JAFP-18-0039, James A. FitzPatrick Nuclear Power Plant - 2017 Annual Radioactive Effluent Release Report

James A. FitzPatrick Nuclear Power Plant - 2017 Annual Radioactive Effluent Release Report

ML18122A345
Person / Time
Site:	FitzPatrick
Issue date:	04/30/2018
From:	William Drews Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
JAFP-18-0039
Download: ML18122A345 (164)

Text

Exelon Generation Company LLCJames A. FitzPatrick NPP P.O. Box 110 Lycoming, NY 13093

JAFP-18-0039

April 30, 2018

United States Nuclear Regulatory Commission

Attn: Document Control Desk

Washington, D.C. 20555-0001

James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333

SUBJECT:

2017 Annual Radioactive Effluent Release Report

Dear Sir or Madam:

This letter transmits the James A. FitzPatrick Nuclear Power Plant's (JAF) Annual Radioactive Effluent Release Report for the period of January 1, 2017 through December 31, 2017. The enclosure is submitted in accordance with 10 CFR 50.36a and the Reporting Requirements of Technical Specifications Section 5.6.3 and Technical Requirements Manual Appendix H, Offsite

Dose Calculation Manual (ODCM), Part 1 Section 6.2, Radioactive Effluent Release Report.

This report (Enclosure 1) includes, as an Addendum, an Assessment of the Radiation Doses to the Public due to the radioactive liquid and gaseous effluents released during the 2017 calendar year. The format used for the effluent data is outlined in Appendix B of Regulatory Guide 1.21, Revision 1. Distribution is in accordance with Regulatory Guide 10.1, Revision 4.

Included in this letter are the procedures associated with changes in the Process Control

Program (Enclosure 2).

There are no new regulatory commitments contained in this letter.

William C. Drews Regulatory Assurance Manager - JAF JAFP-18-0039 Page 2 of 2 If you have any questions concerning the enclosed report, please contact Mr. Jeff Gerber, Chemistry Manager, at (315) 349-6635.

Sincerely, c >>----William C. Drews Regulatory Assurance Manager -JAF WCD/JG/dc Enclosure 1: Annual Radioactive Effluent Release Report, January 1 -December 31, 2017 Enclosure 2: Process Control Program Procedure Changes cc: Regional Administrator, Region I U.S. Nuclear Regulatory Commission 2100 Renaissance Blvd., Suite 100 King of Prussia, PA 19406-2713

' Resident Inspector's Office U.S. Nuclear Regulatory Commission James A. FitzPatrick Nuclear Power Plant P.O. Box 136 Lycoming, NY 13093 Tanya Hood NRC Project Manager J. Gerber (CHEM/JAF)

B. Landers (CHEM/JAF)

K. Stoffle (NMP)

JAFP-18-0039

Enclosure 1

Annual Radioactive Effluent Release Report January 1 - December 31, 2017 (38 Pages)

EXELON FITZPATRICK, LLC JAMES A. FITZPATRICK NUCLEAR POWER PLANT ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT

JANUARY 1, 2017 - DECEMBER 31, 2017

DOCKET NO. 50-333 LICENSE NO. DPR-59

EXELON FITZPATRICK, LLC JAMES A. FITZPATRICK NUCLEAR POWER PLANT ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY 2017 - DECEMBER 2017 1 SUPPLEMENTAL INFORMATION

FACILITY: JAFNPP LICENSEE: EXELON FITZPATRICK, LLC

1. Offsite Dose Calculation Manual Part 1 Radiological Effluent Controls a. Fission and Activation Gases:

(1) The dose rate at or beyond the site boundary due to radioactive materials released from the plant in gaseous effluent shall be limited as follows:

(a) Less than or equal to 500 mrem/year to the whole body and less than or equal to 3000 mrem/year to the skin from noble gases.

(2) The air dose to areas at or beyond the site boundary from noble gases released from the plant in gaseous effluent shall be limited:

(a) During any calendar quarter, to less than or equal to 5 mrad from gamma radiation, and less than or equal to 10 mrad from beta radiation; and, (b) During any calendar year, to less than or equal to 10 mrad from gamma radiation and less than or equal to 20 mrad from beta radiation.

b. Tritium, Iodines and Particulates, Half Lives > 8 days:

(1) The dose to a member of the public at or beyond the site boundary from Iodine-131, Iodine-133, Tritium, and radionuclides in particulate form with half-lives greater than 8 days released from the plant in gaseous effluent shall be limited:

(a) During any calendar quarter to less than or equal to 7.5 mrem to any organ; and,

(b) During any calendar year to less than or equal to 15 mrem to any organ.

(c) Less than 0.1% of the limits of ODCM Part 1, Section 3.4 Specification 3.4.1.c.1.a and 3.4.1.c.1.b as a result of burning contaminated oil.

(2) The dose rate at or beyond the site boundary due to radioactive materials released from the plant in gaseous effluents shall be limited as follows:

(a) Less than or equal to 1500 mrem/year to any organ from Iodine-131, Iodine-133, Tritium and for radioactive materials in particulate form with half-lives greater than 8 days (inhalation pathway only).

EXELON FITZPATRICK, LLC JAMES A. FITZPATRICK NUCLEAR POWER PLANT ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY 2017 - DECEMBER 2017 2 SUPPLEMENTAL INFORMATION (continued)

c. Liquid Effluents:

(1) The concentration of radioactive materials released to the unrestricted areas shall not exceed ten times the values specified in 10 CFR 20.1001-20.2402, Appendix B, Table 2, column 2. For dissolved or entrained noble gases the concentration shall be limited to 2.00E-04 Ci/ml.

(2) The dose to a member of the public from radioactive materials released from the plant in liquid effluents to unrestricted areas shall be limited as follows:

(a) During any calendar quarter, limited to less than or equal to 1.5 mrem to the whole body and to less than or equal to 5 mrem to any organ; and, (b) During any calendar year, limited to less than or equal to 3 mrem to the whole body and to less than or equal to 10 mrem to any organ.

2. 10X Effluent Concentrations

a. Fission and activation gases: (None specified)

b. Iodines: (None specified)

c. Particulates, half-lives >8 days: (None specified)

d. Liquid effluents: Quarter 1 Quarter 2 Quarter 3 Quarter 4

(1) Fission and activation None None None None products (mixture EC)

(Ci/ml) (2) Tritium (Ci/ml) 1.00E-02 1.00E-02 1.00E-02 1.00E-02

(3) Dissolved and entrained gases (Ci/ml) 2.00E-04 2.00E-04 2.00E-04 2.00E-04

EXELON FITZPATRICK, LLC JAMES A. FITZPATRICK NUCLEAR POWER PLANT ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY 2017 - DECEMBER 2017 3 SUPPLEMENTAL INFORMATION (continued)

3. Average Energy (None specified)

4. Measurements and Approximations of Total Radioactivity

a. Fission and Activation Gases: Continuous monitor on each release path calibrated to a marinelli grab sample analyzed by gamma spectroscopy; bubbler grab sample analyzed for Tritium.

b. Iodines: Gamma spectral analysis of charcoal cartridge and particulate filter on each release path.

c. Particulates: Gamma spectral analysis of each particulate filter and charcoal cartridge for each release path. A four week per quarter composite of particulate filters for each release path for Strontium-89 and Strontium-90. One week per month particulate filter for each release path for

gross alpha.

d. Liquid Effluents: Gamma spectral analysis of each batch discharged, except composite analysis for Strontium-89, Strontium-90, Iron-55, Tritium, and Alpha.

e. Solid Waste: Gamma spectral analysis of a representative sample of each waste shipment. Scaling factors established from offsite composite sample analyses to estimate concentration of non-gamma emitters. Low activity trash shipments curie content is estimated by dose rate measurement and

application of appropriate scaling factors.

f. Error Estimation Method: Overall error for sampling and analysis estimated by combining individual errors using error propagation methods. This process is composed of determinate and undeterminate errors.

Determinate - Pump flowrates, volume measurements and analysis collection yields Undeterminate - Random counting error estimated using accepted statistical calculations

EXELON FITZPATRICK, LLC JAMES A. FITZPATRICK NUCLEAR POWER PLANT ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY 2017 - DECEMBER 2017 4 SUPPLEMENTAL INFORMATION (continued)

5. Batch Releases

a. Liquid: Canal Quarter 1 Quarter 2 Quarter 3 Quarter 4 (1) Number of batch releases: 1.00E+00 0.00E+00 0.00E+00 2.00E+00

(2) Total time period for batch 8.70E+01 0.00E+00 0.00E+00 3.50E+01 release: (min)

(3) Maximum time period for 8.70E+01 0.00E+00 0.00E+00 3.10E+01 batch release: (min)

(4) Average time period for 8.70E+01 0.00E+00 0.00E+00 1.75E+01 batch release: (min)

(5) Minimum time period for 8.70E+01 0.00E+00 0.00E+00 4.00E+00 batch release: (min)

(6) Total Activity Released (Ci) 1.36E-06 0.00E+00 0.00E+00 8.51E-05

(7) Total Volume Released (liters) 1.32E+03 0.00E+00 0.00E+00 1.32E+04

b. Liquid: Non-Canal Quarter 1 Quarter 2 Quarter 3 Quarter 4 (1) Number of batch releases: 3.00E+01 5.30E+01 1.08E+02 5.74E+02

(2) Total time period for batch 2.87E+02 1.32E+02 2.31E+02 1.83E+03 release: (min)

(3) Maximum time period for 1.68E+02 4.00E+00 1.30E+01 2.65E+02 batch release: (min)

(4) Average time period for 9.57E+00 2.49E+00 2.14E+00 3.20E+00 batch release: (min)

(5) Minimum time period for 1.00E+00 1.00E+00 1.00E+01 1.00E+00 batch release: (min)

(6) Total Activity Released (Ci) 0.00E+00 0.00E+00 1.51E-04 0.00E+00

(7) Total Volume Released (liters) 1.63E+05 7.40E+04 8.73E+04 6.94E+05

c. Gaseous There were no gaseous batch releases for this report period.

EXELON FITZPATRICK, LLC JAMES A. FITZPATRICK NUCLEAR POWER PLANT ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY 2017 - DECEMBER 2017 5 SUPPLEMENTAL INFORMATION (continued)

6. Continuous Releases

a. Liquid: Non-Canal Quarter 1 Quarter 2 Quarter 3 Quarter 4 (1) Number of releases: 1.40E+01 1.40E+01 1.40E+01 1.40E+01

(2) Total Activity Released (Ci) 2.09E-02 1.18E-02 9.94E-03 9.96E-03

(3) Total Volume Released (liters) 7.20E+06 7.09E+06 6.75E+06 6.03E+06

b. Liquid: Canal Quarter 1 Quarter 2 Quarter 3 Quarter 4 (1) Number of releases: 0 0 0 0

(2) Total Activity Released (Ci) N/A N/A N/A N/A

EXELON FITZPATRICK, LLC JAMES A. FITZPATRICK NUCLEAR POWER PLANT ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY 2017 - DECEMBER 2017 6 TABLE 1A GASEOUS EFFLUENTS - SUMMATION OF ALL RELEASES EST TOTAL UNIT QTR 1 QTR 2 QTR 3 QTR 4 ERROR %

A. FISSION AND ACTIVATION GASES 1. Total Release Ci 1.98E+01 1.26E+02 9.44E+01 1.80E+02 2.50E+01 2. Average release rate for period Ci/sec 2.54E+00 1.61E+01 1.19E+01 2.26E+01 3. Percentage ODCM Limit % * * *

• B. IODINE-131 1. Total Iodine-131 Ci 1.97E-04 2.02E-04 8.85E-05 7.08E-05 2.50E+01 2. Average release rate for period Ci/sec 2.53E-05 2.57E-05 1.11E-05 8.91E-06 3. Percentage ODCM Limit % * * *

• C. PARTICULATES 1. Particulates with half-lives >8 days Ci 8.86E-05 4.46E-06 3.13E-05 2.27E-06 3.60E+01 2. Average release rate for period Ci/sec 1.14E-05 5.68E-07 3.94E-06 2.86E-07 3. Percentage ODCM Limit % * * *

• 4. Gross alpha radioactivity Ci 1.58E-07 2.38E-07 1.53E-07 2.39E-07 2.50E+01 D. TRITIUM 1. Total Release Ci 5.39E+00 3.36E+00 6.65E+00 7.76E+00 2.50E+01 2. Average release rate for period Ci/sec 6.93E-01 4.28E-01 8.36E-01 9.76E-01 3. Percentage ODCM Limit % * * *

• E. CARBON-14 (See Attachment 8)

• F. PERCENT OF APPLICABLE ODCM LIMITS FISSION AND ACTIVATION GASES UNIT QTR 1 QTR 2 QTR 3 QTR 4 1. Quarterly gamma air dose limit % 1.17E-02 4.08E-02 3.28E-02 4.35E-02 2. Quarterly beta air dose limit % 7.37E-04 2.95E-03 2.32E-03 3.17E-03

3. Yearly gamma air dose limit % 5.84E-03 2.04E-02 1.64E-02 2.17E-02

4. Yearly beta air dose limit % 3.68E-04 1.47E-03 1.16E-03 1.58E-03

5. Whole body dose rate limit % 9.25E-03 5.27E-02 2.59E-02 3.96E-03

6. Skin dose rate limit % 1.98E-03 1.15E-02 5.62E-03 8.52E-04 HALOGENS, TRITIUM AND PARTICULATES WITH HALF-LIVES >8 DAYS 7. Quarterly dose limit (organ) % 3.41E-02 2.65E-02 1.53E-02 1.56E-02 8. Yearly dose limit (organ) % 1.70E-02 1.33E-02 7.67E-03 7.78E-03

9. Organ dose rate limit % 4.48E-05 1.24E-05 2.22E-05 2.45E-05 EXELON FITZPATRICK, LLC JAMES A. FITZPATRICK NUCLEAR POWER PLANT ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY 2017 - DECEMBER 2017 7 TABLE 1B GASEOUS EFFLUENTS - ELEVATED RELEASE CONTINUOUS MODE NUCLIDES RELEASED

1. Fission Gases UNIT QUARTER 1 QUARTER 2 QUARTER 3 QUARTER 4 Argon-41 Ci 5.46E+00 8.12E+00 7.54E+00 4.19E+00 Krypton-85 Ci ND ND ND ND Krypton-85m Ci 1.12E+00 1.42E+01 1.20E+01 3.39E+01 Krypton-87 Ci 1.66E+00 6.90E+00 5.77E+00 2.11E+00 Krypton-88 Ci 2.20E+00 1.96E+01 1.43E+01 3.01E+01 Krypton-89 Ci 3.17E-02 ND ND ND Xenon-133 Ci 2.94E-03 4.99E+01 3.40E+01 1.06E+02 Xenon-133m Ci ND 7.97E-01 2.39E-01 ND Xenon-135 Ci 1.64E+00 1.63E+01 9.13E+00 1.62E-01 Xenon-135m Ci 1.66E+00 4.10E+00 4.35E+00 5.80E-01 Xenon-137 Ci 6.66E-02 ND ND ND Xenon-138 Ci 5.93E+00 6.46E+00 7.17E+00 ND

TOTAL Ci 1.98E+01 1.26E+02 9.44E+01 1.77E+02

2. Iodines

Iodine-131 Ci 8.72E-05 1.89E-04 4.16E-05 1.38E-05 Iodine-132 Ci 4.36E-04 4.06E-05 ND ND Iodine-133 Ci 1.80E-03 7.68E-04 5.19E-05 3.57E-05 Iodine-134 Ci 8.89E-04 ND ND ND Iodine-135 Ci 2.71E-03 2.89E-04 ND ND

TOTAL Ci 5.92E-03 1.29E-03 9.35E-05 4.95E-05

3. Particulates Barium-140 Ci ND ND ND ND Cobalt-60 Ci 5.57E-07 ND ND ND Cesium-137 Ci ND ND 2.13E-07 ND Manganese-54 Ci 3.02E-07 ND ND ND Strontium-89 Ci 2.82E-07 1.43E-06 3.99E-06 2.27E-06 Zinc-65 Ci ND ND 1.25E-06 ND TOTAL Ci 1.14E-06 1.43E-06 5.45E-06 2.27E-06

4. Tritium Hydrogen-3 Ci 3.28E-01 6.75E-01 6.19E-01 3.03E-01 Note: There were no batch releases for this report period.

EXELON FITZPATRICK, LLC JAMES A. FITZPATRICK NUCLEAR POWER PLANT ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY 2017 - DECEMBER 2017 8 TABLE 1C GASEOUS EFFLUENTS - GROUND LEVEL RELEASES CONTINUOUS MODE NUCLIDES RELEASED

1. Fission Gases UNIT QUARTER 1 QUARTER 2 QUARTER 3 QUARTER 4 Argon-41 Ci ND ND ND ND Krypton-85 Ci ND ND ND ND Krypton-85m Ci ND ND ND ND Krypton-87 Ci ND ND ND ND Krypton-88 Ci ND ND ND ND Xenon-133 Ci 8.17E-04 2.33E-02 1.80E-03 1.19E-02 Xenon-133m Ci ND ND ND ND Xenon-135 Ci 1.84E-03 2.84E-02 1.08E-03 1.52E-02 Xenon-135m Ci ND 8.35E-04 ND 2.78E-03 Xenon-137 Ci ND ND ND ND Xenon-138 Ci ND ND ND ND

TOTAL Ci 2.66E-03 5.25E-02 2.88E-03 2.99E-02

2. Iodines Iodine-131 Ci 1.10E-04 1.29E-05 4.69E-05 5.70E-05 Iodine-132 Ci ND ND ND ND Iodine-133 Ci 5.49E-05 9.87E-05 1.62E-04 3.05E-04 Iodine-134 Ci ND ND ND ND Iodine-135 Ci ND ND ND ND

TOTAL Ci 1.64E-04 1.12E-04 2.09E-04 3.62E-04

3. Particulates Chromium-51 Ci 1.22E-05 ND 1.42E-05 ND Cobalt-58 Ci ND ND 1.09E-06 ND Cobalt-60 Ci 1.36E-05 ND 3.13E-06 ND Manganese-54 Ci 1.53E-05 3.03E-06 5.48E-06 ND Iron-59 Ci 5.49E-06 ND 1.96E-06 ND Strontium-89 Ci ND ND ND ND Zinc-65 Ci 4.09E-05 ND ND ND TOTAL Ci 8.75E-05 3.03E-06 2.59E-05 ND

4. Tritium Hydrogen-3 Ci 5.06E+00 2.69E+00 6.03E+00 7.45E+00 Note: There were no batch releases for this report period.

EXELON FITZPATRICK, LLC JAMES A. FITZPATRICK NUCLEAR POWER PLANT ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY 2017 - DECEMBER 2017 9 TABLE 2A LIQUID EFFLUENTS - SUMMATION OF ALL RELEASES EST TOTAL UNIT QTR 1 QTR 2 QTR 3 QTR 4 ERROR %

A. FISSION AND ACTIVATION PRODUCTS 1. Total Release (not including tritium, gases and alpha) Ci ND ND ND ND NA

2. Average diluted concentration during period Ci/ml ND ND ND ND 3. Percentage ODCM Limit  % NA NA NA NA

B. TRITIUM 1. Total Release Ci 2.09E-02 1.18E-02 1.01E-02 1.00E-02 2.50E+01 2. Average diluted concentration during period (Note 1) Ci/ml 2.84E-06 1.64E-06 1.48E-06 1.46E-06 3. Percentage ODCM Limit  % * * *

• C. DISSOLVED AND ENTRAINED GASES 1. Total Release Ci ND ND ND ND NA

2. Average diluted concentration during period Ci/ml ND ND ND ND

3. Percentage ODCM Limit % NA NA NA NA

D. GROSS ALPHA RADIOACTIVITY 1. Total Release Ci ND 4.95E-08 ND ND 4.20E+01 E. VOLUME OF WASTE RELEASED (PRIOR TO DILUTION) liters 7.36E+06 7.17E+06 6.84E+06 6.80E+06 F. VOLUME OF DILUTION WATER USED DURING PERIOD liters 5.93E+06 0 0 5.64E+07 G. PERCENT OF APPLICABLE ODCM LIMITS 1. Quarterly Whole Body Dose % 6.26E-05 3.45E-05 7.36E-05 3.04E-05 2. Quarterly Organ Dose % 1.88E-05 1.04E-05 2.21E-05 9.11E-06

3. Annual Whole Body Dose % 3.13E-05 1.73E-05 3.68E-05 1.52E-05

4. Annual Organ Dose % 9.39E-06 5.18E-06 1.10E-05 4.55E-06

Note 1: Concentration includes summation from diluted and undiluted values from Canal and Non-Canal releases (Table 2B).

EXELON FITZPATRICK, LLC JAMES A. FITZPATRICK NUCLEAR POWER PLANT ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY 2017 - DECEMBER 2017 10 TABLE 2B LIQUID EFFLUENTS CANAL BATCH MODE NUCLIDES RELEASED UNIT QUARTER 1 QUARTER 2 QUARTER 3 QUARTER 4

1. Fission and Activation Products

ND Ci ND ND ND ND

2. Tritium Hydrogen-3 Ci 1.36E-06 ND ND 8.51E-05

3. Dissolved and Entrained Gases

ND Ci ND ND ND ND

TABLE 2B LIQUID EFFLUENTS CANAL CONTINUOUS MODE NUCLIDES RELEASED UNIT QUARTER 1 QUARTER 2 QUARTER 3 QUARTER 4

1. Fission and Activation Products

ND Ci ND ND ND ND

2. Tritium Hydrogen-3 Ci ND ND ND ND

3. Dissolved and Entrained Gases

ND Ci ND ND ND ND

EXELON FITZPATRICK, LLC JAMES A. FITZPATRICK NUCLEAR POWER PLANT ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY 2017 - DECEMBER 2017 11 TABLE 2B (SUPPLEMENT)

LIQUID EFFLUENTS NON-CANAL CONTINUOUS MODE NUCLIDES RELEASED UNIT QUARTER 1 QUARTER 2 QUARTER 3 QUARTER 4

1. Fission and Activation Products

ND Ci ND ND ND ND

2. Tritium Hydrogen-3 Ci 2.09E-02 1.18E-02 9.94E-03 9.96E-03

3. Dissolved and Entrained Gases ND Ci ND ND ND ND

EXELON FITZPATRICK, LLC JAMES A. FITZPATRICK NUCLEAR POWER PLANT ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY 2017 - DECEMBER 2017 12 TABLE 2B (SUPPLEMENT)

LIQUID EFFLUENTS NON-CANAL BATCH MODE NUCLIDES RELEASED UNIT QUARTER 1 QUARTER 2 QUARTER 3 QUARTER 4

1. Fission and Activation Products

ND Ci ND ND ND ND

2. Tritium Hydrogen-3 Ci ND ND 1.51E-04 ND

3. Dissolved and Entrained Gases ND Ci ND ND ND ND

EXELON FITZPATRICK, LLC JAMES A. FITZPATRICK NUCLEAR POWER PLANT ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY 2017 - DECEMBER 2017 13 TABLE 2B (continued)

ABNORMAL RELEASE LIQUID EFFLUENTS CANAL CONTINUOUS MODE NUCLIDES RELEASED UNIT QUARTER 1 QUARTER 2 QUARTER 3 QUARTER 4

1. Fission and Activation Products ND Ci ND ND ND ND

2. Tritium ND Ci ND ND ND ND

3. Dissolved and Entrained Gases ND Ci ND ND ND ND

EXELON FITZPATRICK, LLC JAMES A. FITZPATRICK NUCLEAR POWER PLANT ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY 2017 - DECEMBER 2017 14 TABLE 3A SOLID WASTE AND IRRADIATED FUEL SHIPMENTS A. SOLID WASTE SHIPPED OFFSITE FOR BURIAL OR DISPOSAL (NOT IRRADIATED FUEL)

EST. TOTAL 1. Type of Waste UNIT CLASS A CLASS B CLASS C ERROR %

a. Spent resins, filter sludges, m 3 8.55E+01 0.00E+00 0.00E+00 1.00E+01 evaporator bottoms, etc. Ci 6.37E+01 0.00E+00 0.00E+00 1.00E+01

b. Dry compressible waste, m 3 2.17E+03 0.00E+00 0.00E+00 1.00E+01 contaminated equipment, etc. Ci 3.05E+00 0.00E+00 0.00E+00 1.00E+01

c. Irradiated components, m 3 0.00E+00 0.00E+00 0.00E+00 1.00E+01 control rods, etc. Ci 0.00E+00 0.00E+00 0.00E+00 1.00E+01

d. Other: Dry compressible m 3 1.49E+02 0.00E+00 0.00E+00 1.00E+01 waste, contaminated equipment, Ci 1.74E-02 0.00E+00 0.00E+00 1.00E+01 spent resins for volume reduction.

2. Estimate of Major Nuclide Composition (by type of waste)

a. Spent resins, filter sludges, evaporator bottoms, etc.

Isotope Percent Curies Fe-55 1.44E+01 9.17E+00 E Co-60 1.93E+01 1.23E+01 E Cs-137 3.26E+00 2.08E+00 E Mn-54 7.16E+00 4.56E+00 E Ni-63 3.88E+00 2.48E+00 E Zn-65 5.17E+01 3.29E+01 E

b. Dry compressible waste, contaminated equipment, etc.

Isotope Percent Curies Fe-55 7.41E+01 2.26E+00 E Co-60 1.05E+01 3.21E-01 E Cs-137 1.10E+00 3.35E-02 E Mn-54 5.77E+00 1.76E-01 E Ni-63 1.89E+00 5.76E-02 E Zn-65 5.77E+00 1.76E-01 E

(E- Estimated M- Measured)

EXELON FITZPATRICK, LLC JAMES A. FITZPATRICK NUCLEAR POWER PLANT ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY 2017 - DECEMBER 2017 15 TABLE 3A (continued)

SOLID WASTE AND IRRADIATED FUEL SHIPMENTS

c. Irradiated components, control rods, etc.

None

d. Other: Dry compressible waste, contaminated equipment, spent resins, contaminated oil, glycol and water for volume reduction.

Isotope Percent Curies H-3 2.33E+01 4.04E-03 E Co-60 2.89E+00 5.02E-04 E Cs-137 7.38E+01 1.28E-02 E

(E- Estimated M- Measured)

Percentage of nuclides and total activities are based on a combination of direct measurements and scaling for non-gamma emitting nuclides.

EXELON FITZPATRICK, LLC JAMES A. FITZPATRICK NUCLEAR POWER PLANT ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY 2017 - DECEMBER 2017 16 TABLE 3A (continued)

SOLID WASTE AND IRRADIATED FUEL SHIPMENTS

3. Solid Waste Disposition No. of Shipments Mode of Transportation Destination

55 Trucks *Energy Solutions Oak Ridge, TN

8 Trucks *Energy Solutions Kingston, TN

14 Trucks Energy Solutions, Clive , UT

• Volume Reduction Facility

B. IRRADIATED FUEL SHIPMENTS (Disposition)

No. of Shipments Mode of Transportation Destination

None ----------- ---------------

EXELON FITZPATRICK, LLC JAMES A. FITZPATRICK NUCLEAR POWER PLANT ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY 2017 - DECEMBER 2017 17 TABLE 3B SOLID WASTE AND IRRADIATED FUEL SHIPMENTS A. NRC CLASS A SOURCE OF PROCESSING CONTAINER TYPE OF NUMBER OF WASTE EMPLOYED VOLUME CONTAINER CONTAINERS

Dry compressible Waste (DAW), Non-compacted 1280 ft 3 (36.2m 3) STC 66 Contaminated Equipment, etc.

Dry compressible Waste (DAW), Non-compacted 96 ft 3 (2.72m 3) STC 22 Contaminated Equipment, etc.

Dry compressible Waste (DAW), Non-compacted 99 ft 3 (2.80m 3) STC 1 Contaminated Equipment, etc.

Dry compressible Non-compacted 1033.5 ft 3 (29.3m 3) STC 7 Waste(DAW),

Contaminated Equipment etc.

Dry compressible Non-compacted 217 ft 3 (6.14m 3) STC 1 Waste(DAW),

Contaminated Equipment etc.

Spent Resins, Filter Sludges, evaporator Air Drying 205.8 ft 3 (5.83m 3) HIC 18 Bottoms, etc. Non-compacted

Spent Resins, Filter Sludges, evaporator Air Drying 121.0 ft 3 (3.43m 3) HIC 4 Bottoms, etc. Non-compacted

Contaminated Oil/Water. Non-compacted 1280 ft 3 (36.2m 3) STC 1

Dry compressible Non-compacted 1335.05 ft 3 (37.8m 3) STC 1 Waste(DAW),

Contaminated Equipment etc.

