may alsoue -s -ideGenfc~Rcncig

systems, computcr netwe* onnections, wireless telephoese, orstaton rad-ios to augmenAt its emerencRy coFmmunicAatos.

e. ERO Notification System: VCSNS uses an automated ERO Notification System thatemploys an automatic telephone system to rapidly notify members of the ERO.Procedures specify the course of action to be taken if the ERO Notification System fails.f. NRC Communications (ENS and HPN): Communications with the NRC Operations Center will be performed via the NRC ENS and the HPN circuits or commercial andsatellite telephone lines. Information is normally communicated to the NRC inaccordance with NL-122, Regulatory Notification and Reporting, before establishing anopen ENS and/or HPN line.Installation and use of these NRC telephones is under the direction of the NRC (seeFigure F-3).Emer-gency Notification System: Dedicated telephone equipment is in place between thee -- Formatted:

Indent: Left: 0.5"Control Room and the NRC, with an extension of that line in the TSC. A separate line isavailable in the EOF with the capability of being patched with the station through theNRC. This line is used for NRC event notifications and status updates. Backup power isprovided for these lines.Page 57 of 4-93220 EP-100 Rev QxxI Part 2: Planning Standards and CriteriaV. C. Summer Nuclear StationHPN: There also exists a separate dedicated telephone between the NRC,-the-TS9, and Ithe EOF for conveying health physics information to the NRC as requested or as anopen communication line. Backup power is provided for these lines.2. Medical Communications Communications are established with the primary medical hospitals and transportation services via commercial telephone that is accessed by VCSNS personnel.

3. Communications TestingCommunications equipment is checked in accordance with Section N.2. Communication drills between VCSNS and state and county government facilities are conducted inaccordance with Section N.2.a.ANS siren testing is performed as follows:S ile nt T e st ....................................................................................................

A t le a st b iw e e klyGrowl (or Equipment) Test ........................... Quarterly and following preventive maintenance F u ll V o lum e T e st ....................................................................................................... A n n u a llyPage 58 of 4-93220EP-100 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear StationPage 59 of 4-91220EP- 100 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Station4. Plant AlarmsIn conjunction with the Main Plant Page Systomplant paging systems, the site has audible(pulse, wale, w..bl,, steady, etc.) alarms used to alert site personnel to an unsafe oremergency conditions. The alarms include a Reactor Building/Containment VesselEvacuation Alarm, Radiation Emergency/Site Evacuation Alarm, and Fire Alarm. Activation of these alarms is done from the Control Rooms.Page 60 of 4-"220EP-1 00 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear StationFigure F-1: Notification Scheme (After Full Augmentation) Page 61 of 220EP-100 Rev Oxx Part 2: Plannina Standards and CriteriaV. C. Summer Nuclear StationPart 2: Planning Standards and Criteria V. C. Summer Nuclear StationRoom ---OSCFTSC --- --------- EOF ,-EJICI--Dedicated Phone Link (Independent or Limited PBX)* ---Station Telephone Line (PBX or Commercial) A = Dedicated phone link to dispatch OSC teams between the OSC, TSC, and Control Room.B = Dedicated phone link for use by the ECO or OEM, ED, and Shift Supervisor between theControl Room, the TSC, and the EOF.C = Dedicated phone link for transmission of technical data between the TSC, Control Room,and the EOF.D = Dedicated phone link to discuss mitigating activities and priorities between the TSC andEOF.E = Dedicated phone link to discuss changes in station or affected plant conditions and EPIOneeds between the EOF and the JIC.F = Station telephone line that is a communication link between activated facilities. Figure F-2: ERF Communications MatrixPage 62 of 4-Q2,220EP-100 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear StationFigure F-3: NRC Communications for Nuclear ResponsePage 63 of 4-9-220EP-100 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear StationSection G: Public Education and Information This section describes the VCSNS public education and information program. It outlines themethods for distributing public information materials on an annual basis and describes how thepublic is informed in the event of an emergency.

1. Public Information Publication The state of South Carolina has overall responsibility for maintaining a continuing disasterpreparedness public education program.

The EPIO publication for the VCSNS is updatedannually, in coordination with state and county agencies, to address how the general publicis notified and what their actions should be in an emergency. SCE&G distributes thepublication annually to all residents within the 10-mile plume exposure EPZ and toappropriate locations where a transient population may obtain a copy. The publicinformation publication includes the following information:

a. Educational information on radiation

b. Information regarding who to contact for additional information

c. A description of possible protective measures for the public (take shelter,

evacuate, and/or ingest a radioprotective drug).d. A map of major evacuation routese. A list of reception centers to coordinate sheltering of evacuees and instructions on howto obtain additional information, especially for the disabled or their caretakers and thosewithout transportation

2. Public Education Materials Public information publications instruct the public to go indoors and turn on their radios ortelevisions when they hear the ANS sirens operating.

These publications also identify thelocal radio and television stations to which the public should tune in for information related tothe emergency. Information is also provided to the transient population by means of signs atlocal business establishments and at the entrances to recreational areas around the VCSNSwith instructions to be followed in the event of an emergency at VCSNS. A list of radio andtelevision stations that will transmit emergency information is provided on the signs.Telephone numbers where additional information can be obtained are also provided. Page 64 of 4-93220EP-1 00 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Station3. Media Accommodations

a. The SCANA Public Affairs Group is notified when an Unusual Event or higheremergency condition exists. They will handle public and media inquires in the earlystages of the event (until the JIC is activated) by distributing background information, news releases, and providing information to SCANA management.

1) The EPI Oroanization:

The EPIO is part of the ERO. It may be activated at any timeat the discretion of VCSNS management

However, when there is a procedural requirement to activate the EOF, the EPIO shall also be activated.

The primary purpose of the EPIO is to disseminate information from VCSNS's EROabout the emergency events to the public, via the news media. However, theauthority for issuance of news releases for the classification of an Unusual Event orbefore to ERO activation will always reside with the SCANA Public Affairs Group.Upon activation, the EPIO has the responsibility and authority for issuance of newsreleases to the public after the information gains the approval of the fGiQCompany Spokesperson. The EPIO is comprised of senior managers from SCANA who will function asspokespersons, and other individuals including personnel from VCSNS and theSCANA Govemmental Affairs and Human Resources areas. SCANA'sspokespersons disseminate information to the news media/public conceming theemergency events out of the JIC.2) The Joint Information Center: The JIC is the facility in which media personnel gather to receive information related to the emergency event. The JIC is thelocation where approved news releases will be provided to the media fordissemination to the public. News releases are coordinated between the EOF andJIC personnel and state and/or federal representatives in the JIC. Publicinformation personnel operate designated portions of the EOF or from EQf,-aa-the JIC, which is under the direction of the ECO/Company Spokesperson and functions as the single point of contact to interface with federal, state, and local authorities who are responsible for disseminating information to the public.VCSNS has a designated JIC co-located with the EOF. The JIC is equipped withappropriate

seating, lighting, and visual aids to allow for public announcements andbriefings to be given to the news media. Additionally, the JIC is equipped withcommercial telephone lines for making outgoing calls. The EPIO functions from theJIC and EOF in preparing and releasing VCSNS information regarding theemergency event. The JIC is activated at the discretion of the Emergency ControlOfficer in the EOF. Functions of the JIC include:* Serving as the primary location for accumulating accurate and currentinformation regarding the emergency conditions and writing news releases* Providing work space and phones for public information personnel from the state,counties, NRC, FEMA, and industry-related organizations

• Providing responses to media inquiries through Media Monitoring Stafftelephones that the media can call for information about an emergency Page 65 of -93220EP- 100 Rev 0xx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Stationb. The news media is not permitted into the EOF during an emergency

4. Coordination of Public Information

a. The JIC is staffed by SCANA, VCSNS, and federal, state, and county government publicinformation representatives who will be the source of public information during anemergency at the station.

The ECO (Company Spokesperson) is the primaryspokesperson for SCANA. The ECO (Company Spokesperson) has direct access to allnecessary information (see Section B.5). All information will be coordinated beforeconducting news briefings.

b. Rumors or misinformation are identified during an emergency by the Media Monitors andRumor Control Monitors.

They respond to telephone calls from the public and the media,and monitor media reports.5. Media Orientation Emergency Preparedness, in conjunction with SCANA Public Affairs Group, offers programs(at least annually) to acquaint news media with the Emergency Plan, information concerning radiation, and points of contact for release of public information in an emergency. Page 66 of 1-93220EP-IO00 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear StationSection H: Emergency Facilities and Equipment Onsite and offsite facilities are available for emergency assessment, communications, first aidand medical care, and damage control. Of particular importance are the ERFs: the ControlRoom, TSC, OSCs, a4d-EOF, and JIC.This section describes the emergency facilities and equipment used by the ERO and outlinesthe requirements that aid in timely and accurate response actions. It also describes thesurveillance programs used to monitor and ensure that these facilities and equipment aremaintained in a high degree of constant readiness.

1. Control Rooms, Technical Support Center, and Operational Support CentersVCSNS has established a TSC that is activated upon declaration of an Alert or higherclassification.

VCSNS has also established an-three OSCs, one in each of the Units. TheOSC in the affected Unit will be activated. Until they become operational, required functions of these facilities are performed by shift personnel and directed from the affected/lead Unit'sControl Room. These facilities may be activated at the discretion of the lED at an UnusualEvent classification.

a. Control Room: There is a Control Room for each of the Units on the site. The VCSNSreactor and major plant systems are operated from the GCntrol R emthese locations.

Each Control Room is equipped with instrumentation to supply detailed information onthe reactor and its major systems. Each Control Room is continuously staffed withqualified licensed operators. The Control Room is the first onsite facility to becomeinvolved with the response to emergency events. The lead Control Room will be thedesignated location for the lED. The lead Control Room will be designated as follows: ifthe event is a site wide event or only affects the Unit 1 Protected Area, then the Unit 1Control Room is the lead, if the event affects the Units 2 & 3 Protected Area only, thenthe Unit 2 Control Room is the lead. If the event only affects a single Unit, then thatUnit's Control Room is the lead. Control Room personnel must evaluate and effectcontrol over the emergency and initiate activities necessary for coping with theemergency until such time that augmented emergency response facilities can beactivated. These activities shall include:" Reactor and plant control" Initial direction of all plant related operations " Accident recognition, classification, mitigation, and initial corrective actions" Alerting of onsite personnel

• Activation of the ERO notification system" Activation of the ERFs" Notification of offsite agencies* Activation of ERDSPage 67 of 4-93220EP-100 Rev 0xx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Station" Continuous evaluation of the magnitude and potential consequences of an incident" Initial dose projections

" Recommendations for immediate protective actions for the publicAs other ERFs become activated, they will provide support to the Control Room. Overallcommand and control of the emergency will transfer to the EOF when it is properly staffedand ready to take over these responsibilities. Throughout all emergencies, the ControlRoom maintains its emergency activation status until its normal operational status may beresumed or its recovery activities are initiated.

b. Technical Support Center: VCSNS has established a TSC for use during emergency situations by station management, technical, and engineering support personnel.

Thisfacility is located outside the Protected Area southwest of Unit 1 and northeast of Units 2& 3. This location provides the ability to respond and activate the facility in a timelyfashion, independent of which Unit is affected. It also will permit the use of the TSC in asecurity event that may curtail the entry of ERO personnel into the affected Protected Area(s). The TSC directly meets most of the requirements of NUREG 0696, "Functional Criteria for Emergency Response Facilities". It does not lend itself to face to facecommunications with the Control Room. The TSC is provided with communications linksthat can transmit and receive direct voice and data communications from any of theaffected Control Rooms. These communications have alternate pathways that can alsobe used as needed. Security personnel are positioned in the TSC to enhance themovement of personnel between the TSC and the Control Room, as necessary. TheTSC is activated for all emergencies classified as Alert or higher. Activation of thisfacility for other events is optional. When activated, the TSC functions include:" Support for the Control Room's emergency response efforts* Continued evaluation of event and classification of emergencies

• Assessment of the plant status and potential offsite impact* Coordination of emergency response actions within the Protected Areas* Communication with the NRC via ENS* Activation of the ERDS or ensuring that it is activated The TSC is the onsite location used to support the Control Rooms for assessment ofplant statuses and potential offsite impact, and for implementation of emergency actions.The TSC provides technical data and information to the EOF.Figure B-lb illustrates the staffing and organization of the TSC.The TSC provides reliable voice communications to the Control Rooms, OSCs, EOF,and NRC. In addition, it provides facsimile transmissions capability and electronic transfer capabilities (see Section F).Page 68 of 1-"220EP-1 00 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear StationThe TSC is sized to accommodate a minimum of 2-0-forty (40) personnel and theirsupporting equipment.

This includes provisions for NRC representatives. The TSC isalso sized and configured to accommodate a Back-up Operational Support Center(OSC).The Back-up OSC includes a designated command area and work areas for OSCpersonnel. Personnel will have access to plant data and network computer

systems, aswell as communications

systems, such as telephone and radio systems.Personnel in the TSC shall be protected from radiological

hazards, including directradiation and airborne contaminants under accident conditions with similar radiological habitability as Control Room personnel.

To ensure adequate radiological protection, periodic radiation surveys of the TSC are conducted or portable radiation monitors maybe used. These systems indicate radiation dose rates and airborne radioactivity insidethe TSC while in use. In addition, KI is available for use as required. In the event that theTSC becomes uninhabitable, implementing procedures will provide guidance on thetransfer of duties and relocation of the staff until such time that the TSC staff is able tofulfill their duties as assigned. The TSC has access to a complete set of as-built drawings and other records, including general arrangement

diagrams, piping and instrument diagrams (P&IDs),

and theelectrical schematics. The TSC has the capability to record and display vital plant data,in real time, to be used by knowledgeable individuals responsible for engineering andmanagement support of reactor operations, and for implementation of emergency procedures. The Back-up TSC is the area immediately adjacent to the lead Unit's Control Room anda Remote TSC is included in the Emergency Operations Facility Building. The Remote TSC is designed to allow evaluators and decision makers access to plantdata and network computer systems to support event evaluations, development ofmitigation strategies, and determination of emergency classifications. The facility alsohas access to communications

systems, such as telephone (land based and satellite) systems and radio systems with direct links to the onsite personnel.

Using thesesystems, communications may be established with Security, the Units' Control Rooms,the EOF, and OSC(s). The building provides work space for engineering personnel withaccess to plant drawings, system information, and plant procedures. A limited numberof hard copies of procedures are provided for reference or as back-up to networksystems.c. Operational Support Centers: The OSCs are the locations tr-where the 4Unit's supportpersonnel report during an emergency and from which they will be dispatched forassignments or duties in support of emergency operations. The affected Unit's OSCshall be activated whenever the TSC is activated, but need not remain activated at theAlert level if its use is judged unnecessary by the ED. At the Site Area Emergency andGeneral Emergency levels, the unit's OSC or an altemate OSC shall be activated at alltimes. Activation for other events is optional. VCSNS disciplines reporting to the OSCsinclude, but are not limited to:a Operating personnel not assigned to the Control RoomPage 69 of 4--220EP-IO 0 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Station* Health Physics personnel

• Chemistry personnel
• Maintenance personnel (Mechanical, Electrical, and I&C)Figure B-lb illustrates the staffing and organization for the OSCTrhe-Each OSC is equipped with communication links to the Control Rooms and the TSC(see Section F). A limited inventory of supplies will be kept in the OSCs or accessible tothe OSCs. This inventory will include respirators, protective

clothing, flashlights, andportable survey instruments.

Refer to the Unit Annexes for additional information regarding the OSCs.A Back-up (Remete)-OSC is included in the configuration and sizing of the Technical Support Center and a Remote OSC is included in the Joint Information Center Building, which also houses the EOF. The Back-up OSC includes a designated command area,work areas for OSC groups, and staging areas (break room/kitchen) for OSC DamageControl personnel. The Remote OSC is designed to allow evaluators and decision makers access to plantdata and network computer systems to support event evaluations and development ofmitigation strategies and mission while planning for return to the site. The facility alsohas access to communications

systems, such as telephone (land based and satellite) systems and radio systems with direct links to the onsite personnel.