Dry compressible Non-compacted 1504.1 ft 3 (42.6m 3) STC 1 Waste(DAW),

Contaminated Equipment etc. HIC-High Integrity Contai ner, STC-Strong Tight Container EXELON FITZPATRICK, LLC JAMES A. FITZPATRICK NUCLEAR POWER PLANT ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY 2017 - DECEMBER 2017 18 B. NRC CLASS B SOURCE OF PROCESSING CONTAINER TYPE OF NUMBER OF WASTE EMPLOYED VOLUME CONTAINER CONTAINERS

None C. NRC CLASS C SOURCE OF PROCESSING CONTAINER TYPE OF NUMBER OF WASTE EMPLOYED VOLUME CONTAINER CONTAINERS None HIC-High Integrity Container, STC-St rong Tight Container

EXELON FITZPATRICK, LLC JAMES A. FITZPATRICK NUCLEAR POWER PLANT ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY 2017 - DECEMBER 2017 19 ATTACHMENT NO. 1 CHANGES TO THE OFFSITE DOSE CALCULATION MANUAL (ODCM)

In accordance with the James A. FitzPatrick Nuclear Power Plant Offsite Dose Calculation Manual (ODCM), Part 1 Radiological Effluent Controls (REC) Section 6.2.3, changes made to the Offsite Dose Calculation Manual (ODCM) during the reporting period shall be included in

the Annual Radioactive Effluent Release Report.

The latest revision of the ODCM (Rev. 14) became effective during calendar year 2016. There

were no changes to the ODCM in 2017.

EXELON FITZPATRICK, LLC JAMES A. FITZPATRICK NUCLEAR POWER PLANT ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY 2017 - DECEMBER 2017 20 ATTACHMENT NO. 2

SUMMARY

OF CHANGES TO THE PROCESS CONTROL PROGRAM In accordance with the James A. FitzPatrick Nuclear Power Plant Offsite Dose Calculation Manual (ODCM), Part 1 Radiological Effluent Controls Section 6.2.3, changes made to the Process Control Program (PCP) during the reporting period shall be included in the Annual

Radioactive Effluent Release Report.

EN-RW-105 Rev. 5, Process Control Program (issued 8/27/15).

RW-AA-100 Rev. 12, Process Control Program for Radioactive Wastes (issued 9/26/17),

supersedes EN-RW-105.

EN-RW-102 Rev. 14, Radioactive Shipping Procedure RW-AA-600 Rev. 1, Guidelines for Tracking Processed Liners (issued 9/5/17), supersedes EN-RW-102.

EN-RW-106 Rev. 5, Integrated Transportation Security Plan EN-RW-106 Rev. 6, Integrated Transportation Security Plan (issued 1/5/17)

EN-RW-106 Rev. 7, Integrated Transportation Security Plan (issued 5/23/17)

EN-RW-108, Rev. 2, Radioactive Shipment Accident Response

OP-AA-106-102 Rev. 7, Accidents Involving the Transportation of Rad Materials (issued 9/7/17), supersedes EN-RW-108.

EXELON FITZPATRICK, LLC JAMES A. FITZPATRICK NUCLEAR POWER PLANT ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY 2017 - DECEMBER 2017 21 ATTACHMENT NO. 3

SUMMARY

OF CHANGES TO THE ENVIRONMENTAL MONITORING AND DOSE CALCULATION LOCATIONS In accordance with the James A. FitzPatrick Nuclear Power Plant Offsite Dose Calculation Manual (ODCM), Part 1, Radiological Effluent Controls Section 6.2.3 a listing of new locations for dose calculation and/or environmental monitoring identified by the land use census shall be

included in the Annual Radioactive Effluent Release Report.

During the reporting period, no changes in Dose Calculation Receptor Locations and/or the Environmental Monitoring were required based on the results of the land use census.

The following garden sample locations were added in 2017 as measured from the Nine Mile Point Unit 2 Reactor centerline. Sample location #240 located in the East Sector at 96 degrees and 1.86 miles. Sample location #69 in the East-South-East Sector at 124 degrees and 2.29 miles. Gardens were selected based on samples available, sector and deposition (D/Q) values.

EXELON FITZPATRICK, LLC JAMES A. FITZPATRICK NUCLEAR POWER PLANT ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY 2017 - DECEMBER 2017 22 ATTACHMENT NO. 4 DEVIATIONS FROM THE REQUIRED ENVIRONMENTAL SAMPLING SCHEDULE In accordance with the James A. FitzPatrick Nuclear Power Plant Offsite Dose Calculation Manual (ODCM), Part 1, Radiological Effluent Controls Section 6.2.7, the cause for the unavailability of any environmental samples required during the report period shall be included in

the Annual Radioactive Effluent Release Report.

The following reports samples that were a deviation from the requirements of ODCM Part 1, Table 5.1-1. ODCM Part Section 5.1.1.c.1 allows for deviations from the program due to hazardous conditions, seasonal unavailability, theft, uncooperative residents, or to a malfunction of automatic sampling equipment.

A. ODCM Program Deviations The following are deviations from the program specified by the ODCM:

17FI-461 Turbine Building Iodine and Particulate Sampler Flow Indicator failed bench calibration on 12/28/16. Due to the lack of replacement parts, compensatory actions were taken to maintain required sample flow and representative sampling capabilities. Once replacement flow indicator was obtained, validated and installed the permanent plant equipment was restored to

service on 5/2/17.

17RM-351 Normal Service Water Radiation Monitor was declared inoperable on 5/11/17 due to sporadic low flow alarms during load drops. Chemistry initiated required compensatory sampling for an inoperable Normal Service Water Radiation Monitor. Multiple troubleshooting efforts were made but without conclusive results. Decision was made to change out 17FIT-10 Normal Service Water Radiation Flow Indicator. The existing flow indicator was obsolete and an Engineering Change Request was processed to install an updated style flow indicator. 17FIT-10 was replaced, calibrated and monitored prior to being

declared operable on 7/13/2017.

Groundwater Monitoring Well #8 well casing was found damaged on 5/17/17. This allowed surface water to enter Groundwater Monitoring Well #8 contents.

Well casing was repaired and a new j-plug installed on 6/7/2017. Groundwater Monitoring Well #8 was pumped and validated to be recharging on 6/27/17. This allowed a valid third quarter 2017 sample to be obtained from Groundwater Monitoring Well #8.

EXELON FITZPATRICK, LLC JAMES A. FITZPATRICK NUCLEAR POWER PLANT ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY 2017 - DECEMBER 2017 23 The following are deviations from the program specified by the ODCM: 09/26/17-10/03/17 Air Station R5 Offsite sample pump was inoperable for approximately 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br />. Out of service time was determined based upon sample pump run time integrator. The inoperability was due to loss of power to the sample station. No

corrective actions were required to restore power to the station. 10/10/17-10/17/17 Air Station R5 Offsite Sample pump was inoperable for approximately 4.9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br />. Out of service time was determined based upon sample pump run time integrator. The inoperability was due to loss of power to the sample station. No

corrective actions were required to restore power to the station.

Air Sampling Station Operability Assessment The ODCM required air sampling program consists of 5 individual sampling locations. The collective operable time period for the air monitoring stations was 43,773 hours0.00895 days <br />0.215 hours <br />0.00128 weeks <br />2.941265e-4 months <br /> out of a possible 43,800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br />. The air sampling availability factor for the report period was 99.9%.

EXELON FITZPATRICK, LLC JAMES A. FITZPATRICK NUCLEAR POWER PLANT ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY 2017 - DECEMBER 2017 24 ATTACHMENT NO. 5 ANNUAL

SUMMARY

OF HOURLY METEOROLOGICAL DATA The James A. FitzPatrick Nuclear Power Plant Offsite Dose Calculation Manual (ODCM), Part 1, Radiological Effluent Controls Section 6.2 and 6.2.2 states in part: The Annual Radioactive Effluent Release Report submitted prior to May 1 of each year may include an annual summary of meteorological data collected over the previous year. If the meteorological data is not included, the licensee shall retain it on file and provide it to the U.S. Nuclear Regulatory Commission upon

request.

In accordance with the aforementioned ODCM requirement, meteorological data is not included in

this report. It is retained on file and is available upon request.

EXELON FITZPATRICK, LLC JAMES A. FITZPATRICK NUCLEAR POWER PLANT ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY 2017 - DECEMBER 2017 25 ATTACHMENT NO. 6 MAJOR MODIFICATIONS TO RADIOACTIVE LIQUID, GASEOUS AND SOLID WASTE TREATMENT SYSTEMS In accordance with the James A. FitzPatrick Nuclear Power Plant Offsite Dose Calculation Manual (ODCM), Part 1 Radiological Effluent Controls Section 7.0, Major Modifications to Radioactive Waste Treatment Systems (liquid, gaseous and solid) shall be reported in the Annual Radioactive Effluent Release Report for the period in which the modification is completed and made operational.

There were no major modifications to any liquid, gaseous, or solid radioactive waste treatment systems.

EXELON FITZPATRICK, LLC JAMES A. FITZPATRICK NUCLEAR POWER PLANT ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY 2017 - DECEMBER 2017 26 ATTACHMENT NO. 7 ONSITE GROUNDWATER MONITORING In response to the Nuclear Energy Institute (NEI) Groundwater Protection Initiative, JAF instituted a groundwater monitoring program in 2007. FitzPatrick's Groundwater Monitoring Well Program consist of twenty-two wells which are sampled quarterly.

All samples collected were analyzed for tritium and gamma emitting radionuclides. The detection limits and results are reported in the following tables. All sample results were <LLD for gamma emitting nuclides and tritium. There is no potential to influence any offsite drinking well. No drinking water pathway exists at the James A. FitzPatrick site under normal operating conditions due to the direction and distance of the nearest water intake (Oswego, 8.5 miles west of the JAF

discharge).

In conclusion, there were no plant related isotopes detected in groundwater monitoring wells during 2017 that are attributable to James A. FitzPatrick.

EXELON FITZPATRICK, LLC JAMES A. FITZPATRICK NUCLEAR POWER PLANT ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY 2017 - DECEMBER 2017 27 ATTACHMENT NO. 7 (continued)

ONSITE GROUNDWATER MONITORING A) Gamma Isotopic Monitoring For 2017, the 22 monitoring wells were sampled quarterly, providing enough water was present, and analyzed below the required lower limits of detection in accordance with the

Offsite Dose Calculation Manual (ODCM) Part 1, Table 5.1-3.

Radionuclide LLD Value (pCi/L) Radionuclide LLD Value (pCi/L) Tritium (H-3) 3000 Zirconium-95 15 Manganese-54 15 Niobium-95 15 Cobalt-58 15 Iodine-131 15 Iron-59 30 Cesium-134 15 Cobalt-60 15 Cesium-137 18 Zinc-65 30 Barium/Lanthanum-140 15 There were no plant related gamma emitting nuclides or tritium detected in 2017 samples.

Gross Beta and Hard to Detect nuclide analysis not required.

EXELON FITZPATRICK, LLC JAMES A. FITZPATRICK NUCLEAR POWER PLANT ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY 2017 - DECEMBER 2017 28 ATTACHMENT NO. 7 (continued)

ONSITE GROUNDWATER MONITORING B) Tritium Summary Well Name # Samples in 2017 # Positive Samples in 2017 Minimum Positive Concentration Maximum Positive Concentration MW-1A 4 0 MW-1B 4 0 MW-2A 4 0 MW-2B 4 0 MW-3A 4 0 MW-3B 4 0 MW-4A 4 0 MW-4B 4 0 MW-5 4 0 MW-6 4 0 MW-7 4 0 MW-8 4 0 MW-9 4 0 MW-10A 4 0 MW-10B 4 0 MW-13 4 0 MW-14 4 0 MW-15 4 0 MW-16 4 0 MW-19 4 0 MW-20 4 0 MW-21 4 0 Note 1: All results are in pCi/L.

Note 2: A total of 88 samples were analyzed for H-3 in 2017, all results were <LLD.

EXELON FITZPATRICK, LLC JAMES A. FITZPATRICK NUCLEAR POWER PLANT ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY 2017 - DECEMBER 2017 29 ATTACHMENT NO. 8 GASEOUS EFFLUENTS - CARBON-14 a) Date: January 01, 2017 - December 31, 2017 b) Location: Elevated Release - Main Stack c) Duration: 365 Days d) Flow rate:

N/A e) Volume Released: N/A f) Nuclides Released:

Carbon-14 g) Curies Released(1): UNIT QTR 1 QTR 2 QTR 3 QTR 4 Ci 1.20E+00 2.55E+00 2.66E+00 2.66E+00 Ci/sec 3.40E-01 3.39E-01 3.39E-01 3.40E-01 h) Resultant Doses: See Addendum 1-Assessment of Radiation Doses to the Public January-December 2017 Table 1, Section D

i) Dose Calculations:

Doses were calculated in accordance with the Offsite Dose Calculation Manual (ODCM) Part 2, Section 4.4.1

(1)Curies released calculated using the methodology in EPRI Technical Report 1021106 "Estimation of Carbon-14 in Nuclear Power Plant Gaseous Effluents".

EXELON FITZPATRICK, LLC JAMES A. FITZPATRICK NUCLEAR POWER PLANT ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY 2017 - DECEMBER 2017 30 ATTACHMENT NO. 9 EVENTS LEADING TO CONDITIONS WHICH RESULTED IN EXCEEDING RADIOACTIVITY LIMITS.

In accordance with the James A. FitzPatrick Nuclear Power Plant Offsite Dose Calculation Manual (ODCM), Part 1 Radiological Effluent Controls Section 6.2.9, the report shall contain the events leading to the conditions which resulted in exceeding the radioactivity limits for the specified outdoor radioactive radwaste tanks specified in the Technical Requirements Manual, TRM 3.7.E

The radioactivity limits for the specified outdoor radioactive radwaste tanks were not exceeded.

EXELON FITZPATRICK, LLC JAMES A. FITZPATRICK NUCLEAR POWER PLANT ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY 2017 - DECEMBER 2017 31 ADDENDUM 1

ASSESSMENT OF RADIATION DOSES TO THE PUBLIC JANUARY - DECEMBER 2017

1. INTRODUCTION The James A. FitzPatrick Nuclear Power Plant Offsite Dose Calculation Manual (ODCM), Part 1 Radiological Effluent Controls, requires an assessment of the radiation doses to the likely most exposed member of the public due to radioactive liquid and gaseous effluents. This assessment of doses to the likely most exposed member of the public is based on accepted methodologies found in

the Offsite Dose Calculation Manual (ODCM).

2. DOSE LIMITS A. DOSE FROM LIQUID EFFLUENTS (ODCM, Part 1, Section 2.3)

Applicability

Applies to doses from radioactive material in liquid effluents.

Objective

To ensure that the dose limitations of 10 CFR 50, Appendix I, are met.

Specifications The dose to a member of the public from radioactive materials released from the plant in liquid effluents to Unrestricted Areas shall be limited as follows:

1. During any calendar quarter, limited to less than or equal to 1.5 mrem to the whole body and to less than or equal to 5 mrem to any organ.

2. During any calendar year, limited to less than or equal to 3 mrem to the whole body and to less than or equal to 10 mrem to any organ.

B. GASEOUS DOSE RATES (ODCM, Part 1, Section 3.2)

Applicability Applies to the radiation dose from radioactive material in gaseous effluents.

Objective To ensure that the dose rates at or beyond the site boundary from gaseous effluents do not exceed the annual dose limits of 10 CFR 20 for Unrestricted Areas.

EXELON FITZPATRICK, LLC JAMES A. FITZPATRICK NUCLEAR POWER PLANT ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY 2017 - DECEMBER 2017 32 ADDENDUM 1 (continued)

Specifications The dose rate at or beyond the Site Boundary due to radioactive materials released from the plant in gaseous effluents shall be limited as follows:

1. Less than or equal to 500 mrem/year to the whole body and less than or equal to 3000 mrem/year to the skin from noble gases; and,

2. Less than or equal to 1500 mrem/year to any organ from Iodine-131, Iodine-133, Tritium and for radioactive materials in particulate form with half-lives greater than 8 days (inhalation pathway only).

C. AIR DOSE, NOBLE GASES (ODCM, Part 1, Section 3.3)

Applicability Applies to the air dose due to noble gases in gaseous effluents.

Objective To ensure that the noble gas dose limitations of 10 CFR 50, Appendix I, are met.

Specifications The air dose to areas at or beyond the Site Boundary from noble gases released from the plant in gaseous effluents shall be limited:

1. During any calendar quarter, to less than or equal to 5 mrad from gamma radiation, and less than or equal to 10 mrad from beta radiation; and,

2. During any calendar year, to less than or equal to 10 mrad from gamma radiation and less than or equal to 20 mrad from beta radiation.

EXELON FITZPATRICK, LLC JAMES A. FITZPATRICK NUCLEAR POWER PLANT ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY 2017 - DECEMBER 2017 33 ADDENDUM 1 (continued)

D. DOSE DUE TO IODINE-131, IODINE-133, TRITIUM AND RADIONUCLIDES IN PARTICULATE FORM (ODCM, Part 1, Section 3.4)

Applicability Applies to the cumulative dose from Iodine-131, Iodine-133, Tritium, and radionuclides in particulate form with half-lives greater than 8 days in gaseous effluents.

Objective

To ensure that the dose limitations of 10 CFR 50, Appendix I, are met.

Specifications The dose to a member of the public at or beyond the Site Boundary from Iodine-131, Iodine-133, Tritium, and radionuclides in particulate form with half-lives greater than 8 days released from the plant in gaseous effluents shall be limited:

a. During any calendar quarter to less than or equal to 7.5 mrem to any organ; and,

b. During any calendar year to less than or equal to 15 mrem to any organ.

c. Less than 0.1% of the limits of ODCM Part 1, Section 3.4, Specifications 3.4.1.c.1.a and 3.4.1.c.1.b as a result of burning contaminated oil.

E. TOTAL DOSE FROM URANIUM FUEL CYCLE (ODCM, Part 1, Section 4.0)

Applicability Applies to radiation dose from releases of radioactivity and radiation from uranium fuel cycle sources. Objective

1. To assure that the requirements of 40 CFR 190 are met.

2. To assure that the requirements of 10 CFR 72.104 are met in accordance with Section 3.2.3, Required Action A.2, Certificate of Compliance 1014 Appendix A, Technical Specifications for the Hi-Storm 100 Cask System.

Specifications The dose or dose commitment to any member of the public, due to releases of radioactivity and radiation, from uranium fuel cycle sources shall be limited as follows:

1. Less than or equal to 25 mrem/year to the whole body; and,

2. Less than or equal to 25 mrem/year to any organ except the thyroid which shall be limited to less than or equal to 75 mrem/year.

EXELON FITZPATRICK, LLC JAMES A. FITZPATRICK NUCLEAR POWER PLANT ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY 2017 - DECEMBER 2017 34 ADDENDUM 1 (continued)

3. DOSE ASSESSMENT A. METHODOLOGY The assessment of radiation doses to the public due to radioactive liquid and gaseous effluents is performed in accordance with the ODCM. The ODCM is based on methodologies and models suggested by the Guidance Manual For "Preparation of Radiological Effluent Technical Specifications for Nuclear Power Plants" (NUREG-0133) and "Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10CFR50, Appendix I" (Regulatory Guide

1.109).

B. ASSUMPTIONS

Dose calculations are performed using formulas and constants defined in the ODCM.

Specific radioactive release activities used in the dose calculations are listed in the Annual Radioactive Effluent Release Report (1.21 Report) for the period of January 1, 2017 to December 31, 2017. Historical meteorological data was used to generate tables of average dispersion factors. Locations of interest were identified from the 2017 land use census.

These tables are available upon request.

C. ASSESSMENT RESULTS

SUMMARY

The calculated doses to the public due to radioactive effluents are listed in Table 1. The calculated doses are small fractions of their respective dose limits.

4. 40 CFR 190 DOSE ASSESSMENT A. METHODOLOGY Evaluation to demonstrate compliance with the 40 CFR 190 dose limits must be performed when the doses calculated for 10 CFR 50 compliance exceed twice their respective limits.

When additional dose assessment is required to demonstrate compliance with 40 CFR 190 it is performed in accordance with the ODCM.

B. RESULTS

SUMMARY

The cumulative dose contribution from liquid and gaseous effluents for this report period were calculated and are listed in Table 1. The cumulative dose contribution from direct radiation from the reactor unit and from radwaste storage tanks is measured by environmental thermoluminescent dosimeters for the report period. This data is contained in the Annual Environmental Operating Report. The calculated doses from liquid and gaseous effluents are less than twice their respective 10 CFR 50 limits; therefore, additional calculations are not necessary to demonstrate compliance with 40 CFR 190 dose limits.

EXELON FITZPATRICK, LLC JAMES A. FITZPATRICK NUCLEAR POWER PLANT ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY 2017 - DECEMBER 2017 35 ADDENDUM 1 (continued)

TABLE 1 ANNUAL DOSE ASSESSMENT 2017 A. LIQUIDS QUARTER 1 2 3 4 ANNUAL

(a) (a) (a) (a) (a)

Organ (mrem) 9.39E-07 5.18E-07 1.10E-06 4.55E-07 3.02E-06 % of Limit 1.88E-05 1.04E-05 2.21E-05 9.11E-06 3.02E-05

(b) (b) (b) (b) (b)

Whole Body (mrem) 9.39E-07 5.18E-07 1.10E-06 4.55E-07 3.02E-06 % of Limit 6.26E-05 3.45E-05 7.36E-05 3.04E-05 1.01E-04 (a) Dose to the Child Liver primarily by the potable water pathway. (b) Dose to the Child Whole Body primarily by the potable water pathway.

EXELON FITZPATRICK, LLC JAMES A. FITZPATRICK NUCLEAR POWER PLANT ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY 2017 - DECEMBER 2017 36 ADDENDUM 1 (continued)

TABLE 1 (cont)

ANNUAL DOSE ASSESSMENT 2017 B. NOBLE GASES QUARTER 1 2 3 4 ANNUAL

Total Body (mrem/yr) 4.63E-02 2.64E-01 1.30E-01 1.98E-02 2.64E-01 % of Limit 9.25E-03 5.27E-02 2.59E-02 3.96E-03 5.27E-02

Skin (mrem/yr) 5.94E-02 3.44E-01 1.69E-01 2.56E-02 3.44E-01 % of Limit 1.98E-03 1.15E-02 5.62E-03 8.52E-04 1.15E-02

Gamma (mrad) 5.84E-04 2.04E-03 1.64E-03 2.18E-03 6.44E-03 % of Limit 1.17E-02 4.08E-02 3.28E-02 4.35E-02 6.44E-02

Beta (mrad) 7.37E-05 2.95E-04 2.32E-04 3.17E-04 9.17E-04 % of Limit 7.37E-04 2.95E-03 2.32E-03 3.17E-03 4.59E-03 C. IODINES AND PARTICULATES QUARTER 1 2 3 4 ANNUAL

(a) (a) (b) (b) (a)

Organ (mrem) 2.55E-03 1.99E-03 1.15E-03 1.17E-03 6.68E-03 % of Limit 3.41E-02 2.65E-02 1.53E-02 1.56E-02 4.46E-02

(b) (b) (b) (b) (b)

Organ Dose Rate 6.71E-04 1.86E-04 3.34E-04 3.67E-04 6.71E-04 (mrem/yr)

% of Limit 4.48E-05 1.24E-05 2.22E-05 2.45E-05 4.48E-05

(a) Dose to the Infant Thyroid primarily by the Grass/Goat/Milk pathway. (b) Dose to the Child Thyroid primarily by the Vegetation pathway.

EXELON FITZPATRICK, LLC JAMES A. FITZPATRICK NUCLEAR POWER PLANT ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY 2017 - DECEMBER 2017 37 ADDENDUM 1 (continued)

TABLE 1 (cont)

ANNUAL DOSE ASSESSMENT 2017 D. CARBON 14 QUARTER 1 2 3 4 ANNUAL

(a) (a) (a) (a) (a)

Organ (mrem) 3.82E-03 8.15E-03 8.49E-03 8.49E-03 2.90E-02 % of Limit 5.09E-02 1.09E-01 1.13E-01 1.13E-01 1.93E-01

(a)

Organ Dose Rate NA NA NA NA 2.90E-02 (mrem/yr)

% of Limit NA NA NA NA 1.93E-03

(a) Dose to the Child Bone primarily by the vegetation pathway.

JAFP-18-0039

Enclosure 2

Process Control Program Procedure Changes RW-AA-100 Revision 12 RW-AA-600 Revision 1 EN-RW-106 Revision 6

EN-RW-106 Revision 7 OP-AA-106-102 Revision 7 (122 Pages)

RW-AA-100 Revision 12Page 1of 13Level 3 -Information UsePROCESS CONTROL PROGRAM FOR RADIOACTIVE WASTES 1.PURPOSE1.1.The purpose of the Process Control Program (PCP) is to:1.1.1.Establish the process and boundary conditions for the preparation of specific procedures for processing, sampling, analysis, packaging, storage, and shipment of solid radwaste in accordance with local, state, and federal requirements. (CM-1)1.1.2.Establish parameters which will provide reasonable assurance that all Low Level Radioactive Wastes (LLRW), processed by the in-plant waste process systems on-site OR by on-site vendor supplied waste processing systems, meet the

acceptance criteria to a Licensed Burial Facility, as required by 10CFR Part 20, 10CFR Part 61, 10CFR Part 71, 49CFR Parts 171-172, "Technical Position on Waste Form (Revision 1)" [1/91],"Low-Level Waste Licensing Branch Technical Position on Radioactive Waste Classification" [5/83], and the Station Technical

Specifications, as applicable.1.1.3.Provide reasonable assurance that waste placed in "on-site storage" meets the requirements as addressed within the Safety Analysis Reports for the low level

radwaste storage facilities for dry and/or processed wet waste.

2.TERMS AND DEFINITIONS 2.1.Blending: The mixing of LLRW with different concentrations of radionuclides, typically in an effort to create a relatively homogeneous mixture for disposal.

2.2.Classification Controlling Nuclides

One or more nuclides, listed in Table 1 or Table 2 of 10CFR61.55, whose concentration is the specific basis for the classification of the waste container. This could be a single nuclide or multiple

nuclides that make up >50% of the sum of the fractions.

2.3.Compaction: When dry wastes such as paper, wood, plastic, cardboard, incinerator ash, and etc. are volume reduced through the use of a compactor.

2.4.Concentration Averaging: The averaging of the radionuclide concentrations for specific wastes or mixture of waste over the volume or weight of the waste.

2.5.Dewatering:

The process of removing fluids from liquid waste streams to produce awaste form that meets the requirements of 10CFR Part 61 and applicable burial site criteria, <0.5% by volume when the waste is packaged to an "unstable" state, or

<1% by volume when the waste is packaged to a "stable" form.

RW-AA-100 Revision 12Page 2of 13 2.6.Encapsulation

Encapsulation is the surrounding of a radioactive source or component with a nonradioactive material. Encapsulation involves a radioactive core surrounded by a non-radioactive matrix.

2.7.High Integrity Container (HIC):

A disposable container that is approved to the Requirements of 10CFR61. The use of HIC's is an alternative to solidification or encapsulation in a steel container to meet burial stability. HIC's are used to package

dewatered liquid wastes, (e.g. filter cartridges, filter media, resin, sludges, etc), or

dry active waste.

2.8.Homogeneous Waste: Waste in which concentrations of radionuclides of concern are likely to approach uniformity in the context of reasonable foreseeable intruder scenarios(This is because hot spots are a concern with respect to protection of an individual who may inadvertently intrude into the burial site).

2.9.Incineration, RVR, and/or Glass Vitrification of Liquid or Solid: Dry or wet waste processed via incineration and/or thermal processing where the volume is reduced by thermal means meets 10CFR61 requirements.

2.10.Liquid Waste Processing Systems: In-plant or vendor supplied processing systems consisting of equipment utilized for evaporation, filtration, demineralization, dewatering, compression dewatering, solidification, or reverse osmosis (RO) for the

treatment of liquid wastes (such as Floor Drains, Chemical Drains and Equipment

Drain inputs).

2.11.Mixable Waste: Waste that is amenable to physical mixing to create relatively uniform radionuclide concentrations.

2.12.Nuclides of Concern

A nuclide in the waste in concentrations greater than 1% of the concentration of that nuclide listed in Table 1 of 10CFR61.55 or 1% of the applicable class-dependent concentration of that nuclide in Table 2 of 10CFR61.55, Column 2 or 3.

2.13.Process Control Program (PCP): The program which contains the current formulas, sampling, analysis, tests, and determinations to be made to ensure that processing and packaging of solid radioactive waste based on demonstrated

processing of actual or simulated wet solid wastes will be accomplished in such a way as to assure thewaste meets the stabilization criteriaspecified in 10CFR Parts 20, 61 and 71, state regulations, and burial site requirements.

2.14.Solidification:

Liquid waste processed to either an unstable or stable form per 10CFR61 requirements. Waste solidified does not have to meet the 300-year free standing monolith criteria. Approved formulas, samples and tests do not have to

meet NRC approval for wastes solidified in a container meeting stability criteria (e.g.

High Integrity Container).

RW-AA-100 Revision 12Page 3of 13 2.15.Solidification Media: An approved media (e.g. Barnwell -vinyl ester styrene, cement, bitumen) when waste containing nuclides with greater than 5-year half lives is solidified in a container with activity greater than 1 micro curie/cc. Waste solidified

in a HIC is approved by the commission meeting the 10CFR61 stabilization criteria, including 1% free standing liquids by volume when the waste is packaged to a "stable" form and <0.5% when waste is packaged to an "unstable" form. The formulas, sampling, analysis, and test do not require NRC approval, because the

HIC meets the stability criteria.2.15.1.Solidification to an unstable or stable state is performed by vendors, when applicable. Liquid waste solidified to meet stabilization criteria (10CFR61 and 01-91 Branch Technical Requirements) shall have documentation available that

demonstrates that the process is approved by the NRC or disposal facility.

2.16.Stabilization: Liquid waste processed to a "stable state" per 10CFR61 Requirements. Established formulas, samples, and tests shall beapproved by the NRC in order to meet solidification "stabilization" criteria. This processing method is

currently not available, because the NRC recognizes that waste packed in a High Integrity Container meets the 300-year stabilization criteria. In theevent that this

processing method becomes an acceptable method, then the NRC shall approve the

stabilization formulas, samples, tests, etc.

2.17.Waste Streams:

Consist of but are not limited to

!Filter media (powdered, bead resin and fiber), !Filter cartridges, !Pre-coat body feed material, !Contaminated charcoal,!Fuel pool activated hardware,!Oil Dry absorbent material added to a container to absorb liquids

!Fuel Pool Crud

!Sump and tank sludges, !High activity filter cartridges, !Concentrated liquids, !Contaminated waste oil, !Dried sewage or wastewater plant waste, !Dry Active Waste (DAW): Waste such as filters, air filters, low activity cartridge filters, paper, wood, glass, plastic, cardboard, hoses, cloth, and metals, etc, which have become contaminated as a consequence of normal

operating, housekeeping and maintenance activities.

!Other radioactive waste generated from cleanup of inadvertent contamination.

3.RESPONSIBILITIES3.1.Implementation of this Process Control Program (PCP) is described in procedures at each station and is the responsibility of the each site to implement.

RW-AA-100 Revision 12Page 4of 13 4.MAIN BODY4.1.Process Control Program Requirements4.1.1.A change to this PCP (Radioactive Waste Treatment Systems) may be made provided that the change is reported as part of the annual radioactive effluent

release report, Regulatory Guide 1.21, and is approved by the Plant Operations

Review Committee (PORC). 4.1.2.Changes become effective upon acceptance per station requirements.

4.1.3.A solidification media, approved by the burial site, may be REQUIRED when liquid radwaste is solidified to a stable/unstable state.

4.1.4.When processing liquid radwaste to meet solidification stability using a vendor supplied solidification system:

1.If the vendor has its own Quality Assurance (QA) Program, then the vendor shallADHERE to its own QA Program and shall have SUBMITTED its process system topical report to the NRC or agreement state.

2.If the vendor doesnotHAVE its own Quality Assurance Program, then the vendor shallADHERE to an approved Quality Assurance Topical Reportstandard belonging to the Station or to another approved vendor.4.1.5.The vendor processing system(s) is/are controlled per the following:1.A commercial vendor supplied processing system(s) may be USED for theprocessing of LLRW streams.2.Vendors that process liquid LLRW at the sites shall MEET applicable QualityAssuranceTopical Report and Augmented Quality Requirements.4.1.6.Vendor processing system(s) operated at the site shallbeOPERATED and CONTROLLED in accordance with vendor approved procedures or station procedures based upon vendor approved documents.4.1.7.All waste streams processed for burial or long term on-site storage shall MEET the waste classification and characteristics specified in 10CFR Part 61.55, Part61.56, the 5-83 Branch Technical Position for waste classification, and the applicable burial

site acceptance criteria (for any burial site operating at the time the waste was

processed).4.1.8.An Exelon Nuclear plant may store waste at another Exelon Nuclear plant, provided formal NRC approval has been RECEIVEDfor the transfer of waste.

RW-AA-100 Revision 12Page 5of 134.2.General Waste Processing RequirementsNOTE:On-site resin processing involves tank mixing and settling, transferring to the station or vendor processing system via resin water slurry or vacuuming into approved waste containers,and, when applicable, dewatering for burial.4.2.1.Vendor resin beds may be USED for decontamination of plant systems, such as, SFP (Spent Fuel Pool), RWCU (reactor water cleanup), and SDC (Shut Down

Cooling). These resins are then PROCESSED via the station orvendor processing system.4.2.2.Various drains and sump discharges will be COLLECTED in tanks or suitable containers for processing treatment. Water from these tanks may be SENT through a filter, demineralizer, concentrator or vendor supplied processing systems.4.2.3.Process waste (e.g. filter media, sludges, resin, etc) will be periodically DISCHARGED to the station or vendor processing system for onsite waste treatment or PACKAGED in containers for shipment to offsite vendor for volume reduction processing.4.2.4.Process water (e.g. chemical, floordrain, equipment drain, etc.) may be SENT to either the site waste processingsystems or vendor waste processing systems for further filtration, demineralization for plant re-use, or discharge.4.2.5.All dewatering and solidification/stabilization will be PERFORMED by either utility site personnel or by on-site vendors or will bePACKAGED and SHIPPED to an off-site vendor low-level radwaste processing facility.4.2.6.Dry Active Waste (DAW) will beHANDLED and PROCESSED per the following:1.DAW will be COLLECTED and SURVEYED and may be SORTED forcompactable and non-compactable wastes.2.DAW may be packaged in containers to facilitate on-site pre-compactionand/or off-site vendor contract requirements.3.DAW items may be SURVEYED for release onsite or offsite when applicable.4.Contaminated filter cartridges will be PLACED into a HIC or will beENCAPSULATED in an in-situ liner for disposal or SHIPPED to an offsite waste processor in drums, boxes or steel liners per the vendor site criteria for

processing and disposal.

RW-AA-100 Revision 12Page 6of 134.2.7.Filtering devices using pre-coat media may be USED for the removal of suspended solids from liquid waste streams. The pre-coat material or cartridges from these

devices may be routinely REMOVED from the filter vessel and discharged to a Filter Sludge Tank or Liner/HIC. Periodically, the filter sludge may beDISCHARGED to the vendor processing system for waste treatment onsite or PACKAGED in containers for shipment to offsite vendor for volume reduction processing.4.2.8.Activated hardware stored in the Spent Fuel Pools will be PROCESSED periodically using remote handling equipment and may then be PUT into a container for shipment or storage in the pool or loading the processedactivated hardware into the Dry Caskstorage system.4.2.9.High Integrity Containers (HIC):1.For disposal at Barnwell, vendors supplyingHIC's to the station shall PROVIDE a copy of the HIC Certificate of Compliance, which details specific limitations on use of the HIC.2.For disposal at Cliveor WCS,vendors supplyingHIC's to the station shall PROVIDE a copy of the HIC Certificate of Conformance, which details specific limitations on use of the HIC.3.Vendors supplyingHIC's to the stationshall PROVIDE a handling procedurewhich establishes guidelines for the utilization of the HIC. These guidelines serve to protect the integrity of the HIC and ensure the HIC is handled in

accordance with the requirements of the Certificate of Compliance or

Certificate of Conformance.4.2.10.Lubricants and oils contaminated as a consequence of normal operating and maintenance activities may be PROCESSED on-site (by incineration, for oils

meeting 10CFR20.2004 and applicable state requirements, or by an approved

vendor process) or SHIPPED offsite (for incineration or other acceptable processing method).4.2.11.Former in-plant systems GE or Stock Drum Transfer Cart and Drum Storage Areas may be USED for higher dose DAW storage at Clinton, Dresden, Quad Cities, Braidwood, Byronand Nine Mile Point.4.2.12.Certain waste, including flowable solids from holding pond, oily waste separator, cooling tower basin and emergency spray pond, may be disposed of onsite under the provisions of a 10CFR20.2002 permit. Specific requirements associated with the

disposal shall be incorporated into station implementing procedures. (CM-2)

RW-AA-100 Revision 12Page 7of 134.2.13.Concentration averaging may be PERFORMEDtocombineLLRW having differentconcentrations of radionuclides to form a homogeneous mixturein accordance with

the guidance in the NRC's Branch Technical Position on Concentration Averaging and Encapsulation-1995, NRC-2011-0022:

!For homogeneous waste types such as resins and filter media, the concentration of the mixture for classification purposes may be based on either the highest radionuclide concentration in any of the individual waste types contributing to the mixture or the volumetric or weight-averaged nuclide

concentrations in the mixture provided that the concentrations of the

individual waste type contributors to the mixture are within a factor of 10 of

the average concentration of the resulting mixture. (NOTE: a designed collection of homogeneous waste types (from different sourceswithin a facility) is not considered 'mixing' and the concentration for classification

purposes may be the average concentration of the combination).

!For non-homogeneous waste types such as activated metals, cartridge filters or components incorporating radioactivity in their design, the concentration should be determined from the total weight or displaced volume (excluding major void spaces) of the component. Mixtures of components in a disposal

container is permissible. Concentration averaging of a mixture of components of similar types canbe performed in accordance with the NRC's Branch

Technical Position on Concentration Averaging and Encapsulation and any

State or Disposal Site specific requirements.4.2.14.Blending may be PERFORMEDfor routine LLRWsuch as resins and filter media in accordance with the guidance in the NRC's Branch Technical Position on Concentration Averaging and Encapsulation as further clarified in SECY 2010-0043.

The concentration of the mixture may be determined based on the total activity of all

components in the mixture divided by the total volume or mass of the mixture.

Reasonable effort should be made to mix blended LLRWso that activity is evenly distributed.4.2.15.Encapsulation may be PERFORMED for routine wastes such as filters, filter cartridges, or sealed sources centered in an encapsulated mass,in accordance with

the guidance in the NRC's Branch Technical Position on Concentration Averaging and Encapsulation.Classification may be based on the overall volume of the final

solidified mass provided that;

!The minimum solidified volume or mass should be reasonably difficult to move by hand.

!The maximumsolidified volume or mass used for determining concentration forany single discrete source should beno more than0.2

m 3or 500Kg (typically 55-gallon drum).

!The maximum amount of gamma-emitting radioactivity or radioactive material is <0.02 mrem/hr on the surface of the encapsulation over a 500-year decay period.

RW-AA-100 Revision 12Page 8of 13

!The maximum amount of any radionuclide in a single encapsulation, when averaged over the waste and encapsulating media, does not exceed the maximum concentration limits for Class C waste.

!Written procedures should be established to ensure that the radiation source(s) is reasonably centered (or distributed) within the encapsulating media.!All other disposal facility requirements for encapsulated material are met.4.3.Burial Site Requirements4.3.1.Waste sent directly to burial shall COMPLY with the applicable parts of 49CFR171-172, 10CFR61, 10CFR71, and the acceptance criteria for the applicable

burial site.4.4.Shipping and Inspection Requirements4.4.1.All shipping/storage containers shallbe INSPECTED , as required by station procedures, for compliance with applicable requirements (Department of Transportation (DOT), Nuclear Regulatory Commission (NRC), station, on-site

storage, and/or burial site requirements) prior to use.4.4.2.Containers of solidified liquid waste shallbe INSPECTED for solidification quality and/or dewatering requirements per the burial site, offsite vendor acceptance, or

station acceptance criteria, as applicable.4.4.3.Shipments sent to an off site processor shallbe INSPECTED to ensure that the applicable processor's waste acceptance criteria are being met.4.4.4.Shipmentssentfor off sitestorageshall MEET the storage site's waste acceptance criteria.4.5.Inspection and Corrective Action4.5.1.Inspection results that indicate non-compliance with applicable NRC, State, vendor, or site requirements shall be IDENTIFIED and TRACKED through the Corrective

Action Program.4.5.2.Administrative controls for preventing unsatisfactory waste forms from being released for shipment are described in applicable station procedures.

If the provisions of the Process Control Program are not satisfied, thenSUSPEND shipments of defectively packaged radioactive waste from the site. (CM-1)4.5.3.If freestanding water or solidification not meeting program requirements is observed, thensamples of the particular series of batches shallbeTAKEN to determine the cause. Additional samples shallbeTAKEN , as warranted, to ensure that no freestanding water is present and solidification requirements are maintained.

RW-AA-100 Revision 12Page 9of 134.6.Procedure and Process Reviews 4.6.1.The Exelon Nuclear Process Control Program and subsequent changes (other thaneditorial/minor changes) shallbeREVIEWED and APPROVED in accordance with the station procedures, plant-specific Technical Specifications (Tech Spec),

Technical Requirements Manual (T&RM), Operation Requirements Manual (ORM),

as applicable, for the respective station and LS-AA-106. Changes to the Licensees

Controlled Documents, UFSAR, ORM, or TRM are controlled by the provisions of

10CFR 50.59.4.6.2.Any changes to the PCP shall be reviewed to determine if reportability is required in the Annual Radiological Effluent Release Report (ARERR). The Radwaste

Specialist shall ensure correct information is SUBMITTED to the ODCM program owner prior to submittal of the ARERR.4.6.3.Procedures shall be IMPLEMENTED as follows:

!Station processes or other vendor waste processing/operating procedures shall betechnically reviewed andapproved per RM-AA-102-1006.

!Procedures related to waste manifests, shipment inspections, and container activity determinationsare CONTROLLED by Radiation Protection Standard Procedures (RP-AA-600 Series).

!Site waste processing IS CONTROLLED by site operating procedures.

!Liquid processed by vendor equipment shallbe PERFORMED in accordance with vendor procedures.

!The dewatering procedures implemented by Vendor for the purpose of compliance to the Process Control ProgramSHALL BE REVIEWED and APPROVED in accordance with the plant specific TRM or ORM (either Current Technical Specifications (CTS)or Improved Technical Specifications (ITS), as applicable for the respective stations).

RW-AA-100 Revision 12Page 10of 134.7.Waste Types, Point of Generation, and Processing Method Methods of processing and individual vendors may CHANGE due to changing financial and regulatory options. The table below is a representative sample. It is

not intended be all encompassing.WASTE STREAM POINTS OF GENERATIONAVAILABLE WASTE PROCESSING METHODS Bead ResinSystems -Fuel Pool, Condensate, Reactor Water Cleanup, Blowdown, Equipment Drain, Chemical and Volume Control Systems, Floor Drain, Maximum Recycle, Blowdown, Boric Acid Recycling System, Vendor

Supplied Processing Systems, and Portable Demin System Dewatering, solidification to an unstable/stable state Thermal Processing Free Release to a Land Fill Powdered ResinSystems - (Condensate System, Floor Drain/Equipment Drain filtration, Fuel Pool)Dewatering, solidification to an unstable/stable state Thermal Processing Concentrated WasteWaste generated from Site Evaporators resulting typically from the Floor Drain and Equipment Drain

Systems Solidification to an unstable/stable state Thermal Processing SludgeSedimentation resulting from various sumps, condensers, tanks, cooling tower, emergency spray pond, holding pond, and oily waste separators Dewatering, solidification to an unstable/stable state Thermal Processing Evaporation on-site or at an offsite processorOn-site disposal per 10CFR20.2002 permit Filter cartridgesSystems -Floor/Equipment Drains, Fuel Pool; cartridge filters are typically generated from clean up activities

within the fuel pool, torus, etc Dewatering, solidification to an unstable/stable state Processed by a vendor for volume reduction Dry Active Waste Paper, wood, plastic, rubber, glass, metal, and etc. resulting from daily plant activities Decon/Sorting for Free ReleaseCompaction/Super-compaction Thermal Processing by Incineration or glass vitrification Sorting for Free Release Metal melting to an ingot Contamin ated Oil Oil contaminated with radioactive materials from any in-plant system.

Solidification unstable state Thermal Processing by Incineration Free Release for recycling RW-AA-100 Revision 12Page 11of 13WASTE STREAM POINTS OF GENERATIONAVAILABLE WASTE PROCESSING METHODS Drying Bed SludgeSewage Treatment and Waste Water Treatment Facilities Free release to a landfill or burial MetalsSee DAWSee DAW Irradiated HardwareFuel Pool, Reactor ComponentsVolume Reduction for packaging efficiencies 5.DOCUMENTATION5.1.Records of reviews performed shall be retained for the duration of the unit operating license. This documentation shall contain:1.Sufficient information to support the change together with the appropriate analyses or evaluations justifying the change, and2.A determination which documents that the change will maintain the overall conformance of waste products to Federal (10CFR61 and the Branch Technical Position), State, or other applicable requirements, including

applicable burial site criteria.

6.REFERENCES6.1.Station Commitments:6.1.1.Peach Bottom CM-1, T03819, Letter from G.A. Hunger, Jr., dated Sept. 29 1994, transmitting TSCR93-16 (Improved Technical Specifications). (Step 1.1.1, 4.5.2)6.1.2.LimerickCM-2, T03896, 10CFR20.2002 permit granted to Limerick via letter dated July10,1996. (Step 4.2.12)6.2.Technical Specifications:6.2.1.The details contained in Current Tech Specs (CTS)or Improved Technical Specifications (ITS), as applicable, in regard to the Process Control Program (PCP),

are to be relocated to the Licensee Controlled Documents. Some facilities have

elected to relocate these details into the Operational Requirements Manual (ORM).

Relocation of the description of the PCP from the CTS or ITS does not affect the safe operation of the facility. Therefore, the relocation details are not required to be in the CTS or the ITS to provide adequate protection of the public health and safety. 6.3.UFSAR6.3.1.Braidwood UFSAR, Section 11.4, Solid Waste Management System RW-AA-100 Revision 12Page 12of 136.3.2.Byron UFSAR Section 11.4, Solid Waste Management System6.3.3.Calvert Cliffs UFSAR Section11.1.2.3 Solid Waste Processing System 6.3.4.Clinton USAR Table 11.4, Solid Waste Management System 6.3.5.Dresden UFSAR Section11.4, Waste Management System 6.3.6.Ginna UFSAR Section11.4, Solid Waste Management System 6.3.7.James A. FitzPatrick UFSARSection 11.3, Radioactive Solid Waste System6.3.8.LaSalle UFSARSection 11.4.2.7 Storage areas, Table 12.3.6-IRSF Storage Area 6.3.9.Limerick UFSAR Section11.4, Solid Waste Management 6.3.10.Nine Mile Point Unit 1 UFSAR Section2.3Solid Waste System6.3.11.Nine Mile Point Unit 2UFSAR Section 11.4, Solid Waste Management System 6.3.12.Oyster Creek UFSAR Section11.4, Solid Waste Management System 6.3.13.Peach Bottom UFSAR Section9.0, Radioactive Waste Systems 6.3.14.Quad CitiesUFSARSection11.4.4.5,Interim Radwaste Storage Facility6.3.15.Three Mile Island UFSAR Section11.2, Radioactive Waste Disposal Systems Summary6.4.Writers'

References:

!Amendment No. 202 to Facility Operating License No. NPF-11 and Amendment No. 189 to Facility Operating License (FOL) No. NPF-18 for the LaSalle County Station (LSCS), Units 1 and 2

!Code of Federal Regulations: 10 CFR Part 20, Part 61, Part 71, 49 CFR Parts171-172

!I.E. Circular 80.18, 10CFR 50.59 Safety Evaluation for Changes to Radioactive Waste Treatment Systems

!Low Level Waste Licensing Branch Technical Position on Radioactive Waste Classification, May 1983

!NRCBranch Technical Position on Blending of Low-Level Radioactive Waste, SECY-10-0043

!NRC Concentration Averaging and Encapsulation Branch Technical Position, NRC-2011-0022

!Regulatory Guide 1.21, Measuring Evaluating, and Reporting Radioactivity in Solid Wastes and Releases of Radioactive materials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants

!Technical Position on Waste Form (Revision 1), January 1991 RW-AA-100 Revision 12Page 13of 136.5.Users'

References:

!CY-AA-170-2000, Annual Radioactive Effluent Release Report

!LS-AA-106, Plant Operations Review Committee

!Quality Assurance Program(QATR)

!RM-AA-101, Records Management Program

!RM-AA-102-1006, Processing Vendor Documents

!RP-AA-600 Series, Radioactive Material/Waste Shipments 7.ATTACHMENTS-None RW-AA-600 Revision 1Page 1of 5Level 3 -Information UseGUIDELINES FOR TRACKINGOF PROCESSED LINERS 1.PURPOSE1.1.The purpose of this procedure isto track actionsoncea lineris declared full.Trackingitemsincludelineraccrual,resinsampleanalysis/review, characterization, classification method, storage ofliner, andadjustmenttoaccrual ifnecessary.1.2.This procedure is intended to be used for Class B waste liners. It is not necessary for all liners to follow this tracking process. It can however, be used if the site/corporate determines the need for tracking based on performance ormanagementof liners.This is a suggested method and does not have to be followed in order.

2.TERMS ANDDEFINITIONS 2.1.Accrual:Fundsallocated for establishing the liability based on the existingcontractrates when the waste container isconsideredfull (85%or greater).NOTE:If the liner cannot be filled to 85% or greater due to operational issues and is deemed complete for this evolution, then the accrual amount is determined by the liner burial volume multiplied by the waste class price per

cubic footExample:(Linerburial volumex price per ft 3of waste= accrual) 2.2.WasteClassification:Determinationofradioactivewastegiventheconcentrationoflong lived radionuclides and the concentration of short lived radionuclides for which requirements on institutional controls, waste form, and disposal methods are

effective.

2.3 Process Memo: A copy of the Vendor's form used to document contents of liners during filling/dewatering operations.

3.RESPONSIBILITIES3.1.Radwaste/EnvironmentalSupervisoris responsible for implementation of this procedure.3.2.Radwaste Specialistis responsible for tracking mechanism and proper accrual.

3.3.Radwaste Specialistis responsible forobtaining the samples.

RW-AA-600 Revision 1Page 2of 53.4.RP Shipping Specialistis responsible for determining waste classificationofthe resinliner.3.5.Chemistry Management is responsible for resin sample analysis.3.6.Radiochemist is responsible for the technical reviewof the resin sampleisotopic scans.3.7.Business Operation Site Controlleris responsible for ensuringaccruals are recorded properly and tracked to the disposal linerinvoice.

4.MAIN BODY4.1.Upon notification that a linerisapproximately85%full, or deemed complete for thisevolution, the Radwaste Specialistshall INITIATEAttachment 1byrecording lineridentificationnumber.NOTE:If the liner cannot be filled to 85% or greater due to operational issues and is deemed complete for this evolution, then the accrual amount is determined by the liner burial volume multiplied by the waste class price per

cubic footExample:(liner burial volume x price per ft3 of waste = accrual)4.2.Radwaste SpecialistshallCREATE passport assignments to individuals responsiblefor applicable steps on Attachment 1.4.3.Radwaste Specialistshall VERIFYthatthe linerhasbeenplacedonthe Radwasteaccrualspreadsheet. Theproper amount accruedisbasedon theburial size (volume) of the liner andtype of waste thatwastransferredinto the liner.Condensate/Radwasteresin willtypicallybe accrued asClass A, and Reactor Water Clean-up resin (RWCU)Primary Resin or Filter Sludge willinitially be accrued asClass B. This should bebased on historicaldata.4.4.Radwaste Specialist shallARRANGEfor the radiological survey of the liner. RW and RP personnel should coordinate activity. 4.5.Radwaste Specialist shall VERIFY resin sample was delivered to the lab by a qualified person, and REQUESTChemistry Management to schedule resin sample analysis.

RW-AA-600 Revision 1Page 3of 5NOTE:Resinsamplesshouldbeanalyzedwithintwoweeksofreceipt and theLiner serial numbershall be used to

track the sample4.6.Chemistry Managementshall VERIFY that waste samples have been analyzed in accordance with Chemistry Procedures, protocol, and processes.4.6.1.Chemistry personnel ENTERthe liner serial number/tracking numberinto the counting room system to serve as a unique identifier which may be used as a search field at a later date. 4.7.Chemistry Managementshall VERIFY that waste sample analysis has been provided to the Radiochemist.4.8.Radiochemist shall REVIEW waste sample analysis for accuracy and PROVIDEthe results to the RW Specialist.4.9.RadwasteSpecialist will PROVIDEthe Processing memoand any other information on the liner as necessary to the RP Shipping Specialist. 4.10.The RP Shipping Specialist shallCHARACTERIZE the liner within 2 weeks of the receipt of the Process memo, radiological survey, and isotopic sample(s). This

duration may be altered if a 10CFR61 sample must be analyzed.4.11.If there is any change in classification from the classification expected for that waste liner type, then PERFORM the following:4.11.1.RP Shipping Specialist shall INFORM Radwaste Specialist and appropriate Radwaste/Environmental Management. 4.11.2.The RP Shipping SpecialistshouldGENERATE an IR noting the change.4.11.3.Radwaste/EnvironmentalManagement and Radwaste Specialistshall REVIEW results for accuracyandINFORM Business Ops and theSenior Leadership Team (SLT)of the classificationchange and the impactto the Radwastebudget.4.11.4.RW Specialist shallMAKE the proper accrual change as directed.NOTE:Accruals reductions should not take place until the liner has been accepted for burial by the disposal site operator4.12.Radwaste Specialist shall DOCUMENTthe liner storage location (Low-Level Radwaste Storage Facility/IRSF or designated Radwaste Storage location).

RW-AA-600 Revision 1Page 4of 5 4.DOCUMENTATION4.6.Recordsof liner classification, storage, and accrual are kept in accordance with other procedures.Thisprocedure isthemechanismtodriveconnectionofthe departmentsinvolved in the process. No documentation isrequired.

5.REFERENCES5.6.IR 1502266, IR 25275855.7.BO-AA-1201Accrual Guidelines 5.8.RP-AA-605 10CFR 61 Program 6.ATTACHMENTS6.6.Attachment 1, Liner Tracking RW-AA-600 Revision 1Page 5of 5 ATTACHMENT 1 Liner TrackingPAGE 1 OF 1 LinerID# ___________________________________

Liner Model__________________________________

Burial Volume (ft

3) ____________________________

Initials / DatePassport assignments created ATI#_______________________/________

Waste Stream _______________________________________/________

Waste Type _________________________________________/________

Expected Waste Class _________________________________/________

Waste sample(s)obtained________/________

Process memo, radiological survey, and isotopic sample analysis delivered to Shipping Specialist

________/________10CFR61 Sample required (Y / N)______________/________Liner characterized and waste class determined________/________

Actual Waste Class ___________________________________/________

If required, notification of classification change made________/________

If required, Radwaste accrual adjusted________/________

If required, notification made to Bus Ops and SMT________/________

Liner storage location: ____________________________/________Copy of Liner data/information remains with RW Specialist until shipped

__________________________/__________RadwasteSpecialistDate NUCLEARMANAGEMENT MANUAL N ON-QUALITY RELATEDEN-RW-106REV. 6 INFORMATIONAL U SEPage 1 of 47Integrated Transportation Security PlanProcedure Contains NMM ECH eB REFLIBForms:

YES NOProcedure Revision Type: NewNON-EditorialEditorial TCCancellationHQNEffectiveDateProcedure Owner:Title: Site:Alan ZelieManager, RP

PNPSGovernance Owner:Title:

Site:Reid TagliamonteManager, Fleet RP HQN1/5/17SiteSite Procedure ChampionTitleANOBert LynchManager, RPBRPN/AN/ACNSChris SundermanManager, RPGGNSRoy MillerManager, RPIPECScott StevensManager, RPJAFRobert HeathManager, RPPLPDave NestleManager, RPPNPSAlan ZelieManager, RPRBSShannon PeterkinManager, RPVYMichael PletcherManager, RPW3Eric NealManager, RPHQNReid TagliamonteManager, Fleet RPFor site implementation dates see ECH eB REFLIB using site tree view (Navigation panel).Site and NMM Procedures Canceled or Superseded By This Revision NoneProcess Applicability Exclusion:

All Sites:Specific Sites: ANO BRP CNS GGNS IPEC JAF PLP PNPS RBS VY W3Change StatementThe purpose of this revision is to add requirements for refresher training per 10 CFR 37.43 in response to CR-WF3-2016-02243.Added step 5.6[6]

Add Check off for attachment 9.6 and 9.7 to verify Department of Homeland Security and MARSEC levels priorto shipment of Category 1 and Category 2 quantities of radioactive material.Associated PRHQN #:

2016-00323Procedure Writer:Ron SchwartzContains Proprietary Information:

YES NO NUCLEARMANAGEMENT MANUAL N ON-QUALITY RELATEDEN-RW-106REV. 6 INFORMATIONAL U SEPage 2 of 47Integrated Transportation Security Plan__________________________________________________________________________TABLE OF CONTENTSSection Title Page1.0PURPOSE .............................................................................................