Using thesesystems, communications may be established with the Units' Control Rooms, the EOF,and TSC. The building provides work space for staging damage control teams and hasaccess to plant drawings, system information, and plant procedures. A limited numberof hard copies of procedures are provided for reference or as back-up to networksystems.2. Emergency Operations FacilityThe EOF is the location where the ECO will direct a staff in evaluating and coordinating theoverall company activities involved with an emergency. Activation of the EOF is mandatory upon declaration of a Site Aro EmergFencAlert or higher classification. The EOF is locatedin Richland County near the intersection of Bickley Road and SC Hwy 176 and is outside the10 Mile Emergency Planning Zone and greater than 10 miles from the Technical SupportCenter (TSC). The EOF provides for:* Management of overall emergency response* Performance of the non-delegable emergency notification and PAR development andnotification functions when in command and control* Notification of appropriate corporate and station management

• Coordination of offsite radiological and environmental assessments
• Determination of recommended public protective actions" Management of recovery operations from an Alert or higher classification
• Coordination of emergency response activities with federal, state, and county agenciesPage 70 of 220EP-100 Rev 0xx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear StationThe EOF was designed with the following considerations:
• The EOF is provided with access limiting devices when not in use and assigned securitypersonnel during activation to ensure that only authorized personnel are permitted to enterthe facility.
• The location provides optimum functional and availability characteristics for carrying outoverall strategic direction of VCSNS emergency and support operations, determination ofpublic protective actions to be recommended to offsite officials, and coordination withfederal, state, and county agencies.
• It is of sufficient size to accommodate about 50 people including NRC representatives.

" It meets the criteria of NUREG-0696, 'Functional Criteria for Emergency ResponseFacilities" regarding

location, structure, habitability, size, communications, instrumentation, data system equipment, power supplies, technical data, records availability, andmanagement.

The EOF power is backed with an emergency diesel generator and has anuninterruptable power source to maintain loads during the transfer between powersources." It is equipped with reliable voice communications capabilities to the TSC, the ControlRooms, the NRC, and the state and county EOCs. In addition, the EOF has facsimile, computer transmission, and electronic transfer capabilities. " Equipment is provided to gather, store, and display data needed in the EOF to analyzeand exchange information on plant conditions with the station. The EOF technical datasystem receives, stores, processes, and displays information sufficient to performassessments of the actual and potential onsite and offsite environmental consequences ofan emergency condition. " The EOF has ready access (either through hard copies or electronic media) to plantrecords, procedures, and emergency plans needed for effective overall management ofVCSNS emergency response resources.

• It is designed to support a fRemote TSC (RTSC) and fRemote OSC (ROSC) in the eventof an emergency which limits access to the site.Page 71 of 441220EP-1 00 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Station3. Joint Information CenterThe JIC is the location where the Company Spokesperson will direct a staff in providing andcoordinating the release of information during an emergency.

The JIC is co-located with theEOF outside the 10-mile EPZ. The JIC provides facilities and equipment for VCSNS, federal,state, and county agencies to interface with each other and to provide a location whereinformation regarding the event is released to the media and general public.4. Emergency Operations CentersEOCs operated by the state and county communities have been established to performdirection and control of emergency response functions, as outlined in their respective plans.The respective state EOC is capable of continuous (24-hour) operations for a protracted period. These centers contain sufficient communications (radio, telephone, and facsimile) equipment, maps, emergency plans, and status boards to provide the necessary interfaces with other federal, state, county, and station emergency facilities. The county EOCs serve as command and control headquarters for local emergency response activities as well as a center for the coordination of communications to field unitsand to the state EOC. These EOCs have the equipment necessary, (such as facsimile

machines, telecommunications equipment, radios, photocopiers, wall maps, etc.) to carryout their emergency responsibilities.

Page 72 of 4-9-220EP-100 Rev Oxx Part 2: Planning Standards and Criteria V. C. Summer Nuclear Station5. Activation NOTE: NUREG-0654 Criterion II.B.5 states that the "licensee must be able to augment on-shift capabilities within a short period after declaration of an emergency." It furtherreferences that short period as 30 and 60 minutes. VCSNS will adequately staff its on-shiftpersonnel to support the Control Room personnel upon declaration of an Alert or higherclassification. This staffing will fulfill the NUREG-0654 Criterion II.B.5 for 30-minute responders and provides additional support to the Onshift ERO within a 75 minute responsefor on-call ERO personnel. The time frames for rapid augmentation of a nuclear power plantstaff in the event of an emergency are not regulatory requirements but rather administrative times set by VCSNS. It is VCSNS's intent to expend its best efforts to meet theaugmentation criteria times regarding staffing Emergency Response Facilities withsufficiently skilled individuals capable of handling an emergency. Due to diversity of normalresidential patterns for the stations' staff, possible adverse weather conditions, and roadcongestion, these time frames might be exceeded. VCSNS has put into place plans and procedures to ensure timely activation of its ERFs. TheShift Supervisor (as lED) will initiate a call-out in accordance with the emergency planningprocedures. The ERO augmentation process identifies individuals who are capable offulfilling the specific response functions that are listed in Table B-la. This table wasdeveloped based on the functions listed in NUREG-0654, Table B-1.Although the response time will vary due to factors such as weather and traffic conditions, atime of 75 minutes for minimum staffing, has been established for the ERO personnel responding to the station emergency facilities, following the declaration of an Alert or higheremergency classification. Additionally, plans have been developed to ensure timelyfunctional activation and staffing of the JIC when the classification of Alert or higherclassification is declared. It is the intention of the organization to be capable of activating the applicable ERFs within15 minutes of achieving minimum staffing. The facility can be declared activated when thefollowing conditions are met:NOTE: NU-RE-G-0654 C-riterFionA lI.BR.5 states that the "lien-see muct ho able to augmentohitcpbilities wti a short period afterF decalaration of an emergencY." It furtFherF deAfinethat short poriod as 30 and- 60 minutes. VCSNSS will adequately staff its. on shift personnel tsuipport the Control Room personnel upon declaration of an Alort Or higher classification. T-his- safUfing W"il fulfill the NU-RE-G-0-651i C-riter~io-n Il.R-.5 fo-r 30 Minute responders and-provides additional support to the Ons~hift ERG to perm~it A 60 m4inut Fresponse for on callERG pe99rsonn1. The tiMe frames6 for rapidG au1gmentation Of a nuclear power plant Mtaf in heVent of an emnergency arc not rigid inviolate requirements but rather goals. it is VCSNS's-intAnt to ex(pend its beSt efforts to moot* the augmentation critoria goals regarding staffingEmFergency Rer.ponse Facilities-w~ith suffIc~iently skilled individuals capable of handlinig anemergancy. Both the NRC and- VCS2NS realite that due toa diversity of normal residential1 patterns fo6httos taff, possible adverse w~eather con-d-itions; and read congestion, those timfe frames mnight be eXceeded. CSShas, put into place plans and prese;Adu'Ares to ensur1-e timely actiVation Of its E-Rr~r. ThShift Supervisor (as ElED) w.Aill initiate a c-all ou-t- in acorane ith- the em~ergency plannnprocedures. The ERO augmentation processietfesidvdas who are capableoPage 73 of 494220EP-100 Rev Oxx Part 2: Planning Standards and Criteria V. C. Summer Nuclear Stationfullfi~llin the GPocific response func~tions that are- listed in Tables BR la. This table wasdevelopod b;Ased on the fnctons listed inR NUREG 0654, Table B 1.Although the response time will Yar3' duo to- factors 91uch as weAatherF an4d traffic: conditions, agoal of about 6-0 mninutes-for minimumn

staffing, has boon established forF the ERG perSOnneresponding to the station onsite mernegcncy fac*iities, following the declaration of an; Ale ohigher emergencY classification, and to the EF=F following the notification Of a Site AreaE=mBergenY or higher emergency classifiation,.

Additionally, planrs have bendvlpdto ensre ti W:cly functional activation and staffing of the JIG when the class~flatien of Site AreaEmnergency is. dec~arad. it is the goal of the organiziation-to -be capable of activating the applic-able ERF w.ithin 15a. Minimum staffing has been achievedb. Personnel have been briefed on the situation

c. The facility is functionally capable of performing the appropriate activityThe senior manager in charge may elect to activate their facility without meeting minimumstaffing if it has been determined that sufficient personnel are available to fully respond tothe specific event (this would not constitute a successful minimum staff response).

Although the minimum staffing criteria applies to the J.G, theThe 6075- minute responsetime and 15-minute activation times are not applicable to the JIC. Public Information personnel must first coordinate the decision to activate the JIC with the appropriate offsiteauthorities responding to the facility. Page 74 of 4--220EP-IO00 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Station6. Monitoring Equipment OnslteThe station is equipped with instrumentation for seismic monitoring, radiation monitoring, fireprotection, and meteorological monitoring. Instrumentation for the detection or analysis ofemergency conditions is maintained in accordance with station Technical Specifications, ifapplicable or commitments made to the NRC. The actual instrumentation will not bedescribed in detail in this plan. Additional

details, if required, of the equipment will appear intheiitIach Unit's Annex. This equipment

includes, but is not limited to, the following:

a. Geophysical Monitors1) Meteorological Instrumentation:

There are two permanent meteorological monitoring stations located near the station for display and recording of windspeed, wind direction, and ambient and differential temperature for use in makingoffsite dose projections. Meteorological information is presented in the ControlRoom, TSC, and EOF by means of the plant computer system. This information isremotely interrogated using a computer or other data access terminal. With regard to VCSNS's meteorological monitoring

program, since themeteorological facilities are not composed of structures,

systems, and components that prevent or mitigate the consequences of postulated accidents and are not"safety-related,"

those aspects of quality assurance germane to providing goodmeteorological information for a nuclear power station were adopted into the QualityAssurance Program Description (QAPD).The National Weather Service (NWS), or regional weather forecast providers, maybe contacted during severe weather periods. These providers analyze national andlocal weather in order to provide localized weather forecasts for the VCSNS area, asappropriate.

2) Seismic Monitoring:

The VGSNS-seismic monitoring system measures and recordsthe acceleration (earthquake ground motion) of the structure. Earthquakes producelow frequency accelerations which, when detected by the remote sensing devices,are permanently recorded as information which defines the response spectrum. The system remains in a standby condition until an earthquake causes the remoteunit(s) to activate the recording circuits and tape transports. It also provides signalsfor immediate remote indication that specific preset response accelerations havebeen exceeded.

3) Hvdrological Monitors:

The design basis flood, probable maximum precipitation, and other improbable, conceivable extremes in hydrologic natural phenomena arewell below any design limits for the units as detailed in their FSARs. Hence, thereare no specific, dedicated hydrological monitors. Page 75 of 493220EP- 100 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Stationb. Radiological Monitors and Sampling1) The RMS: In-plant radiological measurements provide information that may helpdetermine the nature, extent, and source of emergency conditions. The RMS isavailable to give early warning of a possible emergency and provides for acontinuing evaluation of the situation in the Control Room. Radiation monitoring instruments are located at selected areas within the facility to detect, measure, andrecord radiation levels. In the event the radiation level should increase above apreset level, an alarm is initiated in the Control Room. Certain radiation monitoring instruments also alarm locally in selected areas of the facility. The RMS is dividedinto 3 subsystems: a) Area Radiation Monitors are used for the direct measurement of in-plantexposure rates. The area radiation monitor readings allow in-plant exposurerate determinations to be made remotely without requiring local hand-held meter surveys. This information may be used, initially, to aid in thedetermination of plant area accessibility. In addition to permanent

monitors, portable continuous air monitors measure airborne particulate and airborneiodine activities at various locations within the operating areas.b) Process radiation monitors are used for the measurement of radioactive noble gas, iodine, and particulate concentrations in plant effluent and othergaseous and fluid streams.c) The accident, or high range, RMS monitors radiation levels at variouslocations within the operating area. These are high range instruments used totrack radiation levels under accident or post-accident conditions.

Theseinstruments include the containment monitors. The RMS provides the necessary activity or radiation levels required fordetermining source terms in dose projection procedures. Key RMS data islinked to the plant computer, which allows information to be passed to the TSCand EOF. The isotopic mix, including isotopes such as those in Table 3 ofNUREG-0654, is based upon a default accident mix Refer to the unit-specific FSAR for further detail on the RMS capabilities and design.2) Liauid and Gaseous Sampling Systems: The process sampling system consists ofthe normal sampling system and additional sampling panels located throughout theplant Sampling systems are installed or can be modified to permit reactor coolantand containment atmosphere sampling even under severe accident conditions. The sampling systems use a number of manual sampling techniques to enablereactor coolant and containment sampling operations over a wide range of plantconditions. They are capable of providing information relative to post-accident plantconditions to allow operator actions to be taken to mitigate and control the course ofan accident. Refer to the respective Units FSAR for further detail on samplingcapabilities.

3) Portable Radiation Monitoring Eauipment:

Portable radiation survey instruments are available for a wide variety uses such as area, sample, and personnel surveysPage 76 of 493220EP- 100 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Stationand continued accident assessment. Instruments are stored throughout the plantand in the emergency facilities.

c. Process Monitors:

The Control Room and applicable redundant backup locations areequipped with extensive plant process monitors for use in both normal and emergency conditions. These indications include but are not limited to reactor coolant systempressure and temperature, containment pressure and temperature, liquid levels, flowrates, status or lineup of equipment components. This instrumentation provides the basisfor initiation of corrective actions.1) Plant Monitorina/Information System: A plant monitoring/information systemprovides the data acquisition and database capability for performing plantmonitoring and functions. The system is designed to scan, convert to engineering units, conduct reasonability and alarm limit checks, apply required transformations, store for recall and analysis, and display the reading of transformed data from plantinstrumentation. The system scans flows, pressures, temperatures, fluid levels,radiation levels, equipment, and valve status at required frequencies. Scannedvariables are quality tagged. The system provides for short and midterm storage ofdata for online retrieval and fast recall, and long-term storage to appropriate media.2) Safety Parameter Display System (SPDS): SPDS provides a reliable display ofplant parameters from which the safety status of operation may be assessed in theControl Room, TSC, and EOF for the station. The primary function of the SPDS isto help operating personnel in the Control Room make quick assessments of plantsafety status. SPDS and/or other display systems in the TSC and EOF promote theexchange of information between these facilities and the Control Room and assiststhe emergency organization in the decision making process. It also provides datatrending information regarding current and past status of the affected Unit(s).d. Fire Detection System: The fire detection system is designed to quickly detect visible orinvisible smoke (or other products of combustion) and/or heat in designated areas of theplant. The fire alarm communication systems and subsystems are located at strategic points throughout the plant to wam personnel of a nuclear incident or other emergency conditions. Existing plant alarm systems are sufficiently audible to alert personnel in theevent of a fire or need for assembly. These alarm communication systems consist ofwarning sirens and lights (in high noise areas) and the PA system. Refer to therespective Unit's FSAR for further description of the unit's fire protection system.7. Monitoring Equipment OffaiteVCSNS has made provisions to acquire data from and have access to the following offsitesources of monitoring and analysis equipment:

a. Geoohvsical Monitors:

In the event that both onsite meteorological towers or monitoring instrumentation becomes inoperative, meteorological data may be obtained directly fromthe NWS or the intemet.A South Carolina State Network (SCSN) seismometer is located about 3.2 miles east-southeast of the VCSNS Unit 1. This seismometer near Jenkinsville has beenoperational since November 1973, and is monitored by the University of South Carolina. Page 77 of 49-0220EP-100 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear StationThe SCSN seismometer provides background information relative to seismic activity inthe area, including confirmation of earthquake occurrences and magnitudes. In addition, a central point of contact is the National Earthquake Information Service inGolden, Colorado to obtain information about a seismic event.The EOF will coordinate hydrology and seismology expertise in the event onsiteinformation becomes unavailable.

b. Radioloaical Environmental Monitors and Samplina:

The state of South Carolina DHECwill conduct an extensive offsite environmental monitoring program to provide data onmeasurable levels of radiation and radioactive materials in the environs. VCSNS also maintains an offsite environmental monitoring program as well. Theprogram is described fully in the Offsite Dose Calculation Manual and includes:

• Fixed continuous air samplers" Routine sampling of river water, milk, and fish" A fixed thermo-luminescent dosimeter (TLD) monitoring networkThe TLD program consists of the following elements:
• A near-site ring of dosimeters covering the 16 meteorological sectors* A 16-sector ring of dosimeters placed in a zone within about 5 miles from the plant" TLDs placed at each of the normal fixed air sampler locations (typically about 8-15 airsamplers)

c. Laboratory Facilities:

External facilities for counting and analyzing samples can beprovided by the other nuclear stations in the area. These laboratories can act as backupfacilities in the event that the station's counting room(s) and laboratory become unusableor the offsite radiological monitoring and environmental sampling operation exceeds thecapacity of the station capabilities during an emergency. It is estimated that theselaboratories will be able to respond within several hours from initial notification. Outside analytical assistance may be requested from state and federal agencies, orthrough contracted vendors. The state maintains a radiological laboratory that providesindependent analysis. The DOE, through the Interagency Radiological Assistance Program has access to any national laboratory with DOE contract (i.e., Savannah RiverSite, Brookhaven, Oak Ridge, Lawrence Livermore, etc.).A general description of the laboratory capabilities is provided in Section C.3.8. Offslte Monitoring Equipment StorageVCSNS maintains a sufficient supply of emergency equipment (such as portable survey,counting, and air sampling instrumentation and other radiological monitoring equipment andsupplies) that may be used for environmental monitoring. These supplies meet the initialrequirements of two environmental Field Monitoring Teams. During subsequent phases ofPage 78 of 4-9a220EP-100 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Stationan emergency, additional equipment is available from other utility or state Field Monitoring Teams, INPO mutual aid, and offsite response organizations.