32.0REFERENCES

....................................................................................... 3 3.0DEFINITIONS......................................................................................... 4 4.0RESPONSIBILITIES .............................................................................. 75.0DETAILS ............................................................................................. 85.1PRECAUTIONSANDLIMITATIONS

...................................................... 85.2GENERAL ............................................................................................. 8 5.3RISKASSESSMENT.............................................................................. 8 5.4CARRIERTSPANDCONTRACTSMANAGEMENT .............................. 95.5CARRIERHAZARDOUSMATERIALTRANSPORTATIONSECURITYPLAN ........................................................................................... 105.6TRAINING ........................................................................................... 11 5.7ADDITIONALSECURITYMEASURESFORRADIOACTIVESHIPMENTS-CATEGORY1ANDCATEGORY2QUANTITIES ......... 125.8TYPESOFHAZMATSHIPMENTSADDRESSEDBYTHEENTERGY(EOI/ENOI)TSP-RA............................................................................ 255.9INFORMATION .................................................................................... 26 6.0INTERFACES ...................................................................................... 27 7.0RECORDS ........................................................................................... 27 8.0SITESPECIFICCOMMITMENTS ......................................................... 27 9.0ATTACHMENTS .................................................................................. 28

ATTACHMENT9.1TSP-RATABLES .................................................................. 29 ATTACHMENT9.2SAMPLE CARRIER AFFIRMATION LETTER ................................. 35 ATTACHMENT9.3LICENSE VERIFICATION SYSTEM CREDENTIAL GUIDE ................ 36 ATTACHMENT9.4MANUAL LICENSE VERIFICATION FORM GUIDE ......................... 37 ATTACHMENT9.5MANUAL LICENSE VERIFICATION PROCEDURE GUIDE ............... 39 ATTACHMENT9.610CFR37SUBPART DCATEGORY 1PHYSICAL PROTECTION REQUIREMENT CHECKLIST ...................................................................... 41 ATTACHMENT9.710CFR37SUBPART DCATEGORY 2PHYSICAL PROTECTION REQUIREMENT CHECKLIST ...................................................................... 45 ATTACHMENT9.810CFR37SUBPART DCATEGORY 1QUANTITIES OF C ONCERN STATE COORDINATION L OG ..................................................................... 47__________________________________________________________________________

NUCLEARMANAGEMENT MANUAL N ON-QUALITY RELATEDEN-RW-106REV. 6 INFORMATIONAL U SEPage 3 of 47Integrated Transportation Security Plan1.0 PURPOSEThis document implements the requirements of the DOT Transportation SecurityRequirements and the NRC's Additional Security Measures for Radioactive Material -Category 1 and Category 2 Quantities. The requirements stem from the Department ofTransportation as well as the Nuclear Regulatory Commission.

2.0 REFERENCES

[1] 49 Code of Federal Regulations, Part 172-173, Hazardous Materials[2] EPRI Hazardous Material Transportation Security Plan Risk Assessment[3] 10 CFR Parts 70, 71, 72 and 73 (NRC Regulations)[4] 33 CFR 105, Temporary Interim Rule, Effective July 1, 2003 (US Coast GuardRegulations)[5] 49 CFR 172.800, Revised Regulations, Effective March 25, 2003 (DOT Regulations)[6] American Chemistry Council, et al; Transportation Security Guidelines for the U.S.Chemical Industry, 2001[7] DOE Memorandum, Jessie Roberson to Distribution, Approval of CommercialShipments of Radioactive Materials and Waste on Behalf of the Office ofEnvironmental Management, June 27, 2003[8] DOT-RSPA, Enhancing Security of Hazardous Materials Shipments Against Acts ofTerrorism or Sabotage Using RSPA's Risk Management Self-Evaluation Framework(RMSEF), January 2002[9] DOT-RSPA, Three Case Studies for the Risk Management Framework for HazardousMaterials Transportation, November 1, 2000[10] DOT-RSPA, Flyer DHM50-0023-1002, Shippers and Carriers Enhanced SecurityMeasures, not dated[11] DOT Slide Presentation, Hazardous Materials Transportation Security, NEITransportation Security Meeting, May 29, 2003[12] DOT Federal Motor Carrier Safety Administration, Hazardous Materials CompanyAnti-Terrorism Tips, DOT Web Site, Internet download July 7, 2003[13] Federal Register, Volume 68, Number 126, page 39315-39338, 33 CFR 105, July 1, 2003 NUCLEARMANAGEMENT MANUAL N ON-QUALITY RELATEDEN-RW-106REV. 6 INFORMATIONAL U SEPage 4 of 47Integrated Transportation Security Plan2.0 continued[14] GAO Report to Congressional Requesters, GAO-03-435 Rail Safety and Security,Some Actions Already Taken to Enhance Rail Security, but Risk-based Plan Needed,April 2003[15] NRC, Fact Sheet on Dirty Bombs, NRC Web Site, internet download, June 30. 2003[16] U.S. Department of Justice, Special Report, A Method to Assess the Vulnerability ofU.S. Chemical Facilities, November 2002[17] NRC letter from J. E. Dyer dated July 19, 2005, "Issuance of Order for AdditionalSecurity Measures on the Transportation of Radioactive Material Quantities ofConcern" EA 05-007[18] NEI 14-XX [Rev C], Implementation Guidelines for 10 CFR 37 Subpart D PhysicalProtection in Transit[19] 10 CFR Part 37, "Physical Protection Of Category 1 And Category 2 Quantities OfRadioactive Material"[20] NUREG-2155, Rev. 1, "Implementation Guidance for 10 CFR Part 37, 'PhysicalProtection of Category 1 and Category 2 Quantities of Radioactive Material'"3.0 DEFINITIONS[1] Acronyms:ANI - American Nuclear InsurersASM - Additional Security Measures (EA 05-007)

COTP - Captain of the Port (US Coast Guard designation)

DAW - Dry Active Waste DOT - Department of Transportation ENOI - Entergy Nuclear Operations, Incorporated EOI - Entergy Operations, Incorporated FBI - Federal Bureau of Investigation LLEA - Local Law Enforcement Agencies MCC - Movement Control Center NEI - Nuclear Energy Institute NRC - Nuclear Regulatory Commission SAS - Secondary Alarm Station SRCP - Security Risk Control Points TSA - Transportation Security Administration TSP - Transportation Security Plan NUCLEARMANAGEMENT MANUAL N ON-QUALITY RELATEDEN-RW-106REV. 6 INFORMATIONAL U SEPage 5 of 47Integrated Transportation Security Plan3.0[1] continuedTSP-RA - Transportation Security Plan - Risk AssessmentUSCGS - U.S. Coast Guard Service

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

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

[4]Greater Than Class C Waste (GTCC) - Low-level radioactive waste that exceeds theconcentration limits of radionuclides established for Class C waste in 10 CFR Part

61.55.[5]Hazardous Material - For the purposes of the TSP-RA, this term includes thedefinition in 49CFR173.403 and as listed in associated table under 49CFR172.101.

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

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

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

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

NUCLEARMANAGEMENT MANUAL N ON-QUALITY RELATEDEN-RW-106REV. 6 INFORMATIONAL U SEPage 6 of 47Integrated Transportation Security Plan3.0 continued

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

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

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

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

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

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

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

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

NUCLEARMANAGEMENT MANUAL N ON-QUALITY RELATEDEN-RW-106REV. 6 INFORMATIONAL U SEPage 7 of 47Integrated Transportation Security Plan3.0 continued

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

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

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

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

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

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

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

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

NUCLEARMANAGEMENT MANUAL N ON-QUALITY RELATEDEN-RW-106REV. 6 INFORMATIONAL U SEPage 8 of 47Integrated Transportation Security Plan5.0 DETAILS5.1 PRECAUTIONS AND LIMITATIONS None5.2 GENERALNOTE"Tables" referenced in this procedure are located in Attachment 9.1, "TSP-RA Tables"Table 1: Typical Radioactive and Hazardous Material ShipmentsTable 2: Hazmat Carriers, Types of Hazmat Shipments and Quantities ShippedTable 3: Determination of Hazardous Materials of Significance to This AssessmentTable 4: Category 1 and Category 2 ThresholdTable 5: Hazardous Materials of Significant Concern Shipped from Facilities[1] The Physical or Industrial Security Plans already contain security procedures, accesscontrols, requirements for employee background checks, etc. Such procedures,controls regulations and therefore need not be duplicated.[2] The Entergy (EOI / ENOI) standard language approach to the TSP consists of asimplified and minimal TSP document plus an attachment used in association with theprocedure.5.3 RISK ASSESSMENT[1] This TSP-RA is applicable to packaging, staging/storage in preparation for transport,and shipment of the radioactive and hazardous materials addressed in 49 CFR172.800. Table 1 identifies the types of radioactive and hazardous materialsshipments.[2] Transportation Carriers contracted to carry radioactive and/or hazardous materialsand who's TSPs are relied upon to provide all necessary security during transport andduring storage incidental to movement. This includes the categories of carriers listedin Table 2.

NUCLEARMANAGEMENT MANUAL N ON-QUALITY RELATEDEN-RW-106REV. 6 INFORMATIONAL U SEPage 9 of 47Integrated Transportation Security Plan5.3 continued[3] For bulk quantity shipments of hazardous material identified in Table 5 which willcross bridges spanning water, through tunnels under water, or on water which ispatrolled by the USCGS, regardless of whether the shipment is made by highway, railor vessel, advance notification of the shipment or of a series of shipments is to begiven to the affected USCGS Port Authority. The licensee SHALL notify the USCGSat least 10 days before the shipment physically begins within the United States. For shipments where 10 days of advance notice is not possible, the notification is to bemade as soon as practicable. The notification SHALL be made to the appropriateUSCGS Port Authority. (The USCGS may choose to require facility-specificnotification for other materials.)[4] In the event that a shipment of material described in 5.3[3] arrives at the intendedconsignee but is refused by the consignee, the Carrier maintains responsibility forsecurity of the shipment until it arrives at an acceptable destination designated by the shipper.[5]IF the U.S. Department of Homeland Security's (DHS's) National Terrorism AdvisorySystem (NTAS) issues an "Elevated Alert" or "Imminent Alert",ORIF the USCGSMARSEC Level reaches 2 or 3 (as applicable to each plant),THENCategory 1 andCategory 2as well as HRCQ shipments arenot to be shipped

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

NUCLEARMANAGEMENT MANUAL N ON-QUALITY RELATEDEN-RW-106REV. 6 INFORMATIONAL U SEPage 10 of 47Integrated Transportation Security Plan5.5 CARRIER HAZARDOUS MATERIAL TRANSPORTATION SECURITY PLAN[1] The Carrier will affirm each time (i.e., separate shipment) that it has a HazardousMaterial Transportation Security Plan in place prior to approval of the contract orcontract amendment, that the plan meets all applicable Federal and Internationaltransportation security regulations in effect as of the contract or contract amendmentdate, and that said TSP will be updated in a timely manner to remain current withrevised and new Federal and International transportation security regulations.[2] The Carrier is also responsible for implementing regulations for commercial driverlicenses hazardous material endorsements.[3] Advanced approval of the Carrier's TSP is not required for implementation of thiscontract. However, it will be made available for review and approval by an authorizedrepresentative of ENTERGY (EOI / ENOI) if requested and on reasonable verbal orwritten notice, with due consideration given to document security and control.[4] The Transportation Security Plan for Carriers under contract shall be reviewed at leastannually.[5] Prior to dispatching any driver to an ENTERGY (EOI / ENOI) facility for the purposesof transporting hazardous material, the Carrier is to verify that the driver has theappropriate commercial driver license hazardous material endorsements.[6] The carrier is to also notify the designated ENTERGY (EOI / ENOI) representative ofthe name of the driver and any other requested driver identification information, whichwill be used to verify that the appropriate driver has arrived to transport the shipment.[7] Transportation of any of the hazardous materials identified in 49 CFR 172.800 is notto be assigned or subcontracted without the prior written agreement of all parties.NOTESome vendors subcontract carriers to prepare and ship hazardous materials off-site. Forexample, a major maintenance contractor may subcontract an independent transportationcompany to ship hazardous materials from one plant to the next.[8] All contracts OR purchase orders, where applicable, which potentially involvetransportation of the hazardous materials covered in the TSP are to be examined toensure that subcontracted carriers haveAND maintain a TSP acceptable toENTERGY (EOI / ENOI). Consideration is to be given to amending any such contractsto include the preceding language OR to include a restriction similar to the following:"Transportation of any of the hazardous materials identified in 49 CFR 172.800 will notbe assigned or subcontracted without the prior written agreement of all parties."

NUCLEARMANAGEMENT MANUAL N ON-QUALITY RELATEDEN-RW-106REV. 6 INFORMATIONAL U SEPage 11 of 47Integrated Transportation Security Plan5.5 continued[9] It is recommended that an affirmation letter on carrier letterhead paper be receivedfrom the carrier prior to awarding any transportation contract or other scheduledcarrier for radioactive and non-radioactive materials. A copy of the affirmation isavailable in Attachment 9.2, "Sample Carrier Affirmation Letter."

5.6 TRAINING[1] Employees involved with processing (including vehicles) and transporting hazardousmaterial must be provided with the following personnel security awareness andtransportation security training modules:Security Awareness TrainingIn-Depth Transportation Security Training module (including specificinformation on the existence of the company's TSP).[2] Both training modules may supplement the existing hazmat employee trainingprogram consistent with the intent of and frequency specified in 49 CFR 172.704. Re-qualification training will be provided at the same frequency as other hazmatemployee training.[3] All new hazardous material employees must receive this training within 90 days ofemployment.[4] Hazmat employees must receive training required by 49 CFR 172.704 at least onceevery three years.[5] Hazmat employees required to have In-Depth Security Training must receive trainingat least once every three yearsOR IF the security plan for which training is required isrevised during the three-year recurrent training cycle,THEN the employee mustreceive training within 90 days of implementation of the revised plan.[6] Personnel responsible for implementing the Integrated Transportation Security Planshall have refresher training as required by 10 CFR 37.43 at a frequency not toexceed 12 monthsAND when significant changes are made to the security program.[10 CFR 37.43(c)(3)] [CR-WF3-2016-02243]

NUCLEARMANAGEMENT MANUAL N ON-QUALITY RELATEDEN-RW-106REV. 6 INFORMATIONAL U SEPage 12 of 47Integrated Transportation Security Plan5.7 ADDITIONAL SECURITY MEASURES FOR RADIOACTIVE SHIPMENTS -CATEGORY 1 AND CATEGORY 2 QUANTITIES5.7.1 GeneralNOTEThis section is based on the 10 CFR part 37 subpart D final rule, NUREG 2155 Q & A, andNRC response to industry questions.[1] Section 5.7 applies to the following activitiesTransfer and receipt of a category 1 and category 2 quantity of radioactivematerial.Preplanning and coordination of shipments,Physical protection during shipment,Notifications, investigations, and event reporting,[2] Attachments 9.6 through 9.8 of this procedure includes a table of 10 CFR Part 37Subpart D Physical Protection requirement checklists for category 1 and category 2quantity of radioactive material shipments.5.7.2 Transfer of Category 1 and Category 2 Quantities of Radioactive Material5.7.2.1License Verification[1] Any licensee transferring a category 2 quantity of radioactive material is required toperform and document licensee verification activities based on the quantity of materialbeing transferred. The purpose of the licensee verification is to make sure thetransferee's license is valid and authorized to receive the type, form and quantity ofradioactive material transferred. Use Attachment 9.3, "License Verification SystemCredential Guide" to obtain credentials for using the License Verification System.[2] Except for emergencies, the licensee is required to use the Licensee VerificationSystem (LVS) developed by the NRC or contact the regulatory agency (NRC orAgreement State) to verify that the license is valid before shipping a category 2quantity of radioactive material.

NUCLEARMANAGEMENT MANUAL N ON-QUALITY RELATEDEN-RW-106REV. 6 INFORMATIONAL U SEPage 13 of 47Integrated Transportation Security Plan5.7.2.1 continued

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

OR Attachment 9.5, "Manual License VerificationProcedure Guide."[4] The licensee is not required to perform license verification of transfers to theDepartment of Energy, other Federal entities, or transfers within the sameorganization of the licensee. Verification is not required for imports and exports,however the requirements of 10 CFR Part 110, "Export and Import of NuclearEquipment and material," would apply5.7.2.2Category 2 Transfer[1] The licensee transferring the category 2 quantity of radioactive material will verify thetransferee is authorized to receive the radioactive material prior to shipment. Thelicensee uses the LVS or direct contact with the applicable regulatory agency.[2] The licensee may not use a fax, email, or a copy of the recipient's license to verify thetransferee is authorized to receive a category 2 quantity of radioactive material. Theverification of each shipment is required and the licensee should document theverification process used (i.e. LVS, regulatory agency contact, or recipient licenseecertification).

[3]IF the licensees rely on the recipient licensee's certification, as permitted in anemergency situation above,AND later discover the recipient's license is not valid,THEN the licensee should contact the LLEA and the NRC's Operation Center if theshipment has been delivered.5.7.2.3Category 1 Transfer[1] The licensee transferring a category 1 quantity of radioactive material is required tomeet the same requirements as the transfer of a category 2 quantity of radioactivematerial.[2] In addition to the requirements for transfer for category 2 transfers, verify that thereceiving licensee is authorized to receive radioactive material at the addressrequested for delivery.

NUCLEARMANAGEMENT MANUAL N ON-QUALITY RELATEDEN-RW-106REV. 6 INFORMATIONAL U SEPage 14 of 47Integrated Transportation Security Plan5.7.3 Guidance for Physical Protection During TransitNOTESection 5.7.3 addresses the shipping licensee responsibility for implementing 10 CFR Part37 Subpart D requirements for preplanning and coordination and physical protection duringtransit.5.7.3.1Licensee Responsibility[1] The shipping licensee is responsible for meeting the requirements of 10 CFR Part 37Subpart D unless the receiving licensee has agreed in writing to arrange for the in-transit physical protection. The licensee is also responsible for meeting therequirements of Subpart D for category 1 or category 2 quantity of radioactive materialfrom the point that the material enters the United States for import and until thematerial is under the jurisdiction of a U.S. Government agency at a port, bordercrossing, or airport for material exported.[2] The licensee should have a contract with the carrier that obligates the carrier tocomply with the applicable requirements in Subpart D[3] The shipping licensee is responsible for providing physical security of a category 2 orgreater quantity of radioactive material until the carrier accepts the consignment ofradioactive material for shipment and begins movement of the loaded transportvehicle. The shipping licensee's control applies outside of the protective area until thedeparture of the shipment.5.7.3.2Category 1 Shipment[1] The shipping licensee must conduct preplanning and coordination activities with thereceiving licensee and with each state that the shipment enters. The shipping licenseepreplanning and coordination procedures should address, as a minimum, the followingitems:Shipment contract(s) with a carrier that identify carriers responsibilities forimplementing applicable regulations,Protocol for carrier actions to take if a shipment is rerouted during bad weatheror other unusual event,Shipping licensee should preplan and coordinate the shipments arrival anddeparture time with the receiving licensee,Shipping licensee establish protocol for coordinating and contacting thegovernor of the State or the governor's designee, NUCLEARMANAGEMENT MANUAL N ON-QUALITY RELATEDEN-RW-106REV. 6 INFORMATIONAL U SEPage 15 of 47Integrated Transportation Security Plan5.7.3.2[1] continuedShipping licensee works with the States to identify its intention to provideescorts and any additional State-imposed transportation security requirements',Shipping licensee works with the carrier to identify safe haven(s) along theroute at approximately 50 mile intervals, if available,Carrier coordination with State escorts if applicable.[2] The licensee maintains documentation of the above activities as attachments to theshipping package.[3] A licensee that transports, or delivers to a carrier for transport in a single shipment byroad, a category 1 quantity of radioactive material should address the following items,as a minimum:(a) Licensee establishes or uses a carrier that has established movement controlcenters (MCC). The MCC should:Monitor shipments on a continuous basis 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, 7 days aweek,Maintain the ability to immediately communicate with LLEA in anemergency,Provide positive confirmation of the location of the shipment, its status,individuals in control of the shipment,Develop and implement preplanned procedures in response todeviations from the authorized route (s), ORProvide notification of actual or attempted theft or diversion or suspiciousactivity related to the theft, loss, or diversion of a shipment,Immediately awareness if a shipment deviates from shipping plans,planned route, unscheduled stops, or scheduled stops longer thanexpected,Redundant communications consisting of two systems that do not relyon the same hardware or software to transmit a signal,The use of telemetric monitoring system to permit the remote monitoringand reporting of the location of a transport vehicle or package, NUCLEARMANAGEMENT MANUAL N ON-QUALITY RELATEDEN-RW-106REV. 6 INFORMATIONAL U SEPage 16 of 47Integrated Transportation Security Plan5.7.3.2[3](a) continuedEnsure carrier provides a second individual when the driving time periodis greater than the maximum number of allowable hours of service in a 24-hour duty day as established by the DOT,The driver or accompanying individual or both perform the following:Periodically call the MCC to provide verbal status of the shipmentand delivery,Maintain vigilance of the surrounding environment duringtransport,Maintain constant visual surveillance when transport vehicle is stopped,Periodically walk around vehicle while it is not in motion, toconfirm no apparent safety or security related issues,Confirm no evidence of tampering with the contents of the vehicleor no unusual or suspicious activity in the immediate vicinity.Normal operating procedures address activities to meet regulatoryrequirements:Refueling and comfort stops,Meal stops, andRoutine check-in.(b) Contingency procedures address issues that could interfere with complianceduring preparation for transport or during transport:Bad weather,Suspicious activities,Mechanical breakdown,Road or bridge closures, detours, accidents, orAcute illness.

NUCLEARMANAGEMENT MANUAL N ON-QUALITY RELATEDEN-RW-106REV. 6 INFORMATIONAL U SEPage 17 of 47Integrated Transportation Security Plan5.7.3.2[3](b) continuedCommunication protocol for:Duress codes to enable off-site individual to signal the need forassistance,Authentication codes to confirm the true identity of the employee,Loss of communication actions to take.(c) Licensee ensures access to normal and contingency procedures by drivers,accompanying personnel, and MCC personnel.5.7.3.3Category 2 Shipment[1] A licensee that transports, or delivers to a carrier for transport in a single shipment byroad, a category 2 quantity of radioactive material should include the following itemsas a minimum in its preplanning and coordination process:Coordinate the expected arrival time and the no-later-than (NLT) arrival time,and the method of notification of receipt of shipment with the receiving licensee.Shipping licensee initiates investigation if shipment has not arrived by morethan 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> past NLTThe receiving licensee confirms to the shipping licensee that the shipment hasarrived by phone, e-mail, or facsimile as agreed in the preplanning andcoordination activities.Shipping licensee notifies the receiving licensee of any new NLT arrival time assoon as practicable after the driver or authorized member of the transfer crewdetermines the category 2 shipment cannot arrive before the NLT arrival time.[2] A licensee that transports category 2 quantity of radioactive material should addressthe following items, as a minimum:Establishment of a security zone around the radioactive material, the use of thetransport vehicle is permitted,[37.47(a)]Limit access to the security zone to authorized individuals,[37.47(c)]Monitor, detect, assess, and respond to any unauthorized access,[37.49]

NUCLEARMANAGEMENT MANUAL N ON-QUALITY RELATEDEN-RW-106REV. 6 INFORMATIONAL U SEPage 18 of 47Integrated Transportation Security Plan5.7.3.3 continued[3] A licensee that transports, or delivers to a carrier for transport in a single shipment byroad, a category 2 quantity of radioactive material should address the following items,as a minimum:The use of carriers with an established, documented package tracking systemthat allows shipping licensee to see the chain of custody for the package andwho is accountable at each stage of the trip,The shipping licensee or carrier can promptly determine if the shipment is lostor missing,The tracking system requires an authorized signature (receiving licenseesemployee or contractor) before release for delivery or return,Licensee's carrier maintains constant control and surveillance during transitwith capability to immediately summon response by an armed LLEA, trained emergency services personnel to prevent or mitigate any collateral impacts of asafety event, or immediately requests assistance for emergency or urgentconditions to avoid or minimize unplanned delay of shipment.Immediate communication to summon response or assistance may be met withcell or satellite phones and two-way radios. No backup communication systemis required.The licensee's carrier maintains a package-tracking system with a reliable on-demand capability to ascertain the last location and current status of theshipment.[4] A licensee who transports, or delivers to a carrier for transport in a single shipment byrail, a category 2 quantity of radioactive material should address the following items,as a minimum:The use of a carrier with a documented, proven, and reliable tracking system,The capability to allow the shipping licensee or carrier to identify when andwhere package was when the train last reported, and when it will arrive at the next point of control,The carrier maintains constant control and surveillance during transit and hasthe capability for immediately communication to summon an appropriateresponse or assistance, NUCLEARMANAGEMENT MANUAL N ON-QUALITY RELATEDEN-RW-106REV. 6 INFORMATIONAL U SEPage 19 of 47Integrated Transportation Security Plan5.7.3.3[4] continuedImmediate communication to summon response or assistance may be met withcell or satellite phones, and two-way radios. No backup communication system is required,The tracking system requires an authorized signature (receiving licensees'employee or contractor) before release for delivery or return.5.7.4 Advance Notification of Shipment of Category 15.7.4.1Advance Notification[1] The shipping licensee provides advance notification to the NRC and the governor of aState or the governor's designee in writing and postmarked 7 days before theshipment begins.[2] Notifications by fax or email are required 4 days before transport within or through the state.[3] The shipping licensee should confirm the notification by fax or its intended recipientreceives email. The preferred notification method to the NRC is by email toRAMQC_SHIPMENTS@nrc.gov or by fax to 301-816-5151. The contact informationof governors and governor's designee is available on the NRC Web site at http://nrc-stp.ornl.gov/special/designee.pdf[4] The following is a summary of the information to be furnished in an AdvanceNotification of Shipment:The name, address, and telephone number of the shipper, carrier, and receiverof the category 1 radioactive material,The license numbers of the shipper and receiver,A description of the radioactive material contained in the shipment, includingthe radionuclides and quantity,The point of origin of the shipment and the estimated time and date that theshipment will commence,The estimated time and date that the shipment is expected to enter each Statealong the route,The estimated time and date of arrival of the shipment at the destination,A point of contact, with a telephone number, for current shipment information.

NUCLEARMANAGEMENT MANUAL N ON-QUALITY RELATEDEN-RW-106REV. 6 INFORMATIONAL U SEPage 20 of 47Integrated Transportation Security Plan5.7.4.1 continued[5] The licensee is expected to include all of the above information when it makes theinitial advance notification. Any missing information is required to be provided beforecommencement of the shipment.5.7.4.2Updating Advance Notification[1] The shipping licensee is required to provide a revision notice with any information thatwas not available when the initial notification was submitted.[2] The shipping licensee is required to notify any affected State's governor or designeeas soon as it discovers or is advised of the following changes in the shipment:A change is made to the description of the radioactive material radionuclides orquantities,A change is made in the shipment's point of origin or estimated time or date ofcommencement,A change of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> or more is made in the estimated time or date that theshipment is expected to enter each State along the route,A change of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> or more is made in the estimated time or date of arrival ofthe shipment at the destination,A change is made in the name or telephone number of the point of contact forcurrent shipment information.[3] The driver or other authorized member of the transfer crew is to make notification ofany changes in shipment information en route as soon as the change is determined.

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

NUCLEARMANAGEMENT MANUAL N ON-QUALITY RELATEDEN-RW-106REV. 6 INFORMATIONAL U SEPage 21 of 47Integrated Transportation Security Plan5.7.5 Reporting of Events5.7.5.1Shipment Investigations

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

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

NUCLEARMANAGEMENT MANUAL N ON-QUALITY RELATEDEN-RW-106REV. 6 INFORMATIONAL U SEPage 22 of 47Integrated Transportation Security Plan5.7.5.2Category 1 Notifications[1] The shipping licensee must make the following notifications after determining ashipment of category 1 quantities of radioactive material is lost or missing:Notify the LLEA as soon as the carrier has completed its first unsuccessfulattempt to locate the material and confirmed its inability to trace it was not aresult of human error, or a malfunction of the position monitoring system,Notify the NRC Operations Center within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after determining the category1 shipment is lost or missing. Discuss with the NRC the expected frequency of updates,Notify the NRC and the LLEA as soon as possible when the lost or missinglicensed material is again in the physical possession of, or in a locationotherwise under the control of the carrier, shipping, or recipient licensee,authorized State or Federal agency, or an LLEA that is able to prevent or deterunauthorized access to the material.[2] The shipping licensee must make the following notifications as soon as possible upondiscovery of any actual or attempted theft, or diversion of a shipment, or suspiciousactivities related to the theft or diversion of a shipment of a category 1 quantity ofmaterial:Notify the designated LLEA along the shipment route as soon as possible,ANDNotify the NRC Operations Center (301-816-5100). The NRC will notify otheraffected States and Federal partners as appropriate.[3] The Transportation Security Administration (TSA) has guidance for private or contractcarrier employees that list a number of activities that may be considered suspicious.[4] A written report is required to be submitted to the NRC within 30 days of the shippinglicensee's initial telephonic notifications that a shipment of category 1 material is lostor missing, or telephonic notification of actual, or attempted theft or diversion of ashipment of category 1 material.

NUCLEARMANAGEMENT MANUAL N ON-QUALITY RELATEDEN-RW-106REV. 6 INFORMATIONAL U SEPage 23 of 47Integrated Transportation Security Plan5.7.5.2 continued[5] The written report is provided to the Director, Division of Security Policy, Office ofNuclear Security and Incident Response and must provide the following information:A description of the licensed material involved, including kind, quantity, andchemical and physical form;A description of the circumstances under which the loss or theft occurred;A statement of disposition, or probable disposition, of the licensed materialinvolved;Actions that have been taken, or will be taken to recover the material;Procedures or measures that have been, or will be, adopted to ensure againsta recurrence of the loss or theft of licensed material.[6] After filing the written report, if the shipping licensee gathers any information notpreviously reported to the NRC, such as findings from a completed investigation of theloss or theft of category 1 material, the licensee has to report that additionalinformation within 30 days.[7] A Condition Report will be initiated to document any actual or attempted theft ordiversion of a shipment or any suspicious activity related to a shipment of category 1quantities of radioactive material.[8] Contact the site Licensing group in the event of an accident (e.g., shipment is lost,missing, actual or attempted theft or diversion, vehicular accident etc.) involvingcategory 1 quantities of radioactive material to ensure appropriate notification of ANI ismade.5.7.5.3Category 2 Notifications[1] The shipping licensee is required to notify the NRC Operations Center within 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />sof its determining a shipment of category 2 quantities of radioactive material is lost ormissing. If after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from its determination the licensee still cannot locate thematerial, the NRC operations Center must be notified again.[2] The shipping licensee is also required to notify the NRC Operations Center as soon aspossible after discovery of an actual or attempted theft or diversion of a category 2quantity shipment or any suspicious activity related to a shipment.[3] The shipping licensee is required to notify the NRC Operations Center when a lost ormissing shipment of category 2 quantities of radioactive material has been located.

NUCLEARMANAGEMENT MANUAL N ON-QUALITY RELATEDEN-RW-106REV. 6 INFORMATIONAL U SEPage 24 of 47Integrated Transportation Security Plan[4] A written report is required to be submitted to the NRC within 30 days of the shippinglicensee initial telephonic notifications that a shipment of category 2 material is lost ormissing or telephonic notification of actual or attempted theft or diversion of ashipment of category 1 material.[5] After filing the written report, if the shipping licensee gathers any information notpreviously reported to the NRC, such as findings from a completed investigation of theloss or theft of category 2 materials, the licensee has to report that additionalinformation to the NRC within 30 days.[6] A Condition Report will be initiated to document any actual or attempted theft ordiversion of a shipment or any suspicious activity related to a shipment of category 2quantities of radioactive material.[7] Contact the site Licensing group in the event of an accident (e.g., shipment is lost,missing, actual or attempted theft or diversion, vehicular accident etc.) involvingcategory 2 quantities of radioactive material to ensure appropriate notification of ANI ismade.5.7.6 Records5.7.6.1Documentation[1] The records that result from the activities in this procedure are to be retained aminimum of three years as required but typically through the life of the nuclear powerplant's license.[2] The following records are generated as a result of implementing this section:Licensee verification documentationDocumentation for preplanning and coordination, and any revision.Documentation is to include:Any phone conversations or e-mail communications that it has with thereceiving licensee to include the names of the individuals participating inthe call or e-mail communications a general description of the shipment,and the departure and arrival timesAny interactions with the governor's designee to include the names ofthe individuals participating in the call or e-mail, the route-affected States' decisions on escorts, the safe havens identified, and any otherinformation that the licensee considers pertinentAdvance notification and any revision and cancellation notices NUCLEARMANAGEMENT MANUAL N ON-QUALITY RELATEDEN-RW-106REV. 6 INFORMATIONAL U SEPage 25 of 47Integrated Transportation Security Plan5.7.6.1[2] continuedWritten reports and additional substantive information[3] Records resulting from the activities in this procedure are to be retained with recordsgenerated by EN-RW-102, "Radioactive Shipping Procedure."5.7.6.2Protection of Information[1] The information to be furnished in advance notification of category 1 quantities ofradioactive material shipment shall be protected against unauthorized disclosure asspecified in 10 CFR 73.21 Protection of Safeguards Information: Performancerequirements. The schedule information specified in 37.77(b) is provided to Stateofficials, State employees, and other individuals that are not licensees of the NRC oran Agreement State.[2] The governor of a State or his or her designated State employee representative,Federal, State, or local law enforcement personnel are relieved from the fingerprinting,identification, and criminal history records checks, and other elements of backgroundinvestigations and are permitted access to the category 1 shipping information.[3] A licensee that plans to transport or deliver to a carrier for transport, licensed materialthat is a category 1 quantity of radioactive material will only use carriers that certifythey have an access authorization program that meets the requirements of 10 CFR73.21 and 10 CFR 73.23. The carrier must include in the access authorizationprogram the vehicle drivers, accompanying individuals, movement control centerpersonnel, and any individual whose assigned duties provide access to shipment information on category 1 quantities of radioactive material.[4] The shipment of category 2 quantities of radioactive material does not require thecommercial drivers and package handlers to meet the access authorization programrequirements since these individuals are subject to DOT security requirements.5.8 TYPES OF HAZMAT SHIPMENTS ADDRESSED BY THE ENTERGY (EOI / ENOI)TSP-RA[1] Specifically for Nuclear Power Reactors, this transportation security plan (TSP)applies to:(a) Radioactive laundry shipments,(b) Some shipments of low-level radioactive waste (dry active waste) to offsite processors,(c) Some shipments of radioactive vendor equipment offsite, and NUCLEARMANAGEMENT MANUAL N ON-QUALITY RELATEDEN-RW-106REV. 6 INFORMATIONAL U SEPage 26 of 47Integrated Transportation Security Plan5.8[1] continued(d) Shipments of processed radioactive waste and reactor hardware for offsitedisposal.NOTEFor Highway Route Controlled Quantity shipments of radioactive materials, the shipper mustrefer to the NRC Physical Security Plan along with the Additional Security Measures forRadioactive Shipments - Category 1 and Category 2 Quantities (Section 5.7 of thisprocedure).[2] A highway route-controlled quantity of a Class 7 (radioactive) material, as defined in49 CFR 173.403, in a motor vehicle, rail car, or freight container;[3] More than 25 kg (55 pounds) of a Division 1.1, 1.2, or 1.3 (explosive) material in amotor vehicle, rail car, or freight container;[4] More than one L (1.06 qt) per package of a material poisonous by inhalation, asdefined in Part 171.8 of this subchapter, that meets the criteria for Hazard Zone A, asspecified in § 173.116(a)or 173.133(a) of this subchapter;[5] A shipment of a quantity of hazardous materials in bulk packaging having a capacityequal to or greater than 13,248 L (3,500 gallons) for liquids or gases or more than13.24 cubic meters (468 cubic feet) for solids;[6] A shipment in other than a bulk packaging of 2,268 kg (5,000 pounds) gross weight ormore of one class of hazardous materials for which placarding of a vehicle, rail car, orfreight container is required for that class under the provisions of subpart F of this part;[7] A select agent or toxin regulated by the Centers for Disease Control and Preventionunder 42 CFR part 73; or[8] A quantity of hazardous material that requires placarding under the provisions ofsubpart F of this part.5.9 INFORMATION[1] Attachment 9.1 provides all associated tables that are applicable to the ENTERGY(EOI / ENOI) Risk Assessment.

NUCLEARMANAGEMENT MANUAL N ON-QUALITY RELATEDEN-RW-106REV. 6 INFORMATIONAL U SEPage 27 of 47Integrated Transportation Security Plan6.0 INTERFACES[1] EN-RW-102, "Radioactive Shipping Procedure" 7.0 RECORDSNOTERecords resulting from the activities in this procedure are retained with records generated byEN-RW-102, "Radioactive Shipping Procedure."[1] Licensee verification documentation[2] Documentation for preplanning and coordination, and any revision[3] Advance notification and any revision and cancellation notices[4] Written reports and additional substantive information[5] Attachment 9.6, "10 CFR37 Subpart D Category 1 Physical Protection Requirement Checklist"[6] Attachment 9.7, "10 CFR37 Subpart D Category 2 Physical Protection Requirement Checklist"[7] Attachment 9.8, "10 CFR 37 Subpart D Category 1 Quantities of Concern StateCoordination Log"8.0 SITE SPECIFIC COMMITMENTS None NUCLEARMANAGEMENT MANUAL N ON-QUALITY RELATEDEN-RW-106REV. 6 INFORMATIONAL U SEPage 28 of 47Integrated Transportation Security Plan9.0 ATTACHMENTS9.1 TSP-RA Tables9.2 Sample Carrier Affirmation Letter9.3 License Verification System Credential Guide9.4 Manual License Verification Form Guide 9.5 Manual License Verification Procedure Guide 9.6 10 CFR 37 Subpart D Category 1 Physical Protection Requirement Checklist 9.7 10 CFR 37 Subpart D Category 2 Physical Protection Requirement Checklist 9.8 10 CFR 37 Subpart D Category 1 Quantities of Concern State Coordination Log NUCLEARMANAGEMENT MANUAL N ON-QUALITY RELATEDEN-RW-106REV. 6 INFORMATIONAL U SEPage 29 of 47Integrated Transportation Security Plan ATTACHMENT9.1TSP-RATABLESSheet 1 of 6[33 CFR 105.400]TABLE 1Typical Radioactive and Hazardous Materials ShipmentsRADIOACTIVE MATERIALS SHIPMENTSTYPES OF MATERIALS SHIPPEDTYPICAL MATERIALS IN SHIPMENTRadioactive Material Category 1 and Category 2 asdefined in Attachment 9.1, Table 4, "Category 1 andCategory 2 Threshold".Examples include, but are not limited to: certain radioactivecalibration sources, ion-exchange resin, certain activated reactorcomponents and limited amounts of irradiated reactor fuel.Highway route controlled quantities (HRCQ) of radioactive material.Highly irradiated reactor components; some Greater Than ClassC (GTCC) wastes.Shipment of Type B quantities of radioactive materials in an NRC-approved shipping container.High activity resin, filters, and irradiated reactor components,such as control rod blades and velocity limiters.Shipment of radioactive materials in bulk packaging of 3,500 gallons or more for liquids or 468 cubic feet or more for solids.Radioactively contaminated oil or aqueous liquids; routine sea-land and inter-modal containers of dry active waste.Shipment in other than bulk packaging of 5,000 pounds or more of radioactive materials that is required to be placarded.Most shipments made in Type A or Type B casks.A quantity of radioactive material that requiresplacarding.Most radioactive waste shipments, laundry shipments, vendorequipment shipments.HAZARDOUS MATERIALS SHIPMENTSTYPES OF MATERIALS SHIPPEDTYPICAL MATERIALS IN SHIPMENTA quantity of hazardous materials in a bulk packaginghaving a capacity equal to or greater than 3500 gallons(13,248 liters) for liquids or gases or more than 468 ft 3 (13.24 m 3) for solids.Most shipments of diesel fuel, used oil,acids, caustics, sodiumhypochlorite, and similar hazmat.A quantity of hazardous material that requires placarding.Most shipments of hazardous waste (such as paint waste, partscleaning solutions, and lab packs), liquid and solid mixed waste, PCB waste, asbestos and waste water treatment chemicals.

NUCLEARMANAGEMENT MANUAL N ON-QUALITY RELATEDEN-RW-106REV. 6 INFORMATIONAL U SEPage 30 of 47Integrated Transportation Security Plan ATTACHMENT9.1TSP-RATABLESSheet 2 of 6TABLE 2Hazmat Carriers, Types of Hazmat Shipments, and Quantities Shipped CARRIERCATEGORYTYPICAL MATERIALSTRANSPORTED BY THISCARRIER CATEGORYMAXIMUM QUANTITIESPER SHIPMENTLaundry services suppliers1. Radioactive laundry2. Low activity DAWCo-60 = < 1 CiCs-137 = < 1 CiPlant maintenance equipmentand services suppliers (includingtheir subcontracted Carriers)1. Low activity radioactive materialCo-60 = < 8.1 CiCs-137 = < 10 CiWaste processors

, and otherwaste Carriers and HazmatCarriers1. Radioactive materials and waste2. Reactor components and otherirradiated hardware3. Vendor equipment4. Hazardous waste5. Mixed waste

6. PCB waste 7. Asbestos wasteHRCQ, excluding spentfuel (rarely)RAMQC (rarely)Type A and Type BLSA/SCOBulk and/or placardedhazmatCommon carrier (FederalExpress, UPS)Radioactive sourcesCould be Category 1 or 2EntergyRadioactive material/specialtools/sourcesCould be Category 1 or 2 NUCLEARMANAGEMENT MANUAL N ON-QUALITY RELATEDEN-RW-106REV. 6 INFORMATIONAL U SEPage 31 of 47Integrated Transportation Security Plan ATTACHMENT9.1TSP-RATABLESSheet 3 of 6TABLE 3Determination of Hazardous Materials of Significance to This Assessment (a)HazardClass (b)Hazard Class Division Of Concern (c)(c)General Description of Significant Hazard or Class (d)Typical Materials Shipped in this Hazard Class Division by these Facilities and Discussion of Relative Significance (e)Significance to This Risk Assessment11.1, 1.2,1.3ExplosivesNo significant quantity of explosives are shippedby these facilities.

None22.3Poison Gas(inhalation hazard)Anhydrous ammonia gas, chlorine gas.High3NoneFlammable (liquids) Diesel fuel, gasoline, paint, solvents. Thesematerials are relatively low toxicity (i.e., are notacutely toxic; do not contain lethal concentrations or doses).

Low44.3Dangerous WhenWetSodium. No significant quantities of suchmaterials are shipped by these facilities.

(Significant quantities may be shipped by sodium-moderated reactors if any are included in the facility listing in Section 1.1. Significance would be Low.)

None55.2Organic Peroxide,Type B (may be liquid or solid and are thermallycontrolled)Type B organic peroxides can undergo a thermalexplosion. As a genera; rule, they are not shipped by any of these facilities. In the event a shipment becomes necessary, the shipment ispre-approved in writing by the DOT AssociateAdministrator and is shipped in accordance with the instructions provided by the Associate Administrator.

None66.1Poison InhalationHazard (liquid poisons)Hydrazine and most other hazmat in this divisionare not Hazard Zone A or B (Package Group I)and are, therefore, notHighsignificance.)Note: some plants may still have stabilizedacrolein on site, which would beHighsignificance.)Medium8NoneCorrosivesAcids, caustics. These materials are relativelylow toxicity (i.e., are not acutely toxic; do notcontain lethal concentrations or doses).

Low9NoneMiscellaneousHazardous waste, solid, n.o.s.; Hazardouswaste, liquid, n.o.s.; asbestos; PCBs. Thesematerials are relatively low toxicity (i.e., are notacutely toxic; do not contain lethal concentrationsor doses).

Low NUCLEARMANAGEMENT MANUAL N ON-QUALITY RELATEDEN-RW-106REV. 6 INFORMATIONAL U SEPage 32 of 47Integrated Transportation Security Plan ATTACHMENT9.1TSP-RATABLESSheet 4 of 6TABLE 4Category 1 and Category 2 ThresholdThe terabecquerel (TBq) values are the regulatory standard. The curie (Ci) values specifiedare obtained by converting from the TBq value. The curie values are provided for practicalusefulness only.RadioactivematerialCategory 1(TBq)Category 1 (Ci)Category 2(TBq)Category 2 (Ci)Americium-241601,6200.616.2Americium-241/Be601,6200.616.2Californium-252205400.25.40Cobalt-60308100.38.10Curium-244501,3500.513.5Cesium-1371002,700127.0Gadolinium-1531,00027,00010270Iridium-192802,1600.821.6Plutonium-238601,6200.616.2Plutonium-239/Be601,6200.616.2Promethium-14740,0001,080,00040010,800Radium-226401,0800.410.8Selenium-752005,400254.0Strontium-901,00027,00010270Thulium-17020,000540,0002005,400Ytterbium-1693008,100381.0Continued on next page NUCLEARMANAGEMENT MANUAL N ON-QUALITY RELATEDEN-RW-106REV. 6 INFORMATIONAL U SEPage 33 of 47Integrated Transportation Security Plan ATTACHMENT9.1TSP-RATABLESSheet 5 of 6 Note:Calculations Concerning Multiple Sources or Multiple RadionuclidesThe "sum of fractions" methodology for evaluating combinations of multiple sources ormultiple radionuclides is to be used in determining whether a location meets or exceeds thethreshold and is thus subject to the requirements of this procedure.I. If multiple sources of the same radionuclide and/or multiple radionuclides are aggregatedat a location, the sum of the ratios of the total activity of each of the radionuclides must bedetermined to verify whether the activity at the location is less than the category 1 orcategory 2 thresholds of Table 4, as appropriate. If the calculated sum of the ratios, using theequation below, is greater than or equal to 1.0, then the applicable requirements of this part apply.II. First determine the total activity for each radionuclide from Table 4. This is done by addingthe activity of each individual source, material in any device, and any loose or bulk materialthat contains the radionuclide. Then use the equation below to calculate the sum of the ratiosby inserting the total activity of the applicable radionuclides from Table 4 in the numerator ofthe equation and the corresponding threshold activity from Table 4 in the denominator of theequation.Calculations must be performed in metric values (i.e., TBq) and the numerator anddenominator values must be in the same units.

R 1 = total activity for radionuclide 1 R 2 = total activity for radionuclide 2 R N = total activity for radionuclide n AR 1 = activity threshold for radionuclide 1 AR 2 = activity threshold for radionuclide 2 AR N = activity threshold for radionuclide n NUCLEARMANAGEMENT MANUAL N ON-QUALITY RELATEDEN-RW-106REV. 6 INFORMATIONAL U SEPage 34 of 47Integrated Transportation Security Plan ATTACHMENT9.1TSP-RATABLESSheet 6 of 6TABLE 5Hazardous Materials of Significant Concern Shipped From FacilitiesHazard Class DivisionOf ConcernGeneral Descriptionof SignificantHazard or ClassTypical Materials Shipped in this Hazard Class Division bythese Facilities and Discussion of Relative Significance2.3Poison Gas(inhalation hazard)Anhydrous ammonia gas, chlorine gas.

NUCLEARMANAGEMENT MANUAL N ON-QUALITY RELATEDEN-RW-106REV. 6 INFORMATIONAL U SEPage 35 of 47Integrated Transportation Security Plan ATTACHMENT9.2SAMPLE CARRIER AFFIRMATION LETTERSheet 1 of 1EXAMPLE: Date:To: Entergy (EOI / ENOI)(Appropriate Site Address)

Subject:

Carrier Hazardous Material Transportation Security Plan(Carrier Company Name) affirms that we have a Hazardous Material Transportation SecurityPlan in place which meets all applicable Federal and International transportation securityregulations in effect as of the contract or contract amendment date, and that saidTransportation Security Plan will be updated in a timely manner to remain current withrevised and new Federal and International transportation security regulations. We furtheraffirm that our Transportation Security Plan fully implements the regulations for commercialdriver licenses hazardous material endorsements.Our Transportation Security Plan will be made available for review and approval by anauthorized representative of ENTERGY (EOI / ENOI) NS if requested and on reasonableverbal or written notice, with due consideration given to document security and control. Weunderstand that we will not mail, send, or otherwise transmit any confidential documents toENTERGY (EOI / ENOI).Prior to dispatching any driver to an ENTERGY (EOI / ENOI) facility for the purposes oftransporting hazardous material, we will verify that the driver has the appropriate commercialdriver license hazardous material endorsements. We also agree to notify a designatedENTERGY (EOI / ENOI) representative of the name of the driver and any other requesteddriver identification information, which will be used to verify that the appropriate driver hasarrived to transport the shipment.It is further agreed that transportation of any of the hazardous materials identified in 49 CFR172.800 will not be assigned or subcontracted without the prior written agreement of all parties.Authorized Carrier Representative Signature Block NUCLEARMANAGEMENT MANUAL N ON-QUALITY RELATEDEN-RW-106REV. 6 INFORMATIONAL U SEPage 36 of 47Integrated Transportation Security Plan ATTACHMENT9.3LICENSE VERIFICATION SYSTEM CREDENTIAL GUIDESheet 1 of 1NOTEThe purpose of this guide is to aid individuals in getting credentialed for using the NRCLicense Verification System (LVS).The NRC LVS web site provides an on-line User Guide.[1] Using a web browser, go to http://www.nrc.gov.[2] Click on "Nuclear Security" tab.[3] Click on the "Radioactive Material Security" bulleted item.[4] Click on "License Verification System (LVS)" under "NRC Activities for RadioactiveMaterial Security."[5] Click on "Get credentialed for LVS." A public Disclosure of Submitted Information will appear.IF you want to continue with getting your LVS Credentialed,THEN click on "IACCEPT."[6] After you mouse click on I ACCEPT, the Web Page Portfolio Enrollment Module willappear. Fill out all the information requested from the Portfolio Enrollment RequestForm. Once all the required information blocks are filled out, mouse click on Submit atthe lower right corner of the request form.

NUCLEARMANAGEMENT MANUAL N ON-QUALITY RELATEDEN-RW-106REV. 6 INFORMATIONAL U SEPage 37 of 47Integrated Transportation Security Plan ATTACHMENT9.4MANUAL LICENSE VERIFICATION FORM GUIDESheet 1 of 2[1] Using a web browser, go to http://www.nrc.gov.[2] Click on "Nuclear Security" tab.[3] Click on "Radioactive Material Security" bulleted item.[4] Click on "License Verification System (LVS)" under "NRC Activities for RadioactiveMaterial Security."[5] Click on "Manual License Verification Form." A PDF document similar to the followingshould display.

NUCLEARMANAGEMENT MANUAL N ON-QUALITY RELATEDEN-RW-106REV. 6 INFORMATIONAL U SEPage 38 of 47Integrated Transportation Security Plan ATTACHMENT9.4MANUAL LICENSE VERIFICATION FORM GUIDESheet 2 of 2[6] Save the form in PDF format.NOTEAt this time the green "Submit by E-mail" button on the form does not work.

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

NUCLEARMANAGEMENT MANUAL N ON-QUALITY RELATEDEN-RW-106REV. 6 INFORMATIONAL U SEPage 39 of 47Integrated Transportation Security Plan ATTACHMENT9.5MANUAL LICENSE VERIFICATION PROCEDURE GUIDESheet 1 of 2Manual License VerificationNOTEThe purpose of this attachment is to guide licensees transferring Category 1 and/or Category2 quantities of radioactive materials in verifying licenses outside of the License VerificationSystem (LVS).Steps for Licensees[1] Contact the LVS Help Desk by phone at 1-877-671-6787 or by email atLVSHelp.Resource@nrc.gov.[2] Be prepared to provide the following information to the LVS Help Desk representative.(a) Transferring licensee information:License-issuing agencyLicensee nameLicense numberContact name and titleContact phoneContact emailContact fax number(b) Receiving licensee information:License-issuing agencyLicensee nameLicense numberAmendment number or license issue dateAuthorized storage location addressMaterial(s) being requestedChemical/Physical form of the material(s) being requestedQuantity/Activity being requested NUCLEARMANAGEMENT MANUAL N ON-QUALITY RELATEDEN-RW-106REV. 6 INFORMATIONAL U SEPage 40 of 47Integrated Transportation Security Plan ATTACHMENT9.5MANUAL LICENSE VERIFICATION GUIDESheet 2 of 2[3] The transferring licensee will receive notification from the LVS Help Desk of theverification outcome as soon as the verification is complete by the license issuingregulatory agency.[4] The verification outcome will include a notification of whether:(a) The requested materials, quantities, and authorized location are authorized onthe license, OR(b) The requested materials, quantities, and/or authorized location are NOTauthorized on the license, OR(c) Other reason (with an explanation)[5] The licenseemust keep a copy of the verification outcome sent by the LVS HelpDesk for their records in accordance with the 10 CFR Part 37 requirements for keeping records of license verifications.

NUCLEARMANAGEMENT MANUAL N ON-QUALITY RELATEDEN-RW-106REV. 6 INFORMATIONAL U SEPage 41 of 47Integrated Transportation Security Plan ATTACHMENT9.610CFR37SUBPART DCATEGORY 1PHYSICAL PROTECTION REQUIREMENT CHECKLISTSheet 1 of 4Shipment Number: _______________________[1] Verify the recipient is authorized to receive the type, form and quantity of material perNRC's License Verification System OR License Issuing Authority in accordance with 10 CFR 37.71(initials)[2] Verify the delivery address matches the location authorized in the recipient's license.(initials)[3] Attach documentation of license verification.(initials)

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

Planned arrival date and time: __________________________________(initials)

NUCLEARMANAGEMENT MANUAL N ON-QUALITY RELATEDEN-RW-106REV. 6 INFORMATIONAL U SEPage 42 of 47Integrated Transportation Security Plan ATTACHMENT9.610CFR37SUBPART DCATEGORY 1PHYSICAL PROTECTION REQUIREMENT CHECKLISTSheet 2 of 4[6] Provide advance notification to the NRC prior to transport per 10 CFR 37.77.Notification by mail must be postmarked at least seven (7) days prior tocommencement of transport. Other means of notification must reach NRC at leastfour (4) days prior to shipment commencement.Information required in notification.