9. Meteorological Monitoring The station has installed and maintains two meteorological towers equipped withinstrumentation for continuous reading of the wind speed, wind direction, air temperature, and vertical temperature difference (AT). Additional capabilities are available to obtainrepresentative current meteorological information from other sources, such as the NWS. Afull description of the onsite meteorological capabilities is given in Section 4 of the Unit4Annexes.10. OSC Capabilities T+he-Each OSC provides an area for coordinating and planning of OSC activities and thestaging of personnel.

Additional space is available in adjacent offices and locker rooms toaccommodate additional personnel as may be required. Alternate locations are available. The onsite storerooms maintain a supply of parts and equipment for normal plantmaintenance. These parts, supplies, and equipment are available for damage control use asnecessary. Sufficient radiation protection equipment (i.e., protective

clothing, respiratory protection gear, KI, and other health physics equipment and supplies) is stored and maintained nearthe OSC (as well as the other ERFs). Damage GControl tTeam equipment is available in themaintenance shops which are near the OSCs. This equipment may include items such as acamera, portable

lighting, and additional portable communications equipment.

The areasnear the OSC are stocked with an assortment of first aid and medical treatment equipment and supplies. When an emergency condition exists at one Unit, additional supplies can beobtained from other unaffected units and through corporate resources upon request. TheOSC maintains reliable voice communications with the Control Room, TSC, and EOF. For adescription of communications equipment, refer to Section F.11. Facility and Equipment Readiness Emergency facilities and equipment are inspected and inventoried in accordance withemergency preparedness procedures. These procedures provide information on locationand availability of emergency equipment and supplies. An inventory of all emergency equipment and supplies is performed on a quarterly basis and after each use in an actualemergency or drill. During this inventory, radiation monitoring equipment is checked to verifythat required calibration period and location are in accordance with the inventory lists.Surveillances include an operational check of instruments and equipment. Equipment,

supplies, and parts which have a shelf-life are identified,

checked, and replaced asnecessary.

Sufficient reserves of instruments and equipment are maintained to replacethose which are removed from emergency kits or lockers for calibration or repair.Page 79 of -93220EP-1 00 Rev 0xx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Station12. Emergency Equipment and SuppliesBelow is a list of typical equipment and supplies dedicated for emergency use in the VCSNSERFs. Refer to Emergency Equipment Checklist Procedure for specific equipment andsupplies found in the various locations: Control Rooms* Emergency Plan Implementing Procedures

• Drawings of Facility and Plant Site" Self-Contained Breathing Apparatus

" Portable radios* Telephone (landlines,-Gel8klaF, and satellite) " Dose Assessment Computer" Potassium Iodide (KI) (provided by the OSC)Operational Support Centers* Protective

clothing, Self Contained Breathing Apparatus, and respirators may be stored inalternate areas of the plant with access from the OSC0 Emergency Plan Implementing Procedures a Telephones and- ortable Rakdie0 Flashlights w/batteries

• Portable Survey Meters* Dosimetry (TLDs and Self-Reading Dosimeters) 0 Portable Air Sampler0 Air Sampler Filter paper0 Silver Zeolite cartridges a Potassium Iodide (KI)* 800 MHz RadioTechnical Support Center" Telephones
• Flashlights w/batteries
• Emergency Plan Implementing Procedures

" Graphs, Overlays, and Maps* Drawings of Facility and Plant Site" Potassium Iodide (KI)Page 80 of 1-93220EP-1 00 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear StationEmergency Operations Facility" Dose Assessment Computer* Telephones " Flashlights w/batteries " Emergency Plan Implementing Procedures " Graphs, Overlays, and Maps" Drawings of Facility and Plant SiteJoint Information Center" Telephones " Flashlights w/batteries " Emergency Plan Implementing Procedures

• Graphics,

Overlays, and Maps" Graphics of Facility and Plant Site" Media Monitoring devices13. General Use Emergency Equipment Inventory procedures identify the equipment that comprise the kits used in an emergency situation that are available within each emergency facility.

14. Collection Point for Field SamplesThe environmental lab located in a SCE&G facility near site has been designated as thecentral point for the receipt and analysis of radiological field monitoring samples.

Samplingand analysis equipment is available for activity determination of these samples. Sufficient field monitoring equipment is maintained at the station for initial sampling. Instrumentation and equipment used for sample activity determination are routinely calibrated to ensuretimely availability. Page 81 of 1-93220EP-100 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear StationSection 1: Accident Assessment To effectively coordinate and direct all facets of the response to an emergency situation, diligentaccident assessment efforts are required throughout the emergency. All four emergency classifications have similar assessment methods;

however, each classification requires agreater magnitude of assessment effort dependent upon the plant symptoms and/or initiating event(s).

1. Plant Parameters and Corresponding Emergency Classification Plant system and effluent parameter values are used in the determination of accidentseverity and subsequent emergency classification.

Environmental and meteorological events are also determining factors in emergency classification. An emergency condition can be the result of just one parameter or condition change, or the combination of several.The specific

symptoms, parameter values or events for each level of emergency classification are detailed in the emergency implementing procedures.

Specific plant systemand effluent parameters that characterize a classifiable event (EALs) are presented in theUnit Annexes.In order to adequately assess the emergency condition, each emergency facility has thenecessary equipment and instrumentation installed to make available essential plantinformation on a continuous basis. Evaluation of plant conditions is accomplished throughthe monitoring of plant parameters both from indication in the Control Room and within theplant. Some of the more important plant parameters to be monitored in the Control Roomare assembled into a single display location, which is entitled the SPDS. The SPDSmonitors such parameters relative to the plant design such as: reactor coolant systempressure, reactor or pressurizer water level, containment

pressure, reactor power, safetysystem status, containment radiation level and effluent monitor readings.

Theinstrumentation and equipment capabilities available for each emergency facility aredescribed in Section H.2. Onsite Accident Assessment Capabilities The resources available to provide initial and continuing information for accidentassessment throughout the course of an event include plant parameter display systems,liquid and gaseous sampling system, Area and Process RMSs, and Accident RMSs (whichincludes the high range containment radiation monitors). Descriptions of these systems aregiven in Section H.6.b.3. Source Term Determination Source term (or core damage) estimations serve several roles within the VCSNSEmergency Preparedness Program. For planning

purposes, core damage considerations are used as the bases for several of the EAL ICs and as the threshold for the declaration ofa General Emergency (the definition of a General Emergency specifies conditions whichinvolve 'substantial' core degradation or melting as one of the bases for classification).

Page 82 of 1-93220EP-1 00 Rev 0xx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear StationFrom an implementation perspective, core damage estimations provide a means ofrealistically differentiating between the four core states (no damage, clad failure, fuel melt,and vessel melt-through) to:* Evaluate the status of the fuel barriers and how their status relates to the risks andpossible consequences of the accident" Provide input on core configuration for prioritization of mitigating activities " Determine the potential quality (type) and/or quantity (%) of source term available forrelease in support of projected offsite doses and PARs* Provide information that quantifies the severity of an accident in terms that can be readilyunderstood and visualized

• Support the determination of radiological protective actions that should be considered forlong term recovery activities The assessment methodologies used by VCSNS are intended to provide a rapid bestestimate of core damage which, when evaluated

together, help to develop an overall pictureof the extent of core damage. The methods used to estimate the amount or type of coredamage occurring under accident conditions includes the following:

" Containment Radiation Monitors: An indirect method used to determine the amount ofcore damage. Applicable to loss of coolant accident (LOCA) scenarios. Based on an end-of-life source term and static nuclide ratio assumptions yielding a limited accuracy. Validany time following an accident. " Core Temperatures: Methods such as core exit thermocouple, peak core temperatures, and hot leg temperatures provide indirect methods used to indicate the type and/oramount of core damage. Applicable for all types of accidents. Valid any time following anaccident. " Core Uncovery: Methods such as core uncovery time, reactor vessel level, and sourcerange monitor count rate provide indirect methods used to indicate the type of coredamage (clad failure or fuel melt). Applicable for all types of accidents. Provides arelatively accurate estimate of the state of the core early in the event. Valid any timefollowing an accident. " Containment Hydrogen Concentration: An indirect method used to establish the type ofcore damage. Applicable to LOCA-type accidents where all the Hydrogen generated bythe metal-water reaction is released into containment. Valid any time following anaccident. Page 83 of 4-93220EP-100 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Station" Sample Analysis -Isotopic Ratio Comparison: A direct method used to establish the typeof core damage. Compares expected isotopic ratios with a sample to determine a generalcore state. Applicable under all types of accidents. Valid any time following an accident.

• Sample Analysis

-Presence of Abnormal Isotopes: A direct method used to provide ago/no-go indication of fuel melt by the presence of unusually high concentrations of theless volatile fission products. Applicable under all types of accidents. Valid any timefollowing an accident. " Sample Analysis -Concentration Evaluation: A direct method that yields the mostaccurate numerical estimations of the amount of core damage. Applicable for all types ofaccidents. Requires the sampled system(s) be in a steady state that usually prevents itsuse until the plant is in a stable condition.

4. Effluent Monitor Data and Dose Projection Dose assessment or projection represents the calculation of an accumulated dose at sometime in the future if current or projected conditions continue.

During an accident, the plantparameter display system and personal computers will provide the ERO with the timelyinformation required to make decisions. Radiological and meteorological instrumentation readings are used to project dose rates at predetermined distances from the Station, and todetermine the integrated dose received. Dose assessment methods used by the ERO toproject offsite doses include:a. Monitored Release Points: This method uses the plant's effluent radiation monitors andsystem flow rates. Effluent release points are used to directly calculate a release rate.The point of the release determines the way the source term is affected and is adjustedby the dose assessment process.b. Containment Leakage/Failure: This method uses a variety of containment failures or leakrates in conjunction with available source term estimations to develop a release rate tothe environment. A direct vent of containment can be modeled as a failure to isolate.c. Release Point Samples: This method uses a sample at the release point and anestimated flow rate to develop a release rate at the point of release.d. Field Monitoring Team Data: This method uses a field survey or sample and theatmospheric model to back calculate a release rate and ratio concentrations ofradioactive material at various points up and downwind of plume centerline. Page 84 of 1-49220EP-1 00 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear StationThe computer applications used to provide dose calculations are evaluated against theEPA-400 plume exposure PAGs applicable for the early phase of an accident. Theseevaluations place an emphasis on determining the necessity for offsite PARs. Doseassessment actions will be performed in the following sequence: First: Onset of a release to one hour post-accident: Shift personnel will rely on asimplified computerized dose model to assist them in developing offsitedose projections using real time data from effluent monitors and sitemeteorology. Second: One hour post-accident to event termination: Estimates of offsite dosesbased on more sophisticated techniques are provided. Dedicated EROpersonnel will analyze the offsite consequences of a release using morecomplex computerized dose modeling. These additional methods are ableto analyze more offsite conditions than the simplified quick method, as wellaccount for more specific source term considerations.

5. Meteorological Information Local meteorological data is available from the onsite meteorological towers. The dataavailable includes wind speed, wind direction, temperature, and vertical temperature difference (AT). This data is used by VCSNS, the state, and NRC to provide near real-time predictions of the atmospheric effluent transport and diffusion.

Meteorological data from thetower are available in the Control Room, TSC, and EOF. A full description of the onsitemeteorological capabilities is given in Section 4 of the Unit Annexes.6. Unmonltored ReleaseDose projections can be made during a release through use of actual sample data insituations where effluent monitors are either off-scale or inoperative or the release occurs byan unmonitored flow path. In the absence of effluent sample data, a dose projection can beperformed simply by specifying the accident category as a default. The selection of a defaultaccident category defines the mix, the total curies, and the release pathway(s). The totalnumber of curies from a default mix for each isotope is used to provide an upper bound forrelease concentration, and hence, an upper bound for the dose rate and dose to the public.7. Field Monitoring In addition to the capabilities and resources described in Section H.7.b and H.8, VCSNSmaintains the ability to take offsite air samples and to directly measure gamma dose rates inthe event of an airborne or liquid release. The capability to take offsite soil, water, andvegetation samples is also provided by either the Field Teams or South CarolinaDepartment of Health and Environmental Control (SCDHEC) Teams.The environmental monitoring equipment, as described in Section H, includes portablesurvey, counting, and air sampling instrumentation and other radiological monitoring equipment and supplies to be used by the Field Monitoring Teams. Samples are taken at Ipredetermined locations as well as those specified both during and after a release.Environmental measurements are used as an aid in the determination and assessment ofprotective and recovery actions for the general public.Page 85 of 4-9220EP-1 00 Rev 0xx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Station8. Field TeamsField Teams are dispatched by VCSNS to perform a variety of functions during conditions that may involve significant releases of radioactive materials from the plant. Radiological survey and sample data is used to define affected area boundaries, verify or modify doseprojections and PARs, and assess the actual magnitude, extent, and significance of a liquidor gaseous release.In addition to contamination and dose rate measurements, the change out of environmental TLDs can be performed. Other actions may include soil, water, and vegetation sampling. The initial environmental surveys involve simple-to-perform measurements to quicklyconfirm or modify the dose projections based on plant parameters. Subsequent environmental monitoring efforts will be aimed at further defining the offsite consequences including instituting an expanded program to enable prompt assessments of any subsequent releases from the plant.The expertise necessary to conduct limited offsite environmental survey and sampling existonsite 24 hours a day. A minimum of two offsite Field Teams are notified and activated at aSite Are-a Emorgencyan Alert or higher classification. Teams are composed of twoindividuals who are assembled at the .l,-o NucleaFr Depleymt Building a near site SCANAfacility to use dedicated survey and sampling equipment. Teams are then dispatched incompany vehicles into the surrounding area when a release is ongoing or is expected tooccur. Radiological survey and sample data is transmitted to the emergency facilities. SCDHEC support can be used to perform collection,

shipment, and analysis ofenvironmental sample media.9. Iodine Monitoring Field monitoring equipment has the capability to detect and measure airborne radioiodine concentrations as low as 1x10"7 pCi/cc in the field. Interference from the presence of noblegas and background radiation will be minimized by ensuring that monitoring teams move toareas of low background before analyzing the sample cartridge.

The collected air sample ismeasured by hand-held survey meter as an initial check of the projection derived from plantdata to determine if significant quantities of elemental iodine have actually been released(the chemical form that would pose a health hazard).10. Dose Estimates Specific procedures exist for the correlation of air activity levels to dose rate for keyisotopes. These procedures also provide a method to estimate the integrated dose from theprojected and actual dose rates and for the comparison of these estimates with the PAGs.11. State Monitoring Capabilities The state (SCDHEC) has the ability to dispatch their own field monitoring teams to track theairborne radioactive plume. The state also has the ability and resources to coordinate withfederal and VCSNS monitoring teams to compare sample results.Page 86 of .1-93220EP-IO00 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear StationSection J: Protective ResponseProtective response consists of emergency

actions, taken during or after an emergency situation, which are intended to minimize or eliminate hazards to the health and safety of thepublic and/or station personnel.

A range of protective actions has been developed foremergency workers and the general public in the plume exposure pathway EPZ. Additionally, guidelines have been established to aid in choosing protective actions during an emergency thatare consistent with federal guidance. VCSNS is responsible for onsite actions, while theresponsibility for offsite actions rests with the state, county, and other offsite response agencies.

1. Notification of Onsite Personnel For all emergency classifications, all personnel within the Owner Controlled Area (OCA) arenotified of the initial classification or escalation of an emergency by recognizable alarms,and/or verbal announcements over the plant public address system. Announcements include the emergency classification and response actions to be taken by personnel onsite(such as ERO, non-ERO, contractor personnel, and visitors).

Contractors and visitors will beprovided information on how to respond in the event of an emergency. Provisions are madeto alert personnel in high noise areas and outbuildings within the Protected Areas, asapplicable. The station has identified locations where people might be expected to be present outsidethe Protected Areas but within the OCA. Accountability of persons within the OCA butoutside the Protected Areas is not required.

However, provisions including public addresssystem announcements, sirens, and security patrols are established for notification ofpersonnel within the OCA any time a site evacuation has been initiated, or as otherwise deemed appropriate.

2. Evacuation Locations If a site evacuation is required, nonessential personnel are directed to either assemblewithin designated assembly areas or to immediately evacuate the site. Personnel will bedirected to either proceed to their homes or to reassemble at designated offsite locations (Offsite Holding Areas). Visitors to the station will assemble with and follow the instructions of their escorts.

Nonessential personnel within the Protected Areas will normally exit throughthe normal access point. Personal transportation (if available) will normally be used andestablished evacuation routes will be followed. Personnel without transportation will beidentified and provided transportation as necessary. Personnel needing transportation areinstructed to request assistance from personnel evacuating the site. In the event thatpersonal vehicles cannot be utilized for evacuation, the lED or ED will request offsiteassistance to support personnel evacuation.

3. Radiological Monitoring of EvacueesPersonnel evacuating the site will be monitored for contamination by the portal monitors asthey exit the Protected Areas, with portable friskers in assembly areas, or sent to offsitemonitoring locations on an as needed basis. If there is no release of radioactive materials within the unit, limited monitoring may be used to speed the evacuation process.Page 87 of 4-93220EP-1 00 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Station4. Protective Actions for Onslte Personnel Evacuation is the primary protective action anticipated for onsite personnel not havingimmediate emergency response assignments.

The station has identified locations that serveas assembly areas and offsite locations (Offsite Holding Areas) for nonessential personnel when they are not instructed to proceed home. The specific locations of these areas areprovided in the Unit Annexes. Implementing procedures describe equipment,

supplies, andgeneral operation of these facilities.

The ED will designate personnel within the OCA asessential or nonessential. Evacuation of nonessential personnel is usually conducted immediately after accountability if a Site Area Emergency or General Emergency has beendeclared and conditions permit. Evacuation shall commence in accordance with VCSNSprocedures as directed by the lED or ED or his/her designee, unless one of the following conditions exist:a. Severe weather conditions threaten safe transport

b. A significant radiological hazard would be encountered

c. There is a security threat occurring that would have an adverse impact on the personnel while leaving the sited. A condition similar to the above in magnitude, which in the opinion of the OEMG, lED orED would adversely affect the site personnel Security forces will be dispatched, when available, to access road(s) to control entry to sitefacilities.

Unauthorized and non-ERO personnel will be denied entry.The initiation of a site evacuation will be reported to the appropriate state and countyagencies. In the event that evacuation is not the best protective action, the onsite personnel will bedirected to take other protective actions including: sheltering for extremely inclement weather or during an ongoing radiological release and take immediate cover for securityevents when evacuation will place personnel in jeopardy. Page 88 of 4-94220EP-100 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Station5. Accountability The purpose of accountability is to determine the locations of all personnel inside theProtected Area(s) and to muster emergency personnel at prearranged locations. Whenaccountability of onsite personnel is determined to be necessary by the lED or the ED, allpersonnel within the Protected Area(s) shall be accounted for and the names of missingindividuals (if any) are determined within 30 minutes of the announcement. Should missingpersonnel be identified, search and rescue operations are initiated. Accountability is usually performed in conjunction with asembly, and is required to beinitiated whenever a Site Area Emergency or higher classification is declared. Themovement of personnel for the purposes of accountability may be delayed if their health andsafety could be in jeopardy, such as severe weather or for security concerns. If it is determined that the prearranged assembly area is unfit for personnel, the lED or theED may designate an alternative assembly area and direct personnel using appropriate communication systems that are available. Once established, accountability within the Protected Area(s) is maintained throughout thecourse of the event, unless specifically terminated by the ED.6. Provisions for Onsite Personnel VCSNS maintains an inventory of respiratory protection equipment, anti-contamination

clothing, and KI that is made available to emergency workers remaining onsite shouldconditions warrant.

During the course of an emergency, protective actions are considered tominimize radiological exposures or contamination problems associated with all onsitepersonnel. For those who must work within the restricted area of the affected unit, measuresthat are considered are:a. Use of Respirators: On-shift and emergency response personnel use respiratory protection in any environment involving exposure to high level gaseous activity oroxygen deficient atmosphere, or where air quality is in doubt. In the presence of airborneparticulates, emergency response personnel may be directed by Health Physicspersonnel to use full-face filter-type respirators. The criteria for issuance of respiratory protection are described in Radiation Protection procedures.

b. Use of Protective Clothing:

Anti-contamination

clothing, located in or near the OSC andstation dress out areas is available for use by onsite personnel.

The criteria for issuanceof protective clothing are described in Radiation Protection procedures.

c. Use of Potassium Iodide (KI): The use of KI may be recommended when a projected dose of 25 Rem committed dose equivalent (CDE) is exceeded for an emergency worker's thyroid.

This is the value specified in EPA 400-R-92-001, "Manual of Protective Action Guides and Protective Actions for Nuclear Incidents." The OSC and the TSCmaintain a supply of KI. The Radiological Assessment Supervisor has the responsibility for approval of issuing KI to VCSNS onsite emergency workers.Page 89 of 4-91220EP-1 00 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Station7. Mechanism for Implementing Protective Action Recommendations Plant conditions, projected dose and dose rates, and/or field monitoring data are evaluated to develop PARs for the purpose of preventing or minimizing exposure to the general public.PARs are provided to the offsite agencies responsible for implementing protective actionsfor the general public within the 10-mile EPZ. PARs are approved by the ECO.In an emergency that requires immediate protective actions be taken before activation of theoffsite emergency facilities, PARs are provided directly to the state and county 24 hourwarning points by the lED.8. Evacuation Time EstimateAn independent Evacuation Time Estimate Study has been performed to provide estimates of the time required to evacuate resident and transient populations surrounding the VCSNSsite for various times of the year under favorable and adverse conditions. Evacuation TimeEstimate for evacuation of the plume exposure EPZ is referenced in Appendix 5 anddetailed in the referenced Evacuation Time Estimate Study.9. Capability of Implementing Protective Action Recommendations The responsibility for implementing protective measures based on PAGs for the offsitepopulation at risk is the responsibility of the state and county governments. Detailedprocedures for public protective actions are contained in the state and county radiological emergency response plans as appropriate. The state agencies are responsible for evaluation of VCSNS PARs and preparing arecommendation to the governor, or his/her appointed agent. The decision made and theorder given based on the state agencies' recommendation becomes the Protective ActionDirective (PAD) which is implemented by the offsite agencies. The counties within the10-mile EPZ may make PADs prior to those of the governor when they determine the needto protect the health and safety of the public in their county.If the plant conditions are stable and offsite radiological conditions are such that the publichealth and safety are not endangered, then return to evacuated areas may be discussed with the state. State authorities are responsible for actually recommending return andtransmitting this recommendation. Page 90 of 1-9Q220EP-100 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Station10. Implementation of Protective Action Recommendations The VCSNS, state, and county emergency plans used to implement the protective measures for the plume exposure pathway take numerous factors into consideration. Among these considerations are:a. Most of the public evacuees are expected to travel in their own vehicles, leaving the EPZvia designated evacuation routes. The state and county plans contain official maps andinformation on the locations of reception centers and shelters.

b. The population distribution around the station for the 10-mile radius is illustrated inFigure J-1. More details of populations can be found in the Evacuation Time Estimate, see Appendix 5 for revision details.c. As indicated in Section E, offsite agencies are notified in the event the Emergency Planis activated.

State and county agencies have the capability to notify members of thetransient and resident population within the plume exposure pathway EPZ.d-l. Items addressed separately in state and county emergency plans.m. At a General Emergency classification, VCSNS will provide the state and counties withPARs for the public. For incidents involving actual, potential, or imminent releases ofradioactive material to the atmosphere, EPA 400-R-92-001, the NRC ResponseTechnical Manual (RTM-96) and NUREG-0654, Supp. 3 are used as the basis for thegeneral public PARs.1) Plant-Based PARsFigure J-2 has been developed to aid VCSNS personnel providing PARs based onthe above. Possible plant-based PARs issued at a General Emergency include:" Shelter of the general public within a two mile radius and five miles downwind(puff release above PAGs) and institute KI policy" Evacuation of the general public within a two mile radius and five milesdownwind and institute KI policy" Evacuation of the general public within a five mile radius and ten miles downwindand institute KI policyIn addition to the above actions to minimize or prevent potential exposure toradiation, a recommendation for the remainder of the EPZ to monitor the Emergency Alerting Station(s) will be provided to the offsite authorities. Page 91 of 1-93220EP-1 00 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Station2) Dose-Based PARsEvacuation is recommended if projected doses reach the minimum EPA PAGs(1 Rem TEDE or 5 Rem CDE thyroid). Shelter is recommended if projected doses reach the minimum EPA PAGs (1 RemTEDE or 5 Rem CDE Thyroid) AND a puff release is in progress. Many assumptions exist in dose assessment calculations, involving both source termand meteorological

factors, which make computer predictions over long distances suspect.

However, in the event dose assessment results indicate the need torecommend actions beyond the outer EPZ boundaries, Field Teams are dispatched to downwind areas to verify the calculated exposure rates before issuing ad hocPARs outside the EPZ.Station personnel normally do not have the necessary information to determine whether off site conditions would require sheltering instead of evacuation.

An effort tobase PARs on external factors (such as road conditions, traffic/traffic control,weather, or offsite emergency response capabilities) is usually performed by thestate.11. Ingestion Pathway Protective MeasuresThe responsibility for specifying protective measures to be used for the ingestion pathwayrests with the states of South Carolina and North Carolina. These measures include themethods for protecting the public from consumption of contaminated water and foodstuffs.

12. Monitoring of EvacueesThe state and county organizations have the capability to register and monitor evacuees atdesignated reception centers.

This capability includes personnel and equipment capable ofmonitoring residents and transients evacuating from the plume exposure EPZ and arriving atthe reception

centers, in accordance with FEMA guidelines.

Page 92 of 4-932220EP-100 Rev Gxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Stationw-58NF2NNW \/ NNE567WNWENEwwF1037EF1017ESEF684Ring Total Population 0-2 mile 2460-5 mile 1,7280-10 mile 12,988Figure J-1: Sector Population Distribution Page 93 of 493220EP-1 00 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear StationGeneralEmergency Declaredas there been severe core YESdamage AND is a radiological.." 'release in progress? NO-Are there KNOVNN.. YESimpediments to.evacuaon? N.NO* Can release duration be -accurately determined AND...1wit the release be of shod/.-.d u ratio n ( <l h r)?yYESa oeNOIs a Radiologim YES progress AND offstteare projected to be a". 5 REM CDE in anpreviously evIa release in ',edose projections" 1 REM TEDE OR >y EPZ zone NOT .acuated?NOIs a Radiological release inprogress AND Field Team results are1 REM TEDE OR n 5 REM CDE inany EPZ zone NOT previously evacuated? ..Do te totlowing conditions exist.1. Severe core damage in progressAND2. Large fission product inventory incontainment AND3. Imminent projected containment.. f tailure or release underway? NOEVACUATE 2 mileradius AND 5 milesdownwindSHELTER all otherEPZ zonesCONSIDER the useof KI (Potassium Iodide) in accordance with State Plans andPolicy.IYESEVACUATE 5t mileradius AND 10 milesdownwind. SHELTER all otherEPZ zonesCONSIDER the useof KI (Potassium Iodide) in accordance with State Plans andPolicy.CONTINUEYESModify Protective ActionRecommendations asnecessary. DO NOTrelax protective actions in any EPZzones that werepreviously evacuated. NOCONTINUEContinue assessmen of containment fissiorproduct inventory, dose projections, Field Team data, ancmeteorological conditions todetermine if PARSneed to be expandedReview doseprojections todetermine if protectiov actions are neededbeyond the 1 t-itleEPZ.CONTINUEFigure J-2: PAR Flowchart Page 94 of -19g220EP-100 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear StationSection K: Radiological Exposure ControlThis section of the plan describes the means for controlling emergency worker radiological exposures during an emergency, as well as the measures that are used by VCSNS to providenecessary assistance to persons injured or exposed to radiation and/or radioactive materials. Exposure guidelines in this section are consistent with EPA Emergency Worker and Lifesaving Activity PAGs described in EPA 400-R-92-001 (EPA-400).

1. Emergency Exposure Guidelines Being licensed by the NRC, VCSNS maintains personnel exposure control programs inaccordance with 10 CFR 20 under normal operating conditions.

The ED is assigned thenon-delegable responsibility for authorizing personnel exposure levels under emergency conditions in compliance with EPA-400. In emergency situations, workers may receiveexposure under a variety of circumstances in order to ensure the safety and protection ofothers and of valuable property. These exposures will be justified if the maximum risks orcosts to others that are avoided by their actions outweigh the risks to which the workers aresubjected. The Emergency Worker Dose Limits are as follows:Dose Limit(Rem TEDE) Activity Condition Personnel should be kept within normal 100-5 All CFR 20 limits during bona fide emergencies, except as authorized for activities asindicated below5-10 Protecting valuable property Lower dose not practicable 10-25 Lifesaving or protection of large Lower dose not practicable populations > 25 Lifesaving or protection of large Only on a voluntary basis to persons fullypopulations aware of the risks involvedLimit dose to the lens of the eye to 3 times the above values and doses to any other organ(including skin and body extremities) to 10 times the above values.Whenever

possible, the concurrence of the Radiological Assessment Supervisor should besecured before exposing individuals to dose equivalents beyond the EPA-400 lower limit.2. Emergency Radiation Protection ProgramThe Radiological Assessment Supervisor is the individual responsible for implementing theradiation protection actions during an emergency.