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

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

NUCLEARMANAGEMENT MANUAL N ON-QUALITY RELATEDEN-RW-106REV. 6 INFORMATIONAL U SEPage 43 of 47Integrated Transportation Security Plan ATTACHMENT9.610CFR37SUBPART DCATEGORY 1PHYSICAL PROTECTION REQUIREMENT CHECKLISTSheet 3 of 4[9] Verify the carrier meets the requirements for physical protection of Category 1quantities of radioactive material during shipments by road per 10 CFR 37.79(a).(initials)

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

NUCLEARMANAGEMENT MANUAL N ON-QUALITY RELATEDEN-RW-106REV. 6 INFORMATIONAL U SEPage 44 of 47Integrated Transportation Security Plan ATTACHMENT9.610CFR37SUBPART DCATEGORY 1PHYSICAL PROTECTION REQUIREMENT CHECKLISTSheet 4 of 4

[13]IF the highway shipment driving time is greater than the maximum number of hoursestablished by the Department of Transportation,THEN verify there is anaccompanying individual.(initials)

[14]Verify that the U.S. Department of Homeland Security's (DHS's) National TerrorismAdvisory System (NTAS) has not issued an "Elevated Alert" or "Imminent Alert",OR/IF the USCGS MARSEC Level has not reached 2 or 3 (as applicable to eachplant), prior to shipment.(initials)[15] Notify Site Security (S.A.S) of shipment AND have Security make a log entry.Date and time of notification: ________________________Security point of contact: ___________________________Security log entry number: __________________________(initials)Performed by (print, sign, date): _______________________________________________

Reviewed by (print, sign, date): ________________________________________________

NUCLEARMANAGEMENT MANUAL N ON-QUALITY RELATEDEN-RW-106REV. 6 INFORMATIONAL U SEPage 45 of 47Integrated Transportation Security Plan ATTACHMENT9.710CFR37SUBPART DCATEGORY 2PHYSICAL PROTECTION REQUIREMENT CHECKLISTSheet 1 of 2Shipment Number: _______________________[1] Verify the recipient is authorized to receive the type, form and quantity of material perNRC's License Verification System OR License Issuing Authority in accordance with 10 CFR 37.71(initials)[2] Attach documentation of license verification.(initials)

[3]IF shipping to a licensee in an agreement state,THEN obtain written verification oflicensee compliance with physical security requirements for Category 2 quantities ofradioactive materials in accordance with 10 CFR 37. Attach verificationdocumentation.(initials)[4] Pre-plan and coordinate shipment arrival and departure times with receiving licensee.Planned departure date and time: _________________________________

Planned arrival date and time: __________________________________

No-Later-Than date and time: ___________________________________(initials)[5] Verify the carrier meets the requirements for physical protection of Category 2quantities of radioactive material during shipments by road per 10 CFR 37.79(a).(initials)[6] Verify the carrier has established a package tracking system that allows the shipper ortransporter to identify where the package was last and when it should arrive at thenext point of control.(initials)

NUCLEARMANAGEMENT MANUAL N ON-QUALITY RELATEDEN-RW-106REV. 6 INFORMATIONAL U SEPage 46 of 47Integrated Transportation Security Plan ATTACHMENT9.710CFR37SUBPART DCATEGORY 2PHYSICAL PROTECTION REQUIREMENT CHECKLISTSheet 2 of 2[7] Verify the carrier has constant control and/or surveillance during transit and has thecapability for immediate communication to summon appropriate response or assistance.(initials)[8] Verify the carrier has established a tracking system that requires an authorizedsignature prior to releasing the package for delivery or return.(initials)

[9]IF provided,THEN attach carrier verification of 10 CFR 37 compliance.(initials)[10] Notify Site Security (S.A.S) of shipment AND have Security make a log entry.Date and time of notification: ________________________

Security point of contact: ___________________________

Security log entry number: __________________________(initials)

[11]Verify that the U.S. Department of Homeland Security's (DHS's) National TerrorismAdvisory System (NTAS) has not issued an "Elevated Alert" or "Imminent Alert",OR/IF the USCGS MARSEC Level has not reached 2 or 3 (as applicable to eachplant), prior to shipment.(initials)[12] Refer to 10 CFR 71.97 to see if the shipment also meets the criteria for HighwayRoute Control Quantity limits requiring advanced notification.(initials)Performed by (print, sign, date): _______________________________________________Reviewed by (print, sign, date): ________________________________________________

NUCLEARMANAGEMENT MANUAL N ON-QUALITY RELATEDEN-RW-106REV. 6 INFORMATIONAL U SEPage 47 of 47Integrated Transportation Security Plan ATTACHMENT9.810CFR37SUBPART DCATEGORY 1QUANTITIES OF C ONCERN STATE COORDINATION L OGSheet 1 of 1Shipment Number: _______________________State:___________________________State representative name and title:Date of coordination conversation:Expected entry:Date and time: Location:Expected exit:Date and time: Location:Does the state intend to provide law enforcement escorts?Safe havens identified:Additional discussion items concerning shipment through state:Performed by (Print, sign, date):Reviewed by (Print, sign, date):

James A. NON-QUALITY RELATED EN-RW-106 I FitzPatrick NPP INFORMATIONAL USE Page 1of47 Integrated Transportation Security Plan Procedure Revision T e: New D NON-Editorial

[8J Editorial D TC D Cancellation D Effective Procedure Owner: Adam King Date Title: Manager, RP 5/23/17 Site: JAF Site Procedures Canceled or Superseded By This Revision None Process Applicability Exclusion:

JAF: LJ Change Statement REV. 7 The purpose of this revision is to give guidance on how to proceed during a change in Threat Level Advisory when issued by Home Land Security and/or the NRC. I Procedure Writer: Ryan Conger Contains Proprietary Information:

YES D NO [8J James A. NON-QUALITY RELATED EN-RW-106 I FitzPatrick NPP INFORMATIONAL USE Page 2 of 47 Integrated Transportation Security Plan TABLE OF CONTENTS Section Title Page 1.0 PURPOSE .................................................................................................

3

2.0 REFERENCES

..........................................................................................

3 3.0 DEFINITIONS

............................................................................................

4 4.0 RESPONSIBILITIES

.................................................................................

7 5.0 DETAILS .................................................................................................

8 5.1 PRECAUTIONS AND LIMITATIONS

........................................................

8 5.2 GENERAL .................................................................................................

8 5.3 RISK ASSESSMENT

.................................................................................

8 5.4 CARRIER TSP AND CONTRACTS MANAGEMENT

...............................

9 5.5 CARRIER HAZARDOUS MATERIAL TRANSPORTATION SECURITY PLAN ...............................................................................................

10 5.6 TRAINING ...............................................................................................

11 5.7 ADDITIONAL SECURITY MEASURES FOR RADIOACTIVE SHIPMENTS-CATEGORY 1 AND CATEGORY 2 QUANTITIES

.........

12 5.8 TYPES OF HAZMAT SHIPMENTS ADDRESSED BY THE EXELON (EOI / ENOI) TSP-RA .........................................................................................

25 5.9 INFORMATION

........................................................................................

26 6.0 INTERFACES

..........................................................................................

27 7 .0 RECORDS ...............................................................................................

27 8.0 SITE SPECIFIC COMMITMENTS

...........................................................

27 9.0 ATTACHMENTS

......................................................................................

28 ATTACHMENT 9.1 TSP-RAT ABLES ....................................................................

29 ATTACHMENT 9.2 SAMPLE CARRIER AFFIRMATION LETTER ..................................

35 ATTACHMENT 9.3 LICENSE VERIFICATION SYSTEM CREDENTIAL GUIDE ................

36 ATTACHMENT 9.4 MANUAL LICENSE VERIFICATION FORM GUIDE ..........................

37 ATTACHMENT 9.5 MANUAL LICENSE VERIFICATION PROCEDURE GUIDE ................

39 ATTACHMENT 9.6 10 CFR 37 SUBPART D CATEGORY 1 PHYSICAL PROTECTION REQUIREMENT CHECKLIST

.........................................................................

41 ATTACHMENT 9.7 10 CFR 37 SUBPART D CATEGORY 2 PHYSICAL PROTECTION REQUIREMENT CHECKLIST

.........................................................................

45 ATTACHMENT 9.8 10 CFR 37 SUBPART D CATEGORY 1 QUANTITIES OF CONCERN STATE COORDINATION LOG ........................................................................

47 REV. 7 James A. NON-QUALITY RELATED EN-RW-106 I REV. 7 FitzPatrick NPP INFORMATIONAL USE Page 3 of 47 Integrated Transportation Security Plan 1.0 PURPOSE This document implements the requirements of the DOT Transportation Security Requirements and the NRC's Additional Security Measures for Radioactive Material -Category 1 and Category 2 Quantities.

The requirements stem from the Department of Transportation as well as the Nuclear Regulatory Commission.

2.0 REFERENCES

[1] 49 Code of Federal Regulations, Part 172-173, Hazardous Materials

[2] EPRI Hazardous Material Transportation Security Plan Risk Assessment

[3] 10 CFR Parts 70, 71, 72 and 73 (NRG Regulations)

[4] 33 CFR 105, Temporary Interim Rule, Effective July 1, 2003 (US Coast Guard Regulations)

[5] 49 CFR 172.800, Revised Regulations, Effective March 25, 2003 (DOT Regulations)

[6] American Chemistry Council, et al; Transportation Security Guidelines for the U.S. Chemical Industry, 2001 [7] DOE Memorandum, Jessie Roberson to Distribution, Approval of Commercial Shipments of Radioactive Materials and Waste on Behalf of the Office of Environmental Management, June 27, 2003 [8] DOT-RSPA, Enhancing Security of Hazardous Materials Shipments Against Acts of Terrorism or Sabotage Using RSPA's Risk Management Self-Evaluation Framework (RMSEF), January 2002 [9] DOT-RSPA, Three Case Studies for the Risk Management Framework for Hazardous Materials Transportation, November 1, 2000 [10] DOT-RSPA, Flyer DHM50-0023-1002, Shippers and Carriers Enhanced Security Measures, not dated [11] DOT Slide Presentation, Hazardous Materials Transportation Security, NEI Transportation Security Meeting, May 29, 2003 [12] DOT Federal Motor Carrier Safety Administration, Hazardous Materials Company Anti-Terrorism Tips, DOT Web Site, Internet download July 7, 2003 [13] Federal Register, Volume 68, Number 126, page 39315-39338, 33 CFR 105, July 1, 2003 James A. NON-QUALITY RELATED EN-RW-106 I REV. 7 FitzPatrick NPP INFORMATIONAL USE Page 4 of 47 Integrated Transportation Security Plan 2.0 continued

[14] GAO Report to Congressional Requesters, GA0-03-435 Rail Safety and Security, Some Actions Already Taken to Enhance Rail Security, but Risk-based Plan Needed, April 2003 [15] NRC, Fact Sheet on Dirty Bombs, NRC Web Site, internet download, June 30. 2003 [16] U.S. Department of Justice, Special Report, A Method to Assess the Vulnerability of U.S. Chemical Facilities, November 2002 [17] NRC letter from J. E. Dyer dated July 19, 2005, "Issuance of Order for Additional Security Measures on the Transportation of Radioactive Material Quantities of Concern" EA 05-007 [18] NEI 14-XX [Rev C], Implementation Guidelines for 10 CFR 37 Subpart D Physical Protection in Transit [19] 10 CFR Part 37, "Physical Protection Of Category 1 And Category 2 Quantities Of Radioactive Material" [20] NUREG-2155, Rev. 1, "Implementation Guidance for 10 CFR Part 37, 'Physical Protection of Category 1 and Category 2 Quantities of Radioactive Material'" [21] RIS-2005-12, NRC Regulatory Issue Summary, NRC Threat Advisory and Protective Measures System. 3.0 DEFINITIONS

[1] Acronyms:

ANI -American Nuclear Insurers ASM -Additional Security Measures (EA 05-007) COTP -Captain of the Port (US Coast Guard designation)

DAW -Dry Active Waste DOT -Department of Transportation ENOI -Entergy Nuclear Operations, Incorporated EOI -Entergy Operations, Incorporated FBI -Federal Bureau of Investigation NTAS-National Terrorism Advisory System LLEA -Local Law Enforcement Agencies MCC -Movement Control Center NEI -Nuclear Energy Institute NRC -Nuclear Regulatory Commission SAS -Secondary Alarm Station James A. NON-QUALITY RELATED EN-RW-106 I FitzPatrick NPP INFORMATIONAL Use Integrated Transportation Security Plan 3.0[1] continued SRCP -Security Risk Control Points TSA -Transportation Security Administration TSP -Transportation Security Plan TSP-RA -Transportation Security Plan -Risk Assessment USCGS -U.S. Coast Guard Service Page 5 of 47 REV. 7 [2] Aggregated

-Accessible by the breach of a single physical barrier that would allow access to radioactive material in any form, including any devices that contain the radioactive material, when the total activity equals or exceeds a category 2 quantity of radioactive material [3] Dry Active Waste -Dry, solid radioactive waste (as opposed to wet wastes such as resins, filters, or filter media) [4] Greater Than Class C Waste (GTCC) -Low-level radioactive waste that exceeds the concentration limits of radionuclides established for Class C waste in 10 CFR Part 61.55. [5] Hazardous Material -For the purposes of the TSP-RA, this term includes the definition in 49CFR173.403 and as listed in associated table under49CFR172.101.

[6] Highway Route Control Quantities (HRCQ) -A quantity within a single package which exceeds 3000 times the A 1 value for special form or 3000 times the A2 value for normal form or 1000 TBq (27,000 Ci), whichever is the least. [7] Lost or Missing Licensed Material -Means licensed material whose location is unknown. [8] Low Specific Activity (LSA) -Radioactive material with limited specific activity which satisfies the following limits: ores containing only naturally occurring radionuclides, solid un-irradiated natural or depleted uranium or natural thorium or their solid or liquid mixtures, etc. (see 49CFR173.403 for exact definition).

[9] Materials of Significant Concern -For the purposes of the TSP-RA, this refers to hazardous materials which are known or presumed to be so acutely toxic to humans as to afford a hazard to health during transportation, thereby representing a significant transportation security risk. [1 O] Movement Control Center -An operations center that is remote from transport activity and that maintains position information on the movement of radioactive material, receives reports of attempted attacks or thefts, provides a means for reporting these and other problems to appropriate agencies and can request and coordinate appropriate aid.

James A. NON-QUALITY RELATED EN-RW-106 I REV. 7 FitzPatrick NPP INFORMATIONAL Use Page 6 of 47 Integrated Transportation Security Plan 3. O continued

[11] National Security Threat Level -Transportation of certain types of hazmat shipments may be restricted during periods of elevated security threat levels. The degree of restriction, associated risk, and the affected hazmat shipments will affect the level of security control applied to certain hazmat shipments.

The National Security Threat Level is established by the Department of Homeland Security and serves as a general guide for the security threat level established by other agencies, such as the NRC and USCGS. Also note that the NRC and USCGS may have different (higher) security threat levels than the national security threat level. Nuclear plant security activities are governed by the highest security threat level applied by the NRC and, as applicable, the USCGS. [12] NO-LATER-THAN Arrival Time -The date and time that the shipping licensee and the receiving licensee have established as the time at which an investigation will be initiated if the shipment has not arrived at the receiving facility.

[13] NRC Security Threat Level -Corresponds to the National Security Threat Level. However, it is independently controlled and established by the NRC, and fluctuates independently from the National Threat Level. This is the primary threat level monitored by nuclear plants, and it encompasses a combination of threats from National, Maritime, and other sources. [14] MARSEC Level -Maritime Security [Threat] Level as identified and maintained by the USCGS. It is independently controlled and established by the USCGS, and fluctuates independently from the National Threat Level or the NRC Threat Level. The MARS EC is also monitored by the affected nuclear plants, which respond accordingly.

[15] Physical Security Plan (PSP) -For a nuclear plant, this is the PSP required by 10 CFR 73. For some decommissioning nuclear plants and for other licensed nuclear support facilities (e.g., radioactive laundry vendors, waste processors, nuclear plant maintenance facilities), this refers to the "industrial security plan." The term PSP also encompasses the USCGS FSP and all of the related requirements specified in 33 CFR 105, Subpart D. [16] Radioactive Material -For the purposes of the TSP-RA, this term includes both radioactive materials and radioactive wastes. [17] Safe Haven -Readily accessible site at which security is present or from which, in the event of an emergency, the transport crew can notify and wait for local law enforcement authorities.

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

James A. NON-QUALITY RELATED EN-RW-106 I REV. 7 FitzPatrick NPP INFORMATIONAL USE Page 7 of 47 Integrated Transportation Security Plan 3.0 continued

[19] Telemetric Positioning Monitoring

-A data transfer system that captures information by instrumentation and/or measuring devices about the location and status of a transport vehicle or package between the departure and destination locations.

[20] TSP -Hazardous Material (and Radioactive Material)

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

[22] Unauthorized Persons -An unauthorized person is any person who is not authorized by the shipper or the transportation carrier to have access to hazardous materials or transport conveyances being prepared for transportation.

This includes all persons who are not employed by the shipper or the transportation carrier, including members of the general public, unless such persons are specifically authorized by the shipper or transportation carrier to have access to hazardous materials or transport vehicles being prepared for transportation.

4.0 RESPONSIBILITIES

[1] Materials, Purchasing

& Contracts Manager is responsible for supporting the key elements of the procedure within the requirements of Section 5.0 [3]. [2] Training Manager is responsible for the key elements of the procedure to ensure that Hazardous Material (HAZMAT) AND 10 CFR Part 37.43(c) training requirements outlined in Section 5.0 of this procedure are developed and implemented.

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

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

James A. NON-QUALITY RELATED I FitzPatrick EN-RW-106 REV. 7 NPP INFORMATIONAL USE Page 8 of 47 Integrated Transportation Security Plan 5.0 DETAILS 5.1 PRECAUTIONS AND LIMITATIONS None 5.2 GENERAL NOTE "Tables" referenced in this procedure are located in Attachment 9.1, "TSP-RA Tables" Table 1: Typical Radioactive and Hazardous Material Shipments Table 2: Hazmat Carriers, Types of Hazmat Shipments and Quantities Shipped Table 3: Determination of Hazardous Materials of Significance to This Assessment Table 4: Category 1 and Category 2 Threshold Table 5: Hazardous Materials of Significant Concern Shipped from Facilities

[1] The Physical or Industrial Security Plans already contain security procedures, access controls, requirements for employee background checks, etc. Such procedures, controls regulations and therefore need not be duplicated.

[2] The Entergy (EOI / ENOI) standard language approach to the TSP consists of a simplified and minimal TSP document plus an attachment used in association with the procedure.

5.3 RISK ASSESSMENT

[1] This TSP-RA is applicable to packaging, staging/storage in preparation for transport, and shipment of the radioactive and hazardous materials addressed in 49 CFR 172.800. Table 1 identifies the types of radioactive and hazardous materials shipments.

[2] Transportation Carriers contracted to carry radioactive and/or hazardous materials and who's TSPs are relied upon to provide all necessary security during transport and during storage incidental to movement.

This includes the categories of carriers listed in Table 2.

James A. NON-QUALITY RELATED EN-RW-106 I REV. 7 FitzPatrick NPP INFORMATIONAL USE Page 9 of 47 Integrated Transportation Security Plan 5.3 continued

[3] For bulk quantity shipments of hazardous material identified in Table 5 which will cross bridges spanning water, through tunnels under water, or on water which is patrolled by the USCGS, regardless of whether the shipment is made by highway, rail or vessel, advance notification of the shipment or of a series of shipments is to be given to the affected USCGS Port Authority.

The licensee SHALL notify the USCGS at least 10 days before the shipment physically begins within the United States. For shipments where 10 days of advance notice is not possible, the notification is to be made as soon as practicable.

The notification SHALL be made to the appropriate USCGS Port Authority. (The USCGS may choose to require facility-specific notification for other materials.)

[4] In the event that a shipment of material described in 5.3[3] arrives at the intended consignee but is refused by the consignee, the Carrier maintains responsibility for security of the shipment until it arrives at an acceptable destination designated by the shipper. [5] IF the U.S. Department of Homeland Security's (DHS's) National Terrorism Advisory System (NTAS) issues an "Elevated Alert" or "Imminent Alert", OR IF the USCGS MARSEC Level reaches 2 or 3 (as applicable to each plant), THEN Category 1 and Category 2 as well as HRCQ shipments are not to be shipped. [6] IF the U.S. Department of Homeland Security's (DHS's) National Terrorism Advisory System declares a threat condition OR the NRC establishes protective measures while a Category1, Category 2 or HRCQ shipment is in transit THEN refer to RIS 2005-12 for guidance.

[7] The shipment of all hazardous material described in Table 1 may have other controls implemented by the shipper (during shipment preparation

& shipping coordination) or carrier (en-route security).

5.4 CARRIER TSP AND CONTRACTS MANAGEMENT

[1] The optimum approach is for the carrier to implement its own TSP which addresses all aspects of the transportation security regulations, including hazmat employee training and driver commercial licenses and endorsements.

Accordingly, MP&C will incorporate standard language in their Contracts and Purchase Orders, where applicable, that will require the transportation company to implement its own TSP. It is not necessary to review and approve each carrier's TSP prior to implementation by the carrier. [2] The language in Section 5.5, "Carrier Hazardous Material Transportation Security Plan," or similar language, is to appear in every carrier contract where the carrier is anticipated to transport any of the highly hazardous materials identified in 49 CFR 172.800. The end user (contract requisitioner) should identify whether the James A. NON-QUALITY RELATED EN-RW-106 I REV. 7 FitzPatrick NPP INFORMATIONAL USE Page 10 of 47 Integrated Transportation Security Plan transportation of hazardous materials is anticipated when submitting a request for a new contract.

5.5 CARRIER HAZARDOUS MATERIAL TRANSPORTATION SECURITY PLAN [1] The Carrier will affirm each time (i.e., separate shipment) that it has a Hazardous Material Transportation Security Plan in place prior to approval of the contract or contract amendment, that the plan meets all applicable Federal and International transportation security regulations in effect as of the contract or contract amendment date, and that said TSP will be updated in a timely manner to remain current with revised and new Federal and International transportation security regulations.

[2] The Carrier is also responsible for implementing regulations for commercial driver licenses hazardous material endorsements.

[3] Advanced approval of the Carrier's TSP is not required for implementation of this contract.

However, it will be made available for review and approval by an authorized representative of ENTERGY (EOI / ENOI) if requested and on reasonable verbal or written notice, with due consideration given to document security and control. [4] The Transportation Security Plan for Carriers under contract shall be reviewed at least annually.

[5] Prior to dispatching any driver to an ENTERGY (EOI / ENOI) facility for the purposes of transporting hazardous material, the Carrier is to verify that the driver has the appropriate commercial driver license hazardous material endorsements.

[6] The carrier is to also notify the designated ENTERGY (EOI / ENOI) representative of the name of the driver and any other requested driver identification information, which will be used to verify that the appropriate driver has arrived to transport the shipment.

[7] Transportation of any of the hazardous materials identified in 49 CFR 172.800 is not to be assigned or subcontracted without the prior written agreement of all parties. NOTE Some vendors subcontract carriers to prepare and ship hazardous materials off-site.

For example, a major maintenance contractor may subcontract an independent transportation company to ship hazardous materials from one plant to the next. [8] All contracts OR purchase orders, where applicable, which potentially involve transportation of the hazardous materials covered in the TSP are to be examined to ensure that subcontracted carriers have AND maintain a TSP acceptable to ENTERGY (EOI / ENOI). Consideration is to be given to amending any such contracts to include the preceding language OR to include a restriction similar to the following:

James A. NON-QUALITY RELATED EN-RW-106 I REV. 7 FitzPatrick NPP INFORMATIONAL USE Page 11of47 Integrated Transportation Security Plan 5.5 continued "Transportation of any of the hazardous materials identified in 49 CFR 172. 800 will not be assigned or subcontracted without the prior written agreement of all parties." [9] It is recommended that an affirmation letter on carrier letterhead paper be received from the carrier prior to awarding any transportation contract or other scheduled carrier for radioactive and non-radioactive materials.

A copy of the affirmation is available in Attachment 9.2, "Sample Carrier Affirmation Letter." 5.6 TRAINING [1] Employees involved with processing (including vehicles) and transporting hazardous material must be provided with the following personnel security awareness and transportation security training modules:

• Security Awareness Training

• In-Depth Transportation Security Training module (including specific information on the existence of the company's TSP). [2] Both training modules may supplement the existing hazmat employee training program consistent with the intent of and frequency specified in 49 CFR 172.704. qualification training will be provided at the same frequency as other hazmat' employee training.

[3] All new hazardous material employees must receive this training within 90 days of employment.

[4] Hazmat employees must receive training required by 49 CFR 172.704 at least once every three years. [5] Hazmat employees required to have In-Depth Security Training must receive training at least once every three years OR IF the security plan for which training is required is revised during the three-year recurrent training cycle, THEN the employee must receive training within 90 days of implementation of the revised plan. [6] Personnel responsible for implementing the Integrated Transportation Security Plan shall have refresher training as required by 10 CFR 37.43 at a frequency not to exceed 12 months AND when significant changes are made to the security program. [10 CFR 37.43(c)(3)]

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James A. NON-QUALITY RELATED EN-RW-106 I FitzPatrick NPP INFORMATIONAL USE Page 12 of 47 Integrated Transportation Security Plan 5.7 ADDITIONAL SECURITY MEASURES FOR RADIOACTIVE SHIPMENTS

-CATEGORY 1 AND CATEGORY 2 QUANTITIES 5.7.1 General NOTE REV. 7 This section is based on the 10 CFR part 37 subpart D final rule, NUREG 2155 Q & A, and NRC response to industry questions.

[ 1] Section 5. 7 applies to the following activities

• Transfer and receipt of a category 1 and category 2 quantity of radioactive material.

• Preplanning and coordination of shipments,

• Physical protection during shipment,

• Notifications, investigations, and event reporting, [2] Attachments 9.6 through 9.8 of this procedure includes a table of 10 CFR Part 37 Subpart D Physical Protection requirement checklists for category 1 and category 2 quantity of radioactive material shipments.

5.7.2 Transfer of Category 1 and Category 2 Quantities of Radioactive Material 5.7.2.1 License Verification

[1] Any licensee transferring a category 2 quantity of radioactive material is required to perform and document licensee verification activities based on the quantity of material being transferred.

The purpose of the licensee verification is to make sure the transferee's license is valid and authorized to receive the type, form and quantity of radioactive material transferred.

Use Attachment 9.3, "License Verification System Credential Guide" to obtain credentials for using the License Verification System. [2] Except for emergencies, the licensee is required to use the Licensee Verification System (LVS) developed by the NRC or contact the regulatory agency (NRC or Agreement State) to verify that the license is valid before shipping a category 2 quantity of radioactive material.

James A. NON-QUALITY RELATED EN-RW-106 I FitzPatrick REV. 7 NPP INFORMATIONAL USE Page 13 of 47 Integrated Transportation Security Plan 5. 7.2.1 continued

[3] IF there exists an emergency where the licensee cannot verify the license of the transferee by the LVS or regulatory agency, THEN the licensee may accept written verification by the transferee that it is authorized to receive the type, form and quantity of radioactive material being transferred.

In which case use Attachment 9.4 "Manual License Verification Form Guide," OR Attachment 9.5, "Manual License Verification Procedure Guide." [4] The licensee is not required to perform license verification of transfers to the Department of Energy, other Federal entities, or transfers within the same organization of the licensee.

Verification is not required for imports and exports, however the requirements of 10 CFR Part 110, "Export and Import of Nuclear Equipment and material," would apply 5.7.2.2 Category 2 Transfer [1] The licensee transferring the category 2 quantity of radioactive material will verify the transferee is authorized to receive the radioactive material prior to shipment.

The licensee uses the LVS or direct contact with the applicable regulatory agency. [2] The licensee may not use a fax, email, or a copy of the recipient's license to verify the transferee is authorized to receive a category 2 quantity of radioactive material.

The verification of each shipment is required and the licensee should document the verification process used (i.e. LVS, regulatory agency contact, or recipient licensee certification).

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

5.7.2.3 Category 1 Transfer [1] The licensee transferring a category 1 quantity of radioactive material is required to meet the same requirements as the transfer of a category 2 quantity of radioactive material.

[2] In addition to the requirements for transfer for category 2 transfers, verify that the receiving licensee is authorized to receive radioactive material at the address requested for delivery.

James A. NON-QUALITY RELATED EN-RW-106 I REV. 7 FitzPatrick NPP INFORMATIONAL USE Page 14 of 47 Integrated Transportation Security Plan 5.7.3 Guidance for Physical Protection During Transit NOTE Section 5.7.3 addresses the shipping licensee responsibility for implementing 10 CFR Part 37 Subpart D requirements for preplanning and coordination and physical protection during transit. 5.7.3.1 Licensee Responsibility

[1] The shipping licensee is responsible for meeting the requirements of 10 CFR Part 37 Subpart D unless the receiving licensee has agreed in writing to arrange for the transit physical protection.

The licensee is also responsible for meeting the requirements of Subpart D for category 1 or category 2 quantity of radioactive material from the point that the material enters the United States for import and until the material is under the jurisdiction of a U.S. Government agency at a port, border crossing, or airport for material exported.

[2] The licensee should have a contract with the carrier that obligates the carrier to comply with the applicable requirements in Subpart D [3] The shipping licensee is responsible for providing physical security of a category 2 or greater quantity of radioactive material until the carrier accepts the consignment of radioactive material for shipment and begins movement of the loaded transport vehicle. The shipping licensee's control applies outside of the protective area until the departure of the shipment.

5.7.3.2 Category 1 Shipment [1] The shipping licensee must conduct preplanning and coordination activities with the receiving licensee and with each state that the shipment enters. The shipping licensee preplanning and coordination procedures should address, as a minimum, the following items:

• Shipment contract(s) with a carrier that identify carriers responsibilities for implementing applicable regulations,

• Protocol for carrier actions to take if a shipment is rerouted during bad weather or other unusual event,

• Shipping licensee should preplan and coordinate the shipments arrival and departure time with the receiving licensee,

• Shipping licensee establish protocol for coordinating and contacting the governor of the State or the governor's designee, James A. NON-QUALITY RELATED EN-RW-106 I REV. 7 FitzPatrick NPP INFORMATIONAL USE Page 15 of 47 Integrated Transportation Security Plan 5. 7.3.2[1] continued

• Shipping licensee works with the States to identify its intention to provide escorts and any additional State-imposed transportation security requirements',

• Shipping licensee works with the carrier to identify safe haven(s) along the route at approximately 50 mile intervals, if available,

• Carrier coordination with State escorts if applicable.