Radiation protection guidelines includethe following: Volunteers over 45 years of age are considered first for any emergency response actionrequiring exposure greater than normal limits. Routine dose limits shall not be extended toemergency dose limits for declared pregnant individuals. As in the case of normaloccupational

exposure, doses received under emergency conditions should be maintained as low as reasonably achievable.

Page 95 of 4-93220EP-100 Rev 0xx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Station* Persons undertaking any emergency operation in which the dose will exceed 25 RemTEDE should do so only on a voluntary basis and with full awareness of the risks involvedincluding the numerical levels of dose at which acute effects of radiation will be incurredand numerical estimates of the risk of delayed effects." In the context of the emergency limits, exposure of workers that is incurred for theprotection of large populations may be considered justified for situations in which thecollective dose avoided by the emergency operation is significantly larger than thatincurred by the workers involved. " Exposure accountability is maintained and proper personnel radiological monitorng equipment is provided for all personnel during emergency conditions.

• Access to high radiation areas is only permitted with prior approval of the applicable Radiological Assessment Supervisor.

Personnel are not allowed to enter known orpotential high radiation areas unless their exposure has been property evaluated.

• Periodic habitability surveys of emergency facilities are performed during an emergency.

Ifthe facility is determined to be uninhabitable, the facility is evacuated in order to prevent orminimize exposure to radiation and radioactive materials. Altemate assembly areas areestablished, as necessary, to relocate and monitor evacuated personnel.

3. Personnel Monitoring

a. Emergency workers will receive TLD badges and personal self-reading dosimeters capable of measuring expected exposures on a real time basis. The capability exists forthe emergency processing of TLDs on a 24-hour per day basis, if necessary.

b. Emergency worker dose records are maintained by Health Physics (as appropriate) inaccordance with the emergency and radiological protection procedures.

Emergency workers are instructed to read their dosimeters frequently. TLDs may be processed withincreased periodicity.

4. Non-V. C. Summer Personnel Exposure Authorization The responsibility for authorizing non-VCSNS emergency workers (i.e., state and localagency emergency workers) to receive exposures in excess of the EPA-400 General PublicPAGs rests with the state and county organizations, except when such emergency workersare onsite. Authorization of exposures in excess of EPA General Public PAGs, in this latterinstance, rests with the ED.Page 96 of 4-9,220EP-IO00 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Station5. Contamination and Decontamination During an emergency, the ED is responsible for preventing or minimizing personnel exposure to radioactive materials deposited on the ground or other surfaces inside theProtected Area(s).

Special consideration should be given to setting up contamination control Iarrangements for personnel entering the OSC after completion of assigned activities. TheOEM is responsible for preventing or minimizing personnel exposure to radioactive materials deposited on the ground or other surfaces beyond the Protected Areas to the OwnerControlled Area. The OEM is also responsible for the VCSNS Field Team members that areassigned to track and sample the release plume.a. During emergency conditions, normal plant contamination control criteria will be adheredto as much as possible.

However, these limits may be modified by the ORMC inaccordance with existing radiation protection procedures, should conditions warrant.b. Contamination Control Means: Personnel found to be contaminated will normally beattended to at decontamination areas located onsite. The decontamination facilityconsists of a men's and women's showers, toilet, locker room, and change areas.Temporary decontamination areas can also be set up inside at various locations.

Decontamination showers and supplies are provided onsite with additional personnel decontamination equipment and capabilities. Decontamination supplies will includesoaps, shampoo, mild detergents, 3% Hydrogen Peroxide solutions, plastic bags, plasticsuits, cotton swabs, oral hygiene products, and Saline solutions. Shower and sinkdrains in the Radiation Controlled Area are routed to the miscellaneous wasteprocessing system where the liquid is processed and monitored prior to discharge. Potentially contaminated emergency vehicles will be surveyed before they are allowed toleave the plant or offsite assembly area. If the survey area is not suitable for monitoring and decontamination due to radiological or other concerns, vehicles will be surveyed atan alternate location.

6. Contamination Control MeasuresControls are established and maintained 24 hours per day to contain the spread of loosesurface radioactive contamination.

a. Contaminated Areas are isolated as restricted areas with appropriate radiological protection and access control.

Personnel leaving Contaminated Areas are monitored toensure that they and their clothing are not contaminated. If contamination aboveacceptable levels is found, they will be decontaminated in accordance with plantprocedures. If normal decontamination procedures do not reduce personnel contamination to acceptable levels, the case will be referred to a competent medicalauthority.

Supplies, instruments, and equipment that are in Contaminated Areas or havebeen brought into Contaminated Areas will be monitored before removal.

If personnel are found to be contaminated, they will be decontaminated using normal plantdecontamination techniques and facilities. Contaminated materials will be disposed of asradwaste. Contaminated vehicles will be decontaminated before being released. Anambulance responding and transporting injured contaminated personnel will bemonitored and decontaminated before departing the medical facility by VCSNSpersonnel or sent to the county emergency worker decon facility, during a declaredemergency. Page 97 of 1-93220EP-IO00 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Stationb. Measures will be taken to control onsite access to potentially contaminated potablewater and food supplies. Under emergency conditions, when uncontrolled releases ofactivity have occurred, eating, drinking, and chewing are prohibited in all onsite VCSNSERFs until such time as habitability surveys indicate that such activities are permissible.

c. Restricted areas and contaminated items will be returned to normal use whencontamination levels have been returned to acceptable levels. Contamination controlcriteria for returning areas and items to normal use are contained in the plantprocedures.

7. Decontamination of Relocated Personnel Efforts will be made to prevent contaminated vehicles operated by nonessential personnel todepart the VCSNS site. Alternate forms of transportation will be made available to reducethe possibilities of transporting contamination offsite with suspected contaminated vehicles.

Nonessential onsite personnel may be evacuated to an offsite holding area or assemblyarea, as discussed in Section J. Radiological controls personnel at that location monitorevacuees and determine the need for decontamination. Existing and temporary facilities tolimit contamination and exposure will be used and established at the site as necessary during an emergency situation. In the event that decontamination of site evacuees locally isnot possible, personnel will be sent to designated locations for monitoring anddecontamination. Provisions for extra clothing are made and suitable decontaminates areavailable for the expected types of contaminations, particularly with regards to skincontaminations. Page 98 of 1-92R220EP-100 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear StationSection L: Medical and Public Health SupportThis section describes the arrangements for medical services for contaminated injuredindividuals at the station.1. Offsite Hospital and Medical Service Facilities Arrangements, by letter of agreement, are maintained by SCE&G with Palmetto HealthRichland Hospital for receiving and treating contaminated or exposed persons with injuriesrequiring immediate medical care. Hospital personnel have been trained and the hospital isequipped to handle contaminated or radiation injured individuals. Specifically, training ofmedical support personnel at Palmetto Richland Hospital includes basic training on thenature of radiological emergencies, diagnosis and treatment, and follow-up medical care.Station personnel are available to assist medical personnel with decontamination, radiation

exposure, and contamination control.

Materials that are identified as contaminated arecollected by Health Physics personnel and returned to VCSNS for decontamination ordisposal. Because of the specialized nature of the diagnosis and treatment of radiation

injuries, VCSNS maintains an agreement with the REAC/TS in Oak Ridge, Tennessee.

REAC/TS willprovide a backup response capability for patients with serious contamination/ingestion orwho have been excessively exposed to radiation. REAC/TS has a radiological emergency response team of physicians, nurses, Health Physicists, and necessary support personnel on 24-hour call to provide consultative or direct medical or radiological assistance. Specifically, the REAC/TS team has expertise and is equipped to conduct: medical andradiological triage; decontamination procedures and therapies for external contamination and internally deposited radionuclides, including chelation therapy; diagnostic andprognostic assessments or radiation-induced injuries; and radiation dose estimates bymethods that include cytogenetic

analysis, bioassay, and in vivo counting.

Victims of accidents or medical emergencies who are determined as not being contaminated or excessively exposed to radiation may be treated at the closest appropriate medical facilityas determined by the responding Emergency Medical Services Crew Chief.2. Onsite First Aid Capability The station maintains onsite first aid supplies and equipment necessary for the treatment ofcontaminated or injured persons. In general, physicians or nurses are not staffed at VCSNS,and as such, medical treatment given to injured persons is of a "first response" nature. TheMedical Emergency Response Team (MERT) is comprised of on-shift personnel trained asFirst Responders. The MERT is dispatched by the Control Room or the OSC when it isactivated. At least two of these individuals are available on shift at all times to supportimmediate response in the Protected Areas. VCSNS also maintains an agreement with alocal physician. That physician serves as the VCSNS's company physician and is available to respond to the site to augment medical treatment as required. Page 99 of -.93220EP-IO00 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear StationAdditionally, the Health Physics Specialists at VCSNS are experienced and trained in thecontrol of radioactive contamination and decontamination work for injured or ill personnel. Health Physics Specialists are dispatched to support the MERT if there is a possibility ofcontamination associated with the injury/illness. The functions of station personnel inhandling onsite injured people are:a. Afford rescueb. Administer first responder aid including such resuscitative measures as are deemednecessary

c. Request and escort offsite medical assistance to the injured/ill individual in a timelymanner when neededd. Begin decontamination procedures as appropriate

e. Arrange for suitable transportation to a hospital when requiredPrimary attention shall be directed to the actual factors involved in the treatment of injuriesor illness, such as: control of bleeding, resuscitation including heart and lung, control ofbleeding after resuscitation, protection of wounds from bacterial or radioactive contamination and the immobilization of fractures.

VCSNS personnel provide an initial estimate of the magnitude of surface contamination ofthe injured and preliminary estimates of total body dose to the injured. Primary rapid andsimple decontamination of the surface of the body (when possible and advisable) beforetransportation to a designated hospital may be carried out. This activity would be as directedor performed by Health Physics personnel. If decontamination is not considered due to theimmediacy of medical treatment, efforts will be made to isolate and reduce the spread of thecontamination before transportation. When additional professional medical care is neededand contamination is not a factor, injured or ill persons are transported to a local clinic orhospital. Contaminated and injured or ill persons are transported to Palmetto HealthRichland Hospital from the VCSNS site.First aid facilities at VCSNS are designed to provide basic first responder aid to injured or illpersonnel before arrival of offsite medical support. First aid facilities are located in each ofthe uUnits and are described in the Unit Annexes. Medical equipment and supplies areavailable at these locations. In the event of a mass casualty

incident, medical triage is implemented.

MERT members aretrained for medical triage using START (Simple Triage and Rapid Treatment) or other similarprincipals. Each victim is screened and categorized in order to prioritize victim treatment. Inthe event that station and local response resources are exceeded by the number ofcasualties, the South Carolina Emergency Operations Plan is implemented to acquireadditional resources by the offsite response agencies. Page 100 of 4.93220EP- 100 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Station3. Medical Transportation In situations when transportation of a victim(s) to a hospital is required, arrangements aremade by the station for prompt ambulance transport of persons with injuries and/or illnessinvolving radioactivity to Palmetto Richland Hospital. Such service is available on a 24-hourper day basis and is confirmed by letter of agreement with the Fairfield County Emergency Medical Services (FCEMS). The FCEMS is located approximately two miles from VCSNSand is staffed with Emergency Medical Technicians, Paramedics, and additional qualified personnel capable of handling medical emergency situations. VCSNS maintains acommunications link with the FCEMS by means of an ESSX telephone, radio and normaltelephone lines. VCSNS security personnel will expedite and escort the responding ambulance(s) to the victim's location. In the event that a helicopter is requested by the response personnel to transport victim(s) toappropriate medical care, a primary helicopter landing zone is available onsite for use.Alternate landing zones are determined by response personnel and marked to assist thelanding of the helicopter. If additional assistance is required for the transportation of accident

victims, the Lexington County Emergency Medical Services (LCEMS) will respond.

This support would most likelybe used in a case where multiple casualty victims would require transportation to offsitemedical facilities. LCEMS is located approximately 15 miles from VCSNS and is staffed withEmergency Medical Technicians and Paramedics. Should the need arise, assistance fromthe LCEMS and other response organizations would be requested by FCEMS or theIncident Commander. Radiation monitoring services shall be provided by VCSNS Health Physics personnel whenever it becomes necessary to use the ambulance service for the transportation ofcontaminated persons.A qualified Health Physics person shall accompany the ambulance to the hospital upon thedetermination that the injured or ill person is contaminated or if the determination cannot bemade that the individual is free of surface contamination. Additional Health Physicspersonnel may be contacted and dispatched to Palmetto Health Richland Hospital to assistin the monitoring and decontamination of the injured victim(s), the hospital facilities, and theambulance and response personnel as needed.Page 101 of 4-14220EP-IO00 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear StationSection M: Reentry and Recovery PlanningThis section describes the measures to be taken for reentry into the areas of the Station whichhave been evacuated as a result of an accident. It also outlines the VCSNS RecoveryOrganization and its concepts of operation.

1. Reentry and Recoverya. Evaluating Reentry Conditions During an emergency, immediate actions are directed toward limiting the consequences of the accident to afford maximum protection to station personnel and the general public.Once corrective measures have been taken and effective control of the plant has beenreestablished, a more methodical approach to reentry is taken. This Emergency Plandivides reentry into two separate categories:

• Reentry during the emergency phase of an accident is performed to save a life, controla release of radioactive

material, prevent further damage to plant equipment or restoreplant equipment.

If necessary, this category of reentry may be performed usingemergency exposure limits. Briefings, rather than written radiation protection procedures, may be used when making these entries.All reentry activities conducted during the emergency are authorized by the ED andcoordinated by the OSC Supervisor and the Radiological Assessment Supervisor.

• Reentry during the recovery phase of an accident is performed using normal exposurelimits. Either normal procedures or procedures that consider existing as well aspotential conditions inside affected areas are developed specifically for each reentry.Reentry activities during the recovery phase are authorized by the Recovery Directorand coordinated by the recovery organization managers in charge of personnel making the reentry.The following items are considered when planning for any reentry:" Review of available radiation surveillance data to determine plant areas potentially affected by radiation and/or contamination
• Review of radiation exposure history of personnel required to participate in theaccident mitigation or recovery operations
• Determination of the need for additional personnel and the sources of these additional personnel
• Review of adequacy of radiation survey instrumentation and equipment (types, rangesnumber, calibration, etc.)" Review of nonradiological hazards and required protective measures (e.g., fire,electrical, atmosphere, Hazmat)Page 102 of 41-93220EP-100 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Station" Preplanning of activities and briefings for the reentry team that include the following:

-Personnel knowledge requirements -Methods and procedures that will be employed during the entry-Specific tasks to be performed -Anticipated radiation and contamination levels as well as "turn back" limits-Radiation survey equipment and types and ranges of dosimetry required-Shielding requirements and availability -Appropriate communications -Personal protective equipment (PPE) requirements -Access control procedures -Decontamination requirements -Debriefing requirements -Respiratory protection " A review of security controls to prevent unauthorized or unintentional entry intohazardous or secured areas.b. Evaluating Entry into RecoveryThe Recovery Phase is that period when major repairs are being performed to return theplant to an acceptable condition and the possibility of the emergency condition degrading no longer exists. Once the plant has been stabilized, contained, andcontrolled, the Recovery Phase may be entered. It is the responsibility of the ED todeclare emergency phase terminated and entry into Recovery after obtaining concurrence from the ED and consulting with offsite authorities if a Site Area Emergency or General Emergency has been declared. Establishment of Recovery can be conducted from any emergency classification level.However, it is possible that the lower classifications of Unusual Event and Alert willconclude with the overall event being terminated. There may be cases where certainEAL ICs remain exceeded, but the station is under control and no further danger ofdegradation exists. In such a case, it may be appropriate to enter Recovery. Site AreaEmergency and General Emergency classifications will require a Recovery Phase to beestablished before event termination. VCSNS may consult with/notify the cognizant governmental agencies before declaring Recovery or event termination during anUnusual Event or Alert. When in a Site Area Emergency or a General Emergency, VCSNS will consult and notify the cognizant governmental agencies before declaring Recovery or event termination. Page 103 of 93220EP-100 Rev 0xx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear StationTermination/Recovery considerations are contained in the implementing procedures toprovide guidance for evaluating the risk of entering Recovery without alleviating theintent of the Initiating Condition. The purpose of Recovery is to provide the necessary personnel to affect the long-term activities and to return the plant to an acceptable condition. The following conditions are guidelines for the determination of establishing Recovery(this is not intended to be a complete list and additional criteria may apply, depending onthe specifics of the event):* The risk to the health and safety of the public has been mitigated " Plant parameters and equipment status have been established and controlled " In-plant radiation levels are stable or decreasing, and acceptable, given the plantconditions " The potential for uncontrolled releases of radioactive material to the environment hasbeen eliminated " Environmental monitoring has been established " The radioactive plume has dissipated and plume tracking is no longer required (theonly environmental assessment activities in progress are those necessary to assessthe extent of deposition resulting from passage of the plume)" VCSNS workers have been protected " Any security threat has been neutralized, and/or plant Security is under the direction ofVCSNS personnel as part of a Unified Command Incident Command System." Adequate plant safety systems are operable" The reactor is in a stable shutdown condition and long-term core cooling is available " The fuel pool damage has been mitigated, or spent fuel damage has been contained and controlled " Primary and/or secondary containment integrity has been established

• Plant systems and equipment are restored and/or replaced such that plant conditions are stable and highly unlikely to degrade further* Conditions that initiated the emergency have been contained, controlled, eliminated, orstabilized such that the emergency classification is no longer applicable

" The operability and integrity of unit or externally supplied radioactive waste systems,decontamination facilities, power supplies, electrical equipment and of plantinstrumentation including radiation monitoring equipment Page 104 of 4.93220EP-1 00 Rev Gxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Station" Any fire, flood, earthquake, high winds, or similar emergency condition or securitythreat no longer exists" All required notifications have been made" Discussions have been held with federal, state, and county agencies and agreement has been reached to terminate the emergency for a Site Area Emergency or a GeneralEmergency " At an Alert or higher classification, the ERO is in place and emergency facilities areactivated " All contaminated injured personnel have been treated and/or transported to a medicalcare facility* Offsite conditions do not unreasonably limit access of outside support to the stationand qualified personnel and support services are available It is not necessary that all conditions listed above be met; however, all items must beconsidered before entering the recovery phase. For example, it is possible after a severeaccident that some conditions remain that exceed an Emergency Action Level, but entryinto the Recovery Phase is appropriate.

2. Recovery Organization Once plant conditions have been stabilized and the Recovery Phase has been initiated, theECO with assistance from senior management may form a Recovery Organization for long-term operations.

These types of alterations should be discussed with the NRC before theyare implemented.

• For events of a minor nature, (i.e., for Unusual Event classifications),

the normal on shiftorganization is normally adequate to perform necessary recovery actions." For events where damage to the plant has been significant, but no offsite releases haveoccurred and/or protective actions were not performed, (i.e., for Alert classifications) thestation ERO, or portions

thereof, should be adequate to perform the recovery tasks beforereturning to the normal station organization.

" For events involving major damage to systems required to maintain safe shutdown of theplant and/or offsite radioactive releases have occurred, (i.e., for Site Area Emergency orGeneral Emergency classifications) the station recovery organization is put in place.Page 105 of 41-93220EP-IO00 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear StationThe specific members of the station recovery organization are selected based on thesequence of events that preceded the recovery activities as well as the requirements of therecovery phase. The basic framework of the station recovery organization is as follows:a. The Recovery Director: The ECO is initially designated as the Recovery Director. TheRecovery Director is charged with the responsibility for directing the activities of thestation recovery organization. These responsibilities include:" Ensuring sufficient personnel, equipment, or other resources from SCE&G and otherorganizations are available to support recovery" Directing the development of a recovery plan and procedures " Deactivating any of the plant ERO that was retained to aid in recovery, in theappropriate manner. Depending on the type of accident and the onsite and offsiteaffects of the accident, portions of the ERO may remain in place after initiation of therecovery phase" Coordinating the integration of available federal and state assistance into onsiterecovery activities " Coordinating the integration of SCE&G support with federal, state, and countyauthorities into required offsite recovery activities " Approving information released by the public information organization that pertains tothe emergency or the recovery phase of the accident" Determining when the recovery phase is terminated

b. The Recovery Plant Manager:

The General Manager, Nuclear Plant Operations or adesignated alternate, will become the Recovery Plant Manager. The Recovery PlantManager reports to the Recovery Director and is responsible for:* Coordinating the development and implementation of the recovery plan andprocedures

• Ensuring that adequate engineering activities to restore the plant are properlyreviewed and approved" Directing all onsite activities in support of the station recovery effort" Designating other VCSNS recovery positions required in support of onsite recoveryactivities Page 106 of 4-9,220EP-100 Rev Oxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Stationc. The Recovery Offsite Manager:

A senior member of Nuclear Support Services or adesignated alternate is the Recovery Offsite Manager. The Recovery Offsite Managerreports to the Recovery Director and is responsible for:* Providing liaison with offsite agencies and coordinating VCSNS assistance for offsiterecovery activities " Coordinating VCSNS ingestion exposure pathway EPZ sampling activities and thedevelopment of an offsite accident analysis report" Developing a radiological release report" Designating other VCSNS recovery positions required in support of offsite recoveryactivities

d. The Company Spokesperson:

A senior SCANA Public Relations Group individual isdesignated as the Company Spokesperson. The Company Spokesperson reports to theRecovery Director and is responsible for:" Functioning as the official spokesperson to the press for SCE&G on all matters relatingto the accident or recovery" Coordinating with all public information groups (federal, state, county, etc.)" Coordinating media monitoring and rumor control" Determining what public information portions of the ERO will remain activated The remainder of the recovery organization is established on an initial recovery plandeveloped at the end of the emergency phase or just after entry into the Recovery Phase.Consideration is given to recovery activity needs and use of the normal stationorganizations. Individual recovery supervisors may be designated in any or all of thefollowing areas:" Training" Health Physics* Chemistry " Technical/Engineering Support" Nuclear Oversight " Operations " Security" Maintenance " Corporate Support" Special Offsite Areas (Community Representatives, Environmental Samples,Investigations, etc.)Page 107 of 1-93220EP-1 00 Rev Gxx Part 2: Planning Standards and CriteriaV. C. Summer Nuclear Station3. Recovery Phase Notifications When the decision is made to enter the Recovery Phase, all members of the ERO areinformed of the change. All VCSNS personnel are instructed on the Recovery Organization and their responsibilities during the recovery effort. The offsite authorities are notified of theshift to and the basic structure and management of the Recovery Organization.

4. Total Population ExposureTotal population exposure calculations are performed and periodically updated during theRecovery Phase of an accident.

A procedure has been developed for estimating the totalpopulation exposure resulting from the accident from data collected in cooperation with thestate and other federal agencies. Total population exposure is determined through a varietyof processes including: " Examination of prepositioned environment monitoring TLDs" Bioassay* Estimates based on release rates and meteorology " Estimates based on environmental monitoring of food, water, and ambient dose ratesThe state will be the lead agency in the collection and analysis of environmental air, soil,foliage, food, and water samples and for the generation of radiation monitoring reports.VCSNS environmental sampling activities will be coordinated with state efforts, asrequested, and results shared with the cognizant agencies. Page 108 of 4-9-220EP-1 00 Rev Oxx Part 2: Planning Standards and CriteriaV.C. Summer Nuclear StationSection N: Drill and Exercise ProgramThis section describes the Drill and Exercise Program that VCSNS has implemented to:* Verify the adequacy of the Emergency Preparedness Program* Develop,

maintain, and evaluate the capabilities of the ERO to respond to emergency conditions and safeguard the health and safety of station personnel and the general public" Identify deficiencies in the Emergency Plan and its associated procedures, or in thetraining of response personnel, and ensure that they are promptly corrected

" Identify deficiencies in the relationship between the Emergency Plan and the VCSNSSecurity Plan and ensure that they are promptly corrected " Ensure the continued adequacy of emergency facilities,

supplies, and equipment, including communications networks1. Exercises Exercises provide an opportunity to evaluate the ability of participating organizations toimplement a coordinated response to postulated emergency conditions.

Provisions will bemade for qualified personnel from VCSNS, other commercial nuclear facilities, or federal,state, or local governments to observe and critique each exercise as appropriate. Exercises are conducted to ensure that all major elements of the emergency plan and preparedness program are demonstrated at least once in each exercise cycle. Each scenario variation shall be demonstrated at least once during the cycle and shall include, but not limited to, thefollowing: " An off-hours exercise between 6:00 p.m. and 4:00 a.m.. Weekends and holidays arealso considered off-hour periods." Hostile action directed at the plant site involving the integration of offsite resources with onsite response; VCS participates on a rotating basis with other fixed nuclearfacilities in the state of South Carolina" An initial classification of, or rapid escalation to, Site Area Emergency or GeneralEmergency

• No radiological release or an unplanned minimal radiological release that requiresthe site to declare a Site Area Emergency, but does not require declaration ofGeneral Emergency
• An ingestion pathway exercise

VCSNS participates on a rotating basis with theother fixed nuclear facilities in the state of South Carolina.

Page 109 of 4.-93220EP-IO00 Rev Gxx Part 2: Planning Standards and CriteriaV.C. Summer Nuclear Stationa. Biennial Exercises Federally prescribed exercises are conducted at the station in order to test the adequacyof timing and content of implementing procedures and methods; to test emergency equipment and communication networks; and to ensure that emergency personnel arefamiliar with their duties. Exercises involving offsite agency participation, required underSections F.2.b., F.2.c., & F.2.d. to 10 CFR 50 Appendix E, are conducted at the stationbased on FEMA guidance and the respective state and county emergency responseplans.Full participation exercises will include appropriate offsite local and state authorities andVCSNS personnel physically and actively taking part in testing the integrated capability to adequately assess and respond to a declared emergency at the station. Additionally, full participation exercises will include testing the major observable portions of the onsiteand offsite emergency plans and mobilization of state, local, and VCSNS personnel andother resources in sufficient numbers to verify the capability to respond to the accidentscenario. Some of the offsite response actions may be provided for evaluation in an out-of-sequence manner. These exercises are to be scheduled in an attempt to provide orsimulate various weather conditions. These exercises are usually conducted in conjunction with a full participation exercise asthe state chooses.Where full participation by offsite agencies occurs, the sequence of events simulates anemergency that may result in the release of radioactivity to the offsite environs or thethreat of such a release, sufficient in magnitude to warrant a response by offsiteauthorities. The sequence of events will be submitted to the NRC and FEMA in a timelyfashion to ensure that the scenario is judged to provide adequate opportunity fordemonstration of the agreed upon objectives and extent of play.In the event of an inadequate demonstration of the offsite response, VCSNS willparticipate and support the conduct of activities that are designed to address thedeficient or weak demonstrations.

b. Off-Year Exercises An Off-Year Exercise is conducted at the station during the calendar year when an NRCEvaluated Exercise is not scheduled.

An Off-Year Exercise shall involve the station andits facilities in order to demonstrate at least the functions of management andcoordination of emergency

response, accident assessment, protective action decision-making, or plant system repair and corrective actions.

Off-Year Exercises involve no orlimited participation by offsite agencies, although a routine offer is made to determine theextent of participation by the offsite authorities. Emphasis is placed on development andconduct of an exercise that is more mechanically and operationally realistic. Players maybe able, by implementing appropriate procedures and corrective

actions, to determine the outcome of the scenario to a greater extent than when core damage and the releaseof radioactivity that are prerequisites for demonstration of all objectives which mayinclude security response activities.

Page 110 of 41-9220EP-1 00 Rev Oxx Part 2: Planning Standards and CriteriaV.C. Summer NUC102r Station2. DrillsIn addition to the exercises described above, VCSNS conducts drills for the purpose oftesting, developing, and maintaining the proficiency of emergency responders. Drills arescheduled on the Emergency Preparedness annual events plan, which contains provisions for the following drills:a. Training DrillsTraining Drills may be conducted before a Biennial Exercise where FEMA evaluation ofstate and local performance is expected. Training Drills may be conducted before Off-Year Exercises that only involve VCSNS. The Training Drill is a training and experience tool for the participants to sharpen awareness and practice skills necessary toaccomplish specific Emergency Plan duties and responsibilities. It also provides a "dryrun" for experience dealing with multiple Controllers, Observers and Evaluators that maybe in excess of those provided in training drills.b. Communication Drills" Monthly: The primary and alternate methods to notify the state and local government warning points and EOCs within the plume exposure pathway EPZ are demonstrated. Also, the capability to notify the NRC is demonstrated using the ENS." Quarterly: The capability to notify the NRC Region and federal EROs as listed in theEmergency Telephone Directory are demonstrated from the EOF. Also, computer andcritical communications equipment shall be functionally tested." Annually: The emergency communications systems outlined in Section F are fullytested. This includes (1) communications between the plant and the state and localEOCs and Field Teams, (2) communications between the Control Rooms, the TSC,and the EOF (3) communications between the TSC and the OSCs, and (4)communications between the EOF and the JIC.Each of these drills includes provisions to ensure that all participants in the test are ableto understand the content of the messages.

c. Fire Drills: Fire drills shall be conducted in accordance with the station Technical Specifications, Fire Protection Plan, and/or station procedures.

d. Medical Emergency Drills: A medical emergency drill, involving a simulated contaminated individual and containing provisions for participation by local supportservices organizations (i.e., ambulance and support hospital) is conducted annually.

Theoffsite portions of the medical drill may be performed as part of the required biennialexercise.

e. Radiological Monitoring Drills: Plant environs and radiological monitoring drills (onsiteand offsite) are conducted annually.

These drills include collection and analysis of allsample media (such as, water, vegetation, soil, and air), and provisions forcommunications and record keeping. Collection of milk is demonstrated in accordance with the ingestion pathway exercises. Page 111 of 49.a220EP-100 Rev Oxx Part 2: Planning Standards and CriteriaV.C. Summer Nuclear Stationf. Health Physics Drills: Health Physics drills involving a response to, and analysis of,simulated elevated airborne and liquid samples and direct radiation measurements within the plant are conducted semiannually in the each Protected Area.g. Augmentation Drills: Augmentation drills serve to demonstrate the capability of theprocess to augment the on-shift staff with a TSC, OSCs, EOF, and JIC after declaration of an emergency. These drills are conducted using the following methods:" Semiannually, an unannounced off-hours ERO augmentation drill where no actualtravel is required. " At least once per exercise cycle, an off-hours unannounced activation of the ERONotification System with actual response to the emergency facilities is conducted tosupport the response te-the-u;*of the ERO.h. Accountability Drills: Accountability drills are conducted annually for the Protected Area.The drill includes ascertaining the names of all missing individuals within the Protected Area and accounting for all individuals within the Protected Area continuously throughout the event.3. Conduct of Drills and Exercises Advance knowledge of the scenario will be kept to a minimum to allow "free-play" decisionmaking and to ensure realistic participation by those involved. Before the drill or exercise, apackage will be distributed to the Controllers and Evaluators that will include the scenario, alist of performance objectives, and a description of the expected responses. Drills will be provided to ensure that each member of the ERO will have an opportunity toparticipate in a drill in their assigned facility at least once in a two-year period. Drills will berotated among the Units and their specific ERFs to provide the needed opportunities for themembers of the ERO.For each emergency preparedness exercise or drill conducted, a scenario package isdeveloped that includes at least the following:

a. The basic objective(s) of the drill or exercise and the appropriate evaluation criteriab. The date(s),

time period, place(s), and participating organizations

c. The simulated eventsd. A list of anticipated Drill/Exercise Performance (DEP) opportunities including classification, notifications and PARse. A time schedule of real and simulated initiating eventsf. A narrative summary describing the conduct of the scenario to include such things assimulated casualties, offsite fire department assistance, rescue of personnel, use ofprotective

clothing, deployment of radiological monitoring teams, and public information activities.