[2] The licensee maintains documentation of the above activities as attachments to the shipping package. [3] A licensee that transports, or delivers to a carrier for transport in a single shipment by road, a category 1 quantity of radioactive material should address the following items, as a minimum: (a) Licensee establishes or uses a carrier that has established movement control centers (MCC). The MCC should:

• Monitor shipments on a continuous basis 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, 7 days a week,

• Maintain the ability to immediately communicate with LLEA in an emergency,

• Provide positive confirmation of the location of the shipment, its status, individuals in control of the shipment,

• Develop and implement preplanned procedures in response to deviations from the authorized route (s), OR

• Provide notification of actual or attempted theft or diversion or suspicious activity related to the theft, loss, or diversion of a shipment,

• Immediately awareness if a shipment deviates from shipping plans, planned route, unscheduled stops, or scheduled stops longer than expected,

• Redundant communications consisting of two systems that do not rely on the same hardware or software to transmit a signal,

• The use of telemetric monitoring system to permit the remote monitoring and reporting of the location of a transport vehicle or package, James A. NON-QUALITY RELATED EN-RW-106 I REV. 7 FitzPatrick NPP INFORMATIONAL USE Page 16 of 47 Integrated Transportation Security Plan 5. 7.3.2[3](a) continued

• Ensure carrier provides a second individual when the driving time period is greater than the maximum number of allowable hours of service in a 24-hour duty day as established by the DOT,

• The driver or accompanying individual or both perform the following:

Periodically call the MCC to provide verbal status of the shipment and delivery, Maintain vigilance of the surrounding environment during transport, Maintain constant visual surveillance when transport vehicle is stopped, Periodically walk around vehicle while it is not in motion, to confirm no apparent safety or security related issues, Confirm no evidence of tampering with the contents of the vehicle or no unusual or suspicious activity in the immediate vicinity.

• Normal operating procedures address activities to meet regulatory requirements:

Refueling and comfort stops, Meal stops, and Routine check-in. (b) Contingency procedures address issues that could interfere with compliance during preparation for transport or during transport:

• Bad weather,

• Suspicious activities,

• Mechanical breakdown,

• Road or bridge closures, detours, accidents, or

• Acute illness.

James A. NON-QUALITY RELATED EN-RW-106 I REV. 7 FitzPatrick NPP INFORMATIONAL USE Page 17 of 47 Integrated Transportation Security Plan 5. 7.3.2[3](b) continued (c) 5.7.3.3

• Communication protocol for: Duress codes to enable off-site individual to signal the need for assistance, Authentication codes to confirm the true identity of the employee, Loss of communication actions to take. Licensee ensures access to normal and contingency procedures by drivers, accompanying personnel, and MCC personnel.

Category 2 Shipment [1] A licensee that transports, or delivers to a carrier for transport in a single shipment by road, a category 2 quantity of radioactive material should include the following items as a minimum in its preplanning and coordination process:

• Coordinate the expected arrival time and the no-later-than (NL T) arrival time, and the method of notification of receipt of shipment with the receiving licensee.

• Shipping licensee initiates investigation if shipment has not arrived by more than 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> past NL T

• The receiving licensee confirms to the shipping licensee that the shipment has arrived by phone, e-mail, or facsimile as agreed in the preplanning and coordination activities.

• Shipping licensee notifies the receiving licensee of any new NL T arrival time as soon as practicable after the driver or authorized member of the transfer crew determines the category 2 shipment cannot arrive before the NL T arrival time. [2] A licensee that transports category 2 quantity of radioactive material should address the following items, as a minimum:

• Establishment of a security zone around the radioactive material, the use of the transport vehicle is permitted, [37.47(a)]

• Limit access to the security zone to authorized individuals, [37.47(c)]

• Monitor, detect, assess, and respond to any unauthorized access, [37.49]

James A. NON-QUALITY RELATED EN-RW-106 I REV. 7 FitzPatrick NPP INFORMATIONAL USE Page 18 of 47 Integrated Transportation Security Plan 5. 7.3.3 continued

[3] A licensee that transports, or delivers to a carrier for transport in a single shipment by road, a category 2 quantity of radioactive material should address the following items, as a minimum:

• The use of carriers with an established, documented package tracking system that allows shipping licensee to see the chain of custody for the package and who is accountable at each stage of the trip,

• The shipping licensee or carrier can promptly determine if the shipment is lost or missing,

• The tracking system requires an authorized signature (receiving licensees employee or contractor) before release for delivery or return,

• Licensee's carrier maintains constant control and surveillance during transit with capability to immediately summon response by an armed LLEA, trained emergency services personnel to prevent or mitigate any collateral impacts of a safety event, or immediately requests assistance for emergency or urgent conditions to avoid or minimize unplanned delay of shipment.

• Immediate communication to summon response or assistance may be met with cell or satellite phones and two-way radios. No backup communication system is required.

• The licensee's carrier maintains a package-tracking system with a reliable demand capability to ascertain the last location and current status of the shipment.

[4] A licensee who transports, or delivers to a carrier for transport in a single shipment by rail, a category 2 quantity of radioactive material should address the following items, as a minimum:

• The use of a carrier with a documented, proven, and reliable tracking system,

• The capability to allow the shipping licensee or carrier to identify when and where package was when the train last reported, and when it will arrive at the next point of control,

• The carrier maintains constant control and surveillance during transit and has the capability for immediately communication to summon an appropriate response or assistance, James A. NON-QUALITY RELATED EN-RW-106 I REV. 7 FitzPatrick NPP INFORMATIONAL USE Page 19 of 47 Integrated Transportation Security Plan 5. 7.3.3[4] continued

• Immediate communication to summon response or assistance may be met with cell or satellite phones, and two-way radios. No backup communication system is required,

• The tracking system requires an authorized signature (receiving licensees' employee or contractor) before release for delivery or return. 5. 7.4 Advance Notification of Shipment of Category 1 5. 7.4.1 Advance Notification

[1] The shipping licensee provides advance notification to the NRC and the governor of a State or the governor's designee in writing and postmarked 7 days before the shipment begins. [2] Notifications by fax or email are required 4 days before transport within or through the state. [3] The shipping licensee should confirm the notification by fax or its intended recipient receives email. The preferred notification method to the NRC is by email to RAMQC_SHIPMENTS@nrc.gov or by fax to 301-816-5151.

The contact information of governors and governor's designee is available on the NRC Web site at stp.ornl.gov/special/designee.pdf

[4] The following is a summary of the information to be furnished in an Advance Notification of Shipment:

• The name, address, and telephone number of the shipper, carrier, and receiver of the category 1 radioactive material,

• The license numbers of the shipper and receiver,

• A description of the radioactive material contained in the shipment, including the radionuclides and quantity,

• The point of origin of the shipment and the estimated time and date that the shipment will commence,

• The estimated time and date that the shipment is expected to enter each State along the route,

• The estimated time and date of arrival of the shipment at the destination,

• A point of contact, with a telephone number, for current shipment information.

James A. NON-QUALITY RELATED I FitzPatrick EN-RW-106 REV. 7 NPP INFORMATIONAL USE Page 20 of 47 Integrated Transportation Security Plan 5. 7.4. 1 continued

[5] The licensee is expected to include all of the above information when it makes the initial advance notification.

Any missing information is required to be provided before commencement of the shipment.

5.7.4.2 Updating Advance Notification

[1] The shipping licensee is required to provide a revision notice with any information that was not available when the initial notification was submitted.

[2] The shipping licensee is required to notify any affected State's governor or designee as soon as it discovers or is advised of the following changes in the shipment:

• A change is made to the description of the radioactive material radionuclides or quantities,

• A change is made in the shipment's point of origin or estimated time or date of commencement,

• A change of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> or more is made in the estimated time or date that the shipment is expected to enter each State along the route,

• A change of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> or more is made in the estimated time or date of arrival of the shipment at the destination,

• A change is made in the name or telephone number of the point of contact for current shipment information.

[3] The driver or other authorized member of the transfer crew is to make notification of any changes in shipment information en route as soon as the change is determined.

[4] IF the shipment is canceled, THEN the shipping licensee is required to notify the States to which advance notification was provided AND the NRG, OR Agreement State agency with jurisdiction in the State of origin. The licensee is required to send a cancellation notice via email, facsimile, or written correspondence as soon as possible.

A telephone call may be necessary to ensure timely receipt of the notice to provide a State time to cancel any planned escorts.

James A. NON-QUALITY RELATED EN-RW-106 I REV. 7 FitzPatrick NPP INFORMATIONAL Use Page 21of47 Integrated Transportation Security Plan 5. 7 .5 Reporting of Events 5.7.5.1 Shipment Investigations

[1] IF the licensee asks for a status of its shipment, AND the carrier's telemetric monitoring system or railroad's communications center cannot tell where the shipment is within a few minutes AND the shipping licensee is not confident that the tracking and communication system are functioning normally, THEN the licensee should consider the shipment lost or missing [2] The shipping licensee must investigate immediately if a category 1 quantity shipment is lost or missing. [3] The investigation of the lost or missing category 1 quantity shipment should include as a minimum the following actions:

• Determine the time and location of the last transport crew check-in.

• Determine where communication was lost.

• Determine where tracking was lost.

• Confirm that the equipment is working properly.

• Contact the escort if one was being used. [4] The shipping licensee must investigate immediately if a category 2 quantity shipment does not arrive by the NL T arrival time based on the receiving licensee notification.

[5] The investigation of the lost or missing category 2 quantity shipments should include as a minimum the following actions:

• Determine the shipment's last known location from carrier.

• Determine the shipment's current location.

[6] IF the carrier cannot determine the location of the shipment, THEN the shipping licensee notifies the NRG Operations Center that a category 2 quantity shipment is lost or missing [7] Contact the NRG Operations Center if the shipment is still missing after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the initial notification.

James A. NON-QUALITY RELATED EN-RW-106 I FitzPatrick REV. 7 NPP INFORMATIONAL USE Page 22 of 47 Integrated Transportation Security Plan 5.7.5.2 Category 1 Notifications

[1] The shipping licensee must make the following notifications after determining a shipment of category 1 quantities of radioactive material is lost or missing:

• Notify the LLEA as soon as the carrier has completed its first unsuccessful attempt to locate the material and confirmed its inability to trace it was not a result of human error, or a malfunction of the position monitoring system,

• Notify the NRC Operations Center within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after determining the category 1 shipment is lost or missing. Discuss with the NRC the expected frequency of updates,

• Notify the NRC and the LLEA as soon as possible when the lost or missing licensed material is again in the physical possession of, or in a location otherwise under the control of the carrier, shipping, or recipient licensee, authorized State or Federal agency, or an LLEA that is able to prevent or deter unauthorized access to the material.

[2] The shipping licensee must make the following notifications as soon as possible upon discovery of any actual or attempted theft, or diversion of a shipment, or suspicious activities related to the theft or diversion of a shipment of a category 1 quantity of material:

• Notify the designated LLEA along the shipment route as soon as possible, AND

• Notify the NRC Operations Center (301-816-5100).

The NRC will notify other affected States and Federal partners as appropriate.

[3] The Transportation Security Administration (TSA) has guidance for private or contract carrier employees that list a number of activities that may be considered suspicious.

[4] A written report is required to be submitted to the NRC within 30 days of the shipping licensee's initial telephonic notifications that a shipment of category 1 material is lost or missing, or telephonic notification of actual, or attempted theft or diversion of a shipment of category 1 material.

James A. NON-QUALITY RELATED EN-RW-106 I REV. 7 FitzPatrick NPP INFORMATIONAL USE Page 23 of 47 Integrated Transportation Security Plan 5. 7.5.2 continued

[5] The written report is provided to the Director, Division of Security Policy, Office of Nuclear Security and Incident Response and must provide the following information:

• A description of the licensed material involved, including kind, quantity, and chemical and physical form;

• A description of the circumstances under which the loss or theft occurred;

• A statement of disposition, or probable disposition, of the licensed material involved;

• Actions that have been taken, or will be taken to recover the material;

• Procedures or measures that have been, or will be, adopted to ensure against a recurrence of the loss or theft of licensed material.

[6] After filing the written report, if the shipping licensee gathers any information not previously reported to the NRG, such as findings from a completed investigation of the loss or theft of category 1 material, the licensee has to report that additional information within 30 days. [7] A Condition Report will be initiated to document any actual or attempted theft or diversion of a shipment or any suspicious activity related to a shipment of category 1 quantities of radioactive material.

[8] Contact the site Licensing group in the event of an accident (e.g., shipment is lost, missing, actual or attempted theft or diversion, vehicular accident etc.) involving category 1 quantities of radioactive material to ensure appropriate notification of ANI is made. 5.7.5.3 Category 2 Notifications

[1] The shipping licensee is required to notify the NRG Operations Center within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of its determining a shipment of category 2 quantities of radioactive material is lost or missing. If after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from its determination the licensee still cannot locate the material, the NRG operations Center must be notified again. [2] The shipping licensee is also required to notify the NRG Operations Center as soon as possible after discovery of an actual or attempted theft or diversion of a category 2 quantity shipment or any suspicious activity related to a shipment.

[3] The shipping licensee is required to notify the NRG Operations Center when a lost or missing shipment of category 2 quantities of radioactive material has been located.

James A. NON-QUALITY RELATED EN-RW-106 I REV. 7 FitzPatrick NPP INFORMATIONAL USE Page 24 of 47 Integrated Transportation Security Plan [4] A written report is required to be submitted to the NRC within 30 days of the shipping licensee initial telephonic notifications that a shipment of category 2 material is lost or missing or telephonic notification of actual or attempted theft or diversion of a shipment of category 1 material.

[5] After filing the written report, if the shipping licensee gathers any information not previously reported to the NRC, such as findings from a completed investigation of the loss or theft of category 2 materials, the licensee has to report that additional information to the NRC within 30 days. [6] A Condition Report will be initiated to document any actual or attempted theft or diversion of a shipment or any suspicious activity related to a shipment of category 2 quantities of radioactive material.

[7] Contact the site Licensing group in the event of an accident (e.g., shipment is lost, missing, actual or attempted theft or diversion, vehicular accident etc.) involving category 2 quantities of radioactive material to ensure appropriate notification of ANI is made. 5.7.6 Records 5.7.6.1 Documentation

[1] The records that result from the activities in this procedure are to be retained a minimum of three years as required but typically through the life of the nuclear power plant's license. [2] The following records are generated as a result of implementing this section:

• Licensee verification documentation

• Documentation for preplanning and coordination, and any revision.

Documentation is to include:

• Any phone conversations or e-mail communications that it has with the receiving licensee to include the names of the individuals participating in the call or e-mail communications a general description of the shipment, and the departure and arrival times

• Any interactions with the governor's designee to include the names of the individuals participating in the call or e-mail, the route-affected States' decisions on escorts, the safe havens identified, and any other information that the licensee considers pertinent

• Advance notification and any revision and cancellation notices James A. NON-QUALITY RELATED EN-RW-106 I REV. 7 FitzPatrick NPP INFORMATIONAL USE Page 25 of 47 Integrated Transportation Security Plan 5. 7. 6. 1 [2] continued

• Written reports and additional substantive information

[3] Records resulting from the activities in this procedure are to be retained with records generated by EN-RW-102, "Radioactive Shipping Procedure." 5.7.6.2 Protection of Information

[1] The information to be furnished in advance notification of category 1 quantities of radioactive material shipment shall be protected against unauthorized disclosure as specified in 10 CFR 73.21 Protection of Safeguards Information:

Performance requirements.

The schedule information specified in 37.77(b) is provided to State officials, State employees, and other individuals that are not licensees of the NRC or an Agreement State. [2] The governor of a State or his or her designated State employee representative, Federal, State, or local law enforcement personnel are relieved from the fingerprinting, identification, and criminal history records checks, and other elements of background investigations and are permitted access to the category 1 shipping information.

[3] A licensee that plans to transport or deliver to a carrier for transport, licensed material that is a category 1 quantity of radioactive material will only use carriers that certify they have an access authorization program that meets the requirements of 10 CFR 73.21 and 10 CFR 73.23. The carrier must include in the access authorization program the vehicle drivers, accompanying individuals, movement control center personnel, and any individual whose assigned duties provide access to shipment information on category 1 quantities of radioactive material.

[4] The shipment of category 2 quantities of radioactive material does not require the commercial drivers and package handlers to meet the access authorization program requirements since these individuals are subject to DOT security requirements.

5.8 TYPES OF HAZMAT SHIPMENTS ADDRESSED BY THE ENTERGY (EOI / ENOI) TSP-RA [1] Specifically for Nuclear Power Reactors, this transportation security plan (TSP) applies to: (a) Radioactive laundry shipments, (b) Some shipments of low-level radioactive waste (dry active waste) to offsite processors, (c) Some shipments of radioactive vendor equipment offsite, and James A. NON-QUALITY RELATED EN-RW-106 I REV. 7 FitzPatrick NPP INFORMATIONAL USE Page 26 of 47 Integrated Transportation Security Plan 5.8[1] continued (d) Shipments of processed radioactive waste and reactor hardware for offsite disposal.

NOTE For Highway Route Controlled Quantity shipments of radioactive materials, the shipper must refer to the NRC Physical Security Plan along with the Additional Security Measures for Radioactive Shipments

-Category 1 and Category 2 Quantities (Section 5.7 of this procedure).

[2] A highway route-controlled quantity of a Class 7 (radioactive) material, as defined in 49 CFR 173.403, in a motor vehicle, rail car, or freight container;

[3] More than 25 kg (55 pounds) of a Division 1.1, 1.2, or 1.3 (explosive) material in a motor vehicle, rail car, or freight container;

[4] More than one L (1.06 qt) per package of a material poisonous by inhalation, as defined in Part 171.8 of this subchapter, that meets the criteria for Hazard Zone A, as specified in § 173.116(a)or 173.133(a) of this subchapter;

[5] A shipment of a quantity of hazardous materials in bulk packaging having a capacity equal to or greater than 13,248 L (3,500 gallons) for liquids or gases or more than 13.24 cubic meters (468 cubic feet) for solids; [6] A shipment in other than a bulk packaging of 2,268 kg (5,000 pounds) gross weight or more of one class of hazardous materials for which placarding of a vehicle, rail car, or freight container is required for that class under the provisions of subpart F of this part; [7] A select agent or toxin regulated by the Centers for Disease Control and Prevention under 42 CFR part 73; or [8] A quantity of hazardous material that requires placarding under the provisions of subpart F of this part. 5.9 INFORMATION

[1] Attachment 9.1 provides all associated tables that are applicable to the ENTERGY (EOI I ENOI) Risk Assessment.

James A. NON-QUALITY RELATED EN-RW-106 I REV. 7 FitzPatrick NPP INFORMATIONAL USE Page 27 of 47 Integrated Transportation Security Plan 6.0 INTERFACES

[1] EN-RW-102, "Radioactive Shipping Procedure" 7.0 RECORDS NOTE Records resulting from the activities in this procedure are retained with records generated by EN-RW-102, "Radioactive Shipping Procedure." [1] Licensee verification documentation

[2] Documentation for preplanning and coordination, and any revision [3] Advance notification and any revision and cancellation notices [4] Written reports and additional substantive information

[5] Attachment 9.6, "10 CFR37 Subpart D Category 1 Physical Protection Requirement Checklist" [6] Attachment 9.7, "10 CFR37 Subpart D Category 2 Physical Protection Requirement Checklist" [7] Attachment 9.8, "10 CFR 37 Subpart D Category 1 Quantities of Concern State Coordination Log" 8.0 SITE SPECIFIC COMMITMENTS None James A. NON-QUALITY RELATED EN-RW-106 I REV. 7 FitzPatrick NPP INFORMATIONAL USE Page 28 of 47 Integrated Transportation Security Plan 9.0 ATTACHMENTS 9.1 TSP-RA Tables 9.2 Sample Carrier Affirmation Letter 9.3 License Verification System Credential Guide 9.4 Manual License Verification Form Guide 9.5 Manual License Verification Procedure Guide 9.6 10 CFR 37 Subpart D Category 1 Physical Protection Requirement Checklist 9.7 10 CFR 37 Subpart D Category 2 Physical Protection Requirement Checklist 9.8 10 CFR 37 Subpart D Category 1 Quantities of Concern State Coordination Log James A. NON-QUALITY RELATED EN-RW-106 I REV. 7 FitzPatrick NPP INFORMATIONAL USE Page 29 of 47 Integrated Transportation Security Plan ATTACHMENT 9.1 TSP-RAT ABLES Sheet 1 of 6 [33 CFR 105.400] TABLE 1 T ical Radioactive and Hazardous Materials Shi ments RADIOACTIVE MATERIALS SHIPMENTS TYPES OF MATERIALS SHIPPED Radioactive Material Category 1 and Category 2 as defined in Attachment 9.1, Table 4, "Category 1 and Category 2 Threshold".

Highway route controlled quantities (HRCQ) of radioactive material.

Shipment of Type B quantities of radioactive materials in an NRG-approved shipping container.

Shipment of radioactive materials in bulk packaging of 3,500 gallons or more for liquids or 468 cubic feet or more for solids. Shipment in other than bulk packaging of 5,000 pounds or more of radioactive materials that is required to be placarded.

A quantity of radioactive material that requires placarding.

TYPES OF MATERIALS SHIPPED A quantity of hazardous materials in a bulk packaging having a capacity equal to or greater than 3500 gallons (13,248 liters) for liquids or gases or more than 468 ft 3 (13.24 m 3) for solids. A quantity of hazardous material that requires placarding.

TYPICAL MATERIALS IN SHIPMENT Examples include, but are not limited to: certain radioactive calibration sources, ion-exchange resin, certain activated reactor components and limited amounts of irradiated reactor fuel. Highly irradiated reactor components; some Greater Than Class C (GTCC) wastes. High activity resin, filters, and irradiated reactor components, such as control rod blades and velocity limiters.

Radioactively contaminated oil or aqueous liquids; routine land and inter-modal containers of dry active waste. Most shipments made in Type A or Type B casks. Most radioactive waste shipments, laundry shipments, vendor equipment shipments.

TYPICAL MATERIALS IN SHIPMENT Most shipments of diesel fuel, used oil, acids, caustics, sodium hypochlorite, and similar hazmat. Most shipments of hazardous waste (such as paint waste, parts cleaning solutions, and lab packs), liquid and solid mixed waste, PCB waste, asbestos and waste water treatment chemicals.

James A. NON-QUALITY RELATED FitzPatrick EN-RW-106 I REV. 7 NPP INFORMATIONAL USE Page 30 of 47 Integrated Transportation Security Plan ATTACHMENT 9.1 TSP-RA TABLES Sheet 2 of 6 TABLE 2 H azma tC arriers, T ypes o f H t Sh" t azma 1pmen s, an dQ ff Sh" uan 1 1es 1ppe d CARRIER TYPICAL MATERIALS MAXIMUM QUANTITIES CATEGORY TRANSPORTED BY THIS PER SHIPMENT CARRIER CATEGORY Laundry services suppliers

1. Radioactive laundry Co-60 = < 1 Ci 2. Low activity DAW Cs-137 = < 1 Ci Plant maintenance equipment

1. Low activity radioactive Co-60 = < 8.1 Ci and services suppliers material Cs-137 = < 10 Ci (including their subcontracted Carriers)

Waste processors, and other 1. Radioactive materials and HRCQ, excluding spent waste Carriers and Hazmat waste fuel (rarely) Carriers 2. Reactor components and other RAMQC (rarely) irradiated hardware 3. Vendor equipment Type A and Type B 4. Hazardous waste LSA/SCO 5. Mixed waste Bulk and/or placarded

6. PCB waste hazmat 7. Asbestos waste Common carrier (Federal Radioactive sources Could be Category 1 or 2 Express, UPS) Entergy Radioactive material/special Could be Category 1 or 2 tools/sources James A. NON-QUALITY RELATED EN-RW-106 I REV. 7 FitzPatrick NPP INFORMATIONAL Use Page 31of47 Integrated Transportation Security Plan ATTACHMENT 9.1 TSP-RA TABLES Sheet 3 of 6 TABLE 3 D t f e ermma ion o f H azar d ous M t . I f s* T t Th" A a eria so 1gm 1cance o IS ssessmen t (a) (b) (c)(c) (d) (e) Hazard Hazard General Typical Materials Shipped in this Hazard Class Significance Class Class Description Division by these Facilities and Discussion of to This Risk Division of Significant Relative Significance Assessment Of Concern Hazard or Class 1 1.1, 1.2, Explosives No significant quantity of explosives are shipped None 1.3 bv these facilities.

2 2.3 Poison Gas Anhydrous ammonia gas, chlorine gas. High (inhalation hazard) 3 None Flammable (liquids)

Diesel fuel, gasoline, paint, solvents.

These Low materials are relatively low toxicity (i.e., are not acutely toxic; do not contain lethal concentrations or doses). 4 4.3 Dangerous When Sodium. No significant quantities of such None Wet materials are shipped by these facilities. (Significant quantities may be shipped by sodium-moderated reactors if any are included in the facility listing in Section 1.1. Significance would be Low.) 5 5.2 Organic Peroxide, Type B organic peroxides can undergo a thermal None Type B (may be explosion.

As a genera; rule, they are not liquid or solid and shipped by any of these facilities.

In the event a are thermally shipment becomes necessary, the shipment is controlled) pre-approved in writing by the DOT Associate Administrator and is shipped in accordance with the instructions provided by the Associate Administrator.

6 6.1 Poison Inhalation Hydrazine and most other hazmat in this division Medium Hazard (liquid are not Hazard Zone A or B (Package Group I) poisons) and are, therefore, not High significance.)

Note: some plants may still have stabilized acrolein on site, which would be High significance.)

8 None Corrosives Acids, caustics.

These materials are relatively Low low toxicity (i.e., are not acutely toxic; do not contain lethal concentrations or doses). 9 None Miscellaneous Hazardous waste, solid, n.o.s.; Hazardous Low waste, liquid, n.o.s.; asbestos; PCBs. These materials are relatively low toxicity (i.e., are not acutely toxic; do not contain lethal concentrations or doses).

James A. NON-QUALITY RELATED EN-RW-106 I REV. 7 FitzPatrick NPP INFORMATIONAL Use Page 32 of 47 Integrated Transportation Security Plan ATTACHMENT 9.1 TSP-RA TABLES Sheet 4 of 6 TABLE 4 Category 1 and Category 2 Threshold The terabecquerel (TBq) values are the regulatory standard.

The curie (Ci) values specified are obtained by converting from the TBq value. The curie values are provided for practical usefulness only. r----Category 2 Category 2 --* Radioactive material Category 1 Category 1 (TBq) (Ci) (TBq) * (Ci) --60-r 1,620 I 0.6r-ricium-241 16.2 I Americium-241

/Be 60 I 1,620 0.6, 16.2 r Californium-252 r 20 I 5401 0.21 5.40 lcobalt-60 I 30 I 810 I 0.31 8.10 I Curium-244 I 50 I 1,350 I 0.51 13.5 ---[ --100-1 2,100 r-----1 T Cesium-137 27.0 I Gadolinium-153 I 1.000 I 21.000 I 10 I 270 I 8of 1--*-"-f 2, 160 0.8. 21.6 I *mT-. r---*---1,620 0.6 16.2 tonium-239/Be I 60 1,620 I 0.61 16.2 I Promethium-147 140,0001 1,080,0001 400 I 10,800 I Radium-226 I 40 I 1,080 0.41 10.8 I Selenium-75 200 I 5,400 21 54.0 ntium-90 1-:-000-1 27,000*1----10*1*

270 Thulium-170 l 20.000 I 540,000 I 200 I 5,400 Ytterbium-169 r--"-*-3aa-r 8,100 r-*-"_" ___ 31 81.0 Continued on next page James A. NON-QUALITY RELATED EN-RW-106 I REV. 7 FitzPatrick NPP INFORMATIONAL USE Page 33 of 47 Integrated Transportation Security Plan ATTACHMENT 9.1 TSP-RAT ABLES Sheet 5 of 6 Note: Calculations Concerning Multiple Sources or Multiple Radionuclides The "sum of fractions" methodology for evaluating combinations of multiple sources or multiple radionuclides is to be used in determining whether a location meets or exceeds the threshold and is thus subject to the requirements of this procedure.

I. If multiple sources of the same radionuclide and/or multiple radionuclides are aggregated at a location, the sum of the ratios of the total activity of each of the radionuclides must be determined to verify whether the activity at the location is less than the category 1 or category 2 thresholds of Table 4, as appropriate.

If the calculated sum of the ratios, using the equation below, is greater than or equal to 1.0, then the applicable requirements of this part apply. II. First determine the total activity for each radionuclide from Table 4. This is done by adding the activity of each individual source, material in any device, and any loose or bulk material that contains the radionuclide.

Then use the equation below to calculate the sum of the ratios by inserting the total activity of the applicable radionuclides from Table 4 in the numerator of the equation and the corresponding threshold activity from Table 4 in the denominator of the equation.

Calculations must be performed in metric values (i.e., TBq) and the numerator and denominator values must be in the same units. R1 =total activity for radionuclide 1 R2 = total activity for radionuclide 2 RN = total activity for radionuclide n AR1 = activity threshold for radionuclide 1 AR2 = activity threshold for radionuclide 2 ARN = activity threshold for radionuclide n II L l R1 R2 Rn --+ .. + AR1 AR2 ARn > 1.0 James A. NON-QUALITY RELATED EN-RW-106 I REV. 7 FitzPatrick NPP INFORMATIONAL USE Page 34 of 47 Integrated Transportation Security Plan ATTACHMENT 9.1 TSP-RA TABLES Sheet 6 of 6 TABLE 5 H azar d ous M t . I f s* T t C a ena so 1gm 1can oncern Sh" 1ppe dF rom F Tf ac111es Hazard Class General Description Typical Materials Shipped in this Hazard Class Division by Division of Significant these Facilities and Discussion of Relative Significance Of Concern Hazard or Class 2.3 Poison Gas Anhydrous ammonia gas, chlorine gas. (inhalation hazard)

James A. NON-QUALITY RELATED EN-RW-106 I REV. 7 FitzPatrick NPP INFORMATIONAL USE Page 35 of 47 Integrated Transportation Security Plan ATTACHMENT 9.2 SAMPLE CARRIER AFFIRMATION LETTER Sheet 1 of 1 EXAMPLE: Date: To: Entergy (EOI I ENOI) (Appropriate Site Address)

Subject:

Carrier Hazardous Material Transportation Security Plan (Carrier Company Name) affirms that we have a Hazardous Material Transportation Security Plan in place which meets all applicable Federal and International transportation security regulations in effect as of the contract or contract amendment date, and that said Transportation Security Plan will be updated in a timely manner to remain current with revised and new Federal and International transportation security regulations.

We further affirm that our Transportation Security Plan fully implements the regulations for commercial driver licenses hazardous material endorsements.

Our Transportation Security Plan will be made available for review and approval by an authorized representative of ENTERGY (EOI I ENOI) NS if requested and on reasonable verbal or written notice, with due consideration given to document security and control. We understand that we will not mail, send, or otherwise transmit any confidential documents to ENTERGY (EOI I ENOI). Prior to dispatching any driver to an ENTERGY (EOI I ENOI) facility for the purposes of transporting hazardous material, we will verify that the driver has the appropriate commercial driver license hazardous material endorsements.

We also agree to notify a designated ENTERGY (EOI I ENOI) representative of the name of the driver and any other requested driver identification information, which will be used to verify that the appropriate driver has arrived to transport the shipment.

It is further agreed that transportation of any of the hazardous materials identified in 49 CFR 172.800 will not be assigned or subcontracted without the prior written agreement of all parties. Authorized Carrier Representative Signature Block James A. NON-QUALITY RELATED EN-RW-106 I REV. 7 FitzPatrick NPP INFORMATIONAL USE Page 36 of 47 Integrated Transportation Security Plan ATTACHMENT 9.3 LICENSE VERIFICATION SYSTEM CREDENTIAL GUIDE Sheet 1of1 NOTE The purpose of this guide is to aid individuals in getting credentialed for using the NRC License Verification System (LVS). The NRC LVS web site provides an on-line User Guide. [1] Using a web browser, go to http://www.nrc.gov.

[2] Click on "Nuclear Security" tab. [3] Click on the "Radioactive Material Security" bulleted item. [4] Click on "License Verification System (LVS)" under "NRC Activities for Radioactive Material Security." [5] Click on "Get credentialed for LVS." A public Disclosure of Submitted Information will appear. IF you want to continue with getting your LVS Credentialed, THEN click on "I ACCEPT." [6] After you mouse click on I ACCEPT, the Web Page Portfolio Enrollment Module will appear. Fill out all the information requested from the Portfolio Enrollment Request Form. Once all the required information blocks are filled out, mouse click on Submit at the lower right corner of the request form.

James A. NON-QUALITY RELATED EN-RW-106 I REV. 7 FitzPatrick NPP INFORMATIONAL USE Page 37 of 47 Integrated Transportation Security Plan ATTACHMENT 9.4 MANUAL LICENSE VERIFICATION FORM GUIDE Sheet 1 of 2 [1] Using a web browser, go to http://www.nrc.gov.

[2] Click on "Nuclear Security" tab. [3] Click on "Radioactive Material Security" bulleted item. [4] Click on "License Verification System (LVS)" under "NRG Activities for Radioactive Material Security." [5] Click on "Manual License Verification Form." A PDF document similar to the following should display. .. MANUAL LICENSE VC!Rlf'ICATION fU!PORT

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James A. NON-QUALITY RELATED EN-RW-106 I REV. 7 FitzPatrick NPP INFORMATIONAL USE Page 38 of 47 Integrated Transportation Security Plan ATTACHMENT 9.4 MANUAL LICENSE VERIFICATION FORM GUIDE Sheet 2 of 2 [6] Save the form in PDF format. NOTE At this time the green "Submit by E-mail" button on the form does not work. [7] WHEN completed, THEN email the form to LVSHelp.Resource@nrc.gov.

James A. NON-QUALITY RELATED EN-RW-106 I REV. 7 FitzPatrick NPP INFORMATIONAL USE Page 39 of 47 Integrated Transportation Security Plan ATTACHMENT 9.5 MANUAL LICENSE VERIFICATION PROCEDURE GUIDE Sheet 1 of 2 Manual License Verification NOTE The purpose of this attachment is to guide licensees transferring Category 1 and/or Category 2 quantities of radioactive materials in verifying licenses outside of the License Verification System (LVS). Steps for Licensees

[1] Contact the LVS Help Desk by phone at 1-877-671-6787 or by email at L VS Help.Resource@nrc.gov.

[2] Be prepared to provide the following information to the LVS Help Desk representative. (a) Transferring licensee information:

• License-issuing agency

• Licensee name

• License number

• Contact name and title

• Contact phone

• Contact email

• Contact fax number (b) Receiving licensee information:

• License-issuing agency

• Licensee name

• License number

• Amendment number or license issue date

• Authorized storage location address

• Material(s) being requested

• Chemical/Physical form of the material(s) being requested

• Quantity/Activity being requested James A. NON-QUALITY RELATED EN-RW-106 I REV. 7 FitzPatrick NPP INFORMATIONAL USE Page 40 of 47 Integrated Transportation Security Plan ATTACHMENT 9.5 MANUAL LICENSE VERIFICATION GUIDE Sheet 2 of 2 [3] The transferring licensee will receive notification from the L VS Help Desk of the verification outcome as soon as the verification is complete by the license issuing regulatory agency. [4] The verification outcome will include a notification of whether: (a) The requested materials, quantities, and authorized location are authorized on the license, OR (b) The requested materials, quantities, and/or authorized location are NOT authorized on the license, OR (c) Other reason (with an explanation)

[5] The licensee must keep a copy of the verification outcome sent by the LVS Help Desk for their records in accordance with the 10 CFR Part 37 requirements for keeping records of license verifications.

James A. NON-QUALITY RELATED EN-RW-106 I REV. 7 FitzPatrick NPP INFORMATIONAL USE Page 41of47 Integrated Transportation Security Plan ATTACHMENT 9.6 10 CFR 37 SUBPART D CATEGORY 1 PHYSICAL PROTECTION REQUIREMENT CHECKLIST Sheet 1of4 Shipment Number: [1] Verify the recipient is authorized to receive the type, form and quantity of material per NRC's License Verification System OR License Issuing Authority in accordance with 10 CFR 37.71 (in it) [2] Verify the delivery address matches the location authorized in the recipient's license. (in it) [3] Attach documentation of license verification. (in it) [4] IF shipping to a licensee in an agreement state, THEN obtain written verification of licensee compliance with physical security requirements for Category 1 quantities of radioactive materials in accordance with 10 CFR 37. Attach verification documentation. (in it) [5] Pre-plan and coordinate shipment arrival and departure times with receiving licensee.

Planned departure date and time: ______________

_ Planned arrival date and time: (in it)

James A. NON-QUALITY RELATED EN-RW-106 I REV. 7 FitzPatrick NPP INFORMATIONAL USE Page 42 of 47 Integrated Transportation Security Plan ATTACHMENT 9.6 10 CFR 37 SUBPART 0CATEGORY1 PHYSICAL PROTECTION REQUIREMENT CHECKLIST Sheet 2 of 4 [6] Provide advance notification to the NRG prior to transport per 10 CFR 37.77. Notification by mail must be postmarked at least seven (7) days prior to commencement of transport.

Other means of notification must reach NRG at least four (4) days prior to shipment commencement.

Information required in notification.

IF information is not available at the time of shipment, THEN provide the information as soon as possible, but before commencing shipment.

• Name, address, telephone number, and license number of shipper.

• Name, address, and telephone number of carrier.

• Name, address, telephone number, and license number of the recipient.

• Description of radioactive material, including radionuclides and quantities.

• Point of origin and estimated date and time shipment will commence.

• Estimated date and time shipment expected to enter each state along route.

• Estimated date and time of arrival

• Point of contact and telephone number to obtain current shipment information Date and time of notification: (in it) [7] Pre-plan and coordinate shipment information with the Governor, or designee, of any state through which the shipment will pass, including the State's intentions to provide law enforcement escorts and identification of safe havens. Use attachment 9.8, "Category 1 Quantities of Concern State Coordination Log," or equivalent, to document coordination activities.

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

Attach documentation of notification. (in it)

James A. NON-QUALITY RELATED EN-RW-106 I REV. 7 FitzPatrick NPP INFORMATIONAL USE Page 43 of 47 Integrated Transportation Security Plan ATTACHMENT 9.6 10 CFR 37 SUBPART 0CATEGORY1 PHYSICAL PROTECTION REQUIREMENT CHECKLIST Sheet 3 of 4 [9] Verify the carrier meets the requirements for physical protection of Category 1 quantities of radioactive material during shipments by road per 10 CFR 37. 79(a). [1 O] IF provided, THEN attach carrier verification of 10 CFR 37 compliance. (init) (in it) [11] Verify normal and emergency contingency procedures addressing the following are available to drivers, accompanying personnel AND the movement control center.

• Notification to communications center and law enforcement agencies

• Communication protocols that include a strategy for authentication and duress codes and provisions for refueling or other stops.

• Loss of communications

• Response to actual or attempted theft or diversion of shipment (in it) [12] Verify movement control center(s) established to maintain position information from a remote location comply with the following:

• The center has the ability to immediately contact appropriate law enforcement agencies.

• The center has redundant communications with transport or escort vehicle.

• The center continuously and actively monitors shipment by telemetric position monitoring, or alternative tracking system, twenty-four hours a day, seven days a week.

• The center is prepared to implement pre-planned procedures in response to deviations from authorized route or notification of suspicious activities or attempted theft or diversion of material. (in it)

James A. NON-QUALITY RELATED EN-RW-106 I REV. 7 FitzPatrick NPP INFORMATIONAL USE Page 44 of 47 Integrated Transportation Security Plan ATTACHMENT 9.6 10 CFR 37 SUBPART D CATEGORY 1 PHYSICAL PROTECTION REQUIREMENT CHECKLIST Sheet 4 of 4 [13] IF the highway shipment driving time is greater than the maximum number of hours established by the Department of Transportation, THEN verify there is an accompanying individual. (in it) [14] Verify that the U.S. Department of Homeland Security's (DHS's) National Terrorism Advisory System (NTAS) has not issued an "Elevated Alert" or "Imminent Alert", OR/IF the USCGS MARSEC Level has not reached 2 or 3 (as applicable to each plant), prior to shipment. (in it) [15] Notify Site Security (S.A.S) of shipment AND have Security make a log entry. Date and time of notification:

Security point of contact: ---------------------

Security log entry number: ------------------(in it) [16] IF the U.S. Department of Homeland Security's (DHS's) National Terrorism Advisory System declares a threat condition OR the NRC establishes protective measures while a Category1, Category 2 or HRCQ shipment is in transit THEN refer to RIS 2005-12 for guidance.

Performed by (print, sign, date): --------------------

Reviewed by (print, sign, date): -----------------------------------------

James A. NON-QUALITY RELATED EN-RW-106 I REV. 7 FitzPatrick NPP INFORMATIONAL USE Page 45 of 47 Integrated Transportation Security Plan ATTACHMENT 9.7 10 CFR 37 SUBPART 0 CATEGORY 2 PHYSICAL PROTECTION REQUIREMENT CHECKLIST Sheet 1 of 2 Shipment Number: (1] Verify the recipient is authorized to receive the type, form and quantity of material per NRC's License Verification System OR License Issuing Authority in accordance with 10 CFR 37.71 (in it) [2] Attach documentation of license verification. (in it) [3] IF shipping to a licensee in an agreement state, THEN obtain written verification of licensee compliance with physical security requirements for Category 2 quantities of radioactive materials in accordance with 10 CFR 37. Attach verification documentation. (in it) [4] Pre-plan and coordinate shipment arrival and departure times with receiving licensee.

Planned departure date and time: ______________

_ Planned arrival date and time: No-Later-Than date and time: [5] Verify the carrier meets the requirements for physical protection of Category 2 quantities of radioactive material during shipments by road per 10 CFR 37. 79(a). (in it) (in it) [6] Verify the carrier has established a package tracking system that allows the shipper or transporter to identify where the package was last and when it should arrive at the next point of control. (in it)

James A. NON-QUALITY RELATED EN-RW-106 I REV. 7 FitzPatrick NPP INFORMATIONAL USE Page 46 of 47 Integrated Transportation Security Plan ATTACHMENT 9.7 10 CFR 37 SUBPART D CATEGORY 2 PHYSICAL PROTECTION REQUIREMENT CHECKLIST Sheet 2 of 2 [7] Verify the carrier has constant control and/or surveillance during transit and has the capability for immediate communication to summon appropriate response or assistance.

[8] Verify the carrier has established a tracking system that requires an authorized signature prior to releasing the package for delivery or return. [9] IF provided, THEN attach carrier verification of 10 CFR 37 compliance.

[1 O] Notify Site Security (S.A.S) of shipment AND have Security make a log entry. Date and time of notification:

---

Security point of contact: ___________

_ Security log entry number: ___________

_ (in it) (in it) (in it) (in it) [11] Verify that the U.S. Department of Homeland Security's (DHS's) National Terrorism Advisory System (NTAS) has not issued an "Elevated Alert" or "Imminent Alert", OR/IF the USCGS MARSEC Level has not reached 2 or 3 (as applicable to each plant), prior to shipment.

[12] Refer to 10 CFR 71.97 to see if the shipment also meets the criteria for Highway Route Control Quantity limits requiring advanced notification. (in it) (in it) [13] IF the U.S. Department of Homeland Security's (DHS's) National Terrorism Advisory System declares a threat condition OR the NRG establishes protective measures while a Category1, Category 2 or HRCQ shipment is in transit THEN refer to RIS-2005-12 for guidance.

Performed by (print, sign, date): ---------------------

Reviewed by (print, sign, date): ----------------------

James A. NON-QUALITY RELATED EN-RW-106 I REV. 7 FitzPatrick NPP INFORMATIONAL Use Page 47 of 47 Integrated Transportation Security Plan ATTACHMENT 9.8 10 CFR 37 SUBPART D CATEGORY 1 QUANTITIES OF CONCERN STATE COORDINATION LOG Sheet 1 of 1 Shipment Number: State representative name and title:--------------------

Date of coordination conversation:

---

Expected entry: Date and time: Location:

---

Expected exit: Date and time: Location:

---

Does the state intend to provide law enforcement escorts? _____ _ Safe havens identified:

Additional discussion items concerning shipment through state: ________ _ Performed by (Print, sign, date): Reviewed by (Print, sign, date): --------------------

OP-AA-106-102Revision7Page1of10Level 2-Reference UseACCIDENTS INVOLVINGTHE TRANSPORTATION OF RAD MATERIALS 1.PURPOSE1.1.This procedure provides guidance for the emergency response activities andnotifications to be performed following an offsite incident involving a vehicle containingradioactive materials. This procedure applies to the response to company vehiclestransporting licensed radioactive materials, and to contractors or couriers transportingradioactive materials originating from Exelonnuclear facilities.1.2.Departmentof Transportation (DOT) regulations require:

1.2.1.Carriers of radioactive material shipments to have a DOT shipping paper andassociated emergency response information for shipments except small quantities (DOT definition of small quantity is referred to as excepted quantity). The emergency response information provides the driver with basic information in the event of an accident.1.2.2.The Station to provide a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day emergency response phone number whilethe shipment is in progress on each shipping paper. This number is typically theStation emergency response number.1.3.Texas Department of State Health Services (DSHS) requires:

1.3.1.In the event of a transportation accident of radioactive materials coming from Exelonnuclear facilities and traveling through the state of Texas are required to providenotifications at a minimum, to the emergency number on the shipping documentation,Texas local law enforcement, the DSHS,and the shipper. The DSHS 24-Hour emergency phone number is (512) 458-7460.1.3.2.Exelon is required to ensure that notification has been provided to DSHS (512) 458-7460 and the Texas local law enforcement.

2.TERMS AND DEFINITIONS2.1.Transportation Accident:(must meet either step2.1.1or step2.1.2)

OP-AA-106-102Revision7Page2of10NOTE:The Exelon definition of transportation accident is providedbelow. This definition parallels the DOT definition of a transportation "incident" in 49CFR for which notification to the National Response Center is required. For purposes of this procedure, the term "hazardous materials" refers to radioactive material under transport.NOTE:A traffic accident involving a radioactive shipment thatresults in a death, injured person hospitalization, or any of the other criteria specified below does notmeet thecriteriafor transportation accident unless the death, injury requiringhospitalization, etc., is thedirect resultof the hazardousmaterial.2.1.1.As a direct result of hazardous materials, one of the followingoccurs:A person is killed, orAn injured personis hospitalized, orEstimated carrier or property damage exceeds $50,000, orAn evacuation of the general public occurs lasting one or more hours, orOne or more major transportation arteries or facilities are closed or shutdownfor one hour or more hours,orFlight pattern of an aircraft is altered.

OR2.1.2.Fire, breakage, spillage, or suspected radioactive contamination occurs.Breakage:is defined as the loss of package integrity.Spillage:is defined as leakage from any package.Package:is defined on the Radioactive Shipment Notification Form.2.2.Transportation Incident:is an event notmeeting the requirements of step2.1.Includes events related to Security and safe transportation of the shipment 3.RESPONSIBILITIES3.1.The Radiation Protection Department provides a Radioactive Shipment NotificationForm and Emergency Response Information to the Operations Department.3.2.In the event a driver or other individual calls the listed emergency response number,the Operations Department shall immediately assist in the mitigation and resolution ofthe accident as necessary. (Reference6.5)

OP-AA-106-102Revision7Page3of10 4.MAIN BODYNOTE:The Shift Manager may transfer control of this event. Both partiesinvolved in thetransfer control must understand their roles and the responsibilities that are transferred. Face to face verbal communication should occur. The transfer can be made to any individual proficient intransportation events; however, the recommended person isthe Radiation Protection Manager.NOTE:As an issue of potential public interest, the company CommunicationsDepartment should handle all interactions with the media and other non-official outside groups. Communications with government agencies suchas the NRC or the DOT are the responsibility of the Shift Manager or theperson in control of the event at the Station.4.1.The Shift Manager shall ensure the following activities are completed:4.1.1.COMPLETEAttachment 1, "Transportation Accident / Incident Reporting Form" whilethe caller is on the phone.

1.VERIFY / OBTAINthe Radioactive Shipment Notification Form and EmergencyResponse Information provided to the Operations Department by the RadiationProtection Department. This step is notapplicable for small quantity shipments(DOT definition of small quantities is referred to as excepted quantities).NOTE:Specific requirements for off normaland emergencycommunications for RAMQC Shipments are Safeguards Information-Modified Handling, use appropriate security measures when making these communications.

2.REVIEWthe Radioactive Shipment Notification to DETERMINEif the shipmentis Radioactive Material Quantity of Concern (RAMQC) shipment performed inaccordance with RP-AA-600-1006 orRP-AA-600-1009.

A.Ifthe shipment is a RAMQC shipment performed in accordance with RP-AA-600-1006 orRP-AA-600-1009,thenCONTACTSecurity, obtain acopy of SY-AA-101-134-1002,and INITIATEimmediate NRCinvestigation and notification requirements.4.1.2.DETERMINEif the situation is a transportation accident or transportation incidentusing the criteria of step2.1or step2.2.

OP-AA-106-102Revision7Page4of104.1.3.Refer to LS-AA-1120 for reportability requirements since conditions may require areport within 15 minutes.1.Applicable sections of the reportability manual include RAD 1.7 and RAD 1.24.4.1.4.EVALUATEinitiation of a prompt investigation in accordance with RP-AA-1004"Radiation Protection Stop Work Authority and Corporate RPM Event Notification" andOP-AA-106-101-1001 "Event Response Guidelines".4.1.5.Ifthe criteria of a transportation accident per step2.1are met,thenPROCEED to step 4.2.Ifnot ,then PROCEEDto step 4.3.4.2.Transportation Accident Notifications:NOTE:The current telephone numbers for non-Exelon response facilities arefound in the Emergency Response Facilities (ERF) telephone directory.4.2.1.COMPLETEAttachment 2, "Transportation Accident / Incident Notification Log" as thefollowing notifications are made:

1.NOTIFYthe Station Duty Officer and / or Duty Station Manager.

2.NOTIFYthe Station Radiation Protection Manager (RPM) or designee.

3.NOTIFYthe Nuclear Duty Officer.

4.NOTIFYthe United States Department of Transportation / National ResponseCenter if Exelon Nuclear is the carrier;otherwiseVERIFYthe carrier has madethis notification. This notification must include as aminimum:A.Name of the person making the notification.

B.Phone number of the person making the notification.

C.Name and address of the carrier.

D.Date, time, and location of the accident.

E.Extent of injuries, if applicable.

F.Name of hazard, classification, and quantity of hazardous materialsinvolved.G.Type of accident and nature of hazardous material involvement includingwhether a dangerous conditions currently exists.

5.NOTIFYthe Illinois Emergency Management Agency if the shipment originatedin Illinois. The State official will ask a series of questions in order to evaluatethe situation.

OP-AA-106-102Revision7Page5of10 6.Ifthe accident occurred outside of the State of Illinois,thenNOTIFY theappropriate State Emergency Response Agency using the phone number contained under the State Emergencytab in the ERF directory or other site-specific telephone reference.

7.NOTIFYthe NRC Operations Center using the Emergency Notification System(ENS) following notification of the accident in accordance with the Exelon Reportability Reference Manual.

8.Iftheshipment involves Special Nuclear Material (plutonium, enriched uranium,or other fissile isotopes),thenNOTIFYthe Nuclear Materials Custodian.

9.Ifthe shipment involves mixed hazardous and radiological waste,thenNOTIFYthe Exelon Nuclear EnvironmentalServices Department(via theNuclear Duty Officer, if necessary).

10.NOTIFYCorporate Communications and affected site communicator of theevent. The need to develop a comprehensive company response will be required.11.NOTIFYAmerican Nuclear Insurers(ANI)4.2.2.Ifan Exelon Nuclear response team shouldbe dispatched to the accident location,then COORDINATEwith the Nuclear Duty Officer.4.2.3.EXITthis procedure.4.3.Transportation Incident Notifications:4.3.1.NOTIFYthe Station Duty Officer and / or the Duty Station Manager.4.3.2.NOTIFYthe Nuclear Duty Officer.4.3.3.NOTIFYthe Station Radiation Protection Manager (RPM) or designee.4.3.4.Ifan Exelon Nuclear response team should be dispatched to the incident location,then COORDINATEwith the Nuclear Duty Officer.4.3.5.CONSIDERnotifying the agencies listed on Attachment 2.

Ifagenciesare notified, then DOCUMENTthe notification on Attachment 2.

1.NOTIFYCorporate Communications and affected site communicator of theevent. The need to develop a comprehensive company response may be required OP-AA-106-102Revision7Page6of104.3.6.In the event of a transportation accident of radioactive materials coming from Exelonnuclear facilities and traveling through the state of Texas are required to providenotifications at a minimum, to the emergency number on the shipping documentation,Texas local law enforcement, the DSHS, and the shipper. The DSHS 24-Hour emergency phone number is (512) 458-7460.4.3.7.Exelon is required to ensure that notification has been provided to DSHS 512-458-7460.

5.DOCUMENTATION-None 6.REFERENCES6.1.Commitments6.1.1.Braidwood: 456-200-98-CAQS00043. (Entire Procedure)6.2.Exelon Nuclear Reportability Manual, current revision.

6.3.Code of Federal Regulation 49CFR171.15 and 49CFR171.16.6.4.Code of Federal Regulations 49CFR172.604.

6.5.NRC Information Notice 92-62, "Emergency Response Information Requirements forRadioactive Material Shipments".6.6.Code of Federal Regulations 10CFR50.72(b)(2)(vi).6.7.Emergency Resources Manual INPO 86-032 or most recent revision.

6.8.RP-AA-600-1006,Shipment of Category 1 Quantities of Radioactive Material or Waste(Category 1 RAMQC)6.9.RP-AA-600-1009, Shipment of Category 2 Quantities of Radioactive Material or Waste(Category 2 RAMQC)6.10.SY-AA-101-134-1002, RAMQC Shipment Notification Requirements-SafeguardsInformation-Modified Handling.

7.ATTACHMENTS7.1.Attachment 1, Transportation Accident / Incident Notification Form7.2.Attachment 2, Transportation Accident / Incident Notification Log OP-AA-106-102Revision7Page7of10ATTACHMENT 1Transportation Accident / Incident Notification FormPage 1 of 2Date / Time Of This CallDate / Time Of The EventName Of CallerCompany Name And Address Of CallerTelephone Number Of Caller (On Scene)Exelon Nuclear Shipment NumberIs this a RAMQC Shipment YESorNOIncident Location(As specific as possible, include State,County, Road, Intersection)If in Illinois and if known:(Section, Township, Range)Vehicles Involved.AS A DIRECT RESULT OF THE HAZARDOUS MATERIAL, WERE:People Killed?YESorNOPeople Injured?YESorNOInjured Taken To Hospital?If YES, Where?YESorNODoes The Estimate Of Carrier OrProperty Damages Exceed $50,000?YESorNOHas A Major Transportation Artery OrFacility Been Closed One Or More Hours?YESor POTENTIALor NO OP-AA-106-102Revision7Page8of10ATTACHMENT 1Transportation Accident / Incident Notification FormPage 2 of 2Has An Evacuation Of The GeneralPublic Lasting One Or More Hours

Occurred?YESor POTENTIALor NOHas The Flight Pattern Of An AircraftBeen Altered?YESor POTENTIALor NOWere Package(s) Impacted By Fire?(Package defined on Radioactive ShipmentNotification Form)YESorNOWas there a Loss Of Package(s) Integrity?If YES, then does the potential exist for aspread of contamination?YESorNONOTE:If ALL of the above questions are answered NO,then a transportation accident hasnotoccurred.Name Of Emergency ResponseUnits Contacted Or At The SceneName Of Hazard Being ShippedUN ID Number(Reference number of hazard)Public HealthPrecautions Implemented, If AnyWeather Conditions:(Rain, snow, temperature, etc.)Person Completing This Form.(Please print)

OP-AA-106-102Revision7Page9of10ATTACHMENT 2Transportation Accident / Incident Notification LogPage 1 of 2NOTE:The current telephone numbers for non-Exelon ResponseFacilities are found in the Emergency Response Facilities(ERF) telephone directory.PositionDate/Time ContactedPerson Contacted4.2.1.1Station Duty Officer__ / __ / __ _______

AND / ORDuty Station Manager__ / __ / __ _______4.2.1.2Rad Protection Manager__ /__ / __ _______4.2.1.3Nuclear Duty Officer__ / __ / __ _______4.2.1.4United States Departmentof Transportation/National Response Center__ / __ / __ _______Ensure the following information is provided to USDOT as a minimum:Name of person making contact(your name)Phone number of StationName and address of CarrierDate, time, and location of the accident / incidentExtent of injuries, if applicableName, classification, and quantityof hazardous material involvedAccident information including type,nature of hazardIf a hazardous condition still exists OP-AA-106-102Revision7Page10of10ATTACHMENT 2Transportation Accident / Incident Notification LogPage 2 of 2PositionDate/Time ContactedPerson Contacted4.2.1.5Illinois Emergency MgmtAgency__ / __ / __ _______4.2.1.6Non-Illinois StateEmergency Agency__ / __ / __ _______Agency:Person:4.2.1.7NRC OperationsCenter__ / __ / __ _______4.2.1.8Nuclear Material Cust(SNM shipments only)__ / __ / __ _______4.2.1.9Exelon Nuclear EnvironServices Dept (mixed waste shipments only)__ / __ / __ _______4.2.1.10American Nuclear Insurers__ / __ / __ _______Other Agencies/Individuals Contacted:

CONSIDER:NRC/NRC Regional CommunicationsNearest Site CommunicatorCorporate CommunicationsAll CompanyCommunicatorsState AuthoritiesInstitute ofNuclear Power OperationsLocal AuthoritiesTransportation CompanyCommunicationsDestination Communications (agencyreceiving the shipment)Contractor CommunicationsName of AgencyDate/Time Contacted Person Contacted__ / __ / __ _________ / __ / __ _________ / __ / _________