Page 112 of 4-3220EP-100 Rev Oxx Part 2: Planning Standards and CriteriaV.C. Summer Nuclear Stationg. A list of qualified participants

h. Instructions for the conduct of the drill/exercise for the controller organization Prior approval by the appropriate Station Management is obtained for all drills and exercises conducted in support of the Emergency Preparedness Program.4. Critique and Evaluation Drill and exercise performance objectives are evaluated against measurable demonstration criteria.

As soon as possible following the conclusion of each drill or exercise, a critique isconducted to evaluate the ability of the ERO to implement the Emergency Plan and itsimplementing procedures. A formal written critique report is prepared by the Manager, Emergency Planning following adrill or exercise involving the evaluation of designated objectives or following the finalsimulator session with ERO participation. The report will evaluate the ability of the ERO torespond to a simulated emergency situation or sequence of events. The report will alsocontain corrective actions and recommendations for improvement. Biennially, representatives from the NRC observe and evaluate the licensee's ability toconduct an adequate self-critical critique. For full offsite participation exercises, both theNRC and FEMA will observe,

evaluate, and critique.

Critique comments identified by participants during a training drill where objectives are notformally being evaluated will be reviewed and dispositioned by the Emergency Preparedness Unit, but are not required to be included in a formal report.5. Resolution of Drill and Exercise FindingsThe critique and evaluation process is used to identify areas of the Emergency Preparedness Program that require improvement. The Manager, Emergency Planning isresponsible for evaluation of recommendations and comments to determine which items willbe incorporated into the program or require corrective

actions, and for the scheduling,

tracking, and evaluation of the resolution to the items.Whenever exercises and/or drills indicate deficiencies in the Emergency Plan orcorresponding implementing procedures, such documents will be revised as necessary.

Page 113 of 4-193220EP-100 Rev Gxx Part 2: Planning Standards and CriteriaV.C. Summer Nuclear StationSection 0: Emergency Response TrainingThis section describes the emergency response training that is provided to those who may becalled upon in an emergency. It outlines the training provided by VCSNS to both its employees and offsite support personnel requiring site access.1. Assurance of TrainingThe Emergency Plan Training Program assures the training, qualification, and requalification of individuals who may be called on for assistance during an emergency. Specificemergency response task training, prepared for each Emergency Plan position, is described in lesson plans and study guides. The lesson plans, study guides, and written tests arecontained in the ERO Training Program. Responsibilities for implementing the trainingprogram are contained in plant procedures. A description of the content of the trainingcourses is given in the VC Summer Training and Qualification Procedures (TQP).Offsite training is provided to support organizations that may be called upon to provideassistance in the event of an emergency. The following outlines the training received bythese organizations:

a. Emergency Preparedness shall annually train, or document an annual written offer totrain, those non-VCSNS organizations that may provide specialized services during anuclear plant emergency (e.g., local law enforcement, firefighting, medical services, transport of injured, etc.). The training made available is designed to acquaint theparticipants with the special problems potentially encountered during a nuclear plantemergency, notification procedures and their expected roles. Those organizations thatmust enter the site shall also receive site-specific emergency response training and beinstructed as to the identity (by position and title) of those persons in the onsiteorganization who will control their support activities.

b. Training of offsite EROs is described in their respective radiological emergency plans,with support provided by VCSNS as requested.

Page 114 of 4-91220EP-100 Rev Oxx Part 2: Planning Standards and CriteriaV.C. Summer Nuclear Station2. Functional Training of the EROIn addition to general and specialized classroom

training, members of the ERO receiveperiodic performance-based emergency response training.

Performance-based training isprovided using one or more of the following methods:" Familiarization Sessions: A familiarization session is an informal, organized tabletopdiscussion of predetermined objectives. " Walk-throuahs: Consists of a facility walk-through to familiarize plant ERO personnel withprocedures, communications equipment, and facility layout. Walk-throughs also providethe opportunity to discuss facility activities, responsibilities, and procedures with aninstructor.

• Drills: A drill is a supervised instruction period aimed at testing, developing, andmaintaining skills in a particular operation.

Drills described in Section N of this plan are apart of training. These drills allow each individual to demonstrate the ability to perform theirassigned emergency functions. During drills, on-the-spot correction of erroneous performance may be made and a demonstration of the proper performance offered by theController.

3. First Aid ResponseSelected station personnel are trained in accordance with the VCSNS approved First AidProgram and medical triage. MERTs will likely be augmented with additional personnel suchas fire brigade members and other personnel qualified to assist in the rescue.4. Emergency Response Organization Training ProgramERO personnel who are responsible for implementing this plan receive specialized training.

The training program for emergency response personnel is developed based on therequirements of 10 CFR 50, Appendix E and position specific responsibilities as defined inthis document. On-shift emergency response personnel perform emergency response activities as anextension of their normal duties and are trained annually as part of their duty specifictraining. Additional Emergency Preparedness information is provided as part of the StationOrientation Training (SOT).Page 115 of 49.a220EP-100 Rev Oxx Part 2: Planning Standards and CriteriaV.C. Summer Nuclear StationNew ERO personnel receive an initial overview course that familiarizes them with theEmergency Plan by providing basic information in the following areas as well as specificinformation as delineated in the sections below:" Planning Basis" Emergency Classifications

• ERO and Responsibilities

" Call-out of ERO" ERFs" Communications Protocol/EPIO " Offsite Organizations Emergency response personnel in the following categories receive knowledge and/orperformance based training initially and retraining thereafter on an annual basis:a. Directors,

Managers, Supervisors, and selected Coordinators within the Station ERO:Personnel identified by the Emergency Planning Telephone Directory as Directors,

Managers, Supervisors, and selected Coordinators for the Station ERO receive trainingappropriate to their position in accordance with the approved ERO training program.These personnel receive specialized training in the areas of:" Notifications

" Emergency Classifications " Protective Action Recommendations " Emergency Acton Levels" Emergency Exposure ControlThe ECOs and EDs along with selected

managers, coordinators, and IEDs receivetraining in accordance with the approved ERO training program.

Training in accidentassessment sufficient to classify an event and to mitigate the consequences of an eventis also covered.b. Personnel Responsible for Accident Assessment: The skills and knowledge required toperform plant stabilization and mitigation are a normal function of operations-specific positions, as identified in Section B of this Plan. Power changes and planned andunplanned reactor shutdowns are handled on a normal operation basis. Subsequent plant stabilization and restoration is pursued using normal operating procedures. Licensed operators receive routine classroom and simulator training to ensureproficiency in this area.Page 116 of 1-93220EP- 100 Rev Oxx Part 2: Planning Standards and CriteriaV.C. Summer Nuclear Station1) Active Senior Licensed Control Room Personnel shall have training conducted inaccordance with the approved ERO training program such that proficiency ismaintained on the topics listed below. These subjects shall be covered as aminimum on an annual basis.* Event Classification

• Protective Action Recommendations
• Radioactive Release Rate Determination
• Notification form completion and use of ESSX* Federal, state, and county notification procedures as appropriate
• Site-specific procedures for activating the onsite and offsite ERO2) Core Damage Assessment Personnel:

During an emergency when core/cladding damage is suspected, a specialized group of trained individuals perform coredamage assessment. At a minimum, personnel responsible for core damageassessment receive classroom and hands-on training in the following areas:* Available instrumentation and equipment

• Isotopic assessment and interpretation
• Core damage assessment methodology and/or proceduralized assessment methodsc. Field Teams and Radiolo-gical Analysis Personnel

1) Field Radiological Monitoring:

Field radiological monitoring is performed by trainedindividuals who provide samples and direct readings for dose assessment calculations and dose projection comparisons. Personnel identified as members of Field Teams receive training in accordance withthe approved training program. Field Team members receive classroom and hands-on training in the following areas:* Equipment and equipment checks* Communications

• Plume tracking techniques

2) Personnel Monitoring:

Personnel monitoring is performed by trained individuals who monitor station personnel and their vehicles for contamination during anemergency. Health Physics personnel receive classroom and hands-on training inthe following areas:* Personnel monitoring equipment and techniques

• Decontamination techniques for personnel
• Decontamination techniques for vehiclesPage 117 of4--932220 EP-100 Rev Oxx Part 2: Planning Standards and CriteriaV.C. Summer Nuclear Station3) Dose Assessment:

Dose assessment training includes the skills and knowledge necessary for calculation and interpretation of an offsite release and its impact onthe environment under varying meteorological conditions. Individuals responsible for performing dose assessment are trained in the following areas:* Computerized dose assessment

• Protective Action Recommendations
• Field Monitoring Team interface
• PAGs associated with offsite plume exposure doses* Basic meteorology

d. Police, Security, and Firefighting Personnel

1) Local Police and Firefighting Personnel:

The local police and fire departments areinvited to receive training as outlined in Part l.a of this section.2) Security Personnel: Station security personnel are trained in accordance withtraining defined by the SOT and VCSNS Security Program.3) Fire Brigade Teams: Station fire brigade members are trained in accordance withtraining defined by the VCSNS Fire Protection Program.e. Repair and Damage Control Teams: Operations, Maintenance, Chemistry, and HealthPhysics personnel are trained as part of their normal job-specific duties to respond toboth normal and abnormal plant operations. Operations personnel are trained to: (1) recognize and to mitigate degrading conditions in the plant, (2) mechanically and electrically isolate damaged or malfunctioning equipment, (3) isolate fluid leaks, and (4) minimize transients. Maintenance personnel are trained to troubleshoot and repair damaged ormalfunctioning electrical, mechanical, or instrumentation systems as appropriate to theirjob classification. Chemistry personnel are trained to take system samples and perform appropriate laboratory chemical analysis of the samples.Health Physics personnel are trained to assess the radiological hazards associated withequipment repair and instruct personnel as to the appropriate protective clothingrequirements, respiratory protection requirements, stay times, and other protective actions specific to the conditions present.Page 118 of 4-93220EP-100 Rev Gxx Part 2: Planning Standards and CriteriaV.C. Summer Nuclear StationAt least 50% of personnel from the organizations below, who are potential responders tothe OSC as Damage Control Team members, are required to be qualified in the use ofrespiratory protection equipment. This includes in-plant supervision and craft/technical personnel for the following organizations: " Operations " Health Physics* Chemistry " Maintenance (Mechanical, Electrical, and I&C)f. Medical Emergency Response Team and Rescue Personnel: MERT and rescue teammembers receive training as outlined in Part 3 of this section, First Aid Response.

g. Local Support Service Personnel:

Local support service personnel providing assistance during an emergency are invited to receive training as outlined in Parts l.a and l.b ofthis section.h. Medical Support Personnel: Onsite medical personnel receive specialized training in thehandling of contaminated victims and hospital interface. Offsite ambulance and hospitalpersonnel are offered annual training in accordance with a program provided byEmergency Preparedness. EPIO Personnel: Corporate and station personnel responsible for disseminating publicinformation and responding to media and public information requests receive specialized public information training.

j. Communications Personnel:

ERO personnel receive training on communications protocol as a part of the initial Emergency Response Overview Course. Personnel usingspecialized communications equipment that is not part of their normal daily functionreceive initial and requalification training on the equipment. Personnel involved innotifications to offsite agencies receive specialized training in the notification process.Page 119 of 41-93220EP-100 Rev Gxx Part 2: Planning Standards and CriteriaV.C. Summer Nuclear Station5. General,

Initial, and Annual Training Program Maintenance

a. Station departments and Emergency Preparedness share the responsibility for ensuringthat the ERO receives all necessary training and retraining.

In order to carry this out,responsibilities are assigned as follows:Station responsibilities for Station ERO personnel: " Station management shall ensure the attendance of onsite personnel for training, including required Emergency Planning courses.* The station shall conduct onsite emergency personnel initial and retraining for stationERO personnel using approved lesson plans." The Station Training Department shall provide those shift personnel included in acontinuing training program an annual review of the following items as a minimum:-Assembly Areas-ERF assignment -Potential Hazards (radiological and nonradiological) -Anticipated actions including assembly requirements, protective equipment requirements (clothing, masks, SCBA, etc.), the use of KI, emergency exposurelimits, and accountability requirements.

b. Initial and Requalification ERO Training:

The proficiency of emergency responsepersonnel (as defined in 10 CFR 50 Appendix E) is ensured by the following means:" Assigning individuals to emergency duties that are similar to those performed as a partof their regular work assignment or experience " Initial training and annual retraining on applicable generic and site-specific portions ofthe emergency plan and the corresponding implementing procedures. Individuals notdemonstrating the required level of knowledge in initial or retraining classes receiveadditional training on the areas requiring improvement. Annual retraining is conducted on a calendar year basis" Training on Emergency Plan changes shall be completed within 120 days ofimplementation of the change* Participation in exercises and/or drills as developed or authorized by the Emergency Preparedness Department and designed to sharpen those skills that they are expectedto use in the event of an actual emergency All personnel assigned position specific responsibilities in the ERO are documented byinclusion in the Emergency Planning Telephone Directory listing of positions and personnel. Page 120 of 4-9220EP-100 Rev Oxx Part 2: Planning Standards and CriteriaV.C. Summer Nuclear Stationc. Station Orientation Training (SOT): All personnel with unescorted station access areprovided with initial orientation training on the notification and instruction methods usedin the event of an emergency. Additionally, all badged individuals also receive initialorientation on the basic principles of radiological safety including the effects of radiation and the theory and use of radiation detection devices. Appropriate actions for escortedindividuals shall be the responsibility of the escort. SOT provides initial and annualrequalification training on the basic elements of the Emergency Plan for all personnel working at the plant. Specifically, these elements include:" Station emergency alarms and their meaning" Assembly areas" Site and exclusion area evacuation procedures

• Special precautions and limitations during an emergency
• Purpose of the Emergency PlanPage 121 of 4-93220EP-100 Rev Oxx Part2: Planning Standards and CriteriaV.C. Summer Nuclear StationSection P: Responsibility for the Maintenance of the Planning EffortThis section describes the responsibilities for development, review, and distribution of theEmergency Plan and actions that must be performed to maintain the Emergency Preparedness Program.

It also outlines the criteria for ensuring that personnel who perform the planning areproperly trained.1. Emergency Preparedness Staff TrainingThe Emergency Preparedness staff is involved in maintaining an adequate knowledge ofstate-of-the-art planning techniques and the latest applications of emergency equipment andsupplies. At least once each calendar year, each member of the Emergency Preparedness staff is involved in one of the following activities: " Training courses specific or related to emergency preparedness

• Observation of or participation in drills and/or exercises at other stations* Participation in industry review and evaluation programs aimed towards emergency preparedness programs/issues

" Participation in regional or national emergency preparedness

seminars, committees, workshops, or forums* Specific training courses in related areas, such as systems, equipment, operations, radiological protection, or problem identification and resolution

2. Authority for the Emergency Preparedness EffortThe Vice President, Nuclear Operations, is responsible for the safe and reliable operation ofthe VCSNS. The issuance and control of this Plan and the activities associated withemergency preparedness shall be the overall responsibility of the Vice President, NuclearOperations.

This individual is assigned the responsibility for overall implementation of theVCSNS Emergency Plan and Unit Annexes.3. Responsibility for Development and Maintenance of the PlanThe Manager-Emergency Planning and Supervisors-Emergency Services are responsible for the overall Emergency Preparedness Program associated with the operation of VCSNSand to administer the program to ensure availability of resources in the event of anemergency. Page 122 of 49-Q220EP-IO00 Rev Oxx Part 2: Planning Standards and CriteriaV.C. Summer Nuclear StationThe Manager, Emergency Planning is assisted by the station Emergency Preparedness Unitstaff. Specific responsibilities include the following: Program Administration " Develop and maintain the Emergency Plan, Appendices, Unit Annexes, implementing procedures and administrative documents " Develop and maintain 10 CFR 50.54(q) evaluations for changes to Emergency Plandocuments " Coordinate and maintain the Emergency Plan activities schedule" Develop and maintain working relationships and coordinate meetings with federal, state,and local agencies" Ensure integration of plans between the station and offsite agencies* Provide an opportunity to discuss EALs and the availability of SCE&G Quality SystemsGroup audit results relating to interface with govemmental agencies* Coordinate, negotiate, and maintain agreements and contracts with offsite agencies andsupport organizations

• Obtain Letters of Agreement with major medical facilities, and medical consultants specifically skilled in the medical aspects of radiation accidents resulting in excessive

exposure, contamination, and/or ingestion of radioactive materials

• Coordinate the development and annual distribution of the station's public information publication
• Coordinate and administer the self-assessment program to monitor and evaluate theadequacy of the Emergency Preparedness Program" Coordinate and support Emergency Plan audits and inspections
• Ensure the documentation and resolution of adverse conditions in the Emergency Preparedness Program discovered through drills, audits, etc. in accordance with theCorrective Action Program* Coordinate and develop Operational Experience responses as assigned* Coordinate,

document, and review Emergency Preparedness Performance Indicator dataand reports* Provide oversight of NRC Drill and Exercise Performance (DEP) evaluations duringLicense Operator Qualification and Requalification Training* Coordinate and conduct Emergency Plan Event reviews and reports" Maintain adequate documentation/files to support Emergency Plan activities Page 123 of 41-93220EP-100 Rev Gxx Part 2: Planning Standards and CriteriaV.C. Summer Nuclear Station" Develop and manage the Emergency Plan budget" Maintain the Emergency Planning Telephone Directory Drills and Exercises

" Coordinate and maintain the Emergency Plan drill and exercise schedule" Coordinate and conduct exercises and drills* Coordinate NRC, FEMA, state, and local exercise scheduling and development activities " Coordinate drill and exercise scenario development activities " Develop and publish drill and exercise scenario manuals" Coordinate and perform Controller and Evaluator functions for drills and exercises " Coordinate the selection and ensure the training of Controllers for onsite drills andexercises " Coordinate response cells for drills and exercises

• Maintain documentation of drill and exercise objectives demonstration and their results" Develop and issue drill and exercise reportsFacilities and Equipment
• Provide maintenance and administration of the Alert and Notification System (ANS)" Provide maintenance of the ERO Emergency Notification System" Ensure the ERFs are maintained in a constant state of readiness

" Coordinate and review the Emergency Plan equipment inventories " Coordinate and conduct maintenance and testing of the communications systems* Maintain the Emergency Plan computer applications Page 124 of 1-93220EP-100 Rev Oxx Part 2: Planning Standards and Criteria V.C. Summer Nuclear StationERO Qualification and Administration " Develop and maintain ERO lesson plans, examinations, and qualification records" Ensure through letters,

meetings, seminars, or other means available, that all affectedpersonnel in the ERO are informed of changes to the Emergency Plan and procedures

" Maintain Emergency Plan SOT content* Coordinate,

schedule, and conduct ERO qualification and requalification training" Oversee the maintenance of ERO training records* Maintain and coordinate publishing of the ERO duty rosters" Provide adequate oversight and support for the training of offsite response personnel

• Coordinate conduct of Emergency Medical Assistance Program training" Coordinate annual training for the mediaThe Vice President, Nuclear Operations is responsible for implementation of the Emergency Plan, with the General Manager, Nuclear Support Services overseeing the process.

TheGeneral Manager, Nuclear Support Services has the following responsibilities formaintenance of the Emergency Preparedness Program:" Ensure the adequate staffing and training of station ERO members" Schedule and conduct drills and exercises to maintain the state of readiness of theEmergency Preparedness Program* Ensure the operational readiness of station facilities and communication systems for useduring an emergency " Ensure the operational readiness of station emergency equipment and supplies ismaintained

• Ensure the Emergency Plan implementing procedures are maintained Page 125 of-1-94220 EP-100 Rev Oxx Part 2: Planning Standards and CriteriaV.C. Summer Nuclear Station4. Emergency Plan and Agreement Revisions The Emergency Plan, the Appendices and Unit Annexes, and supporting Agreements arereviewed on an annual basis. The annual Emergency Plan review/update includes requiredchanges, as directed by management, and those changes identified during audits,assessments,

training, drills, and exercises.

The Manager, Emergency Planning isresponsible for determining which recommended changes are incorporated into anEmergency Plan or emergency procedure revision. In those years when the review does notwarrant a revision, a letter or memorandum to that affect will be issued.The Emergency Plan and the Appendices and Unit Annexes shall be revised as needed andthe most current approved revisions shall remain in effect so long as they are verified ascurrent. Revisions to the Emergency Plan are reviewed by the Plant Safety ReviewCommittee before approval. Changes to the Plan are made without NRC approval only ifsuch changes do not reduce the effectiveness of the Plan in accordance with 10 CFR50.54(q), and the Plan as changed continues to meet the standards of 10 CFR 50.47(b) andthe requirements of 10 CFR 50, Appendix E. Proposed changes that reduce or have apotential to reduce the effectiveness of the approved Plan are not implemented without priorapproval by the NRC." Proposed revisions to the Emergency Plan, the Appendices, and Unit Annexes shall becompleted in accordance with the VCSNS review and approval processes. " Emergency Plan and the Appendices and Unit Annexes changes shall be categorized as(1) minor/administrative or (2) significant programmatic changes. Minor/administrative changes shall be implemented within 30 days of approval. Significant programmatic changes shall be implemented as soon as practical and within 90 days of final stationapproval. " After review and approval, the Emergency Plan and the Appendices and Unit Annexesshall be:a) Reviewed by the Manager, Emergency Planning or designeeb) Approved for use by the General Manager, Nuclear Plant Operations, or designee. " The Implementing Procedures shall be developed and revised concurrent with theEmergency Plan, Appendices, and Unit Annexes, and reviewed every two years.Annually, each Letter of Agreement is reviewed and certified current in order to ensure theavailability of assistance from each supporting organization not already a party to the SouthCarolina Operational Radiological Emergency Response Plan.5. Emergency Plan Distribution Emergency Plans, the Appendices, and Unit Annexes, and the implementing procedures aredistributed as necessary on a controlled basis to the ERFs. Electronic copies of documents are also available on the company's computer network. All controlled document holders areissued revision changes upon approval. Selected

federal, state, and local agencies, andother appropriate locations requiring them are also issued copies. Procedures are in placethat control the revision of the Emergency Plan.PAGE 126 OF 4-93220EP-1 00 Rev Oxx Part 2: Planning Standards and CriteriaV.C. Summer Nuclear Station6. Supporting Emergency Response PlansOther plans that support this Emergency Plan are:* NUREG-0728, U.S. NRC, "Concept of Operations:

NRC Incident Response"

National Response Framework

• South Carolina Operational Radiological Emergency Response Plan* Fairfield County Emergency Operations Plan* Newberry County Emergency Operations Plan* Richland County Emergency Operations Plan* Lexington County Emergency Operations Plan* State of North Carolina Emergency Response Plan for Nuclear Power Facilities
• DOE, Region 3, "Radiological Assistance Plan"* INPO Emergency Resources Manual* VCSNS Security Plan -Note: The Plan contains safeguards information that must bewithheld from public disclosure under provisions of 10 CFR 73.21.7. Implementing and Supporting Procedures Appendix 3 of this Plan contains a listing, by title, of those procedures that implement thisPlan during an emergency.

Additionally, administrative procedures that outline the stepstaken to maintain the VCSNS Emergency Preparedness Program have been developed andare also listed in Appendix 3.8. Cross-Reference to Planning CriteriaThe Plan is formatted in the same manner as NUREG-0654, "Criteria for Preparation andEvaluation of Radiological Emergency Response Plans and Preparedness in support ofNuclear Power Plants." The use of this format lends itself to uncomplicated comparison ofthe criteria set forth in NUREG-0654. Appendix 6 provides the cross reference for this Planto the criteria in NUREG-0654. PAGE 127 OF 4-9-220EP-1 00 Rev Oxx Part 2: Planning Standards and CriteriaV.C. Summer Nuclear Station9. Audit/Assessment of the Emergency Preparedness ProgramTo meet the requirements of 10 CFR 50.54(t), the Manager, Emergency Planning shallcoordinate an independent review of the Emergency Preparedness Program to examineconformance with 10 CFR 50.47, 10 CFR 50.54, and 10 CFR 50, Appendix E. Included inthe audit/assessment are the following: " The Emergency Plan and associated implementing procedures " The Emergency Preparedness Training

Program, including drills and exercises

• The readiness of the Station ERO to perform its function" The documents and programs used to direct and document the administrative portion ofthe Emergency Preparedness Program* The readiness of facilities and equipment to perform as outlined in the plan andprocedures
• The interfaces between VCSNS, the state, and county governmental agencies pertaining to the overall Emergency Preparedness ProgramThe Nuclear Safety Review Committee will ensure that an audit of the VCSNS Emergency Planning Program is performed at least once every 12 months.Results of this audit are submitted for review to the Vice President, Nuclear Operations.

TheManager, Emergency Planning ensures that any findings that deal with offsite interfaces arereviewed with the appropriate agencies. Written notification will be provided to the state andcounties regarding the results of the audit on the adequacy of interface with the state andlocal governments and the availability of the audit records for review at VCSNS.10. Maintenance of Emergency Telephone NumbersNames and phone numbers of the ERO, support personnel/agencies, and ERFs in theemergency plan implementing procedures and the Emergency Planning Telephone Directory shall be reviewed and updated at least quarterly. PAGE 128 OF 41-"220EP-IO00 Rev Oxx

Annex 1: Unit IV. C. Summer Nuclear StationAnnex 1: Unit ISection 1: Introduction This VCSNS Emergency Plan Annex provides unit specific details for Unit 1.This includes a unit description (type of reactor, relationship to other units, special emergency equipment), shift staffing, EALs, and any emergency facility locations which differ from thosedescribed in the Plan for a full understanding and representation of the Station's emergency response capabilities. This Unit 1 Annex is subject to the same review and audit requirements as the Radiation Emergency Plan.1.1 Unit 1 Description The VCSNS is owned jointly by SCE&G and Santee Cooper but is operated by SCE&G. Anarea map showing geographical location of the facility is provided on Figure 1-1 in Part 1 of theVCSNS Emergency Plan.Unit 1 uses a pressurized water reactor nuclear steam supply system, designed and furnished by Westinghouse Electric Corporation and a turbine generator, designed and furnished byGeneral Electric Company. The system uses chemical shim and control rods for reactivity control and U-tubed steam generators. A diagrFam identify'ing Unit 1 facilitic is provided in theUnit 1 Ann^.x Figure A! 1PAGE 129 OF 1-93220EP-100 Rev Oxx Annex 1: Unit 1V. C. Summer Nuclear StationAnnex 1: Unit I V. C. Summer Nuclear StationFigure Al-1: Unit I Facility Layout (specimen) PAGE 130 OF 4-91220EP-100 Rev Oxx Annex 1: Unit IV. C. Summer Nuclear StationSection 2: Organizational Control of Emergencies Section B of the Plan describes the station's ERO. When the ERO is fully activated, it will bestaffed as described in Section B of the Plan. This section and table of the Unit 1 Annexdescribes the on-shift ERO staffing and their responsibilities to implement the Plan.2.1 Normal Shift StaffingThe VCSNS operating organization includes the personnel encompassing both themanagement and operation of the unit. The maintenance and technical support personnel staffing the station organization are normally onsite daily Monday through Friday, holidaysexcluded. Plant personnel who are on duty on a 24-hour basis are listed in Table 2-1.The Shift Supervisors, one of whom is on duty at all times, are responsible for the safe andefficient operation of the plant in accordance with the Technical Specifications and operating procedures during their assigned shift. The duty Shift Supervisor maintains control over plantoperations as the senior licensed operator unless properly relieved by another member of thestation staff who holds a valid SRO License. The Control Room Supervisor maintains controlover the conduct of operations and personnel in the Control Room.Shift Engineers perform accident assessment and evaluate operating conditions. Organizationally, they report to the Manager-Operations. While on duty they diagnose off-normal events and report to the Shift Supervisor. The duties of the Shift Engineer do not includethe manipulation of controls or the supervision of operators. When on duty, he will be available to the Shift Supervisor in the Control Room within 10 minutes of being summoned. Duringemergency conditions, the Shift Engineer will report to the Control Room and perform the dutiessimilar to a Shift Technical Advisor (STA).During off-hour shifts, the plant is staffed to support continuous operation. The normaloperational staff includes (as a minimum) two licensed SROs (the Shift Supervisor and ControlRoom Supervisor), two licensed reactor operators, and five non-licensed operators. In addition, a Shift Engineer is assigned to each shift. The initial emergency organization during off-hours shifts consists of the operating staff, with the Shift Supervisor serving as the lED. The lED maybe relieved in the Control Room by another SRO qualified as an lED. Initial actions in regard tofirst aid, firefighting, rescue, damage control, radiation monitoring, emergency classification, notifications, and dose assessment are performed by the normal operational staff.2.2 Shift Emergency Response Positional Responsibilities The Unit 1 Annex, Table 2-1 outlines shift ERO positions required to meet minimum staffing andthe major tasks assigned to each position. PAGE 131 OF 1-93220EP-100 Rev Oxx Annex 1: Unit IV. C. Summer Nuclear StationTable 2-1: V. C. Summer On-Shift Staffing and ERO Positions MinimumShiftFunctional Area Major Tasks Shift Position Compliment ERO Position1. Plant Operations Control Room Shift Supervisor 1 Interim Emer. Dir.and Assessment Staff Control Room 1 Control Roomof Operational Supervisor Supervisor Aspects Reactor Operator 2 Reactor OperatorAuxiliary Operator 5 Auxiliary Operator2. Emergency Command and Shift Supervisor (a) Interim Emergency Direction and Control DirectorControl3. Notification & Emergency Shift Supervisor (a) Interim Emergency Communication Communications DirectorCommunicator 1 (e) State/County Communicator (e)4. Radiological Dose Health Physics 1 Health PhysicsAccident Assess./Health Specialist Specialist Assessment and PhysicsSupport of In-plant Surveys Health Physics 1 Health PhysicsOperational Specialist Specialist AccidentAssessment Chemistry Chemistry Specialist 1 Chemistry Specialist

5. Plant System Technical Shift Engineer 1 Shift EngineerEngineering, SupportRepair andCorrective Actions Repair and Mechanical Maint. Mechanical Maint.Corrective Mechanic 2 MechanicActions Electrical Maint. Electrical Maint.Electrician 42 Electrician Il&C Maint. I&C Maint. MechanicMechanic 426. In-Plant Protective Radiation Health Physics (b) Health PhysicsActions Protection Specialist Specialist

7. Fire Fighting

-Fire Brigade (c)(f) Fire Brigade8. First Aid and -Medical Emergency (b)(f) Plant Personnel Rescue Response TeamOperations

9. Site Access Security and Security Force (d) Security ForceControl and Accountability Personnel Accountability (a) The Shift Supervisor shall function as the lED until relieved by the Emergency

Director, Offsite Emergency

Manager, and Emergency Control Officer(b) May be provided by shift personnel assigned other functions (c) Per station Fire Protection Plan(d) Per VCSNS Security Plan(e) Telephone Communicator only(f) Support provided by offsite response organizations PAGE 132 OF 493220EP-1 00 Rev Oxx}}